Memo
to
docket
From:
Jan
King
On
3/
5/
04,
Tom
Helms,
Lydia
Wegman,
Doug
Grano,
Bill
Neuffer,
Kevin
Culligan
and
I
had
a
conference
call
with
Art
Fraas
of
OMB.
Below
is
a
summary
of
the
items
discussed
and
our
responses.

1.
What
is
the
cost
of
this
Phase
2
rule
by
itself?
Is
the
Phase
2
rule
a
major
rule?
Language
added
to
E.
O.
12866.

2.
Is
the
"
one
third
potential
electric
output/
25
MWe
sales
criteria"
used
to
define
EGUs
in
Title
IV,
the
SIP
Call,
the
IAQR
and
the
utility
mercury
rule?
Yes
3.
Is
the
"
sales
under
firm
contract
to
the
grid"
criteria
used
in
all
four
rules?
No,
it
is
only
used
in
the
SIP
Call,
we
are
not
changing
this
definition
in
the
phase
II
rule
(
and
we
don't
have
the
flexibility
to
as
we
never
took
comment
on
it).
We
used
this
definition
because
it
was
consistent
with
the
way
we
created
the
budgets.
In
the
IAQR
and
the
mercury
rule
we
are
using
a
more
simple
sales
criteria.

4.
How
many
EGUs
are
in
the
coarse
grid
portion
of
the
States
of
AL,
GA,
MI
and
MO?

Fine
Grid
Coarse
Grid
%
Units
in
Fine
Grid
MW
Coarse
Grid
MW
%
MMW
in
Units
Units
Fine
Grid
Fine
Grid
AL
40
17
70.2
11477
2565
81.7
GA
70
27
72.2
16596.4
1271.5
92.9
MI
75
16
82.4
16504.7
1032.7
94.1
MO
18
59
23.4
7263.3
6611.3
52.3
5.
What
are
our
plans
in
lifting
the
8
hr
stay?
After
discussion,
Art
said
we
would
discuss
this
outside
of
the
context
of
the
Phase
II
rule,
and
that
the
language
in
the
rule
could
stay
as
is.

6.
Add
language
in
rule
about
the
IAQR.
A
paragraph
was
added
to
the
rule
discussing
the
IAQR
rule
in
relation
to
the
NOx
SIP
Call
.
