We
believe
that
all
of
the
records
necessary
to
implement
this
rule
are
readily
available
at
industrial
sources
and
therefore,
we
do
not
need
to
require
additional
recordkeeping.
For
a
variety
of
reasons
(
e.
g.
regulatory,
tax
purposes,
etc.),
records
of
replacement
activities
including
information
on
cost
and
nature
of
the
changes
are
regularly
kept
at
sources.
In
particular,
for
vast
majority
electric
utilities,
the
Federal
Energy
Regulatory
Commission
(
FERC)
either
requires
such
items
to
be
regularly
reported
.
In
addition,
other
utilities,
not
covered
by
FERC
rules,
also
voluntarily
report
the
same
information.
In
addition,
EPA
has
separate
authority
to
do
inspections
of
sources
to
review
records
and
to
require
information
or
records
to
be
provided
by
owners
and
operators.
Again,
for
all
of
these
reasons
we
saw
no
need
for
additional
recordkeeping
to
be
required
in
today's
rule.
