Comments from OMB

6/12/07

Please comment in Chapter 5 about how increase in coal energy output for
the East is consistent with known control on EGU trading.  Also, please
comment on how table 5.5 is consistent with your statements about
Executive Order 13211: Actions that Significantly Affect Energy Supply,
Distribution or Use.  It would seem that table 5.5 would suggest this
rule is “…significantly affect energy supply, distribution, or
use…” when coupled with the known controls for EGU.

Discussion has been added to reflect the CAIR process.  Because this is
only an illustrative analysis, and does not proscribe how states will
implement a proposed standard, EO 13211 does not apply.

Table 4.1:  include results for all regions.

	Numbers were not calculated for all regions.

 

Section 4.1.2:

Please provide discussion of why you selected a 200 km radius.  Please
discuss how the extrapolated tons would change if you assumed a smaller
radius; i.e., if the number of areas increased.  Please discuss how the
200 km radius is affected by state borders.  Please discuss how the 200
km radius is affected by natural boundaries (Great Lakes, Rocky
Mountains, Oceans, etc).  Please add note that states a sensitivity
analysis of alternative assumptions regarding the 200 km radius will be
conducted in the final RIA.

Further discussion has been added about the 200 km radius and its
appropriateness. 

Section 4.2:

Please provide discussion of how higher/lower impact ratios will affect
the resulting extrapolated tons estimate. Please provide discussion that
regional specific impact ratios would likely be more appropriate to use.

	Discussion has been added.

Please provide a statement that notes that regionally disaggregated
impact ratios will be conducted for the final RIA.

	Methodology for the final RIA is still under consideration.

