NOTE

DATE:  March 5, 2012

TO:  Docket EPA-HQ-OAR-2011-0660

FROM:  Mary Johnson

SUBJECT:  Summary of Early Outreach to Small Entities

Standards of Performance for GHG Emissions for New Stationary Sources:
EGUs:  Proposed Rule

The EPA’s outreach to small entities regarded planned actions for new
and existing sources, but only new sources would be affected by the
currently proposed action.  At that time, the EPA believed it likely
that proposed regulations for greenhouse gas (GHG) emissions from
electric utility generating units (EGUs) (new sources as well as
existing sources) would not result in a significant economic impact on a
substantial number of small entities (SISNOSE).  However, because the
EPA believes that outreach to small entities is an important element in
the development of these regulations, the EPA requested that a Small
Business Advocacy Review (SBAR) Panel be convened to allow that outreach
to occur.

It has since been determined that new source performance standards
(NSPS) for emissions of carbon dioxide (CO2) for new affected
fossil-fuel-fired EGUs will be proposed at this time.  At a future date,
the EPA intends to promulgate emission guidelines for states to develop
plans reducing CO2 emissions from existing fossil-fuel-fired EGUs.

Summary of April 6, 2011 Call with Small Entities

When conducted, this conference call with small entity representatives
was referred to as Pre-Panel Outreach (i.e., informal outreach prior to
beginning the formal SBAR Panel process).  The purpose of the meeting
was to provide small entity representatives with an overview of recent
EPA proposals impacting the power sector.  Specifically, overviews of
the Transport Rule, the Toxics Rule, and the 316(b) Rule proposals were
presented.  A list of conference call participants is attached to this
note.  Copies of the three presentations are included as attachments to
the docket entry Conference Call with Small Entities_04-2011_email.

Summary of February and March 2011 Listening Sessions

The EPA also engaged in outreach with entities that would potentially be
affected by GHG standards for EGUs.  Small entities and organizations
that represent and include small entities were included in the outreach.
 The outreach consisted of the Assistant Administrator of EPA’s Office
of Air and Radiation holding four listening sessions with various types
of stakeholders during February and March 2011.  Specifically, listening
sessions were held with (1) the electric power industry, (2)
environmental and environmental justice groups, (3) State and Tribal
representatives, and (4) coalition groups.  Stakeholder input received
during the listening sessions and as part of the public comment process
associated with the proposed settlement agreement requiring that the EPA
establish NSPS and emission guidelines for fossil fuel-fired EGUs is
located in Docket EPA-HQ-OAR-2011-0090.

Attachment

