




Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units 

Response to Comments on January 8, 2014 Proposed Rule


                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                     U.S. Environmental Protection Agency
                                       
                                August 3, 2015

Chapter 1
Contents
1.1	Introduction	3
1.2	Background	4
1.3	Stakeholder Engagement	4
1.4	Public Comments	5
1.5	Organization of This Document	25




Introduction
This document provides the Environmental Protection's (EPA's) responses to public comments on the Proposed Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units. The Notice of Proposed Rulemaking was published in the Federal Register on January 8, 2013, at 79 FR 1430. The EPA received comments on the proposed rule via mail, e-mail, facsimile, and at a public hearings held in Washington, DC on February 6, 2014. Copies of all comments submitted and transcripts for the public hearings are available electronically through http://www.regulations.gov by searching Docket ID: EPA-HQ-OAR-2013-0495.
On June 18, 2014, the EPA proposed standards of performance to limit emissions of CO2 from modified and reconstructed fossil fuel-fired electric utility steam generating units and natural gas-fired stationary combustion turbines (79 FR 34959). This document only contains responses to comments on the January 8, 2014 proposal. A separate Response-to-Comments document has been developed for comments on the June 18, 2014 proposal. 
The EPA refers to the standards of performance for new, modified and reconstructed fossil fuel-fired EGUs as the `Carbon Pollution Standards'. The Response-to-Comments Document, together with the preamble to the final Carbon Pollution Standards, presents the responses of the EPA to the more than two million public comments received on the proposals described above. The EPA has addressed all significant issues raised in the public comments.
As a result of changes made to the preamble and final rule prior to signature, and due to the volume of comments received, some responses in the Response-to-Comments Documents may not reflect the language in the preamble and final rule in every respect. Where the response is in conflict with the preamble or the final rule, the language in the final preamble and rule controls and should be used for purposes of understanding the scope, requirements, and basis of the final rule. In addition, due to the large number of comments that addressed similar issues, as well as the volume of the comments received, the Response-to-Comments Documents do not always cross-reference each response to the commenter(s) who raised the particular issue involved. The responses presented in this document are intended to augment the responses to comments that appear in the preamble to the final rule or to address comments not discussed in that preamble. Although portions of the preamble to the final rule are paraphrased in this document where useful to add clarity to responses, the preamble itself remains the definitive statement of the rationale for the revisions adopted in the final rule. In many instances, particular responses presented in the Response-to-Comments Documents include cross references to responses on related issues that are located either in the preamble to the Carbon Pollution Standards, the Technical Support Documents, or elsewhere in the Response-to-Comments Documents. All issues on which the EPA is taking final action in the Carbon Pollution Standards are addressed in the Carbon Pollution Standards rulemaking record.
Accordingly, the Response-to-Comments Documents, together with the preamble to the Carbon Pollution Standards and the information contained in the Technical Support Documents, and the rest of the administrative record should be considered collectively as the agency's response to all of the significant comments submitted on the two proposals described above. The Response-to-Comments Documents incorporate directly or by reference the significant public comments addressed in the preamble to the Carbon Pollution Standards as well as other significant public comments that were submitted on the proposed rule.
Background
On April 13, 2012, the EPA initially proposed standards under CAA section 111(b) for newly constructed fossil fuel-fired electric utility steam generating units (77 FR 22392). The EPA withdrew that proposal on January 8, 2014 (79 FR 1352), and, on the same day, proposed the standards addressed in the final rule associated with this response-to-comments (RTC) document.  Specifically, the EPA proposed standards of performance under CAA section 111(b) to limit emissions of CO2 from newly constructed fossil fuel-fired electric utility steam generating units and newly constructed natural gas-fired stationary combustion turbines. 
In support of the January 2014 proposal, on February 26, 2014, the EPA published a notice of data availability (NODA) (79 FR 10750). Through the NODA and an associated technical support document, Effect of EPAct05 on Best System of Emission Reduction for New Power Plants, the EPA solicited comment on its interpretation of the provisions in the Energy Policy Act of 2005 (EPAct05), including how the provisions may affect the rationale for the EPA's proposed determination that partial CCS is the best system of emission reduction adequately demonstrated for fossil fuel-fired electric utility steam generating units.
On June 18, 2014, the EPA proposed standards of performance to limit emissions of CO2 from modified and reconstructed fossil fuel-fired electric utility steam generating units and natural gas-fired stationary combustion turbines (79 FR 34959; June 2014 proposal). Specifically, the EPA proposed standards of performance for: (1) modified fossil fuel-fired electric utility steam generating units, (2) modified natural gas-fired stationary combustion turbines, (3) reconstructed fossil fuel-fired electric utility steam generating units, and (4) reconstructed natural gas-fired stationary combustion turbines.
Stakeholder Engagement
The EPA engaged extensively with a broad range of stakeholders and the general public regarding climate change, carbon pollution from power plants, and carbon pollution reduction opportunities. These stakeholders included industry and electric utility representatives, state and local officials, tribal officials, labor unions, non-governmental organizations and many others.
In February and March 2011, early in the process of developing carbon pollution standards for new power plants, the EPA held five listening sessions to obtain information and input from key stakeholders and the public. Each of the five sessions had a particular target audience: the electric power industry, environmental and environmental justice organizations, states and tribes, coalition groups, and the petroleum refinery industry.
The EPA conducted subsequent outreach prior to the June 2014 proposals of standards for modified and reconstructed EGUs and emission guidelines for existing EGUs, as well as during the public comment periods for the proposals. Although this stakeholder outreach was primarily framed around the GHG emission guidelines for existing EGUs, the outreach encompassed issues relevant to this rulemaking and provided an opportunity for the EPA to better understand previous state and stakeholder experience with reducing CO2 emissions in the power sector. In addition to 11 public listening sessions, the EPA held hundreds of meetings with individual stakeholder groups, and meetings that brought together a variety of stakeholders to discuss a wide range of issues related to the electricity sector and regulation of GHGs under the CAA. The agency met with electric utility associations and electricity grid operators. Agency officials engaged with labor unions and with leaders representing large and small industries, many of which have been utilities and industry representatives directly related to the electricity sector. The agency also met with energy industries such as coal and natural gas interests, as well as with representatives of energy intensive industries, such as the iron and steel and aluminum industries, to help understand the potential concerns of large industrial purchasers of electricity. In addition, the agency met with companies that offer new technology to prevent or reduce carbon pollution. The agency provided and encouraged multiple opportunities for engagement with state, local, tribal, and regional environmental and energy agencies. The EPA also met with representatives of environmental justice organizations, environmental groups, and religious organizations.
Public Comments
The EPA received more than 2.5 million comments submitted in response to the original April 2012 proposal for newly constructed fossil fuel-fired EGUs. Because the original proposal was withdrawn, the EPA instructed commenters that wanted their comments on the April 2012 proposal to be considered in connection with the January 2014 proposal to submit new comments to the EPA or to re-submit their previous comments. We received more comments in response to the January 2014 proposal.
The EPA has given stakeholder input provided prior to the proposals, as well as during the public comment periods for each proposal, careful consideration during the development of the final rule and, as a result, it includes elements that are responsive to many stakeholder concerns and that enhance the rule. This preamble and the Response-to-Comments (RTC) document summarize and provide the agency's responses to the comments received.    
Upon publication of the January 8, 2014 proposal for newly constructed fossil fuel-fired EGUs, the EPA offered a 60-day public comment period. On March 6, 2014, in order to provide the public additional time to submit comments and supporting information, the EPA extended the comment period by 60 days, to May 9, 2014, giving stakeholders over 120 days to review, and comment upon, the January 2014 proposal, as well as the NODA. A public hearing was held on February 6, 2014, with 159 speakers presenting testimony. 
The EPA received more than 2 million comments on the proposed standards for newly constructed fossil fuel-fired EGUs from a range of stakeholders that included industry and electric utility representatives, trade groups, equipment manufacturers, state and local government officials, academia, environmental organizations, and various interest groups. The agency received comments on a range of topics, including the determination that a new highly efficient steam generating EGU implementing partial CCS was the BSER for such sources, the level of the CO2 standard based on implementation of partial CCS, the criteria that defines which newly constructed natural gas-fired stationary combustion turbines will be subject to standards, the establishment of subcategories based on combustion turbine size, and the rule's potential effects on the Prevention of Significant Deterioration (PSD) preconstruction permit program and title V operating permit program. Table 1 presents the list of public commenters.

Table 1. List of Commenters Cited in this Summary Document Submitting Comments to EPA Air and Radiation Docket Number EPA-HQ-OAR-2013-0495 Regarding Standards of Performance for GHG Emissions from New EGUs (Proposed January 8, 2014, 79 FR 1430)
                             EPA-HQ-OAR-2013-0495 
                                 Document No.
                             Name and Affiliation
                                     0192
Media Production Center, Wildlife Conservation Society
                                     0296
Hunton & Williams
                                     0401
Sorgo Fuels
                                     0583
Private Citizen
                                     0585
Chamber of Commerce
                                     0586
The Board of the Douglas County Global Warming Coalition
                                     0587
Twin Valleys Public Power District
                                     0588
Competitive Enterprise Institute (CEI)
                                     0636
ClearStack Power, LLC
                                     0775
Pax World Management LLC
                                     0782
North Carolina Conservation Network
                                     0783
Trillium Asset Management, LLC
                                     0784
Kansas House of Representatives
                                     0785
Private Citizen
                                     0825
Private Citizen
                                     0827
Private Citizen
                                     0829
The Young Democrats of America (YDA)
                                     0830
The Association of Union Constructors (TAUC)
                                     0833
Private Citizen
                                     0834
Novetas Solutions, LLC
                                     0836
Advocacy Department, Mass Audubon
                                     0837
Private Citizen
                                     0838
ICLEI Local Governments for Sustainability USA
                                     0840
Navajo County District III
                                     0915
Georgia Interfaith Power & Light
                                     0933
Long Island Sierra Club
                                     1386
Private Citizen
                                     1419
Friends United for a Safe Environment (FUSE)
                                     1508
Private Citizen
                                     1510
Committee For A Constructive Tomorrow (CFACT)
                                     1511
Arlington County Board
                                     1512
American Academy of Pediatrics (AAP)
                                     1529
Public Health Institute (PHI)
                                     1530
New Progressive Alliance (NPA)
                                     1612
Sustainable Community Initiatives and Community Forklift, LLC
                                     1624
Distinguished University Teaching Professor
                                     1635
Private Citizen
                                     1637
Envirometrics, Inc.
                                     1650
Private Citizen
                                     1652
Private Citizen
                                     1658
Private Citizen
                                     1678
Private Citizen
                                     1681
Burrell Mining Products, Inc.
                                     1695
Mission Economic Development Corporation
                                     1747
Climate Solutions-Practical Solutions to Global Warming
                                     1871
Medical Advocates for Healthy Air (MAHA)
                                     1884
Private Citizen
                                     1889
Private Citizen
                                     1896
Kentucky Environmental Foundation
                                     1898
The Synthesis Foundation
                                     1899
First Energy
                                     1900
University of Minnesota Duluth
                                     1901
Private Citizen
                                     1902
American Public Power Association (APPA)
                                     1959
National Rural Electric Cooperative (NRECA)
                                     1961
Private Citizen
                                     1974
Clean Energy Action
                                     1975
Coalition on the Environment and Jewish Life (COEJL) et al.
                                     2059
League of Women Voters of the San Antonio Area (LMV)
                                     2107
Private Citizen
                                     2227
ClearStack Power, LLC
                                     2228
Sierra Club
                                     2329
Value the Verde Ecotourism
                                     2470
Florida Public Service Commission
                                     2471
City Water Light & Power
                                     2472
Missouri Public Service Commission (MoPSC)
                                     2512
League of Women Voters of the United States
                                     2525
New Progressive Alliance
                                     2572
Waupaca Coalition for Public Response, Inc. (WCPR)
                                     2658
Institute for 21st Century Energy, U.S. Chamber of Commerce
                                     2674
Monmouth County Audubon Society
                                     2741
Blue Planet, LLC
                                     2771
Private Citizen
                                     2864
State of North Dakota Public Service Commission
                                     2980
Climate Parents
                                     2981
Coal Utilization Research Council (CURC)
                                     2983
SanDiego350.org
                                     2984
Sempra Energy
                                     3043
Interfaith Power & Light
                                     3093
Greater Pittsburgh Chamber of Commerce
                                     3107
Plano Chamber of Commerce
                                     3175
PW Power Systems (PWPS)
                                     3176
Alabama Public Service Commission (APSC)
                                     3179
Mesa County Board of County Commissioners
                                     3180
Utah Physicians for a Healthy Environment (UPHE)
                                     3236
American Farm Bureau Federation
                                     3353
Azul et al.
                                     3360
Energy Producing States Coalition (EPSC)
                                     3593
The Energy and Environmental Law Institute (E&E Legal) & The Free Market Environmental Law Clinic (FMELC)
                                     3594
Oregonians for Renewable Energy Progress (OREP)
                                     3862
Occidental Chemical Corporation
                                     4619
ClearStack Power LLC
                                     4625
Private Citizen
                                     4634
Institute for 21st Century Energy,U.S. Chamber of Commerce
                                     4710
Minnkota Power Cooperative, Inc.
                                     4711
Dresser-Rand
                                     4814
Southern States Energy Board (SSEB)
                                     4845
Guam Power Authority
                                     4846
The Center for Regulatory Effectiveness
                                     4867
Resources for the Future
                                     4926
State of Indiana House of Representatives
                                     4927
State of Indiana Senate
                                     5156
Office of Attorney General, State of West Virginia
                                     5512
Chamber of Commerce, Frisco, Texas
                                     5532
Building Materials Reuse Association
                                     5537
Northeast States for Coordinated Air Use Management (NESCAUM), Arthur N. Marin
                                     5567
Missoula City-County Air Pollution Control Board
                                     5599
Clean Air Markets LLC
                                     5602
Citizens Hearing, Virginia Chapter of the Sierra Club
                                     5604
Bossier Parish Police Jury
                                     5605
Citizens Hearing, Southern Alliance for Clean Energy et al.
                                     5606
Citizens Hearing, Clean Air Carolina and North Carolina Conservation Network
                                     5630
Great Lakes Metro Chambers Coalition
                                     5631
Mississippi Energy Institute
                                     5731
Division of Environment, Kansas Department of Health and Environment (KDHE)
                                     5732
Environmental Law Project (ELP), University of Pennsylvania Law School
                                     5746
Private Citizen
                                     6115
Private Citizen
                                     6273
Private Citizen
                                     6501
The United States Conference of Mayors
                                     6505
Mitsubishi Hitachi Power Systems Americas, Inc. (MHPSA)
                                     6538
League of Women Voters of Santa Barbara
                                     6564
Apex Compressed Energy Storage, LLC
                                     6870
Division of Environment, Kansas Department of Health and Environment (KDHE)
                                     6871
Pennsylvania Senate Coal Caucus
                                     6948
West Virginia Chamber of Commerce
                                     6949
Energy Producing States Coalition (EPSC)
                                     6962
Waupaca Coalition for Public Response
                                     7017
L. Ramos-Hernandez
                                     7433
Public Utilities Commission of Ohio (PUCO)
                                     7475
Alaska Power Association (APA)
                                     7502
Garden Club of America (GCA)
                                     7503
Douglas County Global Warming Coalition, Oregon
                                     7533
Wyoming Machinery Company
                                     7540
The Clean Energy Group
                                     7893
Alaska Power Association (APA)
                                     7976
Californians for Rational Regulation
                                     7977
Kentucky Energy and Environment Cabinet
                                     7990
Pacific Gas and Electric Company (PG&E)
                                     7994
Missouri River Energy Services (MRES) and Western Minnesota Municipal Power Agency
                                     8009
Berthold Klein
                                     8020
National Tribal Air Association (NTAA)
                                     8022
Utility Air Regulatory Group (UARG)
                                     8023
Los Angeles Department of Water and Power (LADWP),  Mark J. Sedlacek
                                     8024
Unions for Jobs and Environmental Progress (UJEP)
                                     8032
Western Farmers Electric Cooperative (WFEC)
                                     8079
Industrial Contractors Inc.
                                     8348
Babcock & Wilcox Power Generation Group, Inc. (B&W), Kiplin C. Alexander
                                     8349
Illinois Municipal Electric Agency (IMEA)
                                     8487
Defenders of Wildlife
                                     8501
Indiana Coal Council, Inc.
                                     8742
Georgia Farm Bureau
                                     8743
Excelsior Energy, Inc.
                                     8906
Nebraska Farm Bureau Federation (NFBF)
                                     8909
National Association of Clean Air Agencies (NACAA), Stu Clark and Larry Greene
                                     8911
Californian's for Rational Regulation
                                     8918
Great River Energy, Mary Jo Roth
                                     8923
North American Coal Corporation
                                     8924
Center for Rural Affairs
                                     8925
Electric Power Research Institute, Inc. (EPRI)
                                     8937
Black Hills Corporation (BHC)
                                     8939
Fond du Lac Band of Lake Superior Chippewa
                                     8944
Solar Turbines Incorporated, Leslie Witherspoon
                                     8947
Algenol Biofuels Inc.
                                     8948
Delaware Solid Waste Authority (DSWA), Angela D. Marconi
                                     8949
Enefit American Oil
                                     8952
Gas Turbine Association (GTA),  William H. Day
                                     8954
American Coal Council (ACC)
                                     8955
Campbell County Conservation District (CCCD)
                                     8956
National Association of County and City Health Officials
                                     8957
Pennsylvania Department of Environmental Protection (DEP) , E. Christopher Abruzzo
                                     8958
Florida Electric Power Coordinating Group Environmental Committee (FCG-EC)
                                     8964
City of Jackson, Ohio
                                     8966
Pennsylvania Coal Alliance (PCA), John Pippy
                                     8967
Prairie Band Potawatomi Nation
                                     8968
Office of the Commissioner of Securities and Insurance, Montana State
                                     8969
City of Orville, Ohio
                                     8970
Village of Plymouth
                                     8971
Ohio Coal Association
                                     8972
Business Council for Sustainable Energy (BCSE) - Lisa Jacobson
                                     8973
Orrville Utilities, Jeff Brediger
                                     8974
Oklahoma Municipal Power Authority (OMPA),  David W. Osburn
                                     8995
Borough of Smethport
                                     9001
Surry-Yadkin EMC
                                     9002
Domtar Corporation
                                     9003
South Carolina Department of Health and Environmental Control (DHEC)
                                     9004
Connecticut Department of Energy and Environmental Protection (DEEP)
                                     9033
Alstom
                                     9034
Buckeye Power, Inc.
                                     9035
Center for Climate and Energy Solutions (C2ES)
                                     9042
Colorado Department of Public Health and Environment
                                     9047
Private Citizen
                                     9107
ARCTECH Inc.
                                     9190
Pocahontas Land Corporation
                                     9191
Kentucky Coal Association (KCA)
                                     9192
We Energies
                                     9193
Iowa Farm Bureau Federation
                                     9194
Florida Municipal Electric Association (FMEA)
                                     9195
Committee on Science, Space, and Technology, U.S. House of Representatives
                                     9196
Electric Reliability Coordinating Council (ERCC)
                                     9197
International Brotherhood of Boilermakers
                                     9198
Waste Management (WM)
                                     9201
National Mining Association (NMA)
                                     9202
Eco-Justice Ministries
                                     9317
Georgia Environmental Protection Division (EPD)
                                     9318
Village of Oak Harbor
                                     9319
National Mining Association (NMA)
                                     9320
Seminole Electric Cooperative, Inc.
                                     9321
ARIPPA
                                     9326
Institute of Clean Air Companies (ICAC)
                                     9381
NextEra Energy, Inc.
                                     9382
Hoosier Energy Rural Electric Cooperative
                                     9396
Alliance for Fuel Options, Reliability and Diversity (AFFORD)
                                     9397
Mississippi Department of Environmental Quality (MDEQ)
                                     9398
Private Citizen
                                     9401
Industrial Energy Consumers of America (IECA)
                                     9403
Power4Georgians, LLC (P4G)
                                     9406
Exelon Corporation
                                     9407
Southern Illinois Power Cooperative (SIPC)
                                     9408
JEA
                                     9409
National Alliance of Forest Owners (NAFO)
                                     9422
Omaha Public Power District (OPPD)
                                     9423
Texas Commission on Environmental Quality (TCEQ), Public Utility Commission of Texas (PUC), and Railroad Commission of Texas (RRC)
                                     9424
Colorado Springs Utilities
                                     9425
Dominion Resources Services, Inc.
                                     9426
Duke Energy Business Services, LLC
                                     9427
Municipal Electric Authority of Georgia (MEAG)
                                     9428
Western Farmers Electric Cooperative
                                     9469
Powder River Basin Resource Council
                                     9471
PPl Services Corporation
                                     9472
American Coalition for Clean Coal Electricity (ACCCE)
                                     9486
Indiana Department of Environmental Management
                                     9487
Southeastern Legal Foundation, Inc.
                                     9494
National Federation of Independent Business (NFIB)
                                     9496
Western Organization of Resource Councils (WORC)
                                     9497
Mississippi Public Service Commission (MPSC)
                                     9498
Murray Energy Corporation (Murray Energy)
                                     9499
Golden Spread Electric Cooperative, Inc
                                     9500
American Wind Energy Association (AWEA)
                                     9503
International District Energy Association (IDEA)
                                     9504
National Environmental Development Association/Clean Air Project (NEDA/CAP)
                                     9505
State of West Virginia Office of Attorney General, State Nebraska Office of Attorney General, et al.
                                     9507
City Utilities of Springfield, Missouri (CU)
                                     9508
City of New York
                                     9509
Energy Recovery Council (ERC)
                                     9510
American Fuel & Petrochemical (AFPM) and American Petroleum Institute (API)
                                     9512
The SSM Coalition
                                     9513
Sierra Club
                                     9514
Sierra Club
                                     9515
Institute for Policy Integrity
                                     9589
The League of Women Voters of Texas
                                     9590
Utah Mining Association (UMA)
                                     9591
Public Service Enterprise Group, Inc. (PSEG) and The Clean Energy Group
                                     9592
Gainesville Regional Utilities (GRU)
                                     9593
Xcel Energy Inc.
                                     9594
Forging Industry Association (FIA)
                                     9595
Tennessee Electric Cooperative Association (TECA)
                                     9596
Santee Cooper
                                     9597
Consumers Energy Company
                                     9599
Tri-State Generation and Transmission Association, Inc., Sunflower Electric Power Corporation
                                     9600
Minnkota Power Cooperative, INC.
                                     9601
North Dakota Association of Rural Electric Cooperatives (NDAREC)
                                     9602
Nebraska Public Power District (NPPD)
                                     9646
Delaware Department of Natural Resources and Environmental Control on the Environmental Protection (DNREC)
                                     9648
Division of Air Quality (DAQ), North Carolina Department of Environment and Natural Resources (NCDENR)
                                     9649
Kansas City Board of Public Utilities, Unified Government of Wyandotte County, Kansas City, Kansas
                                     9650
The Ronald Reagan Legal Center, Landmark Legal Foundation
                                     9654
LPP Combustion, LLC
                                     9655
Partnership for a Better Energy Future
                                     9656
Natural Gas Supply Association (NGSA)
                                     9657
American Action Forum (AAF)
                                     9660
Eleven States' Attorney Generals
                                     9661
Tampa Electric Company (TEC)
                                     9664
Clean Air Task Force (CATF)
                                     9665
General Electric Company (GE)
                                     9666
Utility Air Regulatory Group (UARG), Hunton & Williams LLP
                                     9667
GE Energy Financial Services on behalf of EFS Shady Hills, LLC
                                     9668
GE Energy Financial Services on behalf of Cogen Technologies Linden Venture, L.P.
                                     9671
City of Piqua, Ohio
                                     9672
City of Piqua, Ohio
                                     9675
BioProcess Algae (BPA)
                                     9676
Biomass Power Association
                                     9677
Cleco Corporation
                                     9678
America's Natural Gas Alliance (ANGA)
                                     9681
Environmental Defense Fund, et al.
                                     9682
United States Senate, Oklahoma
                                     9683
CCS Alliance
                                     9684
Competitive Enterprise Institute (CEI)
                                     9685
A. G. Randol III
                                     9686
A. G. Randol III
                                     9687
A. G. Randol III
                                     9723
Montana-Dakota Utilities, Co.
                                     9725
Ambre Energy
                                     9730
California Air Pollution Control Officers Association (CAPCOA)
                                     9731
Independent Petroleum Association of America (IPAA)
                                     9733
American Forest & Paper Association (AF&PA) and American Wood Council (AWC)
                                     9734
East Kentucky Power Cooperative (EKPC)
                                     9735
United States Senate, North Dakota
                                     9736
City of Hubbard
                                     9737
A.G. Randol 
                                     9765
Wyoming Department of Environmental Quality (WDEQ)
                                     9766
Algae Biotechnology Organization (ABO)
                                     9767
Cass County Electric Cooperative Inc.
                                     9768
Accelergy Corporation
                                     9769
NorthWestern Energy
                                     9770
Minnesota Municipal Utilities Association (MMUA)
                                     9771
California Air Resources Board (ARB)
                                     9772
Treasure State Resource Industry Association (TSRIA)
                                     9773
Wisconsin Department of Natural Resources (WDNR)
                                     9774
Wisconsin Department of Natural Resources (WDNR)
                                     9775
Salt Lake City, Utah
                                     9776
National Mining Association (NMA)
                                     9777
Luminant
                                     9779
Puget Sound Energy (PSE)
                                     9780
Edison Electric Institute (EEI), Quinlan J. Shea
                                     10017
Ohio EPA
                                     10020
Heat Mining Company LLC
                                     10021
Heat Mining Company LLC
                                     10022
Golden Valley Electric Association (GVEA)
                                     10023
Kansas City Power & Light Company (KCP&L)
                                     10024
Missouri Joint Municipal Electric Utility Commission (MJMEUC)
                                     10025
Our Children's Trust
                                     10026
Bioenergy Association of California (BAC)
                                     10027
Coalition For Renewable Natural Gas (RNGC)
                                     10028
State of South Dakota
                                     10029
Sapphire Energy
                                     10030
Wolverine Power Supply Cooperative Inc.
                                     10031
Oglethorpe Power
                                     10032
Idaho Farm Bureau Federation
                                     10033
American Water Works Association
                                     10034
The George Washington University Regulatory Studies Center
                                     10035
Biotechnology Industry Organization (BIO)
                                     10036
Coal Utilization Research Council (CURC)
                                     10038
CHP Association
                                     10039
Ameren Corporation
                                     10040
Center for Biological Diversity (CBD) et. al
                                     10041
Center for Biological Diversity (CBD) et. al
                                     10042
Center for Biological Diversity (CBD) et. al
                                     10043
Indiana Municipal Power Agency (IMPA)
                                     10044
Energy and Environment Legal Institute (EELI) and Free Market Environmental Law Clinic (FMELC)
                                     10045
Biogenic CO2 Coalition
                                     10046
Murray Energy Corporation
                                     10047
Regional Air Pollution Control Agency
                                     10048
Salt River Project Agricultural Improvement and Power District (SRP)
                                     10049
Private Citizen
                                     10050
Arizona Mining Association (AMA)
                                     10051
Rubber Manufacturers Association (RMA)
                                     10052
Berkshire Hathaway Energy Company
                                     10053
America's Electric Cooperatives
                                     10082
Georgia Public Service Commission
                                     10083
WEST Associates
                                     10084
Competitive Enterprise Institute
                                     10085
American Chemistry Council (ACC)
                                     10086
Old Dominion Electric Cooperative (ODEC)
                                     10087
Institute for Energy Research
                                     10088
Lignite Energy Council
                                     10089
Office of the People's Counsel for the District of Columbia
                                     10090
National Wildlife Federation (NWF)
                                     10091
Cato Institute
                                     10092
Ohio Utility Group
                                     10093
Yale Environmental Law Association, 2013-2014 Student Board
                                     10094
Illinois Farm Bureau
                                     10095
Southern Company
                                     10096
House of Representatives, Congress of the United States
                                     10097
Associated Electric Cooperative, Incorporated (AECI)
                                     10098
AFPM & API
                                     10099
United States Senate, Committee on Environment and Public Works United States Senate
                                     10100
Class of '85 Regulatory Response Group
                                     10102
Arizona Public Service Company
                                     10103
Navajo Nation Environmental Protection Agency
                                     10104
Consumer Energy Alliance
                                     10105
Nevada Division of Environmental Protection (NDEP)
                                     10106
Clean Wisconsin
                                     10108
Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), Western Resource Advocates (WRA)
                                     10119
Center for Biological Diversity, Friends of the Earth, Chesapeake Climate Action Network and Greenpeace USA
                                     10131
National Waste & Recycling Association and Solid Waste Association of North America (SWANA)
                                     10134
Indiana-Kentucky Electric Corporation (IKEC), Ohio Valley Electric Corporation (OVEC)
                                     10135
Pennsylvania Public Utility Commission (PAPUC)
                                     10136
Partnership for Policy Integrity (PFPI)
                                     10137
Carbon Sequestration Council (CSC)
                                     10141
Unknown
                                     10237
Concentrating Solar Power Alliance
                                     10238
Wabash Valley Power Association (WVPA)
                                     10239
National Association of Manufacturers (NAM), et al.
                                     10240
Arizona Departmetn of Environmental Quality (ADEQ)
                                     10241
A.G. Randol 
                                     10242
SCANA Corporation
                                     10243
DTE Energy
                                     10294
Falkirk Mining Company
                                     10296
Private Citizen
                                     10301
U.S. House of Representatives
                                     10304
Private Citizen
                                     10358
Northwest Iowa Power Cooperative
                                     10374
The Green Party of the United States
                                     10387
South Mississippi Electric (SME)
                                     10388
Associated Industries of Missouri
                                     10389
Siemens Energy, Inc.
                                     10390
El Paso Electric Company
                                     10391
Southeastern Legal Foundation, Inc. (SLF)
                                     10392
City of St. Mary's Ohio
                                     10393
Manitowoc Public Utilities (MPU)
                                     10394
South Coast Air Quality Management District (SCAQMD)
                                     10395
Basin Electric Power Cooperative
                                     10396
Office of the Governor, Wyoming
                                     10397
Energy Recovery Council (ERC)
                                     10398
Montana Public Service Commission
                                     10466
TransAlta Centralia Generation, LLC (TCG)
                                     10466
TransAlta Centralia Generation, LLC (TCG)
                                     10499
Center for Biological Diversity, Friends of the Earth, Chesapeake Climate Action Network and Greenpeace USA
                                     10500
Arkansas Electric Cooperative Corporation (AECC)
                                     10501
San Miguel Electric Cooperative, Inc.
                                     10502
The Right Climate Stuff (TRCS) Research Team
                                     10503
National Association of Manufacturers (NAM), et al.
                                     10504
Aurora Energy, LLC
                                     10518
Cape Hatteras Electric Cooperative
                                     10520
Otter Tail Power Company
                                     10525
Tribal Environmental Policy Center (TEPC)
                                     10527
Private Citizen
                                     10551
Arizona's Generation and Transmission Cooperatives (AzGT)
                                     10552
Arch Coal, Inc
                                     10553
New York State Caucus of Environmental Legislators (NYSCEL),
                                     10554
FirstEnergy
                                     10555
Wisconsin Manufacturers & Commerce (WMC)
                                     10556
Gulf Coast Lignite Coalition  (GCLC), Jackson Walker L.L.P.
                                     10557
Woods Hole Oceanographic Institution
                                     10594
Private Citizen
                                     10606
Golder Associates Inc.
                                     10607
West Virginia Coal Association (WVCA)
                                     10608
Montana Electric Cooperatives' Association (MECA)
                                     10615
Gulf Coast Lignite Coalition  (GCLC), Jackson Walker L.L.P.
                                     10617
Audubon New York
                                     10618
American Electric Power (AEP)
                                     10619
Oklahoma Department of Environmental Quality
                                     10620
Forest County Potawatomi Community
                                     10621
Portland General Electric Company (PGE)
                                     10660
The Air Permitting Forum
                                     10661
Competitive Enterprise Institute
                                     10662
West Virginia Department of Environmental Protection
                                     10663
Oglethorpe Power Corporation
                                     10664
Arizona State University
                                     10665
Utah Associated Municipal Power Systems (UAMPS)
                                     10667
Texas Mining and Reclamation Association (TMRA)
                                     10668
Texas Mining and Reclamation Association (TMTA)
                                     10670
Marathon Petroleum Company LP
                                     10676
Guam Power Authority
                                     10680
Alliance Coal, LLC
                                     10681
Department of Ecology, State of Washington
                                     10682
Alliance for Industrial Efficiency
                                     10693
American Lung Association
                                     10765
G. Y. Sugiyama
                                     10785
60 plus
                                     10786
North American Carbon Capture & Storage Association (NACCSA)
                                     10788
PowerSouth Energy Cooperative
                                     10791
Tampa Electric Company (TEC)
                                     10869
Union of Concerned Scientists
                                     10870
North Dakota Department of Health, Division of Air Quality
                                     10876
Borough of Hatfield, Pennsylvania
                                     10877
EFS Shady Hills LLC
                                     10878
Florida Municipal Electric Association (FMEA)
                                     10879
South Carolina Department of Health and Environmental Control
                                     10880
Western Fuels Association Inc.
                                     10881
California Department of Justice
                                     10928
Illinois Coal Association (ICA)
                                     10929
Minnesota Power (ALLETE)
                                     10930
Utah Physicians for a Healthy Environment (UPHE)
                                     10930
Utah Physicians for a Healthy Environment (UPHE)
                                     10950
Cogen Technologies Linden Venture, L.P.
                                     10951
Peabody Energy Company
                                     10952
The National Rural Electric Cooperative Association
                                     10953
Southern Environmental Law Center et al.
                                     10961
Private Citizen
                                     10962
Deseret Power Electric Cooperative
                                     10963
Rosebud Mining Company
                                     10965
Association of Electric Companies of Texas ("AECT")
                                     10966
Law Office
                                     10967
Mississippi Manufacturers Association (MMA)
                                     10974
Colorado Mining Association (CMA)
                                     10975
Natural Resource Partners LP
                                     10991
Bay Area Air Quality Management District (BAAQMD)
                                     11005
Clean Air Task Force (CATF)
                                     11036
Private Citizen
                                     11051
Private Citizen
                                     11052
Private Citizen
                                     11053
Private Citizen
                                     11054
Private Citizen
                                     11056
Michigan House of Representatives
                                     11057
Brattleboro Town Clerk
                                     11058
City of Long Beach
                                     11062
Hallador Energy Co.
                                     11063
Regency Energy Partners dba PVR Partners L.P.
                                     11083
Covanta
                                     11105
Private Citizen
                                     11134
S. Fakhari
                                     11184
Public Hearing Rm A 2-6-2014
                                     11221
Public Hearing Rm B 2-6-2014


Organization of This Document
This RTC document is organized into Chapters as follows:
      Chapter 1: Introduction
      Chapter 2: Legal Issues
      Chapter 3: Costs and Benefits
      Chapter 4: Climate Science, Rational Basis Analysis and Endangerment
      Chapter 5: Applicability to New EGUs, IGCC, and CTs
      Chapter 6: Standards for Utility Boilers and IGCC Units
      Chapter 7: Standards for Stationary Combustion Turbines
      Chapter 8: Other Configurations and Fuels
      Chapter 9: Other Rules and Programs
      Chapter 10: Issues for which EPA Requested Comments
      Chapter 11: Monitoring and Compliance
      Chapter 12: Recordkeeping and Reporting
      Chapter 13: Startup, Shutdown and Malfunction
      Chapter 14: Statutory and Executive Orders
      Chapter 15: General Provisions
      Chapter 16: Rule Language
      Chapter 17: Incorporation by Reference
      Chapter 18: General

