Technical Support Document (TSD)
for the Revised CSAPR Update for the 2008 Ozone NAAQS
Docket ID No. EPA-HQ-OAR-2020-0272
Allowance Allocation
Proposed Rule TSD
U.S Environmental Protection Agency
Office of Air and Radiation
2020
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Allowance Allocation to Existing and New Units under the Proposed Revised CSAPR Update Rule
Federal Implementation Plan (FIP)
This Technical Support Document (TSD) provides information that supports EPA's
determination of unit-level allocations for existing and new units under the proposed Revised CSAPR
Update Rule. Section VIII.C.2 of the preamble discusses state budgets, and section VIII.C.3 discusses
how the budgets are apportioned (i.e., allocated) to existing and new units under FIP program structure.
This TSD provides additional information in support of unit level allocations and elaborates on the data
and methodology used to arrive at the proposed allocations. The TSD is organized as follows:
1)	Overview
2)	New Unit Set-Asides and Allocations
3)	Allocation Methodology for Existing Units
a.	List of Existing Units
b.	Data and Calculations
c.	States with state-approved allocation methodologies
EPA anticipates that some states will submit State Implementation Plans (SIPs) with revised unit-level
allocations to existing units that will replace those defined in the FIP. Section VIII.D of the proposed
Revised CSAPR Update preamble explains when and how states may replace the FIP allocations for
vintage year 2022 or later through specific SIP procedures.
1. Overview
As discussed in preamble section VIII.B, each state's budget is comprised of the emissions that EPA
estimates remain after the state has made the reductions required to eliminate its significant contribution
to nonattainment and interference with maintenance of the relevant National Ambient Air Quality
Standards (NAAQS) in downwind states in an average year. EPA proposed the Revised CSAPR Update
with a limited interstate trading program. Emission allowances are used in the implementation of this
program. Specifically, EPA creates one allowance for each ton of emissions allowed in each year under
each state's emission budget. Each allowance has a "vintage" year, which is the year for which the
allowance is issued. Covered sources are required to submit such an allowance for each ton of the
relevant pollutant emitted during the compliance year. To implement the programs, allowances are
initially allocated among covered sources within a state.
As discussed in the preamble, under the FIP, EPA allocates allowances to sources in the state equal to
that state's total budget. The methodology used to determine states' budgets is independent of and not
affected by the methodology used to determine initial allowance allocations. In other words, initial
allowance allocations in no way impact the state budget. The state budgets are determined independently
through the multi-factor analysis outlined in section VII of the proposed Revised CSAPR Update
preamble. Regardless of the methodology used by EPA or a state to allocate allowances to sources
within the state, emissions in each covered state that significantly contribute to nonattainment or interfere
with maintenance in another state will be prohibited. In sum, the allocation methodology has no impact
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on the rule's ability to satisfy the statutory mandate of CAA section 110(a)(2)(D)(i)(I) to eliminate
significant contribution and interference with maintenance in downwind states.
As discussed in section VIII.C.3 of the preamble, under the FIPs, EPA will distribute the entire
budget to units located in the state subject to the FIP. However, this budget would first be divided into
three different subgroups listed below (note, amounts vary by state):
1)	New unit set-aside (NUSA)
2)	Indian Country new unit set-aside (Indian country NUSA)
3)	Existing unit budget
An initial amount of the state budget (95% to 98%, depending on the state) would be distributed to
"existing" units (i.e., units online before January 1, 2019) in advance of the vintage year for which they
are issued. The remaining amount would be held back for "new" units in NUSA and Indian country
NUSA accounts. A "new" unit qualifying for allocations from a NUSA or Indian country NUSA would
typically be a unit that commenced commercial operation on or after January 1, 2019, but some older
units that do not receive allocations as existing units may also qualify for allocations. If any of the NUSA
or Indian country NUSA allowances are not allocated to qualifying "new" units, then the allowances
would be allocated to "existing" units on the same basis as the initial existing unit budget so they will be
available to existing units for compliance.
The proposed Revised CSAPR Update identifies potentially covered existing units under the rule and
the proposed allocations for each of those units under the FIP. This TSD details how the list of existing
units was determined, how the proposed allocations were calculated, and how the quantity of allowance
set-asides for new units and Indian Country new units were determined. Following these descriptions, an
appendix showing each affected EGU's allocation under the proposed Revised CSAPR Update FIP along
with the underlying data and calculations used to derive the allocations comprises most of the document.
2) New Unit Set Asides and Allocations
As explained in section VIII.C.3, the proposed Revised CSAPR Update uses January 1, 2019 as
the cut-off date used to distinguish "new units" from "existing units" for purposes of allowance
allocation. Allocations to existing units are based on historical heat input over a five-year baseline as well
as historical emissions data over an eight-year baseline. To allocate using this methodology, EPA needs
at least one full ozone season of heat input and emissions data from an "existing unit" If a unit did not
come online prior to January 1, 2019, it may not have provided a full ozone season of data at the time of
the Revised CSAPR Update's finalization.1 For this reason, EPA could not use a date later than January
1, 2019 for the cut-off date. Units that came online after January 1, 2019 are considered "new units" for
purposes of allocation under the proposed Revised CSAPR Update FIPs and will receive their allocations
from the NUSA or Indian country NUSA for their states.
The new unit set-aside for ozone season NOx for each state is a percentage of the state's total
budget. This percentage is the sum of a "base" percentage that all states receive for "potential" new units
and a state-specific percentage reflecting emissions from "planned" units. For purposes of this document,
1 Under the CSAPR trading program regulations, new units are generally required to complete certification of their
emissions monitoring systems and begin reporting emissions data to EPA by 180 days after they commence
commercial operation.
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the "potential" units on which the new source set-aside base percentage relies are those units that are
projected new builds in the IPM modeling of the proposed Revised CSAPR Update. In other words, they
are units that do not show up in the modeling input but do show up in the modeling output. "Planned"
units, on which the state-specific percentage of the new source set-aside is based, are those units that are
already identified in the modeling input because they are specific plants that are already built or are under
construction, but that commence commercial operation on or after January 1, 2019. Because the location
of these "planned" units is already known and identified in the modeling input, the portion of the new unit
set-aside corresponding to these units is state-specific.
EPA has proposed to use the same base percentage of the new unit set-aside of 2 percent
established in the original Cross State Air Pollution Rule finalized in 2011 and the CSAPR Update Rule
finalized in 2016. EPA identified the 2 percent value as a reasonable set-aside for potential new units as it
reflected the high end of state-level emissions from projected - or potential - new units. EPA determined
that this 2 percent level was reasonable for the Revised CSAPR Update as well. By selecting the high-
end percentage, EPA chose a conservative envelope that would provide a pool of new unit set-aside
allowances large enough to cover emissions from "potential" new units in states.2 EPA chose this basis in
order to preserve a reasonable amount of allowances for new unit allocations in every state, as new units
may not be sited in the same locations that EPA's modeling assumes for analytical purposes.
The "state-specific" percentage represents the share of each state budget that EPA projects to be
emitted from "planned" units in 2024. As discussed previously, determining the state-specific percentage
is necessary given the new unit definition used in the proposed rule. EPA is determining a state-specific
percentage for projected emissions from "planned" units because unlike the location of new capacity that
the model projects to be built, the location of planned units is already known.
Under the existing CSAPR Update trading program, EPA has already approved a SIP revision for
one state - New York - that reflects a state preference to set aside 5 percent of the budget for the NUSA
rather than the amount that EPA would have allocated under the CSAPR Update FIP. For purposes of this
proposal, EPA intends to replicate individual state's allocation preferences to the extent practicable where
those preferences are known from prior SIP revisions. Accordingly, for New York EPA proposes to set
aside 5 percent of each budget for new units, split between a NUSA and an Indian country NUSA in the
same manner as for other states.
The base and state-specific percentages were added for each state to determine the size of that
state's new-unit set asides, which are shown in Tables 1A through ID below. The same information
calculated with the same methodology for all 23 CSAPR states, including the eleven Original CSAPR
Group and CSAPR Update states not in the proposed Revised CSAPR Update, is in Tables A-1A through
A-ID in Appendix A.
Table 1A: 2021 New Unit Set-Asides (NUSA) and Indian Country NUSAs
State
$1,600 per-ton
Portion set
Total NUSA
NUSA for
Indian

Emission
aside for
for new units
new units
country

Budgets (tons)
new units
(tons)
not in Indian
NUSA


(%)

country
(tons)




(tons)

Illinois
9,444
2
181
181

Indiana
12,500
2
253
253

2 As explained in the preamble for the proposed Revised CSAPR Update, after 5 years of non-operation, the
allocation for existing units is redirected to the new unit set asides, thereby offsetting the need for additional
allowances to be withheld from existing unit allocations for purposes of the new unit set asides.
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Kentucky
14,384
2
289
289

Louisiana
15,402
3
459
444
15
Maryland
1,522
2
31
31

Michigan
12,727
3
384
371
13
New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
Ohio
9,605
3
285
285

Pennsylvania
8,076
4
326
326

Virginia
4,544
2
91
91

West Virginia
13,686
2
273
273

Table IB: 2022 New Unit Set-Asides (NUSA) and Indian Country NUSAs
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Illinois
9,415
2
181
181

Indiana
11,998
2
238
238

Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
11,767
3
352
340
12
New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
Ohio
9,676
3
291
291

Pennsylvania
8,076
4
326
326

Virginia
3,656
2
76
76

West Virginia
12,813
2
261
261

Table 1C: 2023 New Unit Set-Asides (NUSA) and Indian Country NUSAs
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Illinois
8,397
2
173
173

Indiana
11,998
2
238
238

Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
9,803
3
296
286
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New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
Ohio
9,676
3
291
291

Pennsylvania
8,076
4
326
326

Virginia
3,656
2
76
76

West Virginia
11,810
2
236
236

Table ID: 2024 and Onwards; New Unit Set-Asides (NUSA) and Indian Country NUSAs
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Illinois
8,397
2
173
173

Indiana
9,447
2
188
188

Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
9,614
3
287
277
10
New Jersey
1,253
2
27
27

New York
3,119
5
156
153
3
Ohio
9,676
3
291
291

Pennsylvania
8,076
4
326
326

Virginia
3,395
2
68
68

West Virginia
11,810
2
236
236

For each control period, any allowances remaining in a state's new unit set-aside (after
allocations are made to new units in accordance with the Revised CSAPR Update regulations) are
distributed to the existing units in that state in proportion to the existing units' original allocations. This
ensures that total allocations to units in the state are equal to the state budget in that year.
Each Indian country new unit set-aside equals a proportion of the "base" new unit set-aside
included in this proposed Revised CSAPR Update (the base percentage, as described above, is 2 percent
of the state budget). As under CSAPR and the CSAPR Update, EPA has proposed to reserve allowances
for the Indian country new unit set-aside only from each state's "base" percentage of the new unit set-
aside. EPA is not reserving these allowances from the state-specific percentage of each state's new unit
set-aside because that percentage is specifically calculated on the basis of projected emissions from
"planned" units, none of which are located in Indian country. EPA is creating Indian country set-asides in
each state as a share of that state's base percentage portion of the new unit set-aside, i.e., as a share of the
2 percent portion of the total budget in that state. EPA is determining the size of the Indian country set-
aside (within that 2 percent portion of the state budget) on the basis of the percentage of Indian country
relative to the entire state. EPA has calculated that the maximum percentage of Indian country in any
state within the Revised CSAPR Update region is no higher than 5 percent, and is using that level as a
basis for establishing Indian country set-asides for all states whose geographic boundaries encompass
Indian country. Therefore, the Indian country set-aside is 5 percent of the base percentage new unit set-
aside, which is equivalent to 0.1 percent of the total state budget (i.e., 5 percent of 2 percent is 0.1
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percent). EPA assessed the share of Indian country within each state using the American Indian
Reservations/Federally Recognized Tribal Entities dataset, which contains data for the 562 federally
recognized Tribal entities in the contiguous U.S. and Alaska. EPA analyzed the share of square miles of
Indian country within the total square miles of a state whose geographic boundaries encompass that
Indian country. As explained above, EPA then took the highest percentage as the number to be applied
across all states with Indian Country to determine the Indian Country new unit set-aside. The Indian
country new unit set-asides in the Revised CSAPR Update states with Indian country are shown in Tables
1A through ID.
New units are allocated allowances from the set-aside accounts described above. The proposed
rule provides that a unit's new unit set-aside allocation initially equals that unit's emissions for the control
period in the preceding year. EPA determines whether the total amount of initial allowance allocations
for all units in a state for a control period exceeds the amount in the state's new unit set-aside for the
control period. If the amount in the new unit set-aside is exceeded, EPA allocates each unit a
proportionate share of the new unit set-aside based on the unit's initial allocation amount relative to other
new units' initial allocation amounts. If allowances remain in the new unit set-aside, EPA then allocates
additional allowances to each new unit that commenced commercial operation during the year of the
control period or the prior year in order to bring the unit's total allocation up to the amount of the unit's
emissions in the control period, if sufficient allowances are available. Any unallocated allowances in the
new unit set-aside are allocated to existing units in proportion to their share of the current existing-unit
allocations. Unused allowances in the Indian country new unit set-aside are first transferred to the
respective state's new unit set-aside. If allowances remain unused in the state's new unit set-aside, they
are then proportionally distributed, as previously described, to existing units in that state.
Beginning in the 2023 control period, EPA is proposing to modify the above two-round NUSA
process to a one-round process in order to simplify the allocation process and eliminate potential
inequities. In this one-round process, which is proposed to apply to all CSAPR trading programs, EPA
proposes to allocate allowances to all eligible units in proportion to their emissions in a given control
period. This proposed procedure would apply to both NUSAs and Indian Country NUSAs.
3) Allocation Methodology for Existing Units
The allocation methodology bases a unit's allocation on the unit's historical heat input but limits any
unit's allocation to its historical maximum emissions. Implementation of this methodology involves
identifying potentially covered units and determining appropriate data baselines for each unit. EPA first
identified the list of potential covered units. Next, EPA compiled reported data on each unit and
calculated its share of heat input. Both stages are described below.
a) List of Potential Existing CSAPR Update Units
The list of units to which allocations are made in the proposed rule is based on proposed
applicability criteria discussed in section VIII.C of the preamble and 40 CFR 97.1004 of the proposed
Revised CSAPR Update regulations. Note that because the applicability criteria are the same criteria used
in CSAPR Update, the inventory of units under the proposed rule would be the same inventory of units
currently reporting under the CSAPR Update trading program for the states covered under the proposed
rule; however, many units that were considered new units under the CSAPR Update would be considered
existing units under the Revised CSAPR Update. For purposes of the proposed rule, existing units are
units that are covered under these criteria and that commenced commercial operation prior to January 1,
2019. This cutoff date is used in the definition of existing unit because it assures that at least one full
ozone season of historical data will be available to determine each existing unit's allocation in the final
rule. EPA is proposing to include 2020 historical data in the final rule, as it should be available by the
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time of final rule promulgation. These proposed allocation tables contain a list of units that EPA believes,
based on best available data, meet the covered and existing unit criteria. As described above, the percent
of the state budgets allocated to existing units varies between 95% and 98% for each state depending on
the number of planned units in each state.
As EPA used the same applicability criteria in this proposal as those used in the CSAPR Update,
to identify the potential existing Revised CSAPR Update units, EPA relied on data reported to EPA
indicating which units were covered under CSAPR Update. All units were already identified and
reporting as subject to CSAPR trading programs.
b) Data and Calculations
For the units identified through the process in section 3a) above. EPA used reported heat-input
data from 2015-2019 and reported emissions data from the EPA database for the years 2012-2019.The
heat input-based allocation method proposed and described below is used to allocate the existing unit
portion of the state's budget (i.e., the state budget less the state's new unit set-aside and, if applicable, the
Indian country new unit set-aside for the state).
Specifically, the heat input approach with the historical maximum emissions upper bound
establishes a baseline historical heat input value for each potential existing unit and sets a unit's share of
available allowances under the Revised CSAPR Update trading program equal to the unit's percentage
share of the total baseline historical heat input for all potential existing CSAPR Update units in the
state. This approach is applied to each state separately, using the portion of that state's budget available
for potential existing Revised CSAPR Update units in that state. In instances where the heat input-based
allocation to a given unit exceeds the unit's historical maximum emissions over the baseline period, this
historical maximum emissions is used as an upper bound on the allocation and the unit's allocation is set
equal to this emission level.
Allocations under this approach for each existing unit are determined by applying the following
steps.
1.	For each unit in the list of potential existing Revised CSAPR Update units, ozone season heat
input values for the baseline period of 2015 through 2019 are identified using data reported to
EPA. For a baseline year for which a unit has no data on heat input (e.g., for a baseline year
before the year when a unit started operating), the unit is assigned a zero value. (Step 2 explains
how such zero values are treated in the calculations.) The allocation method uses a five-year
baseline in order to improve representation of a unit's normal operating conditions over time.
2.	For each unit, the three highest, non-zero ozone season heat input values within the five-year
baseline are selected and averaged. Selecting the three highest, non-zero ozone season heat input
values within the five-year baseline reduces the likelihood that any particular single year's
operations (which might be negatively affected by outages or other unusual events) determine a
unit's allocation. If a unit does not have three non-zero heat input values during the five-year
baseline period, EPA averages only those years for which a unit does have non-zero heat input
values. For example, if a unit has only reported data for 2018 and 2019 among the baseline years
and the reported heat input values are 2 and 4 mmBtus respectively, then the unit's average heat
input used to determine its pro-rata share of the state budget is (2+4)/2 = 3.
3.	Each unit is assigned a baseline heat input value calculated as described in step 2 above. This
baseline heat input value is referred to in the data tables in the rulemaking docket as the "three-
year average heat input."
4.	The three-year average heat inputs of all potential existing units in a state are summed to obtain
that state's total "three-year average heat input."
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5.	Each unit's three-year average heat input is divided by the state's total three-year average heat
input to determine that unit's share of the state's total three-year average heat input.
6.	Each unit's share of the state's total three-year average heat input is multiplied by the existing-
unit portion of the state budget (i.e., the state budget less the state's new unit set-aside and, if
applicable, the Indian country new unit set-aside for the state) to determine that unit's initial
allocation.
7.	An eight-year (2012-2019) historical emissions baseline is established for ozone season NOx
based on data reported to EPA. This eight-year historical emissions baseline is used in order to
capture the unit-level emissions before and after the implementation of the original CSAPR.
8.	For each unit, the maximum ozone season NOx emissions from the eight-year baseline for each
unit is identified. These values are referred to as the "maximum historical baseline emissions" for
each unit.
9.	If a unit has a historical heat-input based allocation (as determined in step 6) that exceeds its
maximum historical baseline emissions (as determined in step 8), then its allocation equals the
maximum historical baseline emission for that unit.
10.	The difference (if positive) under step 9 between a unit's historical heat-input-based allocation
and its "maximum historical baseline emissions" would be reapportioned on the same basis as
described in steps 1 through 6 to units whose historical-heat-input-based allocation does not
exceed its maximum historical baseline emissions. Steps 7, 8, and 9 are repeated with each
revised allocation distribution until the entire existing-unit portion of the state budget is allocated.
The resulting allocation value is rounded to the nearest whole number using conventional
rounding. The table below provides an example application of the steps 1-10 in a hypothetical
state.
Source data can be found at ampd.epa.gov/ampd
Table 2: Demonstration of Allocations Using Proposed Allocation Methodology in a Three-Unit
State Wit
i an 80 Ton State Budget

Step 1-6
Step 7,8,9
Step 10

Historical Heat-input-based Initial
Allocation
Maximum Historical
Baseline Emissions
Proposed
Allocation
Unit A
20
16
16
Unit B
30
50
32
Unit C
30
50
32
Where can Ifind these data?
The unit level allocations can be found in the separate file titled "Revised CSAPR Update for the 2008
Ozone NAAQS - Unit Level Allocations and Underlying Data" published as an Excel file and available in
the docket. The file contains six worksheets. The first, titled "Proposed Allocations", identifies each unit
and its proposed 2021, 2022, 2023 and 2024 and beyond allocations under the trading program. The
second worksheet, titled "Underlying Data for FIP", shows all the data and calculations that are
enumerated above. Each of the ten steps is color coded and displayed in sequential order moving from
left to right across the spreadsheet. The formulas to derive any calculated values are explained directly
beneath the column header. The third and fourth worksheets show data and calculations described in
section 3c) (States with state-approved allocation methodologies) for states where state-approved
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allocation methodologies from SIP submittals were used in place of EPA's default allocation
methodology described above. The fifth worksheet lists those units proposed as non-operating units as of
January 1, 2021; EPA is not determining allocations for these units as existing units. If the units resume
operation, they would have to comply with the program (and would qualify for NUSA allocations). The
sixth worksheet lists units which came on-line after January 1, 2019 and are considered new units.
Rounding
EPA uses conventional rounding for its allocation purposes and applies rounding at the unit level for
existing unit allocations. For example, if State A has a 500 ton budget with a 5% new unit set-aside, then
its existing unit allocation would be 475 tons. If there are only two covered existing units in the state with
equal heat inputs and historical maximum emissions above 500 tons, then the steps described above
would result in an allocation of 237.5 tons for each unit. This unit level allocation for each of these units
would round to 238 allowances, which would sum to 476 allowances. The difference between the sum of
the rounded existing unit level allocations and the state budget (i.e., 500-476), would be the actual new
unit set-aside amount for the state. EPA notes that, because of rounding, the actual number of allowances
in the new unit set-aside will sometimes be a percentage of the state budget marginally greater or less than
the percentage identified in the tables above. In other words, the percentage approximated for the new
unit set aside in the tables above may be 5%, but the actual total allowances in the new unit set-aside may
equal 5.1% or 4.9% of the state budget. Because EPA does not issue allowances or allow surrender of
allowances for compliance using fractional tons, this type of rounding is necessary.
Consent Decrees
EPA's consent decrees with fossil fuel-fired power plants were examined to evaluate if these impact unit
level allocations, (https://www.epa.gov/enforcement/coal-fired-power-plant-enforcement)
Tonnage limits were first evaluated. There are no ozone season tonnage limits, only annual tonnage
limits. The annual tonnage limits were each checked and in all cases are above the proposed unit-level
allocations of ozone season allowances under this rule. In other words, no ozone season unit-level
allocation exceeds the annual limitation established in the consent decrees. Therefore, tonnage limits in
the consent decrees are not relevant to the ozone season unit level allocation process in the Revised
CSAPR Update.
EPA also looked at NOx emission rate limits in these consent decrees; this information can be found in a
separate file entitled "Revised CSAPR Update for the 2008 Ozone NAAQS - Impact Of Consent
Decrees". When the emission rate limits are applied with an assumption of average heat input, EPA found
that collectively, across all units with emission rate limits under the consent decrees, the amount of
allowances allocated to the units could exceed the estimated emissions allowed under the units' rate limits
by a total of 486 tons in 2021, 119 tons in 2022, 83 tons in 2023 and 2024 and beyond. This analysis
included 45 units with consent decree NOx emission rate limits that are proposed as existing units in the
Revised CSAPR Update Rule. Moreover, EPA determined that if maximum allowable heat inputs were
assumed instead of average heat inputs, no unit would have an allowance allocation exceeding its
emission rate limit in any program year. Therefore, EPA concluded that the emission rate limits in the
consent decrees would affect very few allowances in the Revised CSAPR Update trading programs, if
any. Any effort to reallocate the allowances potentially made unusable by emission rate limits would
require EPA to make assumptions about individual units' future utilization and heat input. Because this
would require the use of unit-level projections whose application in setting unit-level allocations would be
difficult to support, and because few allowances are potentially at risk, EPA has chosen not to adjust
allocations to reflect emission rate limits defined in the consent decrees.
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c) States with state-approved allocation methodologies
In the CSAPR Update, if, at the time the rule was finalized, EPA had already approved a SIP revision
addressing the allocation of CSAPR ozone season NOx allowances among the units in the state, and if the
SIP's allocation provisions could be applied to an updated budget, EPA used allocation methodology in
the approved SIP revision to govern the allocation of allowances among that state's units under the final
CSAPR Update. EPA received no adverse comments on that aspect of the CSAPR Update proposal and is
proposing to do the same in the proposed Revised CSAPR Update.
Two of the states that would be covered by the proposed Revised CSAPR Update - Indiana and New
York - have approved SIPs with state methodologies for allocating allowances. See 83 FR 64472 (Dec.
17, 2018) (Indiana); 84 FR 38878 (Aug. 8, 2019) (New York). The allocation methodologies used for
existing units in these states are described below.
Indiana
1)	In step 1, instead of the standard baseline period of 2015 through 2019, ozone season heat input
values for the baseline period of 2012 through 2019 are identified using data reported to EPA.
2)	In step 2, standard methodology is used to average the three highest, non-zero ozone season heat
input values within this larger eight-year baseline.
3)	Standard unit level allocation methodology and standard NUSA methodology are utilized from
this point forward.
New York
1)	Preliminary allocation for each unit is computed as the average of the unit's ozone season NOx
emissions for the years 2017 to 2019, with zero data years included as zeroes.
2)	All preliminary unit allocations at the end of step 1) are summed. If the sum is no more than 85%
of the state budget, proceed to step 4). If the sum exceeds 85% of the state budget, first do step 3).
3)	Apply an equivalent ratio to all preliminary unit allocations from step 1) to reduce the sum of all
unit allocations to 85% of the state budget.
4)	The preliminary unit allocation value is rounded to the nearest whole number using conventional
rounding.
5)	The total portion of the state budget set aside for new units is 5.0%; this includes 0.1% as an
Indian country NUSA and 4.9% as a NUSA for units in the state other than Indian country within
the state's borders.
6)	The difference between the sum of all unit allocations and the total NUSA portion is allocated to
NYSERDA. By definition this must be at least 10% of the state budget, though it could be higher.
11

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Appendix A
Table A-1A: 2021 NUSA and Indian Country ]>
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Alabama
7,786
2
156
148
8
Arkansas
8,708
2
174
174

Georgia
7,808
2
156
156

Illinois
9,444
2
181
181

Indiana
12,500
2
253
253

Iowa
7,714
2
154
146
8
Kansas
5,384
2
108
103
5
Kentucky
14,384
2
289
289

Louisiana
15,402
3
459
444
15
Maryland
1,522
2
31
31

Michigan
12,727
3
384
371
13
Mississippi
6,315
2
126
120
6
Missouri
11,358
2
227
227

New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
Ohio
9,605
3
285
285

Oklahoma
8,717
2
174
165
9
Pennsylvania
8,076
4
326
326

Tennessee
4,367
2
87
87

Texas
42,312
2
846
804
42
Virginia
4,544
2
91
91

West Virginia
13,686
2
273
273

Wisconsin
4,875
3
146
141
5
USAs for All Group 1, 2, and 3 States
Table A-1B: 2022 NUSA and Indian Country fS
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Alabama
7,610
2
152
144
8
Arkansas
8,330
2
167
167

Georgia
7,808
2
156
156

Illinois
9,415
2
181
181

USAs for All Group 1, 2, and 3 States
12

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Indiana
11,998
2
238
238

Iowa
7,626
2
153
145
8
Kansas
5,384
2
108
103
5
Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
11,767
3
352
340
12
Mississippi
6,315
2
126
120
6
Missouri
11,358
2
227
227

New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
Ohio
9,676
3
291
291

Oklahoma
8,717
2
174
165
9
Pennsylvania
8,076
4
326
326

Tennessee
4,367
2
87
87

Texas
41,995
2
840
798
42
Virginia
3,656
2
76
76

West Virginia
12,813
2
261
261

Wisconsin
4,875
3
146
141
5
Table A-1C: 2023 NUSA and Indian Country ]>
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Alabama
7,610
2
152
144
8
Arkansas
8,330
2
167
167

Georgia
7,808
2
156
156

Illinois
8,397
2
173
173

Indiana
11,998
2
238
238

Iowa
7,266
2
145
138
7
Kansas
5,384
2
108
103
5
Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
9,803
3
296
286
10
Mississippi
6,315
2
126
120
6
Missouri
11,079
2
222
222

New Jersey
1,253
2
27
27

New York
3,137
5
157
154
3
USAs for All Group 1, 2, and 3 States
13

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Ohio
9,676
3
291
291

Oklahoma
8,717
2
174
165
9
Pennsylvania
8,076
4
326
326

Tennessee
4,367
2
87
87

Texas
41,807
2
836
794
42
Virginia
3,656
2
76
76

West Virginia
11,810
2
236
236

Wisconsin
4,622
3
139
134
5
Table A-1D: 2024 NUSA and Indian Country ]>
State
$1,600 per-ton
Emission
Budgets (tons)
Portion set
aside for
new units
(%)
Total NUSA
for new units
(tons)
NUSA for
new units
not in Indian
country
(tons)
Indian
country
NUSA
(tons)
Alabama
7,610
2
152
144
8
Arkansas
8,330
2
167
167

Georgia
7,808
2
156
156

Illinois
8,397
2
173
173

Indiana
9,447
2
188
188

Iowa
7,266
2
145
138
7
Kansas
5,384
2
108
103
5
Kentucky
11,936
2
240
240

Louisiana
14,871
3
445
430
15
Maryland
1,498
2
33
33

Michigan
9,614
3
287
277
10
Mississippi
6,315
2
126
120
6
Missouri
11,079
2
222
222

New Jersey
1,253
2
27
27

New York
3,119
5
156
153
3
Ohio
9,676
3
291
291

Oklahoma
8,717
2
174
165
9
Pennsylvania
8,076
4
326
326

Tennessee
4,367
2
87
87

Texas
41,807
2
836
794
42
Virginia
3,395
2
68
68

West Virginia
11,810
2
236
236

Wisconsin
4,104
3
123
119
4
USAs for All Group 1, 2, and 3 States
14

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