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MassDEP ...

    COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS

    DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108 617-292-5500

     DEVAL L. PATRICK IAN A. BOWLES Governor Secretary TIMOTHY P. MURRAY LAURIE BURT Lieutenant Governor Commissioner

    MassDEP

    Bureau of Waste Prevention

    Response To Comments On:

    310 CMR 7.70

    “Massachusetts CO Budget Trading Program” 2

    and Amendments to:

    310 CMR 7.29

    “Emissions Standards for Power Plants”

    and

    310 CMR 7.00: Appendix B(7)

    “Emission Banking, Trading, and Averaging”

    Regulatory Authority:

    M.G.L. c. 111, Sections 142A through 142E

    December 2007

    Table of Contents

    Table of Contents ........................................................................................................................2 I. Regulation History and Notes .................................................................................................3 II. Public Comment Process .......................................................................................................4 III. Comments and Responses ....................................................................................................5 A. 310 CMR 7.29 and 310 CMR 7.00 Appendix B(7) (Amendments) ....................................5

    B. 310 CMR 7.70: Massachusetts CO2 Budget Trading Program ...........................................8

    1. Applicability ...................................................................................................................8

    2. Size and Structure of the Cap ........................................................................................ 10

    3. Allocation ..................................................................................................................... 10

    4. Temporal Flexibility Mechanisms ................................................................................. 12

    5. Offsets (General Comments)......................................................................................... 12

    6. Offsets (Specific Categories) ........................................................................................ 14

    7. Allowance Retirements for Voluntary Purchases of Renewable Energy ........................ 16

    8. Economic Impact and Cost Controls ............................................................................. 17

    9. Imports and Leakage .................................................................................................... 18

    10. Coordination with other State and Federal Programs ................................................... 19

    11. Allowance Tracking Accounts .................................................................................... 20

    12. Monitoring.................................................................................................................. 20 IV. List of Commenters ............................................................................................................ 30 A. Organizations .................................................................................................................. 30 B. Massachusetts State Legislators ....................................................................................... 30

    C. Unaffiliated Citizens ........................................................................................................ 30

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    I. Regulation History and Notes In August of 2007, the Massachusetts Department of Environmental Protection (MassDEP)

    proposed replacement of the CO emissions standards of 310 Code of Massachusetts Regulations 2

    (CMR) 7.29: Emissions Standards for Power Plants with the CO requirements of 310 CMR 7.70: 21Massachusetts CO Budget Trading Program. Corresponding amendments to 310 CMR 7.00: 2

    Appendix B(7) and 310 CMR 7.29 were also proposed, and a Technical Support Document was

    published.

    The Massachusetts CO Budget Trading Program establishes a cap-and-trade program to regulate 2

    emissions of CO that occur after January 1, 2009 from fossil-fuel-fired units that serve an electric 2

    generator with a nameplate capacity of 25 megawatts (MW) or greater.

    These amendments to 310 CMR 7.29 and 310 CMR 7.00: Appendix B(7) are intended to provide

    for an orderly transition to the Massachusetts CO Budget Trading Program. These amendments to 2310 CMR 7.29 and Appendix B(7) will terminate the CO requirements of 310 CMR 7.29 on 22December 31, 2008 and terminate the Greenhouse Gas Credit Banking and Trading Program in

    2013. These amendments also facilitate the transition by combining and postponing the final

    compliance date for 310 CMR 7.29 until September 1, 2009, expanding the geographic scope for

    the creation of GHG Credits, and allowing for the limited exchange of GHG Credits for CO 2

    allowances.

     1 The MA CO Budget Trading Program implements the CO Budget Trading Program in MA. The CO Budget 222

    Trading Program is often referred to, in other contexts, as the Regional Greenhouse Gas Initiative (RGGI).

    Throughout this document, the terms CO allowances and CO offset allowances refer to allowances that can used to 22comply with the state-specific requirements of the CO Budget Trading Program in any participating state. 22 The Greenhouse Gas Credit Banking and Trading Program, established in 310 CMR Appendix B(7), allows for the creation of GHG (Greenhouse Gas) Credits. GHG Credits can be created for emission reduction, avoided emission or

    sequestered emission projects and can be used for compliance with the CO limits established in 310 CMR 7.29: 2Emissions Standards for Power Plants, or exchanged for CO allowances in accordance with the exchange provisions 2established in 310 CMR 7.70(5)(c) and amendments to 310 CMR 7.00 Appendix B(7).

     3

II. Public Comment Process

    MassDEP held four public hearings and solicited written testimony on the proposed regulations in

    accordance with Massachusetts General Laws (MGL) Chapter 30A. On August 10, 2007,

    MassDEP published notice of the public hearings and public comment period on the proposed

    regulations and amendments in the Springfield Republican and the Boston Globe, and notified

    interested parties via electronic mail. Public hearings were held on the dates and at the

    Massachusetts locations specified below. The public comment period closed on September 24,

    2007.

    Hearings Held: Monday, September 10, 2007 in Wilmington

     Tuesday, September 11, 2007 in Lakeville

     Tuesday, September 11, 2007 in Holyoke

     Wednesday, September 12, 2007 in Boston

    This document summarizes and responds to major comments that were received during the public

    comment period. MassDEP appreciates the input from those who testified at the public hearings

    and submitted written comments into the hearing docket. A full list of commenters is listed at the

    end of this document.

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III. Comments and Responses

    A. 310 CMR 7.29 and 310 CMR 7.00 Appendix B(7) (Amendments)

    3Comment: One commenter indicated that it has experienced difficulty procuring GHG Credits

    and recommended that MassDEP extend the deadlines for affected facilities to demonstrate

    compliance with 310 CMR 7.29 CO standards until 2012 since the market has been unable to 2

    produce GHG Credits. (Dominion)

    Response: MassDEP has retained its proposal to postpone and combine the 2007 and 2008 CO 2

    compliance demonstration deadlines from January 30, 2008 and 2009 to September 1, 2009. As

    discussed in the Technical Support Document, this timeline will help reduce the administrative

    burden on MassDEP and the regulated facilities. MassDEP has also taken two additional steps to

    provide compliance options to the facilities regulated pursuant to 310 CMR 7.29. First, through

    amendments to 310 CMR 7.00: Appendix B(7), MassDEP is expanding the geographic area within

    which projects must be located in order to qualify for GHG Credits for reduced, avoided, or 4sequestered emissions of GHGs from the region to the entire United States. Second, as noticed in

    the Environmental Monitor on December 24, 2007, MassDEP is proposing to allow facilities to 5demonstrate compliance by paying into the GHG Expendable Trust, in accordance with 310 CMR 7.00 Appendix B(7)(d)6. MassDEP has concluded that these changes will provide sufficient

    compliance flexibility for affected facilities, and that it is not necessary to extend the deadline for

    affected facilities to demonstrate compliance beyond September 2009. Comment: One commenter stated that MassDEP should keep 310 CMR 7.29 in place until the

    MA CO Budget Trading Program has successfully commenced (Clean Water Action), while 2

    another suggested that the provisions of 7.29 should be structured to automatically “sunset” upon the commencement of the Massachusetts CO Budget Trading Program (NRG). A third 2

    commenter suggested that MassDEP repeal the CO rate provisions of 310 CMR 7.29 before they 2

    take effect on January 1, 2008 (Dominion). Several commenters expressed general support for

    MassDEP’s proposal to end the CO provisions of 310 CMR 7.29 with the implementation of 310 2

    CMR 7.70 on January 1, 2009 (FPL, Northeast GHG Coalition, Dominion).

    Response: As proposed, MassDEP is retaining 310 CMR 7.29’s CO emissions cap standards for 22007 and 2008, and its CO emissions rate standards for 2008. The CO emissions standards of 22310 CMR 7.29 will be replaced by the cap-and-trade provisions of the Massachusetts CO Budget 2

     3 A GHG Credit is “a credit based on an amount of emission reductions, avoided emissions or sequestered emissions of a GHG. One GHG Credit has an assigned value of one ton of carbon dioxide equivalent. GHG Credits shall be

    expressed in whole tons. When certifying or verifying GHG Credits, the number of GHG Credits is rounded down for

    decimals less than 0.5 and rounded up for decimals of 0.5 or greater,” as defined in 310 CMR 7.00 Appendix B(7)(b). 4 The original geographic scope for GHG Credit projects included Connecticut, Delaware, Maine, Massachusetts,

    Maryland, New Hampshire, New Jersey, New York, and Vermont. 5The GHG Expendable Trust is “ the trust established pursuant to 801 CMR 50.00 for the purpose of providing a

    separate segregated interest-bearing account for the receipt of payments made pursuant to 310 CMR 7.00: Appendix

    B(7)(d)5,” as defined in 310 CMR 7.00 Appendix B(7)(b).

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Trading Program beginning on January 1, 2009. This schedule will ensure continuity in

    MassDEP’s effort to regulate CO emissions from electric generating units. 2

    Comment: One commenter noticed that 310 CMR 7.00 Appendix B(7)(d)5.c., which provides for

    payments into the GHG Expendable Trust, was not included in the proposed amendments. The

    commenter requested confirmation that MassDEP does not intend to eliminate 310 CMR 7.00

    Appendix B(7)(d)5.c. (NRG).

    Response: MassDEP is not eliminating or amending 310 CMR 7.00, Appendix B (7)(d)5.c.

    Comment: One commenter requested that MassDEP extend the proposed deadline to receive 6exchangeable GHG Credits under 310 CMR 7.29 for CO Budget Trading Program CO 227allowances beyond December 31, 2012. The commenter noted that this timeframe is shorter than

    the ten-year or twenty-year allocation period for offset projects under the MA CO Budget Trading 2Program (Dominion). Another commenter requested that MassDEP move the proposed deadline

    for the creation of exchangeable GHG Credits forward to correlate with the end of the first

    three-year compliance period under the MA CO Budget Trading Program on December 31, 2011. 2

    This commenter also asserted that the application deadlines for establishing project eligibility for

    GHG Credit exchange are too lenient and will encourage more ineligible GHG Credits to be

    created for compliance with 310 CMR 7.70 and not 310 CMR 7.29. (Environment Northeast) Response: MassDEP is retaining the proposed December 31, 2012 deadline for the verification of

    GHG Credits that may be exchanged for CO allowances under the MA CO Budget Trading 22Program. The purpose of this exchange is to compensate those who invested in projects because of

    the GHG Credit program without creating an alternative means to acquire CO Budget Trading 2Program CO allowances. MassDEP has concluded that the 2012 deadline balances these two 2

    objectives. Consistent with the Department’s intent to have an orderly transition to the MA CO 2

    Budget Trading Program, MassDEP is finalizing the amendments to 310 CMR 7.00 Appendix B(7)

    to clarify that applications for certification of GHG Credits that are received after the effective date

    of these regulations will not result in the creation of GHG Credits that can be exchanged for CO 2

    allowances.

    Comment: Regarding the exchange of GHG Credits for CO allowances, several commenters 2asserted that GHG Credits should not be discounted at a ratio of 2 to 1, and that there should be a 1 to

    1 recognition for such investments that reduce, sequester or avoid greenhouse gas emissions

    (Dominion, Northeast GHG Coalition, Entergy). According to one of these commenters, the 2 to 1

    discount for GHG Credits is contrary to development of a national cap and trade program, and such

    a policy would also discriminate against offset projects that meet all the key criteria for an

    environmentally beneficial project, such as real, measurable, verifiable GHG reductions (Northeast

    GHG Coalition). One commenter expressed support for the proposal to exchange one CO 2

    allowance for every two GHG Credits (Environment Northeast).

     6 The CO Budget Trading Program is “a multi-state CO air pollution control and emissions reduction program 22

    established by regulation in several states, including Massachusetts pursuant to 310 CMR 7.70, for the purpose of

    reducing emissions of CO from CO budget sources,” as defined in 310 CMR 7.70(1)(b). 227 A CO allowance is a “limited authorization by the Department or a participating state under the CO Budget Trading 22Program to emit up to one ton of CO, subject to all applicable limitations contained in 310 CMR 7.70,” as defined in 2

    310 CMR 7.70(1)(b).

     6

Response: A 2 to 1 exchange ratio was chosen because GHG Credits are not equivalent to CO 28offset allowances or CO allowances, and because this ratio strikes an appropriate balance 2

    between recognizing investments in GHG Credit-generating projects and achieving the full

    benefits of the MA CO Budget Trading Program. MassDEP is therefore finalizing its proposal to 2

    discount GHG Credits at a ratio of 2 to1.

    Comment: One commenter suggested that the exchange provisions unfairly favor MA CO 2Budget Trading Program-ineligible projects. While GHG Credits earned by such projects may be

    exchanged for CO allowances, GHG Credits earned by MA CO Budget Trading 22Program-eligible projects may only be exchanged for CO offset allowances, the use of which is 2

    constrained (NRG).

    Response: MassDEP has concluded that its proposal does not disadvantage MA CO Budget 2Trading Program-eligible projects. MA CO Budget Trading Program-eligible projects projects 2

    will be able to apply for CO offset allowances at an undiscounted rate of one CO offset 22allowance for each GHG Credit. This option will adequately reward investment in eligible projects.

    MassDEP is allowing the exchange of GHG Credits from MA CO Budget Trading 2Program-eligible projects for CO offset allowances to encourage MA CO Budget Trading 22Program-eligible projects to participate in the GHG Credit market, instead of simply waiting for a

    market to develop for the CO Budget Trading Program. 2

    Comment: One commenter suggested that MassDEP amend the final regulation to cap the

    Greenhouse Gas Credit Exchange Set-aside at 1% of the MA CO Budget Trading Program base 2 9budget, or 266,602 CO allowances (Environment Northeast). 2

    Response: As proposed, MassDEP will allocate sufficient CO allowances to the Greenhouse Gas 2

    Credits Exchange Set-aside to cover the exchange of all unused GHG Credits from MA CO 2Budget Trading Program-ineligible projects for CO allowances at a 2:1 ratio. The reference to 2

    266,602 CO allowances was included in the Technical Support Document to illustrate the likely 2

    magnitude of the program, and not to imply that the number of allowances available for exchange

    would be limited.

    Comment: One commenter requested clarification regarding the proposal to allow the exchange

    of GHG Credits for CO Budget Trading Program CO allowances. The commenter stated, “It 22

    appears that DEP intended for proposed 310 CMR 7.70(10)(c)(4)(e) and related provisions to

    ensure that only RGGI eligible offset projects would receive RGGI allowance credit a vital concern as allowing other sources of offsets to earn offset (and thereby allowance) credit would

    undermine the entire regional program.” (CLF)

     8 A CO offset allowance is a “CO allowance that is awarded to the sponsor of a CO emissions offset project pursuant 222to 310 CMR 7.70(10)(g) and is subject to the relevant compliance deduction limitations of 310 CMR 7.70(6)(e)1.c.,”

    as defined in 310 CMR 7.70(1)(b). 9 The Massachusetts CO Budget Trading Program base budget is “the annual amount of CO tons available in 22Massachusetts for allocation in a given allocation year, in accordance with the CO Budget Trading Program. CO 22offset allowances awarded pursuant to 310 CMR 7.70(10) and Early Reduction CO Allowances awarded pursuant to 2310 CMR 7.70(5)(c)2. are separate from and additional to COallowances allocated from the Massachusetts CO 2 2

    Budget Trading Program Base Budget,” as defined in 310 CMR 7.70(1)(b).

     7

Response: MassDEP did not intend to entirely prevent projects that do not meet the requirements

    of 310 CMR 7.70 from earning CO Budget Trading Program CO allowances; in fact, the 2:1 22

    exchange provisions in 310 CMR 7.00 Appendix B(7) and 310 CMR 7.70 explicitly allow for this

    to occur through direct allocations of CO allowances. These allocations are necessary to provide 2a fair return on investment for projects that were initiated for the purpose of complying with the

    CO provisions of 310 CMR 7.29. MassDEP also notes that the CO allowances which will be 22

    exchanged are included in the MA CO Budget Trading Program base budget; therefore the 2exchange program will not undermine the environmental objectives of the CO Budget Trading 2

    Program by expanding the cap. It is true, however, that only projects that meet the requirements of

    310 CMR 7.70(10) can earn CO offset allowances, and that any project that meets the 2requirements of 310 CMR 7.70(10) can earn CO offset allowances unless the reduced, avoided, or 2

    sequestered emissions have already been used for compliance with the CO provisions of 310 2

    CMR 7.29. These exchange provisions will provide for a smooth transition from the GHG Credit

    program to the MA CO Budget Trading Program. MassDEP also notes that GHG Credit 2

    applications received after the effective date of these regulations will not generate GHG Credits

    that can be exchanged for CO allowances. 2

    Comment: Several commenters expressed concern about the supply of GHG Credits available for

    compliance with 310 CMR 7.29. Specifically, it was requested that the geographic scope be

    expanded and that payments into the GHG Trust be allowed as soon as possible (FirstLight,

    Dominion).

    Response: Provisions allowing MassDEP to accept payments into the GHG Expendable Trust

    under certain conditions are retained in the final regulation, and the geographic scope in which

    emission reduction, avoided emission, or sequestered emission projects can be located is also

    expanded to the entire United States. In addition, as noticed in the Environmental Monitor on

    December 24, 2007, MassDEP is proposing to allow payments into the GHG Expendable Trust, in

    accordance with 310 CMR 7.00 Appendix B(7)(d)6. Furthermore, MassDEP intends to propose,

    early in 2008, additional amendments to 310 CMR 7.00 Appendix B(7) that will clarify the

    process and requirements by which emission reduction, avoided emission or sequestered emission

    projects located outside of the United States may, under certain conditions, be used for compliance

    with the CO2 emissions standards of 310 CMR 7.29. The date by which MassDEP must annually

    evaluate the availability and price of GHG Credits is therefore being postponed from February 15

    to June 1 to allow time for the development of these amendments. As an additional point of

    clarification, MassDEP notes that these actions shall have no effect on whether or not MassDEP

    determines, in accordance with 310 CMR 7.00 Appendix B(7)(d)4., that insufficient GHG Credits

    are available for 2007 on or before June 1, 2008, and should not be interpreted as any indication of

    whether or not MassDEP shall make such finding.

    B. 310 CMR 7.70: Massachusetts CO2 Budget Trading Program

    1. Applicability

    Comment: One commenter asserted that a cap and trade program to address carbon emissions

    should cover all CO sources (Mirant). Another suggested that methane emissions from landfills 2

    should be included, and that the purpose should be revised to acknowledge life cycle emissions of

    six GHG gases (Covanta).

     8

     Budget Trading Program is to control CO emissions Response: The purpose of the MA CO22

    associated with the generation of electricity. MassDEP acknowledges that adequately addressing

    the climate problem will eventually require economy-wide regulation of greenhouse gas emissions.

    The MA CO Budget Trading Program represents a first step. 2

    10 Comment: A number of comments were received regarding the definition of “eligible biomass.”

    Many requested that the definition be clarified, and specific objections were raised regarding the

    phrases “energy crops,” “sustainably harvested,” and “old growth” (H2 Diesel, Environment

    Northeast). Some commenters argued that such terms should be tightly defined to exclude fuels

    that do not fully meet the standards (Environment Northeast, CLF). Others argued for a less

    restrictive definition to encourage the use of biomass fuels and processes (NE Biofuels

    Collaborative, Senator Morrissey and Representative Dempsey, Northeast GHG Coalition, Bob

    Machaver, FirstLight, Covanta), in several cases providing specific examples of fuels that could be

    excluded under the proposed definition (NRG, H2 Diesel, International Paper Products). Several

    commenters requested that MassDEP broaden the definition to be consistent with the Division of

    Energy Resource’s Renewable Portfolio Standard regulations, or to include any biomass fuel that

    has been approved by MassDEP through a Beneficial Use Determination (NRG, Dominion,

    Senator Menard).

    Response: MassDEP has concluded that the proposed definition of eligible biomass correctly

    balances the need to acknowledge CO emissions benefits associated with the substitution of 2

    certain biomass fuels for fossil fuels with the need to consider the full range of environmental

    impacts associated with biomass fuels. MassDEP acknowledges ongoing scientific and

    technological progress in addressing life-cycle CO emissions associated with biomass fuels, and 211plans to work with other participating states to develop additional guidance on this matter. However, MassDEP believes that the proposed definition of “eligible biomass” provides adequate

    direction to allow for implementation of the relevant provisions of the MA CO Budget Trading 2

    Program.

    Comment: “Liquid Biofuels” are listed as materials that qualify as “Eligible Biomass”; however

    there is no formula provided in 310 CMR 7.70(8)(g) to quantify the portion of the CO emissions 2

    from these fuels that are of biomass origin. A formula should be added to 7.70(8)(g) to quantify

    the CO emissions resulting from combustion of the “bio” portion of a liquid biofuel, so that these 2

    emission can be excluded from the CO reconciliation process (i.e. do not have to be offset by CO 22

    Allowances). It does not make sense to list biofuels as eligible biomass fuels, and then provide no

    means to determine the CO emissions attributable to the biomass fraction of these fuels. (Bob 2

    Machaver)

Response: The GHG emissions benefits of combusting liquid biofuels in place of fossil fuels can

    vary significantly due to the wide range of their production processes, and recent scientific efforts

     10 “Eligible biomass includes sustainably harvested woody and herbaceous fuel sources that are available on a

    renewable or recurring basis (excluding old-growth timber), including dedicated energy crops and trees, agricultural

    food and feed crop residues, aquatic plants, unadulterated wood and wood residues, animal wastes, other clean organic

    wastes not mixed with other solid wastes, biogas, and other neat liquid biofuels derived from such fuel sources.

    Sustainably harvested shall be determined by the Department,” as defined in 310 CMR 7.70(1)(b). 11 A participating state is “a state that is a member of the CO Budget Trading Program and has promulgated a 2regulation consistent with 310 CMR 7.70,” as defined in 310 CMR 7.70(1)(b).

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have not yet produced adequate methods to quantify these benefits for specific fuels. Therefore,

    MassDEP has revised the definition of eligible biomass so that it no longer includes liquid biomass

    fuels. This means that CO emissions associated with the combustion of liquid biofuels cannot be 2

    deducted from a facility's compliance obligation. However, MassDEP will continue to research

    this issue, along with other participating states, and may propose amendments to the definition of

    “eligible biomass” in the future. Comment: One commenter requested that MassDEP revise its applicability criteria so that any

    unit will be exempt from the program if the fossil fuel combusted comprises no more than 50

    percent of the annual heat input on a Btu basis during any year, regardless of whether that unit

    commenced operation before or after January 1, 2005. (FirstLight)

    Response: MassDEP is finalizing the applicability requirements and definition of “fossil fuel

    fired” as proposed without modification. The language in the “fossil fuel fired” definition is

    intended to allow facilities that burn a significant portion of biomass to be excluded from the MA

    CO Budget Trading Program. The January 1, 2005 date was intended to differentiate between 2

    existing biomass facilities and new state of the art biomass facilities. For facilities operating prior

    to that date, the threshold was set at 50% in recognition of the fact that existing older biomass

    facilities may have difficulty obtaining the higher 95% threshold applied to newer state of the art

    facilities. Both the 50% and 95% thresholds are “once in always in” thresholds, meaning that if a

    facility ever exceeded or exceeds in the future the applicable threshold, that facility would be

    subject to the program. MassDEP points out that the monitoring section of the MA CO Budget 2

    Trading Program provides for quantification of CO emissions from eligible biomass, and that the 2

    emissions from eligible biomass are not included in the calculations to determine the facility’s

    compliance obligation.

    2. Size and Structure of the Cap Comment: On the basis of recent emissions data, several commenters concluded that the base

    budget is too high to drive actual reductions in CO emissions (UCS, MA Sierra Club, 2

    Environment Northeast, Environmental Entrepreneurs). Others argued that the base budget is too

    small to account for expected demand growth (AIM, MA Food Association, Retailers Association

    of MA, Boston Real Estate Board, NRG), or that it should have been set higher using 1990

    emissions data, a baseline used in various other contexts (Senators Morrissey and Dempsey, James

    Smith, AIM).

    Response: The MA CO Budget Trading Program initially aims to stabilize emissions from 2009 2

    through 2014 at a level roughly equivalent to historical emissions, and the base budget was

    established to be consistent with this goal. The most recent emissions estimates that were

    available at the time were used in setting the base budget, and MassDEP does not believe that it is

    appropriate to revisit it at this time.

    3. Allocation

    Comment: One commenter stated that the MA Energy Facilities Siting Board (EFSB) has

    previously required some new facilities to offset CO emissions and suggested that direct 2

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