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Statement of Need: The issuance of standards of performance for modified and reconstructed power plants is an action item in President Obama's Climate Action Plan (CAP). The CAP calls for the EPA to issue a proposal by no later than June 1, 2014 and to issue a final rule by no later than June 1, 2015.

Summary of the Legal Basis: CO2 is a regulated pollutant and thus is subject to regulation under section 111 of the Clean Air Act as amended in 1990.

Alternatives: Alternatives were discussed in the proposal preamble published on June 18, 2014, at 79 FR 34959.

Anticipated Costs and Benefits: The EPA anticipates few covered units will trigger the reconstruction or modification provisions in the period of analysis (through 2025). As a result, we do not anticipate any significant costs or benefits associated with this proposal.

Risks: The risk addressed is the current and future threat of climate change to public health adn welfare, as demonstrated in the 2009 Endangerment and Cause or Contribute Findings for Greenhouse Gases under section 202(a) of the Clean Air Act.