The Integrated Planning Model Summary Run Results document is not included in the Certified Index to the Record and has not been lodged with the Court, but is available on the EPA website.

Because of time constraints and the EPA's voluminous record, the LPSC focused on the Rule itself in preparing its Brief Supporting Petitioners.

For instance, the Rule states, based on the Integrated Planning Model, that "[n]ew combined cycle units are 20 GW by 2030," but does not clarify that "0" are projected with CCS.

The data shows that EPA's conclusions with regard to achievability and cost were drawn based on projections that no significant combined cycle generation will ever be added with carbon capture, transportation, and sequestration infrastructure.

Results from the EPA's Integrated Planning Model show that "0" combined cycle natural gas generating facilities will be added with CCS through 2055.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, et al., Respondents.

To the Honorable John G. Roberts, Jr., Chief Justice of the United States and Circuit Justice for the District of Columbia Circuit

EPA IPM Summary Run Results Projections for Continental U.S. 2023 Reference Case All costs and prices are in 2022-year dollars

National Wholesale Electricity Price (mills/kWh) Natural Gas Prices (2022 $/MMBtu) Henry Hub Delivered Minemouth Coal Prices (2022 $/MMBtu) Appalachia Imports Interior Waste Coal West National TOTAL CAPACITY (Cumulative GW) Hydro Non-Hydro Renewables Biomass Geothermal Landfill Gas Solar Wind Distributed Solar PV Coal Coal without CCS IGCC without CCS Coal with CCS Energy Storage Nuclear Natural Gas CC without CCS CC with CCS

Other Grand Total NEW HARDWIRED CAPACITY (Cumulative GW) Hydro Non-Hydro Renewables Biomass Geothermal Landfill Gas Solar Wind Coal Coal without CCS IGCC without CCS Coal with CCS Energy Storage Nuclear Natural Gas CC without CCS CC with CCS

CC Retirements Coal Retirements CT Retirements Nuclear Retirements O/G Retirements IGCC Retirements Biomass Retirements Fuel Cell Retirements Fossil_Other Retirements Geothermal Retirements Hydro Retirements Landfill Gas Retirements Non Fossil_Other Retirements Energy Storage Retirements Grand Total GENERATION MIX (thousand GWh) Hydro Non-Hydro Renewables Biomass Biomass Co-firing Geothermal Landfill Gas Solar Wind Distributed Solar PV Coal Coal without CCS (Biomass Co-firing is included) IGCC without CCS Coal with CCS Energy Storage 2028 2028 2028 1,141 2030 2030 2030 1,329 2035 2035 2035 2,229 1,483 2040 2040 2040 3,097 2,236 1,167 2045 2045 2045 4,032 1,194 2,800 1,313 2050 2050 2050 4,094 1,230 2,818 1,427 2055 2055 2055 4,200 1,268 2,880 Nuclear Natural Gas CC without CCS CC with CCS

Coal Use by Region (million tons) Power Sector Appalachia Imports Interior Waste Coal West Non-Power Sector Appalachia Interior West Power Sector Coal Use by Rank (million tons) Bituminous Subbituminous Lignite Natural Gas Use (Trillion cubic feet) 1,652 1,612 4,418 1,670 1,635 4,560 1,344 1,302 4,981 5,348 5,825 6,080 1,107 1,050 6,345 2028 2030 2035 2040 2045 2050 2055 Note: Distributed Solar PV are not included in the Grand Total of "Total Capacity" and "Generation Mix"

The Integrated Planning Model Summary Run Results document is not included in the Certified Index to the Record and has not been lodged with the Court, but is available on the EPA website.

Because of time constraints and the EPA's voluminous record, the LPSC focused on the Rule itself in preparing its Brief Supporting Petitioners.

For instance, the Rule states, based on the Integrated Planning Model, that "[n]ew combined cycle units are 20 GW by 2030," but does not clarify that "0" are projected with CCS.

The data shows that EPA's conclusions with regard to achievability and cost were drawn based on projections that no significant combined cycle generation will ever be added with carbon capture, transportation, and sequestration infrastructure.

Results from the EPA's Integrated Planning Model show that "0" combined cycle natural gas generating facilities will be added with CCS through 2055.

EPA IPM Summary Run Results Projections for Continental U.S. 2023 Reference Case All costs and prices are in 2022-year dollars

National Wholesale Electricity Price (mills/kWh) Natural Gas Prices (2022 $/MMBtu) Henry Hub Delivered Minemouth Coal Prices (2022 $/MMBtu) Appalachia Imports Interior Waste Coal West National TOTAL CAPACITY (Cumulative GW) Hydro Non-Hydro Renewables Biomass Geothermal Landfill Gas Solar Wind Distributed Solar PV Coal Coal without CCS IGCC without CCS Coal with CCS Energy Storage Nuclear Natural Gas CC without CCS CC with CCS

Other Grand Total NEW HARDWIRED CAPACITY (Cumulative GW) Hydro Non-Hydro Renewables Biomass Geothermal Landfill Gas Solar Wind Coal Coal without CCS IGCC without CCS Coal with CCS Energy Storage Nuclear Natural Gas CC without CCS CC with CCS

CC Retirements Coal Retirements CT Retirements Nuclear Retirements O/G Retirements IGCC Retirements Biomass Retirements Fuel Cell Retirements Fossil_Other Retirements Geothermal Retirements Hydro Retirements Landfill Gas Retirements Non Fossil_Other Retirements Energy Storage Retirements Grand Total GENERATION MIX (thousand GWh) Hydro Non-Hydro Renewables Biomass Biomass Co-firing Geothermal Landfill Gas Solar Wind Distributed Solar PV Coal Coal without CCS (Biomass Co-firing is included) IGCC without CCS Coal with CCS Energy Storage 2028 2028 2028 1,141 2030 2030 2030 1,329 2035 2035 2035 2,229 1,483 2040 2040 2040 3,097 2,236 1,167 2045 2045 2045 4,032 1,194 2,800 1,313 2050 2050 2050 4,094 1,230 2,818 1,427 2055 2055 2055 4,200 1,268 2,880 Nuclear Natural Gas CC without CCS CC with CCS

Coal Use by Region (million tons) Power Sector Appalachia Imports Interior Waste Coal West Non-Power Sector Appalachia Interior West Power Sector Coal Use by Rank (million tons) Bituminous Subbituminous Lignite Natural Gas Use (Trillion cubic feet) 1,652 1,612 4,418 1,670 1,635 4,560 1,344 1,302 4,981 5,348 5,825 6,080 1,107 1,050 6,345 2028 2030 2035 2040 2045 2050 2055 Note: Distributed Solar PV are not included in the Grand Total of "Total Capacity" and "Generation Mix"

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, et al., Respondents.

To the Honorable John G. Roberts, Jr., Chief Justice of the United States and Circuit Justice for the District of Columbia Circuit

I, Bryant Lee, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for the Applicant.

by sending three copies of same, addressed to each individual respectively, through FedEx Overnight Mail.

Additionally, the Application is also being served by email to individuals who waived paper service.

On the same date as above, I sent to this Court one copy of the within Reply in Support of Application for Immediate Stay of Final Agency Action Pending Appellate Review through FedEx Overnight Mail.

Notary Public State of New York No. 01BR6004935 Qualified in Richmond County Commission Expires March 30, 2026 #331712