I talked to TNRCC today and they informed me that the timeline for applying for VOC ERCs is 180 days after shutdown, and for VOC DERCs for 2001 it is 90 days after shutdown. NOx ERCs can only be applied for in 2003 after the 2002 allowances are unused.

Marc N. Phillips
Director, Regulatory Technical Analysis
713-646-7646 (cell 713-594-6919)
marc.phillips@enron.com