Allen
Basala/
RTP/
USEPA/
US
08/
31/
2005
03:
16
PM
To
Amy_
E._
Flynn@
omb.
eop.
gov
cc
Jim
Ketcham­
Colwill/
DC/
USEPA/
US@
EPA,
John
Silvasi/
RTP/
USEPA/
US@
EPA,
Jan
Tierney/
DC/
USEPA/
US@
EPA,
Thomas
Gillis/
DC/
USEPA/
US@
EPA,
Peter
Nagelhout/
DC/
USEPA/
US@
EPA,
Larry
Sorrels/
RTP/
USEPA/
US@
EPA,
Ron
Evans/
RTP/
USEPA/
US@
EPA,
Jason
Burnett/
DC/
USEPA/
US@
EPA
Subject
Per
discussion
Amy,

I
have
attached
redline
strikes
of
the
difference
analysis
as
well
as
appendix
B.
Here
are
the
changes
made
to
each
p
our
discussions
this
morning.
Also,
we
had
inadvertently
left
off
a
change
agreed
to
with
Margo
S.
several
days
ago.

I
assume
this
completes
the
changes
to
the
economics
package.

Allen
O:
919­
541­
5622
H:
919­
467­
4584
Change
to
the
title
of
Appendix
B.

Impact
of
Selected
Federal
and
Local
Measures
on
Predicted
8­
hour
Design
Values
in
the
Eastern
U.
S.
Illustrative
Control
Strategies
and
Projected
2010
8
hour
Ozone
Levels
in
16
Nonattainment
Areas
Change
to
page
4
Appendix
B
wording
on
model
versus
data
limitations.

As
used
in
this
analysis,
AirControlNET
included
a
broad
menu
of
stationary
source
control
measures
(
e.
g.,
ad
on
control
technologies
and
combustion
controls)
but
did
not
provide
a
comprehensive
menu
of
existing
controls
know
to
be
available
for
all
types
of
sources.
For
example,
due
to
model
limitations
a
lack
of
data
on
the
percentage
of
emiss
reductions
and
associated
costs,
the
analysis
did
not
consider
additional
state
strategies
to
reduce
emissions
from
fuels,
highway
vehicles,
or
non­
road
engines.
The
model
also
is
limited
in
terms
of
the
This
lack
of
data
also
limited
the
number
of
control
measures
considered
in
area
emissions
sectors.

Emission
reduction
possibilities
are
considered
within
and
nearby
the
non­
attainment
area.
5
5These
area
are
within
state
but
not
more
than
100
km
for
VOC
emissions
and
no
more
than
200
km
for
NOx
emissions.
The
controls
are
presented
on
a
cost
per
ton
of
VOC
or
NOx
reduced
and
put
in
ascending
order.
Controls
are
selected
until
the
emission
reduction
target
is
met
or
until
a
cost
per
ton
level
of
$
10,000
is
reached.
This
limitation
was
used
in
this
analysis
to
avoid
large
upward
biases
in
the
control
cost
in
view
of
the
limited
number
of
control
measures
that
cou
be
considered
for
selection
in
the
local
control
strategy.

Change
on
page
10
to
delete
the
introductory
sentence.

Ozone
Mortality
Health
Benefits.
Ozone
mortality
is
one
category
where
new
studies
suggest
significant
additional
economic
benefits.

Change
to
the
title
page
of
the
difference
analysis
Appendix
B:
Impact
of
Selected
Federal
and
Local
Control
Measures
on
Predicted
8­
hour
Desi
Values
in
the
Eastern
U.
S.
Illustrative
Control
Strategies
and
Projected
2010
8­
hour
Ozone
Levels
in
16
Nonattainment
Areas
Changes
to
the
difference
analysis
Section
6.1
Achieving
targeted
tarted
reductions
from
certain
EGUs
can
lower
the
overall
cost
of
the
local
attainment
strategy
where
the
incremental
cost
of
targeted
EGU
emission
reductions
is
less
than
the
cost
of
achieving
similar
reductions
and
air
quality
improvements
from
other
types
of
sources.

The
intent
of
these
consultations
would
not
be
to
upset
market
behavior
or
incentives.
Furthermore
Rather,
w
anticipate
that
these
consultations
will
affect
individual
control
decisions
for
a
few
areas.

Changes
to
the
difference
analysis
Section
6.2
For
Subpart
2
areas
that
are
classified
as
moderate
or
higher
choosing
to
use
the
2004
emissions
inventory,
th
RFP
requirement
must
be
met
at
the
start
of
the
ozone
season
in
2009.
In
moderate
areas
with
a
12
month
ozone
season,
the
RFP
requirement
would
have
to
be
met
by
1­
01­
09.
