"Johansson, Robert" <Robert_C._Johansson@omb.eop.gov> 

05/18/2007 04:04 PM

	

To

Marjorie Jones/RTP/USEPA/US@EPA

cc

Lydia Wegman/RTP/USEPA/US@EPA

Subject

RIA Questions ---









Hi Margie,

 

Here are some questions that we have on the briefing material.  

Not sure if you want to pass along to the relevant people to answer and
follow up at next week’s briefing or if you want to send us something
beforehand that addresses some of the easier questions? Let me know. 
PS.  Can you send me Ron’s contact info?

 

Cheers,

Rob

 

Ozone RIA Questions --- Cost Briefing Package for May 16th

 

(1)     Costs, page 3:

a.       Under the RIA control scenario, what emission rates do you
apply to sources covered under CAIR and how do those compare to rates
projected under CAIR? 

b.       Do you have a county NA map for .065?

c.       Do we understand correctly that only KS and AL will have a NA
area added at 0.065?

 

(2)     Costs, page 6:

a.       Why aren’t parts of Alabama included in the 200 km area of
Atlanta at 0.075?

b.       How many NA counties and contributing counties (using the 200km
area) are there at 0.070 and at 0.065?  How many NA monitors?

 

(3)     Costs, page 6:

a.       We recommend that you compute impact ratios using Approach B
for all monitors

 

(4)     Costs, page 7:

a.       Please identify where each of  the 127 NA counties fall on the
impact ratio spectrum

b.       Similarly, please identify where the 280 (at 0.065) fall on
this spectrum

c.       What happens when you Bin related counties instead of choosing
0.1 impact ratios for all?

d.       Please provide the complete list of areas where ozone transport
is a major contributor to local ozone concentrations.  Please provide
the complete list of areas where it’s not.  Please provide those
lists.  Please also confirm that for each of the locations the RIA will
present the residual needed to attain .084, the residual needed to
attain, .070,  the area specific impact ratio,  as well as the emissions
in that each area, by sector.  Having this information, including the
more tailored impact ratio is important.   

 

(5)     Costs, page 10:

a.       It is unclear if these three cost methods are only for NOX or
are for VOCs as well.

b.       How do the estimates and costs per ton change between as you
trade off among the precursors?

 

(6)     Costs, page 11:

a.       Provide function for cost curve as well as marginal cost curve.

 

(7)     Costs, page 12: 

a.       How are existing control costs relevant when modeling showed
that application of existing controls did not result in projected
attainment.  

 

(8)     Costs, page 13:

a.       Please depict total cost curves as well for three methods.

b.       Do you estimate the marginal cost curve with an intercept?

c.       Once again, how would these curves differ if VOCs reductions
came before Nox reductions?

d.       Please provide function estimates and goodness of fit.

 

(9)     Costs, page 14:

a.       At 0.065 to extrapolate, you use the three methods right?

b.       Please explain why going down to 0.065 only brings in two
additional 200 km areas.

c.       How is cost savings computed, and is it done for benefits? Is
there over control for 0.070? 

d.       If you were to calculate the costs for 0.079 could you use the
same convention?

e.       Have you calculated the abatement cost function for all areas,
even those in attainment?  If not, for areas that over control, which
cost/ton estimates would you use? 

f.        Is it correct to use a 0.10 impact ratio for the rest of the
US?  I would think impact ratios would be some function of the starting
point?

 

Ozone RIA Questions --- Benefits Briefing Package for May 16th

 

(10) Benefits, page 3 and page 4:

a.       If you are in attainment at 0.070, how do you calculate the
benefits of 0.075?

b.       Can you walk us through the example on page 3 for a blue area
–vs- a yellow area?

c.       If you are in non-attainment at 0.070, do you first force
attainment through monitor roll-back and then go back up to 0.075, or do
you start from the NA level using existing controls and then scale to
0.075? Under either method (in 10 c. above), how do you reconcile
benefits calculations with the concept of “over-control” savings
adjustments discussed in the cost side (from 9 c. above)? Similarly, if
in the 0.070 scenario, the monitor is actually below 0.070, how are the
benefits calculated for 0.075?

d.       Would you use the same convention for calculating the benefits
of 0.079?

 

(11) Benefits, page 5:

a.       How many monitors NA at 0.065?

 

(12) Benefits, page 9:

a.       You implicitly assume that 0.075 ppm control strategy would
incorporate regional controls and lead to an overestimate of benefits
– would the same be true for costs? 

 

(13) Benefits, CA glidepath:

a.       It looks like about 25% of benefits would not be expected to
occur by 2020; i.e., the portion of CA above the glidepath.  Is that
correct?

 

(14) Benefits, page 16.  Please explain slide 16.  

a.       What are the implications for benefits uncertainty given the
likelihood of CA attainment? 

b.       How will you display the benefits and the costs of know
controls and how will you display the benefits and costs of extrapolated
controls?

 

________________________________________________

Robert Johansson, Ph.D.

OMB/OIRA/NREA

725 17th St. NW, Room 10202

Washington, DC 20503

(P) 202-395-7873

(F) 202-395-7285

(E) RJohansson@omb.eop.gov

 

