Ron Evans/RTP/USEPA/US 

10/11/2007 04:32 PM

	

To

Robert_C._Johansson@omb.eop.gov

cc

Subject

Fw: RESEND:  SAB letter on extrapolated costs









Rob, here is the response to your question of the other day, I thought
that I had previously forwarded it to you.  Sorry.

Ron Evans

Leader, Air Benefit & Cost Group

HEID/OAQPS/OAR/EPA

Mail Drop C-439-02

919-541-5488

919-541-0839 fax

----- Forwarded by Ron Evans/RTP/USEPA/US on 10/11/2007 04:30 PM -----

Jim DeMocker/DC/USEPA/US

10/01/2007 12:56 PM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

Subject

Re: RESEND:  SAB letter on extrapolated costs









Hi Ron. I'm out in Arizona this week with only spotty email access. 

The ozone NAAQS in question is the 8-hr, and the SAB recommended that we
"keep it simple" with a fixed dollar per ton assigned to the
unidentified measures. They also endorsed our plan to itemize the total
costs so readers can see how much of the total cost comes from
unidentified measures. Then it is also straightforward to conduct and
report the cost aspects of our overall uncertainty analysis. 

That is our plan for 812 anyway. 

I'd be happy to help any way I can. Thanks for letting me know what's
going on. 

Cheers... Jim

--------------------------

From Jim DeMocker by Wireless Handheld

    ----- Original Message -----

    From:  Ron Evans

    Sent: 10/01/2007 10:59 AM

    To: Jim DeMocker

    Cc:  Janet Cakir; Lisa Conner; walton.tom@epa.gov

    Subject: Fw: RESEND:  SAB letter on extrapolated costs

Jim, we are working on figuring out how to present extrapolated costs
and benefits for the final ozone NAAQS RIA due in March 2008.  We plan
to have some methodological options developed over the next month or so.
 As I see the options, they are:

1)  Directly follow the preference of SAB and not place a value on the
emissions to be reduced 

2)  Place a value on the tons using a simple $/ton cost estimate

3)  Place a value on the tons using a marginal cost approach

We used a mixture of number 2 and number 3 in the proposal.

Given the dictates of EO 12866 and OMB Circular A-4, I doubt that I will
be able to use only #1.  Number 3 seems to be opposed by the  SAB
advice, leaving me to believe that we will end up with a version of
number 2 at the end of the process.  As we move forward we will involve
you as much as you like.

With this as a background, can you supply me with the answers to Rob's
questions below?

----- Forwarded by Ron Evans/RTP/USEPA/US on 10/01/2007 10:52 AM -----

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

10/01/2007 10:48 AM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

Subject

RE: RESEND:  SAB letter on extrapolated costs









Can you provide the context for this letter?  It appears as though the

questions were being posed for previous rulemakings; i.e., what was the

ozone naaqs std being modeled in the background review document?  

"The Project Team has been unable to identify measures that yield

sufficient emission

reductions to comply with the National Ambient Air Quality Standards

(NAAQS) and relies on

unidentified pollution control measures to make up the difference.

Emission reductions attributed to

unidentified measures appear to account for a large share of emission

reductions required for a few

large metropolitan areas but a relatively small share of emission

reductions in other locations and

nationwide."

Which naaqs and levels does this refer to?

Rob

 

