Ron Evans/RTP/USEPA/US 

03/07/2008 09:31 AM

	

To

Janet Cakir/RTP/USEPA/US@EPA

cc

Lydia Wegman, Tricia Crabtree/RTP/USEPA/US@EPA

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Fw: Ron, I'll have initial RIA comments to you by cob today









----- Forwarded by Ron Evans/RTP/USEPA/US on 03/07/2008 09:30 AM -----

"King, Heidi R." <Heidi_R._King@omb.eop.gov> 

03/07/2008 09:27 AM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

Subject

Ron, I'll have initial RIA comments to you by cob today









 

I hope all is well --

h

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

From: Evans.Ron@epamail.epa.gov [mailto:Evans.Ron@epamail.epa.gov] 

Sent: Friday, March 07, 2008 9:08 AM

To: McGartland.Al@epamail.epa.gov

Cc: Crabtree.Tricia@epamail.epa.gov; Morgan.Cynthia@epamail.epa.gov;

Kopits.Elizabeth@epamail.epa.gov; King, Heidi R.;

Cakir.Janet@epamail.epa.gov; Wegman.Lydia@epamail.epa.gov;

Simon.Nathalie@epamail.epa.gov; Johansson, Robert;

simon.nathalie@epa.gov; Gillis.Thomas@epamail.epa.gov;

Crabtree.Tricia@epamail.epa.gov

Subject: Re: Fw: NCEE comments on Ozone RIA - Appendix 9B

Generally, there are reductions occurring between 2020 and 2030 in SJ

and SC which Houston obviously does not get advantage of.   More

specifically, the locomotive/marine rule gets 120,000 tons of reduction

in that area.  See chapter 9, Appendix B

  "Overall, the loco-marine 2030 inventory contains about 120,000 fewer

tons of NOx than the 2020 loco-marines inventory for the geographic area

in California being analyzed."

                                                                        

             Al                                                         

             McGartland/DC/US                                           

             EPA/US                                                  To 

                                      Ron Evans/RTP/USEPA/US@EPA        

             03/06/2008 06:01                                        cc 

             PM                       Bryan Hubbell/RTP/USEPA/US@EPA,   

                                      Cynthia Morgan/DC/USEPA/US@EPA,   

                                      Elizabeth Kopits/DC/USEPA/US@EPA, 

                                      Heidi_R._King@omb.eop.gov, Janet  

                                      Cakir/RTP/USEPA/US@EPA, Lydia     

                                      Wegman/RTP/USEPA/US@EPA, Nathalie 

                                      Simon/DC/USEPA/US@EPA,            

                                      Robert_C._Johansson@omb.eop.gov,  

                                      simon.nathalie@epa.gov, Thomas    

                                      Gillis/DC/USEPA/US@EPA, Tricia    

                                      Crabtree/RTP/USEPA/US@EPA         

                                                                Subject 

                                      Re: Fw: NCEE comments on Ozone    

                                      RIA -  Appendix 9B(Document link: 

                                      Ron Evans - New)                  

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Can I ask a follow up?  Houston also has to reduce to meet the current

standard -- or anothe way of saying it is that LA, SJ an dHouston are

all starting from the same place -- attainment of the existing standard.

Why does Houston need over twice as many tons reduced as either LA or

SJ?   So, I am not sure why the increment to meet the current standard

being so high in SC and SJ would suggest much about the tons needed to

attain the new standard.

Al McGartland, PhD.

Director, National Center for Environmental Economics US EPA

1201 Pennsylvania Ave., N.W.

Washington, D.C. 20460

202.566.2244

                                                                        

             Ron                                                        

             Evans/RTP/USEPA/                                           

             US                                                      To 

                                      Elizabeth Kopits/DC/USEPA/US@EPA  

             03/06/2008 05:47                                        cc 

             PM                       Al McGartland/DC/USEPA/US@EPA,    

                                      Bryan Hubbell/RTP/USEPA/US@EPA,   

                                      Cynthia Morgan/DC/USEPA/US@EPA,   

                                      Heidi_R._King@omb.eop.gov, Janet  

                                      Cakir/RTP/USEPA/US@EPA, Lydia     

                                      Wegman/RTP/USEPA/US@EPA, Nathalie 

                                      Simon/DC/USEPA/US@EPA,            

                                      Robert_C._Johansson@omb.eop.gov,  

                                      simon.nathalie@epa.gov, Thomas    

                                      Gillis/DC/USEPA/US@EPA, Tricia    

                                      Crabtree/RTP/USEPA/US@EPA         

                                                                Subject 

                                      Fw: NCEE comments on Ozone RIA -  

                                      Appendix 9B                       

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Here is a response to your question about Houston

Your question:    Consequently, the extrapolated cost estimates also

appear low to us.  For example, how is it that both South Coast and San

Joaquin will reach attainment of 0.075 for $680M (using the $15,000

fixed cost approach) (Table 9b.4) and $1B using the mid hybrid approach

(Table 9b-6), but Houston's extrapolated cost for 0.075 using fixed

approach was $1.6B (from Table 5a.19), and  $2.4B using mid hybrid

approach (Table 5a.23)?

Houston needs an additional 110,000 tons to reach 0.075ppm in the year

2020.  LA, and SJ needs 45,000 tons for the year 2030.  As discussed on

page 2 of Appendix 9b, the locomotive marine rule will results in an

additional 120,000 tons of emission reductions.  This along with the

increment to meet the current standard being so high, results in SC & SJ

not needing as many reductions as Houston.

----- Forwarded by Ron Evans/RTP/USEPA/US on 03/06/2008 04:28 PM -----

                                                                        

             Elizabeth                                                  

             Kopits/DC/USEPA/                                           

             US                                                      To 

                                      Ron Evans/RTP/USEPA/US@EPA        

             03/06/2008 04:25                                        cc 

             PM                       Al McGartland/DC/USEPA/US@EPA,    

                                      Bryan Hubbell/RTP/USEPA/US@EPA,   

                                      Cynthia Morgan/DC/USEPA/US@EPA,   

                                      Heidi_R._King@omb.eop.gov, Janet  

                                      Cakir/RTP/USEPA/US@EPA, Lydia     

                                      Wegman/RTP/USEPA/US@EPA, Nathalie 

                                      Simon/DC/USEPA/US@EPA,            

                                      Robert_C._Johansson@omb.eop.gov,  

                                      simon.nathalie@epa.gov, Thomas    

                                      Gillis/DC/USEPA/US@EPA            

                                                                Subject 

                                      Re: NCEE comments on Ozone RIA -  

                                      Appendix 9B(Document link: Ron    

                                      Evans - New)                      

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Hi Ron,

Thanks for getting back to us, but we are still confused.  The figures

we cited below for Houston were the reductions and costs necessary to

reach attainment of tighter standards incremental to full attainment of

the current standard.  So the large difference between the South

Coast/San Joaquin and Houston (to take one example) results are still

perplexing.

But if you'd prefer, we can talk about this further once OMB has had a

chance to comment on this chapter too.

Thanks,

Elizabeth and Cynthia

                                                                        

             Ron                                                        

             Evans/RTP/USEPA/                                           

             US                                                      To 

                                      Elizabeth Kopits/DC/USEPA/US@EPA  

             03/06/2008 03:39                                        cc 

             PM                       Al McGartland/DC/USEPA/US@EPA,    

                                      Bryan Hubbell/RTP/USEPA/US@EPA,   

                                      Cynthia Morgan/DC/USEPA/US@EPA,   

                                      Heidi_R._King@omb.eop.gov, Janet  

                                      Cakir/RTP/USEPA/US@EPA, Lydia     

                                      Wegman/RTP/USEPA/US@EPA, Nathalie 

                                      Simon/DC/USEPA/US@EPA,            

                                      Robert_C._Johansson@omb.eop.gov,  

                                      simon.nathalie@epa.gov, Thomas    

                                      Gillis/DC/USEPA/US@EPA            

                                                                Subject 

                                      Re: NCEE comments on Ozone RIA -  

                                      Appendix 9B(Document link:        

                                      Elizabeth Kopits)                 

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

See comments in blue.   Let me know if you have additional questions.

                                                                        

             Elizabeth                                                  

             Kopits/DC/USEPA/                                           

             US                                                      To 

                                      Ron Evans/RTP/USEPA/US@EPA        

             03/06/2008 12:13                                        cc 

             PM                       Al McGartland/DC/USEPA/US@EPA,    

                                      Bryan Hubbell/RTP/USEPA/US@EPA,   

                                      Cynthia Morgan/DC/USEPA/US@EPA,   

                                      Heidi_R._King@omb.eop.gov, Janet  

                                      Cakir/RTP/USEPA/US@EPA, Lydia     

                                      Wegman/RTP/USEPA/US@EPA, Nathalie 

                                      Simon/DC/USEPA/US@EPA,            

                                      Robert_C._Johansson@omb.eop.gov,  

                                      simon.nathalie@epa.gov, Thomas    

                                      Gillis/DC/USEPA/US@EPA            

                                                                Subject 

                                      NCEE comments on Ozone RIA -      

                                      Appendix 9B(Document link: Ron    

                                      Evans - New)                      

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

                                                                        

Hi Ron,

In order to get our reactions to you as quickly as possible, we are

keeping our comments on Appendix 9B to major ones only.  Our main

concern is that the 2030 emissions reductions (and hence costs) needed

to bring South Coast and San Joaquin into attainment appear to us to be

very low.

Most of the reductions need to occur as part of meeting the current

ozone standard.  See Table 9b.2  Therefore the costs of going a little

further are not dramatic.

On p. 2, you note that the NOx reductions needed to get the Los Angeles

and San Joaquin Valley areas into attainment by 2030 (Table 9b.2) are

based on the NOx targets for Los Angeles South Coast Air Basin in Table

9b.1.   Does that mean that you are assuming if emissions are reduced by

90+% in South Coast then San Joaquin will also come into full

attainment, or are you reducing both South Coast and San Joaquin

emissions by 90+%??   What are  the  emission reductions needed to meet

the various standards in San Joaquin, assuming the estimates in Table

9b.2 are based on South Coast only?

The 90% is to get both areas into attainment.  The geographic area for

CA includes most of the state.  Therefore we reduce both to get the most

extreme area into attainment.  9b.2 includes a large area.  See Maps

from Chapter 4.

In Table 9b.3, something doesn't seem right.  When compared to

extrapolated tons needed in other areas, the estimates in Table 9b.3

appear to us to be so low as to not pass the laugh test, but perhaps we

are missing something?   For example, how is it that only 78,000 tons

are needed to bring BOTH South Coast and San Joaquin into attainment

with 0.065, yet 180,000 extrapolated tons were needed (post application

of supplemental controls) to bring Houston into attainment of 0.065 (see

Table 5.2)?   Even with the additional emissions reductions expected

from mobile programs between 2020 and 2030, the magnitude of these

differences seem strange to us.

This is due to the large amount of emissions needed to meet the current

standard.

Consequently, the extrapolated cost estimates also appear low to us.

For example, how is it that both South Coast and San Joaquin will reach

attainment of 0.075 for $680M (using the $15,000 fixed cost approach)

(Table 9b.4) and $1B using the mid hybrid approach (Table 9b-6), but

Houston's extrapolated cost for 0.075 using fixed approach was $1.6B

(from Table 5a.19), and  $2.4B using mid hybrid approach (Table 5a.23)?

Thanks,

Elizabeth and Cynthia

