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

03/06/2008 03:43 PM

	

To

Ron Evans/RTP/USEPA/US@EPA, Elizabeth Kopits/DC/USEPA/US@EPA

cc

Al McGartland/DC/USEPA/US@EPA, Nathalie Simon/DC/USEPA/US@EPA, Bryan
Hubbell/RTP/USEPA/US@EPA, Janet Cakir/RTP/USEPA/US@EPA, Lydia
Wegman/RTP/USEPA/US@EPA, Nathalie Simon/DC/USEPA/US@EPA, "Johansson,
Robert" <Robert_C._Johansson@omb.eop.gov>, Nathalie
Simon/DC/USEPA/US@EPA, Thomas Gillis/DC/USEPA/US@EPA

Subject

RE: NCEE comments on Ozone RIA -  Appendix 9B









Ron, I have no blue -

Sorry! 

h

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

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

Sent: Thursday, March 06, 2008 3:40 PM

To: Kopits.Elizabeth@epamail.epa.gov

Cc: McGartland.Al@epamail.epa.gov; Simon.Nathalie@epamail.epa.gov;

Hubbell.Bryan@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

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

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

