Ron Evans/RTP/USEPA/US 

03/06/2008 05:47 PM

	

To

Elizabeth Kopits/DC/USEPA/US@EPA

cc

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

03/06/2008 04:25 PM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

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









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

03/06/2008 03:39 PM

	

To

Elizabeth Kopits/DC/USEPA/US@EPA

cc

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









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

Elizabeth Kopits/DC/USEPA/US

03/06/2008 12:13 PM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

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









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

