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

12/17/2007 05:09 PM

	

To

Janet Cakir/RTP/USEPA/US@EPA, "Johansson, Robert"
<Robert_C._Johansson@omb.eop.gov>

cc

"Fraas, Arthur G." <Arthur_G._Fraas@omb.eop.gov>

Subject

RE: Issue with Baseline in EPA's Ozone Final RIA









Thank you Janet --

heidi 

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

From: Cakir.Janet@epamail.epa.gov [mailto:Cakir.Janet@epamail.epa.gov] 

Sent: Monday, December 17, 2007 3:03 PM

To: Johansson, Robert; King, Heidi R.

Cc: Fraas, Arthur G.

Subject: Issue with Baseline in EPA's Ozone Final RIA

Heidi,

     We've raised to Lydia the idea that the Ozone NAAQS RIA should have

a baseline that reflects only on the books reality and that there is a

need to develop a benefit/cost analysis of the current Ozone standard as

a part of our analysis.  We've also informed her of your belief that

under the assumption of an "on the books reality baseline" our mobile

controls do not fit.  Her thoughts were in line with ours that EPA did a

benefit/cost analysis of the current standard in 2005 for the Ozone

implementation rule.  A new analysis would not be a part of the Ozone

RIA analysis because it's goal is incremental to the 2005 implementation

analysis.  The reason we developed a new baseline was to do due

diligence to establishing an updated starting point for our incremental

analysis that reflects an updated control database and inventory.  She

also noted that the mobile controls could reasonably be implemented to

meet the current standard and their presence in the baseline is

appropriate.  We understand that these are assumptions and are willing

to discuss what the appropriate caveats should be.

    Please let me know if you think we need to elevate this issue

further.

Thanks,

Janet

_______________________________________

Janet F. Cakir, Ph.D.

Environmental Protection Specialist

Air Benefits Cost Group

109 TW Alexander Dr., (C439-02)

Research Triangle Park, NC 27711

Tel:  (919) 541-4853

Fax: (919) 541-0839

email:  cakir.janet@epa.gov

