-----Forwarded by Melanie King/RTP/USEPA/US on 02/15/2010 09:32PM -----
To: Melanie King/RTP/USEPA/US@EPA 
From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> 
Date: 02/12/2010 06:31PM 
cc: RobertJ Wayland/RTP/USEPA/US@EPA 
Subject: Clarifying questions on RICE
Hi Melanie,

Attached you'll find a spreadsheet of the costs and benefits for area source engines between 
300 and 500 HP.  The attached analysis shows that requiring controls for these engines, if 
they run less than ~100 hrs per year, is not cost-beneficial (costs of controls exceed the 
PM2.5 benefits).  Do you know how many engines in this group run less than 100 hours per 
year and are not emergency engines?  

Additionally, for these sized engines running 100 hours, the estimate of reporting costs is 1/3 
of the total annual costs.  Given that these engines will have control devices installed, and 
emissions reductions will be achieved, is there any flexibility to ease the reporting 
requirements?  Furthermore, is there any flexibility in lessening in the reporting requirements 
for the area source engines subject to emissions limits (and thus technology controls)?


Thanks,
Cortney



