-----Forwarded by Melanie King/RTP/USEPA/US on 02/15/2010 09:30PM -----
To: "Higgins,Cortney" <Cortney_Higgins@omb.eop.gov> 
From: Melanie King/RTP/USEPA/US 
Date: 02/14/2010 09:47PM 
cc: RobertJ Wayland/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA, Michael 
Horowitz/DC/USEPA/US@EPA 
Subject: Re: Clarifying questions on RICE

Hi Cortney, 
Regarding the spreadsheet you sent – typically when we are evaluating MACT or GACT for a 
control technology, we do not include costs for recordkeeping and reporting in the analysis.  
We would only look at the annual cost associated with the control device, including the 
operation and maintenance cost and the annualized capital cost.  So we would not do our 
analysis the same as the way you’ve done it in your attached spreadsheet.
 
On the reporting costs, one thing to keep in mind is that 80 percent of those costs are initial 
costs for reading instructions, training personnel, and the initial testing and compliance 
notifications.  So those are one-time costs that would only be incurred in the first year.  We 
have tried to minimize the burden of the reporting costs as much as possible, however we do 
need some reporting so that we can ensure sources are complying with the rule, and we feel 
that semiannual compliance reports are appropriate and not overly burdensome.  Note that 
we do not require reporting for emergency engines and for engines <100 HP at major 
sources and <300 HP at area sources. 
 
Melanie King 
Energy Strategies Group 
Sector Policies and Programs Division 
Office of Air Quality Planning and Standards 
U.S. Environmental Protection Agency 
 
Mail Code D243-01 
RTP, NC  27711 
 
Phone:  (919) 541-2469 
Fax:       (919) 541-5450 
king.melanie@epa.gov

-----"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov> wrote: -----
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


 
 
[attachment "Engine_hours_CBA_OMB.xls" removed by Melanie King/RTP/USEPA/US]

