December 14, 2011

Note:

Subject: Cost estimates for MATS rule monitoring requirements.

To: SPPD management and MATS rule writers

From: 	Steffan Johnson , SPPD, MPG
	
This is a note regarding the estimated costs of monitoring as required by the MATS rule.  Cost estimates are generated from the CEMS cost model, 2007 version, publicly available at http://www.epa.gov/ttn/emc/cem.html.


The annual monitoring, reporting, and record-keeping burden for this collection (averaged over the first 3 years after the effective date of the standards) is estimated to be $157.5 million. This includes 698,907 labor hours per year at a total labor cost of $49.0 million per year, and total non-labor capital costs of $108.2 million per year. This estimate includes initial and annual performance tests, semiannual excess emission reports, developing a monitoring plan, notifications, and record-keeping. Initial capital expenses to purchase monitoring equipment for affected units are estimated at a cost of $231.1 million. This includes 504,629 labor hours at a total labor cost of $35.0 million for planning, selection, purchase, installation, configuration, and certification of the new systems and total non-labor capital costs of 196.1 million. All burden estimates are in 2007 dollars and represent the most cost effective monitoring approach for affected facilities.
