Summary of Methodology and Data Used to Estimate Burden Relief and 

Evaluate Resource Requirements at Alternative Greenhouse Gas (GHG)
Permitting Thresholds

March 2010

1.  Introduction

This paper summarizes an assessment of the estimated resource
requirements for permitting authorities to include GHG at several
possible major source permitting thresholds and the burden reduction and
costs savings for permitting authorities and sources as a result of
requiring the inclusion of GHG in the title V and Prevention of
Significant Deterioration (PSD) permitting programs at thresholds
greater than the current statutory requirements.  A preliminary analysis
to support the tailoring rule proposal resulted in an earlier version of
this Technical Support Document, found at EPA-HA-OAR-2009-0517.  Based
on comments received on the proposal and updates to key assumptions,
this revised summary presents the updated methodology and burden
reduction estimates resulting from several permitting threshold
alternatives considered for the final tailoring rule.  The analysis was
performed considering GHG emissions on a carbon dioxide equivalent
(CO2e) basis, which represents the sum of the six primary GHG with their
respective global warming potentials (GWP) applied.  Time and costs
associated with permit activities are derived from existing Information
Collection Requests (ICRs) for the title V and PSD programs.   Estimates
for the number of affected sources used in this analysis were obtained
from the GHG thresholds evaluation, which can be found at
EPA-HQ-OAR-2009-0517.

2.  Methodology for Estimating Permitting Burden Due to GHG Emission
Sources

This section describes the basic methodology we used to estimate the
different types and quantities of permitting actions that would be
affected by addressing GHGs under the PSD and title V permitting
programs.   The final burden results summarized in Section 3 are based
on the methodologies described in this section.   In developing our
methodology, we established different applicability options under which
GHG emission sources would be regulated.  These GHG applicability
thresholds range from the statutory threshold levels (100 and 250 tpy)
to  different combinations of major source and significance levels based
on GHG emissions, and finally, applicability based on GHG-related
additions to otherwise occurring permitting actions for non-GHGs (also
referred to here and in the preamble for this action as the ‘anyway’
source approach).   We considered several different major source/major
modification threshold combinations.  We chose the combinations to
reflect representative, incremental steps along the possible range. 
Because it is time- and resource- intensive to develop estimates for a
given step, we chose intervals that best reflect representative points
within the range given those time and resource constraints.   For
example, as it became evident from the analysis that the 100,000 tpy
CO2e major source threshold would be a viable option under one of the
phase-in steps in the GHG tailoring rule, we needed to then evaluate
different GHG significance level options in combination with the 100,000
tpy CO2 major source level to determine the ultimate impact on PSD and
title V permitting activity.  

PSD Permits 

Table 2-1 summarizes EPA’s estimate of modifications and new
construction PSD permitting actions potentially affected by the addition
of GHG as a regulated air pollutant at different GHG threshold options
for PSD applicability. These actions are broken down by type of
modification and new construction activity.  Three types of
modifications are included in this analysis: major modifications at
major sources that are triggered by increased conventional pollutant
emissions, but also exceed the significance level for GHG; modifications
previously considered minor that become major modifications due to GHG
emissions occurring at existing major sources; and modifications at
newly major GHG sources due solely to emissions exceeding the
significance level threshold for GHG. For new construction, two types of
sources are listed – those that are major sources due solely to the
emissions of GHG, and those which are classified as major due to
conventional pollutant emissions, but also exceed the GHG significance
level (or ‘anyway’ sources). 

The first line items in Table 2-1 for modifications and new construction
present estimates of GHG-related permitting actions that would occur at
‘anyway’ sources ; these are labeled in the table as  “Current
Modifications – Add Additional GHG” and “Newly Constructed Major
Sources – Add Additional GHG.”  The August 2008 ICR for the New
Source Review (NSR) program estimates that 282 PSD and 519
non-attainment NSR permits are issued annually. EPA’s initial burden
analysis concentrated solely on the 282 annual PSD actions. If a source
is major for a pollutant for which an area is designated non-attainment,
all significant emissions or significant emissions increases of
pollutants for which the area is in attainment are still subject to 



Table 2-1.  Estimated Number of PSD Permit Actions Exceeding GHG
Threshold Options

Threshold	100/250 tpy major; 100/250 tpy sig. level	25,000 tpy major;
25,000 tpy sig. level	50,000 tpy major; 50,000 tpy sig. level	100,000
tpy major;  50,000 tpy sig. level	100,000 tpy major; 75,000 tpy sig.
level	100,000 tpy major; 100,000 tpy sig. level	Non-GHG

Current Modifications – Add Additional GHG	448	448	448	448	448	448	448

Minor Modifications Becoming Newly Major	17,894	8,947	1,789	1,789	895	0
0

Modifications at Newly Major Sources	43,942	250	117	20	20	20	0

Modifications Total	62,284	9,645	2,354	2,257	1,363	468	448

Newly Constructed Major Sources - Add Additional GHG	240	240	240	240	240
240	240

Newly Constructed Major Sources	19,649	10	3	2	2	2	0

Newly Constructed Sources Total	19,889	250	243	242	242	242	240

Total	82,173	9,895	2,597	2,499	1,605	710	688



PSD review. Thus, some of the facilities applying for nonattainment
permits may also undergo PSD actions at the same time.  Although there
is no way of accurately predicting which of the

519 nonattainment actions might also coincide with a PSD action related
to GHG emissions, we believe it is likely that most will since they
typically involve large emission sources; thus, it is assumed all
nonattainment actions from the ICR annual estimate will also need a PSD
permit.  Therefore, in this final analysis, to more accurately depict
the number of PSD permitting actions occurring annually, it is assumed
that all 801 permitting actions above involve a PSD action.  We estimate
that 70% of these permit actions are modifications, or 560 of the 801,
based on feedback received from the National Association of Clean Air
Agencies (which estimated that some 65% of these permitting actions
involve modifications); other commenters on the proposed tailoring rule
(who generally said that most permitting actions involve modifications);
 and EPA program staff experience. Further, 80% of these modifications
are expected to involve combustion activities with GHG emission levels
exceeding the statutory thresholds and any of the significance levels we
considered, up to an including the 100,000 tpy CO2e level, thus
requiring the inclusion of GHG related requirements in a PSD permit.
This equates to 448 modifications annually.  We believe that any of the
modifications that would be subject to PSD due to the conventional
emissions would also be large enough to increase GHGs by at least
100,000 tpy of CO2e.

The 240 remaining annual permit actions—labeled in Table 2-1 as
“Newly Constructed Major Source- Add Additional GHG”—are assumed
to be construction of new major sources as determined by emissions of
one or more NAAQS pollutants. Due to the size and emissions of sources
currently subject to the PSD permitting program, it is believed all of
these newly constructed major sources will exceed each of the GHG
thresholds we considered, including the 100,000 tpy CO2e, and will also
need to include GHG-related requirements in the PSD permit. In total,
all 688 major permitting actions mentioned above will need to factor in
GHG requirements as indicated in Table 2-1. For permitting authorities,
50 additional burden hours are estimated to include the GHG requirements
in a permit.  For affected sources, approximately 222 additional burden
hours are needed, based on the two line items in the current NSR ICR we
expect to be impacted by the addition of GHG – approximately 120 hours
to “obtain guidance on data needs” and 102 hours for the
“preparation of BACT analysis.”  That is, the current NSR ICR
indicates that on average, affected sources spend 222 hours for these
two activities for their conventional pollutants.  We expect that they
will need to spend an equal amount of time for these two activities for
their GHG emissions.  The sources will need to “obtain guidance on
data needs” because they will be analyzing their emissions from GHG
units and will need to prepare a separate BACT analysis for their GHG
emissions, or else expand the BACT analysis they would otherwise do for
their conventional pollutants to account for their GHG emissions.  We
believe that the remaining activities that the affected sources must
undertake would not be appreciably lengthened by their need to include
GHG emissions.  

According to the NSR ICR, approximately 74,591 minor permitting actions
occur annually, including the following:  30% involve new minor sources,
new synthetic minor sources, and synthetic-based modifications; 30%
involve true minor modifications; 20% involve netting-based minor
modifications; and 20% involve minor/administrative permit revisions. 
We believe that a number of projects that could have taken limits or
netted out of PSD review and thereby obtain a minor permit will now be
required to apply for a major PSD permit, depending on the significance
threshold set for GHG. These projects are identified in Table 2-1 under
“Minor Modifications Becoming Newly Major.”  Combining the number of
synthetic-based modifications (7,459) and netting-based modifications
(14,909) identified in the ICR, approximately 22,368 of these actions
could potentially become major modifications subject to PSD review if
their associated GHG emissions increases exceed the selected GHG
significance level option.  We did not count ‘new minor sources’ and
‘new synthetic minors’ because we have already accounted for them as
potential major GHG sources if their PTE emissions exceed the selected
GHG major source threshold option. 

Based on staff review of samples of minor source permits, it is
estimated that 80% of the current minor modification actions likely
involve combustion sources – totaling 17,894 actions of the total
22,368 minor modification actions.  Some of these actions may trigger
the requirements of the PSD program depending on their GHG emission
increases and the selected GHG significance threshold.    In the absence
of any experience involving GHG sources and any sufficient quantitative
data from commenters, we determined the number of these actions on the
following basis:  We assumed the following percentage of the total
17,984 actions would move to a major modification status due to GHG
increases for each of the GHG significance level options considered in
this analysis: 50% at 25,000 tpy CO2e; 10% at 50,000 tpy CO2e; 5% at
75,000 tpy CO2e; and zero at 100,000 tpy CO2e.  To determine these
percentages, we considered the relative emissions of CO2 emissions to
NOx emissions at the current major modification significance level
threshold for NOx (40 tpy).  For example, for an average natural gas
combustion boiler (a common industrial combustion unit that is part of
many modification projects), a 40 tpy NOx emissions would coincide with
a 56,000 tpy CO2e level.  Since many combustion related projects keep
just under the 40 tpy NOx level to avoid major modification status, we
assume that the CO2e emissions for a similar project will be around the
50,000 tpy CO2e level.  Based on the relationship in combustion-related
emission levels between NOx and CO2e just described, we believe it is
reasonable to expect that all these currently minor modification
projects involving combustion units will exceed the 100 tpy GHG
significance level under the baseline scenario.  This is because we do
not believe that the sources at which these projects occur will be able
to structure their operations so as to limit their GHG emissions to less
than 100 tpy GHGs.  However, at higher GHG significance level options,
we assume that a decreasing proportion of projects will be significantly
large enough, or they may emit GHGs close enough to the GHG significance
level to be able to limit their operations or net-out for GHGs like they
can for NOx.  In the absence of experience and quantitative information
from commenters we made the following assumptions regarding how many of
these formerly minor modification projects would be subject to major PSD
review at the different GHG significance level options:  at the 25,000
tpy CO2e significance level, we estimate that half of the modifications
will be able to limit their operations to avoid PSD ;  at the 50,000 tpy
CO2e significance level, we estimate that 10% of these previously minor
now major modifications  will be covered by PSD;  at the 75,000 tpy CO2e
significance level  we estimate that only 5% of these currently minor
modification projects move into a major modification status for GHGs;
and lastly, at the 100,000 tpy CO2e significance level, we assume that
none of these projects will be large enough by themselves to trigger
major PSD review.

In addition to sources becoming subject to PSD requirements because of
GHG emissions related to modifications, new construction will occur that
will require a PSD permit solely due to the source’s potential GHG
emission levels, identified in Table 2-1 as “Newly Constructed Major
Sources.” Based on the source data obtained from the GHG thresholds
evaluation, these newly constructed major sources involve both
industrial and commercial/residential facilities. The current NSR ICR
notes that permitting authorities spend approximately 300 hours
processing and issuing a new construction industrial source PSD permit.
Sources spend almost 870 hours on average preparing for the same permit.
In the previous burden analysis, commercial/residential permits were
assumed to require only 20% of the time necessary for an industrial
permit. While it is still believed that these sources are less complex
than their industrial counterparts in terms of numbers and types of
emissions sources and control requirements, EPA now estimates the
commercial/residential permits to take 70% of the time required to
complete an industrial permit, resulting in approximately 210 hours and
866 hours for permitting authorities and sources respectively. This is
based on comments received, which stated that we had significantly
underestimated the amount of time needed.  These commenters emphasized
that commercial and residential sources will generally be located in
populated areas, and therefore may elicit significant amounts of public
input, which in turn will increase the amount of time needed compared to
our initial estimates.  However, the commenters generally did not
provide quantitative information.   As a result, we conducted further
evaluation of the additional support and outreach activities for
permitting authorities to assist with applicability determinations and
emissions calculations, as virtually all commercial/residential sources
will have no experience with the PSD permitting process. There are also
many permit preparation activities that represent a fixed cost, such as
preparation of notices and public hearings. Of the sources falling in
this category, the number requiring PSD permitting will vary depending
on where the thresholds for triggering PSD review (both major source and
modifications thresholds) are established.

Table 2-2. Average Permitting Authority Burden per GHG PSD Permit Type

Activity	Burden Hours per Permit - Industrial	Burden Hours per Permit -
Commercial/ Residentiala

 	Attend Preapplication Meetings	36	27

 	Answer Respondent Questions	20	15

 	Log In and Review Data Submissions	16	12

 	Request Additional Information	8	6

 	Analyze for and Provide Confidentiality Protection	24	2

 	Prepare Completed Applications for Processing	38	29

 	 File and Transmit Copies	8	6

 	Prepare Preliminary Determination	36	27

 	Prepare Notices for and Attend Public Hearings	40	30

 	Application Approval	48	36

 	Notification of Applicant of PA Determination	8	6

 	Submittal of Information on BACT/LAER to RBLC	19	14

Total Burden Hours per Permit	301	210

aIn general, to process commercial/residential permits, permitting
authorities will have to spend 75% of the amount of time they spend on
industrial permits, except they will have to spend even less time on
confidentiality due to the fact that most residential sources are not
likely to be concerned about confidentiality.  Commercial/residential
permits will be much simpler than industrial permits, but a large part
of the permitting costs are fixed costs.  For example, organizing and
holding a hearing for a much simpler permit, compared to a more complex
permit, nevertheless take almost as long because of the document
preparation, travel, and organizational details.



Table 2-3. Average Source Burden per GHG PSD Permit Type

Activity	Burden Hours per Permit - Industrial	Burden Hours per Permit -
Commercial/ Residentiala

Preparation and Planning

 	Determination of Compliance Requirements	170	170

 	Obtain Guidance on Data Needs	120	120

 	Preparation of BACT Analysis	102	102

Data Collection and Analysis

 	Air Quality Modeling	200	40

 	Determination of Impact on Air Quality Related Values	100	30

 	Post-construction Air Quality Monitoring	50	20

Permit Application

 	Preparation and Submittal of Permit Application	60	60

 	Public Hearings	24	24

 	Revisions to Permit	40	40

Total Burden	866	606

aPSD permit applications for commercial/residential sources will be
significantly simpler than industrial source PSD permit applications.
However, due to their inexperience, we estimate commercial/residential
sources will take as long to complete their steps for their permit
application as it will for industrial sources to complete their steps.

Commercial/residential sources will, on average, have much less work for
data collection and analysis.  We estimate that they will have
approximately 25% as much work in these areas (90 hours) compared to
industrial sources (350 hours).  However, commercialresidential sources
will have to spend some time on data collection analysis is because some
of them will have conventional pollutants that they emit in amounts that
exceed the “significance” levels, but not the “major” levels,
and they will have to analyze those conventional pollutants.  Our 25%
estimate is based, in the absence of actual experience or quantitative
data from commenters, on our judgment that significantly less than 50%
of commercial/residential sources emit conventional pollutants in
amounts that equal or exceed the significance levels, but those that do
may have to spend more time than industrial sources on data collection
because they are unfamiliar with the tasks and therefore will face a
learning curve.



Finally, an existing, but newly classified major source for GHG, may
undergo a modification for which it will then be subject to PSD
permitting requirements. This category of PSD permitting activity is
listed on Table 2-1 as “Modifications at Newly Major Sources.” With
this new major source status, these facilities must apply for and be
issued a PSD permit, if they undergo a major modification.  See Appendix
A for a list of newly major sources at different major source GHG
thresholds.   We estimate that 4% of these newly major sources will
undergo modifications.  This rate was obtained by dividing the current
560 annual PSD modification-related permit actions (i.e., 70% of 801
actions identified in the NSR ICR) by the existing major source
population of 14,700 major source title V permits. This represents our
best available estimate of the rate of PSD modification activity at
major sources, and we make the assumption that this rate will also apply
for newly major GHG sources.  We recognize that there is some level of
uncertainty in applying this rate to GHG-only sources, particularly for
sources in unconventional sectors such as commercial and residential
categories, however we believe at higher GHG threshold levels, where
large industrial sources predominate, that this modification rate
provides a reasonable estimate of modification activity. As no data are
yet available for commercial/residential sources and because we cannot
conclude that they will differ from industrial sources, we select the
same 4% rate for modification activity.

Title V Permits

Title V programs also complete several types of permitting actions
annually, including processing and issuing new permits, permit
revisions, and permit renewals.  Newly constructed major sources or
sources designated newly major due to a modification are required to
apply for and be issued a title V permit in order to operate. In
addition to sources new to title V, permitting authorities must add GHG
terms to permits for sources exceeding the threshold set for GHG
emissions. Permitting authorities may face burdens to update existing
title V permits for GHG under two possible scenarios: (1) EPA
promulgates or approves any applicable requirements for GHGs that would
apply to such a source, which would generally require a permit reopening
or renewal application, or (2) the source makes a change that would
result in an applicable requirement for GHG to newly apply to the
source, such as PSD review, which would generally require an application
for a permit revision.  Permitting authorities will also need to process
permit renewal applications, generally on a five-year cycle, and such
renewals would need to assure that the permit properly addresses GHG.  

The April 2007 Title V ICR estimates that 50 permits are completed every
year for new sources. For this analysis, it is assumed that all 50 of
these typically large industrial-type sources will be capable of
potentially emitting GHG and will need to add GHG-related requirements
to the permit. The estimated burden per title V permit in the ICR
represents an average of multiple pollutants; we estimate the addition
of GHGs will add an additional 10% of the time currently estimated for a
new title V permit.  We believe that 10% is the appropriate amount
because for the most part, these sources will simply need to add
information concerning inventory, reporting, or monitoring of their GHG
emissions, as appropriate, which they can readily do. 

The ICR also identifies 3,267 permit renewals conducted on an annual
basis. As not all sources potentially emit GHG above a determined
threshold, this analysis examines the estimated 80% involving combustion
activities that most likely have the potential to emit GHG above the
series of potential thresholds evaluated. Therefore, approximately 2,614
sources will need to address GHG in the new version of the permit.

Revisions to title V permits will also be necessary based on the number
of modifications calculated for this analysis. Revisions occurring
specifically due to GHG may involve significant revisions, minor
revisions, or administrative actions to operating permits. EPA estimates
that this activity will require 40 hours per permit on average for
permitting authorities to complete. The number of operating permit
revisions will vary based on the number of previously minor
modifications now qualifying as major modifications, and modifications
at newly major sources, both listed in Table 2-1. At any level, it is
assumed that the 448 modifications involving combustion that occur
annually will need to include any GHG requirements in the revision of
their respective title V permits.  EPA estimates that permitting
authorities will spend, in addition to the current burden to issue a
title V permit revision, an additional 10% of the 40 hours needed to
complete this process, or four hours per action.

Finally, new industrial and commercial/residential sources will be
entering title V permitting programs annually due solely to their GHG
emissions.  These commercial/residential sources that exceed the major
source threshold solely due to their GHG emissions will not likely have
substantial applicable requirements in the near term and/or will not
require as much time to process as those for industrial sources, which
have other applicable requirements in addition to those related to their
GHG emissions.  However, upon further evaluation and in response to
comments from permitting authorities, EPA believes its initial estimate
of one-tenth of the burden hours required was considered too low.
Permitting authorities would confront substantial challenges as they
have little experience with such sources and their GHG emissions.
Commercial/residential sources themselves will have no experience with
the title V permitting process, which will increase the time needed to
assess GHG emissions, complete the application, and respond to
permitting authority comments. We also expect that in many cases the
draft permits will undergo high levels of public participation through
public comment periods, public hearings, and petitions for
reconsideration. Therefore, EPA assumes preparing a permit for affected
commercial/residential sources will take 50% of the time a permitting
authority currently spends on issuing a title V permit for an industrial
source.

Table 2-4. Average Permitting Authority Burden per GHG Title V Permit

Activity	Burden Hours per Permit - Industrial	Burden Hours per Permit -
Commercial/ Residentiala

Permit Application Review	100	33

Draft Permits Preparation	150	50

Comment Period Notification	10	10

Hold Public Hearings	100	90

Interaction with EPA	20	5

Analyze Public Comments	40	20

Permits Issuance	8	6

Total Burden	428	214

aCommercial/residential permits will be simpler, so that it would take
the permitting authority about 1/3 of the time to review the permit
application and draft the permit than it would for an industrial source
permit.  The comment period notification and time for public hearings,
however, would be about the same because of the fixed time burdens
necessary to provide notice and hold hearings.  The amount of time
interacting with EPA would be much less because of the relative
simplicity of the permits.  Analyzing public comments would take half as
long as for an industrial permit because although the permits are much
simpler, there could be a fair amount of public interest because of the
location of the source.  Permit issuance would take a  less time than
for an industrial source because most of the costs are fixed, although
the permit is simpler.



Table 2-5. Average Source Burden per GHG Title V Permit

Activity	Burden Hours per Permit - Industrial	Burden Hours per Permit -
Commercial/ Residentiala

Prepare Application	300	150

Draft Permits Interaction	40	20

Public Hearing Participation	10	10

Total Burden	350	180

aCommercial/residential permit applications will be significantly
simpler than industrial source title V permit applications. However, due
to their inexperience, we estimate commercial/residential sources will
take half as long to complete their steps for their permit application
as it will for industrial sources to complete their steps. Less
interaction, again 50% less time, will be needed with permitting
authorities during the permit drafting process. However, public hearing
participation will likely require the same amount of time because of the
fixed time burdens necessary to complete hearings.



Uncertainties in Estimates of Affected Sources

In order to estimate the number of facilities that exceed a given GHG
threshold (such as a 100 or 250 tpy CO2e emission threshold for baseline
analysis), it is necessary to have emissions inventory data at the
facility or building level, including, and particularly for lower
threshold scenarios, numerous small sources in the residential and
commercial sectors (e.g., apartment buildings and office buildings).  
Historically, however, EPA has not collected sector-wide, facility-level
information for GHG emissions under the CAA (with the exception of
information from electric generating units required to report CO2
emissions under the Acid Rain Program reporting requirements).  To date,
national EPA inventories of GHG sources have primarily focused on
‘top-down’ estimates of GHG emissions from sectors and sources, and
not facility-level estimates.  As a result, many of the uncertainties
described here result from the absence of a comprehensive data set of
facility-level GHG emissions across all sectors.   A full description of
the methodology used for determining facility level emissions is
provided in our GHG thresholds evaluation study, which can be found at
EPA-HQ-OAR-2009-0517. 

For residential, commercial, and smaller manufacturing operations, our
current analysis relies on sample facility datasets and ‘top-down’
sector data (e.g., national fuel consumption statistics and/or building
characteristics).   There are inherent uncertainties in developing
source counts from the allocation of these nationally aggregated
statistics.  The allocation factors we used, based on U.S. Energy
Information Administration statistical sampling procedures and energy
consumption statistics, are likely the best available to estimate the
population of residential, commercial, and small manufacturing sources
exceeding different GHG thresholds.  However, uncertainties may result
in either overestimating or underestimating GHG emissions for a given
individual facility.  It is worth noting that our estimates for the
largest GHG emitting sources, such as electric utilities and refineries,
are derived from bottom-up calculations of individual facility/building
emissions so that there is  increased certainty in evaluating and
comparing the facility counts at the higher GHG threshold scenarios
where residential and commercial sources are not highly affected. 
Although there are different levels of uncertainty in our facility level
estimates across sectors, we do believe that the data are sufficiently
robust to use in the aggregate to assess national permitting level
impacts.  

EPA’s estimate of affected sources is based on their potential to emit
(PTE) emissions, as opposed to actual emission levels.  PTE is defined
as the maximum capacity of a stationary source to emit a pollutant under
its physical and operational design, including certain legal
limitations, for example, on emissions or hours of operation.  NSR and
Title V programs both use PTE for defining and identifying major
sources.   Although we have attempted to identify reasonable adjustments
to account for PTE in our methodology, there are significant
uncertainties in our PTE-based estimates, particularly for the
commercial, residential and small manufacturing sectors that have not
traditionally been subject to any form of air permitting.   In practice,
for example, for the residential sector and for many of the facilities
in the commercial sector, where CO2 emissions are primarily due to space
heating/appliance usage, the combustion units are not likely to be used
constantly at their maximum rated capacity because heating is not needed
year-round and heating systems have thermostats.  However, for our
analysis we do assume full PTE-based estimates for the residential and
commercial sectors, using PTE adjustment factors of 10 and 6.6,
respectively to adjust actual emissions to PTE level.  Absent industry
specific data, for small manufacturing source categories we assume a PTE
adjustment factor of 2; individual manufacturing facilities may operate
their combustion equipment at levels above and below this capacity
utilization rate, but we believe this PTE adjustment reflects a
reasonable average rate across the variety of small manufacturing
facilities included in the threshold analysis.  Ultimately, the number
of sources brought into either the NSR or Title V programs due solely to
their PTE would depend on how EPA interprets PTE for various types of
emitting equipment (e.g., space-heating furnaces in residential and
commercial buildings), and the extent to which streamlined mechanisms
are made available for sources to obtain legal limits on their PTE so
that the programs are not applicable.   No such decisions or
interpretations have been made at this point and, as mentioned in the
preamble, they will require significant time to develop.  As a result,
our threshold analysis uniformly assumes that no PTE limits are in place
for any of the affected sectors, which may likely be the case in the
immediate stages of GHG permitting for affected sources.

There is significant uncertainty in both our modification rate for newly
major GHG sources and in our estimate of modification activity at
existing major sources that will become subject to PSD review for GHG
emission increases. The general uncertainty results from predicting not
only how many major sources will undergo physical or operational changes
in any given year, but also which of those changes would result in GHG
emissions increases that would exceed a proposed GHG significance level.
  First, information is not available across sectors and source
categories on the types and numbers of specific physical and operational
changes that would result in GHG emissions increases in amounts that can
be estimated and that therefore can be compared to various GHG emissions
significance levels.  Second, there is uncertainty in how many project
modifications will occur within any given year because decisions on
these projects are driven by facility- and sector-based growth patterns
and business planning decisions.  Lastly, some source categories and
units that emit GHGs have not previously been subject to any type of
permitting or reporting requirements; as a result, for these sources,
there is very little historical record for use in estimating the number
and types of projects that would occur at these sources and, in turn,
establish an appropriate significance level for GHGs.  

Uncertainties in Permitting Costs

The primary reference sources for our estimate of burden hours and costs
for permitting GHGs are the most recent ICRs for the PSD and title V
programs.   There a number of uncertainties introduced in using these
references for costing GHG permitting activities.   First, we are
assuming that the average, conventional pollutant per-permit costs will
be similar for GHGs.  We do recognize the likelihood that residential
and commercial permits would be simpler and have a lower per-permit
burden than traditional industrial sources, and have made adjustments
for this: however, for industrial sources we assume per-permit costs on
par with what are estimated in the latest ICRs for PSD and title V
programs.  There is uncertainty in applying these average ICR-based
costs to GHG permitting, even for industrial sources, because there is
no historical track record for permitting these GHG sources and thus any
cost efficiencies that have been realized over the years for
conventional pollutant permitting, and thus reflected in the current
ICRs, may not be initially realized for GHG permitting.  For example, we
assume the same public hearing estimate as included in the ICR for
current PSD permits (i.e., that 1 in 50 major PSD permits require a
hearing)—for  GHG sources this number may be higher initially if there
ends up being significantly more public interest in these permits.  We
do believe overall, however, that larger facilities, especially those
affected at higher threshold levels, will have had sufficient permitting
experience such that out ICR-based costs should reasonably reflect the
added burden of including GHGs. 

As mentioned above, in our burden scenario analyses we do discount the
ICR-based per-permit costs for residential and commercial sources to
reflect what we believe will generally be simpler permits, involving
primarily uniform combustion type equipment. For PSD we discount the
per-permit cost by 30%, and for title V we discount the per-permit cost
by 50%.   There is significant uncertainty in these estimated discounts
since we have no track record for permitting these smaller commercial
and residential sources.   However, we do believe that, based solely on
the type and uniformity of the GHG emission units that would be subject
to permitting at these facilities under lower GHG threshold scenarios,
that average per-permit costs would be less than those currently
experienced by more complex industrial facilities, with numerous
emission units, for currently regulated pollutants.  

3.  Evaluation of ICR-based Resource Requirements for Permitting
Authorities at Different 

     Possible GHG Permitting Thresholds

	For the proposal, EPA examined resource requirements at the
statutory-based 100/250 tpy CO2e emission levels—referred to as the
‘baseline’ analysis in the following tables—as well as at 10,000
tpy, 25,000 tpy, and 50,000 tpy CO2e levels. Due to comments received on
the proposal and this improved burden analysis, the 10,000 tpy threshold
was eliminated as not being a viable alternative since it did not
adequately address administrative necessity concerns. In this analysis,
in addition to the baseline analysis, EPA broadened the options to
consider thresholds ranging from a 25,000 tpy CO2e major source
applicability level for PSD and title V up to a 100,000 tpy CO2e level,
with associated PSD GHG significant levels of equal magnitude. EPA also
considered the impact on burden of different PSD GHG significance levels
combined with the 100,000 tpy major source level, including 50,000 CO2e,
75,000 CO2e, and 100,000 CO2e. The choice of a PSD significance level
also has a direct impact on title V burdens since a greater number of
PSD permit requirements that result from modification activities will
result in a greater number of necessary title V revisions.

PSD Permits

Table 3-1 presents the estimated burden for permitting authorities at
different possible PSD GHG major source applicability thresholds. 
Descriptions of the different thresholds selected are provided below.
Burden estimates for the PSD program are calculated based on listed
values obtained from Tables 6-1 and 6-2 the NSR ICR. The ICR does not
distinguish between new construction and modification actions;
therefore, Table 3-1 combines the actions into permit preparation
issuance based solely on GHG emissions or the addition of GHG
requirements to permits being issued for conventional sources, or
“anyway” permits. PSD permit preparation and issuance is further
divided into industrial and commercial/residential sources since less
time is required for commercial/residential sources.

Baseline

After receiving comments on the proposal and reevaluating the initial
estimates, EPA has determined the impact of regulating GHG emissions
under current PSD statutory thresholds for applicability. Baseline
burden and cost were calculated at the 100 tpy and 250 tpy major source
permitting threshold (the 100 tpy threshold applies to the 28 source
categories identified in the Clean Air Act section 169(1)).  At these
thresholds, the additional annual permitting burden for permitting
authorities is estimated at 19.5 million hours at a cost of $1.5
billion.

Table 3-1. Additional Permitting Authority PSD Burden with GHG (Annual)

Activity	Burden Hours per Permit	Affected Permits	Total Burden (hours)
Total Cost ($2007)a

100/250 tpy Major /100 tpy Significance Threshold (“Baseline”)

 	PSD Permit Preparation and Issuance - Industrial	301	26,089	7,852,789
$606,392,367

 	PSD Permit Preparation and Issuance - Commercial/Residentialb	210
55,509	11,656,890	$900,145,046

 	Additions to Current PSD Applicationsc	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	19,544,079	$1,509,193,780

25,000 tpy Major/ 25,000 tpy Significance Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	9197	2,768,297
$213,767,894

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	63
13,230	$1,021,621

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	2,815,927	$217,445,883

50,000 tpy Major/ 50,000 Significance Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	1906	573,706
$44,301,577

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	28
5,880	$454,054

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	613,986	$47,411,999

100,000 tpy Major/ 50,000 tpy Significance Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	1809	544,509
$42,046,985

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	4
840	$64,865

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	579,749	$44,768,218

100,000 tpy Major/ 75,000 tpy Significance Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	915	275,415
$21,267,546

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	4
840	$64,865

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	310,655	$23,988,779

100,000 tpy Major/ 100,000 tpy Significance Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	20	6020	$464,864

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	4
840	$64,865

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	41,260	$3,186,097

Non-GHG-Based Threshold

 	PSD Permit Preparation and Issuance - Industrial	301	0	0	$0

 	PSD Permit Preparation and Issuance - Commercial/Residential	210	0	0
$0

 	Additions to Current PSD Applications	50	688	34,400	$2,656,368

 	Total Additional Burden	 	 	34,400	$2,656,368

aLabor cost of $77.22/hr from Prevention of Significant Deterioration
and Non-Attainment Area New Source Review (Renewal), EPA ICR Number
1230.23, OMB Control Number 2060-0003, 2008. 

bAssume permit preparation and issuance for commercial/residential
permits takes 70% the amount of time needed to prepare and issue an
industrial permit. 

cFor current permit applications, assume it takes an additional 50 hours
to include GHG requirements in the permit.



Alternate Threshold Scenarios

After determining the baseline, additional annual burden was determined
at six different major stationary source threshold levels in order to
evaluate the relative differences in impacts to permitting authorities.
Estimates represent the additional burden and costs due to GHG
permitting beyond to the burden currently experienced by permitting
authorities and sources.

The first scenario is the threshold proposed in the GHG Tailoring Rule
of 25,000 tpy CO2e. Results of this analysis indicate a total of 9,260
new permits, plus 688 permit actions to include GHG related requirements
into current PSD permitting actions (including both new construction and
modifications).  This additional workload equates to 2.8 million hours
for permitting authorities at a cost of $217 million. Note this is an
increase over our initial results at proposal of over 185,000 burden
hours and $8.7 million. Again, increases are due to more accurate
estimates of annual modifications and burden associated with
commercial/residential permits.

Increasing the emission threshold to 50,000 tpy will lead to an
estimated 614,000 hours additional burden at a cost of $47.4 million.
This scenario estimates 1,934 new construction or modification
activities will be subject to PSD permitting annually due to GHG.

Setting a threshold of 100,000 tpy with a significance level of 50,000
tpy, permitting authorities will spend an estimated 580,000 hours
preparing and issuing permits, at a cost of $44.8 million. At this
level, EPA estimates 1,813 new actions require PSD permits.

Next, at the 100,000 tpy threshold with a 75,000 tpy significance level,
the annual permitting authority burden will increase by 311,000 hours at
a cost of $24 million. In this scenario, 919 new permit actions will
occur annually. 

At a 100,000 tpy threshold, with a 100,000 tpy significance level for
modifications, EPA estimates there are 20 new industrial PSD permit
actions and four commercial/residential. Permitting authorities will
spend an estimated 41,000 additional hours on permits at a cost of $3.2
million.

The final scenario involves only sources that are required to get a PSD
permit due to their non-GHG emissions and then are further required to
add GHG related requirements as a result of GHG emissions increases from
modifications, or GHG emissions at newly constructed facilities,
exceeding a significance threshold of 75,000 tpy GHG. In this scenario,
only the annual 688 PSD permit actions derived from the NSR ICR are
expected to need the inclusion of GHG related requirements to the
permits. The additional burden to permitting authorities under this
scenario is estimated at 34,000 hours at a cost of $2.7 million.

Title V Permits

Table 3-2 presents the estimated burden for permitting authorities at
different possible title V GHG major source applicability thresholds. 
Descriptions of the different thresholds selected are provided below.
Burden estimates are calculated and annual values derived from Tables 7
and 8 of the current Title V ICR.  

Baseline

EPA reevaluated our estimates of the additional administrative burden
and cost of including GHG emitters in the title V program at the current
100 tpy statutory threshold level. To determine the impact of regulating
GHG emissions under current title V program, baseline Table 3-2.
Additional Permitting Authority Title V Burden with GHG (Annual)

Activity	Burden Hour per Permit	Affected Permits	Total Burden (hours)
Total Cost ($2007)b

100 tpy (associated with PSD 100/250 tpy maj./100 tpy sig.)

 	New Permit Preparation and Issuance – Industrial	428	71,829
30,742,812	$1,414,169,352

 	Add GHG component to new Non-GHG Permitb	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residentialc	214
1,985,948	424,992,872	$19,549,672,112

 	Permit Revisions - due to GHG 	40	61,836	2,473,440	$113,778,240

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewalsd	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	458,236,592	$21,078,883,232

25,000 tpy (associated with PSD 25,000 tpy maj./25,000 tpy sig.)

 	New Permit Preparation and Issuance – Industrial	428	2,103	899,941
$41,397,301

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	214	444
94,945	$4,367,455

 	Permit Revisions - due to GHG 	40	9,197	367,880	$16,922,480

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	1,390,234	$63,950,764

50,000 tpy (associated with PSD 50,000 tpy maj./50,000 tpy sig.)

 	New Permit Preparation and Issuance – Industrial	428	981	419,868
$19,313,928

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	214	208
44,441	$2,044,271

 	Permit Revisions - due to GHG 	40	1,906	76,240	$3,507,040

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	568,017	$26,128,767

100,000 tpy (associated with PSD 100,000 tpy maj./50,000 tpy sig.) 

 	New Permit Preparation and Issuance – Industrial	428	172	73,473
$3,379,773

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	214	18
3,781	$173,911

 	Permit Revisions - due to GHG 	40	1,809	72,360	$3,328,560

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	177,082	$8,145,772

Table 3-2 cont’d. Additional Permitting Authority Title V Burden with
GHG (Annual)

Activity	Burden Hour per Permit	Affected Permits	Total Burden (hours)
Total Cost ($2007)b

100,000 tpy (associated with PSD 100,000 tpy maj./75,000 tpy sig.) 

 	New Permit Preparation and Issuance – Industrial	428	172	73,473
3,379,773

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	214	18
3,781	$173,911

 	Permit Revisions - due to GHG 	40	915	36,600	$1,683,600

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	141,322	$6,500,812

100,000 tpy (associated with 100,000 tpy maj./ 100,000 tpy sig.)

 	New Permit Preparation and Issuance – Industrial	428	172	73,473
$3,379,773

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	214	18
3,781	$173,911

 	Permit Revisions - due to GHG 	40	20	800	$36,800

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	105,522	$4,854,012

Non-GHG Based Threshold 

 	New Permit Preparation and Issuance – Industrial	428	0	0	0

 	Add GHG component to new Non-GHG Permit	43	50	2,150	$98,900

 	New Permit Preparation and Issuance - Commercial/Residential	21	0	0
$0

 	Permit Revisions - due to GHG 	40	0	0	$0

 	Permit Revisions - add GHG to Current Non-GHG Permits	4	448	1,792
$82,432

 	Permit Renewals	9	2,614	23,526	$1,082,196

 	Total Additional Burden	 	 	27,468	$1,263,528

aSalaries from Title V ICR adjusted to 2007 dollars using 2007 OPM
General Schedule Salary Table available at:
http://www.opm.gov/oca/07tables/index.asp

bIncorporating GHG information/requirements into significant revisions
and permit renewals adds an additional 10% of the current time (90 hours
each)

cNew commercial/residential permits require half the time needed for new
industrial permits

dThe Title V ICR estimates that 3,267 permits annually undergo renewal -
assume 80% of these involve combustion

burden and cost are calculated at the 100 tpy threshold level, which is
the generally applied major source applicability level under title V. At
the statutory threshold level, it is estimated that 

over six million sources will become newly subject to title V. A source
generally must apply for a title V permit within one year of becoming
subject to permitting, then the permitting authority must take final
action (issue or deny) on the permit applications within 18 months of
receipt. We expect these new permits will not be issued all at once, but
rather will come in over a three-year time frame based on the statutory
requirements listed above.  Therefore, we assume that one-third of the
newly subject sources will apply for and obtain a permit annually,
requiring almost 460 million burden hours to prepare and issue over two
million new operating permits at an additional cost of $21.1 billion.

Alternate Threshold Scenarios

After determining the baseline, additional burden was determined at six
different major stationary source threshold levels in order to evaluate
the relative differences in impacts to permitting authorities. Estimates
represent the additional annual burden and costs due to GHG permitting
beyond the burden and costs currently experienced by permitting
authorities and sources. 

The first scenario is the threshold proposed in the GHG Tailoring Rule
of 25,000 tpy CO2e. Results of this analysis indicate a total of 2,547
new permits, as well as 50 permits that would need to include GHG
requirements in their permits.  This additional workload equates to 1.4
million hours for permitting authorities at a cost of $64 million. Note
that this is an increase over our initial results at proposal of
approximately 985,000 burden hours and $45 million. As with PSD
programs, increases are due to more complete estimates of annual
modifications and the revised burden associated with
commercial/residential permits.

Increasing the emission threshold to 50,000 tpy will lead to an
estimated 568,000 hours additional burden at a cost of $26.1 million.
This scenario estimates 1,189 new sources will be subject to title V
permitting annually due to GHG.

To examine the impact of significance levels on the overall burden, EPA
considered the impact on burden of different PSD GHG significance levels
of 50,000 CO2e, 75,000 CO2e, and 100,000 CO2e combined with the 100,000
tpy major source level The choice of a PSD significance level has a
direct impact on title V burdens since a greater number of PSD permit
requirements that result from modification activities will result in a
greater number of necessary title V revisions. This effect is apparent
in Table 3-2. Note that for all three scenarios, EPA estimates there are
172 industrial and 18 commercial/residential new title V permit actions
due to GHG. 

Setting a threshold of 100,000 tpy with a PSD significance level of
50,000 tpy, permitting authorities will spend an estimated 177,000 hours
preparing and issuing permits, at a cost of $8.1 million. Note that
under this scenario, 1,809 revisions are estimated annually to update
existing operating permits due to modification activities.  Utilizing a
75,000 tpy PSD significance level, the annual permitting authority
burden is estimated to increase by 161,000 hours at a cost of $7.4
million. At this significance level, 915 operating permit revisions will
be necessary due to GHG. This decrease from the previous scenario is due
to fewer modifications exceeding the higher significance level threshold
and requiring revisions to an operating permit. At a 100,000 tpy
threshold, with a 100,000 tpy PSD significance level for modifications,
EPA estimates there are only 20 permit revisions annually. Permitting
authorities will spend an estimated 106,000 additional hours on permits
at a cost of $4.9 million.

The final scenario involves only sources that are required to get a
title V permit for emissions other than GHG and that are required to add
GHG related requirements. Under this scenario, only the annual issuance
of 50 permits noted in the Title V ICR are expected to need the
inclusion of GHG related requirements to the permits. The additional
burden to permitting authorities under this scenario is estimated at 27
million hours at a cost of $1.3 million.

4.  Burden Relief Estimates for Permitting Authorities and Sources at
Several Possible GHG Major Source Applicability Thresholds for Title V
and PSD

The following tables indicate the estimated burden relief when comparing
the baseline levels with several threshold levels for GHG applicability
as described in the previous sections. In Tables 4-1 through 4-4, the
first three columns indicate the cost per permit and total cost to
permitting authorities at a GHG threshold level equal to the statutory
threshold levels for title V and PSD (100 and 100/250 tpy,
respectively). The next three columns reflect the estimated costs for
permitting authorities with the permitting thresholds (both for PSD and
title V) set at the specified levels. In the final three columns, the
burden relief is estimated – the time and costs alleviated relative to
the baseline levels by establishing several GHG permitting thresholds as
previously described. 

The burden relief for sources at the different permitting thresholds is
presented in Tables 4-5, 4-6, and 4-7 below. Table 4-8 estimates the
cost savings if a non-GHG based related trigger is used. This
information on burden relief was used to compile the final Regulatory
Impact Analysis (RIA) for the final GHG tailoring rule. Please see the
final RIA contained in the public docket for this GHG tailoring rule for
a full explanation and description of the burden relief provided by the
final GHG tailoring rule actions. 



Table 4-1. Estimated Burden Relief for Permitting Authorities Utilizing
a 25,000 tpy Major/ 25,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	25,000 tpy or Greater	Avoided
Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$19,688	71,829	$1,414,175,915	$19,688
2,103	$41,403,864	$19,688	69,726	$1,372,772,051

 	Current Industrial - Add GHG	$1,978	50	$98,900	$1,978	50	$98,900
$1,978	0	$0

 	New Commercial/Residential 	$9,844	1,985,948	$19,549,672,112	$9,844
444	$4,370,736	$9,844	1,985,504	$19,545,301,376

 	Permit Revisions - Due to GHG	$1,840	61,836	$113,778,240	$1,840	9,197
$16,922,480	$1,840	52,639	$96,855,760

 	Permit Revisions - Add GHG	$184	448	$82,432	$184	448	$82,432	$184	0
$0

 	Permit Renewals	$414	2,614	$1,082,196	$414	2,614	$1,082,196	$414	0	$0

 	Total Permits Affected	 	2,122,725	 	 	14,856	 	 	2,107,869	 

PSD Permits

 	New Industrial 	$23,243	26,089	$606,386,627	$23,243	9,197
$213,765,871	$23,243	16,892	$392,620,756

 	New Commercial/Residential 	$16,216	55,509	$900,133,944	$16,216	63
$1,021,608	$16,216	55,446	$899,112,336

 	Current Applications - Add GHG	$3,861	688	$2,656,368	$3,861	688
$2,656,368	$3,861	0	$0

 	Total Permits Affected	 	82,286	 	 	9,948	 	 	72,338	 

Total Permitting Authority Costs	 	 	$22,588,066,734	 	 
$281,404,455	 	 	$22,306,662,279





Table 4-2. Estimated Burden Relief for Permitting Authorities Utilizing
a 50,000 tpy Major/50,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	50,000 tpy or Greater	Avoided
Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$19,688	71,829	$1,414,175,915	$19,688	981
$19,313,928	$19,688	70,848	$1,394,861,987

 	Current Industrial - Add GHG	$1,978	50	$98,900	$1,978	50	$98,900
$1,978	0	$0

 	New Commercial/Residential 	$9,844	1,985,948	$19,549,672,112	$9,844
208	$2,047,552	$9,844	1,985,740	$19,547,624,560

 	Permit Revisions - Due to GHG	$1,840	61,836	$113,778,240	$1,840	1,906
$3,507,040	$1,840	59,930	$110,271,200

 	Permit Revisions - Add GHG	$184	448	$82,432	$184	448	$82,432	$184	0
$0

 	Permit Renewals	$414	2,614	$1,082,196	$414	2,614	$1,082,196	$414	0	$0

 	Total Permits Affected	 	2,122,725	 	 	6,207	 	 	2,116,518	 

PSD Permits

 	New Industrial 	$23,243	26,089	$606,386,627	$23,243	1,906	$44,301,158
$23,243	24,183	$562,085,469

 	New Commercial/Residential 	$16,216	55,509	$900,133,944	$16,216	28
$454,048	$16,216	55,481	$899,679,896

 	Current Applications - Add GHG	$3,861	688	$2,656,368	$3,861	688
$2,656,368	$3,861	0	$0

 	Total Permits Affected	 	82,286	 	 	2,622	 	 	79,664	 

Total Permitting Authority Costs	 	 	$22,588,066,734	 	 	$73,543,622
 	 	$22,514,523,112





Table 4-3. Estimated Burden Relief for Permitting Authorities Utilizing
a 100,000 tpy Major/75,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	100,000 tpy; 75,000 tpy or Greater
Avoided Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$19,688	71,829	$1,414,175,915	$19,688	172
$3,386,336	$19,688	71,657	$1,410,789,579

 	Current Industrial - Add GHG	$1,978	50	$98,900	$1,978	50	$98,900
$1,978	0	$0

 	New Commercial/Residential 	$9,844	1,985,948	$19,549,672,112	$9,844
18	$177,192	$9,844	1,985,930	$19,549,494,920

 	Permit Revisions - Due to GHG	$1,840	61,836	$113,778,240	$1,840	915
$1,683,600	$1,840	60,921	$112,094,640

 	Permit Revisions - Add GHG	$184	448	$82,432	$184	448	$82,432	$184	0
$0

 	Permit Renewals	$414	2,614	$1,082,196	$414	2,614	$1,082,196	$414	0	$0

 	Total Permits Affected	 	2,122,725	 	 	4,217	 	 	2,118,508	 

PSD Permits

 	New Industrial 	$23,243	26,089	$606,386,627	$23,243	915	$21,267,345
$23,243	25,174	$585,119,282

 	New Commercial/Residential 	$16,216	55,509	$900,133,944	$16,216	4
$64,864	$16,216	55,505	$900,069,080

 	Current Applications - Add GHG	$3,861	688	$2,656,368	$3,861	688
$2,656,368	$3,861	0	$0

 	Total Permits Affected	 	82,286	 	 	1,607	 	 	80,679	 

Total Permitting Authority Costs	 	 	$22,588,066,734	 	 	$30,499,233
 	 	$22,557,567,501





Table 4-4. Estimated Burden Relief for Permitting Authorities Utilizing
a Non-GHG Trigger

 	All Title V 100tpy and PSD 250 tpy	Non-GHG Trigger	Avoided Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$19,688	71,829	$1,414,175,915	$19,688	0
$0	$19,688	71,829	$1,414,175,915

 	Current Industrial - Add GHG	$1,978	50	$98,900	$1,978	50	$98,900
$1,978	0	$0

 	New Commercial/Residential 	$9,844	1,985,948	$19,549,672,112	$9,844	0
$0	$9,844	1,985,948	$19,549,672,112

 	Permit Revisions - Due to GHG	$1,840	61,836	$113,778,240	$1,840	0	$0
$1,840	61,836	$113,778,240

 	Permit Revisions - Add GHG	$184	448	$82,432	$184	448	$82,432	$184	0
$0

 	Permit Renewals	$414	2,614	$1,082,196	$414	2,614	$1,082,196	$414	0	$0

 	Total Permits Affected	 	2,122,725	 	 	3,112	 	 	2,119,613	 

PSD Permits

 	New Industrial 	$23,243	26,089	$606,386,627	$23,243	0	$0	$23,243
26,089	$606,386,627

 	New Commercial/Residential 	$16,216	55,509	$900,133,944	$16,216	0	$0
$16,216	55,509	$900,133,944

 	Current Applications - Add GHG	$3,861	688	$2,656,368	$3,861	688
$2,656,368	$3,861	0	$0

 	Total Permits Affected	 	82,286	 	 	688	 	 	81,598	 

Total Permitting Authority Costs	 	 	$22,588,066,734	 	 	$3,919,896
 	 	$22,584,146,838



Table 4-5. Estimated Burden Relief for Sources Utilizing a 25,000 tpy
Major/25,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	25,000 tpy or Greater	Avoided
Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$46,350	71,829	$3,329,289,600	$46,350
2,103	$97,474,050	$46,350	69,726	$3,231,815,550

 	Current Industrial - Add GHG	$4,440	50	$222,000	$4,440	50	$222,000
$4,440	0	$0

 	New Commercial/Residential 	$23,175	1,985,948	$46,024,344,900	$23,175
444	$10,289,700	$23,175	1,985,504	$46,014,055,200

 	Permit Revisions - Due to GHG	$1,677	61,836	$103,698,972	$1,677	9,197
$15,423,369	$1,677	52,639	$88,275,603

 	Permit Revisions - Add GHG	$156	448	$69,888	$156	448	$69,888	$156	0
$0

 	Permit Renewals	$780	2,614	$2,038,920	$780	2,614	$2,038,920	$780	0	$0

 	Total Permits Affected	 	2,122,725	 	 	14,856	 	 	2,107,869	 

PSD Permits

 	New Industrial 	$84,530	26,089	$2,205,303,170	$84,530	9,197
$777,422,410	$84,530	16,892	$1,427,880,760

 	New Commercial/Residential 	$59,152	55,509	$3,283,468,368	$59,152	63
$3,726,576	$59,152	55,446	$3,279,741,792

 	Current Applications - Add GHG	$21,669	688	$14,908,272	$21,669	688
$14,908,272	$21,669	0	$0

 	Total Permits Affected	 	82,286	 	 	9,948	 	 	72,338	 

Total Source Costs	 	 	$54,963,344,090	 	 	$921,575,185	 	 
$54,041,768,905





Table 4-6. Estimated Burden Relief for Sources Utilizing a 50,000 tpy
Major/50,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	50,000 tpy or Greater	Avoided
Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$46,350	71,829	$3,329,289,600	$46,350	981
$45,469,350	$46,350	70,848	$3,283,820,250

 	Current Industrial - Add GHG	$4,440	50	$222,000	$4,440	50	$222,000
$4,440	0	$0

 	New Commercial/Residential 	$23,175	1,985,948	$46,024,344,900	$23,175
208	$4,820,400	$23,175	1,985,740	$46,019,524,500

 	Permit Revisions - Due to GHG	$1,677	61,836	$103,698,972	$1,677	1,906
$3,196,362	$1,677	59,930	$100,502,610

 	Permit Revisions - Add GHG	$156	448	$69,888	$156	448	$69,888	$156	0
$0

 	Permit Renewals	$780	2,614	$2,038,920	$780	2,614	$2,038,920	$780	0	$0

 	Total Permits Affected	 	2,122,725	 	 	6,207	 	 	2,116,518	 

PSD Permits

 	New Industrial 	$84,530	26,089	$2,205,303,170	$84,530	1,906
$161,114,180	$84,530	24,183	$2,044,188,990

 	New Commercial/Residential 	$59,152	55,509	$3,283,468,368	$59,152	28
$1,656,256	$59,152	55,481	$3,281,812,112

 	Current Applications - Add GHG	$21,669	688	$14,908,272	$21,669	688
$14,908,272	$21,669	0	$0

 	Total Permits Affected	 	82,286	 	 	2,622	 	 	79,664	 

Total Source Costs	 	 	$54,963,344,090	 	 	$233,495,628	 	 
$54,729,848,462





Table 4-7. Estimated Burden Relief for Sources  Utilizing a 100,000 tpy
Major/75,000 tpy PSD Significance Threshold

 	All Title V 100tpy and PSD 250 tpy	100,000 tpy; 75,000 tpy or Greater
Avoided Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$46,350	71,829	$3,329,289,600	$46,350	172
$7,972,200	$46,350	71,657	$3,321,317,400

 	Current Industrial - Add GHG	$4,440	50	$222,000	$4,440	50	$222,000
$4,440	0	$0

 	New Commercial/Residential 	$23,175	1,985,948	$46,024,344,900	$23,175
18	$417,150	$23,175	1,985,930	$46,023,927,750

 	Permit Revisions - Due to GHG	$1,677	61,836	$103,698,972	$1,677	915
$1,534,455	$1,677	60,921	$102,164,517

 	Permit Revisions - Add GHG	$156	448	$69,888	$156	448	$69,888	$156	0
$0

 	Permit Renewals	$780	2,614	$2,038,920	$780	2,614	$2,038,920	$780	0	$0

 	Total Permits Affected	 	2,122,725	 	 	4,217	 	 	2,118,508	 

PSD Permits

 	New Industrial 	$84,530	26,089	$2,205,303,170	$84,530	915	$77,344,950
$84,530	25,174	$2,127,958,220

 	New Commercial/Residential 	$59,152	55,509	$3,283,468,368	$59,152	4
$236,608	$59,152	55,505	$3,283,231,760

 	Current Applications - Add GHG	$21,669	688	$14,908,272	$21,669	688
$14,908,272	$21,669	0	$0

 	Total Permits Affected	 	82,286	 	 	1,607	 	 	80,679	 

Total Source Costs	 	 	$54,963,344,090	 	 	$104,744,443	 	 
$54,858,599,647





Table 4-8. Estimated Burden Relief for Sources Utilizing a Non-GHG
Trigger

 	All Title V 100tpy and PSD 250 tpy	Non-GHG Trigger	Avoided Burden

Activity	Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)
Cost per Permit (2007$)	Number of Permits	Total Cost (2007$)	Cost per
Permit (2007$)	Number of Permits	Total Cost (2007$)

Title V Permits

 	New Industrial - Due to GHG	$46,350	71,829	$3,329,289,600	$46,350	0
$0	$46,350	71,829	$3,329,289,600

 	Current Industrial - Add GHG	$4,440	50	$222,000	$4,440	50	$222,000
$4,440	0	$0

 	New Commercial/Residential 	$23,175	1,985,948	$46,024,344,900	$23,175
0	$0	$23,175	1,985,948	$46,024,344,900

 	Permit Revisions - Due to GHG	$1,677	61,836	$103,698,972	$1,677	0	$0
$1,677	61,836	$103,698,972

 	Permit Revisions - Add GHG	$156	448	$69,888	$156	448	$69,888	$156	0
$0

 	Permit Renewals	$780	2,614	$2,038,920	$780	2,614	$2,038,920	$780	0	$0

 	Total Permits Affected	 	2,122,725	 	 	3,112	 	 	2,119,613	 

PSD Permits

 	New Industrial 	$84,530	26,089	$2,205,303,170	$84,530	0	$0	$84,530
26,089	$2,205,303,170

 	New Commercial/Residential 	$59,152	55,509	$3,283,468,368	$59,152	0
$0	$59,152	55,509	$3,283,468,368

 	Current Applications - Add GHG	$21,669	688	$14,908,272	$21,669	688
$14,908,272	$21,669	0	$0

 	Total Permits Affected	 	82,286	 	 	688	 	 	81,598	 

Total Source Costs	 	 	$54,963,344,090	 	 	$17,239,080	 	 
$54,946,105,010





APPENDIX A

Table A-1. Newly Major Affected Source Estimates Based on Threshold
Level

Source Type	100/250 tpy PSD	100 tpy Title V 	25,000 tpy	50,000 tpy
100,000 tpy

EGUs	285	285	124	0	0

Industrial	141,160	170,910	4,002	1,934	256

Oil/Gas/Coal production	2,588	2,588	187	75	52

Waste Treatment	3,344	3,358	1,927	910	193

Commercial 	731,477	1,355,921	1,161	600	51

Residential	182,350	4,535,500	160	20	0

Total	1,061,204	6,068,562	7,561	3,539	552

Based on information contained in the “Technical Support Document for
Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air Quality
Policy and Standards; March 29, 2010 and information retrieved from
EPA's enforcement and compliance history online (ECHO) database during
January 2010.  ECHO is a computer-data based created and maintained by
the EPA that contains source-specific data submitted primarily by state
and local environmental agencies.  See 
http://www.epa-echo.gov/echo/index.html.

 “Summary of ICR-based Data Used to Estimate Avoided Burden and
Evaluate Resource

Requirements at Alternative GHG Permitting Thresholds;” Prepared by
EPA Staff; August 2009.

 “Technical Support Document for Greenhouse Gas Emissions Thresholds
Evaluation;” Office of Air Quality Policy and Standards; March 29,
2010.

 Prevention of Significant Deterioration and Non-Attainment Area New
Source Review (Renewal), EPA ICR Number 123.23, OMB Control Number
2060-0003, 2008. A copy of this document is available in the docket for
the final Tailoring Rule.

 GHG threshold options are all based on tpy CO2e.  The Non-GHG option is
based on a PSD action being triggered for a non-GHG, conventional
pollutant (e.g., nitric oxides), where a GHG-related PSD review is only
necessary when associated GHG emissions for the project exceed 75,000
tpy CO2e.

 “NACAA Summary on Permitting GHGs Under the Clean Air Act”;
Memorandum from Mary Stewart Douglas, National Association of Clean Air
Agencies to Juan Santiago, EPA/OAQPS, September 3, 2009.

 The 80% estimate was obtained by reviewing a sample of PSD modification
permits to determine the number involving combustion that would emit
GHGs.  This review showed that approximately 80% of PSD permitting
actions involve combustion units of all types.  These permitting actions
are being permitted for, or taking limits for, NOx or some other
combustion-related emission.  These run the gamut of industrial
activity, from power generators to manufacturing facilities, and many
other types.

 A well-known gas with a familiar BACT process, such as NOx, requires an
average of 20-30 burden hours to be included in a permit. As less is
known regarding GHGs and the BACT decision process, expert staff
judgment set the burden for permitting authorities to add GHG to permits
at 50 hours.  This is because determining BACT entails review and
analysis of the available control techniques.  For a well-known
pollutant, the experience of the permitting authority allows it to
efficiently consider the various options and narrow them down promptly
to the one that should be considered BACT.  Because no BACT
determinations have ever been made, permitting authorities will need to
invest additional time into reviewing the available technologies and
selecting which one should be considered the best for the particular
source.  In the absence of any previous experience selecting BACT for
GHG sources, we estimate that twice as much time will be necessary as
for conventional pollutants. 

 See NSR ICR at page 11.

  See footnote 6, above (basis for 80% calculation).

 “Technical Support Document for Greenhouse Gas Emissions Thresholds
Evaluation;” Office of Air Quality Policy and Standards; March 29,
2010.

 See Tables 2-2 and 2-3.

 Information Collection Request for State Operating Permit Regulations
(Renewal), EPA ICR Number 1587.07, OMB Control Number 2060-0243, 2007. A
copy of this document is available in the docket for the final Tailoring
Rule.

 The 80% estimate was obtained through a review of existing title V
permit source categorization.  

 The Title V ICR indicates the burdens associated with revisions are as
follows: 90 hours for a significant revision, 30 hours for a minor
revision, and 5 hours for an administrative action. See Table 8 at 23.
It is not known which revision will be required for any modification
that exceeds the GHG significance level threshold; therefore, EPA
averages the three permitting burdens to obtain a value of 40 hours per
permit.

 “Technical Support Document for Greenhouse Gas Emissions Thresholds
Evaluation;” Office of Air Quality Policy and Standards; March 29,
2010.

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