REGULATORY IMPACT ANALYSIS
FOR
PROPOSED
OZONE
NATIONAL AMBIENT AIR QUALITY STANDARD
Prepared by:
Innovative Strategies and Economics Group
Office of Air Quality Planning and Standards
U.S. EPA
Research Triangle Park, N.C.
December 1996
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REGULATORY IMPACT ANALYSIS
FOR
PROPOSED
OZONE
NATIONAL AMBIENT AIR QUALITY STANDARD
Prepared by:
Innovative Strategies and Economics Group
Office of Air Quality Planning and Standards
U.S. EPA
Research Triangle Park, N.C.
December 1996
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REGULATORY IMPACT ANALYSIS
TABLE OF CONTENTS
TABLE OF CONTENTS
ACRONYMS, ABBREVIATIONS, AND DEFINITIONS
EXECUTIVE SUMMARY
I. INTRODUCTION 1-1
A. INTRODUCTION 1-1
1. TITLE AND DESCRIPTION 1-2
2 SCHEDULES FOR OMB REVIEW . . . . ! 1-2
B. ANALYTICAL SCOPE 1-3
C. LIMITATIONS OF SEGREGATED ANALYSES FOR THE OZONE AND
PARTICULATE MATTER NAAQS 1-5
D. ANALYTICAL LIMITATIONS 1-9
E. CAVEAT 1-13
F. REFERENCES 1-14
H. STATEMENT OF NEED FOR THE PROPOSED REGULATION II-1
A. INTRODUCTION II-1
B. BACKGROUND E-l
1. LEGISLATIVE REQUIREMENTS AND JUDICIAL
REVIEW E-l
2. ESTABLISHMENT OF NAAQS FOR PHOTOCHEMICAL
OXIDANTS H-2
3. REVIEW AND REVISION OF NAAQS FOR PHOTOCHEMICAL
OXIDANTS . . H-3
4. CURRENT REVIEW OF OZONE NAAQS E-5
C. MARKET FAILURES H-5
D. THE NATURE OF THE AMBIENT OZONE AIR POLLUTION
PROBLEM H-6
1. HEALTH CONSIDERATIONS . . E-7
2. WELFARE CONSIDERATIONS E-8
E. REFERENCES H-8
m. ALTERNATIVES EXAMINED IE-1
A. INTRODUCTION EI-1
B. GENERAL DESIGN OF ALTERNATIVES EI-1
1. THE CURRENT STANDARD (1H1EX-120) m-2
2. ALTERNATIVE 8H5EX-80 M-2
3. ALTERNATIVE 8H4AX-80 EI-3
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4. ALTERNATIVE 8H1AX-80 EI-3
5. ALTERNATIVE 8H3AX-90 IH-3
6. ALTERNATIVE 8H5AX-70 III-4
C. THE SECONDARY STANDARD EI-4
D. OTHER ALTERNATIVES IJ3-4
1. NO REGULATION III-5
2. MARKET ORIENTED APPROACHES IH-5
E. REFERENCES IH-6
IV. METHODOLOGY: ESTIMATING AIR QUALITY IV-1
A. INTRODUCTION IV-1
B. METHODOLOGY FOR DETERMINING THE ANALYTICAL
BASE CASE IV-1
1. VOC EMISSIONS AND COST PROJECTIONS IV-1
a. TITLE I VOC REDUCTIONS IV-2
b. TITLE II VOC REDUCTIONS IV-4
c. TITLE in VOC REDUCTIONS (MACT) IV-5
d. RCRA VOC REDUCTIONS IV-5
2. NOx EMISSIONS AND COST PROJECTIONS IV-6
a. TITLE I NOx REDUCTIONS IV-7
b. TITLE n VOC AND NOx REDUCTIONS IV-10
3. REGIONAL NOx MANAGEMENT IV-12
C. THE METHODOLOGY FOR DETERMINING OZONE
CONCENTRATIONS IN 2007 IV-13
1. THE CENTROID METHODOLOGY TV-14
2. ADJUSTMENTS TO MONITORED DATA IV-15
3. THE REGRESSION IV-16
4. INTERPOLATION TO CENTROID "PROXY" MONITORS .... IV-19
5. LIMITATIONS AND CAVEATS FOR USING THE CENTROID
MODEL IV-20
6. CONCLUSIONS IV-22
D. REFERENCES IV-23
V. METHODOLOGIES FOR DETERMINING EMISSION REDUCTION TARGETS
AND CONTROL STRATEGIES V-l
A. INTRODUCTION V-l
B. IDENTIFYINGNONATTAINMENTAREAS ...V-l
1. DETERMINATION OF NONATTAINMENT AREAS - COSTS ... V-l
2. IDENTIFICATION OF MARGINAL NONATTAINMENT
AREAS V-3
C. IDENTIFYING TARGETED REDUCTIONS V-5
D. SELECTING INCREMENTAL CONTROL MEASURES V-8
E. RESIDUAL NONATTAINMENT V-10
F. ESTIMATING PARTIAL ATTAINMENT AIR QUALITY V-l2
U
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G. REFERENCES
V-13
VI. EMISSION REDUCTION AND COST ANALYSIS OF OZONE
ALTERNATIVES VI-1
A. INTRODUCTION VI-1
B. EMISSION REDUCTIONS AND COSTS UNDER THE REGIONAL
CONTROL SCENARIO VI-2
1. SUMMARY OF TOTAL EMISSION REDUCTIONS AND CONTROL
COSTS BY NONATTAINMENT AREA VI-4
a. THE CURRENT STANDARD (1H1EX-120) AND THE
8H3AX-90 ALTERNATIVE VI-5
b. ALTERNATIVE 8H5EX-80 VI-7
c. ALTERNATIVE 8H4AX-80 VI-8
d. ALTERNATIVES 8H1AX-80 AND 8H4AX-70 VI-10
2. THE SECONDARY STANDARD VI-12
C. COMPARISON OF ALTERNATIVE PRIMARY STANDARDS VI-12
D. CONCLUSIONS OF THE REGIONAL CONTROL
SCENARIO ANALYSIS VI-17
E. EMISSION REDUCTIONS AND COSTS UNDER THE LOCAL
CONTROL SCENARIO VI-17
1. SUMMARY OF TOTAL EMISSION REDUCTIONS AND
CONTROL COSTS BY NONATTAINMENT AREA VI-17
a. THE CURRENT STANDARD (1H1EX-120) AND THE
8H2AX-90 ALTERNATIVE VI-18
b. ALTERNATIVE 8H5EX-80 VI-19
c. ALTERNATIVE 8H4AX-80 VI-20
d. ALTERNATIVES 8H1AX-80 AND 8H4AX-70 VI-23
F. CONCLUSIONS OF THE LOCAL CONTROL SCENARIO VI-23
G. RESIDUAL NONATTAINMENT VI-24
G. REFERENCES VI-26
VH. SUMMARY OF POTENTIALLY AFFECTED ENTITIES VII-1
A. STATIONARY POINT SOURCES VH-1
1. VOC CONTROL MEASURES VH-1
2. NOx CONTROL MEASURES VH-3
B. STATIONARY AREA SOURCES VH-4
1. VOC CONTROL MEASURES VH-4
2. NOx CONTROL MEASURES VH-7
C. ON-HIGHWAY MOBILE SOURCES VH-7
1. REFORMULATED GASOLINE VH-7
2. REFORMULATED DIESEL FUEL VH-8
3. ENHANCED INSPECTION AND MAINTENANCE (I/M) VH-8
4. LOW EMISSION VEHICLES VH-9
D. NONROAD MOBILE SOURCES VH-9
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1. CALIFORNIA STANDARDS FOR £ 175 HP NONROAD DIESEL
ENGINES VH-9
2. NONROAD ENGINES - EMISSION REDUCTION BENEFITS
ASSOCIATED WITH PHASE I REFORMULATED GASOLINE VII-10
3. MARINE VESSEL EMISSION FEES VII-10
4. RECREATIONAL VEHICLES - CALIFORNIA STANDARDS . VII-11
E. COMPARISON OF ALTERNATIVE OZONE NAAQS ON
AFFECTED SOURCES VII-11
F. REFERENCES VII-15
VIII ECONOMIC ASSESSMENT VIII-1
A. INTRODUCTION VIII-1
B. COST EFFECTIVENESS VHI-2
1. BACKGROUND VIII-2
2. ALTERNATIVE COST-EFFECTIVENESS
METHODOLOGIES VIII-4
C. METHODOLOGY AND LIMITATIONS OF IMPACTS ANALYSIS OF
EACH CONTROL MEASURE VHI-5
1. STATIONARY POINT SOURCE CONTROL MEASURES VIU-6
a. METHODOLOGY VHI-6
b. LIMITATIONS OF POINT SOURCE CONTROL
MEASURE METHODOLOGY VHI-7
2. STATIONARY AREA SOURCE CONTROL MEASURES VDI-8
a. METHODOLOGY VIE-8
b LIMITATIONS OF THE AREA SOURCE CONTROL
METHODOLOGY Vm-9
3. MOBILE SOURCE CONTROL MEASURES VHI-10
a. ON-HIGHWAY CONTROL MEASURES VTO-10
b. NONROAD CONTROL MEASURES Vffl-13
D. RESULTS OF IMPACTS ANALYSIS OF EACH CONTROL
MEASURE Vm-15
1. ALTERNATIVE 8H5EX-80 VHI-16
2. ALTERNATIVE 8H4AX-80 Vm-17
4. ALTERNATIVE 8H1AX-80 VOI-17
E. METHODOLOGY AND LIMITATIONS OF IMPACTS ANALYSIS
OF SIC CODES POTENTIALLY AFFECTED BY MORE THAN ONE
CONTROL MEASURE VIII-17
F. RESULTS OF IMPACTS ANALYSIS OF SIC CODES POTENTIALLY
AFFECTED BY MORE THAN ONE CONTROL MEASURE VHI-18
G. ANALYTICAL ASSUMPTIONS AND LIMITATIONS VHI-18
H. ENVIRONMENTAL JUSTICE ANALYSES VHI-19
I. GOVERNMENTAL ENTITIES IMPACT VHI-20
J. CONCLUSIONS VHI-20
1. SUMMARY OF RESULTS VHI-20
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2. KEY CONTROL MEASURES vm-21
3. KEY SIC CODES Vni-23
K. REFERENCES Vm-24
IX. BENEFITS OF OZONE NAAQS ATTAINMENT IX-1
A ECONOMIC CONCEPTS OF BENEFITS IX-1
1. BENEFIT CATEGORIES APPLICABLE TO THE
REGULATION IX-1
2. ECONOMIC BENEFITS IX-3
3. LINKING THE REGULATION TO BENEFICIAL OUTCOMES . IX-4
B. HUMAN HEALTH EFFECTS IX-5
1. INTRODUCTION IX-5
2. QUANTIFIED HEALTH EFFECT BENEFITS EX-8
a. TYPES OF HEALTH STUDIES IX-8
b. HUMAN CLINICAL STUDIES IX-8
c. EPIDEMIOLOGICAL STUDIES IX-9
3. HEALTH BENEFITS METHODOLOGY IX-11
a. BASELINE OF ANALYSIS IX-11
b. OZ-ONE IX-11
4. HEALTH EFFECTS MODELS IX-12
a. CLINICAL AND EPIDEMIOLOGICAL MODELS IX-12
b. TIME PERIOD OF ANALYSIS .. IX-13
c. INCIDENCES VERSUS INCIDENCE-DAYS IX-14
d. AGGREGATION BY HEALTH ENDPOINT IX-15
e. NATIONAL RESULTS IX-18
5. MONETIZED HEALTH EFFECT BENEFITS IX-19
a. ECONOMIC VALUATION IX-19
b. VALUATION ESTIMATES DC-20
c. NATIONAL MONETIZED BENEFITS IX-22
C. WELFARE EFFECTS IX-24
1. INTRODUCTION IX-24
2. MONETIZED WELFARE BENEFITS ASSESSMENT IX-25
a. CENTROID METHOD: REGIONAL AND LOCAL
CONTROL STRATEGIES PARTIAL ATTAINMENT
AND FULL ATTAINMENT SCENARIOS IX-27
i. BACKGROUND IX-27
ii. METHODOLOGY EX-27
iii. RESULTS IX-28
b. GIS-BASED METHOD: FULL ATTAINMENT
SCENARIO EX-31
i. BACKGROUND IX-31
ii. METHODOLOGY IX-31
iii. RESULTS IX-32
3. NON-MONETIZED WELFARE BENEFITS IX-32
V
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D. SUMMARY OF HEALTH AND WELFARE BENEFITS IX-34
E. REFERENCES IX-39
X. BENEFIT-COST COMPARISON X-l
A. INTRODUCTION X-l
B. COMPARISON OF BENEFITS TO COSTS X-l
C. KEY RESULTS AND CONCLUSIONS X-l
D. GENERAL LIMITATIONS OF THE BENEFIT-COST COMPARISON . . . X-2
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
vi
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LIST OF ACRONYMS
ACT
Alternative Control Techniques
AIRS
Aerometric Information Retrieval System
AIRCOST
utility S02 control cost model (E.H.Pechan & Associates)
AF
air/fuel adjustment
AP-42
compilation of air pollutant emissions factors
BARCT
best available retrofit control technology
BEA
Bureau of Economic Analysis
BOOS
burners out-of-service
CAA
Clean Air Act
CAAAC
Clean Air Act Advisory Committee
CASAC
Clean Air Scientific Advisory Committee
CRDM
Climatological Regional Dispersion Model
CARB
California Air Resources Board
CO
carbon monoxide
CS-C
control strategy-cost
CTG
control technique guidelines
DOE
Department of Energy
EPA
Environmental Protection Agency
EIA
Energy Information Administration
ERCAM
Emission Reductions and Cost Analysis Models
ERCAM NOx
Enhancements to the Emission Reduction and Cost Analysis Models for No,
ERCAM VOC Enhancements to the Emission Reduction and Cost Analysis Models for VOC
ESP
FAC
FACA
FGD
FGR
FIP
FMVCP
GCVTC
GDP
GSP
ICI
ISCST
VM
IR
LAER
LEA
LEV
LNB
MACT
electrostatic precipitator
aerosol coefficients
Federal Advisory Committee Act
flue gas desulfurization
flue gas recirculation
Federal implementation plan
Federal Motor Vehicle Control Program
Grand Canyon Visibility Transport Commission
gross domestic product
Gross State Product
industrial, commercial, and institutional
Industrial Source Complex Short Term
inspection/maintenance
ignition timing retardation
lowest achievable emission rate
low excess air
low emission vehicle
low-NOj burner
maximum achievable control technology
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MSA
metropolitan statistical area
NAAQS
national ambient air quality standards
NAMS
National Air Monitoring Stations
NAPAP
National Acid Precipitation Assessent Program
NEI
National Emissions Inventory
nh3
ammonia
NSR
New Source Review
NGR
natural gas recirculation
N0X
oxides of nitrogen
NPI
National Particulate Inventory
NSCR
non-selective catalytic reduction
NSPS
New Source Performance Standard
OMB
Office of Management and Budget
OMTG
open market trading guidelines
O&M
operating and maintenance
OAQPS
Office of Air Quality Planning and Standards
OFA
overfire air
OMS
Office of Mobile Sources
OXYFIRING
firing of glass furnaces with oxygen-enriched combustion air
PAMS
Photochemical Assessment Monitoring Stations
PM
Particulate Matter
P-V valves
pressure-vacuum valves
RACT
reasonably available control technology
RADM
RegionalAcid Deposition Model
RFA
Regulatory Flexibility Analysis
RIA
Regulatory Impact Analysis
RIS
Regulatory Impact Statement
ROM
Regional Oxidant Modeling
RVP
Reid Vapor Pressure
S-R
source-receptor
SBREFA
Small Business Regulatory Enforcement Fairness Act
SCAQMD
South Coast Air Quality Management District
SCR
selective catalytic reduction
SIC
Standard Industrial Classification
SIP
State implementation plan
SLAMS
State and Local Air Monitoring Stations
SNCR
selective non-catalytic reduction
SOA
secondary organic aerosols
SOCMI
Synthetic Organic Chemical Manufacturing Industry
so2
sulfur dioxide
SBA
Small Business Administration
SPMS
special purpose monitors
TAC
total annual costs
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TCI
total capital investment
TSP
total suspended particulate
ULNB
ultra low-NOx burner
UMRA
Unfunded Mandates Reform Act
USD A
U.S. Department of Agriculture
VOC
volatile organic compound
VMT
vehicle miles traveled
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EXECUTIVE SUMMARY FOR OZONE REGULATORY IMPACT ANALYSIS
The Clean Air Act directs the Environmental Protection Agency (EPA) to identify and set
national standards for pollutants which cause adverse effects to public health and the environment.
EPA is also required to review the health and welfare-based standards at least once every five
years to determine whether, based on new research, revisions to the standards are necessary to
continue to protect public health and the environment. Recent scientific evidence indicates that
ground-level ozone not only affects people with impaired respiratory systems (such as
asthmatics), but healthy adults and children as well. The new studies taken into account during
this latest review show health effects at levels below that of the current standard (0.12 ppm, 1-
hour form). In particular, exposure of active children and outdoor workers engaged in moderate
exercise for 6-8 hours may experience several acute effects such as decreased lung function and
acute lung inflammation (which could lead to premature aging of the lung) down to 0.08 ppm.
Recent studies also provide evidence of an association between elevated ozone levels and
increases in hospital admissions; and animal studies indicate repeated exposure to high levels of
ozone for several months can produce permanent structural damage in the lungs. As a result of
the most recent review process, EPA is proposing to revise the primary (health-based) and
secondary (welfare-based) National Ambient Air Quality Standards (NAAQS) for ozone.
Pursuant to Executive Order 12866, this draft Regulatory Impact Analysis (RIA) assesses the
costs, economic impacts, and benefits associated with the implementation of these and alternative
NAAQS for ozone.
In setting the primary air quality standards, EPA's first responsibility under the law is to
select standards that protect public health. In the words of the Clean Air Act, for each criteria
pollutant EPA is required to set a standard that protects public health with "an adequate margin
of safety." As interpreted by the Agency and the courts, this decision is a health-based decision
that specifically is not to be based on cost or other economic considerations. This reliance on
science and prohibition against the consideration of cost does not mean that cost or other
economic considerations are not important or can be ignored. In fact, the Agency believes that
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consideration of cost is an essential decision making tool. However, under the health-based
approach required by the Clean Air Act, the appropriate place for cost and efficiency
considerations is during the development of implementation strategies, strategies that will allow
communities, to meet the health-based standards. Through the development of national emissions
standards for cars, trucks, fuels, large industrial sources and power plants, for example, and
through the development of appropriately tailored state and local implementation plans, the
implementation process is where decisions are made — both nationally and within each community
— affecting how much progress can be made, and what time lines, strategies and polices make the
most sense.
In summary, this draft RIA and associated analyses are intended to generally inform the
public about the potential costs and benefits that may result when the proposed revisions to the
ozone NAAQS are implemented by the States, but are not relevant to establishing the standards
themselves.
General Limitations of this Analysis
The consideration of cost and, to be more specific, the use of cost-benefit analyses,
provides a structured means of evaluating and comparing various implementation policies, as well
as a means of comparing the variety of tools and technologies available for air pollution control
efforts. The Agency has found the use of such analyses to be of significant value in developing
regulatory options over the years.
General limitations, however, continue to affect the accuracy of cost-benefit analyses. For
example, wide ranges of uncertainties often exist within an analysis, especially within studies of
national scope involving forecasts over extended periods of time. Analyses, and therefore results,
continue to be limited by the inability to monetize certain health or welfare benefits - such as
protection against loss of lung function, or ecosystem damage. Comparisons of such incomplete
benefits to the more quantifiable and usually more complete control costs can be misleading. In
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addition, though pollution control costs are generally more quantifiable, those costs may be
overstated for many reasons: regulated entities concerned about such costs often overstate their
cost projections to support their position; a belief by some analysts that conservative planning
requires over-estimation; or an inability to forecast significant improvements in the cost-
effectiveness of pollution control that generally occur over analytical periods of five to ten years.
Cost-benefit analyses also often notably fail to deal with distributional issues, (i.e. to
provide for the consideration of equity among those who would receive benefits and those on
whom the costs would fall). For example, while the direct costs of proposed controls may fall on
large industrial sources, costs are often passed on to a large customer base, or to a broader
community base. Therefore, while the costs per family may be small, the benefits to those who
avoid respiratory problems or death may be large. Further analysis is necessary to fully
understand these effects.
These limitations notwithstanding, the process of developing such analyses can still
provide useful insights for those working to develop implementation strategies because the
analytical framework provides an evaluation, however roughly, of strategies or tools against a
common yardstick. For example, this economic analysis provides estimates concerning possible
cost impacts for certain industrial categories. Tailored regional strategies would likely serve to
mitigate negative impacts on local industries. Finally, these analyses can help to identify existing
data gaps, additional information needs, and tools and limitations inherent in certain strategies.
Within these kinds of practical problems lie the general difficulty associated with cost-
benefit analyses. By their nature cost-benefit studies must be full of caveats and warnings about
the value of their conclusions. Even the most narrowly focused and rigorous should therefore
clearly not be the sole determinative test, but should instead serve as useful analytical tools.
Unfortunately, the tendency is for such analyses to be referred to in more definitive terms, and for
the conclusions, as uncertain as they may be, to taken out of context. Such conclusions should
clearly not be the case here.
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Specific Limitations of this Analysis
EPA is proposing decisions on the PM and ozone NAAQSs simultaneously. Because
these NAAQSs are separate regulatory decisions, separate RIAs were prepared. However,
significant overlap may exist in both the benefits and costs associated with reducing ozone and
PM concentrations. Some community health studies find associations between both pollutants
and health effects such as lung function changes, increased hospital admissions and increased
mortality. This overlap is due to important commonalities between ozone and PM (primarily
PM2.5) such as 1) similar atmospheric residence times leading to long-range transport; 2) similar
combustion-related source categories that emit gaseous precursors that lead to ozone and PM
formation; and 3) similar atmospheric chemistry driven by the same chemical reactions and
intermediate chemical species which often favor both high ozone and fine particle levels (see 61
F.R. 29719, June 12, 1996 - Advance Notice of Proposed Rulemaking). This RIA employed
existing non-integrated technical models and implementation strategies that were not able to
adequately account for these commonalities.
As a consequence of having prepared separate RIAs for the PM and Ozone NAAQSs, the
sum of the estimated impacts presented in these analyses is likely to overstate the control cost
impacts resulting from joint attainment of both proposed standards. Controls designed to reduce
one pollutant frequently also achieve reductions of the other. Such co-control can be direct or
indirect via air chemistry interactions. Thus, for example, if control measures designed to reduce
PM also achieve significant ozone reductions, the benefits of attaining the proposed PM standard
presented in this analysis may be understated. Similarly, if control measures designed to reduce
ozone also achieve significant PM reductions, the benefits of attaining the proposed ozone
standard may be understated.
Another major limitation which affects the results of this RIA is the assumption of the
current implementation approach from which to measure the cost of attaining the new standards.
The strategies used are limited in part because of our inability to predict the breadth and depth of
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the creative approaches to implementing these new NAAQS, and in part by technical limitations in
modeling capabilities. These limitations, in effect, force costs to be developed based on
compliance strategies that may reflect suboptimal approaches to implementation, and therefore,
those that likely reflect higher potential costs for attaining the new standard. This approach
renders the result specifically useful as an incentive to pursue lower cost options, but is limited as
a helpful indicator of likely costs. EPA has not estimated the increases in effectiveness or
reductions in cost that might result from new implementation strategies.
It is important to recognize here that if new ozone or particulate matter standards are
finalized under the Clean Air Act, the Act allows for substantial new flexibility in the
development of implementation strategies, both for control strategies as well as schedules. To the
extent that it is warranted, the Act allows for an extension of attainment deadlines as well. This
new flexibility may also mean the development of different patterns of designations, and moving
away from the traditional attainment-nonattainment delineations. Thus, cost estimates presented
in this RIA may overstate actual costs and the net benefit estimates presented understate actual
net benefits. However, the CAA would require that States eventually achieve the standards.
Even under the current standards, the Agency has begun to put an emphasis on strategies
that can use the marketplace to reduce costs, utilize national strategies where they make sense,
and that can look to regional and other cooperative approaches — so that we maximize
efficiencies and minimize costs throughout the pollution control system. EPA and a large number
of States are already working in this direction through the Ozone Transport Assessment Group,
through the Ozone Transport Commission in the Northeast and through our own efforts to
encourage market approaches for ozone precursors. We also are working with Western States
through the Grand Canyon Visibility Transport Commission, which is addressing the visibility
impacts of both ozone and particles.
Specific to the new ozone and PM standards, EPA also has established a formal advisory
committee under the Federal Advisory Committee Act. The specific purpose of the broad-based
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stakeholder group is to advise EPA on ways to develop innovative, flexible, practical and cost-
effective implementation strategies, and to advise us directly on transitional strategies as well.
Among the innovative strategies that FACA may consider are the "Cool Cities," "Green
Lights," and "Climate Wise" programs, as well as development of clean fuel fleets and economic
incentive programs (such as California's RECLAIM and EPA's Acid Rain program) to harness
market forces to reduce pollution in the most cost-effective manner possible. FACA also may
consider an integrated control strategy that analyzes control measures jointly (e.g., reformulated
gasoline, low-emission vehicles, and selective catalytic reduction). This integrated control analysis
is expected to result in lower estimated costs. At the present moment, however, the potential
extent of the impact on ambient ozone concentrations (or the cost of attaining alternative
standards) resulting from programs such as these is not clear.
This group has specifically been tasked with consideration of strategies that would allow
the future integration of ozone, PM, and regional haze control programs. This approach is
intended to develop control strategies that recognize the significant overlap and similarities that
exist among these pollutants as mentioned above.
Similarities between ozone and PM clearly provide management opportunities for
optimizing and coordinating monitoring networks, emission inventories and air quality models,
and for creating opportunities for coordinating and minimizing the regulatory burden for sources
that would otherwise be required to comply with separate controls for each of these pollutants.
Significant shortcomings also exist as to the data available for these analyses. Existing
emissions inventories and modeling to date, either on a national scale, or on an aggregated basis,
simply do not provide a sufficient analytical basis from which to draw accurate results.
Projections concerning which areas will be classified as nonattainment can only be developed
through extrapolation from existing ozone data — an imprecise exercise at best — and through the
use of very uncertain modeling exercises. For example, at the time this analysis was begun, the
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best available inventory of VOC and NOx emissions was based on the Interim 1990 inventory,
which requires reporting of only sources greater than one hundred tons per year of VOC or NOx.
Many sources, while contributing to the overall ozone problem, may not have been part of this
analysis' inventory. Shortcomings exist for modeling as well. The Regional Oxidant Model
(ROM) was the best ozone modeling tool available for this RIA. However, the ROM model
applies to a rectangular grid which includes all or part of the thirty seven states in the East.
Predicting ozone concentrations in the West based upon modeled results in the East reduces the
reliability of this RIA's results. The combination of these uncertainties must inevitably provide
uncertain results.
And finally, the nature of these kinds of analyses is that of a snapshot in time. The cost of
implementing these standard revisions in the first few years will mainly be related to planning,
control strategy development and creating state implementation plans. Therefore, we selected a
year more reflective of the implementation of a new standard. The year 2007 was chosen because
most of the mandatory CAAA requirements will have fully taken effect and most areas currently
in violation are required to achieve attainment with the current NAAQS standard by this year.
Therefore, results are based on air quality modeling performed for this single "representative"
year. Multi-year air quality modeling was not feasible because of resource constraints. The
limitations imposed by this snapshot approach are particularly troublesome in this case, primarily
because of two reasons.
First, in terms of developing strategies or technologies, a decade can see many changes.
For example, relative to air pollution control policy, since 1987 we have seen large
scale revisions of the Clean Air Act - including complete rewrites of nonattainment, acid rain and
air toxics policies - the Intermodal Surface Transportation and Efficiency Act, and the Energy
Policy Act. Recently, we have also seen the introduction of utility deregulation at the state and
national level. All of these actions, both together and individually, are having important and, in
some cases, dramatic effects on air pollution control policy.
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In terms of technology, in the last decade we have seen the introduction of three
generations of cleaner gasoline (i.e. low RVP, oxygenated and reformulated fuels), cleaner diesel
fuels, the introduction of cleaner vehicles (such as electric vehicles), dramatic improvements in
scrubber technology for sulfur dioxide controls, the development of replacements for phased-out
CFC's, far more cost-effective ways to control auto tail-pipe emissions and the development of
on-board diagnostic equipment to assure those cleaner standards continue to be met over time.
Second, relative to attainment of national ambient air quality standards, since 1990 alone
we have seen more than half of the areas in violation of the standards for ozone and carbon
monoxide begin to meet the standards, many actually ahead of schedule. Moreover, the costs
associated with many of these efforts are less than was estimated, even as late as 1990.
Therefore, in the case of air pollution control, ten years is a very long time over which to
carry assumptions. Furthermore, a 2007 snapshot does not allow sufficient time for all areas to
reach attainment, even under the current standard. Given the likelihood that new standards will
result in additional time for some areas, it is clear that some areas will not be required to be in
attainment by 2007. This analysis recognizes this by not arbitrarily forcing all areas to reach
attainment of the new standards in 2007 by the use of extreme control measures recognizing that
such extreme measures are unlikely ever to be put in place.
Also, specific to the limitations of this analysis, the additional costs and health benefits of a
separate secondary standard have not been estimated. However, a number of inferences can be
made from the results of the welfare benefits analysis under the full attainment scenarios. For
the proposed standard, monetized benefits from commodity crops of the most stringent secondary
standard incremental to the primary standard are close to zero. This indicates that the proposed
primary standard is binding for those areas where commodity crops are grown (which includes
California). For these areas, there would be no incremental improvements and, therefore, no
additional costs or health benefits. For areas where we do not know if the proposed primary
standard is binding (areas where commodity crops are not grown), the air quality database created
ES-8
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to perform the commodity crops analysis will be used to estimate any additional health benefits.
These benefits are expected to be small because the benefits curves flatten as the air quality
improves marginally. At this time, it is not possible to estimate these costs of emission reductions
necessary to attain the secondary standard because of incomplete emission inventory data in these
areas. However, the Agency will attempt to address these costs in the RIA for the promulgation
of this proposed NAAQS.
The reader should keep all of the above limitations in mind when reviewing and
interpreting the results presented below.
Nature and Sources of Ozone
Ozone is created when its two primary components, volatile organic compounds (VOCs)
and oxides of nitrogen (NOx), combine in the presence of sunlight under specific meteorological
conditions. Because ozone cannot be formed without VOC and NOx, these two classes of
compounds are often referred to as precursors, which are, for the most part, emitted directly into
the atmosphere from a combination of natural and anthropogenic sources. Attempts to decrease
ozone pollution in the United States has been confounded by a number of factors, including the
inherent non-linearity of the photochemical smog mechanism, the contribution of natural
precursor emissions, long range transport of ozone and its precursors (primarily NOx),
meteorological variability, the general lack of essential data (primarily inventory related), and the
limitations of current modeling tools. Based on the review of the scientific criteria and the
recommendations of the external advisors, the EPA is proposing to revise the ozone standard.
Overview of RIA Methodology: Inputs and Assumptions
Due to the long lead time needed to complete certain analyses, this RIA does not directly
analyze the implementation of the proposed ozone primary (an eight hour concentration based
ES-9
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third highest daily maximum .08 ppm form) or secondary standards. Instead, the analyses
presented here provide upper and lower bounds to the expected costs, benefits, and economic
impacts associated with the proposed standard given the implementation of current command-
and-control strategies and other limitations discussed throughout. Two alternative eight hour
forms examined (an eight hour concentration based fifth highest daily maximum .08 ppm form,
referred to in the RIA as the 8H5EX-80 form; and an eight hour concentration based second
highest average daily maximum .08 ppm form, referred to as the 8H1AX-80 form) are used to
bound the estimates of the likely costs of the proposed standard. We also estimated the costs and
benefits of other alternative options presented in the ozone Staff Paper. Figure ES-1 summarizes
the analytical steps used to estimate these benefits and costs of the alternatives analyzed.
FIGURE ES-1
Flowchart of Analytical Steps
Estimate 2007 Emissions
1
Estimate Ambient Ozone Air Quality
1
Determine Nonattainment Areas and Establish VOC and NOx Targets
Estimate Costs
1
Estimate Economic Impacts
As noted earlier, the year 2007 was chosen to provide an appropriate baseline for a period
in which the new standards are being implemented. These analyses have been constructed such
that benefits are estimated incremental to those derived from the combined effects of
implementing both the Clean Air Act Amendments and the current ozone NAAQS as of the year
2007. These analyses provide a "snapshot" of potential benefits and costs of the proposed ozone
Estimate Human Health and Welfare
Benefits
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NAAQS in the context of (1) implementation of CAA requirements between now and 2007, (2)
the effects on air quality that derive from economic and population growth, and (3) the beneficial
effects on air quality that the Agency expects will result from a series of current efforts to provide
regional level strategies to manage the long range transport of NOx. In particular, this RIA
approximates the combined beneficial effects from a number of separate regional efforts by
applying a NOx control strategy similar to the Ozone Transport Region (OTR) Memorandum of
Understanding (MOU), which requires a 0.15 pounds per million BTU cap on utility and fossil
fuel boilers and a 49-State light Emission Vehicle (LEV) program in all of its member States.
Programs such as these would, upon implementation, reduce the effect of long-range transport.
Analyses were conducted for all counties in the contiguous United States. To predict
baseline air quality in the year 2007, emission inventories were developed for 1990 and then
projected to 2007 based upon estimated national population growth and industrial development.
Clean Air Act-mandated controls (e.g., Title IVOC and NOx Reasonably Available Control
Technology, Title II mobile source inspection/maintenance programs, Title III air toxics controls
and Title IV Acid Rain NOx controls) were applied to these inventories to estimate emission
reductions through 2007 as a result of CAA requirements. Predicted 2007 CAA emissions were
entered into an air quality model that relates emission sources to county-level ozone
concentrations. Modeled air quality was used to identify counties predicted to not attain the
alternative ozone standard levels1. We identified nonattainment areas by identifying each county
that was expected to exceed the NAAQS (in accordance with current Agency procedures for
identifying nonattainment areas). The potential costs and economic impacts on affected industry
sectors was then analyzed. County level ozone concentrations fed directly into the benefits
analyses performed in this RIA. Potential health and welfare benefits are estimated from predicted
changes in ozone air quality in monitored as well as unmonitored counties as a result of control
1 For the purposes of this RIA, the term attain or attainment is used to indicate that ozone air quality level
specified by the standard alternative is achieved. Because the analyses in this RIA are based on one-year of air
quality data, they are only estimates of actual attainment because the standard alternatives are specified as 3-
year averages.
ES-11
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strategies applied in the cost analysis. Finally, benefits and costs were compared to examine
questions of economic efficiency.
We applied what we considered a reasonable set of control measures for controlling ozone
under the Clean Air Act. For some counties, the analysis finds that the control measures
identified in the cost analysis would not be sufficient to result in attainment of the alternatives by
2007. This incomplete attainment situation is believed to be in part a byproduct of the analysis
itself. However, there are likely to be be cases in which currently identifiable controls are not
enough to reach attainment of the revised standard by 2007, which is the attainment date for
certain nonattainment areas under the current standard. Control strategies necessary to achieve
attainment of the proposed ozone standard in all areas may be identified in the future. It is also
reasonable to assume that only some areas will be required to attain the standard in the year 2007.
It is possible that some areas will be given additional time to reach attainment, so that attainment
of the standard occurs after 2007. EPA has convened a large group of stakeholders to develop
new PM and ozone NAAQS implementation strategies that may offer States innovative and more
effective approaches to attainment of the ozone NAAQS.
This analysis focuses on the costs, economic impacts, and benefits associated with partial
attainment of alternative ozone standards. All comparisons of benefits and costs are made on a
partial attainment basis. While plausible estimates of full-attainment benefits also are presented,
no credible approach for estimating full-attainment costs could be developed. Nevertheless, an
average cost per ton range of values is presented in conjunction with the emission reductions
necessary to achieve full attainment. This information is presented in the cost chapter for the
purposes of completeness.
Cost and Economic Impact Analyses
Annual control costs (in 1990 dollars) to attain each alternative NAAQS were estimated
for controls installed in 2007 at sources within the identified nonattainment areas. In each area,
ES-12
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control measures came exclusively from within the nonattainment area (within the baseline,
however, regional strategies were applied to all counties, regardless of attainment status because
the ozone problem is driven largely by regional transport for the Eastern U.S.). This RIA assumes
that marginal nonattainment areas will not incur control costs, only administrative costs.
However, it is possible that additional control measures may be needed to achieve some air quality
improvements in some marginal nonattainment areas. The costs associated with achieving the
improvements are likely to be small relative to other costs presented in this RIA. To the extent
that there are control costs associated with these marginal nonattainment areas, the costs
presented in this analysis are understated but are not expected to significantly affect the national
estimates due to the small magnitude of the costs in question. The administrative costs of
implementing the ozone NAAQS has not been estimated in this analysis. However, administrative
costs will be assessed for the part 51 Ozone NAAQS analysis, in fulfillment of Paperwork
Reduction Act requirements.
Annual costs were estimated by applying control measures for the purpose of meeting
emission "targets" identified for each nonattainment area to meet each alternative NAAQS. It is
expected that as the NAAQS is made more stringent (e.g., moving from the current standard to an
8-hour, 5 exceedance standard), the VOC or NOx emission targets decrease. In general, the
estimated targets for each nonattainment area under each of the alternative NAAQS conforms to
this expectation. However, upon review of the data used in this analysis, there are several
important metropolitan areas where the target estimates do not decrease as the stringency of the
alternative standards increase. To the extent that the emission targets are overestimated, the
control costs presented for the affected alternatives are also underestimated (although the
presence of residual nonattainment may result in zero marginal control costs regardless of the
level of the targets). The emission targets will be more closely examined for the RIA for
promulgation of the proposed NAAQS.
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Economic impacts based on these control costs were estimated for the same ozone
NAAQS alternatives. These impacts include a screening analysis providing estimated annual
average cost-to-sales ratios for all affected industries and small entities.
Key Results and Conclusions
• Annual identifiable control costs corresponding to the partial attainment of the two ozone
alternatives which bound the proposed standard range from approximately $0.6 to $2.5
billion per year incremental to the current standard.
• The total number of residual nonattainment areas corresponding to the two ozone
alternatives which bound the proposed standard range between 12 and 24 areas.
• The implication of residual nonattainment is that areas with a VOC or NOx deficit need
more time; new control strategies (e.g., regional controls or economic incentive
programs); and/or new technologies in order to attain the standard.
• Under the control scenario selected, at least one or more establishments (e.g. industrial
plant) in up to 25 to 30 percent of U.S. industries (as defined by 3-digit SIC codes) may
be affected by the chosen alternative as estimated in a screening analysis that calculated
cost-to-sales ratios for each affected industry. Approximately 1/4 of these are estimated
to have cost-to-sales ratios exceeding 3 percent, and therefore may experience potentially
significant impacts. At least one or more small establishments in up to 18 percent of
affected U.S. industries are estimated to have cost-to-sales ratios exceeding 3 percent, and
therefore these small establishments may experience potentially significant impacts.
These results are highly sensitive to the choice of control scenario. Because of the
previously discussed limitations of the implementation strategy used for the analysis, the
results are only useful as guidance for the FACA committee in designing new approaches
to controlling both ozone and PM.
ES-14
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Benefit Analysis
Health and welfare benefits were estimated for attainment of alternative ozone standards.
While ozone and its precursors can be transported large distances, the health benefits of air quality
improvements outside of nonattainment areas (based on controls within those areas) was not
assessed which will lead to an understatement of actual benefits. The change in incidence of
health and welfare effects was estimated for each air quality change scenario as defined by the
2007 baseline and post-attainment air quality distributions. These changes in incidence were then
monetized by multiplying the estimated change in incidence of each endpoint by its associated
dollar value of avoiding an occurrence of an adverse effect. These endpoint-specific benefits were
then summed across all counties to derive an estimate of total benefit. Because there are
categories for which benefits are not quantified or monetized given lack of scientific and economic
data, the benefit estimates presented in this analysis are incomplete.
The benefits in this analysis are estimated only for effects directly related to ozone
exposure. Reduction of ozone also results in reduced effects of ozone precursors (VOC and
NO J and of other toxic substances produced in the photochemical processes that form ozone
(formaldehyde, fine particles). The benefits of the indirect effects, which may be substantial, have
not been quantified. Table ES-1 lists the health and welfare benefit categories that are reasonably
associated with reducing ozone in the atmosphere, specifying those for which sufficient
quantitative information exists to permit benefit calculations.
Monetized benefits for full attainment of each of the ozone alternatives have been
estimated. Implicit within this analysis is the assumption that all counties reach attainment of each
of the standard alternatives. However, the control strategy-cost analysis indicates that some
counties do not reach attainment of the alternative standards given that the control measures
identified in the cost analysis do not sufficiently reduce emissions to achieve attainment in 2007.
Estimates of full attainment benefits are presented to allow an understanding of the scope of
ES-15
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TABLE ES-1: Benefit Categories
Unquantified Benefit Categories
Quantified Benefit Categories
(in numbers of incidences and/or dollars)
Health Benefit Categories
(from a reduction in ozone and related pollutants)
Airway responsiveness
Coughs
Increased susceptibility to respiratory infection
Pain upon deep inhalation
Acute inflammation and respiratory cell damage
Mortality
Premature aging of lungsfchronic respiratory damage
Hospital admissions for all respiratory illnesses
Reduced cancer and adverse attacks from toxic ozone precursors and
Hospital admissions for pneumonia
associated oxidant products
Hospital admissions for chronic obstructive pulmonary disease
Reduced mortality/morbidity from lower fine particle levels
(COPD)
Presence of any of 19 acute respiratory symptoms/ restricted activity
days
Self-reported asthma attacks
Worker productivity
Change in lung function
Lower respiratory symptoms
Welfare Benefit Categories
Ecosystem and vegetation effects in Class I areas (e.g. National Paries)
Increased yields for
Damage to urban ornamentals (e.g., grass, flowers, shrubs, trees)
Commodity crops
Reduced yield of tree seedlings and non-commercial forests
Fruits and vegetables
Damage to ecosystems
Commercial forests
Materials damage
Nitrogen deposition in sensitive nitrogen-saturated coastal estuaries and
ecosystems
Visibility
benefits that would be attributable to alternative standards provided that control strategies to
reach complete attainment can be identified and adopted. Benefit results for partial attainment are
also presented to assure that benefits and costs can be appropriately compared. Estimates of
benefits for hypothetical full attainment in 2007 are also presented to allow an understanding of
the scope of benefits that would be attributable to alternative standards in the event that control
strategies to reach complete attainment are identified and implemented by that date.
ES-16
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Key Results and Conclusions
• Estimated total monetized benefits associated with implementation of the proposed ozone
standard incremental to the current ozone NAAQS are substantial based on the
alternatives which bracket the proposal.
~ Full attainment of the lower bound ozone alternative results in estimated benefits of
between $0.1 and $1.4 billion per year. Annual benefits range between an estimated $0.2
and $2.8 billion for the upper bound alternative under full attainment. Mortality benefits
represent about 90% of the upper bound benefits estimate.
~ Partial attainment of the lower bound ozone alternative results in estimated annual benefits
between $0.1 to $0.6 billion. Partial attainment of the upper bound ozone alternative have
an expected benefit of between $0.1 billion and 1.5 billion per year.
• The major benefit categories that contribute to the quantified benefits include mortality,
hospital admissions, acute respiratory symptoms and welfare effects. In particular,
mortality accounts for the high end of the benefits range estimate. However, this analysis
excludes a number of other benefit categories.
Benefit-Cost Comparison
Comparing benefits and costs provides one framework for evaluating alternative
standards. The economically efficient alternative maximizes net social benefits (i.e., social benefits
minus social costs). Both the Agency and the courts have defined the NAAQS standard setting
decisions, both the initial standard setting and each subsequent review, as health-based decisions
that specifically are not to be based on cost or other economic considerations. Instead, this draft
benefit-cost comparison is intended to generally inform the public about the potential costs and
ES-17
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benefits that may result when the proposed revisions to the Ozone NAAQS are implemented by
the States.
Key Conclusions and Limitations
• Within the uncertainties of these analyses and their underlying assumptions, costs and
benefits of the partial attainment scenario seem to be of similar magnitude for the partial
attainment of the alternatives which bound the proposed approach.
• Firm conclusions about the actual net benefits resulting from the proposed standard should
not be drawn from this analysis because of the uncertainties and incompleteness discussed
throughout this executive summary.
• A number of these non-monetized benefit categories may be significant. If they could be
monetized and added to this analysis, the estimate of the net benefits associated with the
proposed alternative could be positive.
• The scope of this analysis did not allow consideration of flexibility in ozone management.
The Agency expects the implementation portion of this ozone NAAQS review to result in
more flexible control strategies and lower costs. This a second major reason why the cost
estimates presented may overstate actual costs and the net benefit estimates presented may
understate actual net benefits.
• Due to the existence of residual non-attainment, the partial attainment cost estimates
presented understate the actual full cost of attaining the alternative standards. Thus, the
net benefits associated with full attainment cannot be estimated with any degree of
confidence.
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There are benefits from ozone control that could not be monetized in the benefit analysis,
which in turn affect the benefit-cost comparison. Unmonetized benefit categories include:
effects in lung function; unquantified chronic respiratory damage and premature aging of
the lungs, sinusitis and hay fever; increased susceptibility to respiratory infection; and
protection of Class I areas, forests, ornamental plants, mature trees and seedlings, and
ecosystems. Health effects from exposure to toxic air pollutants and reduced mortality
and morbidity from fine particles are also not included. The effect of our inability to
monetize these benefit categories leads to an underestimation of the monetized benefits
presented in this RIA.
Health benefits calculated in this analysis were estimated only within each identified
nonattainment area. However, the reduction of ozone precursor emissions in
nonattainment areas is expected to reduce ambient ozone concentrations outside of the
nonattainment areas due to the transport of air pollution. The effect of not estimating
health benefits outside of the identified nonattainment areas leads to an underestimation of
the monetized benefits presented in this analysis, to the extent that controls in
nonattainment areas or regional or national controls improve air quality in attainment
areas.
The uncertainty associated with the benefit estimates may be significantly greater than the
uncertainty associated with the costs estimates. In particular, the benefit estimates vary
greatly depending on the mortality risk reduction measure. This issue leads to caution in
interpreting this ozone benefit-cost comparison.
There are uncertainties in the adjustment of the benefit calculations to account for residual
nonattainment (labeled as partial attainment).
Comparisons across alternative standards should be made with caution because control
strategies identified do not result in full attainment of the alternatives. As the stringency
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of the standard increases, areas showing residual nonattainment will have a more difficult
time to meet a more stringent standard and the cost of this increasing difficulty is not
included in these estimates.
This analysis only considers the control measure costs. The administrative costs to the
States of activities such as changing their State Implementation Plans are not included in
this analysis. These costs will be included in the analysis. These costs will be included in
the analysis for the implementation phase of these standards.
Under the current implementation strategy, marginal nonattainment areas generally
undertake non-control pollution management efforts (e.g., develop an emissions inventory
and keep it updated). This analysis assumes that these efforts indirectly produce air
quality improvements. To the extent that there are control costs associated with marginal
nonattainment areas, this analysis may underestimate the costs which these areas will
actually incur.
Due to uncertainties associated with the air quality model (which results in an
overestimation of the emission reduction targets), an assumption was made that if an area
could achieve at least 75% of its emission reduction target, it was assumed to potentially
be able to attain the alternative standard. (See the cost chapter for a more complete
discussion of this assumption.)
The costs presented in this analysis represent the control costs of a partial attainment
scenario, given the existence of residual nonattainment. Due to significant uncertainties,
this analysis does not estimate full-attainment costs. However, the cost chapter provides
information on average cost per ton values in conjunction with emission reduction
information for the reader's consideration.
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o The cost and benefit estimates presented in the results do not account for market reactions
to the new alternatives. The cost and benefit estimates represent the direct costs and
benefits but not the true social costs (calculated after market adjustments to price and
output changes, etc.) associated with implementation of the alternatives examined. Social
costs are typically somewhat smaller than direct costs, while social benefits may be greater
or less than direct benefits depending on the specific market adjustments and substitutions
that occur. Because the effect of market reactions was not assessed, indirect costs and
benefits to consumers and producers could not be quantified. It is anticipated that some of
the costs associated with control measures will be borne indirectly by consumers instead of
producers.
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Table ES-2
Comparison of Benefits and Costs
Regional ControlStrategy Baseline1
(Billions of 1990S)
(Estimates are incremental from the current standard)
Alternative
Ozone
NAAQS
Annual Monetized
Benefits
Annual
Costs of
Partial
Attain-
ment
(c)
Annual Net
Benefits of
Partial
Attainment
(b-c)2
Number
of RNA
Areas5
Deficit Tons
in RNA
Areas
(thousands)
Popula-
tion in
RNA
Areas
Full Attain-
ment
(a)
Partial
Attain-
ment
(b)
Current
Standard4
$0.2-$2.7
$0.1 -$0.8
$1.2
$(1.1)-$(0.4)
4
370-562 VOC
ONOx
39 million
Incremental from the Current Standard:
.08 ppm, 8
hour, 4 AX
$0.1 -$1.4
$0 - $0.6
$0.6
$(0.4) - $0
8 areas
102-155 VOC
17-25 NOX
14 million
.08 ppm, 8
hour, 1 AX
$0.2 - $2.8
$0.1 -$1.5
$2.5
$(2.4)-$(1.0)
20 areas
422-642 VOC
73-111 NOX
32 million
1 Includes NOx cap and 49-state LEV.
2 Numbers in () denote negative values.
3 See the Cost Chapter for a more detailed treatment of residual nonattainment
4 The current standard is assumed to be approximately equal to an 8-hour, .09 ppm, 2AX alternative.
Table ES-3
Comparison of Benefits and Costs
Local Control Strategy1 Baseline
(Billions of 1990S)
Alternative
Ozone
NAAQS
Annual Monetized
Benefits
Annual
Costs of
Partial
Attain-
ment
(c)
Annual Net
Benefits of
Partial
Attainment
(b-c)
Number
of RNA
Areas2
Deficit Tons
in RNA Areas
(thousands)
Popula-
tion in
RNA
Areas
Full Attain-
ment
(a)
Partial
Attain-
ment
(b)
Current
Standard
$0.2-$3.3
I
O
$2.3
$(2.2)-$(1.2)
6
506-770 VOC
8-13 NOx
57
million
Incremental from the Current Standard:
.08 ppm, 8
hour, 4 AX
$0.1 -$2.0
i
O
$2.2
$(2.4)-$(1.1)
12 areas
188-285 VOC
36-54 NOx
28
million
.08 ppm, 8
hour, 1 AX
$0.2 - $3.8
$0.1 -$2.1
$6.3
$(6.2)-$(4.2)
37 areas
515-783 VOC
117-178 NOx
53
million
1 This scenario represents a very inefficient approach for meeting the standard. The reader should refer to
the regional control scenario for a better estimate of likely costs.
2 Numbers in () denote negative values.
3 See the Cost Chapter for a more detailed treatment of residual nonattainment
4 The current standard is assumed to be approximately equal to an 3-hour, .09 ppm, 2AX alternative.
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I.
INTRODUCTION, ANALYTICAL SCOPE AND LIMITATIONS
1(A) INTRODUCTION
The Clean Air Act directs the Environmental Protection Agency (EPA) to identify and set
national standards for pollutants which cause adverse effects to public health and the environment.
EPA is also required to review the health and welfare-based standards at least once every five
years to determine whether, based on new research, revisions to the standards are necessary to
continue to protect public health and the environment. Recent scientific evidence indicates that
ground-level ozone not only affects people with impaired respiratory systems (such as
asthmatics), but healthy adults and children as well. The new studies taken into account during
this latest review show health effects at levels below that of the current standard (0.12 ppm, 1-
hour form). In particular, active children and outdoor workers exposed for 6-8 hours of ozone
levels as low as 0.08 ppm may experience several acute effects such as decreased lung function,
acute lung inflammation, and premature aging of the lung. Recent studies also provide evidence
of an association between elevated ozone levels and increases in hospital admissions; and animal
studies indicate repeated exposure to high levels of ozone for several months can produce
permanent structural damage in the lungs. As a result of the most recent review process, EPA
proposing to revise the primary (health-based) and secondary (welfare-based) National Ambient
Air Quality Standards (NAAQS) for ozone. Pursuant to Executive Order 12866, this draft
Regulatory Impact Analysis (RIA) assesses the costs, economic impacts, and benefits associated
with the implementation of these and alternative NAAQS for ozone.
In setting the primary air quality standards, EPA's first responsibility under the law is to
select standards that protect public health. In the words of the Clean Air Act, for each criteria
pollutant EPA is required to set a standard that protects public health with "an adequate margin
of safety." As interpreted by the Agency and the courts, this decision is a health-based decision
that specifically is not to be based on cost or other economic considerations. This reliance on
science and prohibition against the consideration of cost does not mean that cost or other
economic considerations aren't important or can be ignored. In fact, the Agency believes that
consideration of cost is an essential decision making tool. However, under the health-based
approach required by the Clean Air Act, the appropriate place for cost and efficiency
considerations is during the development of implementation strategies, strategies that will allow
communities, to meet the health-based standards. Through the development of national emissions
standards for cars, trucks, fuels, large industrial sources and power plants, for example, and
through the development of appropriately tailored state and local implementation plans, the
implementation process is where decisions are made — both nationally and within each community
— affecting how much progress can be made, and what time lines, strategies and polices make the
most sense.
In other words, this draft RIA and associated analyses are intended to generally inform the
public about the potential costs and benefits that may result when the proposed revisions to the
ozone NAAQS are implemented by the States, but are not relevant to establishing the standards
themselves. Ozone has an adverse effect on plants, animals, and human health. Ozone is created
when its two primary components, volatile organic compounds (VOCs) and oxides of nitrogen
(NOx), combine in the presence of sunlight under specific meteorological conditions. Because
ozone cannot be formed without VOC and NOx, these two classes of compounds are often
-------
referred to as precursors, which are, for the most part, emitted directly into the atmosphere from
a combination of natural and anthropogenic sources. Attempts to decrease ozone pollution in the
United States has been confounded by a number of factors, including the inherent non-linearity of
the photochemical smog mechanism, the contribution of natural precursor emissions, long range
transport of ozone and its precursors (primarily NOx), meteorological variability, the general lack
of essential data (primarily inventory related), and the limitations of current modeling tools.
1(A)(1) TITLE AND DESCRIPTION
This report is titled: The Ozone NAAOS Regulatory Impact Analysis for 40 CFR Part 50
National Ambient Air Quality Standard for Precursors of Ozone, prepared in fulfillment of the
requirements of the Unfunded Mandates Reform Act (UMRA), and Executive Orders (EO)
12291 and 12866. This report was completed according to the guidelines established in the EPA
Guidelines for Implementing the Regulatory Flexibility Act, revised April 1992 by the Office of
Policy, Planning, and Evaluation, Office of Regulatory Management and Evaluation.
The Unfunded Mandated Reform Act of 1995 (P.L. 104-4) )E.O. 12875, Enhancing
Intergovernmental Partnerships, 12/24/94), in Title n, section 201, directs agencies "unless
otherwise prohibited by law [to] assess the effects of Federal regulatory actions on State, local,
and tribal governments, and the private sector. . ." Section 202 of Title II directs agencies to
provide a qualitative and quantitative assessment of the anticipated costs and benefits of a Federal
mandate resulting in annual expenditures of $100 million or more, including the costs and benefits
to State, local, and tribal governments, or the private sector. Since the NAAQS themselves do not
establish any requirements applicable to State, local, and tribal governments, or the private sector,
the Unfunded Mandates Reform Act does not apply. However, the Agency has conducted general
analyses of the potential impacts of control measures the States might adopt to attain the
proposed NAAQS, and has included those analyses in this RIA. Executive Order 12875
"Enhancing the Intergovernmental Partnership" (10/26/93) was also taken into account in the
development of this RIA.
The Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) was
developed to assure that Agencies consider the impacts of their rulemakings on small entities.
Since the NAAQS themselves do not establish any requirements applicable to small entities,
SBREFA does not apply to this rulemaking. However, the Agency has conducted general
analyses of control measures the States might adopt to attain the proposed NAAQS, and has
included those analyses in this RIA.
1(A)(2) SCHEDULES FOR OMB REVIEW
The Agency anticipates this report will be presented as part of a compete package to
OMB in early November 1996. OMB review will proceed through the month of November.
Following OMB review, the Agency anticipates publication of the new ozone NAAQS under 40
CFR part 50 in late November of 1996, with a targeted promulgation time of late June 1997.
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1(B) ANALYTICAL SCOPE
The current development of a new NAAQS for ozone has two separate and distinct
components: the development of the standard itself, which is codified under 40 CFR part 50, and
the development of cost effective implementation strategies to manage that new standard, codified
under 40 CFR part 51. Under ideal circumstances, the schedule of NAAQS development would
permit a single RIA and ICR to determine the overall impact of the combined 40 CFR parts 50
and 51 rulemakings. However, resource and scheduling constraints including the additional time
for Federal Advisory Committee Act (FACA) requirements preclude a unified approach to the
NAAQS analysis. Consequently, the regulatory analysis associated with the development and
implementation of a new ozone standard has been broken into two separate components. This
RIA analyzes the development of a new standard under 40 CFR part 50. By June 1997, a second
RIA and ICR will follow this RIA and will analyze the implementation of that new standard under
40 CFR part 51, scheduled to be proposed in June 1997. Therefore, for the same post-control
ozone concentrations, the results in the present analysis are likely to overstate the actual costs and
understate the actual benefits which derive from the implementation process. While the analysis of
implementation strategies will probably show lower costs and lower levels of residual
nonattainment, the level of uncertainty associated with these results is much higher.
This RIA establishes a baseline air quality in 2007 which incorporates (1) the full
implementation of the Clean Air Act Amendments of 1990 (CAAA), (2) the effects on air quality
that derive from economic and population growth, and (3) the beneficial effects on air quality that
the Agency expects will result from a series of current efforts to provide regional level strategies
to manage the long range transport of NOx. In particular, the thirty-seven Easternmost States
have banded together to form the Ozone Transport Assessment Group (OTAG) \ which is
investigating alternative regional strategies similar to the Ozone Transport Region (OTR)2
Memorandum of Understanding (MOU), which requires a 0.15#/MBtu NOx cap on utility and
fossil fuel boilers and a California styled Light Emission Vehicle (LEV) program in all of its
member States. Such programs would, upon implementation, reduce the affect of long range
ozone precursor transport. Following the application of regional strategies in the East, this
analysis approximated 2007 air quality to identify areas where ozone concentrations above the
standard may remain. The RIA's analytical team applied additional measures to those areas,
following current implementation practices (Section 110 (a) subpart (2) of the Act).
1 The Ozone Transport Assessment Group consists of: Alabama, Arkansas, Connecticut, Delaware, the District
of Columbia, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland,
Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, New Hampshire, New Jersey, New
York, North Carolina, North Dakota, Ohio, Oklahoma, Pennsylvania, Rhode Island, South Carolina, South
Dakota, Tennessee, Texas, Vermont, Virginia, West Virginia, and Wisconsin. Figure VI-8 in Chapter VI of
this RIA displays the OTAG region. See Figure VI-1 for a map of the OTR and OTAG States.
2 The Ozone Transport Region (OTR) contains part or all of eleven States, plus the District of Columbia. The
eleven States are: Maine, Vermont, Connecticut, New Hampshire, Massachusetts, Rhode Island, New York,
New Jersey, Maryland, Pennsylvania, and the northwestern counties of Virginia.
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While the above scenario provides information based on the best approximation of the
expected air quality in 2007, the regional efforts that have been included have not been fully
developed. Although regional strategies represent the current thinking of ozone managers across
the country, there is a chance that these strategies will not be implemented. If that were to
happen, this RIA's air quality estimates for the analytical year would understate the level of
ozone. Therefore, for completeness, the analysis includes a discussion of the costs and benefits
associated each alternative without the imposition of a regional strategy. For convenience in
discussion, the baseline for this analysis will be called the "Regional Control Scenario" (RCS), and
the sensitivity analysis performed without the regional strategies will be called the "Local Control
Scenario" (LCS).
The current primary NAAQS is expressed in a one expected exceedance form, applied on
a site-by-site basis. Since promulgation of the current NAAQS in 1979, a number of concerns
have been raised about the one expected exceedance form, including its stability vis a vis
attainment status; data handling conventions, including procedures for adjusting for missing data;
and the evaluation of air quality on a site-by-site basis rather than some form of averaging across
monitoring sites. Section V.I. of the Staff Paper discusses these issues in detail. While the
adequacy of public health protection remains the foremost consideration in evaluating alternative
forms of the primary standard, CASAC recommended investigation of alternative forms of the
primary standard which may provide added stability in determining attainment status.
Consequently, the Administrator has focused consideration on (1) revising the primary NAAQS to
allow for multiple (up to five) expected exceedances per year, averaged over three years; and (2)
adopting a concentration based statistic, such as the three year average of the nth-highest daily
maximum eight hour average.
After carefully considering the information presented in the Criteria Document and the
Staff Paper, the advice and recommendations of CASAC, and for the reasons discussed in the
ANPR, the Administrator proposes replacing the existing one hour primary standard with an eight
hour, 0.08 ppm primary standard. The proposed 0.08 ppm eight hour standard would be met at an
ambient air quality monitoring site when the three year average of the annual third highest daily
maximum eight hour average ozone concentration is less than 0.08 ppm, subject to data handling
conventions specified in the proposed revisions to Appendix H of 40 CFR part 50.
This RIA examines five standards incremental to the costs, benefits, and economic impacts
associated with applying all necessary and available controls to achieve the current (1H1EX-120)3
standard in 2007. These alternative standards include: an eight hour five exceedance 0.08 ppm
(8H5EX-80) form; an eight hour concentration based fifth highest daily maximum 0.08 ppm
(8H4AX-80) form; an eight hour concentration based second highest average daily maximum 0.08
ppm (8H1AX-80) form; an eight hour 0.09 ppm form set at no more than the third highest
3 The shorthand terms in parentheses are consistent with those used in the Staff Paper (c.f., Figure V-7, p. 92).
The first term in the shorthand, XH, refers to the number of hours used for averaging ozone concentrations. The
next term, YAX or YEX, indicates two things: the " Y" term indicates the number of occurrences greater than
the proposed level which can take place before triggering nonattainment; the "A" indicates the standard
employs a concentration based averaging of the highest daily maximum ozone concentrations, and the "E"
indicates the standard employs an expected exceedance form, similar to that which is being used by the current
standard. The last term indicates the level of the standard in part per billion.
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average daily maximum ozone concentration; and an eight hour 0.07 ppm form set at no more
than the fifth highest average daily maximum ozone concentration. While numerous other
alternatives were examined by the Agency and CASAC. the Agency believes the set of standards
chosen for analysis provides sufficient range for RIA purposes. The three eight hour 0.08 ppm
alternatives analyzed by this RIA allow for comparisons between alternative forms of the standard
at the same level and between different exceedance levels within the same form of the standard.
While a complete examination of the 0.09 ppm and the 0.07 ppm alternatives may have provided
some additional insight, resource constraints precluded the analysis of additional alternative
standards. However, the staff analyzed existing monitored data against each of the five alternative
standards and has concluded that, for analytical purposes: (1) the 0.09 ppm alternative is similar
to the current 1H1EX-120 standard, and (2) the 0.07 ppm alternative provides a level of
protection similar to the 8H1AX-80 form. This RIA does not directly analyze the proposed ozone
primary standard. Instead, it provides upper and lower bounds to the expected costs, benefits, and
economic impacts associated with the proposed standard, given the implementation of current
command-and-control strategies. This RIA also discusses one alternative form of the ozone
secondary standard.
The remainder of this chapter discusses the analytical limitations which surround this RIA.
Chapter II discusses the background of the ozone NAAQS and the need for regulatory action.
Chapter HI discusses the alternatives examined in this RIA as well as a discussion of regulatory
alternatives not taken. This RIA's methodology can be found in chapters IV and V, and Chapter
VI discusses the projected costs and scope of each alternative NAAQS. Chapters VII and VIE
provide an overview of potential economic impacts which could be derived by each alternative
standard, given the implementation of current command-and-control strategies. Chapter EX
describes the health and welfare benefits of each alternative standard under the framework of this
analysis' limitations. The chapter presents benefits for full attainment, as well as for a level of
attainment which approximates the level of control available within this analysis. Chapter X brings
the benefits and costs discussions together for comparison.
1(C) LIMITATIONS OF SEGREGATED ANALYSES FOR THE OZONE AND
PARTICULATE MATTER NAAQS
Concurrent with the review of the ozone NAAQS, the Agency is also reviewing the
NAAQS for PM. There are many similarities between these two pollutants. Ideally, the RIA
would have conducted its economic analysis taking this jointness into account. However, since
each NAAQS review is a separate regulatory decision, the health effects and scientific information
for each pollutant need to be judged separately and on their own merits. Furthermore, the Agency
is in the process of developing the scientific tools and models needed to assess the interactions of
these pollutants.
Concurrent with the review of these two NAAQS, EPA has requested the assistance of
stakeholder groups to help design a new implementation approach to controlling PM and ozone.
This stakeholder group has been charged to evaluate new approaches to controlling these
pollutants, focusing on the interaction of these pollutants in the atmosphere. As part of this
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process, EPA will strive to perform an integrated analysis for the proposal of the implementation
package in June 1997. A more fully integrated analysis will be available in subsequent stages of
the implementation process. The reasons for doing an integrated analysis follow.
While not all attributes of ozone and PM are linked, important commonalities exist
between ozone and PM which provide the technical and scientific rationale for integrated analysis.
Similarities in pollutant sources, formation, and control exist between ozone and PM, in particular
with respect to the fine fraction of particles addressed by the current PMNAAQS. These
similarities include.
(1) atmospheric residence times of several days, leading to regional-scale transport of the
pollutants,
(2) similar gaseous precursors, including NOx and VOC, which contribute to the formation of
both ozone and PM in the atmosphere,
(3) similar combustion-related source categories, such as utilities, industrial boilers, and
mobile sources, which emit particles directly as well as gaseous precursors of particles
(e.g., S02, NOx, VOC) and ozone (e.g., NOx, VOC), and
(4) similar atmospheric chemistry driven by the same chemical reactions and intermediate
chemical species which often favor both high ozone and fine particle levels.
These similarities provide opportunities for optimizing technical analysis tools (Le.,
monitoring networks, emission inventories, air quality models) and integrated emission reduction
strategies to yield important co-benefits across various air quality management programs.
Integration could result in a net reduction of the regulatory burden on some source category
sectors that would otherwise be impacted separately by ozone, PM, and visibility protection
control strategies. However, it is not possible at this time to perform a fully integrated benefit-cost
analysis. Among the difficulties in performing such an integrated analysis are: the significant
differences in methodologies used for the two pollutants (e.g., air quality models); data are not
currently available to assess the atmospheric interactions of these pollutants; and the control cost
estimates presented in each RIA were developed from different bases and, therefore, cannot be
directly compared, attributed to one pollutant or the other, or aggregated. Moreover, efforts to
develop integrated implementation strategies have not been completed.
Separate analyses of the ozone and PM RIAs may cause misinterpretation of the total
benefits, costs, and economic impact estimates from each RIA. For example, control of ozone
precursors (VOC and NOJ could result in reduced PM concentrations via reductions in organic
and nitrate aerosols. Thus, the total benefits associated with ozone precursor controls may include
an indirect component associated with the benefits of reducing adverse effects caused by PM and
the cost savings associated with not having to impose as stringent PM controls as would
otherwise be necessary to meet the PM NAAQS. To the extent that such indirect benefits exist,
the benefit estimates presented in the separate ozone RIA may understate the actual total benefits
accruing from ozone precursor controls. Additionally, the PM RIa may overstate benefits and
costs if PM reductions are achieved through controls intended to reduce ozone. Similarly, ozone
and PM nonattainment areas and air quality management practices overlap, making it difficult to
attribute costs when controls reduce both ozone and PM concentrations. Ozone and PM co-
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control may result in duplication of control cost estimates used in the separate RIAs, resulting in
over- or underestimation of costs depending on the types and numbers of control measures
selected. Table 1-1 lists some common control measures and source categories.
One of the other major limitations which affects the results of this RIA is the assumption
of the current implementation approach to measure the cost of attaining the new standards. The
strategies used are limited in part because of our inability to predict the breadth and depth of the
creative approaches to implementing these new NAAQS, and in part by technical limitations in
modeling capabilities. This limitation, in effect, forces costs to be developed based on compliance
strategies that reflect the suboptimal approaches to implementation, and therefore those that likely
reflect higher potential costs for attaining the new standard. This required approach renders the
result specifically useful as an incentive to pursue lower cost options, but not as a helpful indicator
of likely costs.
It is important to recognize here that if new ozone or particulate standards are finalized
under the Clean Air Act, the Act allows for substantial new flexibility in the development of
implementation strategies, both for control strategies as well as schedules. To the extent that it is
warranted, the Act allows for an extension of attainment deadlines as well. This new flexibility
may also mean the development of different patterns of designations, and moving away from the
traditional attainment-nonattainment delineations.
Even under the current standards, the Agency has begun to put an emphasis on strategies
that can use the marketplace to reduce costs, utilize national strategies where they make sense,
and that can look to regional and other cooperative approaches - so that we maximize
TABLE 1-1
PM-OZONE INTEGRATED CONTROL MEASURES
Control Measure Examples of Applicable Source Cateqorv(ies)
Reformulated gasoline
Highway and rton-road vehicles-gasoline
Reformulated diesd fuel
Highway and non-road vehicles-diesel
Enhanced inspection/maintenance
Highway vehicles-gasoline
Air/fuel adjustment + ignition timing retardation
Internal combustion engines (natural gas)
Low emission vehicles
Highway vehicles-gasoline
Vapor balance (Stage 1)
Service stations (fuel truck unloading)
Selective/non-selective catalytic reduction
Utility, industrial, & commercial-Institutional boilers; gas turbines; nitric
acid mfg.; Internal combustion engines; process heaters; cogeneration;
municipal & medical waste incinerators: iron & steel mills
Low-NO. burners
Utility, industrial, & commercial-institutional boilers; process heaters;
co-generation; residential natural gas; iron & steel mills; cement mfg.
VOC add-ons (incineration, adsorption, condensation, etc.)
Aircraft/marine/paper/misc. surface coating; web offset lithography;
synthetic fiber mfg.; gasoline bulk terminals
Coating reformulation
Wood product/furniture
California Air Resources Board (CARB) best available
retrofit control technology (BARCT) limits/Federal
implementation plan (FIP) rule
Automobile refinishing
Product reformulation
Aerosols
VOC fugitive controls
Petroleum refineries; synthetic organic chemical mfg.
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efficiencies and minimize costs throughout the pollution control system. EPA and a large number
of states are already working in this direction through the Ozone Transport Assessment Group,
through the Ozone Transport Commission in the Northeast and through our own efforts to
encourage market approaches for ozone precursors. We also are working with Western States
through the Grand Canyon Visibility Transport Commission, which is addressing the visibility
impacts of both ozone and particles.
Specific to new standards, EPA also has established a formal advisory committee under
the Federal Advisory Committee Act. The specific purpose of the broad-based stakeholder group
is to advise EPA on ways to develop innovative, flexible, practical and cost-effective
implementation strategies, and to advise us directly on transitional strategies as well.
This group has specifically been tasked with consideration of strategies that would allow
the future integration of ozone, PM, and regional haze control programs. This approach is
intended to develop control strategies that recognize the significant overlap and similarities that
exist among these pollutants as mentioned above.
These similarities clearly provide management opportunities for optimizing and
coordinating monitoring networks, emission inventories and air quality models, creating
opportunities for coordinating and minimizing the regulatory burden for sources that would
otherwise be required to comply with separate controls for each of these pollutants.
Significant shortcomings also exist as to the data available for these analyses. Existing
emissions inventories and modeling to date, either on a national scale, or on an aggregated basis,
simply do not provide a sufficient analytical basis from which to draw accurate results. Projections
concerning which areas will be classified as nonattainment can only be developed through
extrapolation from existing ozone data — an imprecise exercise at best — and through the use of
very uncertain modeling exercises. For example, at the time this analysis was begun, the best
available inventory of VOC and NOx emissions was based on the Aerometric Information
Retrieval System (AIRS) Interim 1990 inventory, which requires reporting of only sources greater
than one hundred tons per year of VOC or NOx. Many sources, while contributing to the overall
ozone problem, do not report to AIRS and, therefore, were not part of this analysis' inventory.
Shortcomings exist for modeling as well. The Regional Oxidant Model (ROM) was the best
ozone modeling tool available for this RIA. However, the ROM model applies to a rectangular
grid which includes all or part of the thirty seven states in the East. Predicting ozone
concentrations in the West based upon modeled results in the East reduces the reliability of this
RIA's results. The combination of these uncertainties must inevitably provide uncertain results.
And finally, the nature of these kind of analyses is that of a snapshot in time. The cost of
implementing these standard revisions in the first few years will mainly be related to planning,
strategy development and creating state implementation plans. Therefore, we selected a year more
reflective of the implementation of a new standard. The year 2007 was chosen because most of
the mandatory CAAA requirements will have fully taken effect and most areas currently in
violation are expected to achieve attainment with the current NAAQS standard by this year.
Analysis results are presented for this single future year because results are based on air quality
modeling performed for a single "representative" year. Multi-year air quality modeling was not
feasible because of resource constraints. Moreover, the snapshot approach simplifies the
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presentation and interpretation of results. The limitations imposed by this snapshot approach are
particularly troublesome in this case, primarily because of two reasons.
First of all, in terms of developing strategies or technologies, a decade can see many
changes. For example, relative to air pollution control policy, since 1987 we have seen large scale
revisions of the Clean Air Act - including complete rewrites of nonattainment, acid rain and air
toxics policies - the Intermodal Surface Transportation and Efficiency Act, and the Energy Policy
Act. Recently, we have also seen the introduction of utility deregualtion at the state and national
level. All of these actions, both together and individually, are having important and, in some cases
dramatic, effects on air quality.
In terms of technology, in the last decade we have seen the introduction of three
generations of cleaner gasoline (i.e. low RVP, oxygenated and reformulated fuels), cleaner diesel
fuels, the introduction of cleaner vehicles (such as electric vehicles), dramatic improvements in
scrubber technology for sulfur dioxide controls, the development of replacements for phased out
CFC's, far more cost-effective ways to control auto tail-pipe emissions and the development of
on-board diagnostic equipment to assure those cleaner standards continue to be met over time.
Relative to attainment of national ambient air quality standards, since 1990 alone we have
seen more than half of the areas in violation of the standards for ozone and carbon monoxide
begin to meet the standards, many actually ahead of schedule. Moreover, the costs associated
with many of these efforts are less than was estimated, even as late as 1990.
Therefore, in the case of air pollution control, ten years is a very long time over which to
carry assumptions. Furthermore, a 2007 snapshot does not allow sufficient time for all areas to
reach attainment, even under the current standard. Given the likelihood that new standards will
result in additional time for some areas, it is clear that some areas will not be required to be in
attainment by 2007. This analysis recognizes this by not arbitrarily forcing all areas to reach
attainment in 2007 by the use of extreme control measures recognizing that such extreme
measures are unlikely ever to be put in place. The reader should keep all of the above limitations
in mind when reviewing and interpreting the results presented below.
(D) ANALYTICAL LIMITATIONS
Presented below are a number of key analytical limitations. They are not presented in any
particular order, nor is any relative ranking of importance or impact to be implied.
Flexibility: Except for the provision for regional NOx controls in the Eastern United
States, this RIA does not take into account any potential changes to the implementation process
which might provide market based or other flexible programs to States, nonattainment areas, or
sources. These are considerations which have been left for the 40 CFR part 51 analysis.
Consequently, this analysis concentrates on alternative forms and levels of die primary and
secondary ozone standard under the current implementation paradigm set out in subpart (2).
Therefore, the results found in this RIA will be (a) incomplete, due to the problem of residual
nonattainment, and (b) more burdensome than the final results, once the 40 CFR part 51
implementation process has been completed. Because the reported costs of this RIA do not
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capture all the costs of full attainment, the first restriction causes this analysis to understate the
true costs of attaining any given standard. The second forces the analysis to artificially
overestimate the true regulatory impact of the proposed ozone standard. This is due to the
restrictive nature of the subpart (2) requirements which form the basis of implementation for the
proposed alternative NAAQS.
In the 40 CFR part 51 RIA, several subpart (2) implementation requirements specific to
the current standard will be dropped, allowing for economic creativity and flexibility in how the
Agency approaches management of the new standard. EPA expects these changes will reduce the
cost of available reductions, increase the amount of ozone removed, and decrease the size and
number of residual nonattainment areas. However, until the completion of the implementation
stage of the ozone NAAQS, the results of this RIA should be considered only an intermediate step
in the overall NAAQS development process.
Modeling Limitations: With respect to the part 50 ozone NAAQS analysis, several
significant shortcomings in the data must be identified. First, the ozone management process
within the EPA is made up of a series of independent but interrelated components. Each of these
components follows its own procedures for the gathering, verification, and dissemination of data
(emissions inventories, source inventories, monitoring data, etc.) often times resulting in data
incompatibility. The following is a list of the major considerations the RIA team identified for this
analysis. For many of these issues, we anticipate performing sensitivity analyses to determine the
relevant ranges of uncertainty embodied by each. However, these sensitivity analyses will be
deferred until the second half of this NAAQS analysis when the part 51 implementation effects
can be more accurately defined.
The Interim 1990 Inventory and the 2007 Base Case Inventory: (1) Bureau of Economic
Analysis (BEA) Growth Factors: Emissions for stationary (point and area) non-solvent non-
utility sources for 1990 and 2007 were projected from the 1985 National Acidic Precipitation
Assessment Project (NAPAP) Inventory using BEA growth factors. Consequently, emissions for
some sources could be either over or underestimated depending on how accurate the BEA growth
factors reflect changes in source emissions over time. In addition, BEA factors may not accurately
reflect growth in nonattainment areas. BEA factors may be a good surrogate for state-level
emissions but not for estimating growth on an individual point source level.
(2) Emission Factors: For many of the stationary source categories in the inventory,
emission factors have been updated since 1990. These changes may significantly change emission
estimates for some source categories. In general, the NAPAP area source inventory utilized a top-
down approach by multiplying an activity indicator by an emission factor and then allocating
emissions from the national to the county level. The direction and magnitude of this cannot be
determined within the scope of this RIA.
(3) Area Source Inventory Limitations: The area source inventory accounts for emissions
not included in the point source inventory. However, area sources are harder to identify than point
sources and their estimation emissions contains a high degree of uncertainty. Most emission
estimates for this RIA were derived from demographic data. For example, this RIA estimates
some area source emissions at the national level, utilizing a mass balance approach. This national
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value was then allocated to the county level using County Business Patterns data. Because area
sources are generally small, the overall impact of this caveat will also be small.
(4) Scope of Applicability: Preparation of the 2007 base case scenario for the cost and
economic impact analyses incorporated the effects of control measures that would be
implemented by 2007. The projected coverage for some measures have diverged from their
predicted values since the base case scenario was finalized. For example, the Base Case Inventory
was created when it was generally believed that Pennsylvania would apply some sort of Statewide
reformulated gasoline program. Since that time, the only area that has adopted that measure is
Philadelphia. These divergences operate to both increase and decrease VOC and NOx inventories,
depending on the control measure in question. The magnitude and direction of these divergences
are beyond the scope of this RIA.
(5) Rule Effectiveness: The Agency assumed an eighty percent rule effectiveness (RE) rate
for most stationary VOC sources equipped with an emissions control system. For some areas,
such as Baton Rouge, RE improvements accounted for as much as sixty percent of the available
VOC emission reductions. However, for some source categories, current work on the Compliance
Assurance Monitoring Rule indicates the RE level may actually be ninety percent or higher and
that it varies significantly across control measures. Therefore, estimated reductions from rule
effectiveness improvements may be overstated. Adjusting these RE estimates to accommodate
current information would (1) reduce the baseline ozone concentration for a given area, (2)
reduce the need for and the availability of control measures for ozone management, (3) decrease
marginal costs and benefits in identified nonattainment areas4, and (4) change the number of
residual nonattainment areas. The NAAQS analytical team plans to adjust the rule effectiveness
control measure as a part of its inventory adjustment for the part 51 analysis.
Meteorology: Meteorology affects the predicted air quality in a given area because the
concentration of ozone in the troposphere depends on emissions and meteorology. While the
Regional Oxidant Model (ROM) factors into account both meteorology and emissions when it
develops expected air quality values, it uses the same (1987) meteorology for each scenario,
which causes a significant degree of correlation between any two ROM modeled years, even if
emission levels differ significantly. While this is not necessarily wrong, this treatment of
meteorology should be taken into consideration when interpreting ROM data.
The Regional Oxidant Model: ROM does not model the entire contiguous United States,
It is limited to a roughly rectangular grid formed by 47° and 26° North Latitudes, and 67° and 99°
West Longitudes. While this area encompasses more than three quarters of the area having
monitored ozone exceedances, it cannot be used to predict ozone in the Western United States,
nor is there an analogous emissions based model available which can be used to predict ozone
concentrations in the entire non-ROM domain. Lees important from a cost perspective, crop loss
benefits calculations require the application of a geographically based national ozone model.
Finally, ROM does not model an entire year. Instead, ROM estimates ozone concentrations in just
A However, given the ievel of uncertainty within this analysis, available air quality models may not be sensitive
enough to change in response to changes in VOC inventories due to placing RE reductions in the baseline or
the inventory of available controls. Therefore, the removal of RE VOC reductions from the inventory could
require the application of other controls to take their place. These new controls, by design, would cost more
than the RE reductions.
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the three month period during the summer when ozone concentrations are the highest. While this
is a lesser problem for the cost and economic impact components of this RIA, the effect of this
limitation may be to underestimate benefits throughout the remainder of the year.
Because the ozone NAAQS is a national rule, its national impacts had to be estimated
over an entire year. This meant that either multiple models to predict the ozone concentrations
had to be used, one for the ROM domain and others for the non-ROM domain and the remainder
of the year not predicted by ROM; or a model which would serve as a reasonable predictor of
ozone concentrations for the entire continental United States had to be found.
The Centroid Model: The analysts chose to apply one model across the entire country.
However, the Centroid Model that was chosen has its own limitations, primarily based on the
manner in which it creates its predicted values. The Centroid Model does not use emission
factors. Instead, it is an interpolation model which establishes an ozone concentration value for a
specific location (in this case, the geographic centroid of each county) based upon the observed
concentrations found at the three nearest and surrounding monitors. To establish a link between
observed 1990 monitored data) and expected ozone concentrations in the year 2007, the Centroid
model used ROM predicted baseline emissions to develop monitor estimates for the year 2007. A
full description of the Centroid Model methodology can be found in Chapter IV and the docket.
Since the Centroid Method does not use emissions, it could not be used to directly verify the
effectiveness of the targeted VOC and NOx reductions for a given area. The technical team plans
to perform additional sensitivity runs for the current and proposed standards.
Residual Nonattainment: Under each of the standards examined, some areas may not
reach attainment within the time frame of this analysis. Each analysis embodies a specific level of
residual nonattainment. This level varies between standards such that the end points differ for
each alterative standard. Therefore the measurable costs of each alternative do not necessarily
reflect the true differences in costs between standards. The Staff Paper makes the assumption that
the number of nonattainment counties can be an indicator of the relative equivalence of alternative
primary standards from a risk perspective (c.f., p. A-21, Table A-4). To the extent that this
assumption is true, the most reliable metric in this RIA for evaluating the relative nature of each
alternative is the number of counties affected.
Analytical Endpoints: Residual nonattainment limits comparisons between control
costs and monetized benefits. Given the NAAQS is a national standard, the appropriate measure
of benefits should be full attainment nationwide. While this RIA presents full attainment benefits
as a measure of the proposed NAAQS, there is no scientifically supportable method for
determining the costs of full attainment. Therefore, this analysis understates costs by allowing for
residual nonattainment while overstating monetized benefits when measured at full attainment. To
accommodate this shortfall, this RIA also presents the benefits associated with the change in
ozone associated with partial attainment in residual nonattainment areas. This value, while it
corresponds to the costs of attainment in this analysis, must be viewed within the scope of the
caveats listed here and in the remainder of this RIA.
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Health Benefits Estimation: A significant short-coming of the health benefits analysis is
the inability to quantify and/or monetize many benefit categories. A summary of these categories
is presented in the executive summary as well as the benefits chapter of this RIA. The result of
this short-coming is that the monetized benefit estimates presented in this RIA are an
underestimate of the true benefits expected to result from attainment of the proposed ozone
NAAQS. Compounding this underestimation is the limits of the analysis to only calculate health
benefits associated with ozone reductions occurring in identified nonattainment areas. However,
ozone precursors can be transported over large distances and therefore, emission reductions
occurring inside identified nonattainment areas may reduce ambient ozone concentrations outside
of those areas. Limiting the health benefits estimations to only inside of identified nonattainment
areas leads to an underestimation of the monetized health benefits associated with the proposed
ozone NAAQS. Last, one significant category of uncertainty associated with the health benefits
analysis is the estimation of ozone-induced mortality. This RIA includes recent assessments of
ozone-induced mortality that were not included in the ozone Criteria Document and Staff Paper.
The high estimate of the monetized health benefits presented in this RIA is driven by the mortality
results. Although the Agency recognizes that a high degree of uncertainty exists in the estimation
of ozone-induced mortality, the evidence linking a causal relationship between ozone exposure
and mortality is significant enough in these new studies to warrant inclusion of this category in
this analysis.
Welfare Benefits Monetization: A significant number of welfare benefits categories
remain unmonetized because no direct measure of their values exist! A summary of these
categories is presented in the executive summary as well as in the benefits chapter of this RIA. As
a result of this limitation, the monetized benefit estimates presented in this RIA are
underestimated with respect to the benefits expected to result from attainment of the proposed
ozone NAAQS. In addition, the monetized crop yield loss benefits estimated for partial attainment
of a standard (recognizing residual non-attainment) results in an underestimation of the potential
benefits accrued by a particular standard. Other limitations specific to the analyses of crop yield
loss monetization are: (1) the extrapolation of limited monitored air quality data to national air
quality distributions; (2) the application of exposure-response functions from NCLAN open-top
chamber studies extrapolated to 1990 ambient air exposure patterns and crop production; (3) the
use of alternative non-NCLAN exposure-response functions for a variety of fruits and vegetables
not included in the NCLAN studies; (4) the use of a quadratic rollback methodology to project
the "just attain" air quality distributions without a direct link to an emissions control strategy; and
(5) the use of economic models with inherent uncertainties.
1(E) CAVEAT
This economic analysis provides estimates concerning possible negative cost and
employment impacts for certain industrial categories organized by SIC codes. As is noted in the
relevant sections, these estimates are uncertain for two reasons: 1) They do not take into account
the variety of localized or regional implementation strategies that may follow the setting of new
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standards. Such tailored strategies will likely serve to mitigate negative impacts on local
industries, and 2) They do not account for growth in revenue and employment that also may result
from additional pollution control equipment sales, or from substitutions that will transfer revenue
from one industry to another (e.g., oil to natural gas). Regardless of these uncertainties, however,
these estimates will be useful in guiding implementation activities, for they serve to pinpoint
efforts to mitigate potential negative economic impacts.
1(F) REFERENCES
U.S. Environmental Protection Agency. (1996a) Air quality criteria for ozone and related
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos. EPA/600/P-
93/004aF-cF.
U.S. Environmental Protection Agency. (1996b) Review of the national ambient air quality
standards for ozone: assessment of scientific and technical information. OAQPS Staff
Paper . Research Triangle Park, NC: Office of Air Quality Planning and Standards; EPA
report no. EPA/4521R-96-007. Available from NTIS, Springfield, VA; PB96-203435.
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n.
STATEMENT OF NEED FOR THE PROPOSED REGULATION
n(A) INTRODUCTION
Congress passed the Clean Air Act to protect public health and the environment from the
adverse effects of air pollution. This section briefly describes the need for regulation due to the
nature of ozone pollution and summarizes the statutory requirements affecting the development
and revision of the ozone NAAQS. The current development of a new NAAQS for ozone has two
separate and distinct components: the development of the standard itself, codified under 40 CFR
part 50; and the development of cost-effective implementation strategies to achieve the new
standard, codified under 40 CFR part 51. Normally, the process of NAAQS development would
be handled as a single entity, with only one RIA to determine the combined impacts of parts 50
and 51. However, resource constraints and FACA requirements within the Agency resulted in two
separate phases. The phase which is assessed in this RIA pertains to the development of a new
standard under part 50. The second phase, which pertains to the implementation of the new
standard under part 51, will be analyzed in a separate RIA.
n(B) BACKGROUND
H(B)(1) LEGISLATIVE REQUIREMENTS AND JUDICIAL REQUIREMENTS
Two sections of the Clean Air Act (Act) govern establishment and revision of NAAQS.
Section 108 (42 U.S.C. 7408) directs the Administrator to identify pollutants which "may
reasonably be anticipated to endanger public health and welfare" and to issue air quality criteria
for them. These air quality criteria are intended to "accurately reflect the latest scientific
knowledge useful in indicating the kind and extent of all identifiable effects on public health or
welfare which may be expected from the presence of [a] pollutant in the ambient air...
Section 109 (42 U.S.C. 7409) directs the Administrator to propose and promulgate
"primary" and "secondary" NAAQS for pollutants identified under section 108. Section 109(b)(1)
defines a primary standard as one "the attainment and maintenance of which, in the judgment of
the Administrator, based on the criteria and allowing an adequate margin of safety, [is] requisite
to protect the public health."1 A secondary standard, as defined in section 109(b)(2), must
"specify a level of air quality the attainment and maintenance of which, in the judgment of the
Administrator, based on [the] criteria, is requisite to protect the public welfare from any known or
anticipated adverse effects associated with the presence of [the] pollutant in the ambient air."
Welfare effects as defined in section 302(h) [42 U.S.C. 7602(h)] include, but are not limited to,
"effects on soils, water, crops, vegetation, manmade materials, animals, wildlife, weather, visibility
1 The legislative history of section 109 indicates that a primary standard is to be set at "the maximum
permissible ambient air level . . . which will protect the health of any [sensitive] group of the population,"
and that for this purpose "reference should be made to a representative sample of persons comprising the
sensitive group rather than to a single person in such a group." S. Rep. No. 91-1196, 91st Cong., 2d Sess.
10 (1970). The legislative history specifically identifies bronchial asthmatics as a sensitive group to be
protected. Id.
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and climate, damage to and deterioration of property, and hazards to transportation, as well as
effects on economic values and on personal comfort and well-being."
The U.S. Court of Appeals for the District of Columbia Circuit has held that the "margin
of safety" requirement for primary standards was intended to address uncertainties associated with
inconclusive scientific and technical information available at the time of standard setting. It was
also intended to provide a reasonable degree of protection against hazards that research has not
yet identified. Lead Industries Association v. EPA. 647 F.2d 1130, 1154 (D.C. Cir. 1980), cert,
denied, 101 S. Ct. 621 0980^; American Petroleum Institute v. Costle. 665 F.2d 1176, 1177
(D.C. Cir. 1981), cert, denied, 102 S. Ct. 1737 (1982). Both kinds of uncertainties are
components of the risk associated with pollution at levels below those at which human health
effects can be said to occur with reasonable scientific certainty. Thus, by selecting primary
standards that provide an adequate margin of safety, the Administrator is seeking not only to
prevent pollution levels that have been demonstrated to be harmful but also to prevent lower
pollutant levels that may pose an unacceptable risk of harm, even if the risk is not precisely
identified as to nature or degree.
In selecting a margin of safety, the EPA considers such factors as the nature and severity
of the health effects involved, the size of the sensitive population(s) at risk, and the kind and
degree of the uncertainties that must be addressed. Given that the margin of safety requirement by
definition only comes into play at levels where there is no conclusive showing of adverse effects,
such factors, which involve unknown or only partially quantified risks, have their inherent limits as
guides to action. The selection of a particular approach to providing an adequate margin of safety
is a policy choice left specifically to the Administrator's judgment. Lead Industries Association v.
EPA, supra. 647 F.2d at 1161-62.
Section 109(d)(1) of the Act (enacted in 1977) requires that "not later than December 31,
1980, and at 5-year intervals thereafter, the Administrator shall complete a thorough review of the
criteria published under section 108 and the national ambient air quality standards .. . and shall
make such revisions in such criteria and standards and promulgate such new standards as may be
appropriate . ..Section 109(d)(2) requires that an independent scientific review committee be
appointed and provides that at corresponding intervals the committee "shall complete a review of
the criteria . . . and the national primary and secondary ambient air quality standards . . . and shall
recommend to the Administrator any new . . . standards and revisions of existing criteria and
standards as may be appropriate...
H(B)(2) ESTABLISHMENT OF NAAQS FOR PHOTOCHEMICAL OXIDANTS
On April 30, 1971, the EPA promulgated NAAQS for photochemical oxidants under
section 109 of the Act (36 FR 8186). Identical primary and secondary NAAQS were set at an
hourly average of 0.08 parts per million (ppm) total photochemical oxidants not to be exceeded
more than 1 hr per year. Scientific and technical bases for these NAAQS were provided in the
document, Air Quality Criteria for Photochemical Oxidants (U.S. DHEW, 1970). The primary
standard was based in part on several epidemiology studies conducted in Los Angeles, which
reported a relationship between ambient oxidant levels and aggravation of respiratory disease. The
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secondary standard was based on evidence of acute and chronic vegetation injury and
physiological effects, including growth alterations, reduced yields, and changes in the quality of
plant products (U.S. DHEW, 1970, p. 6-18).
H(B)(3) REVIEW AND REVISION OF NAAQS FOR PHOTOCHEMICAL OXIDANTS
In 1977, the EPA announced (42 FR 20493) that it was reviewing the 1970 Criteria
Document in accordance with section 109(d)(1) of the Act and, in 1978, published a revised
Criteria Document (U.S. EPA, 1978). Based on the revised Criteria Document, EPA published
proposed revisions to the original NAAQS in 1978 (43 FR 16962) and final revisions in 1979 (44
FR 8202). The primary standard was revised from 0.08 ppm to 0.12 ppm; the secondary standard
was set identical to the primary standard; the chemical designation of the standards was changed
from photochemical oxidants to ozone; and the form of the standards was revised from a
deterministic form to a statistical form, which defined attainment of the standards as occurring
when the expected number of days per calendar year with maximum hourly average
concentrations greater than 0.12 ppm is equal to or less than one. The revised standards were
upheld on judicial appeal. American Petroleum Institute v. Costle. supra.
In 1982 (47 FR 11561), the EPA announced plans to revise the 1978 Criteria Document.
In 1983, the EPA announced (48 FR 38009) that review of primary and secondary standards for
ozone had been initiated. The EPA subsequently provided a number of opportunities for public
review and comment on drafts of the Criteria Document and associated Staff Paper (U.S. EPA,
1989). After reviewing the draft Criteria Document in 1985 and 1986, the CASAC sent to the
Administrator a "closure letter" outlining key issues and recommendations indicating that it was
satisfied with the final draft of the 1986 Criteria Document (U.S. EPA, 1986).
Following closure, a number of scientific articles and abstracts were published or accepted
for publication that appeared to be of sufficient importance concerning potential health and
welfare effects of ozone to warrant preparation of a Supplement to the 1986 Criteria Document
(U.S. EPA, 1992). The CASAC, having already reviewed two drafts of the Staff Paper in 1986
and 1987, concluded that sufficient new information existed to recommend incorporation of
relevant new information into a third draft of the Staff Paper.
The CASAC held a public meeting in 1988 to review a draft Supplement and the third
draft Staff Paper. Major issues included the definition of adverse health effects of ozone; the
significance of health studies suggesting that exercising individuals exposed for 6 to 8 hours to
ozone levels at or below 0.12 ppm may experience lung inflammation and transient decreases in
pulmonary function; the possibility that chronic irreversible effects may result from long-term
exposures to elevated levels of ozone; and the importance of analyses indicating that agricultural
crop damage may be better defined by a cumulative seasonal average than by a 1-hr peak level of
ozone. In its closure letter of 1989 (58 FR 13018), the CASAC indicated that the Supplement and
Staff Paper (U.S. EPA, 1989) "provide an adequate scientific basis for the EPA to retain or revise
primary and secondary standards for ozone." With regard to the emerging database on exposures
of 6 hours or more, CASAC concluded that such information could better be considered in the
next review of the ozone NAAQS.
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On October 22, 1991, the American Lung Association (ALA) and other plaintiffs filed suit
under section 304 of the Act to compel the EPA to complete its review of the criteria and
standards for ozone. The U.S. District Court for the Eastern District of New York subsequently
issued an order requiring the Administrator to sign a Federal Register notice announcing its
proposed decision on whether to revise the standards for ozone by August 1, 1992 and to sign a
Federal Register notice announcing EPA's final decision by March 1, 1993.
On August 10, 1992 (57 FR 35542), the EPA published a proposed decision under section
109(d)(1) that revisions to the existing primary and secondary standards were not appropriate at
that time. The notice explained (see 57 FR 35546) that the proposed decision would complete the
EPA's review of information on health and welfare effects of ozone assembled over a 7-year
period and contained in the 1986 Criteria Document and its Supplement. The notice indicated that
the Administrator had not taken into account more recent studies on the health and welfare effects
of ozone because these studies had not been assessed in the 1986 Criteria Document or its
Supplement, nor had they collectively undergone the rigorous, integrative review process
(including CASAC review) necessary to incorporate them into a new criteria document. Because
that process and other necessary steps could not, in EPA's view, be completed in time to meet the
March 1993 deadline for a final decision, the proposed decision was based on EPA's evaluation of
key information published through early 1989, as contained in the 1986 Criteria Document and its
Supplement; the 1989 Staff Paper assessment of the most relevant information in these
documents; and the advice and recommendations of the CASAC as presented both in the
discussion of these documents at public meetings and in the CASAC's 1986 and 1989 closure
letters.
In view of the potential significance of the more recent scientific papers, as well as
ongoing research on the health and welfare effects of ozone, the August 10, 1992 notice also
announced the EPA's intention to proceed as rapidly as possible with the next review of the air
quality criteria and standards for ozone. Shortly thereafter, the EPA's Environmental Criteria and
Assessment Office (ECAO) formally initiated action to update the 1986 Criteria Document and its
Supplement (57 FR 38832).
On March 9, 1993 (58 FR 13008), the EPA published a final decision concluding that
revisions to the current primary and secondary NAAQS for ozone were not appropriate at that
time. Given the potential importance of the new studies and the EPA's continuing concern about
the health and welfare effects of ozone, the March 9, 1993 notice emphasized the Administrator's
intention to complete the next review of the NAAQS as rapidly as possible and, if appropriate, to
propose revisions of the standards at the earliest possible date. The Administrator subsequently
adopted a substantially accelerated schedule for the next review (59 FR 5164).
The ALA sought judicial review of the March 1993 decision under section 307(b) of the
Act. Noting that the Administrator intended to reconsider that decision as rapidly as possible in
light of the more recent scientific information, EPA sought and was subsequently granted a
voluntary remand of ALA's petition for review.
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11(B)(4) CURRENT REVIEW OF OZONE NAAQS
As indicated above, ECAO initiated action to update the air quality criteria document for
ozone in August 1992 (57 FR 38832). A series of peer-review workshops was held on draft
chapters of the revised Criteria Document (CD; U.S. EPA, 1996a) in July 1993 (58 FR 35454)
and September 1993 (59 FR 48063), and a first external review draft was made available for
CAS AC and public review on January 31, 1994 (59 FR 4278).
On November 18, 1993, ECAO and OAQPS discussed with CASAC (58 FR 59034)
EPA's accelerated schedule for completing the ozone NAAQS review, formally published on
February 3, 1994 (59 FR 5164). In December 1993, OAQPS completed an Ozone NAAQS
Development Project Plan, which identified key issues to be addressed in the Staff Paper (U.S.
EPA, 1996b)and the basis for the initial scientific and technical assessments planned to address the
issues. OAQPS also met with a subcommittee of the CASAC in December 1993 (58 FR 59034)
and March 1994 to discuss methodologies used in the exposure and risk assessments summarized
in the Staff Paper.
The CASAC reviewed the first external review draft of the revised CD at a public meeting
held on July 20-21, 1994 and made recommendations for revisions. At a public meeting held on
March 21-22, 1995, the CASAC reviewed a second external review draft of the Criteria
Document and a first external review draft of a portion of the Staff Paper. Following revisions of
both CD and Staff Paper, an external review draft of the entire Staff Paper and Chapter 5 of the
CD were reviewed at a public meeting held on September 19-20, 1995. Following that meeting,
"closure letters" on the draft CD and the primary portion of the draft Staff Paper dated November
28, 1995 and November 30, 1995, were forwarded by the CASAC Chairman to the EPA
Administrator. CASAC reviewed a revised version of the secondary standard portion of the draft
Staff Paper on March 21, 1996, and a closure letter was sent from the CASAC Chairman to the
EPA Administrator on April 4, 1996. The Staff Paper was made available to the public in June
1996 and the CD in July 1996.
1(C) MARKET FAILURES
In the absence of government regulation, market-oriented economic systems typically fail
to prevent elevated levels of pollution in the environment because the environment is a public
good. More specifically, individual sources treat the assimilative capacity of the environment as a
"free good" resource to dispose of unused byproduct emissions. Under these conditions, emitters
of pollutants and pollutant precursors do not internalize the full social cost of damages created by
their own emissions. Ozone damages include increased morbidity and mortality; property damage
from soiling, staining, and corrosion; and productive loss due to decreased worker efficiency, crop
and livestock damage, and increased wear and tear on capital stocks. While subject to limitations
in record keeping and other forms of uncertainty, all of these damages are measurable. In
addition, ozone causes other damages which are much harder, if not impossible, to quantify.
These damages include habitat loss, diminished biodiversity, reductions in aesthetic quality, option
values, and existence values.
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The divergence between the private cost of production and the social cost of production
occurs because the source does not bear the full cost of its activities (market costs plus external
damages). The outcome of the cost divergence is market failure, where as described in this case,
the level of output is such that marginal social benefits are not equal to marginal social cost. The
result is economic inefficiency, or a mis-allocation of society's resources; the polluting activity
(e.g., the release of ozone precursors) occurs at too high a level in comparison to the optimally
efficient situation, thus reducing the potential total benefits to society. Generally, command-and-
control regulatory strategies do not attempt to correct for the divergence between social and
private costs. However, regulatory strategies that do internalize the negative externality may not
result in zero air pollution. Economic efficiency calls for abatement up to the point where
additional abatement would cost more than the additional benefits would be worth to society.
In addition to government regulation, other potential mechanisms may be used to correct
for the negative externality brought about by air pollution. Negotiations or litigation under tort
and common law, in theory, could result in compensation to persons for the damages that they
incur. However, two major obstacles block the correction by the private market for pollution-
based inefficiencies and inequities. The first obstacle is high transaction costs when many people
are affected by many pollution sources, as is typically the case with air pollution problems.
Transaction costs of compensating those adversely affected arise and accumulate because the
current and future injury to each individual must be appraised, the injury must be apportioned to
each source, and damage suits or negotiations must be conducted. In an unregulated market, each
source of precursor emissions and each affected person would have to litigate or negotiate. The
transaction costs would be so high as to probably exceed the benefits of reduced air emissions.
These obstacles suggest the need for another mechanism for solving air pollution problems.
The second obstacle to resolution by the private sector is due to the public good nature of
air resource. There is no mechanism to limit anyone's access to cleaner air, so the benefits of
cleaner air can be enjoyed by individuals whether or not they have paid for them. This is the
classic "free rider" problem. Everyone has an incentive not to contribute resources for litigation or
negotiation, thinking that he or she would freely benefit from the efforts of others. While
regulatory intervention can mitigate the impacts of the types of market failures discussed above,
they generally do not occur without imposing their own costs. Typically, these costs include
administration, enforcement, and the redistribution of resources at all levels. The purpose of this
report is to analyze, identify, and mitigate these regulatory costs.
H(D) THE NATURE OF THE AMBIENT OZONE AIR POLLUTION PROBLEM
Ozone has an adverse effect on human health, plants, and animals. Numerous and diverse
health effects have been linked to ozone exposure in laboratory experiments, including lung
inflammation, effects on lung host defense mechanisms, morphological (lung structure) effects,
respiratory symptoms, pulmonary function decrements, changes in lung biochemistry, and
genotoxicity. Although these effects each have different physiological mechanisms, each effect is
initiated by the preliminary interactions of ozone and ozone reaction products with fluids and
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epithelial cells in the respiratory tract. In addition, scientific literature has demonstrated an
association between ozone exposure and: visible leaf damage, growth reductions and yield loss in
annual crops, growth reductions in tree seedlings and mature trees, and effects that can have
impacts at the forest stand and ecosystem level.
The "public good" characteristic of ambient air causes a failure of the market to promote
an optimal level of air pollution control. The result of this market failure is that human health,
plants, and animals experience adverse effects from elevated levels of ozone. The purpose of this
proposed ozone NAAQS is to mitigate the effects of this market failure in order to provide further
protection of human health, plants, and animals from the effects of ozone exposure.
11(D)(1) HEALTH CONSIDERATIONS
The current primary ozone NAAQS was set in 1979 with a 1-hr averaging time with the
intention of protecting the public against the health effects associated with short-term (one- to
three-hour) and prolonged acute (six- to eight-hour) exposures to ozone. At that time, the health
effects potentially associated with longer-term ozone exposures which were not well documented.
Since 1979, numerous researchers have investigated the health effects associated with short-term
and prolonged acute exposures to ozone. Numerous controlled-exposure studies of human
subjects engaged in activities (e.g., stationary cycling) involving heavy and moderate exertion
provide a basis for quantitative concentration-response relationships between one- and three- hour
ozone exposures and a variety of lung function parameters and respiratory symptoms. In addition,
field and epidemiological studies now provide additional evidence of associations between one-
hour ambient ozone levels and health effects ranging from respiratory symptoms and lung function
decrements to increased hospital admissions for respiratory causes. However, the field and
epidemiological studies have not been analyzed sufficiently as yet to determine whether the
observed effects correlate as well or better with six- to eight-hour exposures as with the one- to
three-hour exposures. In addition to these health effects, daily mortality studies have suggested a
possible association between ambient ozone levels and an increased risk of mortality. More recent
controlled-exposure studies have been conducted providing evidence that the same respiratory
effects (i.e., lung function decrements and respiratory symptoms) occur when human subjects are
exposed to ozone concentrations as low as 0.08 ppm while engaging in activities involving
intermittent, moderate exertion for prolonged exposure periods of six to eight hours. These
effects occur at lower concentrations of ozone and at less severe exertion levels than in the one-
to three-hour exposure studies. Other effects, such as the presence of biochemical indicators of
inflammation and reductions in pulmonary defense mechanisms, potentially leading to increased
susceptibility to infection, have also been reported for prolonged exposures and, in some cases,
for short-term exposures. Although the biological effects reported in laboratory animal studies can
be extrapolated to human health effects only with great uncertainty, a large body of toxicological
evidence exists which suggests that repeated exposures to ozone over periods of months to years
can accelerate aging of the lungs and cause structural damage. The extent to which these effects
might affect the quality of life of the elderly remains uncertain at this time.
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The current one-hour averaging time is judged to adequately address acute health effects
associated with exposures of between one and three hours because these effects typically begin to
occur within the first hour of exposure, during moderate and heavy exertion. On the other hand,
an eight-hour averaging time is judged to be more appropriate for addressing similar health
effects, although of a larger magnitude, associated with six- to eight-hour exposures, since health
effects typically build up over time in moderately exercising subjects, approaching a plateau
somewhat beyond the 6.6 hour exposure periods for which most of the prolonged exposure
studies have been conducted.
11(D)(2) WELFARE CONSIDERATIONS
In the area of welfare effects, especially in terms of agricultural productivity, the Staff
Paper (EPA, 1996b) provides data and methodology for the valuation of damages to crops. In its
review of welfare effects and valuation, the CASAC concluded that although absolute benefit
values are uncertain estimates of crop losses, they provide relative incremental benefits associated
with specific standards. Nevertheless, there are many sources of uncertainties inherent in such
analyses.
Some of the most important caveats and limitations concerning the valuation of crop yield
loss include: (1) the extrapolation of limited monitored air quality data to national air quality
distributions; (2) the application of exposure-response functions from NCLAN open-top chamber
studies extrapolated to 1990 ambient air exposure patterns and crop production; (3) the use of
alternative non-NCLAN exposure-response functions for a variety of fruits and vegetables not
included in the NCLAN studies; (4) the use of a quadratic rollback methodology to project the
"just attain" air quality distributions without a direct link to an emissions control strategy; and (5)
the use of economic models with inherent uncertainties.
H(E) REFERENCES
Johnson, T; Capel, J.; Mozier, J.; McCoy, M. (1996a). Estimation of ozone exposures
experienced by outdoor children in nine urban areas using a probabilistic version of NEM.
Prepared by IT/Air Quality Services for U.S. EPA, OAQPS; Research Triangle Park, NC,
August.
Johnson, T.; Capel, J.; McCoy, M.; Mozier, J. (1996b) Estimation of ozone exposures
experienced by outdoor workers in nine urban areas using a probabilistic version of NEM.
Prepared by IT/Air Quality Services for U.S. EPA, OAQPS; Research Triangle Park, NC,
August.
U.S. Department of Health, Education, and Welfare. (1970) Air quality criteria for
photochemical oxidants. Washington, DC: National Air Pollution Control Administration;
publication no. AP-63. Available from: NTIS, Springfield, VA; PB-190262/BA.
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U.S. Environmental Protection Agency. (1996a) Air quality criteria for ozone and related
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos. EPA/600/P-
93/004aF-cF.
U.S. Environmental Protection Agency. (1996b) Review of the national ambient air quality
standards for ozone: assessment of scientific and technical information. OAQPS Staff
Paper . Research Triangle Park, NC: Office of Air Quality Planning and Standards; EPA
report no. EPA/4521R-96-007. Available from NTIS, Springfield, VA; PB96-203435.
U.S. Environmental Protection Agency. (1992) Summary of selected new information on effects
of ozone on health and vegetation: supplement to 1986 air quality criteria for ozone and
other photochemical oxidants. Research Triangle Park, NC: Office of Health and
Environmental Assessment, Environmental Criteria and Assessment Office; EPA report
no. EPA/600/8-88/105F. Available from: NTIS, Springfield, VA; PB92-235670.
U.S. Environmental Protection Agency. (1989) Review of the national ambient air quality
standards for ozone: assessment of scientific and technical information. OAQPS staff
paper. Research Triangle Park, NC: Office of Air Quality Planning and Standards; EPA
report no. EPA-450/2-92/001. Available from: NTIS, Springfield, VA; PB92-190446.
U.S. Environmental Protection Agency. (1986) Air quality criteria for ozone and other
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos.
EPA-600/8-84-020aF-eF. 5v. Available from: NTIS, Springfield, VA; PB87-142949.
U.S. Environmental Protection Agency. (1978) Air quality criteria for ozone and other
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report no.
EPA-600/8-78-004. Available from: NTIS, Springfield, VA; PB80-124753.
Whitfield, R.G.; Biller, W.F.; Jusko, M.J.; Kesler, J.M. (!996) A probabilistic assessment of health
risks associated with short-term exposure to tropospheric ozone. Report prepared for U.S.
EPA. OAQPS. Argonne National Laboratory; Argonne, IL, August. (For copies, contact
Harvey M. Richmond, U.S. Environmental Protection Agency, OAQPS, MD-15,
Research Triangle Park, N.C. 27711, (919) 541-5271.)
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EI. ALTERNATIVES EXAMINED
IH(A) INTRODUCTION
This RIA examines five standards incremental to the costs, benefits, and economic impacts
associated with applying all necessary and available controls to achieve the current (1H1EX-120)
standard in 2007. These alternative standards include: an eight hour five exceedance 0.08 ppm
(8H5EX-80) form; an eight hour concentration based fifth highest daily maximum 0.08 ppm
(8H4AX-80) form; an eight hour concentration based second highest average daily maximum 0.08
ppm (8H1AX-80) form; an eight hour 0.90 ppm form set at no more than the third highest
average daily maximum ozone concentration; and an eight hour 0.07 ppm form set at no more
than the fifth highest average daily maximum ozone concentration. While numerous other
alternatives were examined by the Agency and CASAC, the set of standards chosen for analysis
provides sufficient range for RIA purposes. While a complete examination of the 0.90 ppm and
the 0.07 ppm alternatives may have provided some additional insight, resource constraints
precluded the analysis of additional alternative standards. However, for analytical purposes, the
0.90 ppm alternative is similar to the current 1H1EX-120 standard, and the 0.07 ppm alternative
provides a level of protection similar to the 8H1 AX-80 form. This RIA does not directly analyze
the proposed ozone primary standard. Instead, it provides upper and lower bounds to the
expected costs, benefits, and economic impacts associated with the proposed standard, given the
implementation of current command-and-control strategies. This RIA also discusses one
alternative form of the ozone secondary standard. The remainder of this chapter provides a
complete description of these seven standards.
ni(B) GENERAL DESIGN OF ALTERNATIVES
In selecting a primary standard for ozone, the Administrator must specify 1) averaging
time, 2) ozone concentration (i.e., level), and 3) form (i.e., the air quality statistic to be used as a
basis for determining compliance with the standard). The one hour averaging time specified in the
current NAAQS was selected primarily on the basis of health effects associated with short-term
(i.e., one to three hour) exposures, with qualitative consideration given to preliminary information
on potential associations with longer exposure periods. Since that selection, substantial new health
effects information has become available which demonstrates associations between a wide range
of health effects and prolonged (i.e., six to eight hour) exposures below the level of the current
one hour standard. Additionally, results from quantitative risk analyses show that attaining a
standard with an eight hour averaging time reduces the risk of experiencing health effects
associated with both one hour and eight hour exposures and an eight hour averaging time is more
directly associated with health effects of concern at lower ozone concentrations than is the one
hour averaging time. Based on the assessment of relevant scientific and technical information in
the Criteria Document (EPA, 1996(a)), the Agency believes the present one-hour standard should
be eliminated and replaced with an eight hour standard. Consequently, the Administrator proposes
the primary ozone standard be expressed by comparing the three year average of the third highest
daily maximum eight hour average ozone concentrations to the proposed level of the standard. An
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area would not be in compliance with the proposed standard when the three year average of the
annual third highest daily maximum eight hour ozone concentration is greater than 0.08 ppm.
m(B)(l) THE CURRENT STANDARD (1H1EX-120)
The test for determining attainment of the current primary ozone standard specifies
that the expected number of days per year on which the level is exceeded is to be less than or
equal to 1.0 (values less than 1.05 rounded down)1, averaged over a three year period, and that
specific adjustments are to be made for missing data. The attainment test specifies the "expected
number" of days with concentrations above 0.12 ppm (i.e., exceedance days) is determined by
calculating the average number of exceedances during the most recent three years, adjusting for
missing monitoring days during the designated ozone season. All sites must meet the standard for
the area to be designated in attainment of the ozone NAAQS.
As noted above, compliance with the ozone NAAQS is judged on the basis of expected
exceedances. However, a simple attainment test that gives comparable results can be performed
using the air quality design value. Given the expected exceedance form of the ozone NAAQS, the
design value for the current standard is defined as "...the concentration with expected number of
exceedances equal to one". In statistical terms, this is known as the characteristic largest value
(CLV): the value which is exceeded once per year on average. With three complete years of data,
a simple tabular estimate of the design value is the fourth highest daily maximum concentration
measured during the three years. If this design value is less than or equal to the level of the
standard, then the standard is attained, since if the design value is reduced to the level of the
NAAQS, there will be three daily maximum concentrations greater than the standard, or one day
per year on average. Similarly, for two years of data the design value is the third largest value, and
the second largest for a single year of data. Ozone air quality modeling used for this RIA is limited
to a single year's worth of modeled data, so this analysis employs the design value methodology
to identify areas of expected nonattainment. Consequently, for the current standard, the single
year's daily maximum ozone concentrations were rank ordered and the second highest expected
concentration became that area's design value.
m(B)(2) ALTERNATIVE 8H5EX-80
This form is computationally the same as the cuirent one hour expected exceedance
standard except that five exceedances of the standard are allowed per year on average. If the
design value for a specific monitor is less than or equal to 85 ppm, the standard is attained. With
three complete years of data, the design value based attainment test compares the sixteenth
1 Due to the Agency's rounding conventions, the standard is actually attained when the expected number of days
per calendar year with maximum hourly average concentrations of 125 ppm is equal to or less than one. This
rounding convention holds for all forms of the standard and throughout this RIA, a reference to any particular
standard should be understood to include this 5 ppm rounding "buffer".
m-2
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highest daily maximum eight hour concentration to the level of the standard (0.08 ppm). In other
words, if the design value is reduced to the level of the NAAQS, there will be fifteen daily
maximum concentrations greater than the standard, or five days per year on average. As with the
current standard, modeling limitations require the use of a single year design value. Consequently,
for analytical purposes, an area does not attain the NAAQS if its sixth largest ozone concentration
is greater than or equal to 85 ppm.
111(B)(3) ALTERNATIVE 8H4AX-80
The 8H4AX-80 primary ozone ambient air quality standard is met at an ambient air quality
monitoring site when the three year average of the annual second highest daily maximum eight
hour ozone concentration is less than or equal to 0.08 ppm. Data completeness requirements for
eight hour forms of the standard also apply.2 The 8H4AX-80 standard is not met when the three
year average of the annual fifth highest daily maximum eight hour ozone concentration is greater
than 85 ppm.
111(B)(4) ALTERNATIVE 8H1AX-80
The average annual second highest daily maximum concentration standard is met at an
ambient air quality monitoring site when the three year average of the annual second-highest daily
maximum eight hour ozone concentration is less than or equal to 85 ppm. The primary standard is
not met (i.e., the site is nonattainment) when the three year average of the annual second highest
daily maximum eight hour ozone concentration is greater than 85 ppm (i.e., the average second
highest average daily maximum concentration is 85 ppm or greater). In terms of design value, the
8H1AX-80 form is analogous to the current standard. The primary standard is not met when the
second highest daily maximum ozone concentration is 85 ppm or greater.
m(B)(5) ALTERNATIVE 8H3AX-90
To fully address the range of the CAS AC recommendations, this RIA established a
concentration based 0.90 ppm form of the eight hour standard such that the number of average
daily maximums which exceeded the standard would result in a standard slightly more protective
than the current standard. Based upon monitored data, the Agency set the number of allowable
average daily maximums greater than a 0.90 ppm standard at three. For analytical purposes, this
RIA determined the affect of the 8H3 AX-90 form of the standard is sufficiently close to that of
2 Data completeness requires that for the three year period at a monitoring site, daily maximum 8-hour average
concentrations must be available for at least 90 percent, on average, of the days during the designated ozone
monitoring season, with a minimum data completeness in any one year of at least 75 percent of the designated
sampling days, provided there is no obvious pattern of missing data on ozone conducive days.
m-3
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the current 1H1EX-120 form of the standard that a separate analysis was not necessary. For this
RIA, the discussion of the current standard should be considered representative of the expected
effects of the 8H3AX-90 form. EPA plans to assess this assumption if warranted by public
comments on the proposal.
111(B)(6) ALTERNATIVE 8H5AX-70
To address the other end of the CAS AC recommended range, and to limit the additional
analysis necessary to do it, the staff established a concentration based 0.07 ppm form of the eight
hour standard such that the number of average daily maximums which exceeded the standard
would approximate the affect expected from the most stringent 0.08 ppm form. Based upon
monitored data, the number of allowable average daily maximums greater than a 0.07 ppm
standard was set at five. Similar to what was established for the 8H3AX-90 form, the staff
determined the affect of the 8H5AX-70 form of the standard is sufficiently close to that of the
current 8H1AX-80 form of the standard that a separate analysis was not necessary. For this RIA,
the discussion of the 8H1 AX-80 standard should be considered representative of the expected
effects of the 8H5AX-70 form.
m(C) THE SECONDARY STANDARD
The Ozone Staff Paper (EPA, 1996(b)) concludes consideration should be given to a new
seasonal standard (in the form of a three month, twelve hour SUM06 index in the range of
approximately 25 to 38 ppm-hours) should the Administrator determine that additional protection
is needed beyond the substantial protection that is estimated to result from any of the
recommended alternative primary standards. This recommendation is based on a substantial data
base linking agricultural crop yield loss to ambient ozone exposures and to a growing scientific
literature on damage to tree seedlings and ecosystems caused by exposures to low concentrations
of ozone. Based on a thorough review of the latest scientific information, the Administrator is
proposing a secondary standard that is identical to the proposed primary ozone NAAQS or the
alternative described above at the 25 ppm-hours level.
m(D) OTHER ALTERNATIVES
Because this RIA deals with the current implementation strategy as defined under title I
section 110(a) subpart 2 of the Act, there is little room for regulatory flexibility. However, within
this RIA, the analysis incorporated some regional control scenarios which approximate the
expected effects from current regional efforts as a second "layer" of baseline controls. However,
the application of regional NOx controls in the Eastern United States does not constitute an
exhaustive application of flexibility to the ozone implementation process. No additional flexibility
m-4
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was considered because subpart (2) restricts the analyst's ability to define nonattainment areas in
terms of area and in the types of regulatory strategies that are applicable.
Based upon the classification of the nonattainment area, subpart (2) requires specific
controls and targeted reductions prior to the area's mandated attainment date. Oftentimes, these
requirements are more costly and less effective than other emission reduction alternatives which
are readily available. Consequently, the analysis performed for this RIA should not be viewed as
the "bottom line" because it does not represent this RIA's expectation of the true impact of the
proposed primary and secondary ozone standards. Instead, this analysis should be considered an
upper bound on the potential costs of the proposed ozone standard. Below, this section of the
RIA discusses several alternative approaches not taken by this RIA and the reason behind those
decisions.
HI(D)(1) NO REGULATION
One alternative to changing the ozone standard would be to maintain the status quo.
However, recent new scientific evidence examined by the Criteria Document and the Staff Paper
indicate the current one hour standard does not provide an adequate level of protection as
required by the Act. Consequently, the Administrator determined that an eight hour 0.08 ppm
ozone standard provides the requisite degree of public health protection. Therefore, given the
requirements of the Act for the Agency to provide an adequate level of public health protection, a
"no action" alternative was not considered a reasonable alternative.
m(D)(2) MARKET ORIENTED APPROACHES
Current Agency efforts for ozone management through the application of market based
mechanisms may be identified in the FACA process, but for the purposes of this RIA, such
flexibility was not a viable consideration. Most economic incentive programs involve either items
outside the scope of this analysis (e.g., taxes and fees) or could not be applied within the
framework of the methodology used (e.g., trading schemes). Consequently, this RIA does not
assess the impacts of such strategies, leaving their analysis until after the FACA committee makes
its recommendations.
IH-5
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ni(E) REFERENCES
U.S. Environmental Protection Agency. (1996a) Air quality criteria for ozone and related
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos. EPA/600/P-
93/004aF-cF.
U.S. Environmental Protection Agency. (1996b) Review of the national ambient air quality
standards for ozone: assessment of scientific and technical information. OAQPS Staff
Paper. Research Triangle Park, NC: Office of Air Quality Planning and Standards; EPA
report no. EPA/4521R-96-007. Available fromNTIS, Springfield, VA; PB96-203435.
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IV. METHODOLOGY: ESTIMATING AIR QUALITY
IV(A) INTRODUCTION
The analytical foundation for this RIA resides in the prediction of air quality in the year
2007. Ozone concentrations are a function of meteorology, precursor emissions, and the air
chemistry that transforms them into ozone. Air chemistry and meteorological considerations are
exogenously determined, which leaves the inventory of precursor emissions as the only
endogenous component of this analysis. The purpose of this chapter is to discuss the process
through which the analytical team identified future VOC and NOx inventories as inputs to the air
quality models that predicted air quality values on a county by county basis for the year 2007.
IV(B) METHODOLOGY FOR DETERMINING THE ANALYTICAL BASE CASE
"Base case" refers to the projected inventories of VOC and NOx control measures
projected to exist in the United States in the analytical base year, 2007,1 beginning with the 1990
interim emissions inventory. Economic growth works to increase the number of emissions sources
over time, and that rate of increase varies between geographic regions, between SIC categories,
and within SIC categories across regions. This section of the RIA discusses the process by which
the staff projected the inventory of available VOC and NOx control measures to the analytical
base year. Control measures, motor vehicle measures, and offsets discussed below in IV(B)(1),
(2) and (3) are a distillation of the information documented in "Ozone NAAOS Review CAA
Base Case Evaluation for 2007 - Draft Final Report" (hereinafter referred to as the "base case
technical support document" or Pechan 1994c). The emissions and cost projections are based on
two to four year-old data. In many cases, the projections have changed significantly since that
time. The Agency plans to use updated estimations in future NAAQS analyses.
IV(B)(1) VOC EMISSIONS AND COST PROJECTIONS
The EPA projected emissions and costs for the control of VOCs by using the Emission
Reduction and Cost Analysis Model for VOC (ERCAM-VOC)2 in conjunction with the Interim
1 2007 was chosen because most of the mandatory CAAA requirements will have taken full effect and most
areas currently in violation are expected to achieve attainment of the cunent NAAQS standard by this year.
2 The Emission Reduction and Cost Analysis Model (ERCAM) was initially developed by E.H. Pechan and
Associates, Inc. under contract to the EPA, for examining the cost and emission impacts of alternative
strategies for reducing NOx and VOC emissions. The model covers ali sectors of ozone season VOC and NOx
emitters including stationary point sources, area sources, and mobile sources.
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1990 Inventory.3 CAA provisions in titles I, II, and HI affect VOC emissions. Table 4-1 shows a
summary of VOC emission reductions and costs by title for projection year 2007.
IV(B)( 1 )(a) TITLE I VOC REDUCTIONS
Consumer and Producer Products: The 1990 CAA Amendments direct EPA to
complete a study of significant VOC emitting products and regulate to Best Achievable Control
levels categories of consumer or commercial products that account for at least 80 percent of VOC
emissions in four prioritized groups. This analysis assumes a 50 percent VOC emission reduction
after all four groups have been regulated, rule effectiveness of 80 percent, and a cost effectiveness
of $2,000 per ton of VOC reduction. This measure is applied to control VOC emissions from
personal products, household products, automotive products, and commercial adhesives.
AIM Coatings: In anticipation of a rulemaking, this analysis estimated 45 percent control
by 2002,4 an 80 percent rule effectiveness, and a cost effectiveness of $2,000 per ton, applied to
emissions from architectural surface coatings, industrial maintenance coatings, and traffic paints.
Stage II Vapor Recovery: Title I of the CAA requires Stage II (at the nozzle) vapor
recovery systems for gasoline dispensing stations in ozone nonattainment areas which have a
designation of serious, severe or extreme. In addition, this analysis models Stage II vapor
recovery across the entire Northeast ozone transport region (OTR) to capture the impact of the
stage II comparability provision of the 1990 Amendments, which requires the OTR to adopt stage
II or measures achieving comparable reductions. This analysis assumes Stage II to be fully
implemented in 1996, assuming size cutoffs of 10,000 gallons of gasoline per month (50,000
gallons for independent small business marketers). The Act prescribes a control device efficiency
of 95 percent. Annual inspections are assumed to bring the overall VOC reduction from Stage II
vapor recovery to 86 percent at a cost of $908 per ton. Stage II vapor recovery reductions are
measured prior to onboard vapor recovery reductions (i.e., from an uncontrolled baseline).
Reasonably Available Control Technology (RACT): Ozone nonattainment areas and
the OTR must install RACT on all major stationary sources. The definition of major source varies
according to the nonattainment severity as follows: moderate or marginal, 100 tpy; serious, 50
tpy; severe, 25 tpy; extreme, 10 tpy; and for the OTR, 50 tpy. Point and area source RACT
controls are described in the base case technical support document. This analysis assumes that all
point source emitters are above the major source size definition. Some Title HI MACT overlaps
with RACT requirements. In these cases, reductions and costs have been attributed to Title HI to
prevent underestimation of emission reductions and costs attributed to RACT. The impact of
3 The Interim 1990 Inventory is not connected to AIRS. It was developed for EPA by E.H. Pechan and
Associates for use in the base case technical support document. For more information, see EPA-454/R-93-
021 a, May 1993: "Regional Interim Emission Inventories (1987-199D, Volume I - Development
Methodologies".
4 Inventory estimates for this source category were established before the AIM coating rule was proposed.
Subsequent information not included in this analysis indicates the level of reduction and the cost per ton
discussed above are probably overstated.
IV-2
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VOC RACT on sources less than 50 tpy is not adequately captured in this RIA because the 1990
Interim Inventory for stationary point sources inventories did not contain emissions for them.
New CTGs: To date, only the Synthetic Organic Chemical Manufacturing Industry
(SOCMI) reactor/distillation CTG has been finalized. Shipbuilding and repair and aerospace
CTGs parallel the MACT standards and are therefore included under Title HI. Alternative control
technique (ACT) guidelines were published in place of the remaining new CTG categories,
including clean-up solvents, volatile organic liquid (VOL) storage tanks, batch processes, web
offset lithography5, plastic parts coating, autobody refinishing, and wood furniture coating6 The
majority of these categories are included under Title HI MACT as well.7 In addition, there is
overlap between the SOCMI HON and SOCMI reactor process rules with source reductions
attributed to the HON rather than the new CTG. Costs and reductions for expected new CTGs
can be found in the base case technical support document. The emission reductions for new CTGs
in Table 4-1 includes those associated with SOCMI Reactor/Distillation, batch processes, and
web offset lithography. Costs and reductions for the other categories are accounted for under
Title HI since there are MACT regulations expected in addition to the new CTGs.
Rate of Progress (ROP): The 1990 CAA Amendments (CAAA) require interim
emission targets to be met in ozone nonattainment areas prior to an area's attainment deadline.
Costs for measures that come on-line after 1996 will already be included within the cost for
mandatory controls in 2007, so progress requirement costs should only reflect the cost of
measures that an area would not otherwise implement. The 1990 Amendments further require
serious, severe, and extreme nonattainment areas to achieve a 3 percent reduction per year until
their attainment deadline. These post-1996 ROP requirements can be met by either VOC or NOx
(or a combination) emission reductions (depending on the results of UAM modeling and targets
chosen for attainment). The hierarchy for choosing ROP measures is:
1) New CTG categories that have been delayed or published as ACTs;
2) Title HI controls scheduled for promulgation in 1997;
3) Stage II vapor recovery (if not already required);
4) Reformulated gasoline (if not already required); and
5) Enhanced I/M (if not already required).
The base case technical support document shows costs for measures not otherwise
implemented by 2007 under CAA requirements. Based on these measures, the incremental
reduction in 2007 due to 1996 ROP requirements is 503 tpd, with an incremental annual cost of
$188 million.
5 For this analysis, web offset lithography costs are zero, due to the availability of recovery credits.
6 The Agency issued a wood furniture CTG earlier in 1996, but it was not available in time for this analysis.
7 The costs and emission reductions for SOCMI reactor/distillation (EPA, 1991b), batch processes (EPA,
1991 c), and web offset lithography (EPA, 1992a) are the only source categories included in this analysis as
new CTGs.
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Point Source VOC Offsets: Point source VOC offsets were modeled by projecting no
growth in emissions after 1996 for moderate, serious, and severe ozone nonattainment areas and
in the OTR. Offsets were measured as the growth that would occur between 1996 and 2007
without the growth constraint. The level of offsets needed is shown in Table 4-1. Once a
nonattainment area is redesignated to attainment, new sources are subject to Prevention of
Significant Deterioration provisions rather than NSR. This may decrease the amount of offsets
required, particularly in less severe nonattainment areas that would be expected to redesignate
earlier. Reductions to achieve offsets come from increasing control on existing sources, plant
closures, or mobile source controls (such as vehicle scrappage programs). Plant closures are
included within the decreases in activity predicted for certain industry categories already
incorporated within the calculation of the required offsets. Measures needed to meet offsets must
be accounted for after measures needed to meet 15 percent ROP requirements since these
measures would already be in an area's SIP and could therefore not be used for offsets.8
Maintenance Plans: During the redesignation process, States must submit maintenance
plans to EPA that show that future precursor emissions will not exceed those in the attainment
inventory. Potential impacts of maintenance were analyzed by examining the emission projections
for each nonattainment area through 2007. Since emissions continued to show a decline, no
further controls were modeled to simulate maintenance plan requirements. Additional controls
may be needed if the levels are not sufficient to reach attainment, but this is covered under the
analysis of the current standard in Chapter V of this RIA as a residual base case ozone problem.
IV(B)(l)(b) TITLE H VOC REDUCTIONS
Spark Ignition Standards: Only Phase I costs are included in this analysis because cost
data were not available for Phase II standards. The EPA estimates a 45 percent VOC reduction in
2007 for this source category at a cost of $213 per ton of reductions. The EPA established the
cost effectiveness of this category as the net present value of the stream of costs between 1990
and 2007 divided by the net present value of the stream of emission reductions. Further
clarification for this category can be found in Attachments A and B of the base case technical
support document.
Recreational Marine Vessels: This analysis estimates overall per-engine VOC
reductions will be 50 percent, with a starting year of 1998 and a 17-year life span for engines.
Therefore, overall reductions in 2007 are estimated at 20 percent with expected fleet turnover at
that time. Since no cost data are available, a generic value of $2,000 per ton is used to represent
annual costs.
8 The NSR emission offset program allows construction of a major new source which emits pollutants in excess
of specified amounts and would contribute to an existing violation of a NAAQS only if that source obtains
equivalent offsetting emission reductions (emission offsets) from existing sources. The CAAA increased the
stringency of offset requirements in ozone nonattainment areas by decreasing the major source size threshold
and increasing the offset ratio. The size threshold for triggering NSR depends on the classification of the ozone
nonattainment area.
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Onboard Vapor Recovery: The rule requires installation of onboard refueling vapor
recovery (ORVR) systems beginning in model year 1998 for light-duty gasoline vehicles (LDGV),
2001 for light-duty gasoline trucks (LDGT) with Gross Vehicle Weight Rating (GVWR) of 6,000
lbs or less (LDGT1), and 2004 for remaining LDGTs (LDGT2). Vehicle refueling emissions are
projected by multiplying forecasted gasoline consumption by MOBILE5a (EPA, 1994b) State
adjusted emission factors (grams per gallon). Cost effectiveness values for this category came
from the Onboard RIA and are based on the 1998 net present value of costs and reductions. The
EPA estimates incremental per vehicle costs for onboard (including production costs, operating
costs, and fuel economy benefits) at $5 per vehicle for all light duty vehicles (EPA, 1993a). This
per vehicle cost was multiplied by the expected annual sales to determine the annual cost in 2007.
Nationwide, cost effectiveness is estimated to be $142 per ton.
IV(B)( 1 )(c) TITLE EI VOC REDUCTIONS (MACT)
MACT standards are expected to reduce VOC emissions because many Hazardous Air
Pollutants (HAPS) are also VOCs. The base technical support document shows the MACT
standards modeled and the associated reductions.9 The percentage reductions are from baseline
(rather than uncontrolled) levels. This analysis assumes that RACT is already part of the baseline
for sources covered by MACT. Many nonattainment areas may already have standards equivalent
to MACT as a result of ozone nonattainment related controls (e.g., RACT, CTGs, State
Implementation Plan [SIP] measures). No attempt is made to distinguish whether these controls
are also classified as RACT or SIP measures in the ozone nonattainment areas. Also, reductions in
nonattainment areas may be overestimated if the SIP requirements are already as stringent as the
MACT standards will be. As shown in Table 4-1, Title HI MACT reductions are estimated to be
almost 1.8 million tpy nationally and approximately 5 .6 thousand tons per day. This analysis
assumes rule effectiveness is 80 percent and rule penetration is 100 percent. Any penetration rates
less than 100 percent were incorporated into the control technology efficiency parameter.10
IV(B)(l)(d) RCRA VOC REDUCTIONS
Hazardous Waste Treatment Storage and Disposal Facilities (TSDFs): Emissions
from TSDFs are regulated through RCRA and will restrict emissions from tanks, containers, and
surface impoundments as well as 90-day accumulation tanks at generators. The Agency expects
the reduction to be approximately 94 percent, at a cost of $191 per ton and 80 percent rule
effectiveness (STAAPA-ALAPCO, 1993).
9 Of the MACT controls in the technical support document, only halogenated solvent cleaners, coke ovens, and
the hazardous organic national NESHAP (HON) are effective in 1996.
10 MACT reductions incorporate "rule penetration" when the MACT standards have provisions which exempt
certain sources and an 80 percent rule effectiveness parameter not included in the MACT RIAs.
IV-5
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TABLE 4-1
VOC EMISSION REDUCTIONS FOR PROJECTED YEAR 2007
Measure
Annual
Reductions
(thousands of
tons)
Ozone
Season *
Title I
Consumer and Commercial Products 570 2.1
AIM Coatings 295 1.1
Stage II Vapor Recovery 149 0.4
RACT" 606 2.3
New CTGs" 64 0.2
Reasonable Further Progress 0.5
Title II
Spark Ignition Standards 606 2.1
Recreational Marine Vessels 95 0.3
Onboard Vapor Recovery *** 277 0.8
Title III
MACT" 1,795 5.6
RCRA
Treatment Storage and Disposal Facilities (TSDFs) 1,741 4.8
Landfills — 119 00
6,317
20.2
TOTAL
* Tons per day
** See Appendix A for a further discussion of each of these VOC categories.
"" The standard specifies a 3 year phase-in at 40 percent in the first model year, 80 percent in the
second, and 100 percent thereafter.
***' 17% of consumer solvent emissions are believed to come from landfill disposal.
Landfills: The EPA expects reduced landfill emissions of 98 percent at a cost of $530
per ton with an 80 percent rule effectiveness. Emissions from landfills are not included in the area
source inventory. The Agency assumes 17 percent of consumer solvent emissions come from
landfill disposal (55 FR24468, 1991).
IV(B)(2) NOx EMISSIONS AND COST PROJECTIONS
NOx emissions and control costs were projected to 2007 for expected CAA controls using
the ERCAM model for NOx (ERCAM-NOx). The model uses the Interim 1990 Inventory as the
basis for projecting emissions and costs. 1990 utility emission estimates are based on EIA Form
767 fuel use data submitted by utilities. This comprised the set of existing units. New utility units
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were then added to this inventory and could be classified as planned 11 and generic 12 units. The
methodology for estimating growth in emissions at existing utility units was based on process-
level (SCC) capacity utilization changes to acknowledge utility units that are not fully utilized in
1990 may be used more extensively in the future. Projection year capacity factors were developed
at the process level based on the average capacity utilization calculated for each unit from 1987
through 1991.13 Utility units of all fuel types were assumed to retire after 65 years of service.
The analysis team used the set of utility NOx control equations listed in the ERCAM-NOx
model documentation to calculate NOx emission reductions costs from electric utilities. This
analysis assumes a rule effectiveness of 100 percent for utility units since continuous emission
monitors are required. If this rate was within 10 percent of the required controlled emission rate,
it was assumed that the controlled emission rate could be achieved by minor operational changes
at no additional cost. Control measures were assigned to each utility unit based on the degree of
operational change necessary for that unit to achieve its required emissions limit. A listing of these
controls can be found in the technical support document (Pechan 1994c).
IV(B)(2)(a) TITLE I NOx REDUCTIONS
Utility RACT Controls: Rates for utility units required to apply RACT controls under
Title I are specified in the NOx Supplement to the Title I General Preamble. These include
emission rate limits for oil- and gas-fired boilers. New units sited in nonattainment areas or the
OTR are subject to more stringent NSR emission limits. Emission rates are summarized in the
technical document (Pechan 1994c) which encompasses controls specified by Title I, Title IV, and
new source performance standard (NSPS) regulations. This RIA assumes any unit affected by
Title I that was already at or below the limit required for that type of unit continued emitting at
that lower rate. RACT was applied to major sources in ozone nonattainment areas and the OTR.
NSR provisions require lowest achievable emission rate (LAER) level controls for new or
modified major stationary source in nonattainment areas and the OTR. Specific LAER
requirements are not listed, but limits of 0.10 lb NOx/MMBtu for coal-fired boilers and 0.05 lb
NOx/MMBtu for oil- or gas-fired boilers were determined for LAER.
Utility NOx Offsets: Nonattainment NSR requires NOx emissions from new units
located in nonattainment areas or the OTR to be offset by emission reductions at other sources
within the same nonattainment area. Emissions from existing units that retired between 1996 and
2007 were subtracted from the offset requirement. The remaining emissions from new units were
offset at a 1-to-l ratio by applying selective catalytic reduction (SCR) controls to existing units
within the nonattainment area or rest-of-State area.
11 A planned unit is one that did not exist in 1990 but was expected to come on-line in the future.
12 Generic units are 'placeholders" created in the utility data base to meet future generation needs not met by
existing or planned units.
13 The process used for calculating these values is discussed in more detail in the ERCAM-NOx model
documentation.
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Units from which offsets would be obtained were selected by ordering the set of existing
units in the given area by decreasing controlled 2007 emissions. An assumed NOx reduction of 80
percent from the application of SCR was applied to each existing unit until the area's offset
requirement was met. The final offset in a given area was taken from the unit with the lowest
emissions that could still provide the necessary reduction. If a nonattainment area did not have
sufficient existing utility emissions to offset all new utility NOx emissions, the shortfall was taken
from the closest nonattainment area to it.
Non-Utility RACT: Title I of the CAAA requires NOx RACT 14 on major sources in
nonattainment areas. In addition, NOx RACT is required throughout the OTR. NOx RACT
controls are to be installed no later than May 21, 1995. In order to model the costs and reductions
associated with this requirement, representative RACT levels were chosen for each source type.
The fraction of emissions above the source size cutoff is equivalent to the penetration rate for a
fuel combustion area source category. The controls developed for point source industrial boilers
were utilized for area sources with the average cost per ton values used to estimate total annual
cost. NSR requirements include provisions for applying LAER to new major sources. This was
modeled as a 95 percent efficiency with a rule effectiveness of 100 percent to simulate the
enhanced monitoring program for all NSR units and top down BACT and LAER constraints.
Costs for LAER were not estimated in this analysis. The costs associated with the offset
provisions of NSR for non-utility point source emitters include the cost of applying more stringent
control to existing units to achieve the necessary offsets.
Non-Utility NOx Offsets: Non-utility point source offsets were modeled by assuming
no point source emission growth occurs after 1996 in moderate, serious, severe, and extreme
ozone nonattainment areas and the OTR. The amount of offsets required was then estimated as
the new source growth between 1996 and the model year. Any negative growth that occurs was
considered a decrease in source activity. While existing source emitters are potentially subject to
the NOx RACT requirements for ozone nonattainment and ozone transport areas, new major
sources were subject to NSR requirements. Any positive growth which occurred after 1996 from
existing non-utility point sources within the OTR or an ozone nonattainment area of moderate,
serious, severe, or extreme classification was subject to the NSR provisions, including provisions
for applying LAER to new major sources, which was modeled as a 95 percent efficiency with a
rule effectiveness of 100 percent. These assumptions were used to simulate the enhanced
monitoring program required for all NSR units and top-down BACT and LAER constraints.
Maintenance Plans: During the redesignation process, States must submit maintenance
plans to EPA that show that future precursor emissions will not exceed those in the attainment
inventory. Whether an area will need to implement controls equivalent to the reductions achieved
through this area source cap depends on the trend in emissions from the remaining source
categories. If the area continues to show declines in motor vehicle and nonroad emissions (due to
control measures which increase in effectiveness over time) or stationary source emissions (due to
14 EPA has defined RACT as the lowest emission limitation that a particular source can meet by the application of
a control technology that is reasonably available, given technological and economic feasibility. RACT control
levels are specified individually by each State.
IV-8
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new MACT initiatives) sufficient to offset any growth in stationary source emissions, then the
area source cap is not needed to demonstrate maintenance.
Table 4-2 shows the NOx reductions resulting from this cap. These reductions are
measured as the difference in 2007 area source emissions with and without this constraint. Since
these caps begin in the attainment year for each area, overall reductions will be highest for
moderate areas (with an attainment deadline of 1996) and zero for severe-17 and extreme areas,
which are not required to attain until 2007 or 2010.
TABLE 4-2
NOx EMISSION REDUCTIONS FOR PROJECTED YEAR 2007
Reductions
(thousands of tons)
Ozone Season *
Measure
Annual
Title 1
Utility RACT / LAER Controls
3,257
9.5
Utility NOx Offsets
70
0.2
Non-Utility RACT / LAER Controls
494
1.4
Non-Utility NOx Offsets
9
0.0
Basic I/M
5
0.0
Enhanced I/M
440
1.3
Title II
Reformulated Gasoline
53
0.0
California Reformulated Gasoline
33
0.1
California LEV Standards
124
0.4
Compression Ignition
498
1.7
Sparte Ignition
(23)
-0.1
Marine Vessels
(2).
0.0
Title IV
Control DeveloDment Technoloav
3.338
9.7
TOTAL
8,296
24.2
tons per day
Basic I/M Programs: The EPA established performance standards and other
requirements for basic and enhanced I/M programs on November 5, 1992, requiring enhanced I/M
programs in serious, severe, or extreme ozone nonattainment areas with urbanized populations of
200,000 or more; CO nonattainment areas with a 12.7 ppm or higher design value and an
urbanized area population of 200,000 or more; and all metropolitan statistical areas with a
population of 100,000 or more in the Northeast OTR.
Costs for basic I/M are based on the regulatory analysis for enhanced I/M. EPA estimates
total per vehicle cost, based on the inspection fee, average repair cost, and the fuel economy
benefit, at $5.70, which was applied to LDGVs, LDGTls, and LDGT2s where basic I/M is
chosen as a control. If basic I/M was selected for projections and the county already has a current
I/M program, then no additional cost was attributed to that area.
Enhanced I/M Programs: The Agency estimated the per vehicle cost for enhanced I/M
to be $6.70, based on a test fee of $9 ($18 per test and a biennial program), an average repair cost
of $14.20 per vehicle, and an average fuel economy benefit of $16.50 per vehicle. In the typical
ozone nonattainment area, adopting an enhanced I/M program reduces passenger car emitted
IV-9
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NOx by 10 to 11 percent vis a vis a base case that includes basic I/M programs. Factors that
affect area-to-area variations in these values include ambient temperatures, fuel characteristics,
and travel speeds. While primarily a NOx management tool, some VOC emission reductions result
from the application of enhanced inspection and maintenance measures. The Agency expects these
VOC reductions to cost $500 per ton reduced. Associated NOx emission reductions are $1,850
per ton. Annual costs are estimated by applying the per vehicle costs to the projected vehicle
registrations for an area.
IV(B)(2)(b) TITLE II VOC AND NOx REDUCTIONS
The EPA expects evaporative VOC emissions to be reduced in future gasoline-powered
cars as new Federal (and California) evaporative test procedures are applied. EPA expects the
initial retail price equivalent increase of about $10 per vehicle to be largely offset by fuel savings
(EPA 1993b). Therefore, the net cost to the consumer is estimated to be $1 for light-duty
vehicles (LDVs), $8 for light-duty trucks (LDTs), and -$13 for heavy-duty vehicles (HDVs).
Emission reductions resulting from the improved evaporative test procedure are estimated using
MOBILE5a. EPA estimates a weighted average cost effectiveness figure of $500 per metric ton
(VOC) or $454 per short ton. Annual costs are estimated using the net vehicle cost and the
estimated sales in the projection year.
Motor vehicle emissions contribute almost 30 percent of 1990 anthropogenic VOC
emissions and 32 percent of NOx emissions (Pechan, Sept. 1994). Therefore, the 1990 Clean Air
Act Amendments targeted motor vehicles for further control of both VOC and NOx. Motor
vehicle related controls result from Title I ozone and CO-related nonattainment provisions as well
as Title n, which specifically addresses mobile sources. This section summarizes the emission
reductions and costs of these motor vehicle measures. Motor vehicle projections were based on
ERCAM-VOC and ERCAM-NOx. Base year VMT was projected to future years based on
national VMT projections from the MOBELE4 Fuel Consumption Model, scaled to metropolitan
areas based on population projections and adjusted to ozone season daily values using temporal
allocation factors. Ozone nonattainment area-specific emission factors were then applied (by
vehicle type and roadway classification) to project future year ozone season daily emissions.
Annual emissions were projected by allocating VMT to a monthly basis and applying State-
specific MOBILE5a15 emission factors based on the monthly temperature and RVP data. Control
options are specified at the county level. VOC and NOx motor vehicle control measures are
documented in the base case technical support document.
Tier I Emission Standards: The emission benefits of the Federal Tier l16 emission
standards in Title II of the CAAA were estimated using the emission factor equations from
15 A complete discussion of mobile source modeling can be found in reference 'User's Guide to MOBILES
(Mobile Source Emission Factor Model)". EPA-AA-AQAB-94-01, MAy 1994.
16 Tier 1 emission standards are: 0.25 g/mile for non-methane organic gases (NM0G)3 and 0.4 g/mile NO,, 3.4
g/mile for CO.
IV-10
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M0BILE5a. Each model year vehicle (or group of model years) has a corresponding emission
factor equation. The differences between estimated Tier 0 (pre-CAA vehicles) and Tier 1 vehicle
emission rates over the expected vehicle lifetime were compared with net present value control
costs to estimate the cost effectiveness of an emission standard. Tier 0 and Tier 1 LDGV emission
factor equations for VOC and NOx are listed in the base case technical support document. EPA
estimates the cost of Federal Tier 1 emission standards will be about $3,700 per ton for VOC
control. This value was estimated using the same $36.75 per vehicle cost figure as above, but the
emission factor equations changed with MOBELE5.
Reformulated Gasoline: EPA estimated the cost of Phase I reformulated gasoline to be
about 4.3 cents per gallon in the summer. Since there is no RVP control in the winter, the
wintertime cost of reformulated gasoline is slightly less than the summertime cost, or
approximately 4.2 cents per gallon. Wintertime reformulated gasoline costs in oxygenated fuel
areas are computed at 2.1 cents per gallon. The Agency estimated Phase II average costs to be
8.6 cents per gallon. (EPA, 1991a)17
California Reformulated Gasoline: California Phase 1 reformulated gasoline standards
mandate limits on RVP, use of deposit control additives, and the elimination of leaded gasoline.
Each of these directives results in higher per-gallon costs of fuels to consumers. The California
Air Resources Board (CARB) estimates the consumer costs of each of these three proposals. The
total cost of California Phase 1 reformulated gasoline is estimated to be no greater than 1.5 cents
per gallon. This is based on summing the maximum cost for RVP incurred annually (0.6 cents per
gallon), the maximum cost for the typical range of deposit control additives (0.5 cents), and the
maximum cost for lead elimination (0 4 cents). California has adopted regulations for Phase 2
reformulated gasoline. Phase 2 costs are significantly higher than those for Phase 1 regulations
and represent an attempt to generate maximum reductions in criteria and toxic pollutants, and in
the mass and reactivity of emissions from gasoline fueled vehicles. Phase 2 gasoline must meet
specified standards for sulfur, benzene, aromatic hydrocarbons, olefin, RVP, oxygen, 90 percent
distillation temperature (T90), and 50 percent distillation temperature (T50). Phase 2 standards
apply in California beginning January 1, 1996. This analysis assumes that California Phase 2
reformulated gasoline will cost an additional 17 cents per gallon.
California LEV Standards: LEV was modeled for only California in the base case
analysis. CARB established four new classes of light and medium-duty vehicles in 1990 with
increasingly stringent emission levels: transitional low emission vehicle (TLEV), LEV, ultra-low
emission vehicle (ULEV), and zero-emission vehicle (ZEV). CARB also established a decreasing
fleet average standard for emissions of nonmethane organic gas (NMOG). Auto manufacturers
can meet the fleet average NMOG standard using any combination of TLEVs, LEVs, ULEVs,
and ZEVs they choose. However, CARB also included a ZEV requirement as part of the LEV
regulations, which was modified in 1996 to provide for introduction of ZEVs into California by
automobile manufacturers but removed specific sales requirements until 2003, where 2 percent of
17 Proposed VOC standards using $5,000 per ton VOC as a lower limit were estimated to cost 6.5 to 8.3 cents
per gallon for 7.5 psi RVP fuel and 8.4 to 10.2 cents per gallon for 6.8 psi RVP fuel. Similar costs for
proposed VOC standards using $10,000 per ton VOC as an upper limit are 7.7 to 10.1 cents and 9.6 to 12
cents per gallon, respectively.
IV-11
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the vehicles produced for sale in California must be zero-emitting vehicles. This percentage
increases to 5 percent in 2001, and to 10 percent in 2003. In 1994, the Ozone Transport
Commission (OTC) voted to recommend that EPA mandate the California LEV program in the
Northeast, and shortly thereafter presented a petition to EPA. OTR LEV was not included in the
base case analysis performed by E.H. Pechan. It was, however, included for the thirty seven
Easternmost United States in the form of the 49-state LEV program for the determination of
baseline air quality for purposes of this RIA. Further discussion of California LEV can be found in
the base case technical support document.
IV(B)(3) REGIONAL NOx MANAGEMENT
This RIA's baseline includes the following:
• Full implementation of current Clean Air Act Amendments of 1990 Amendments. A
discussion of this assumption can be found in the previous section of chapter.
Current implementation techniques mandated under subpart (2) of the Act hold.
The analytical team believes the most appropriate implementation strategy for this RIA
would be the strict application of subpart (2) requirements, leaving any future flexibility to
the analysis performed for the part 51 implementation strategies.
• Implementation of a regional NOx strategy in the East which approximates the
efforts of current regional efforts by OTC and OTAG. Current efforts to address long
range NOx transport issues include the OTR and efforts to expand the OTR requirements
to the thirty seven Eastern United States. While these efforts are not complete, the staff
anticipates their implementation far in advance of the 2007 air quality assessment
undertaken for this RIA. The stafFbelieves that these efforts will be in place in the year
2007, and because they are being undertaken to attain the current ozone NAAQS, they
should be included in the analytical baseline of this RIA.
Current regional modeling efforts affect this RIA's baseline air quality by: (a) significantly
reducing the affect of long range NOx transport in the East, (b) reducing the number of
nonattainment areas under each alternative and the targeted reductions necessary within those that
remain, and (c) reducing the number of residual nonattainment areas under each alternative. For
purposes of identification, this baseline will be referred to in this RIA as the "Regional Control
Scenario" (RCS). However, while these regional analyses are under way at this time, the
strategies they represent are not in place. While the analytical team for this RIA believes these
measures (or other measures with similar effects) represent a truer picture of the anticipated 2007
air quality, there is still a chance these regional efforts will not come to pass. Therefore, this
second baseline, referred to in this RIA as the "Local Control Scenario" (LCS), provides an upper
bound to the anticipated costs of the new ozone NAAQS in the event regional efforts fail to arise
before 2007. LCS results appear at the end of this chapter, behind those of the analytical baseline
(RCS). The only difference between the RCS baseline and the LCS is that under the regional
control strategy, a 0.15# per million BTU NOx cap and a California LEV program are applied to
IV-12
-------
each county in the ROM domain prior to the identification of areas where local ozone controls are
still needed.18
IV(C) THE METHODOLOGY FOR DETERMINING OZONE CONCENTRATIONS IN 2007
"Baseline" refers to the set of hourly predicted ozone concentration values for each
county in the contiguous United States predicted for the year 2007, prior to the imposition of
any controls that may be needed to fully attain a NAAQS within a given nonattainment area.
The baseline ozone concentration includes all regional control measures applied to meet the
current standard. This section discusses the process we employed to create the analytical
baseline, as well as a second baseline for the LCS. The staff used these baselines to identify
eight sets of nonattainment areas, one each for the four alternative standards which were
analyzed directly under the Regional Control Scenario (RCS) and the Local Control Scenario
(LCS).
Monitored ozone concentrations greater than the standard are a necessary condition for
an area to be considered nonattainment. Consequently, an argument can be made that any
future violation of an ozone NAAQS should be based upon the presence of a monitor to record
it. The number of counties with ozone concentrations that exceed the standard is probably
greater than the number of counties for which such exceedances have been monitored.
Therefore, examining only those couaties which contain ozone monitors would understate the
true nature of the ozone problem and the cost of its correction. In addition, ozone precursors
and ozone itself can travel long distances. Consequently, transport is an important
consideration for this analysis. For these reasons, the technical staff determined that, to fully
model the impact of each alternative ozone standard in the year 2007, it would need to model
ozone in every county of the contiguous United States for every hour of the analytical year.
Ideally, we would have used an emissions inventory based model, but the Regional Oxidant
Model (ROM)19, the most sophisticated ozone model available at the time of this analysts,
models only the Eastern United States for a ninety day period during the ozone season.
Other models have been employed for other areas, specifically the Southern Coast of
California, but for the remainder of the country (part or all of the seventeen Westernmost
States,) no ozone models existed. Staff investigated using a "patchwork" approach to ozone
modeling through which ROM would be used to model the Eastern United States, South Coast
18 Statistical inference describes the population but does not address the specific characteristics of the individual
observations within it. Consequently, the reader should keep in mind that the analyses performed within this
RIA do not identify actual nonattainment areas in the analytical year. Instead, the identified counties which
exceed any given standard and the nonattainment areas which come from them should be viewed as
representative of the expected scope of each alternative's nonattainment problem. Given the limitations of the
analyses presented in this and other chapters, the technical staff for this RIA believes that, on average, the
predictions made herein are reasonable. For any given area, the models employed can over or under predict the
true level of any estimation.
19 A discussion of the ROM model can be found in the docket in the documents listed at the end of this chapter.
IV-13
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modeling efforts would be used for the Los Angeles area, and a third model would be
developed to predict ozone concentrations in the Non-Rom-Non-California (NRNC)
remainder. Staff decided such an approach had significant methodological problems, primarily
with respect to aggregation and comparison. While each model would provide estimations of
the ozone concentrations in 2007, there was no guarantee that the predictions would be
comparable. An ozone concentration in one area may or may not be equivalent to the same
modeled value for another area, if the two values were derived by different models. Even if
the problems associated with a patchwork approach could be resolved, these models still would
not have addressed the need for modeling an entire year. This problem was most significant
for the health benefits analysis, where outcomes are more directly linked to the ozone
concentration.
Consequently, the Agency's analysts decided to apply a single modeling methodology
across the entire contiguous United States and use this approach to approximate the expected
ozone concentrations through out the analytical year. Although the model that was chosen has
limitations, the analysts believes that the benefits of having a single comprehensive national
model exceeded these limitations. Based on an analytical foundation of existing monitored data
and ROM predictions for the Eastern United States, we developed an extrapolation technique
(hereinafter called "Centroid") which allowed us to estimate ozone concentrations in every
county in the United States in the year 2007. A more complete discussion of the Centroid
methodology can be found below, and a complete discussion of the Centroid methodology can
be found in the docket (Mathtech, 1996).
IV(C)(1) THE CENTROID METHODOLOGY
The Centroid methodology was based upon three existing data sets: the Aerometric
Information Retrieval System (AIRS) Air Quality Subsystem (AQS) recorded values of actual
ozone concentrations for 1990, and two ROM model runs for air quality. There are 890
monitor records in the 1990 AIRS database, many of which are in the Western United States,
outside the ROM domain. The record for each monitor included the monitor identifier and
8760 hourly ozone concentration values, one observation for each hour in the analytical year.
ROM predictions for 1990 were based upon the 1990 AIRS inventory and 1987 meteorology
for the ozone season, with hourly observations predicted for each ROM gridpoint. For each
ROM gridpoint, the ROM predictions for hourly ozone concentrations in 2007 were based
upon the expected air inventories described above in IV(B), above (plus any adjustments to the
inventory necessary to approximate the effects of regional control measures under the RCS).
The objective of the Centroid methodology was to compare the ROM predicted ozone
concentrations in 1990 and those for our analytical baseline in 2007 to calculate a metric which
could be applied universally to 1990 monitored values to transform them into a prediction of
2007 monitored values across the contiguous Untied States and throughout the analytical year.
To do this, the analysts regressed ROM 1990 predicted values against ROM predicted 2007
values and then applied the coefficients from this regression to the hourly observations in 1990
to predict the average expected change in ozone concentration for those monitors. Once these
IV-14
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data were transformed into hourly predicted ozone concentrations at monitor sites, these hourly
predictions were interpolated to the geographic centroid of each county in the forty eight
contiguous United States. The regression and interpolation processes are described below, in
the remainder of this section.
IV(C)(2) ADJUSTMENTS TO MONITORED DATA
Most of the monitor records in the "AMP350" report of the AQS subsystem of AIRS
had data missing for some hours during the year. For example, many monitor records have the
midnight hour missing. In addition, many locations have a well defined ozone season and
monitors often operate only during this season. No data are available outside of the ozone
season for these monitors. Finally, some monitors occasionally fail to report hourly data,
causing problems in determining 8-hour averages. The staff also discovered that more than one
set of data were sometimes reported from the same site location. Therefore, the EPA
developed a set of criteria and data assumptions to provide a defensible foundation for
compliance analysis based on these monitor data:
Collocated Monitors: Each record had to correspond to a unique monitor. However,
upon examination, it was discovered that seven monitoring sites had two sets of records. The
EPA selected the maximum of the hourly values across the two collocated records.
Data Obsolescence: The analysts compared a list of the latest available 1990 monitor
identifiers used for compliance purposes against the monitor identifiers in the AIRS database.
The AIRS data had eleven monitors that did not exist in the EPA compliance list. These
monitors were dropped from the current list of 1990 compliance monitors because the reported
data was considered not suitable. Six monitors appeared on the compliance list that did not
exist in the AIRS data. Of these six monitors, two were outside the continental United States.
The remaining four monitors were late entries from NAPAP and were discarded for the
present analysis. After adjusting for missing and dropped monitor records, 879 monitors
remained.
Ozone Season Adjustments: Most monitors are not operated for 24 hours a day, 365
days per year. In fact a significant number of monitors are operated only during the ozone
season. EPA reviewed the definitions of ozone seasons, and, with the exception of Indiana,
Michigan and Texas, the ozone season used in the present analysis is the same as the ozone
season used by staff and its contractors. Indiana and Michigan now have ozone seasons which
end a month earlier than the definitions in place in 1988. The shorter Indiana and Michigan
ozone seasons were adopted to be consistent with the present definition. Texas has ozone
seasons which vary across the state from 8 months to the entire year. The ozone season used
for Texas in this analysis was the entire year.
Selection Criteria: In previous analyses, the analysts excluded any monitor without
data for the major portion of a year. To identify modeled nonattainment areas, any monitor
having 90 days' worth of values during the ozone season was included in the analysis, as long
as it reported at least eighteen hours for each day.
IV-15
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Missing Values: In previous ozone benefits analyses, missing monitor hours were
filled-in using the mean of the concentration values for that monitor and hour of the day over
the month which contained the missing value. However, a mean value skews the 8-hour
average concentration. Therefore, the staff employed a different "fill-in" methodology. Rather
than substitute a mean concentration value for a missing hour, the actual concentration value
registered at the nearest monitor was used as the fill-in value, subject to the following
limitations: only the nearest 25 monitors would be considered, and no data was to be
"imported"from a monitor more than 500 miles away from the monitor having a missing data
hour.20 If the two criteria could not be met, then the mean of the concentration values method
was used for that monitor and hour of the day. After testing these assumptions and filling in
for missing data, we observed the following characteristics:
• On average, it took twenty three monitors to completely specify data during the ozone
season,
• The average distance from a monitor to the location of a monitor used to import
missing data was 4.4 miles, and
• On average, the farthest monitor used for filling in missing data was 150 miles from
the monitor with missing data.
IV(C)(3) THE REGRESSION
After completing the data set for each monitor through the processes described above,
the next step was to use these data to predict the ozone concentration for each hour at each
monitor site in the year 2007. To do this, the analysts used an Ordinary Least Squares (OLS)
regression of 1990 ROM predicted concentrations and a number of additional explanatory
variables against ROM predicted ozone concentrations in 2007. This regression allowed the
staff to predict the average expected change in ozone concentrations between 1990 and 2007.
OLS regressions are defined as BLUE - the Best Linear Unbiased Estimator of the
relationship between a dependent variable and its independent variable descriptors. "Best"
refers to the OLS characteristic that no other linear predictor has a lower variance.
Consequently, while the estimates derived through the OLS process have a built in error when
compared to observed values, no other linear model will consistently produce a better estimate
of actual values such that the error term has a lesser variance. "Unbiased" means the OLS
estimator does not carry within it any systematic error. Error terms are normally distributed
with an average value of zero. Therefore, while still an estimator, there is no better linear
20 la the East, observations have a greater variance but sites are closer to each other, which mitigates the
affects of greater variability on predicted results. In the West, where monitors are spread out and counties
are larger, the affects are just the opposite. Western ozone concentrations tend to have a relatively low
variance. Therefore the low variability in monitored values mitigates the affect of a wider distribution of
sites on predicted results.
IV-16
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estimator which could be applied to this analysis. The remainder of this section discussed this
regression.
Functional Form: One of the key limitations of the OLS regression is that it is a
linear program used to predict the photochemistry of ozone creation which constitutes a highly
non-linear system. The staff investigated including quadratic terms within the OLS model to
mitigate this limitation. In sample regressions on subsets of the data, the analysts determined
that although a quadratic term based upon 1990 ROM predicted air quality was statistically
significant, the explanatory power of such a term was minimal. Sample regressions indicated
the coefficient for such a term had a magnitude of approximately 10^, indicating that only for
ozone concentrations in excess of 224 ppm did the coefficient make a difference in the
predicted ozone concentration outside the range of measurement error. Observations with
values equal to or greater than 224 occur only in the worst nonattainment areas, where the
predictive power of the quadratic term would not be needed to identify nonattainment areas. In
addition, sample regressions performed without a quadratic term had coefficients of regression
(R2) above 0.90. Consequently, regressions run with a quadratic term contributed little to the
overall explanatory power of the pure linear functional form. Therefore, this analysis rejected
the inclusion of a quadratic term and applied OLS techniques on only linear terms.
Sample Selection: Data from the 1990 and 2007 ROM hourly predicted grid cell
ozone concentrations were arrayed side by side into a set of over thirty million entries, such
that each 1990 observation matched its 2007 counterpart in grid cell location, time of day, and
date of observation. From this array, we applied a random number generator (LOTUS's
@RAND function) to identify three random sets of numbers, the first for the x coordinate of
the ROM grid cell, the second for the y coordinate of the ROM grid cell, and the third for the
hour of observation. This set of coordinates, (x, y, t) formed the basis upon which the OLS
regression could be performed. Geographically, ROM contains grid cells over water (primarily
the Atlantic, the Gulf of Mexico, and the Great Lakes) and in Canada. Agency analysts culled
the sample to remove these extraneous data elements.
The analysis team considered selecting its sample from a subset of the data such that the
peak ozone concentrations were better represented in the regression. However, the data set
from which the sample was selected had its own inherent bias toward higher ozone levels.
Because the ROM data set covers the ninety day ozone season, one would expect ROM
predicted ozone concentrations to be higher than actual values selected from outside the ozone
season. Consequently, without further restricting the data set from which samples were drawn,
the regression emphasizes higher values by virtue of exclusion. Together with the actual data
available for monitored sites in 1990, the RIA analysts believes the OLS regression is
sufficient to characterize the ozone problem.
IV-17
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TABLE IV-1
REGRESSION EQUATION STATISTICS
(Ordinary Least Squares)
INDEPENDENT
VARIABLES
REGIONAL CONTROL STRATEGY
(7,484 Observations)
LOCAL CONTROL STRATEGY
(1,093 Observations)
COEFFICIENT
T-STATISTIC
COEFFICIENT
T-STATISTIC
Constant
9.4709
6.362
-1.09765
-0.403
ROM90
0.78766
292.809
0.904335
193.696*
MFGPC
0.37046
0.506
1.66716
1.306"
POP07
-2.3576
-2.487
2.47670
1.404 "
SEVR
0.88009
2.941
0.601086
1.255
SERS7
0.39421
1.247
-0.789582
-1.580 '*
MAMD
1.3104
7.088
0.258379
0.748
Adjusted R'
.92
.973
Statistically significant at the one percent level
Statistically significant at the twenty percent level
Model specification: To specify the relationship between 1990 and 2007 ozone
concentrations, this regression includes five additional descriptive variables: MFGPC, POP07,
SEVR, SERS, and MAMD. MFGPC is the growth rate in manufacturing earnings per capita
between 1990 and 2007, determined through Bureau of Economic Analysis (BEA, 1990) data for
the appropriate county. POP07 is the population growth rate for the county, also determined by
data from the Census. SEVR, SERS, and MAMD are three binary variables which record the
subpart (2) nonattainment classification associated with the 1990 ozone concentration for each
county. Each variable records a one if the area would be classified severe, serious, or moderate
and marginal respectively. If not, the variable records a zero.21
In sample runs, the regression revealed the five additional explanatory variables had
little significance and, in several cases, contradicted the a priori expectations of the staffs
experts. The analysts believe the insignificance of these variables arises from the fact that the
ROM model already accommodates these characteristics; but because the regressions will be
used to extrapolate air quality beyond the ROM domain, the five additional descriptive
variables must be retained to account for differences in air quality, especially in non-ROM
counties. The results of the two regressions are listed below in Table IV-1. A more detailed
discussion of the regression can be found in the docket (MathTech, 1996).
Results: The OLS regression resulted in a coefficient of approximately 0.79 for the
1990 ROM-predicted ozone concentrations. Because the coefficient for ROM90 is less than
unity, given the full implementation of the Clean Air Act Amendments of 1990 and the
21 For an area in attainment, all three variables would record a zero. Therefore, each dummy variable can be
interpreted as the marginal change in ozone concentration that can be expected to occur between 1990 and
2007 due to the severity of the area's ozone problem, relative to an area's meeting the standard.
IV-18
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application of a regional NOx program in the East, one can expect ozone concentrations to
decline between now and 2007, everything else held constant.22 In other words, ROM predicts
that for the ROM domain, on average, the rate of decrease in ozone concentrations due to the
imposition of 1990 CAAA requirements will be greater than the rate of increase in ozone
concentrations due to economic growth for that same area. This general conclusion also holds
for the local control scenario sensitivity analysis, reported in the rightmost two columns of
Table IV-1.
The independent variables for growth rate and nonattainment area designation explain
additional variation modeled by ROM between 1990 and 2007. A priori, it is expected that,
everything else held constant, areas with higher growth rates should experience increases in
ozone concentrations between 1990 and 2007. These expectations are sensitive, however, to
the inherent nonlinearities of the ROM model and the particular control strategies being
modeled by ROM. Both these factors contribute to the differences observed in Table IV-1
between the regression results for the two baselines.
Application: Under the assumption that the estimated relationship found in the ROM
domain would hold in the Western United States, the results of the regression analysis were
applied to each monitor by multiplying each hourly monitored value by the appropriate scalar
coefficients. These adjusted hourly values constituted a nation-wide prediction of monitored
ozone concentrations in the year 2007. From the projected monitor values, the analytical team
interpolated ozone concentrations to the geographic centroid of each county through a process
described in the next section of this chapter. This interpolation does not lose any of the data
richness found in the original monitored values. Instead, applying the OLS results to each
observed value resulted in a linear transformation of that value to a 2007 predicted ozone
concentration. Because the transformation was linear and based upon actual monitored values,
the transformation kept the relative magnitudes of each observation.
IV(C)(4) INTERPOLATION TO CENTROID "PROXY" MONITORS
Based on the fill-in methodology described above, the Centroid methodology
establishes a complete hour-by-hour stream of observations for each ozone monitor in the
country. From the OLS regression described above, the staff used those monitored values to
predict monitored ozone concentrations in the analytical year 2007. To completely specify the
air quality in the contiguous United States, this RIA applies the Centroid methodology to
create a "proxy" monitor at the geographic centroid of each county. For each county centroid
"proxy" monitor, hourly ozone concentrations were assigned as if an actual monitor had been
in operation at that location. The following methodology was employed to establish the hourly
values associated with each "proxy" monitor.
22 From a partial derivative standpoint, this is true, but because of the constant term, this is not always the case.
For some low levels of ozone, the 2007 value can actually be overwhelmed by the magnitude of the other
statistics. However, these levels were much too low to affect any of this RIA's conclusions.
rv-i9
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For each county centroid, the RIA analysts identified the three closest ozone monitors
that formed a triangle around it, ignoring relative elevations and calculated the hourly ozone
concentration at the county centroid "proxy" monitor according to the following formula:
^ {D ~ d )
C = T J- C
c'' / = 1 D
3
where D = = dj
j -- i
where Cc j represents the concentration at the centroid "proxy" monitor for the i* hourly
observation, Cj;i represents the concentration at the j"1 monitor for the i4 hourly observation,
with 1,2, and 3 representing the surrounding actual monitors from which the linear
transformation was performed. D represents the sum of the distance between each of the three
surrounding monitors (dj) and the enclosed centroid "proxy" monitor. Because Cc; is the
distance weighted average of the values associated with its three surrounding monitors, by
construction, its value was bounded by the lowest and highest values of those three monitors.
Some county centroids (for example, along the U.S.-Mexican, the U.S.-Canadian
border, and continental coasts) could not be interpolated by using three surrounding monitors.
For some other monitors, the distance from the centroid to one of the three closest surrounding
monitors was greater than Ave hundred miles. In these cases, the analytical staff defined an
alternative weighting scheme where weights were defined which varied inversely with dis-
tance. In this weighting scheme, the three nearest monitors were used,23 whether or not they
enclosed the centroid. 277 counties in the contiguous United States required the alternative
weighting scheme, but none of them affected the results of this analysis. Under this alternative
weighting scheme, the centroid was either part of a larger network of monitors and did not
carry the design value which triggered nonattainment, or the county was not part of a
nonattainment area.
IV(C)(5) LIMITATIONS AND CAVEATS FOR USING THE CENTROID MODEL
Predicting concentration values in some future year involves a great deal of uncertainty.
However, the values have been produced under a specific set of assumptions and within the
confines of a model that, at the time of this analysis, represents best estimates of what the
levels and patterns of concentrations will be in 2007. The major assumptions that must be
considered in applying the results of this analysis include:
23 This weighting scheme is similar to other kriging methods used for predicting ozone concentrations. See
Lefohn, A.S., et als., "An Evaluation of the Kriging Method to Predict 7-h Seasonal Mean Ozone
Concentrations for Estimating Crop Losses," JAPCA 37:595-602 (1987).
IV-20
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• County concentrations can be represented by interpolating values from
surrounding monitors to the geographic centroid of the county. Predicting ozone
concentrations based upon a linear transformation of the concentrations at the three
closest surrounding monitors must, by design, produce a predicted value bounded by
the highest and lowest of the three observations. Therefore, ozone predictions in any
given county may be over or under predicted at the geographic centroid. This was of
special concern for counties without monitors, since the county's design value ozone
concentration would be driven by centroid values. However, the technical staff who
worked on this problem do not believe this is a major concern because, as explained
earlier in this chapter, there is an indirect relationship between the density of monitors
and the variation in observations across monitors which minimizes the limitations of
this caveat. In the East, monitors more than in the West for any given hour. However,
in the East, monitors are much denser, thereby diminishing the variation in centroid
interpolations. In the West, the opposite hold: monitors are farther apart but have very
low variation, which again reduces the variance at centroid locations.
• There is a linear relationship between monitored values. This may or may not hold
true, depending on the centroid and its surrounding monitors. Again, this is probably
more true in the East where sites are closer than in the West.
• Modeled concentration values for 2007 also represent modeled concentration
values for the other two years necessary for a three year averaging period. The
ozone primary standards analyzed in this RIA all deal with a three year averaging
period. In all cases, either the number of exceedances or the monitored values
themselves are averaged over three years. However, the analytical scope of this RIA
was limited to a single years' observations and the analysts assumed a single year's data
represented a three year stream of values. While this may appear to be less rigorous,
the level of uncertainty in current modeling techniques limits the value of adding a
second and third year to the analysis. While the staff recognizes the potential for
differences based on the limitation of a single year's data, the direction and magnitude
of that bias are (a) unknown, and (b) probably not very large so long as a year with
"representative" meteorology has been chosen. Using the 0.08 ppm five expected
exceedence form for purposes of illustration, five expected average exceedences over
three years actually means that, in any given year, up to sixteen exceedances can be
allowed, so long as the other two averaging years do not have any exceedances of their
own. Therefore, the standard value for any given year could be any of the actual
exceedences in that year between the first and the sixteenth highest daily concentration.
However, the underlying assumption is that this RIA is modeling a representative year,
and that, on average, the ozone concentrations observed for other years would be very
similar. Consequently, the staff believes that the actual ozone concentration which
would trigger nonattainment is probably limited to a much narrower range, probably
between the fourth and eighth highest value for the modeled year. Empirically,
monitored data supports this hypothesis. For example, analysis of the three year period
from 1993 through 1995 at sites which had three years' worth of data, the ozone
IV-21
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concentration which triggers nonattainment occurred 29 percent of the time in 1993, 28
percent of the time in 1994, and 43 percent of the time in 1995.
• Meteorological conditions are the same in 2007,1990, and 1987. Ozone
concentrations are a function of precursor inventories and meteorology, with the
variance in meteorological data much greater than that for inventories. Therefore, air
quality models reveal the greatest change when the model changes its meteorology.
However, most modeling is performed with meteorology held constant, mainly because
of the resource intensive nature of changing it. Using the same meteorology in each
analytical year carries with it the underlying assumption that the year chosen will
capture the full range of ozone characteristics for all but the most extreme ozone years.
However, in the regressions mn for use in interpolating to areas outside the ROM
domain, constant meteorology has a distinct advantage. Because the regression assesses
the effects of meteorology as constant between 1990 and 2007, it "falls out" of the
analysis, leaving behind a clearer picture of the impact of changing inventories.
Along with the assumptions listed above, the Centroid methodology carries with it
several additional caveats. These include:
• Centroid is monitor driven and the results are limited by the network of monitors
in existence in 1990. This may be especially limiting in the Western United States
where monitors are relatively sparse. Consequently, the model may under predict the
true degree of nonattainment for any or all of the alternative standards. However, this
is a limitation that exists for all of the air quality models that were available at the time
of this analysis.
• The Centroid algorithm cannot be applied in about 10 percent of the counties in
the 48 contiguous United States. Generally, these are counties which fall near interna-
tional or coastal boundaries or where at least one of the nearest three monitors was
more than five hundred miles away. However, as discussed above, this limitation did
not affect the overall results of this analysis.
• The present analysis extrapolates outside the ROM domain, under the assumption
that ROM temporal relationships between 1990 and 2007 hold for the Western
United States. Various explanatory variables were included in the regression equation
to control for possible spatial differences in data that help to explain variations in
concentrations over time.
IV(C)(6) CONCLUSIONS
While the application of an air chemistiy driven national model would have been the
optimal means by which the technical staff would have made its impact determinations, no
such model existed at the time of this RIA. The best available air chemistry model at the time
of this analysis was the Regional Oxidant Model. However, this model could not meet the
need for a national complete year analysis. Therefore, this RIA developed an alternative model
IV-22
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for predicting air quality in the year 2007 which relied upon the predictive strength of the
ROM model but allowed for temporal and spacial interpolation. While Centroid has several
significant limitations, statistical analysis of it compared to ROM, 1990 modeling predictions,
and with independent sources indicate Centroid is statistically similar to each of the
benchmarks analyzed. Therefore, while Centroid is not a pollutant dispersion model, it was the
only tool available, given the requirements of this analysis. Therefore, the technical staff
believes the Centroid model is a reasonable analytical tool for establishing preliminary
impacts.
IV(D) REFERENCES
BEA, 1990, Bureau of Economic Analysis, United States Department of Commerce: State
Projection Diskettes, BEA REA 90-420, June 1990.
EPA, 1990: U.S. Environmental Protection Agency, "1985 NAPAP Emissions Inventory:
Development of Temporal Allocation Factors," EPA-600/7-89-010d, April 1990.
EPA, 1991a: U.S. Environmental Protection Agency, Office of Air Quality Planning and
Standards, "Technical Guidance - Stage n Vapor Recovery Systems for Control of
Vehicle Refueling Emissions at Gasoline Dispensing Facilities - Volume 1," EPA-
450/3-91-022a, Research Triangle Parte, NC, November 1991.
EPA, 1991b: U.S. Environmental Protection Agency, "Control of Volatile Organic
Compound Emissions from Reactor Processes and Distillation Operations Processes in
the Synthetic Organic Chemical Manufacturing Industry," Draft, June 1991.
EPA, 1991c: U.S. Environmental Protection Agency, "Control of Volatile Organic
Compound Emissions from Batch Processes," OAQPS, September 1991.
EPA, 1991d: U.S. Environmental Protection Agency, "MOBILE4.1 Fuel Consumption
Model," draft output, August 12, 1991.
EPA, 1992a: U.S. Environmental Protection Agency, "Control Techniques Guidelines for
Offset Lithographic Printing," Draft, December 1992.EPA, 1992b: Environmental
Protection Agency, "I/M Costs, Benefits, and Impacts Analysis (Draft)," February
1992.
EPA, 1989: The United States Environmental Protection Agency, Atmospheric Research and
Exposure Assessment Laboratory, Office of Research and Development, "Development
of the Regional Oxidant Model Version 2.1", April, 1989.
IV-23
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EPA, 1993a: U.S. Environmental Protection Agency, "Final Regulatory Impact Analysis:
Refueling Emission Regulations for Light Duty Vehicles and Trucks and Heavy Duty
Vehicles," Draft, Office of Air and Radiation, December 1, 1993.
EPA, 1993b: Environmental Protection Agency, "Final Regulatory Impact Analysis and
Summary and Analysis of Comments: Control of Vehicular Evaporative Emissions,"
Office of Air and Radiation, Office of Mobile Sources, Regulation Development and
Support Division, February 1993.
EPA, 1994a: U.S. Environmental Protection Agency, Office of Mobile Sources, "Draft
Regulatory Impact Analysis and Regulatory Support Document: Control of Air
Pollution; Emission Standards for New Nonroad Spark-Ignition Engines At or Below
19 Kilowatts (25 Horsepower)" April 1994.
EPA, 1994b: U.S. Environmental Protection Agency, Office of Mobile Sources, "Users
Guide to MOBILE5 (Mobile Source Emission Factor Model)," EPA-AA-AQAB-94-01,
May 1994.
MathTech, 1996: "Technical Support Document For Nonattainment Area Ozone Reduction
Analysis", prepared for the United States Environmental Protection Agency, Innovative
Strategies and Economics Group, Office of Air Quality Planning and Standards, March
1996.
Pechan, 1994a: E.H. Pechan and Associates, Inc., "Regional Oxidant Modeling of the 1990 Clean
Air Act Amendments: Default Projection and Control Data", prepared for the United
States Environmental Protection Agency, Source Receptor Analysis Branch, Office of Air
Quality Planning and Standards, August 1994.
Pechan, 1994b: E.H. Pechan and Associates, Inc., "Regional Oxidant Modeling: Development of
the OTC Emission Control Strategies", prepared for the United States Environmental
Protection Agency, Source Receptor Analysis Branch, Office of Air Quality Planning and
Standards, September 1994.
Pechan, 1994c: E.H. Pechan and Associates, Inc., "Ozone NAAQS Review Clean Air Act Base
Case Evaluation for 2007", prepared for the United States Environmental Protection
Agency, Ambient Standards Branch, Office of Air Quality Planning and Standards,
September 1994.
Pechan, 1994d: E.H. Pechan and Associates, Inc., "Analysis of Incremental Emission Reductions
and Costs of VOC and NOx Control Measures", prepared for the United States
Environmental Protection Agency, Ambient Standards Branch, Office of Air Quality
Planning and Standards, September 1994.
IV-24
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V. METHODOLOGIES FOR DETERMINING EMISSION REDUCTION TARGETS
AND CONTROL STRATEGIES
V(A) INTRODUCTION
This RIA does not, nor did it intend to predict the actual ozone concentration that will
occur in the analytical year. Given the limitations of the analyses presented in this and other
chapters, the technical staff for this RIA believes that, on average, the predictions made herein are
reasonable. Instead, the identified counties which exceed any given standard and the
nonattainment areas which come from them should be viewed as representative of the expected
scope of each alternative's nonattainment problem. However, for any given area, the models
employed can over or under predict the true level of any estimation. Therefore, the counties and
nonattainment areas identified within this RIA should be viewed as representative of the expected
scope of each alternative's nonattainment problem, rather than as a declaration of future
attainment status.
Once emission inventories had been estimated for the year 2007, the next step was to
estimate air quality for the analytical year. This was done by extrapolating 1990 monitored air
quality data to 2007, using the Regional Oxidant Model (ROM) estimates of air quality in the
Eastern United States as a scaling factor. After predicting ozone concentrations in 2007 for the
entire contiguous United States, the RIA team identified potential nonattainment counties and
their related nonattainment areas according to the requirements of subpart (2), described below in
section V(B). ROM modeling and Urban Airshed Model - IV (UAM-IV) estimates of targeted
precursor reductions for the current standard were then used as an input into the establishment of
VOC and NOx targets for all identified nonattainment areas. This process is described in section
V(C). V(D) describes the process by which projected inventories were translated into control
strategies, and V(E) discusses the residual nonattainment phenomenon.
V(B) IDENTIFYING NONATTAINMENT AREAS
V(B)(1) DETERMINATION OF NONATTAINMENT AREAS - COSTS
The Clean Air Act (CAA) in Sec 107(d)(4) states:
"If an ozone nonattainment area located within a metropolitan statistical area or
consolidated metropolitan statistical area (as established by the Bureau of the
Census) is classified under part D of this title as a Serious, Severe, or Extreme
Area, the boundaries of such area are hereby revised (on the date 45 days after
such classification) by operation of law to include the entire metropolitan statistical
area or consolidated metropolitan statistical area."
The CAA further states:
"The governor can undertake a study to evaluate whether the entire metropolitan
statistical area or consolidated metropolitan statistical area should be included
-------
within the nonattainment area. Whenever a Governor finds and demonstrates to
the satisfaction of the Administrator, and the Administrator concurs in such
finding, that with respect to a portion of a metropolitan statistical area (MSA) or
consolidated metropolitan statistical area (CMSA), sources in the portion do not
contribute significantly to violation of the national ambient air quality standard, the
Administrator shall approve the Governor's request to exclude such portion from
the nonattainment area. In making such finding, the Governor and the
Administrator shall consider factors such as population density, traffic congestion,
commercial development, industrial development, meteorological conditions, and
pollution transport."
These principles apply to all nonattainment areas. If the air quality of an area violates the
ozone standard, or if sources in that area contribute to violations in a nearby area, the area must
be designated nonattainment. The general presumption is to designate the entire CMSA or MSA
(C/MSA) or county, which ever is larger. Adjacent counties to a C/MSA should be attached to
the CMSA. Monitors are placed in counties downwind of the urban areas and may be located in
counties just outside the C/MSA. When these counties measure violations they should be
attached to the C/MSA or counties which contribute to the violation.
The above process for defining nonattainment areas does not necessarily hold when
actually applied to a given area surrounding a monitor deemed not in attainment of the current
standard. Instead, the CAA methodology acts as a starting point for a politically and economically
driven process of adjustment that operates to reduce the size of the nonattainment area. This
process cannot be modeled. Therefore, the analytical staff decided that when identifying
nonattainment areas in the year 2007 for each of the alternative standards under each baseline
scenario, the strict letter of the Act should be followed without regard for any process that would
work to change the size and shape of the nonattainment area. While this decision tends to
overstate the size of nonattainment areas and, hence, the associated costs and benefits of
attainment, the decision does not incorporate subjective assessments of what changes might occur
in any given nonattainment area. A second source of potential over-estimation in this analysis
occurs because of differences between county definitions and those of C/MSAs. In many cases, a
C/MSA definition includes partial counties. This analysis, however, includes the entire county
whenever this situation arises. Therefore, the analysis has a second tendency for a slight
overprediciton of the costs and benefits associated with each alternative standard.
For each county that exceeded the standard for any of the alternative standards, the
following area identification rules were applied:
• If the county was included in the definition of a C/MSA, the entire C/MSA was
identified as nonattainment.
• No partial counties were included in a nonattainment area definition. For partial
counties within C/MSAs, the entire county was included in the nonattainment area
definition.
V-2
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• If a county was identified as exceeding any standard and was not part of a C/MS A
definition, but was contiguous or very close to a C/MSA area which had been identified as
nonattainment, the nonattainment area "absorbed" that near-by county.1
• If a county was identified as exceeding one or more of the alternative standards and
was not sufficiently close to an existing C/MSA, the nonattainment area was defined as
that single county.
• When a group of contiguous counties each recorded a violation but those counties were
not part of or near a nonattainment C/MSA, those individual counties were combined into
a single nonattainment area.
V(B)(2) IDENTIFICATION OF MARGINAL NONATTAINMENT AREAS
The current implementation strategy under part 51 requires marginal nonattainment areas
to perform six tasks (EPA, 1996a):
Institute a New Source Review (NSR) program
Develop an emissions inventory
Develop emission statements
Establish periodic inventories
Institute RACT "fix-ups"
Perform I/M corrections
The first four tasks listed above do not require the imposition of control measures.
Instead, each task incurs only administrative costs. While administrative efforts do not result in
direct reductions of pollution, the Agency has long recognized the ability of non-control pollution
management efforts to indirectly produce air quality improvements, as noted in the RIA for the
part 70 Operating Permits Rule (EPA, 1992). For instance, a source may discover upon
developing a new emission inventory that a simple adjustment to its boiler temperature can result
in more efficient combustion and lower NOx emissions. Generally, administrative costs for these
items are small, given the relative magnitude of the command-and-control costs associated with
VOC and NOx measures. For example, the 1996 ICR for the Operating Permits Rule lists the data
collection burden to sources as about $45 million annually for the entire nation. The subset of
ozone nonattainment areas which would incur these costs would make that cost much smaller.
Consequently, administrative costs are not included in this RIA. Administrative costs will be
discussed in detail as part of the Paperwork Reduction Act requirements for the part 51
implementation part of this NAAQS process.
The goal of identifying nonattainment areas was to minimize the number of NAs necessary to fully incorporate
all identified counties. If, for example, a county was identified as nonattainment and it sat between two existing
C/MS As, the staff selected the closest C/MSA to define as nonattainment if: both areas were already identified
as nonattainment However, if one C/MSA had been identified as nonattainment and the other had not, the staff
chose the nonattainment C/MSA, even if it was further from the original nonattainment county.
V-3
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The last two tasks listed above, while they require the application of control measures, are
designed to correct shortfalls in previously required controls with regard to I/M and RACT.
However, when creating its baseline inventories, the methodology employed in this RIA did not
allow for less than one hundred percent compliance for each requirement. Therefore, by
construction, while RACT "fix-ups" and I/M corrections may exist for any given marginal
nonattainment area, those measures do not appear in the available inventory of controls.
Consequently, these two tasks carry with them zero control costs within this analysis.
This inventory limitation may result in an underestimation of measurable control costs but
for several reasons, the staff believes the overall impact on costs is small. First, the CAA
mandated controls are for rule effectiveness improvements on existing measures. Current Agency
estimates put the average rate of rule effectiveness at over ninety-five percent (EPA, 1996e,
forthcoming). Consequently, the marginal improvements from the CAA mandated improvements
(and their subsequent costs) will probably be very low. Second, these controls are for
improvements in marginal nonattainment areas identified in 2007. Many of these areas will have
been marginal nonattainment areas for a number of years prior to 2007. During that time, they
would have been working toward addressing rule effectiveness. Consequently, there may be little
left to do within these control cost categories in 2007. This assumption will be reviewed and may
be relaxed during the next stage of the analysis.2
Given the mandatory tasks listed above and the two assertions that (1) administrative
efforts may result in marginal improvements of air quality and (2) mandatory control measures
may exist and be employed in some marginal nonattainment areas even though this analysis cannot
identify when this may occur, this RIA assumes the mandatory measures listed above are
sufficient for marginal nonattainment areas to attain the standard. However, it is possible that
additional control measures may be needed to achieve some air quality improvements in some
marginal nonattainment areas. Although the costs associated with achieving the improvements are
likely to be small relative to other costs presented in this RIA, to the extent that there are control
costs associated with these areas, the costs presented in this analysis are understated.
Marginal nonattainment under the current standard ranges from .12 to .138 ppm, or 15%
beyond the standard. To determine an analogous range of marginal nonattainment for the
alternative eight hour standards, the Agency's analysts investigated three different approaches: (1)
rolling back the upper end of the current marginal nonattainment range by the same percentage
that would be applied to roll back the current standard to achieve a .08 ppm level (i.e., by a factor
of .86), (2) applying a similar distribution to nonattainment classifications to that which was used
for the current standard, and (3) increasing the level of the .08 ppm standard by the same amount
that would achieve the upper bound of the current marginal nonattainment range (i.e., by a factor
of .15). The first approach resulted in too many marginal nonattainment areas. Multiplying the
.138 ppm upper bound by the .86 factor resulted in an upper bound for the eight hour standards of
.117 ppm. Under this scenario most nonattainment areas under an eight hour standard would be
2 The Interim Implementation Procedure established by the Agency to address the transition between the current
and proposed ozone NAAQS includes a requirement for a 3% RFP to address ozone concentrations above the
standard. This requirement was not a part of the current CAA requirements and was not considered for this
analysis. However, the Agency plans on investigating this RFP requirement in the future, if appropriate.
V-4
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able to qualify as "marginal". Investigation of the second approach indicated it was unnecessarily
complex. As the form of the eight hour standard changes, so does the number of nonattainment
areas and their distribution. The second approach would result in a slightly different upper bound
for marginal nonattainment in all of the eight hour forms. Therefore, the staff applied the third
approach and established the upper bound for an analogous marginal nonattainment classification
under an eight hour averaging time at .092 ppm, or 115% of the standard3
V(C) IDENTIFYING TARGETED REDUCTIONS
Once nonattainment areas were defined under each alternative standard, the Agency's
technical staff determined VOC and NOx reduction targets for each area exhibiting modeled air
quality worse than that found in a marginal nonattainment area. The technical staff relied primarily
upon the expertise of its air quality modelers for their recommended VOC and NOx targets. The
Agency's air modelers used a number of sources to determine VOC and NOx targets for the RIA
team:
ROM modeling: While limited to only the Eastern United States, ROM modeled air
quality was an integral component in understanding the dynamics of air chemistry vis a vis
emissions inventories. Over the years the Agency has performed a series of ROM analyses (matrix
runs and NAAQS simulations) designed to investigate the regional implications of localized
control for across-the-board VOC, NOx, and VOC + NOx reductions. Generally, these sensitivity
runs were performed for targeted reductions in ten percent increments, providing a fairly clear
picture of the interrelationship between emissions and air quality in each area. Within the
limitations of the ROM model, these sensitivity runs provided the Agency with a source of
targeted VOC and NOx reductions to attain the current standard and the eight hour alternatives
within the ROM domain.
UAM modeling: The Urban Airshed Model (UAM-IV or UAM-V) predicts air quality
in specific metropolitan areas,4 utilizing meteorological and emissions data. Because UAM
domains are defined for areas that violate or are in danger of violating the current ozone standard,
these domains were generally areas that were predicted to violate at least one of the proposed
standards. Therefore, the technical team further clarified its VOC and NOx targets for each UAM
area based upon discussions with UAM modelers at the State, Regional and National level, as
well as the results of the 1995 3rd Urban Airshed Modeling Workshop (UAM, 1995).5
3 This range is consistent with the analysis performed in the Staff Paper (c.f., pp. A-21 -22).
4 The size of the UAM modeling domain is fixed and does not necessarily correspond to the area of the MSA,
CMSA or nonattainment area associated with that urban location.
5 The 3rd Uiban Airshed Modeling Workshop was held on September 12 - 14 1995 in Arlington, VA. The
individual reports, key topic presentations, materials and panel recommendations from that meeting were
gathered in a notebook which was distributed in October.
V-5
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OTAG modeling: Separate from the efforts in many of the Easternmost United States, a
number of OTAG modeling efforts have been undertaken to determine the necessary reductions to
achieve the current standard with the application of broad regional programs as a first step. Much
of this work has been done with the help of the Agency's modelers utilizing the ROM model but
some additional work has been done with UAM-V as well. Information from these modeling runs
was combined with that garnered from other modeling efforts to establish estimates of the
required VOC and NOx reductions to achieve each alternative standard.
AIRS data: In addition to the modeling results listed above, each nonattainment area has
an emissions inventory for VOCs and NOx which is maintained by the AIRS program in RTP.
This database supplied specific data, including population, emissions inventory and source
geographical information which was used to further characterize nonattainment areas for purposes
of aggregating nonattainment areas by control strategies.
Other Data: The staff also relied on several other sources of air quality modeling,
including the South Coast Air Quality Modeling District (SCAQMD) and modeling efforts
undertaken by other ozone nonattainment areas.
The sets of nonattainment areas under the LCS scenario always included the complete set
of predicted nonattainment areas under the corresponding RCS scenario. In addition, time
constraints prevented a complete modeling analysis to establish RCS targets. Consequently, this
RIA established targets for LCS standards and then adjusted that information to accommodate the
beneficial effect of regional strategies. For the current standard, existing ROM and UAM
modeling efforts drove this RIA's methodology for determining VOC and NOx emission
reduction targets. For example, of the ten predicted nonattainment areas in 2007 with ozone
concentrations greater than marginal under the LCS for the current standard, seven were part of
the ROM domain and had targets established under ROM, UAM modeling, or both. For the three
nonattainment areas outside the ROM modeling domain, the California South Coast FIP (EPA,
1990) and additional modeling information garnered from the South Coast Air Quality
Management District provided sufficient detail for VOC or NOx targets to be developed. One
draw-back of this approach was that ROM and UAM modeling do not always use the same
meteorology, episodes, or analytical base years, all of which work to drive their analyses toward
different conclusions.
Determining the appropriate level of reductions for the eight hour standards was
somewhat more problematic. Outside of a few ROM analyses, very little eight hour modeling had
ever been done, and most existing work did not include regional NOx controls in its baseline.
Consequently, a series of new eight hour ROM runs were performed to identify local VOC and
NOx strategies under the LCS for each of the three alternative NAAQS. For areas outside the
ROM domain, the analysis relied upon advice from air quality modelers and air chemists to
establish targets for each eight hour alternative standard. For identified nonattainment areas which
had no ROM or UAM modeling, targets were assigned for these "new" areas that were similar to
the targets in "similar" nonattainment areas which had been modeled, using geographic
characteristics as a measure of similarity.
Without sensitivity runs to determine appropriate RCS targets, the Agency's analysts
needed to define a metric which would approximate the change in targets necessary for each
V-6
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alternative NAAQS under the RCS. The staff determined improvements which occur in any
nonattainment area come from three components: the effects of local controls, the effects of the
local contribution of any controls applied to address regional strategies, and the beneficial
transport effects from upwind areas controlling for regional and local strategies. The inventories
developed for this RIA allowed the team to differentiate between the first two components, but
regional transport could not be quantified. However, the regional strategies chosen for inclusion
in the analytical baseline focussed on NOx controls while most of the identified nonattainment
areas in this RIA use VOC controls. Under the RCS, four of the forty identified nonattainment
areas for the most stringent alternative used NOx strategies. Under the other eight hour
alternatives, only one area, Atlanta, used NOx strategies. Under the current standard, no identified
nonattainment area was assigned NOx targets. Given that regional controls focussed on NOx
controls and the benefits of ozone reductions occur primarily in VOC management areas, the staff
approximated the average improvement in air quality by examining the ROM regressions used to
in the Centroid methodology. As described in the previous chapter, the ROM-based regressions
performed with and without regional strategies provided two sets of coefficients. Comparing the
coefficients on the ROM90 terms from the LCS and RCS regressions provides an estimate of the
average change in ozone concentrations one would expect from the application of a regional
control strategy. The ratio of coefficients is:
RQM90rcs _ 79 ^ ^
.90 ~ '
Therefore, holding everything else constant, one would expect that, on average, air quality would
improve by approximately 12% in the ROM domain in 2007 due to the imposition of a regional
control strategy.6 After identifying appropriate targets for each of the alternative standards under
the LCS, the analysis team applied the regional strategy adjustment factor to each target to
identify appropriate reductions for the analytical baseline.
Would a different adjustment factor have been a better approximation of the air quality
improvements found through the RCS? The staff performed a sensitivity analysis of this factor by
looking at the change in impacts expected to occur under a .94 adjustment factor (i.e., applying
half of the 12% average improvement). Examining the most stringent scenario, the analysis
revealed there would be no change in the cost analysis presented in this RIA due to a .94
adjustment factor. For residual nonattainment areas under a .88 adjustment factor, there would be
no change in costs or economic impacts because they had already exhausted their inventory of
identified controls. However, three areas which had been considered within the range of this
analysis' uncertainty and potentially able to attain the standard would change to residual
6 The two regressions described in the previous chapter include a number of other explanatory variables.
However, of these variables, only one was significant under each regression, and it displayed different signs for
the two regressions. Because of the lack of significance, the technical team ignored these variables in
establishing a regional strategy adjustment factor.
V-7
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nonattainment areas, but since they had already exhausted all identified control measures, their
costs did not change. The three areas identified as able to fully reach their targeted reductions
would be considered attainment areas under a .94 factor. Therefore, this RIA assumes the .88
factor is a reasonable measure of the change in targeted reductions required under the RCS.
An analysis of administrative costs associated with the ozone NAAQS will be considered
during the part 51 implementation process, including actions that need to be taken by marginal
nonattainment areas for ozone. The Agency will also consider the issues of Federal conformity
and impacts on military readiness during the part 51 implementation process, and attempt to
provide cost estimates associated with Federal conformity. The Agency did not estimate the cost
associated with every known control measure, however. Time and resource constraints, in
conjunction with having limited data prevent the Agency from analyzing the potential impacts of
the ozone and PM NAAQS on regional transportation emissions, implementation of TCM, and
localized transportation related effects. At this time, it is not possible to estimate the impact that
the NAAQS will have on transportation plans in identified nonattainment areas because
uncertainties are associated with these estimates. For example, because mobile sources are not
individually inventoried, the actual number of establishments affected by these control measures is
unknown. Consequently, any cost analysis using these control measures on mobile sources is
highly speculative. Control measures such as these currently not included in the ozone control
strategy cost analysis will be considered during the part 51 implementation process.
Time and resource constraints, in conjunction with having limited data also prevented the
Agency from analyzing the potential impacts of the ozone and PM NAAQS on sources that
receive Federal funding and are located in identified nonattainment areas, This information is not
contained in the estimate of control strategy costs for the Federal Government (SIC 971). For
each nonattainment area, the Agency has estimated the cost of controlling stationary sources only
to achieve the ozone and PM NAAQS. Although the level of detail in the data bases the Agency
used for this RIA is not sufficient to identify the ownership status associated with these controlled
sources, it is reasonable to believe that some of these sources are located on Federal facilities.
V(D) SELECTING INCREMENTAL CONTROL MEASURES
Chapter IV(B) of this RIA describes the control measures included in this analysis. In
general, the staff considered only conventional controls in developing its control strategies.
Examples of conventional controls include reformulated fuels, enhanced I/M, and metal product
surface coatings. In addition to these conventional controls, a number of less common controls
were available for this analysis which had sufficient engineering and economic data to be included
as well. Examples of these "extraordinary" controls include "layering" controls on combustion
sources (e.g., LNB + FGR) and add-on controls for paper surface coating.
In some cases, the staff determined a specific control measure was not able to be included
in this analysis. Typically, this decision was made based upon the lack of available data to fully
characterize the cost effectiveness of the measure, or time and resource constraints prevented the
Agency from assessing the potential impacts of the ozone NAAQS. In particular, the staff did not
assess regional transport emissions, implementation of TCM, and localized transportation effects.
V-8
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At this time it is not possible to estimate the impact that the NAAQs will have on transportation
plans in identified nonattainment areas because uncertainties are associated with these estimates.
For example, because mobile sources are not individually inventoried, the actual number of
establishments affected by those control measures is unknown. Consequently, any cost analysis
using these control measures on mobile sources is highly speculative. These excluded controls are
identified below. For each nonattainment area identified, the team created an inventory of
anticipated control measures for VOC and NOx reductions in accordance with the methodology
laid out inTV(B) and in the technical support document (Pechan 1994 a, 1994b). These measures
were rank ordered from least to most expensive, with the following adjustments:
• locomotive controls were removed from the inventory because the inter-regional
characteristics of the industry limited their effectiveness as a local control measure;
• mobile source transportation control measures (TCMs) were removed, including
Employee Commute Options (ECO) and Group 1, 2, and 3 TCMs, because of the degree
of uncertainty associated with estimations for reductions and costs per ton;
unless Federal reform was selected as a VOC measure, it was deleted from the list of
available NOx control measures prior to selection of the NOx attainment strategy; and
if California Reform was selected for either VOCs or NOx, then Federal reform was also
selected, because the California program was modeled incremental to the Federal
program.
Once the inventory of control measures for each nonattainment area had been rank
ordered by cost per ton of reduction, this RIA sequentially added control measures to the
nonattainment area's control strategy until the sum of all selected precursor reductions met or just
exceeded the targeted reductions established for that area.7 In most cases this process resulted in
all available control measures being selected without the targeted reduction being achieved.
Unless the available control measures allowed for a strategy that included at least seventy five
percent of the necessary VOC and NOx reductions for an area, that area was deemed to have
"Residual Nonattainment", a condition which is discussed under section V(D)(4) of this RIA.
Current implementation strategies under subpart (2) allow for trading within a
nonattainment area. In addition, if it can be shown that the control of a small number of sources
can allow the nonattainment area to attain, then subpart (2) allows for the control of those
identified sources and the exemption of other sources within the nonattainment area from having
to reduce their own levels of pollution. The control measure selection process incorporated in this
RIA precludes the use of trading within a nonattainment area because the least costly controls are
always chosen as part of this analysis' control strategy. Any trading outside the control strategy
determined by this RIA must, by construction, result in a higher cost. For the same reasons, local
management of a single source or small group of sources and exempting other polluters would
7 VOC and NOx control measures have step-wise cost curves. Consequently, the need for an additional
increment to reach targeted levels seldom resulted in an exact match between targeted and necessary
reductions. Generally, when a small reduction was still needed, the next available control measure resulted in
total reductions greater than the NOx target
V-9
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increase costs above those in this RIA. In areas of residual nonattainment, these points are moot,
because no further controls have been identified outside the control strategy which could provide
these sorts of flexibility. Therefore, for reporting purposes, this RIA identifies only "least cost"
measures from its menu of available controls in determining the cost of attainment.
V(E) RESIDUAL NONATTAINMENT
Selection of controls to meet or exceed an area's VOC and NOx targets does not
necessarily result in modeled attainment. In areas where there were enough controls available to
achieve modeled reduction targets, areas with ozone concentrations greater than the standard
could still exist for several reasons, including but not limited to:
• hot spots: The correct VOC and / or NOx reductions were identified and available, but
because of source distribution, the selection of a least cost strategy proved ineffective.
This type of residual nonattainment can be eliminated through an iterative process which
identifies the correct control measures to eliminate hot spots.
• speciation: The correct VOC and / or NOx targets were identified and available but the
most interactive precursors in the air column were not removed under the least cost
strategy employed. As with hot spot residual nonattainment, successive modeling
iterations can eliminate this type of residual nonattainment.
® undercontrol: The VOC and / or NOx targeted reductions were wrong and those
included were insufficient for attainment, but additional unused control measures exist.
When additional controls still remain in the areas inventory, undercontrol residual
nonattainment can be eliminated by adding additional measures to the control strategy.
Clearly, the test for modeled attainment in any given area relies on the model's ability
to incorporate emissions reductions and air chemistry. However, the Centroid method could
not directly accommodate changes in emissions or air chemistry, so this analysis cannot
identify hot-spots, speciation, or undercontrol. Therefore, this analysis assumes the VOC and
NOx targets are correct for any given nonattainment area, subject to the results of any
confirmation runs which may be run subsequent to the submission of this RIA.
In many cases, the physical inventory of available VOC and/or NOx controls could not
provide the necessary tons of reductions needed to attain a nonattainment area's targets. When
undercontrol of this sort occurs, the area cannot attain the standard. * These areas are defined
as "residual nonattainment areas" (RNAs). This condition was not unexpected. Residual
nonattainment has always been a problem. However, because of the separation between the
standard setting and implementation processes of the NAAQS, the Agency does not believe the
8 In these cases, the RIA does not attempt to "force" attainment. Allowing for many types of flexibility are
beyond the strict subpart (2) scope of this RIA. Any further reductions of the residual nonattainment problem
have been deferred until the completion of the implementation process under part 51, where issues of transport,
flexibility, and co-control can be fully discussed in the context of a single (proposed) ozone standard..
V-10
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level of residual nonattainment reported in this RIA is necessarily correct. Instead, the conclusions
drawn in this RIA must be considered as an upper bound, subject to improvement based on the
additional flexibility and creativity that will be identified under the part 51 implementation
process. Several factors mitigate the level of residual nonattainment expected in the year 2007:
Flexibility in Ozone Management: As this RIA has stated repeatedly, this analysis is
only the first of a multi-step process. Under the restrictions of subpart (2) of the Act, the analysis
is bound to a narrowly defined range of control mechanisms. With the promulgation of a new
ozone standard the Agency will employ broader and more flexible control strategies. For example,
additional flexibility may make it easier for nonattainment areas to employ market based
mechanisms beyond their borders. Consequently, the application of greater flexibility in ozone
management is a means to further reduce the problem of residual nonattainment.
Exogenous Efforts: Currently, there are a number of efforts under way which will
reduce the level of ambient ozone and its precursors. For example, the South Coast Air Quality
Management District in California, the Ozone Transport Commission (OTC) and the Lake
Michigan Ozone Study (LMOS) area considering the application of regional ozone strategies. To
some extent, these regional strategies are included in the baseline, which anticipates some sort of
broad-based regional NOx control agreement. Comparisons between the LCS and RCS
conclusions found in chapters VI and VII of this RIA provide an indication of the impact of such
strategies on the residual nonattainment problem. Other efforts designed to reduce sulfur dioxide
(S02) and particulate matter (PM) emissions will have synergistic impacts on the overall
concentration of ozone in urbanized areas. These synergies will be fully discussed as a component
of the integrated part 51 implementation strategy for ozone, particulate matter, and regional haze.
Technological Change: Many of the control technologies used today did not exist when
the current standard was originally promulgated, but were created in response to the regulatory
needs of the Act. The analytical team believes that the trend for the innovation of better, faster,
and cheaper controls will continue and that the current efforts to revise the NAAQS will act as a
catalyst for their creation. A part of the residual nonattainment problem will be solved by new
controls and process changes which will come into use before the year 2007.
Because of the tendency for ROM modeling to over-predict ozone concentrations under
the one and eight hour averaging times (EPA, 1996d), there is a high probability that the actual
VOC or NOx target for any given area will be less than 100% of the target identified for this RIA.
Consequently, areas within this analysis identified as not having sufficient VOC or NOx control
measures to achieve their targeted reductions may still be able to attain the standard. Based on
discussions with EPA modelers and other scientists about the degree of ROM overprediciton,
agency analysts picked 75% of an areas's targeted reductions as a lower limit for potential
attainment. In other words, for areas which could not meet their appropriate standard by applying
all available controls, if that area could achieve at least 75% of that target, it could be considered
V-ll
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"within the range of uncertainty" and identified as an area of potential attainment.9 The cost
chapter reports both types of areas separately but combines then in its conclusions as areas which
are able to attain. This assumption will be investigated further under the part 51 implementation
process if necessary.
V(F) ESTIMATING PARTIAL ATTAINMENT AIR QUALITY
In the context of this analysis, the term post-control refers to the effects on air quality
after control measures are applied but reflecting the existence of residual nonattainment. This
post-control scenario is presented in contrast to the full attainment scenario for each baseline and
all ozone alternatives. Resource constraints and data limitations prevent a comprehensive
modeling to establish a direct relationship between ozone precursor emission reductions and
ambient ozone air quality. Therefore, the benefits analysis uses a rollback procedure that directly
reduces ambient ozone air quality to meet the attainment criteria of each alternative NAAQS. For
the full attainment scenario, this rollback procedure is applied independent of the control
measures identified in the cost analysis. However, benefits associated with full attainment of a
NAAQS are not directly comparable to the cost estimates presented in this RIA due to the
presence of residual nonattainment. Therefore, a second scenario for estimating benefits was
established. This scenario is referred to as the post-control scenario because it is intended to
reflect the degree of emissions control that the cost analysis identifies as being available for each
identified nonattainment area. Since predicted residual nonattainment areas are identified in the
cost analysis, the benefits estimates for a post-control scenario will be smaller than the benefits
estimates for a full attainment scenario.
Recognizing that the photochemistry behind ozone formation is not linear but also
recognizing that air quality modeling results were not available for estimating post-control air
quality, and given the need to provide benefit and cost estimates that reflect relatively comparable
air quality, the post-control scenario uses a linear assumption between the VOC and NOx target
achieved and the effect on baseline ozone air quality. For example, if the cost analysis shows that
a nonattainment area can only achieve half of its targeted reductions, the post-control scenario
would reflect this residual nonattainment by rolling back air quality to only half the distance
between the baseline ozone concentration and the concentration specified by each ozone
alternative. From this methodology, the benefits analysis was able to estimate benefits reflective
of the degree of residual nonattainment identified for each nonattainment area in the costs
analysis. This adjustment for the post-control scenario allows benefit and cost estimates to be
considered on a more comparable basis.
9 For instance, Philadelphia's 8H1AX-80 target under the Local Control Scenario called for an 80% reduction of
VOCs, approximately 800 tons per day (tpd). Therefore, this RIA would have considered Philadelphia "within
the range of uncertainty" if it could have achieved at least 75% of that target, or 600 tpd. Under the Regional
Control Scenario, Philadelphia's target was 88% of its original target, or about 700 tpd. Given the level of
uncertainty associated with this analysis, however, the RIA would have considered Philadelphia to be "within
the range of uncertainty" if it could achieve at least 75% of that target, or about 530 tpd.
V-12
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V(G) REFERENCES
Pechan, 1994a: E.H. Pechan and Associates, Inc., "Ozone NAAQS Review Clean Air Act Base
Case Evaluation for 2007", prepared for the United States Environmental Protection
Agency, Ambient Standards Branch, Office of Air Quality Planning and Standards,
September 1994.
Pechan, 1994b: E.H. Pechan and Associates, Inc., "Analysis of Incremental Emission Reductions
and Costs of VOC and NOx Control Measures", prepared for the United States
Environmental Protection Agency, Ambient Standards Branch, Office of Air Quality
Planning and Standards, September 1994.
UAM, 1995: "3rd Urban Airshed Modeling Workshop Proceedings", from a workshop held
September 12-14, 1995 in Arlington, VA, 1995.
EPA, 1990: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "Regulatory Impact Analysis For the Proposed South Coast District
Federal Implementation Plan", July, 1990.
EPA, 1992: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "Regulatory Impact Analysis and Regulatory Flexibility Analysis for
Operating Permits Regulations" June, 1992.
EPA, 1996a: The United States Environmental Protection Agency, Ozone Policy and Strategies
Group, Office of Air Quality Planning and Standards, "Ozone Carbon Monoxide
Particulate Matter Sulfur Dioxide Lead Areas Designated Nonattainment" April, 1996.
EPA, 1996b: "Air Quality Criteria for Ozone and Related Photochemical Oxidants", Office of
Health and Environmental Assessment, Environmental Criteria and Assessment Office;
EPA report nos. EPA/600/P-93/004aF-cF.
EPA, 1996c: "Information Collection Request for Part 70 Operating Permit Rules", Office of Air
Quality Planning and Standards, EPA report no. EPA/600/P-93/004aF-cF.
EPA, 1996d: "Air Quality and Modeling Analyses To Identify Implications of Some Prospective
Ozone NAAQS" Office of Air Quality Planning and Standards, Emissions Monitoring and
Analysis Division, March, 1996.
EPA, 1996e: "Regulatory Impact Analysis for the Compliance Assurance Monitoring Rule"
Office of Air Quality Planning and Standards, Air Quality Strategies and Standards
Division, 1996 (forthcoming).
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VI. EMISSION REDUCTION AND COST ANALYSIS OF OZONE ALTERNATIVES
VI(A) INTRODUCTION
After carefully considering the information presented in the Criteria Document, the Staff
Paper, and the advice and recommendations of CASAC, the Agency proposes replacing the
existing one hour primary ozone standard with a new eight hour 0.08 ppm primary standard. The
proposed standard would be met at an ambient air quality monitoring site when the three year
average of the annual third highest daily maximum eight hour average ozone concentration is less
than or equal to 0.08 ppm.
The alternative standards analyzed for this RIA are all forms with an eight hour averaging
time. Chapter IV of this RIA contain detailed discussions of the methodology used to predict
ozone concentrations in the analytical year 2007. These predictions were used to identify counties
which failed to meet each of six alternatives: the current one hour, one expected exceedance 0.12
ppm standard (1H1EX-120); an eight hour, fifth highest average1 daily maximum concentration
based 0.08 ppm standard (8H4AX-80); an eight hour, five expected exceedances 0.08 ppm
standard (8H5EX-80); an eight hour second highest average daily maximum concentration based
0.08 ppm standard (8H1AX-80); an eight hour third highest average daily maximum eight hour
average ozone concentration 0.09 ppm standard (8H2AX-90); and an eight hour fifth highest
average daily maximum eight hour average ozone concentration 0.07 ppm standard (8H4AX-70).2
The 8H4AX-80 and the 8H1 AX-80 forms bound the proposed standard. The 0.07 ppm and 0.09
ppm forms allow for analysis of the full range of CASAC recommendations. While this RIA does
not analyze the proposed standard directly, the selected alternatives bound the costs, benefits, and
economic impacts which the staff expects will result from the proposed standard under the
analytical framework of this RIA.
To better approximate the rounding convention utilized in monitoring, the actual ozone
concentration level that resulted in an exceedance was .005 ppm greater than the standard, i.e.,
for 0.12 ppm, an actual exceedance of the standard was not recorded unless the modeled ozone
concentration was greater than or equal to . 125 ppm; for an 0.08 ppm standard, the modeled
concentration level was .085 ppm. No rounding convention was applied to the ozone
concentration levels established for marginal nonattainment.
The staff performed its analysis against a baseline which included the following:
Full implementation of current Clean Air Act Amendments of 1990 Amendments. A
discussion of this assumption can be found in chapter IV of this RIA.
1 For all of the standards analyzed, the averaging time is three years.
2 As stated earlier in this RIA, resource constraints precluded the direct analysis of the 0.07 ppm and the 0.09
ppm alternative standards. However, the staff analyzed existing hourly monitored data reconfigured to provide
eight hour averages and determined a fifth highest average daily maximum ozone concentration at 0.07 ppm is
analytically similar in the size, location, and number of nonattainment areas to the 8H1 AX-80 form and that a
third highest average daily maximum ozone concentration at 0.09 ppm is analytically similar to the current
1H1EX-120 standard. Therefore, within the range of this analysis' uncertainty, the Staffbelieves the 8H4AX-
70 has the same economic impacts and costs as the 8H1AX-80 form. Similarly, the Staffbelieves the 8H2AX-
90 form has the same costs and economic impacts as the current 1H1EX-120 form.
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Current implementation techniques mandated under subpart (2) of the Act hold.
The staff believes the most reasonable implementation strategy for this RIA would be the
strict application of subpart (2) requirements, leaving any future flexibility to the analysis
performed for the part 51 implementation strategies.3
Implementation of a regional NOx strategy in the East which approximates the
efforts of current regional efforts by OTAG, CAPI, and other on-going efforts.
Current efforts to address long range NOx transport issues include the Clean Air Power
Initiative (CAPI), efforts to expand the OTR requirements to the thirty seven Eastern
United States. While these efforts are not complete, the staff anticipates their
implementation far in advance of the 2007 air quality assessment undertaken for this RIA.
The staff believes that these efforts will be in place in the year 2007, and because they are
being undertaken to attain the current ozone NAAQS, they should be included in the
analytical baseline of this RIA.
Current regional transport efforts affect this RIA's baseline air quality by: (a) significantly
reducing the affect of long range NOx transport in the East, (b) reducing the number of
nonattainment areas under each alternative and the targeted reductions necessary within those that
remain, and (c) reducing the number of residual nonattainment areas under each alternative. For
purposes of identification, this RIA's analytical baseline will be referred to as the "Regional
Control Scenario" (RCS).
The staff also performed sensitivity analysis on its cost and benefits work under a second
baseline which did not allow for the inclusion of regional control strategies in the East. While
efforts are under way at this time to implement several regional NOx strategies in the East, these
efforts are not in place at this time. While the staff believes regional measures represent a truer
picture of the anticipated 2007 air quality, it must still present an accurate assessment of the
potential costs of the rulemaking. Therefore, this second baseline, refereed to in this RIA as the
"Local Control Scenario" (LCS), provides an upper bound to the anticipated costs of the new
ozone NAAQS in the event regional efforts fail to arise before 2007. LCS results appear at the
end of this chapter, behind those of the analytical baseline (RCS).
VT(B) EMISSION REDUCTIONS AND COSTS UNDER THE REGIONAL CONTROL
SCENARIO
Concurrent with the staffs analysis of a new ozone NAAQS, other efforts are under way
which affect the 2007 analytical base case and base line. Thirteen Northeastern States and the
District of Columbia united to form a single Ozone Management Region (OTR). Based upon their
approach, a larger organization has been formed out of the thirty seven Eastern-most States and
3 Although the staff is currently working closely with industry leaders to craft an implementation strategy that
will allow for much greater flexibility for attainment in any given area, these strategies do not exist at the
present time, nor does the staff know what they will look like. Consequently, any attempt to anticipate those
strategies would (a) miss some strategies which will be applied, (b) include some strategies which will not be
included, and (3) create unnecessary complications to this analysis.
VI-2
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D C., called the Ozone Transport Assessment Group (OTAG) Figure VI-1 displays the OTAG
membership. Currently, OTAG plans to apply regional strategies to address transport issues.
FIGURE VI-1
OTAG MEMBER STATES
OTAG MEMBER STATES
H Osooc Transport
~ Othot Off AO Me«4>9f£(26)
While the regional NOx control efforts mentioned above are not complete, it is prudent to
incorporate the expected VOC and NOx reductions from their efforts into the 2007 base line. The
following analysis includes, for the OTAG States, the application of a 0.15 pounds per million
BTU cap on NOx emissions from utilities and other combustion boilers and a California styled
LEV program These strategies are applied as a part of the analytical baseline but should not be
interpreted as a recommendation for, or a prediction of the results of any of the above efforts.
Instead, the strategies included in the baseline are "placeholders" in anticipation of the successful
completion of these efforts.. Identification of nonattainment areas and the strategies necessary to
attain the standard follow the requirements of subpart (2). The economic impacts of the regional
and local controls necessary to attain each of the alternative standards can be found in the next
chapter of this RIA.
Current OTAG efforts have focused on a number of alternative scenarios, which the staff
compared to its own estimate of potential controls. In every case but the most extreme, the
VI-3
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OTAG strategies represent a lower level of control than that included in this RIA. However, the
staff's projected regional strategy was not designed to represent OTAG alone. Instead, it was
designed to approximate the expected reductions of a number of different regional efforts at the
same time. Therefore, given that OTAG represents only a part of the regional control predicted in
this RIA, estimates of air quality improvements can be considered reasonable. References to the
States included in this RIA's regional scenario will be referred to as "the RCS States".
VI(B)( 1) SUMMARY OF TOTAL EMISSION REDUCTIONS AND CONTROL COSTS
BY NONATTAINMENT AREA
Regional controls apply to only the ROM domain, which contains all of the thirty one
Eastern United States included in the RCS States and the eastern part of the six remaining RCS
States. For areas west of the ROM domain, the staff assumed the LCS baseline was a reasonable
approximation of the ozone concentrations that would be found under the RCS. The
methodologies employed for identifying nonattainment areas, appropriate control targets and
strategies, and the level of RNA for each alternative can be found in chapters IV and V of this
RIA. Section VI(B)(l)(a) describes the costs associated with attaining the current standard in the
year 2007. They show that current Clean Air Act requirements, even in conjunction with a
regional NOx strategy in the East, must be augmented by additional local controls to achieve the
standard. These costs are a part of the baseline, and are presented for purposes of completeness.
The costs associated with each alternative standard are marginal costs, above the baseline. In
other words, the costs associated with each alternative below are the costs above and beyond
those associated with the current standard. As stated before, one must remember the baseline
costs for the current standard and tho marginal costs associated with each alternative do not
represent full attainment in every area of the country.
The National Low Emission Vehicle (NLEV) program and regional NOx controls on
utilities constitute the bulk of the regional controls included in the baseline. The cost of the NLEV
program - a voluntary initiative under development by the automobile industry and a group of
states - is projected to be over $600 million per year (EPA, 1996b). The utility NOx reductions
were evaluated as part of the Clean Air Power Initiative (CAPI) report recently issued by EPA.
By interpolating between 2005 and 2010, it is possible to derive a cost estimate for a 0.15 pound
per million Btu control strategy. That cost is $2.3 billion for the year 2007.
Tables VI-2, 3,4, 7, 8, and 9 below show the marginal control cost of attaining alternative
standards under the RCS or the sensitivity analysis LCS. Frequently, these tables show zero costs
for VOCs, NOx, or both. This does not mean that there is no additional cost to attaining the
alternative standard in these areas. Instead, it means that the menu of modeled controls has been
exhausted and that there are no more controls to employ, even though the alternative standard is
more restrictive than the current standard. Consequently, the proper interpretation of the total
cost from the 2007 baseline (for the LCS, and with the regional control strategies included for the
RCS,) for any eight hour NAAQS alternative is to sum the marginal costs for that area with the
total costs for that area under the current standard. For example, Table VI-3 lists the marginal
cost for available controls necessary to attain the 8H4AX-80 standard in Baton ROuge as $16.1
VI-4
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million per year. Under Table VI-1 for the current standard, the cost for Baton Rouge to attain
the current standard is $14.5 million per year. Therefore, from the 2007 baseline, after
implementing regional NOx control measures, the cost of available controls to directly attain the
8H4AX-80 standard is ($16.1 + $14.5), or $30.6 million per year. For Bakersfield, however, the
data show different information. Table VI-3 indicates the marginal control cost for Bakersfield is
zero, while Table VI-1 lists the total control cost for Bakersfield toward attaining the current
standard is $7.9 million per year. This indicates that the menu of available controls for attaining
the current standard was exhausted and that, even though the 8H4AX-80 standard is more
restrictive, no additional controls could be applied to attain it.
The implementation strategies which are now under discussion by the broad stakeholder
group consider additional factors which allow for more areas to attain. Appendix A, Table 1
shows the modeled nonattainment area counties for the current standard. Appendix A, Tables 2,
3, and 4 show the modeled nonattainment counties for the 8H5EX-80, 8H4AX-80 and 8H1AX-
80 standards, respectively. The tables include all identified nonattainment areas, including areas
expected to be classified as marginal nonattainment.
VI(B)(l)(a) THE CURRENT STANDARD (1H1EX-120) AND THE 8H3AX-90
ALTERNATIVE
40 CFR part 50 establishes the current ozone primary standard as: "0.12 part per million
(235jig/m3).. . attained when the expected number of days per calendar year with maximum
hourly average concentrations above 0.12 part per million (235fig/m3) is equal to or less than
one ..."4 Appendix H to 40 CFR part 50 describes "expected exceedance" as the arithmetic
mean over three years of the total number of exceedances of the standard. Because the data for
this analysis covered only a single year, this analysis assumed the three analogous monitored
values for each averaging year will be the same. In this way, a single year's worth of data can fully
describe the three year averaging period. For the average number of exceedances over three years
to be greater than one, there must be at least four exceedences in three years. Since the highest
value in the analysis' model represents three years' worth of identical data, the fourth highest
value over three years - the one that would trigger nonattainment - must necessarily be the same
as the second daily highest value from the modeled data. In other words, the design value for each
county was established by identifying the highest value for each day, removing that day from the
analysis, and selecting the highest remaining daily value.
The 1H1EX-120 and the 8H2AX-90 forms of the standard are analytically the same.
Therefore, the remainder of this discussion will refer only to the 1H1EX-120 form with the clear
understanding that the discussion applies equally to both forms The staff identified thirty four
modeled nonattainment counties in the year 2007 for the current 1H1EX-120 standard. Assigning
these counties to nonattainment areas added an additional forty seven counties, for a total of
eighty one counties in twenty nonattainment areas. These areas ranged in size from twenty three
counties in the New York nonattainment area to single county nonattainment areas in Bakersfield,
4 40 Code of Federal Regulations part 50, §50.9(a).
VI-5
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Fairfield, New Haven, Reno, San Diego, Santa Barbara, and Visalia. Ten of the identified
nonattainment areas were within the Regional Oxidant Model (ROM) domain. California had
fifteen counties in seven nonattainment areas. Three areas were located in Non-ROM-Not-
California (NRNC) areas. Fourteen of the twenty nonattainment areas had a maximum expected
ozone concentration of less than 138 ppm and therefore were considered to be in "marginal"
nonattainment.
TABLE VI-1
Total Costs for the Current (1H1EX-120) and 8H2AX-90
Standards In the Year 2007
VOC
NOx
TOTAL
VOC
NOx
TOTAL
Area
Cost*
Cost"
cosr
Area
Cost*
Cost'
cosr
Bakersfield
$7.9
$0.0
$7.9
Los Angeles
$265.7
$0.0
$265.7
Baton Rouge
$14.5
$0.0
$14.5
New York
$271.8
$192.0
$463.8
Houston*
$416.7
$0.0
$416.7
San Diego
$439
$0.0
$439
TOTALS $1,020.6 $192.0 $1,212.5
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
The six remaining nonattaiment areas would require VOC or NOx control strategies to
reduce ozone concentrations to the level of the standard These areas included Bakersfield, Los
Angeles, and San Diego in the West; and Baton Rouge, Houston, and New York in the East,
totaling forty one counties, seven in the West and thirty four in the Eastern United States. In the
East, modeled ozone concentrations ranged from 146 ppm in New York to 173 ppm in Houston.
Los Angeles recorded the highest expected 2007 ozone concentration of 276 ppm. These costs
are a part of the baseline and are reported here for purposes of completeness. Of the six
nonattainment areas which would require the application of control measures, Baton Rouge was
the only area able to reach its targeted reductions. Of the remaining five, Houston was the only
area which was able to reach at least seventy-five percent of its targeted emissions.5 Houston was
identified as an area within the range of uncertainty for this analysis and counted as a potential
attainment area. The remaining four nonattainment areas were identified as having residual
nonattainment.
Table VI-1 lists the costs for nonattainment areas expected to require additional control
measures to achieve the current standard, given the implementation of CAA requirements and a
regional strategy in the East. Appendix B, Table B-l fists the counties within each of the current
standard nonattainment areas. The VOC and NOx targets established to attain the current
standard after the imposition of RCS baseline items result in an expected reduction of
5 c.f., Chapter V, section E for a discussion of this assumption.
VI-6
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approximately 38 thousand tons of NOx per year and 333 thousand tons of VOC. NOx reductions
above and beyond the CAAA requirements necessary to attain the current standard will cost an
expected $192 million annually. VOC reductions will cost another $1 billion, for a total baseline
cost to achieve the current standard of $1.2 billion per year, or roughly, $5 per year per capita.6
VI(B)(l)(b) ALTERNATIVE 8H5EX-80
The staff identified seventy three modeled nonattainment counties in the year 2007 for the
8H5EX-80 standard. Assigning these nonattainment counties to nonattainment areas added ninety
two more counties, for a total of 167 nonattainment counties in thirty one nonattainment areas.
New York contained the largest number of counties with twenty three. Eight areas became single
county nonattainment areas. Twenty of the identified nonattainment areas were in the ROM
domain. Nine areas were in California and two were located in NRNC areas.
Twenty one of the thirty one identified nonattainment areas had a maximum estimated
ozone concentration of less than .092 ppm7. Of the remaining ten, five were in the ROM domain
and five were in California. None of the remaining nonattainment areas were in the NRNC
domain. Table VI-2 lists the costs for nonattainment areas where VOC or NOx controls would be
required. Appendix B, Table B-2 lists the counties within each of the 8H5EX-80 nonattainment
areas. None of the ten Greater-Than-Marginal nonattainment areas could achieve their VOC or
NOx targets for the 8H5EX-80 standard, and only Baton Rouge and Houston were able to
achieve at least seventy five percent of their targets. Consequently, the staff identified Baton
Rouge and Houston as the only 8H5EX-80 areas potentially able of attaining the standard and
defined the other eight nonattainment areas as residual nonattainment.
The VOC and NOx strategies for the 8H5EX-80 standard result in an expected reduction
of approximately 23 thousand tons of NOx and 27 thousand tons of VOC per year beyond the
reductions which occur to as part of the baseline. NOx reductions beyond those necessary to
attain the current standard in 2007 will cost approximately $117 million annually. The annual cost
of additional VOC controls will run an expected $138 million. The staff estimates the total
marginal cost to achieve the 8H5EX-80 standard at $255 million per year, or about $1 annually
per capita.
Most of the costs arise from the inclusion of additional nonattainment areas relative to the
identified areas which required additional controls beyond the 2007 baseline to achieve the current
standard. This makes cost comparisons misleading. While the stringency of the standard appears
to have increased from the current standard, the availability of controls has not. Areas where the
6 The ozone NAAQS is a national rule, potentially affecting every citizen of the United States. Therefore, the
staff employed a per capita valuation which distributed costs across the entire United States, rather than for just
the populations within nonattainment areas.
7 92 ppm was determined to be an analogous Marginal nonattainment level for an eight hour standard. A
discussion of this value and the methodology employed to achieve it can be found in Chapter I V(D)(2):
"Identification of Marginal Nonattainment Areas".
VT-7
-------
staff predicts current standard residual nonattainment area also areas of predicted residual
nonattainment for each (more stringent) alternative standard as well. Therefore, while precursor
TABLE VI-2
Marginal Costs for the 8H5EX-80 Standard
In the Year 2007
VOC
NOx
Total
VOC
NOx
Total
Area
Cost*
Cost*
Cost*
Area
Cost*
Cost*
Cost*
Atlanta, GA
$76.6
$110.8
$187.3
Houston, TX *
$0.0
$0.0
$0.0
Atlantic City
$3.3
$6.1
$9.4
Los Angeles, CA
$0.0
$0.0
$0.0
Bakersfield, CA
$0.0
$0.0
$0.0
New York, NY
$0.0
$0.0
$0.0
Baton Rouge, LA *
$16.1
$0.0
$16.1
Sacramento, CA
$22.2
$0.0
$22.2
Fresno, CA
$19.3
$0.2
$19.4
San Diego, CA
$0.0
$0.0
$0.0
TOTALS $137.5 $117.0 $254.5
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
targets increase to accommodate the stricter standard, there are no additional controls available to
address this increase. Of the six current standard areas predicted to need additional control
beyond the RCS baseline, only Baton Rouge had an increase in control measures. This increase
happened because the additional stringency of the 8H5EX-80 standard increased the size of the
Baton Rouge nonattainment area by one county. For the other five areas, either they were areas of
residual nonattainment and had no additional controls available, or they were new nonattainment
areas (e.g., Atlanta) and had positive marginal costs. The economic impacts of the 8H5EX-80
standard are fully discussed in Chapter VII "Summary of potentially Affected Entities" and
Chapter VIII "Economic Assessment".
VI(B)(l)(c) ALTERNATIVE 8H4AX-80
For the 8H4AX-80 standard, the staff identified eighty five modeled nonattainment
counties in the year 2007. Assigning these nonattainment counties to nonattainment areas added
an extra 117 counties, for a total of 202 nonattainment counties in thirty seven nonattainment
areas. The New York nonattainment area contained twenty three counties, the largest for the
8H4AX-80 standard. Ten areas became single county nonattainment areas. Twenty six of the
identified nonattainment areas were in the ROM domain., an additional eight areas were in
California and three were located in NRNC areas. Shaded area indicates where the available VOC
and NOx control measures were potentially sufficient to attain the standard.
VT-8
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TABLE VI-3
Marginal Costs for the 8H4AX-80 Standard
in the Year 2007
VOC
NOx
Total
VOC
NOx
Total
Area
Cost*
Cost*
Cost*
Area
Cost*
Cost*
Cost*
Atlanta, GA
$77.6
$110.8
$187.3
Modesto, CA
$7.0
$0.0
$7.0
Atlantic City
$3.3
$6.1
$9.4
New York, NY
$0.0
$0.0
$0.0
Bakersfield, CA
$0.0
$0.0
$0.0
Philadelphia, PA
$237.5
$83.1
$320.6
Baton Rouge, LA
$16.1
$0.0
$16.1
Portland, OR *
$40.9
$2.9
$43.9
Fresno, CA
$19.3
$0.2
$19.4
Sacramento, CA
$22.2
$0.0
$22.2
Houston, TX *
$0.0
$0.0
$0.0
San Diego, CA
$0.0
$0.0
$0.0
Los Angeles, CA
$0.0
$0.0
$0.0
Visalia, CA
$3.8
$0.0
$3.8
TOTALS $423.0 $203.0 $626.0
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
Twenty three of the thirty seven nonattainment areas had a maximum estimated ozone
concentration of less than 92 ppm. Of the remaining fourteen nonattainment areas, six were in the
ROM domain, seven were in California, and one was in the NRNC domain. Table VI-3 lists the
nonattainment areas for which VOC or NOx controls would be required.fAppendix A, Table A-3
lists the counties within each of the sixty eight 8H4AX-80 nonattainment areas. Only the Portland,
Oregon nonattainment area could reach its targeted reductions. Of the remaining thirteen
nonattainment areas, only Houston had sufficient control measures available to reach at least
seventy five percent of its target and was determined to be within the range of uncertainty and
potentially able to attain the standard. The remaining twelve areas have residual nonattainment.
The VOC and NOx targets found in Table VI-3 result in an expected marginal reduction
of approximately 50 thousand tons of NOx and 115 million tons of VOC per year. NOx
reductions beyond the analytical baseline and any additional reductions necessary to attain the
current standard will have a marginal cost of about $203 million annually. VOC reductions will
have a marginal cost of about $423 million annually. Total predicted marginal costs for the
8H4AX-80 standard will reach about $626 million annually. On a per capita basis, the marginal
cost of the 8H4AX-80 standard relative to the current standard, is approximately $3 per year.
Chapters VII "Summary of potentially Affected Entities" and Chapter VE "Economic
Assessment" of this RIA include discussions of the affects of the strategies used to meet the
8H4AX-80 standard.
VI-9
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VI(B)(l)(d) ALTERNATIVES 8H1AX-80 AND 8H4AX-70
The 8H1AX-80 and the 8H4AX-70 forms of the standard are analytically the same.
Therefore, the remainder of this discussion will refer only to the 1H1EX-120 form with the clear
understanding that the discussion applies equally to both forms. The staff identified 236 modeled
nonattainment counties in the year 2007 for the 8H1 AX-80 standard. When these nonattainment
counties were assigned to nonattainment areas, 191 additional counties were added, for a total of
427 nonattainment counties in seventy five nonattainment areas. The Washington D.C. /
Baltimore nonattainment area contained the largest number of counties, with twenty nine
counties. Seventeen counties became single county nonattainment areas, seven in the West and
ten in the East. The staff classified five Eastern single county nonattainment areas as marginal.
Fifty seven of the identified nonattainment areas were in the ROM domain. Thirteen
nonattainment areas were in California and five areas were located in NRNC areas. Thirty five of
the seventy five nonattainment areas had a maximum estimated ozone concentration of less than
92 ppm. Of the remaining forty, twenty five were in the ROM domain, nine were in California,
and six were in the NRNC domain. Three of the forty nonattainment areas for which controls
needed to be identified were able to achieve their targeted reductions. Thirteen more areas could
reach at least seventy-five percent of their targeted reductions and were determined to be within
the analysis' range of uncertainty. These areas were identified as potentially able to achieve the
standard. The remaining twenty-four nonattainment areas were identified as areas of residual
nonattainment. Table VI-4 lists the nonattainment areas for which VOC or NOx controls would
be required to attain the 8H1 AX-80 standard. Appendix A, Table A-4 lists the counties within the
8H1AX-80 nonattainment areas
VOC and NOx targets result in an expected reduction of approximately 290 thousand tons
of NOx per year and about 660 thousand tons of VOC beyond that necessary to meet the current
standard. Marginal NOx reductions will cost an expected $702 million annually, and marginal
VOC reductions will cost another $1.8 billion, for a total marginal cost to achieve the 8H1 AX-80
standard of $2.5 billion per year. The marginal cost per capita for control measures to attain the
8H1 AX-80 standard is about $10 per year. The economic impacts of the 8H5EX-80 standard are
fully discussed in Chapter VII "Summary of potentially Affected Entities" and Chapter VIE
"Economic Assessment".
VI-10
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TABLE VI-4
Marginal Costs for the 8H1AX-80 and 8H4AX-70 Standards In 2007
Area
VOC
Cost*
NOx
Cost*
Total
Cost*
Area
VOC
Cost*
NOx
Cost*
Total
Cost*
Atlanta, GA
$80.6
$121.2
$201.8
Muskegon
$7.9
$2.8
$10.7
Atlantic City
$3.3
$6.1
$9.4
Nashville, TN *
$22.0
$43.3
$65.4
Bakersfleld, CA
$0.0
$0.0
$0.0
New London, CT
$23.3
$20.4
$43.7
Balt./Wash. D.C.
$79.3
$2.0
$81.3
New Orleans, LA*
$1.9
$3.5
$5.4
Baton Rouge, LA
$16.1
$0.0
$16.1
New York, NY
$0.0
$0.0
$0.0
Beaumont. TX
$193.4
$0.0
$193.4
Philadelphia, PA
$237.5
$83.1
$320.6
Chicago, IL
$196.0
$111.1
$307.1
Phoenix, AZ
$54.3
$Z4
$56.7
Cincinnati, OH *
$62.4
$32.0
$94.4
Portland, ME *
$0.1
$17.7
$17.9
Dallas, TX *
$172.3
$4.1
$176.4
Portland, OR*
$41.7
$3.5
$45.2
Eugene, OR
$3.1
$1.9
$5.0
Providence, Rl
$22.1
$13.8
$36.0
Fairfield
$10.9
$14.3
$25.2
Redding, CA
$4.7
$1.7
$6.4
Fresno, CA
$22.6
$0.6
$23.2
Reno, NV
$6.3
$0.2
: $6.5
Grand Rapids, Ml *
$69.6
$14.2
$83.8
Sacramento, CA
$23.2
$0.7
$23.9
Hartford, CT
$26.7
$22.4
$49.1
St. Louis, MO «
S232X)
:: $47.7
$279.7
Houston, TX*
$6.6
$0.1
¦:¥: *7.2
San Diego, CA
$0.0
$0.0
$0.0
Huntington, WV
$21.5
$6.0
$27.5
Santa Barbara, CA
$4.1
$0.2
$4.3
Knoxvilte.TN'
$48.2
$41.3 .
: $89.5
Seattle, WA
$93.3
$80.4
$173.7
Los Angeles, CA
$0.0
$0.0
$0.0
Stockton, CA
$6.8
$0.0
$6.8
Manitowoc
$7.9
$2.5
$10.4
TeflCity*
$0.2
$0.3
$0.4
Modesto, CA
$7.0
$0.0
$7.0
Visalia, CA
$4.2
$0.0
$4.2
TOTALS $1,813.1 $702.0 $2,515.1
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the
standard, asterisks indicate areas within the range of uncertainty which could potentially attain while achieving less than
100% of their targeted reductions.
VI-11
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VI(B)(2) THE SECONDARY STANDARD
The costs and health benefits of a separate secondary standard have not been estimated.
However, a number of inferences can be made from the results of the welfare benefits analysis
under the full attainment scenarios. For the proposed standard, monetized benefits from
commodity crops of the most stringent secondary standard incremental to the primary standard
are close to zero. This indicates that the proposed primary standard is binding for those areas
where commodity crops are grown (which includes California). For these areas, there would be
no incremental improvements and, therefore, no additional costs or health benefits. For areas
where we do not know if the proposed primary standard is binding (areas where commodity crops
are not grown), the air quality database created to perform the commodity crops analysis could be
used to estimate any additional health benefits. These benefits are expected to be small because
the benefits curves flatten as the air quality improves marginally. The costs, if existing, would be
best determined under the implementation strategies developed under the part 51 rule.
VI(C) COMPARISON OF ALTERNATIVE PRIMARY STANDARDS
As stated above among the caveats, one must be careful when comparing alternative forms
of the standard. As the above analyses indicate, each alternative reaches a different endpoint vis a
vis the location, size, and degree of residual nonattainment. Therefore, while it may appear
straight forward to infer one of the alternative standards is more costly than the current standard,
that conclusion is not appropriate. However, the Staff Paper sets out a process through which
different standards can be compared (EPA, 1996). In Appendix A of the Staff Paper, the Agency
equates the five expected exceedance form of the 0.08 ppm eight hour ozone standard with the
fifth highest average daily maximum ozone concentration 0.08 ppm eight hour form, based on
three considerations: (1) the same year's inventory data, (2) the same meteorology applied to each
standard, and (3) the same number of identified nonattainment counties under each standard.
Given the first two conditions hold for this RIA, similar conclusions can be reached here. If a
standard has more nonattainment counties associated with it, one can reasonably expect that
standard to provide greater protection than a standard with fewer identified nonattainment
counties. In this manner, the application of 1990 inventory data grown to 2007 and 1987
meteorology indicates the least protective form of the standard examined is the current 1H1EX-
120 form. In order of increasing protection, the 8H5EX-80 form ranks second, the 8H4AX-80
form ranks third, and the 8H1AX-80 form is the most protective.
Costs are not a reliable metric, but for another reason. While it is true that costs increase
as the rank ordering of the three alternatives increases, the differences in cost, (or, more directly,
the lack of differences) are an artifact of the maximal application of control measures within areas
which experience residual nonattainment. For example, Tables VI-2, 3, and 4 lists a zero marginal
cost for each alternative standard in Los Angeles. Because Los Angeles is a residual
VI-12
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nonattainment area for each eight hour standard analyzed in this RIA, the true cost of attaining
each alternative standard in Los Angeles cannot be determined. Consequently, while it may offer
some insight into the relative costs associated with each standard, aggregate total costs
underestimate the true cost of each alternative to such an extent that the metric's reliability must
be limited. The usefulness of cost as a measurement of relative severity cannot be applied even
within the same nonattainment area. Again using Los Angeles as an example, one would expect
the strategies associated with increasingly restrictive standards to require increasing numbers of
controls. Because the definition of Los Angeles' nonattainment area does not change between
standards, neither does the set of control measures within each control strategy. While this may
seem obvious, less apparent is the situation within Atlanta. A nonattainment area under each
alternative, the 8H5EX-80 and the 8H4AX-80 forms include the same twenty counties in
FIGURE VI-1
THE NUMBER OF COUNTIES IN DIFFERENT NONATTAINMENT
CATEGORIES BY ALTERNATIVE STANDARDS
8H5EX-80
8H4AX-80 8H1AX-80
Marginal Nonattainment
GTM Areas Which Can Attain
Residual Nonattainment
GTM refers to areas in categories "Greater Than Marginal"
VI-13
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Atlanta's nonattainment area definition. However, for the most stringent eight hour standard, five
more counties join the Atlanta nonattainment area definition. The additional $6 million associated
with these five counties represents the inclusion of all available controls in the Atlanta control
FIGURE VI-2
THE MARGINAL INCREASE IN POPULATION WITHIN NONATTAINMENT
CATEGORIES FOR EACH ALTERNATIVE
250 -,
1150
i
C
C
o
8H5EX-80 8H4AX-80
8H1AX-80
Marginal Nonattainment
GTM Areas Which Can Attain
Residual Nonattainment
GTM refers to areas in categories "Greater Than Marginal'
strategy - nothing more. It does not represent the marginal cost of going from the 8H4AX-80
standard to the 8H1AX-80 standard because in each case, the area remains nonattainment but
represents different partial attainment air quality, different effected populations, and different
geographic areas.
If no single metric will work to compare alternative standards, perhaps the limited
usefulness of a number of different comparisons can combine to tell a reasonable story. Given the
above caveats, Figure VI-1 shows the relative number of counties in different nonattainment
classifications. Figure VI-2 displays the distribution of populations between marginal and worse-
than-marginal nonattainment classifications under the three alternatives. The values are presented
in millions of persons. Figure VI-3 displays the relative cost for available control measures for
VI-14
-------
each alternative. The values are presented in millions of 1990 dollars. Figure VI-4 displays the
relative cost per capita for each alternative, in 1990 dollars.
FIGURE VI-3
THE MARGINAL COST OF AVAILABLE CONTROL MEASURES TO ATTAIN
ALTERNATIVE STANDARDS
$12.00
$10.00
o
? $8.00
C
"55
o
O
f $6.00
10
O
k.
o»
a.
«
c
S $4.00
(0
$2.00
$0.00
Within the limitations of comparison listed above, of the alternative eight hour primary
ozone standards analyzed by this RIA, the 8H5EX-80 standard ranks as least restrictive in terms
of number of nonattainment areas (thirty one), size of nonattainment areas (167 counties), and
marginal cost of reaching VOC and NOx targets ($255 million).1 It also has the smallest
population in residual nonattainment (46 million people). The standard is also the least costly on a
per capita basis, with an expected annual per capita cost of about one dollar more than that of the
current standard. The 8H5EX-80 standard has the smallest amount of residual nonattainment,
with intractable areas clustered primarily in those areas which one would most expect persistent
8H5EX-80 8H4AX-80 8H1AX-80
1 This is the cost of available measures, without estimating the cost of residual nonattainment.
VI-15
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nonattainment to exist: Southern California and along the Ozone Transport Corridor between
Northern Virginia and New Hampshire.
FIGURE VI-4
MARGINAL COST PER CAPITA FOR ALTERNATIVE OZONE NAAQS
3000
2500
2000
S 1500
c
o
1000
500
8H5EX-80
8H4AX-80
8H1AX-80
Areas Which Can Attain ||||j Residual Nonattainment Areas
The 8H4AX-80 standard ranks next in terms of marginal cost ($626 million), number of
nonattainment areas (37), and the number of counties contained within them (202). The marginal
cost of the 8H4AX-80 standard is nearly two and a half times that of the 8H5EX-80 standard.
The counties within 8H4AX-80 nonattainment areas represent a twenty percent increase over the
8H5EX-80 form, with residual nonattainment centered on the same geographic areas, but
somewhat larger in area than under the 8H5EX-80 form. Almost fifteen percent more people (13
million) would live in nonattainment areas under the 8H4AX-80 standard versus the 8H5EX-80
standard. The per capita cost of control strategies adds an extra three dollars to that of the current
standard.
VI-16
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The most restrictive alternative examined by this RIA is the 8H1AX-80 standard, under
which 427 counties are designated as part of nonattainment areas, over twice that of the 8H4AX-
80 standard. Residua! nonattainment is also more pervasive, spreading even further beyond the
8H5EX-80 form's residual nonattainment boundaries. This RIA estimates the marginal control
strategy cost for the 8H1AX-80 standard to be $2.5 billion, over four and a half times that of the
8H4AX-80 standard. Per capita, the 8H1AX-80 standard does no better, increasing the per capita
cost of the current standard by about $10 per year.
VI(D) CONCLUSIONS OF THE REGIONAL CONTROL SCENARIO ANALYSIS
In terms of area affected, populations affected, costs, and the pervasiveness of residual
nonattainment, the 8H5EX-80 form of the standard has the least measurable impact beyond that
associated with not changing the current standard. Under the above ranking criteria, the 8H4AX-
80 ozone standard ranks second and the 8H1AX-80 form ranks last. The proposed standard falls
somewhere between the 8H4AX-80 and the 8H1AX-80 forms in terms of costs, number of
affected counties, number of nonattainment areas, and the number of residual nonattainment
areas. However, given the caveats associated with this RIA's analytical methodology, its
inventories, and its inability to resolve the residual nonattainment problem, the relative ranking of
alternatives cannot be considered conclusive.
VT(E) EMISSION REDUCTIONS AND COSTS UNDER THE LOCAL CONTROL
SCENARIO
For purposes of completeness, the staff performed a sensitivity analysis assuming current
regional efforts are not successful and only local controls may be used to address ozone problems.
The LCS baseline, therefore, includes the full implementation of current CAA requirements for
reductions and projected emissions growth by SIC code in accordance with the methodologies
described in Chapter IV of this RIA. The following sections of this chapter perform the same
analyses discussed above - only without the application of a regional control strategy in the ROM
domain. For the West, nonattainment areas and targets are the same as those employed in the
RCS baseline analysis. The costs, number of counties, number of nonattainment and residual
nonattainment areas for each alternative under this LCS analysis indicate the same relative ranking
as that shown for the baseline analysis. In addition, the costs, populations, and nonattainment area
counts for each alternative are higher under the LCS than under their respective RCS analyses.
VI(E)(1) SUMMARY OF TOTAL EMISSION REDUCTIONS AND CONTROL COSTS
BY NONATTAINMENT AREA
Based upon the control strategy selection process described in Chapter V, Section D, the
staff observed the following cost impacts on the three alternative ozone primary standards when
VI-17
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performing its sensitivity analysis based upon an ozone concentration baseline that does not
include the include a regional control scenario in the East. Counterintuitive results (e.g.,
reductions in tons reduced under stricter standards) are an artifact of the process through which
nonattainment areas are identified and should not be considered errors.
VI(E)(l)(a) THE CURRENT STANDARD (1H1EX-120) AND THE 8H2AX-90
ALTERNATIVE
The 1 HI EX-120 and the 8H2AX-90 forms of the standard are analytically the same. The
remainder of this discussion will refer only to the 1H1EX-120 form with the clear understanding
that the discussion applies equally to both forms. The staff identified sixty five modeled
nonattainment counties in the year 2007 for the current 1H1EX-120 standard under the LCS.
When these nonattainment counties were assigned to nonattainment areas in accordance with
current part 51 implementation practices, it identified 141 additional counties, for a total of 206
counties in twenty seven nonattainment areas. Seventeen of the twenty seven nonattainment areas
had a maximum expected ozone concentration of less than 138 ppm. Of the ten remaining
nonattaiment areas which would be required to implement VOC or NOx control strategies to
attain the current standard, three were in California and the remainder were in the ROM domain.
Of the ten, only Beaumont had sufficient measures to attain the current standard. No area fell
within the seventy five percent "range of uncertainty", so the staff identified all nine remaining
areas as in residual nonattainment. Table IV-5 lists the costs associated with attainment strategies
for the current standard under the LCS. Appendix A, Table A-5 lists the counties within each of
the current standard nonattainment areas under the LCS.
TABLE VI-5
Supplemental Analysis:
Total Costs for the Current (1H1EX-120) and 8H2AX-90
Standards In the Year 2007 Under the LCS
VOC
NOx
TOTAL
VOC
NOx
TOTAL
Area
Cost*
Cost'
cost*
Area
Cost*
Cost'
cosr
Bakersfield
$7.9
$0.0
$7.9
Los Angeles
$265.7
$0.0
$265.7
Baton Rouge
$33.7
$2.0
$35.8
New London
$7.2
$7.0
$14.2
Beaumont
$193.4
$0.0
$193.4
New York
$359.5
$278.0
$637.5
Boston
$21.8
$305.3
$327.1
Philadelphia
$252.3
$98.1
$350.5
Houston
$437.1
$13.8
$450.9
San Diego
$43.9
$0.0
$43.9
TOTALS $1,622.5 $704.3 $2,326.8
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
VI-18
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The VOC and NOx targets established to attain the current standard under the LCS
scenario result in an expected reduction of approximately 182 thousand tons of NOx per year and
578 thousand tons of VOC. NOx reductions will cost an expected $700 million annually. VOC
reductions will cost another $1.6 billion, for a total baseline cost to achieve the current standard
of $2.3 billion per year, or about $9 per year per capita, almost twice the per capita cost
associated than with the current standard under the RCS.
VI(E)(l)(b) ALTERNATIVE 8H5EX-80
The staff identified 166 modeled nonattainment counties in the year 2007 for the 8H5EX-
80 standard. Assigning these nonattainment counties to nonattainment areas resulted in a
total of 374 nonattainment counties in fifty seven nonattainment areas. Thirty five of the fifty
seven nonattainment areas had a maximum estimated ozone concentration of less than 92 ppm. Of
the remaining twenty two nonattainment areas, seventeen were in the ROM domain, the other five
were in California. Table VI-6 lists the marginal cost in nonattainment areas for which VOC or
NOx controls would be required. Appendix B, Table B-6 lists the counties within each of the
8H5EX-80 standard nonattainment areas under the LCS. Three nonattainment areas could
achieve their targets for the 8H5EX-80 standard. Two more areas came within twenty five
percent of their VOC or NOx targets and the technical team determined they were probably able
to attain the 8H5EX-80 standard. The other seventeen nonattainment areas were identified as
having residual nonattainment.
The VOC and NOx controls in Table VI-6 result in an expected reduction of
approximately 100 thousand tons of NOx per year and 350 thousand tons of VOC per year
beyond that which is required to meet the current standard. Marginal NOx reductions carry an
expected marginal cost of $1.2 billion annually. VOC reductions will have an expected marginal
cost of $322 million, for a total marginal cost to achieve the 8H5EX-80 standard under
the LCS of $1.5 billion per year. On a per capita basis, the staff expects the marginal cost per
person per year for the 8H5EX-80 standard under the LCS to be about $6, an increase in marginal
per capita costs over the 8H5EX-80 alternative under an RCS of approximately six times. These
impacts are fully discussed in Chapter VII "Economic Assessment".
VI-19
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TABLE VI-6
Supplemental Analysis:
Marginal Costs for the 8H5EX-80 Standard In the Year 2007
Under the LCS
VOC
NOx
TOTAL
VOC
NOx
TOTAL
Area
Cost*
Cost'
cosr
Area
Cost*
Cost'
COST*
Athens, GA
$4.6
$6.6
$11.2
Macon, GA *
$10.2
$122.4
$132.6
Atlanta, GA
$98.1
$408.6
$506.7
Nashville, TN
$25.9
$84.0
$109.9
Bakersfield, CA
$0.0
$0.0
$0.0
New London, CT
$0.0
$0.0
$0.0
Baton Rouge, LA
$0.0
$0.0
$0.0
New Yorfc, NY
$0.0
$0.0
$0.0
Beaumont, TX
($193.4)
$0.0
($193.4)
Owensboro, KY
$1.9
$29.4
$31.3
Boston, MA
$21.8
$305.2
$327.0
Philadelphia, PA
$0.0
$0.0
$0.0
Cincinnati, OH"
$50.3
($265.0)
($214.7)
Providence, Rl
$26.5
$18.6
$45.0
Fresno, CA
$19.3
$0.2
$19.4
Sacramento, CA
$22.2
$0.0
$22.2
Grand Rapids, Ml
$78.6
$20.1
$98.7
San Diego, CA
$0.0
$0.0
$0.0
Hartford, CT
$25.0
$23.8
$48.8
Springfield, MA
$2.5
$30.9
$33.4
Houston, IX
$7.1
$1.1
$8.2
Washington D.C.
$121.6
$440.5
$562.1
Los Angeles, CA
$0.0
$0.0
$0.0
TOTALS
$322.2
$1,226.3
$1,548.4
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
VI(E)(l)(c) ALTERNATIVE 8H4AX-80
The staff identified 207 modeled nonattainment counties in the year 2007 for the 8H4AX-
80 standard under the LCS. Assigning these nonattainment counties to nonattainment areas added
225 more counties, for a total of 432 nonattainment counties in sixty eight nonattainment areas.
Fifty three of the identified nonattainment areas were in the ROM domain. Nine areas were in
California and three areas were located in NRNC areas. Thirty eight of the sixty eight
nonattainment areas had a maximum estimated ozone concentration of less than 92 ppm. Of the
remaining thirty nonattainment areas, twenty one were in the ROM domain, seven were in
California, and one was in the NRNC domain. Table VI-7 lists the marginal costs for
nonattainment areas for which VOC or NOx controls would be required. Appendix A, Table A-7
VI-20
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TABLE VI-7
Supplemental Analysis:
Marginal Costs for the 8H4AX-80 Standard In the Year 2007 Under the LCS
Area
VOC
Cost*
NOx
Cost*
Total
Cost*
Area
VOC
Cost*
NOx
Cost*
Total
Cost*
Athens, GA
$4.6
$6.6
$11.2
Los Angeles, CA
$0.0
$0.0
$0.0
Atlanta, GA
$98.1
$408.6
$506.7
Macon, GA*
$10.6
$123.1
$133.7
Bakersfield, CA
$0.0
$0.0
$0.0
Modesto, CA
$7.0
$0.0
$7.0
Bangor, ME *
$4.6
$16.0
$20.8
Nashville, TN *
$25.9
$84.8
$110.7
Baton Rouge, LA
$0.0
$0.0
$0.0
New London, CT
$0.0
$0.0
$0.0
Beaumont, TX
$0.0
$0.0
w.o
New York, NY
$0.0
$0.0
$0.0
Boston, MA
$0.0
$0.0
$0.0
Owensboro, KY
$3.1
$52.1
$55.1
Chicago, IL
$293.8
$81.2
$375.0
Philadelphia, PA
$0.0
$0.0
$0.0
Cincinnati, OH *
$721
$40.3
$112.4
Portland, OR *
$40.9
$2.9
$43.9
Dallas, TX *
$195.5
$97.0
$292.6
Providence, Rl
$26.5
$18.6
$45.0
Fresno, CA
$19.3
$0.2
$19.4
Sacramento, CA
$22.2
$0.0
$22.2
Grand Rapids, Ml *
$80.6
$20.1
$100.7
San Diego, CA
$0.0
$0.0
$0.0
Hartford, CT
$25.0
$23.8
$48.8
Springfield, MA
$2.5
$30.9
$33.4
Houston, TX
$7.1
$3.6
$10.7
Visalia, CA
$3.8
$0.0
$3.8
Huntington, VW
$22.9
$7.5
$30.4
Washington, D.C.
$121.6
$142.1
$263.8
TOTALS $1,087.9 $1,159.3 $2,247.2
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
lists the counties within each of the 8H4AX-80 nonattainment areas under the LCS.
Three nonattainment areas could reach their targets. Six other nonattainment area had
sufficient reductions available to reach at least seventy five percent of their VOC and NOx target.
The staff identified the remaining twenty one nonattainment areas as having residual
nonattainment. The VOC and NOx targets found in Table VI-7 result in an expected reduction of
approximately 450 thousand tons of NOx per year and 400 thousand tons of VOC per year
beyond the reductions necessary for the current standard. Marginal NOx reductions to attain the
8H4AX-80 standard have an expected marginal cost of $1.4 billion annually. VOC reductions will
have an expected marginal cost of $ 1.1 billion, for a total marginal cost to achieve the 8H4AX-80
standard of $2.5 billion per year. The staff expects the LCS scenario per capita marginal cost to
attain the 8H4AX-80 standard will be about $10, or four times greater than the marginal per
capita cost of the 8H4AX-80 standard under the RCS.
VI-21
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TABLE VI-8
Marginal Costs for the 8H1AX-80 and 8H4AX-70 Standards In the Year 2007 Under the LCS
VOC
NO*
Total
VOC
NOx
Total
Allentown, PA
$10.6
$10.2
$20.8
Louisville, KY
$97.3
$27.7
$124.9
Athens, GA
$4.2
$6.0
$10.2
Macon, GA
$13.0
$129.7
$142.7
Atlanta, GA
$103.8
$417.6
$521.4
Memphis. TN *
$60.3
$116.9
$177.2
Augusta, GA
$13.8
$89.3
$103.1
Milwaukee, Wl
$46.7
$33.2
$79.9
Austin, TX
$6.3
$3.7
$10.0
Mobile, AL
$45.2
$2.1
$47.2
Bakersfield, CA
$0.0
$0.0
$0.0
Modesto, CA
$7.0
$0.0
$7.0
Bangor, ME
$5.3
$26.3
$31.6
Nashville, TN
$29.9
$95.2
$125.2
Barnstable, MA *
$0.7
$25.3
$26.0
New London, CT
$0.0
$0.0
$0.0
Baton Rouge, LA
$0.7
$0.2
$0.9
New Orleans, LA
$50.5
$7.0
$57.5
Beaumont, TX
$0.0
$0.0
$0.0
New York, NY
$8.1
$6.9
$15.0
Birmingham, AL
$24.8
$181.0
$205.7
Norfolk, VA*
$14.8
$138.0
$152.8
Boston, MA
$0.0
$0.0
$0.0
Owensboro, KY *
$3.1
$52.4
$55.5
Charlotte, NC
$31.4
$191.8
$223.2
Philadelphia, PA
$0.0
$0.0
$0.0
Chattanooga, TN
$19.0
$37.2
$56.3
Phoenix, AZ
$54.3
$2.4
$56.7
Chicago, IL
$293.8
$81.2
$375.0
Pittsburgh, PA
$39.2
$49.3
$88.6
Cincinnati, OH *
$99.6
$43.4
$143.0
Portland, ME
$1.1
$32.4
$33.5
Columbia, SC
$13.0
$92.0
$105.0
Portland, OR
$41.7
$3.5
$45.2
Columbus, OH
$11.5
$6.6
$18.1
Providence, Rl
$26.5
$18.6
$45.0
Dallas, TX *
$205.0
$21.2
$226.2
Raleigh, NC *
-$26.4
$121.7
$148.1
Dayton, OH
$212
$0.9
$22.1
Redding, PA
$4.7
$1.7
$6.4
Detroit, Mi
$190.0
$109.4
$299.5
Redding, CA
$24.1
$5.8
$29.9
Dover, DE
$9.9
$11.1
$21.0
Reno, NV
if-:. $6.3:
$0.2
$6.5
Eugene, OR
$3.1
$1.9
$5.0
Richmond, VA
$15.6
$109.4
$125.0
EvansviBe, IN
$3.0
$1.5
: $4.4
Rochester, NY*
, . $107.9
$22.6
$130.5
Fresno, CA
$22.6
$0.6
$23.2
Sacramento, CA
$23.2
$0.7
$23.9
Gadsden, AL
$5.4
$17.1
$22.5
St. Lotas, MO *
: $252.5
; $61.3
$313.7
Grand Rapids, Ml
$91.4
$24.9
$116.2
San Diego, CA
$0.0
$0.0
$0.0
Green Bay, Wl
$23.4
$8.0
$31.5
Santa Barbara, CA
$4.1
$0.2
$4.3
Greensboro, NC
$34.0
$127.3
$161.2
Seattle. WA
• $93.3
$8&4
$173.7
Harrisburg, PA
$9.8
$12.7
$22.5
Sherman, TX :
; $0.9
$0.7
$1.6
Hartford, CT
$25.0
$23.8
$48.8
Shreveport, LA ;
$10.0
. $1.8
$11.7
Houston, TX
$15.1
$1.9
$17.0
Springfield, MA
$2.5
$30.9
$33.4
Huntington, WV
$32.7
$13.0
$45.6
State Cofege, PA
' ; $4.7
$0.5
$5.2
Indianapolis, IN
$18.2
: 57.0
$25.2
Stockton, CA
$6.8
$0.0
$6.8
Johnson Ctty, TN *
$18.4
$288.5
$307.0
Tulsa, OK
: $8.2
$1.1
$9.3
Knoxville, TN
$43.9
$95.8
$139.7
Visalia, CA
$4.2
$0.0
$4.2
Los Angeles, CA
$0.0
$0.0
$0.0
Washington, D.C.
$134.1
$450.5
$584.6
York PA
son
*7?
S1R5
TOTALS $2,687.2 $3,590.3 $6,277.6
* In Millions of 1990 dollars
Shaded area indicates where the available VOC and NOx control measures were considered sufficient to attain the standard, asterisks
indicate areas within the range of uncertainty which could potentially attain while achieving less than 100% of their targeted reductions.
VI-22
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VI(E)(l)(d) ALTERNATIVES 8H1AX-80 AND 8H4AX-70
The 8H1AX-80 and the 8H4AX-70 forms of the standard are analytically the same. The
remainder of this discussion will refer only to the 8H1AX-80 form with the clear understanding
that the discussion applies equally to both forms. The staff identified 581 modeled nonattainment
counties in the year 2007 for the 8H1 AX-80 standard under the LCS, based on all current CAAA
requirements being fully met and all possible efforts have been undertaken to meet the current
standard. When these nonattainment counties were assigned to nonattainment areas in accordance
with current part 51 implementation practices, 218 counties were added, for a total of 799
nonattainment counties in 129 nonattainment areas. Fifty four of the 129 nonattainment areas had
a maximum estimated ozone concentration of less than 92 ppm. Of the remaining seventy five
nonattainment areas, sixty were in the ROM domain, ten were in California, and five were in the
NRNC domain. Table VI-8 lists the marginal costs associated with the nonattainment areas for
which VOC or NOx controls would be required. Appendix A, Table A-8 lists the counties within
each of 8H1 AX-80 nonattainment areas. Based upon their expected reductions, seventeen
nonattainment areas had sufficient measures available in their inventories to reach their targets.
Another twelve nonattainment areas were able to attain at least seventy five percent of their
targets and the staff identified them as areas probably able to reach attainment. The remaining
forty six nonattainment areas have predicted residual nonattainment.
The VOC and NOx targets incorporated in Table VI-8 result in an expected reduction of
approximately 1.1 million additional tons of NOx per year beyond those necessary to attain the
current standard, and 1.2 million tons of VOC per year. NOx reductions above and beyond
CAAA requirements and those measures necessary to attain the current standard will have a
marginal cost of about $3 .6 billion annually. VOC reductions will have an expected marginal cost
of $2.7 billion, for a total marginal cost to achieve the 8H1 AX-80 standard of $6.3 billion per
year. Per capita, the marginal cost of attaining the 8H1 AX-80 standard under a local control
strategy scenario, is about $25, an increase in marginal per capita costs over the 8H1AX-80
standard with a regional strategy in the East of 250%.
VI(F) CONCLUSIONS OF THE LOCAL CONTROL SCENARIO ANALYSIS
The results of the LCS analysis parallel those of the analysis performed for the baseline. In
terms of area affected, populations affected, costs, and the number of residual nonattainment
areas, the 8H5EX-80 form of the standard is again the least restrictive eight hour alternative. The
8H4AX-80 ozone standard ranks second and the 8H1 AX-80 form ranks last. However, the
caveats relating to methodology, inventories, and residual nonattainment still apply, reducing the
degree of reliability which can be placed upon any conclusions reached. However, the LCS
analysis provides a framework for one important consideration: The LCS analyses illustrates the
need for greater flexibility within the ozone implementation process.
Clearly, for many areas, the problem is not one of not doing enough, but not being able to
do much of anything at all. For example, Los Angeles requires VOC reductions on the order of
seventy five to ninety percent, while available control measures account for less than ten percent.
VI-23
-------
In areas of persistent nonattainment, further reliance upon command-and-control measures results
in the application of additional add-on controls which are generally not cost effective. In areas of
residual nonattainment, there are simply no more controls to apply under the restricted
implementation scheme we used for this analysis. Under subpart (2), only counties within the
nonattainment area can participate in an attainment strategy. For instance, the ozone level in
York, Maine determined the Boston C/MSA's design value for all six alternative standards under
the LCS. However, for three of the alternatives examined, York was the only county which
recorded an ozone concentration greater than the marginal nonattainment level cut-off. In all
alternatives, at least seventy five percent of the counties in the Boston C/MSA had ozone
concentrations below the level of the standard. Because of the violation in York, all twelve
counties in the Boston nonattainment area must, according to subpart (2), participate in strategies
to reduce VOC and NOx emissions, regardless of their relative contribution to the solution. Given
the relatively low number of counties which actually record a violation for many nonattainment
areas, the application of a regional strategy that transcends nonattainment area boundaries may
reduce the ozone concentrations to such an extent that many of these areas would not become
nonattainment areas in the first place. Then, with the imposition of additional flexibility, such as
more meaningful definitions of nonattainment areas, the ability to take credit for upwind control,
and market based mechanisms, the level of residual nonattainment may be reduced to the two or
three historic areas where the ozone problem is the worst: i.e., Southern California, the Gulf
Coast, and the North Atlantic Coast.
Much of this flexibility is planned for the part 51 integrated implementation analysis when
the Agency investigates the applicability of trading schemes, alternative definitions of
nonattainment area size and designation, long range transport issues, the applicability of
intermittent voluntary controls, and jointness in control between ozone and PM. However, the
analytical baseline includes some regional NOx management through the incorporation of an
OT AG-wide NOx cap and LEV program. A detailed discussion of this baseline is included in
Chapter IV of this RIA.
In terms of area affected, populations affected, costs, and the pervasiveness of residual
nonattainment, the 8H5EX-80 form of the standard has the least measurable impact beyond that
associated with not changing the current standard. Under the above ranking criteria, the proposed
ozone standard ranks second and the 8H1AX-80 form ranks last. However, given the caveats
associated with this RIA's analytical methodology, its inventories, and its inability to resolve the
residual nonattainment problem, the relative ranking of alternatives cannot be considered
conclusive
VI(G) RESIDUAL NONATTAINMENT
Tables VI-9 and VI-10 display the tons of VOC and NOx reductions necessary to fully
attain each alternative standard, incremental to the lull attainment of the current standard. Table
VI-9 represents the RCS and Table VI-10 presents information on the LCS. Estimating the cost
associated with additional emission reductions needed to eliminate residual nonattainment is a
difficult task, given that this analysis is not able to identify specific controls to achieve these
VI-24
-------
reductions by 2007. The implication of residual nonattainment is that areas with a VOC or NOx
deficit need more time; new control strategies (e.g., regional controls or economic incentive
programs); and/or new technologies in order to attain the standard. However, some indication of
the nature of the residual nonattainment problem is presented in this analysis for the purpose of
completeness.
TABLE VI-9
ESTIMATIONS OF THE NATURE THE OF RESIDUAL NONATTAINMENT
PROBLEM FOR ALTERNATIVE1 STANDARDS UNDER THE RCS
STANDARD
VOC (tpy)2S
NOx (tpy)2S
Current Standard4
370 - 562
0
Incremental from the current standard:
8H5EX-801
11-17
13-19
8H4AX-802
102 -155
17-25
8H1AX-802
422 - 642
73-111
1 Alternative standard values are incremental to the full attainment of the current standard.
2. In thousands of tons.
3. Numbers represent low - high range values, with the point estimate above and without parentheses.
4. The current standard is assumed to be approximately equal to an 8-hour, .09 ppm, 2AX alternative.
The marginal cost associated with the most expensive current control approaches might be
a starting point for evaluating residual nonattainment. For example, this RIA has performed a
detailed analysis of a few sample cities in terms of the marginal cost of controls. The cost of the
most expensive controls used in the model range between $30,000 and $80,000 per ton. It has
been suggested that these may appropriately reflect the marginal cost (on top of identified
controls) to achieve emission reductions necessary to attain a more stringent standard. Although
such costs could be applied to the VOC or NOx deficits, the Agency does not view these cost
estimates as the most appropriate range to apply to the emission reduction deficits; the Agency
believes lower costs are more appropriate. This assertion is based in part on historic evidence
associated with the cost of emission controls which indicates that, instead of spending extremely
high costs to achieve each ton of reduction, sources have demonstrated an ability to adopt
economic incentive programs such as RECLAIM in Los Angeles or develop innovative strategies
and new technologies for NOx and VOC emission controls. Second, some areas have been given
additional time to attain the standard. Also, imposing additional local controls for some areas may
be less effective than improving regional controls.
The Agency has prepared a number of analyses from which cost estimates are available. A
range of $2,000 to $10,000 per ton has been identified for estimating the cost associated with
each ton of VOC or NOx deficit. The range was estimated by the Agency as the average
incremental cost per ton to achieve the current 0.12 ppm 1-hour NAAQS for achieving the 1990
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CAAA requirements. Also, $10,000 per ton is a point estimate used in the California Federal
Implementation Plan (FIP) analysis. $5,000 per ton (the average result of the 812(a) draft report)
could be used as a point estimate of the cost of these additional emission reductions. Based on
these cost estimates, the Agency believes this range is appropriate for estimating the cost of
residual nonattainment.
However, it should be noted that uncertainties are associated with the cost range
presented above. The range is used to represent the average cost of reducing each ton of VOC or
NOx and therefore treats the cost of reducing each ton as equal. An average cost estimate does
not differentiate between lower and higher marginal costs of these additional emission reductions.
Within the relevant range of this analysis, the marginal cost of achieving each additional unit of
emission reduction is higher than the marginal cost of achieving the previous unit. Resource
limitations prevent a treatment of these emission reductions in a marginal approach. Therefore,
the average cost per ton approach is preferred.
TABLE VI-10
ESTIMATIONS OF THE NATURE OF THE RESIDUAL NONATTAINMENT
PROBLEM FOR ALTERNATIVE STANDARDS UNDER THE LCS1
STANDARD
VOC (tpy)2 3
NOx (tpy)2 3
Current Standard4
506 - 770
8-13
Incremental from the Current Standard:
8H5EX-80
100-150
20-30
8H4AX-80
190-290
40-50
8H1AX-80
520 - 780
120-180
1 This scenario represents an unlikely air quality baseline for the year 2007. The reader should refer to the regional control
scenario for a better estimate of the likely baseline.
2. In thousands of tons.
3. Numbers represent low - high range values, with the point estimate above and without parentheses.
4. The current standard is assumed to be approximately equal to an 8-hour, .09 ppm, 2AX alternative.
VI(H) REFERENCES
EPA, 1990: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "Regulatory Impact Analysis for the Proposed South Coast District
Federal Implementation Plan" July, 1990.
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EPA, 1996a: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "Review of National Ambient Air Quality Standards for Ozone Assessment
of Scientific and Technical Information, OAQPS Staff Paper," June, 1996.
EPA, 1996b: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "National Low Emissions Vehicle Regulatory Impact Analysis" 1996.
EPA, 1996c: The United States Environmental Protection Agency, Office of Air Quality Planning
and Standards, "Clean Air Power Initiative White Paper", 1996.
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CHAPTER VH SUMMARY OF POTENTIALLY AFFECTED ENTITIES
This chapter briefly summarizes the control measures, economic sectors, and Standard
Industrial Classification (SIC) codes potentially affected by the control measures considered in the
ozone NAAQS review. The control measures cover stationary (point and area) and mobile (on-
highway and nonroad) sources of VOC and NOx emissions. The Agency prepared the emission
reduction and control cost analyses to support the ozone NAAQS review. The analyses compared
the incremental impacts of three NAAQS alternatives to the current standard. To analyze the
impacts associated with each of the NAAQS alternatives relative to the current standard, the
Agency developed control measures as surrogates for control measures that State or local
agencies may potentially use in their State Implementation Plans (SIPs) to attain each of the
NAAQS alternatives. This chapter refers to surrogate control measures as incremental measures.
Appendix C, Table C-l shows the incremental control measures and potentially affected source
categories for stationary and mobile sources of VOC and NOx emissions.
This chapter limits the discussion of control measures to those selected during the least-
cost control analysis of each alternative. Therefore, for some control measures, several control
techniques were considered but not selected because they were not the most cost-effective
technique for achieving the emission reductions needed. Consequently, not all available control
techniques for a control measure are identified in the following discussion. References at the end
of this chapter provide information about the sources used in the ERCAM to estimate control
costs using data contained in the Interim 1990 Inventory.
VD(A) STATIONARY POINT SOURCES
The Interim 1990 Inventory generally includes point source facilities that emit 100 tons
per year or more of one of the criteria air pollutants, along with SIC codes for most of the
associated facilities. For each of the incremental control measures, the Agency used ERCAM to
identify all of the potentially affected facilities and their SIC codes. The SIC codes and sectors
potentially affected by the incremental VOC and NOx control measures for stationary point
sources can be found in Appendix C, Tables C-2 and C-3, respectively.
VH(A)(1) VOC CONTROL MEASURES
The incremental control measures for point sources of VOC emissions include industrial,
wood product, and metal product surface coating; rule effectiveness improvements; and
incineration/open burning. The industrial surface coating operations incremental control measure
utilizes add-on control equipment to achieve VOC emission reductions beyond those achieved by
Maximum Achievable Control Technology (MACT) standards (Pechan, 1994a). This control
measure was applied to automobile, light-duty truck, and plastic parts surface coating operations.
The incremental control measure for wood products surface coating operations applies the VOC
limits for wood products surface coating operations contained in the ozone Federal
Implementation Plan (FIP) for California, based on the use of reformulated coatings and/or
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improved transfer efficiency of coating application equipment (Pechan, 1994a). The control
measure was applied to wood furniture and flatwood products surface coating operations.
The incremental control measure for metal surface coating operations uses reformulated
coatings and/or improved transfer efficiency for coating application equipment (Pechan, 1994a),
applied to beverage can, metal coil, metal furniture, large appliance, and miscellaneous metal parts
surface coating operations. The Agency estimated incremental control costs associated with this
control measure to be zero and, therefore, did not analyze its economic impacts or identify its
potentially affected SIC codes.
The point source inventory also contains source classification codes (SCCs) for "general"
or "unspecified" surface coating emission sources. SCC descriptions are not explicit about the
type of coating operation with which they are associated. Therefore, the Agency relied upon
engineering judgment to assign the general and unspecified SCCs to the industrial and other
general surface coating categories. The SCCs assigned to the industrial surface coating category
cover the following general categories of surface coating emissions: solvent-based paints,
lacquers, enamels, adhesives, primers, and thinning solvents. The SCC for general lacquer use was
assigned to the wood products surface coating category. This step was necessary to link
potentially applicable control measures with the SCCs to estimate emission reductions and control
costs. The SIC codes associated with the "general/ unspecified" emission sources assigned to the
industrial and wood products surface coating categories did not correspond to the names of
specific types of surface coating operations (e.g., automobile, light-duty truck, and plastic parts
surface coating operations). Therefore, Appendix C, Table C-2 lists the "general/unspecified"
SICs separately from the specific types of coating operations.
The control measure for incineration/open burning requires affected entities to cease open
burning activities on days that are predicted to exceed the ozone NAAQS. Burning activities
would be shifted to days where emissions would not contribute to the potential for a NAAQS
exceedance. The control measure reduces emissions on specific days, but not total annual
emissions (Pechan, 1994a). The Agency did not analyze the economic impacts of this control
measure or identify its potentially affected SIC codes because it does not increase costs to the
affected entities.
Rule effectiveness improvements were applied to simulate the effects of improving the
implementation of regulations. A rule effectiveness improvement may take several forms, ranging
from more frequent and in-depth training of inspectors and/or plant personnel to increased
monitoring, record keeping, and reporting (STAPPA/ALAPCO, 1993). The Interim 1990
Inventory used a default rule effectiveness value of 80 percent in its point source estimates for
VOC emissions. The 80 percent default value is based on EPA guidance. In some instances, the
Interim 1990 Inventory assumed a rule effectiveness of 100 percent. This analysis assumes
emission points with base year control efficiencies of greater than 50 percent will improve their
rule effectiveness from 80 to 90 percent, achieved through increased stack monitoring, record
keeping, and reporting.
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Vn(A)(2) NOx CONTROL MEASURES
The incremental control measure for utility boilers uses a post-combustive selective
catalytic reduction (SCR) control technique (Pechan, 1994a). The Agency also considered
combustion modification techniques [e.g., low-NOx burners (LNB), overfire air (OFA), natural
gas reburn (NGR), and flue-gas recirculation (FGR)]. However, the Agency found SCR was the
most cost-effective technique for achieving the NOx emission reductions needed from utility
boilers. Planned and generic units were used to estimate emissions associated with future growth
in utility boiler emissions. For the areas for which costs and emission reductions were estimated
under each of the three NAAQS alternatives, the control measure affected natural gas and oil
tangentially fired utility boilers in the point source inventory.
Industrial boilers typically produce steam to generate mechanical power or electricity.
The incremental control measure applied to coal, oil, and natural gas fired industrial boilers is
based on the use of SCR (Pechan, 1994a). As with utility boilers, the Agency also considered
combustion modification techniques (e.g., LNB and NGR) and post-combustion control
techniques [e.g., selective noncatalytic reduction (SNCR)]; however, SCR was found to be the
most cost-effective technique for achieving the NOx emission reductions needed from industrial
boilers.
Essentially all NOx emissions from cement manufacturing come from high temperatures
generated in cement kilns. The incremental control measure applied to cement kilns is based on
the use of SCR (Pechan, 1994a). Glass manufacturing furnaces are a source of NOx emissions.
Oxy-firing was the incremental control measure for glass manufacturing furnaces (Pechan,
1994a).
The incremental control measure for natural gas-fired turbines is based on the use of SCR
and steam injection combined. For oil-fired turbines, the incremental control measure applies SCR
and water injection combined (Pechan, 1994a). For natural gas-fired reciprocating internal
combustion (IC) engines, nonselective catalytic reduction (NSCR) is applied as the incremental
control measure (Pechan, 1994a).
Process heaters transfer heat to fluids. When steam heat cannot supply sufficient heat, the
most common fuels used in process heaters are oil and natural gas. The incremental control
measure for natural gas-fired and oil-fired process heaters uses LNB and SCR combined (Pechan,
1994a).
Municipal waste incinerators burn solid waste. Municipal waste incinerator source
category include four combustor types: starved air - multi-chamber; mass bum - single chamber;
derived fuel; and conical design (tee pee), municipal refuse. The incremental control measure for
municipal waste incinerators applies SNCR (Pechan, 1994a).
The incremental VOC control measure previously described for incineration/open burning
also achieves NOx emissions reductions and, therefore, was modeled as an incremental NOx
control measure.
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Vn(B) STATIONARY AREA SOURCES
The area source inventory accounts for stationary source emissions not included in the
point source inventory. Appendix C, Tables C-4 and C-5 show the SIC codes and sectors
potentially affected by the area source incremental control measures for VOC and NOx. The
Standard Industrial Classification Manual 1987 was used to identify the SIC codes potentially
affected by the NOx control measures for residential natural gas consumption (i.e., water and
space heaters). For the VOC control measures, the Standard Industrial Classification Manual
1987 and the documentation of area source category codes for the Aerometric Information and
Retrieval System (AIRS) Area and Mobile Subsystem (AMS) were used to identify the potentially
affected SIC codes for each control measure (EPA 1993). The area source category codes used
in the Interim 1990 Inventory are the same as those used in AIRS/AMS.
As with the NOx control measures for industrial boilers in the point source inventory, the
NOx control measures for the area source industrial fuel combustion (i.e., coal, oil, and natural
gas) categories have the potential to affect a variety of SIC codes. The area source inventory and
the AIRS/AMS documentation do not provide any information on the SIC codes associated with
the source category codes for the area source industrial fuel combustion categories. The NOx
control measures for area source industrial fuel combustion are based on the extension of point
source control measures to obtain emission reductions from the area source component of the
Interim 1990 Inventory. Costs for these area source control measures were estimated for
establishments that emit from 25 to 100 tons per year of VOC or NOx. Therefore, the National
Emissions Inventory (NEI) was used to identify SIC codes potentially affected by these control
measures.1 The SCCs affected by the corresponding point source control measures were used to
identify plants in the NEI with uncontrolled NOx emissions between 25 and 100 tons per year.
The SIC codes associated with the plants identified were then selected for the RIA and small
business impact analysis.
VH(B)(1) VOC CONTROL MEASURES
The incremental control measure for controlling VOC emissions from retail gasoline
service stations is based on the installation of pressure vacuum (PV) valves on the vent lines of
underground storage tanks plus Stage IRACT guidelines. Under Stage I requirements, tank truck
operators must recover gasoline vapors displaced in storage tanks when they are filled with
gasoline (Pechan, 1994a). The Stage I requirements would directly affect entities that transport
gasoline from bulk plants and terminals to gasoline service stations [i.e., SIC code 517 (Petroleum
and Petroleum Products Wholesalers)]; however, the Stage I vapor recovery requirements offset
the costs associated with the installation and use of the vapor recovery equipment.
1 The NEI was developed by EPA in 1995 and 1996 to support improvements to photochemical grid modeling of ozone precursor*. The NEI
contains 1990 base year emission inventories supplied by the States, which previously had not been included in the Interim 1990 Inventory.
The NEI was used for this analysis because many States provided data for a significant number of plants that emit less than 100 tons per year of
VOC and NOx.
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RACT formed the basis for the control measure for bulk terminals in ozone nonattainment
areas, based on the use of submerged fill and vapor recovery or other control systems to achieve a
recommended emission limit of 80 mg/liter (0.67 lb/1,000 gal). Mandatory leak detection and
repair programs are required to prevent leaks in the vapor collection system (Pechan, 1989). This
control measure would potentially affect SIC code 517 (Petroleum and Petroleum Wholesalers).
The industrial surface coating control measure is based on the use of add-on control
equipment to achieve VOC emission reductions beyond those achieved by MACT standards
(Pechan, 1994a). This control measure is applied to paper, aircraft, and marine surface coating
operations in the area source inventory. The incremental control measures for metal product,
flatwood product, and wood furniture surface coating operations use reformulated coatings
and/or improve the transfer efficiency of coating application equipment (Pechan, 1994a).
Miscellaneous surface coating operations use low-VOC coatings to achieve emission reductions
equivalent to those achieved by MACT standards, or apply add-on controls to achieve VOC
reductions beyond those achieved by MACT standards (Pechan, 1994a). Table C-4 presents the
SIC codes that would potentially be affected by these control measures.
Two control measures affect autobody refinishing operations: Option 1 is based on low-
VOC coating limits identical to the California's Best Available Retrofit Control Technology limits,
surface preparation product limits, and the use of painting gun cleaners. Option 2 is based on
requirements proposed in the California FIP, that would require the use of low-VOC coatings (or
an emission control system) and a transfer efficiency equivalent to that achieved through the use
of high-volume, low-pressure spray equipment. SIC code 753 (Automotive Repair Shops) could
be affected by the two control measures for this source category.
RACT requirements formed the basis for the incremental VOC control measures for
cutback asphalt and web offset lithography operations. The Agency estimated the incremental
control cost for cutback asphalt operations to be zero. For web offset lithography operations, the
incremental control measure uses VOC recovery equipment which results in a net savings rather
than a cost (Pechan, 1994a). Because these control measures do not increase costs, the Agency
did not analyze them or identify their potentially affected SIC codes.
Adhesives typically consist of a base material plus additives such as diluents, solvents,
catalysts, hardeners, inhibitors, and retarders. Manufacturers of industrial adhesives can reduce
VOC emissions through product reformulation (i.e., conversion to water-based, diluent-based,
and solventless products) and product substitution. The incremental VOC control measure for
industrial adhesives involves RACT requirements (Pechan, 1994a). The manufacturers of
industrial adhesives (SIC code 289) would potentially be affected by this control measure.
Leak detection and repair (RACT) form the basis for the incremental control measure for
fugitive VOC emission leaks from petroleum refineries and synthetic organic chemical
manufacturing industry (SOCMI) facilities (Pechan, 1994a). For SOCMI batch reactor processes,
the control measure is based on RACT use of condensers, scrubbers, carbon adsorption, thermal
destruction, or changing operational practices to control emissions from process vents. The
fugitive VOC control measure for oil and natural gas production fields is based on the
implementation of an equipment and maintenance program to control emissions from storage
tanks and transfer operations (Pechan, 1989). Table C-4 shows the SIC codes for each source
category potentially affected by these control measures.
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Aerosol spray paints are a subcategory of consumer and commercial products that include,
for example, general flat and enamel paints, hobby paints, automotive exact-match paints, and
fluorescent paints. Most aerosol spray paint products consist of the paint resin and pigment
(solids) additives, solvents, and propellants. Aerosol paints are used widely by homeowners,
industry, commercial operations, and artists and hobbyists. The primary method for decreasing
VOC emissions associated with the use of aerosol paint products is through product
reformulation to high-solids or water-based paints, reducing the solvent content by changing the
resin type, or substituting HFC-152a or compressed air for VOC-based propellant
(STAPPA/ALAPCO, 1993). Two incremental control measures for aerosol paints are based on
VOC content limits contained in draft rules being prepared by the California Air Resources Board
(CARB) and the South Coast Air Quality Management District in California. The CARB's draft
Statewide rule establishes two tiers of VOC-content limits on categories of aerosol coating
products: the first tier of limits would be effective in 1996 and the second, more stringent tier of
limits would be effective in 1999. One of the incremental measures is based on the CARB's Tier
II limits. The CARB's Tier II limits are expected to achieve an additional 10 to 15 percent
reduction over the Tier I limits which were already included in the base-case CAA scenario. The
Tier I limits were estimated to achieve a 20 percent reduction in VOC emissions. The second
incremental control measure is based on a draft rule being prepared by the South Coast Air
Quality Management District. The limits being considered in the draft rule would achieve an
incremental reduction of 40 percent, or 60 percent overall (Pechan, 1994a). These two control
measures would potentially affect SIC code 285 (Paints, Varnishes, Lacquers, Enamels, and
Allied Products).
The VOC control measure for pesticide application is based on a draft rule prepared by
CARB that was also included in the rulemaking for the California ozone FTP. The agency assumed
that if the incremental measure is selected for a nonattainment area, it would be applied Statewide.
The incremental measure would require producers of agricultural and/or structural pesticides to
lower the VOC content of pesticide products by: reducing fumigant usage, alternative application
methods, microencapsulation, and integrated pest management programs (STAPPA/ALAPCO,
1993). The control measure would potentially affect SIC code 287 (Agricultural Chemicals).
The incremental control measure for pharmaceutical manufacturing is based on RACT
recommendations for installation of surface condensers for reactors, distillation operations,
crystallizers, centrifuges, and vacuum dryers that emit 6.8 kg/day (15 lb/day). RACT also
recommends the installation of a vapor balance system for emissions associated with the transfer
of liquids containing VOC to tanks with a capacity of more than 7,500 liters (2000 gal). In
addition, RACT recommends pressure/vacuum vents for liquid storage tanks, covering exposed
liquid surfaces (e.g., centrifuges, rotary vacuum filters, and tanks), and the implementation of leak
detection and repair programs (Pechan, 1989). SIC code 282 (Drugs) would potentially be
affected by this control measure.
The control measure for SOCMI and polymer manufacturing fugitive emission leaks is
also based on RACT recommendations for leak detection and repair programs (Pechan, 1989).
This control measure would potentially affect SIC code 286 (Industrial Organic Chemicals).
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Vn(B)(2) NOx CONTROL MEASURES
RACT applies to the incremental NOx control measure for area source industrial coal, oil,
and natural gas fuel combustion categories, applied to sources that emit from 25 to 100 tons per
year of NOx (Pechan, 1994a). Appendix C, Table C-5 shows the SIC codes identified from the
NEI as potentially being affected by the control measures for area source fuel combustion
sources. The incremental NOx control measures for residential natural gas consumption are based
on the use of LNB for residential water heaters and space heaters, based on an assumed
implementation schedule that phases in the use of units equipped with LNB as conventional units
reach the end of their useful life (Pechan, 1994a). Manufacturers of residential water heaters and
space heaters (SIC codes 363 and 343, respectively) would potentially be affected by these
control measures. Because there are no additional costs associated with LNB water heaters, the
economic impacts of the control measure on SIC code 363 were not analyzed.
The incremental control measure for open burning was applied to control NOx emissions.
The NOx control measure previously discussed for the incineration/open burning point source
category also applies for controlling NOx emissions from this area source category (Pechan,
1994a). The economic impacts of this control measure were not analyzed because it does not
increase costs to the affected entities. Therefore, the SIC codes potentially affected by the control
measure were not identified for this analysis.
VH(C) ON-HIGHWAY MOBILE SOURCES
Light-duty vehicles, light-duty trucks, medium-duty vehicles, and heavy-duty vehicles use
a combination of fuel reformulations, new vehicle exhaust emission standards, and enhanced
inspection and maintenance (I/M) programs to control VOC and NOx emissions. These measures
represent controls that have already been applied in some ozone nonattainment areas, and will be
applied as incremental controls in other areas. Each control measure is discussed separately in the
following sections. Appendix C, Table C-6 shows the SIC codes and sectors that would
potentially be affected by each of the control measures.
Vn(C)(l) REFORMULATED GASOLINE
The cost analysis for on-highway vehicles includes control measures based on the Federal
reformulated gasoline program and California's program. Reformulated gasoline control measures
reduce VOC and NOx emissions from gasoline-powered motor vehicles. The Federal program
was required by the CAA to be implemented in 1995 in the nine worst ozone nonattainment areas
(EPA, 1992). Additional areas, primarily ozone nonattainment areas within the Northeast Ozone
Transport Region (OTR), are included in this program. Emission reductions from the Federal
reformulated gasoline program for all areas that utilize this program are included in the base case
CAA controls scenario. For other areas, reformulated gasoline is the third control measure applied
after application of the enhanced 17M and low emission vehicle (LEV) control measures.
VH-7
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A second control measure is based on the Phase 2 requirements of California's
reformulated gasoline program. Phase 2 gasoline must meet specified standards for sulfur,
benzene, aromatic hydrocarbons, olefin, Reid vapor pressure (RVP), oxygen, 90 percent
distillation temperature, and 50 percent distillation temperature. Phase 2 standards apply to all
gasoline powered vehicles in California beginning in 1996 (Pechan, 1994a). California's
reformulated gasoline program is applied statewide in California in the base case CAA scenario.
The Federal and California reformulated gasoline control measures will impact refineries
that supply gasoline to the areas in which one of these programs is chosen as a least-cost option.
Petroleum refineries would incur direct costs caused by increased production costs associated
with reformulating gasoline. These costs, if passed on, would potentially affect wholesalers and
distributors of reformulated gasoline, gasoline service stations, and consumers.
VH(C)(2) REFORMULATED DIESEL FUEL
The reformulated diesel fuel control measure is designed to reduce NOx emissions by
setting limits on the amount of sulfur and aromatics in diesel fuel. The control measure is based on
California's reformulated diesel fuel program which affects on-highway and nonroad diesel
vehicles. The control measure would affect light-duty, medium-duty, and heavy-duty trucks
outside California. California's rule establishes a 500 parts per million sulfur limit as well as a 10
percent limit on aromatics (or 20 percent for small refiners) for its vehicular diesel fuel. The rule
contains an equivalency provision that allows refiners to make diesel with more than 10 percent
aromatics if engine testing demonstrates equivalent emissions (Pechan, 1994a). The impacts of
reformulated diesel fuel program would directly impact refineries, due to the increased production
costs required to modify the composition of diesel fuels. These costs, if passed on, would
potentially affect wholesalers and distributors of reformulated diesel fuel, gasoline service stations,
and consumers.
Vn(C)(3) ENHANCED INSPECTION AND MAINTENANCE (I/M)
Enhanced I/M programs test vehicle emissions while the vehicle is idling. Enhanced I/M
programs are required in both ozone and carbon monoxide (CO) nonattainment areas, depending
upon population and nonattainment classification or design value. Within the OTR, States or areas
must implement enhanced I/M programs in any C/MSA or portion of a C/MSA with a 1990
population of 100,000 or more (Pechan, 1994a). The base case includes the effects of I/M
programs required under the CAA. For the purposes of this analysis, enhanced I/M programs are
used as an incremental control measure in areas where they are not already required by the CAA.
The enhanced I/M program will apply to light-duty vehicles and trucks. The impacts of an
I/M program are incurred in terms of inspection fees, and repair costs in the event of test failure.
In addition to individual automobile owners, enhanced I/M programs will impact businesses that
use specific types of vehicles as the main source of revenue (such as trucking, courier, and taxi
companies) and fleet vehicles of non-transport companies (Pechan, 1994b). Decentralized
VH-8
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automobile inspection and repair industry will incur any costs associated with establishing
emission stations, as well as increased revenue resulting from increased repair activities.
VH(C)(4) LOW EMISSION VEHICLES
Low emission vehicle (LEV) programs establish requirements for phasing-in LEVs into
the automobile fleet. In September 1990, the CARB approved a LEV program which includes
light and medium-duty motor vehicle emissions standards that progressively reduce emissions
from vehicles of model years 1994 through 2003. CARB's regulations establish four new classes
of light-duty and medium-duty vehicles with increasingly stringent emission levels: transitional
low emission vehicles (TLEVs), LEVs, ultra low emission vehicles (ULEVs), and zero emission
vehicles (ZEVs). The California LEV program requires a fleet composition of 75 percent LEVs,
15 percent ULEVs, and 10 percent ZEVs by 2003 (Pechan, 1995).
Since 1990, several States in other areas of the country have adopted the California
emission standards. In February 1994, the Northeast Ozone Transport Commission (OTC) States
voted to recommend that the EPA mandate the California LEV program in the Northeast OTR,
and shortly thereafter presented a petition to EPA. Massachusetts and New York have already
enacted legislation for a LEV program. To produce vehicles that meet the standards for LEVs,
ULEVs, and ZEVs, automobile manufacturers will be required to add emission controls to
engines. The direct impacts of any LEV program will, therefore, be incurred by automobile
manufacturers. Depending on the ability of the manufacturers to pass the increased production
costs forward, automobile dealerships may also be impacted by the costs of LEV program, as well
as automobile consumers.
VH(D) NONROAD MOBILE SOURCES
Incremental control measures for nonroad sources include emission standards for large
nonroad compression ignition (diesel) engines and small recreational vehicle spark-ignition
(gasoline) engines; emission fees for commercial marine vessels; and reformulated gasoline for
nonroad vehicles. Appendix C, Table C-6 shows the SIC codes and sectors potentially affected by
each of the control measures.
VH(D)(1) CALIFORNIA STANDARDS FOR * 175 BHP NONROAD DIESEL ENGINES
This control measure is based on California's NOx standard of 5.8 grams per brake
horsepower-hour (g/bhp-hr) for compression ignition engines at or above 175 brake horsepower
(bhp). Compression ignition engines at or above 175 bhp are used in logging and construction
equipment. Construction equipment using this engine size include excavators, cranes, bore/drill
rigs, off-highway tractors, scrapers, rubber tired dozers, and off-highway trucks. Logging
equipment with compression ignition engines at or above 175 bhp include machines used to cut
and bunch timber. To comply with the California standards, it will be necessary for manufacturers
VH-9
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to modify compression ignition engines. The most likely and effective engine modifications
include retarding the injection timing, improving fuel pumps and nozzles, and combustion
chamber modifications. The impacts of the CARB standards for large, non-road engines are
associated with the required variable hardware costs of producing cleaner engines
(STAPPA/ALAPCO, 1993; Pechan, 1994a, 1994c).
The direct impacts of this control measure would be incurred by the manufacturers of
compression ignition engines for logging and construction equipment, classified under SIC code
351 (Internal Combustion Engines, not elsewhere classified). Depending on the ability of the
engine manufacturers to pass the increased production costs forward, the equipment
manufacturers may also be impacted, as well as the construction and forest product industries that
purchase the equipment.
VH(D)(2) NONROAD ENGINES - EMISSION REDUCTION BENEFITS ASSOCIATED
WITH PHASE I REFORMULATED GASOLINE
The control measure modeled for nonroad engines simulates the emission reduction
benefits associated with the use of reformulated gasoline in nonroad engines in ozone
nonattainment areas. The reformulated gasoline control measure described under the previous
discussion of the on-highway control measures applies here, as well. The nonroad recreational
vehicle categories for which emission reduction benefits were estimated include airport services,
recreational, industrial, light commercial/utility, construction, farm, lawn and garden, and logging
equipment (Pechan, 1994a).
Vn(D)(3) MARINE EMISSION FEES
This control measure is based on a draft rule prepared for the California ozone FIP to
control NOx emissions. The draft rule involved a three-tier emission fee structure based on a price
of $10,000 per ton of NOx. With the fee structure in effect, vessel operators would control the
maximum amount of NOx emissions possible as long as the cost was less than $10,000 per ton.
Otherwise, vessel operators would presumably pay the fee (Pechan, 1994a). This control measure
would potentially affect most commercial diesel-fueled marine vessels classified under SIC codes
441 (Deep Sea Foreign Transportation of Freight), 442 (Deep Sea Domestic Transportation of
Freight), 443 (Freight Transportation on the Great Lakes), and 444 (Water Transportation of
Freight, not elsewhere classified). However, the County Business Patterns did not report any
establishments for SIC codes 441, 442, and 443 for the nonattainment area counties for which
control costs were estimated. Consequently, these three SIC codes were not included in the
economic impact analysis for this control measure
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Vn(D)(4) RECREATIONAL VEHICLES - CALIFORNIA STANDARDS
The control measure for recreational vehicles is based on a proposed rule developed by
California in 1993. The rule would set hydrocarbon, NOx, and carbon monoxide emission
standards for nonroad motorcycles, all-terrain vehicles, golf carts, and specialty vehicles with an
engine size of 25 hp or more beginning with the 1997 model year. The rule would also establish
hydrocarbon, NOx, and carbon moNOxide emission standards for specialty vehicles with an
engine size of less than 25 hp beginning with the 1995 model year (Pechan, 1994a).
VU(E) COMPARISON OF ALTERNATIVE OZONE NAAQS ON AFFECTED SOURCES
This section discusses the impact of control measure selection on SIC codes for the three
alternative standards. While the data are illustrative, they have limitations. For example, the
Agency discovered that for a significant number of nonattainment areas under all of the alternative
standards examined, VOC and NOx targeted reductions exceeded available VOC and NOx
reductions. Consequently, for many nonattainment areas, the control strategies applied do not
change appreciably from one alternative to another. What little change does occur between
alternatives usually results from a change in the definitions of nonattainment areas, rather than
from changes in control strategies within the same area. Figure VII-1 illustrates the number of
control measures affecting different numbers of SIC codes (i.e., 1, 2, 3,4, 5, and more than 5).
Forty-eight control measures apply to the most stringent alternative (8H1AX-80), twenty-eight of
which (fifty-eight percent) affect only one SIC code. Thirty-two controls apply to the 8H4AX-80
alternative, with nineteen (fifty-nine percent) affecting only one SIC code. Under the 8H5EX-80
alternative, twenty-seven measures were analyzed, of which fifteen (or fifty-six percent) affect
only one SIC code.
Figure VH-2 displays the distribution of control measures that affect only one SIC code
among the eight SIC code divisions they affect. The Manufacturing division (SIC codes 20
through 39) makes up about seventy percent of the SIC codes that are affected by only one
control measure for the 8H1AX-80 alternative, with the Mining division (SIC codes 10 through
14) and the Transportation division (SIC codes 40 through 49) both associated with four SIC
codes, or eleven percent of the total. The remainder of SIC codes are distributed among the
Agriculture (SIC codes 01 through 09); Wholesale (SIC codes 50 and 51) and Retail (SIC codes
52 through 59) Trade; and Services (SIC codes 70 through 89) division; each division is
associated with one SIC code (or three percent of the total) under the most stringent alternative.
Under the 8H4AX-80 and the 8H5EX-80 alternatives, the Manufacturing division makes up about
ninety percent of the SIC codes affected by only one measure. The Services division (SIC codes
70 through 89) accounts for the second highest number of SIC codes under the 8H4AX-80
alternative, with one SIC code each in the Transportation, Wholesale Trade, and Retail Trade
divisions. Under the 8H5EX-80 alternative, the Transportation and Services divisions have the
second highest number of SIC codes (2) affected by one measure. The Wholesale Trade, Retail
Trade, and Public Administration divisions (SIC codes 90 through 97) account for the remainder.
VH-11
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FIGURE IV-1
THE EXPECTED EFFECT OF CONTROLS ON INDUSTRY
1 2 3 4 5 more
than
5
Number of SIC Codes Affected
~ 8H5EX-80 H8H4AX-80 ¦8H1AX-80
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FIGURE VII-2
THE NUMBER OF SIC CODES AFFECTED BY ONE CONTROL MEASURE
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H
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A
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D
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G
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B
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E
Wholesale Trade
H
Public Admin.
C
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F
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Figure VII-3 displays the relative number of SIC codes affected by different numbers of control
measures (i.e., 1, 2, 3, 4, 5, and more than 5). Differences in the number of SIC codes affected by
controls can be attributed to changes in the nonattainment area status of counties. The 8H1AX-80
alternative uses forty-eight measures affecting 134 different SIC codes. Thirty-eight SIC codes
are affected by one measure (or twenty-eight percent of the total), and 117 SIC codes (or eighty-
seven percent) are affected by five or fewer control measures. Under the 8H4AX-80 alternative,
thirty-two measures are used affecting 107 unique SIC codes. Of these SIC codes, fifty-seven (or
fifty-three percent) are affected by one control measure, and 106 (or ninety-nine percent) of SIC
codes are affected by five or fewer control measures. Under the 8H5EX-80 alternative, twenty-
seven measures affect 104 different SIC codes. Sixty-nine SIC codes, (or sixty-six percent)
FIGURE VII-3
THE EFFECT ON SIC CODES FROM CONTROLS
o 50
¦o 40
5 20
more
than
5
Number of Controls Applied
~ 8H5EX-80 H8H4AX-80 ¦ 8H1AX-80
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are affected by one control measure, and 103 SIC codes (or ninety-nine percent) are affected by
five or fewer control measures.
The Agency believes that when the part 51 implementation process has been completed,
the impact of applying optimal control strategies will differ from that illustrated above. The
difference will be due to several factors. First, the part 51 analysis will assume subpart (2) does
not apply to ozone NAAQS implementation. This will provide much needed flexibility to the
ozone management process and allow regulators the opportunity to achieve targeted reductions
through greater flexibility. Since the current classification scheme for nonattainment areas has
been in place for a number of years, much of that flexibility within existing nonattainment areas
has probably already been captured. Additional lower cost strategies will have to be found outside
current nonattainment areas. Including new areas into nonattainment area definitions will probably
increase the number of controls applied as well as the number of affected SIC codes. Second, the
part 51 RIA will have two analytical advantages over the current methodology: a new, state-of-
the-art air quality model which will incorporate ozone precursors and particulate matter (PM);
and a revised emissions inventory which incorporates much of the latest engineering and scientific
data about precursor reductions and their associated costs. Through these changes, the Agency
will be to take advantage of the jointness in control that often occurs between ozone and PM.
Vn(F) REFERENCES
EPA, 1992: Regulatory Impact Analysis: U.S. Environmental Protection Agency, Office of Air
and Radiation. Reformulated Gasoline and Anti-Dumping Regulations. Washington, DC.
September 22,1992.
EPA, 1993: Aerometric Information and Retrieval System (AIRS) Area and Mobile Source
Category Codes. U.S. Environmental Protection Agency, Office of Air Quality Planning
and Standards, Technical Support Division, National Air Data Branch, Research Triangle
Park, NC. May 1993.
OMB, 1987: Executive Office of the President. Office of Management and Budget. Standard
Industrial Classification Manual 1987. Washington, DC. 1987.
Pechan, 1989: E.H. Pechan & Associates, Inc. ERCAM-VOC: Description and Applications.
Draft. Prepared for U.S. Environmental Protection Agency, Office of Policy, Planning and
Evaluation, Washington, DC. EPA Contract No. 68-01-7047, Work Assignment No. 126.
Pechan, 1994a: E.H. Pechan & Associates, Inc. Analysis of Incremental Emission Reductions and
Costs of VOC and NOx Control Measures. Draft. Prepared for U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards, Ambient Standards
Branch, Research Triangle Park, NC. Pechan Report No. 94.09.011/1737. September
1994.
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Pechan, 1994b: E.H. Pechan & Associates. Inc. Regulatory Impact Analyses for the Sacramento
Nonattainment Area, South Coast Nonattainment Area, and Ventura County Federal
Implementation Plans. Prepared for U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Innovative Strategies and Economics Group, Research
Triangle Park, NC. December 1994.
Pechan, 1994c: E.H. Pechan & Associates, Inc. The Emission Reduction and Cost Analysis
Model forNOx (ERCAM-NOx). Final Report. Prepared for U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards, Ozone/CO Programs
Branch, Research Triangle Park, NC. Pechan Report No. 94.05.002/1701. May 1994.
Pechan, 1995: E.H. Pechan & Associates, Inc. Analysis of Costs, Benefits, and Feasibility
Regarding Implementation of OTC Petition on California LEVs. Prepared for U.S.
Environmental Protection Agency, Office of Mobile Sources, Ann Arbor, MI. January
1995.
STAPPA/ALAPCO, 1993: Meeting the 15-PercentRate-of-Progress Requirement Under the
Clean Air Act: A Menu of Options. State and Territorial Air Pollution Program
Administrators (STAPPA) and Association of Local Air Pollution Control Officers
(ALAPCO). September 1993.
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CHAPTER Vm ECONOMIC ASSESSMENT
Vin(A) INTRODUCTION
This chapter describes the economic impact analysis conducted for stationary and mobile
source control measures. It serves as an indicator of possible economic impacts, not as a final
analysis. Full assessment of the economic impacts associated with the proposed ozone primary
NAAQS must wait until the part 51 implementation process has been completed. This analysis,
while in places looks similar to a Regulatory Flexibility Screening Analysis (RFSA), should not be
considered an RFSA, nor should this chapter be considered as fulfillment of any SBREFA
requirement. The results of this analysis serve as inputs to the development of implementation
strategies which will help attain the proposed standard while mitigating possible disproportionate
impacts on specific sectors or segments of the economy (e.g., small businesses and governments).
Because of the number of industries/entities potentially affected by this NAAQS, EPA
developed a cost-to-sales ratio methodology for use as a screening tool to identify industries and
entities for which control measure impacts may be significant. The approach compares average
control measure costs with average sales revenue of establishments in potentially affected
industries on a SIC code basis (OMB, 1987). The analysis was conducted at the 3-digit SIC code
level because of the extensive number of 4-digit SIC codes potentially affected by the control
measures and the fact that financial data are more often available at the 3-digit SIC code level.
Because the methodologies of the economic impact and small entity screening analyses are
similar, the methodologies and results of these analyses are described together in this chapter.
This analysis was conducted for three alternative NAAQS (i.e., 8H1AX-80, 8H4AX-80, and
8H5EX-80) which are more stringent than the current NAAQS (i.e., 1H1EX-120). The costs
used for the screening analysis are the incremental costs of each alternative relative to the current
ozone standard. Cost-to-sales and cost-to-expenditure ratios are not included in this RIA.
Since the small entity screening analysis has been designed to provide input into the part
51 RIA with regard to RFA and SBREFA requirements, the staff designed its analysis to follow
the same steps. The RFA requires Federal agencies to give special consideration to the impact of a
regulation on small businesses to determine whether or not the proposed regulation will have a
significant economic impact on a substantial number of small entities. According to a standard
rule of thumb often used in previous rulemakings at EPA and other agencies, a significant impact
on small entities occurs when:
• 20% or more of the affected small entities1 have an expected cost (of regulation) to sales
ratio equal to or greater than 3%, and
• if the 20% criteria is met, that the actual number of significantly affected small entities is
more than 100.
1 SBREFA guidelines state the definition for "small" for any given industry should come from the Small
Business Administration listing codified in 13 CFR121.201.
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This RIA uses one hundred employees as its definition of "small" for this RIA because:
1) control cost data were not generated on a firm-level; and 2) published sales data typically are
not available for a five hundred employee threshold.2
Control measures often affect entities at more than one point from production to final sale
(e.g., manufacturing and retail trade). For example, automobile manufacturers are directly affected
by many measures, but other entities are indirectly affected, such as automobile dealerships and
businesses purchasing fleet vehicles. Given the complexities of determining the degree of cost
pass-through from the directly affected entities, EPA analyzed only the direct impact of each
control measure on entities.3
The reader should note this analysis did not include any ongoing work of the
Subcommittee of the Clean Air Act Advisory Committee (CAAAC) when it estimated the
economic impacts presented in this chapter. As indicated earlier in this RIA, the control strategies
which emerge from this process will most likely cost less and be more environmentally effective
than the ones analyzed here. Further, this RIA does not take into account any jointness which
may exist in control strategies for ozone and PM. Such jointness may have significant bearing on
the costs, benefits, and economic impacts associated with the implementation strategies for
reducing ozone and PM concentrations. Since this RIA and this economic analysis employed
existing non-integrated technical models and implementation strategies, results from these
analyses should be interpreted with these limitations in mind.
The economic impacts presented in this chapter only reflect the direct costs of the
application of the control measures selected in the cost analysis summarized in Chapter VI. The
Agency recognizes that the economic impacts associated with the control measures, both positive
and negative, area distributed beyond the directly affected industries (e.e., the natural gas industry
receiving additional revenues due to increased demand for cleaner fuels, the pass-through effect of
regulatory costs on consumer demand), but was unable to prepare estimates of these because of
limited data. The EPA will provide market impact estimates using a sample of affected industries
for the costs associated with the implementation plans that will develop during the part 51
implementation process.
Vm(B) COST EFFECTIVENESS
Vm(B)(l) BACKGROUND
Executive Order 12866 states that when it is feasible, benefit-cost analysis shall be used to
evaluate and compare regulatory alternatives, which is the primary focus of the Ozone NAAQS
RIA. Another tool that is used when benefits cannot be quantified is the measure cost-
effectiveness. Cost-effectiveness is used to rank a set of least-cost alternatives that achieve
2 The one hundred employee threshold was also used for the RIA and RFA analyses for the California FIP and
the PM NAAQS review. From a consistency standpoint, one hundred employees was the appropriate choice.
3 Judicial precedent has been set for RFA analyses that such analyses are required only for small entities which
are directly regulated [Mid-Tex Electric Cooperative, Inc. v. FERC, 773 F.2d 327 (D.C. Cir. 1985)].
vni-2
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differing degrees of air quality improvements or health risk reductions. The ranking of alternatives
is an important tool that allows policy-makers to identify inferior and/or dominant strategies
among regulatory alternatives4. For environmental policy, cost-effectiveness is calculated as the
cost of an alternative divided by the expected emission reductions.
Routinely, the EPA provides a measure of the cost-effectiveness (C/E) of regulations that
allows for a historical comparison of effectiveness of a rule with other regulations passed by the
EPA when actual benefit cost analysis are not done. Traditionally, C/E is measured as total
national costs of the rule divided by national emission reductions. For example, the control of
volatile organic compounds (VOCs) from consumer and commercial products has been proposed
to reduce 82,000 Mg/year of VOC nationwide at a cost of $27.0 million (1991$). This yields a
C/E measure of $ 330 per Mg, which can be used to compare with other EPA regulations.
The EPA has been requested to consider new approaches towards presenting cost-
effectiveness comparisons in its rules that target the reduction of ozone. The primary concern is
that the traditional C/E measure does not consider the appropriate measure of emission reductions
to compare with a program's cost. Under section 183(e) of the Clean Air Act, the EPA is tasked
with developing standards that will facilitate compliance with the Ozone NAAQS through the
control of VOCs that are emitted from consumer and commercial products, such as: hair sprays,
deodorants, paints and other coatings. Some of these rules will be implemented nationwide.
Consequently, emission reductions will be achieved in both ozone nonattainment areas as well as
attainment areas.
EPA recently raised this issue in its Consumer and Commercial Products (CC&P) rule and
received the comments summarized below. EPA is repeating the request for comments here since
this RIA will be reviewed by a much broader audience. The comments on the CC&P rule received
on the various methods to measure C/E for these rules reflect a wide dispersion of opinions. Some
commenters recommend that the EPA maintain the traditional C/E measure because restricting the
measurement to a subset of anticipated emission reductions does not accurately reflect all of the
benefits of the rule. Other commenters argue that the traditional C/E measure creates a bias
against tailored, local, and seasonal approaches. They state that the C/E methodology should
measure that cost against emission reductions that actually affect the nation's public health. Thus
weighting reductions by their relationship to improvements in public health is a recommended
approach. Similarly, another commenter stated the EPA should concentrate on measuring C/E for
the primary objective of the standard - meeting the NAAQS in nonattainment areas. This
commenter also recommend that EPA consider only emission reductions that occur during the
"ozone season." Finally, other cementers support all variations of the measure of C/E.
Not all of the comments received will be relevant to the Ozone NAAQS since the
traditional C/E measure would be the same as a measure restricted to nonattainment area emission
reductions. However, the audience of this report is broad and can provide additional insight on
4 It is often assumed that cost-effectiveness can be used as a proxy for a benefits valuation. Cost-effectiveness
is not a proxy for the quantification of benefits because two control strategies may achieve the same level of
emission reductions (and thus accrue the same level of benefits), but one strategy may do so at a much higher
cost. Cost-effectiveness would identify the higher cost strategy as inferior and thus it would not be
implemented, even though it achieves the same level of benefits as the other alternative.
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the issue not only as it pertains to the NAAQS, but also for other programs to be developed in the
future. Below is a general discussion of the potential approaches and issues of measuring C/E.
Vni(B)(2) ALTERNATIVE COST-EFFECTIVENESS METHODOLOGIES
The first alternative approach that has been suggested for rules that are implemented
nationwide is to measure C/E for emissions occurring in ozone nonattainment areas only, even if a
control alternative is expected to achieve additional reductions outside of nonattainment areas.
The premise for this approach is that the primary objective of such control strategies is to reduce
levels of ozone to meet the NAAQS in nonattainment areas. In doing so, the measure would
compare national cost (for control in both nonattainment areas and attainment areas) with
emission reductions in nonattainment areas only. This has an advantage of presenting a narrower
measure of the effectiveness of a strategy to achieve the primary objective - reducing levels of
ozone to meet the NAAQS. However, it also presents a measure that might be used to compare
with the traditional approach; these are not comparable. The traditional measure places equal
value on attainment area and/or non-ozone season reductions; alternatives would be based on the
emission reductions that are the focus of the regulatory program.
To account for the multiple objectives achieved by such rules, the measure of cost-
effectiveness should represent some weighting of the objectives, or it must focus on the most
important objective to the exclusion of the others. The EPA's traditional measure of C/E provides
a measure of equal weighting (or equal value to society and the environment) given to emission
reductions in both nonattainment areas and attainment areas. The alternative approach assumes
that the secondary afifect of reductions in attainment areas has no value to society and the
environment, and applies a zero weighting to attainment area emission reductions. Numerous
studies demonstrate that a positive value exists for emission reductions in attainment areas by
decreasing damages to ecosystems, agricultural crops, and other species. However, this value is
likely to be less than the value to be placed on nonattainment area emission reductions. Thus, a
weighting that is between 0 and 100 should be applied to attainment area emission reductions, but
the EPA does not have a method to determine the proper weight to apply to attainment area
emission reductions. Therefore, for rules that achieve reductions nationally the C/E can be
presented in a range representing (1) equal weighting for all emission reductions through the use
of the traditional measure of C/E, and (2) zero value weighting to attainment area reductions
through the use of the first alternative measure of C/E; recognizing that the most appropriate
value is between these two extremes.
A second alternative that is suggested is to measure C/E for the "ozone season" only (i.e.,
for emission reductions achieved during typical peak ozone months of the year). This measure
would compare national costs with a subset of national emission reductions - those reduced in
nonattainment areas during peak ozone months of the year. This approach would in effect apply
an additional breakdown of the weighting of nonattainment area emission reductions. As is
discussed above, the weight could be anywhere from 0 to 100, with the difference being applied
to non-ozone season emission reductions. The value of non-ozone season emissions could be
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lower than those of the ozone season, but not zero since there are studies showing positive health
benefits to reductions during all seasons of the year.
This approach would allow valid comparisons to be made between the cost effectiveness
of national year-round rules and, for example, nonattaLnment area specific rules applying during
the ozone season. Such a comparison of cost effectiveness is valid because it is a comparison of
the cost (wherever and whenever incurred) to achieve emission reductions that are the regulatory
objective - in this case, nonattainment area ozone season emissions. Using a traditional cost
effectiveness approach one cannot compare the cost effectiveness of such differing control
strategies.
VDI(C) METHODOLOGY AMD LIMITATIONS OF IMPACTS ANALYSIS OF EACH
CONTROL MEASURE
The analysis excluded eight source categories from this chapter's analysis because they
had zero or negative costs.5 Seven SIC codes in the Interim 1990 Point Source Inventory were
mis-coded and were removed. The analysis also excluded residential natural gas space heaters
from the analysis because County Business Patterns did not report any establishments for SIC
code 343 (Heating Equipment, Except Electrical and Warm Air; and Plumbing Fixtures) in the
counties for which the control measure was selected. A list of these control measures and the
reasons for exclusion can be found in Appendix D, Table D-l. Two types of analyses were
performed for the remaining control measures. The first analysis estimates cost-to-sales ratios for
SIC codes potentially affected by each individual control measure selected under each NAAQS
alternative. The methodology and results of this analysis are presented in sections B and C,
respectively. The second analysis estimates cost-to-sales ratios for SIC codes potentially affected
by more than one control measure. The methodology and results of the second analysis are
presented in sections D and E, respectively.
Appendix D, Table D-2 presents an overview of the data sources used and the
methodologies employed for each of the source categories potentially affected by a NAAQS
alternative. To develop cost-to-sales ratios for the incremental control measures, the RIA team
first identified the potentially affected SIC codes. Control measure and the SIC code impacts are
presented in Chapter VH. Chapter VII also describes the methods used to identify the SIC code(s)
potentially affected by each control measure. The following sections are organized by the
following four general emission source categories:
Point sources are relatively large emitters of air pollutants. Because of their significant
contribution to total emissions, each individual point source is identified in the Interim
1990 Inventory. In addition to emissions data, additional source-specific information is
typically available, including operating rate and associated SIC code.
• Area sources emit smaller quantities of air pollutants than point sources. Typically, each
individual emissions source and its associated SIC code is not delineated in the area source
5 Negative costs for VOC measures are due to recovery credits for reduced VOC use or production cost savings.
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emissions inventory. One example of an area source category is VOC emissions from
automobile refinishing operations.
On-highway sources comprise motor vehicles that are generally used on the nation's road
system (e.g., automobiles, motorcycles, freight trucks).
• Nonroad sources comprise mobile sources that do not use the nation's roads (e.g., marine
vessels, locomotives, airplanes).
Vin(C)( 1) STATIONARY POINT SOURCE CONTROL MEASURES
Vffl(C)(l)(a) METHODOLOGY
To calculate a national average cost per establishment, the analysis team estimated the
total number of establishments potentially affected by each measure. Point sources in the Interim
1990 Inventory are assigned a unique plant identification code. The estimated number of affected
establishments for each point source control measure is represented by the total number of unique
plant identification codes affected. Estimates of affected establishments were summed for each
point source control measure selected under each ozone NAAQS alternative. These estimates
were then divided into the total cost of each control measure to develop the average cost-per-
establishment for each point source control measure.
Each point source in the Interim 1990 Inventory is also identified by an SIC code, which
was used for linking the average cost per establishment with a measure of the national average
sales per establishment for each potentially affected industry. National sales data are generally
available by 3-digit SIC code from the Bureau of the Census' Enterprise Statistics and related
publications (DOC, 1989a,b; DOC, 1990a,c-g; DOC, 1991a,b; DOC, 1995a,b). In the absence of
revenue data, the team substituted payroll data from County Business Patterns. This analysis
utilizes average national sales data. For each potentially affected SIC code, the analysis obtained
the following two values: (1) a national average sales per establishment over all employee size
categories, and (2) a national average sales per establishment for establishments with less than one
hundred employees. Some SIC codes did not have sufficient data to calculate an average sales per
establishment value for small establishments. In these cases, EPA calculated the ratio of average
sales per small establishment to average sales for all establishments at the 2-digit SIC code level.
This ratio was then applied to the average sales per establishment over all size categories at the 3-
digit SIC code level to estimate average sales per small establishment for that 3-digit SIC code.
For consistency, EPA projected the Bureau of Census' revenue data to 2007 levels using
the same BEA growth factors that were used to project emissions (DOC, 1990b). Since control
cost data reflect 1990 price levels, this analysis updated the 1987 Bureau of Census price levels to
1990 dollar terms using the ratio of the 1987:1990 gross domestic product (GDP) implicit price
deflator. For some SIC codes where 1987 data were not available, 1992 sales revenue data were
used, instead. Separate growth factors were developed to project sales for these SIC codes from
1992 through 2007. The average sales per establishment by SIC code was calculated for small
businesses by dividing total sales for establishments with less than one hundred employees by the
number of establishments with less than one hundred employees. Similarly, the average sales per
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establishment for all employee size categories was calculated by dividing total industry revenue by
the total number of establishments. This analysis divided the average cost per establishment for
each point source control measure by the average sales per establishment for each potentially
affected SIC code. Cost data were linked to sales data at the greatest level of common SIC code
detail - generally the 3-digit SIC code level. For each control measure and affected SIC code,
EPA computed a cost-to-sales ratio for small establishments and a cost-to-sales ratio for all
establishments.
Certain affected point sources from the Interim 1990 Inventory are identified by SIC codes
associated with government entities. For these SIC codes, the technical team employed a similar
methodology for calculating average cost-to-sales ratios. To gauge the impact of control
measures on government entities, EPA compiled expenditure information for government
functions identified as potentially affected by point source control measures. Data on government
expenditures by type of government (Federal, State, county, or municipality) and government
function (e.g., highways) are available from the Census of Government (DOC, 1990e). The data
reported for specific government functions were linked to the corresponding SIC code(s) to
provide government expenditures by county for each SIC code and county affected by one or
more point source control measures. Average annual 1987 government expenditures by county
were projected to 2007 using BEA growth factors for State and local governments. The average
cost of each applicable control measure by county was then divided by average expenditures by
county to determine a ratio analogous to the cost-to-sales ratio developed for private industries.
For potentially affected entities classified in SIC code 971 (National Security) in the point source
inventory, control costs were summed for all counties in the United States and divided by Federal
expenditures to develop an appropriate cost-to-expenditure ratio. Because government entities do
not operate in a competitive free market, they have more flexibility in trying to offset additional
costs, including reallocating funds from other government functions, and/or raising taxes or user
fees. Therefore, a cost-to-expenditure ratio of 5 percent was used to determine potentially
significant adverse impacts on government entities.
Vm(C)(l)(b) LIMITATIONS OF POINT SOURCE CONTROL MEASURE
METHODOLOGY
Source-specific cost estimates were not prepared for each emissions source. In some
cases, costs were estimated by applying an average cost-effectiveness value to the emission
reduction estimated for each point source. Also, since the estimated emission reduction is
calculated based on the emissions reported for that source in the Interim 1990 Inventory, any
limitations associated with that inventory are reflected in the cost-to-sales ratio analysis.
Cost estimates were developed using information available before 1994, and, in some
cases, reflect information from the mid-1980s. Recent and future developments in control
technology may result in lower cost estimates than those utilized for this analysis. A complete
discussion of the methods employed in estimating point source control measure costs can be
found in the docket (Pechan, 1994a; Pechan, 1994b; Pechan, 1994d).
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Point source cost estimates used in this analysis were available as a total for each
nonattainment area/control measure combination. Identification of the plants affected by each
control measure in each affected nonattainment area county were also provided. To link total
costs to individual point sources, the team assumed all plants affected by a given control measure
incur the same costs. In reality, plants in different industries and plants of different sizes incur
different costs. Therefore, the average cost per establishment reported for each control measure/
SIC code combination may be over- or under-stated.
Revenue data represent national averages by industry. Given the number of entities
potentially affected by the ozone NAAQS alternatives, it was not practicable to compile revenue
information for each entity. Furthermore, the Interim 1990 Inventory provides the plant name for
each point source - not firm ownership. Identifying the company that owns each plant would be a
complicated and resource-intensive process. Given these problems, the analysis was conducted on
an establishment-level rather than a firm-level basis. Sales revenue data are readily available by
SIC code for different employee size categories from the U.S. Bureau of the Census. Because
these revenue data are not generally available by State or county, average national sales revenues
were compared with point source costs for each potentially affected SIC code.
Finally, sufficient data were not reported in the Interim 1990 Inventory to classify affected
plants as small establishments. Therefore, EPA used this RIA's average cost per establishment to
establish potential impacts on small businesses. Since average costs for small entities differ from
the average costs calculated in this analysis, small business impacts are also mis-stated.
Vm(C)(2) STATIONARY AREA SOURCE CONTROL MEASURES
Vm(C)(2)(a) METHODOLOGY
Cost data for each area source control measure were provided by nonattainment area and
control measure. Potentially affected SIC codes are provided in Chapter VII of this report. To
estimate the number of affected establishments, EPA used county and SIC code data reported in
the 1990 County Business Patterns (DOC, 1990c). EPA estimated average costs for each area
source control measure by dividing the total control measure costs on a national level by the total
number of establishments obtained using one of the following means:
• For control measures affecting basic industries that make products that are generally
exportable out-of-state (e.g., automobile manufacturing), sum the total number of
establishments for each affected SIC code on a national basis.
• For control measures assumed to serve a national market, (and would all be affected by of
this measure in other areas of the country), identify the number of establishments on a
national level based on information from related analyses. For example, the number of
firms on a national level affected by the CARB and SCAQMD standards for aerosol paint
reformulation is based on the results of a survey conducted by CARB.
For control measures affecting service industries assumed to involve localized markets
(e.g., P-V valves for gasoline service stations), or with an unknown geographic market
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(e.g., synthetic fiber manufacturing), sum the number of establishments for each SIC code-
nonattainment area county combination.
For bulk terminals; industrial adhesives; surface coating operations and industrial fuel
combustion, estimates for the number of potentially affected establishments.6 Costs for these
control measures were estimated for establishments that emit from 25 up to 100 tons per year of
VOC or NOx. The uncontrolled emissions for all of the establishments associated with the SIC
codes were summed and multiplied by an 80 percent rule effectiveness value factor and the
control efficiency used in ERCAM to estimate total emission reductions. Total costs were then
calculated for each control measure by multiplying the total emission reduction value by the
control measure cost-effectiveness value used in ERCAM. The total cost was then divided by the
total number of establishments used to develop the total cost estimate to obtain an average cost
per establishment. This methodology estimated average costs per establishment for a sample of
establishments potentially affected by a control measure when information on the total number of
potentially affected establishments was unavailable. The methodology was simplified by
calculating a constant average cost per establishment value for all SIC codes affected by a control
measure.
The RIA compared average cost per establishment data to average sales per establishment
data for each affected SIC code to determine potentially significant economic impacts. Average
sales per establishment data were compiled for affected SIC codes using the methods described in
the point source methodology section. For each potentially affected SIC code, the average cost
per establishment was then divided by the average sales per establishment to yield the cost-to-
sales ratio for each control measure-SIC code combination.
Vm(C)(2)(b) LIMITATIONS OF THE AREA SOURCE CONTROL METHODOLOGY
All of the limitations described in the point source control measure methodology also
apply to the area source control analysis. There are additional analytical limitations associated
with the area source control methodology. First, there may be significant differences between the
number of establishments associated with the area source portion of the emissions inventory and
the number of establishments in affected counties reported in County Business Patterns. Because
area sources are not individually inventoried, the actual number of establishments affected by the
control measures is unknown. Therefore, there is no direct relationship between these emission
estimates and the number of establishments reported in County Business Patterns.
6 Because area source control measures obtain emission reductions from smaller sources not included in the
point source inventory, data from the NEI were used to estimate average costs per establishment for each of
these control measures. The NEI was developed by EPA in 1995 and 1996 to improve photochemical grid
modeling of ozone precursors. The NEI contains 1990 base year emission inventories supplied by the States
after the Interim 1990 Inventory was developed. The NEI was used for this analysis because it contains
emission data for a significant number of plants that emit less than one hundred tons per year of uncontrolled
VOC and NOx emissions.
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Second, for the area source control measures that affect emission sources from entities
classified under a variety of SIC codes, it was difficult to clearly identify the SIC codes that would
actually be affected. These control measures include the NOx measures for industrial coal, oil, and
natural gas combustion. The RIA used the NEI as the source for identifying the SIC codes most
likely affected. However, this analysis cannot estimate the extent to which the SIC codes analyzed
under- or over-estimate the SIC codes actually affected.
Finally, the average cost per plant does not differ between sources because information is
not available to identify specific costs for individual industries. Therefore, costs were allocated
evenly across affected establishments. The EPA recognizes that this is a shortcoming of the
analysis, but information is not available to determine which SIC codes/industries will incur higher
per establishment costs relative to other affected SIC codes/industries.
Vm(C)(3) MOBILE SOURCE CONTROL MEASURES
This analysis relied upon existing mobile source RIAs prepared for specific mobile source
regulatory programs that form the basis for some of the incremental control measures in this
report. The RIAs typically do not estimate the economic impacts of the control measure on the
industries affected. Instead, these RIAs generally calculate the annual cost and the per unit retail
price increase associated with a regulation. For example, the impact of the Federal reformulated
gasoline (RFG) control measure was estimated in terms of the annual cost increase and the
increased retail price per gallon of gasoline, instead of estimating the impact of the RFG program
on the refinery industry. A series of documents describes how these mobile source RIA costs were
incorporated into ERCAM for use in estimating the costs and emission reductions for the mobile
source control measures (Pechan, 1994a; Pechan, 1994b).
For consistency with the stationary source methodology, the RIA determined the impact
of these measures on entities that are directly impacted. Because of significant differences in the
implementation and cost estimation for the mobile source control measures, it was not possible to
develop a general methodology for use with all of these measures. The following sections describe
the methodology that was employed for each control measure.
Vm(C)(3)(a) ON-HIGHWAY CONTROL MEASURES
Federal Reformulated Gasoline: For this category, the RIA calculated cost-to-sales
ratios for refineries. The average cost per establishment for producing RFG was calculated by
dividing the total of the RFG program costs by the total number of establishments that are
projected to produce RFG. This cost-per-establishment figure was then compared to national
average sales-per-establishment data to analyze the potential for significant economic impacts in
the gasoline refining industry.
To estimate the total number of potentially affected establishments for this control
measure, it was first necessary to obtain the total number of refineries that produce gasoline.
Contacts with the American Petroleum Institute and the National Petroleum Refinery Association
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indicate that gasoline and other petroleum product information is not available for each refinery in
the United States. The total number of refineries that produce gasoline was estimated by dividing
the number of U.S. gasoline producing refineries as surveyed in a 1991 EPA study by the total
number of U.S. refineries surveyed in that study, and then applying this ratio to the January 1991
total number of refineries as published in the Petroleum Supply Annual (DOE, 1991).
The RIA assumes the proportion of RFG consumption relative to national gasoline
consumption (excluding California) at 53 percent. For this analysis, EPA calculated an average
cost-per establishment based on an estimate of the number of gasoline refineries that would be
producing RFG under each of the ozone NAAQS alternatives. These estimates were generated
based on county-level fuel consumption estimates. On-road fuel use was estimated by dividing
1990 county-level vehicle miles traveled (VMT) data by vehicle type-specific fuel economy (miles
per gallon) available from the MOBELE4.1 Fuel Consumption Model (EPA 1991). Off-road
gasoline consumption was estimated by applying the ratio of 1990 VOC emissions for off-road
gasoline vehicles to onroad gasoline vehicles (25 percent) to county-level on-road gasoline
consumption. The ratio of total gasoline consumed in nonattainment areas where the Federal RFG
measure was selected to total U.S. gasoline consumption (both on-road and nonroad gasoline)
was then calculated for each alternative. This ratio was applied to the estimated total number of
gasoline refineries in the United States to compute the estimated number of gasoline refineries
affected by the Federal RFG. The team developed separate establishment estimates for each ozone
NAAQS alternative (i.e., as more areas are assumed to implement this measure under more
stringent NAAQS alternatives, more gasoline refineries are assumed to be affected).
The Office of Mobile Sources has developed three RIAs describing the costs for RFG: a
February 1993 Vehicle Evaporative Emissions RIA (EPA, 1993a), a December 1993
Reformulated Gasoline RIA, and a June 1994 Renewable Oxygenate Requirements RIA. At the
time that RFG costs were input into ERCAM, only the February 1993 RIA had been released.
The December 1993 costs of Phase II RFG declined substantially from the costs used in ERCAM,
which estimated 6.8 to 8.3 cents per gallon for 7.5 psi Reid vapor pressure (RVP) fuel and 8.4 to
10.2 cents per gallon for 6.8 psi RVP fuel. The December 1993 RIA revised the Phase II cost to
4.2 to 6.1 cents per gallon, for a total annual cost of approximately $1 billion. The December RIA
also stated that smaller refineries are not required to produce RFG, and will not be significantly
impacted because of sufficient demand for conventional gasoline. The June 1994 RIA rulemaking
requires that 30 percent of the mandatory oxygen content specification for RFG be obtained from
renewable oxygenates.7 This RIA estimated the total additional cost of the renewable oxygenate
program for Phase I to fall between $4 million and $60 million per year, and for Phase II costs
would range from $22 million to $60 million annually (EPA, 1994). The RIA also estimated the
renewable oxygenate requirement will have one-time costs of approximately $15.6 million for
additional storage facilities and approximately $2 million for additional blending capacities. A
subsequent court ruling on September 13, 1994, stayed the renewable requirement pending
judicial review.
7 To ensure that the ozone benefits from the RFG program are not adversely affected by the requirement, EPA
requires that during the VOC control period, only renewable oxygenates that do not exhibit volatility-related
commingling effects when mixed with gasoline would receive renewable oxygenate credit
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Because revised RFG program costs are not reflected in ERCAM, the analysis must be
caveated in that the RFG program and costs have changed since they were originally modeled.
The costs of the program are likely to be higher or lower than those employed in this analysis,
depending upon the number of areas that ultimately are assumed to implement the measure, and
the fate of the renewable oxygenate requirement. Since that time, the program has been dropped
and future analyses will be adjusted accordingly.
Low Emission Vehicle Program: The California LEV program will impact automobile
manufacturers and indirectly impact automobile dealerships, operators of fleet vehicles, and
general consumers. This section presents the approach used to generate cost-to-sales ratios for
automobile manufacturers, as well as quantitative information on the potential indirect impacts of
the LEV program on automobile dealerships.
Impact on Automobile Manufacturers: Because automobile manufacturers serve a
national market, the RIA assumed all of the establishments reported in County Business Patterns
for SIC code 3711 would be affected by this control measure. The RIA summed the total cost of
this measure across all affected nonattainment areas and compared this sum to the total average
revenue per automobile manufacturer. This approach must be caveated because actual impacts
may differ from those presented in the cost-to-sales ratios due to a lack of cost data relating to
nonattainment area-specific implementation. For example, the estimated cost per vehicle may vary
depending upon the number of areas affected, and, therefore, the number of automobiles that will
be required to meet the program's requirements. Also, the assumption that all automobile
manufacturing establishments are affected by this measure under each alternative may overstate
the number of affected establishments.
Impact on Automobile Dealers: As stated previously, this RIA analyzes the potential
impacts of control measures, including the California LEV program, on directly affected entities.
An RFA analysis was previously conducted for a national low emission vehicle (NLEV) program
(Pechan, 1995). For this program, which is included in the control strategy baseline for this
analysis, the RIA estimated the potential for indirect impacts on automobile dealers. The
California LEV program requires that 10 percent of vehicles be zero-emission vehicles (ZEVs)
beginning in 2003. The EPA's NLEV regulations would require that 100 percent of model year
2001 automobiles meet California's LEV standards. California's standards are defined as 0.075
gram per mile (gpm) nonmethane organic gases (NMOG), 3.4 gpm CO, and 0.2 gpm NOx.
Unlike the California LEV program, the NLEV program would not require that any vehicles be
ZEVs.
For the NLEV program, the RIA performed a worst-case analysis for automobile
dealerships assuming full-cost pass through to dealers and no cost pass through to consumers.
This analysis concluded the NLEV program would not have a significant economic impact on
automobile dealerships. The cost-to-sales ratios reported for this analysis ranged from 0.1 percent
to 0.3 percent for large dealerships and 0.2 percent to 0.8 percent for small dealerships (Pechan,
1995). Similar impacts on automobile dealers may be expected from the California LEV program.
Inspection and Maintenance (I/M) Programs: The enhanced I/M program will directly
affect households in nonattainment areas for which the control measure was selected. For the
ozone NAAQS review, EPA relies on the results of a detailed RIA of this program that was
conducted for the California ozone FIP (Pechan, 1994c). This analysis evaluated the impacts of an
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enhanced I/M program based on projected costs as a percentage of total household transportation
expenditures and household income. The increased automobile repair expenditures under the
enhanced I/M program were compared to income and pre-control transportation expenditures for
households in different income stratifications. Ratios of average percent of income spent on
transportation (with and without control costs) to average income for different income levels,
provide pre-control and post-control comparison ratios.
For nonindividually owned vehicles, a modified version of the above analysis was
employed. Instead of estimating expenditures and control cost per capita, these costs are
estimated per vehicle and applied to fleet vehicles. An analysis was conducted comparing the
percentage increase in annual expenditures per vehicle for fleet operators, assuming inspection
failure. An analysis of the impact of the enhanced I/M program on small businesses in the car
rental industry and for SIC code 7513 Truck Leasing and Rental, Without Drivers was also
conducted by developing cost-to-sales ratios for these industries. Additionally, the impact of a
centralized test-only inspection program on the automobile inspection and repair industry was
evaluated. Appendix B presents the methodology, limitations, and results of the enhanced I/M
program analysis for the California FIP, modified when necessary for the ozone NAAQS review.
An I/M flexibility rule has been finalized (60 FR 20934, April 28, 1995) which revises
some of the program requirements that had been earlier assumed in developing enhanced I/M
costs for ERCAM. These revisions include the establishment of a separate "low enhanced"
performance standard; deletion of the prohibition that motorists can receive only one hardship
exemption during a vehicle's lifetime; and for the "high enhanced" performance standard, adding a
visual inspection of the positive crankcase ventilation (PCV) valve on all model year 1968-1971
light-duty vehicles (LDVs) and light-duty trucks (LDTs) and of the exhaust gas recirculation
(EGR) valve on all model year 1972-1983 LDVs and LDTs. For areas that may choose to adopt
the low enhanced performance standard, emission reductions and costs estimated by ERCAM
would tend to overstate actual values.
VHI(C)(3)(b) NONROAD CONTROL MEASURES
This section describes the analytical approaches employed in the RIA and RFA analysis for
nonroad source control measures. The limitations associated with each approach are also
identified.
California Phase II Exhaust Standards for Nonroad Diesel Engines 2:175 HP: This
measure was analyzed for its effect on the heavy-duty nonroad diesel engine manufacturing
industry because engine manufacturers are directly affected by the control measure. Estimating the
number of affected establishments for this control measure was problematic. It is possible, for
example, that all manufacturers of heavy-duty nonroad diesel engines will produce engines that
meet C ARB's Phase II standards if the program is implemented in several areas of the country.
However, only a subset of heavy-duty nonroad diesel engine manufacturers may produce engines
meeting this standard if this control measure is selected for only a few nonattainment areas.
As a preliminary approach, EPA employed nonattainment area-specific establishment data
for SIC code 3519 (Internal Combustion Engines) and collected establishment data from County
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Business Patterns for only those counties assigned the CARB Phase II standard as a control
measure. This process may underestimate the number of potentially affected establishments
because manufacturers located outside nonattainment areas may also sell engines in nonattainment
areas that must comply with the standard. However, no information is available for improving the
estimate of affected establishments at this time. Understating the number of establishments results
in an overestimation of the cost-to-sales ratio impacts because a lower number of affected
establishments results in a higher cost-per-establishment value that is then compared to the
average sales-per-establishment value.
For its screening analysis, EPA used the national value of shipments and the number of
establishments that manufacture heavy-duty nonroad diesel engines from Census of
Manufacturers' data to estimate average costs per establishment. To estimate the number of
establishments at the county level, EPA used the ratio of the national value of shipments for
heavy-duty nonroad diesel engines to the total national value of shipments for all engine types
reported under SIC code 3519 (70 percent). This ratio was used to estimate the number of
establishments potentially affected within each nonattainment area county for which the control
measure was selected. The total cost for all nonattainment area counties was then divided by the
total number of establishments estimated for the counties to calculate the average cost-per-
establishment for this control measure.
California Reformulated Diesel Fuel: Federal low-sulfUr diesel fuel regulations have
been included in the base case analysis. California reformulated diesel regulations are quite similar
to the Federal program, except that the Federal regulations only apply to on-highway vehicles,
while the California regulations also apply to nonroad vehicles.
The RIA estimated the total number of diesel fuel refineries in each State from a 1990
EPA survey's ratio of U.S. diesel producing refineries to total U.S. refineries. This ratio was
applied to the January 1991 total number of operating refineries by State as published in the
Petroleum Supply Annual (DOE, 1991).
For this analysis, EPA employed an approach that is analogous to that used in estimating
the number of gasoline refineries affected under the Federal and California RFG control measures.
On-road diesel fuel consumption estimates were developed for each county in the United States
based on fuel economy data from EPA's MOBILE4.1 Fuel Consumption Model and county-level
VMT estimates. Off-road diesel consumption was estimated by taking the ratio of 1990 NOx
emissions for nonroad diesel vehicles to onroad diesel vehicles (38 percent) and applying it to
county-level on-road diesel consumption. The RIA then calculated the ratio of total diesel
consumed for a given NAAQS alternative to total U.S. diesel consumption (both on-road and
nonroad gasoline) and applied it to the estimated total number of diesel refineries in the United
States. The result is the estimated number of diesel refineries affected by the reformulated diesel
program for each NAAQS alternative in this RIA. Total costs were then divided by the total
estimated number of affected refineries to develop an average cost-per-establishment value for use
in the cost-to-sales ratio analysis.
Recreational Vehicles: This control measure is based on a California proposal to set
emission standards for off-highway motorcycles, all-terrain vehicles, golf carts, and specialty
vehicles. The industries identified as impacted by this CARB-developed control measure are
classified in SIC code 375 (Motorcycles, Bicycles, and Parts) and SIC code 379 (Transportation
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Equipment, not elsewhere classified). For this analysis, EPA employed nonattainment area-
specific establishment data for these two SIC codes. As with the CARB Phase n standards, the
RIA obtained establishment data from the County Business Patterns for those counties affected by
the control measure. This may underestimate the number of potentially affected establishments
because manufacturers located outside of the affected counties may also sell engines in
nonattainment area counties that must comply with the standard. However, no information is
available for improving the estimate of affected establishments at this time. Understating the
number of establishments would overestimate the average cost per establishment, and, thus,
would overestimate the cost-to-sales ratio impacts.
Because the two affected SIC codes include data for other transportation equipment that
is not affected by this control measure (e.g., SIC code 375 includes bicycles), it was necessary to
adjust the total number of establishments reported in County Business Patterns for SIC codes 375
and 379. The EPA obtained data to calculate the ratios of the national value of shipments for
motorcycles to the total value of shipments for SIC code 375, and the ratio of the national value
of shipments data for all-terrain vehicles, golf carts, and specialty vehicles to the total value of
shipments for SIC code 3799. These data are available in the Census of Manufacturers (DOC,
1990a). By coincidence, 50 percent of SIC code 375 and 50 percent of SIC code 3799 represent
the proportion of total establishments in each SIC code and nonattainment area that is affected by
this measure.
Commercial Marine Vessels: The industries potentially affected by this control measure
are classified in SIC codes 441 and 442 (Deep Sea Transportation of Freight) and SIC codes 443
and 444 (Other Water Transportation of Freight, including transportation along the Great Lakes-
St. Lawrence Seaway and river transportation). The RIA allocated the total costs for this measure
to establishments within nonattainment areas which were classified in any of these four SIC codes.
Cost-to-sales ratios were then calculated for each SIC code using sales data from Enterprise
Statistics (DOC, 1995a).
This control measure is based on a draft rule that was dropped from the California FIP.
The draft rule included a three-tier emission fee structure based on a price of $10,000 per ton of
NOx reduction. With this fee program in place, vessel operators would modify fuel combustion
equipment to control the maximum amount of NOx possible as long as the cost was less than
$10,000 per ton. Otherwise, vessel operators would pay the fee. Before it was dropped from the
FIP, the basis for the control measure was changed. The revised measure would achieve NOx
reductions by moving the shipping lane to beyond 25 miles of the Southern California coast. The
cost of this shipping lane change was estimated by calculating the increased fuel costs necessary
to reroute shipping travel. The shifting of shipping lanes may be a feasible control option for other
areas of the country. The EPA conducted a cost-to-sales revenue analysis of this measure using
ERCAM costs. The ERCAM costs reflect the $10,000 per ton cost-effectiveness number.
Vm(D) RESULTS OF IMPACTS ANALYSIS OF EACH CONTROL MEASURE
The cost-to-sales ratios in the following analyses were calculated using the incremental
cost associated with each alternative relative to the current NAAQS. For each control measure-
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SIC code combination, the staff estimated the average annual cost per establishment for most of
the control measure-SIC code combinations. Stationary area source controls may affect
establishments in a number of different industries. Because of the uncertainty inherent in
quantifying the number of potentially affected establishments, the average cost per establishment
for stationary area sources may be over- or understated. Further, it was not possible to determine
the extent to which one industry affected by a stationary area source control measure may incur
higher costs than establishments in another industry affected by the same control measure. As a
result, each area source control measure shows the same average cost per establishment for each
affected SIC code. Some area source control measures may affect a broad range of SIC codes.
For these SIC codes, calculating an average cost per establishment based on the number of
establishments nation-wide would result in an underestimation of average costs per establishment.
In these cases, the RIA used the methodology outlined in the previous section, which applied to
all area source surface coating measures; bulk terminals; industrial adhesive; and all area source
industrial fuel combustion measures. Because the cost data do not provide a method for
estimating differential costs for small versus large establishments, the same average annual cost
per establishment value for each control measure-SIC code combination was used for generating
cost-to-sales ratios for all establishments and for small establishments. Mobile source cost-to-sales
ratios do not appear in this RIA because of the degree of uncertainty associated with the
methodology used to derive them.
The results of the cost-to-expenditure ratio analysis for government agencies indicated
that one county agency would be potentially affected under the 8H1AX-80 alternative, and none
would be affected under the other two alternatives. The SIC code for Federal agencies was
identified as potentially affected under all three NAAQS alternatives. For government entities, the
total cost of control measures was used to calculate cost-to-expenditure ratios rather than an
average cost per establishment. The reason an average cost per establishment was not calculated
for control measures affecting government agencies is that an agency would be expected to incur
all costs, whereas in individual industry SIC codes, any number of different firms could share the
total costs for a particular control measure-SIC code combination. Because the SBA's definition
for small government entity is based on the population served, it was not possible to develop
separate small entity cost-to-expenditure ratios for these control measures.
Vm(D)(l) ALTERNATIVE 8H5EX-80
The RE improvements control measure resulted in the highest point source cost-to-sales
ratio at all establishments, and the glass manufacturing/oxy-firing control measure resulted in the
highest ratios at small establishments. Among the area source control measures selected for
meeting this alternative, the miscellaneous surface coating/add-on control levels measure is
associated with the highest cost-to-sales ratio for all establishments. The paper surface
coating/add-on control levels measure is associated with the highest ratio for small establishments.
No county government agencies were affected by control measures selected under this alternative.
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Vm(D)(2) ALTERNATIVE 8H4AX-80
As with the 8H5EX-80 standard, the stationary point source control measure accounting
for the highest cost-to-sales ratio for this alternative is the RE improvements measure. The area
source control measure accounting for the highest cost-to-sales ratio under this alternative is the
miscellaneous surface coating/add-on control levels measure. No county government agencies
were affected by control measures selected under this alternative.
VIII(D)(3) ALTERNATIVE 8H1AX-80
The impacts estimated for this alternative represent the broadest range of potentially
affected SIC codes, and the highest cost-to-sales ratios. The highest cost-to-sales ratios for area
source control measures are associated with add-on controls for miscellaneous surface coating.
For most types of point source control measures selected under this alternative, cost-to-sales
ratios are greater than 3 percent. The point source measure accounting for the highest cost-to-
sales ratio for this alternative is the add-on control measure for industrial surface coating
operations. Only one county government agency (i.e., Fairfax, Virginia) was identified as
potentially affected by the point source wood product coating VOC control measure. Only one
point source was identified as potentially being affected in the county, classified under SIC
code 9223 (Correctional Institutions). The cost-to-expenditure ratio for the SIC code was zero.
\HI(E) METHODOLOGY AND LIMITATIONS OF IMPACTS ANALYSIS OF SIC
CODES POTENTIALLY AFFECTED BY MORE THAN ONE CONTROL
MEASURE
In addition to the analysis of the individual impacts, the RIA developed cumulative cost-
to-sales ratios for SIC codes affected by more than one incremental control measure. Because the
entities affected by the point source control measures are identified by a unique plant identification
code in the Interim 1990 Inventory, sufficient data were available to calculate cost-to-sales ratios
for plants affected by more than one control measure. This cumulative analysis was performed on
a 3-digit SIC code level, and includes only those SIC codes for which at least one plant is affected
by more than one incremental control measure. The limitations discussed earlier for the point
source control measures apply to the cumulative impacts analysis as well. Because specific entity
information is not available for the mobile and area source control measures, it was not possible to
quantify the cumulative impact of the costs associated with point source control measures and
mobile/area source control measures.
For government entities affected by more than one control measure, the number of
potentially affected establishments does not represent the number of individual plants affected, but
indicates the number of county/Federal government agencies affected.
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vm(F)
RESULTS OF IMPACTS ANALYSIS OF SIC CODES POTENTIALLY
AFFECTED BY MORE THAN ONE CONTROL MEASURE
The final output of the cumulative analysis is a summary of the number of SIC codes
potentially affected by the combination of overlapping point source control measures and an
analysis of the proportion of these SIC codes associated with potentially significant impacts.
17 industry SIC codes are affected by more than one control measure for the
8H5EX-80 alternative, 14 of which are associated with cost-to-sales ratios of greater than 3
percent when average revenue data for small establishments are employed. The Federal
government (SIC code 971-National Security) is the only government agency identified as
potentially affected by more than one control measure under this alternative. Control costs were
estimated for one point source establishment. The cost-to-expenditure ratio for the establishment
is zero.
For the 8H4AX-80 alternative, there are 34 industry SIC codes affected by more than one
control measure. The analysis indicates that 31 of these SIC codes have cost-to-sales ratios of 3
percent or greater when average small establishment revenue data are employed. The Federal
government (SIC code 971-National Security) is the only government agency identified as
potentially affected by more than one control measure under this alternative. Control costs were
estimated for three point source establishments. The cost-to-expenditure ratio for this SIC code is
zero.
78 3 -digit SIC codes are affected by more than one control measure for the 8H1AX-80
ozone alternative. Employing average revenue data for small establishments, 75 of the 78 3-digit
SIC codes have cost-to-sales ratios of 3 percent or greater. The Federal government (SIC code
971-National Security) is the only government agency identified as potentially affected by more
than one control measure under this alternative. Control costs were estimated for eight point
source establishments. The cost-to-expenditure ratio for this SIC code is zero.
Vm(G) ANALYTICAL ASSUMPTIONS AND LIMITATIONS
This analysis incorporates a number of assumptions and limitations, including:
• Analytical results reflect the costs estimated from current control strategies, not the costs from
new control strategies emerging from the CAAAC FACA process.
• Data limitations prevented this analysis from differentiating between small and large entities in
the application of control strategies.
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• The cost inputs to the analyses have several limitations, namely:
• detailed cost estimates were not prepared for each emissions source;
• disaggregation to the firm level could not be performed because control cost data was
only available at the establishment level;
• cost estimates were developed using information available through 1994; recent and
future developments in control through the 2007 analysis year could results in costs that
are significantly lower than those utilized for this analysis;
• this analysis does not incorporate new control strategies emerging from the FACA
process or any future technological changes which may provide new or improved control
measures;
• the same average cost per establishment was used for both the economic analysis and the
small entity impact analysis because sufficient data are not reported in the NPI to classify
plants as small establishments; and
• the average cost per plant shown for individual SIC codes affected by the area source
fuel combustion and surface coating control measures does not differ because
information is not available to identify specific costs for individual industries.
• The revenue (sales) data used in these analyses represent national averages by industry. This
means that the cost/sales ratios do not accurately predict impacts on specific establishments.
• Because area and mobile sources are not individually inventoried, the actual number of
establishments affected by these control measures is unknown: Generally, the number of
establishments in affected counties that are reported in County Business Patterns was used to
estimate the number of affected establishments.
• This analysis did not estimate impacts of indirectly affected sectors of the economy.
Vm(H) ENVIRONMENTAL JUSTICE ANALYSIS
Environmental justice refers to the unintentional disproportionate impact on minority and
low income populations. This RIA cannot fully assess the potential for environmental justice
considerations until the implementation process is completed under 40 CFR part 51:
vm-i9
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Vm(I) GOVERNMENTAL ENTITIES IMPACT
The Unfunded Mandates Reform Act of 1995 (UMRA) requires Federal government
agencies to assess the effects of Federal regulatory actions on State, local, and tribal governments
(Public Law 104-4, signed March 22, 1995). Under Section 202 of UMRA, EPA must prepare a
budgetary impact statement to accompany any proposed or final rule that includes a Federal
mandate that may result in total estimated costs to State, local, or tribal governments of $100
million or more. Implementation of the control strategies examined may result in an aggregate
annual cost of $100 million or more to State and local governments under at least one of the PM
alternatives. This section of the chapter is not an unfunded mandates analysis, but does provide
estimates of the potential budgetary impact of the control strategies used in the control strategy-
cost analysis affecting State and local government agencies. This analysis will be useful in guiding
future implementation activities, for they can direct efforts to mitigate potential negative
economic impacts on governmental entities. No monitoring and administrative costs were used as
inputs to estimate the impacts on governmental entities.
It is the Agency's position that once the ozone and PM NAAQS are set or revised, the
States are primarily responsible for ensuring their attainment and maintenance. Under section 110
and part D of Title I of the Clean Air Act, States develop State implementation plans (SIP's)
containing control measures as needed to attain and maintain a level of air quality that complies
with the NAAQS. For example, in order to be in conformity with federal requirements and
thereby receive federal funding, transportation control measures (TCM) cannot be federally
funded or approved unless they are consistent with SIP's.
Vm(J) CONCLUSIONS
This section summarizes the results of the cost-to-sales ratio analyses presented in the
previous sections. The purpose of this section is to show the relative impacts of the three ozone
NAAQS alternatives relative to the current standard, to identify the control measures with the
most significant impacts under each alternative, and to identify the SIC codes with the highest
potentially significant impacts under each alternative.
Vm(J)(l) SUMMARY OF RESULTS
The results presented in the previous sections were used to generate Table VIII-1, which
summarize the number of SIC codes with cost-to-sales ratios of 1 percent or greater, 3 percent or
greater, and 10 percent or greater under each alternative. Table VIII-1 (1) provides a comparison
of the occurrence of potentially significant impacts on SIC codes from one alternative to another,
and (2) evaluates the effect of changing the threshold of significant impacts to a lower or higher
cost-to-sales ratio.
For point sources, each potentially affected SIC code is counted as one record in the
second column of Table VIII-1. For stationary area and mobile sources, it was not possible to
vm-20
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estimate the cumulative impacts of the control measures on an SIC code because of the
uncertainties involved in identifying the establishments and SIC codes affected by more than one
control measure. Therefore, each area and mobile source control measure-SIC code combination
which resulted in cost-to-sales ratios of 3 percent or more is counted as one record in column 2 of
Table VIII-1. Based on column 2 of this table, the 8H5EX-80 alternative is associated with the
least number of SIC codes/SIC code-control measure combinations with cost-to-sales ratios of 3
percent or greater (149); the 8H1AX-80 alternative is associated with the highest number of SIC
codes/SIC code-control measure combinations with ratios of at least 3 percent (328).
Column 3 in Table VIII-1 presents the total number of SIC codes potentially affected by
control measures under each alternative, ranging from 104 under the 8H5EX-80 alternative to
134 under the 8H1AX-80 alternative. The remaining columns in Table VIII-1 display the number
of different SIC codes with cost-to-sales ratios of one percent or greater, three percent or greater,
and ten percent or greater. These columns differ from the second column in that an SIC code is
only counted once when it is potentially affected by more than one control measure. For area and
mobile sources, EPA uses the control measure associated with the highest cost-to-sales ratio for
these columns. For stationary point sources, the cumulative impact analysis results provide a
single cost-to-sales ratio for each affected SIC code. The fifth column in Table VDI-1 shows the
number of unique SIC codes for which the cost-to-sales ratio was three percent or greater. The
8H5EX-80 control measures have the least number of SIC codes (i.e., 21) with cost-to-sales
ratios greater than or equal to three percent. Control measures for the most stringent alternative
(8H1AX-80) have the most affected SIC codes (i.e., 64) with cost-to-sales ratios greater than or
equal to three percent.
Table VDI-1 also presents the number of unique SIC codes with potentially significant
impacts when cost-to-sales ratios are computed using average revenues for small establishments in
an industry. Compared to the cost-to-sales ratios for all establishments, the number of unique SIC
codes with a cost-to-sales ratio above a given threshold increases when computed using average
revenues for small size establishments. For example, for the 8H4AX-80 alternative under a three
percent threshold, the number of SIC codes increases from thirty-four to forty-two.
VHI(J)(2) KEY CONTROL MEASURES
Although the purpose of this RIA is to identify potentially affected industries for FACA
purposes, this chapter also evaluates the extent to which the uncertainties in cost estimates may
contribute to the high impacts. To do so, control measures that resulted in high cost-to-sales
ratios under each of the three ozone NAAQS alternatives were identified. This analysis
investigated control measures that consistently resulted in high cost-to-sales ratios. For each
alternative, the RIA ranked control measure-SIC code combinations in descending order by the
cost-to-sales ratio for all establishments. Several control measures may affect a large number of
SIC codes under all of the three NAAQS alternatives. These measures include rule effectiveness
improvements for VOC point sources, add-on control levels for point source industrial surface
coating, and MACT-level and VOC add-on controls for miscellaneous surface coating operations
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Table VIII-1
Summary of Industry Impacts
SIC Codes
10 % Threshold
3% Threshold
1% Threshold
NAAQS
Alternative
3% Threshold
Total SIC Code/
Code-Control
Measure
Combinations"
Total
Number of
SIC Codes
Potentially
Affected
Average
Revenue for All
Establishments
Average
Revenue for
Small
Establishments
Average
Revenue for All
Establishments
Average
Revenue for
Small
Establishments
Average
Revenue for All
Establishments
Average
Revenue for
Small
Establishments
8H1AX-80
328
134
54
69
64
81
78
99
8H4AX-80
173
107
26
39
34
42
43
61
8H5EX-80
149
104
10
22
21
28
27
45
Represents the total number of SIC codes with cost-to-sales ratios of 3% or greater that are affected by point source control measures, plus the total number of SIC code-control
measure combinations with cost-to-sales ratios of 3% or greater for area and mobile source measures.
Vin-22
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for all three alternative NAAQS. For example, RE improvements for VQC point sources affect 41
industries under the 8H1AX-80 alternative. Of this total, thirty-four industries have an average
cost-to-sales ratio of 3 percent or greater when calculated for all establishments. Forty of the
potentially affected industries have a small establishment average cost-to-sales ratio of 3 percent
or greater. A high proportion of affected industries with cost-to-sales ratios of 3 percent or
greater seems to indicate that average control costs in these industries may be unreasonably high.
Further research may determine if the high impacts are associated with limitations of the
methodology and/or data inputs (e.g., the average cost per plant estimate) or if further economic
analyses would clarify the reasonableness of the cost-to-sales methodology for these control
measures.
Another important issue related to the cost data used in this analysis is that the average
cost per establishment does not always account for plant size. In other words, any economies or
diseconomies of scale associated with controlling larger plants compared to controlling smaller
plants are not always reflected in the cost estimate. This may, in part, explain high cost-to-sales
ratios associated with many of the control measures.
Vm(J)(3) KEY SIC CODES
The RIA also used the results of the individual control measure analysis to the twenty SIC
codes associated with the highest impacts under each alternative. Some SIC codes are consistently
associated with very high cost-to-sales ratios, but for only one or two control measures. Other
SIC codes may affect several control measures, with high expected cost-to-sales ratios for as few
as one measure. The SIC codes with the highest potential for impact varies considerably between
the three alternatives. For example, nine of the twenty SIC codes associated with the highest cost-
to-sales ratios under the 8H1 AX-80 alternative are not on the list of the SIC codes associated
with the highest ratios under each of the other two alternatives. SIC codes 349 (Miscellaneous
Fabricated Metal Products), 342 (Cutlery, Handtools, and Hardware), and 347 (Metal Services,
not elsewhere classified) are associated with the greatest potential for impacts greater than or
equal to three percent under the 8H1AX-80 alternative; SIC codes 346 (Metal Forgings and
Stampings) and 342 (Cutlery, Handtools, and Hardware) have the greatest potential for impact
under the 8H4AX-80 alternative; and SIC code 291 (Petroleum Refining) has the greatest
potential for impact under the 8H5EX-80 alternative.
Some SIC codes are associated with only one control measure. For example, RE
improvements for VOC point sources affect only the Laundry, Cleaning, and Garment Services
industry (SIC code 721) under all three alternatives. In addition, some of the SIC codes appearing
in these tables have only one or two plants affected. Under the 8H1 AX-80 alternative, there is
only one facility in the Chemicals and Allied Products industry (SIC code 516) affected by RE
improvements.
Add on controls for miscellaneous surface coating measures affect many SIC codes with
high cost-to-sales ratios. For example, nine of the twenty most heavily affected SIC codes are
affected by this control measure under the most severe NAAQS alternative. Incremental cost-to-
sales ratio analyses indicate the add-on control measure for miscellaneous surface coating
Vm-23
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operations (as well as for paper, aircraft, and marine surface coating operations) may have high
cost-to-sales ratios as well.
The results of the cost-to-sales analyses were performed within a highly uncertain
framework. Limitations in cost data and inventories may under or over estimate actual impacts,
and this RIA cannot determine the direction or magnitude of that difference. Additionally, some
results appear excessive due to possible mis-coding within Census data or because some data
came from regional information which may not be representative of a national value. For example,
the cost-effectiveness value used to estimate costs8 is based on the cost-effectiveness of add-on
controls for a wood product coating rule developed by the South Coast Air Quality Management
District in California. According to the South Coast Air Quality Management District, wood
product coating facilities were expected to comply with the stringent limits of the rule by the use
of reformulated coatings at a cost effectiveness of $20/ton. Consequently, there may be
considerable uncertainty in using the $9,630/ton cost-effectiveness value to estimate the cost of
controls for small miscellaneous, paper, aircraft, and marine surface coating operations in the area
source inventory. Further research would be needed to determine how representative the cost-
effectiveness value is for estimating control costs for these operations.
VIII (K) REFERENCES
DOC, 1989a: U.S. Department of Commerce. Bureau of the Census. 1987 Census of Agriculture,
Volume 1. Geographic Area Series, Part 51: United States Summary and State Data. AC-87-A-
51. Washington, DC. November 1989.
DOC, 1989b: U.S. Department of Commerce. Bureau of the Census. 1987 Census of Mining
Industries, Industry Series. Various volumes. Washington, DC. Issued November 1989.
DOC, 1990a: U.S. Department of Commerce. Bureau of the Census. 1987 Census of
Manufactures. Industry Series. Washington, DC. 1990.
DOC, 1990b: U.S. Department of Commerce. Bureau of Economic Analysis. BE A Regional
Projections to 2040, Volume 1: States. Washington, DC: U.S. Government Printing Office. June
1990.
DOC, 1990c: U.S. Department of Commerce. Bureau of the Census. County Business Patterns
1990. Washington, DC.
DOC, 1990d: U.S. Department of Commerce. Bureau of the Census. 1987 Census of
Construction Industries: Industry Series. Various volumes. Washington, DC. Issued March 1990.
8 $9,630/ton of VOCs reduced from uncontrolled levels
vm-24
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DOC, 1990e: U.S. Department of Commerce. Bureau of the Census. 1987 Census of
Government. Washington, DC.
DOC, 1990f: U.S. Department of Commerce. Bureau of the Census. 1987 Census of Retail
Trade: Establishment and Firm Size. RC-87-S-1. Washington DC. Issued January 1990.
DOC, 1990g: U.S. Department of Commerce. Bureau of the Census. 1987 Census of Service
Industries: Subject Series. SC87-S-1. Washington DC. Issued April 1990.
DOC, 1991a: U.S. Department of Commerce. Bureau of the Census. Enterprise Statistics:
Company Summary (ES87-3). Washington, DC. 1991.
DOC, 1991b: U.S. Department of Commerce. Bureau of the Census. 1987 Census of
Transportation: Miscellaneous Subjects. TC87-S-1. Washington DC. Issued July 1991.
DOC, 1995a: U.S. Department of Commerce. Bureau of the Census. 1992 Census of
Transportation, Communications, and Utilities: Establishment and Firm Size. UC87-S-1.
Washington, DC. Issued May 1995.
DOC, 1995b: U.S. Department of Commerce. Bureau of the Census. 1992 Census of Financial,
Insurance, and Real Estate Industries: Establishment and Firm Size. FC92-S-1. Washington, DC.
Issued July 1995.
DOE, 1991: U.S. Department of Energy, Energy Information Administration, Office of Oil and
Gas. Petroleum Supply Annual 1990, Volume 1, DOE/ELA-0340(90)/1, May 1991.
EPA, 1991: U.S. Environmental Protection Agency, Office of Mobile Sources, Computer reports
of the MOB1LE4.1 Fuel Consumption Model, August 1991.
EPA, 1992. U.S. Environmental Protection Agency, "EPA Guidelines for Implementing the
Regulatory Flexibility Act." Prepared by the Office of Regulatory Management and Evaluation,
and the Office of Policy, Planning, and Evaluation. Revised April 1992.
EPA, 1993a: U.S. Environmental Protection Agency, Office of Mobile Sources, Regulation
Development and Support Division, Final Regulatory Impact Analysis and Summary and Analysis
of Comments: Control of Vehicular Evaporative Emissions, February 1993.
EPA, 1993b: U.S. Environmental Protection Agency, Office of Mobile Sources, Regulation
Development and Support Division, Final Regulatory Impact Analysis for Reformulated Gasoline,
December 13, 1993.
Vm-25
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EPA, 1994: U.S. Environmental Protection Agency, Office of Mobile Sources, Final Regulatory
Impact Analysis and Summary of Comments for: Renewable Oxygenate Requirements, June 29,
1994.
OMB, 1987: Executive Office of the President. Office of Management and Budget. Standard
Industrial Classification Manual 1987. Washington, DC. 1987.
Pechan, 1994a: E.H. Pechan & Associates, Inc. Analysis of Incremental Emission
Reductions and Costs of VOC and NOx Control Measures. Draft. Prepared for U.S.
Environmental Protection Agency, Ambient Standards Branch. Pechan Report
No. 94.09.011/1737. September 1994.
Pechan, 1994b: E.H. Pechan & Associates, Inc. The Emission Reduction and Cost
Analysis Model for NOx (ERCAM-NOx). Final Report. Prepared for U.S. Environmental
Protection Agency, Ozone/CO Programs Branch. Pechan Report No. 94.05.002/1701. May 1994.
Pechan, 1994c: E.H. Pechan & Associates, Inc. Regulatory Impact Analyses for the Sacramento
Nonattainment Area, South Coast Nonattainment Area, and Ventura County Federal
Implementation Plans. Prepared for U.S. Environmental Protection Agency. December 1994.
Pechan, 1994d: E.H. Pechan & Associates, Inc. Ozone NAAQS Review Clean Air Act Base
Case Evaluation for 2007. Draft Final Report. Prepared for U.S. Environmental Protection
Agency. September 1994.
Pechan, 1995: E.H. Pechan & Associates, Inc. Analysis of Costs and Benefits of a National Low
Emission Vehicle Program. Draft report prepared for U.S. Environmental Protection Agency,
Office of Mobile Sources, Ann Arbor, MI. June 30, 1995.
VHI-26
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EX BENEFITS OF OZONE NAAQS ATTAINMENT
IX(A) ECONOMIC CONCEPT OF BENEFITS
One rationale for environmental regulation, such as this National Ambient Air Quality
Standard for ozone, is to provide benefits to society by enhancing (improving and protecting)
human health and overall public welfare. This chapter provides information on the types and
levels of social benefits anticipated from the proposed rulemaking. This information includes: (1)
background information on benefits assessment, by describing benefit categories and issues in
benefits estimation; (2) qualitative descriptions of the types of benefits associated with four ozone
NAAQS alternatives; (3) quantitative estimates of benefit categories for which concentration-
response information is available; and (4) monetized estimates of benefit categories for which
economic valuation data are available.
IX(A)( 1) BENEFIT CATEGORIES APPLICABLE TO THE REGULATION
To implement a benefit analysis, the types or categories of benefits that apply need to be
defined. Figure IX-1 provides an example of the types of benefits potentially observed as a result
of changes in air quality. The types of benefits identified in both the health and welfare categories
can generally be classified as use benefits or non-use benefits.
FIGURE IX-1
EXAMPLES OF POTENTIAL BENEFITS OF AIR QUALITY IMPROVEMENTS
USE BENEFITS
EXAMPLES
Direct
'Human Health Risk Reductions (e.g., less incidences of
coughing)
'Increased Crop Yields
Indirect
'Non-Consumptive Use (e.g., improved visibility for recreational
activities)
Option Value
'Risk Premium for Uncertain Future Demand
'Risk Premium for Uncertain Future Supply
(e.g., treating as insurance, the protection of a forest just in case
a new use for a forest product will be discovered in the future)
Aesthetic
'Residing, working, traveling, and/or owning property in reduced
smog locations
NON-USE BENEFITS
Bequest
'Intergenerational Equity (e.g., an older generation wanting a
younger generation to inherit a protected environment)
Existence
'Stewardship/Preservation/Altruistic Values (e.g., an individual
wanting to protect a forest even if he knows that he will never use
the forest)
'Ecological Benefits
-------
Use benefits are the values associated with an individual's desire to avoid his or her own
exposure to an environmental risk. Use benefit categories can embody both direct and indirect
uses of affected ambient air, and the direct use category embraces both consumptive and
nonconsumptive activities. In most applications to air pollution scenarios, the most prominent use
benefit categories for air are those related to human health risk reductions, effects on crops and
plant life, visibility, and materials damage.
Non-use (intrinsic) benefits are values an individual may have for lowering air pollution
concentrations or the level of risk unrelated to his or her own exposure. Improved environmental
quality can be valued by individuals apart form any past, present, or anticipated future use of the
resource in question. Such nonuse values may be of a highly significant magnitude; however, the
benefit value to assign to these motivations often is a matter of considerable debate. Whereas
human uses of a resource can be observed directly and valued with a range of technical economic
techniques, nonuse values can only be ascertained from directly asking survey respondents to
reveal their values.
Non-use values may be related to the desire to know that a clean environment be available
for the use of others now and in the future, or may be related to the desire to know that the
resource is being preserved for its own sake, regardless of human use. The component of non-use
value that is related to the use of the resource by others in the future is referred to as the bequest
value. This value is typically thought of as altruistic in nature. For example, the value that an
individual places on reducing the general population's risk of ozone exposure either now or in the
future is referred to as the bequest value. Another potential component of non-use value is the
value that is related to preservation of the resource for its own sake, even if there is no human use
of the resource. This component of non-use value is sometimes referred to as existence value.
An example of an existence value is the value placed on the ecological benefit of protecting areas
know as wetlands because they play a crucial role in our ecological system, even if the wetlands
themselves are not directly valued by humans. A key distinction between bequest value and
existence value is that bequest values are anthropocentric while existence values are viewed by
some as completely distinct from human valuation.
The majority of health and welfare benefit categories presented in this analysis can be
classified as direct use benefits. These benefits are discussed in greater detail compared to other
benefit categories presented in Figure IX-1 because more scientific and economic information has
been gathered for the direct use benefit category. For example, scientific studies have been
conducted to discern the relationship between ozone exposure and subsequent effects on specific
health risks and agricultural commodities. In addition, economic valuation of these benefits can
be accomplished because a market exists for some categories (making it possible to collect supply,
demand, and price information) or contingent valuation studies have been conducted for
categories that people are familiar with (such as willingness-to-pay surveys for non-market
commodities).
Detailed scientific and economic information is not as readily available for the remainder
of the benefit categories listed in Figure IX-1. Information pertaining to indirect use, option
value, aesthetic, bequest, and existence benefits is often more difficult to collect. For example,
lowering ambient ozone concentrations in an area is expected to improve visibility in the affected
area while also reducing physical damage to ornamental plants in the same area. A homeowner
IX-2
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living in the affected area with ornamental plants in his yard is expected to benefit from the
improved visibility while his plants may experience either an improved appearance or an extended
life. Although scientific information can help identify the benefit categories of improved visibility
and decreased damage to urban ornamentals, lack of more detailed scientific information (e.g.,
concentration-response relationships for urban ornamentals) or economic information (e.g., how
much value a homeowner places on improved visibility in his neighborhood or city) prevent
further quantification of these benefit categories.
Another problem related to lack of information is the ability to identify all benefit
categories that might result from environmental regulation. A cost analysis is expected to provide
a more comprehensive estimate of the cost of an environmental regulation because technical
information is available for identifying the technologies that would be necessary to achieve the
desired pollution reduction. In addition, market or economic information is available for the many
components of a cost analysis (e.g., energy prices, pollution control equipment, etc.). A similar
situation typically does not exist for estimating the benefits of environmental regulation. The
nature of this problem is due to the non-market characteristic of many benefit categories. Since
many pollution effects (e.g., adverse health or agricultural effects) have not traditionally been
traded as a market commodity, economists and analysts have had to rely upon scientific and
economic theory to identify relevant benefit categories. This lack of observable markets may lead
to the omission of significant benefit categories from an environmental benefits discussion.
The inability to quantify the majority of the benefit categories listed in Figure IX-1 as well
as the possible omission of relevant environmental benefit categories will cause the quantified
benefits presented in this report to clearly be underestimated. Due to the lack of information, it is
not possible to estimate the magnitude of the benefits that have been unqualified.
EX(A)(2) ECONOMIC BENEFITS
The general term "benefits" refers to any and all outcomes of the regulation that are
considered positive; that is, that contribute to an enhanced level of social welfare. The term
"economic benefits" refers to the dollar value associated with all the expected positive impacts of
the regulation; that is, all regulatory outcomes that lead to higher social welfare. Conceptually,
the monetary value of benefits is approximated by the sum of the predicted changes in "consumer
(and producer) surplus." These "surplus" measures are standard and widely accepted terms of
applied welfare economics, and reflect the degree of well-being enjoyed by people given different
levels of goods and prices (including those associated with environmental quality).
This conceptual economic foundation raises several relevant issues and potential
limitations for the benefits analysis of the regulation. First, the standard economic approach to
estimating environmental benefits is anthropocentric - all benefit values arise from how
environmental changes are perceived and valued in present-day values. Thus, all near-term as
well as temporally distant future physical outcomes associated with reduced pollutant loadings
need to be predicted and then translated into the framework of present-day human activities and
concerns.
IX-3
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IX(A)(3)
LINKING THE REGULATION TO BENEFICIAL OUTCOMES
Conducting a benefits analysis for anticipated changes in air emissions is a challenging
exercise. Assessing the benefits of a regulatory action requires that a chain of events be specified
and understood. As shown in Figure 2, which illustrates the causality for air quality related
benefits, these relationships span the spectrum of: (1) institutional relationships and policy-
making; (2) the technical feasibility of pollution abatement; (3) the physical-chemical properties of
air pollutants and their consequent linkages to biologic/ecologic responses in the environment, and
(4) human responses and values associated with these changes.
FIGURE IX-2
EXAMPLE METHODOLOGY OF A BENEFITS ANALYSIS
Specified Ozone NAAQS Alternative
l
Expected Changes in Production Processes and/or Treatment
i
Reductions in Pollutant Emissions
Reductions in Ambient Ozone Air Quality
Change in Plant Damage and Crop
Yields
Change in Adverse Human Health
Symptoms and Risk
l
Change in Supply and Value of Crops
and Vegetables
Change in Value of Reduced Adverse
Human Health Symptoms and Risk
The first two steps of Figure IX-2 reflect the institutional and technical aspects of
implementing the regulation (the improved process changes or pollutant abatement). The benefit
analyses presented in this document begin at the step of estimating reductions in ambient ozone
air quality. In this analysis, lack of a national ozone air quality model precludes creating a direct
link between the imposition of pollution control equipment (as identified in the cost analysis) and
the resulting ambient ozone concentration. Rather, this analysis relies on a rollback methodology
that reduces hourly ozone concentrations from two different baselines in the year 2007: one
referred to as the regional control strategies baseline and one referred to as the local control
strategies baseline. Chapter IV of this report presented the methodology used to estimate baseline
ambient ozone air quality in the year 2007.
This RIA also presents two scenarios for analyzing reductions in ambient ozone air
quality. The first, referred to as the full attainment scenario, relies on the assumption that all areas
will be able to attain any ozone NAAQS being evaluated. The health and welfare benefits
presented under this scenario represent the identifiable benefits that should accrue if all areas in
the United States could comply with the standard being analyzed. The second scenario, referred
IX-4
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to as the partial attainment scenario, is intended to reflect residual nonattainment information as
presented in the cost analysis. For each area identified as not having sufficient control measures
to allow it to attain a particular standard, the rollback methodology has been scaled
proportionally. The scaling of the rollback methodology is intended to reflect the degree of
nonattainment for each residual nonattainment area. The health and welfare benefits presented
under this partial attainment scenario represent the identifiable benefits that should result from the
application of control measures as identified in the cost analysis. Note that the benefits presented
for the full attainment scenario will always exceed the benefits presented for the partial attainment
scenario since the partial attainment scenario accounts for residual nonattainment. Chapter 5
presented the methodology used to estimate ozone concentrations for the partial attainment
scenario.
Other information necessary for these benefit analyses are the physical and chemical
parameters and the consequent improvement in the environment (e.g., concentration-response
data). Finally, the analysis reaches the stage at which anthropocentric benefit concepts begin to
apply, such as illustrated by reductions in human health risk and improvements in crop yields.
These final steps reflect the focal point of the benefits analyses, and are defined by the benefits
categories described above. Below, relevant benefit categories are described qualitatively, and
where possible, quantitatively.
IX(B) HUMAN HEALTH EFFECTS
This health benefits analysis estimates that incremental to the current NAAQS, full
attainment of the proposed ozone NAAQS will yield annual monetized health benefits in the range
between $4 million and $2.3 billion. Adjusting the health benefit estimates to reflect the presence
of residual nonattainment, the annual monetized health benefits are expected to range between $2
million and $1.2 billion. The health benefit categories examined in this analysis and the
methodology used to estimate the monetized health benefits are presented below.
IX(B)(1) INTRODUCTION
This section presents a qualitative description of the documented human health effects
associated with exposure to ozone. The proposed ozone NAAQS is expected to further reduce
emissions of volatile organic compounds (VOCs) and nitrogen oxides (NOJ. The reaction of
these pollutants in the ambient air in the presence of sunlight and heat results in the formation of
ozone. As discussed below, exposure to ozone can result in a variety of adverse health effects.1
Numerous and diverse health effects have been linked to ozone exposure in laboratory
experiments, including lung inflammation, effects on lung host defense mechanisms,
morphological (lung structure) effects, respiratory symptoms, pulmonary function decrements,
changes in lung biochemistry, and genotoxicity (cellular transformation effects). Although these
'See the Ozone Staff Paper an the Ozone Criteria Document for more detailed discussions
of the health effects listed in this report.
IX-5
-------
effects each have different physiological mechanisms, each effect is initiated by the preliminary
interactions of ozone and ozone-reaction products with fluids and epithelial cells in the respiratory
tract.
These health effects have been attributed to short-term (1 to 3 hours), prolonged (6 to 8
hours), and long-term (months to years) exposures to ozone. Adverse health effects which have
been attributed to exposure to ambient ozone include: transient changes in pulmonary function,
transient respiratory symptoms and effects on exercise performance, increased airway
responsiveness, transient pulmonary inflammation, increased susceptibility to respiratory infection,
increased hospital admissions and emergency room visits, reduced worker productivity, and
possibly, premature mortality. Short-term effects are observed at ozone concentrations as low as
. 12 ppm, while similar health effects have been observed following prolonged exposures to ozone
at ozone concentrations as low as .08 ppm (i.e., at lower levels of exercise than for short-term
exposures.) For a detailed discussion of adverse human health effects associated with ozone
exposure, refer to the ozone Criteria Document and Staff Paper .
The human health effects that will be quantified (expressed in terms of incidences reduced)
and sometimes monetized (expressed in terms of dollars) are presented in Table IX-1. These
health effects include: change in forced expiratory volume (DFEV); lower respiratory symptoms;
coughs; pain upon deep inhalation; mortality; hospital admissions for all respiratory illnesses,
pneumonia, and chronic obstructive pulmonary disease (COPD); the presence of any of 19 acute
respiratory symptoms; self-reported asthma attacks; restricted activity days; sinusitis and hay
fever; worker productivity; and development of definite asthma.
A number of community epidemiology studies have suggested a possible association of
ozone or oxidants with mortality. Early studies of this issue were flawed, but more recent work
provides some additional insights. Several recent studies of daily mortality have included ozone,
either alone or in combination with PM and other pollutants. These studies are summarized in the
Particulate Matter Criteria Document (PM CD). The PM CD includes studies in New York City
(Thurston and Kinney, 1995), Philadelphia (Moolgavkar et al., 1995; Samet et al., 1996; and
Cifiientes and Lave, 1996) Los Angeles (Kinney et al., 1995), and Toronto, Canada (Ozkaynak et
al., 1994). Each of these studies found evidence of associations between ozone and daily
mortality that was statistically significant or nearly significant. The relative strength and
consistency for ozone mortality relationships, however, varied among different model
specifications and co-pollutants included. Until a more complete assessment of those emerging
studies can be conducted, the evidence is sufficient to estimate an ozone-induced mortality
benefit.
In addition to the studies above, Kinney and Ozkaynak (1991) reanalyzed earlier data
concluding that ozone explained a small but statistically significant portion of daily mortality in
Los Angeles. A study in eastern Tennessee of limited duration and lower ozone levels found no
ozone association (Dockery, 1992). The ozone criteria document review of the literature
concluded that although an association existed between high ozone levels and mortality has been
suggested, the strength of any such association remains unclear. A more recent assessment of
these and other studies for the purpose of conducting benefit assessments for the UN ECE
provided a range of estimates for ozone-mortality of 0.01 to 0.02% per ppb ozone (EFTEC Ltd.,
1996). The issue of the relative role of ozone and PM in mortality studies has been raised in the
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context of the particulate matter criteria review, particularly in two recent studies of Philadelphia
daily mortality by Moolgavkar et al. and HEI (Samet et al.). These studies have raised the
observation by some that although particulate matter may be a better surrogate for air pollution
that appears to be causing increased mortality, it is difficult to single out any one pollutant as
wholly responsible for all of the observed effects. In the HEI study of daily mortality, ozone
appeared to be separable from a group of other pollutants that contained PM. Although the
Agency recognizes that a high degree of uncertainty exists in the estimation of ozone-induced
mortality, the evidence linking a causal relationship between ozone exposure and mortality is
significant enough in these new studies to warrant inclusion of this category in this analysis.
Because benefit functions from the recent Moolgovkar study are readily available, the staff chose
to use the function derived from that study to derive an estimate for use in the upper bound of the
range of benefit estimates. A complete discussion of how mortality was included in these
estimates appears in the aggregation section of this chapter.
All categories of health benefits listed in Table IX-1 that are monetized are also quantified.
However, some categories of benefits that are quantified have not been monetized due to one of
two reasons: (1) because willingness-to-pay values are not available or (2) to prevent double-
counting some overlapping effects. These issues are discussed in greater detail further in this
chapter. For categories of health benefits listed as unqualified, scientific data is not available for
quantifying the relationship between ozone and incidences of each symptom. However, the
Criteria Document and Staff Paper present scientific evidence supporting an association between
these health effects and ozone exposure. For example, the collective toxicologic data on chronic
exposure to ozone garnered in animal exposure and human population studies provide a
biologically plausible basis for considering the possibility that repeated inflammation associated
with exposure to zone over a lifetime may result in sufficient damage to respiratory tissue such
that individuals later in life may experience a reduced quality of life. However, such relationships
remain highly uncertain due to ambiguities in the data.
TABLE JX-t
HEALTH BENEFfT CATEGORIES
Unquantified Healtt) Benefit Categories
Quantified Benefit Categories1
(in terms of incidences
reduced only)
Monetized Benefit Categories'
(in terms of dollars)
Airway responsiveness
Pulmonary inflammation
Increased susceptibility to respiratory
infection
Acute inflammation and respiratory ceil
damage
Chronic respiratory damage/Premature
aging of lungs
DFEV (change in forced
expiratory volume)
Restricted activity days
Lower respiratory symptoms
Coughs
Pain upon deep inhalation
Mortality
Hospital admissions for all respiratory
illnesses
Hospital admissions for pneumonia
Hospital Admissions for chronic
obstructive pulmonary disease (COPD)
Presence of Any of 19 Acute Respiratory
Symptoms
Self-Reported Asthma Attacks
Worker Productivity
1 Unquantified health benefit categories are described at length in the Ozone Staff Paper and Criteria Document.
2 Quantified health benefit categories are described at length in the Ozone Staff Paper and Criteria Document and are estimated
in terms of incidences reduced in this RIA.
3 Monetized health benefit categories are described at length in the Ozone Staff Paper and Criteria Document, are estimated in
terms of incidences reduced in this RIA, and are monetized in this RIA.
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The result of having significant gaps in the benefits calculations leads to an
underestimation of the monetized benefits presented in this report. The effect of the
underestimation is to severely limit any conclusions that can be reached regarding the monetized
benefits and net benefit estimates of each of the alternative ozone NAAQS.
IX(B)(2) QUANTIFIED HEALTH EFFECT BENEFITS
IX(B)(2)(a) TYPES OF HEALTH STUDIES
Scientific research about ozone's adverse health impacts uses a broad array of methods
and procedures. The research methods used to investigate the health effects of ozone have
become considerably more sophisticated over time and will continue to evolve in the future. This
progress is the result of better available research techniques and data, and the ability to focus
further research more sharply on key remaining issues based on the contributions of earlier work.
The available health effects studies that are being used as the basis of this health benefits
assessment are divided into two categories: (1) human clinical studies and (2) epidemiology
studies. Epidemiological research in air pollution investigates the association between exposure
to air pollution and observed health effects in the study population. Human clinical studies
involve examination of human responses to controlled conditions in a laboratory setting. EPA has
conducted research on health effects from exposure to pollution using each approach, and studies
using these techniques have been considered in various formal regulatory proceedings. Each type
of study (as it is used for air pollution research) is described below.
IX(B)(2)(b) HUMAN CLINICAL STUDIES
Clinical studies of air pollution involve exposing human subjects to various levels of air
pollution in a carefully controlled and monitored laboratory situation. The physical condition of
the subjects is measured before, during, and after the pollution exposure. The measured physical
condition can include general biomedical information (e.g., pulse rate and blood pressure),
physiological effects specifically affected by the pollutant (e.g., lung function), the onset of
symptoms (e.g., wheezing or chest pain), or the ability of the individual to perform specific
physical or cognitive tasks (e.g., maximum sustainable speed on a treadmill). These studies often
involve exposing the individuals to pollutants while exercising, thus increasing the amount of
pollutants that are actually introduced into the lungs.
Clinical studies can isolate cause-effect relationships between pollutants and certain human
health effects. Repeated experiments altering the pollutant level, exercise regimen duration and
types of participants can potentially identify effect thresholds, the impact of recovery (rest)
periods, and the differences in response among population groups. While cost considerations tend
to limit the number of participants and experimental variants examined in a single study, clinical
studies can follow rigorous laboratory scientific protocols, such as the use of placebos (clean air)
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to establish a baseline level of effects and precise measurement of certain health effects of
concern.
There are drawbacks to using clinical studies as the basis for a comprehensive benefits
analysis. Clinical studies are appropriate for examining acute symptoms caused by short-term
exposure to a pollutant. While this permits examination of some important health effects from air
pollution, such as asthma attacks caused by sulfur oxides, it excludes studying more severe effects
or effects caused by long term exposure. Another drawback is health effects measured in some
well-designed clinical studies are selected on the basis of the ability to measure precisely the effect
rather than a larger symptom, for example forced expiratory volume. The impact of some
clinically measurable health effects such as lung function on future medical condition or lifestyle
changes are not well understood.
Ethical limits on experiments involving humans also impose important limits to the
potential scope of clinical research. Chronic effects cannot be investigated because people cannot
be kept in controlled conditions for an extended period of time, and because these effects are
generally irreversible. Participation is generally restricted to healthy subjects, or at least to
exclude people with substantial health conditions that compromise their safe inclusion in the
study. This methodology can cause clinical studies to avoid providing direct evidence about
populations of most concern, such as people who already have serious respiratory diseases.
Ethical considerations also limit the exposures to relatively modest exposure levels, and to
examining only mild health effects that do no permanent damage. Obviously for ethical reasons,
human clinical evidence cannot be obtained on the possible relationship between pollution and
mortality, heart attack, stroke, or cancer.
The precision to which exposure conditions are controlled in clinical studies also creates
an obstacle to using clinical dose-response functions for benefit analysis. It is difficult to
extrapolate results from clinical settings to daily exposures faced by the whole population. For
example, many clinical studies evaluate effects on exercising individuals. Only a small portion of
the population engages in strenuous activity (manual labor or exercise) at any time. Reflecting
these fundamental differences between the laboratory setting and the "real world" imposes a
formidable burden on researchers to provide information about human activity patterns, exercise
levels, and pollution levels.
IX(B)(2)(c) EPIDEMIOLOGICAL STUDIES
Epidemiological studies evaluate the relationship between ambient exposures to and health
effects in the human population, typically in a "natural" setting. Statistical techniques (typically
variants of multivariate regression analysis) are used to estimate quantitative concentration-
response relationships between pollution levels and health effects.
Epidemiology studies can examine many of the types of health effects that are difficult to
study using a clinical approach. Epidemiological results are well-suited for quantitative benefit
analyses because they provide a means to estimate the incidence of health effects related to
varying degrees of ambient air pollution without further extensive modeling effort. These
estimated relationships implicitly take into account at least some of the complex real-world human
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activity patterns, spatial and temporal distributions of air pollution, synergistic effects of multiple
pollutants and other risk factors, and compensating or mitigating behavior by the subject
population. Suspected relationships between air pollution and the effects of both long-term and
short-term exposure can be investigated using an epidemiological approach. In addition,
observable health endpoints are measured, unlike clinical studies which often monitor endpoints
that do not result in observable health effects (e.g., forced expiratory volume). Thus, from the
point of view of conducting a benefits analysis, the results of epidemiological studies, combined
with measures of ambient pollution levels and the size of the relevant population, provide all of
the essential components.
Two types of epidemiological studies are considered for dose-response modeling: cohort
and longitudinal studies. Cohort-based studies are population-based studies where initially disease
free individuals are followed over a certain period of time, with periodic reporting of the health
status from the individuals. Studies about relatively rare events such as cancer incidence or
mortality can require tracking the individuals over a long period of time, while more common
events (e.g., respiratory symptoms) occur with sufficient frequency to evaluate the relationship
over a much shorter time period. An important feature of cohort studies is that information is
known about each individual, including other potential variables related to the disease being
studied. These variables, called confounders, are important to identify because if they are not
accounted for in the study and they are associated with air pollution levels, a biased estimate of air
pollution to human health may be estimated. The exposure information can range from data from
a personal exposure monitor carried by the participants for a few weeks in a study concerning
minor symptoms, to monitoring data of ambient air concentrations.
A second type of epidemiological study is the longitudinal or time-series studies. The
relationship between population-wide health information such as counts for daily mortality,
hospital admissions, or emergency room visits (e.g., heart attack, mortality, acute asthma attack
or chronic bronchitis) and ambient levels of air pollution are evaluated. One advantage of this
study design is it allows "the population to serve as its own control". Changes in such factors as
tobacco, alcohol and illicit drug use, access to health care, employment, and nutrition may have a
pronounced impact on the health of an individual, and, if they vary with the pollution variable of
interest, need to be included in a cohort study. However, such potential confounding factors are
unlikely to vary with pollution levels and these variables do not need to be evaluated in the
analysis.
Some of the drawbacks of epidemiological research are: (1) it is difficult to adequately
characterize exposure; (2) measurement errors may occur in the explanatory variables; (3) the
influence of unmeasured variables; and (4) correlations between the pollution variables of concern
and other variables (both the included and omitted variables). These factors can potentially lead
to spurious conclusions. However, epidemiological studies involve a large number of people and
do not suffer extrapolation problems like clinical studies.
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IX(B)(3) HEALTH BENEFITS METHODOLOGY
Due to the advantages and disadvantages of both clinical and epidemiological studies, this
analysis uses health effects data from both types of studies to estimate the potential health-related
benefits of the ozone NAAQS. This approach allows a broader range of scientific evidence to be
used to estimate the potential health benefits. However, as explained above, the types of health
effects examined in each type of study are not comparable. For example, an epidemiological
study might attempt to estimate the number of hospital admissions that occur for the treatment of
respiratory symptoms compared to a clinical study that might attempt to estimate the number of
coughs that are elicited from a specific exposure incident. For this reason, the results from the
epidemiological and clinical approaches must be considered as alternative approaches for
estimating the health-related benefits of the ozone NAAQS rather than as two approaches with
results that can be combined.
For this analysis, the choice of the health effects modeled were as inclusive as possible.
Since ozone is associated with a variety of health effect endpoints, the effects may overlap with
each other, as described below. Despite this overlap, the analysis presents separate estimates of
incidences for all health effects.
IX(B)(3)(a) BASELINE OF ANALYSIS
As discussed earlier in this report, air quality data have been generated for two baseline
scenarios in the year 2007. The first baseline scenario is referred to as regional control strategies
while the second scenario is referred to as local control strategies. Although benefit estimates are
estimated from both baseline scenarios, the EPA expects the regional control strategies scenario
to represent the more realistic air quality baseline for the year 2007.
IX(B)(3)(b) OZ-ONE
OZ-ONE is the computer model used in this report to estimate health effects changes and
the associated economic benefits due to estimated changes in ambient ozone. This program
generates ozone concentration data for a baseline situation as well as an estimate of post-rollback
ozone concentrations. The air quality methodology using the centroid approach (as described in
chapter 6 of this report) identified baseline ozone air quality in the year 2007. In addition, chapter
6 identified predicted ozone nonattainment areas for each alternative ozone NAAQS analyzed in
this report. The quadratic roll-back methodology was then employed to estimate post-rollback
ambient ozone concentrations for each of the nonattainment areas under each of the alternative
ozone NAAQS scenarios.
Lack of the use of an air chemistry model necessitates the development of a methodology
to estimate changes in air quality. The application of quadratic rollback attempts to estimate
reductions in ozone concentrations, given that control measures are expected to be applied in
nonattainment areas. Although the choice of a rollback methodology is expected to affect the
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calculation of benefits (the number adverse incidences avoided is influenced by the estimate of the
change ozone air quality) an analysis of the difference in impacts between various rollback
methodologies (e.g., quadratic, peak-shaving, linear) has not been performed for this analysis.
The risk assessment conducted for the Ozone Staff Paper used a Weibull distribution to
roll back ozone air quality concentrations. The Weibull distribution is data intensive because it
relies on historical air quality data specific to geographical regions. The data-intensive nature of
this work is one of many reasons why the Staff Paper only analyzed health risks in nine case-study
cities. One goal of this RIA is to conduct a benefits analysis on a national scope for the year
2007. Lack of historical data on a geographical region for the analysis year requires a more
generalized approach for estimating air quality changes. This requirement led to the development
of the quadratic rollback methodology. (Mathtech, 1996a).
The ozone nonattainment areas analyzed in this health benefits analysis are the same as the
nonattainment areas examined in the cost analysis, with one exception - areas identified as
"marginal" nonattainment areas. Current implementation guidelines require increasingly stringent
control measures as the degree of nonattainment increases. Marginal nonattainment areas fall
within the range closest to attainment. These marginal areas are not expected to be required to
implement control measures in order to bring themselves into attainment. Rather, the Agency
expects that these areas will implement less costly administrative measures (e.g., performing
quality assurance checks on their inventory information) to achieve attainment. The cost analysis
in this RIA does not estimate the administrative costs associated with these marginal areas
although the Agency expects these costs to be relatively low. However this benefits analysis
applies quadratic roll-back to all identified ozone nonattainment areas, including those labeled as
marginal, because implementation of the ozone NAAQS will include requirements for all
nonattainment areas to comply with the NAAQS.
In addition to processing air quality data, OZ-ONE evaluates a variety of health effects
that are associated with ozone exposure. OZ-ONE evaluates the health effects under the 2007
baseline and post-rollback ozone scenarios (assuming that all identified nonattainment areas fully
comply with each of the alternative ozone NAAQS being evaluated). The change in the number
of effects (e.g., the number of cough incidences) represents the basic output of the OZ-ONE
program. Therefore, the health effects estimates presented later in this chapter represent the
difference in the number of health incidences that are expected to occur between the baseline and
post-rollback ozone air quality.
IX(B)(4) HEALTH EFFECTS MODELS
IX(B)(4)(a) CLINICAL AND EPIDEMIOLOGICAL MODELS
The goal of this phase of the analysis is to estimate expected changes in the number of
cases of different health endpoints as ozone concentrations change in response to the
implementation of alternative ozone NAAQS.
Table E-l in Appendix E lists the clinical models used in this analysis. This table provides
author information for each clinical model included in this analysis. Health endpoints evaluated by
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the clinical models include: change in forced expiratory volume (DFEV) of £ 10%, st 15%, 220%;
lower respiratory symptoms; cough; and pain upon deep inhalation. A review of these models is
not included in this report because an evaluation of each model is provided in the Ozone Staff
Paper's Risk and Exposure Analysis.
Each clinical model identifies the change in health effect as a rate; for example, as a per
capita value. In order to identify the aggregate population impact, it is necessary to specify the
population affected. The clinical analysis evaluates the concentration-response functions for two
sub-population groups: outdoor children and outdoor workers. These results are then summed
to provide a total estimate of benefits of ozone control. This methodology is consistent with the
methodology used in the risk and exposure analysis conducted for the Ozone Staff Paper.
Table E-2 in Appendix E lists the epidemiological models that are used in this analysis.
This table provides author information for the 18 epidemiological models used in this analysis.
Health endpoints evaluated by these models include: mortality, hospital admissions for a variety of
conditions, the presence of acute respiratory symptoms, self-reported asthma attacks, minor
restricted activity days (MRADs), respiratory restricted activity days (RRADs), sinusitis and hay
fever, development of definite asthma, and worker productivity (resulting in changes in daily
wages). A review of these models is not provided in this report because all of these models were
previously evaluated in the Section 812(a) draft report. Therefore, the reader should consult the
Section 812 (a) draft report for a more detailed discussion of these models.
Each epidemiological model identifies the change in health effect as a rate; for example as
a per capita value. In order to identify the aggregate population impact, it is necessary to specify
the population affected. The population data is location specific (i.e., the population is specific to
each MSA) and reflects the population included within the study parameters of the
epidemiological model. For example, if a particular model is identified only with individuals over
65 years of age, then the prediction of impacts is limited to that population group. Extrapolation
to other age groups presumes that age does not matter for purposes of evaluating the effects of
ozone. This assumption does not appear to be credible for many of the health end-points
considered in this analysis since age appears to be a significant variable in many studies.
Under each approach, the concentration-response function, the air quality data, and the
population information are applied in the following procedure: Each model is evaluated with the
nonattainment area-specific ozone data (baseline and post-attainment) in order to predict per
capita changes in the associated health endpoint. These changes in per capita health impacts are
then multiplied by the appropriate population count to obtain a measure of the expected change in
impacts for a specific geographic area. However, adjustments to the time period of analysis and
the count of incidences are made before the results are reported as health benefits on a national
basis.
EX(B)(4)(b) TIME PERIOD OF ANALYSIS
To ensure additional consistency with the risk and exposure analysis, two additional
adjustments were made to the clinical studies. Activity pattern factors (i.e., the amount of time
people spend outdoors, indoors, etc.) from the risk and exposure analysis were incorporated into
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the OZ-ONE program. These activity pattern data were only available for the ozone season.
Although the ozone season varied from area to area, the "season" was significantly less than a full
calendar year in the majority of areas. Since the activity pattern factors were an integral
component of the health benefits calculation, it was necessary to limit the calculation of the
clinical health benefits to each nonattainment MSA's ozone season. (See the Ozone Staff Paper)
An area's ozone season is the period of time during a year when the potential for high
ozone concentrations is greatest. Given that the concentration-response functions predict a
greater number of health incidences given higher ozone concentrations, it is likely that the ozone
season will provide the majority of the number of incidences expected to occur during a year. In
addition, any action that would decrease an area's ozone concentration would be expected to
produce the greatest health benefits during the ozone season compared to any other time of year.
Therefore, the evaluation of the clinical concentration-response functions during an area's ozone
season is expected to capture the majority of the health benefits expected to occur during a full
calendar year.
Unlike the clinical studies, the epidemiological studies are designed to examine human
health effects in a "natural" setting. As such, information such as human activity patterns and
exercise levels are assumed to be built into the concentration-response relationship. Thus, the
activity pattern data need not be incorporated into the epidemiological models. Since all
information used to evaluate the epidemiological models were available for a full calendar year,
the epidemiological model results represent results for the entire year in 2007.
IX(B)(4)(c) INCIDENCES VERSUS INCIDENCE-DAYS
When evaluating the clinical studies, OZ-ONE provides an estimate of the number of times
(incidences) that a health symptom would occur over a 16-hour day (8 am to 12 am) during an
MSA's ozone season. However, dollar estimates from the contingent valuation (CV) surveys that
are used to estimate the economic value of these health effects are estimated in terms of dollars
per avoided "symptom day." For example, evaluation of a clinical coughing model over a 16-hour
day would yield the total number of times a cough is expected to occur during this time period
given a particular level of ambient ozone. This estimate does not differentiate between multiple
coughs experienced by one person versus one cough experienced by many people. Moreover, the
definition of a symptom day does not appear to be well defined in the CV studies. Lacking
further information, this analysis will define a symptom day as "...the value of avoiding a symptom
experienced over one day."
Due to the definition of a symptom day as reported in the contingent valuation surveys, it
is necessary to convert the number of incidences of a health symptom into a comparable count of
the number of symptom days. This conversion is accomplished by applying each clinical
concentration-response function to the daily two-hour period (or other relevant time period, as
defined by each model) reported as having the highest ambient ozone concentration during that
day. This time period corresponds to the highest probability of response among the affected
population for that day and as such, this daily period will capture the maximum number of people
that would experience a health symptom as a result of ozone exposure if activity patterns were
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constant across the day. Where available, activity pattern information was used in conjunction
with ozone concentration data to identify the two-hour period (or other relevant time period) of
each day that would provide the greatest impact. This period was then used to define the
"incidence-day" (i.e., symptom day) value for each concentration-response model. Therefore, the
results (labeled incident-days) presented for the clinical models represent values for only one two-
hour period (or other relevant time period) of each day during an area's ozone season.
The above methodology is not concerned with the total number of incidents which would
result from ambient ozone exposure. Instead, it is only concerned with the count of days over the
affected population in which incidents occur. A person experiencing multiple incidents during the
same day is classified as experiencing one incident day, thereby avoiding double-counting and
adhering to the format of the contingent valuation estimates.
Unlike the clinical studies, the results of the epidemiological studies are expressed in the
same units as the contingent valuation studies. For example, one epidemiological study included
in this analysis estimates the number of pneumonia-related hospital admissions that are expected
to occur given a particular level of ambient ozone. In this case, the results would be expressed in
terms of incidences of hospital admissions. The contingent valuation estimates used to value this
benefit category are expressed in dollars per incident avoided. Thus, no adjustments need to be
made to the calculation of the epidemiological results.
EX(B)(4)(d) AGGREGATION BY HEALTH ENDPOINT
This section describes the methodology used to aggregate results within each health
endpoint category since the majority of the health endpoints evaluated in this analysis have more
than one model to provide estimates of the number of incidences of a health effect. In addition,
multiple models evaluate varying degrees of the same health endpoint (coughing incidences and
moderate to severe coughing incidences).
The clinical models included in OZ-ONE reflect exercise protocols with both moderate
(medium breathing) and heavy (fast breathing) ventilation rates. The count of incidence-days is
computed for individuals who meet the breathing rate criteria specified in the underlying clinical
study. Therefore, individuals who meet different breathing rate criteria should be considered
members of different populations. As such, individuals should not be assigned to multiple
breathing sub-categories for the same exposure period. Based on the above rationale, this
analysis assumes that incidence-day results for populations with different breathing rates are
mutually exclusive and therefore, additive.
For all clinical health endpoint categories except two (respiratory symptoms), a range of
results is estimated using the following procedure: The lower bound estimate within each
breathing sub-category will be summed to provide a total lower bound estimate! A similar
procedure will be followed to provide an upper bound estimate for each health endpoint category.
The best estimate will be defined as the sum of the mean of each breathing sub-category result.
This approach makes use of all information provided by the evaluation of each model and
provides a sense of the variability in the estimate of effects.
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For the two remaining health endpoint categories, lower respiratory symptoms and
moderate/severe lower respiratory symptoms, only one model is available for each category.
Therefore, the count of incidence days from these models are presented as the best estimate for
these health endpoint categories.
The following procedure will be used to aggregate the results of the epidemiological
models:
Mortality: Four models were identified that predict changes in mortality rates due to
changes in ozone. Although this analysis presents the results of each of the models, only the
results from two of the models will be included in the aggregation procedure. As will be
discussed later, this health endpoint category comprises the majority of the monetized benefits
under the epidemiological approach. Given this distribution, the results of this category were
examined in greater detail compared to the other categories. Closer examination of the results
revealed that the estimated ozone coefficients in two of the models (the two Dockery et al.
models) were estimated with a relatively low level of precision (high standard errors) and were
not statistically significant from zero. Of the two remaining models, one model (Moolgavkar et
al.) was statistically significant from zero while one model (Kinney et al.) provided a result of zero
incidences with adequate precision. Given this information, the lower bound of the mortality
category is set equal to the results of the Kinney model while the upper bound of the range is set
equal to the results of the Moolgavkar model. A best estimate is not calculated for this category
due to the high degree of uncertainty associated with these estimates.
Hospital Admissions: There are four categories of hospital admissions that are included
in this analysis: (1) All Respiratory Illnesses; (2) Daily Respiratory Admissions; (3) Pneumonia;
and (4) Chronic Obstructive Pulmonary Disease (COPD). The aggregation of these hospital
admissions endpoints is more complex than that described for the mortality models because the
All Respiratory Illnesses category encompasses all other hospital admissions endpoints.
For aggregation within each hospital admissions category, the following procedure is
used: where there is more than one epidemiological model for any one of the categories, the
model providing the lowest number incidences reduced is used as the lower bound estimate of a
range while the model providing the greatest number of incidences reduced is used as the upper
bound estimate of the range. The mean of the results of all models within each category will serve
as the best estimate for that category.
For aggregation across the hospital admissions categories, simply summing the results of
the four hospital admissions categories would result in double-counting because the first category,
all respiratory illnesses, encompasses all other hospital admissions endpoints. Given that the
remaining three hospital admissions endpoints are subsets of the all respiratory illnesses category,
inclusion of the results from all four categories would be incorrect.
Based on the information described above, the following procedure is used for
aggregating across the hospital admissions categories: Separate classifications for each category
will be retained in order to preserve all information provided by the models. Estimated reductions
in hospital admissions for pneumonia and COPD are reported separately using the aggregation
scheme within each category as previously described. The all respiratory illnesses category
encompasses all other hospital admissions endpoints, leading this category to produce a greater
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number of incidences than the other hospital admissions categories. In addition, this category
covers the same population demographics as the hospital admissions for pneumonia and COPD.
Based on the above evidence, it is possible to use results reported for the all respiratory illnesses
category after subtracting the sum of the results reported for the pneumonia and COPD
categories. The number of incidences remaining after the above calculation now represents
hospital admissions for all respiratory illnesses except for pneumonia and COPD. As will be seen
later, a willingness-to-pay value is not available for the daily respiratory admissions category.
However, the procedure described above for the treatment of the other three hospital admissions
categories should also capture the number of incidences that would have been estimated in the
daily respiratory admissions category. Therefore, incidences estimated under the daily respiratory
admissions category will be left out of the final aggregation scheme. This procedure allows all
incidences reported for the hospital admissions categories to be monetized without double-
counting the results.
Restricted Activity Days: Two models describe the association between ambient ozone
and measures of restricted activity. The differences in these models make it difficult to implement
a consistent aggregation approach within this group. The problem in ordering these two measures
is definitional: it is not clear how either of these two health endpoints is defined. Another issue
with these endpoints related to aggregations is how these models overlap with other models
included in this benefits analysis. It is likely that calculated changes in RRADs and MRADs due
to changes in ozone will involve some change in a respiratory related symptom. In this case, a
separate accounting of restricted activity days will double count any symptom impacts that are
also separately measured. Since this analysis includes an epidemiological model that addresses
respiratory symptoms (Presence of Any of 19 Acute Respiratory Symptoms), the MRAD and the
RRAD models are excluded from the aggregation scheme.
Other Health Endpoints: The remaining four health endpoints (the presence of any of
19 acute respiratory symptoms, self-reported asthma attacks, sinusitis and hay fever, and worker
productivity) have only one epidemiological model that provides estimates for each effect.
Therefore, there is no issue of aggregation within each group.
For all other epidemiological health endpoints, the results of each category are included in
the monetization scheme if a willingness to pay estimate is available for that category. This
approach to monetization should eliminate the probability of double-counting. For example,
mortality and hospital admissions are distinct events. Even though a single individual may
experience both effects, aggregation across these categories should not result in double-counting
as long as the willingness-to-pay values properly reflect the individual's perception of each event
separately. Based on our knowledge of the WTP values, many studies are careful to define the
precise "good" that is to be valued. Although there is no guarantee that individual respondents
did not impose their own set of criteria as to what they should be valuing, we are unaware of
specific studies that have tested for the existence of an effect aggregation bias as part of the
research. For example, we assume that the WTP value for avoiding any of the 19 acute
symptoms is a distinct event that respondents differentiate from the WTP value that a respondent
would report for avoiding an asthma attack (asthma is a chronic condition).
Worker Productivity: The worker productivity category (lower efficiency and reduced
wages) does not have an aggregation issue because results produced by this model are expressed
IX-17
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in terms of dollars (compared to incidences for all other models). Therefore, the results of this
model do not need any conversion scheme. Although this benefit category does not directly
measure health benefits expected to result from reduced ozone exposure, the end product
measured by this model, reduced productivity, is directly related to the health of outdoor workers.
IX(B)(4)(e) NATIONAL RESULTS
All health effects models are evaluated by OZ-ONE using baseline 2007 air quality and
post-rollback air quality. The results produced by OZ-ONE represent the reduction in the number
of incidences (epidemiological models) or incidence-days (clinical models) given an ozone
NAAQS alternative. Tables E-3 to E-6 in Appendix E present the total estimated reductions in
incidences or incidence-days associated with the current ozone NAAQS. These estimates were
calculated for both the regional control and local control strategies baselines. In addition, these
estimates were calculated for the full attainment and partial attainment scenarios. Table E-5
shows that between five to eight million incidence-days of coughing would be reduced for
outdoor workers and outdoor children under the assumption of full attainment of the current
ozone NAAQS, given the regional control strategies baseline. In addition, Table E-5 shows that
between 350 to 950 cases of hospital admissions would be reduced for people aged 65 years and
older, using the same baseline assumptions.
This analysis, like the Staff Paper, uses epidemiological studies to estimate reductions in
hospital admissions. However, the hospital admissions studies included in the section 812(a) draft
report (and included in this RIA) are not identical to the hospital admissions studies used in the
StaffPaper. A comparison of the hospital admissions results presented in the Staff Paper and this
RIA shows that the studies used in the StaffPaper produce significantly higher benefits. Since the
StaffPaper has been through extensive scientific review, the hospital admissions studies used in
the StaffPaper may be incorporated into future revisions of this analysis.
Benefit estimates presented for the alternative ozone NAAQS are presented as incremental
estimates to the current ozone NAAQS. These estimates are presented in Tables E-7 to E-18 in
Appendix E. For example, Table E-7 presents the aggregated clinical results for the .08 ppm, 8-
hour, 5 exceedance alternative under a regional control strategies baseline. Using the full
attainment scenario, this analysis shows outdoor workers and outdoor children can avoid an
additional 1.5 million to 2.9 million incidence-days of coughs, not counting all the coughs that
were reduced for having first attained the current ozone NAAQS. Using the same regional
control strategies baseline and full attainment scenario, Table E-8 provides incidence-day
reduction estimates for the .08 ppm, 8-hour, 4 exceedance alternative. This table shows that
incremental to the five to eight million reduction in incidence-days of coughs for having attained
the current ozone NAAQS, full attainment of the 4 exceedance alternative would yield an
additional 1.7 million to 3.4 million incidence-days of coughs. Clinical results for full attainment
of the .08 ppm, 1 exceedance alternative are presented in Table E-9. Incremental to the current
ozone NAAQS and using the same baseline assumptions as above, we should expect an additional
reduction of 2.7 million to 6 million incidence-days of coughs for outdoor workers and outdoor
children.
IX-18
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EX(B)(5) MONETIZED HEALTH EFFECT BENEFITS
The goal of this phase of the health benefits analysis is to aggregate across the disparate
health endpoint categories. Although dollar estimates have been presented for each of the health
endpoints presented in the quantified health benefits section of this analysis, it is important to
prevent the possibility of double counting or under counting the health effects.
The quantified health effect benefits presented in the previous section represent counts of
changes in specific health measures. Therefore, for each distinct health endpoint, there is a
different unit of measure. This difference prevents an aggregation of impacts across models. One
way to overcome this problem is to convert each physical measure of health impact into a single
metric. When possible, the common metric used for all models presented in this economic benefit
analysis is the willingness to pay (in dollar terms) associated with the improvement in health
predicted by each model. Once all impact measures are converted to doilar measures, aggregation
can be performed. This section presents the methodology and results of the model aggregation.
IX(B)(5)(a) ECONOMIC VALUATION
The social benefit associated with a change in the environment is the sum of each
individual's willingness to pay for (or to avoid) the change. Historically, economists have used
three techniques for valuing the social benefits resulting from reduced morbidity due to an
environmental change.
A traditional valuation strategy has been the "cost of illness" (COI) approach. This
approach assumes that the value of health improvements is the sum of the direct and indirect costs
of illness: the health expenditures made and the loss of labor productivity. The advantage of the
cost of illness approach is that economists can rely on observed human behavior. In addition, the
data are not difficult to collect. This method is commonly accepted by many researchers in the
health care industry because it provides estimates for the value of a wide range of health effects.
However, the COI approach does not provide a conceptually correct measure of willingness to
pay (WTP) because it does not account for many factors associated with experiencing or avoiding
an adverse health symptom (e.g., the value of discomfort an individual feels when experiencing an
adverse health symptom). A second problem with this approach is that many health symptoms
may have several causes. The COI approach is only able to measure the expenditure an individual
makes to treat or avoid a health symptom. This method is not able to identify the cost of illness
caused by a particular pollutant. A third problem with this approach is that it unevenly treats an
individual's and society's willingness to pay for the treatment or avoidance of a health symptom
or risk.
The second approach is the averting behavior method. This method infers willingness to
pay to reduce ambient pollution levels from expenditures to avoid exposure to air pollution (for
example, the operation of air filters) or to mitigate its effects (for example, taking an antihistamine
to avoid an allergic reaction). One advantage of the averting behavior approach is that it also is
based on observed economic behavior. Disadvantages of this approach include: (l)It requires a
IX-19
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considerable amount of data that is difficult to obtain; (2)One must be able to assume that the
averting activity was undertaken to the point the marginal cost of the averting behavior is equal to
the value of the reduced illness/risk, thereby understating the benefits if the averting activity is a
zero-sum activity; (3)The averting activity may produce joint products; and (4)the individual
enjoys not only the savings in expenditures but also gains in expected utility.
The third approach involves conducting a survey and directly asking people what they
would be willing to pay for a good, hypothetically assuming (contingent upon) that a market for
the good exists. This method, referred to as contingent valuation (CV), has been applied to a
variety of non-market goods, including adverse health symptoms. CV is based on sophisticated
survey techniques that may be able to yield valid and reliable WTP values. CV surveys also may
address the issues of existence and bequest values because survey responses may include the
moral satisfaction of contributing to public goods and charity. Although CV has been widely
accepted in recent years, its application is controversial. Potential biases in willingness to pay
estimates include hypothetical bias, strategic bias, starting point bias, vehicle bias, and information
bias. (Freeman, 1993).
IX(B)(5)(b) VALUATION ESTIMATES
Valuation estimates from willingness-to-pay studies are used as the basis for valuing
changes in the number of incidence-days of each health endpoint. With the exception of the three
hospital admissions categories, all values are obtained from Appendix I of the Section 812(a) draft
report. The values presented in Table XI-2 of that report should be thought of as unit values for
the changes in impacts generated from the OZ-ONE computer model. For each health endpoint
category, the product of the willingness-to-pay value, the per capita impacts, and the applicable
population will provide an estimate of the benefits of the ozone change for that impact category.
The section 812(a) draft report includes dollar estimates for only two clinical health
endpoints evaluated in this health benefits analysis: Coughs and Pain Upon Deep Inhalation.
These values are presented in Table IX-2. Additionally, Table IX-2 presents per unit willingness
to pay values available for epidemiological health endpoints included in this analysis. As can be
seen in this table, recommended values are available for all epidemiological health endpoints but
two: Sinusitis and Hay Fever and Development of Definite Asthma. Therefore, it is not be
possible to assign a monetary value to these two endpoints. All unit WTP values used in this RIA
are consistent with the unit values used in the section 812(a) draft report. In general, these unit
values are also consistent with the PM NAAQS RIA, with the exception of the WTP value used
for the Presence of Any of 19 Symptoms endpoint. The PM NAAQS RIA used a different
methodology to derive a WTP value for this endpoint, which resulted in a lower unit WTP value
($18.31). The Agency will adopt a single methodology for valuing this endpoint for the RIAs for
promulgation of these NAAQS.
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TABLE IX-2
WILUNGNESS-TO-PAY ESTIMATES TO AVOID MORBIDITY AND MORTALITY RISKS (1990 $)
Health Endpoint
WTP Value per Incident
Low Estimate
Best Estimate
High Estimate
Cough
$1.26
57.00
$13.84
Pain Upon Deep Inhalation
$1.26
$4.41
$28.04
Mortality
N/E1
$4.8 million
N/E
Hospital Admissions: All Respiratory Illnesses
N/E
$11,972
N/E
Hospital Admissions: Pneumonia
N/E
$15,110
N/E
Hospital Admissions: COPD
N/E
$15,502
N/E
Presence of Any of 19 Acute Respiratory Symptoms
$3.72
$29.33
54.94
Self-Reported Asthma Attacks
$11.81
$32.48
$53.80
The reader should note that the value of the mortality endpoint is at least several orders of
magnitude larger than any of the other values. The relative magnitude of this value suggests that
the majority of the high end of the total monetized benefits will be driven by the mortality
estimates. Recall from Table E-12 (in Appendix £) that the clinical approach does not include the
mortality endpoint. Also, recall from the aggregation discussion that the low estimate for the
mortality category is always equal to zero (results of the Kinney et al. model) while a "best"
estimate is not calculated. Therefore, the only time the $4.8 million value (as reported in Table
IX-2) is used in this analysis is when incidences of mortality are reported for the high estimate
Also note that this analysis uses economic values for the three hospital admissions
endpoints that are different from the values reported for the same categories in the section 812(a)
draft report. The section 812(a) analysis uses the COI approach to derive an economic value for
these health categories. However, since COI estimates do not measure values associated with
pain and suffering (as well as other reductions in well-being) resulting from illness, they
significantly understate the true WTP to avoid illness. For this reason, an adjustment factor is
employed to scale the hospital admissions COI estimate upward to estimate WTP. Following the
strategy employed by Chestnut, the hospital admissions' COI estimate as reported in the section
812(a) draft report is multiplied by a factor of 2. This factor is based on results from three studies
providing evidence on COIAVTP ratios for the same study population addressing the same change
in the same health effect. While this adjustment approach is based on limited evidence, the
resulting hospital admissions valuation estimate is not clearly biased.
To summarize, this analysis monetizes the following health endpoint categories: Coughs,
Pain on Deep Inhalation, Mortality, Hospital Admissions for All Respiratory Illnesses, Hospital
1N/E = not estimated
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Admissions of Pneumonia, Hospital Admissions of COPD, the Presence of Any of 19 Acute
Respiratory Symptoms, and Self-Reported Asthma Attacks.
IX(B)(5)(c) NATIONAL MONETIZED BENEFITS
The monetized value of the reduction in the number of adverse health symptoms is
calculated as the product of the expected reduction in the number of incidences of each symptom
and the monetized value of each health symptom. The results of this computation are presented in
Tables E-19 to E-29 of Appendix E. Recall that a best estimate is not provided for the mortality
category due to the high degree of uncertainty associated with these estimates.
Note that results are presented separately for the clinical and epidemiological models.
Results from the two approaches should be viewed as alternative methods for valuing health
benefits rather than as approaches that can be aggregated. For example, the clinical approach
evaluates health endpoint categories such as respiratory symptoms, coughs, and pain upon deep
inhalation. These categories are similar to some epidemiological health endpoint categories
included in this analysis: hospital admissions for a variety of respiratory symptoms, presence of
any of 19 acute respiratory symptoms, and self-reported asthma attacks. Since an overlap is likely
to occur when using the two approaches, it would be misleading and incorrect to aggregate the
results from the two approaches. Therefore, the results of the clinical and epidemiological are
reported separately.
However, it is possible to use the results from the two approaches to develop a range of
estimates for the monetized benefits. Each approach provides a low, best, and high monetized
health benefit estimate on a national basis. Since the two approaches are alternative methods for
valuing health benefits, the following procedure is used to develop a range of the national
monetized health benefits: The low end of the range is set equal to the approach yielding the
lowest total estimate. The high end of the range is set equal to the high end of the
epidemiological approach because the epidemiological models yield the greatest monetized benefit
values due to the inclusion of the mortality category.
The results of this procedure are presented in Table IX-3. From the regional control
strategies baseline, the monetized health benefits of fully attaining the current ozone NAAQS are
expected to range between $7 million to $2.5 billion. Although the impacts of the proposed
ozone NAAQS were not directly analyzed in this RIA, the impacts of the 4 exceedance and 1
exceedance .08 ppm. 8 hour alternatives can be used to bound the level of benefits we should
expect from the proposed ozone NAAQS. Incremental from the results of the current ozone
NAAQS, the annual health benefits of fully attaining the proposed ozone NAAQS are expected to
range between $4 million and $2.3 billion. The wide range in these health benefit estimates is due
to two factors: (l)the high estimate of the range includes the results of the mortality category,
which comprises greater than 98% of the total estimate while the low estimate of the range
excludes the mortality category and (2)the range of benefits presented for the proposed ozone
NAAQS encompass the results of two NAAQS alternatives.
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TABLE IX-3
SUMMARY OF ANNUAL MONETIZED HEALTH BENEFITS
Year = 2007; (Millions; 1990 $)
(Estimates are incremental from the current standard)
Regional Control Strategies
Baseline
Local Control Strategies
Baseline
Ozone NAAQS
Full Attainment
Scenario
Partial
attainment
Scenario
Full Attainment
Scenario
Partial
attainment
Scenario
Including Mortality Estimates1:
.08 ppm, 8-hour, 4 ex.
$4 - $1,283
$2 -$597
$9-$1,811
$4 -$894
.08 ppm, 8-hour, 1 ex.
$7 - $2,289
$4-$1,223
$15-$3,197
$8-$1,635
Excluding Mortality Estimates2:
.08 ppm, 8-hour, 4 ex.
$4 - $260
$2-$116
$9-$418
$4 -$206
.08 ppm, 8-hour, 1 ex.
$7 - $455
$4 -$237
$15-$722
$8 - $370
The appropriate scenario to examine for benefit-cost comparisons is the partial attainment
scenario. From the regional control strategies baseline, the monetized health benefits of the
current ozone NAAQS are expected to range from $2 million and $650 million. Once again, the
benefits of the 4 exceedance and 1 exceedance alternatives will be used to bound the expected
health benefits for the proposed ozone NAAQS. Incremental from the results for the current
standard, the annual health benefits of the proposed ozone NAAQS under the partial attainment
scenario are expected to range between $2 million and $1.2 billion.
As noted earlier in this chapter, incidences of mortality are reported only for the high end
of the monetized benefits. An examination of the contribution of the mortality estimates to the
monetized benefits reveals that this category constitutes the majority (>98%) of the high end of
the monetized benefits range reported for the epidemiological approach. However, the Agency
also recognizes that a high degree of uncertainty exists in the estimation of ozone-induced
mortality. Without considering mortality in the monetized benefits, the high end of the benefits
range would now be driven by the results of the clinical approach. These results are also
presented in Table IX-3. A comparison of the high estimates shows that generally, the high range
would decrease by a factor of five for the regional control strategies baseline and a factor of four
for the local controls strategies baseline. Although monetized benefits without inclusion of the
mortality estimates are presented in this analysis, the Agency concludes that enough scientific
evidence exists to merit consideration of this category in the analysis. Therefore, the Agency
'High end of range includes epidemiological results of Moolgavkar et al. study for mortality.
*High end of range taken from results of clinical approach results.
IX-23
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considers the monetized benefits that include the mortality category as being the most appropriate
range for evaluating the benefits of reduced ozone exposure.
IX(C) WELFARE EFFECTS
This welfare benefits analysis estimates that incremental to the current NAAQS, full
attainment of the proposed ozone NAAQS will result in monetized annual welfare benefits from
crop yield in the range of $70 to $500 million. Adjusting the welfare estimates to reflect the
presence of residual nonattainment, the annual monetized welfare benefits are expected to range
between $10 and $230 million. These results are based on the CENTROED model for air quality
inputs consistent with the health benefits determination. Although unquantifiable at this time,
additional protection to other sensitive species and ecosystems beyond agricultural crops is
expected to be significant.
IX(C)(1) INTRODUCTION
The effects of ozone on crops, ornamentals, tree seedlings, mature trees, and forested
ecosystems have been studied extensively (USEPA Criteria Document for Ozone and Related
Photochemical Oxidants, July 1996; and USEPA Staff Paper for Ozone, June 1996). Elevated
ozone levels can inhibit the carbohydrate production that occurs through photosynthesis and can
result in the reallocation of available carbohydrates (e.g., from roots to other parts of organism,
causing growth decline at the root level; or affecting the long term storage of carbohydrates
necessary for survival of deciduous trees which lose their leaves and undergo a period of
dormancy each year). Reduced photosynthesis may also result in leaf damage, decreased yield,
reduced plant biomass, increased susceptibility to pest and disease outbreaks (or increased need
for pesticides), and ultimately economic losses.
In addition, the available information further suggests more subtle impacts of 03 acting in
synergy with other natural and man-made stressors to adversely affect individual plants,
populations and whole systems. By disrupting the photosynthetic process, decreasing
carbohydrate storage and growth in roots (reducing plant nutrient uptake), increasing early
senescence of leaves and affecting water use efficiency in trees, 03 exposure can disrupt or change
the nutrient and water flow of an entire system. Weakened trees can become susceptible to pest
and pathogen outbreaks, loss of competitive advantage," and decreased reproductive success (or
seedling survivability), possibly resulting in reduced genetic variability within the species or entire
ecosystem. The San Bernardino Forest is an example of 03 acting as a fundamental stressor
altering the ecosystem structure or species composition and arresting its development. It should
be mentioned that some factors, such as light intensity, relative humidity, and soil water content,
can alter a plant's sensitivity to ozone.
IX-24
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TABLE IX-4
WELFARE BENEFITS CATEGORIES
Quantified Benefits Categories
Unqualified Benefits Categories
Increased Yield for Commodity Crops
Increased Yield for Fruits and Vegetables
Increased Yield for Commercial Forests
Ecosystem and Vegetation Effects in Class I Areas (e.g.,
National Parks)
Damage to Urban Ornamentals (e.g., grass, flowers,
shrubs, trees)
Reduced Yield in Tree Seedlings and Non-Commercial
Forests
Damage to Ecosystems (e.g., increased susceptibility to
pests)
Materials Damage
Nitrogen Deposition in Sensitive Nitrogen-saturated
Coastal Estuaries and Ecosystems
Visibility
Among this range of biological vegetation effects of concern, there is also a range in the
degree of effects quantification. Some effects are quantifiable, either economically or non-
economically, while many can still only be discussed qualitatively. Exposure-response functions
exist for a number of commercially significant crops and seedlings of sensitive tree species.
Although exposure-response functions do not exist for mature trees, quantitative assessments of
yield loss in commercial trees exist based on expert judgement. However, there is insufficient
information at this time (USEPA Criteria Document for Ozone and Related Photochemical
Oxidants, July 1996; and USEPA Staff Paper for Ozone, June 1996) to estimate the severity of
some of the other impacts as a function of ozone ambient levels. Therefore, in the absence of
scientific exposure-response relationships, a qualitative discussion of these other potential benefits
is presented.
The rest of this section consists of two parts: Monetized Welfare Benefits Assessment
and Non-Monetized Welfare Benefits Assessment. The following Table IX-4 presents a
summary of the quantified and unqualified welfare benefits categories.
EX(C)(2) MONETIZED WELFARE BENEFITS ASSESSMENT
This section presents the results of the economic benefits associated with reductions in the
yield of some important commercial crops for alternative standards. Adequate data are currently
available to assess economic benefits for the commodity crops studied in the NCLAN project
(discussed in section VII-D.2 of the USEPA Staff Paper for Ozone, June 1996) and for fruits and
vegetables grown in California.
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Commodity Crops. The economic value associated with varying levels of yield loss for
commodity crops was analyzed using a revised and updated (Mathtech, 1994) Regional Model
Farm (RMF) (Kopp et al., 1985) agricultural benefits model. The RMF is an agricultural benefits
model for crops that account for about 75% of all U.S. sales of agricultural crops (Mathtech,
1994). The results of the model are extrapolated to include 100% of the crops. The RMF
explicitly incorporates exposure-response functions into microeconomic models of agricultural
producer behavior. The model uses the theory of applied welfare economics to value changes in
ambient 03 concentrations brought about by particular policy actions such as attaining alternative
ambient air quality standards.
The measure of welfare calculated by the model is the net change in consumers' and
producers' surplus from baseline 03 concentrations to the 03 concentrations resulting from
attainment of alternative standards. Using the baseline and post-control equilibriums, the model
calculates the change in net consumers' and producers' surplus on a crop-by-crop basis. Dollar
values are aggregated across crops for each standard. This dollar value represents a measure of
the change in social welfare associated with the policy scenario. Although the model calculates
benefits under three alternative welfare measures (perfect competition, price supports, and
modified agricultural policy), the results presented here are based on the "perfect competition"
measure to reflect recent changes in agricultural subsidies. Under the recently revised Farm Bill,
most eligible fanners have enrolled in the program to phase out government crop price supports
for the RMF-relevant crops: wheat, corn, sorghum, and cotton.
For the purpose of this analysis, six crops were analyzed: corn, cotton, peanuts, sorghum,
soybean, and winter wheat. The model employs biological exposure-response information derived
from controlled experiments conducted by the National Crop Loss Assessment Network
(NCLAN) (Lee et al., 1996).
The RMF allows the user to choose between EPA's Regional Oxidant Model (ROM) or
the Aerometric Information Retrieval System (AIRS) as the source of baseline data. AIRS and
ROM are the basis for the CENTROID method. In addition, the most recent update (addendum
to Mathtech 1994) of the RMF completed in June 1995 (Mathtech, 1995) allows for the use of
concentration values generated from the national air quality Geographic Information System
(GIS) projections developed by EPA's National Health and Environmental Effects Laboratory-
Western Ecology Division (NHEERL-WED) (Lee et al., 1996).
Fruit and Vegetable Crops. There are currently no national-level economic models that
incorporate fruits and vegetables, although such efforts are underway. A regional model, the
California Agricultural Resources Model (C ARM), has been developed and used by the California
Air Resources Board (Howitt, 1995a, b). This model was used to analyze the benefits of reducing
ambient 03 on the sensitive crops grown in California (Abt, 1995a). Among these crops are the
economically important fruits and vegetables endemic of California and other states with similar
climate, such as Florida. The crops included in the CARM analysis are: (almonds, apricots,
avocados, cantaloupes, broccoli, citrus, grapes, plums, tomatoes, and dry beans. In 1990,
California crops accounted for almost 50% of the U.S. fruit and vegetable production. The
results of the model are extrapolated to include 100% of the crops.
The CARM is a nonlinear optimization model of California agriculture which assumes that
producers maximize farm profit subject to land, water, and other agronomic constraints. The
IX-26
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model maximizes total economic surplus and predicts producers' shifts in acreage planted to
different crops due to changing market conditions or resources. The version of the CARM used
for this analysis was calibrated to 1990 production and price data.
The quantification of benefits described in sections IX(C)(2)(A-B) below represent
commodity crops and California fruits and vegetables. The results are calculated using SUM06
exposure-response functions, except for some fruits and vegetables for which those functions
were not available. Results are shown incrementally from the current standard. Sections
IX(C)(2)(A-B) differ in air quality inputs (CENTROID vs GIS) to the economic models.
Economic models and exposure-response functions are the same for the various air quality
scenarios. The air quality scenarios described in sections EX(C)(2)(A-B) are: (A) CENTROE)
Method, Regional and Local Control Strategies, Partial Attainment and Full Attainment; and (B)
GIS Method, Full Attainment Results as presented in USEPA Staff Paper for Ozone (1996a).
IX(C)(2)(a) CENTROID METHOD: REGIONAL AND LOCAL CONTROL STRATEGIES
PARTIAL ATTAINMENT AND FULL ATTAINMENT SCENARIOS
i. Background
The analysis presented here is modeled after the monetized welfare benefits analysis for
agricultural crops presented in the USEPA Staff Paper for Ozone (1996a). The methodology was
modified to use the CENTROID model for air quality inputs in order to be consistent with the
cost and health benefits analyses and be able to add all monetized benefits and compare with the
costs.
ii. Methodology
The health and welfare benefit analyses use the same ozone concentration data. Monitor
data from the 1990 AIRS data base are extrapolated to the year 2007 using a statistical
relationship estimated from modeled ozone concentrations. A 2007 baseline file is created which
represents expected monitor concentrations with regional controls. These baseline concentrations
are rolled back to reflect implementation of alternative primary and secondary ozone standards. It
should be noted that the rounding assumptions of implementing the current standard have been
preserved. For calculations involving a secondary standard different than a primary standard, the
concentrations have been rolled back to attainment of the standard without rounding since there is
no implementation precedent for rounding of a secondary standard. However, any monetized
benefits attributed to achievement of a separate secondary standard should be considered slightly
overestimated if a rounding convention is used for a secondary standard different than the
primary.
A quadratic rollback equation is used to define improved concentration values. For the
full attainment scenario calculations, rollback leads to full attainment of a standard. However,
since attainment depends on the availability of emission control options, some nonattainment areas
are not able to fully attain a given primary standard. For these areas, only partial attainment is
IX-27
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assumed in the calculations under the partial attainment scenario and the benefits are reported
accordingly. Once ozone concentrations are constrained by partial attainment for a particular
standard, no further improvements in concentrations are possible for more stringent standards. In
those areas where full attainment of a primary standard is possible, quadratic rollback reduces
concentrations further to fully attain an alternative secondary standard. In those areas where full
attainment of a primary standard is not possible, other rural areas outside of the nonattainment
area are examined and quadratic rollback applied to attain an alternative secondary standard, if
necessary.
For the partial attainment scenario (accounting for residual non-attainment), quadratic
rollback is dependent on the definition of nonattainment areas for each primary standard. A
design value monitor is identified within each nonattainment area. This is the monitor with the
maximum value of ozone concentrations for a specific standard. This monitor establishes the
rollback amounts at all other monitors in the nonattainment area. Ail monitors in the
nonattainment area experience some rollback. However, the absolute improvements in
concentrations are less at monitors with relatively better air quality because of the nature of
quadratic rollback. If the design value monitor only partially attains a given standard, other
monitors in the same nonattainment area will also be limited in the rollback realized for that
standard.
All rollback calculations occur at monitors. Benefit calculations rely on imputed
concentrations at county centroids. Once rollback values at monitors are computed for alternative
standards, the CENTROID interpolation algorithm creates county centroid ozone distributions for
each standard. Counties with centroids enclosed by one or more monitors in nonattainment areas
will have ozone improvements. This is because all monitors in nonattainment areas experience
rollback. However, counties with centroids enclosed by monitors in attainment with a specific
primary standard will be examined for a secondary standard and rolled back to attain that
secondary standard, if necessary. These monitors may or may not show improvement in
concentrations with respect to a secondary standard.
The RMF uses statewide average changes in ozone concentrations to compute benefits.
Baseline and "post-control" statewide values are computed as production weighted averages
across the county centroid ozone distributions. These averages are combined with
exposure-response functions estimated for different crops to predict yield changes at model farms.
The RMF model incorporates the yield change information into an economic model which
calculates changes in economic surplus for each crop and standard. Dollar values are aggregated
across crops for each standard.
iii. Results
Table IX-5 shows monetized welfare benefits incremental to the current standard for
commodity crops using RMF's competitive equilibrium measure and for California fruits and
vegetables using CARM. These results are based on the CENTROID method, the use of SUM06
functions, extrapolation to 100 percent of the crops, and 1990 dollars. Results are shown for
both the RCS and LCS scenarios under both assumptions of full attainment and partial attainment
scenario. Estimates for achieving the current standard range from S190-250M under the RCS full
IX-28
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TABLE IX-5
Monetized Ozone Welfare Benefits Incremental to the Current Standard Based on RMF1
(Millions of dollars)
ALTERNATIVE STANDARD
REGIONAL CONTROL STRATEGY
LOCAL CONTROL STRATEGY
FULL ATTAINMENT
PARTIAL
ATTAINMENT
FULL
ATTAINMENT
PARTIAL
ATTAINMENT
,08ppm, 8hr, 4X
S72-1202
S10-502
$100-230'
$50-1702
.08ppm, 8hr, lx
$195-520
$65-230
$185-610
$115-450
Table IX-6
Comparison of GIS and CENTROID Results: Monetized Ozone Welfare Benefits Incremental to the Current Standard Based on RMF' (in
millions of dollars)
ALTERNATIVE STANDARD
GIS: FULL
ATTAINMENT
CENTROID:
REGIONAL
CONTROL
STRATEGY
CENTROID:
LOCAL CONTROL
STRATEGY
,08ppm, 8hr, 1x
$420-1,250
$195-520
$185-610
'Competitive Equilibrium Measure, CARM, CENTROID, SUM06 Functions, Extrapolation to 100% of Crops, Areawide Rollback, Regional Control
Strategy and Local Control Strategy
2Does not include results from CARM (in progress) nor results from the commercial forests analysis because they are not directly additive in this scenario
Competitive Equilibrium Measure, CARM, SUM06 Functions, Extrapolation to 100% of Crops
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attainment scenario to S220-300M under the LCS full attainment scenario. A stringent secondary
standard incremental to the current primary is estimated to add between $200-300M under either
scenario. Estimates for achieving the current standard range from $110-150M under the RCS
partial attainment scenario to $140-180 under the LCS partial attainment scenario. A stringent
secondary standard incremental to the current primary is estimated to add up to $100M.
The range of results from this analysis represents impacts associated only with available
NCLAN experimental data. Not all cultivars of a crop have been subjected to exposure-response
experiments. Furthermore, the mix of cultivars actually grown in 1990 is not represented by any
single cultivar examined during the NCLAN study. The RMF benefits results associated with
either the "minimum" or "maximum" exposure-response function (endpoints of the range
presented) simply represent impacts that span a range of possible results that could be obtained
with available experimental information. To project monetized benefits nationwide, estimates are
extrapolated to 100% of the crops because the analyses account for only 75% of the commodity
crops and 50% of the fruit and vegetables. A rough approximation of a national estimate is
calculated by proportionally scaling the monetized estimates to the entire market. It is
recognized, however, that factors such as the sensitivity of other cultivars to 03, regional air
quality, and regional economics introduce considerable uncertainty to any such approach to
develop national estimates.
The results from this analysis measure the national economic effects of changes in ambient
03 levels on the production of a subset of important commodity crops and California fruits and
vegetables. The results indicate that a reduction in 03 from 1990 ambient levels to a controlled
level results in a monetary net benefit. Conversely, an increase in 03 to an assumed ambient
concentration across all regions produces a net loss. The results indicate that reductions in 03
from an estimated 2007 baseline to controlled levels result in a monetary net benefit. Two levels
of response were evaluated for each standard to reflect the minimum response and the maximum
response based on results for various cultivars in each crop.
It is important to restate and summarize the uncertainties associated with the results of the
monetized crop yield loss analysis. Uncertainties are introduced by: (1) the extrapolation of
limited monitored air quality data to national air quality distributions; (2) the application of
exposure-response functions from NCLAN open-top chamber studies extrapolated to 1990
ambient air exposure patterns and crop production; (3) the use of alternative non-NCLAN
exposure-response functions for a variety of fruits and vegetables not included in the NCLAN
studies; (4) the use of a quadratic rollback methodology to project the "just attain" air quality
distributions without a direct link to an emissions control strategy; and (5) the use of economic
models with inherent uncertainties. In addition, estimated yield losses are directionally
overestimated because they are based on NCLAN-derived functions which use a background
concentration of 0.025 ppm instead of a background level of 0.04 ppm (which is the midpoint of
the range assumed in Section IV of the USEPA Staff Paper for Ozone, June 1996).
Overestimation of yield losses results in higher benefits. Quantification of the individual or
compounded effects of these uncertainties, or of the directional bias resulting from the above
assumptions, is infeasible at this time. The results presented should be viewed as rough
approximations.
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EX(C)(2)(b) GIS-BASED METHOD: FULL ATTAINMENT SCENARIO
I. Background
A summary of the methodology and results of the monetized crop loss analysis presented
in the StaffPaper is included here for comparison purpose. The main differences between the two
analyses are: the GIS model was used for the StaffPaper analysis, the CENTROID model was
used for the RIA analysis; and the current implementation rounding convention was not used in
the StaffPaper analysis, but was used for the RIA analysis. This comparison is presented to show
that these models produce similar results, notwithstanding the uncertainties that surround both.
ii. Methodology
For a more detailed description of the methodology that employs the GIS model, refer to
the USEPA StaffPaper (1996a). The National Health and Environmental Effects Research
Laboratory-Western Ecology Division (NHEERL-WED) in Corvallis developed a Geographic
Information System-based (GIS-based) approach (Lee et al., 1996 and Herstrom et al., 1995) to
model air quality that has characteristics of both interpolation and modeling. Although this
integrated GIS-based approach is not as complex as a true computer model, it has the advantage
of using data that is readily available across the entire country, it is very inexpensive to run, and it
allows one to quickly produce exposure estimates of any exposure index for multiple months or
years. For RMF applications, the most important advantage of the approach is its ability to
produce a dense grid of 03 exposure values across the U.S. The major limitation associated with
the use of the GIS approach is the lack of monitored air quality data in rural areas. The baseline
for the welfare benefits calculated in this analysis was the 1990 air quality. The year 1990 is
considered a representative year and predicted air quality is rolled-back to attainment of the
standards being analyzed. The 1990 air quality baseline was chosen for consistency reasons: it is
the baseline used for modeling, implementation, and other analyses related to the 03 standard
review.
As with any spatial interpolation technique that must rely on sparse data representative of
urban or near-urban areas, the uncertainty of the GIS-based 03 estimation technique is great and
non-quantifiable. However, the ability of the GIS-based technique to capture trends and
variations of 03 exposure between monitored sites is theoretically improved over other available
methods because it attempts to account for ozone formation and decay, wind direction, cloud
formation, temperature, and elevation.
A quadratic roll-back procedure (Horst, 1995a) was used to generate post-control
conditions. This procedure produces a distribution of 03 concentrations that reflect projected air
quality when an alternative standard is "just attained". The "just-attained" air quality distribution
is not directly linked to an emissions control strategy and does not use a rounding convention.
IX-31
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iii. Results
As evidenced by the results presented in table IX-6, it is estimated that, based on the GIS
model, positive incremental benefits result from attaining a primary standard different from the
current standard. For a 0.08ppm, 8hr, lexceedance standard, the benefits incremental to the
current standard are estimated in the range of $420-$ 1,250. Based on the GIS model, estimates
for achieving the current standard range from $250-420M, with incremental benefits from a
stringent secondary standard estimated to add between $450-830M.
Table IX-6 shows a comparison of the CENTROBD-based RCS and LCS full attainment
scenarios to the GIS-based results. The main differences between the two analyses are: the GIS
model was used for Staff Paper analysis, while the CENTROID model was used for the RIA
analysis; and the current implementation rounding convention was not used for the Staff Paper but
was used for the RIA. This comparison is presented to show that these models produce similar
results, notwithstanding the uncertainties that surround both.
To put the above analyses in perspective, benefits from economic studies reported in the
1996 Criteria Document (1996b) range from $1.3 billion to $2.5 billion. Two of the cited studies
were national in scope and judged adequate in terms of data inputs. Kopp et al. (1985), using the
RMF including corn, soybeans, wheat, cotton, and peanuts, reported $1.3 billion (1980 dollars) in
benefits from the reduction of ambient 03 from 53 to 40 ppb. Adams et al. (1986) included corn,
soybeans, cotton, wheat, sorghum, and barley, and reported $1.7 billion (1980 dollars) in benefits
from a 25% reduction in ambient 03 from 1980 levels. These results are not directly comparable
to the results of either the GIS-based or the CENTROID-based analyses because they are based
on higher baseline air quality (1980 versus 1990 versus 2007, respectively), and they are based on
different post-control average air quality levels that cannot be related to the alternative standards
used in this analysis.
An examination of the monetized benefits indicates that most of the welfare benefits
accrue from the attainment of the 8-hr primary standard alternatives with a small incremental
improvement obtained by the addition of a seasonal secondary standard. The projected national
approximations for commodity crops, fruits and vegetables, urban ornamentals, and commercial
forests in the east suggest benefits in the order of 100 to 600 million dollars for a new 8-hour,
0.08 ppm primary standard alone or in combination with a seasonal secondary standard. Based on
scientific information, monetized benefits alone understate the public welfare benefits obtained
from the adoption of an 8-hour primary standard alone or in combination with a new seasonal
secondary standard.
EX(C)(3) NON-MONETIZED WELFARE BENEFITS
Additional consideration should be given to potential benefits from categories which have
not been monetarily valued, either because no direct measures of their value exist or because the
indirect measurement techniques, such as contingent valuation studies, may be considered
controversial. These unmonetized categories include: ecosystem and vegetation effects in Class I
areas; damage to urban ornamentals; reduced yield in tree seedlings and non-commercial forests;
IX-32
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damage to ecosystems; materials damage; nitrogen deposition in sensitive nitrogen-saturated
coastal estuaries and ecosystem; and visibility.
Based on the studies of agricultural crops and the benefits estimated here, a significant
degree of vegetation protection is estimated to be afforded by an alternative primary standard
more stringent than the current standard. Although unquantifiable at this time, additional
protection to other sensitive species or individuals within a species could be potentially significant
at regional or local levels.
Following is a brief discussion aimed at highlighting what is "at stake" for two categories
of ozone-sensitive vegetation groups for which complete monetization has not been calculated.
These two categories are urban ornamentals and commercial forests.
Ornamentals and Commercial Forests. Urban ornamentals and commercial forests are
additional vegetation categories that represent large economic sectors which are likely to
experience some degree of effects associated with exposure to ambient 03 levels. However, in
the absence of adequate exposure-response functions and economic damage functions for the
potential range of effects relevant to these types of vegetation, no direct quantitative economic
benefits analysis has been conducted. However, significant economic benefits could potentially
result upon attaining the alternative standards analyzed above for commercial crops and fruits and
vegetables.
Ornamentals used in the urban and suburban landscape include shrubs, trees, grass, and
flowers. The types of economic losses that could potentially result from effects that have been
associated with 03 exposure include: 1) reduction in aesthetic services over the realized lifetime of
a plant, 2) the loss of aesthetic services resulting from the premature death (or early replacement)
of an injured plant, 3) the cost associated with removing the injured plant and replacing it with a
new plant, 4) increased soil erosion, 5) increased energy costs from loss of shade in the urban
environment, 6) reduced seedling survivability, and 7) any additional costs incurred over the
lifetime of the injured plant to mitigate the effects of 03-induced injury. It is estimated that more
than $20 billion (1990 dollars) are spent annually on landscaping using ornamentals (Abt, 1995),
both by private property owners/tenants and by governmental units responsible for public areas,
making this a potentially important welfare effects category However, information and valuation
methods are not available to allow for plausible estimates of the percentage of these expenditures
that may be related to impacts associated with 03 exposure.
Recognizing this limitation, but based on data assessing retail expenditures on
environmental horticulture at $23B in 1991 and because of the large uncertainties in the realm of
ecological benefits assessments, we venture to theorize that if only half of a percent of public
expenditures on ornamentals could be traced to ozone-induced damage that would be avoided
with a revised ozone standard, then these benefits would amount to $115M.
Any attempt to estimate economic benefits for commercial forests associated with
attaining alternative 03 standards is constrained by a lack of exposure-response functions for the
commercially important mature trees. Although exposure-response functions have been
developed for seedlings for a number of important tree species, these seedling functions cannot be
extrapolated to mature trees based on current knowledge. Recognizing this limitation, a study by
Pye et al. (1988a,b) used a method involving expert judgments about the effect of 03 levels on
percent growth change to develop estimates of 03-related economic losses for forest products.
EX-33
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An analysis by Mathtech (1995) of forestry sector benefits describes quantitatively the
effect of ozone on tree growth and the demand and supply characteristics of the timber market.
This analysis uses modeled baseline ozone concentrations and a rollback strategy to represent
ozone improvement scenarios. The ozone data used in this analysis coincide with the data used in
the agricultural sector benefits analysis presented in the USEPA Staff Paper (1996a). The
estimates do not include possible non-market benefits such as aesthetic effects.
The analysis is limited to the eastern United States without attempts to extrapolate to the
West due to lack of data on the economic relationships in the national timber market, and timber
acreage and mix of trees in the West. According to the 1993 Statistical Abstract, more than half
of wood production takes place in the western United States.
Until additional effects information becomes available in the form of exposure response
functions for mature trees or for allowing extrapolation of seedling exposure-response functions
to mature trees, the uncertainties associated with estimating monetized benefits for mature
commercial trees will remain. However, based on results from the expert judgement surveys that
suggest that the impact of current ambient ozone on annual growth for commercial trees in the
Northeast and Southeast is about 1 percent yield reduction per year, and adopting a series of
assumptions to establish consistency across several sources of data (Mathtech 1995b), an analysis
of commercial forest benefits shows benefits incremental to the current standard based on, a
primary standard of 0.08ppm 8hr, lx to be in the range of $15-120M. This range cannot be
simply extrapolated to other standard scenarios to be included in the total monetized benefits, but
it is presented here to highlight what is at stake from ozone effects.
IX(D) SUMMARY OF HEALTH AND WELFARE BENEFITS
The purpose of this section is to summarize the health and welfare benefits discussions
presented earlier in this benefits chapter. Annual monetized benefits have been presented
separately for health and welfare effects. It is now possible to sum these health and welfare
benefits to provide a more complete depiction of the total benefits expected to result from
attainment of the proposed ozone NAAQS. These results are presented in table IX-7. Using the
4 exceedance and 1 exceedance, .08 ppm, 8 hour alternatives to bound the results, full attainment
of the proposed ozone NAAQS (incremental from attainment of the current standard and
calculated from the regional control strategies baseline) is expected to yield total annual
monetized benefits in the range of $76 million to $2.8 billion. From these baselines, but adjusting
for the presence of residual nonattainment, total annual monetized benefits for the proposed
ozone NAAQS are expected to range between $12 million and $1.5 billion.
Population estimates for the 2007 analytical year are also relevant for this benefits
analysis. From the Regional Control Strategy baseline, the population estimated to be in
nonattainment areas is approximately 60 million people for the current standard. For the
standards that bound the proposed NAAQS, and incremental from the current standard, the
population estimated to reside in nonattainment areas is expected to range between 39 million and
89 million people.
IX-34
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TABLE IX-7
Summary of Annual Monetized Health and Welfare Benefits
Year =2007
(Millions; 1990 $)
(Estimates are incremental from the current standard)
Ozone NAAQS
Regional Control Strategies Baseline
Local Control Strategies
Baseline
Full Attainment
Scenario
Partial Attainment
Scenario
Full Attainment
Scenario
Partial Attainment
Scenario
.08 ppm, 8-hour, 4 ex.
$76-$1,403
$12-$647
$109-$2,041
$54 - $1,064
.08 ppm, 8-hour, 1 ex.
$202 - $2,809
$69 - $1,453
$200-$3,807
$123-$2,085
Caveats:
'Many categories of unquantified/unmonetized benefits
'Health benefits not calculated outside identified nonattainment areas even though emission reductions withing nonattainment areas are
expected to reduce ozone concentrations outside of nonattainment areas
For the Local Control Strategy baseline, population estimates associated with
nonattainment areas for the current standard are approximately 93 million people. Incremental
from the current standard and for the standards that bound the proposed standard, population
estimates range between 44 million to 86 million people.
The additional costs and health benefits of a separate secondary standard have not been
estimated. However, a number of inferences can be made from the results of the welfare benefits
analysis under the full attainment scenarios. For the proposed standard, monetized benefits from
commodity crops of the most stringent secondary standard incremental to the primary standard
are close to zero. This indicates that the proposed primary standard is binding for those areas
where commodity crops are grown (which includes California). For these areas, there would be
no incremental improvements and, therefore, no additional costs or health benefits. For areas
where we do not know if the proposed primary standard is binding (areas where commodity crops
are not grown), the air quality database created to perform the commodity crops analysis could be
used to estimate any additional health benefits. These benefits are expected to be small because
the benefits curves flatten as the air quality improves marginally. However, cost estimates are not
available for these areas because of incomplete emissions inventory data at this time. The Agency
will attempt to address these costs in the RIA for promulgation of the proposed NAAQS.
In considering these monetized benefit estimates, the reader should be aware that many
limitations for conducting these benefit analyses have been mentioned throughout this RIA. One
significant limitation of both the health and welfare benefit analyses is the inability to quantify
many ozone-induced effects. Table IX-8 lists the categories of benefits that this analysis was able
to quantify and those discussed only in a qualitative manner. In general, if it were possible to
include the unquantified benefit categories in the total monetized benefits, the benefit estimates
presented in this RIA would increase.
As discussed in the ozone Staff Paper, human exposure to ozone is known to cause health
effects such as: airway responsiveness, increased susceptibility to respiratory infection, acute
IX-35
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inflammation and respiratory cell damage, premature aging of the lungs and chronic respiratory
damage. An improvement in ambient ozone air quality (due to implementation of the proposed
ozone NAAQS) is expected to reduce the number of incidences within each effect category that
the U.S. population would experience. Although these health effects are known to be ozone-
induced, scientific information in the form of concentration-response data was not available for
quantifying the benefits associated with reducing these effects. The inability to quantify these
effects leads to an underestimation of the monetized benefits presented in this analysis.
Another short-coming of the health benefit estimates is the inability to monetize many
health effects even though scientific data was available to estimate the reductions in incidences.
Aggregation issues and/or the lack of economic valuation estimates prevented the monetization of
these reductions in incidences. These health effects include: change in lung function (DFEV),
lower respiratory symptoms, and restricted activity days. Although some degree of overlap exists
between these symptoms and other health end-points that were monetized in this analysis (e.g.,
change in lung function may lead to an asthma attack), it is clear that the monetized health
benefits presented in this RIA underestimate the total benefits attributable to the proposed ozone
NAAQS by omitting these categories from the total monetized health benefits.
TABLE IX-8
Summary of Unqualified and Quantified Benefit Categories
Unquantified Benefit Categories
Quantified Benefit Categories
(in numbers of incidences and/or dollars)
Health Benefit Categories (from a reduction in ozone and related pollutants)
Airway responsiveness
Increased susceptibility to respiratory infection
Acute inflammation and respiratory cell damage
Premature aging of lungs/Chronic respiratory damage
Reduced cancer and adverse attacks from toxic ozone
precursors and associated oxidant products
Reduced mortality/morbidity from lower fine particle
levels
Coughs
Pain upon deep inhalation
Mortality
Hospital admissions for all respiratory illnesses
Hospital admissions for pneumonia
Hospital admissions for chronic obstructive pulmonary disease (COPD)
Presence of any of 19 acute respiratory symptoms/restricted activity days
Self-reported asthma attacks
Worker productivity
Change in lung function1
Lower respiratory symptoms
Welfare Benefit Categories
Ecosystem and vegetation effects in Class 1 areas (e.g.
National Parks)
Damage to urban ornamentals (e.g., grass, flowers,
shrubs, trees)
Reduced yields of tree seedlings and non-commercial
forests
Damage to ecosystems
Materials damage
Nitrogen deposition in sensitive nitrogen saturated
coastal estuaries and ecosystems
Visibility
Increased yields for.
Commodity crops
Fruits and vegetables
Commercial forests
'Scientific term is change in forced expiratory volume (FEV)
IX-36
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A potential significant health benefit category associated with the proposed NAAQS is
that toxic ozone precursors and associated oxidant products are also expected to be reduced.
Exposure to toxic air pollutants can cause cancer and other adverse effects in humans. The
proposed NAAQS would require a reduction in ozone precursor emissions, some of which are
likely to include toxic air pollutants. Not being able to quantify these effects leads to an
underestimation of the monetized benefits.
As has been previously presented in this RIA, control strategies to improve ambient ozone
concentrations focus on reducing emissions of ozone precursors — VOC and NOx. The reduction
of NOx emission reductions is expected to affect not only ambient ozone concentrations but also
ambient PM concentrations since NOx is also a precursor for PM formation. The lack of a
comprehensive national modeling prevents a generalizable and quantifiable relationship to be
established between NOx emission reductions and the resulting effect on PM in this analysis.
However, it is expected that if NOx and VOC emissions are reduced, health improvements related
to reduced PM exposure would occur. The effect of quantifying this category would be to
increase the monetized benefit estimates presented in this RIA.
Also related to NOx emission reductions is the effect these reductions are expected to
have on nitrogen deposition in certain estuaries where nitrogen is a nutrient contributing to
eutrophication. Specifically, the effect of nitrogen deposition on the Chesapeake Bay has been
studied. This examination was possible partly because a relationship was established between
NOx emissions and nitrogen deposition. The effect of adding this category to the monetized
benefits would be to increase the estimates.
Another category, reductions of ozone damage to commercial forests, has been partially
monetized in this analysis. Results from expert judgement surveys suggest that the impact of
current ozone on annual growth for commercial trees in the Northeast and Southeast is about one
percent yield reduction per year. The ozone-relevant species included in the surveys are: high
elevation spruce, southern pines, southern hardwoods, northern hardwoods, and low elevation
spruce. Based on this judgement and a series of assumptions adopted to establish consistency
across several sources of data, an analysis of commercial forest benefits (Mathtech 1995b) shows
incremental benefits under the most stringent 8 hour, .08 ppm, primary standard alternative in the
range of $15 million to $120 million. This range cannot be simply extrapolated to other standard
scenarios to be included in the total monetized benefits, but it is presented here to highlight what
is at stake from ozone effects. Although benefit estimates are not available for the other
alternative NAAQS analyzed in this RIA, it is clear that adding this category of benefits to the
monetized benefits for each ozone alternative would increase the estimates.
Another category of potential benefits is related to the effect of ozone on urban
ornamentals (e.g., plants used in urban landscaping). Urban ornamental plants represent an
important area of welfare loss associated with ozone damage. Urban (and suburban) ornamentals
include: grass, flowers, shrubs, and trees. Quantifying economic losses from ozone-induced
damage to urban ornamentals is restricted by the lack of exposure response functions for a
significant number of sensitive species, wide variation in plant sensitivity across and within
species, and difficulty in monetizing the value associated with specific injuries. A report about the
economic implications of injury to urban ornamentals (Abt, 1995b) cites USDA data assessing
retail expenditures on environmental horticulture at $23 billion in 1991. A survey for the National
IX-37
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Gardening Association estimated household spending on plants, turf, associated pest control and
maintenance, and landscaping at $23 billion in 1992. Although there is no analytically solid
method to connect these expenditures to ozone-induced damage, but because of the large
uncertainties in the realm of ecological benefits assessments, we venture to theorize that if only
half of a percent of public expenditures on ornamentals could be traced to ozone-induced damage
that would be avoided with a revised ozone standard, then these benefits would amount to $115
million. The addition of this category would increase the monetized benefit estimates presented in
this RIA.
There are other benefit categories for which there is incomplete information to permit a
quantitative assessment of benefits for this analysis. For some endpoints, gaps exist in the
scientific literature or key analytical components and thus do not support an estimation of
occurrences. In other cases, there is insufficient economic information to allow estimation of the
economic value of adverse effects. Thus, this benefit analysis is incomplete with respect to full
coverage of all potential benefits for ozone alternatives. These potentially significant, but
unqualified welfare benefit categories include: existence and user values related to the protection
of Class I areas (e.g., Grand Canyon National Park), tree seedlings for more than 10 sensitive
species (e.g., black cherry, aspen, ponderosa pine), non-commercial forests, ecosystems, visibility,
materials damage, and reduced acid deposition (nitrates) to aquatic and terrestrial ecosystems.
Although scientific and economic data are not available to allow quantification of the effect of
ozone in these categories, the expectation is that, if quantified, each of these categories would
lead to an increase in the monetized benefits presented in this RIA. For example, the National
Acid Precipitation Assessment Program (NAPAP) reports that user values for visibility changes at
recreation sites in the east and west are in the range of $ 1 -$ 10 per visitor per day. Similarly,
estimates of the economic effects of acidic deposition damages on recreational fishing in the
Adirondack region of New York ranging from $1 million to $13 million annually.
In this list of unqualified benefits, one category of disbenefits must also be mentioned.
Some commentors have suggested that a reduction of ozone to meet health and welfare-based
standards might serve to increase the penetration of ultraviolet light, specifically UV-B, to ground
level. This effect would be a disbenefit to the extent any such increase would increase skin cancer
and other effects associated with increased penetration of UV-B. EPA conducted an analysis and
review of the extent to which the kinds of ozone reductions anticipated for the difference between
the current 1-hour and possible 9-hour standards might produce such an effect. The review
concluded "(1) the numbers resulting from these calculations are quite small and (2) the
limitations of the accuracy and reliability of the input to the calculations produces numbers that
cannot be defended, whether large or small." (Childs, 1994). Accordingly, no attempt to quantify
this potential effect, which is expected to be small, has been made in this analysis.
IX-38
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IX(E) REFERENCES
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U.S. EPA, July.
Abt., Associates Inc. (1995b). Urban Ornamental Plants: Sensitivity to Ozone and Potential
Economic Losses. Report to U.S. EPA, July.
Chestnut, Lauraine. (1995). "Human Health Benefits from Sulfate Reductions Under Title IV of
the 1990 Clean Air Act Amendments." Hagler Bailly Consulting for U.S. EPA, Office of Air and
Radiation, Office of Atmospheric Programs. November 1995.
Childs, N. (1994). Relationship of Reductions in Tropospheric Ozone to UV-B Penetration to
Earth's Surface. EPA memo to Lester Grant. Research Triangle Park, NC.
Economics for the Environment Consultancy (1996). Research Into Damage Valuation Estimates
for Nitrogen Based Pollutants, Heavy Metals and Persistent Organic Pollutants. 16 Percy Street,
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Freeman, M. (1993). The measurement of Environmental and Resource Values. Resources for
the Future. Washington D C.
Herstrom, A., W. Hogsett, D. Tinget, E. Lee, and D. Phillips (1995). Using a Geographical
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Madariaga, B. (1988). Ambient Air Quality Standards for U.S. Agriculture: The Correct Welfare
Measure Revisited. Journal of Environmental Management, 24,139-146.
Mathtech, Inc. (1994). The Regional Model Farm (RMF): An Agricultural Sector Benefits
Assessment Model, Version 3.0 for Personal Computers. Report to U.S. EPA, September.
Mathtech, Inc. (1995a). Addendum to the Regional Model Farm (RMF) User's Guide, Version
3.0 for Personal Computers. Report to U.S. EPA, June.
Mathtech, Inc. (1995b). Forestry Sector Benefits. Report to U.S. EPA,
September.
Mathtech, Inc. (1996a). Technical Support Document for Ozone NAAQS
Analysis: Air Quality, Vol. I. November 23, 1996.
Mathtech, Inc. (1996b). Technical Support Document for Ozone NAAQS Analysis: Benefit
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Mathtech, Inc. (1996c). Technical Support Document for Ozone NAAQS Analysis: Results,
Vol. Ill, November 23, 1996.
Samet, J.; Zeger, S.; Kelsall, J; Xu, J. Air Pollution and Mortality in Philadelphia, 1974-1988.
Report to the Health Effects Institute on Phase IB: Particle Epidemiology Evaluation Project.
Baltimore, Maryland.
U.S. Environmental Protection Agency. (1996a). Air quality criteria for ozone and related
photochemical oxidants. Research Triangle Park, NC: Office of Health and Environmental
Assessment, Environmental Criteria and Assessment Office; EPA report nos. EPA/600/P-
93/004aF-cF.
U.S. Environmental Protection Agency. (1996b). Review of National Ambient Air Quality
Standards for Ozone Assessment of Scientific and Technical Information. OAQPS Staff Paper.
Research Triangle Park, NC: Office of Air Quality Planning and Standards; EPA report no.EPA-
452/R-96-007.
U.S. Environmental Protection Agency. (May 1996). The Benefits and Costs of the Clean Air
Act, 1970 to 1990. Draft Report for the U.S. Congress. Washington D.C.
U.S. Environmental Protection Agency. ( April 1996). Air Quality Criteria for Particulate Matter.
Volumes I-HI. Office of Research and Development. EPA/600/P-95/001aF. Washington D.C.
Dynamac International, Inc., E. H. Lee. (March 18, 1996) Methodology for Calculating Inputs for
Ozone Secondary Standard Benefits Analysis: Part H
EX-40
-------
X BENEFIT-COST COMPARISON
X(A) INTRODUCTION
This chapter provides a discussion of the economic efficiency framework for evaluating
alternative ozone NAAQS. The adoption and implementation of pollution control technologies to
improve ozone air quality are not free. There is a reallocation of society's resources to address
the ozone air pollution problem. In the course of internalizing the air pollution externality, the
cost of reducing VOC and NOx emissions through this NAAQS is reflected in the production,
distribution, and consumption of products affected by the rulemaking. This additional cost is in
contrast to the improvement in society's well-being from a cleaner environment and concomitant
reductions in adverse health and welfare effects. The purpose of this chapter is to compare the
identified marginal costs and monetized marginal benefits attributable to the emission reductions
and resulting ozone air quality. This comparison provides information regarding the relative
efficiency of the proposed ozone NAAQS.
However, the reader should be reminded that both the Agency and the courts have defined
the NAAQS standard setting process as a fundamentally health-based decision that specifically is
not to be based on cost or other economic considerations. This benefit-cost comparison,
therefore, is intended to generally inform the public about the potential costs and benefits that may
result when the proposed revisions to the ozone NAAQS are implemented by the States.
X(B) COMPARISON OF BENEFITS TO COSTS
Table X-l shows the national monetized benefits (with full attainment and adjustment for
residual nonattainment), costs, net benefits (monetized benefits minus costs), and level of residual
nonattainment (by number of nonattainment areas) for each ozone NAAQS alternative, given the
regional control strategies baseline. The annual benefits presented in this table represent total
monetized benefits for health and welfare effects. The total annual costs represent the costs of
attaining each alternative NAAQS, not accounting for residual nonattainment. The appropriate
benefit and cost estimates to compare are the monetized benefits of the partial attainment scenario
compared to the annual costs. Table X-2 shows national monetized benefits, costs, net benefits,
and level of residual nonattainment for the alternative NAAQS, given the local control strategies
baseline.
X(C) KEY RESULTS AND CONCLUSIONS
• The inability to monetize a number of significant benefit categories may constitute
sufficient reason to believe that the net benefits associated with the proposed NAAQS are
positive.
• Within the uncertainties of these analyses and their underlying assumptions, costs and
benefits seem to be of similar magnitude for the partial attainment of the alternatives which
-------
bound the proposed approach.
• The scope of this analysis did not allow for an in-depth examination of the
interrelationship between ozone and PM. The implementation portion of this NAAQS
review will also address co-control measures and the cross-pollutant effects of ozone and
PM management. Due to these non-quantified interrelationships, the costs presented in
this RIA may overstate the control measure costs. To this extent, the net benefits
presented in this RIA will be underestimates.
• The scope of this analysis did not allow consideration of flexibility in ozone management.
The Agency expects the implementation portion of this ozone NAAQS review to result in
lower costs. This is another major reason why the cost estimates presented may overstate
the costs of control and the net benefit estimates presented may understate actual net
benefits.
X(D) GENERAL LIMITATIONS ON THE BENEFIT-COST COMPARISON
There are several general limitations specific to the comparison of benefits and costs for
these ozone NAAQS alternatives. They are:
• Many benefits from ozone control could not be monetized in the benefit analysis, which in
turn affect the benefit-cost comparison. Unmonetized benefit categories include: effects in
lung function; chronic respiratory damage and premature aging of the lungs, sinusitis and
hay fever; increased susceptibility to respiratory infection; and protection of Class I areas,
forests, ornamental plants, mature trees and seedlings, and ecosystems. The effect of our
inability to monetize these benefit categories leads to an underestimation of the monetized
benefits presented in this RIA.
• Health benefits calculated in this analysis were estimated only within each identified
nonattainment area. However, the reduction of ozone precursor emissions in
nonattainment areas is expected to reduce ambient ozone concentrations outside of the
nonattainment areas due to the transport of air pollution. The effect of not estimating
health benefits outside of the identified nonattainment areas leads to an underestimation of
the monetized benefits presented in this analysis.,
• The uncertainty associated with the benefit estimates may be significantly greater than the
uncertainty associated with the costs estimates. In particular, the benefit estimates vary
greatly depending on the mortality risk reduction measure. This issue leads to caution in
interpreting this ozone benefit-cost comparison.
• There are uncertainties in the adjustment of the benefit calculations to account for residual
nonattainment (labeled as partial attainment).
X-2
-------
Due to uncertainties associated with the air quality model (which results in an
overestimation of the emission reduction targets), an assumption was made that if an area
could achieve at least 75% of its emission reduction target, it was assumed to potentially
be able to attain the alternative standard. (See the cost chapter for a more complete
discussion of this assumption.)
Under the current implementation strategy, marginal nonattainment areas generally
undertake non-control pollution management efforts (e.g., develop an emissions inventory
and keep it updated). This analysis assumes that these efforts indirectly produce air
quality improvements. To the extent that there are control costs associated with marginal
nonattainment areas, this analysis may underestimate the costs which these areas will
actually incur.
Comparisons across alternative standards should be made with caution because control
strategies identified do not result in full attainment of the alternatives. As the stringency
of the standard increases, areas showing residual nonattainment will have a more difficult
time to meet a more stringent standard and the cost of this increasing difficulty is not
included in these estimates.
The costs presented in this analysis represent the control costs of a partial attainment
scenario, given the existence of residual nonattainment. Due to significant uncertainties,
this analysis does not estimate full-attainment costs. However, the cost chapter provides
information on average cost per ton values in conjunction with emission reduction
information for the reader's consideration.
The cost and benefit estimates presented in the results do not account for market reactions
to the new alternatives. The cost and benefit estimates represent the direct costs and
benefits but no the true social costs (calculated after market adjustments to price and
output changes, etc.) associated with implementation of the alternatives examined. Social
costs are typically somewhat smaller than direct costs, while social benefits may be greater
or less than direct benefits depending on the specific market adjustments and substitutions
that occur. Because the effect of market reactions was not assessed, indirect costs and
benefits to consumers and producers could not be quantified. It is anticipated that some of
the costs associated with control measures will be borne indirectly by consumers instead of
producers.
-------
Table X-1
Comparison of Benefits and Costs1
Regional Control Strategies Baseline2
(Billions of 1990$)
Alternative
Ozone NAAQS
Annual Monetized
Benefits
Annual
Costs' of
Partial
Attain-
ment
(c)
Annual Net
Benefits4
(b-c)
Number of
Nonattainment
Areas
Residual Nonattainment (RNA)
Full
Attainment
(a)
Partial
Attainment
(b)
Number
of RNA
Areas
Deficit Tons
Associated with
RNA Areas
(in thousands)
Population in
RNA Areas
Current
Standard6
$0.2 - $2.7
$0.1 - $0.8
$1.2
$(1.1)-
$(0.4)
20
4
VOC =370-562
NOx=0
39 million
Incremental from the Current Standard:
80 ppb, 8 hour,
4 AX
$0.1 -$1.4
$0 - $0.6
$0.6
$(0.4) - $0
17
8
VOC=102-155
NOx= 17-25
14 million
80 ppb, 8 hour,
1 AX
$0.2 - $2.8
$0.1 -$1.5
$2.5
$(2.4) -
$(1.0)
55
20
VOC=422-642
NOx=73-111
32 million
1 Numbers may not completely agree due to rounding.
2 Includes NOx cap and 49-state LEV.
2 The costs of residual nonattainment has not been estimated. However, the reader should refer to the cost chapter for a discussion of average cost
per ton values that may be used to estimate the costs associated with residual nonattainment.
3 Numbers in () denote negative values.
4 The current standard is assumed to be approximately equal to an 8-hr., .09 ppm, 2AX alternative.
Caveats:
Significant analytical uncertainties
Limited to existing implementation, basically add-on control measures
Many nonquantified costs and benefits
Does not consider ozone and PM integration issues
X- 4
-------
Table X-2
Comparison of Benefits and Costs1
Local Control Strategies Baseline2
(Billions of 1990$)
Alternative
Ozone NAAQS
Annual Monetized
Benefits
Annual
Costs1 of
Partial
Attain-
ment
(c)
Annual Net
Benefits4
-------
APPENDIX A
N ON ATTAINMENT AREA COUNTIES AND TARGET REDUCTIONS
UNDER EACH ALTERNATIVE NAAQS
-------
TABLE A-l
MODELED NONATTAINMENT AREA COUNTIES
FOR THE CURRENT STANDARD
UNDER THE REGIONAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Atlantic City
Atlantic
Houston
Waller
New York
Richmond
Atlantic City
Cape May
Los Angeles
Los Angeles
New York
Rockland
Bakersfield
Kern
Los Angeles
Orange
New York
Somerset
Baton Rouse
Ascension
Los Angeles
Riverside
New York
Suffolk
Baton Rouge
East Baton
Rouge
Los Angeles
San Bernardino
New York
Sussex
Baton Rouge
Livingston
Los Angeles
Ventura
New York
Union
Baton Rouge
W. Baton Rouge
New Haven
New Haven
New York
Westchester
Beaumont
Hardin
New London
New London
Phoenix
Maricopa
Beaumont
Jefferson
New London
Washington
Portland, ME
Cumberland
Beaumont
Orange
New London
Windham
Portland, ME
York
Bridgeport
Fairfield
New York
Bergen
Portland, OR
Clackamas
Cincinnati
Boone
New York
Bronx
Portland, OR
Clark
Cincinnati
Butler
New York
Essex
Portland, OR
Multnomah
Cincinnati
Campbell
New York
Hudson
Portland, OR
Washington
Cincinnati
Clermont
New York
Hunterdon
Portland, OR
Yamhill
Cincinnati
Dearborn
New York
Kings
Reno
Washoe
Cincinnati
Hamilton
New York
Middlesex
Sacramento
El Dorado
Cincinnati
Kenton
New York
Monmouth
Sacramento
Placer
Cincinnati
Warren
New York
Morris
Sacramento
Sacramento
Fresno
Fresno
New York
Nassau
Sacramento
Yolo
Houston
Brazoria
New York
New York
Salem, OR
linn
Houston
Fort Bend
New York
Ocean
Salem, OR
Marion
Houston
Galveston
New York
Orange
Salem, OR
Polk
Houston
Harris
New York
Passaic
San Diego
San Diego
Houston
Liberty
New York
Putnam
Santa Barbara
Santa Barbara
Houston
Montgomery
New York
Oueens
Visalia
Tulare
A-l
-------
TABLE A-2
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H5EX-80 STANDARD
UNDER THE REGIONAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Atlanta, GA
Barrow
Hartford
Hartford
Philadelphia
Burlington
Atlanta, GA
Butts
Hartford
Litchfield
Philadelphia
Camden
Atlanta, GA
Cherokee
Hartford
Middlesex
Philadelphia
Cecil
Atlanta, GA
Clayton
Hartford
Tolland
Philadelphia
Chester
Atlanta, GA
Cobb
Houston
Brazoria
Philadelphia
Cumberland
Atlanta, GA
Coweta
Houston
Fort Bend
Philadelphia
Delaware
Atlanta, GA
DeKalb
Houston
Galveston
Philadelphia
Gloucester
Atlanta, GA
Douglas
Houston
Harris
Philadelphia
Mercer
Atlanta, GA
Fayette
Houston
Liberty
Philadelphia
Montgomery
Atlanta, GA
Forsyth
Houston
Montgomery
Philadelphia
New Castle
Atlanta, GA
Fulton
Houston
Waller
Philadelphia
Philadelphia
Atlanta, GA
Gwinnett
Los Angeles
Los Angeles
Philadelphia
Salem
Atlanta, GA
Henry
Los Angeles
Orange
Phoenix
Maricopa
Atlanta, GA
Morgan
Los Angeles
Riverside
Portland, ME
Cumberland
Atlanta, GA
Newton
Los Angeles
San Bernardino
Portland, ME
York
Atlanta, GA
Paulding
Los Angeles
Ventura
Portland, OR
Clackamas
Atlanta, GA
Putnam
Mariposa, CA
Mariposa
Portland, OR
Clark
Atlanta, GA
Rockdale
Modesto
Stanislaus
Portland, OR
Multnomah
Atlanta, GA
Spalding
Muskegon
Muskegon
Portland, OR
Washington
Atlanta, GA
Walton
Nashville
Cheatham
Portland, OR
Yamhill
Atlantic City
Atlantic
Nashville
Davidson
Providence
Bristol
Atlantic City
Cape May
Nashville
Dickson
Providence
Kent
Bakersfield
Kem
Nashville
Robertson
Providence
Newport
Baltimore
Anne Arundel
Nashville
Rutherford
Providence
Providence
Baltimore
Baltimore
Nashville
Sumner
Redding, CA
Shasta
Baltimore
Baltimore
Nashville
Williamson
Redding, CA
Tehama
Baltimore
Carroll
Nashville
Wilson
Sacramento
El Dorado
Baltimore
Harford
New Haven
New Haven
Sacramento
Placer
Baltimore
Howard
New London
New London
Sacramento
Sacramento
Baltimore
Queen Annes
New London
Washington
Sacramento
Yolo
Baton Rouge, LA
Ascension
New London
Windham
Salem, OR
Linn
Baton Rouge, LA
East Baton
Rouge
New York
Bergen
Salem, OR
Marion
Baton Rouge, LA
Iberville
New York
Bronx
Salem, OR
Polk
Baton Rouge, LA
Livingston
New York
Essex
San Diego
San Diego
Baton Rouge, LA
W. Baton Rouge
New York
Hudson
Santa Barbara
Santa Barbara
Bridgeport
Fairfield
New York
Hunterdon
Springfield, MA
Hampden
Cincinnati
Boone
New York
Kings
Springfield, MA
Hampshire
Cincinnati
Butler
New York
Middlesex
Visalia
Tulare
Cincinnati
Campbell
New York
Monmouth
Washington, DC
Alexandria
Cincinnati
Clermont
New York
Morris
Washington, DC
Arlington
Cincinnati
Dearborn
New York
Nassau
Washington, DC
Calvert
Cincinnati
Hamilton
New York
New York
Washington, DC
Charles
Cincinnati
Kenton
New York
Ocean
Washington, DC
Fairfax
Cincinnati
Warren
New York
Orange
Washington, DC
Fairfax
Dallas
Collin
New York
Passaic
Washington, DC
Falls Church
Dallas
Dallas
New York
Putnam
Washington, DC
Frederick
Dallas
Denton
New York
Oueens
Washington, DC
Loudoun
A-2
-------
Dallas
Ellis INew York
Richmond (Washington, DC
Manassas
Dallas
Johnson (New York
Rockland
Washington, DC
Manassas Park
Dallas
Kaufman [New York
Somerset
Washington. DC
Montgomery
Dallas
Parker [New York
Suffolk
Washington, DC
Prince George's
Dallas
Rockwall INew York
Sussex
Washington, DC
Prince William
Dallas
Tarrant (New York
Union
Washington, DC
Stafford
Fresno
Fresno
New York
Westchester
Washington, DC
Washington
Hancock, KY
Hancock
Philadelphia
Bucks
A-3
-------
TABLE A-3
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H4AX-80 STANDARD
UNDER THE REGIONAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Allegan, MI
Allegan
Dallas
Parker
New York
Richmond
Atlanta, GA
Barrow
Dallas
Rockwall
New York
Rockland
Atlanta, GA
Butts
Dallas
Tarrant
New York
Somerset
Atlanta, GA
Cherokee
Fresno
Fresno
New York
Suffolk
Atlanta, GA
Clayton
Hancock, KY
Hancock
New York
Sussex
Atlanta, GA
Cobb
Hartford
Hartford
New York
Union
Atlanta, GA
Coweta
Hartford
Litchfield
New York
Westchester
Atlanta, GA
DeKalb
Hartford
Middlesex
Philadelphia
Bucks
Atlanta, GA
Douglas
Hartford
Tolland
Philadelphia
Burlington
Atlanta, GA
Fayette
Houston
Brazoria
Philadelphia
Camden
Atlanta, GA
Forsyth
Houston
Fort Bend
Philadelphia
Cecil
Atlanta, GA
Fulton
Houston
Galveston
Philadelphia
Chester
Atlanta, GA
Gwinnett
Houston
Harris
Philadelphia
Cumberland
Atlanta, GA
Henry
Houston
Liberty
Philadelphia
Delaware
Atlanta, GA
Morgan
Houston
Montgomery
Philadelphia
Gloucester
Atlanta, GA
Newton
Houston
Waller
Philadelphia
Mercer
Atlanta, GA
Paulding
Huntington
Boyd
Philadelphia
Montgomery
Atlanta, GA
Putnam
Huntington
Cabell
Philadelphia
New Castle
Atlanta, GA
Rockdale
Huntington
Carter
Philadelphia
Philadelphia
Atlanta, GA
Spalding
Huntington
Greenup
Philadelphia
Salem
Atlanta, GA
Walton
Huntington
Lawrence
Phoenix
Maricopa
Atlantic City
Atlantic
Huntington
Wayne
Portland, ME
Cumberland
Atlantic City
Cape May
Knox, ME
Knox
Portland, ME
York
Bakersfield
Kern
Knoxville
Anderson
Portland, OR
Clackamas
Baltimore
Anne Arundel
Knoxville
Blount
Portland, OR
Clark
Baltimore
Baltimore
Knoxville
Grainger
Portland, OR
Multnomah
Baltimore
Baltimore
Knoxville
Jefferson
Portland, OR
Washington
Baltimore
Carroll
Knoxville
Knox
Portland, OR
Yamhill
Baltimore
Harford
Knoxville
Sevier
Providence
Bristol
Baltimore
Howard
Knoxville
Union
Providence
Kent
Baltimore
Oueen Annes
Los Angeles
Los Angeles
Providence
Newport
Baton Rouse
Ascension
Los Angeles
Orange
Providence
Providence
Baton Rouge
East Baton
Rouge
Los Angeles
Riverside
Redding, CA
Shasta
Baton Rouse
Iberville
Los Angeles
San Bernardino
Redding, CA
Tehama
Baton Rouse
Livingston
Los Angeles
Ventura
Sacramento
El Dorado
Baton Rouse
W. Baton Rouge
Mariposa, CA
Mariposa
Sacramento
Placer
Beaumont
Hardin
Modesto
Stanislaus
Sacramento
Sacramento
Beaumont
Jefferson
Muskegon
Muskegon
Sacramento
Yolo
Beaumont
Orange
Nashville
Cheatham
Salem, OR
Linn
Bridgeport
Fairfield
Nashville
Davidson
Salem, OR
Marion
Chicago
Cook
Nashville
Dickson
Salem, OR
Polk
Chicago
Du Page
Nashville
Robertson
San Diego
San Diego
Chicago
Grundy
Nashville
Rutherford
Santa Barbara
Santa Barbara
Chicago
Jasper
Nashville
Sumner
Seattle
Kins
Chicago
Kane
Nashville
Williamson
Seattle
Pierce
Chicago
Kendall
Nashville
Wilson
Seattle
Snohomish
Chicago
Kenosha
New Haven
New Haven
Springfield, MA
Hampden
A-4
-------
Chicago
Lake
New London
New London
Springfield. MA
Hampshire
Chicago
Lake
New London
Washington
VUalia
Tulare
Chicago
McHenry
Mew London
Windham
Washington, DC
Alexandria
Chicago
Porter
New York
Bergen
Washington, DC
Arlington
Chicago
Will
New York
Bronx
Washington, DC
Calvert
Cincinnati
Boone
New York
Essex
Washington, DC
Charles
Cincinnati
Butler
New York
Hudson
Washington, DC
Fairfax
Cincinnati
Campbell
New York
Hunterdon
Washington, DC
Fairfax
Cincinnati
Clermont
New York
Kings
Washington, DC
Falls Church
Cincinnati
Dearborn
New York
Middlesex
Washington, DC
Frederick
Cincinnati
Hamilton
New York
Monmouth
Washington, DC
Loudoun
Cincinnati
Kenton
New York
Morris
Washington, DC
Manassas
Cincinnati
Warren
New York
Nassau
Washington, DC
Manassas Park
Dallas
Collin
New York
New York
Washington, DC
Montgomery
Dallas
Dallas
New York
Ocean
Washington, DC
1
Prince George's
Dallas
Denton
New York
Orange
Washington, DC
Prince William
Dallas
Ellis
New York
Passaic
Washington, DC
Stafford
Dallas
Johnson
New York
Putnam
Washington, DC
Washington
Dallas
Kaufman
New York
Queens
A-5
-------
TABLE A-4
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H1AX-80 STANDARD
UNDER THE REGIONAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Allentown
Carbon
Detroit
Livingston
New York
Rockland
Allentown
Lehigh
Detroit
Macomb
New York
Somerset
Allentown
Northampton
Detroit
Monroe
New York
Suffolk
Allentown
Warren
Detroit
Oakland
New York
Sussex
Athens. GA
Clarice
Detroit
St. Clair
New York
Union
Athens, GA
Greene
Detroit
Washtenaw
New York
Westchester
Athens, GA
Jackson
Detroit
Wayne
Philadelphia
Bucks
Athens, GA
Madison
Douglas, WA
Douglas
Philadelphia
Burlington
Athens, GA
Oconee
Eugene, OR
Douglas
Philadelphia
Camden
Atlanta, GA
Baldwin
Eugene, OR
Lane
Philadelphia
Cecil
Atlanta, GA
Barrow
Fresno
Fresno
Philadelphia
Chester
Atlanta, GA
Bartow
Fresno
Kings
Philadelphia
Cumberland
Atlanta, GA
Bleckley
Fresno
Madera
Philadelphia
Delaware
Atlanta, GA
Butts
Fresno
Mariposa
Philadelphia
Gloucester
Atlanta, GA
Cherokee
Fresno
San Benito
Philadelphia
Mercer
Atlanta, GA
Clayton
Grand Rapids,
Allegan
Philadelphia
Montgomery
Atlanta, GA
Cobb
Grand Rapids,
Kent
Philadelphia
New Castle
Atlanta, GA
Coweta
Grand Rapids,
Ottawa
Philadelphia
Philadelphia
Atlanta, GA
DeKalb
Greensboro
Davidson
Philadelphia
Salem
Atlanta, GA
Douglas
Greensboro
Davie
Phoenix
Maricopa
Atlanta, GA
Fayette
Greensboro
Forsyth
Pittsburgh
Allegheny
Atlanta, GA
Forsyth
Greensboro
Guilford
Pittsburgh
Beaver
Atlanta, GA
Fulton
Greensboro
Randolph
Pittsburgh
Fayette
Atlanta, GA
Gwinnett
Greensboro
Stokes
Pittsburgh
Washington
Atlanta, GA
Henry
Greensboro
Yadkin
Pittsburgh
Westmoreland
Atlanta, GA
Laurens
Hancock. ME
Hancock
Portland, ME
Cumberland
Atlanta, GA
Morgan
Harrisburg
Cumberland
Portland, ME
York
Atlanta, GA
Newton
Harrisburg
Dauphin
Portland, OR
Clackamas
Atlanta, GA
Paulding
Harrisburg
Franklin
Portland. OR
Clark
Atlanta, GA
Putnam
Harrisburg
Lebanon
Portland, OR
Multnomah
Atlanta, GA
Rockdale
Harrisbure
Perry
Portland, OR
Washington
Atlanta, GA
Spalding
Hartford
Hartford
Portland, OR
Yamhill
Atlanta, GA
Walton
Hartford
Litchfield
Providence
Bristol
Atlanta, GA
Wilkinson
Hartford
Middlesex
Providence
Kent
Atlanta, GA
Atlantic
Hartford
Tolland
Providence
Newport
Atlanta, GA
Cape May
Hopkins, TX
Hopkins
Providence
Providence
Austin, TX
Hays
Houston
Austin
Raleigh-Durham
Durham
Austin, TX
Travis
Houston
Brazoria
Raleigh-Durham
Franklin
Austin, TX
Williamson
Houston
Foit Bend
Raleigh-Durham
Orange
Bakers field, CA
Kern
Houston
Galveston
Raleigh-Durham
Wake
Baltimore
Anne Arundel
Houston
Harris
Reading, PA
Berks
Baltimore
Baltimore
Houston
liberty
Redding, CA
Shasta
Baltimore
Baltimore
Houston
Montgomery
Redding, CA
Tehama
Baltimore
Caroline
Houston
Walker
Reno
Washoe
Baltimore
Carroll
Houston
Waller
Richmond
Charles City
Baltimore
Harford
Houston
Wharton
Richmond
Chesterfield
Baltimore
Howard
Huntington
Boyd
Richmond
Colonial Heights
A-6
-------
Baltimore
Kent
Huntington
Cabell
Richmond
Dinwiddie
Baltimore
Queen Annes
Huntington
Carter
Richmond
Goochland
Baltimore
Sussex
Huntington
Greenup
Richmond
Haaover
Baltimore
Talbot
Huntington
Lawrence
Richmond
Henrico
Baltimore
Wicomico
Huntington
Wavne
Richmond
Hopewell
Barnwell, SC
Barnwell
Indianapolis
Boone
Richmond
New Kent
Baton Rouse, LA
Ascension
Indianapolis
Hamilton
Richmond
Petersburg
Baton Rouge, LA
Bast Baton
Rouge
Indianapolis
Hancock
Richmond
Powhatan
Baton Rouse, LA
Iberville
Indianapolis
Hendricks
Richmond
Prince George
Baton Rouee, LA
Livingston
Indianapolis
Johnson
Richmond
Richmond
Baton Rouee. LA
W. Baton Rouge
Indianapolis
Marion
Rochester, NY
Livingston
Beaumont, TX
Hardin
Indianapolis
Morgan
Rochester, NY
Monroe
Beaumont, TX
Jefferson
Indianapolis
Shelbv
Rochester, NY
Ontario
Beaumont, TX
Orange
lohnson City
Bristol
Rochester, NY
Orleans
Birmingham, AL
Blount
lohnson City
Carter
Rochester, NY
Wayne
Birmingham, AL
Jefferson
lohnson City
Hawkins
Sacramento
El Dorado
Birmingham. AL
Shelbv
lohnson City
Scon
Sacramento
Nevada
Birmingham, AL
St. Clair
lohnson City
Sullivan
Sacramento
Placer
Birmingham, AL
Walker
lohnson City
Unicoi
Sacramento
Sacramento
Boston, MA
Barnstable
lohnson City
Washington
Sacramento
Yolo
Boston, MA
Middlesex
lohnson City
Washington
Salem, OR
Benton
Boston, MA
Norfolk
Knox, ME
Knox
Salem, OR
Jefferson
Boston, MA
Plymouth
Knoxville
Anderson
Salem, OR
Lincoln
Boston, MA
Suffolk
Knoxville
Blount
Salem, OR
Linn
Bridgeport
Fairfield
Knoxville
Campbell
Salem, OR
Marion
Charlotte
Cabarrus
Knoxville
Grainger
Salem, OR
Polk
Charlotte
Gaston
Knoxville
Jefferson
San Diego
San Diego
Charlotte
Lincoln
Knoxville
Knox
San Francisco
Alameda
Charlotte
Mecklenburg
Knoxville
Sevier
San Francisco
Contra Costa
Charlotte
Rowan
Knoxville
Union
San Francisco
Marin
Charlotte
Union
Los Angeles
Los Angeles
San Francisco
Napa
Charlotte
York
Los Angeles
Orange
San Francisco
San Francisco
Chattanooga, TN
Catoosa
Los Angeles
Riverside
San Francisco
San Mateo
Chattanooga, TN
Dade
Los Angeles
San Bernardino
San Francisco
Santa Clara
Chattanooga. TN
DeKalb
Los Angeles
Ventura
San Francisco
Santa Cruz
Chattanooga. TN
Hamilton
Louisville
Bullitt
San Francisco
Solano
Chattanooga, TN
Marion
Louisville
Clark
San Francisco
Sonoma
Chattanooga, TN
Sequatchie
Louisville
Flovd
Santa Barbara
Santa Barbara
Chattanooga. TN
Walker
Louisville
Harrison
Seattle
King
Chattanooga, TN
Whitfield
Louisville
Jefferson
Seattle
Lewis
Chicago, IL
Cook
Louisville
Oldham
Seattle
Pierce
Chicago, IL
Du Page
Louisville
Shelbv
Seattle
Snohomish
Chicago, IL
Grundy
Manitowoc, WI
Door
Shreveport, LA
Bossier
Chicago, IL
Jasper
Manitowoc, WI
Kewaunee
Shrevepoit, LA
Caddo
Chicago, IL
Kane
Manitowoc, WI
Manitowoc
Springfield, MA
Hampden
Chicago. IL
Kendall
Marshall. OK
Marshall
Springfield, MA
Hampshire
Chicago, IL
Kenosha
Memphis
Crittenden
St. Louis
Bond
Chicago, IL
Lake
Memphis
DeSoto
St. Louis
Clinton
Chicago, IL
Lake
Memphis
Shelbv
St. Louis
Franklin
Chicago, IL
McHenrv
Memphis
Tipton
St. Louis
Jefferson
Chicago, IL
Porter
Milwaukee
Milwaukee
St. Louis
Jersey
Chicago, IL
Will
Milwaukee
Ozaukee
St. Louis
Madison
Cincinnati, OH
Boone
Milwaukee
Racine
St. Louis
Monroe
Cincinnati. OH
Butler
Milwaukee
Washington
St. Louis
St. Charles
A-7
-------
Cincinnati, OH
Campbell
Milwaukee
Waukesha
St. Louis
St. Clair
Cincinnati, OH
Clermont
Modesto
Stanislaus
St. Louis
St. Louis
Cincinnati, OH
Clinton
Modesto
Tuolumne
St. Louis
St. Louis
Cincinnati, OH
Dearborn
Muskegon
Muskegon
State College, PA
Centre
Cincinnati, OH
Hamilton
Nashville
Cheatham
Stockton, CA
San Joaquin
Cincinnati, OH
Kenton
Nashville
Davidson
relt City
Hancock
Cincinnati, OH
Warren
Nashville
Dickson
rell City
Perrv
Cleveland, OH
Cuyahoga
Nashville
Robertson
Tell City
Spencer
Cleveland, OH
Geauga
Nashville
Rutherford
Tulsa, OK
Creek
Cleveland, OH
Lake
Nashville
Sumner
Tulsa, OK
Osage
Cleveland, OH
Lorain
Nashville
Williamson
Tulsa, OK
Rogers
Cleveland, OH
Medina
Nashville
Wilson
Tulsa, OK
Tulsa
Cleveland, OH
Portage
New Bedford
Bristol
Tulsa, OK
Wagoner
Cleveland, OH
Summit
New Haven
New Haven
Tulsa, OK
Washington
Columbia, SC
Lexington
New London
New London
Visalia
Tulare
Columbia, SC
Richland
New London
Washington
Washington, DC
Alexandria
Columbus, OH
Delaware
New London
Windham
Washington, DC
Arlington
Columbus, OH
Fairfield
New Orleans
Jefferson
Washington, DC
Calvert
Columbus, OH
Fayette
New Orleans
Orleans
Washington, DC
Charles
Columbus, OH
Franklin
New Orleans
St. Bernard
Washington, DC
Fairfax
Columbus, OH
Licking
New Orleans
St. Charles
Washington, DC
Fairfax
Columbus, OH
Madison
New Orleans
St. John The
Bap.
Washington, DC
FbIIb Church
Columbus, OH
Pickaway
New Orleans
St. Tammany
Washington, DC
Frederick
Columbus, OH
Union
New York
Bergen
Washington, DC
King George
Dallas
Collin
New York
Bronx
Washington, DC
Loudoun
Dallas
Dallas
New York
Essex
Washington, DC
Manassas
Dallas
Denton
New York
Hudson
Washington, DC
Manassas Park
Dallas
Ellis
New York
Hunterdon
Washington, DC
Montgomery
Dallas
Johnson
New York
Kings
Washington, DC
Prince George's
Dallas
Kaufman
New York
Middlesex
Washington, DC
Prince William
Dallas
Montague
New York
Monmouth
Washington, DC
Stafford
Dallas
Parker
New York
Morris
Washington, DC
Washington
Dallas
Rockwall
New York
Nassau
Willis Wharf. VA
Accomack
Dallas
Tarrant
New York
New York
Willis Wharf, VA
Northampton
Dallas
Wise
New York
Ocean
York, PA
Adams
Dayton
Clark
New York
Orange
York, PA
York
Dayton
Greene
New York
Passaic
Yuba City, CA
Sutter
Dayton
Miami
New York
Putnam
Yuba City. CA
Yuba
Davton
Montgomery
New York
Queens
Detroit
Lapeer
New York
Richmond
A-8
-------
TABLE A-5
MODELED NONATTAINMENT AREA COUNTIES
FOR THE CURRENT STANDARD
UNDER THE LOCAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
MONATTA1NMENT
AREA
COUNTY
NAME
Abilene, TX
Callahan
Grand Rapids, Ml
Barry
Orlando, FL
Oranqe
Abilene, TX
Taylor
Grand Rapids, Ml
Newaygo
Orlando. FL
Seminole
Albany. NY
Albany
Grand Rapids, Ml
Manistee
Orlando, FL
Lake
Albany, NY
Saratoga
Green Bay, Wl
Manitowoc
Orlando. FL
Osceola
Albany, NY
Rensselaer
Green Bay, Wl
Door
Owensboro, KY
Daviess
Albany, NY
Schenectady
Green Bay, Wl
Kewaunee
Owensboro, KY
Hancock
Albany, NY
Montgomery
Green Bay, Wl
Brown
Parkers burg, WV
Wood
Albany, NY
Schoharie
Greensboro, NC
Guilford
Parkersburg, WV
Washington
Allentown, PA
Lehigh
Greensboro, NC
Forsyth
Parkersburq, WV
Athens
Allentown, PA
Northampton
Greensboro, NC
Alamance
Parkersburg, WV
Jackson
Allentown, PA
Carbon
Greensboro, NC
Rockingham
Parkersburg, WV
Meigs
Altoona, PA
Blair
Greensboro, NC
Surry
Parkersburg. WV
Morgan
Athens, GA
Clarke
Greensboro, NC
Yadkin
Parkersburg, WV
Noble
Athens, GA
Oconee
Greensboro, NC
Davie
Parkersburg, WV
Gilmer
Athens, GA
Greene
Greensboro, NC
Patrick
Parkersburg, WV
Wirt
Athens, GA
Madison
Greensboro, NC
Davidson
Pensacola, FL
Escambia
Atlanta, GA
Fulton
Greensboro, NC
Randolph
Pensacola, FL
Santa Rosa
Atlanta, GA
De Kalb
Greensboro, NC
Stokes
Philadelphia, PA
Philadelphi
Atlanta. GA
Cobb
Greenville. SC
Greenville
Philadelphia. PA
Montgomery
Atlanta, GA
Gwinnett
Greenville, SC
Spartanburg
Philadelphia, PA
Delaware
Atlanta, GA
Clayton
Greenville. SC
Anderson
Philadelphia, PA
Bucks
Atlanta. GA
Floyd
Greenville. SC
Pickens
Philadelphia. PA
Camden
Atlanta. GA
Douglas
Greenville, SC
Cherokee
Philadelphia, PA
New Castle
Atlanta. GA
Fayette
Hamsburg, PA
Dauphin
Philadelphia, PA
Burlington
Atlanta. GA
Henry
Harrisburg, PA
Cumberland
Philadelphia, PA
Chester
Atlanta, GA
Bartow
Hamsburg, PA
Lebanon
Philadelphia, PA
Gloucester
Atlanta. GA
Spalding
Hamsburg, PA
Perry
Philadelphia. PA
Atlantic
Atlanta, GA
Rockdale
Hartford. CT
Hartford
Philadelphia. PA
Cumberland
Atlanta, GA
Coweta
Hartford. CT
Middlesex
Philadelphia, PA
Cape May
Atlanta. GA
Newton
Hartford. CT
Tolland
Philadelphia. PA
Cecil
Atlanta. GA
Paulding
Hickory. NC
Wilkes
Philadelphia. PA
Salem
Atlanta, GA
Walton
Hickory. NC
Catawba
Phoenix. AZ
Maricopa
Atlanta, GA
Gordon
Hickory. NC
Burke
Phoenix. AZ
Pinal
Atlanta. GA
Polk
Hickory, NC
Caldwell
Pittsburgh, PA
Allegheny
Atlanta, GA
Jackson
Hickory. NC
Alexander
Pittsburgh, PA
Westmorelan
Atlanta, GA
Barrow
Houston, TX
Harris
Pittsburgh, PA
Washington
Atlanta. GA
Meriwether
Houston, TX
Fort Bend
Pittsburgh, PA
Butler
Atlanta. GA
Haralson
Houston, TX
Galveston
Pittsburgh. PA
Fayette
Atlanta, GA
Butts
Houston, TX
Brazoria
Pittsburgh. PA
Armstrong
Atlanta, GA
Gilmer
Houston, TX
Montgomery
Pittsburgh. PA
Clarion
Atlanta. GA
Morgan
Houston, TX
Walker
Pittsburgh. PA
Tucker
Atlanta, GA
Cleburne
Houston, TX
Wharton
Pittsburgh, PA
Forest
Atlanta. GA
Pike
Houston. TX
Matagorda
Pittsburgh. PA
Beaver
Atlanta, GA
Cherokee
Houston, TX
Polk
Pittsfield, MA
Berkshire
Atlanta, GA
Carroll
Houston, TX
Waller
Portland, ME
Cumberland
Atlanta. GA
Forsyth
Houston, TX
Austin
Portland, OR
Clackamas
Atlanta, GA
Pickens
Houston, TX
Trinity
Portland, OR
Marion
Augusta. GA
Aiken
Houston. TX
Liberty
Portland. OR
Linn
A-9
-------
Augusta, GA
Barnwell
Houston. TX
Chambers
Portland, OR
Benton
Augusta, GA
McDuffie
Huntington, WV
Cabell
Portland, OR
Lincoln
Augusta, GA
Washington
Huntington. WV
Scioto
Portland, OR
Jefferson
Augusta, GA
Bamberg
Huntington, WV
Lawrence
Portland, OR
Multnomah
Augusta, GA
Allendale
Huntington, WV
Boyd
Portland, OR
Washington
Augusta, GA
Glascock
Huntington, WV
Greenup
Portland, OR
Clark
Augusta, GA
Taliaferro
Huntington, WV
Gallia
Portland, OR
Yamhill
Auqusta, GA
Richmond
Huntington, WV
Jackson
Portland, OR
Polk
Augusta, GA
Columbia
Huntington, WV
Pike
Portland, OR
Columbia
Augusta, GA
Edgefield
Huntington, WV
Johnson
Providence, Rl
Providence
Austin, TX
Travis
Huntington, WV
Lawrence
Providence, Rl
Kent
Austin, TX
Williamson
Huntington, WV
Martin
Providence, Rl
Washington
Austin, TX
Burnet
Huntington, WV
Wayne
Providence, Rl
Newport
Austin, TX
Hays
Huntington, WV
Carter
Providence, Rl
Bristol
Austin, TX
Bastrop
Indianapolis, IN
Marion
Raleigh, NC
Wake
Austin, TX
Caldwell
Indianapolis, IN
Madison
Raleigh, NC
Durham
Bakersfield, CA
Kern
Indianapolis, IN
Hamilton
Raleigh, NC
Orange
Banqor, ME
Kennebec
Indianapolis, IN
Bartholomew
Raleiqh, NC
Johnston
Bangor, ME
Hancock
Indianapolis, IN
Morgan
Raleigh, NC
Harriett
Banqor, ME
Knox
Indianapolis. IN
Hancock
Raleigh, NC
Granville
Bangor, ME
Waldo
Indianapolis, IN
Decatur
Raleigh, NC
Person
Banqor, ME
Lincoln
Indianapolis, IN
Rush
Raleigh. NC
Chatham
Banqor. ME
Penobscot
Indianapolis, IN
Johnson
Raleigh, NC
Franklin
Barnstable, MA
Barnstable
Indianapolis, IN
Hendricks
Redding, PA
Berks
Barnstable, MA
Nantucket
Indianapolis. IN
Shelby
Redding, CA
Shasta
Baton Rouge, LA
East Baton
Indianapolis, IN
Boone
Redding, CA
Tehama
Baton Rouge, LA
Ascension
Johnson City. TN
Sullivan
Reno. NV
Washoe
Baton Rouge, LA
Iberville
Johnson City, TN
Washington
Richmond, VA
Henrico
Baton Rouge, LA
Pointe Coup
Johnson City. TN
Carter
Richmond. VA
Chesterfiel
Baton Rouge, LA
West Baton
Johnson City, TN
Tazewell
Richmond. VA
Richmond
Baton Rou.qe, LA
East Felici
Johnson City, TN
Washington
Richmond. VA
Petersburg
Baton Rouge, LA
Livingston
Johnson City, TN
Hawkins
Richmond. VA
Prince Geor
Beaumont, TX
Jefferson
Johnson Citv, TN
Smyth
Richmond, VA
Hopewell
Beaumont, TX
Orange
Johnson City, TN
Russell
Richmond, VA
Dinwiddie
Beaumont, TX
Hardin
Johnson City, TN
Scott
Richmond, VA
Prince Edwa
Biloxi, MS
Harrison
Johnson City, TN
Bristol
Richmond, VA
Colonial He
Biloxi, MS
Jackson
Johnson City, TN
Dickenson
Richmond, VA
New Kent
Biloxi. MS
Hancock
Johnson City, TN
Avery
Richmond, VA
Sussex
Birmingham, AL
Jefferson
Johnson City, TN
Mitchell
Richmond. VA
Greensville
Birmingham, AL
Shelby
Johnson City, TN
Unicoi
Richmond, VA
Charles Cit
Birmingham, AL
St. Clair
Johnstown, PA
Cambria
Richmond, VA
Hanover
Birmingham, AL
Blount
Johnstown, PA
Somerset
Richmond, VA
Powhatan
Bloominqton. IN
Monroe
Johnstown, PA
Jefferson
Richmond, VA
Goochland
Bloomington. IN
Lawrence
Joplin, MO
Neosho
Rochester, NY
Monroe
Bloominqton, IN
Martin
Joplin, MO
Jasper
Rochester, NY
Ontario
Boston. MA
Middlesex
Joplin. MO
Newton
Rochester, NY
Wayne
Boston, MA
Norfolk
Knoxville. TN
Knox
Rochester, NY
Genesee
Boston, MA
Bristol
Knoxville. TN
Blount
Rochester. NY
Wyoming
Boston, MA
York
Knoxville, TN
Anderson
Rochester. NY
Orleans
Boston, MA
Worcester
Knoxville, TN
Sevier
Rochester, NY
Yates
Boston, MA
Essex
Knoxville, TN
Campbell
Rochester, NY
Livingston
Boston, MA
Suffolk
Knoxville, TN
Cumberland
Rocky Mount. NC
Edgecombe
Boston, MA
Plymouth
Knoxville, TN
Whitley
Rocky Mount, NC
Northampton
Boston, MA
Hillsboroug
Knoxville, TN
Jefferson
Rocky Mount, NC
Nash
Boston, MA
Rockingham
Knoxville, TN
Bell
Sacramento, CA
Sacramento
Boston. MA
Merrimack
Knoxville. TN
Loudon
Sacramento, CA
Placer
A-10
-------
Boston, MA
Strafford
Knoxville, TN
Claiborne
Sacramento, CA
Nevada
Buffalo. NY
Erie
Knoxville, TN
Scott
Sacramento, CA
Yolo
Buffalo. NY
Niagara
Knoxville. TN
Grainger
Sacramento. CA
El Dorado
Canton, OH
Stark
Knoxville, TN
McCreary
St Louis, MO
St. Louis
Canton, OH
Carroll
Knoxville, TN
Union
St Louis, MO
St. Louis
Champaign, IL
Champaign
Kokomo, IN
Tipton
St Louis, MO
Madison
Charleston, WV
Mason
Kokomo. IN
Howard
St Louis. MO
St. Charles
Charleston, WV
Roane
Lafayette, IN
Tippecanoe
St Louis. MO
Macoupin
Charleston, WV
Kanawha
Lafayette, IN
Clinton
St Louis, MO
Jersey
Charleston, WV
Putnam
Lancaster. PA
Lancaster
St Louis, MO
Greene
Charlotte, NC
Mecklenburg
Lawton, OK
Greer
St Louis, MO
Bond
Charlotte, NC
York
Lawton, OK
Comanche
St Louis, MO
Washington
Charlotte, NC
Rowan
Lewiston, ME
Sagadahoc
St Louis, MO
St. Clair
Charlotte, NC
Cabarrus
Lewiston, ME
Androscoggi
St Louis. MO
Jefferson
Charlotte, NC
Stanly
Lexington, KY
Fayette
St Louis, MO
Franklin
Charlotte, NC
Chester
Lexington, KY
Pulaski
St Louis, MO
Clinton
Charlotte, NC
Gaston
Lexington, KY
Franklin
St Louis, MO
Lincoln
Charlotte, NC
Union
Lexington, KY
Jessamine
St Louis. MO
Monroe
Charlotte, NC
Lincoln
Lexington, KY
Boyle
St Louis, MO
Warren
Chattanooga, TN
Hamilton
Lexington, KY
Lincoln
St Louis, MO
Crawford
Chattanooga, TN
Bradley
Lexington, KY
Woodford
Salinas. CA
San Benito
Chattanooga, TN
Whitfield
Lexington, KY
Mercer
Salinas, CA
Monterey
Chattanooga, TN
Walker
Lexington, KY
Anderson
San Diego, CA
San Diego
Chattanooga, TN
Catoosa
Lexington, KY
Garrard
San Francisco, CA
Alameda
Chattanooga, TN
Murray
Lexington. KY
Madison
San Francisco. CA
Contra Cost
Chattanooga, TN
Chattooga
Lexington, KY
Clark
San Francisco, CA
Santa Clara
Chattanooga, TN
Dade
Lexington, KY
Scott
San Francisco, CA
San Francis
Chattanooga. TN
Marion
Lexington, KY
Bourbon
San Francisco. CA
San Mateo
Chicago, IL
Lake
Lima, OH
Auglaize
San Francisco, CA
Sonoma
Chicago, IL
Porter
Lima, OH
Logan
San Francisco, CA
Solano
Chicago, IL
Kenosha
Lima, OH
Allen
San Francisco. CA
Marin
Chicago, IL
La Porte
Longview, TX
Gregg
San Francisco, CA
Santa Cruz
Chicago, IL
Jasper
Longview, TX
Titus
San Francisco. CA
Napa
Chicago. IL
Cook
Longview, TX
Franklin
Santa Barbara. CA
Santa Barba
Chicago. IL
Du Page
Longview, TX
Harrison
Savannah. GA
Toombs
Chicago, IL
Lake
Longview, TX
Upshur
Savannah, GA
Appling
Chicago, IL
Will
Los Angeles, CA
Los Angeles
Savannah, GA
Jeff Davis
Chicago. IL
Kane
Los Angeles, CA
Orange
Savannah. GA
Chatham
Chicago. IL
McHenry
Los Angeles. CA
San Bernard
Savannah. GA
Effingham
Chicago, IL
Kankakee
Los Angeles, CA
Riverside
Savannah, GA
Bryan
Chicago, IL
DeKalb
Los Angeles, CA
Ventura
Scranton, PA
Luzerne
Chicago. IL
Kendall
Louisville. KY
Clark
Scranton, PA
Schuylkill
Chicago. IL
Grundy
Louisville, KY
Jackson
Scranton, PA
Susquehanna
Cincinnati. OH
Hamilton
Louisville. KY
Olidham
Scranton, PA
Lackawanna
Cincinnati. OH
Butler
Louisville, KY
Meade
Scranton, PA
Columbia
Cincinnati. OH
Clermont
Louisville. KY
Washington
Scranton, PA
Wyoming
Cincinnati, OH
Warren
Louisville, KY
Jennings
Seattle, WA
King
Cincinnati, OH
Campbell
Louisville, KY
Scott
Seattle, WA
Pierce
Cincinnati, OH
Boone
Louisville, KY
Perry
Seattle, WA
Lewis
Cincinnati, OH
Highland
Louisville, KY
Orange
Seattle, WA
Douglas
Cincinnati, OH
Clinton
Louisville, KY
Breckinridg
Seattle, WA
Snohomish
Cincinnati, OH
Ripley
Louisville. KY
Crawford
Seattle, WA
Kitsap
Cincinnati, OH
Franklin
Louisville. KY
Trimble
Seattle. WA
Thurston
Cincinnati, OH
Grant
Louisville. KY
Jefferson
Seattle. WA
Island
Cincinnati, OH
Carroll
Louisville, KY
Floyd
Sharon, PA
Mercer
Cincinnati. OH
Switzerland
Louisville, KY
Bullitt
Sharon. PA
Venango
A-ll
-------
Cincinnati, OH
Union
Louisville. KY
Harrison
Sheboygan. Wl
Sheboygan
Cincinnati, OH
Kenton
Macon, GA
Bibb
Sherman, TX
Grayson
Cincinnati, OH
Dearborn
Macon, GA
Laurens
Sherman, TX
Marshall
Cincinnati, OH
Brown
Macon, GA
Baldwin
Sherman, TX
Johnston
Cincinnati, OH
Pendleton
Macon, GA
Putnam
Sherman, TX
Love
Cincinnati, OH
Gallatin
Macon, GA
Bleckley
Shreveport, LA
Bossier
Cincinnati, OH
Ohio
Macon, GA
Wilkinson
Shreveport, LA
De Soto
Cleveland, OH
Cuyahoga
Macon, GA
Twiggs
Shreveport, LA
Red River
Cleveland, OH
Summit
Macon, GA
Johnson
Shreveport, LA
Caddo
Cleveland, OH
Lake
Macon, GA
Montgomery
Shreveport, LA
Webster
Cleveland, OH
Portage
Macon, GA
Treutlen
Sprinqfield, MA
Hampden
Cleveland, OH
Ashtabula
Macon, GA
Wheeler
Springfield, MA
Hampshire
Cleveland, OH
Crawford
Macon, GA
Houston
Sprinqfield, MA
Franklin
Cleveland, OH
Lorain
Macon, GA
Peach
State Colleqe, PA
Centre
Cleveland, OH
Medina
Macon, GA
Jones
State Colleqe, PA
Clearfield
Cleveland, OH
Geauga
Memphis, TN
Shelby
State College, PA
Elk
Columbia, SC
Richland
Memphis, TN
De Soto
Stockton, CA
San Joaquin
Columbia, SC
Lexington
Memphis, TN
Tipton
Syracuse, NY
Onondaga
Columbia, SC
Fairfield
Memphis, TN
Tate
Syracuse, NY
Cayuqa
Columbia, SC
Calhoun
Memphis, TN
Crittenden
Syracuse, NY
Madison
Columbus, GA
Marion
Memphis, TN
Fayette
Syracuse, NY
Seneca
Columbus, GA
Muscogee
Milwaukee, Wl
Milwaukee
Syracuse, NY
Oswego
Columbus, GA
Russell
Milwaukee, Wl
Waukesha
Tampa, FL
Pinellas
Columbus, GA
Hams
Milwaukee, Wl
Racine
Tampa, FL
Hillsboroug
Columbus, GA
Chattahooch
Milwaukee, Wl
Ozaukee
Tampa, FL
Pasco
Columbus, OH
Franklin
Milwaukee, Wl
Washington
Tampa, FL
Hemando
Columbus, OH
Licking
Mobile, AL
Mobile
TerTe Haute. IN
Vigo
Columbus, OH
Fairfield
Mobile, AL
Baldwin
Terre Haute, IN
Owen
Columbus, OH
Muskingum
Modesto, CA
Stanislaus
Terre Haute, IN
Clay
Columbus, OH
Ross
Muncie, IN
Delaware
Terre Haute, IN
Vermillion
Columbus, OH
Pickaway
Muncie. IN
Blackford
Texarkana, AR
Red River
Columbus, OH
Knox
Nashville, TN
Sumner
Texarkana, AR
Bowie
Columbus, OH
Madison
Nashville. TN
Williamson
Texarkana. AR
Miller
Columbus. OH
Union
Nashville, TN
Wilson
Tulsa, OK
Tulsa
Columbus, OH
Fayette
Nashville. TN
Maury
Tulsa. OK
Roqers
Columbus. OH
Vinton
Nashville. TN
Robertson
Tulsa. OK
Washington
Columbus, OH
Delaware
Nashville. TN
Barren
Tulsa. OK
Wagoner
Dallas, TX
Dallas
Nashville. TN
Logan
Tulsa, OK
Osage
Dallas. TX
Tarrant
Nashville, TN
Macon
Tulsa, OK
Montgomery
Dallas, TX
Denton
Nashville. TN
Simpson
Tulsa, OK
Labette
Dallas, TX
Collin
Nashville, TN
Cannon
Tulsa. OK
Pawnee
Dallas. TX
Johnson
Nashville, TN
Davidson
Tulsa, OK
Chautauqua
Dallas. TX
Hunt
Nashville, TN
Rutherford
Tulsa, OK
Creek
Dallas, TX
Lamar
Nashville, TN
Dickson
Utica, NY
Oneida
Dallas, TX
Wise
Nashville. TN
Cheatham
Utica, NY
Herkimer
Dallas, TX
Cooke
New London, CT
New London
Visalia, CA
Tulare
Dallas, TX
Hopkins
New London, CT
Windham
Washington, DC
Fairfax
Dallas, TX
Rockwall
New Orleans, LA
St. Tammany
^/ashinqton, DC
Montgomery
Dallas, TX
Palo Pinto
New Orleans, LA
Orleans
Washington, DC
Baltimore
Dallas, TX
Houston
New Orleans, LA
Jefferson
Washington, DC
Prince Geor
Dallas, TX
Eastland
New Orleans, LA
St. Bernard
Washington, DC
Baltimore
Dallas, TX
Montague
New Orleans, LA
St. Charles
Washington, DC
Washington
Dallas, TX
Delta
New Orleans, LA
St. John Th
Washington, DC
Anne Arunde
Dallas, TX
Ellis
New Orleans, LA
Plaguemines
Washington, DC
Prince Will
Dallas, TX
Parker
New Orleans, LA
St. James
Washington, DC
Howard
Dallas. TX
Henderson
New York, NY
Kings
Washington, DC
Harford
A-12
-------
Dallas, TX
Kaufman
New York. NY
Queens
Washington. DC
Arlington
Dallas, TX
Hood
New York, NY
New York
Washington. DC
Frederick
Dayton, OH
Montgomery
New York, NY
Suffolk
Washington, DC
Carroll
Dayton, OH
Clark
NewYorlc, NY
Nassau
Washington. DC
Franklin
Dayton, OH
Greene
New York. NY
Bronx
Washington. DC
Alexandria
Dayton, OH
Miami
New York, NY
Westchester
Washington, DC
Charles
Davton, OH
Preble
New York, NY
Fairfield
Washington. DC
Loudoun
Davton. OH
Champaign
New York, NY
Bergen
Washington. DC
Adams
Detroit, Ml
Oakland
New York, NY
New Haven
Washington. DC
Calvert
Detroit, Ml
Macomb
New York, NY
Essex
Washington, DC
Queen Annes
Detroit, Ml
Washtenaw
New York, NY
Middlesex
Washington. DC
Talbot
Detroit, Ml
St. Clair
New York, NY
Monmouth
Washington, DC
Dorchester
Detroit. Ml
Livinqston
New York, NY
Hudson
Washington, DC
Manassas
Detroit, Ml
Lapeer
New York, NY
Union
Washington, DC
Caroline
Detroit, Ml
Wayne
New York, NY
Passaic
Washington. DC
Somerset
Detroit, Ml
Genesee
New York, NY
Ocean
Washington, DC
Fairfax
Detroit, Ml
Monroe
New York, NY
Morris
Washington. DC
Kent
Detroit, Ml
Lenawee
New York. NY
Richmond
Washinqton. DC
King George
Dover, DE
Sussex
New York, NY
Mercer
Washington. DC
Madison
Dover, DE
Kent
New York, NY
Rockland
Washington. DC
Falls Churc
Dover, DE
Wicomico
New York, NY
Dutchess
Washington, DC
Manassas Pa
Euqene, OR
Lane
New York, NY
Somerset
Washington, DC
Washington
Euqene, OR
Douqlas
New York. NY
Ulster
Washington. DC
Stafford
Evansville, IN
Vanderburgh
New York, NY
Hunterdon
Washington. DC
Berkeley
Evansville, IN
Warrick
New York, NY
Monroe
Washington. DC
Spotsytvani
Evansville, IN
Dubois
New York, NY
Warren
Washington, DC
Fauquier
Evansville, IN
Posey
New York, NY
Putnam
Washington. DC
Jefferson
Evansville, IN
Spencer
New York, NY
Wayne
Washington. DC
Culpeper
Evansville, IN
Pike
New York, NY
Pike
Washington. DC
Warren
Evansville, IN
Henderson
New York, NY
Orange
Washington. DC
Fredericksb
Fort Wayne, IN
Grant
New York, NY
Sussex
Washington. DC
Clarke
Fort Wayne, IN
Huntington
Norfolk. VA
Portsmouth
Waterburv. CT
Litchfield
Fort Wayne, IN
Wabash
Norfolk, VA
Suffolk
Wheeling, WV
Guernsey
Fort Wayne, IN
Allen
Norfolk, VA
York
Wheeling. WV
Belmont
Fort Wayne. IN
DeKalb
Norfolk. VA
Accomack
Wheelinq. WV
Ohio
Fort Wayne, IN
Adams
Norfolk, VA
Isle Of Wig
Wheeling. WV
Marshall
Fort Wayne, IN
Whitley
Norfolk, VA
Southampton
York. PA
York
Fort Wayne, IN
Wells
Norfolk, VA
Northampton
Yuba City, CA
Yuba
Fresno, CA
Fresno
Norfolk, VA
Poquoson
Yuba City, CA
Sutter
Fresno. CA
Kings
Norfolk. VA
Northumberl
Benzie Co. Ml
Benzie
Fresno, CA
Madera
Norfolk. VA
Mathews
Chartevoix Co. Ml
Chartevoix
Fresno, CA
Tuolumne
Norfolk, VA
Surry
Cheboygan Co. Ml
Cheboygan
Fresno. CA
Mariposa
Norfolk. VA
Virginia Be
Chippewa Co. Ml
Chippewa
Gadsden, AL
Etowah
Norfolk. VA
Norfolk
Emmet Co. Ml
Emmet
Gadsden, AL
DeKalb
Norfolk. VA
Newport New
Grand Traverse Co.MI
Grand Trave
Gadsden, AL
Cherokee
Norfolk. VA
Chesapeake
Leelanau Co. Ml
Leelanau
Grand Rapids, Ml
Kent
Norfolk. VA
Hampton
Mackinac Co, Ml
Mackinac
Grand Rapids, Ml
Ottawa
Norfolk. VA
James City
Emporia, VA
Emporia
Grand Rapids, Ml
Muskegon
Norfolk. VA
Gloucester
Franklin. VA
Franklin
Grand Rapids. Ml
Alleqan
Norfolk. VA
Currituck
Grand Rapids, Ml
Ionia
Norfolk. VA
Williamsbur
A-13
-------
TABLE A-6
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H5EX-80 STANDARD
UNDER THE LOCAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Allentown, PA
Lehigh
Dallas, TX
Rockwall
New York, NY
Union
Allentown, PA
Carbon
Dallas, TX
Montague
New York, NY
Ocean
Allentown, PA
Northampton
Dallas, TX
Collin
New York, NY
Morris
Appleton, Wl
Manitowoc
Dallas, TX
Johnson
New York, NY
Richmond
Appleton, Wl
Outagamie
Dallas, TX
Ellis
New York, NY
Mercer
Appleton, Wl
Winnebago
Dallas, TX
Parker
New York, NY
Somerset
Appleton, Wl
Calumet
Dallas, TX
Hunt
New York, NY
Hunterdon
Athens, GA
Oconee
Dallas, TX
Henderson
New York, NY
Warren
Athens, GA
Morgan
Dallas, TX
Kaufman
New York, NY
Bronx
Athens, GA
Greene
Dallas, TX
Hood
New York, NY
Berqen
Athens. GA
Clarke
Dover, DE
Sussex
New York, NY
Essex
Athens, GA
Madison
Dover, DE
Kent
New York, NY
Passaic
Atlanta, GA
De Kalb
Evansville, IN
Warrick
New York, NY
Oranqe
Atlanta, GA
Gwinnett
Evansville, IN
Dubois
New York, NY
Rockland
Atlanta, GA
Clayton
Evansville, IN
Spencer
New York, NY
Dutchess
Atlanta, GA
Floyd
Evansville, IN
Vanderburgh
New York, NY
Sussex
Atlanta, GA
Douglas
Evansville, IN
Henderson
New York, NY
Putnam
Atlanta, GA
Fayette
Evansville, IN
Posey
New York, NY
Pike
Atlanta, GA
Henry
Fresno, CA
Fresno
Owensboro, KY
Hancock
Atlanta, GA
Spalding
Fresno, CA
Mariposa
~wensboro, KY
Daviess
Atlanta, GA
Rockdale
Fresno, CA
Madera
Pensacola, FL
Escambia
Atlanta, GA
Newton
Gadsden, AL
DeKatb
Pensacola, FL
Santa Rosa
Atlanta, GA
Paulding
Gadsden, AL
Cherokee
Philadelphia. PA
Philadelphi
Atlanta, GA
Walton
Gadsden, AL
Etowah
Philadelphia. PA
Montgomery
Atlanta. GA
Polk
Grand Rapids, Ml
Ottawa
Philadelphia. PA
Delaware
Atlanta. GA
Barrow
Grand Rapids, Ml
Muskegon
Philadelphia. PA
Bucks
Atlanta, GA
Butts
Grand Rapids, Ml
Allegan
Philadelphia, PA
Camden
Atlanta, GA
Fulton
Grand Rapids, Ml
Kent
Philadelphia, PA
New Castle
Atlanta, GA
Cobb
Greensboro, NC
Guilford
Philadelphia. PA
Burlington
Atlanta, GA
Cherokee
Greensboro, NC
Alamance
Philadelphia. PA
Chester
Atlanta, GA
Carroll
Greensboro, NC
Forsyth
Philadelphia. PA
Gloucester
Atlanta, GA
Bartow
Greensboro, NC
Davidson
Philadelphia. PA
Atlantic
Atlanta, GA
Coweta
Greensboro, NC
Randolph
Philadelphia, PA
Cumberland
Atlanta, GA
Forsyth
Greensboro, NC
Stokes
Philadelphia. PA
Cape May
Atlanta, GA
Pickens
Greensboro. NC
Yadkin
Philadelphia. PA
Salem
Augusta. GA
Barnwell
Greensboro, NC
Davie
Philadelphia. PA
Cecil
Augusta. GA
Taliaferro
Harrisburg, PA
Dauphin
Phoenix. AZ
Maricopa
Augusta, GA
Richmond
Harrisburg, PA
Adams
Phoenix. AZ
Pinal
Augusta, GA
Aiken
Harrisburg, PA
Cumberland
Portland, OR
Clackamas
Augusta, GA
Columbia
Harrisburg, PA
Lebanon
Portland, OR
Marion
Augusta, GA
McDuffie
Harrisburg, PA
Perry
Portland, OR
Linn
Augusta, GA
Edgefield
Hartford, CT
Middlesex
Portland, OR
Multnomah
Bakersfield, CA
Kem
Hartford, CT
Tolland
Portland, OR
Washington
Bangor, ME
Knox
Hartford. CT
Hartford
Portland, OR
Clark
Bangor, ME
Penobscot
Houston, TX
Harris
Portland, OR
Yamhill
Bangor, ME
Waldo
Houston. TX
Fort Bend
Portland, OR
Polk
Baton Rouge, LA
East Baton
Houston, TX
Galveston
Portland, OR
Columbia
Baton Rouge. LA
Iberville
Houston. TX
Brazoria
Providence, Rl
Kent
A-14
-------
Baton Rome, LA
West Baton
Houston, TX
Montgomery
3rovidence, Rl
Washington
Baton Rouge. LA
East Felici
Houston, TX
Walker
3rovidence, Rl
Providence
Baton Rouqe. LA
Livingston
Houston, TX
Wharton
'rovidence, Rl
Newport
Baton Rouae. LA
Ascension
Houston. TX
Austin
'rovidence, Rl
Bristol
Beaumont, TX
Jefferson
Houston, TX
Liberty
Raleigh, NC
Wake
Beaumont, TX
Oranqe
Houston. TX
Waller
Raleigh, NC
Durham
Beaumont, TX
Hardin
Houston, TX
Chambers
^alerqh, NC
Oranqe
Birmingham, AL
Jefferson
Huntington, WV
Lawrence
3aleiqh. NC
Johnston
Birmingham, AL
Shelby
Huntington, WV
Boyd
Raleigh, NC
Chatham
Birminqham, AL
St. Clair
Huntington, WV
Martin
Raleigh, NC
Franklin
Birmingham, AL
Blount
Huntington, WV
Cabell
Redding, PA
Berks
Boston, MA
Bristol
Huntington, WV
Wayne
Redding, CA
Shasta
Boston. MA
York
Huntington, WV
Greenup
Redding, CA
Tehama
Boston, MA
Middlesex
Huntington, WV
Carter
Sacramento, CA
Sacramento
Boston, MA
Worcester
Johnson City, TN
Sullivan
Sacramento. CA
Placer
Boston, MA
Essex
Johnson City. TN
Bristol
Sacramento, CA
Yolo
Boston, MA
Suffolk
Johnson City, TN
Washincrton
Sacramento, CA
El Dorado
Boston, MA
Norfolk
Johnson City, TN
Carter
St Louis. MO
Madison
Boston, MA
Plymouth
Johnson City, TN
Washington
St Louis, MO
St. Louis
Boston, MA
Hills boroug
Johnson City, TN
Hawkins
St Louis, MO
St. Louis
Boston, MA
Rockingham
Johnson City, TN
Scott
St Louis, MO
St. Clair
Boston, MA
Merrimack
Johnson City, TN
Unicoi
St Louis, MO
St. Charles
Boston, MA
Strafford
Knoxville, TN
Knox
St Louis. MO
Jefferson
Chanotte, NC
Mecklenburg
Knoxville, TN
Anderson
St Louis, MO
Franklin
Charlotte, NC
Rowan
Knoxville, TN
Union
St Louis. MO
Clinton
Charlotte, NC
Cabamjs
Knoxville, TN
Blount
St Louis. MO
Lincoln
Charlotte, NC
Gaston
Knoxville, TN
Sevier
St Louis, MO
Monroe
Charlotte, NC
York
Knoxville, TN
Loudon
St Louis. MO
Jersey
Charlotte. NC
Union
Los Angeles, CA
Los Angeles
St Louis, MO
Warren
Charlotte, NC
Lincoln
Los Angeles, CA
Orange
St Louis. MO
Crawford
Chattanooga, TN
Hamilton
Los Angeles, CA
San Bernard
San Diego, CA
San Diego
Chattanoooa, TN
Walker
Los Angeles. CA
Riverside
Santa Barbara, CA
Santa Barba
Chattanooaa. TN
Catoosa
Los Anqeles. CA
Ventura
Shreveport. LA
Bossier
Chattanoooa, TN
Marion
Louisville. KY
Perry
Shreveport. LA
Caddo
Chattanoooa, TN
Dade
Louisville. KY
Crawford
Shreveport. LA
Webster
Chicago, IL
Porter
Louisville, KY
Jefferson
Springfield, MA
Hampshire
Chicago, IL
La Porte
Louisville, KY
Clark
Springfield, MA
Hampden
Chicago, IL
Jasper
Louisville, KY
Floyd
Springfield, MA
Franklin
Chicago, IL
Cook
Louisville. KY
Bullitt
State College, PA
Centre
Chicago. IL
DuPage
Louisville, KY
Oldham
Visalia, CA
Tulare
Chicago, IL
Lake
Louisville, KY
Harrison
Washington. DC
Baltimore
Chicago, IL
Lake
Louisville. KY
Scott
Washington. DC
Prince Geor
Chicago, IL
Will
Macon. GA
Baldwin
Washington. DC
Baltimore
Chicago, IL
Kane
Macon, GA
Putnam
Washington. DC
Anne Arunde
Chicago, IL
McHenrv
Macon, GA
Bleckley
Washington. DC
Harford
Chicago. IL
Kenosha
Macon. GA
Bibb
Washington. DC
Carroll
Chicago, IL
Kankakee
Macon, GA
Houston
Washington, DC
Talbot
Chicago, IL
De Kalb
Macon. GA
Peach
Washington, DC
Kent
Chicago. IL
Kendall
Macon, GA
Jones
Washington, DC
Fairfax
Chicaqo. IL
Grundy
Macon, GA
Twiggs
Washington, DC
Montqomery
Cincinnati. OH
Butler
Memphis. TN
Shelby
Washington. DC
Washington
Cincinnati. OH
Warren
Memphis, TN
DeSoto
Washington. DC
Prince Will
Cincinnati. OH
Boone
Memphis, TN
Crittenden
Washington. DC
Howard
Cincinnati. OH
Clinton
Memphis, TN
Tipton
Washington, DC
Arlington
Cincinnati, OH
Union
Memphis, TN
Fayette
Washington, DC
Frederick
Cincinnati. OH
Hamilton
Modesto, CA
Stanislaus
Washington. DC
Washington
A-15
-------
Cincinnati, OH
Clermont
Nashville. TN
Sumner
Washington, DC
Alexandria
Cincinnati. OH
Kenton
Nashville, TN
Wilson
Washington, DC
Charles
Cincinnati. OH
Campbell
Nashville, TN
Robertson
Washington, DC
Loudoun
Cincinnati, OH
Dearborn
Nashville, TN
Davidson
Washington, DC
Stafford
Cincinnati, OH
Brown
Nashville, TN
Rutherford
Washington, DC
Berkeley
Cincinnati. OH
Grant
Nashville. TN
Williamson
Washington, DC
Spotsytvani
Cincinnati, OH
Pendleton
Nashville. TN
Dickson
Washington, DC
Calvert
Cincinnati. OH
Gallatin
Nashville, TN
Cheatham
Washington, DC
Fauquier
Cincinnati, OH
Ohio
New London, CT
New London
Washington, DC
Jefferson
Columbia, SC
Richland
New London, CT
Windham
Washington, DC
Queen Annes
Columbia, SC
Lexington
New York, NY
Kings
Washington, DC
Manassas
Columbus, OH
Pickaway
New York, NY
Queens
Washington, DC
Culpeper
Columbus, OH
Franklin
New York, NY
New York
Washington, DC
Warren
Columbus, OH
Licking
New York, NY
Suffolk
Washington, DC
Fairfax
Columbus, OH
Fairfield
New York, NY
Nassau
Washington, DC
Fredericksb
Columbus, OH
Delaware
New York, NY
Westchester
Washington, DC
King George
Columbus, OH
Madison
New York, NY
Fairfield
Washington, DC
Clarke
Dallas, TX
Dallas
New York, NY
New Haven
Washington, DC
Falls Churc
Dallas, TX
Tarrant
New York, NY
Middlesex
Washington, DC
Manassas Pa
Dallas, TX
Denton
New York, NY
Monmouth
York, PA
York
Dallas, TX
Wise
New York, NY
Hudson
A-16
-------
TABLE A-7
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H4AX-80 STANDARD
UNDER THE LOCAL CONTROL STRATEGY
NONATTAINMENT
COUNTY
NONATTAINMENT
COUNTY
NONATTAINMENT
COUNTY
AREA
NAME
AREA
NAME
AREA
NAME
Abilene, TX
Callahan
Dallas, TX
Kaufman
New York, NY
Middlesex
Abilene, TX
Taylor
Dallas, TX
Hood
New York. NY
Monmouth
Allentown, PA
Lehigh
Dayton. OH
Clark
New York, NY
Hudson
Allentown. PA
Carbon
Dayton, OH
Greene
New York. NY
Union
Allentown, PA
Northampton
Dayton, OH
Logan
New York, NY
Ocean
Appleton, Wl
Manitowoc
Dayton, OH
Montgomery
New York, NY
Morris
Appleton, Wl
Outagamie
Dayton, OH
Miami
New York, NY
Richmond
Appleton, Wl
Winnebago
Detroit. Ml
Macomb
New York, NY
Mercer
Appleton, Wl
Calumet
Detroit. Ml
Wayne
New York, NY
Somerset
Athens, GA
Oconee
Detroit, Ml
Oakland
New York, NY
Hunterdon
Athens, GA
Morgan
Detroit, Ml
Genesee
New York, NY
Warren
Athens, GA
Greene
Detroit, Ml
Washtenaw
New York, NY
Putnam
Athens, GA
Clarke
Detroit, Ml
St. Clair
New York, NY
Bronx
Athens, GA
Madison
Detroit. Ml
Monroe
New York, NY
Essex
Atlanta, GA
Fulton
Detroit, Ml
Livingston
New York, NY
Passaic
Atlanta, GA
DeKalb
Detroit. Ml
Lenawee
New York, NY
Orange
Atlanta, GA
Gwinnett
Detroit. Ml
Lapeer
New York, NY
Rockland
Atlanta, GA
Clayton
Dover, DE
Sussex
New York, NY
Dutchess
Atlanta, GA
Floyd
Dover, DE
Kent
New York. NY
Sussex
Atlanta, GA
Douglas
Evansville, IN
Warrick
New York. NY
Pike
Atlanta, GA
Fayette
Evansville. IN
Dubois
Dwensboro, KY
Hancock
Atlanta, GA
Henry
Evansville, IN
Spencer
Owensboro, KY
Daviess
Atlanta. GA
Spalding
Evansville, IN
Vanderburgh
Pensacola. FL
Escambia
Atlanta, GA
Rockdale
Evansville, IN
Henderson
Pensacola, FL
Santa Rosa
Atlanta. GA
Newton
Evansville, IN
Posey
Philadelphia, PA
Philadelphi
Atlanta, GA
Paulding
Fresno, CA
Fresno
Philadelphia, PA
Montgomery
Atlanta, GA
Walton
Fresno, CA
Mariposa
Philadelphia, PA
Delaware
Atlanta. GA
Polk
Fresno. CA
Madera
Philadelphia. PA
Bucks
Atlanta. GA
Barrow
Gadsden, AL
De Kalb
Philadelphia, PA
Camden
Atlanta, GA
Butts
Gadsden, AL
Cherokee
Philadelphia, PA
New Castle
Atlanta. GA
Cobb
Gadsden, AL
Etowah
Philadelphia, PA
Burlington
Atlanta, GA
Cherokee
Grand Rapids, Ml
Kent
Philadelphia, PA
Chester
Atlanta, GA
Carroll
Srand Rapids, Ml
Ottawa
Philadelphia, PA
Gloucester
Atlanta, GA
Bartow
Grand Rapids, Ml
Muskegon
Philadelphia, PA
Atlantic
Atlanta. GA
Coweta
Srand Rapids. Ml
Allegan
Philadelphia. PA
Cumberland
Atlanta. GA
Forsyth
Greensboro, NC
Guilford
Philadelphia, PA
Cape May
Atlanta, GA
Pickens
Greensboro, NC
Alamance
Philadelphia, PA
Salem
Augusta, GA
Aiken
Greensboro, NC
Forsyth
Philadelphia. PA
Cecil
Augusta, GA
Barnwell
Greensboro, NC
Davidson
Phoenix, AZ
Maricopa
Auqusta. GA
Washington
Greensboro. NC
Randolph
Phoenix, AZ
Pinal
Augusta, GA
Bamberg
Greensboro, NC
Stokes
Pittsfield.MA
Berkshire
Augusta. GA
Taliaferro
Greensboro. NC
Yadkin
Portland, OR
Clackamas
Augusta, GA
Richmond
Greensboro, NC
Davie
Portland, OR
Marion
Augusta. GA
Columbia
Harrisburg, PA
Dauphin
Portland, OR
Linn
Auqusta. GA
McDuffie
Hanisburg, PA
Adams
Portland, OR
Multnomah
Auqusta, GA
Edgefield
Harrisburq. PA
Cumberland
Portland. OR
Washington
Bakersfield. CA
Kern
Harrisburg. PA
Lebanon
Portland. OR
Clark
Bangor. ME
Hancock
Harrisburq. PA
Perry
Portland. OR
Yamhill
A-17
-------
Bangor, ME
Knox
Hartford. CT
Hartford
Portland, OR
Polk
Bangor, ME
Penobscot
Hartford. CT
Middlesex
Portland, OR
Columbia
Bangor, ME
Waldo
Hartford. CT
Tolland
Providence, Rl
Kent
Barnstable, MA
Barnstable
Houston. TX
Harris
'rovidence, Rl
Washington
Baton Rouqe, LA
East Baton
Houston, TX
Fort Bend
Providence, Rl
Providence
Baton Rouge, LA
Iberville
Houston, TX
Galveston
Providence, Rl
Newport
Baton Rouge, LA
West Baton
Houston, TX
Brazoria
Providence, Rl
Bristol
Baton Rouge, LA
East Felici
Houston, TX
Montgomery
Raleiqh, NC
Wake
Baton Rouge, LA
Livingston
Houston. TX
Walker
Raleiqh, NC
Durham
Baton Rouge, LA
Ascension
Houston, TX
Wharton
Raleigh, NC
Orange
Beaumont, TX
Jefferson
Houston, TX
Austin
Raleigh, NC
Johnston
Beaumont, TX
Orange
Houston. TX
Liberty
Raleigh, NC
Chatham
Beaumont, TX
Hardin
Houston, TX
Waller
Raleigh, NC
Franklin
Birmingham, AL
Jefferson
Houston, TX
Chambers
Redding, PA
Berks
Birmingham, AL
Shelby
Huntinqton, WV
Lawrence
Redding, CA
Shasta
Birmingham, AL
St. Clair
Huntington, WV
Boyd
Redding, CA
Tehama
Birmingham, AL
Blount
Huntington, WV
Martin
Sacramento, CA
Sacramento
Boston, MA
Bristol
Huntington, WV
Cabell
Sacramento, CA
Placer
Boston, MA
York
Huntington, WV
Wayne
Sacramento, CA
Yolo
Boston, MA
Middlesex
Huntington, WV
Greenup
Sacramento, CA
El Dorado
Boston, MA
Worcester
Huntington, WV
Carter
St Louis. MO
St. Louis
Boston, MA
Essex
Johnson City, TN
Sullivan
St Louis. MO
Madison
Boston, MA
Suffolk
Johnson City, TN
Washington
St Louis. MO
Macoupin
Boston, MA
Norfolk
Johnson City, TN
Bristol
St Louis. MO
St. Louis
Boston, MA
Plymouth
Johnson City. TN
Washington
St Louis. MO
St. Clair
Boston, MA
Hillsboroug
Johnson City, TN
Carter
St Louis. MO
St. Charles
Boston, MA
Rockingham
Johnson City, TN
Hawkins
St Louis. MO
Jefferson
Boston, MA
Merrimack
Johnson City, TN
Scott
St Louis. MO
Franklin
Boston, MA
Strafford
Johnson City, TN
Unicoi
St Louis. MO
Clinton
Charlotte, NC
Mecklenburg
Knoxville. TN
Knox
St Louis. MO
Lincoln
Charlotte, NC
Rowan
Knoxville, TN
Anderson
St Louis. MO
Monroe
Charlotte, NC
Cabarrus
Knoxvilie. TN
Union
St Louis, MO
Jersey
Charlotte. NC
Chester
Knoxville, TN
Blount
St Louis, MO
Warren
Charlotte, NC
Gaston
Knoxville, TN
Sevier
St Louis. MO
Crawford
Charlotte, NC
York
Knoxville, TN
Loudon
San Diego, CA
San Diego
Charlotte, NC
Union
Los Anaeles. CA
Los Angeles
Santa Barbara, CA
Santa Barba
Charlotte. NC
Lincoln
Los Angeles, CA
Orange
Scrantcn, PA
Luzerne
Chattanooga, TN
Hamilton
Los Angeles, CA
San Bernard
Scranton, PA
Lackawanna
Chattanooga, TN
Whitfield
Los Angeles. CA
Riverside
Scranton, PA
Columbia
Chattanooga. TN
Walker
Los Angeles. CA
Ventura
Scranton. PA
Wyoming
Chattanooga, TN
Catoosa
Louisville, KY
Clark
Seattle. WA
King
Chattanooga, TN
Chattooga
Louisville, KY
Perry
Seattle, WA
Pierce
Chattanooqa. TN
Marion
Louisville. KY
Crawford
Seattle. WA
Snohomish
Chattanooga, TN
Dade
Louisville. KY
Jefferson
Seattle, WA
Kitsap
Chicago, IL
Porter
Louisville. KY
Floyd
Seattle, WA
Thurston
Chicago, IL
Kenosha
LouisviBe. KY
Bullitt
Seattle. WA
Island
Chicago, IL
La Porte
Louisville. KY
Oldham
Sharon, PA
Mercer
Chicago, IL
Jasper
Louisville, KY
Harrison
Shreveport, LA
Bossier
Chicago, IL
Cook
Louisville, KY
Scott
Shreveport. LA
Caddo
Chicago, IL
Du Page
Macon, GA
Baldwin
Shreveport, LA
Webster
Chicago, IL
Lake
Macon, GA
Putnam
Springfield, MA
Hampden
Chicago, IL
Lake
Macon, GA
Bleckley
Springfield. MA
Hampshire
Chicago, IL
Will
Macon. GA
Wilkinson
Springfield. MA
Franklm
Chicago, IL
Kane
Macon. GA
Bibb
State Colleqe. PA
Centre
Chicago, IL
McHenrv
Macon. GA
Houston
Tulsa, OK
Tulsa
Chicago, IL
Kankakee
Macon. GA
Peach
Tulsa, OK
Creek
A-18
-------
Chicago, IL
DeKalb
Macon. GA
Jones
Tulsa, OK
Ropers
Chicago, IL
Kendall
Macon. GA
Twiggs
Tulsa. OK
Wagoner
Chicago, IL
Grundy
Memphis. TN
Shelby
Tulsa, OK
Osaqe
Cincinnati, OH
Hamilton
Memphis, TN
De Soto
Visalia. CA
Tulare
Cincinnati, OH
Butler
Memphis, TN
Crittenden
Washington, DC
Fairfax
Cincinnati, OH
Warren
Memphis, TN
Tipton
Washington, DC
Baltimore
Cincinnati, OH
Boone
Memphis. TN
Fayette
Washington, DC
Prince Geor
Cincinnati, OH
Clinton
Milwaukee, Wl
Milwaukee
Washington, DC
Baltimore
Cincinnati, OH
Union
Milwaukee, Wl
Waukesha
Washington, DC
Anne Arunde
Cincinnati, OH
Clermont
Milwaukee, Wl
Racine
Washington, DC
Harford
Cincinnati, OH
Kenton
Milwaukee, Wl
Washington
Washington, DC
Carroll
Cincinnati, OH
Campbell
Milwaukee, Wl
Ozaukee
Washington, DC
Queen Annes
Cincinnati, OH
Dearborn
Modesto, CA
Stanislaus
Washington, DC
Talbot
Cincinnati, OH
Brown
Nashville, TN
Sumner
Washington, DC
Fairfax
Cincinnati, OH
Grant
Nashville, TN
Wilson
Washington, DC
Kent
Cincinnati, OH
Pendleton
Nashville, TN
Robertson
Washington, DC
Montqomerv
Cincinnati, OH
Gallatin
Nashville, TN
Davidson
Washington, DC
Washington
Cincinnati, OH
Ohio
Nashville. TN
Rutherford
Washington, DC
Prince Will
Columbia, SC
Richland
Nashville. TN
Williamson
Washington, DC
Howard
Columbia, SC
Lexington
Nashville, TN
Dickson
Washington, DC
Arlinqton
Columbus, OH
Ross
Nashville, TN
Cheatham
Washington, DC
Frederick
Columbus, OH
Pickaway
New London, CT
New London
Washington, DC
Washington
Columbus, OH
Franldin
New London, CT
Windham
Washington. DC
Alexandria
Columbus, OH
Licking
New Orleans, LA
St. Tammany
Washington, DC
Charles
Columbus, OH
Fairfield
New Orleans, LA
Orleans
Washington. DC
Loudoun
Columbus, OH
Delaware
New Orleans, LA
Jefferson
Washington. DC
Stafford
Columbus, OH
Madison
New Orleans, LA
St. Bernard
Washington, DC
Berkeley
Dallas. TX
Dallas
New Orleans, LA
St. Charles
Washington. DC
Spotsytvani
Dallas, TX
Tarrant
New Orleans, LA
St. John Th
Washington, DC
Calvert
Dallas. TX
Denton
New Orleans. LA
Plaquemines
Washington, DC
Fauguier
Dallas. TX
Wise
New Orleans, LA
St. James
Washington, DC
Jefferson
Dallas. TX
Rockwall
New York. NY
Kings
Washington, DC
Manassas
Dallas. TX
Palo Pinto
New York. NY
Queens
Washington. DC
Culpeper
Dallas. TX
Montague
New York, NY
New York
Washington, DC
Warren
Dallas, TX
Collin
New York. NY
Suffolk
Washington, DC
Fredericksb
Dallas. TX
Johnson
New York. NY
Nassau
Washington. DC
King George
Dallas. TX
Ellis
New York. NY
Westchester
Washington. DC
Clarke
Dallas. TX
Parker
New York. NY
Fairfield
Washington, DC
Falls Churc
Dallas. TX
Hunt
New York. NY
Bergen
Washington. DC
Manassas Pa
Dallas. TX
Henderson
New York, NY
New Haven
fork. PA
York
A-19
-------
TABLE A-8
MODELED NONATTAINMENT AREA COUNTIES
FOR THE 8H1AX-80 STANDARD
UNDER THE LOCAL CONTROL STRATEGY
NONATTAINMENT
AREA
COUNTY
NAME
MONATTAINMENT
AREA
COUNTY
NAME
NONATTAINMENT
AREA
COUNTY
NAME
Atlanta, GA
Fulton
Greensboro, NC
Patrick
Orlando, FL
Lake
Atlanta, GA
Gilmer
Greensboro, NC
Randolph
Orlando, FL
Oranqe
Atlanta, GA
Gordon
3reensboro, NC
Rockingham
Orlando, FL
Osceola
Atlanta, GA
Gwinnett
Greensboro, NC
Stokes
Orlando, FL
Seminole
Atlanta, GA
Haralson
Greensboro, NC
Surry
Owensboro, KY
Daviess
Atlanta, GA
Henry
Greensboro, NC
Yadkin
Owensboro, KY
Hancock
Atlanta, GA
Jackson
Greenville, SC
Anderson
Parkersburq, WV
Athens
Atlanta. GA
Meriwether
Greenville, SC
Cherokee
Parkersburq, WV
Gilmer
Atlanta. GA
Morgan
Greenville, SC
Greenville
Parkersburq, WV
Jackson
Atlanta, GA
Newton
Greenville. SC
Pickens
Parkersburq, WV
Meiqs
Atlanta, GA
Paulding
Greenville, SC
Spartanburg
Parkersburq, WV
Morqan
Atlanta, GA
Pickens
Harrisburg, PA
Cumberland
Parkersburq, WV
Noble
Atlanta, GA
Pike
Harrisburg, PA
Dauphin
Parkersburq, WV
Washington
Atlanta. GA
Polk
Harrisburg. PA
Lebanon
Parkersburq, WV
Wirt
Atlanta. GA
Rockdale
Harrisburg. PA
Perry
Parkersburg, WV
Wood
Atlanta. GA
Spalding
Hartford, CT
Hartford
Pensacola, FL
Escambia
Atlanta, GA
Walton
Hartford, CT
Middlesex
Pensacola, FL
Santa Rosa
Augusta, GA
Aiken
Hartford, CT
Tolland
Philadelphia, PA
Atlantic
Augusta, GA
Allendale
Hickory, NC
Alexander
Philadelphia, PA
Bucks
Augusta. GA
Bamberg
Hickorv. NC
Burke
Philadelphia, PA
Burlington
Augusta. GA
Barnwell
Hickory, NC
Caldwell
Philadelphia, PA
Camden
Augusta, GA
Columbia
Hickory, NC
Catawba
Philadelphia, PA
Cape May
Augusta, GA
Edgefield
Hickory, NC
Wilkes
Philadelphia. PA
Cecil
Augusta, GA
Glascock
Houston, TX
Austin
Philadelphia, PA
Chester
Augusta, GA
McDuffie
Houston. TX
Brazoria
Philadelphia, PA
Cumberland
Augusta, GA
Richmond
Houston. TX
Chambers
Philadelphia, PA
Delaware
Augusta. GA
Taliaferro
Houston. TX
Fort Bend
Philadelphia, PA
Gloucester
Augusta, GA
Washington
Houston. TX
Galveston
Philadelphia, PA
Montgomery
Austin, TX .
Bastrop
Houston, TX
Harris
Philadelphia, PA
New Castle
Austin, TX
Burnet
Houston, TX
Liberty
Philadelphia, PA
Philadetphi
Austin, TX
Caldwell
Houston, TX
Matagorda
Philadelphia, PA
Salem
Austin, TX
Hays
Houston. TX
Montgomery
phoenix AZ
Maricopa
Austin. TX
Travis
Houston. TX
Polk
Phoenix, AZ
Pinal
Austin, TX
Williamson
Houston, TX
Trinity
Pittsburgh, PA
Alleqheny
Bakersfield, CA
Kern
Houston, TX
Walker
Pittsburgh, PA
Armstrong
Bangor, ME
Hancock
Houston. TX
Waller
Pittsburgh, PA
Beaver
Bangor, ME
Kennebec
Houston, TX
Wharton
Pittsburgh, PA
Butler
Bangor, ME
Knox
Huntington. WV
Boyd
Pittsburgh, PA
Clarion
Bangor, ME
Lincoln
Huntington. WV
Cabell
Pittsburgh, PA
Fayette
Bangor, ME
Penobscot
Huntington, WV
Carter
Pittsburgh, PA
Forest
Bangor. ME
Waldo
Huntington, WV
Gallia
Pittsburqh, PA
Tucker
Barnstable. MA
Barnstable
Huntington, WV
Greenup
Pittsburgh, PA
Washington
Barnstable, MA
Nantucket
Huntington, WV
Jackson
Pittsburqh, PA
Westmorelan
Baton Rouge, LA
Ascension
Huntington. WV
Johnson
Pittsfield, MA
Berkshire
Baton Rouge, LA
East Baton
Huntington, WV
Lawrence
Portland, ME
Cumberland
Baton Rouqe, LA
East Felici
Huntington. WV
Lawrence
Portland, OR
Benton
Baton Rouqe, LA
Iberville
Huntington. WV
Martin
Portland, OR
Clackamas
Baton Rouge. LA
Livingston
Huntington. WV
Pike
Portland, OR
Clark
A-20
-------
Baton Rouge, LA
Pointe Coup
Huntington, WV
Scioto
Portland. OR
Columbia
Baton Rouge, LA
West Baton
Huntington, WV
Wayne
Portland, OR
Jefferson
Beaumont. TX
Hardin
Indianapolis, IN
Bartholomew
Portland, OR
Lincoln
Beaumont, TX
Jefferson
Indianapolis, IN
Boone
Portland, OR
Linn
Beaumont, TX
Orange
Indianapolis, IN
Decatur
Portland, OR
Marion
Benzie Co, Ml
Benzie
Indianapolis, IN
Hamilton
Portland, OR
Multnomah
Biloxi, MS
Hancock
Indianapolis. IN
Hancock
Portland, OR
Polk
Biloxi, MS
Harrison
Indianapolis, IN
Hendricks
Portland, OR
Washington
Biloxi. MS
Jackson
ndianapolis, IN
Johnson
Portland. OR
Yamhill
Birmingham, AL
Blount
Indianapolis, IN
Madison
Providence, Rl
Bristol
Birmingham, AL
Jefferson
Indianapolis, IN
Marion
Providence, Rl
Kent
Birmingham, AL
Shelby
Indianapolis. IN
Morgan
Providence, Rl
Newport
Birmingham, AL
St. Clair
Indianapolis, IN
Rush
Providence, Rl
Providence
Bloomington, IN
Lawrence
Indianapolis, IN
Shelby
Providence, Rl
Washington
Bloomington, IN
Martin
Johnson City, TN
Avery
Raleiqh, NC
Chatham
Bloomington. IN
Monroe
Johnson City, TN
Bristol
Raleiqh, NC
Durham
Boston, MA
Bristol
Johnson City, TN
Carter
Raleigh, NC
Franklin
Boston. MA
Essex
Johnson City, TN
Dickenson
Raleigh, NC
Granville
Boston, MA
Hillsboroug
Johnson City, TN
Hawkins
Raleigh, NC
Harnett
Boston, MA
Merrimack
Johnson City, TN
Mitchell
Raleigh, NC
Johnston
Boston, MA
Middlesex
Johnson City, TN
Russell
Raleigh, NC
Orange
Boston, MA
Norfolk
Johnson City, TN
Scott
Raleiqh, NC
Person
Boston, MA
Plymouth
Johnson City, TN
Smyth
Raleiqh, NC
Wake
Boston, MA
Rockingham
Johnson City, TN
Sullivan
Reddinq, CA
Shasta
Boston, MA
Strafford
Johnson City, TN
Tazewell
Reddinq. CA
Tehama
Boston, MA
Suffolk
Johnson City, TN
Unicoi
Redding. PA
Berks
Boston. MA
Worcester
Johnson City, TN
Washington
Reno. NV
Washoe
Boston, MA
York
Johnson City, TN
Washington
Richmond, VA
Charles Cit
Buffalo. NY
Erie
Johnstown, PA
Cambria
Richmond, VA
Chesterfiel
Buffalo. NY
Niagara
Johnstown, PA
Jefferson
Richmond. VA
Colonial He
Canton, OH
Carroll
Johnstown, PA
Somerset
Richmond, VA
Dinwiddie
Canton, OH
Stark
Joplin, MO
Jasper
Richmond, VA
Goochland
Champaign, IL
Champaign
Joplin, MO
Neosho
Richmond, VA
Greensville
Charleston, WV
Kanawha
Joplin. MO
Newton
Richmond. VA
Hanover
Charleston. WV
Mason
Knoxville, TN
Anderson
Richmond. VA
Henrico
Charleston. WV
Putnam
Knoxville. TN
Bell
Richmond. VA
Hopewell
Charleston, WV
Roane
Knoxville, TN
Blount
Richmond, VA
New Kent
Charlevoix Co, Ml
Charlevoix
Knoxville. TN
Campbell
Richmond. VA
Petersburg
Charlotte, NC
Cabarrus
Knoxville. TN
Claiborne
Richmond, VA
Powhatan
Charlotte, NC
Chester
Knoxville, TN
Cumberland
Richmond, VA
Prince Edwa
Charlotte. NC
Gaston
Knoxville. TN
Grainger
Richmond, VA
Prince Geor
Charlotte, NC
Lincoln
Knoxville, TN
Jefferson
Richmond, VA
Richmond
Charlotte. NC
Mecklenburg
Knoxville, TN
Knox
Richmond. VA
Sussex
Charlotte. NC
Rowan
Knoxville, TN
Loudon
Rochester, NY
Genesee
Charlotte. NC
Stanly
Knoxville, TN
McCrearv
Rochester, NY
Livingston
Charlotte, NC
Union
Knoxville, TN
Scott
Rochester, NY
Monroe
Charlotte. NC
York
Knoxville, TN
Sevier
Rochester. NY
Ontario
Chattanooga, TN
Bradley
Knoxville. TN
Union
Rochester, NY
Orleans
Chattanooga, TN
Catoosa
Knoxville, TN
Whitley
Rochester, NY
Wayne
Chattanooga, TN
Chattooga
Kokomo, IN
Howard
Rochester, NY
Wyoming
Chattanooga. TN
Dade
Kokomo, IN
Tipton
Rochester. NY
Yates
Chattanooga, TN
Hamilton
Lafayette, IN
Clinton
Rocky Mount, NC
Edgecombe
Chattanooga, TN
Marion
Lafayette, IN
Tippecanoe
Rocky Mount, NC
Nash
Chattanooga, TN
Murray
Lancaster, PA
Lancaster
Rocky Mount, NC
Northampton
Chattanooga, TN
Walker
Lawton, OK
Comanche
Sacramento, CA
El Dorado
Chattanooga. TN
Whitfield
Lawton. OK
Greer
Sacramento. CA
Nevada
A-21
-------
Cheboygan Co, Ml
Cheboygan
Leelanau Co, Ml
Leelanau
Sacramento, CA
Placer
Chicago, IL
Cook
Lewiston, ME
Androscoggi
Sacramento. CA
Sacramento
Chicago. IL
De Kalb
Lewiston, ME
Sagadahoc
Sacramento. CA
Yolo
Chicago, IL
Du Page
Lexington, KY
Anderson
Salinas, CA
Monterey
Chicago. IL
Grundy
Lexinqton, KY
Bourbon
Salinas. CA
San Benito
Chicago, IL
Jasper
Lexington. KY
Boyle
San Diego. CA
San Dieqo
Chicago, IL
Kane
Lexinqton, KY
Clark
San Francisco, CA
Alameda
Chicago, IL
Kankakee
Lexington, KY
Fayette
San Francisco, CA
Contra Cost
Chicago, IL
Kendall
Lexington, KY
Franklin
San Francisco, CA
Marin
Chicago, IL
Kenosha
Lexington, KY
Garrard
San Francisco, CA
Napa
Chicago, IL
La Porte
Lexington, KY
Jessamine
San Francisco, CA
San Francis
Chicago, IL
Lake
Lexington, KY
Lincoln
San Francisco, CA
San Mateo
Chicago, IL
Lake
Lexington, KY
Madison
San Francisco, CA
Santa Clara
Chicago, IL
McHenry
Lexington, KY
Mercer
San Francisco, CA
Santa Cruz
Chicago, IL
Porter
Lexington, KY
Pulaski
San Francisco, CA
Solano
Chicago, IL
Will
Lexington, KY
Scott
San Francisco, CA
Sonoma
Chippewa Co. Ml
Chippewa
Lexington, KY
Woodford
Santa Barbara, CA
Santa Barba
Cincinnati, OH
Boone
Lima, OH
Allen
Savannah, GA
Appling
Cincinnati, OH
Brown
Lima. OH
Auglaize
Savannah, GA
Bryan
Cincinnati. OH
Butler
Lima, OH
Logan
Savannah. GA
Chatham
Cincinnati, OH
Campbell
Longview, TX
Franklin
Savannah. GA
Effinqham
Cincinnati, OH
Carroll
Longview, TX
Gregg
Savannah, GA
Jeff Davis
Cincinnati, OH
Clermont
Longview, TX
Harrison
Savannah, GA
Toombs
Cincinnati, OH
Clinton
Longview, TX
Titus
Scranton, PA
Columbia
Cincinnati, OH
Dearborn
Longview, TX
Upshur
Scranton, PA
Lackawanna
Cincinnati, OH
Franklin
Los Angeles, CA
Los Angeles
Scranton, PA
Luzerne
Cincinnati, OH
Gallatin
Los Angeles, CA
Orange
Scranton, PA
Schuylkill
Cincinnati, OH
Grant
Los Angeles, CA
Riverside
Scranton, PA
Susquehanna
Cincinnati. OH
Hamilton
Los Angeles, CA
San Bernard
Scranton, PA
Wyominq
Cincinnati. OH
Highland
Los Angeles, CA
Ventura
Seattle. WA
Douqlas
Cincinnati, OH
Kenton
Louisville, KY
Breckinridg
Seattle. WA
Island
Cincinnati. OH
Ohio
Louisville, KY
Bullitt
Seattle. WA
King
Cincinnati, OH
Pendleton
Louisville, KY
Clark
Seattle. WA
Kitsap
Cincinnati, OH
Ripley
Louisville, KY
Crawford
Seattle. WA
Lewis
Cincinnati, OH
Switzerland
Louisville, KY
Floyd
Seattle. WA
Pierce
Cincinnati, OH
Union
Louisville, KY
Harrison
Seattle, WA
Snohomish
Cincinnati, OH
Warren
Louisville, KY
Jackson
Seattle. WA
Thurston
Cleveland, OH
Ashtabula
Louisville, KY
Jefferson
Sharon, PA
Mercer
Cleveland, OH
Crawford
Louisville, KY
Jennings
Sharon, PA
Venanqo
Cleveland. OH
Cuyahoga
Louisville, KY
Meade
Sheboygan, Wl
Sheboygan
Cleveland, OH
Geauga
Louisville, KY
Oldham
Sherman. TX
Grayson
Cleveland. OH
Lake
Louisville, KY
Orange
Sherman, TX
Johnston
Cleveland. OH
Lorain
Louisville, KY
Perrv
Sherman, TX
Love
Cleveland, OH
Medina
Louisville, KY
Scott
Sherman. TX
Marshall
Cleveland, OH
Portage
Louisville, KY
Trimble
Shreveport, LA
Bossier
Cleveland, OH
Summit
Louisville, KY
Washington
Shreveport, LA
Caddo
Columbia, SC
Calhoun
Mackinac Co, Ml
Mackinac
Shreveport. LA
De Soto
Columbia, SC
Fairfield
Macon, GA
Baldwin
Shreveport, LA
Red River
Columbia, SC
Lexington
Macon, GA
Bibb
Shreveport. LA
Webster
Columbia. SC
Richland
Macon, GA
Bleckley
Springfield. MA
Franklin
Columbus, GA
Chattahooch
Macon, GA
Houston
Springfield, MA
Hampden
Columbus, GA
Harris
Macon. GA
Johnson
Springfield. MA
Hampshire
Columbus. GA
Marion
Macon. GA
Jones
St Louis. MO
Bond
Columbus, GA
Muscogee
Macon. GA
Laurens
St Louis. MO
Clinton
Columbus, GA
Russell
Macon. GA
Montgomery
St Louis. MO
Crawford
Columbus, OH
Delaware
Macon. GA
Peach
St Louis. MO
Franklin
A-22
-------
Columbus, OH
Fairfield
Macon, GA
Putnam
St Louis, MO
Greene
Columbus, OH
Fayette
Macon, GA
Treutlen
St Louis, MO
Jefferson
Columbus, OH
Franklin
Macon, GA
Twiggs
St Louis, MO
Jersey
Columbus, OH
Knox
Macon, GA
Wheeler
St Louis, MO
Lincoln
Columbus, OH
Licking
Macon. GA
Wilkinson
St Louis. MO
Macoupin
Columbus, OH
Madison
Memphis, TN
Crittenden
St Louis, MO
Madison
Columbus, OH
Muskingum
Memphis. TN
De Soto
St Louis, MO
Monroe
Columbus, OH
Pickaway
Memphis, TN
Fayette
St Louis, MO
St. Charles
Columbus. OH
Ross
Memphis. TN
Shelby
St Louis, MO
St. Clair
Columbus, OH
Union
Memphis, TN
Tate
St Louis, MO
St. Louis
Columbus, OH
Vinton
Memphis, TN
Tipton
St Louis, MO
St. Louis
Dallas, TX
Collin
Milwaukee. Wl
Milwaukee
St Louis, MO
Warren
Dallas, TX
Cooke
Milwaukee, Wl
Ozaukee
St Louis, MO
Washington
Dallas, TX
Dallas
Milwaukee, Wl
Racine
State College, PA
Centre
Dallas, TX
Delta
Milwaukee, Wl
Washington
State College, PA
Clearfield
Dallas, TX
Denton
Milwaukee, Wl
Waukesha
State College, PA
Elk
Dallas, TX
Eastland
Mobile, AL
Baldwin
Stockton, CA
San Joaquin
Dallas, TX
Ellis
Mobile, AL
Mobile
Syracuse, NY
Cayuqa
Dallas, TX
Henderson
Modesto, CA
Stanislaus
Syracuse, NY
Madison
Dallas, TX
Hood
Muncie, IN
Blackford
Syracuse, NY
Onondaqa
Dallas, TX
Hopkins
Muncie, IN
Delaware
Syracuse, NY
Osweqo
Dallas, TX
Houston
Nashville, TN
Barren
Syracuse, NY
Seneca
Dallas, TX
Hunt
Nashville. TN
Cannon
Tampa, FL
Hernando
Dallas, TX
Johnson
Nashville, TN
Cheatham
Tampa, FL
Hillsborouq
Dallas, TX
Kaufman
Nashville. TN
Davidson
Tampa, FL
Pasco
Dallas, TX
Lamar
Nashville, TN
Dickson
Tampa. FL
Pinellas
Dallas, TX
Montague
Nashville. TN
Logan
Terre Haute. IN
Clay
Dallas, TX
Palo Pinto
Nashville. TN
Macon
Terre Haute, IN
Owen
Dallas, TX
Parker
Nashville. TN
Maury
Terre Haute, IN
Vermillion
Dallas, TX
Rockwall
Nashville, TN
Robertson
Terre Haute, IN
Vigo
Dallas, TX
Tarrant
Nashville. TN
Rutherford
Texarkana, AR
Bowie
Dallas, TX
Wise
Nashville. TN
Simpson
Texarkana, AR
Miller
Dayton, OH
Champaign
Nashville. TN
Sumner
Texarkana, AR
Red River
Dayton. OH
Clark
Nashville. TN
Williamson
Tulsa. OK
Chautauqua
Dayton, OH
Greene
Nashville. TN
Wilson
Tulsa. OK
Creek
Dayton. OH
Miami
New London. CT
New London
Tulsa. OK
Labette
Dayton, OH
Montgomery
New London, CT
Windham
Tulsa, OK
Montgomery .
Dayton, OH
Preble
New Orleans, LA
Jefferson
Tulsa. OK
Osage
Detroit, Ml
Genesee
New Orleans, LA
Orleans
Tulsa. OK
Pawnee
Detroit, Ml
Lapeer
New Orleans, LA
Plaquemines
Tulsa, OK
Rogers
Detroit, Ml
Lenawee
New Orleans, LA
St. Bernard
Tulsa, OK
Tulsa
Detroit, Ml
Livingston
New Orleans. LA
St. Charles
Tulsa, OK
Wagoner
Detroit. Ml
Macomb
New Orleans. LA
St. James
Tulsa, OK
Washinqton
Detroit, Ml
Monroe
New Orleans, LA
St. John Th
Utica, NY
Herkimer
Detroit. Ml
Oakland
New Orleans. LA
St. Tammany
Ubca. NY
Oneida
Detroit, Ml
St. Clair
New York, NY
Bergen
Visalia, CA
Tulare
Detroit. Ml
Washtenaw
New York, NY
Bronx
Washington, DC
Adams
Detroit, Ml
Wayne
New York, NY
Dutchess
Washington, DC
Alexandria
Dover, DE
Kent
New York, NY
Essex
Washington, DC
Anne Arunde
Dover, DE
Sussex
New York, NY
Fairfield
Washington. DC
Arlington
Dover, DE
Wicomico
New York, NY
Hudson
Washington, DC
Baltimore
Emmet Co. Ml
Emmet
New York. NY
Hunterdon
Washington. DC
Baltimore
Emporia, VA
Emporia
New York. NY
Kings
Washington, DC
Berkeley
Eugene, OR
Douglas
New York, NY
Mercer
Washington. DC
Calvert
Eugene, OR
Lane
New York, NY
Middlesex
Washington, DC
Caroline
Evansville. IN
Dubois
New York. NY
Monmouth
Washington. DC
Carroll
A-23
-------
Evansvitle, IN
Henderson
New York. NY
Monroe
Washington, DC
Charles
Evansville, IN
Pike
New York, NY
Morris
Washington, DC
Clarke
Evansville, IN
Posey
New York, NY
Nassau
Washington, DC
Culpeper
Evansville, IN
Spencer
New York, NY
New Haven
Washington. DC
Dorchester
Evansville, IN
Vanderburgh
New York, NY
New York
Washington, DC
Fairfax
Evansville. IN
Warrick
New York, NY
Ocean
Washington, DC
Fairfax
Fort Wayne, IN
Adams
New York, NY
Oranqe
Washington, DC
Falls Churc
Fort Wayne, IN
Allen
New York, NY
Passaic
Washington, DC
Fauquier
Fort Wayne, IN
De Kalb
New York, NY
Pike
Washington, DC
Franklin
Fort Wayne, IN
Grant
New York, NY
Putnam
Washington, DC
Frederick
Fort Wayne, IN
Huntington
New York, NY
Queens
Washington, DC
Fredericksb
Fort Wayne, IN
Wabash
New York, NY
Richmond
Washington, DC
Harford
Fort Wayne, IN
Wells
New York, NY
Rockland
Washington, DC
Howard
Fort Wayne, IN
Whitley
New York, NY
Somerset
Washington, DC
Jefferson
Franklin. VA
Franklin
New York, NY
Suffolk
Washington, DC
Kent
Fresno, CA
Fresno
New York, NY
Sussex
Washington, OC
King Georqe
Fresno, CA
Kings
New York, NY
Ulster
Washington, DC
Loudoun
Fresno, CA
Madera
New York, NY
Union
Washington, DC
Madison
Fresno, CA
Mariposa
New York, NY
Warren
Washington, DC
Manassas
Fresno, CA
Tuolumne
New York, NY
Wayne
Washington, DC
Manassas Pa
Gadsden, AL
Cherokee
New York, NY
Westchester
Washington, DC
Montgomery
Gadsden, AL
De Kalb
Norfolk, VA
Accomack
Washington, DC
Prince Geor
Gadsden, AL
Etowah
Norfolk, VA
Chesapeake
Washington, DC
Prince Will
Grand Rapids, Ml
Allegan
Norfolk, VA
Currituck
Washington, DC
Queen Annes
Grand Rapids, Ml
Barry
Norfolk, VA
Gloucester
Washington, DC
Somerset
Grand Rapids, Ml
Ionia
Norfolk, VA
Hampton
Washington, DC
Spotsylvani
Grand Rapids, Ml
Kent
Norfolk, VA
Isle Of Wiq
Washington, DC
Stafford
Grand Rapids, Ml
Manistee
Norfolk, VA
James City
Washington, DC
Talbot
Grand Rapids. Ml
Muskegon
Norfolk, VA
Mathews
Washington, DC
Warren
Grand Rapids. Ml
Newaygo
Norfolk, VA
Newport New
Washington, DC
Washington
Grand Rapids, Ml
Ottawa
Norfolk, VA
Norfolk
Washington, DC
Washington
Grand Traverse Co.MI
Grand Trave
Norfolk, VA
Northampton
Waterbury. CT
Litchfield
Green Bay, Wl
Brown
Norfolk, VA
Northumberl
Wheeling. WV
Belmont
Green Bay, Wl
Door
Norfolk, VA
Poquoson
Wheelinq, WV
Guernsey
Green Bay, Wl
Kewaunee
Norfolk, VA
Portsmouth
Wheelinq, WV
Marshall
Green Bay, Wl
Manitowoc
Norfolk, VA
Southampton
Wheeling, WV
Ohio
Greensboro, NC
Alamance
Norfolk, VA
Suffolk
York, PA
York
Greensboro. NC
Davidson
Norfolk. VA
Surry
Vuba City. CA
Sutter
Greensboro. NC
Davie
Norfolk, VA
Virginia Be
Yuba City, CA
Yuba
Greensboro. NC
Forsyth
Norfolk, VA
Williamsbur
Greensboro. NC
Guilford
Norfolk. VA
York
A-24
-------
NONATTAINftflENT AREAS UNDER THE RCS
1H1EX-120 (ret
lional)
8H1AX-80 (regional)
8H4AX-80 (regional)
8HSEX-80 (ret
ional)
voc
NOx
VOC
NOx
VOC
NOx
VOC
NOx
Area
Attain?
Tarqet Actual
Tarqet Actual
Attain?
Tarqet
Actual
Tarqet
Actual
Attain?
Tarqet
Actual
Tarqet Actual
Attain?
Tarqet Actual
Tarqet Actual
Atlanta, GA
NO
75
46
NO
66 36
NO
62 36
Atlantic City, NJ
NO
79
17
NO
66
17
NO
62 17
Bakersfleld, CA
NO
40 7
NO
40
7
NO
40
7
NO
40 7
Baltimore/Wash. DC
NO
66
14
Baton Rouge, LA
YES
18 20
NO
26
13
NO
22
13
YES
18 13
Beaumont, TX
YES
26
82
Chicago, IL
NO
44
14
Cincinnati, OH
YES
35
28
Dallas, TX
YES
35
27
Eugene, OR
YES
20
29
Fairfield, NY
NO
79
11
Fresno, CA
NO
50
14
NO
45
15
NO
45 15
Grand Rapids, Ml
YES
44
36
Hartford, CT
NO
79
13
Houston, TX
YES
44 42
YES
57
42
YES
44
42
YES
44 42
Huntington, WV
NO
53
28
Knoxville, TN
YES
53
47
Los Angeles, CA
NO
80 9
NO
90
9
NO
80
9
NO
80 9
Manitowoc, Wl
NO
44
30
Modesto, CA
NO
50
11
NO
25
11
50 3
Muskegon, Ml
NO
44
25
Nashville, TN
YES
44
42
New London, CT
NO
79
13
New Orleans, LA
YES
18
19
New York, NY
NO
62 16
NO
79
16
NO
66
16
NO
62 16
Philadelphia, PA
NO
62
18
NO
53
18
Phoenix, AZ
YES
20
42
Portland, ME
YES
44
33
Portland, OR
YES
25
28
YES
20
28
Providence, Rl
NO
70
18
Redding, CA
NO
50
33
Reno, NV
YES
20
25
Sacramento, CA
NO
40
9
NO
25
7
NO
20 7
St. Louis. MO
YES
31
28
San Diego, CA
NO
80 8
NO
90
8
NO
80
8
NO
80 8
Santa Barbara, CA
NO
90
9
Seattle, WA
YES
20
20
A-25
-------
NONATTAINMENT AREAS UNDER THE RCS
Area
1H1EX-120 (rec
ional)
8H1AX-80 (reqlonal)
8H4AX-80 (regional)
8H5EX-S0 (rec
Ional)
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Stockton, CA
Visalia, CA
Tell City. IN/KY
NO
NO
YES
50 11
50 7
18 23
NO
45 7
NUMBER OF NONATTAINMENT AREAS 6
NUMBER OF AREAS THAT CAN ATTAIN 2
NUMBER OF ATTAINING AREAS WITHIN THE RANGE 1
NUMBER OF RESIDUAL NONATTAINMENT AREAS 4
40
16
8
24
14
2
1
12
10
2
2
8
A-26
-------
NONATTAINMENT AREAS U
MDER THE LCS
1H1EX-120 (rec
tonal)
8H1AX40 (reaional)
8H4AX-S0 (regional)
BHSEX-80 (reaional)
j VOC
NOk
VOC
NOx
VOC
NOx
VOC
NOx
Area
Attain?
Tarqet Actual
Tarqet Actual
Attain?
Tarqet Actual
Target Actual
Attain?
Tarqet Actual
Tarqet Actual
Attain?
Tarqet Actual
Taraet Actual
Allentown, PA
NO
90 15
Athens, GA
NO
85 28
NO
75 29
NO
70 29
Atlanta, GA
NO
85 41
NO
75 43
NO
70 43
Augusta, GA
NO
85 43
Austin, TX
YES
20 20
Bakersfteld, CA
NO
40 7
NO
40 7
NO
40 7
NO
40 7
Bangor, ME
NO
50 28
YES
40 32
Barnstable, MA
YES
50 40
Baton Rouge, LA
NO
20 13
NO
30 14
NO
25 14
NO
20 14
Beaumont, TX
YES
20 60
YES
30 68
YES
20 80
Birmingham, AL
YES
50 45
Boston, MA
NO
40 24
NO
50 24
NO
45 24
NO
40 24
Charlotte, NC
NO
90 45
Chattanooga, TN
NO
70 26
Chicago, IL
NO
50 16
NO
40 16
Cincinnati, OH
YES
40 32
YES
35 29
YES
30 29
Columbia, SC
YES
50 50
Columbus, OM
YES
20 20
Dallas, TX
YES
40 30
YES
35 29
Dayton, OH
YES
20 25
Detroit, Ml
NO
50 30
Dover, DE
NO
90 11
Eugene, OR
YES
20 29
Evansvllle, IN
YES
20 30
Fresno, CA
NO
50 14
NO
45 15
NO
45 15
Gadsden, AL
NO
60 31
Grand Rapids, Ml
NO
50 35
YES
40 35
YES
35 35
Green Bay, Wl
NO
50 32
Greensboro, NC
NO
60 40
Harrisburg, PA
NO
90 15
Hartford, CT
NO
90 13
NO
80 13
NO
75 13
Houston, TX
NO
50 34
NO
65 34
NO
50 34
NO
50 34
Huntington, VW
NO
60 30
NO
50 28
Indianapolis. IN
YES
20 20
Johnson City, TN
YES
60 51
Kroxvllle, TN
NO
60 40
Los Angeles, CA
NO
80 9
NO
90 9
NO
80 9
NO
80 9
A-27
-------
NONATTAINMENT AREAS U
NDER THE LCS
1H1EX-120 (rec
lionall
8H1AX-80 (regional)
8H4AX-30 (reqional)
8H6EX-80 freaional)
VOC
NOx
VOC
NOx
VOC
NOx
VOC
NOx
Area
Attain?
Taraet Actual
Taraet Actual
Attain?
Taraet
Actual
Taraet
Actual
Attain?
Tarqet Actual
Tarqet Actual
Attain?
Tarqet Actual
Tarqet Actual
Louisville, KY
NO
50
30
Macon, GA
NO
80
54
YES
70 56
YES
60 56
Memphis, TN
YES
40
31
Milwaukee, Wl
NO
50
17
Mobile, AL
YES
10
44
Modesto, CA
NO
50
11
NO
25 11
50 3
Nashville, TN
NO
50
32
YES
45 40
YES
40 40
New London, CT
NO
70 14
NO
90
14
NO
75 14
NO
70 14
New Orleans, LA
YES
20
20
New York, NY
NO
70 16
NO
90
16
NO
75 17
NO
70 16
Norfolk, VA
YES
45
35
Owensboro, KY
YES
50
41
YES
40 41
YES
30 33
Philadelphia, PA
NO
60 13
NO
80
18
NO
70 18
NO
65 18
Phoenix, A2
YES
20
42
Pittsburgh, PA
NO
40
17
Portland, ME
NO
50
27
Portland, OR
YES
25
28
YES
20 29
Providence, Rl
NO
80
18
NO
75 18
NO
70 18
Raleigh, NC
YES
50
45
Redding, PA
NO
40
16
Redding, CA
NO
50
33
Reno, NV
YES
20
25
Richmond, VA
NO
70
34
Rochester, NY
YES
40
31
Sacramento, CA
NO
40
9
NO
25 7
NO
20 7
St. Louis, MO
YES
35
29
San Diego, CA
NO
80 8
NO
90
8
NO
80 8
NO
80 8
Santa Barbara, CA
NO
90
9
Seattle, WA
YES
20
20
Sherman, TX
YES
20
21
Shreveport, LA
YES
20
26
Springfield, MA
NO
50
21
NO
40 21
NO
35 21
State College, PA
YES
20
20
Stockton, CA
NO
50
11
Tulsa, OK
YES
20
30
Visalia, CA
NO
50
7
NO
45 7
Washington, DC
NO
75
17
NO
65 16
NO
60 16
A-28
-------
NONATTAINMENT AREAS U
NDER THE LCS
Area
1H1EX-120 tree
ilonal)
8H1AX-80 (regional)
8H4AX-80 (regional)
8H5EX-80 (reqional)
Attain?
VOC
Tarqet Actual
NOx
Tarqet Actual
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Attain?
VOC
Taraet Actual
NOx
Taraet Actual
Attain?
VOC
Tarqet Actual
NOx
Taraet Actual
York. PA
NO
90 14
NUMBER OF NONATTAINMENT AREAS
NUMBER OF AREAS THAT CAN ATTAIN
NUMBER OF ATTAINING AREAS WITHIN THE RANGE
NUMBER OF RESIDUAL NONATTAINMENT AREAS
10
76
1
29
0
12
9
46
30
9
3
21
22
6
3
17
A-29
-------
APPENDIX B
CONTROL MEASURE REDUCTIONS AND COSTS BY NONATTAMMENT AREA
-------
This appendix presents the annual emission reductions and costs associated with the
control measures analyzed for each moderate and above nonattainment area identified under each
ozone NAAQS alternative. The control measures cover stationary (point and area) and mobile
(on-highway and nonroad) sources of VOC and NO,, emissions. To analyze the impacts
associated with the current ozone standard and each of the NAAQS alternatives relative to the
current standard, VOC and NOx control measures were developed as surrogates for control
measures that State or local agencies may potentially use in their State Implementation Plans
(SIPs). The tables in this appendix display the control measures selected for each nonattainment
area using a least-cost approach based on the cost-effectiveness value (i.e., the dollar per ton of
emission reduction) of each control measure.
Tables B-l through B-4 show the control measures selected under the regional control
scenario (RCS). Tables B-5 through B-8 exhibit the control measures selected under the local
control scenario (LCS). Tables B-l and B-5 display the control measures selected for each area
to realize attainment of the current ozone NAAQS. The emission reductions and costs for each
control measure are incremental to the 2007 analytical baseline.
Tables B-2 through B-4 and B-6 through B-8 display control measures selected for each
NAAQS alternative under the RCS and LCS, respectively. For some nonattainment areas, control
measures are listed with zero emission reductions and costs in these tables. The emission
reduction and cost values in these tables represent the incremental level of reduction and cost for
these measures beyond the level achieved for the current NAAQS. The control measures with
zero emission reductions and costs are presented to show the complete list of controls selected
toward achievement of the given NAAQS alternative.
B-l
-------
Table B-1. Current NAAQS (1H1EX-120): Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the RCS
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
CARB Tier 2 Standards - Reform
73.1
0.0
182,664
0
Aerosols
SCAQMD Standards
Reformuiati
73.1
0.0
730,656
0
Aircraft surface coating
Add-on control levels
2.2
0.0
68,403
0
Automobile reflnishing
CARB BARCT limits
33.3
0.0
122,427
0
Automobile refinishing
FIP Rule (VOC Content & TE)
127.1
0.0
2,290,251
0
Metal product surface coating
VOC content limits & improved
21.1
0.0
527
0
Miscellaneous surface coating
Add-on control levels
21.8
0.0
353.720
0
Miscellaneous surface coating
MACT level of control
16.0
0.0
40,089
0
Nonroad gasoline
Reformulated gasoline
37.1
0.0
185,500
0
Open Burning
Episodic Ban
163.0
30.9
0
0
Pesticide Application
Reformulation - FIP rule
3439
0.0
3,198,642
0
Point Sources
RE Improvements
327.4
0.0
654,810
0
Recreational vehicles
CARB standards
35.7
0.0
18,962
0
Service stations - stage l-truck un
Vapor balance & P-V valves
296.1
0.0
7,453
0
Wood furniture surface coating
Reformulation
44.9
0.0
16,824
0
Total
1,617.8
30.9
7,870,928
0
Aerosols
CARB Tier 2 Standards - Reform
86.2
0.0
215,832
0
Automobile refinishing
CARB BARCT limits
22.0
0.0
80,538
0
Metal product surface coating
VOC content limits & improved
57.9
0.0
2,783
0
Miscellaneous surface coating
MACT level of control
15.6
0.0
38,866
0
Nonroad gasoline
Reformulated gasoline
58.8
0.0
294,000
0
Open burning
Seasonal/episodic ban
387.5
73.6
0
0
Point Sources
RE Improvements
6,853.3
0.0
13,706,480
0
Recreational vehicles
CARB standards
268.8
0.0
142,458
0
Service stations - stage Uruck un
Vapor balance & P-V valves
233.8
0.0
5,842
0
Wood furniture surface coating
Reformulation
4.3
0.0
6,116
0
Wood product surface coating
Reformulation
1.3
0.0
83
0
Total
7,989.5
73.6
14,492,998
0
Aerosols
CARB Tier 2 Standards - Reform
558.0
0.0
1,395,252
0
Aerosols
SCAQMD Standards
Reformuiati
558.0
0.0
5,581,008
0
Aircraft surface coating
Add-on control levels
0.4
0.0
12,182
0
Automobile refinishing
CARB BARCT limits
143.2
0.0
526,510
0
Automobile refinishing
FIP Rule (VOC Content & TE)
546.6
0.0
9,849,515
0
marine surface coating
Add-on control levels
116.0
0.0
1,680,807
0'
Metal product surface coating
VOC content limits & improved
1,418.3
0.0
46,297
0
Miscellaneous surface coating
Add-on control levels
68.0
0.0
3,978,067
0
Miscellaneous surface coating
MACT level of control
603.1
0.0
1,507,620
0
Nonroad gasoline
Reformulated gasoline
445.1
0.0
2,225,500
0
Open burning
Seasonal/episodic ban
1,949.0
369.9
0
0
Paper surface coating
Add-on control levels
23.3
0.0
2,415,926
0
Pesticide Application
Reformulation - FIP rule
117.3
0.0
1,089,868
0
Point Source Ind. Surface Coating
Add-on Control Levels
4.4
0.0
80,592
0
Point Source Metal Surface FIP VOC Limits
123.4
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
92.7
0.0
2,318
0
Coating
Point Sources
RE Improvements
192,870.8
0.0
385,741,490
0
Recreational vehicles
CARB standards
707.2
0.0
374,763
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,958.0
0.0
48,969
0
Wood furniture surface coating
Reformulation
126.3
0.0
180,870
0
Wood product surface coating
Reformulation
6.4
0.0
272
0
Bakersfield, CA
Baton Rouge, LA
Houston, TX
B-2
-------
Table B-1 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Total 202,435.5
369.9
416,737,826
0
Aerosols
CARB Tier 2 Standards - Reform
1,932.3
0.0
4,830,684
0
Aerosols
SCAQMD Standards
1,932.3
0.0
19,322,736
0
Reformulati
Aircraft surface coating
Add-on control levels
50.2
0.0
1,580,530
0
Automobile refinishing
CARB BARCT limits
1,267.4
0.0
4,661,736
0
Automobile refinishing
FIP Rule (VOC Content & TE)
4,839.0
0.0
87,207,738
0
marine surface coating
Add-on control levels
105.7
0.0
1,529,243
0
Metal product surface coating
VOC content limits & improved
2,019.0
0.0
50,468
0
Miscellaneous surface coating
Add-on control levels
1,712.7
0.0
65,695,922
0
Miscellaneous surface coating
MACT level of control
1,786.9
0.0
4,467,268
0
Nonroad gasoline
Reformulated gasoline
1,159.7
0.0
5,798,500
0
Open Burning
Episodic Ban
5,012.4
952.0
0
0
Paper surface coating
Add-on control levels
34.8
0.0
2,278,878
0
Pesticide Application
Reformulation - FIP rule
140.0
0.0
1,301,442
0
Point Source Ind. Surface Coating Add-on Control Levels
3,073.1
0.0
56,542,004
0
Point Source Metal Surface FIP VOC Limits
1,426.4
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
4,533.3
0.0
113,332
0
Coating
Point Sources
RE Improvements
3,232.8
0.0
6,465,610
0
Recreational vehicles
CARB standards
257.8
0.0
136,567
0
Service stations - stage I-truck un
Vapor balance & P-V valves
5,983.2
0.0
149,578
0
Wood furniture surface coating
Reformulation
3,574.1
0.0
3,554,033
0
Wood product surface coating
Reformulation
46.6
0.0
1,164
0
Total
44,119.7
952.0
265,687,433
0
Aerosols
CARB Tier 2 Standards - Reform
2,249.3
0.0
5,622,954
0
Aerosols
SCAQMD Standards
2,249.4
0.0
22,491,816
0
Reformulati
Aircraft surface coating
Add-on control levels
62.6
0.0
1,897,352
0
Automobile refinishing
CARB BARCT limits
1,271.0
0.0
4,674,744
0
Automobile refinishing
FIP Rule (VOC Content & TE)
4,852.1
0.0
87,451,109
0
marine surface coating
Add-on control levels
113.1
0.0
1,939,338
0
Metal product surface coating
VOC content limits & improved
1,411.7
0.0
145,762
0
Miscellaneous surface coating
Add-on control levels
1,164.2
0.0
52,340,337
0
Miscellaneous surface coating
MACT level of control
17.7
0.0
44,158
0
Motor Vehicles
California Reform
5,922.6 34,883.3
0
191,994,28
3
Nonroad gasoline
Reformulated gasoline
891.3
0.0
4,456,500
0
Open Burning
Episodic Ban
9,058.7
1,718.9
0
0
Paper surface coating
Add-on control levels
193.4
0.0
16,084,868
0
Pesticide Application
Reformulation - FIP rule
53.7
0.0
497,720
0
Point Source Ind. Surface Coating Add-on Control Levels
568.4
0.0
10,456,812
0
Point Source Metal Surface FIP VOC Limits
335.1
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
308.1
0.0
7,702
0
Coating
Point Sources
RE Improvements
30,217.3
0.0
60,434,510
0
Recreational vehicles
CARB standards
1,526.8
0.0
809,122
0
Service stations - stage I-truck un
Vapor balance & P-V valves
4,984.8
0.0
124,640
0
Wood furniture surface coating
Reformulation
2,200.0
0.0
2,341,442
0
Wood product surface coating
Reformulation
34.2
0.0
2,026
0
Total
69,685.5 36,602.2
271,822,912
191,994,28
3
Aerosols
CARB Tier 2 Standards - Reform
325.4
0.0
813.420
0
B-3
Los Angeles, CA
New York, NY
San Diego. CA
-------
Table B-1 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
Reformulati
325.4
0.0
3,253,680
0
Automobile reflnishing
CARB BARCT limits
186.4
0.0
685,506
0
Automobile reflnishing
FIP Rule{VOC Content &TE)
711.6
0.0
12,823,854
0
Metal product surface coating
VOC content limits & improved
241.3
0.0
6,032
0
Miscellaneous surface coating
Add-on control levels
179.2
0.0
4,992,999
0
Miscellaneous surface coating
MACT level of control
396.7
0.0
991,706
0
Nonroad gasoline
Reformulated gasoline
240 9
0.0
1,204,500
0
Open Burning
Episodic Ban
679.7
129.1
0
0
Paper surface coating
Add-on control levels
2.8
0.0
184,069
0
Pesticide Application
Reformulation - FIP rule
20.4
0.0
189,534
0
Point Source Ind. Surface Coating
Add-on Control Levels
936.2
0.0
17,226,540
0
Point Sources
RE Improvements
362.4
0.0
724,890
0
Recreational vehicles
CARB standards
885.1
0.0
469,092
0
Service stations - stage l-truck un
Vapor balance & P-V valves
980.6
0.0
24,516
0
Wood furniture surface coating
Reformulation
734.4
0.0
275,388
0
Wood product surface coating
Reformulation
6.8
0.0
170
0
Total
7,215.3
129.1
43,865,896
0
B-4
-------
Table B-2. Alternative 8H5EX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the RCS
Reductions
Costs
(1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
RACT to small sources
0.0
19.0
0
32,543
LNB
0.0
141.1
0
118,154
SCR
0.0
169.3
0
1,980,056
SNCR - Urea based
0.0
141.1
0
181,642
LNB
0.0
339.2
0
814,003
Oxy-Firing
0.0
84.8
0
2,819,334
SCR
0.0
296.8
0
1,141,514
LNB + FGR
0.0
1.6
0
16,204
SCR
0.0
3.2
0
34,582
LNB + FGR
0.0
23.1
0
147,037
SCR
0.0
46.2
0
435,056
LNB
0.0
16.3
0
11,879
LNB + FGR
0.0
6.5
0
36,100
SCR
0.0
13.0
0
93,950
California Reform
-686.7
13,703.3
0
71,575,206
Enhanced l/M (w/49 State LEV)
2,793.1
2,205.5
550,208
1,100,415
Federal Reform
9,129.6
2,704.6
74,646,07
5
0
Reform Diesel
0.0
481.5
0
25,282,468
CARB Stds for > 175 HP
0.0
309.7
0
2,526,350
Reformulated gasoline
271.9
0.0
1,360,000
0
Episodic Ban
2,033.8
385.8
0
0
SCR
0.0
3.4
0
2,423,615
Total 13,541.7
21,095.0
76,556,28
3
110,770,10
8
CARB Tier 2 Standards - Reform
4Z3
0.0
105,864
0
SCAQMD Standards
Reformulate
42.3
0.0
423,456
0
CARB BARCT limits
18.8
0.0
69,071
0
FIP Rule (VOC Content & TE)
71.7
0.0
1,292,122
0
Add-on control levels
31.3
0.0
722,827
0
VOC content limits & improved
7.7
0.0
845
0
Add-on control levels
3.8
0.0
221,789
0
California Reform
166.3
1,274.4
0
6,071,805
Reformulated gasoline
25.9
0.0
129,500
0
Episodic Ban
243.5
46.2
0
0
Reformulation - FIP rule
6.7
0.0
62,831
0
RE Improvements
139.4
0.0
278,860
0
CARB standards
40.2
0.0
21,229
0
Vapor balance & P-V valves
321.6
0.0
8,040
0
Reformulation
8.6
0.0
10,454
0
Reformulation
0.4
0.0
21
0
Total
1,170.5
1,320.6
3,346,909
6,071,805
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Add-on control levels
0.0
0.0
0
0
CARB BARCT limits
0.0
0.0
0
0
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
VOC content limits & improved
0.0
0.0
0
0
Add-on control levels
0.0
0.0
0
0
MACT level of control
0.0
0.0
0
0
Reformulated gasoline
0.0
0.0
0
0
Atlanta, GA
Atlantic City, NJ
Bakers field, CA
Area Source Industrial NG Comb
Cement Manufacturing - Dry
Cement Manufacturing - Dry
Cement Manufacturing - Dry
Glass Manufacturing - Container
Glass Manufacturing - Container
Glass Manufacturing - Container
Industrial Boiler - Distillate Oil
Industrial Boiler - Distillate Oil
Industrial Boiler - Natural Gas
Industrial Boiler - Natural Gas
Industrial Boiler - Residual Oil
Industrial Boiler • Residual Oil
Industrial Boiler - Residual Oil
Motor Vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
Nonroad Diesels
N on road gasoline
Open Burning
Utility Boiler - Oil-Gas/Tangential
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Motor Vehicles
Nonroad gasoline
Open Burning
Pesticide Application
Point Sources
Recreational vehicles
Service stations - stage I-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
B-5
-------
Table B-2 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
1.1
0.0
76,493
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards'
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.7
0.0
16
0
Total
1.8
0.0
76,509
0
Aerosols
CARB Tier 2 Standards - Reform
5.3
0.0
13,278
0
Aerosols
SCAQMD Standards
91.6
0.0
916,440
0
Reformulati
Automobile refinishing
CARB BARCT limits
0.3
0.0
1,078
0
Automobile refinishing
FIP Rule (VOC Content & TE)
84.7
0.0
1,526,835
0
marine surface coating
Add-on control levels
20.4
0.0
295,101
0
Metal product surface coating
VOC content limits & improved
45.7
0.0
1,419
0
Miscellaneous surface coating
Add-on control levels
2.3
0.0
160,685
0
Miscellaneous surface coating
MACT level of control
1.8
0.0
4.378
0
Motor Vehicles
Federal Reform
1,260.2
385.9
10,568,26
0
Nonroad gasoline
Reformulated gasoline
5.0
0.0
-------
Table B-2 (continued)
Reductions
(tons per year)
Costs
(1990S)
Nonattainment Area Source Category
Control Measure
VOC NOx
VOC
NOx
Wood product surface coating Reformulation
Total
Houston, TX
Los Angeles, CA
New York, NY
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
Open burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
CARS Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
Add-on control levels
CARB BARCT limits
FIP Rule (VOC Content & TE)
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
Reformulated gasoline
Seasonal/episodic ban
Add-on control levels
Reformulation - FIP rule
Add-on Control Levels
FIP VOC Limits
FIP VOC Limits
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
Add-on control levels
CARB BARCT limits
FIP Rule (VOC Content & TE)
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
Add-on Control Levels
FIP VOC Limits
FIP VOC Limits
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
2.5
5,739.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0 62
373.1 19,258,38
6
0
0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
155,763
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
B-7
-------
Table B-2 (continued)
Reductions
(tons per year)
Costs
(1990$)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
190.8
0.0
476,892
0
Aerosols
SCAQMD Standards
Reformulati
190.7
0.0
1,907,568
0
Automobile refinishing
CARB BARCT limits
123.8
0.0
455,517
0
Automobile refinishing
FIP Rule (VOC Content &TE)
472.8
0.0
8,521,420
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
0
Metal product surface coating
VOC content limits & improved
228.4
0.0
5,663
0
Miscellaneous surface coating
Add-on control levels
116.6
0.0
1,886,434
0
Miscellaneous surface coating
MACT level of control
91.7
0.0
229,219
0
Nonroad gasoline
Reformulated gasoline
101.3
0.0
506,500
0
Open Burning
Episodic Ban
429.8
81.3
0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
0
Pesticide Application
Reformulation - FIP rule
113.8
0.0
1,058,898
0
Point Source Ind. Surface Coating
Add-on Control Levels
361.7
0.0
6,655,556
0
Point Source Metal Surface
FIP VOC Limits
313.9
0.0
0
0
Coating
Point Sources
RE Improvements
40.5
0.0
81,030
0
Recreational vehicles
CARB standards
97.3
0.0
51,601
0
Service stations • stage l-truck un
Vapor balance & P-V valves
646.7
0.0
16,167
0
Wood furniture surface coating
Reformulation
240.2
0.0
90,098
0
Wood product surface coating
Reformulation
16.0
0.0
399
0
Total
3,783.3
81.3
22,209,88
8
0
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
B-8
0.0
0.0
0
0
Sacramento, CA
San Diego, CA
-------
Table B-2 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
B-9
-------
Table B-3. Alternative 8H4AX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the RCS
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NO*
VOC
NOx
Area Source Industrial NG Comb
RACT to small sources
0.0
19.0
0
32,543
Cement Manufacturing - Dry
LNB
0.0
141.1
0
118,154
Cement Manufacturing - Dry
SCR
0.0
169.3
0
1,980,056
Cement Manufacturing - Dry
SNCR - Urea based
0.0
141.1
0
181,642
Glass Manufacturing - Container
LNB
0.0
339.2
0
814,003
Glass Manufacturing - Container
Oxy-Firing
0.0
84.8
0
2,819,334
Glass Manufacturing - Container
SCR
0.0
296.8
0
1,141,514
Industrial Boiler - Distillate Oil
LNB + FGR
0.0
1.6
0
16,204
Industrial Boiler - Distillate Oil
SCR
0.0
3.2
0
34,582
Industrial Boiler - Natural Gas
LNB + FGR
0.0
23.1
0
147,037
Industrial Boiler - Natural Gas
SCR
0.0
46.2
0
435,056
Industrial Boiler - Residual Oil
LNB
0.0
16.3
0
11,879
Industrial Boiler - Residual Oil
LNB + FGR
0.0
6.5
0
36,100
Industrial Boiler - Residual Oil
SCR
0.0
13.0
0
93,950
Motor Vehicles
California Reform
-686.7
13,703.3
0
71,575,206
Motor Vehicles
Enhanced l/M (w/49 State LEV)
2,793.1
2,205.5
550,208
1,100,415
Motor Vehicles
Federal Reform
9,129.6
2,704.6
74,646,075
0
Motor Vehicles
Reform Diesel
0.0
481.5
0
25,282,468
Nonroad Diesels
CARB Stds for > 175 HP
0.0
309.7
0
2,526,350
Nonroad gasoline
Reformulated gasoline
271.9
0.0
1,360,000
0
Open Burning
Episodic Ban
2,033.8
385.8
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
3.4
0
2,423,615
Total 13,541.7
21,095.0
76,556,283
110,770,10
g
Aerosols
CARB Tier 2 Standards - Reform
42.3
0.0
105,864
0
Aerosols
SCAQMD Standards
42.3
0.0
423,456
0
Reformulati
Automobile refinishing
CARB BARCT limits
18.8
0.0
69,071
0
Automobile refinishing
FIP Rule (VOC Content & TE)
71.7
0.0
1,292,122
0
marine surface coating
Add-on control levels
31.3
0.0
722,827
0
Metal product surface coating
VOC content limits & improved
7.7
0.0
845
0
Miscellaneous surface coating
Add-on control levels
3.8
0.0
221,789
0
Motor Vehicles
California Reform
166.3
1,274.4
0
6,071,805
Nonroad gasoline
Reformulated gasoline
25.9
0.0
129,500
0
Open Burning
Episodic Ban
243.5
46.2
0
0
Pesticide Application
Reformulation - FIP rule
6.7
0.0
62,831
0
Point Sources
RE Improvements
139.4
0.0
278,860
0
Recreational vehicles
CARB standards
40.2
0.0
21,229
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
321.6
0.0
8,040
0
Wood furniture surface coating
Reformulation
8.6
0.0
10,454
0
Wood product surface coating
Reformulation
0.4
0.0
21
0
Total
1,170.5
1,320.6
3,346,909
6,071,805
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
0.0
0.0
0
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Atlanta, GA
Atlantic City, NJ
Bakersfield, CA
B-10
-------
Table B-3 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area Source Category
Control Measure
VOC NOx
VOC
NOx
Baton Rouge, LA
Fresno, CA
Houston, TX
Paper surface coating
Pesticide Application
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
N on road gasoline
Open burning
Paper surface coating
Pesticide Application
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Adhesives - industrial
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
Bulk Terminals
Cutback Asphalt
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
N on road gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Metal Surface
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
Add-on control levels
Reformulation - FIP rule
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
CARB BARCT limits
FIP Rule (VOC Content & TE)
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
Federal Reform
Reformulated gasoline
Seasonal/episodic ban
Add-on control levels
Reformulation - FIP rule
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
RACT
CARB Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
CARB BjARCT limits
FIP Rule (VOC Content & TE)
RACT
Switch to emulsified asphalts
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
Enhanced t/V
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
FIP VOC Limits
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
1.1
0.0
0.0
0.0
0.0
0.0
0.7
1.8
5.3
91.6
0.0
0.0
0.0
0.0
00
0.0
0.0
0.0
0.0
0.0
76,493
0
0
0
0
0
16
76,509
13,278
916,440
0.3
0.0
1,078
84.7
0.0
1,526,835
20.4
0.0
295,101
45.7
0.0
1,419
2.3
0.0
160,685
1.8
0.0
4,378
1,260.2
385.9
10,568,265
5.0
0.0
25,000
42.5
8.1
0
4.5
0.0
467,671
36.9
0.0
343,654
902.3
0.0
1,804,560
23.1
0.0
12,266
11.4
0.0
286
0.0
0.0
0
0.0
0.0
0
2,538.0
394.0
16,140,916
1.3
0.0
3,276
100.5
0.0
251,094
100.5
0.0
1,004,376
51.8
0.0
190,706
198.0
0.0
3,567,537
21.8
0.0
36,371
14.0
0.0
0
11.1
0.0
160,048
67.4
0.0
1,680
83.5
0.0
1,305,006
24.1
0.0
60,127
194.8
329.3
77,881
53.6
0.0
268,000
230.7
43.8
0
4.0
0.0
267,273
530.9
0.0
4,937,073
52.6
0.0
0
3,512.0
0.0
7,024,060
51.9
0.0
27,517
339.5
0.0
41,403
93.1
0.0
34,896
2.5
0.0
62
5,739.6
373.1
19,258,386
0.0
0.0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
155,763
0
0
0
0
0
0
0
0
0
0
155,763
0
B-ll
-------
Table B-3 (continued)
Reductions
(tons per year)
Costs
Source Category
Control Measure
VOC
NOx
VOC NOx
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile reflnishing
CARB BARCT limits
0.0
0.0
0
0
Automobile reflnishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open burning
Seasonal/episodic ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
46.7
0.0
116,760
0
Aerosols
SCAQMD Standards
Reformulati
46.7
0.0
467,040
0
Automobile refinishing
CARB BARCT limits
30.0
0.0
110,381
0
Automobile refinishing
FIP Rule (VOC Content & TE)
114.6
0.0
2,064,926
0
Metal product surface coating
VOC content limits & improved
352.8
0.0
8,725
0
Los Angeles, CA
Modesto, CA
B-12
-------
Table B-3 (continued)
Reductions
Costs
New York, NY
Philadelphia, PA
Source Category
Control Measure
VOC
NOx
VOC
NOx
Miscellaneous surface coating
Add-on control levels
54.2
0.0
1,006,908
0
Miscellaneous surface coating
MACT level of control
17.1
0.0
42,760
0
Nonroad gasoline
Reformulated gasoline
25.1
0.0
125,500
0
Open Burning
Episodic Ban
97.6
18.5
0
0
Paper surface coating
Add-on control levels
9.4
0.0
632,619
0
Pesticide Application
Reformulation - FIP rule
108.9
0.0
1,012,621
0
Point Source Ind. Surface Coating Add-on Control Levels
74.1
0.0
1,363,348
0
Point Source Metal Surface FIP VOC Limits
61.0
0.0
0
0
Coating
Recreational vehicles
CARB standards
24.4
0.0
12,907
0
Service stations - stage l-truck un
Vapor balance & P-V valves
131.9
00
3.297
0
Wood furniture surface coating
Reformulation
78.4
00
29,408
0
Wood product surface coating
Reformulation
2.5
0.0
63
0
Total
1,285.4
18.5
6,997,263
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V vatves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
849.5
0.0
2,124.030
0
Aerosols
SCAQMD Standards
Reformulati
849.6
0.0
8,496.120
0
Aircraft surface coating
Add-on control levels
28.0
0.0
1,012,040
0
Automobile refinishing
CARB BARCT limits
550.3
0.0
2,023,964
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,101.0
0.0
37,862,493
0
marine surface coating
Add-on control levels
138.1
0.0
2,413,661
0
Metal product surface coating
VOC content limits & improved
661.9
0.0
23,283
0
Miscellaneous surface coating
Add-on control levels
369.8
0.0
19,157,461
0
Miscellaneous surface coating
MACT level of control
49.0
0.0
122,400
0
Motor Vehicles
California Reform
2,768.4
16,305.2
0
83,136,982
Nonroad gasoline
Reformulated gasoline
516.8
0.0
2,584,000
0
Open Burning
Episodic Ban
2,582.6
489.7
0
0
Paper surface coating
Add-on control levels
68.2
0.0
5,050,766
0
B-13
-------
Table B-3 (continued)
Portland, OR
Sacramento, CA
San Diego, CA
Reductions
Costs
(tons per year)
(1990S)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Pesticide Application
Reformulation - FIP rule
122.7
0.0
1,140,144
0
Point Source Ind. Surface Coating
Add-on Control Levels
5,061.8
0.0
93,137,488
0
Point Source Metal Surface
FIP VOC Limits
366.2
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
97.1
0.0
2,427
0
Coating
Point Sources
RE Improvements
30,474.2
0.0
60,948,430
0
Recreational vehicles
CARB standards
799.6
0.0
423,651
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,028.7
0.0
50,721
0
Wood furniture surface coating
Reformulation
841.2
0.0
884,447
0
Wood product surface coating
Reformulation
13.2
0.0
477
0
Total
51,337.9
16,794.9
237,458,00
3
83,136,982
Bulk Terminals
RACT
219.5
0.0
365,885
0
Cutback Asphalt
Switch to emulsified asphalts
208.2
0.0
0
0
Metal product surface coating
VOC content limits & improved
382.9
0.0
9,546
0
Motor Vehicles
Enhanced l/M
10,296.0
9,747.0
1,458,678
2,917,357
Open Burning
Episodic Ban
2,140.3
405.9
0
0
Pharmaceutical manufacture
RACT
4.2
0.0
1,408
0
Point Source Metal Surface
FIP VOC Limits
139.8
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
217.2
0.0
5,429
0
Coating
Point Sources
RE Improvements
19,187.0
0.0
38,373,910
0
Recreational vehicles
CARB standards
379.1
0.0
200,932
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,190.7
0.0
381,602
0
SOCMI fugitives
RACT
12.7
0.0
1,729
0
Web Offset Lithography
New CTG (carbon adsorber)
249.0
0.0
-31,123
0
Wood furniture surface coating
Reformulation
466.6
0.0
175,013
0
Wood product surface coating
Reformulation
42.0
0.0
1,745
0
Total
35,135.2 10,152.9
40,944,754
2,917,357
Aerosols
CARB Tier 2 Standards - Reform
190.8
0.0
476,892
0
Aerosols
SCAQMD Standards
190.7
0.0
1,907,568
0
Reformulati
Automobile refinishing
CARB BARCT limits
123.8
0.0
455,517
0
Automobile refinishing
FIP Rule (VOC Content & TE)
472.8
0.0
8,521,420
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
0
Metal product surface coating
VOC content limits & improved
228.4
0.0
5,663
0
Miscellaneous surface coating
Add-on control levels
116.6
0.0
1,886,434
0
Miscellaneous surface coating
MACT level of control
91.7
0.0
229,219
0
Nonroad gasoline
Reformulated gasoline
101.3
0.0
506,500
0
Open Burning
Episodic Ban
429.8
81.3
0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
0
Pesticide Application
Reformulation - FIP rule
113.8
0.0
1,058,898
0
Point Source Ind. Surface Coating
Add-on Control Levels
361.7
0.0
6,655,556
0
Point Source Metal Surface
FIP VOC Limits
313.9
0.0
0
0
Coating
Point Sources
RE Improvements
40.5
0.0
81,030
0
Recreational vehicles
CARB standards
97.3
0.0
51,601
0
Service stations - stage l-truck un
Vapor balance & P-V valves
646.7
0.0
16,167
0
Wood furniture surface coating
Reformulation
240.2
0.0
90,098
0
Wood product surface coating
Reformulation
16.0
0.0
399
0
Total
3,783.3
81.3
22,209,888
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
B-14
-------
Table B-3 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Visalia, CA Aerosols
CARB Tier 2 Standards - Reform
42.6
0.0
106,380
0
Automobile refinishing
CARB BARCT limits
11.2
0.0
41,327
0
Automobile refinishing
FIP Rule (VOC Content & TE)
42.9
0.0
773,106
0
Metal product surface coating
VOC content limits & improved
49.9
0.0
1,238
0
Miscellaneous surface coating
Add-on control levels
22.0
0.0
333,737
0
Miscellaneous surface coating
MACT level of control
19.7
0.0
49,270
0
Nonroad gasoline
Reformulated gasoline
23.1
0.0
115,500
0
Open Burning
Episodic Ban
93.7
17.7
0
0
Paper surface coating
Add-on control levels
1.1
0.0
76,493
0
Pesticide Application
Reformulation - FIP rule
250.4
0.0
2,329,073
0
Recreational vehicles
CARB standards
22.4
0.0
11,867
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
110.8
0.0
2,770
0
Wood furniture surface coating
Reformulation
8.2
0.0
3,088
0
Wood product surface coating
Reformulation
2.7
0.0
67
0
Total
700.7
17.7
3,843,916
0
B-15
-------
Table B-4. Alternative 8H1AX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the RCS
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Area Source Industrial NG Comb
RACT to small sources
0.0
40.0
0
68,692
Cement Manufacturing - Dry
LNB
0.0
141.1
0
118,154
Cement Manufacturing - Dry
SCR
0.0
169.3
0
1,980,056
Cement Manufacturing - Dry
SNCR - Urea based
0.0
141.1
0
181,642
Glass Manufacturing - Container
LNB
0.0
339.2
0
814,003
Glass Manufacturing - Container
Oxy-Firing
0.0
84.8
0
2,819,334
Glass Manufacturing - Container
SCR
0.0
296.8
0
1,141,514
Industrial Boiler - Distillate Oil
LNB
0.0
16.2
0
22,570
Industrial Boiler - Distillate Oil
LNB + FGR
0.0
4.5
0
44,896
Industrial Boiler - Distillate Oil
SCR
0.0
9.1
0
95,822
Industrial Boiler - Natural Gas
LNB
0.0
76.1
0
69,300
Industrial Boiler - Natural Gas
LNB + FGR
0.0
38.1
0
237,338
Industrial Boiler - Natural Gas
SCR
0.0
76.2
0
702,239
Industrial Boiler - PC
LNB
0.0
229.5
0
369,572
Industrial Boiler - PC
SCR
0.0
68.9
0
1,770,659
Industrial Boiler - PC
SNCR
0.0
45.9
0
569,962
Industrial Boiler - Residual Oil
LNB
0.0
175.3
0
129,287
Industrial Boiler - Residual Oil
LNB + FGR
0.0
38.3
0
209,562
Industrial Boiler - Residual Oil
SCR
0.0
76.6
0
545,406
Motor Vehicles
California Reform
-715.0
14,570.6
0
75,035,816
Motor Vehicles
Enhanced l/M (w/49 State LEV)
4,867.6
3,819.7
952,657
1,905,313
Motor Vehicles
Federal Reform
9,600.3
2,839.1
78,262,901
0
Motor Vehicles
Reform Diesel
0.0
520.4
0
27,274,484
Nonroad Diesels
CARB Stds for > 175 HP
0.0
326.6
0
2,664,317
Nonroad gasoline
Reformulated gasoline
286.4
0.0
1,432,000
0
Open Burning
Episodic Ban
2,436.9
462.1
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
3.4
0
2,423,615
Total 16,476.2
24,608.9
80,647,558
121,193,55
3
Aerosols
CARB Tier 2 Standards - Reform
42.3
0.0
105,864
0
Aerosols
SCAQMD Standards
42.3
0.0
423,456
0
Reformulati
Automobile refinishing
CARB BARCT limits
18.8
0.0
69,071
0
Automobile refinishing
FIP Rule (VOC Content & TE)
71.7
0.0
1,292,122
0
marine surface coating
Add-on control levels
31.3
0.0
722,827
0
Metal product surface coating
VOC content limits & improved
7.7
0.0
845
0
Miscellaneous surface coating
Add-on control levels
3.8
0.0
221,789
0
Motor Vehicles
California Reform
166.3
1,274.4
0
6,071,805
Nonroad gasoline
Reformulated gasoline
25.9
0.0
129,500
0
Open Burning
Episodic Ban
243.5
46.2
0
0
Pesticide Application
Reformulation - FIP rule
6.7
0.0
62,831
0
Point Sources
RE Improvements
139.4
0.0
278,860
0
Recreational vehicles
CARB standards
40.2
0.0
21,229
0
Service stations • stage l-truck un
Vapor balance & P-V valves
321.6
0.0
8,040
0
Wood furniture surface coating
Reformulation
8.6
0.0
10,454
0
Wood product surface coating
Reformulation
0.4
0.0
21
0
Total
1,170.5
1,320.6
3,346,909
6,071,805
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
0.0
0.0
0
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content &TE)
0.0
0.0
0
0
Atlanta, GA
Atlantic City, NJ
Bakersfield, CA
B-16
-------
Table B-4 (continued)
Reductions
Costs
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
VOC content limits & improved
0.0
0.0
0
0
Add-on control levels
0.0
0.0
0
0
MACT level of control
0.0
0.0
0
0
Reformulated gasoline
0.0
0.0
0
0
Episodic Ban
0.0
0.0
0
0
Reformulation - FIP rule
0.0
0.0
0
0
RE Improvements
0.0
0.0
0
0
CARB standards
0.0
0.0
0
0
Vapor balance & P-V valves
0.0
0.0
0
0
Reformulation
0.0
0.0
0
0
Reformulation
0.7
0.0
16
0
Total
0.7
0.0
16
0
RACT
2.9
0.0
7,333
0
CARB Tier 2 Standards - Reform
838.8
0.0
2,096,568
0
SCAQMD Standards
838.9
0.0
8,386,272
0
Reformulati
Add-on control levels
20.3
0.0
727,841
0
CARB BARCT limits
441.1
0.0
1,622,379
0
FIP Rule (VOC Content &TE)
1,683.9
0.0
30,350,042
0
Switch to emulsified asphalts
11.6
0.0
0
0
Add-on control levels
116.2
0.0
1,679,127
0
VOC content limits & improved
600.4
0.0
26,412
0
Add-on control levels
260.3
0.0
5,369,000
0
MACT level of control
131.2
0.0
327,585
0
Enhanced l/M (w/49 State LEV)
4,219.6
4,304.6
1,004,762
2,009,525
Federal Reform
449.5
131.0
3,989,469
0
Reformulated gasoline
541.9
0.0
2,709,500
0
Episodic Ban
829.7
158.1
0
0
Add-on control levels
40.0
0.0
2,915,609
0
Reformulation - FIP rule
272.8
0.0
2,535,796
0
Add-on Control Levels
147.5
0.0
2,713,264
0
FIP VOC Limits
824.2
0.0
0
0
FIP VOC Limits
7.3
0.0
183
0
RE Improvements
5,980.0
0.0
11,960,320
0
CARB standards
785.1
0.0
416,107
0
Vapor balance & P-V valves
2,761.0
0.0
80,261
0
New CTG (carbon adsorber)
0.4
0.0
-45
0
Reformulation
1,033.9
0.0
395,887
0
Reformulation
18.6
0.0
602
0
Total 22,857.1
4,593.7
79,314,274
2,009,525
CARB Tier 2 Standards - Reform
5.3
0.0
13,278
0
SCAQMD Standards
91.6
0.0
916,440
0
Reformulati
CARB BARCT limits
0.3
0.0
1,078
0
FIP Rule (VOC Content & TE)
84.7
0.0
1,526,835
0
Add-on control levels
20.4
0.0
295,101
0
VOC content limits & improved
45.7
0.0
1,419
0
Add-on control levels
2.3
0.0
160,685
0
MACT level of control
1.8
0.0
4,378
0
Federal Reform
1,260.2
385.9
10,568,265
0
Reformulated gasoline
5.0
0.0
25,000
0
Baltimore-Washington,
DC
Baton Rouge, LA
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
Open Burning
Pesticide Application
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Adhesives - industrial
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
Cutback Asphalt
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
Motor Vehicles
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Web Offset Lithography
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
Nonroad gasoline
B-17
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
42.5
8.1
0
0
4.5
0.0
467,671
0
36.9
0.0
343,654
0
902.3
0.0
1,804,560
0
23.1
0.0
12,266
0
11.4
0.0
286
0
0.0
0.0
0
0
0.0
0.0
0
0
2,538.0
394.0
16,140,916
0
43.3
0.0
1,746
0
313.4
59.3
0
0
22.6
0.0
0
0
96,693.2
0.0
193,386,49
0
0
69.9
0.0
36,998
0
220.0
0.0
5,502
0
6.7
0.0
9,574
0
0.8
0.0
27
0
97,369.9
59.3
193,440,33
7
0
17.5
0.0
43,823
0
1,188.1
0.0
2,969,826
0
1,188.1
0.0
11,879,304
0
8.5
0.0
288,264
0
662.6
0.0
2,436,920
0
2,529.6
0.0
45,587,801
0
89.0
0.0
148,271
0
27.3
0.0
0
0
99.5
0.0
1,440,735
0
3,362.5
0.0
119,678
0
1,416.8
0.0
36,920,959
0
1,271.3
0.0
3,177,986
0
3,819.6 21,388.4
0
110,921,38
5
357.5
304.4
75,325
150,650
70.8
24.8
679,832
0
567.8
0.0
2,839,000
0
2,378.8
451.4
0
0
25.4
0.0
2,636,415
0
314.4
0.0
2,923,605
0
3,315.7
0.0
61,008,144
0
6,953.0
0.0
0
0
78.8
0.0
1,971
0
9,246.9
0.0
18,493,820
0
1,358.2
0.0
719,732
0
3,158.0
0.0
139,715
0
2.6
0.0
-326
0
1,097.1
0.0
1,485,499
0
25.3
0.0
650
0
44,630.7 22,169.0
196,016,94
9
111,072,03
5
Beaumont, TX
Chicago, IL
Open burning
Paper surface coating
Pesticide Application
Point Sources
Recreational vehicles
Sen/ice stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Metal product surface coating
Open Burning
Point Source Metal Surface
Coating
Point Sources
Seasonal/episodic ban
Add-on control levels
Reformulation - FIP rule
RE Improvements
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
VOC content limits & improved
Episodic Ban
FIP VOC Limits
RE Improvements
Recreational vehicles CARB standards
Service stations - stage l-tnick un Vapor balance & P-V valves
Wood furniture surface coating Reformulation
Wood product surface coating Reformulation
Adhesives - industrial
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
Bulk Terminals
Cutback Asphalt
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
Motor Vehicles
Motor Vehicles
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
Web Offset Lithography
Wood furniture surface coating
Wood product surface coating
RACT
CARB Tier 2 Standards • Reform
SCAQMD Standards
Reformulati
Add-on control levels
CARB BARCT limits
FIP Rule (VOC Content & TE)
RACT
Switch to emulsified asphalts
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
California Reform
Enhanced l/M (w/49 State LEV)
Federal Reform
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
Add-on Control Levels
FIP VOC Limits
FIP VOC Limits
RE Improvements
CARB standards
Vapor balance & P-V valves
New CTG (carbon adsorber)
Reformulation
Reformulation
Total
B-18
-------
Table B-4 (continued)
Nonattainment Area
Reductions
Costs
(tons per year)
(1990$)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Adhesives - industrial
RACT
79.4
0.0
198,526
0
Aerosols
CARB Tier 2 Standards - Reform
270.2
0.0
675,798
0
Aerosols
SCAQMD Standards
Reformulati
270.2
0.0
2,703,192
0
Aircraft surface coating
Add-on control levels
51.8
0.0
1,873,198
0
Automobile refinishing
CARB BARCT limits
100.6
0.0
370,237
0
Automobile refinishing
FIP Rule (VOC Content & TE)
384.2
0.0
6,926,038
0
Bulk Terminals
RACT
134.5
0.0
224,072
0
Cutback Asphalt
Switch to emulsified asphalts
70.0
0.0
0
0
marine surface coating
Add-on control levels
9.9
0.0
143,004
0
Metal product surface coating
VOC content limits & improved
233.8
0.0
6,817
0
Miscellaneous surface coating
Add-on control levels
323.3
0.0
11,922,127
0
Miscellaneous surface coating
MACT level of control
42.5
0.0
106,099
0
Motor Vehicles
California Reform
955.8
6,134.8
0
30,656,109
Motor Vehicles
Enhanced l/M (w/49 State LEV)
18,368.9
13,119.3
675,395
1,350,789
Motor Vehicles
Federal Reform
3,876.3
938.1
26,812,203
0
Nonroad gasoline
Reformulated gasoline
138.6
0.0
693,000
0
Open Burning
Episodic Ban
1,973.1
375.1
0
0
Paper surface coating
Add-on control levels
43.0
0.0
3,019,753
0
Pesticide Application
Reformulation - FIP rule
95.9
0.0
890,829
0
Point Source Ind. Surface Coating Add-on Control Levels
155.1
0.0
2,854,300
0
Point Source Metal Surface FIP VOC Limits
455.9
0.0
0
0
Coating
Point Sources
RE Improvements
857.1
0.0
1,714,040
0
Recreational vehicles
CARB standards
202.5
0.0
107,319
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
852.4
0.0
119,526
0
Web Offset Lithography
New CTG (carbon adsorber)
8.0
0.0
•989
0
Wood furniture surface coating
Reformulation
746.9
0.0
315,871
0
Wood product surface coating
Reformulation
8.7
0.0
228
0
Total
30,708.6
20,567.3
62,350,583
32,006,898
Adhesives - industrial
RACT
206.5
0.0
516,108
0
Aerosols
CARB Tier 2 Standards - Reform
569.3
0.0
1,423,242
0
Aerosols
SCAQMD Standards
Reformulati
569.2
0.0
5,692,968
0
Aircraft surface coating
Add-on control levels
10.9
0.0
344,747
0
Automobile refinishing
CARB BARCT limits
275.8
0.0
1,014,479
0
Automobile refinishing
FIP Rule (VOC Content & TE)
1,053.2
0.0
18,977,998
0
Bulk Terminals
RACT
443.3
0.0
738,704
0
Cutback Asphalt
Switch to emulsified asphalts
348.1
0.0
0
0
marine surface coating
Add-on control levels
!5-1
0.0
218,518
0
Metal product surface coating
VOC content limits & improved
1,160.4
0.0
41,375
0
Miscellaneous surface coating
Add-on control levels
738.0
0.0
17,418,524
0
Miscellaneous surface coating
MACT level of control
836.2
0.0
2,090,260
0
Motor Vehicles
Enhanced l/M (w/49 State LEV)
32,776.9
29,743.0
2,029,995
4,059,989
Motor Vehicles
Federal Reform
1,320.5
283.2
7,756,926
0
Nonroad gasoline
Reformulated gasoline
478.5
0.0
2,392,500
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
34.9
0.0
13,809
0
Open Burning
Episodic Ban
2,152.8
408.2
0
0
Paper surface coating
Add-on control levels
69.3
0.0
6,065,109
0
Pesticide Application
Reformulation - FIP rule
153.4
0.0
1,426,100
0
Petroleum refinery fugitives
RACT
167.1
0.0
-75,186
0
Pharmaceutical manufacture
RACT
1.3
0.0
417
0
Point Source Ind. Surface Coating Add-on Control Levels
4,042.7
0.0
74,386,416
0
Cincinnati. OH
Dallas, TX
B-19
-------
Table B-4 (continued)
Nonattainment Area
Reductions
(tons per year)
Costs
(1990$)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Point Source Metal Surface FIP VOC Limits
Coating
204.0
0.0
0
0
Point Source Open Burning
Episodic Ban
9.1
0.0
0
0
Point Source Wood Product FIP VOC Limits
Coating
208.0
0.0
5,202
0
Point Sources
RE Improvements
14,125.2
0.0
28,250,270
0
Recreational vehicles
CARB standards
761.1
0.0
403,346
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,505.1
0.0
592,835
0
SOCMI batch reactor processes
New CTG
1.7
0.0
7,007
0
SOCMI fugitives
RACT
1.0
0.0
141
0
Web Offset Lithography
New CTG (carbon adsorber)
30.3
0.0
-3,789
0
Wood furniture surface coating
Reformulation
695.0
0.0
586,526
0
Wood product surface coating
Reformulation
15.0
0.0
857
0
Total 65,978.9 30,434.4
172,315,40
4
4,059,989
Adhesives - industrial
RACT
398.9
0.0
997,164
0
Aerosols
CARB Tier 2 Standards - Reform
67.3
0.0
168,276
0
Automobile refinishing
CARB BARCT limits
27.4
0.0
100,653
0
Bulk Terminals
RACT
173.6
0.0
289,200
0
Cutback Asphalt
Switch to emulsified asphalts
351.5
0.0
0
0
Metal product surface coating
VOC content limits & improved
92.8
0.0
2,314
0
Miscellaneous surface coating
MACT level of control
49.2
0.0
122,853
0
Motor Vehicles
Enhanced l/M
2,659.9
2,365.1
951,535
1,903,069
Nonroad gasoline
Reformulated gasoline
34.8
0.0
174,000
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
1.2
0.0
470
0
Open Burning
Episodic Ban
473.9
89.9
0
0
Recreational vehicles
CARB standards
75.8
0.0
40,095
0
Service stations - stage l-truck un
Vapor balance & P-V valves
358.9
0.0
186,182
0
Web Offset Lithography
New CTG (carbon adsorber)
67.6
0.0
-8,447
0
Wood furniture surface coating
Reformulation
114.8
0.0
43,029
0
Wood product surface coating
Reformulation
58.6
0.0
1,464
0
Total
5,006.2
2.455.0
3,068,788
1,903,069
Aerosols
CARB Tier 2 Standards - Reform
104.9
0.0
262,200
0
Aerosols
SCAQMD Standards
Reformulati
104.9
0.0
1,048,800
0
Automobile refinishing
FIP Rule (VOC Content & TE)
173.8
0.0
5,062,064
0
Metal product surface coating
VOC content limits & improved
82.5
0.0
11,089
0
Miscellaneous surface coating
Add-on control levels
45.0
0.0
2,937,767
0
Motor Vehicles
California Reform
414.2
2,580.7
0
14,343,658
Nonroad gasoline
Reformulated gasoline
71.6
0.0
358,000
0
Paper surface coating
Add-on control levels
3.1
0.0
313,572
0
Pesticide Application
Reformulation - FIP rule
1.0
0.0
8,816
0
Point Source Ind. Surface Coating Add-on Control Levels
39.4
0.0
725,328
0
Recreational vehicles
CARB standards
218.0
0.0
115,514
0
Service stations - stage l-truck un
Vapor balance & P-V valves
349.8
0.0
8,745
0
Wood furniture surface coating
Reformulation
23.6
0.0
37,782
0
Wood product surface coating
Reformulation
3.1
0.0
80
0
Total
1,634.9
2,580.7
10,889,757
14,343,658
Adhesives • industrial
RACT
14.2
0.0
35,444
0
Aerosols
CARB Tier 2 Standards - Reform
119.6
0.0
298,638
0
Aerosols
SCAQMD Standards
Reformulati
119.6
0.0
1,194,552
0
Automobile refinishing
CARB BARCT limits
58.9
0.0
217,170
0
Automobile refinishing
FIP Rule (VOC Content & TE)
225.5
0.0
4,062,635
0
Eugene, OR
Fairfield, CT
Fresno, CA
B-20
-------
Table B-4 (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Bulk Terminals
RACT
57.2
0.0
95,380
0
Cutback Asphalt
Switch to emulsified asphalts
57.0
0.0
0
0
marine surface coating
Add-on control levels
11.1
0.0
160,048
0
Metal product surface coating
VOC content limits & improved
77.5
0.0
1,931
0
Miscellaneous surface coating
Add-on control levels
93.6
0.0
1,460,681
0
Miscellaneous surface coating
MACT level of control
27.8
0.0
69,321
0
Motor Vehicles
Enhanced l/M
750.9
1,264.0
298,651
597,301
Nonroad gasoline
Reformulated gasoline
63.0
0.0
315,000
0
Open Burning
Episodic Ban
276.4
52.4
0
0
Paper surface coating
Add-on control levels
4.5
0.0
298,193
0
Pesticide Application
Reformulation - FIP rule
742.3
0.0
6,903,465
0
Point Source Metal Surface FIP VOC Limits
52.6
0.0
0
0
Coating
Point Sources
RE Improvements
3,519.3
0.0
7,038,660
0
Recreational vehicles
CARB standards
60.8
0.0
32,225
0
Service stations - stage l-truck un
Vapor balance & P-V valves
454.2
0.0
103,431
0
Web Offset Lithography
New CTG (carbon adsorber)
4.1
0.0
-508
0
Wood furniture surface coating
Reformulation
102.1
0.0
38,279
0
Wood product surface coating
Reformulation
6.2
0.0
154
0
Total
6,898.4
1,316.4
22,623,350
597,301
Adhesives - industrial
RACT
130.6
0.0
326,390
0
Aerosols
CARB Tier 2 Standards - Reform
102.6
0.0
256,368
0
Aerosols
SCAQMD Standards
Reformulati
102.6
0.0
1,025,472
0
Aircraft surface coating
Add-on control levels
3.7
0.0
132,865
0
Automobile refinishing
CARB BARCT limits
62.2
0.0
228,904
0
Automobile refinishing
FIP Rule (VOC Content &TE)
237.6
0.0
4,282,146
0
Cutback Asphalt
Switch to emulsified asphalts
85.3
0.0
0
0
marine surface coating
Add-on control levels
68.1
0.0
985,510
0
Metal product surface coating
VOC content limits & improved
199.1
0.0
4,981
0
Miscellaneous surface coating
Add-on control levels
1,366.5
0.0
31,117,326
0
Motor Vehicles
California Reform
364.6
2,984.1
0
13,408,026
Motor Vehicles
Enhanced l/M (w/49 State LEV)
8,035.8
5,841.0
409,302
818,603
Motor Vehicles
Federal Reform
1,844.4
488.6
13,996,171
0
Nonroad gasoline
Reformulated gasoline
101.6
0.0
508,000
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
37.2
0.0
14,770
0
Open Burning
Episodic Ban
648.1
122.9
0
0
Paper surface coating
Add-on control levels
22.2
0.0
1,402,309
0
Pesticide Application
Reformulation - FIP rule
72.5
0.0
673,506
0
Pharmaceutical manufacture
RACT
138.2
0.0
46,285
0
Point Sources
RE Improvements
6,025.1
0.0
12,050,110
0
Recreational vehicles
CARB standards
548.1
0.0
290,468
0
Service stations - stage l-truck un
Vapor balance & P-V valves
292.2
0.0
7,305
0
Web Offset Lithography
New CTG (carbon adsorber)
8.5
0.0
-1,067
0
Wood furniture surface coating
Reformulation
4,967.9
0.0
1,862,987
0
Wood product surface coating
Reformulation
6.5
0.0
298
0
Total 25,471.2
9,436.6
69,620,406
14,226,629
Aerosols
CARB Tier 2 Standards - Reform
159.0
0.0
397,518
0
Aerosols
SCAQMD Standards
Reformulati
159.1
0.0
1,590,072
0
Aircraft surface coating
Add-on control levels
116.4
0.0
6,094,635
0
Automobile refinishing
FIP Rule (VOC Content & TE)
298.6
0.0
8,697,450
0
Metal product surface coating
VOC content limits & improved
103.8
0.0
13,957
0
Miscellaneous surface coating
Add-on control levels
88.4
0.0
6,479,450
0
Grand Rapids, Ml
Hartford, CT
B-21
-------
Table EM (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
California Reform
708.0
4,400.2
0
22,365,569
Nonroad gasoline
Reformulated gasoline
112.5
0.0
562,500
0
Open Burning
Episodic Ban
890.4
168.9
0
0
Paper surface coating
Add-on control levels
22.7
0.0
2,278,121
0
Pesticide Application
Reformulation - FIP rule
15.3
0.0
141,676
0
Point Source Ind. Surface Coating
Add-on Control Levels
5.8
0.0
107,456
0
Point Source Metal Surface
FIP VOC Limits
102.9
0.0
0
0
Coating
Recreational vehicles
CARB standards
342.0
0.0
181,179
0
Service stations - stage l-truck un
Vapor balance & P-V valves
508.9
0.0
12,723
0
Wood furniture surface coating
Reformulation
92.0
0.0
146,938
0
Wood product surface coating
Reformulation
5.5
0.0
136
0
Total
3,731.3
4,569.1
26,703,811
22,365,569
Adhesives - industrial
RACT
27.2
0.0
68,115
0
Aerosols
CARB Tier 2 Standards - Reform
17.9
0.0
44,754
0
Aerosols
SCAQMD Standards
Reform ulati
17.8
0.0
179,016
0
Automobile refinishing
CARB BARCT limits
2.7
0.0
10,196
0
Automobile refinishing
FIP Rule (VOC Content & TE)
10.6
0.0
190,748
0
Bulk Terminals
RACT
203.7
0.0
339,507
0
Cutback Asphalt
Switch to emulsified asphalts
112.6
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
5.1
0.0
129
0
Miscellaneous surface coating
Add-on control levels
2.6
0.0
46,902
0
Miscellaneous surface coating
MACT level of control
2.2
0.0
5,479
0
Motor Vehicles
Enhanced l/M (w/49 State LEV)
1,635.5
1,168.2
291,551
583,101
Motor Vehicles
Federal Reform
456.6
99.0
2,622,337
0
Nonroad gasoline
Reformulated gasoline
13.7
0.0
68,500
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
11.8
0.0
4,674
0
Open burning
Seasonal/episodic ban
73.7
13.8
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
105.6
0.0
981,616
0
Point Source Ind. Surface Coating
Add-on Control Levels
85.0
0.0
1,564,828
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
62.8
0.0
1,570
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
21.5
0.0
11,363
0
Service stations - stage l-truck un
Vapor balance & P-V valves
260.9
0.0
195,467
0
Web Offset Lithography
New CTG (carbon adsorber)
10.5
0.0
-1,319
0
Wood furniture surface coating
Reformulation
12.1
0.0
4,536
0
Wood product surface coating
Reformulation
1.5
0.0
38
0
Total
3,153.6
1,281.0
6,630,007
583,101
Adhesives - industrial
RACT
23.8
0.0
59,522
0
Aerosols
CARB Tier 2 Standards - Reform
51.1
0.0
127,602
0
Aerosols
SCAQMD Standards
Reform ulati
51.1
0.0
510,408
0
Automobile refinishing
CARB BARCT limits
12.6
0.0
46,575
0
Automobile refinishing
FIP Rule (VOC Content & TE)
48.4
0.0
871,265
0
Bulk Terminals
RACT
36.6
0.0
60,913
0
Cutback Asphalt
Switch to emulsified asphalts
77.5
0.0
0
0
marine surface coating
Add-on control levels
5.7
0.0
82,393
0
Metal product surface coating
VOC content limits & improved
43.3
0.0
1,721
0
Houston, TX
Huntington, WV
B-22
-------
Table B-4 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Miscellaneous surface coating
Add-on control levels
10.0
0.0
164,121
0
Miscellaneous surface coating
MACT level of control
13.7
0.0
34,223
0
Motor Vehicles
California Reform
145.1
1,267.4
0
5,466,889
Motor Vehicles
Enhanced l/M (w/49 State LEV)
3,256.8
2,435.5
263,196
526,392
Motor Vehicles
Federal Reform
729.3
205.3
5,708,990
0
Nonroad gasoline
Reformulated gasoline
23.7
0.0
118,500
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
0.5
0.0
188
0
Open Burning
Episodic Ban
443.0
83.6
0
0
Paper surface coating
Add-on control levels
0.5
0.0
38,060
0
Pesticide Application
Reformulation - FIP rule
4.3
0.0
39,618
0
Point Source Ind. Surface Coating
Add-on Control Levels
12.4
0.0
228,344
0
Point Sources
RE Improvements
6,281.0
0.0
12,561,840
0
Recreational vehicles
CARB standards
34.0
0.0
18,019
0
Service stations - stage l-truck un
Vapor balance & P-V valves
241.6
0.0
93,577
0
SOCMI batch reactor processes
New CTG
105.1
0.0
426,152
0
SOCMI fugitives
RACT
61.3
0.0
8,345
0
Web Offset Lithography
New CTG (carbon adsorber)
8.7
0.0
-1,087
0
Wood furniture surface coating
Reformulation
26.8
0.0
10,523
0
Total
11,747.9
3,991.8
21,473,008
5,993,281
Adhesives - industrial
RACT
329.4
0.0
823,688
0
Aerosols
CARB Tier 2 Standards - Reform
108.5
0.0
271,524
0
Aerosols
SCAQMD Standards
Reformulati
108.5
0.0
1,086,096
0
Aircraft surface coating
Add-on control levels
4.0
0.0
125,719
0
Area Source Industrial Coal Comb
RACT to small sources
0.0
22.7
0
88,259
Area Source Industrial Oil Comb
RACT to small sources
0.0
0.8
0
1,758
Automobile refinishing
CARB BARCT limits
33.1
0.0
121,990
0
Automobile refinishing
FIP Rule (VOC Content & TE)
126.6
0.0
2,282,141
0
Cement Manufacturing - Dry
LNB
0.0
262.9
0
210,670
Cement Manufacturing - Dry
SCR
0.0
315.5
0
3,530,444
Cement Manufacturing - Dry
SNCR - Urea based
0.0
262.9
0
323,865
Commercial Marine Vessels
Emission Fees
0.0
33.2
0
331,535
Cutback Asphalt
Switch to emulsified asphalts
280.6
0.0
0
0
Industrial Boiler • Distillate Oil
LNB
0.0
2.2
0
3,080
Industrial Boiler - Distillate Oil
LNB + FGR
0.0
0.5
0
4,283
Industrial Boiler - Distillate Oil
SCR
0.0
0.9
0
9,136
Industrial Boiler - Natural Gas
LNB
0.0
31.2
0
28,823
Industrial Boiler - Natural Gas
LNB + FGR
0.0
6.2
0
38,107
Industrial Boiler - Natural Gas
SCR
0.0
12.6
0
112,742
Industrial Boiler • PC
LNB
0.0
884.5
0
1,421,744
Industrial Boiler - PC
SCR
0.0
265.4
0
6,811,724
Industrial Boiler - PC
SNCR
0.0
176.9
0
2,192,644
Industrial Boiler • Residual Oil
LNB
0.0
16.2
0
12,168
Industrial Boiler - Residual Oil
LNB + FGR
0.0
6.2
0
34,572
Industrial Boiler - Residual Oil
SCR
0.0
12.6
0
89,980
Industrial Boiler - Stoker
SCR
0.0
90.9
0
905,202
Industrial Boiler - Stoker
SNCR
0.0
113.6
0
244,779
marine surface coating
Add-on control levels
122.4
0.0
1,771,300
0
Metal product surface coating
VOC content limits & improved
167.1
0.0
8,216
0
Miscellaneous surface coating
Add-on control levels
179.3
0.0
8,570,343
0
Miscellaneous surface coating
MACT level of control
32.9
0.0
82,138
0
Motor Vehicles
California Reform
-113.2
3,111.8
0
14,082,175
Motor Vehicles
Enhanced l/M (w/49 State LEV)
8,942.2
6,407.4
1,648.631
3,297,263
B-23
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
Federal Reform
1,943.4
541.8
14,703,239
0
Motor Vehicles
Reform Diesel
0.0
131.0
0
6,648,656
Nonroad Diesels
CARB Stds for > 175 HP
0.0
67.8
0
553,880
Nonroad gasoline
Reformulated gasoline
58.7
0.0
293,500
0
Open Burning
Episodic Ban
938.2
177.9
0
0
Paper surface coating
Add-on control levels
13.5
0.0
308,857
0
Pesticide Application
Reformulation - FIP rule
9.3
0.0
86,601
0
Point Source Ind. Surface Coating Add-on Control Levels
864.0
0.0
15,896,772
0
Process Heaters - Natural Gas
LNB + SCR
0.0
10.9
0
304,598
Process Heaters - Natural Gas
ULNB
0.0
62.7
0
40,020
Recreational vehicles
CARB standards
42.8
0.0
22,703
0
Service stations - stage l-tnjck un
Vapor balance 8 P-V valves
358.2
0.0
8,956
0
Web Offset Lithography
New CTG (carbon adsorber)
79.9
0.0
-9,997
0
Wood furniture surface coating
Reformulation
284.6
0.0
106,743
0
Wood product surface coating
Reformulation
2.1
0.0
135
0
Total
14,916.1
13,029.2
48,209,295
41,322,107
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
19.9
0.0
49,596
0
Aerosols
SCAQMD Standards
Reformulati
19.9
0.0
198,384
0
Automobile refinishing
CARB BARCT limits
8.1
0.0
29,881
0
Automobile refinishing
FIP Rule (VOC Content & TE)
31.0
0.0
558,983
0
marine surface coating
Add-on control levels
96.5
0.0
1,395,871
0
Metal product surface coating
VOC content limits & improved
34.7
0.0
865
0
Miscellaneous surface coating
Add-on control levels
31.5
0.0
547,300
0
Miscellaneous surface coating
MACT level of control
56.8
0.0
142,041
0
Motor Vehicles
California Reform
56.6
580.5
0
2,299,274
Motor Vehicles
Enhanced l/M (w/49 State LEV)
1,274.4
1,030.2
91,780
183,560
Motor Vehicles
Federal Reform
304.4
88.5
2,403,498
0
Nonroad gasoline
Reformulated gasoline
15.4
0.0
77,000
0
Los Angeles, CA
Manitowoc, Wl
B-24
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
163.5
30.9
0
0
1.1
0.0
75,421
0
34.9
0.0
324,459
0
104.4
0.0
1,920,776
0
16.4
0.0
0
0
17.9
0.0
447
0
40.7
0.0
21,584
0
48.6
0.0
1,220
0
2.5
0.0
-312
0
116.4
0.0
43,659
0
2.0
0.0
50
0
2,497.6
1,730.1
7,882,503
2,482,834
46.7
0.0
116,760
0
46.7
0.0
467,040
0
30.0
0.0
110,381
0
114.6
0.0
2,064,926
0
352.8
0.0
8,725
0
64.2
0.0
1,006,908
0
17.1
0.0
42,760
0
25.1
0.0
125,500
0
97.6
18.5
0
0
9.4
0.0
632,619
0
108.9
0.0
1,012,621
0
74.1
0.0
1,363,348
0
61.0
0.0
0
0
24.4
0.0
12,907
0
131.9
0.0
3,297
0
78.4
0.0
29,408
0
2.5
0.0
63
0
1,285.4
18.5
6,997,263
0
22.1
0.0
55,344
0
22.1
0.0
221,376
0
1.9
0.0
67,602
0
11.9
0.0
43,723
0
45.4
0.0
817,916
0
98.5
0.0
3,018,808
0
60.2
608.9
0
2,717,140
1,589.5
1,175.3
47,591
95,182
350.5
99.1
2,836,015
0
20.9
0.0
104,500
0
190.1
35.9
0
0
6.2
0.0
414,248
0
8.6
0.0
79,850
0
111.9
0.0
59,310
0
63.7
0.0
1,594
0
406.8
0.0
152,532
0
3,010.3
1,919.2
7,920,409
2,812,322
0.0
27.7
0
107,750
0.0
0.5
0
1,073
Modesto, CA
Muskegon, Ml
Nashville, TN
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Recreational vehicles
Service stations - stage l-truck un
Web Offset Lithography
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Wood product surface coating
Aerosols
Aerosols
Aircraft surface coating
Automobile refinishing
Automobile refinishing
Miscellaneous surface coating
Motor Vehicles
Motor Vehicles
Motor Vehicles
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Recreational vehicles
Service stations - stage l-truck un
Wood furniture surface coating
Area Source Industrial Coal Comb
Area Source Industrial Oil Comb
Episodic Ban
Add-on control levels
Reformulation - FIP rule
Add-on Control Levels
FIP VOC Limits
FIP VOC Limits
CARB standards
Vapor balance & P-V valves
New CTG (carbon adsorber)
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
CARB BARCT limits
FIP Rule (VOC Content & TE)
VOC content limits & improved
Add-on control levels
MACT level of control
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
Add-on Control Levels
FIP VOC Limits
CARB standards
Vapor balance & P-V valves
Reformulation
Reformulation
Total
CARB Tier 2 Standards - Reform
SCAQMD Standards
Reformulati
Add-on control levels
CARB BARCT limits
FIP Rule (VOC Content & TE)
Add-on control levels
California Reform
Enhanced l/M (w/49 State LEV)
Federal Reform
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
CARB standards
Vapor balance & P-V valves
Reformulation
Total
RACT to small sources
RACT to small sources
B-25
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Commercial Marine Vessels
Emission Fees
0.0
27.6
0
274,516
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
37.3
0
801,585
Gas Turbines-Oil
SCR + WATER INJECTION
0.0
246.5
0
5,652,452
IC Engines - Natural Gas
NSCR
0.0
491.3
0
1,241,469
Industrial Boiler - Distillate Oil
LNB + FGR
0.0
6.3
0
64,698
Industrial Boiler - Distillate Oil
SCR
0.0
12.6
0
138,075
Industrial Boiler - Natural Gas
LNB
0.0
6.8
0
6,100
Industrial Boiler - Natural Gas
LNB + FGR
0.0
69.0
0
438,362
Industrial Boiler - Natural Gas
SCR
0.0
138.0
0
1,297,032
Industrial Boiler - PC
SCR
0.0
66.6
0
1,794,222
Industrial Boiler - PC
SNCR
0.0
44.4
0
577,548
Industrial Boiler - Residual Oil
LNB + FGR
0.0
1.7
0
9,893
Industrial Boiler - Residual Oil
SCR
0.0
3.5
0
25,747
Industrial Boiler - Stoker
SCR
0.0
39.7
0
413,030
Motor Vehicles
California Reform
-162.8
4,007.3
0
20,150,267
Motor Vehicles
Enhanced \M (w/49 State LEV)
11,604.1
8,719.2
567,807
1,135,614
Motor Vehicles
Federal Reform
2,630.3
768.2
21,020,978
0
Motor Vehicles
Reform Diesel
0.0
152.3
0
7,739,306
Municipal Waste Combustors
SNCR
0.0
131.6
0
439,269
Nonroad Diesels
CARB Stds for > 175 HP
0.0
104.6
0
852,643
Nonroad gasoline
Reformulated gasoline
91.6
0.0
458,000
0
Open Burning
Episodic Ban
746.4
141.4
0
0
Process Heaters - Distillate Oil
LNB + SCR
0.0
0.0
0
1,637
Process Heaters - Natural Gas
LNB + SCR
0.0
5.4
0
170,509
Process Heaters - Natural Gas
ULNB
0.0
5.9
0
3,734
Total 14,909.6
15,255.4
22,046,785
43,336,531
Aerosols
CARB Tier 2 Standards - Reform
158.8
0.0
396,912
0
Aerosols
SCAQMD Standards
Reformulati
158.8
0.0
1,587,648
0
Aircraft surface coating
Add-on control levels
13.4
0.0
704,628
0
Automobile refinishing
CARB BARCT limits
6.5
0.0
24,006
0
Automobile refinishing
FIP Rule (VOC Content & TE)
238.2
0.0
6,660,863
0
marine surface coating
Add-on control levels
2.9
0.0
41,886
0
Metal product surface coating
VOC content limits 8 improved
283.2
0.0
16,501
0
Miscellaneous surface coating
Add-on control levels
71.7
0.0
6,276,407
0
Miscellaneous surface coating
MACT level of control
19.7
0.0
49,140
0
Motor Vehicles
California Reform
630.1
3,961.2
0
20,401,080
Nonroad gasoline
Reformulated gasoline
164.1
0.0
820,500
0
Open Burning
Episodic Ban
849.4
161.1
0
0
Paper surface coating
Add-on control levels
24.2
0.0
2,346,314
0
Pesticide Application
Reformulation - FIP rule
10.1
0.0
93,725
0
Point Source Ind. Surface Coating Add-on Control Levels
97.8
0.0
1,799,888
0
Point Sources
RE Improvements
1,007.7
0.0
2,015,530
0
Recreational vehicles
CARB standards
604.1
0.0
320,133
0
Service stations - stage l-truck un
Vapor balance & P-V valves
460.7
0.0
11,517
0
Wood furniture surface coating
Reformulation
77.4
0.0
122,710
0
Wood product surface coating
Reformulation
5.3
0.0
130
0
Total
4,884.1
4,122.3
23,288,438
20,401,080
Cutback Asphalt
Switch to emulsified asphalts
1,068.4
0.0
0
0
Metal product surface coating
VOC content limits & improved
277.9
0.0
9,701
0
Motor Vehicles
Enhanced J/M (w/49 State LEV)
11,508.4
6,549.1
1,773,573
3,547,145
Oil and natural gas production fiel
RACT (equipment/maintenance)
268.9
0.0
106,656
0
Open Burning
Episodic Ban
1,167.1
221.5
0
0
New London, CT
New Orleans, LA
B-26
-------
Table B-4 (continued)
Reductions
Costs
(tons per year)
(1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Pharmaceutical manufacture
RACT
5.7
0.0
1,878
0
Point Source Metal Surface
FIP VOC Limits
20.4
0.0
0
0
Coating
Service stations - stage l-truck un
Vapor balance & P-V valves
598.5
0.0
14,963
0
Web Offset Lithography
New CTG (carbon adsorber)
115.6
0.0
-14,447
0
Wood product surface coating
Reformulation
1.4
0.0
89
0
Total 15,032.3
6,770.6
1,892,413
3,547,145
New York, NY Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content &TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
o.o
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Philadelphia, PA Aerosols
CARB Tier 2 Standards - Reform
849.5
0.0
2,124,030
0
Aerosols
SCAQMD Standards
Reformulati
849.6
0.0
8,496,120
0
Aircraft surface coating
Add-on control levels
28.0
0.0
1,012,040
0
Automobile refinishing
CARB BARCT limits
550.3
0.0
2,023,964
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,101.0
0.0
37,862,493
0
marine surface coating
Add-on control levels
138.1
0.0
2,413,661
0
Metal product surface coating
VOC content limits & improved
661.9
0.0
23,283
0
Miscellaneous surface coating
Add-on control levels
369.8
0.0
19,157,461
0
Miscellaneous surface coating
MACT level of control
49.0
0.0
122,400
0
Motor Vehicles
California Reform
2,768.4 16,305.2
0
83,136,982
Nonroad gasoline
Reformulated gasoline
516.8
0.0
2,584,000
0
Open Burning
Episodic Ban
2,582.6
489.7
0
0
Paper surface coating
Add-on control levels
68.2
0.0
5,050,766
0
Pesticide Application
Reformulation - FIP rule
122.7
0.0
1,140,144
0
Point Source Ind. Surface Coating
Add-on Control Levels
5,061.8
0.0
93,137,488
0
Point Source Metal Surface
FIP VOC Limits
366.2
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
97.1
0.0
2,427
0
Coating
Point Sources
RE Improvements
30,474.2
0.0
60,948,430
0
Recreational vehicles
CARB standards
799.6
0.0
423,651
0
B-27
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
(1990$)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Service stations - stage l-truck un
Vapor balance & P-V valves
2,028.7
0.0
50,721
0
Wood furniture surface coating
Reformulation
841.2
0.0
884,447
0
Wood product surface coating
Reformulation
13.2
0.0
477
0
Total
51,337.9
16,794.9
237,458,00
3
83,136,982
Adhesives - industrial
RACT
39.2
0.0
98,028
0
Aerosols
CARB Tier 2 Standards - Reform
402.0
0.0
1,004,856
0
Automobile refinishing
CARB BARCT limits
182.6
0.0
671,796
0
Bulk Terminals
RACT
115.1
0.0
191,712
0
Cutback Asphalt
Switch to emulsified asphalts
109.7
0.0
0
0
Metal product surface coating
VOC content limits & improved
521.6
0.0
12,986
0
Miscellaneous surface coating
MACT level of control
417.7
0.0
1,044,188
0
Motor Vehicles
Enhanced l/M
21,094.9
12,639.6
1,199,840
2,399,679
Motor Vehicles
Federal Reform
36,455.7
3,002.3
47,793,100
0
Nonroad gasoline
Reformulated gasoline
306.9
0.0
1,534,500
0
Open Burning
Episodic Ban
1,589.9
303.4
0
0
Recreational vehicles
CARB standards
318.6
0.0
168,875
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,131.7
0.0
212,983
0
Web Offset Lithography
New CTG (carbon adsorber)
6.4
0.0
-795
0
Wood furniture surface coating
Reformulation
891.0
0.0
334,128
0
Wood product surface coating
Reformulation
23.1
0.0
576
0
Total
63,606.1
15,945.3
54,266,773
2,399,679
Area Source Industrial Coal Comb
RACT to small sources
0.0
0.1
0
235
Area Source Industrial NG Comb
RACT to small sources
0.0
1.6
0
2,349
Area Source Industrial Oil Comb
RACT to small sources
0.0
3.7
0
7,486
Commercial Marine Vessels
Emission Fees
0.0
90.8
0
907,683
Industrial Boiler • Distillate Oil
LNB + FGR
0.0
2.9
0
29,602
Industrial Boiler - Distillate Oil
SCR
0.0
5.8
0
63,175
Industrial Boiler - Natural Gas
LNB + FGR
0.0
0.9
0
5,706
industrial Boiler - Natural Gas
SCR
0.0
1.8
0
16,880
Industrial Boiler - Residual Oil
LNB + FGR
0.0
66.3
0
379,442
Industrial Boiler - Residual Oil
SCR
0.0
132.5
0
987,553
Motor Vehicles
California Reform
208.9
1,844.3
.0
7,957,384
Motor Vehicles
Reform Diesel
0.0
81.5
0
4,121,838
Nonroad Diesels
CARB Stds for >175 HP
0.0
4.0
0
33,035
Nonroad gasoline
Reformulated gasoline
23.3
0.0
117,000
0
Open Burning
Episodic Ban
801.7
152.3
0
0
Residential NG Consumption
LNB Space heaters
0.0
12.5
0
20,258
Utility Boiler - Oil-Gas/Tangential
LNB + FGR + OFA
0.0
58.2
0
977,858
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
181.7
0
2,235,995
Total
1,033.9
2,640.9
117,000
17,746,479
Bulk Terminals
RACT
364.1
0.0
606,885
0
Cutback Asphalt
Switch to emulsified asphalts
320.2
0.0
0
0
Metal product surface coating
VOC content limits & improved
406.7
0.0
10,136
0
Motor Vehicles
Enhanced l/M
11,068.2
10,483.5
1,747,796
3,495,591
Open Burning
Episodic Ban
2,265.5
429.5
0
0
Pharmaceutical manufacture
RACT
4.2
0.0
1,408
0
Point Source Metal Surface
FIP VOC Limits
139.8
0.0
0
0
Phoenix, AZ
Portland, ME
Portland, OR
Coating
Point Source Wood Product FIP VOC Limits
Coating
Point Sources
Recreational vehicles
Service stations - stage l-truck un
RE Improvements
CARB standards
Vapor balance & P-V valves
217.2
19,187.0
403.8
1,432.7
0.0
0.0
0.0
0.0
5,429
38,373,910
214,057
562,989
B-28
-------
Table B-4 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
SOCMI fugitives
RACT
12.7
0.0
1,729
0
Web Offset Lithography
New CTG (carbon adsorber)
259.3
0.0
-32,399
0
Wood furniture surface coating
Reformulation
487.7
0.0
182,937
0
Wood product surface coating
Reformulation
43.4
0.0
1,779
0
Total 36,612.5
10,913.0
41,676,656
3,495,591
Providence, Rl Aerosols
CARB Tier 2 Standards - Reform
133.1
0.0
332,580
0
Aerosols
SCAQMD Standards
Reformulati
133.1
0.0
1,330,320
0
Aircraft surface coating
Add-on control levels
0.2
0.0
4,764
0
Automobile refinishing
CARB BARCT limits
83.6
0.0
307,511
0
Automobile refinishing
FIP Rule (VOC Content & TE)
319.2
0.0
5,752,666
0
marine surface coating
Add-on control levels
131.6
0.0
1,905,058
0
Metal product surface coating
VOC content limits & improved
285.3
0.0
7,100
0
Miscellaneous surface coating
Add-on control levels
193.3
0.0
3,130,460
0
Miscellaneous surface coating
MACT level of control
129.2
0.0
323,006
0
Motor Vehicles
California Reform
410.5
2,548.7
0
13,834,606
Nonroad gasoline
Reformulated gasoline
101.8
0.0
509,000
0
Open Burning
Episodic Ban
510.9
97.1
0
0
Paper surface coating
Add-on control levels
0.8
0.0
50,406
0
Pesticide Application
Reformulation - FIP rule
1.6
0.0
15,196
0
Point Source Ind. Surface Coating Add-on Control Levels
177.8
0.0
3,270,692
0
Point Source Metal Surface FIP VOC Limits
129.6
0.0
0
0
Coating
Point Sources
RE Improvements
2,381.3
0.0
4,762,520
0
Recreational vehicles
CARB standards
545.9
0.0
289,257
0
Service stations - stage I-truck un
Vapor balance & P-V valves
313.0
0.0
7,823
0
Wood furniture surface coating
Reformulation
402.2
0.0
150,805
0
Wood product surface coating
Reformulation
5.1
0.0
130
0
Total
6,389.1
2,645.8
22,149,294
13,834,606
Redding, CA Adhesives - industrial
RACT
97.0
0.0
242,361
0
Aerosols
CARB Tier 2 Standards - Reform
26.1
0.0
65,190
0
Aerosols
SCAQMD Standards
Reformulati
26.1
0.0
260,760
0
Automobile refinishing
CARB BARCT limits
12.7
0.0
46,813
0
Automobile refinishing
FIP Rule (VOC Content & TE)
48.6
0.0
875,746
0
Bulk Terminals
RACT
303.5
0.0
505,794
0
Cutback Asphalt
Switch to emulsified asphalts
180.7
0.0
0
0
marine surface coating
Add-on control levels
6.4
0.0
93,094
0
Metal product surface coating
VOC content limits & improved
18.8
0.0
468
0
Miscellaneous surface coating
Add-on control levels
8.6
0.0
133,220
0
Miscellaneous surface coating
MACT level of control
3.7
0.0
9,223
0
Motor Vehicles
Enhanced l/M
2,316.3
3,420.1
841,481
1,682,962
Nonroad gasoline
Reformulated gasoline
13.7
0.0
68,500
0
Open Burning
Episodic Ban
15.6
3.0
0
0
Paper surface coating
Add-on control levels
64.3
0.0
774,483
0
Pesticide Application
Reformulation - FIP rule
24.2
0.0
225,693
0
Recreational vehicles
CARB standards
12.8
0.0
6,824
0
Service stations - stage l-truck un
Vapor balance & P-V valves
731.0
0.0
547,670
0
Web Offset Lithography
New CTG (carbon adsorber)
14.3
0.0
-1,791
0
Wood furniture surface coating
Reformulation
7.4
0.0
2,761
0
Wood product surface coating
Reformulation
8.3
0.0
208
0
Total
3,940.1
3,423.1
4,698,498
1,682,962
Reno, NV Aerosols
CARB Tier 2 Standards - Reform
44.1
0.0
110,244
0
Automobile refinishing
CARB BARCT limits
30.8
0.0
113,240
0
B-29
-------
Table B-4 (continued)
Reductions
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Metal product surface coating
VOC content limits & improved
37.5
0.0
934
0
Miscellaneous surface coating
MACT level of control
30.7
0.0
76,867
~
Motor Vehicles
Enhanced l/M
1.537.1
1,483.5
94,145
188,291
Motor Vehicles
Federal Reform
1.919.7
357.6
5,606,016
0
Nonroad gasoline
Reformulated gasoline
39.8
0.0
199,000
0
Open Burning
Episodic Ban
82.3
15.6
0
0
Recreational vehicles
CARB standards
118.5
0.0
62,805
0
Service stations - stage l-taick un
Vapor balance & P-V valves
153.1
0.0
3,845
0
Web Offset Lithography
New CTG (carbon adsorber)
97.0
0.0
-12,130
0
Wood furniture surface coating
Reformulation
68.8
0.0
25,794
0
Wood product surface coating
Reformulation
2.0
0.0
50
0
Total
4,161.4
1,856.7
6,280,810
188,291
Adhesives - industrial
RACT
34.5
0.0
86,360
0
Aerosols
CARB Tier 2 Standards - Reform
201.3
0.0
503,034
0
Aerosols
SCAQMD Standards
Reformulati
201.2
0.0
2,012,136
0
Automobile refinishing
CARB BARCT limits
127.1
0.0
467,563
0
Automobile refinishing
FIP Rule (VOC Content & TE)
485.3
0.0
8,746,744
0
Bulk Terminals
RACT
12.8
0.0
21,347
0
Culback Asphalt
Switch to emulsified asphalts
72.2
0.0
0
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
0
Metal product surface coating
VOC content limits & improved
236.7
0.0
5,867
0
Miscellaneous surface coating
Add-on control levels
119.5
0.0
1,938,485
0
Miscellaneous surface coating
MACT level of control
105.2
0.0
262,951
0
Motor Vehicles
Enhanced l/M -
828.8
1,377.3
326,808
653,615
Nonroad gasoline
Reformulated gasoline
106.5
0.0
532,500
0
Open Burning
Episodic Ban
444.0
84.0
0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
0
Pesticide Application
Reformulation - FIP rule
114.2
0.0
1,062,488
0
Point Source Ind. Surface Coating Add-on Control Levels
361.7
0.0
6,655,556
0
Point Source Metal Surface FIP VOC Limits
313.9
0.0
0
0
Coating
Point Sources
RE Improvements
40.5
0.0
81,030
0
Recreational vehicles
CARB standards
102.4
0.0
54,329
0
Service stations - stage l-truck un
Vapor balance & P-V valves
799.0
0.0
130,285
0
Web Offset Lithography
New CTG (carbon adsorber)
6.6
0.0
-825
0
Wood furniture surface coating
Reformulation
252.5
0.0
94,698
0
Wood product surface coating
Reformulation
16.0
0.0
399
0
Total
4,989.2
1,461.3
23,248,681
653,615
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
0.0
0.0
0
0
Sacramento, CA
San Diego, CA
Automobile refinishing
Automobile refinishing
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Point Source Ind. Surface Coating
Point Sources
Recreational vehicles
Reformulati
CARB BARCT limits 0.0 0.0 0 0
FIP Rule (VOC Content &TE) 0.0 0.0 0 0
VOC content limits & improved 0.0 0.0 0 0
Add-on control levels 0.0 0.0 0 0
MACT level of control 0.0 0.0 0 0
Reformulated gasoline 0.0 0.0 0 0
Episodic Ban 0.0 0.0 0 0
Add-on control levels 0.0 0.0 0 0
Reformulation - FIP rule 0.0 0.0 0 0
Add-on Control Levels 0.0 0.0 0 0
RE Improvements 0.0 0.0 0 0
CARB standards 0.0 0.0 0 0
B-30
-------
Table B-4 (continued)
Reductions
(tons per year)
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards - Reform
50.1
0.0
125,256
0
Aerosols
SCAQMD Standards
Reformulati
50.1
0.0
501,024
0
Aircraft surface coating
Add-on control levels
10.5
0.0
330,223
0
Automobile refinishing
CARB BARCT limits
25.1
0.0
92,413
0
Automobile refinishing
FIP Rule (VOC Content & TE)
95.9
0.0
1,728,785
0
Metal product surface coating
VOC content limits & improved
44.0
0.0
1,098
0
Miscellaneous surface coating
Add-on control levels
18.2
0.0
303,110
0
Miscellaneous surface coating
MACT level of control
45.7
0.0
114,149
0
Motor Vehicles
Enhanced l/M
1,827.6
2,680.2
106,112
212,224
Nonroad gasoline
Reformulated gasoline
26.0
0.0
130,000
0
Open Burning
Episodic Ban
134.4
25.5
0
0
Paper surface coating
Add-on control levels
1.3
0.0
84,224
0
Pesticide Application
Reformulation - FIP rule
34.8
0.0
323,156
0
Point Sources
RE Improvements
91.6
0.0
183,230
0
Recreational vehicles
CARB standards
5.8
0.0
3,072
0
Service stations - stage l-truck un
Vapor balance & P-V valves
196.0
0.0
4,901
0
Wood furniture surface coating
Reformulation
52.3
0.0
19,616
0
Wood product surface coating
Reformulation
1.6
0.0
40
0
Total
2,711.0
2.705.7
4,050,409
212,224
Adhesives - industrial
RACT
105.8
0.0
264,172
0
Aerosols
CARB Tier 2 Standards - Reform
467.2
0.0
1,167,756
0
Aerosols
SCAQMD Standards
Reformulati
467.0
0.0
4,671,024
0
Automobile refinishing
CARB BARCT limits
250.9
0.0
922,119
0
Bulk Terminals
RACT
248.4
0.0
413,881
0
Cutback Asphalt
Switch to emulsified asphalts
454.5
0.0
0
0
Metal product surface coating
VOC content limits & improved
578.7
0.0
14,445
0
Miscellaneous surface coating
MACT level of control
240.4
0.0
601,215
0
Motor Vehicles
California LEV
8,992.7
15,879.0
12,434,797
12,434,797
Motor Vehicles
California Reform
1,615.1
4,241.6
0
65,175,421
Motor Vehicles
Enhanced l/M
4,292.7
3,491.0
1,372,151
2,744,303
Motor Vehicles
Federal Reform
11,865.0
3,331.6
67,981,645
0
Nonroad gasoline
Reformulated gasoline
292.5
0.0
1,462,500
0
Open Burning
Episodic Ban
1,232.7
233.9
0
0
Pesticide Application
Reformulation - FIP rule
71.3
0.0
662,233
0
Point Source Metal Surface FIP VOC Limits
8.8
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
93.1
0.0
2,327
0
Coating
Recreational vehicles
CARB standards
628.9
0.0
333,244
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,104.6
0.0
699,089
0
Web Offset Lithography
New CTG (carbon adsorber)
532.5
0.0
-66,548
0
Wood furniture surface coating
Reformulation
989.4
0.0
371,013
0
Wood product surface coating
Reformulation
22.6
0.0
1,182
0
Total 35,554.8
27,177.1
93,308,245
80,354,520
Adhesives - industrial
RACT
18.4
0.0
45,877
0
Aerosols
CARB Tier 2 Standards - Reform
364.1
0.0
910,368
0
Aerosols
SCAQMD Standards
364.1
0.0
3,641,472
0
Santa Barbara, CA
Seattle, WA
St. Louis, MO
Reformulati
B-31
-------
Table B-4 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Aircraft surface coating Add-on control levels 120.4 0.0 3,790,114 0
Automobile refinishing CARB BARCT limits 183.9 0.0 676,359 0
Automobile refinishing FIP Rule (VOC Content & TE) 702.2 0.0 12,652,662 0
Cutback Asphalt Switch to emulsified asphalts 46.5 0.0 0 0
marine surface coating Add-on control levels 17.2 0.0 249,014 0
Metal product surface coating VOC content limits & improved 836.5 0.0 35,843 0
Miscellaneous surface coating Add-on control levels 241.9 0.0 15,971,880 0
Miscellaneous surface coating MACT level of control 176.0 0.0 440,252 0
Motor Vehicles California Reform 24.8 8,761.5 0 45,829,827
Motor Vehicles Enhanced l/M (w/49 State LEV) 26,691.5 19,604.6 948,486 1,896,971
Motor Vehicles Federal Reform 6,064.0 1,717.0 47,795,117 0
Nonroad gasoline Reformulated gasoline 151.4 0.0 757,000 0
Oil and natural gas production fiel RACT (equipment/maintenance) 4.2 0.0 1,690 0
Open Burning Episodic Ban 1,607.9 304.9 0 0
Paper surface coating Add-on control levels 23.6 0.0 2,442,361 0
Pesticide Application Reformulation - FIP rule 217.1 0.0 2,019,308 0
Point Source Ind. Surface Coating Add-on Control Levels 7,192.0 0.0 132,332,06 0
4
Point Source Metal Surface FIP VOC Limits 874.2 0.0 0 0
Coating
Point Sources RE Improvements 3,298.8 0.0 6,597,740 0
Recreational vehicles CARB standards 253.0 0.0 133,902 0
Service stations • stage l-truck un Vapor balance & P-V valves 1,235.8 0.0 30,896 0
Web Offset Lithography New CTG (carbon adsorber) 2.2 0.0 -281 0
Wood furniture surface coating Reformulation 335.3 0.0 482,482 0
Wood product surface coating Reformulation 6.8 0.0 168 0
Total 51,055.8 30,388.0 231,954,77 47,726,798
4
Stockton, CA Aerosols CARB Tier 2 Standards - Reform 63.9 0.0 159,828 0
Aerosols SCAQMD Standards 63.9 0.0 639,312 0
Reformulati
Automobile refinishing CARB BARCT limits 30.9 0.0 113,829 0
Automobile refinishing FIP Rule (VOC Content & TE) 118.2 0.0 2,129,416 0
marine surface coating Add-on control levels 2.6 0.0 37,680 0
Metal product surface coating VOC content limits & improved 315.6 0.0 7,806 0
Miscellaneous surface coating Add-on control levels 86.9 0.0 1,429,779 0
Miscellaneous surface coating MACT level of control 38.0 0.0 94,975 0
Nonroad gasoline Reformulated gasoline 32.9 0.0 164,500 0
Open Burning Episodic Ban. 146.1 27.8 0 0
Paper surface coating Add-on control levels 5.3 0.0 358,421 0
Pesticide Application Reformulation - FIP rule 162.5 0.0 1,510,952 0
Point Source Wood Product FIP VOC Limits 138.0 0.0 3,449 0
Coating
Recreational vehicles CARB standards 31.5 0.0 16,720 0
Service stations - stage l-truck un Vapor balance & P-V valves 184.4 0.0 4,610 0
Wood furniture surface coating Reformulation 214.0 0.0 80,240 0
Total 1,634.7 27.8 6,751,517 0
Tell City (IN-KY) Cutback Asphalt Switch to emulsified asphalts 40.9 0.0 0 0
Metal product surface coating VOC content limits & improved 9.8 0.0 323 0
Motor Vehicles Enhanced l/M (w/49 State LEV) 626.6 531.0 130,727 261,453
Oil and natural gas production fiel RACT (equipment/maintenance) 2.2 0.0 840 0
Open Burning Episodic Ban 73.8 13.9 0 0
Petroleum refinery fugitives RACT 52.5 0.0 -23,622 0
B-32
-------
Table B-4 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Point Source Metal Surface FIP VOC Limits
220.4
0.0
0
0
Coating
Web Offset Lithography
New CTG (carbon adsorber)
14.8
0.0
-1,846
0
Wood furniture surface coating
Reformulation
118.8
0.0
44,537
0
Total
1,159.8
544.9
150,959
261,453
Visalia, CA
Aerosols
CARB Tier 2 Standards - Reform
42.6
0.0
106,380
0
Aerosols
SCAQMD Standards
Reform ulati
42.6
0.0
425,520
0
Automobile refinishing
CARB BARCT limits
11.2
0.0
41,327
0
Automobile refinishing
FIP Rule (VOC Content & TE)
42.9
0.0
773,106
0
Metal product surface coating
VOC content limits & improved
49.9
0.0
1,238
0
Miscellaneous surface coating
Add-on control levels
22.0
0.0
333,737
0
Miscellaneous surface coating
MACT level of control
19.7
0.0
43,270
0
Nonroad gasoline
Reformulated gasoline
23.1
0.0
115,500
0
Open Burning
Episodic Ban
93.7
17.7
0
0
Pesticide Application
Reformulation - FIP rule
250.4
0.0
2,329,073
0
Recreational vehicles
CARB standards
22.4
0.0
11,867
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
110.8
0.0
2,770
0
Wood furniture surface coating
Reformulation
8.2
0.0
3,088
0
Wood product surface coating
Reformulation
2.7
0.0
67
0
Total
742.2
17.7
4,192,943
0
B-33
-------
Table B-5. Current NAAQS (1H1EX-120): Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the LCS
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
146.2
0.0
0
913,320
Reform ulati
Aircraft surface coating
Add-on control levels
2.2
0.0
0
68,403
Automobile refinishing
FIP Rule (VOC Content & TE)
160.4
0.0
0
2,412,678
Metal product surface coating
VOC content limits & improved
21.1
0.0
0
527
Miscellaneous surface coating
Add-on control levels
21.8
0.0
0
353,720
Miscellaneous surface coating
MACT level of control
16.0
0.0
0
40,089
Nonroad gasoline
Reformulated gasoline
37.1
0.0
0
185,500
Open Burning
Episodic Ban
163.0
30.9
0
0
Pesticide Application
Reformulation - FIP rule
343.9
0.0
0
3,198,642
Point Sources
RE Improvements
327.4
0.0
0
654,810
Recreational vehicles
CARB standards
35.7
0.0
0
18,962
Service stations - stage l-truck un
Vapor balance & P-V valves
298.1
0.0
0
7,453
Wood furniture surface coating
Reformulation
44.9
0.0
0
16,824
Total
1,617.8
30.9
0
7,870,928
Aerosols
CARB Tier 2 Standards - Reform
95.4
0.0
238,926
0
Aerosols
SCAQMD Standards
95.5
0.0
955,704
0
Reformulati
Automobile refinishing
CARB BARCT limits
22.6
0.0
82,694
0
Automobile refinishing
FIP Rule (VOC Content &TE)
85.8
0.0
1,547,000
0
marine surface coating
Add-on control levels
20.4
0.0
295,101
0
Metal product surface coating
VOC content limits & improved
103.9
0.0
4,224
0
Miscellaneous surface coating
Add-on control levels
2.3
0.0
160,685
0
Miscellaneous surface coating
MACT level of control
17.4
0.0
43,244
0
Motor Vehicles
California LEV
1,452.2
2,588.1
2,029,332
2,029,332
Motor Vehicles
Federal Reform
1,561.9
538.1
11,154,029
0
Nonroad gasoline
Reformulated gasoline
67.5
0.0
337,500
0
Open Burning
Episodic Ban
463.5
88.1
0
0
Paper surface coating
Add-on control levels
4.5
0.0
467,671
0
Pesticide Application
Reformulation - FIP rule
78.7
0.0
731,892
0
Point Sources
RE Improvements
7,755.6
0.0
15,511,040
0
Recreational vehicles
CARB standards
309.4
0.0
164,007
0
Service stations - stage l-truck un
Vapor balance & P-V valves
251.7
0.0
6,290
0
Wood furniture surface coating
Reformulation
4.3
0.0
6,116
0
Wood product surface coating
Reformulation
1.3
0.0
83
0
Total
12,393.9
3,214.3
33,735,538
2,029,332
Metal product surface coating
VOC content limits & improved
43.3
0.0
1,746
0
Open Burning
Episodic Ban
313.4
59.3
0
0
Point Source Metal Surface FIP VOC Limits
22.6
0.0
0
0
Coating
Point Sources
RE Improvements
96,693.2
0.0
193,386,49
o
0
Recreational vehicles
CARB standards
69.9
0.0
36,998
0
Service stations - stage l-truck un
Vapor balance & P-V valves
220.0
0.0
5,502
0
Bakersfield, CA
Baton Rouge, LA
Beaumont, TX
Boston, MA
Wood furniture surface coating Reformulation
Total
Area Source Industrial NG Comb
Area Source Industrial Oil Comb
Commercial Marine Vessels
Gas Turbines - Natural Gas
Gas Turbines - Oil
Glass Manufacturing - Container
RACT to small sources
RACT to small sources
Emission Fees
SCR + STEAM INJECTION
SCR + WATER INJECTION
LNB
6.7
97,369.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0 9,574
59.3 193,440,31
0
0
0
0
0
0
0
133.3
5.6
424.5
0.2
49.6
73.9
0
0
200,842
11,097
4,244,709
84,232
890,285
177,254
B-34
-------
Table B-5 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Glass Manufacturing - Container
Oxy-Firing
0.0
18.5
0
613,928
Glass Manufacturing - Container
SCR
0.0
64.6
0
248,572
IC Engines - Natural Gas
NSCR
0.0
71.3
0
302,388
IC Engines - Oil
SCR
0.0
534.7
0
4,958,122
Industrial Boiler - Distillate Oi
LNB + FGR
0.0
44.8
0
459,376
Industrial Boiler - Distillate Oi
SCR
0.0
89.7
0
980,373
Industrial Boiler - Natural Gas
LNB + FGR
0.0
127.3
0
809,325
Industrial Boiler - Natural Gas
SCR
0.0
254.3
0
2,394,636
Industrial Boiler - Other
LNB + FGR
0.0
6.0
0
61,664
Industrial Boiler - Other
SCR
0.0
12.1
0
131,600
Industrial Boiler - PC
SCR
0.0
0.9
0
25,225
Industrial Boiler - PC
SNCR
0.0
0.6
0
8,120
Industrial Boiler - Residual Oil
LNB + FGR
0.0
457.9
0
2,622,125
Industrial Boiler - Residual Oil
SCR
0.0
916.0
0
6,824,419
Industrial Boiler - Stoker
SCR
0.0
12.7
0
132,610
Industrial Cogeneration - Nat. Ga
LNB
0.0
48.9
0
47,086
Industrial Cogeneration - Nat. Ga
LNB + FGR
0.0
9.8
0
62,250
Industrial Cogeneration - Nat. Ga
SCR
0.0
19.6
0
184,184
Motor Vehicles
California LEV
14,684.3
26,387.2
19,020,590
19,020,590
Motor Vehicles
California Reform
2,780.2
6,380.1
0
99,666,930
Motor Vehicles
Reform Diesel
0.0
1,228.5
0
17,919,520
Municipal Waste Combustors
SNCR
0.0
43.4
0
145,140
N on road Diesels
CARB Stds for > 175 HP
0.0
351.4
0
2,867,255
Nonroad gasoline
Reformulated gasoline
557.7
0.0
2,788,500
0
Open Burning
Episodic Ban
1,857.4
352.5
0
0
Process Heaters - Natural Gas
LNB + SCR
0.0
0.0
0
304
Residential NG Consumption
LNB Space heaters
0.0
1,246.1
0
2,008,262
Residential NG Consumption
Water heater replacement
0.0
386.3
0
0
Utility Boiler - Cyclone
SCR
0.0
4,557.9
0
56,188,822
Utility Boiler - Oil-Gas/Tangenti
LNB + FGR + OFA
0.0
1,940.5
0
7,706,715
Utility Boiler - Oil-Gas/Tangenti
SCR
0.0
2,013.1
0
20,158,378
Utility Boiler - Oil-Gas/Wall
LNB + FGR + OFA
0.0
31.4
0
1,136,476
Utility Boiler - Oil-Gas/Wall
SCR
0.0
7,237.8
0
42,291,603
Utility Boiler -PC/Wall
SCR
0.0
970.0
0
9,713,098
Total
19,879.6
56,503.0
21,809,090
305,297,51
5
Aerosols
CARB Tier 2 Standards - Reform
561.0
0.0
1,402,674
0
Aerosols
SCAQMD Standards
561.0
0.0
5,610,696
0
Reformulati
Automobile refinishing
CARB BARCT limits
143.2
0.0
526,510
0
Automobile refinishing
FIP Rule (VOC Content & TE)
546.6
0.0
9,849,515
0
marine surface coating
Add-on control levels
116.2
0.0
1,684,017
0
Metal product surface coating
VOC content limits & improved
1,420.1
0.0
46,340
0
Miscellaneous surface coating
Add-on control levels
68.0
0.0
3,978,067
0
Miscellaneous surface coating
MACT level of control
603.5
0.0
1,508,563
0
Motor Vehicles
California LEV
9,647.9
17,306.0
13,788,716
13,788,716
Nonroad gasoline
Reformulated gasoline
450.1
0.0
2,250,500
0
Open Burning
Episodic Ban
1,959.8
372.0
0
0
Paper surface coating
Add-on control levels
23.3
0.0
2,415,926
0
Pesticide Application
Reformulation • FIP rule
129.5
0.0
1,202,956
0
Point Source Ind. Surface Coating Add-on Control Levels
4.4
0.0
80,592
0
Point Source Metal Surface FIP VOC Limits
123.4
0.0
0
0
Houston, TX
Coating
B-35
-------
Table B-5 (continued)
Nonattairiment Area
Reductions
(tons per year)
Costs
(1990$)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Point Source Wood Product
Coating
FIP VOC Limits
92.7
0.0
2,318
0
Point Sources
RE Improvements
196,046.7
0.0
392,093,22
0
379,063
0
Recreational vehicles
CARB standards
715.4
0.0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,973.8
0.0
49,366
0
Wood furniture surface coating
Reformulation
126.3
0.0
180,870
0
Wood product surface coating
Reformulation
6.4
0.0
272
0
Total 215,319.3 17,678.0
437,050,18
1
0
13,788,716
Aerosols
SCAQMD Standards
Reformulati
3,864.6
0.0
24,153,420
Aircraft surface coating
Add-on control levels
50.2
0.0
0
1,580,530
Automobile refinishing
FIP Rule (VOC Content & TE)
6,106.4
0.0
0
91,869,474
marine surface coating
Add-on control levels
105.7
0.0
0
1,529,243
Metal product surface coating
VOC content limits & improved
2,019.0
0.0
0
50,468
Miscellaneous surface coating
Add-on control levels
1,712.7
0.0
0
65,695,922
Miscellaneous surface coating
MACT level of control
1,786.9
0.0
0
4,467,268
Nonroad gasoline
Reformulated gasoline
1,159.7
0.0
0
5,798,500
Open Burning
Episodic Ban
5,012.4
952.0
0
0
Paper surface coating
Add-on control levels
34.8
0.0
0
2,278,878
Pesticide Application
Reformulation - FIP rule
140.0
0.0
0
1,301,442
Point Source Ind. Surface Coating
Add-on Control Levels
3,073.1
0.0
0
56,542,004
Point Source Metal Surface
Coating
FIP VOC Limits
1,426.4
0.0
0
0
Point Source Wood Product
Coating
FIP VOC Limits
4,533.3
0.0
0
113,332
Point Sources
RE Improvements
3,232.8
0.0
0
6,465,610
Recreational vehicles
CARB standards
257.8
0.0
0
136,567
Service stations - stage l-truck un
Vapor balance & P-V valves
5,983.2
0.0
0
149,578
Wood furniture surface coating
Reformulation
3,574.1
0.0
0
3,554,033,
Wood product surface coating
Reformulation
46.6
0.0
0
1,164
Total
44.119.7
952.0
0
265,687,43
3
Aerosols
CARB Tier 2 Standards - Reform
44.0
0.0
109,962
0
Aerosols
SCAQMD ' Standards
Reformulati
44.0
0.0
439,848
0
Aircraft surface coating
Add-on control levels
3.7
0.0
195,702
0
Automobile refinishing
FIP Rule (VOC Content & TE)
31.0
0.0
901,542
0
Metal product surface coating
VOC content limits & improved
31.8
0.0
4,270
0
Miscellaneous surface coating
Add-on control levels
11.4
0.0
688,680
0
Motor Vehicles
California LEV
726.1
1,455.2
1,115,752
1,115,752
Motor Vehicles
California Reform
180.6
403.7
0
5,886,687
Nonroad gasoline
Reformulated gasoline
50.2
0.0
251,000
0
Open Burning
Episodic Ban
87.2
16.6
0
0
Paper surface coating
Add-on control levels
11.5
0.0
1,149,765
0
Pesticide Application
Reformulation - FIP rule
6.9
0.0
63,556
0
Point Source Ind. Surface Coating
Add-on Control Levels
43.4
0.0
799,204
0
Point Sources
RE Improvements
671.2
0.0
1,342,470
0
Recreational vehicles
CARB standards
152.7
0.0
80,892
0
Service stations - stage l-truck un
Vapor balance & P-V valves
141.1
00
3,529
0
Wood furniture surface coating
Reformulation
34.3
0.0
54,834
0
Total
2.271.1
1,875.5
7,201,006
7,002,439
Aerosols
CARB Tier 2 Standards - Reform
2,547.7
0.0
6,368,928
0
Los Angeles, CA
New London, CT
New York, NY
B-36
-------
Table B-5 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Aerosols SCAQMD Standards 2,547.9 0.0 25,475,712 0
Reformulati
Aircraft surface coating Add-on control levels 72.3 0.0 2,406,278 0
Automobile refmishing CARB BARCT limits 1,331.7 0.0 4,898,113 0
Automobile refinishing FIP Rule (VOC Content & TE) 5,440.1 0.0 102,002,01 0
5
marine surface coating Add-on control levels 113.2 0.0 1,942,544 0
Metal product surface coaling VOC content limits & improved 1,601.4 0.0 169,351 0
Miscellaneous surface coating Add-on control levels 1,290.7 0.0 61,726,005 0
Miscellaneous surface coating MACT level of control 17.7 0.0 44,158 0
Motor Vehicles California LEV 35,237.4 59,342.2 44,652,472 44,652,472
Motor Vehicles California Reform 6,942.1 14,622.0 0 233,306,69
9
Motor Vehicles Enhanced l/M 120.4 120.4 44,994 89,969
Motor Vehicles Federal Reform 99.2 24.8 407,733 0
Nonroad gasoline Reformulated gasoline 1,076.5 0.0 5,382,500 0
Open Burning Episodic Ban 10,288.5 1,952.1 0
Paper surface coating Add-on control levels 215.6 0.0 18,252,178 0
Pesticide Application Reformulation - FIP rule 75.7 0.0 701,948 0
Point Source Ind. Surface Coating Add-on Control Levels 674.6 0.0 12,411,168 0
Point Source Metal Surface FIP VOC Limits 362.1 0.0 0 0
Coating
Point Source Wood Product FIP VOC Limits 308.1 0.0 7,702 0
Coating
Point Sources RE Improvements 34,426.8 0.0 63,853,600 0
Recreational vehicfes CARB standards 2,026.1 0.0 1,073,735 0
Service stations - stage l-truck un Vapor balance & P-V valves 5,918.0 0.0 147,982 0
Wood furniture surface coating Reformulation 2,329.0 0.0 2,516,746 0
Wood product surface coating Reformulation 41.5 0.0 2,222 0
Total 115,104.3 76,061.5 359,488,08 278,049,36
4 0
Philadelphia, PA Aerosols CARB Tier 2 Standards - Reform B45.9 0.0 2,115,240 0
Aerosols SCAQMD Standards B46.0 0.0 8,460,960 0
Reformulati
Aircraft surface coating Add-on control levels 28.0 0.0 1,012,040 0
Automobile refinishing CARB BARCT limits 538.4 0.0 1,979,953 0
Automobile refinishing FIP Rule (VOC Content & TE) 2,055.3 0.0 37,039,187 0
marine surface coating Add-on control levels 169.3 0.0 3,133,282 0
Metal product surface coating VOC content limits & improved 660.6 0.0 23,139 0
Miscellaneous surface coating Add-on control levels 363.9 0.0 18,947,807 0
Miscellaneous surface coating MACT level of control 49.0 0.0 122,400 0
Motor Vehicles California LEV 12,095.2 19,957.8 15,736,303 15,736,303
Motor Vehicles California Reform 2,614.0 5,331.8 0 82,411,343
Nonroad gasoline Reformulated gasoline 518.2 0.0 2,591,000 0
Open Burning Episodic Ban 2,617.5 496.4 0 0
Paper surface coating Add-on control levels 65.0 0.0 4,729,047 0
Pesticide Application Reformulation - FIP rule 124.4 0.0 1,156,270 0
Point Source Ind. Surface Coating Add-on Control Levels 5,049.4 0.0 92,909,144 0
Point Source Metal Surface FIP VOC Limits 339.2 0.0 0 0
Coating
Point Source Wood Product FIP VOC Limits 97.1 0.0 2,427 0
Coating
Point Sources RE Improvements 30,515.8 0.0 61,031,650 0
Recreational vehicles CARB standards 801.1 0.0 424,358 0
Service stations - stage l-truck un Vapor balance & P-V valves 2,221.4 0.0 55,538 0
B-37
-------
Table B-5 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Wood furniture surface coating
Reformulation
820.4
0.0
859,129
0
Wood product surface coating
Reformulation
13.5
0.0
491
0
Total
63,448.6 25,786.0
252,329,36
5
98,147,646
San Diego, CA
Aerosols
CARB Tier 2 Standards - Reform
325.4
0.0
813,420
0
Aerosols
SCAQMD Standards
325.4
0.0
3,253,680
0
Reformulati
Automobile refinishing
CARB BARCT limits
186.4
0.0
685,506
0
Automobile refinishing
FIP Rule (VOC Content & TE)
711.6
0.0
12,823,854
0
Metal product surface coating
VOC content limits & improved
241.3
0.0
6,032
0
Miscellaneous surface coating
Add-on control levels
179.2
0.0
4,992,999
0
Miscellaneous surface coating
MACT level of control
396.7
0.0
991,706
0
Nonroad gasoline
Reformulated gasoline
240.9
0.0
1,204,500
0
Open Burning
Episodic Ban
679.7
129.1
0
0
Paper surface coating
Add-on control levels
2.8
0.0
184,069
0
Pesticide Application
Reformulation - FIP rule
20.4
0.0
189,534
0
Point Source Ind. Surface Coating Add-on Control Levels
936.2
0.0
17,226,540
0
Point Sources
RE Improvements
362.4
0.0
724,890
0
Recreational vehicles
CARB standards
885.1
0.0
469,092
0
Service stations - stage l-truck un
Vapor balance & P-V valves
980.6
0.0
24,516
0
- Wood furniture surface coating
Reformulation
734.4
0.0
275,388
0
Wood product surface coating
Reformulation
6.8
0.0
170
0
Total
7,215.3
129.1
43,865,896
0
B-38
-------
Table B-6. Alternative 8H5EX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the LCS
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Industrial Boiler - Stoker
SCR
0.0
5.3
0
23,455
Industrial Boiler - Residual Oil
SCR
0.0
8.7
0
22,258
Industrial Boiler - Distillate Oil
LNB
0.0
2.7
0
3,765
Industrial Boiler - Natural Gas
SCR
0.0
205.6
0
730,049
Area Source Industrial NG Comb
RACT to small sources
0.0
14.6
0
24,646
Open Burning
Episodic Ban
183.4
34.7
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
16.4
0
133,422
Motor Vehicles
California Reform
1,274.9
474.4
3,602,027
3,381,626
Motor Vehicles
Enhanced l/M
1,140.5
991.4
394,978
789,956
Motor Vehicles
California LEV
425.0
842.6
639,267
639,267
Motor Vehicles
Reform Diesel
0.0
56.7
0
861,901
Total
3,023.8
2,653.1
4,636,272
6,610,345
Utility Boiler-PC/Wall
SCR
0.0
26,524.7
0
88,115,238
Utility Boiler - PC/Tangential
SCR
0.0
48,973.9
0
169,190,588
Utility Boiler - Oil-Gas/Wall
SCR
0.0
1,311.5
0
9,837,161
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
5.2
0
2,423,615
Industrial Boiler - PC
SCR
0.0
1,594.6
0
15,090,051
Industrial Boiler - Stoker
SCR
0.0
41.5
0
186,329
Industrial Boiler - Residual Oil
SCR
0.0
755.8
0
2,241,934
Industrial Boiler - Distillate Oil
SCR
0.0
23.0
0
130,734
Industrial Boiler - Natural Gas
SCR
0.0
662.9
0
2,674,891
Area Source Industrial NG Comb
RACT to small sources
0.0
62.2
0
107,109
Open Burning
Episodic Ban
2.417.3
458.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
334.7
0
2,729,478
Glass Manufacturing - Container
Oxy-Firing
0.0
720.8
0
4,774,851
Cement Manufacturing - Dry
SCR
0.0
451.5
0
2,279,852
Motor Vehicles
California Reform
13,454.9
8,667.4
82,160,287
77,361,722
Motor Vehicles
Enhanced l/M
3,421.6
3,126.3
1,224,295
2,448,590
Motor Vehicles
California LEV
10,540.4
18,750.8
14,761,639
14,761,639
Motor Vehicles
Reform Diesel
0.0
977.2
0
14,231,310
Total
29,834.2
113,442.5
98,146,221
408,585,092
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
1.1
0.0
76,493
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.7
0.0
16
0
Total
1.8
0.0
76,509
0
Open Burning
Episodic Ban
-19.0
-3.7
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Athens, GA
Atlanta, GA
Bakersfield, CA
Baton Rouge, LA
B-39
-------
Table B-6 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Metal product surface coating
VOC content limits & improved
0.4
0.0
20
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Adhesives - industrial
RACT
3.0
0.0
7,459
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
-1.4
0.0
-21,243
0
Miscellaneous surface coating
MACT level of control
2.1
0.0
5,299
0
Aerosols
SCAQMD Standards
Reformulati
-1.1
0.0
-7,230
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Cutback Asphalt
Switch to emulsified asphalts
17.2
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
-0.9
0.0
-23
0
Pesticide Application
Reformulation - FIP rule
-38.9
0.0
-361,287
0
Recreational vehicles
CARB standards
-7.3
0.0
-3,884
0
Motor Vehicles
Federal Reform
90.9
0.0
-129,011
0
Motor Vehicles
Enhanced l/M
134.6
138.1
51,188
102,377
Motor Vehicles
California LEV
-10.6
-24.8
-22,024
-22,024
Total
169.0
109.6
-480,736
80,353
Utility Boiler - PC/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
0.0
0
0
Utility Boiler - Cyclone
SCR
0.0
0.0
0
0
Industrial Boiler - Stoker
SCR
0.0
0.0
0
0
Industrial Boiler - Residual Oil
SCR
0.0
0.0
0
0
Industrial Boiler - Distillate Oil
SCR
0.0
0.0
0
0
Industrial Boiler - Natural Gas
SCR
0.0
0.0
0
0
IC Engines - Natural Gas
NSCR
0.0
0.0
0
0
IC Engines - Oil
SCR
0.0
0.0
0
0
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
0.0
0
0
Area Source Industrial Oil Comb
RACT to small sources
0.0
0.0
0
0
Area Source Industrial NG Comb
RACT to small sources
0.0
0.0
0
0
Residential NG Consumption
LNB Space heaters
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
0.0
0
0
Commercial Marine Vessels
Emission Fees
0.0
0.0
0
0
Industrial Boiler - Other
SCR
0.0
0,0
0
0
Industrial Cogeneration - Nat. Gas SCR
0.0
0.0
0
0
Glass Manufacturing - Container
Oxy-Firing
0.0
0.0
0
0
Municipal Waste Combustors
SNCR
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Motor Vehicles
Reform Diesel
0.0
0.0
0
0
Total
0.0
0.0
0
0
Open Burning
Episodic Ban
2,072.1
394.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
155.1
0.0
2,854,300
0
Point Source Metal Surface FIP VOC Limits
455.9
0.0
0
0
Coating
Point Sources
RE Improvements
857.1
0.0
1,714,040
0
Bulk Terminals
RACT
151.5
0.0
252,353
0
Metal product surface coating
VOC content limits & improved
239.9
0.0
7,037
0
Wood product surface coating
Reformulation
9.1
0.0
254
, 0
Wood furniture surface coating
Reformulation
746.9
0.0
315,871
0
Adhesives - industrial
RACT
112.3
0.0
280;881
0
B-40
-------
Table B-6 (continued)
Reductions
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NO*
Paper surface coating
Add-on control levels
43.5
0.0
3,044,887
0
Miscellaneous surface coating
Add-on control levels
338.3
0.0
12,751,156
0
Automobile refinishing
FIP Rule (VOC Content & TE)
492.1
0.0
7,406,063
0
Miscellaneous surface coating
MACT level of control
43.5
0.0
108,727
0
Aerosols
SCAQMD Standards
Reformulati
565.1
0.0
3,532,770
0
Aircraft surface coating
Add-on control levels
51.8
0.0
1,873,198
0
marine surface coating
Add-on control levels
9.9
0.0
143,004
0
Cutback Asphalt
Switch to emulsified asphalts
139.3
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
921.4
0.0
158,426
0
Web Offset Lithography
New CTG (carbon adsorber)
9.6
0.0
-1,187
0
Pesticide Application
Reformulation - FIP rule
130.7
0.0
1,213,893
0
Recreational vehicles
CARB standards
212.6
0.0
112,612
0
Motor Vehicles
California Reform
10,111.3
3,905.1
29,324,120
32,364,736
Motor Vehicles
Enhanced l/M
11,801.5
8,822.8
872,858
1,745,717
Motor Vehicles
California LEV
4,328.1
7,902.2
6,168,250
6,168,250
Total
33,998.6
21,024.1
72,133,513
40,278,702
Adhesives - industrial
RACT
1.3
0.0
3,276
0
Aerosols
CARB Tier 2 Standards - Reform
100.5
0.0
251,094
0
Aerosols
SCAQMD Standards
Reformulati
100.5
0.0
1,004,376
0
Automobile refinishing
CARB BARCT limits
51.8
0.0
190,706
0
Automobile refinishing
FIP Rule (VOC Content & TE)
198.0
0.0
3,567,537
0
Bulk Terminals
RACT
21.8
0.0
36,371
0
Cutback Asphalt
Switch to emulsified asphalts
14.0
0.0
0
0
marine surface coating
Add-on control levels
11.1
0.0
160,048
0
Metal product surface coating
VOC content limits & improved
67.4
0.0
1,680
0
Miscellaneous surface coating
Add-on control levels
83.5
0.0
1,305,006
0
Miscellaneous surface coating
MACT level of control
24.1
0.0
60,127
0
Motor Vehicles
Enhanced l/M
194.8
329.3
77,881
155,763
Nonroad gasoline
Reformulated gasoline
53.6
0.0
268,000
0
Open Burning
Episodic Ban
230.7
43.8
0
0
Paper surface coating
Add-on control levels
4.0
0.0
267,273
0
Pesticide Application
Reformulation - FIP rule
530.9
0.0
4,937,073
0
Point Source Metal Surface FIP VOC Limits
52.6
0.0
0
0
Coating
Point Sources
RE Improvements
3,512.0
0.0
7,024,060
0
Recreational vehicles
CARB standards
51.9
0.0
27,517
0
Service stations - stage l-truck un
Vapor balance & P-V valves
339.5
0.0
41,403
0
Wood furniture surface coating
Reformulation
93.1
0.0
34,896
0
Wood product surface coating
Reformulation
2.5
0.0
62
0
Total
5,739.6
373.1
19,258,386
155,763
Open Burning
Episodic Ban
838.2
158.8
0
0
Point Sources
RE Improvements
6,025.1
0.0
12,050,110
0
Metal product surface coating
VOC content limits & improved
199.1
0.0
4,981
0
Wood product surface coating
Reformulation
6.5
0.0
298
0
Wood furniture surface coating
Reformulation
5,374.7
0.0
2,015,519
0
Adhesives - industrial
RACT
130.6
0.0
326,390
0
Miscellaneous surface coating
Add-on control levels
1,465.0
0.0
34,136,134
0
Automobile refinishing
FIP Rule (VOC Content & TE)
357.1
0.0
5,372,689
0
Aerosols
SCAQMD Standards
Reformulati
249.4
0.0
1,558,560
0
marine surface coating
Add-on control levels
68.1
0.0
985,510
0
Cutback Asphalt
Switch to emulsified asphalts
85.3
0.0
0
0
Fresno, CA
Grand Rapids, Ml
B-41
-------
Table B-6 (continued)
Reductions
(tons per year)
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Pharmaceutical manufacture
RACT
138.2
0.0
46,285
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
37.2
0.0
14,770
0
Service stations - stage l-truck un
Vapor balance & P-V valves
355.9
0.0
8,899
0
Web Offset Lithography
New CTG (carbon adsorber)
8.5
0.0
-1,067
0
Pesticide Application
Reformulation - FIP rule
81.1
0.0
753,356
0
Recreational vehicles
CARB standards
660.0
0.0
349,778
0
Motor Vehicles
California Reform
5,771.8
2,152.6
17,444,686
16,125,166
Motor Vehicles
Enhanced l/M
5,589.0
4,425.7
456,892
913,783
Motor Vehicles
California LEV
2,132.3
3,930.0
3,060,281
3,060,281
Total
29,573.1
10,667.1
78,584,070
20,099,230
Open Burning
Episodic Ban
890.4
168.9
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
5.8
0.0
107,456
0
Point Source Metal Surface
FIP VOC Limits
102.9
0.0
0
0
Coating
Metal product surface coating
VOC content limits & improved
90.3
0.0
12,139
0
Wood product surface coating
Reformulation
4.7
0.0
116
0
Wood furniture surface coating
Reformulation
46.7
0.0
74,532
0
Paper surface coating
Add-on control levels
13.7
0.0
1,374,240
0
Miscellaneous surface coating
Add-on control levels
43.6
00
3,164,929
0
Automobile refinishing
FIP Rule (VOC Content & TE)
269.8
0.0
7,859,989
0
Aerosols
SCAQMD Standards
Reformulati
276.6
0.0
1,728,300
0
Aircraft surface coating
Add-on control levels
115.6
0.0
6,053,206
0
Service stations - stage l-truck un
Vapor balance & P-V valves
467.5
0.0
11,687
0
Pesticide Application
Reformulation - FIP rule
12.5
0.0
115,841
0
Recreational vehicles
CARB standards
296.1
0.0
156,879
0
Motor Vehicles
California Reform
710.1
1,313.5
486,500
19,984,065
Motor Vehicles
California LEV
2,649.3
4,889.5
3,811,174
3,811,174
Total
5,995.6
6,371.9
24,956,988
23,795,239
Open Burning
Episodic Ban
73.7
13 8
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
85.0
0.0
1,564,828
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
62.8
0.0
1,570
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Bulk Terminals
RACT
203.7
0.0
339,507
0
Metal product surface coating
VOC content limits & improved
5.1
0.0
129
0
Wood product surface coating
Reformulation
1.5
0.0
38
0
Wood furniture surface coating
Reformulation
12.1
0.0
4,536
0
Adhesives - industrial
RACT
27.2
0.0
68,115
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
2.6
0.0
46,902
0
Automobile refinishing
FIP Rule (VOC Content & TE)
13.3
0.0
200,944
0
Miscellaneous surface coating
MACT level of control
2.2
0.0
5,479
0
Aerosols
SCAQMD Standards
Reformulati
35.7
0.0
223,770
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Cutback Asphalt
Switch to emulsified asphalts
112.6
0.0
0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
11.8
0.0
4,674
0
Service stations - stage l-truck un
Vapor balance & P-V valves
260.9
0.0
195,467
0
Web Offset Lithography
New CTG (carbon adsorber)
10.5
0.0
-1,319
0
Pesticide Application
Reformulation - FIP rule
105.6
0.0
981,616
0
Recreational vehicles
CARB standards
21.5
0.0
11,363
0
Hartford, CT
Houston, TX
B-42
-------
Table B-6 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
Federal Reform
1,537.0
173.5
4,941,337
0
Motor Vehicles
Enhanced l/M
888.9
750.5
291,551
583,103
Motor Vehicles
California LEV
279.7
633.8
471,922
471,922
Total
3,753.4
1,571.6
9,352,429
1,055,025
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage I-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Utility Boiler -PC/Wall
SCR
0.0
28,812.3
0
98,504,407
Industrial Boiler - PC
SCR
0.0
408.0
0
3,211,810
Industrial Boiler - Stoker
SCR
0.0
160.3
0
723,909
Industrial Boiler - Residual Oil
SCR
0.0
35.1
0
89,951
Industrial Boiler - Distillate Oil
SCR
0.0
3.6
0
14,401
Industrial Boiler - Natural Gas
SCR
0.0
824.0
0
2,947,503
Area Source Industrial NG Comb
RACT to small sources
0.0
40.8
0
70,340
Open Burning
Episodic Ban
624.9
118.6
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
38.4
0
313,798
Glass Manufacturing - Container
Oxy-Firing
0.0
42.5
0
266,848
Cement Manufacturing - Dry
SCR
0.0
493.1
0
2,359,895
Cement Manufacturing - Wet
SCR
0.0
419.6
0
1,675,408
Motor Vehicles
California Reform
3,022.7
995.0
7,928,050
7,436,718
Motor Vehicles
Enhanced l/M
2,705.8
2,127.9
872,699
1,745,399
Motor Vehicles
California LEV
1,023.5
1,819.7
1,412,305
1,412,305
Motor Vehicles
Reform Diesel
0.0
113.2
0
1,623,901
Total
7,376.9
36,452.1
10,213,054
122,396,593
Utility Boiler - PC/Tangential
SCR
0.0
10,608.4
0
38,924,513
Industrial Boiler - PC
SCR
0.0
224.4
0
4,796,549
Industrial Boiler - Stoker
SCR
0.0
39.7
0
413,030
Industrial Boiler - Residual Oil
SCR
0.0
5.2
0
35,640
Industrial Boiler - Distillate Oil
SCR
0.0
19.8
0
213,310
Industrial Boiler - Natural Gas
SCR
0.0
225.7
0
1,841,638
IC Engines - Natural Gas
NSCR
0.0
1,474.8
0
1,313,705
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
246.5
0
5,652,452
Los Angeles, CA
Macon, GA
Nashville, TN
B-43
-------
Table B-6 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
New London, CT
New York, NY
Process Heaters - Natural Gas
Area Source Industrial Coal Comb
Open Burning
Nonroad Diesels
Commercial Marine Vessels
Municipal Waste Combustors
Motor Vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
Open Burning
Point Source Ind. Surface Coating
Point Sources
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Paper surface coating
Miscellaneous surface coating
Automobile refinishing
Aerosols
Aircraft surface coating
Service stations - stage l-truck un
Pesticide Application
Recreational vehicles
Motor Vehicles
Motor Vehicles
Open Burning
Point Source Ind. Surface Coating
Point Source Metal Surface
Coating
Point Source Wood Product
Coating
Point Sources
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Paper surface coating
Miscellaneous surface coating
Automobile refinishing
Miscellaneous surface coating
Aerosols
Aircraft surface coating
marine surface coating
Service stations - stage l-truck un
Pesticide Application
Recreational vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
LNB + SCR 0.0 11.3
RACT to small sources 0.0 27.7
Episodic Ban 746.4 141.4
CARB Stds for > 175 HP 0.0 104.6
Emission Fees 0.0 27.6
SNCR 0.0 131.6
California Reform 6,233.1 2,567.0
Enhanced l/M 6,669.3 5,484.2
California LEV 2,738.0 4,903.5
Reform Diesel 0.0 265.6
Total 16,386.8 26,509.0
Episodic Ban 0.0 0.0
Add-on Control Levels 0.0 0.0
RE Improvements 0.0 0.0
VOC content limits & improved 0.0 0.0
Reformulation 0.9 0.0
Reformulation 0.0 0.0
Add-on control levels 0.0 0.0
Add-on control levels 0.0 0.0
FIP Rule (VOC Content & TE) 0.0 0.0
SCAQMD Standards 0.0 0.0
Reformulati
Add-on control levels 0.0 0.0
Vapor balance & P-V valves 0.0 0.0
Reformulation - FIP rule 0.0 0.0
CARB standards 0.0 0.0
California Reform 0.0 0.0
California LEV 0.0 0.0
Total 0.9 0.0
Episodic Ban 0.0 0.0
Add-on Control Levels 0.0 0.0
FIP VOC Limits 0.0 0.0
FIP VOC Limits 0.0 0.0
RE Improvements 0.0 0.0
VOC content limits & improved 0.0 0.0
Reformulation 0.0 0.0
Reformulation 0.0 0.0
Add-on control levels 0.0 0.0
Add-on control levels 0.0 0.0
FIP Rule (VOC Content & TE) 0.0 0.0
MACT level of control 0.0 0.0
SCAQMD Standards 0.0 0.0
Reformulati
Add-on control levels 0.0 0.0
Add-on control levels 0.0 0.0
Vapor balance & P-V valves 0.0 0.0
Reformulation - FIP rule 0.0 0.0
CARB standards . 0.0 0.0
California Reform 0.0 0.0
Enhanced l/M 0.0 0.0
California LEV 0.0 0.0
Total 0.0 0.0
0
0
0
0
0
0
21,478,978
567,807
3,839,754
0
25,886,538
0
0
0
0
22
0
0
0
0
0
0
0
0
0
0
0
22
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
174,243
107,750
0
852,643
274,516
439,269
20,150,267
1,135,613
3,839,754
3,869,653
84,034,545
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
B-44
-------
Table B-6 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Owensboro, KY Utility Boiler - PC/Wall
SCR
0.0
4,635.5
0
21,299,059
Utility Boiler - PC/Tangential
SCR
0.0
1,944.4
0
7,109,311
Area Source Industrial Coal Comb
RACT to small sources
0.0
94.6
0
354,725
Area Source Industrial Oil Comb
RACT to small sources
0.0
8.8
0
18,458
Area Source Industrial NG Comb
RACT to small sources
0.0
172.4
0
272,704
Open Burning
Episodic Ban
168.3
31.9
0
0
Motor Vehicles
Federal Reform
548.9
113.3
1,709,186
0
Motor Vehicles
Enhanced l/M
740.2
470.9
191,738
383,477
Total
1,457.4
7,471.8
1,900,924
29,437,734
Philadelphia, PA Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulate
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Service stations - stage Mruck un
Vapor balance & P-V valves
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Total
0.0
0.0
0
0
Providence, Rl Open Burning
Episodic Ban
560.1
106.4
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
177.8
0.0
3,270,692
0
Point Source Metal Surface
FIP VOC Limits
129.6
0.0
0
0
Coating
Point Sources
RE Improvements
2,381.3
0.0
4,762,520
0
Metal product surface coating
VOC content limits & improved
481.8
0.0
11,958
0
Wood product surface coating
Reformulation
5.6
0.0
141
0
Wood furniture surface coating
Reformulation
403.0
0.0
151,099
0
Paper surface coating
Add-on control levels
3.3
0.0
220,089
0
Miscellaneous surface coating
Add-on control levels
195.0
0.0
3,156,486
0
Automobile refinishing
FIP Rule (VOC Content & TE)
434.2
0.0
6,533,259
0
Miscellaneous surface coating
MACT level of control
148.9
0.0
372,146
0
Aerosols
SCAQMD Standards
Reformulati
296.8
0.0
1,854,330
0
marine surface coating
Add-on control levels
134.5
0.0
1,946,944
0
Service stations - stage I-truck un
Vapor balance & P-V valves
356.5
0.0
8,909
0
Pesticide Application
Reformulation - FIP rule
2.8
0.0
26,709
0
Recreational vehicles
CARB standards
789.7
0.0
418,473
0
Motor Vehicles
California Reform
590.1
1,002.0
737,000
15,574,996
Motor Vehicles
California LEV
2,302.1
3,756.5
2,980,279
2,980,279
Total
9,393.1
4,864.9
26,451,034
18,555,275
B-45
-------
Table B-6 (continued)
Reductions
(tons per year)
Costs
(1990S)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
CARB Tier 2 Standards - Reform
190.8
0.0
476,892
0
Aerosols
SCAQMD Standards
Reformulati
190.7
0.0
1,907,568
0
Automobile refinishing
CARB BARCT limits
123.8
0.0
455,517
0
Automobile refinishing
FIP Rule (VOC Content & TE)
472.8
0.0
8,521,420
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
0
Metal product surface coating
VOC content limits & improved
228.4
0.0
5,663
0
Miscellaneous surface coating
Add-on control levels
116.6
0.0
1,886,434
0
Miscellaneous surface coating
MACT level of control
91.7
0.0
229,219
0
Nonroad gasoline
Reformulated gasoline
101.3
0.0
506,500
0
Open Burning
Episodic Ban
429.8
81.3
0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
0
Pesticide Application
Reformulation - FIP rule
113.8
0.0
1,058,898
0
Point Source Ind. Surface Coating Add-on Control Levels
361.7
0.0
6,655,556
0
Point Source Metal Surface FIP VOC Limits
313.9
0.0
0
0
Coating
Point Sources
RE Improvements
40.5
0.0
81,030
0
Recreational vehicles
CARB standards
97.3
0.0
51,601
0
Service stations - stage l-truck un
Vapor balance & P-V valves
646.7
0.0
16,167
0
Wood furniture surface coating
Reformulation
240.2
0.0
90,098
0
Wood product surface coating
Reformulation
16.0
0.0
399
0
Total
3,783.3
81.3
22,209,888
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0 .
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
256.4
0
6,961,478
Industrial Boiler - PC
SCR
0.0
44.3
0
948,195
Industrial Boiler - Stoker
SCR
0.0
108.2
0
1,127,084
Industrial Boiler - Residual Oil
SCR
0.0
141.9
0
976,271
Industrial Boiler - Natural Gas
SCR
0.0
159.9
0
1,342,660
IC Engines - Natural Gas
NSCR
0.0
58.5
0
179,810
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
106.6
0
511,328
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
146.7
0
731,902
Residential NG Consumption
LNB Space heaters
0.0
531.5
0
653,642
Open Burning
Episodic Ban
2,129.9
404.0
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
33.8
0
275,292
Commercial Marine Vessels
Emission Fees
0.0
252.3
0
2,523,158
Motor Vehicles
California Reform
398.0
672.7
467,000
10,679,254
Sacramento, CA
San Diego, CA
Springfield, MA
B-46
-------
Table B-6 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
California LEV
1,714.3
2,857.2
2,038,322
2,038,322
Motor Vehicles
Reform Diesel
0.0
134.5
0
1,911,328
Total
4,242.2
5,908.5
2,505,322
30,859,724
Utility Boiler - PC/Wall
SCR
0.0
28,076.6
0
86,025,342
Utility Boiler - PC/Tangential
SCR
0.0
25,456.0
0
101,567,747
Utility Boiler - Oil-Gas/Wall
SCR
0.0
5,738.6
0
52,216,489
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
3,364.4
0
41,194,478
Utility Boiler - Cyclone
SCR
0.0
2,833.2
0
33,909,713
Industrial Boiler - PC
SCR
0.0
3,950.8
0
31,280,313
Industrial Boiler - Stoker
SCR
0.0
111.5
0
1,161,708
Industrial Boiler - Residual Oil
SCR
0.0
713.4
0
4,674,888
Industrial Boiler - Distillate Oil
SCR
0.0
107.4
0
1,126,417
Industrial Boiler - Natural Gas
SCR
0.0
936.8
0
7,865,392
IC Engines - Oil
SCR
0.0
362.2
0
1,968,033
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
48.8
0
2,592,825
Process Heaters - Natural Gas
LNB + SCR
0.0
6.3
0
183,156
Area Source Industrial Coal Comb
RACT to small sources
0.0
29.7
0
118,154
Area Source Industrial Oil Comb
RACT to small sources
0.0
13.1
0
20,421
Area Source Industrial NG Comb
RACT to small sources
0.0
45.6
0
65,735
Residential NG Consumption
LNB Space heaters
0.0
2,607.8
0
3,207,326
Open Burning
Episodic Ban
911.4
173.4
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
486.9
0
3,972,107
Commercial Marine Vessels
Emission Fees
0.0
536.0
0
5,358,057
Industrial Boiler - Other
SCR
0.0
15.8
0
169,106
Glass Manufacturing - Container
Oxy-Firing
0.0
59.9
0
396,919
Cement Manufacturing - Dry
SCR
0.0
2,187.8
0
11,048,592
Cement Manufacturing - Wet
SCR
0.0
808.4
0
3,405,438
Iron & Steel Mills - Reheating
LNB + FGR
0.0
444.8
0
233,562
Iron & Steel Mills - Annealing
LNB + SCR
0.0
70.3
0
360,338
Municipal Waste Combustors
SNCR
0.0
140.2
0
467,984
Point Source Ind. Surface Coating
Add-on Control Levels
353.0
0.0
6,494,372
0
Point Source Metal Surface
FIP VOC Limits
824.2
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
7.3
0.0
183
0
Coating
Point Sources
RE Improvements
5,634.0
0.0
11,268,280
0
Bulk Terminals
RACT
833.1
0.0
1,388,281
0
Metal product surface coating
VOC content limits & improved
645.8
0.0
28,410
0
Wood product surface coating
Reformulation
26.9
0.0
810
0
Wood furniture surface coating
Reformulation
1,229.7
0.0
469,264
0
Adhesives - industrial
RACT
176.5
0.0
441,529
0
Paper surface coating
Add-on control levels
83.3
0.0
3,404,679
0
Miscellaneous surface coating
Add-on control levels
455.2
0.0
8,406,296
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,273.6
0.0
34,205,397
0
Miscellaneous surface coating
MACT level of control
129.3
0.0
323,092
0
Aerosols
SCAQMD Standards
Reformulati
1,895.6
0.0
11,844,990
0
Aircraft surface coating
Add-on control levels
21.9
0.0
787,137
0
marine surface coating
Add-on control levels
105.4
0.0
1,522,900
0
Cutback Asphalt
Switch to emulsified asphalts
234.1
0.0
0
0
Synthetic fiber manufacture
RACT (adsorber)
1,408.2
0.0
1,991,973
0
Service stations - stage I-truck un
Vapor balance & P-V valves
3,690.7
0.0
604,238
0
Web Offset Lithography
New CTG (carbon adsorber)
38.2
0.0
-4,787
0
Pesticide Application
Reformulation - FIP rule
233.8
0.0
2,173,301
0
Washington, DC
B-47
-------
Table B-6 (continued)
Reductions Costs
jtons per year) (1990$)
Nonattainment Area Source Category
Control Measure
voc
NOx
VOC
NOx
Recreational vehicles
CARB standards
838.9
0.0
444,536
0
Motor Vehicles
Federal Reform
2,980.7
580.8
12,457,815
0
Motor Vehicles
Enhanced l/M
2,309.2
2,294.4
881,214
1,762,429
Motor Vehicles
California LEV
15,654.8
28,610.7
22,493,022
22,493,022
Motor Vehicles
Reform Diesel
0.0
1,483.5
0
21,669,143
Total 42,994.8 112,295.1
121,626,93
2
440,514,833
B-48
-------
Table B-7. Alternative 8H4AX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the LCS
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category Control Measure VOC NOx VOC NOx
Athens, GA Industrial Boiler - Stoker SNCR 0.0 3.7 0 7,766
Industrial Boiler - Residual Oil SCR 0.0 8.7 0 22,256
Industrial Boiler - Distillate Oil LNB 0.0 2.7 0 3,765
Industrial Boiler - Natural Gas SCR 0.0 205.6 0 730,049
Area Source Industrial NG Comb RACT to small sources 0.0 14.6 0 24,646
Open Burning Episodic Ban 163.4 34.7 0 0
Nonroad Diesels CARB Stdsfor > 175 HP 0.0 16.4 0 133,422
Motor Vehicles California Reform 1,274.9 474.4 3,602,027 3,381,626
Motor Vehicles Enhanced l/M 1,140.5 991.4 394,978 789,956
Motor Vehicles California LEV 425.0 842.6 639,267 639,267
Motor Vehicles Reform Diesel 0.0 56.7 0 861,901
Total 3,023.8 2,651.5 4,636,272 6,594,656
Atlanta, GA Utility Boiler - PC/Wall SCR 0.0 26,524.7 0 88,115,238
Utility Boiler-PC/Tangential SCR 0.0 48,973.9 0 169,190,588
Utility Boiler - Oil-Gas/Wall SCR 0.0 1,311.5 0 9,837,161
Utility Boiler-Oil-Gas/Tangential SCR 0.0 5.2 0 2,423,615
Industrial Boiler-PC SCR 0.0 1,594.6 0 15,090,051
Industrial Boiler - Stoker SCR 0.0 41.5 0 166,329
Industrial Boiler-Residual Oil SCR 0.0 755.8 0 2,241,934
Industrial Boiler - Distillate Oil SCR 0.0 23.0 0 130,734
Industrial Boiler - Natural Gas SCR 0.0 662.9 0 2,674,891
Area Source Industrial NG Comb RACT to small sources 0.0 62.2 0 107,109
Open Burning Episodic Ban 2,417.3 458.5 0 0
Nonroad Diesels CARB Stdsfor >175 HP 0.0 334.7 0 2,729,478
Glass Manufacturing - Container Oxy-Firtng 0.0 720.8 0 4,774,851
Cement Manufacturing - Dry SCR 0.0 45t.5 0 2,279,852
Motor Vehicles California Reform 13,454.9 8,667.4 62,160,287 77,361,722
Motor Vehicles Enhanced l/M 3,421.6 3,126.3 1,224,295 2,448,590
Motor Vehicles California LEV 10,540.4 18,750.8 14,761,639 14,761,639
Motor Vehicles Reform Diesel 0.0 977.2 0. 14,231,310
Total 29,834.2 113,442.5 98,146,221 408,585,092
Bakersfield, CA Aerosols CARB Tier 2 Standards - Reform 0.0 0.0 0 0
Aerosols SCAQMD Standards 0.0 0.0 0 0
ReformuEati
Aircraft surface coating Add-on control levels 0.0 0.0 0 0
Automobile refinishing CARB BARCT limits 0.0 0.0 0 0
Automobile refinishmg F1P Rule (VOC Content & TE) 0.0 0.0 0 0
Metal product surface coating VOC content limits & improved 0.0 0.0 0 0
Miscellaneous surface coating Add-on control levels 0.0 0.0 0 0
Miscellaneous surface coating MACT level of control 0.0 0.0 0 0
Nonroad gasoline Reformulated gasoline 0.0 0.0 0 0
Open Burning Episodic Ban 0.0 0.0 0 0
Paper surface coating Add-on control levels 1.1 0.0 76,493 0
Pesticide Application Reformulation - FIP rule 0.0 0.0 0 0
Point Sources RE Improvements 0.0 0.0 0 0
Recreational vehicles CARB standards 0.0 0.0 0 0
Service stations - stage l-truck un Vapor balance & P-V valves 0.0 0.0 0 0
Wood furniture surface coating Reformulation 0.0 0.0 0 0
Wood product surface coating Reformulation 0.7 0.0 16 0
Total 1.8 0.0 76,509 0
Bangor, ME Utility Boiler • Oil-Gas/Wall SCR 0.0 17.5 0 115,439
Industrial Boiler - Residual Oil SCR 0.0 959.5 0 6,597,030
B-49
-------
Table B-7 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Area Source Industrial Oil Comb
RACT to small sources
0.0
5.1
0
10,356
Area Source Industrial NG Comb
RACT to small sources
0.0
1.9
0
2,766
Open Burning
Episodic Ban
453.0
85.9
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
2.7
0
21,307
Commercial Marine Vessels
Emission Fees
0.0
8.5
0
85,048
Motor Vehicles
California Reform
907.7
573.6
3,170,613
5,481,359
Motor Vehicles
Enhanced l/M
1,671.7
1,380.8
550,911
1,101,822
Motor Vehicles
California LEV
648.1
1,359.5
1,031,460
1,031,460
Motor Vehicles
Reform Diesel
0.0
102.7
0
1,586,852
Total
3,680.5
4,497.7
4,752,984
16,033,439
Open Burning
Episodic Ban
-19.0
-3.7
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.4
0.0
20
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Adhesives - industrial
RACT
3.0
0.0
7,459
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
-1.4
0.0
-21,243
0
Miscellaneous surface coating
MACT level of control
2.1
0.0
5,299
0
Aerosols
SCAQMD Standards
Reformulati
-1.1
0.0
-7,230
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Cutback Asphalt
Switch to emulsified asphalts
17.2
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
-0.9
0.0
-23
0
Pesticide Application
Reformulation - FIP rule
-38.9
0.0
-361,287
0
Recreational vehicles
CARB standards
-7.3
0.0
-3,884
0
Motor Vehicles
Federal Reform
90.9
0.0
-129,011
0
Motor Vehicles
Enhanced l/M
134.6
138.1
51,188
102,377
Motor Vehicles
California LEV
-10.6
-24.8
-22,024
-22,024
Total
169.0
109.6
-480,736
80,353
Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Total
0.0
0.0
0
0
Utility Boiler - PC/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
0.0
0
0
Utility Boiler - Cyclone
SCR
0.0
0.0
0
0
Industrial Boiler - Stoker
SCR
0.0
0.0
0
0
Industrial Boiler - Residual Oil
SCR
0.0
0.0
0
0
Industrial Boiler - Distillate Oil
SCR
0.0
0.0
0
0
Industrial Boiler - Natural Gas
SCR
0.0
0.0
0
0
IC Engines - Natural Gas
NSCR
0.0
0.0
0
0
IC Engines - Oil
SCR
0.0
0.0
0
0
Gas Turbines-Oil
SCR ~ WATER INJECTION
0.0
0.0
0
0
Area Source Industrial Oil Comb
RACT to small sources
0.0
0.0
0
0
Area Source Industrial NG Comb
RACT to small sources
0.0
0.0
0
0
Residential NG Consumption
LNB Space heaters
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Baton Rouge, LA
Beaumont, TX
Boston, MA
B-50
-------
Table B-7 (continued)
Reductions
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Nonroad Diesels
CARB Stds for > 175 HP
0.0
0.0
0
0
Commercial Marine Vessels
Emission Fees
0.0
0.0
0
0
Industrial Boiler - Other
SCR
0.0
0.0
0
0
Industrial Cogeneration - Nat. Gas
SCR
0.0
0.0
0
0
Glass Manufacturing - Container
Oxy-Firing
0.0
0.0
0
0
Municipal Waste Combustors
SNCR
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Motor Vehicles
Reform Diesel
0.0
0.0
0
0
Total
0.0
0.0
0
0
Open Burning
Episodic Ban
2,815.3
534.1
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
3,534.3
0.0
65,031,028
0
Point Source Metal Surface
FIP VOC Limits
7,008.5
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
78.8
0.0
1,971
0
Coating
Point Sources
RE Improvements
9,297.3
0.0
18,594,560
0
Bulk Terminals
RACT
156.2
0.0
260,239
0
Metal product surface coating
VOC content limits & improved
3,668.8
0.0
128,230
0
Wood product surface coating
Reformulation
26.6
0.0
682
0
Wood furniture surface coating
Reformulation
1,275.3
0.0
1,590,807
0
Adhesives - industrial
RACT
331.6
0.0
828,791
0
Paper surface coating
Add-on control levels
40.3
0.0
3,027,556
0
Miscellaneous surface coating
Add-on control levels
1,570.4
0.0
39,738,704
0
Automobile refinishing
FIP Rule (VOC Content & TE)
3,285.2
0.0
49,424,510
0
Miscellaneous surface coating
MACT level of control
1,317.1
0.0
3,292,516
0
Aerosols
SCAQMD Standards
Reformulati
2,458.6
0.0
15,363,210
0
Aircraft surface coating
Add-on control levels
8.5
0.0
288,264
0
marine surface coating
Add-on control levels
99.5
0.0
1,440,735
0
Cutback Asphalt
Switch to emulsified asphalts
305.7
0.0
0
0
Pharmaceutical manufacture
RACT
3.7
0.0
1,245
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
3,489.1
0.0
345,038
0
Web Offset Lithography
New CTG (carbon adsorber)
36.2
0.0
-4,532
0
Pesticide Application
Reformulation - FIP rule
479.6
0.0
4,459,519
0
Recreational vehicles
CARB standards
1,404.9
0.0
744,518
0
Motor Vehicles
California Reform
6,002.9
7,555.5
66,425,541
57,839,073
Motor Vehicles
Enhanced l/M
1,994.0
1,579.0
630,296
1,260,592
Motor Vehicles
California LEV
17,287.5
27,888.6
22,137,966
22,137,966
Total
67,975.9
37,557.2 293,751,393
81,237,630
Open Burning
Episodic Ban
2,072.1
394.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
155.1
0.0
2,854,300
0
Point Source Metal Surface
FIP VOC Limits
455.9
0.0
0
0
Coating
Point Sources
RE Improvements
857.1
0.0
1,714,040
0
Bulk Terminals
RACT
151.5
0.0
252,353
0
Metal product surface coating
VOC content limits & improved
239.9
0.0
7,037
0
Wood product surface coating
Reformulation
9.1
0.0
254
0
Wood furniture surface coating
Reformulation
746.9
0.0
315,871
0
Adhesives - industrial
RACT
112.3
0.0
280,881
0
Paper surface coating
Add-on control levels
43.5
0.0
3,044,887
0
Miscellaneous surface coating
Add-on control levels
338.3
0.0
12,751,156
0
Automobile refinishing
FIP Rule (VOC Content & TE)
492.1
0.0
7,406,063
0
Miscellaneous surface coating
MACT level of control
43.5
0.0
108,727
0
Chicago, IL
Cincinnati, OH
B-51
-------
Table B-7 (continued)
Reductions
Costs
11990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
Reformulati
565.1
0.0
3,532,770
0
Aircraft surface coating
Add-on control levels
51.8
0.0
1,873,198
0
marine surface coating
Add-on control levels
9.9
0.0
143,004
0
Cutback Asphalt
Switch to emulsified asphalts
139.3
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
921.4
0.0
158,426
0
Web Offset Lithography
New CTG (carbon adsorber)
9.6
0.0
-1,187
0
Pesticide Application
Reformulation - FIP rule
130.7
0.0
1,213,893
0
Recreational vehicles
CARB standards
212.6
0.0
112,612
0
Motor Vehicles
California Reform
10,111.3
3,905.1
29,324,120
32,364,736
Motor Vehicles
Enhanced l/M
11,801.5
8,822.8
872,858
1,745,717
Motor Vehicles
California LEV
4,328.1
7,902.2
6,168,250
6,168,250
Total
33,993.6
21,024.1
72,133,513
40,278,702
Open Burning
Episodic Ban
2,255.6
427.5
0
0
Point Source Ind. Surface Coating Add-on Control Levels
4,042.7
0.0
74,386,416
0
Point Source Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
204.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
208.0
0.0
5,202
0
Coating
Point Sources
RE Improvements
14,125.2
0.0
28,250,270
0
Bulk Terminals
RACT
712.2
0.0
1,186,847
0
Metal product surface coating
VOC content limits £ improved
1,188.4
0.0
42,077
0
Wood product surface coating
Reformulation
19.1
0.0
959
0
Wood furniture surface coating
Reformulation
711.9
0.0
592,881
0
Adhesives - industrial
RACT
361.5
0.0
903,835
0
Paper surface coating
Add-on control levels
77.3
0.0
6,161,139
0
Miscellaneous surface coating
Add-on control levels
745.5
0.0
17,541,443
0
Automobile refinishing
FIP Rule (VOC Content & TE)
1,344.4
0.0
20,223,851
0
Miscellaneous surface coating
MACT level of control
865.5
0.0
2,163,542
0
Aerosols
SCAQMD Standards
Reformulati
1,192.9
0.0
7,455,390
0
Aircraft surface coating
Add-on control levels
33.1
0.0
1,043,143
0
marine surface coating
Add-on control levels
74.8
0.0
1,082,729
0
SOCMI batch reactor processes
New CTG
1.7
0.0
7,007
0
Cutback Asphalt
Switch to emulsified asphalts
519.3
0.0
0
0
Petroleum refinery fugitives
RACT
167.1
0.0
-75,186
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
90.9
0.0
36,011
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,654.1
0.0
854,297
0
Web Offset Lithography
New CTG (carbon adsorber)
48.6
0.0
-6,077
0
Pesticide Application
Reformulation - FIP rule
184.5
0.0
1,715,814
0
Recreational vehicles
CARB standards
795.3
0.0
421.475
0
Motor Vehicles
Federal Reform
5,207.4
778.9
14,270,041
0
Motor Vehicles
Enhanced l/M
27,236.5
20,913.7
2,475,143
4,950,287
Motor Vehicles
California LEV
10,260.7
18,817.9
14,780,676
14,780,676
Total
75,528.2
40,938.0 195,518,925
19,730,963
Adhesives • industrial
RACT
1.3
0.0
3,276
0
Aerosols
CARB Tier 2 Standards - Reform
100.5
0.0
251,094
0
Aerosols
SCAQMD Standards
Reformulati
100.5
0.0
1,004,376
0
Automobile refinishing
CARB BARCT limits
51.8
0.0
190,706
0
Automobile refinishing
FIP Rule (VOC Content & TE)
198.0
0.0
3,567,537
0
Bulk Terminals
RACT
21.8
0.0
36,371
0
Cutback Asphalt
Switch to emulsified asphalts
14.0
0.0
0
0
Dallas, TX
Fresno, CA
B-52
-------
Table B-7 (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
marine surface coating
Add-on control levels
11.1
0.0
160,048
0
Metal product surface coating
VOC content limits & improved
67.4
0.0
1,680
0
Miscellaneous surface coating
Add-on control levels
83.5
0.0
1,305,006
0
Miscellaneous surface coating
MACT level of control
24.1
0.0
60,127
0
Motor Vehicles
Enhanced l/M
194.8
329.3
77,881
155,763
Nonroad gasoline
Reformulated gasoline
53.6
0.0
268,000
0
Open Burning
Episodic Ban
230.7
43.8
0
0
Paper surface coating
Add-on control levels
4.0
0.0
267,273
0
Pesticide Application
Reformulation - FIP rule
530.9
0.0
4,937,073
0
Point Source Metal Surface FIP VOC Limits
52.6
0.0
0
0
Coating
Point Sources
RE Improvements
3,512.0
0.0
7,024,060
0
Recreational vehicles
CARB standards
51.9
0.0
27,517
0
Service stations - stage l-truck un
Vapor balance & P-V valves
339.5
0.0
41,403
0
Wood furniture surface coating
Reformulation
93.1
0.0
34,896
0
Wood product surface coating
Reformulation
2.5
0.0
62
0
Total
5,739.6
373.1
19,258,386
155,763
Open Burning
Episodic Ban
838.2
158.8
0
0
Point Sources
RE Improvements
6,025.1
0.0
12,050,110
0
Metal product surface coating
VOC content limits & improved
199.1
0.0
4,981
0
Wood product surface coating
Reformulation
6.5
0.0
298
0
Wood furniture surface coating
Reformulation
5,374.7
0.0
2,015,519
0
Adhesives - industrial
RACT
130.6
0.0
326,390
0
Paper surface coating
Add-on control levels
28.4
0.0
1,816,557
0
Miscellaneous surface coating
Add-on control levels
1,465.0
0.0
34,136,134
0
Automobile refinishing
FIP Rule (VOC Content & TE)
357.1
0.0
5,372,689
0
Aerosols
SCAQMD Standards
Reformulati
249.4
0.0
1,558,560
0
Aircraft surface coating
Add-on control levels
5.6
0.0
200,467
0
marine surface coating
Add-on control levels
68.1
0.0
985,510
0
Cutback Asphalt
Switch to emulsified asphalts
85.3
0.0
0
0
Pharmaceutical manufacture
RACT
138.2
0.0
46,285
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
37.2
0.0
14,770
0
Service stations - stage l-truck un
Vapor balance & P-V valves
355.9
o.o
8,899
0
Web Offset Lithography
New CTG (carbon adsorber)
8.5
0.0
-1,067
0
Pesticide Application
Reformulation - FIP rule
81.1
0.0
753,356
0
Recreational vehicles
CARB standards
660.0
0.0
349,778
0
Motor Vehicles
California Reform
5,771.8
2,152.6
17,444,686
16,125,166
Motor Vehicles
Enhanced l/M
5,589.0
4,425.7
456,892
913,783
Motor Vehicles
California LEV
2,132.3
3,930.0
3,060,281
3,060,281
Total
29,607.1
10,667.1
80,601,094
20,099,230
Open Burning
Episodic Ban
890.4
168.9
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
5.8
0.0
107,456
0
Point Source Metal Surface FIP VOC Limits
102.9
0.0
0
0
Coating
Metal product surface coating
VOC content limits & improved
90.3
0.0
12,139
0
Wood product surface coating
Reformulation
4.7
0.0
116
0
Wood furniture surface coating
Reformulation
46.7
0.0
74,532
0
Paper surface coating
Add-on control levels
13.7
0.0
1,374,240
0
Miscellaneous surface coating
Add-on control levels
43.6
0.0
3,164,929
0
Automobile refinishing
FIP Rule (VOC Content &TE)
269.8
0.0
7,859,989
0
Aerosols
SCAQMD Standards
Reformulati
276.6
0.0
1,728,300
0
Aircraft surface coating
Add-on control levels
115.6
0.0
6,053,206
0
Grand Rapids, Ml
Hartford, CT
B-53
-------
Table B-7 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Service stations - stage l-lruck un
Vapor balance & P-V valves
467.5
0.0
11,687
0
Pesticide Application
Reformulation - FIP rule
12.5
0.0
115,841
0
Recreational vehicles
CARB standards
296.1
0.0
156,B79
0
Motor Vehicles
California Reform
710.1
1,313.5
486,500
19,984,065
Motor Vehicles
California LEV
2,649.3
4,889.5
3,811,174
3,811,174
Total
5,995.6
6,371.9
24,956,988
23,795,239
Open Burning
Episodic Ban
73.7
13.8
0
0
Point Source Ind. Surface Coating Add-on Control Levels
65.0
0.0
1,564,828
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
62.8
0.0
1,570
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Bulk Terminals
RACT
203.7
0.0
339,507
0
Metal product surface coating
VOC content limits & improved
5.1
0.0
129
0
Wood product surface coating
Reformulation
1.5
0.0
38
0
Wood furniture surface coating
Reformulation
12.1
0.0
4,536
0
Adhesives - industrial
RACT
27.2
0.0
68,115
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
2.6
0.0
46,902
0
Automobile refinishing.
FIP Rule (VOC Content & TE)
13.3
0.0
200,944
0
Miscellaneous surface coating
MACT level of control
2.2
0.0
5,479
0
Aerosols
SCAQMD Standards
Reformulati
35.7
0.0
223,770
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Cutback Asphalt
Switch to emulsified asphalts
112.6
0.0
0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
11.8
0.0
4,674
0
Service stations - stage l-truck un
Vapor balance & P-V valves
260.9
0.0
195,467
0
Web Offset Lithography
New CTG (carbon adsorber)
10.5
0.0
-1,319
0
Pesticide Application
Reformulation - FIP rule
105.6
0.0
981,616
0
Recreational vehicles
CARB standards
21.5
0.0
11,363
, 0
Motor Vehicles
Federal Reform
1,537.0
173.5
4,941,337
0
Motor Vehicles
Enhanced l/M
888.9
750.5
291,551
583,103
Motor Vehicles
California LEV
279.7
633.8
471,922
471,922
Total
3,753.4
1,571.6
9,352,429
1,055,025
Open Burning
Episodic Ban
461.9
87.1
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
12.4
0.0
228,344
0
Point Sources
RE Improvements
6,281.0
0.0
12,561,840
0
Bulk Terminals
RACT
36.6
0.0
60,913
0
Metal product surface coating
VOC content limits & improved
43.3
0.0
1,721
0
Wood furniture surface coating
Reformulation
26.8
0.0
10,523
0
Adhesives - industrial
RACT
24.5
0.0
61,210
0
Miscellaneous surface coating
Add-on control levels
10.0
0.0
164,121
0
Automobile refinishing
FIP Rule (VOC Content & TE)
61.0
0.0
917,840
0
Miscellaneous surface coating
MACT level of control
13.7
0.0
34,223
0
Aerosols
SCAQMD Standards
Reformulati
106.8
0.0
666,870
0
1
marine surface coating
Add-on control levels
5.7
0.0
82,393
0
SOCMI batch reactor processes
New CTG
105.1
0.0
426,152
0
Cutback Asphalt
Switch to emulsified asphalts
89.7
0.0
0
0
SOCMI fugitives
RACT
61.3
0.0
8,345
0
Service stations • stage l-truck un
Vapor balance & P-V valves
244.1
0.0
93,639
0
Web Offset Lithography
New CTG (carbon adsorber)
8.9
0.0
-1,118
0
Pesticide Application
Reformulation - FIP rule
4.3
0.0
39,618
0
Houston, TX
Huntington, WV
B-54
-------
Table B-7 (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Recreational vehicles
CARB standards
35.7
0.0
18,917
0
Motor Vehicles
California Reform
1,767.2
782.3
6,151,689
5,771,978
Motor Vehicles
Enhanced l/M
2,025.9
1,628.6
298,423
596,847
Motor Vehicles
California LEV
726.0
1,426.9
1,091,952
1,091,952
Total
12,151.9
3,924.9
22,917,615
7,460,777
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Utility Boiler - PC/Wall
SCR
0.0
28,812.3
0
98,504,407
Industrial Boiler - PC
SCR
0.0
408.0
0
3,211,810
Industrial Boiler - Stoker
SCR
0.0
160.3
0
723,909
Industrial Boiler - Residual Oil
SCR
0.0
35.1
0
89,951
Industrial Boiler - Distillate Oil
SCR
0.0
12.4
0
58,747
Industrial Boiler - Natural Gas
SCR
0.0
855.4
0
3,059,200
Area Source Industrial NG Comb
RACT to small sources
0.0
41.0
0
70,666
Open Burning
Episodic Ban
656.6
124.6
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
39.5
0
322,834
Glass Manufacturing - Container
Oxy-Firing
0.0
42.5
0
266,848
Cement Manufacturing - Dry
SCR
0.0
493.1
0
2,359,895
Cement Manufacturing - Wet
SCR
0.0
419.6
0
1,675,408
Motor Vehicles
California Reform
3,119.2
1,037.4
8,244,797
7,735,816
Motor Vehicles
Enhanced l/M
2,797.9
2,220.0
907,374
1,814,747
Motor Vehicles
California LEV
1,055.4
1,894.1
1,468,434
1,468,434
Motor Vehicles
Reform Diesel
0.0
120.3
0
1,717,327
Total
7,629.1
36,715.6
10,620,604
123,079,999
Aerosols
CARB Tier 2 Standards - Reform
46.7
0.0
116,760
0
Aerosols
SCAQMD Standards
Reformulati
46.7
0.0
467,040
0
Automobile refinishing
CARB BARCT limits
30.0
0.0
110,381
0
Automobile refinishing
FIP Rule (VOC Content & TE)
114.6
0.0
2,064,926
0
Metal product surface coating
VOC content limits & improved
352.8
0.0
8,725
0
Miscellaneous surface coating
Add-on control levels
64.2
0.0
1,006,908
0
Los Angeles, CA
Macon, GA
Modesto. CA
B-55
-------
Table B-7 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Miscellaneous surface coating
MACT level of control
17.1
0.0
42,760
0
Nonroad gasoline
Reformulated gasoline
25.1
0.0
125,500
0
Open Burning
Episodic Ban
97.6
18.5
0
0
Paper surface coating
Add-on control levels
9.4
0.0
632,619
0
Pesticide Application
Reformulation - FIP rule
108.9
0.0
1,012,621
0
Point Source Ind. Surface Coating Add-on Control Levels
74.1
0.0
1,363,348
0
Point Source Metal Surface FIP VOC Limits
61.0
0.0
0
0
Coating
Recreational vehicles
CARB standards
24.4
0.0
12,907
0
Service stations - stage l-truck un
Vapor balance & P-V valves
131.9
0.0
3,297
0
Wood furniture surface coating
Reformulation
78.4
0.0
29,408
0
Wood product surface coating
Reformulation
2.5
0.0
63
0
Total
1,285.4
18.5
6,997,263
0
Utility Boiler - PC/Tangential
SCR
0.0
10,608.4
0
38,924,513
Industrial Boiler - PC
SCR
0.0
224.4
0
4,796,549
Industrial Boiler - Stoker
SCR
0.0
39.7
0
413,030
Industrial Boiler - Residual Oil
SCR
0.0
5.2
0
35,640
Industrial Boiler - Distillate Oil
SCR
0.0
19.8
0
213,310
Industrial Boiler - Natural Gas
SCR
0.0
225.7
0
1,841,638
IC Engines - Natural Gas
NSCR
0.0
1,474.8
0
1,313,705
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
37.3
0
801,585
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
246.5
0
5,652,452
Process Heaters - Natural Gas
LNB + SCR
0.0
11.3
0
174,243
Area Source Industrial Coal Comb
RACT to small sources
0.0
27.7
0
107,750
Open Burning
Episodic Ban
746.4
141.4
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
104.6
0
852,643
Commercial Marine Vessels
Emission Fees
0.0
27.6
0
274,516
Municipal Waste Combustors
SNCR
0.0
131.6
0
439,269
Motor Vehicles
California Reform
6,233.1
2,567.0
21,478,978
20,150,267
Motor Vehicles
Enhanced l/M
6,669.3
5,484.2
567,807
1,135,613
Motor Vehicles
California LEV
2,738.0
4,903.5
3,839,754
3,839,754
Motor Vehicles
Reform Diesel
0.0
265.6
0
3,869,653
Total
16,386.8
26,546.3
25,886,538
84,836,130
Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Total
0.0
0.0
0
0
Open burning
Seasonal/episodic ban
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface FIP VOC Limits
0.0
0.0
0
0
Coating
Nashville. TN
New London, CT
New York, NY
B-56
-------
Table B-7 (continued)
Reductions
Costs
(tons per year)
(1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Point Source Wood Product FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
Enhanced l/M
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Total
0.0
0.0
0
0
Owensboro, KY Utility Boiler - PC/Wall
SCR
0.0
4,635.5
0
21,299,059
Utility Boiler - PC/Tangential
SCR
0.0
1,944.4
0
7,109,311
Utility Boiler - Cyclone
SCR
0.0
849.3
0
17,090,889
Industrial Boiler - Stoker
SCR
0.0
98.9
0
1,015,716
Industrial Boiler - Residual Oil
SCR
0.0
2.6
0
18,936
Industrial Boiler - Natural Gas
SCR
0.0
30.5
0
244,273
Area Source Industrial Coal Comb
RACT to small sources
0.0
94.6
0
354,725
Area Source Industrial Oil Comb
RACT to small sources
0.0
8.8
0
18,458
Area Source Industrial NG Comb
RACT to small sources
0.0
172.4
0
272,704
Open Burning
Episodic Ban
168.3
31.9
0
0
Nonroad Diesets
CARB Stds for > 175 HP
0.0
6.4
0
52,795
Commercial Marine Vessels
Emission Fees
0.0
307.2
0
3,072,058
Motor Vehicles
California Reform
613.7
219.5
2,568,215
818,529
Motor Vehicles
Enhanced l/M
740.2
470.9
191,738
383,477
Motor Vehicles
California LEV
226.7
400.1
310,311
310,311
Total
1,748.9
9,273.0
3,070,263
52,061,240
Philadelphia, PA Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
B-57
-------
Table B-7 (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
marine surface coating
Add-on control levels
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Total
0.0
0.0
0
0
Bulk Terminals
RACT
219.5
0.0
365,885
0
Cutback Asphalt
Switch to emulsified asphalts
208.2
0.0
0
0
Metal product surface coating
VOC content limits & improved
382.9
0.0
9,546
0
Motor Vehicles
Enhanced l/M
10,296.0
9,747.0
1,458,678
2,917,357
Open Burning
Episodic Ban
2,140.3
405.9
0
0
Pharmaceutical manufacture
RACT
4.2
0.0
1,408
0
Point Source Metal Surface FIP VOC Limits
139.8
0.0
0
0
Coating
Point Source Wood Product FIP VOC Limits
217.2
0.0
5,429
0
Coating
Point Sources
RE Improvements
19,187.0
0.0
38,373,910
0
Recreational vehicles
CARB standards
379.1
0.0
200,932
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,190.7
0.0
381,602
0
SOCMI fugitives
RACT
12.7
0.0
1,729
0
Web Offset Lithography
New CTG (carbon adsorber)
249.0
0.0
-31,123
0
Wood furniture surface coating
Reformulation
466.6
0.0
175,013
0
Wood product surface coating
Reformulation
42.0
0.0
1,745
0
Total
35,135.2
10,152.9
40,944,754
2,917,357
Open Burning
Episodic Ban
560.1
106.4
0
0
Point Source Irvd. Surface Coating Add-on Control Levels
177.8
0.0
3,270,692
0
Point Source Metal Surface FIP VOC Limits
129.6
0.0
0
0
Coating
Point Sources
RE Improvements
2,381.3
0.0
4,762,520
0
Metal product surface coating
VOC content limits & improved
481.8
0.0
11,958
0
Wood product surface coating
Reformulation
5.6
0.0
141
0
Wood furniture surface coating
Reformulation
403 0
0.0
151,099
0
Paper surface coating
Add-on control levels
3.3
0.0
220,089
0
Miscellaneous surface coating
Add-on control levels
195.0
0.0
3,156,486
0
Automobile refinishing
FIP Rule (VOC Content & TE)
434.2
0.0
6,533,259
0
Miscellaneous surface coating
MACT level of control
148.9
0.0
372,146
0
Aerosols
SCAQMD Standards
Reformulati
296.8
0.0
1,854,330
0
marine surface coating
Add-on control levels
134.5
0.0
1,946,944
0
Service stations • stage l-truck un
Vapor balance & P-V valves
356.5
0.0
8,909
0
Pesticide Application
Reformulation - FIP rule
2.8
0.0
26,709
0
Recreational vehicles
CARB standards
789.7
0.0
418,473
0
Motor Vehicles
California Reform
590.1
1,002.0
737,000
15,574,5
I96
Motor Vehicles
California LEV
2,302.1
3,756.5
2,980,279
2,980,279
Total
9,393.1
4,864.9
26,451,034
18,555,275
Aerosols
CARB Tier 2 Standards - Reform
190.8
0.0
476,892
0
Aerosols
SCAQMD Standards
Reformulati
190.7
0.0
1,907,568
0
Automobile refinishing
CARB BARCT limits
123.8
0.0
455,517
0
Automobile refinishing
FIP Rule (VOC Content & TE)
472.8
0.0
8,521,420
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
0
Metal product surface coating
VOC content limits & improved
228.4
0.0
5,663
0
Miscellaneous surface coating
Add-on control levels
116.6
0.0
1,886,434
0
Portland, OR
Providence, Rl
Sacramento, CA
B-58
-------
Table B-7 (continued)
Reductions
Costs
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Miscellaneous surface coating
MACT level of control
91.7
0.0
229,219
0
Nonroad gasoline
Reformulated gasoline
101.3
0.0
506,500
0
Open Burning
Episodic Ban
429.8
81.3
0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
0
Pesticide Application
Reformulation - FIP rule
113.8
0.0
1,058,898
0
Point Source Ind. Surface Coating Add-on Control Levels
361.7
0.0
6,655,556
0
Point Source Metal Surface FIP VOC Limits
313.9
0.0
0
0
Coating
Point Sources
RE Improvements
40.5
0.0
81,030
0
Recreational vehicles
CARB standards
97.3
0.0
51,601
0
Service stations - stage l-truck un
Vapor balance & P-V valves
646.7
0.0
16,167
0
Wood furniture surface coating
Reformulation
240.2
0.0
90,098
0
Wood product surface coating
Reformulation
16.0
0.0
399
0
Total
3,783.3
81.3
22,209,888
0
Aerosols
CARB Tier 2 Standards - Reform
0.0
0.0
0
0
Aerosols
SCAQMD Standards
Reformulati
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
256.4
0
6,961,478
Industrial Boiler - PC
SCR
0.0
44.3
0
948,195
Industrial Boiler - Stoker
SCR
0.0
108.2
0
1,127,084
Industrial Boiler - Residual Oil
SCR
0.0
141.9
0
976,271
Industrial Boiler - Natural Gas
SCR
0.0
159.9
0
1,342,660
IC Engines - Natural Gas
NSCR
0.0
58.5
0
179,810
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
106.6
0
511,328
Gas Turbines - Oil
SCR ~ WATER INJECTION
0.0
146.7
0
731,902
Residential NG Consumption
LNB Space heaters
0.0
531.5
0
653,642
Open Burning
Episodic Ban
2,129.9
404.0
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
33.8
0
275,292
Commercial Marine Vessels
Emission Fees
0.0
252.3
0
2,523,158
Motor Vehicles
California Reform
398.0
672.7
467,000
10,679,254
Motor Vehicles
California LEV
1,714.3
2,857.2
2,038,322
2,038,322
Motor Vehicles
Reform Diesel
0.0
134.5
0
1,911,328
Total
4,242.2
5,908.5
2,505,322
30,859,724
Aerosols
CARB Tier 2 Standards - Reform
42.6
0.0
106,380
0
Automobile refinishing
CARB BARCT limits
11.2
0.0
41,327
0
Automobile refinishing
FIP Rule (VOC Content & TE)
42.9
0.0
773,106
0
Metal product surface coating
VOC content limits & improved
49.9
0.0
1,238
0
Miscellaneous surface coating
Add-on control levels
22.0
0.0
333,737
0
San Diego, CA
Springfield, MA
Visalia, CA
B-59
-------
Table B-7 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Miscellaneous surface coating
MACT level of control
19.7
0.0
49,270
0
Nonroad gasoline
Reformulated gasoline
23.1
0.0
115,500
0
Open Burning
Episodic Ban
93.7
17.7
0
0
Paper surface coating
Add-on control levels
1.1
0.0
76,493
0
Pesticide Application
Reformulation - FIP rule
250.4
0.0
2,329,073
0
Recreational vehicles
CARB standards
22.4
0.0
11,867
0
Service stations - stage l-truck un
Vapor balance & P-V valves
110.8
0.0
2,770
0
Wood furniture surface coating
Reformulation
8.2
0.0
3,088
0
Wood product surface coating
Reformulation
2.7
0.0
67
0
Total
700.7
17.7
3,843,916
0
Utility Boiler - PC/Wall
SCR
0.0
28,076.6
0
86,025,342
Utility Boiler - PC/Tangential
SCR
0.0
25,456.0
0
101,567,747
Utility Boiler - Oil-Gas/Wall
SCR
0.0
5,738.6
0
52,216,489
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
3,364.4
0
41,194,478
Utility Boiler - Cyclone
SCR
0.0
2,833.2
0
33,909,713
Industrial Boiler - PC
SCR
0.0
3,950.8
0
31,280,313
Industrial Boiler - Stoker
SCR
0.0
111.5
0
1,161,708
Industrial Boiler - Residual Oil
SCR
0.0
713.4
0
4,674,888
Industrial Boiler - Distillate Oil
SCR
0.0
107.4
0
1,126,417
Industrial Boiler - Natural Gas
SCR
0.0
936.8
0
7,865,392
IC Engines - Oil
SCR
0.0
362.2
0
1,968,033
Gas Turbines-Oil
SCR + WATER INJECTION
0.0
48.8
0
2,592,825
Process Heaters - Natural Gas
LNB + SCR
0.0
6.3
0
183,156
Area Source Industrial Coal Comb
RACT to small sources
0.0
29.7
0
118,154
Area Source Industrial Oil Comb
RACT to small sources
0.0
13.1
0
20,421
Area Source Industrial NG Comb
RACT to small sources
0.0
45.6
0
65,735
Residential NG Consumption
LNB Space heaters
0.0
2,607.8
0
3,207,326
Open Burning
Episodic Ban
911.4
173.4
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
486.9
0
3,972,107
Commercial Marine Vessels
Emission Fees
0.0
536.0
0
5,358,057
Industrial Boiler - Other
SCR
0.0
15.8
0
169,106
Glass Manufacturing - Container
Oxy-Firing
0.0
59.9
0
396,919
Cement Manufacturing - Dry
SCR
0.0
2,187.8
0
11.048,592
Cement Manufacturing - Wet
SCR
0.0
808.4
0
3,405,438
Iron & Steel Mills - Reheating
LNB + FGR
0.0
444.8
0
233,562
Iron & Steel Mills - Annealing
LNB + SCR
0.0
70.3
0
360,338
Municipal Waste Combustors
SNCR
0.0
140.2
0
467,984
Point Source Ind. Surface Coating
Add-on Control Levels
353.0
0.0
6,494,372
0
Point Source Metal Surface
FIP VOC Limits
824.2
0.0
0
0
Coating
Point Source Wood Product
FIP VOC Limits
7.3
0.0
183
0
Coating
Point Sources
RE Improvements
5,634.0
0.0
11,268,280
0
Bulk Terminals
RACT
833.1
0.0
1,388,281
0
Metal product surface coating
VOC content limits & improved
645.8
0.0
28,410
0
Wood product surface coating
Reformulation
26.9
0.0
810
0
Wood furniture surface coating
Reformulation
1,229.7
0.0
469,264
0
Adhesives - industrial
RACT
176.5
0.0
441,529
0
Paper surface coating
Add-on control levels
83.3
0.0
3,404,679
0
Miscellaneous surface coating
Add-on control levels
455.2
0.0
8,406,296
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,273.6
0.0
34,205,397
0
Miscellaneous surface coating
MACT level of control
129.3
0.0
323,092
0
Aerosols
SCAQMD Standards
Reformulati
1,895.6
0.0
11,844,990
0
Washington, DC
B-60
-------
Table B-7 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Aircraft surface coating
Add-on control levels
21.9
0.0
787,137
0
marine surface coating
Add-on control levels
105.4
0.0
1,522,900
0
Cutback Asphalt
Switch to emulsified asphalts
234.1
0.0
0
0
Synthetic fiber manufacture
RACT (adsorber)
1,408.2
0.0
1,991,973
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
3,690.7
0.0
604,238
0
Web Offset Lithography
New CTG (carbon adsorber)
38.2
0.0
-4,787
0
Pesticide Application
Reformulation - FIP rule
233.8
0.0
2,173,301
0
Recreational vehicles
CARB standards
838.9
0.0
444,536
0
Motor Vehicles
Federal Reform
2,980.7
580.8
12,457,815
0
Motor Vehicles
Enhanced l/M
2,309.2
2,294.4
881,214
1,762,429
Motor Vehicles
California LEV
15,654.8
28,610.7
22,493,022
22,493,022
Motor Vehicles
Reform Diesel
0.0
1,483.5
0
21,669,143
Total
42,994.8 112,295.1 121,626,932
440,514,833
B-61
-------
Table B-8. Alternative 8H1AX-80: Marginal Emission Reductions and Costs
by Nonattainment Area and Control Measure Under the LCS
Reductions
(tons per year)
Costs
Nonattainment
Area
I
Source Category
Control Measure
VOC
NOx
VOC
NOx
Open Burning
Episodic Ban
522.3
99.0
0
0
Point Source Metal Surface Coating FIP VOC Limits
66.4
0.0
0
0
Point Sources
RE Improvements
40.5
0.0
81,030
0
Metal product surface coating
VOC content limits & improved
125.3
0.0
3,132
0
Wood product surface coating
Reformulation
2.0
0.0
49
0
Wood furniture surface coating
Reformulation
98.0
0.0
100,469
0
Paper surface coating
Add-on control levels
3.3
0.0
222,718
0
Miscellaneous surface coating
Add-on control levels
63.5
0.0
3,580,162
0
Automobile refinishing
FIP Rule (VOC Content & TE)
220.0
0.0
3,310,551
0
Aerosols
SCAQMD Standards -
165.8
0.0
1,036,530
0
Reformulati
marine surface coating
Add-on control levels
2.0
0.0
28,661
0
Service stations - stage l-truck un
Vapor balance & P-V valves
202.2
0.0
5,056
0
Pesticide Application
Reformulation - FIP rule
28.5
0.0
265,497
0
Recreational vehicles
CARB standards
70.5
0.0
37,302
0
Motor Vehicles
California Reform
304.6
566.5
230,000
8,428,826
Motor Vehicles
Enhanced l/M
340.0
237.2
94,640
189,279
Motor Vehicles
California LEV
1,158.1
2,060.6
1,603,354
1,603,354
Total
3,413.0
2,963.3
10,599,15
o
10,221,459
Industrial Boiler - Stoker
SNCR
0.0
3.7
0
7,766
Industrial Boiler - Residual Oil
SCR
0.0
8.7
0
22,258
Industrial Boiler - Distillate Oil
LNB
0.0
2.7
0
3,765
Industrial Boiler - Natural Gas
SCR
0.0
205.6
0
730,049
Area Source Industrial NG Comb
RACT to small sources
0.0
13.4
0
22,673
Open Burning
Episodic Ban
148.2
28.1
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
15.0
0
122,028
Motor Vehicles
California Reform
1,163.9
424.9
3,244,410
3,045,364
Motor Vehicles
Enhanced l/M
1,037.8
888.7
356,005
712,011
Motor Vehicles
California LEV
389.6
757.6
576,178
576,178
Motor Vehicles
Reform Diesel
0.0
49.6
0
756,347
Total
2,739.5
2,398.0
4,176,593
5,998,439
Utility Boiler - PCAA/all
SCR
0.0
26,524.7
0
88,115,238
Utility Boiler - PC/Tangential
SCR
0.0
48,973.9
0
169,190,588
Utility Boiler - Oil-Gas/Wall
SCR
0.0
1,311.5
0
9,837,161
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
5.2
0
2,423,615
Industrial Boiler - PC
SCR
0.0
1,594.6
0
15,090,051
Industrial Boiler - Stoker
SCR
0.0
41.5
0
186,329
Industrial Boiler - Residual Oil
SCR
0.0
781.1
0
2,315,996
Industrial Boiler - Distillate Oil
SCR
0.0
23.0
0
130,734
Industrial Boiler - Natural Gas
SCR
0.0
1,057.8
0
4,070,197
IC Engines - Natural Gas
NSCR
0.0
189.8
0
140,995
Area Source Industrial NG Comb
RACT to small sources
0.0
82.2
0
140,967
Open Burning
Episodic Ban
2,803.3
531.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
351.8
0
2,869,290
Glass Manufacturing - Container
Oxy-Firing
0.0
720.8
0
4,774,851
Cement Manufacturing - Dry
SCR
0.0
451.5
0
2,279,852
Motor Vehicles
California Reform
14,818.9
9,276.1
86,558,42
5
81,497,785
Motor Vehicles
Enhanced l/M
4,661.3
4,386.8
1,703,128
3,406,256
Motor Vehicles
California LEV
10,972.5
19,802.5
15,536,78
15,536,781
Allentown, PA
Athens, GA
Atlanta, GA
B-62
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOX
Motor Vehicles
Reform Diesel
0.0
1,065.8
0
15,564,564
Total
33,256.0117,172.1
103,798,3417,571,250
id
Utility Boiler - PC/Tangential
SCR
0.0
2,269.6
0
12,239,652
Industrial Boiler - PC
SCR
0.0
5,957.0
0
46,310,139
Industrial Boiler - Stoker
SCR
0.0
851.4
0
3,819,644
Industrial Boiler - Residual Oil
SCR
0.0
929.5
0
2,713,729
Industrial Boiler - Distillate Oil
SCR
0.0
75.1
0
350,197
Industrial Boiler - Natural Gas
SCR
0.0
1,622.2
0
5,775,774
Nitric Acid Manufacturing Plant
NSCR
0.0
1,132.3
0
797,910
Area Source Industrial Coal Comb
RACT to small sources
0.0
15.7
0
62,428
Area Source Industrial Oil Comb
RACT to small sources
0.0
3.8
0
8,147
Area Source Industrial NG Comb
RACT to small sources
0.0
77.0
0
130,543
Open Burning
Episodic Ban
738.5
140.1
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
52.2
0
425,056
Motor Vehicles
California Reform
4,227.9
1,369.9
10,744,73
o
10,078,541
Motor Vehicles
Enhanced l/M
3,669.3
2,903.1
1,181,263
2,362,526
Motor Vehicles
California LEV
1,359.9
2,478.2
1,911,700
1,911,700
Motor Vehicles
Reform Diesel
0.0
162.7
0
2,290,691
Total
9,995.6
20,039.8
13,837,69
3
89,276,677
Open Burning
Episodic Ban
375.7
71.1
0
0
Bulk Terminals
RACT
485.2
0.0
808,657
0
Metal product surface coating
VOC content limits & improved
107.3
0.0
2,674
0
Wood product surface coating
Reformulation
2.5
0.0
63
0
Wood furniture surface coating
Reformulation
161.2
0.0
60,460
0
Adhesives - industrial
RACT
518.3
0.0
1,295,885
0
Miscellaneous surface coating
MACT level of control
234.3
0.0
585,769
0
Aerosols
CARB Tier 2 Standards -
125.5
0.0
313,854
0
Reform
Cutback Asphalt
Switch to emulsified asphalts
792.2
0.0
0
0
SOCMI fugitives
RACT
12.8
0.0
1,739
0
Pharmaceutical manufacture
RACT
106.2
0.0
35,568
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
87.4
0.0
34,636
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
1,594.6
0.0
1,194,723
0
Web Offset Lithography
New CTG (carton adsorber)
161.9
0.0
-20,255
0
Recreational vehicles
CARB standards
168.0
0.0
89,049
0
Motor Vehicles
Enhanced l/M
6,268.9
4,560.1
1,872,174
3,744,347
Total
11,202.0
4,631.2
6,274,996
3,744,347
Aerosols
CARB Tier 2 Standards -
0.0
0.0
0
0
Reform
Aerosols
SCAQMD Standards -
0.0
0.0
0
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Augusta, GA
Austin, TX
Bakersfield, CA
B-63
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonatta inment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.7
0.0
16
0
Total
0.7
0.0
16
0
Utility Boiler - Oil-Gas/Wall
SCR
0.0
50.1
0
5,697,710
Industrial Boiler - Residual Oil
SCR
0.0
1,040.4
0
7,152,915
Area Source Industrial Oil Comb
RACT to small sources
0.0
6.2
0
12,504
Area Source Industrial NG Comb
RACT to small sources
0.0
3.1
0
4,509
Residential NG Consumption
LNB Space heaters
0.0
10.7
0
17,152
Open Burning
Episodic Ban
686.3
130.1
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
4.2
0
33,156
Commercial Marine Vessels
Emission Fees
0.0
8.5
0
85,048
Motor Vehicles
California Reform
983.4
775.4
3,212,613
8,241,243
Motor Vehicles
Enhanced l/M
1,671.7
1,380.8
550,911
1,101,822
Motor Vehicles
California LEV
963.4
2,042.8
1,549,621
1,549,621
Motor Vehicles
Reform Diesel
0.0
159.3
0
2,436,714
Total
4,304.8
5,611.6
5,313,145
26,332,394
Utility Boiler - Oil-Gas/Wall
SCR
0.0
5,418.1
0
21,157,763
Residential NG Consumption
LNB Space heaters
0.0
43.7
0
70,375
Open Burning
Episodic Ban
28.8
5.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
19.4
0
158,751
Motor Vehicles
California Reform
112.7
187.6
192,000
2,696,295
Motor Vehicles
California LEV
354.2
750.6
508,058
508,058
Motor Vehicles
Reform Diesel
0.0
49.6
0
754,159
Total
495.7
6,474.5
700,058
25,345,401
Open Burning
Episodic Ban
14.5
2.7
0
.0
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.7
0.0
42
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Adhesives - industrial
RACT
3.0
0.0
7,459
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content &TE)
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
2.1
0.0
5,299
0
Aerosols
SCAQMD Standards -
Reformulati
6.7
0.0
41,850
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Cutback Asphalt
Switch to emulsified asphalts
17.2
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
5.6
0.0
139
0
Pesticide Application
Reformulation - FIP rule
2.9
0.0
26,951
0
Recreational vehicles
CARB standards
10.2
0.0
5,399
0
Motor Vehicles
Federal Reform
161.9
31.9
475,253
0
Motor Vehicles
Enhanced l/M
134.6
138.1
51,188
102,377
Motor Vehicles
California LEV
49.6
113.3
82,863
82,863
Total
409.0
286.0
696,443
185,240
Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Metal Surface Coating FIP VOC Limits
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.8
0.0
27
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Bangor, ME
Barnstable, MA
Baton Rouge, LA
Beaumont, TX
B-64
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area Source Category
Control Measure
voc
NOx
voc
NOx
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Total
0.8
0.0
27
0
Birmingham, AL Utility Boiler - PC/Wall
SCR
0.0
29,995.2
01
14,055,991
Utility Boiler - PC/Tangential
SCR
0.0
7,589.1
0
25,043,588
Industrial Boiler - PC
SCR
0.0
4.8
0
121,708
Industrial Boiler - Natural Gas
SCR
0.0
28.0
0
223,625
Area Source Industrial Coal Comb
RACT to small sources
0.0
36.2
0
145,287
Area Source Industrial Oil Comb
RACT to small sources
0.0
7.0
0
15,288
Area Source Industrial NG Comb
RACT to small sources
0.0
393.2
0
662,240
Open Burning
Episodic Ban
1,025.0
194.7
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
87.8
0
716,135
Cement Manufacturing - Dry
SCR
0.0
1,777.4
0
8,544,422
Cement Manufacturing - Wet
SCR
0.0
558.7
0
2,240,339
Motor Vehicles
California Reform
6,580.6
2,308.5
19,203,30
18,051,111
Boston, MA
Charlotte, NC
Motor Vehicles
Enhanced l/M
7,143.8
5,024.0
2,125,452
4,250,905
Motor Vehicles
California LEV
2,454.5
4,354.9
3,439,368
3,439,368
Motor Vehicles
Reform Diesel
0.0
237.2
0
3,465,787
Total
17,203.9
52,596.7 24,768,12
1
180,975,793
Utility Boiler -PC/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Wall
SCR
0.0
0.0
0
0
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
0.0
0
0
Utility Boiler - Cyclone
SCR
0.0
0.0
0
0
Industrial Boiler - Stoker
SCR
0.0
0.0
0
0
Industrial Boiler - Residual Oil
SCR
0.0
0.0
0
0
Industrial Boiler - Distillate Oil
SCR
0.0
0.0
0
0
Industrial Boiler • Natural Gas
SCR
0.0
0.0
0
0
IC Engines - Natural Gas
NSCR
0.0
0.0
0
0
IC Engines - Oil
SCR
0.0
0.0
0
0
Gas Turbines - Oil
SCR ~ WATER INJECTION
0.0
0.0
0
0
Area Source Industrial Coal Comb
RACT to small sources
0.0
1.2
0
4,177
Area Source Industrial Oil Comb
RACT to small sources
0.0
0.0
0
0
Area Source Industrial NG Comb
RACT to small sources
0.0
0.0
0
0
Residential NG Consumption
LNB Space heaters
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
0.0
0
0
Commercial Marine Vessels
Emission Fees
0.0
0.0
0
0
Industrial Boiler - Other
SCR
0.0
0.0
0
0
Industrial Cogeneration - Nat. Gas
SCR
0.0
0.0
0
0
Glass Manufacturing - Container
Oxy-Firing
0.0
0.0
0
0
Municipal Waste Combustors
SNCR
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Motor Vehicles
Reform Diesel
0.0
0.0
0
0
Total
0.0
1.2
0
4,177
Utility Boiler - PCM/all
SCR
0.0
17,770.5
0
55,135,167
Utility Boiler - PC/Tangential
SCR
0.0
8,775.0
0
54,917,608
Utility Boiler - Oil-Gas/Wall
SCR
0.0
1,063.8
0
6,836,668
Industrial Boiler - PC
SCR
0.0
4,375.4
0
34,162,612
Industrial Boiler - Stoker
SCR
0.0
21.5
0
223,817
Industrial Boiler - Residual Oil
SCR
0.0
391.3
0
1,842,444
B-65
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Industrial Boiler - Distillate Oil
SCR
0.0
0.2
0
2,849
Industrial Boiler - Natural Gas
SCR
0.0
95.3
0
368,848
Area Source Industrial Coal Comb
RACT to small sources
0.0
150.6
0
600,700
Area Source Industrial Oil Comb
RACT to small sources
0.0
12.8
0
28,822
Area Source industrial NG Comb
RACT to small sources
0.0
179.7
0
301,317
Open Burning
Episodic Ban
1,284.1
243.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
129.0
0
1,053,617
Motor Vehicles
California Reform
8,366.8
3,083.8
25,352,91
g
23,743,252
Motor Vehicles
Enhanced l/M
8,040.1
6,549.9
1,492,409
2,984,818
Motor Vehicles
California LEV
3,254.9
5,749.9
4,510,636
4,510,636
Motor Vehicles
Reform Diesel
0.0
347.0
0
5,111,750
Total
20,945.9
48,939.2
31,355,96 191,824,925
Chattanooga, TN Industrial Boiler - PC
SCR
0.0
802.4
0
6,328,215
Industrial Boiler - Stoker
SCR
0.0
621.2
0
2,842,055
Industrial Boiler - Residual Oil
SCR
0.0
200.1
0
586,747
Industrial Boiler - Distillate Oil
SCR
0.0
22.0
0
106,982
Industrial Boiler - Natural Gas
SCR
0.0
613.2
0
2,187,373
Area Source Industrial Coal Comb
RACT to small sources
0.0
18.2
0
71,177
Area Source Industrial NG Comb
RACT to small sources
0.0
41.8
0
71,643
Open Burning
Episodic Ban
1,011.9
191.9
0
0
Nonroad Diesels
CARB Stds for> 175 HP
0.0
66.0
0
540,036
Commercial Marine Vessels
Emission Fees
0.0
40.0
0
399,126
Cement Manufacturing - Wet
SCR
0.0
265.6
0
1,070,720
Motor Vehicles
California Reform
5,665.0
1,901.1
14,780,48
Q
13,876,967
Motor Vehicles
Enhanced l/M
4,898.2
4,022.1
1,624,627
3,249,253
Motor Vehicles
California LEV
1,834.7
3,434.3
2,629,275
2,629,275
Motor Vehicles
Reform Diesel
0.0
216.1
0
3,278,489
Total
13,409.8
12,456.0
19,034,38
37,238,058
Chicago, IL Open Burning Episodic Ban
Point Source Ind. Surface Coating Add-on Control Levels
Point Source Metal Surface Coating FIP VOC Limits
2,815.3
3,534.3
534.1
0.0
9
0
65,031,02
8
0
0
Point Source Wood Product
Coating
Point Sources
Bulk Terminals
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Adhesives - industrial
Paper surface coating
Miscellaneous surface coating
Automobile refinishing
Miscellaneous surface coating
Aerosols
Aircraft surface coating
FIP VOC Limits
RE Improvements
RACT
VOC content limits & improved
Reformulation
Reformulation
RACT
Add-on control levels
Add-on control levels
FIP Rule (VOC Content & TE)
MACT level of control
SCAQMD Standards -
Reformulati
Add-on control levels
7,008.5
0.0
0
0
78.8
0.0
1,971
0
9,297.3
0.0
18,594,56
0
0
156.2
0.0
260,239
0
3,668.8
0.0
128,230
0
26.6
0.0
682
0
1,275.3
0.0
1,590,807
0
331.6
0.0
828,791
0
40.3
0.0
3,027,556
0
1,570.4
0.0
39,738,70
4
0
3,285.2
0.0
49,424,51
0
0
1,317.1
0.0
3,292,516
0
2,458.6
0.0
15,363,21
0
0
8.5
0.0
288,264
0
B-66
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Cincinnati, OH
Columbia, SC
marine surface coating
Add-on control levels
99.5
0.0
1,440,735
Cutback Asphalt
Switch to emulsified asphalts
305.7
0.0
0
Pharmaceutical manufacture
RACT
3.7
0.0
1,245
Service stations - stage l-truck un
Vapor balance & P-V valves
3,489.1
0.0
345,038
Web Offset Lithography
New CTG (carbon adsorber)
36.2
0.0
-4,532
Pesticide Application
Reformulation - FIP rule
479.6
0.0
4,459,519
Recreational vehicles
CARB standards
1,404.9
0.0
744,518
Motor Vehicles
California Reform
6,002.9
7,555.5
66,425,54
Motor Vehicles
Motor Vehicles
Enhanced l/M
California LEV
Total
1,994.0
17,287.5
1,579.0
27,888.6
67,975.9 37,557.2
1
630,296
22,137,96
6
293,751,3
93
0
0
0
0
0
0
0
57,839,073
1,260,592
22,137,966
81,237,630
Open Burning
Episodic Ban
2,188.4
415.9
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
155.1
0.0
2,854,300
0
Point Source Metal Surface Coating FIP VOC Limits
455.9
0.0
0
0
Point Sources
RE Improvements
10,748.2
0.0
21,496,31
o
0
Bulk Terminals
RACT
250.8
0.0
417,687
0
Metal product surface coating
VOC content limits & improved
258.8
0.0
7,644
0
Wood product surface coating
Reformulation
9.7
0.0
269
0
Wood furniture surface coating
Reformulation
1,122.3
0.0
471,160
0
Adhesives - industrial
RACT
224.4
0.0
561,093
0
Paper surface coating
Add-on control levels
45.4
0.0
3,068,288
0
Miscellaneous surface coating
Add-on control levels
426.6
0.0
15,274,06
0
Automobile refinishing
Miscellaneous surface coating
Aerosols
Aircraft surface coating
marine surface coating
SOCMI batch reactor processes
Cutback Asphalt
SOCMI fugitives
Service stations • stage I-truck un
Web Offset Lithography
Pesticide Application
Recreational vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
FIP Rule (VOC Content & TE)
MACT level of control
SCAQMD Standards
Refomiulati
Add-on control levels
Add-on control levels
New CTG
Switch to emulsified asphalts
RACT
Vapor balance & P-V valves
New CTG (carbon adsorber)
Reformulation • FIP rule
CARB standards
California Reform
Enhanced l/M
California LEV
Total
508.5
43.8
594.4
0.0
0.0
0.0
7
7,653,386
109,533
3,715,980
51.8
0.0
1,873,198
0
9.9
0.0
143,004
0
107.4
0.0
435,460
0
233.3
0.0
0
0
61.0
0.0
8,304
0
1,000.2
0.0
213,149
0
32.9
0.0
-4,104
0
192.6
0.0
1,788,800
0
225.3
0.0
119,227
0
10,738.9
4,223.6
31,682,91
o
34,582,839
12,538.1
9,488.4
1,129,634
2,259,268
4,561.9
8,465.0
6,583,926
6,583,926
46,785.6
22,592.9
99,603,22
43,426,033
Utility Boiler - PC/Wan
SCR
0.0
Utility Boiler - PC/Tangential
SCR
0.0
Utility Boiler - Oil-Gas/Wall
SCR
0.0
Industrial Boiler - PC
SCR
0.0
Industrial Boiler - Stoker
SCR
0.0
Industrial Boiler - Residual Oil
SCR
0.0
Industrial Boiler - Natural Gas
SCR
0.0
Area Source Industrial Coal Comb
RACT to small sources
0.0
12,643.7
2,548.8
366.3
2,458.5
31.0
42.6
42.3
24.1
43,437,417
11,393,538
3,487,790
19,157,697
140,584
123,972
151,099
95,923
B-67
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Area Source Industrial Oil Comb
RACT to small sources
0.0
5.0
0
10,713
Area Source Industrial NG Comb
RACT to small sources
0.0
55.8
0
93,301
Open Burning
Episodic Ban
1,200.2
228.1
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
51.0
0
416,509
Motor Vehicles
California Reform
4,004.7
1,285.1
10,104,17
4
9,465,335
Motor Vehicles
Enhanced l/M
3,325.8
2,715.6
1,110,577
2,221,153
Motor Vehicles
California LEV
1,200.7
2,343.7
1,797,255
1,797,255
Total
9,731.4
24,841.6
13,012,00
g
91,992,286
Columbus, OH
Open Burning
Episodic Ban
1,441.5
274.0
0
0
Point Source Wood Product
FIP VOC Limits
201.1
0.0
5,028
0
Coating
Point Sources
RE Improvements
2,207.8
0.0
4,415,770
0
Bulk Terminals
RACT
124.2
0.0
206,804
0
Metal product surface coating
VOC content limits & improved
240.7
0.0
6,010
0
Wood product surface coating
Reformulation
14.0
0.0
343
0
Wood furniture surface coating
Reformulation
385.4
0.0
144,484
0
Adhesives - industrial
RACT
445.2
0.0
1,113,110
0
Automobile refinishing
CARB BARCT limits
90.5
0.0
332,819
0
Aerosols
CARB Tier 2 Standards
238.9
0.0
596,988
0
Reform
Cutback Asphalt
Switch to emulsified asphalts
400.5
0.0
0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
44.0
0.0
17,410
0
Service stations • stage I-truck un
Vapor balance & P-V valves
1,365.0
0.0
686,069
0
Web Offset Lithography
New CTG (carbon adsorber)
235.1
0.0
-29,364
0
Recreational vehicles
CARB standards
175.4
0.0
92,831
0
Nonroad gasoline
Reformulated gasoline
122.8
0.0
614,000
0
Motor Vehicles
Enhanced l/M
11,493.3
7,983.8
3,297,083
6,594,167
Total
19,245.4
8,257.8
11,499,38
5
6,594,167
Dallas, TX
Open Burning
Episodic Ban
2,370.9
449.5
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
4,042.7
0.0
74,386,41
0
Point Source Open Burning
Episodic Ban
0.0
0.0
V
0
0
Point Source Metal Surface Coating
FIP VOC Limits
204.0
0.0
0
0
Point Source Wood Product
FIP VOC Umits
208.0
0.0
5,202
0
Coating
Point Sources
RE Improvements
14,125.2
0.0
28,250,27
o
0
Bulk Terminals
RACT
1,175.5
0.0
1,958,930
0
Metal product surface coating
VOC content limits & improved
1,515.7
0.0
50,164
0
Wood product surface coating
Reformulation
25.4
0.0
1,114
0
Wood furniture surface coating
Reformulation
760.9
0.0
611,283
0
Adhesives - industrial
RACT
489.9
0.0
1,224,984
0
Paper surface coating
Add-on control levels
108.3
0.0
6,534,254
0
Miscellaneous surface coating
Add-on control levels
768.4
0.0
17,912,05
3
0
Automobile refinishing
Miscellaneous surface coating
Aerosols
Aircraft surface coating
marine surface coating
FIP Rule (VOC Content & TE) 1,417.8
MACT level of control
SCAQMD Standards
Reformulati
Add-on control levels
Add-on control levels
879.8
1,240.0
43.8
74.8
0.0 21,327,26
0
0.0 2,198,958
0.0 7,750,320
0.0 1,379,067
0.0 1,082,729
B-68
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
SOCMI batch reactor processes
New CTG
1.7
0.0
7,007
0
Cutback Asphalt
Switch to emulsified asphalts
667.1
0.0
0
0
Petroleum refinery fugitives
RACT
167.1
0.0
-75,186
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
118.2
0.0
46,827
0
Service stations - stage l-truck un
Vapor balance & P-V valves
3,128.7
0.0
1,060,077
0
Web Offset Lithography
New CTG (carbon adsorber)
70.0
0.0
-8,747
0
Pesticide Application
Reformulation - FIP rule
263.9
0.0
2,454,867
0
Recreational vehicles
CARB standards
824.0
0.0
436,662
0
Motor Vehicles
Federal Reform
6,747.7
1,030.4
18,082,81
1
0
Motor Vehicles
Enhanced l/M
28,497.3
21,982.9
2,889,377
5,778,753
Motor Vehicles
California LEV
10,664.3
19,720.7
15,451,18
3
15,451,183
Total
80,601.1
43,183.5
205,017,8
82
21,229,936
Open Burning
Episodic Ban
1,106.0
210.0
0
0
Point Source Metal Surface Coating FIP VOC Limits
321.6
0.0
0
0
Point Sources
RE Improvements
1,072.8
0.0
2,145,470
0
Bulk Terminals
RACT
109.1
0.0
181,719
0
Metal product surface coating
VOC content limits & improved
135.6
0.0
3,387
0
Wood product surface coating
Reformulation
3.2
0.0
81
0
Wood furniture surface coating
Reformulation
230.9
0.0
86,569
0
Adhesives - industrial
RACT
74.8
0.0
186,934
0
Automobile refinishing
CARB BARCT limits
60.4
0.0
222,514
0
Aerosols
CARB Tier 2 Standards
156.5
0.0
391,302
0
Reform
Cutback Asphalt
Switch to emulsified asphalts
65.7
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
532.7
0.0
110,998
0
Web Offset Lithography
New CTG (carbon adsorber)
4.2
0.0
-522
0
Recreational vehicles
CARB standards
111.4
0.0
59,062
0
Motor Vehicles
Federal Reform
5,472.4
1,065.6
17,400,89
2
0
Motor Vehicles
Enhanced l/M
6,017.5
4,436.3
432,305
864,610
Total
15,474.8
5,711.9
21,220,71
1
864,610
Open Burning
Episodic Ban
6,329.5
1,201.0
0
0
Point Sources
RE Improvements
6,128.4
0.0
12,256,70
0
0
Metal product surface coating
VOC content limits & improved
976.2
0.0
24,402
0
Wood product surface coating
Reformulation
13.9
0.0
640
0
Wood furniture surface coating
Reformulation
894.2
0.0
335,354
0
Adhesives - industrial
RACT
679.9
0.0
1,699,437
0
Paper surface coating
Add-on control levels
27.8
0.0
1,796,907
0
Miscellaneous surface coating
Add-on control levels
335.9
0.0
16,961,55
9
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,129.4
0.0
32,037,10
6
0
Aerosols
SCAQMD Standards
1,427.2
0.0
8,920,140
0
Reformulati
Aircraft surface coating
Add-on control levels
5.2
0.0
183,826
0
marine surface coating
Add-on control levels
63.9
0.0
924,593
0
SOCMI batch reactor processes
New CTG
45.3
0.0
183,544
0
Cutback Asphalt
Switch to emulsified asphalts
585.6
0.0
0
0
SOCMI fugitives
RACT
27.1
0.0
3,686
0
Dayton, OH
Detroit, Ml
B-69
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Oil and natural gas production fiel
RACT (equipment/maintenance)
3.7
0.0
1,479
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,287.6
0.0
57,195
0
Web Offset Lithography
New CTG (carbon adsorber)
57.5
0.0
-7,198
0
Pesticide Application
Reformulation - FIP rule
174.0
0.0
1,617,418
0
Recreational vehicles
CARB standards
927.1
0.0
491,288
0
Motor Vehicles
California Reform
32,663.3
11,304.7
93,144,59
g
87,262,066
Motor Vehicles
Enhanced l/M
32,251.6
23,427.6
2,745,095
5,490,191
Motor Vehicles
California LEV
12,421.1
21,058.8
16,672,04
3
16,672,043
Total
100,455.
4
56,992.1
190,049,8
12
109,424,300
Dover, DE
Open Burning
Episodic Ban
736.8
139.6
0
0
Point Sources
RE Improvements
474.5.
0.0
949,000
0
Metal product surface coating
VOC content limits & improved
197.7
0.0
4,898
0
Wood furniture surface coating
Reformulation
233.9
0.0
87,742
0
Paper surface coating
Add-on control levels
3.3
0.0
218,263
0
Miscellaneous surface coating
Add-on control levels
47.3
0.0
845,535
0
Automobile refinishing
FIP Rule (VOC Content & TE)
114.3
0.0
1,719,832
0
Miscellaneous surface coating
MACT level of control
29.5
0.0
73,707
0
Aerosols
SCAQMD Standards -
88.6
0.0
553,440
0
Reformulati
marine surface coating
Add-on control levels
14.0
0.0
202,774
0
Service stations - stage l-truck un
Vapor balance & P-V valves
130.3
0.0
3,272
0
Pesticide Application
Reformulation - FIP rule
102.4
0.0
952,097
0
Recreational vehicles
CARB standards
42.6
0.0
22,630
0
Motor Vehicles
California Reform
815.2
718.7
2,110,658
8,316,929
Motor Vehicles
Enhanced l/M
1,792.2
1,540.1
616,934
1,233,867
Motor Vehicles
California LEV
920.9
1,996.9
1,560,627
1,560,627
Total
5,743.5
4,395.3
9,921,409
11,111,423
Eugene, OR
Adhesives - industrial
RACT
398.9
0.0
997,164
0
Aerosols
CARB Tier 2 Standards -
67.3
0.0
168,276
0
Reform
Automobile refinishing
CARB BARCT limits
27.4
0.0
100,653
0
Bulk Terminals
RACT
173.6
0.0
289,200
0
Cutback Asphalt
Switch to emulsified asphalts
351.5
0.0
0
0
Metal product surface coating
VOC content limits & improved
92.8
0.0
2,314
0
Miscellaneous surface coating
MACT level of control
49.2
0.0
122,853
0
Motor Vehicles
Enhanced l/M
2,659.9
2,365.1
951,535
1,903,069
Nonroad gasoline
Reformulated gasoline
34.8
0.0
174,000
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
1.2
0.0
470
0
Open Burning
Episodic Ban
473.9
89.9
0
0
Recreational vehicles
CARB standards
75.8
0.0
40,095
0
Service stations - stage l-truck un
Vapor balance & P-V valves
358.9
0.0
186,182
0
Web Offset Lithography
New CTG (carbon adsorber)
67.6
0.0
-8,447
0
Wood furniture surface coating
Reformulation
114.8
0.0
43,029
0
Wood product surface coating
Reformulation
58.6
0.0
1,464
0
Total
5,006.2
2,455.0
3,068,788
1,903,069
Evansville, IN
Open Burning
Episodic Ban
498.6
94.5
0
0
Point Source Metal Surface Coating FIP VOC Limits
599.3
0.0
0
0
Point Source Wood Product
FIP VOC Limits
2,017.4
0.0
50,434
0
Coating
Point Sources
RE Improvements
2.6
0.0
5,110
0
Bulk Terminals
RACT
447.5
0.0 745,502
B-70
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Metal product surface coating
VOC content limits & improved
155.1
0.0
4,227
0
Wood product surface coating
Reformulation
1.7
0.0
42
0
Wood Furniture surface coating
Reformulation
129.4
0.0
69,798
0
Adhesives - industrial
RACT
247.0
0.0
617,312
0
Automobile refinishing
CARB BARCT limits
32.4
0.0
119,310
0
Miscellaneous surface coating
MACT level of control
56.4
0.0
140,911
0
Aerosols
CARB Tier 2 Standards -
53.4
0.0
133,488
0
Reform
Cutback Asphalt
Switch to emulsified asphalts
182.6
0.0
0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
27.0
0.0
10,690
0
Service stations - stage l-truck un
Vapor balance & P-V valves
306.4
0.0
155,344
0
Web Offset Lithography
New CTG (carbon adsorber)
80.3
0.0
-10,032
0
Recreational vehicles
CARB standards
48.9
0.0
25,847
0
Nonroad gasoline
Reformulated gasoline
29.1
0.0
145,500
0
Motor Vehicles
Enhanced l/M
2,588.9
1,830.5
736,854
1,473,708
Total
7,504.0
1,925.0
2,950,337
1,473,708
Fresno, CA
Adhesives - industrial
RACT
14.2
0.0
35,444
0
Aerosols
CARB Tier 2 Standards -
119.6
0.0
298,638
0
Reform
Aerosols
SCAQMD Standards -
119.6
0.0
1,194,552
0
Reformulati
Automobile refinishing
CARB BARCT limits
58.9
0.0
217,170
0
Automobile refinishing
FIP Rule (VOC Content & TE)
225.5
0.0
4,062,635
0
Bulk Terminals
RACT
57.2
0.0
95,380
0
Cutback Asphalt
Switch to emulsified asphalts
57.0
0.0
0
0
marine surface coating
Add-on control levels
11.1
0.0
160,048
0
Metal product surface coating
VOC content limits & improved
77.5
0.0
1,931
0
Miscellaneous surface coating
Add-on control levels
93.6
0.0
1,460,681
0
Miscellaneous surface coating
MACT level of control
27.8
0.0
69,321
0
Motor Vehicles
Enhanced l/M
750.9
1,264.0
298,651
597,301
Nonroad gasoline
Reformulated gasoline
63.0
0.0
315,000
0
Open Burning
Episodic Ban
276.4
52.4
0
0
Paper surface coating
Add-on control levels
4.5
0.0
298,193
0
Pesticide Application
Reformulation - FIP rule
742.3
0.0
6,903,465
0
Point Source Metal Surface Coating
FIP VOC Limits
52.6
0.0
0
0
Point Sources
RE Improvements
3,519.3
0.0
7,038,660
0
Recreational vehicles
CARB standards
60.8
0.0
32,225
0
Service stations - stage l-truck un
Vapor balance & P-V valves
454.2
0.0
103,431
0
Web Offset Lithography
New CTG (carbon adsorber)
4.1
0.0
-508
0
Wood furniture surface coating
Reformulation
102.1
0.0
38,279
0
Wood product surface coating
Reformulation
6.2
0.0
154
0
Total
6,898.4
1,316.4
22,623,35
0
597,301
Gadsden, AL
Utility Boiler - PC/Tangential
SCR
0.0
644.2
0
7,221,513
Industrial Boiler - Residual Oil
SCR
0.0
22.2
0
63,390
Industrial Boiler • Natural Gas
SCR
0.0
741.0
0
2,676,647
Area Source Industrial Coal Comb
RACT to small sources
0.0
5.6
0
21,983
Area Source Industrial Oil Comb
RACT to small sources
0.0
1.6
0
3,332
Area Source Industrial NG Comb
RACT to small sources
0.0
68.6
0
115,813
Open Burning
Episodic Ban
319.1
60.8
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
18.1
0
148,361
Iron & Steel Mills - Reheating
LNB + FGR
0.0
282.8
0
145,027
Motor Vehicles
California Reform
1,658.7
545.3
4,214,478
3,961,791
B-71
-------
Table B-8 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
Enhanced l/M
1,406.0
1,143.7
462,235
924,471
Motor Vehicles
California LEV
513.5
977.1
748,129
748,129
Motor Vehicles
Reform Diesel
0.0
67.3
0
1,033,553
Total
3,897.3
4,578.3
5,424,842
17,064,009
Grand Rapids, Ml
Open Burning
Episodic Ban
924.5
175.4
0
0
Point Sources
RE Improvements
6,025.1
0.0
12,050,11
o
0
Metal product surface coating
VOC content limits & improved
218.1
0.0
5,456
0
Wood product surface coating
Reformulation
6.5
0.0
298
0
Wood furniture surface coating
Reformulation
5,407.2
0.0
2,027,744
0
Adhesives - industrial
RACT
245.9
0.0
614,665
0
Paper surface coating
Add-on control levels
32.8
0.0
2,069,547
0
Miscellaneous surface coating
Add-on control levels
1,539.4
0.0
38,461,77
3
0
Automobile refinishing
FIP Rule (VOC Content & TE)
387.4
0.0
5,829,631
0
Aerosols
SCAQMD Standards
294.4
0.0
1,838,700
0
Reformulati
Aircraft surface coating
Add-on control levels
5.6
0.0
200,467
0
marine surface coating
Add-on control levels
68.1
0.0
985,510
0
Cutback Asphalt
Switch to emulsified asphalts
244.3
0.0
0
0
Pharmaceutical manufacture
RACT
138.2
0.0
46,285
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
37.7
0.0
14,970
0
Service stations • stage l-truck un
Vapor balance & P-V valves
403.3
0.0
10,082
0
Web Offset Lithography
New CTG (carbon adsorber)
18.7
0.0
-2,341
0
Pesticide Application
Reformulation - FIP rule
128.0
0.0
1,189,470
0
Recreational vehicles
CARB standards
777.1
0.0
411,888
0
Motor Vehicles
California Reform
6,672.3
2,634.1
21,071,73
o
19,487,874
Motor Vehicles
Enhanced l/M
6,676.3
5,413.5
846,421
1,692,841
Motor Vehicles
California LEV
2,497.1
4,758.5
3,690,850
3,690,850
Total
32,748.0
12,981.5
91,363,25
6
24,871,565
Green Bay, Wl
Open Burning
Episodic Ban
385.8
73.1
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
1044
0.0
1,920,776
0
Point Source Metal Surface Coating FIP VOC Limits
16.4
0.0
0
0
Point Source Wood Product
FIP VOC Limits
17.9
0.0
447
0
Coating
Metal product surface coating
VOC content limits & improved
112.8
0.0
4,425
0
Wood product surface coating
Reformulation
3.9
0.0
171
0
Wood furniture surface coating
Reformulation
185.1
0.0
142,522
0
Adhesives - industrial
RACT
281.1
0.0
702,740
0
Paper surface coating
Add-on control levels
38.5
0.0
3,952,517
0
Miscellaneous surface coating
Add-on control levels
56.0
0.0
1,903,772
0
Automobile refinishing
FIP Rule (VOC Content & TE)
110.3
0.0
1,659,932
0
Miscellaneous surface coating
MACT level of control
108.7
0.0
271,727
0
Aerosols
SCAQMD Standards
97.4
0.0
608,130
0
Reformulati
marine surface coating
Add-on control levels
261.1
0.0
3,778,474
0
SOCMI batch reactor processes
New CTG
1.7
0.0
6,931
0
Cutback Asphalt
Switch to emulsified asphalts
176.5
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
123.4
0.0
3,091
0
Web Offset Lithography
New CTG (carbon adsorber)
2.5
0.0
-312
0
Pesticide Application
Reformulation - FIP rule
50.2
0.0
466,507
0
Recreational vehicles
CARB standards
104.0
0.0
55,132
0
B-72
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Greensboro, NC
Harrisburg, PA
Hartford, CT
Motor Vehicles
Motor Vehicles
Motor Vehicles
California Reform
Enhanced l/M
California LEV
Total
1,902.8
2,203.0
786.2
7,129.7
789.5
1,639.3
1,416.2
3,918.1
6,331,524
513,145
1,114,158
23,435,80
8
Utility Boiler - PC/Wall
SCR
0.0
17,957.6
0
Utility Boiler - PC/Tangential
SCR
0.0
1,165.3
0
Industrial Boiler - PC
SCR
0.0
88.6
0
Industrial Boiler - Stoker
SCR
0.0
233.8
0
Industrial Boiler - Residual Oil
SCR
0.0
604.4
0
Industrial Boiler - Natural Gas
SCR
0.0
4.6
0
Area Source Industrial Coal Comb
RACT to small sources
0.0
157.9
0
Area Source Industrial Oil Comb
RACT to small sources
0.0
12.7
0
Area Source Industrial NG Comb
RACT to small sources
0.0
158.7
0
Open Burning
Episodic Ban
2,245.0
425.2
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
125.5
0
Cogeneration - Coal
SCR
0.0
991.3
0
Motor Vehicles
California Reform
8,488.8
3,395.3
27,632,24
Motor Vehicles
Motor Vehicles
Motor Vehicles
Open Burning
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Paper surface coating
Miscellaneous surface coating
Automobile refinishing
Aerosols
Enhanced l/M 8,319.7 7,158.9 1,431,332
California LEV 3,432.1 6,284.5 4,919,313
Reform Diesel 0.0 396.7 0
Total 22,485.6 39,161.0 33,982,89
1
Episodic Ban 750.9 142.4 0
VOC content limits & improved 96.4 0.0 2,407
Reformulation 5.8 0.0 144
Reformulation 26.1 0.0 26,756
Add-on control levels 11.1 0.0 748,944
Add-on control levels 36.7 0.0 2,502,769
FIP Rule (VOC Content &TE) 165.8 0.0 2,492,928
SCAQMD Standards - 167.9 0.0 1,049,280
Reformulati
Aircraft surface coating
Add-on control levels
3.3
0.0
117,525
marine surface coating
Add-on control levels
2.0
0.0
28,661
Service stations - stage I-truck un
Vapor balance & P-V valves
302.3
0.0
7,557
Pesticide Application
Reformulation - FIP rule
46.3
0.0
429,883
Recreational vehicles
CARB standards
69.5
0.0
36,896
Motor Vehicles
California Reform
392.7
715.2
227,500
Motor Vehicles
Enhanced l/M
283.3
233.7
88,688
Motor Vehicles
California LEV
1,367.2
2,598.7
1,995,763
Total
3,727.3
3,690.0
9,755,701
Open Burning
Episodic Ban
890.4
168.9
0
Point Source Ind. Surface Coating
Add-on Control Levels
5.8
0.0
107,456
Point Source Metal Surface Coating FIP VOC Limits
102.9
0.0
0
Metal product surface coating
VOC content limits & improved
90.3
0.0
12,139
Wood product surface coating
Reformulation
4.7
0.0
116
Wood furniture surface coating
Reformulation
46.7
0.0
74,532
Paper surface coating
Add-on control levels
13.7
0.0
1,374,240
Miscellaneous surface coating
Add-on control levels
43.6
0.0
3,164,929
Automobile refinishing
FIP Rule (VOC Content & TE)
269.8
0.0
7,859,989
Aerosols
SCAQMD Standards -
Reformulati
276.6
0.0
1,728,300
5,874,730
1,026,289
1,114,158
8,015,177
57,665,046
12,725,521
1,859,550
1,771,700
2,445,920
38,686
630,344
27,933
266,136
0
1,022,860
9,199,840
25,932,237
2,862,664
4,919,313
5,890,406
127,258; 156
0
0
0
0
0
0
0
0
0
0
0
0
0
10,522,263
177,377
1,995,763
12,695,403
0
0
0
0
0
0
0
0
0
0
B-73
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
vex:
NOx
Aircraft surface coating
Add-on control levels
115.6
0.0
6,053,206
0
Service stations - stage l-truck un
Vapor balance & P-V valves
467.5
0.0
11,687
0
Pesticide Application
Reformulation - FIP rule
12.5
0.0
115,841
0
Recreational vehicles
CARB standards
296.1
0.0
156,879
0
Motor Vehicles
California Reform
710.1
1,313.5
486,500
19,984,065
Motor Vehicles
California LEV
2,649.3
4,889.5
3,811,174
3,811,174
Total
5,995.6
6,371.9
24,956,98
q
23,795,239
Open Burning
Episodic Ban
118.0
22.1
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
85.0
0.0
1,564,828
0
Point Source Metal Surface Coating FIP VOC Limits
0.0
0.0
0
0
Point Source Wood Product
FIP VOC Limits
62.8
0.0
1,570
0
Coating
Point Sources
RE Improvements
1,468.8
0.0
2,937,520
0
Bulk Terminals
RACT
463.9
0.0
773,103
0
Metal product surface coating
VOC content limits & improved
12.9
0.0
321
0
Wood product surface coating
Reformulation
9.7
0.0
242
0
Wood furniture surface coating
Reformulation
12.1
0.0
4,536
0
Adhesives - industrial
RACT
54.9
0.0
137,302
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
2.6
0.0
46,902
0
Automobile refinishing
FIP Rule (VOC Content & TE)
31.6
0.0
476,588
0
Miscellaneous surface coating
MACT level of control
3.3
0.0
8,222
0
Aerosols
SCAQMD Standards -
61.1
0.0
383,160
0
Reformulati
marine surface coating
Add-on control levels
0.0
0.0
0
0
SOCMI batch reactor processes
NewCTG
217.0
0.0
879,774
0
Cutback Asphalt
Switch to emulsified asphalts
193.4
0.0
0
0
SOCMI fugitives
RACT
130.6
0.0
17,792
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
12.4
0.0
4,910
0
Service stations - stage l-truck un
Vapor balance & P-V valves
389.8
0.0
292,007
0
Web Offset Lithography
New CTG (carbon adsorber)
16.2
0.0
-2,028
0
Pesticide Application
Reformulation - FIP rule
149.0
0.0
1,384,808
0
Recreational vehicles
CARB standards
36.8
0.0
19,476
0
Motor Vehicles
Federal Reform
2,364.8
311.5
7,043,832
0
Motor Vehicles
Enhanced l/M
1,568.9
1,345.3
519,516
1,039,032
Motor Vehicles
California LEV
495.8
1,129.5
840,930
840,930
Total
7,961.4
2,808.4
17,335,31
1,879,962
Open Burning
Episodic Ban
677.8
128.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
106.2
0.0
1,954,356
0
Point Sources
RE Improvements
6,281.0
0.0
12,561,84
o
0
Bulk Terminals
RACT
312.3
0.0
520,139
0
Metal product surface coating
VOC content limits & improved
60.4
0.0
2,175
0
Wood furniture surface coating
Reformulation
47.7
0.0
18,348
0
Adhesives - industrial
RACT
123.4
0.0
308,284
0
Miscellaneous surface coating
Add-on control levels
27.2
0.0
984,745
0
Automobile refinishing
FIP Rule (VOC Content & TE)
83.8
0.0
1,259,957
0
Miscellaneous surface coating
MACT level of control
13.7
0.0
34,223
0
Aerosols
SCAQMD Standards
172.5
0.0
1,075,530
0
Reformulati
marine surface coating
Add-on control levels
5.7
0.0
82,393
O
SOCMI batch reactor processes
NewCTG
105.1
0.0
426,152
0
Houston, TX
Huntington, WV
B-74
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
Cutback Asphalt
Switch to emulsified asphalts
274.0
0.0
0
SOCMI fugitives
RACT
61.3
0.0
8,345
Oil and natural gas production fiel
RACT (equipment/maintenance)
12.8
0.0
5,039
Service stations - stage l-truck un
Vapor balance & P-V valves
597.4
0.0
345,603
Web Offset Lithography
New CTG (carbon adsorber)
18.2
0.0
-2,290
Pesticide Application
Reformulation - FIP rule
23.2
0.0
215,388
Recreational vehicles
CARB standards
59.0
0.0
31,170
Motor Vehicles
California Reform
2,852.2
1,338.1
10,278,75
g
Motor Vehicles
Enhanced l/M
3,340.0
2,779.3
747,441
Motor Vehicles
California LEV
1,154.5
2,393.5
1,818,804
Total
16,409.4
6,638.9
32,676,40
NOx
0
0
0
0
0
0
0
9,645,697
1,494,881
1,818,804
12,959,382
0
0
0
0
0
0
0
0
0
0
0
Indianapolis, IN
Open Burning
Point Source Metal Surface Coating
Point Sources
Bulk Terminals
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Adhesives - industrial
Automobile refinishing
Miscellaneous surface coating
Aerosols
1
Episodic Ban 2,063.1 391.5 0
FIP VOC Limits 28.1 0.0 0
RE Improvements 3,550.0 0.0 7,099,980
RACT 1,343.1 0.0 2,237,728
VOC content limits & improved 497.2 0.0 17,521
Reformulation 13.0 0.0 430
Reformulation 738.2 0.0 541,637
RACT 681.3 0.0 1,703,266
CARB BARCT limits 104.3 0.0 383,634
MACT level of control 311.2 0.0 778,066
CARB Tier2 Standards- 219.3 0.0 548,148
Reform
Johnson City, TN
Cutback Asphalt
Switch to emulsified asphalts
694.0
0.0
0
0
Pharmaceutical manufacture
RACT
46.7
0.0
15,664
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,126.1
0.0
1,290,026
0
Web Offset Lithography
New CTG (carbon adsorber)
253.7
0.0
-31,718
0
Recreational vehicles
CARB standards
208.9
0.0
110,710
0
Motor Vehicles
Enhanced l/M
12,258.3
8,426.4
3,494,813
6,989,625
Total
25,136.5
8,817.9
18,189,90
5
6,989,625
Utility Boiler -PC/Wall
SCR
0.0
24,187.3
0
81,013,209
Utility Boiler - PC/Tangential
SCR
0.0
8,176.7
0
30,541,085
Utility Boiler - Oil-Gas/Wall
SCR
0.0
915.8
0
6,975,580
Industrial Boiler - Cyclone
NGR
0.0
13.1
0
162,580
Industrial Boiler - PC
SCR
0.0
15,515.4
0119,291,243
Industrial Boiler • Stoker
SCR
0.0
5,334.9
0
23,531,608
Industrial Boiler • Residual Oil
SCR
0.0
87.2
0
252,888
Industrial Boiler • Distillate Oil
SCR
0.0
50.6
0
241,946
Industrial Boiler - Natural Gas
SCR
0.0
51.8
0
189,219
IC Engines - Natural Gas
NSCR
0.0
812.7
0
144,518
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
17.5
0
126,036
Process Heaters - Natural Gas
LNB + SCR
0.0
0.1
0
1,876
Nitric Acid Manufacturing Plant
NSCR
0.0
25.8
0
215,939
Area Source Industrial Coal Comb
RACT to small sources
0.0
26.8
0
105,786
Area Source Industrial Oil Comb
RACT to small sources
0.0
2.6
0
5,374
Area Source Industrial NG Comb
RACT to small sources
0.0
32.8
0
54,795
Open Burning
Episodic Ban
1,585.5
300.9
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
56.5
0
461,591
Commercial Marine Vessels
Emission Fees
0.0
24.4
0
243,554
Glass Manufacturing - Container
Oxy-Firing
0.0
135.2
0
857,196
B-75
-------
Table B-8 (continued)
Nonattainment
Area
Reductions
Costs
(tons per year)
(1990S)
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
California Reform
5,060.2
1,933.2
14,094,50
3
14,220,239
Motor Vehicles
Enhanced l/M
4,710.6
4,202.5
1,656,671
3,313,342
Motor Vehicles
California LEV
1,714.3
3,558.2
2,681,437
2,681,437
Motor Vehicles
Reform Diesel
0.0
251.4
0
3,900,308
Total
13,070.6
65,713.4
18,432,61 288,531,349
1
Utility Boiler - PC/Wall
SCR
0.0
5,998.5
0
18,742,279
Utility Boiler - PC/Tangential
SCR
0.0
8,106.7
0
26,025,212
Industrial Boiler - PC
SCR
0.0
1,326.8
0
10,426,112
Industrial Boiler - Stoker
SCR
0.0
839.0
0
4,058,426
Industrial Boiler - Residual Oil
SCR
0.0
56.3
0
200,607
Industrial Boiler - Distillate Oil
LNB
0.0
4.1
0
5,856
Industrial Boiler - Natural Gas
SCR
0.0
57.5
0
207,217
Process Heaters - Natural Gas
LNB + SCR
0.0
73.6
0
344,618
Area Source Industrial Coal Comb
RACT to small sources
0.0
38.4
0
147,350
Area Source Industrial Oil Comb
RACT to small sources
0.0
2.8
0
5,962
Area Source Industrial NG Comb
RACT to small sources
0.0
39.0
0
61,946
Open Burning
Episodic Ban
1,281.6
242.8
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
85.0
0
694,198
Commercial Marine Vessels
Emission Fees
0.0
57.6
0
575,089
Cement Manufacturing - Dry
SCR
0.0
841.3
0
4,064,979
Motor Vehicles
California Reform
12,632.6
3,713.8
38,361,90
g
18,059,394
Motor Vehicles
Enhanced l/M
6,375.2
5,293.0
2,109,902
4,219,805
Motor Vehicles
California LEV
2,210.2
4,496.3
3,414,811
3,414,811
Motor Vehicles
Reform Diesel
0.0
301.1
0
4,554,860
Total
22,499.6
31,573.6
43,886,62
95,808,720
Aerosols
CARB Tier 2 Standards
0.0
0.0
0
0
Reform
Aerosols
SCAQMD Standards
0.0
0.0
0
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Source Metal Surface Coating FIP VOC Limits
0.0
0.0
0
0
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Knoxville. TN
B-76
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Open Burning
Episodic Ban
1,928.7
365.7
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
2,629.9
0.0
48,388,78
o
0
Point Source Metal Surface Coating FIP VOC Limits
287.3
0.0
0
0
Point Source Wood Product
FIP VOC Limits
39.4
0.0
986
0
Coating
Point Sources
RE Improvements
945.0
0.0
1,889,970
0
Bulk Terminals
RACT
138.5
0.0
230,461
0
Metal product surface coating
VOC content limits & improved
345.8
0.0
14,845
0
Wood product surface coating
Reformulation
9.4
0.0
563
0
Wood furniture surface coating
Reformulation
834.0
0.0
397,989
0
Adhesives - industrial
RACT
194.0
0.0
484,559
0
Paper surface coating
Add-on control levels
19.3
0.0
490,293
0
Miscellaneous surface coating
Add-on control levels
1,166.3
0.0
20,744,73
8
0
Automobile refinishing
FIP Rule (VOC Content & TE)
397.0
0.0
5,970,802
0
Miscellaneous surface coating
MACT level of control
110.2
0.0
275,106
0
Aerosols
SCAQMD Standards
366.8
0.0
2,290,320
0
Reformulati
marine surface coating
Add-on control levels
34.1
0.0
494,512
0
Cutback Asphalt
Switch to emulsified asphalts
227.1
0.0
0
0
Petroleum refinery fugitives
RACT
52.5
0.0
-23,622
0
Pharmaceutical manufacture
RACT
20.3
0.0
6,790
0
Service stations - stage (-truck un
Vapor balance & P-V valves
799.0
0.0
262,474
0
Web Offset Lithography
New CTG (carbon adsorber)
21.0
0.0
-2,636
0
Pesticide Application
Reformulation - FIP rule
117.1
0.0
1,089,365
0
Recreational vehicles
CARB standards
155.5
0.0
82,423
0
Motor Vehicles
California Reform
3,164.9
2,014.5
9,141,402
21,741,142
Motor Vehicles
Enhanced l/M
8,160.4
6,004.6
900,516
1,801,031
Motor Vehicles
California LEV
2,911.5
5,310.9
4,134,846
4,134,846
Total
25,075.0
13,695.7
97,265,48
2
27,677,019
Utility Boiler-PC/Wall
SCR
0.0
28,812.3
0
98,504,407
Industrial Boiler - PC
SCR
0.0
752.3
0
5,922,003
Industrial Boiler - Stoker
SCR
0.0
160.3
0
723,909
Industrial Boiler - Residual Oil
SCR
0.0
294.5
0
859,704
Industrial Boiler - Distillate Oil
SCR
0.0
12.4
0
58,747
Industrial Boiler - Natural Gas
SCR
0.0
891.5
0
3,188,713
Area Source Industrial NG Comb
RACT to small sources
0.0
47.4
0
81,530
Open Burning
Episodic Ban
856.6
162.6
0
0
N on road Diesels
CARB Stds for >175 HP
0.0
46.7
0
381,506
Glass Manufacturing - Container
Oxy-Firing
0.0
42.5
0
266,848
Cement Manufacturing - Dry
SCR
0.0
493.1
0
2,359,895
Cement Manufacturing - Wet
SCR
0.0
419.6
0
1,675,408
Motor Vehicles
California Reform
3,727.4
1,285.2
10,062,13
1
9,445,702
Motor Vehicles
Enhanced l/M
3,339.9
2,733.4
1,106,025
2,212,049
Motor Vehicles
California LEV
1,253.7
2,329.5
1,789,979
1,789,979
Motor Vehicles
Reform Diesel
0.0
155.6
0
2,222,513
Total
9,177.6
38,638.9
12,958,13 129,692,913
*
Utility Boiler • Cyclone
SCR
0.0
5,531.8
0
88,425,740
Industrial Boiler - Stoker
SCR
0.0
155.8
0
1,572,925
Industrial Boiler - Residual Oil
SCR
0.0
60.7
0
403,127
Louisville, KY
Macon, GA
Memphis, TN
B-77
-------
Table B-8 (continued)
Reductions
Costs
(1990$)
Nonattainment
Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Industrial Boiler - Distillate Oil
SCR
0.0
34.8
0
364,499
Industrial Boiler - Natural Gas
SCR
0.0
514.5
0
4,231,577
IC Engines - Natural Gas
NSCR
0.0
1,386.6
0
237,702
IC Engines - Oil
SCR
0.0
825.8
0
324,265
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
71.4
0
1,242,784
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
99.9
0
786,261
Process Heaters - Natural Gas
LNB + SCR
0.0
77.2
0
733,581
Process Heaters - Distillate Oil
LNB + SCR
0.0
98.5
0
3,459,895
Area Source Industrial Coal Comb
RACT to small sources
0.0
218.2
0
849,906
Area Source Industrial Oil Comb
RACT to small sources
0.0
19.4
0
31,018
Area Source Industrial NG Comb
RACT to small sources
0.0
102.0
0
176,219
Open Burning
Episodic Ban
566.3
107.1
0
0
Nonroad Diesels
CARB Stdsfor> 175 HP
0.0
115.1
0
935,762
Commercial Marine Vessels
Emission Fees
0.0
538.3
0
5,382,359
Point Source Ind. Surface Coating
Add-on Control Levels
340.1
0.0
6,259,312
0
Point Source Metal Surface Coating
FIP VOC Limits
16.8
0.0
0
0
Point Sources
RE Improvements
4,609.6
0.0
9,219,170
0
Bulk Terminals
RACT
194.0
0.0
323.258
0
Metal product surface coating
VOC content limits & improved
530.4
0.0
17,475
0
Wood product surface coating
Reformulation
5.4
0.0
308
0
Wood furniture surface coating
Reformulation
1,227.9
0.0
460,432
0
Adhesives - industrial
RACT
204.0
0.0
510,073
0
Paper surface coating
Add-on control levels
57.4
0.0
2,411,152
0
Miscellaneous surface coating
Add-on control levels
375.9
0.0
8,933,296
0
Automobile refinishing
FIP Rule (VOC Content & TE)
328.1
0.0
4,933,164
0
Miscellaneous surface coating
MACT level of control
54.4
0.0
135,950
0
Aerosols
SCAQMD Standards
346.2
0.0
2,162,760
0
Milwaukee, Wl
Reformulati
marine surface coating
Add-on control levels
3.8
0.0
54,648
Cutback Asphalt
Switch to emulsified asphalts
180.2
0.0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,349.3
0.0
665,608
Web Offset Lithography
New CTG (carbon adsorber)
222.0
0.0
-27,756
Pesticide Application
Reformulation - FIP rule
181.5
0.0
1,687,689
Recreational vehicles
CARB standards
116.3
0.0
61,551
Motor Vehicles
Federal Reform
6,090.8
1,125.8
18,444,45
5
Motor Vehicles
Enhanced l/M
6,145.1
4,641.7
711,062
Motor Vehicles
California LEV
2,500.4
4,153.0
3,287,891
Motor Vehicles
Reform Diesel
0.0
216.0
0
Total
25,645.9
20,093.6
60,251,49
8
Open Burning
Episodic Ban
2,714.9
516.3
0
Point Source Ind. Surface Coating
Add-on Control Levels
439.4
0.0
8,086,064
Point Source Metal Surface Coating
FIP VOC Limits
1,256.7
0.0
0
Point Sources
RE Improvements
514.3
0.0
1,028,570
Metal product surface coating
VOC content limits & improved
382.3
0.0
13,833
Wood product surface coating
Reformulation
5.5
0.0
217
Wood furniture surface coating
Reformulation
221.1
0.0
129,870
Paper surface coating
Add-on control levels
7.2
0.0
739,470
Miscellaneous surface coating
Add-on control levels
1,012.5
0.0
17,495,88
g
Automobile refinishing
FIP Rule (VOC Content & TE)
490.3
0.0
7,376,398
Miscellaneous surface coating
MACT level of control
865.9
0.0
2,164,630
0
0
0
0
0
0
0
1,422,123
3,287,891
3,044,678
116,912,312
0
0
0
0
0
0
0
0
0
0
0
B-78
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Aerosols
SCAQMD Standards
478.6
0.0
2,990,580
0
Reformulati
marine surface coating
Add-on control levels
2.1
0.0
29,350
0
Service stations - stage l-truck un
Vapor balance & P-V valves
633.6
0.0
15,856
0
Pesticide Application
Reformulation - FIP rule
48.4
0.0
449,636
0
Recreational vehicles
CARB standards
355.2
0.0
188,175
0
Motor Vehicles
California Reform
989.9
1,795.1
681,500
27,848,003
Motor Vehicles
California LEV
4,186.4
6,698.7
5,323,070
5,323,070
Total
14,604.3
9,010.1
46,713,10
8
33,171,073
Open Burning
Episodic Ban
630.5
119.8
0
0
Point Sources
RE Improvements
21,973.0
0.0
43,946,00
o
0
Metal product surface coating
VOC content limits & improved
93.0
0.0
4,150
0
Wood product surface coating
Reformulation
3.9
0.0
250
0
Wood furniture surface coating
Reformulation
55.5
00
79,862
0
Cutback Asphalt
Switch to emulsified asphalts
429.4
0.0
0
0
SOCMI fugitives
RACT
389.2
0.0
53,028
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
100.8
0.0
39,986
0
Service stations - stage l-truck un
Vapor balance & P-V valves
293.7
0.0
7,343
0
Web Offset Lithography
New CTG (carbon adsorber)
39.8
0.0
-4,975
0
Recreational vehicles
CARB standards
29.7
0.0
15,721
0
Motor Vehicles
Enhanced l/M
3,265.6
2,481.9
1,032,990
2,065,981
Total
27,304.1
2,601.7
45,174,35
5
2,065,981
Aerosols
CARB Tier 2 Standards -
46.7
0.0
116,760
0
Reform
Aerosols
SCAQMD Standards -
46.7
0.0
467,040
0
Reformulati
Automobile refinishing
CARB BARCT limits
30.0
0.0
110,381
0
Automobile refinishing
FIP Rule (VOC Content & TE)
114.6
0.0
2,064,926
0
Metal product surface coating
VOC content limits & improved
352.8
0.0
8,725
0
Miscellaneous surface coating
Add-on control levels
64.2
0.0
1,006,908
0
Miscellaneous surface coating
MACT level of control
17.1
0.0
42,760
0
Nonroad gasoline
Reformulated gasoline
25.1
0.0
125,500
0
Open Burning
Episodic Ban
97.6
18.5
0
0
Paper surface coating
Add-on control levels
9.4
0.0
632,619
0
Pesticide Application
Reformulation • FIP rule
108.9
0.0
1,012,621
0
Point Source Ind. Surface Coating
Add-on Control Levels
74.1
0.0
1,363,348
0
Point Source Metal Surface Coating FIP VOC Limits
61.0
0.0
0
0
Recreational vehicles
CARB standards
24.4
0.0
12,907
0
Sen/ice stations - stage l-truck un
Vapor balance & P-V valves
131.9
0.0
3,297
0
Wood furniture surface coating
Reformulation
78.4
0.0
29,408
0
Wood product surface coating
Reformulation
2.5
0.0
63
0
Total
1,285.4
18.5
6,997,263
0
Utility Boiler - PC/Tangential
SCR
0.0
10,608.4
0
38,924,513
Industrial Boiler - PC
SCR
0.0
411.4
0
6,261,012
Industrial Boiler - Stoker
SCR
0.0
39.7
0
413,030
Industrial Boiler - Residual Oil
SCR
0.0
19.5
0
78,816
Industrial Boiler - Distillate Oil
SCR
0.0
20.3
0
218,482
Industrial Boiler • Natural Gas
SCR
0.0
244.8
0
1,910,614
IC Engines - Natural Gas
NSCR
0.0
3,659.7
0
2,591,036
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
316.2
0
2,596,960
Gas Turbines - Oil
SCR ~ WATER INJECTION
0.0
246.5
0
5,652,452
Mobile, AL
Modesto, CA
Nashville, TN
B-79
-------
Table B-8 (continued)
Nonattainment
Area
Reductions
Costs
l
(tons per year)
(1990S)
[
Source Category
Control Measure
VOC
NOx
VOC
NOx
Process Heaters - Natural Gas
LNB + SCR
0.0
11.3
0
174,243
Area Source Industrial Coal Comb
RACT to small sources
0.0
110.2
0
417,861
Area Source Industrial Oil Comb
RACT to small sources
0.0
9.9
0
20,524
Area Source Industrial NG Comb
RACT to small sources
0.0
151.8
0
240,219
Open Burning
Episodic Ban
1,064.9
201.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
118.2
0
963,791
Commercial Marine Vessels
Emission Fees
0.0
27.6
0
274,516
Municipal Waste Combustors
SNCR
0.0
131.6
0
439,269
Motor Vehicles
California Reform
7,291.5
2,984.6
24,637,77
o
23,108,747
Motor Vehicles
Enhanced l/M
7,689.3
6,365.8
912,070
1,824,139
Motor Vehicles
California LEV
3,095.6
5,647.0
4,396,974
4,396,974
Motor Vehicles
Reform Diesel
0.0
318.7
0
4,709,895
Total
19,141.3
31,644.7
29,946,81
4
95,217,093
Open Burning
Episodic Ban
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Aerosols
SCAQMD Standards
0.0
0.0
0
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Motor Vehicles
California Reform
0.0
0.0
0
0
Motor Vehicles
California LEV
0.0
0.0
0
0
Total
0.0
0.0
0
0
Open Burning
Episodic Ban
1,225.0
232.5
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
418.7
0.0
7,703,252
0
Point Source Metal Surface Coating
FIP VOC Limits
20.4
0.0
0
0
Point Sources
RE Improvements
1,977.9
0.0
3,955,870
0
Metal product surface coating
VOC content limits & improved
300.2
0.0
10,860
0
Wood product surface coating
Reformulation
1.4
0.0
89
0
Wood furniture surface coating
Reformulation
18.9
0.0
27,213
0
Adhesives - industrial
RACT
543.8
0.0
1,359,416
0
Automobile refinishing
FIP Rule (VOC Content & TE)
203.0
0.0
3,050,535
0
Miscellaneous surface coating
MACT level of control
35.0
0.0
87,480
0
Aerosols
SCAQMD Standards ¦
439.6
0.0
2,747,430
0
Reformulati
marine surface coating
Add-on control levels
252.0
0.0
3,647,850
0
SOCMI batch reactor processes
NewCTG
1,029.8
0.0
4,174,398
0
Cutback Asphalt
Switch to emulsified asphalts
1,144.9
0.0
0
0
SOCMI fugitives
RACT
649.2
0.0
88,456
0
Pharmaceutical manufacture
RACT
5.7
0.0
1,878
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
270.1
0.0
107,119
0
Service stations • stage l-truck un
Vapor balance & P-V valves
624.3
0.0
15,609
0
Web Offset Lithography
New CTG (carbon adsorber)
117.3
0.0
-14,663
0
Pesticide Application
Reformulation - FIP rule
15.0
0.0
139,202
0
New London, CT
New Orleans, LA
B-80
-------
Table B-8 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment
Area Source Category Control Measure VOC NOx VOC NOx
Recreational vehicles
CARB standards
583.7
0.0
362,286
0
Motor Vehicles
Federal Reform
7,862.9
1,062.1
17,915,06
2
0
Motor Vehicles
Enhanced l/M
6,495.6
4,588.4
1,943,435
3,886,871
Motor Vehicles
California LEV
2,447.5
3,979.6
3,144,649
3,144,649
Total
26,781.9
9,862.6
50,467,42
6
7,031,520
Open Burning
Episodic Ban
309.8
58.7
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
20.1
0.0
369,380
0
Point Source Metal Surface Coating FIP VOC Limits
0.0
0.0
0
0
Point Source Wood Product
FIP VOC Limits
0.0
0.0
0
0
Coating
Point Sources
RE Improvements
23.7
0.0
47,450
0
Metal product surface coating
VOC content limits & improved
22.3
0.0
1,182
0
Wood product surface coating
Reformulation
1.2
0.0
59
0
Wood furniture surface coating
Reformulation
41.0
0.0
41,407
0
Paper surface coating
Add-on control levels
1.7
0.0
109,560
0
Miscellaneous surface coating
Add-on control levels
14.0
0.0
519,847
0
Automobile refinishing
FIP Rule (VOC Content & TE)
73.3
0.0
1,102,707
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Aerosols
SCAQMD Standards
77.3
0.0
482,250
0
Reformulati
Aircraft surface coating
Add-on control levels
0.0
0.0
0
0
marine surface coating
Add-on control levels
0.6
0.0
10,930
0
Service stations - stage 1-truck un
Vapor balance & P-V valves
134.8
0.0
3,374
0
Pesticide Application
Reformulation - FIP rule
13.2
0.0
122,147
0
Recreational vehicles
CARB standards
33.8
0.0
17,965
0
Motor Vehicles
California Reform
1,042.5
587.8
3,814,299
4,873,195
Motor Vehicles
Enhanced l/M
1,700.1
1,441.0
564,759
1,129,519
Motor Vehicles
California LEV
573.7
1,285.2
914,210
914,210
Total
4,083.3
3,372.7
8.121,526
6,916,924
Utility Boiler - PC/Wall
SCR
0.0
1,607.9
0
7,019,681
Utility Boiler - PC/Tangential
SCR
0.0
7,314.9
0
32,483,283
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
1,599.7
0
12,055,511
Industrial Boiler - PC
SCR
0.0
1,012.2
0
8,058,459
Industrial Boiler - Stoker
SCR
0.0
444.3
0
2,430,986
Industrial Boiler - Residual Oil
SCR
0.0
790.4
0
4,044,791
Industrial Boiler - Distillate Oil
SCR
0.0
134.6
0
1,181,221
Industrial Boiler - Natural Gas
SCR
0.0
52.7
0
427,031
IC Engines - Oil
SCR
0.0
37.0
0
393,293
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
4.0
0
756,335
Gas Turbines - Oil
SCR + WATER INJECTION
0.0
6.0
0
1,421,641
Process Heaters - Natural Gas
LNB + SCR
0.0
40.9
0
741,368
Process Heaters - Distillate Oil
LNB + SCR
0.0
8.2
0
291,284
Area Source Industrial Coal Comb
RACT to small sources
0.0
196.7
0
785,155
Area Source Industrial Oil Comb
RACT to small sources
0.0
10.2
0
21,387
Area Source Industrial NG Comb
RACT to small sources
0.0
157.4
0
263,335
Residential NG Consumption
LNB Space heaters
0.0
312.0
0
384,394
Open Burning
Episodic Ban
1,227.3
232.1
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
120.0
0
977,564
Commercial Marine Vessels
Emission Fees
0.0
1,073.4
0
10,732,157
Glass Manufacturing - Container
Oxy-Firing
0.0
773.5
0
4,841,947
Iron & Steel Mills - Reheating
LNB + FGR
0.0
9.7
0
4,973
B-81
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Owensboro, KY
Philadelphia, PA
Phoenix, AZ
Municipal Waste Combustors
Motor Vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
Utility Boiler - PC/Wall
Utility Boiler - PC/Tangential
Utility Boiler - Cyclone
Industrial Boiler - Stoker
Industrial Boiler - Residual Oil
Industrial Boiler - Natural Gas
Area Source Industrial Coal Comb
Area Source Industrial Oil Comb
Area Source Industrial NG Comb
Open Burning
Nonroad Diesels
Commercial Marine Vessels
Motor Vehicles
Motor Vehicles
Motor Vehicles
Motor Vehicles
Open Burning
Point Source Ind. Surface Coating
Point Source Metal Surface Coating
Point Source Wood Product
Coating
Point Sources
Metal product surface coating
Wood product surface coating
Wood furniture surface coating
Paper surface coating
Miscellaneous surface coating
Automobile refinishing
Miscellaneous surface coating
Aerosols
Aircraft surface coating
marine surface coating
Service stations - stage l-truck un
Pesticide Application
Recreational vehicles
Motor Vehicles
Motor Vehicles
Adhesives - industrial
Aerosols
Automobile refinishing
Bulk Terminals
Cutback Asphalt
SNCR 0.0
California Reform 1,345.3
Enhanced l/M 11,553.4
California LEV 4,367.3
Reform Diesel 0.0
Total 18,493.3
SCR 0.0
SCR 0.0
SCR 0.0
SCR 0.0
SCR 0.0
SCR 0.0
RACT to small sources 0.0
RACT to small sources 0.0
RACT to small sources 0.0
Episodic Ban 168.3
CAR B Stds for > 175 H P 0.0
Emission Fees 0.0
California Reform 613.7
Enhanced l/M 740.2
California LEV 226.7
Reform Diesel 0.0
Total 1,748.9
Episodic Ban 0.0
Add-on Control Levels 0.0
FIP VOC Limits 0.0
FIP VOC Limits 0.0
RE Improvements 0.0
VOC content limits & improved 0.0
Reformulation 0.0
Reformulation 0.0
Add-on control levels 0.0
Add-on control levels 0.0
FIP Rule (VOC Content & TE) 0.0
MACT level of control 0.0
SCAQMD Standards 0.0
Reformulati
Add-on control levels 0.0
Add-on control levels 0.0
Vapor balance & P-V valves 0.0
Reformulation - FIP rule 0.0
CARB standards 0.0
California Reform 0.0
California LEV 0.0
Total 0.0
RACT 39.2
CARB Tier 2 Standards 402.0
Reform
CARB BARCT limits 182.6
RACT 115.1
Switch to emulsified asphalts 109.7
39.3
2,142.0
8,366.2
7.261.6
364.6
34,111.5
4,635.5
1,944.4
849.3
98.9
2.6
30.5
94.6
8.8
172.4
31.9
6.4
307.2
219.5
470.9
400.1
24.7
9.297.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0
5,469,157
3,582,246
5,796,411
0
14,847,81
4
0
0
0
0
0
0
0
0
0
0
0
0
2,568,215
191,738
310,311
0
3,070,263
0
0
O
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
98,028
0.0 1,004,856
0.0
0.0
0.0
671,796
191,712
0
123,048
30,333,761
7,164,492
5,796,411
5,249,072
137,982,580
21,299,059
7,109,311
17,090,889
1,015,716
18,936
244,273
354,725
18,458
272,704
0
52,795
3,072,058
818,529
383,477
310,311
383,255
52,444,495
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
B-82
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Metal product surface coating
VOC content limits & improved
521.6
0.0
12,986
0
Miscellaneous surface coating
MACT level of control
417.7
0.0
1,044,188
0
Motor Vehicles
Enhanced l/M
21,094.9
12,639.6
1,199,840
2,399,679
Motor Vehicles
Federal Reform
36,455.7
3,002.3
47,793,10
o
0
Nonroad gasoline
Reformulated gasoline
306.9
0.0
1,534,500
0
Open Burning
Episodic Ban
1,589.9
303.4
0
0
Recreational vehicles
CARB standards
318.6
0.0
168,875
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,131.7
0.0
212,983
0
Web Offset Lithography
New CTG (carbon adsorber)
6.4
0.0
-795
0
Wood furniture surface coating
Reformulation
891.0
0.0
334,128
0
Wood product surface coating
Reformulation
23.1
0.0
576
0
Total
63,606.1
15,945.3
54,266,77
3
2,399,679
Open Burning
Episodic Ban
2,807.4
532.4
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
457.3
0.0
8,415,148
0
Point Source Metal Surface Coating FIP VOC Limits
94.2
0.0
0
0
Point Sources
RE Improvements
277.8
0.0
555,530
0
Metal product surface coating
VOC content limits & improved
279.6
0.0
6,988
0
Wood product surface coating
Reformulation
6.4
0.0
160
0
Wood furniture surface coating
Reformulation
170.8
0.0
175,194
0
Adhesives - industrial
RACT
6.6
0.0
16,405
0
Paper surface coating
Add-on control levels
9.5
0.0
626,283
0
Miscellaneous surface coating
Add-on control levels
84.3
0.0
4,084,321
0
Automobile refinishing
FIP Rule (VOC Content & TE)
601.2
0.0
9,043,663
0
Aerosols
SCAQMD Standards -
756.7
0.0
4,727,880
0
Reformulati
marine surface coating
Add-on control levels
27.5
0.0
397,368
0
Cutback Asphalt
Switch to emulsified asphalts
6.9
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,083.1
0.0
38,641
0
Pesticide Application
Reformulation - FIP rule
41.6
0.0
387,142
0
Recreational vehicles
CARB standards
276.2
0.0
146,249
0
Motor Vehicles
California Reform
1,752.0
2,747.3
2,103,421
39,884,440
Motor Vehicles
Enhanced l/M
3,010.5
2,411.1
934,087
1,868,173
Motor Vehicles
California LEV
5,656.3
9,697.4
7,585,834
7,585,834
Total
17,405.9
15,388.2
39,244,31
4
49,338,447
Utility Boiler - Oil-Gas/Wall
SCR
0.0
2,505.4
0
15,856,806
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
340.5
0
3,213,853
Industrial Boiler - PC
SCR
0.0
185.3
0
3,961,642
Industrial Boiler - Residual Oil
SCR
0.0
140.7
0
967,230
Industrial Boiler - Distillate Oil
LNB + FGR
0.0
0.7
0
6,724
Area Source Industrial Coal Comb
RACT to small sources
0.0
0.1
0
235
Area Source Industrial Oil Comb
RACT to small sources
0.0
2.1
0
4,290
Open Burning
Episodic Ban
496.9
94.4
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
2.4
0
19,701
Commercial Marine Vessels
Emission Fees
0.0
90.8
0
907,683
Motor Vehicles
California Reform
152.1
361.1
70,000
5,228,271
Motor Vehicles
California LEV
672.9
1,278.1
990,028
990,028
Motor Vehicles
Reform Diesel
0.0
85.0
0
1,256,653
Total
1,321.9
5,086.6
1,060,028
32,413,116
Bulk Terminals
RACT
364.1
0.0
606,885
0
Cutback Asphalt
Switch to emulsified asphalts
320.2
0.0
0
0
Pittsburgh, PA
Portland, ME
Portland, OR
B-83
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Metal product surface coating
VOC content limits & improved
406.7
0.0
10,136
0
Motor Vehicles
Enhanced l/M
11,068.2
10,483.5
1,747,796
3,495,591
Open Burning
Episodic Ban
2,265.5
429.5
0
0
Pharmaceutical manufacture
RACT
4.2
0.0
1,408
0
Point Source Metal Surface Coating
FIP VOC Limits
139.8
0.0
0
0
Point Source Wood Product
FIP VOC Limits
217.2
0.0
5,429
0
Coating
Point Sources
RE Improvements
19,187.0
0.0
38,373,91
o
0
Recreational vehicles
CARB standards
403.8
0.0
214,057
0
Service stations - stage l-truck un
Vapor balance & P-V valves
1,432.7
0.0
562,989
0
SOCMI fugitives
RACT
12.7
0.0
1,729
0
Web Offset Lithography
New CTG (carbon adsorber)
259.3
0.0
-32,399
0
Wood furniture surface coating
Reformulation
487.7
0.0
182,937
0
Wood product surface coating
Reformulation
43.4
0.0
1,779
0
Total
36,612.5
10,913.0
41,676,65
5
3,495,591
Open Burning
Episodic Ban
560.1
106.4
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
177.8
0.0
3,270,692
0
Point Source Metal Surface Coating
FIP VOC Limits
129.6
0.0
0
0
Point Sources
RE Improvements
2,381.3
0.0
4,762,520
0
Metal product surface coating
VOC content limits & improved
481.8
0.0
11,958
0
Wood product surface coating
Reformulation
5.6
0.0
141
0
Wood furniture surface coating
Reformulation
403.0
0.0
151,099
0
Paper surface coating
Add-on control levels
3.3
0.0
220,089
0
Miscellaneous surface coating
Add-on control levels
195.0
0.0
3,156,486
0
Automobile refinishing
FIP Rule (VOC Content & TE)
434.2
0.0
6,533,259
0
Miscellaneous surface coating
MACT level of control
148.9
0.0
372,146
0
Aerosols
SCAQMD Standards -
296.8
0.0
1,854,330
0
Reformulati
marine surface coating
Add-on control levels
134.5
0.0
1,946,944
0
Service stations - stage l-truck un
Vapor balance & P-V valves
356.5
0.0
8,909
0
Pesticide Application
Reformulation - FIP rule
2.8
0.0
26,709
0
Recreational vehicles
CARB standards
789.7
0.0
418,473
0
Motor Vehicles
California Reform
590.1
1,002.0
737,000
15,574,996
Motor Vehicles
California LEV
2,302.1
3,756.5
2,980,279
2,980,279
Total
9,393.1
4,864.9
26,451,03
A
18,555,275
Utility Boiler - PC/Wall
SCR
0.0
15,829.6
t
0
54,107,501
Utility Boiler - PC/Tangential
SCR
0.0
8,264.7
0
31,912,250
Industrial Boiler - Stoker
SCR
0.0
605.6
0
2,825,174
Industrial Boiler - Residual Oil
SCR
0.0
252.1
0
1,078,929
Industrial Boiler - Natural Gas
SCR
0.0
8.8
0
74,162
Area Source Industrial Coal Comb
RACT to small sources
0.0
74.8
0
298,384
Area Source Industrial Oil Comb
RACT to small sources
0.0
5.3
0
11,550
Area Source Industrial NG Comb
RACT to small sources
0.0
74.9
0
125,595.
Open Burning
Episodic Ban
1,431.1
271.5
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
102.6
0
837,631
Motor Vehicles
California Reform
6,674.8
2,598.9
21,432,08
20,099,873
Motor Vehicles
Enhanced l/M
6,757.8
5,523.1
*
1,098,794
2,197,589
Motor Vehicles
California LEV
2,734.3
4,864.7
3,819,443
3,819,443
Motor Vehicles
Reform Diesel
0.0
297.5
0
4,361,319
Providence. Rl
Raleigh, NC
B-84
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area Source Category
Control Measure
VOC
NOx
VOC
NOx
Redding, CA
Redding, PA
Reno, NV
Adhesives - industrial
Aerosols
Aerosols
Automobile refinishing
Automobile refinishing
Bulk Terminals
Cutback Asphalt
marine surface coating
Metal product surface coating
Miscellaneous surface coating
Miscellaneous surface coating
Motor Vehicles
Nonroad gasoline
Open Burning
Paper surface coating
Pesticide Application
Recreational vehicles
Service stations - stage I-truck un
Web Offset Lithography
Wood furniture surface coating
Wood product surface coating
Open Burning
Point Source Ind. Surface Coating
Point Source Metal Surface Coating
Point Source Wood Product
Coating
Point Sources
Wood product surface coating
Wood furniture surface coating
Miscellaneous surface coating
Automobile refinishing
Aerosols
Service stations - stage I-truck un
Pesticide Application
Recreational vehicles
Motor Vehicles
Motor Vehicles
Aerosols
Automobile refinishing
Metal product surface coating
Miscellaneous surface coating
Motor Vehicles
Motor Vehicles
Nonroad gasoline
Total
RACT
CARB Tier 2 Standards -
Reform
SCAQMD Standards -
Reformulati
CARB BARCT limits
FIP Rule (VOC Content & TE)
RACT
Switch to emulsified asphalts
Add-on control levels
VOC content limits & improved
Add-on control levels
MACT level of control
Enhanced l/M
Reformulated gasoline
Episodic Ban
Add-on control levels
Reformulation - FIP rule
CARB standards
Vapor balance & P-V valves
New CTG (carbon adsorber)
Reformulation
Reformulation
Total
Episodic Ban
Add-on Control Levels
FIP VOC Limits
FIP VOC Limits
RE Improvements
Reformulation
Reformulation
Add-on control levels
FIP Rule (VOC Content & TE)
SCAQMD Standards
Reformulati
Vapor balance & P-V valves
Reformulation - FIP rule
CARB standards
California Reform
California LEV
Total
CARB Tier 2 Standards
Reform
CARB BARCT limits
VOC content limits & improved
MACT level of control
Enhanced l/M
Federal Reform
Reformulated gasoline
17,598.0 38,774.1 26,350,31 121,749,400
9
0
0
0
0
0
0
0
0
0
0
1,682,962
0
0
0
0
0
0
0
0
0
1,682,962
0
0
0
0
0
0
0
0
0
0
0
0
0
4,900,950
927,301
5,828,251
0
0
0
188,291
0
0
97.0
0.0
242,361
26.1
0.0
65,190
26.1
0.0
260,760
12.7
0.0
46,813
48.6
0.0
875,746
303.5
0.0
505,794
180.7
0.0
0
6.4
0.0
93,094
18.8
0.0
468
86
0.0
133,220
3.7
0.0
9,223
2,316.3
3,420.1
841,481
13.7
0.0
68,500
15.6
3.0
0
64.3
0.0
774,483
24.2
0.0
225,693
12.8
0.0
6,824
731.0
0.0
547,670
14.3
0.0
-1,791
7.4
0.0
2,761
8.3
0.0
208
3,940.1
3,423.1
4,698,498
432.9
82.1
0
442.7
0.0
8,146,508
130.7
0.0
0
54.8
0.0
1,369
46.7
0.0
93,440
9.2
0.0
230
59.3
0.0
60,839
238.5
0.0
12,666,82
0
78.1
0.0
1,174,411
93.4
0.0
584,070
110.5
0.0
2,763
28.4
0.0
263,729
39.9
0.0
21,112
185.2
336.3
129,000
648.1
1,207.3
927,301
2,598.4
1,625.7
24,071,59
2
44.1
0.0
110,244
30.8
0.0
113,240
37.5
0.0
934
30.7
0.0
76,867
1,537.1
1,483.5
94,145
1,919.7
357.6
5,606,016
39.8
0.0
199,000
B-85
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Open Burning
Episodic Ban
82.3
15.6
0
0
Recreational vehicles
CARB standards
118.5
0.0
62,805
0
Service stations - stage l-truck un
Vapor balance & P-V valves
153.1
0.0
3,845
0
Web Offset Lithography
New CTG (carbon adsorber)
97.0
0.0
-12,130
0
Wood furniture surface coating
Reformulation
68.8
0.0
25,794
0
Wood product surface coating
Reformulation
2.0
0.0
50
0
Total
4,161.4
1,856.7
6,280,810
188,291
Utility Boiler - PC/Tangential
SCR
0.0
11,955.4
0
43,177,923
Utility Boiler - Oil-Gas/Wall
SCR
0.0
538.5
0
4,463,115
Industrial Boiler - PC
SCR
0.0
1,587.5
0
21,934,490
Industrial Boiler - Stoker
SCR
0.0
440.9
0
2,357,476
Industrial Boiler - Residual Oil
SCR
0.0
513.3
0
1,780,719
Industrial Boiler - Distillate Oil
SCR
0.0
11.1
0
118,589
Industrial Boiler - Natural Gas
SCR
0.0
1,061.8
0
3,992,143
Adipic Acid Manufacturing Plant
Thermal Reduction
0.0
12.4
0
6,762
Area Source Industrial Coal Comb
RACT to small sources
0.0
115.2
0
459,773
Area Source Industrial Oil Comb
RACT to small sources
0.0
6.8
0
14,682
Area Source Industrial NG Comb
RACT to small sources
0.0
62.5
0
105,343
Residential NG Consumption
LNB Space heaters
0.0
177.8
0
220,153
Open Burning
Episodic Ban
1,249.5
236.8
0
0
Nonroad Diesels
CARB Stds for >175 HP
0.0
70.8
0
578,031
Commercial Marine Vessels
Emission Fees
0.0
47.9
0
477,250
Motor Vehicles
California Reform
3,349.5
1,926.2
10,913,16
2
20,164,186
Motor Vehicles
Enhanced l/M
6,470.9
5,505.6
844,761
1,689,523
Motor Vehicles
California LEV
2,709.4
4,900.3
3,839,138
3,839,138
Motor Vehicles
Reform Diesel
0.0
276.1
0
3,995,044
Total
13,779.3
29,446.9
15,597,06
1
109,374,339
Open Burning
Episodic Ban
629.4
119.6
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
763.6
0.0
14,049,87
2
0
Point Source Metal Surface Coating
FIP VOC Limits
75.6
0.0
0
0
Point Sources
RE Improvements
25,595.7
0.0
51,191,25
o
0
Metal product surface coating
VOC content limits & improved
240.3
0.0
25,473
0
Wood product surface coating
Reformulation
ZO
0.0
124
0
Wood furniture surface coating
Reformulation
114.8
0.0
112,992
0
Paper surface coating
Add-on control levels
14.4
0.0
957,544
0
Miscellaneous surface coating
Add-on control levels
210.4
0.0
10,611,78
7
0
Automobile refinishing
FIP Rule (VOC Content & TE)
256.1
0.0
3,851,060
0
Aerosols
SCAQMD Standards
279.4
0.0
1,745,730
0
Reformulati
Aircraft surface coating
Add-on control levels
1.5
0.0
43,595
0
marine surface coating
Add-on control levels
9.6
0.0
138,035
0
Service stations - stage l-truck un
Vapor balance & P-V valves
458.1
0.0
11,505
0
Pesticide Application
Reformulation - FIP rule
164.7
0.0
1,532,139
0
Recreational vehicles
CARB standards
121.5
0.0
64,362
0
Motor Vehicles
California Reform
3,072.7
2,166.9
19,793,43
18,561,178
Motor Vehicles
Enhanced l/M
765.1
658.5
259,659
519,317
Motor Vehicles
California LEV
2,674.0
4,960.3
3,522,006
3,522,006
Richmond, VA
Rochester, NY
B-86
-------
Table B-8 (continued)
Reductions
(tons per year)
Costs
(1990$)
Nonattainment
Area Source Category
Control Measure
VOC
NOx
vex:
NOx
Total
35.448.9
7,905.3
107,910,5
65
Adhesives - industrial
RACT
34.5
0.0
86,360
Aerosols
CARB Tier 2 Standards -
201.3
0.0
503,034
Reform
Aerosols
SCAQMD Standards -
201.2
0.0
2,012,136
Reformulate
Automobile refinishing
CARB BARCT limits
127.1
0.0
467,563
Automobile refinishing
FIP Rule (VOC Content & TE)
485.3
0.0
8,746,744
Bulk Terminals
RACT
12.8
0.0
21,347
Cutback Asphalt
Switch to emulsified asphalts
72.2
0.0
0
marine surface coating
Add-on control levels
4.2
0.0
60,687
Metal product surface coating
VOC content limits & improved
236.7
0.0
5,867
Miscellaneous surface coating
Add-on control levels
119.5
0.0
1,938,485
Miscellaneous surface coating
MACT level of control
105.2
0.0
262,951
Motor Vehicles
Enhanced l/M
828.8
1,377.3
326,808
Nonroad gasoline
Reformulated gasoline
106.5
0.0
532,500
Open Burning
Episodic Ban
444.0
84.0
0
Paper surface coating
Add-on control levels
3.1
0.0
206,239
Pesticide Application
Reformulation - FIP rule
114.2
0.0
1,062,488
Point Source Ind. Surface Coating
Add-on Control Levels
361.7
0.0
6,655,556
Point Source Metal Surface Coating
FIP VOC Limits
313.9
0.0
0
Point Sources
RE Improvements
40.5
0.0
81,030
Recreational vehicles
CARB standards
102.4
0.0
54,329
Service stations - stage I-truck un
Vapor balance & P-V valves
799.0
0.0
130,285
Web Offset Lithography
New CTG (carbon adsorber)
6.6
0.0
-825
Wood furniture surface coating
Reformulate on
252.5
0.0
94,698
Wood product surface coating
Reformulation
16.0
0.0
399
Total
4.989.2
1,461.3
23,248,68
1
Open Burning
Episodic Ban
1,840.5
348.9
0
Point Source Ind. Surface Coating
Add-on Control Levels
7,257.0
0.0
133,527,5
12
Point Source Metal Surface Coating
FIP VOC Limits
874.2
0.0
0
Point Sources
RE Improvements
3,298.8
0.0
6,597,740
Bulk Terminals
RACT
80.7
0.0
134,334
Metal product surface coating
VOC content limits & improved
848.6
0.0
36,276
Wood product surface coating
Reformulation
7.4
0.0
181
Wood furniture surface coating
Reformulation
575.3
0.0
572,466
Adhesives - industrial
RACT
75.5
0.0
188,420
Paper surface coating
Add-on control levels
40.0
0.0
2,956,315
Miscellaneous surface coating
Add-on control levels
393.3
0.0
18,678,83
5
Automobile refinishing
FIP Rule (VOC Content & TE)
914.9
0.0
13,762,35
9
Miscellaneous surface coating
MACT level of control
180.9
0.0
452,528
Aerosols
SCAQMD Standards -
770.9
0.0
4,818,120
Reformulate
Aircraft surface coating
Add-on control levels
120.4
0.0
3,790,114
marine surface coating
Add-on control levels
17.6
0.0
255,434
Cutback Asphalt
Switch to emulsified asphalts
189.5
0.0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
14.6
0.0
5,812
Service stations - stage 1-truck un
Vapor balance & P-V valves
1,430.7
0.0
160,749
Web Offset Lithography
New CTG (carbon adsorber)
13.2
0.0
-1,647
Sacramento, CA
St. Louis, MO
0
0
0
0
0
0
0
0
653,615
0
0
0
0
0
0
0
0
0
0
0
0
653.615
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
B-87
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Pesticide Application
Reformulation - FIP rule
376.4
0.0
3,501,244
0
Recreational vehicles
CARB standards
273.5
0.0
144,727
0
Motor Vehicles
California Reform
15,021.2
6,273.9
52,150,49
7
49,212,883
Motor Vehicles
Enhanced l/M
16,476.5
13,312.3
1,339,931
2,679,863
Motor Vehicles
California LEV
6,609.0
11,949.2
9,385,105
9,385,105
Total
57,700.6
31,884.3
252,457,0
52
61,277,850
Aerosols
CARB Tier 2 Standards -
0.0
0.0
0
0
Reform
Aerosols
SCAQMD Standards -
0.0
0.0
0
0
Reformulate
Automobile refinishing
CARB BARCT limits
0.0
0.0
0
0
Automobile refinishing
FIP Rule (VOC Content & TE)
0.0
0.0
0
0
Metal product surface coating
VOC content limits & improved
0.0
0.0
0
0
Miscellaneous surface coating
Add-on control levels
0.0
0.0
0
0
Miscellaneous surface coating
MACT level of control
0.0
0.0
0
0
Nonroad gasoline
Reformulated gasoline
0.0
0.0
0
0
Open Burning
Episodic Ban
0.0
0.0
0
0
Paper surface coating
Add-on control levels
0.0
0.0
0
0
Pesticide Application
Reformulation - FIP rule
0.0
0.0
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
0.0
0.0
0
0
Point Sources
RE Improvements
0.0
0.0
0
0
Recreational vehicles
CARB standards
0.0
0.0
0
0
Service stations - stage l-truck un
Vapor balance & P-V valves
0.0
0.0
0
0
Wood furniture surface coating
Reformulation
0.0
0.0
0
0
Wood product surface coating
Reformulation
0.0
0.0
0
0
Total
0.0
0.0
0
0
Aerosols
CARB Tier 2 Standards -
50.1
0.0
125,256
0
Reform
Aerosols
SCAQMO Standards -
50.1
0.0
501,024
0
Reformulati
Aircraft surface coating
Add-on control levels
10.5
0.0
330,223
0
Automobile refinishing
CARB BARCT limits
25.1
0.0
92,413
0
Automobile refinishing
FIP Rule (VOC Content & TE)
95.9
0.0
1,728,785
0
Metal product surface coating
VOC content limits & improved
44.0
0.0
1,098
0
Miscellaneous surface coating
Add-on control levels
18.2
0.0
303,110
0
Miscellaneous surface coating
MACT level of control
45.7
0.0
114,149
0
Motor Vehicles
Enhanced l/M
1,827.6
2,680.2
106,112
212,224
Nonroad gasoline
Reformulated gasoline
26.0
0.0
130,000
0
Open Burning
Episodic Ban
134.4
25.5
0
0
Paper surface coating
Add-on control levels
1.3
0.0
84,224
0
Pesticide Application
Reformulation - FIP rule
34.8
0.0
323,156
0
Point Sources
RE Improvements
91.6
0.0
183,230
0
Recreational vehicles
CARB standards
5.8
0.0
3,072
0
Service stations - stage l-truck un
Vapor balance & P-V valves
196.0
0.0
4,901
0
Wood furniture surface coating
Reformulation
52.3
0.0
19,616
0
Wood product surface coating
Reformulation
1.6
0.0
40
0
Total
2,711.0
2,705.7
4,050,409
212,224
Adhesives - industrial
RACT
105.8
0.0
264,172
0
Aerosols
CARB Tier 2 Standards
467.2
0.0
1,167,756
0
Reform
Aerosols
SCAQMD Standards
467.0
0.0
4,671,024
0
Seattle, WA
B-88
-------
Table B-8 (continued)
Reductions
Costs
(1990$)
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Automobile refinfshing
CARB BARCT limits
250.9
0.0
922,119
0
Bulk Terminals
RACT
248.4
0.0
413,881
0
Cutback Asphalt
Switch to emulsified asphalts
454.5
0.0
0
0
Metal product surface coating
VOC content limits & improved
578.7
0.0
14,445
0
Miscellaneous surface coating
MACT level of control
240.4
0.0
601,215
0
Motor Vehicles
California LEV
8,992.7
15,879.0
12,434,79
7
12,434,797
Motor Vehicles
California Reform
1,615.1
4,241.6
1
0
65,175,421
Motor Vehicles
Enhanced l/M
4,292.7
3,491.0
1,372,151
2,744,303
Motor Vehicles
Federal Reform
11,865.0
3,331.6
67,981,64
5
0
Nonroad gasoline
Reformulated gasoline
292.5
0.0
1,462,500
0
Open Burning
Episodic Ban
1,232.7
233.9
0
0
Pesticide Application
Reformulation - FIP rule
71.3
0.0
662,233
0
Point Source Metal Surface Coating
FIP VOC Limits
8.8
0.0
0
0
Point Source Wood Product
FIP VOC Limits
93.1
0.0
2,327
0
Coating
Recreational vehicles
CARB standards
628.9
0.0
333,244
0
Service stations - stage l-truck un
Vapor balance & P-V valves
2,104.6
0.0
699,089
0
Web Offset Lithography
New CTG (carbon adsorber)
532.5
0.0
-66,548
0
Wood furniture surface coating
Reformulation
989.4
0.0
371,013
0
Wood product surface coating
Reformulation
22.6
0.0
1,182
0
Total
35,554.8
27,177.1
93,308.24
5
80,354,520
Open Burning
Episodic Ban
145.0
27.5
0
0
Bulk Terminals
RACT
214.3
0.0
356,978
0
Metal product surface coating
VOC content limits & improved
34.5
0.0
859
0
Wood furniture surface coating
Reformulation
26.7
0.0
9,996
0
Cutback Asphalt
Switch to emulsified asphalts
122.5
0.0
0
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
5.5
0.0
2,184
0
Service stations - stage l-truck un
Vapor balance & P-V valves
209.1
0.0
156,635
0
Web Offset Lithography
New CTG (carbon adsorber)
12.4
0.0
-1,559
0
Recreational vehicles
CARB standards
22.4
0.0
11,814
0
Motor Vehicles
Enhanced l/M
1,051.8
856.8
339,174
678,347
Total
1,844.2
884.3
876,081
678,347
Open Burning
Episodic Ban
504.4
95.6
0
0
Point Source Metal Surface Coating
FIP VOC Limits
11.3
0.0
0
0
Point Sources
RE Improvements
83.6
0.0
167,170
0
Metal product surface coating
VOC content limits & improved
78.1
0.0
3,590
0
Wood product surface coating
Reformulation
2.4
0.0
157
0
Wood furniture surface coating
Reformulation
3.8
0.0
5,420
0
Adhesives - industrial
RACT
65.3
0.0
163,220
0
Automobile refinishing
CARB BARCT limits
21.3
0.0
77,831
0
Miscellaneous surface coating
MACT level of control
29.1
0.0
72,735
0
Aerosols
CARB Tier 2 Standards -
71.5
0.0
178,740
0
Reform
Cutback Asphalt
Switch to emulsified asphalts
372.2
0.0
0
0
Pharmaceutical manufacture
RACT
40.4
0.0
13,542
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
355.7
0.0
141,071
0
Service stations - stage l-truck un
Vapor balance & P-V valves
218.6
0.0
5,470
0
Web Offset Lithography
New CTG (carbon adsorber)
43.6
0.0
-5,439
0
Recreational vehicles
CARB standards
218.5
0.0
115,850
0
Motor Vehicles
Federal Reform
3,423.2
502.6
8,125,082
0
Sherman, TX
Shreveport, LA
B-89
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
(tons per year)
(1990S)
>
Source Category
Control Measure
VOC
NOx
VOC
NOx
Motor Vehicles
Enhanced l/M
2,844.1
2,159.7
886,918
1,773,836
Total
8,387.1
2,757.9
9,951,357
1,773,836
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
256.4
0
6,961,478
Industrial Boiler - PC
SCR
0.0
44.3
0
948,195
Industrial Boiler - Stoker
SCR
0.0
108.2
0
1,127,084
Industrial Boiler - Residual Oil
SCR
0.0
141.9
0
976,271
Industrial Boiler - Natural Gas
SCR
0.0
159.9
0
1,342,660
IC Engines - Natural Gas
NSCR
0.0
58.5
0
179,810
Gas Turbines - Natural Gas
SCR + STEAM INJECTION
0.0
106.6
0
511,328
Gas Turbines-Oil
SCR + WATER INJECTION
0.0
146.7
0
731,902
Residential NG Consumption
LNB Space heaters
0.0
531.5
0
653,642
Open Burning
Episodic Ban
2,129.9
404.0
0
0
Nonroad Diesels
CARB Stdsfor> 175 HP
0.0
33.8
0
275,292
Commercial Marine Vessels
Emission Fees
0.0
252.3
0
2,523,158
Motor Vehicles
California Reform
398.0
672.7
467,000
10,679,254
Motor Vehicles
California LEV
1,714.3
2,857.2
2,038,322
2,038,322
Motor Vehicles
Reform Diesel
0.0
134.5
0
1,911,328
Total
4,242.2
5,908.5
2,505,322
30,859,724
Open Burning
Episodic Ban
503.9
95.5
0
0
Point Sources
RE Improvements
15.3
0.0
30,660
0
Metal product surface coating
VOC content limits & improved
37.4
0.0
937
0
Wood furniture surface coating
Reformulation
28.8
0.0
29,558
0
Automobile refinishing
CARB BARCT limits
4.6
0.0
16,614
0
Aerosols
CARB Tier 2 Standards -
Reform
34.2
0.0
85,344
0
Service stations - stage l-tnick un
Vapor balance & P-V valves
98.7
0.0
2,467
0
Recreational vehicles
CARB standards
27.7
0.0
14,690
0
Motor Vehicles
Federal Reform
857.8
237.2
4,280,050
0
Motor Vehicles
Enhanced l/M
750.9
651.4
253,802
507,603
Total
2,359.3
984.1
4,714,122
507,603
Aerosols
CARB Tier 2 Standards
Reform
63.9
0.0
159,828
0
Aerosols
SCAQMD Standards
Reformulati
63.9
0.0
639,312
0
Automobile refinishing
CARB BARCT limits
30.9
0.0
113,829
0
Automobile refinishing
FIP Rule (VOC Content & TE)
118.2
0.0
2,129,416
0
marine surface coating
Add-on control levels
2.6
0.0
37,680
0
Metal product surface coating
VOC content limits & improved
315.6
0.0
7,806
0
Miscellaneous surface coating
Add-on control levels
86.9
0.0
1,429,779
0
Miscellaneous surface coating
MACT level of control
38.0
0.0
94,975
0
Nonroad gasoline
Reformulated gasoline
32.9
0.0
164,500
0
Open Burning
Episodic Ban
146.1
27.8
0
0
Paper surface coating
Add-on control levels
5.3
0.0
358,421
0
Pesticide Application
Reformulation - FIP rule
162.5
0.0
1,510,952
0
Point Source Wood Product
FIP VOC Limits
138.0
0.0
3,449
0
Coating
Recreational vehicles
CARB standards
31.5
0.0
16,720
0
Service stations - stage l-truck un
Vapor balance & P-V valves
184.4
0.0
4,610
0
Wood furniture surface coating
Reformulation
214.0
0.0
80,240
0
Total
1,634.7
27.8
6,751,517
0
Open Burning
Episodic Ban
537.5
101.6
0
0
Point Sources
RE Improvements
1,413.6
0.0
2,827,290
0
Bulk Terminals
RACT
198.9
0.0
331,281
0
Springfield, MA
State College, PA
Stockton, CA
Tulsa, OK
B-90
-------
Table B-8 (continued)
Reductions
Costs
Nonattainment
Area
Source Category
Control Measure
VOC
NOx
VOC
NOx
Metal product surface coating
VOC content limits & improved
220.5
0.0
5,451
0
Wood product surface coating
Reformulation
3.9
0.0
97
0
Wood furniture surface coating
Reformulation
278.4
0.0
104,400
0
Adhesives - industrial
RACT
785.4
0.0
1,963,118
0
Automobile refinishing
CARB BARCT limits
51.7
0.0
190,487
0
Miscellaneous surface coating
MACT level of control
240.3
0.0
600,760
0
Aerosols
CARB Tier 2 Standards -
Reform
137.3
0.0
343,158
0
SOCMI batch reactor processes
New CTG
25.8
0.0
104,520
0
Cutback Asphalt
Switch to emulsified asphalts
771.7
0.0
0
0
SOCMI fugitives
RACT
11.9
0.0
1,625
0
Petroleum refinery fugitives
RACT
104.1
0.0
-46,863
0
Oil and natural gas production fiel
RACT (equipment/maintenance)
937.6
0.0
371,851
0
Service stations - stage l-truck un
Vapor balance & P-V valves
873.8
0.0
445,291
0
Web Offset Lithography
New CTG (carbon adsorber)
154.5
0.0
-19,309
0
Recreational vehicles
CARB standards
114.7
0.0
60,729
0
Nonroad gasoline
Reformulated gasoline
70.0
0.0
350,000
0
Motor Vehicles
Enhanced l/M
6,821.7
5,222.1
571,779
1,143,558
Total
13,753.3
5,323.7
8,205,665
1,143,558
Visalia, CA
Aerosols
CARB Tier 2 Standards
Reform
42.6
0.0
106,380
0
Aerosols
SCAQMD Standards
Reformulati
42.6
0.0
425,520
0
Automobile refinishing
CARB BARCT limits
11.2
0.0
41,327
0
Automobile refinishing
FIP Rule (VOC Content & TE)
42.9
0.0
773,106
0
Metal product surface coating
VOC content limits & improved
49.9
0.0
1,238
0
Miscellaneous surface coating
Add-on control levels
22.0
0.0
333,737
0
Miscellaneous surface coating
MACT level of control
19.7
0.0
49,270
0
Nonroad gasoline
Reformulated gasoline
23.1
0.0
115,500
0
Open Burning
Episodic Ban
93.7
17.7
0
0
Pesticide Application
Reformulation - FIP rule
250.4
0.0
2,329,073
0
Recreational vehicles
CARB standards
22.4
0.0
11,867
0
Service stations - stage l-truck un
Vapor balance & P-V valves
110.8
0.0
2,770
0
Wood furniture surface coating
Reformulation
8.2
0.0
3,088
0
Wood product surface coating
Reformulation
2.7
0.0
67
0
Total
742.2
17.7
4,192,943
0
Washington, DC
Utility Boiler - PC/Wall
SCR
0.0
28,076.6
0
86,025,342
Utility Boiler - PC/Tangential
SCR
0.0
25,456.0
0
101,567,747
Utility Boiler - Oil-Gas/Wall
SCR
0.0
5,738.6
0
52,216,489
Utility Boiler - Oil-Gas/Tangential
SCR
0.0
3,364.4
0
41,194,478
Utility Boiler - Cyclone
SCR
0.0
3,413.4
0
37,657,192
Industrial Boiler - PC
SCR
0.0
3,950.8
0
31,280,313
Industrial Boiler • Stoker
SCR
0.0
118.1
0
1,230,065
Industrial Boiler - Residual Oil
SCR
0.0
732.0
0
4,802,598
Industrial Boiler - Distillate Oil
SCR
0.0
107.4
0
1,126,767
Industrial Boiler - Natural Gas
SCR
0.0
938.5
0
7,879,698
IC Engines - Oil
SCR
0.0
362.2
0
1,968,033
Gas Turbines - Oil
SCR ~ WATER INJECTION
0.0
49.0
0
2,761,373
Process Heaters - Natural Gas
LNB + SCR
0.0
6.3
0
183,156
Area Source Industrial Coal Comb
RACT to small sources
0.0
29.9
0
118,821
Area Source Industrial Oil Comb
RACT to small sources
0.0
64.9
0
115,430
Area Source Industrial NG Comb
RACT to small sources
0.0
91.4
0
120,733
Residential NG Consumption
LNB Space heaters
0.0
2,652.8
0
3,262,702
B-91
-------
Table B-8 (continued)
Reductions Costs
(tons per year) (1990S)
Nonattainment
Area Source Category Control Measure VOC NOx VOC NOx
Open Burning
Episodic Ban
1,410.2
268.2
0
0
Nonroad Diesels
CARB Stds for > 175 HP
0.0
504.6
0
4,116,305
Commercial Marine Vessels
Emission Fees
0.0
642.8
0
6,426,113
Industrial Boiler - Other
SCR
0.0
15.8
0
169,106
Glass Manufacturing - Container
Oxy-Firing
0.0
59.9
0
396,919
Cement Manufacturing - Dry
SCR
0.0
2,187.8
0
11,048,592
Cement Manufacturing - Wet
SCR
0.0
808.4
0
3,405,438
Iron & Steel Mills - Reheating
LNB + FGR
0.0
444.8
0
233,562
Iron & Steel Mills - Annealing
LNB + SCR
0.0
70.3
0
360,338
Municipal Waste Combustors
SNCR
0.0
140.2
0
467,984
Point Source Ind. Surface Coating
Add-on Control Levels
353.0
0.0
6,494,372
0
Point Source Metal Surface Coating
FIP VOC Limits
827.5
0.0
0
0
Point Source Wood Product
FIP VOC Limits
127.4
0.0
3,185
0
Coating
Point Sources
RE Improvements
5,634.0
0.0
11,268,28
o
0
Bulk Terminals
RACT
833.1
0.0
1,388,281
0
Metal product surface coating
VOC content limits & improved
723.2
0.0
30,335
0
Wood product surface coating
Reformulation
27.6
0.0
828
0
Wood furniture surface coating
Reformulation
1,304.8
0.0
534,243
0
Adhesives - industrial
RACT
183.2
0.0
458,274
0
Paper surface coating
Add-on control levels
91.5
0.0
3,946,687
0
Miscellaneous surface coating
Add-on control levels
491.0
0.0
10,149,67
4
0
Automobile refinishing
FIP Rule (VOC Content & TE)
2,374.9
0.0
35,730,47
2
0
Miscellaneous surface coating
MACT level of control
139.0
0.0
347,320
0
Aerosols
SCAQMD Standards -
1,976.7
0.0
12,350,94
0
Reformulate
0
Aircraft surface coating
Add-on control levels
21.9
0.0
787,137
0
marine surface coating
Add-on control levels
106.1
0.0
1,532,530
0
Cutback Asphalt
Switch to emulsified asphalts
244.6
0.0
0
0
Synthetic fiber manufacture
RACT (adsorber)
1,408.2
0.0
1,991,973
0
Service stations - stage l-truck un
Vapor balance & P-V valves
3,815.4
0.0
622,837
0
Web Offset Lithography
New CTG (carbon adsorber)
38.6
0.0
-4,832
0
Pesticide Application
Reformulation - FIP rule
356.5
0.0
3,314,467
0
Recreational vehicles
CARB standards
874.2
0.0
463,181
0
Motor Vehicles
Federal Reform
4,402.6
902.9
17,493,10
2
0
Motor Vehicles
Enhanced l/M
4,267.8
4,103.5
1,581,906
3,163,811
Motor Vehicles
California LEV
16,299.5
30,122.4
23,627,28
5
23,627,285
Motor Vehicles
Reform Diesel
0.0
1,607.5
0
23,591,507
Total
48,332.5117,031.4
134,112,4450,517,897
77
Open Burning
Episodic Ban
482.7
91.6
0
0
Point Source Ind. Surface Coating
Add-on Control Levels
4.4
0.0
80,592
0
Point Source Metal Surface Coating
FIP VOC Limits
17.2
0.0
0
0
Point Source Wood Product
FIP VOC Limits
146.7
0.0
3,668
0
Coating
Metal product surface coating
VOC content limits & improved
88.2
0.0
2,202
0
Wood furniture surface coating
Reformulation
173.5
0.0
178,051
0
Paper surface coating
Add-on control levels
19.1
0.0
1,278,337
0
Miscellaneous surface coating
Add-on control levels
79.9
0.0
3,823,188
0
B-92
-------
Table B-8 (continued)
Reductions Costs
(tons per year) (1990$)
Nonattainment
Area Source Category
Control Measure
VOC
NOx VOC
NOx
Automobile refinishing
FIP Rule (VOC Content & TE)
94.2
0.0 1,417,266
0
Aerosols
SCAQMD Standards -
95.0
0.0 593,850
0
Reformulat
Service stations - stage I-truck un
Vapor balance & P-V valves
108.5
0.0 2,714
0
Pesticide Application
Reformulation - FIP rule
31.7
0.0 294,866
0
Recreational vehicles
CARB standards
40.1
0.0 21,282
0
Motor Vehicles
California Reform
192.6
421.3 130,500
6,049,430
Motor Vehicles
California LEV
761.5
1,490.6 1,144,472
1,144,472
Total
2,335.3
2,003.5 8,970,988
7,193,902
B-93
-------
APPENDIX C
CONTROL MEASURE AND SIC CODE SUPPORTING DATA
-------
Table C-1.Summary of Incremental Control Measures and Potentially Affected Source
Categories for the Ozone NAAQS Review
Source Category
Control Measure
Stationary Point Sources
VOC Emissions
Automob3e and Light-Dirty Truck Surface Coating (Industrial Surface
Coating)
Plastic Parts Surface Coating {Industrial Surface Coating)
Flatwood Products Surface Coating (Wood Products Surface Coating)
Wood Furniture Surface Coating (Wood Products Surface Coating)
General/Unspecified Surface Coating Operations (Industrial Surface
Coating)
General/Unspecified Surface Coating Operations (Wood Products Surface CA FIP VOC limits
Coating)
Add-on Control Levels
Add-on Control Levels
California (CA) ozone Federal Implementation Plan
(FIP) VOC limits
CA FIP VOC limits
Add-on Control Levels
Metal Product Surface Coating
Rule Effectiveness Improvements
Indneraton/Open Burning
NO* Emissions
Utility Boilers: Oil-Gas Tangentially Fired
Industrial Boilers: Pulverized Coal
Industrial Boilers. Stoker (Coal)
Industrial Boilers: Residual Oil
Industrial Boilers: Distillate Oil
Industrial Boilers: Natural Gas
Cement Manufacturing: Dry Kiln
Glass Manufacturing: Container Glass
Gas Turbines Natural Gas
Gas Turbines: Oil
Reciprocating internal Combustion Engines: Natural Gas
Process Heaters: Natural Gas
Process Heaters: Distillate Oil
Municipal Waste Incinerators
Incineration/Open Burning
FIP VOC limits
Increase Compliance with Regulations
Episodic Ban
Selective Catalytic Reduction (SCR)
SCR
SCR
SCR
SCR
SCR
SCR
Oxy-Firing
SCR +¦ Steam Injection
SCR +• Water Injection
Nonselective Catalytic Reduction (NSCR)
Low-NOx Burners (LNB) + SCR
LNB ¦+ SCR
Selective Noncatalytic Reduction (SNCR)
Episodic Ban
Stationary Area Sources
VOC Emissions
Gasoline Service Stations: Underground Storage Tanks and Stage I -
Truck Unloading
Bulk Terminals
Adhesives: Industrial
Aircraft Surface Coating (Industrial)
Autobody Refinishing
Autobody Refinishing
Paper Surface Coating (Industrial)
Flatwood Product Surface Coating
Wood Furniture Surface Coating
Install Pressure Vacuum (PV) Valves on Vent Line -
Vapor Balance [Clean Air Act (CAA) Base Case
Extended to Other Areas]
Reasonably Available Control Technology (RACT):
CAA Base Case Extended to Other Areas
RACT: CAA Base Case Extended to Other Areas
Add-on Control Levels
CA Best Available Retrofit Control Technology
(BARCT)
CA FIP Limits
Add-on Control Levels
Reformulation
Reformulation
C-1
-------
Table C-1 (continued)
Source Category
Stationary Area Sources (cont'd) "
VOC Emissions
Marine Surface Coating
Metal Product Surface Coating
Miscellaneous Surface Coating
Miscellaneous Surface Coating
Pharmaceutical Manufacturing
Cutback Asphalt
Synthetic Organic Chemical Manufacturing Industry (SOCMI)
Batch Reactor Processes
SOCMI Fugitive Emission Leaks
Petroleum Refinery Fugitive Emission Leaks
Oil and Natural Gas Production Fields
Aerosol Paints
Aerosol Paints
Pesticides
NOx Emissions
Industrial Coal Combustion
Industrial Oil Combustion
Industrial Natural Gas Combustion
Residential Water Heaters
Residential Space Heaters
Open Burning
Control Measure
Add-on Control Levels
VOC Content Limits and Improved Transfer Efficiency
Add-on Control Levels
Default Maximum Control Technology (MACT)
Surface Coating Limits
RACT: CAA Base Case Extended to Other Areas
RACT (Switch to Emulsified Asphalt): CAA Base
Case Extended to Other Areas
RACT: CAA Base Case Extended to Other Areas
New Control Techniques Guideline (CTG) Document
RACT: CAA Base Case Extended to Other Areas
RACT (Equipment/Maintenance): CAA Base Case
Extended to Other Areas
California Tier 2 Standards
South Coast Air Quality Management District
(SCAQMD) Potential Standards
Reformulate Coatings to Lower VOC Content (Based
on California Ozone FIP Rule)
RACT to Small Sources
RACT to Small Sources
RACT to Small Sources
LNB
LNB
Episodic Ban
On-Hlghway Motor Vehicles
VOC and NOx Emissions
Light-Duty Gasoline Vehicles and Trucks
Light-Duty Gasoline Vehicles and Trucks
Light-Duty Gasoline Vehicles and Trucks
Light-Duty Gasoline Vehicles and Trucks
Light-, Medium-, and Heavy-Duty Vehicles and Trucks
California Low Emitting Vehicle (LEV) Program
Enhanced Inspection and Maintenance Program
Federal Reformulated Gasoline Program
California Reformulated Gasoline Program
California Reformulated Diesel Program
Nonroad Vehicles
VOC and NOx Emissions
2- and 4-Stroke Nonroad Engine Categories VOC Benefits Associated with Phase I Reformulated
Airport Service Equipment Gasoline Program for On-Highway Vehicles
Recreational Equipment
Industrial Equipment
Logging Equipment (chain saws and shredders)
Light Commercial/Utility Equipment
(generator sets, pumps, air compressors, welders, and pressure
washers)
Construction Equipment (tampers/rammers, plate compactors, rollers,
paving equipment, surfacing equipment, signal boards, concrete/
industrial saws, cement and mortar mixers, and dumpers/tenders)
Farm Equipment (2-wheel tractors, agricultural mowers, sprayers, tillers,
and hydro-power units)
Lawn and Garden Equipment (lawn mowers, tillers,
trimmers/edgers/brush
cutters, leaf blowers/vacuums, snowblowers, rear engine riding
mowers, front mowers, shredders, lawn and garden tractors, wood
splitters, chippers/stump grinders, and commercial turf equipment)
C-2
-------
Table C-1 (continued)
Source Category
Control Measure
Nonroad Vehicles (cont'd)
VOC and NOx Emissions
2175 Horsepower Compression Ignition (Diesel) Engines
Construction Equipment (scrapers, bore/drill rigs, excavators,
cranes, off-highway trucks, rubber tired dozers, and
off-highway tractors)
Logging Equipment (fellers/bunchers)
California Phase II Exhaust Standards
Commercial Marine Vessels
Emission fees
Recreational Vehicles
2-stroke engine category
4-stroke engine category
Potential California Standards
Potential California Standards
C-3
-------
Table C-2.SIC Codes and Sectors Affected by the Control Measures for VOC Sources
in the Stationary Point Source Inventory
Source Category/SIC Code
SIC Description
Sector
Automobile and Light-Duty Truck Surface Coating (Industrial Surface Coating)
371
Motor Vehicles and Equipment
Manufacturing
Plastic Parts Surface Coating (Industrial Surface Coating)
308
Miscellaneous Plastics Products, nec
Manufacturing
Wood Furniture Surface Coating (Wood Product Coating)
251
Household Furniture
Manufacturing
Flatwood Surface Coating (Wood Product Coating)
242
Sawmills and Planing Mills
Manufacturing
243
Millwork, Plywood and Structural Members
Manufacturing
249
Miscellaneous Wood Products
Manufacturing
Surface Coating - General/Unspecified
011
Cash Grains
Agriculture, Forestry, Fishing
203
Preserved Fruits and Vegetables
Manufacturing
243
Millwork, Plywood and Structural Members
Manufacturing
251
Household Furniture
Manufacturing
252
Office Furniture
Manufacturing
291
Petroleum Refining
Manufacturing
295
Asphalt Paving and Roofing Materials
Manufacturing
308
Miscellaneous Plastics Products, nec
Manufacturing
331
Blast Furnace and Basic Steel Products
Manufacturing
332
Iron and Steel Foundries
Manufacturing
339
Miscellaneous Primary Metal Products
Manufacturing
340
Fabricated Metal Products
Manufacturing
341
Metal Cans and Shipping Containers
Manufacturing
342
Cutlery, Handtools, and Hardware
Manufacturing
344
Fabricated Structural Metal Products
Manufacturing
346
Metal Forgings and Stampings
Manufacturing
347
Metal Services, nec
Manufacturing
348
Ordnance and Accessories, nec
Manufacturing
349
Miscellaneous Fabricated Metal Products
Manufacturing
353
Construction and Related Machinery
Manufacturing
358
Refrigeration and Service Machinery
Manufacturing
362
Electrical Industrial Apparatus
Manufacturing
363
Household Appliances
Manufacturing
364
Electric Ughting and Wiring Equipment
Manufacturing
366
Communications Equipment
Manufacturing
367
Electronic Components and Accessories
Manufacturing
370
Transportation Equipment
Manufacturing
371
Motor Vehicles and Equipment
Manufacturing
372
Aircraft and Parts
Manufacturing
373
Ship and Boat Building and Repairing
Manufacturing
376
Guided Missiles, Space Vehicles, Parts
Manufacturing
399
Miscellaneous Manufactures
Manufacturing
458
Airports, Flying Fields, and Services
Transportation and Public Utilities
971
National Security
Public Administration
Rule Effectiveness Improvements
131
Extraction-Crude Petroleum and Natural Gas
Mining
204
Grain Mill Products
Manufacturing
207
Fats and Oils
Manufacturing
226
Textile Finishing, Except Wool
Manufacturing
Rule Effectiveness Improvements (cont'd)
260
Paper and Allied Products
Manufacturing
262
Paper Mills
Manufacturing
263
Paperboard Mills
Manufacturing
265
Paperboard Containers and Boxes
Manufacturing
267
Miscellaneous Converted Paper Products
Manufacturing
C-4
-------
Table C-2 (continued)
Source Categoiy/SIC Code SIC Description Sector
272 Periodicals Manufacturing
275 Commercial Printing Manufacturing
281 Industrial Inorganic Chemicals Manufacturing
282 Plastics Materials and Synthetics Manufacturing
283 Drugs Manufacturing
286 Industrial Organic Chemicals Manufacturing
287 Agricultural Chemicals Manufacturing
291 Petroleum Refining Manufacturing
295 Asphalt Paving and Roofing Materials Manufacturing
299 Miscellaneous Petroleum and Coal Products Manufacturing
306 Fabricated Rubber Products, nec Manufacturing
308 Miscellaneous Plastics Products, nec Manufacturing
329 Miscellaneous Nonmettalic Mineral Products Manufacturing
331 Blast Furnace and Basic Steel Products Manufacturing
341 Metal Cans and Shipping Containers Manufacturing
342 Cutlery, Handtools, and Hardware Manufacturing
346 Metal Forgings and Stampings Manufacturing
347 Metal Services, nec Manufacturing
349 Miscellaneous Fabricated Metal Products Manufacturing
363 Household Appliances Manufacturing
371 Motor Vehicles and Equipment and Supplies Manufacturing
372 Aircraft and Parts Manufacturing
399 Manufacturing Industries, Miscellaneous Manufacturing
461 Pipelines, Except Natural Gas Transportation and Public Utilities
491 Electric Services Transportation and Public Utilities
493 Combination Utility Services Transportation and Public Utilities
495 Sanitary Services Transportation and Public Utilities
509 Miscellaneous Durable Goods Wholesale Trade
516 Chemicals and Allied Products Wholesale Trade
517 Petroleum and Petroleum Products Wholesale Trade
721 Laundry, Cleaning, and Garment Services Services
971 National Security Public Administration
C-5
-------
Table C-3.SIC Codes and Sectors Affected by Control Measures for NOx Sources in
the Stationary Point Source Inventory
Source Category/SIC Code
SIC Description
Sector
Utility Boilers
491
Electric Services
Transportation and Public Utilities
Industrial Boilers
201
Meat Products
Manufacturing
203
Preserved Fruits and Vegetables
Manufacturing
213
Chewing and Smoking Tobacco
Manufacturing
221
Broadwoven Fabric Mills, Cotton
Manufacturing
223
Broadwoven Fabric Mills, Wool
Manufacturing
22S
Textile Finishing, Except Wool
Manufacturing
229
Miscellaneous Textile Goods
Manufacturing
242
Sawmills and Planing Mills
Manufacturing
252
Office Furniture
Manufacturing
254
Partitions and Fixtures
Manufacturing
261
Pulp Mills
Manufacturing
262
Paper Mills
Manufacturing
263
Paperboard Mills
Manufacturing
267
Miscellaneous Converted Paper Products
Manufacturing
275
Commercial Printing
Manufacturing
281
Industrial Inorganic Chemicals
Manufacturing
282
Plastics Materials and Synthetics
Manufacturing
295
Asphalt Paving and Roofing Materials
Manufacturing
301
Tires and Inner Tubes
Manufacturing
311
Leather Tanning and Finishing
Manufacturing
322
Glass and Glassware, Pressed or Blown
Manufacturing
329
Miscellaneous Nonmettalic Mineral Products
Manufacturing
331
Blast Furnace and Basic Steel Products
Manufacturing
333
Primary Nonferrous Metals
Manufacturing
348
Ordnance and Accessories, nec
Manufacturing
362
Electrical Industrial Apparatus
Manufacturing
371
Motor Vehicles and Equipment
Manufacturing
372
Aircraft and Parts
Manufacturing
373
Ship and Boat Building and Repairing
Manufacturing
806
Hospitals
Services
822
Colleges and Universities
Services
971
National Security
Public Administration
Cement Manufacturing
324
Cement, Hydraulic
Manufacturing
Glass Manufacturing-Container
322
Glass -Pressed or Blown
Manufacturing
Gas Turbines
491
Electric Services
Transportation and Public Utilities
492
Gas Production and Distribution
Transportation and Public Utilities
509
Miscellaneous Durable Goods
Wholesale Trade
Reciprocating IC Engines
492
Gas Production and Distribution
Transportation and Public Utilities
Process Heaters
333
Primary Nonferrous Metals
Manufacturing
362
Electrical Industrial Apparatus
Manufacturing
363
Household Appliances
Manufacturing
371
Motor Vehicles and Equipment
Manufacturing
822
Colleges and Universities
Services
Municipal Waste Incinerators
495
Sanitary Services
Transportation and Public Utilities
C-6
-------
Table C-4.SIC Codes and Sectors Affected by Control Measures for NOx and VOC
Sources in the Stationary Area Source Inventory
Source Category
SIC
Code SIC Description
Sector
VOC Emissions
Gasoline Service Stations:
Underground Storage Tanks
Gasoline Service Stations: Stage I •
Truck Unloading
Bulk Terminals
Autobody Refinishing
Aircraft Surface Coating
Marine Surface Coating
Metal Product Surface Coating
554 Gasoline Service Stations
517 Petroleum and Petroleum Products
517 Petroleum and Petroleum Products
753 Automotive Repair Shops
372 Aircraft and Parts
373 Ship and Boat Building and Repairing
Retail Trade
Wholesale Trade
Wholesale Trade
Services
Manufacturing
Manufacturing
341
349
371
375
376
381
382
384
385
386
387
391
393
394
395
396
Metal Cans and Shipping Containers Manufacturing
Miscellaneous Fabricated Metal Products Manufacturing
Motor Vehicles and Equipment Manufacturing
Motorcycles, Bicycles, and Parts Manufacturing
Guided Missiles, Space Vehicles, Parts Manufacturing
Search, Detection, Navigation, Guidance, Manufacturing
Aeronautical, and Nautical Systems, Instruments,
and Equipment
Laboratory Apparatus and Analytical, Optical, Manufacturing
Measuring, and Controlling Instruments
Surgical, Medical, and Dental Instruments and Manufacturing
Supplies
Ophthalmic Goods Manufacturing
Photographic Equipment and Supplies Manufacturing
Watches, Clocks, Clockwork Operated Devices, and Manufacturing
Parts
Jewelry, Silveiware, and Plated War Manufacturing
Musical Instruments Manufacturing
Dolls, Toys, Games and Sporting and Athletic Goods Manufacturing
Pens, Pencils, and Other Artists' Materia Manufacturing
Costume Jewelry, Costume Novelties, Buttons, and Manufacturing
Miscellaneous Notions, Except Precious Metal
399
Miscellaneous Manufacturing Industries
Manufacturing
Paper Surface Coating
267
Converted Paper and Paperboard Products, Except
Containers and Boxes
Manufacturing
Wood Furniture Surface Coating
251
Household Furniture
Manufacturing
252
Office Furniture
Manufacturing
254
Partitions, Shelving, Lockers, and Office and Store
Fixtures
Manufacturing
Wood Product Surface Coating
242
Sawmills and Planing Mills
Manufacturing
243
Millwork, Veneer, Plywood, and Structural Wood
Members
Manufacturing
244
Wood Containers
Manufacturing
245
Wood Buildings and Mobile Homes
Manufacturing
249
Miscellaneous Wood Product
Manufacturing
Adhesives: Industrial
289
Miscellaneous Chemical Products
Manufacturing
C-7
-------
Table C-4 (continued)
SIC
Source Category
Code
SIC Description
Sector
VOC Emissions (cont'd)
Pharmaceutical Manufacturing
283
Drugs
Manufacturing
Miscellaneous Surface Coating
251
Household Furniture
Manufacturing
252
Office Furniture
Manufacturing
342
Cutlery, Handtools, and General Hardware
Manufacturing
343
Plumbing and Heating, Except Electric
Manufacturing
344
Fabricated Structural Metal Products
Manufacturing
345
Screw Machine Products, and Bolts, Nuts, Screws,
Manufacturing
Rivets, and Washers
346
Metal Forgings and Stampings
Manufacturing
347
Metal Services, nec
Manufacturing
348
Ordnance and Accessories, nec
Manufacturing
349
Miscellaneous Fabricated Metal Products
Manufacturing
351
Engines and Turbines
Manufacturing
352
Farm and Garden Machinery
Manufacturing
353
Construction and Related Machinery
Manufacturing
354
Metalworking Machinery and Equipment
Manufacturing
355
Special Industry Machinery
Manufacturing
356
General Industrial Machinery
Manufacturing
357
Computer and Office Equipment
Manufacturing
358
Refrigeration and Service Machinery
Manufacturing
359
Miscellaneous Industrial and Commercial Machinery
Manufacturing
and Equipment
361
Electric Distribution Equipment
Manufacturing
362
Electrical Industrial Apparatus
Manufacturing
363
Household Appliances
Manufacturing
364
Electric Lighting and Wiring Equipment
Manufacturing
365
Household Audio and Video Equipment, and Audio
Manufacturing
Recordings
366
Communications Equipment
Manufacturing
367
Electronic Components and Accessories
Manufacturing
369
Miscellaneous Electrical Machinery, Equipment, and
Manufacturing
Supplies
371
Motor Vehicles and Equipment
Manufacturing
374
Railroad Equipment
Manufacturing
Aerosol Paints
285
Paints, Varnishes, Lacquers, Enamels, and Allied
Manufacturing
Products
Pesticides
287
Pesticides and Agricultural Chemicals, n.e.c.
Manufacturing
Synthetic Organic Chemical
286
Industrial Organic Chemicals
Manufacturing
Manufacturing Industry (SOCMI) Batch
Reactor Processes
SOCMI Fugitive Emission Leaks
286
Industrial Organic Chemicals
Manufacturing
C-8
-------
Table C-4 (continued)
SIC
Source Category
Code
SIC Description
Sector
VOC Emissions (cont'd)
Petroleum Refinery Fugitive Emission
291
Petroleum Refining
Manufacturing
Leaks
295
Asphalt Paving and Roofing Materials
Manufacturing
299
Miscellaneous Petroleum and Coal Products
Manufacturing
Oil and Natural Gas Production Fields
131
Extraction-Crude Petroleum and Natural Gas
Mining
132
Extraction-Natural Gas Liquids
Mining
138
Oil and Gas Field Services
Mining
NOx Emissions
Residential Water Heaters
363
Household Appliances, Miscellaneous
Manufacturing
Residential Space Heaters
343
Heating Equipment, Except Electric and Warm Air
Manufacturing
Furnaces
C-9
-------
Table C-5.SIC Codes and Sectors Potentially Affected by NOx Control Measures for
industrial Fuel Combustion in the Stationary Area Source Inventory
Fuel Type
SIC Natural
Code
SIC Description
Sector
Coal
Oil
Gas
131
Extraction-Crude Petroleum and Natural Gas
Mining
~
144
Sand and Gravel
Mining
~
147
Chemical and Fertilizer Minerals
Mining
/
201
Meat Products
Manufacturing
~
~
/
202
Dairy Products
Manufacturing
~
~
203
Preserved Fruits and Vegetables
Manufacturing
~
~
~
204
Grain Mill Products
Manufacturing
~
/
/
205
Bakery Products
Manufacturing
S
/
206
Sugar and Confectionery Products
Manufacturing
~
/
/
207
Fats and Oils
Manufacturing
~
~
~
208
Beverages
Manufacturing
~
~
~
209
Miscellaneous Food and Kindred Products
Manufacturing
~
~
221
Broadwoven Fabric Mills, Cotton
Manufacturing
~
222
Broadwoven Fabric Mills, Manmade Fiber and Silk
Manufacturing
/
223
Broadwoven Fabric Mills, Wool
Manufacturing
/
/
224
Narrow Fabric Mills
Manufacturing
~
225
Knitting Mills
Manufacturing
~
226
Textile Finishing, Except Wool
Manufacturing
~
~
/
229
Miscellaneous Textile Goods
Manufacturing
~
~
~
233
Women's and Misses' Outerwear
Manufacturing
~
243
Millwork, Plywood, and Structural Members
Manufacturing
~
249
Miscellaneous Wood Products
Manufacturing
~
/
251
Household Furniture
Manufacturing
/
~
262
Paper Mills
Manufacturing
~
~
~
263
Paperboard Mills
Manufacturing
~
265
Paperboard Containers and Boxes
Manufacturing
~
~
267
Miscellaneous Converted Paper Products
Manufacturing
~
~
/
271
Newspapers
Manufacturing
~
275
Commercial Printing
Manufacturing
~
~
280
Chemicals and Allied Products
Manufacturing
~
281
Industrial Inorganic Chemicals
Manufacturing
~
~
/
282
Plastics Materials and Synthetics
Manufacturing
~
~
/
283
Drugs
Manufacturing
~
~
~
284
Soaps, Cleaners, and Toilet Goods
Manufacturing
~
~
~
285
Paints and Allied Products
Manufacturing
~
286
Industrial Organic Chemicals
Manufacturing
~
~
~
287
Agricultural Chemicals
Manufacturing
~
~
/
289
Miscellaneous Chemical Products
Manufacturing
~
~
~
291
Petroleum Refining
Manufacturing
~
295
Asphalt Paving and Roofing Materials
Manufacturing
~
/
299
Miscellaneous Petroleum and Coal Products
Manufacturing
~
301
Tires and Inner Tubes
Manufacturing
~
~
/
305
Gaskets, Packing, and Sealing Devices and Rubber
and Plastic Hose and Belting
Manufacturing
~
306
Fabricated Rubber Products, nec
Manufacturing
~
~
~
308
Miscellaneous Plastics Products, nec
Manufacturing
~
~
/
311
Leather Tanning and Finishing
Manufacturing
~
~
322
Glass -Pressed or Blown
Manufacturing
~
323
Products of Purchased Glass
Manufacturing
~
324
Cement, Hydraulic
Manufacturing
~
325
Structural Clay Products
Manufacturing
~
326
Pottery and Related Products
Manufacturing
~
~
327
Concrete, Gypsum, and Plaster Products
Manufacturing
/
~
329
Miscellaneous Nonmetallic Mineral Products
Manufacturing
~
~
331
Blast Furnace and Basic Steel Products
Manufacturing
~
~
~
C-10
-------
Table C-5 (continued)
Fuel Type
SIC
Code
SIC Description
Sector
Coal
Oil
Natural
Gas
332
Iron and Steel Foundries
Manufacturing
~
333
Primary Nonferrous Metals
Manufacturing
/
334
Secondary Nonferrous Metals
Manufacturing
~
~
S
335
Nonferrous Rolling and Drawing
Manufacturing
~
/
339
Miscellaneous Primary Metal Products
Manufacturing
~
S
341
Metal Cans and Shipping Containers
Manufacturing
/
342
Cutlery, Handtools, and Hardware
Manufacturing
~
343
Plumbing and Heating, Except Electric
Manufacturing
~
344
Fabricated Structural Metal Products
Manufacturing
~
~
346
Metal Forgings and Stampings
Manufacturing
~
/
348
Ordnance and Accessories, nec
Manufacturing
~
349
Miscellaneous Fabricated Metal Products
Manufacturing
~
351
Engines and Turbines
Manufacturing
~
~
352
Farm and Garden Machinery
Manufacturing
~
353
Construction and Related Machinery
Manufacturing
~
~
~
354
Metalworking Machinery
Manufacturing
~
356
General industrial Machinery
Manufacturing
~
357
Computer and Office Equipment
Manufacturing
~
~
358
Refrigeration and Service Machinery
Manufacturing
~
~
359
Miscellaneous Industrial and Commercial Machinery
Manufacturing
~
and Equipment
361
Electric Distribution Equipment
Manufacturing
~
~
362
Electrical Industrial Apparatus
Manufacturing
~
~
~
363
Household Appliances
Manufacturing
~
364
Electric Lighting and Wiring Equipment
Manufacturing
~
365
Household Audio and Video Equipment
Manufacturing
~
366
Communications Equipment
Manufacturing
/¦
367
Electronic Components and Accessories
Manufacturing
~
~
369
Miscellaneous Electrical Equipment and Supplies
Manufacturing
/
371
Motor Vehicles and Equipment
Manufacturing
~
~
~
372
Aircraft and Parts
Manufacturing
~
~
373
Ship arid Boat Building and Repairing
Manufacturing
~
374
Railroad Equipment
Manufacturing
~
376
Guided Missiles, Space Vehicles, Parts
Manufacturing
~
384
Medical Instruments and Supplies
Manufacturing
~
386
Photographic Equipment and Supplies
Manufacturing
/
~
391
Jewelry, Silverware, and Plated Ware
Manufacturing
~
~
393
Musical Instruments
Manufacturing
/
399
Manufacturing Industries, Miscellaneous
Manufacturing
~
C-ll
-------
Table C-6.SIC Codes and Sectors Affected by Control Measures for NOx and VOC
Sources in the On-Highway and Nonroad Mobile Source Inventory
Source Category/Control Measure
SIC
Code
SIC Description
Sector
On-Highway Motor Vehicles
Federal and California Reformulated Gasoline
Programs
291
Petroleum Refineries
Manufacturing
California Reformulated Diesel Fuel Program
291
Petroleum Refineries
Manufacturing
California Low Emission Vehicle Programs
371
551
Motor Vehicles and Equipment
New and Used Car Dealers
Manufacturing
Retail Trade
Enhanced l/M
554
753
Gasoline Service Stations
Households
Automotive Repair Shops
Retail Trade
Services
Nonroad Motor Vehicles
Federal Reformulated Gasoline Program
291
Petroleum Refineries
Manufacturing
California Phase II Exhaust Standards for
Nonroad Diesel Engines *175 hp
351
Internal Combustion Engines, not elsewhere
classified
Manufacturing
Commercial Marine Vessels, Emission Fees1
444
Water Transportation of Freight, Not Elsewhere
Classified
Water T ransportation
Recreational Vehicles - Potential California
Standards for 2- and 4-stroke engines
375
379
Motorcycles, Bicycles, and Parts
Transportation Equipment, Not Elsewhere
Classified
Manufacturing
Manufacturing
'This control measure could potentially affect SIC codes 441,442, and 443. However, the County Business Patterns did not report any
establishments for these SIC codes for the nonattainment area counties for which control costs were estimated. Consequently, these
three SIC codes were not included in the economic impact analysis for this control measure.
C-12
-------
APPENDIX D
ECONOMIC IMPACT ASSESSMENT SUPPORTING INFORMATION
-------
TABLE D-1
Control Measures and SIC Codes Excluded from the Analysis
Source Category, Control
Measure, or SIC code
Reason for Exclusion
Residential Natural Gas
Consumption / Low-NOx Burners
(LNB) for Water Heaters
Costs are 0
Point Source Open Burning /
Episodic Ban
Costs are 0
Area Source Open Burning /
Episodic Ban
Costs are 0
Service Stations: Stage 1 Truck
Unloading/Vapor Balance
Vapor recovery credits will offset equipment installation and
operation costs.
Petroleum Refinery Fugitives / RACT
Costs are negative (1)
Web Offset Lithography / New CTG
(carbon adsorber)
Costs are negative (1)
Cutback Asphalt / Switch to
Emulsified Asphalt
Costs are 0
Point Source Metal Surface
Coating/FIP VOC limits
Costs are 0
Residential Natural Gas
Combustion/LNB for Space Heaters
NA (2)
SIC code 257
SIC code miscoded in Interim 1990 Point Source Inventory
SIC code 928
SIC code miscoded in Interim 1990 Point Source Inventory
(1) Negative costs for VOC measures are due either to recovery credits for reduced VOC use and/or
production cost savings.
(2) No establishments were reported in County Business Patters for the counties for which this control
measure was selected; consequently, average costs per establishment and cost-to-sales ratios could not
be calculated for SIC code 3433.
D-1
-------
TABLE D-2
Sources of Data Used in Screening Analysis
Methodology by Source Category
Source Category
Industries/Entities
Affected
Number of
Affected Entities by SIC
Code
Cost Data
Used in Analysis
Sales Data
Used in
Analysis
Stationary Point Sources
Non-Government Point
Source Categories
Interim 1990 Inventory
(a)
Interim 1990 Inventory (b)
Average cost per plant
Enterprise
Statistics (c)
Non-Defense Government
Point Source Categories
Interim 1990 Inventory
Affected counties listed in Interim
1990 Inventory
Total cost for all affected
plants in a county
Census of
Government
National Defense Related
Point Source Categories
Interim 1990 Inventory
1 (Federal government)
Total cost for all affected
plants
Census of
Government
Stationary Area Sources
Area Source Industrial Fuel
Combustion
National Emissions
Inventory (d)
Not calculated
(e)
Enterprise
Statistics (c)
Bulk Terminals
Petroleum and Petroleum
Products
Not calculated
(0
Enterprise
Statistics (c)
Industrial Adhesives
Product Manufacturers
Not calculated
(0
Enterprise
Statistics (c)
Surface Coating
Product Manufacturers
Not calculated
(0
Enterprise
Statistics (c)
Automobile Refinishing
Automobile Repair/Paint
Shops
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Pesticide Application
Product Manufacturers
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Aerosol Paints
Product Manufacturers
Data from CARB (g)
Average cost per
affected establishment
Enterprise
Statistics (c)
SOCMI Batch Reactor
Processes
Product Manufacturers
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
SOCMI Fugitives
Product Manufacturers
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Pharmaceutical
manufacturing
Product Manufacturers
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Oil/Natural Gas Field
Production
Oil/Gas Extraction
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Service Stations - P-V Valves
Gasoline Service
Stations
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
On-Highwav Motor Vehicles
Low Emission Vehicles
Automobile
Manufacturers
County Business Patterns:
national total
Average cost per
manufacturer
Enterprise
Statistics (c)
Reformulated Gasoline
Petroleum Refineries
(h)
Average cost per
affected refinery
Enterprise
Statistics (c)
Reformulated Diesel Fuel
Petroleum Refineries
0)
Average cost per
affected refinery
Enterprise
Statistics (c)
Enhanced l/M
(i)
(i)
ffl
(i)
Nonroad Vehicles
Recreational Vehicles (CARB
Standards}
Equipment
Manufacturers
County Business Patterns:
affected county total (k)
Average cost per
affected establishment
Enterprise
Statistics (c)
Commercial Marine Vessels
Water Transportation
County Business Patterns:
affected county total
Average cost per
affected establishment
Enterprise
Statistics (c)
Nonroad Diesels (> 175 HP)
Equipment
Manufacturers
County Business Patterns:
affected county total (k)
Average cost per
affected establishment
Enterprise
Statistics (c)
Nonroad Gasoline
Petroleum Refineries
(h)
Average cost per
affected refinery
Enterprise
Statistics (c)
D-2
-------
TABLE D-2 NOTES:
(a)A default SIC code has been identified for each stationary point source category to be used if no SIC
code is identified in the Interim 1990 Inventory. The default value represents the SIC code appearing most
frequently in the Interim 1990 Inventory for each affected source category.
(b) For these stationary point source categories, the total number of affected establishments represents the
total number of plants in the Interim 1990 Inventory.
(c) The Enterprise Statistics data base contains 3-digit SIC code sales data from the Bureau of the Census.
The data base also contains sales data that have been collected from other Census publications (e.g.,
Census of Agriculture).
(d) The NOx control measures for area source industrial fuel combustion represent the expansion of the
application of a corresponding incremental point source measure. The point source SCCs were applied to
NEI data to identify the range of SIC codes that would likely be affected by these area source control
measures.
(e) A cost per establishment was calculated by multiplying the control measure's cost effectiveness ($/ton)
by its emission reduction. A measure's emission reduction was estimated by multiplying 80% rule
effectiveness times the applicable control efficiency times the total uncontrolled NOx emissions at plants in
the NEI with emissions between 25-100 tpy, and then dividing this total by the number of plants with
emissions between 25-100 tpy.
(f) The SIC codes identified as potentially being affected by the VOC control measures were used to identify
plants in the NEI with uncontrolled emissions between 25 and 100 tons per year. The method explained in
footnote (e) was then used to calculate the average cost per establishment for each control measure.
(g) CARB completed a survey and determined that 70 nationwide paint manufacturers would be affected by
the California rule on which this measure is based.
(h) The estimation of the number of refineries affected by the reformulated gasoline control measures is a
two-step process. First, the number of refineries producing gasoline was estimated by using survey results
from EPA on the proportion of a refinery sample that produces gasoline. This percentage was applied to
the total number of operating refineries based on published DOE data. Second, the proportion of total U.S.
gasoline consumption represented by affected nonattainment areas was applied to the number of refineries
that produce gasoline.
(I) The number of refineries affected by the reformulated diesel control measure was estimated using an
approach similar to footnote (h). First, the proportion of refineries producing diesel fuel was obtained from
EPA survey data. Second, the proportion of total U.S. diesel consumption represented by affected
nonattainment area counties was applied to the number of refineries that produce diesel fuel.
(j) The analysis of the enhanced l/M program is based on the approach used in the California FIP analysis,
(k) Since the affected industries are only a subset of the 4-digit SIC code, the total number of affected
establishments in County Business Patterns was weighted by the ratio of the value of shipments for the
affected equipment to the total value of shipments for the affected SIC code.
D-3
-------
TABLE D-3
8H5EX-80 NAAQS Alternative
Cost-to-Sales Ratios by Control Measure and SIC Code for All and Small
Establishments
(in thousands of $1990)
Number of
Average
Annual
Average
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Stationary Point Sources
Cement Manufacturing - Dry
SCR
324
1
$2,280
$27,047
$8,944
8.4%
25.5%
Glass Mfg - Container
Oxy-Firing
322
1
$4,775
$22,318
$1,275
21.4%
374.5%
Ind. Boiler - Distillate Oil
SCR
267
1
$13
$17,201
$4,114
0.1%
0.3%
Ind. Boiler - Distillate Oil
SCR
282
1
$13
$111,791
$16,963
0.0%
0.1%
Ind. Boiler - Distillate Oil
SCR
322
1 .
$13
$22,318
$1,275
0.1%
1.0%
Ind. Boiler - Distillate Oil
SCR
331
1
$13
$49,452
$5,095
0.0%
0.3%
Ind. Boiler - Natural Gas
SCR
267
1
$116
$17,201
$4,114
0.7%
2.8%
Ind. Boiler - Natural Gas
SCR
282
1
$116
$111,791
$16,963
0.1%
0.7%
Ind. Boiler - Natural Gas
SCR
295
1
$116
$6,445
$4,657
1.8%
2.5%
Ind. Boiler - Natural Gas
SCR
322
1
$116
$22,318
$1,275
0.5%
9.1%
Ind. Boiler - Natural Gas
SCR
331
1
$116
$49,452
$5,095
0.2%
2.3%
Ind. Boiler - Residual Oil
SCR
282
1
$47
$111,791
$16,963
0.0%
0.3%
Ind. Boiler - Residual Oil
SCR
295
1
$47
$6,445
$4,657
0.7%
1.0%
Ind. Boiler - Residual Oil
SCR
371
1
$47
$38,564
$2,267
0.1%
2.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
376
1
$3,328
$316,586
$5,142
1.1%
64.7%
Point Source Ind. Surface
Coating
Add-on
Control Levels
971
1
$3,328
$475,435,160
0.0%
Point Sources
RE
131
2
$707
$7,430
$3,265
9.5%
21.7%
Point Sources
RE
207
2
$707
$43,948
$21,299
1.6%
3.3%
Point Sources
RE
282
1
$707
$111,791
$16,963
0.6%
4.2%
Point Sources
RE
286
2
$707
$90,160
$13,860
0.8%
5.1%
Point Sources
RE
287
1
$707
$9,998
$3,481
7.1%
20.3%
Point Sources
RE
291
1
$707
$553,301
$42,456
0.1%
1.7%
Point Sources
RE
295
1
$707
$6,445
$4,657
11.0%
15.2%
Point Sources
RE
495
1
$707
$4,108
$2,936
17.2%
24.1%
Point Sources
RE
721
1
$707
$408
$278
173.5%
254.2%
Utility Boiler -
Oil-Gas/Tangential
SCR
491
1
$2,424
$33,269
$10,705
7.3%
22.6%
Stationary Area Sources
Adhesives - industrial
RACT
289
3
$1
$8,863
$5,318
0.0%
0.0%
Aerosols
SCAQMD
Standards -
Reformulati
285
70
$73
$13,724
$6,287
0.5%
1.2%
Area Source Ind. NG Comb
RACT (small)
131
2
$9
$7,430
$3,265
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
201
32
$9
$19,290
$5,527
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
202
14
$9
$13,315
$5,007
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
203
12
$9
$11,814
$3,495
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
204
15
$9
$9,583
$3,428
. 0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
205
32
$9
$6,172
$1,208
0.2%
0.8%
Area Source Ind. NG Comb
RACT (small)
206
6
$9
$7,010
$2,669
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
207
5
$9
$43,948
$21,299
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
208
18
$9
$14,053
$3,686
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
209
38
$9
$10,134
$3,348
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
222
3'
$9
$17,327
$2,548
0.1%
0.4%
D-4
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Area Source Ind. NG Comb
RACT (small)
223
1
$9
$22,019
$2,238
0.0%
0.4%
Area Source Ind. NG Comb
RACT (small)
226
10
$9
$13,299
$2,913
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
229
14
$9
$8,724
$2,628
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
249
34
$9
$3,325
$1,862
0.3%
0.5%
Area Source Ind. NG Comb
RACT (small)
263
3
$9
$96,730
$21,071
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
265
59
$9
$13,215
$5,965
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
267
52
$9
$17,201
$4,114
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
275
526
$9
$2,058
$1,120
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
280
226
$9
$21,178
$4,833
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
281
20
$9
$22,955
$7,204
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
282
7
$9
$111,791
$16,963
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
283
12
$9
$22,363
$3,008
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
284
56
$9
$12,882
$2,980
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
285
32
$9
$13,724
$6,287
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
286
11
$9
$90,160
$13,860
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
287
5
$9
$9,998
$3,481
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
289
65
$9
$8,863
$5,318
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
291
3
$9
$553,301
$42,456
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
295
28
$9
$6,445
$4,657
0.1%
0.2%
Area Source Ind. NGi Comb
RACT (small)
299
4
$9
$9,142
$6,903
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
301
2
$9
$99,723
$3,747
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
306
11
$9
$9,416
$3,076
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
308
152
$9
$5,716
$2,556
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
322
2
$9
$22,318
$1,275
0.0%
0.7%
Area Source Ind. NG Comb
RACT (small)
323
18
$9
$5,523
$1,746
0.2%
0.5%
Area Source Ind. NG Comb
RACT (smaD)
325
5
$9
$6,826
$3,735
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
326
8
$9
$3,426
$859
0.3%
1.1%
Area Source Ind. NG Comb
RACT (small)
327
124
$9
$3,400
$2,338
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
329
18
$9
$8,551
$2,894
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
331
9
$9
$49,452
$5,095
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
332
5
$9
$8,205
$1,747
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
333
1
$9
$74,465
$4,050
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
334
5
$9
$13,040
$8,343
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
335
17
$9
$36,514
$6,961
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
339
3
$9
$3,490
$2,182
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
341
8
$9
$30,750
$10,316
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
344
152
$9
$4,375
$2,469
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
346
25
$9
$9,507
$2,730
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
348
3
$9
$11,888
$1,003
0.1%
0.9%
Area Source Ind. NG Comb
RACT (small)
349
84
$9
$4,404
$1,989
0.2%
0.5%
Area Source Ind. NG Comb
RACT (small)
352
13
$9
$7,232
$1,480
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
353
29
$9
$6,416
$2,160
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
357
36
$9
$15,064
$2,497
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
358
23
$9
$15,967
$2,683
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
361
15
$9
$15,868
$2,716
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
362
11
$9
$10,107
$1,967
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
363
3
$9
$15,823
$1,850
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
364
13
$9
$13,071
$2,463
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
365
7
$9
$8,303
$1,766
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
367
56
$9
$7,130
$1,627
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
371
52
$9
$38,564
$2,267
0.0%
0.4%
D-5
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(AH)
(Small)
Area Source Ind. NG Comb
RACT (small)
372
11
$9
$80,938
$2,963
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
386
11
$9
$18,748
$2,271
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
391
4
$9
$2,468
$1,090
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
399
76
$9
$1,858
$1,009
0.5%
0.9%
Automobile refinishing
FIP Rule
753
1469
$11
$473
$454
2.3%
2.3%
Bulk Terminals
RACT
517
40
$1
$9,839
$8,410
0.0%
0.0%
Metal prod, surface coatinq
VOCI
mits
373
43
$841
$9,088
$1,459
9.3%
57.7%
Metal prod, surface coatina
VOCI
mits
341
3
$1
$30,750
$10,316
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
349
49
$1
$4,404
$1,989
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
371
46
$1
$38,564
$2,267
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
375
4
$1
$7,336
$2,049
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
376
2
$1
$316,586
$5,142
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
381
8
$1
$50,989
$2,025
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
382
22
$1
$9,496
$2,342
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
384
27
$1
$10,100
$2,241
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
385
4
$1
$12,731
$2,587
0.0%
0.0%
Metal prod. surface coating
VOCI
mits
386
4
$1
$18,748
$2,271
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
387
2
$1
$18,684
$2,833
0.0%
0.0%
Metal prod, surface coating
VOCI
mits
391
6
$1
$2,468
$1,090
0.0%
0.1%
Metal prod, surface coating
VOCI
mits
393
1
$1
$2,545
$1,225
0.0%
0.1%
Metal prod, surface coatinq
VOCI
mits
394
23
$1
$4,191
$1.938
0.0%
0.0%
Metal prod, surface coatinq
VOCI
mits
395
10
$1
$3,227
$1,294
0.0%
0.1%
Metal prod, surface coating
VOCI
mits
396
1
$1
$2,604
$1,126
0.0%
0.1%
Metal prod, surface coating
VOCI
mits
399
56
$1
$1,858
$1,009
0.0%
0.1%
Misc. surface coating
Add-on control
251
34
$539
$5,396
$1,773
10.0%
30.4%
Misc. surface coating
Add-on control
252
9
$539
$12,698
$2,271
4.2%
23.7%
Misc. surface coating
Add-on control
342
10
$539
$7,887
$2,003
6.8%
26.9%
Misc. surface coating
Add-on control
343
12
$539
$8,638
$2,429
6.2%
22.2%
Misc. surface coating
Add-on control
344
142
$539
$4,375
$2,469
12.3%
21.8%
Misc. surface coating
Add-on control
345
1
$539
$3,649
$2,234
14.8%
24.1%
Misc. surface coatinq
Add-on control
346
14
$539
$9,507
$2,730
5.7%
19.7%
Misc. surface coating
Add-on control
347
34
$539
$2,015
$1,371
26.7%
39.3%
Misc. surface coating
Add-on control
349
66
$539
$4,404
$1,989
12.2%
27.1%
Misc. surface coating
Add-on control
363
4
$539
$15,823
$1,850
3.4%
29.1%
Misc. surface coating
Add-on control
371
50
$539
$38,564
$2,267
1.4%
23.8%
Misc. surface coating
MACT control
352
31
$29
$7,232
$1,480
0.4%
2.0%
Misc. surface coating
MACT control
353
17
$29
$6,416
$2,160
0.5%
1.4%
Misc. surface coating
MACT control
354
24
$29
$2,260
$1,154
1.3%
2.6%
Misc. surface coating
MACT control
355
22
$29
$3,761
$1,743
0.8%
1.7%
Misc. surface coating
MACT control
356
24
$29
$5,377
$2,069
0.6%
1.4%
Misc. surface coating
MACT control
357
13
$29
$15,064
$2,497
0.2%
1.2%
Misc. surface coating
MACT control
358
19
$29
$15,967
$2,683
0.2%
1.1%
Misc. surface coatinq
MACT control
359
103
$29
$1,171
$769
2.5%
3.8%
Misc. surface coating
MACT control
361
4
$29
$15,868
$2,716
0.2%
1.1%
Misc. surface coating
MACT control
362
5
$29
$10,107
$1,967
0.3%
1.5%
Misc. surface coating
MACT control
363
4
$29
$15,823
$1,850
0.2%
1.6%
Misc. surface coating
MACT control
364
9
$29
$13,071
$2,463
0.2%
1.2%
Misc. surface coating
MACT control
365
8
$29
$8,303
$1,766
0.4%
1.7%
Misc. surface coating
MACT control
366
17
$29
$12,188
$2,437
0.2%
1.2%
Misc. surface coating
MACT control
367
39
$29
$7,130
$1,627
0.4%
1.8%
Misc. surface coatinq
MACT control
369
12
$29
$12,090
$1,472
0.2%
2.0%
D-6
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(AH)
$17,201
Average
Annual
Sales per
Establish-
ment
(Small)
$4,114
Cost-to-
Sales
Ratio
(All)
15.3%
Cost-to-
Sales
Ratio
(Small)
64.0%
Paper surface coating
Add-on control
267
14
$2,635
Pesticide Application
Reform - FIP
rule
287
17
$377
$9,998
$3,481
3.8%
10.8%
Service stations - stage
l-truck un
P-V valves
554
862
$0
$1,458
$1,191
0.0%
0.0%
Wood furniture surf coating
Reformulation
251
30
$11
$5,396
$1,773
0.2%
0.6%
Wood furniture surf coating
Reformulation
252
9
$11
$12,698
$2,271
0.1%
0.5%
Wood furniture surf coating
Reformulation
254
13
$11
$3,779
$1,958
0.3%
0.6%
Wood furniture surf coating
Reformulation
242
35
$1
$4,630
$2,310
0.0%
0.0%
Wood furniture surf coating
Reformulation
243
140
$1
$4,640
$1,918
0.0%
0.0%
Wood furniture surf coating
Reformulation
244
22
$1
$1,666
$1,298
0.1%
0.1%
Wood furniture surf coating
Reformulation
245
16
$1
$9,840
$3,971
0.0%
0.0%
Wood furniture surf coating
Reformulation
249
27
$1
$3,325
$1,862
0.0%
0.1%
Nonroad Vehicles
Nonroad gasoline
Reform, gas
291
1
$775
$553,301
$42,456
0.1%
1.8%
Recreational vehicles
CARB stds
375
2
$13
$7,336
$2,049
0.2%
0.6%
Recreational vehicles
CARB stds
379
7
$13
$9,164
$2,426
0.1%
0.5%
Onroad Vehicles
Motor Vehicles
Cal. Reform
291
2
$76,891
$553,301
$42,456
13.9%
181.1%
Motor Vehicles
Fed. Reform
291
1
$10,593
$553,301
$42,456
1.9%
25.0%
Motor Vehicles
Reform Diesel
291
1
$25,282
$553,301
$42,456
4.6%
59.6%
D-7
-------
TABLE D-4
8H4AX-80 NAAQS Alternative:
Cost-to-Sales Ratios by Control Measure and SIC Code for All and Small
Establishments
(in thousands of $1990)
Number of
Average
Annual
Average
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Stationary Point Sources
Cement Manufacturing - Dry
SCR
324
1
$2,280
$27,047
$8,944
8.4%
25.5%
Glass Mfg - Container
Oxy-Firing
322
1
$4,775
$22,318
$1,275
21.4%
374.5%
Ind. Boiler - Distillate Oil
SCR
267
1
$13
$17,201
$4,114
0.1%
0.3%
Ind. Boiler - Distillate Oil
SCR
282
1
$13
$111,791
$16,963
0.0%
0.1%
Ind. Boiler - Distillate Oil
SCR
322
1
$13
$22,318
$1,275
0.1%
1.0%
Ind. Boiler - Distillate Oil
SCR
331
1
$13
$49,452
$5,095
0.0%
0.3%
Ind. Boiler - Natural Gas
SCR
267
1
$116
$17,201
$4,114
0.7%
2.8%
Ind. Boiler - Natural Gas
SCR
282
1
$116
$111,791
$16,963
0.1%
0.7%
Ind. Boiler - Natural Gas
SCR
295
1
$116
$6,445
$4,657
1.8%
2.5%
Ind. Boiler - Natural Gas
SCR
322
1
$116
$22,318
$1,275
0.5%
9.1%
Ind. Boiler - Natural Gas
SCR
331
1
$116
$49,452
$5,095
0.2%
2.3%
Ind. Boiler - Residual Oil
SCR
282
1
$47
$111,791
$16,963
0.0%
0.3%
Ind. Boiler - Residual Oil
SCR
295
1
$47
$6,445
$4,657
0.7%
1.0%
Ind. Boiler - Residual Oil
SCR
371
1
$47
$38,564
$2,267
0.1%
2.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
203
1
$9,196
$11,814
$3,495
77.8%
263.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
291
1
$9,196
$553,301
$42,456
1.7%
21.7%
Point Source Ind. Surface
Coating
Add-on
Control Levels
342
1
$9,196
$7,887
$2,003
116.6%
459.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
344
1
$9,196
$4,375
$2,469
210.2%
372.5%
Point Source Ind. Surface
Coating
Add-on
Control Levels
346
1
$9,196
$9,507
$2,730
96.7%
336.9%
Point Source Ind. Surface
Coating
Add-on
Control Levels
364
1
$9,196
$13,071
$2,463
70.4%
373.4%
Point Source Ind. Surface
Coating
Add-on
Control Levels
371
2
$9,196
$38,564
$2,267
23.9%
405.7%
Point Source Ind. Surface
Coating
Add-on
Control Levels
376
1
$9,196
$316,586
$5,142
2.9%
178.8%
Point Source Ind. Surface
Coating
Add-on
Control Levels
971
2
$9,196-
$475,435,160
0.0%
Point Source Wood Product
Coating
FIP VOC
Limits
251
1
$4
$5,396
$1,773
0.1%
0.2%
Point Source Wood Product
Coating
FIP VOC
Limits
349
1
$4
$4,404
$1,989
0.1%
0.2%
Point Sources
RE
131
2
$2,128
$7,430
$3,265
28.6%
65.2%
Point Sources
RE
207
2
$2,128
$43,948
$21,299
4.8%
10.0%
Point Sources
RE
263
1
$2,128
$96,730
$21,071
2.2%
10.1%
Point Sources
RE
265
1
$2,128
$13,215
$5,965
16.1%
35.7%
Point Sources
RE
267
3
$2,128
$17,201
$4,114
12.4%
51.7%
Point Sources
RE
275
2
$2,128
$2,058
$1,120
103.4%
190.0%
Point Sources
RE
282
5
$2,128
$111,791
$16,963
1.9%
12.5%
Point Sources
RE
286
8
$2,128
$90,160
$13,860
2.4%
15.4%
Point Sources
RE
287
2
$2,128
$9,998
$3,481
21.3%
61.1%
Point Sources
RE
291
4
$2,128
$553,301
$42,456
0.4%
5.0%
D-8
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Point Sources
RE
295
1
$2,128
$6,445
$4,657
33.0%
45.7%
Point Sources
RE
299
1
$2,128
$9,142
$6,903
23.3%
30.8%
Point Sources
RE
308
$2,128
$5,716
$2,556
37.2%
83.2%
Point Sources
RE
329
1
$2,128
$8,551
$2,894
24.9%
73.5%
Point Sources
RE
342
1
$2,128
$7,887
$2,003
27.0%
106.2%
Point Sources
RE
346
1
$2,128
$9,507
$2,730
22.4%
77.9%
Point Sources
RE
347
1
$2,128
$2,015
$1,371
105.6%
155.2%
Point Sources
RE
399
1
$2,128
$1,858
$1,009
114.5%
210.9%
Point Sources
RE
491
1
$2,128
$33,269
$10,705
6.4%
19.9%
Point Sources
RE
495
1
$2,128
$4,108
$2,936
51.8%
72.5%
Point Sources
RE
509
1
$2,128
$5,706
$2,587
37.3%
82.2%
Point Sources
RE
517
$2,128
$9,839
$8,410
21.6%
25.3%
Point Sources
RE
721
1
$2,128
$408
$278
522.1%
765.1%
Point Sources
RE
971
1
$2,128
$475,435,160
0.0%
Utility Boiler -
Oil-Gas/Tangential
SCR
491
1
$2,424
$33,269
$10,705
7.3%
22.6%
Stationary Area Sources
Adhesives - industrial
RACT
289
3
$1
$8,863
$5,318
0.0%
0.0%
Aerosols
CARB Tier 2
Standards -
Reform
285
70
$2
$13,724
$6,287
0.0%
0.0%
Aerosols
SCAQMD
Standards -
Reformulati
285
70
$233
$13,724
$6,287
1.7%
3.7%
Aircraft surface coating
Add-on control
372
21
$1,392
$80,938
$2,963
1.7%
47.0%
Area Source Ind. NG Comb
RACT (small)
131
2
$9
$7,430
$3,265
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
201
32
$9
$19,290
$5,527
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
202
14
$9
$13,315
$5,007
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
203
12
$9
$11,814
$3,495
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
204
15
$9
$9,583
$3,428
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
205
32
$9
$6,172
$1,208
0.2%
0.8%
Area Source Ind. NG Comb
RACT (small)
206
6
$9
$7,010
$2,669
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
207
5
$9
$43,948
$21,299
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
208
18
$9
$14,053
$3,686
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
209
38
$9
$10,134
$3,348
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
222
3
$9
$17,327
$2,548
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
223
1
$9
$22,019
$2,238
0.0%
0.4%
Area Source Ind. NG Comb
RACT (small)
226
10
$9
$13,299
$2,913
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
229
14
$9
$8,724
$2,628
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
249
34
$9
$3,325
$1,862
0.3%
0.5%
Area Source Ind. NG Comb
RACT (small)
263
3
$9
$96,730
$21,071
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
265
59
$9
$13,215
$5,965
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
267
52
$9
$17,201
$4,114
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
275
526
$9
$2,058
$1,120
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
280
226
$9
$21,178
$4,833
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
281
20
$9
$22,955
$7,204
0.0%
r 0.1%
Area Source Ind. NG Comb
RACT (small)
282
7
$9
$111,791
$16,963
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
283
12
$9
$22,363
$3,008
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
284
56
$9
$12,882
$2,980
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
285
32
$9
$13,724
$6,287
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
286
11
$9
$90,160
$13,860
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
287
5
$9
$9,998
$3,481
0.1%
0.3%
D-9
-------
Number of
Average
Annual
Average
Annual
Total
Establish-
Average
Cost per
Sales per
Establish-
Sales per
Establish-
Cost-to-
Sales
Cost-to-
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Area Source Ind. NG Comb
RACT (small)
289
65
$9
$8,863
$5,318
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
291
3
$9
$553,301
$42,456
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
295
28
$9
$6,445
$4,657
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
299
4
$9
$9,142
$6,903
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
301
2
$9
$99,723
$3,747
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
306
11
$9
$9,416
$3,076
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
308
152
$9
$5,716
$2,556
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
322
2
$9
$22,318
$1,275
0.0%
0.7%
Area Source Ind. NG Comb
RACT (small)
323
18
$9
$5,523
$1,746
0.2%
0.5%
Area Source Ind. NG Comb
RACT (small)
325
5
$9
$6,826
$3,735
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
326
8
$9
$3,426
$859
0.3%
1.1%
Area Source Ind. NG Comb
RACT (small)
327
124
$9
$3,400
$2,338
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
329
18
$9
$8,551
$2,894
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
331
9
$9
$49,452
$5,095
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
332
5
$9
$8,205
$1,747
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
333
1
$9
$74,465
$4,050
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
334
5
$9
$13,040
$8,343
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
335
17
$9
$36,514
$6,961
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
339
3
$9
$3,490
$2,182
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
341
8
$9
$30,750
$10,316
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
344
152
$9
$4,375
$2,469
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
346
25
$9
$9,507
$2,730
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
348
3
$9
$11,888
$1,003
0.1%
0.9%
Area Source Ind. NG Comb
RACT (small)
349
84
$9
$4,404
$1,989
0.2%
0.5%
Area Source Ind. NG Comb
RACT (small)
352
13
$9
$7,232
$1,480
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
353
29
$9
$6,416
$2,160
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
357
36
$9
$15,064
$2,497
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
358
23
$9
$15,967
$2,683
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
361
15
$9
$15,868
$2,716
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
362
11
$9
$10,107
$1,967
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
363
3
$9
$15,823
$1,850
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
364
13
$9
$13,071
$2,463
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
365
7
$9
$8,303
$1,766
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
367
56
$9
$7,130
$1,627
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
371
52
$9
$38,564
$2,267
0.0%
0.4%
Area Source Ind. NG Comb
RACT (small)
372
11
$9
$80,938
$2,963
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
386
11
$9
$18,748
$2,271
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
391
4
$9
$2,468
$1,090
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
399
76
$9
$1,858
$1,009
0.5%
0.9%
Automobile refinishing
FIP Rule
(VOC Content
& TE)
753
4644
$13
$473
$454
2.7%
2.8%
Bulk Terminals
RACT
517
114
$4
$9,839
$8,410
0.0%
0.0%
Marine Surface Coating
Add-on control
373
77
$810
$9,088
$1,459
8.9%
55.5%
Metal prod, surface coating
VOC limits
341
29
$1
$30,750
$10,316
0.0%
0.0%
Metal prod, surface coating
VOC limits
349
385
$1
$4,404
$1,989
0.0%
0.0%
Metal prod, surface coating
VOC limits
371
176
$1
$38,564
$2,267
0.0%
0.0%
Metal prod, surface coating
VOC limits
375
10
$1
$7,336
$2,049
0.0%
0.0%
Metal prod, surface coating
VOC limits
376
5
$1
$316,586
$5,142
0.0%
0.0%
Metal prod, surface coating
VOC limits
381
50
$1
$50,989
$2,025
0.0%
0.0%
Metal prod, surface coating
VOC limits
382
217
$1
$9,496
$2,342
0.0%
0.0%
Metal prod, surface coating
VOC limits
384
181
$1
$10,100
$2,241
0.0%
0.0%
D-10
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Metal prod, surface coating
VOC limits
385
21
$i
$12,731
$2,587
0.0%
0.0%
Metal prod, surface coating
VOC limits
386
44
$1
$18,748
$2,271
0.0%
0.0%
Metal prod, surface coating
VOC limits
387
7
$i
$18,684
$2,833
0.0%
0.0%
Metal prod, surface coating
VOC limits
391
77
$1
$2,468
$1.090
0.0%
0.1%
Metal prod, surface coating
VOC limits
393
16
$1
$2,545
$1,225
0.0%
0.1%
Metal prod, surface coating
VOC limits
394
125
$1
$4,191
$1,938
0.0%
0.0%
Metal prod, surface coating
VOC limits
395
56
$1
$3,227
$1,294
0.0%
0.1%
Metal prod, surface coating
VOC limits
396
16
$1
$2,604
$1,126
0.0%
0.1%
Metal prod, surface coating
VOC limits
399
327
$1
$1,858
$1,009
0.1%
0.1%
Misc. surface coating
Add-on control
251
131
$1,129
$5,396
$1,773
20.9%
63.7%
Misc. surface coating
Add-on control
252
23
$1,129
$12,698
$2,271
8.9%
49.7%
Misc. surface coating
Add-on control
342
68
$1,129
$7,887
$2,003
14.3%
56.4%
Misc. surface coating
Add-on control
343
40
$1,129
$8,638
$2,429
13.1%
46.5%
Misc. surface coating
Add-on control
344
524
$1,129
$4,375
$2,469
25.8%
45.7%
Misc. surface coating
Add-on control
345
52
$1,129
$3,649
$2,234
31.0%
50.6%
Misc. surface coating
Add-on control
346
99
$1,129
$9,507
$2,730
11.9%
41.4%
Misc. surface coating
Add-on control
347
167
$1,129
$2,015
$1,371
56.0%
82.4%
Misc. surface coating
Add-on control
348
11
$1,129
$11,888
$1,003
9.5%
112.6%
Misc. surface coating
Add-on control
349
306
$1,129
$4,404
$1,989
25.6%
56.8%
Misc. surface coating
Add-on control
363
14
$1,129
$15,823
$1,850
7.1%
61.0%
Misc. surface coating
Add-on control
371
127
$1,129
$38,564
$2,267
2.9%
49.8%
Misc. surface coating
MACT control
351
8
$29
$17,804
$1,779
0.2%
1.7%
Misc. surface coating
MACT control
352
58
$29
$7,232
$1,480
0.4%
2.0%
Misc. surface coating
MACT control
353
70
$29
$6,416
$2,160
0.5%
1.4%
Misc. surface coating
MACT control
354
256
$29
$2,260
$1,154
1.3%
2.6%
Misc. surface coating
MACT control
355
174
$29
$3,761
$1,743
0.8%
1.7%
Misc. surface coating
MACT control
356
186
$29
$5,377
$2,069
0.6%
1.4%
Misc. surface coating
MACT control
357
78
$29
$15,064
$2,497
0.2%
1.2%
Misc. surface coating
MACT control
358
74
$29
$15,967
$2,683
0.2%
1.1%
Misc. surface coating
MACT control
359
635
$29
$1,171
$769
2.5%
3.8%
Misc. surface coating
MACT control
361
28
$29
$15,868
$2,716
0.2%
1.1%
Misc. surface coating
MACT control
362
65
$29
$10,107
$1,967
0.3%
1.5%
Misc. surface coating
MACT control
363
14
$29
$15,823
$1,850
0.2%
1.6%
Misc. surface coating
MACT control
364
85
$29
$13,071
$2,463
0.2%
1.2%
Misc. surface coating
MACT control
365
28
$29
$8,303
$1,766
0.4%
1.7%
Misc. surface coating
MACT control
366
88
$29
$12,188
$2,437
0.2%
1.2%
Misc. surface coating
MACT control
367
192
$29
$7,130
$1,627
0.4%
1.8%
Misc. surface coating
MACT control
369
79
$29
$12,090
$1,472
0.2%
2.0%
Misc. surface coating
MACT control
374
4
$29
$23,567
$5,656
0.1%
0.5%
Paper surface coating
Add-on control
267
113
$2,438
$17,201
$4,114
14.2%
59.3%
Pesticide Application
Reformulation
- FIP rule
287
34
$320
$9,998
$3,481
3.2%
9.2%
Pharmaceutical mfg
RACT
283
17
$0
$22,363
$3,008
0.0%
0.0%
Service stations - stage
1-truck
P-V valves
554
3783
$0
$1,458
$1,191
0.0%
0.0%
SOCMI fugitives
RACT
286
1
$2
$90,160
$13,860
0.0%
0.0%
Wood furniture surf coating
Reformulation
251
170
$20
$5,396
$1,773
0.4%
1.1%
Wood furniture surf coating
Reformulation
252
30
$20
$12,698
$2,271
0.2%
0.9%
Wood furniture surf coating
Reformulation
254
104
$20
$3,779
$1,958
0.5%
1.0%
Wood furniture surf coating
Reformulation
242
157
$1
$4,830
$2,310
0.0%
0.1%
Wood furniture surf coating
Reformulation
243
427
$1
$4,640
$1,918
0.0%
0.1%
Wood furniture surf coating
Reformulation
244
89
$1
$1,666
$1,298
0.1%
0.1%
D-ll
-------
Number of
Average
Annual
Average
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Wood furniture surf coating
Reformulation
245
46
$1
$9,840
$3,971
0.0%
0.0%
Wood furniture surf coating
Reformulation
249
146
$1
$3,325
$1,862
0.0%
0.1%
Nonroad Vehicles
Nonroad gasoline
Reform gas
291
1
$1,016
$553,301
$42,456
0.2%
2.4%
Recreational vehicles
CARB stds
375
5
$30
$7,336
$2,049
0.4%
1.5%
Recreational vehicles
CARB stds
379
20
$30
$9,164
$2,426
0.3%
1.3%
Onroad Vehicles
Motor Vehicles
Cal. Reform
291
5
$47,901
$553,301
$42,456
8.7%
112.8%
Motor Vehicles
Fed. Reform
291
1
$10,593
$553,301
$42,456
1.9%
25.0%
Motor Vehicles
Reform Diesel
291
1
$25,282
$553,301
$42,456
4.6%
59.6%
D-12
-------
TABLE D-5
8H1AX-80 NAAQS Alternative
Cost-to-Sales Ratios by Control Measure and SIC Code for All and Small
Establishments
(in thousands of $1990)
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Stationary Point Sources
Cement Mfq - Dry
SCR
324
2
$3,172
$27,047
$8,944
11.7%
35.5%
Gas Turbines - Nat. Gas
SCR +
STEAM
INJECTION
492
1
$401
$23,847
$13,894
1.7%
2.9%
Gas Turbines - Nat. Gas
SCR +
STEAM
INJECTION
509
1
$401
$5,706
$2,587
7.0%
15.5%
Gas Turbines - Oil
SCR +
WATER
INJECTION
491
1
$5,652
$33,269
$10,705
17.0%
52.8%
Glass Mfq - Container
Oxv-Firincj
322
1
$4,775
$22,318
$1,275
21.4%
374.5%
IC Engines - Natural Gas
NSCR
492
2
$621
$23,847
$13,894
2.6%
4.5%
Indust. Boiler - Distillate Oil
SCR
201
1
$28
$19,290
$5,527
0.1%
0.5%
Indust. Boiler - Distillate Oil
SCR
221
1
$28
$25,356
$1,197
0.1%
2.3%
Indust. Boiler - Distillate Oil
SCR
252
1
$28
$12,698
$2,271
0.2%
1.2%
Indust. Boiler - Distillate Oil
SCR
262
1
$28
$145,607
$17,287
0.0%
0.2%
Indust. Boiler - Distillate Oil
SCR
267
1
$28
$17,201
$4,114
0.2%
0.7%
Indust. Boiler - Distillate Oil
SCR
275
1
$28
$2,058
$1,120
1.4%
2.5%
Indust. Boiler - Distillate Oil
SCR
281
1
$28
$22,955
$7,204
0.1%
0.4%
Indust. Boiler - Distillate Oil
SCR
282
2
$28
$111,791
$16,963
0.0%
0.2%
Indust. Boiler - Distillate Oil
SCR
322
1
$28
$22,318
$1,275
0.1%
2.2%
Indust. Boiler - Distillate Oil
SCR
329
2
$28
$8,551
$2,894
0.3%
1.0%
Indust. Boiler - Distillate Oil
SCR
331
1
$28
$49,452
$5,095
0.1%
0.6%
Indust. Boiler - Distillate Oil
SCR
348
1
$28
$11,888
$1,003
0.2%
2.8%
Indust. Boiler - Distillate Oil
SCR
373
1
$28
$9,088
$1,459
0.3%
1.9%
Indust Boiler - Distillate Oil
SCR
822
1
$28
$8,662
$560
0.3%
5.0%
Indust. Boiler - Distillate Oil
SCR
971
1
$28
$475,435,160
0.0%
Indust. Boiler - Nat. Gas
SCR
201
1
$98
$19,290
$5,527
0.5%
1.8%
Indust. Boiler - Nat. Gas
SCR
203
1
$98
$11,814
$3,495
0.8%
2.8%
Indust. Boiler - Nat. Gas
SCR
221
2
$98
$25,356
$1,197
0.4%
8.2%
Indust. Boiler - Nat. Gas
SCR
223
1
$98
$22,019
$2,238
0.5%
4.4%
Indust. Boiler - Nat Gas
SCR
252
1
$98
$12,698
$2,271
0.8%
4.3%
Indust. Boiler - Nat. Gas
SCR
254
1
$98
$3,779
$1,958
2.6%
5.0%
Indust. Boiler - Nat. Gas
SCR
267
2
$98
$17,201
$4,114
0.6%
2.4%
Indust. Boiler - Nat. Gas
SCR
275
2
$98
$2,058
$1,120
4.8%
8.8%
Indust. Boiler - Nat. Gas
SCR
281
1
$98
$22,955
$7,204
0.4%
1.4%
Indust. Boiler - Nat. Gas
SCR
282
2
$98
$111,791
$16,963
0.1%
0.6%
Indust. Boiler - Nat. Gas
SCR
295
1
$98
$6,445
$4,657
1.5%
2.1%
Indust. Boiler - Nat. Gas
SCR
301
1
$98
$99,723
$3,747
0.1%
2.6%
Indust. Boiler - Nat. Gas
SCR
311
1
$98
$6,984
$3,001
1.4%
3.3%
Indust. Boiler - Nat. Gas
SCR
322
1
$98
$22,318
$1,275
0.4%
7.7%
Indust. Boiler - Nat. Gas
SCR
329
2
$98
$8,551
$2,894
1.2%
3.4%
Indust. Boiler - Nat. Gas
SCR
331
1
$98
$49,452
$5,095
0.2%
1.9%
Indust. Boiler - Nat. Gas
SCR
333
3
$98
$74,465
$4,050
0.1%
2.4%
D-13
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Indust. Boiler - Nat. Gas
SCR
362
1
$98
$10,107
$1,967
1.0%
5.0%
Indust. Boiler - Nat. Gas
SCR
371
1
$98
$38,564
$2,267
0.3%
4.3%
Indust. Boiler - Nat. Gas
SCR
372
1
$98
$80,938
$2,963
0.1%
3.3%
Indust. Boiler - Nat. Gas
SCR
806
1
$98
$15,066
$4,150
0.7%
2.4%
Indust. Boiler - Nat. Gas
SCR
822
2
$98
$8,662
$560
1.1%
17.6%
Industrial Boiler - PC
SCR
261
1
$2,585
$153,545
$33,447
1.7%
7.7%
Industrial Boiler - PC
SCR
263
1
$2,585
$96,730
$21,071
2.7%
12.3%
Industrial Boiler - PC
SCR
282
1
$2,585
$111,791
$16,963
2.3%
15.2%
Industrial Boiler - PC
SCR
348
1
$2,585
$11,888
$1,003
21.7%
257.7%
Industrial Boiler - PC
SCR
371
1
$2,585
$38,564
$2,267
6.7%
114.0%
Industrial Boiler - PC
SCR
822
1
$2,585
$8,662
$560
29.8%
461.6%
Industrial Boiler - Resid. Oil
SCR
203
2
$128
$11,814
$3,495
1.1%
3.7%
Industrial Boiler - Resid. Oil
SCR
223
2
$128
$22,019
$2,238
0.6%
5.7%
Industrial Boiler - Resid. Oil
SCR
226
1
$128
$13,299
$2,913
1.0%
4.4%
Industrial Boiler - Resid. Oil
SCR
242
1
$128
$4,830
$2,310
2.6%
5.5%
Industrial Boiler - Resid. Oil
SCR
254
1
$128
$3,779
$1,958
3.4%
6.5%
Industrial Boiler - Resid. Oil
SCR
261
1
$128
$153,545
$33,447
0.1%
0.4%
Industrial Boiler - Resid. Oil
SCR
262
1
$128
$145,607
$17,287
0.1%
0.7%
Industrial Boiler - Resid. Oil
SCR
282
2
$128
$111,791
$16,963
0.1%
0.8%
Industrial Boiler - Resid. Oil
SCR
295
2
$128
$6,445
$4,657
2.0%
2.7%
Industrial Boiler - Resid. Oil
SCR
301
1
$128
$99,723
$3,747
0.1%
3.4%
Industrial Boiler - Resid. Oil
SCR
311
1
$128
$6,984
$3,001
1.8%
4.3%
Industrial Boiler - Resid. Oil
SCR
371
1
$128
$38,564
$2,267
0.3%
5.6%
Industrial Boiler - Resid. Oil
SCR
373
1
$128
$9,088
$1,459
1.4%
8.7%
Industrial Boiler - Resid. Oil
SCR
806
1
$128
$15,066
$4,150
0.9%
3.1%
Industrial Boiler • Resid. Oil
SCR
971
1
$128
$475,435,160
0.0%
Industrial Boiler - Stoker
SCR
213
1
$174
$58,200
$6,053
0.3%
2.9%
Industrial Boiler - Stoker
SCR
221
1
$174
$25,356
$1,197
0.7%
14.5%
Industrial Boiler - Stoker
SCR
229
1
$174
$8,724
$2,628
2.0%
6.6%
Industrial Boiler - Stoker
SCR
333
2
$174
$74,465
$4,050
0.2%
4.3%
Industrial Boiler - Stoker
SCR
371
1
$174
$38,564
$2,267
0.5%
7.7%
Industrial Boiler - Stoker
SCR
806
1
$174
$15,066
$4,150
1.2%
4.2%
Industrial Boiler - Stoker
SCR
822
2
$174
$8,662
$560
2.0%
31.0%
Municipal Waste Combus
SNCR
495
1
$439
$4,108
$2,936
10.7%
15.0%
Point Source Ind. Surface
Coating
Add-on
Control Levels
11
1
$4,494
$90
$81
4993.3%
5548.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
203
1
$4,494
$11,814
$3,495
38.0%
128.6%
Point Source Ind. Surface
Coating
Add-on
Control Levels
243
1
$4,494
$4,640
$1,918
96.9%
234.3%
Point Source Ind. Surface
Coating
Add-on
Control Levels
251
3
$4,494
$5,396
$1,773
83.3%
253.5%
Point Source Ind. Surface
Coating
Add-on
Control Levels
252
1
$4,494
$12,698
$2,271
35.4%
197.9%
Point Source Ind. Surface
Coating
Add-on
Control Levels
291
1
$4,494
$553,301
$42,456
0.8%
10.6%
Point Source Ind. Surface
Coating
Add-on
Control Levels
295
1
$4,494
$6,445
$4,657
69.7%
96.5%
Point Source Ind. Surface
Coating
Add-on
Control Levels
308
2
$4,494
$5,716
$2,556
78.6%
175.8%
Point Source Ind. Surface
Coating
Add-on
Control Levels
331
2
$4,494
$49,452
$5,095
9.1%
88.2%
Point Source Ind. Surface
Coating
Add-on
Control Levels
332
1
$4,494
$8,205
$1,747
54.8%
257.2%
D-14
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Point Source Ind. Surface
Coating
Add-on
Control Levels
339
1
$4,494
$3,490
$2,182
128.8%
206.0%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
340
4
$4,494
$4,479
$1,862
100.3%
241.4%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
341
2
$4,494
$30,750
$10,316
14.6%
43.6%
Point Source Ind. Surface
Coating
Add-on
Control Levels
342
2
$4,494
$7,887
$2,003
57.0%
224.4%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
344
4
$4,494
$4,375
$2,469
102.7%
182.0%
Point Source Ind. Surface
Coating
Add-on
Control Levels
346
3
$4,494
$9,507
$2,730
47.3%
164.6%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
347
1
$4,494
$2,015
$1,371
223.0%
327.8%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
348
1
$4,494
$11,888
$1,003
37.8%
448.1%
Point Source Ind. Surface
Coating
Add-on
Control Levels
349
3
$4,494
$4,404
$1,989
102.0%
225.9%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
353
3
$4,494
$6,416
$2,160
70.0%
208.1%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
358
2
$4,494
$15,967
$2,683
28.2%
167.5%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
362
2
$4,494
$10,107
$1,967
44.5%
228.5%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
363
2
$4,494
$15,823
$1,850
28.4%
242.9%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
364
1
$4,494
$13,071
$2,463
34.4%
182.5%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
366
1
$4,494
$12,188
$2,437
36.9%
184.4%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
367
2
$4,494
$7,130
$1,627
63.0%
276.2%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
370
2
$4,494
$35,538
$2,260
12.7%
198.9%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
371
27
$4,494
$38,564
$2,267
11.7%
198.2%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
372
3
$4,494
$80,938
$2,963
5.6%
151.7%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
373
2
$4,494
$9,088
$1,459
49.5%
308.0%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
376
1
$4,494
$316,586
$5,142
1.4%
87.4%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
399
1
$4,494
$1,858
$1,009
241.9%
445.4%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
458
1
$4,494
$2,755
$1,430
163.1%
314.3%
Point Source Ind. Surface
Coatinq
Add-on
Control Levels
971
4
$4,494
$475,435,160
0.0%
Point Source Wood Product
Coatinq
FIP VOC
Limits
242
1
$2
$4,830
$2,310
0.0%
0.1%
Point Source Wood Product
Coatinq
FIP VOC
Limits
243
3
$2
$4,640
$1,918
0.1%
0.1%
Point Source Wood Product
Coatinq
FIP VOC
Limits
249
1
$2
$3,325
$1,862
0.1%
0.1%
Point Source Wood Product
Coatinq
FIP VOC
Limits
251
2
$2
$5,396
$1,773
0.0%
0.1%
Point Source Wood Product
Coatinq
FIP VOC
Limits
341
1
$2
$30,750
$10,316
0.0%
0.0%
D-15
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Point Source Wood Product
FIP VOC
349
1
$2
$4,404
$1,989
0.1%
0.1%
Coatinq
Limits
Point Source Wood Product
FIP VOC
371
1
$2
$38,564
$2,267
0.0%
0.1%
Coating
Limits
Point Sources
RE
131
4
$2,043
$7,430
$3,265
27.5%
62.6%
Point Sources
RE
204
1
$2,043
$9,583
$3,428
21.3%
59.6%
Point Sources
RE
207
2
$2,043
$43,948
$21,299
4.7%
9.6%
Point Sources
RE
226
1
$2,043
$13,299
$2,913
15.4%
70.2%
Point Sources
RE
260
1
$2,043
$16,187
$3,526
12.6%
58.0%
Point Sources
RE
262
1
$2,043
$145,607
$17,287
1.4%
11.8%
Point Sources
RE
263
2
$2,043
$96,730
$21,071
2.1%
9.7%
Point Sources
RE
265
5
$2,043
$13,215
$5,965
15.5%
34.3%
Point Sources
RE
267
8
$2,043
$17,201
$4,114
11.9%
49.7%
Point Sources
RE
272
1
$2,043
$7,692
$2,324
26.6%
87.9%
Point Sources
RE
275
13
$2,043
$2,058
$1,120
99.3%
182.4%
Point Sources
RE
281
3
$2,043
$22,955
$7,204
8.9%
28.4%
Point Sources
RE
282
14
$2,043
$111,791
$16,963
1.8%
12.1%
Point Sources
RE
283
4
$2,043
$22,363
$3,008
9.1%
67.9%
Point Sources
RE
286
23
$2,043
$90,160
$13,860
2.3%
14.7%
Point Sources
RE
287
3
$2,043
$9,998
$3,481
20.4%
58.7%
Point Sources
RE
291
22
$2,043
$553,301
$42,456
0.4%
4.8%
Point Sources
RE
295
4
$2,043
$6,445
$4,657
31.7%
43.9%
Point Sources
RE
299
2
$2,043
$9,142
$6,903
22.4%
29.6%
Point Sources
RE
306
1
$2,043
$9,416
$3,076
21.7%
66.4%
Point Sources
RE
308
6
$2,043
$5,716
$2,556
35.8%
79.9%
Point Sources
RE
329
3
$2,043
$8,551
$2,894
23.9%
70.6%
Point Sources
RE
331
9
$2,043
$49,452
$5,095
4.1%
40.1%
Point Sources
RE
341
7
$2,043
$30,750
$10,316
6.7%
19.8%
Point Sources
RE
342
1
$2,043
$7,887
$2,003
25.9%
102.0%
Point Sources
RE
346
2
$2,043
$9,507
$2,730
21.5%
74.9%
Point Sources
RE
347
2
$2,043
$2,015
$1,371
101.4%
149.0%
Point Sources
RE
349
2
$2,043
$4,404
$1,989
46.4%
102.7%
Point Sources
RE
363
1
$2,043
$15,823
$1,850
12.9%
110.5%
Point Sources
RE
371
1
$2,043
$38,564
$2,267
5.3%
90.1%
Point Sources
RE
372
1
$2,043
$80,938
$2,963
2.5%
69.0%
Point Sources
RE
399
1
$2,043
$1,858
$1,009
110.0%
202.5%
Point Sources
RE
461
2
$2,043
$8,585
$6,546
23.8%
31.2%
Point Sources
RE
491
1
$2,043
$33,269
$10,705
6.1%
19.1%
Point Sources
RE
493
1
$2,043
$48,314
$9,973
4.2%
20.5%
Point Sources
RE
495
1
$2,043
$4,108
$2,936
49.7%
69.6%
Point Sources
RE
509
1
$2,043
$5,706
$2,587
35.8%
79.0%
Point Sources
RE
516
1
$2,043
$3,917
$3,412
52.2%
59.9%
Point Sources
RE
517
32
$2,043
$9,839
$8,410
20.8%
24.3%
Point Sources
RE
721
1
$2,043
$408
$278
501.4%
734.8%
Point Sources
RE
971
3
$2,043
$475,435,160
0.0%
Process Heaters - Dist. Oil
LNB + SCR
822
1
$2
$8,662
$560
0.0%
0.3%
Process Heaters - Nat. Gas
LNB + SCR
333
1
$104
$74,465
$4,050
0.1%
2.6%
Process Heaters - Nat. Gas
LNB + SCR
362
1
$104
$10,107
$1,967
1.0%
5.3%
Process Heaters - Nat. Gas
LNB + SCR
363
1
$104
$15,823
$1,850
0.7%
5.6%
Process Heaters - Nat. Gas
LNB + SCR
371
1
$104
$38,564
$2,267
0.3%
4.6%
Process Heaters - Nat. Gas
LNB + SCR
822
1
$104
$8,662
$560
1.2%
18.5%
Util. Boiler - Oil-Gas/Tanq.
SCR
491
2
$2,819
$33,269
$10,705
8.5%
26.3%
D-16
-------
Number of
Average
Annual
Average
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Stationary Area Sources
Adhesives - industrial
RACT
289
498
$8
$8,863
$5,318
0.1%
0.1%
CARB Tier 2
Aerosols
Standards -
Reform
285
70
$18
$13,724
$6,287
0.1%
0.3%
SCAQMD
Aerosols
Standards -
Reformulati
285
70
$1,088
$13,724
$6,287
7.9%
17.3%
Aircraft surface coating
Add-on control
372
261
$1,531
$80,938
$2,963
1.9%
51.7%
Area Source Ind. Coal Comb
RACT (small)
144
15
$13
$1,509
$1,331
0.9%
1.0%
Area Source Ind. Coal Comb
RACT (small)
201
30
$13
$19,290
$5,527
0.1%
0.2%
Area Source Ind. Coal Comb
RACT (small)
202
14
$13
$13,315
$5,007
0.1%
0.3%
Area Source Ind. Coal Comb
RACT (small)
203
13
$13
$11,814
$3,495
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
204
19
$13
$9,583
$3,428
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
206
4
$13
$7,010
$2,669
0.2%
0.5%
Area Source Ind. Coal Comb
RACT (small)
207
2
$13
$43,948
$21,299
0.0%
0.1%
Area Source Ind. Coal Comb
RACT (small)
208
9
$13
$14,053
$3,686
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
225
10
$13
$5,310
$1,968
0.2%
0.7%
Area Source Ind. Coal Comb
RACT (small)
226
6
$13
$13,299
$2,913
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
229
10
$13
$8,724
$2,628
0.2%
0.5%
Area Source Ind. Coal Comb
RACT (small)
243
72
$13
$4,640
$1,918
0.3%
0.7%
Area Source Ind. Coal Comb
RACT (small)
251
53
$13
$5,396
$1,773
0.2%
0.7%
Area Source Ind. Coal Comb
RACT (small)
262
2
$13
$145,607
$17,287
0.0%
0.1%
Area Source Ind. Coal Comb
RACT (small)
267
19
$13
$17,201
$4,114
0.1%
0.3%
Area Source Ind. Coal Comb
RACT (small)
281
13
$13
$22,955
$7,204
0.1%
0.2%
Area Source Ind. Coal Comb
RACT (small)
282
3
$13
$111,791
$16,963
0.0%
0.1%
Area Source Ind. Coal Comb
RACT (small)
283
15
$13
$22,363
$3,008
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
284
9
$13
$12,882
$2,980
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
286
1
$13
$90,160
$13,860
0.0%
0.1%
Area Source Ind. Coal Comb
RACT (small)
287
6
$13
$9,998
$3,481
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
289
23
$13
$8,863
$5,318
0.1%
0.2%
Area Source Ind. Coal Comb
RACT (small)
301
4
$13
$99,723
$3,747
0.0%
0.3%
Area Source Ind. Coal Comb
RACT (small)
306
11
$13
$9,416
$3,076
0.1%
0.4%
Area Source Ind. Coal Comb
RACT (small)
308
98
$13
$5,716
$2,556
0.2%
0.5%
Area Source Ind. Coal Comb
RACT (small)
311
4
$13
$6,984
$3,001
0.2%
0.4%
Area Source Ind. Coal Comb
RACT (small)
324
1
$13
$27,047
$8,944
0.1%
0.1%
Area Source Ind. Coal Comb
RACT (small)
326
20
$13
$3,426
$859
0.4%
1.5%
Area Source Ind. Coal Comb
RACT (small)
327
76
$13
$3,400
$2,338
0.4%
0.6%
Area Source Ind. Coal Comb
RACT (small)
331
9
$13
$49,452
$5,095
0.0%
0.3%
Area Source Ind. Coal Comb
RACT (small)
334
6
$13
$13,040
$8,343
0.1%
0.2%
Area Source Ind. Coal Comb
RACT (small)
346
25
$13
$9,507
$2,730
0.1%
0.5%
Area Source Ind. Coal Comb
RACT (small)
351
1
$13
$17,804
$1,779
0.1%
0.7%
Area Source Ind. Coal Comb
RACT (small)
353
20
$13
$6,416
$2,160
0.2%
0.6%
Area Source Ind. Coal Comb
RACT (small)
354
81
$13
$2,260
$1,154
0.6%
1.1%
Area Source Ind. Coal Comb
RACT (small)
362
16
$13
$10,107
$1,967
0.1%
0.7%
Area Source Ind. Coal Comb
RACT (small)
363
9
$13
$15,823
$1,850
0.1%
0.7%
Area Source Ind. Coal Comb
RACT (small)
371
49
$13
$38,564
$2,267
0.0%
0.6%
Area Source Ind. Coal Comb
RACT (small)
374
3
$13
$23,567
$5,656
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
131
3
$9
$7,430
$3,265
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
147
2
$9
$9,468
$610
0.1%
1.5%
Area Source Ind. NG Comb
RACT (small)
201
38
$9
$19,290
$5,527
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
202
19
$9
$13,315
$5,007
0.1%
0.2%
D-17
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Area Source Ind. NG Comb
RACT (small)
203
16
$9
$11,814
$3,495
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
204
17
$9
$9,583
$3,428
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
205
42
$9
$6,172
$1,208
0.2%
0.8%
Area Source Ind. NG Comb
RACT (small)
206
6
$9
$7,010
$2,669
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
207
6
$9
$43,948
$21,299
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
208
21
$9
$14,053
$3,686
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
209
51
$9
$10,134
$3,348
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
222
6
$9
$17,327
$2,548
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
223
5
$9
$22,019
$2,238
0.0%
0.4%
Area Source Ind. NG Comb
RACT (small)
226
12
$9
$13,299
$2,913
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
229
17
$9
$8,724
$2,628
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
249
42
$9
$3,325
$1,862
0.3%
0.5%
Area Source Ind. NG Comb
RACT (small)
262
3
$9
$145,607
$17,287
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
263
3
$9
$96,730
$21,071
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
265
63
$9
$13,215
$5,965
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
267
56
$9
$17,201
$4,114
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
275
594
$9
$2,058
$1,120
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
280
256
$9
$21,178
$4,833
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
281
27
$9
$22,955
$7,204
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
282
7
$9
$111,791
$16,963
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
283
21
$9
$22,363
$3,008
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
284
63
$9
$12,882
$2,980
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
285
34
$9
$13,724
$6,287
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
286
11
$9
$90,160
$13,860
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
287
6
$9
$9,998
$3,481
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
289
67
$9
$8,863
$5,318
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
291
3
$9
$553,301
$42,456
0.0%
0.0%
Area Source Ind. NG Comb
RACT (small)
295
32
$9
$6,445
$4,657
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
299
4
$9
$9,142
$6,903
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
301
3
$9
$99,723
$3,747
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
306
15
$9
$9,416
$3,076
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
308
172
$9
$5,716
$2,556
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
322
2
$9
$22,318
$1,275
0.0%
0.7%
Area Source Ind. NG Comb
RACT (small)
323
20
$9
$5,523
$1,746
0.2%
0.5%
Area Source Ind. NG Comb
RACT (small)
325
7
$9
$6,826
$3,735
0.1%
0.2%
Area Source Ind. NG Comb
RACT (small)
326
12
$9
$3,426
$859
0.3%
1.1%
Area Source Ind. NG Comb
RACT (small)
327
148
$9
$3,400
$2,338
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
329
22
$9
$8,551
$2,894
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
331
13
$9
$49,452
$5,095
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
332
6
$9
$8,205
$1,747
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
333
1
$9
$74,465
$4,050
0.0%
0.2%
Area Source Ind. NG Comb
RACT (small)
334
6
$9
$13,040
$8,343
0.1%
0.1%
Area Source Ind. NG Comb
RACT (small)
335
19
$9
$36,514
$6,961
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
339
5
$9
$3,490
$2,182
0.3%
0.4%
Area Source Ind. NG Comb
RACT (small)
341
9
$9
$30,750
$10,316
0.0%
0.1%
Area Source Ind. NG Comb
RACT (small)
344
175
$9
$4,375
$2,469
0.2%
0.4%
Area Source Ind. NG Comb
RACT (small)
346
31
$9
$9,507
$2,730
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
348
5
$9
$11,888
$1,003
0.1%
0.9%
Area Source Ind. NG Comb
RACT (small)
349
102
$9
$4,404
$1,989
0.2%
0.5%
Area Source Ind. NG Comb
RACT (small)
352
15
$9
$7,232
$1,480
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
353
33
$9
$6,416
$2,160
0.1%
0.4%
D-18
-------
Average
Average
Number of
Annual
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Area Source Ind. NG Comb
RACT (small)
357
40
$9
$15,064
$2,497
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
358
26
$9
$15,967
$2,683
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
361
15
$9
$15,868
$2,716
0.1%
0.3%
Area Source Ind. NG Comb
RACT (small)
362
15
$9
$10,107
$1,967
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
363
3
$9
$15,823
$1,850
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
364
17
$9
$13,071
$2,463
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
365
9
$9
$8,303
$1,766
0.1%
0.5%
Area Source Ind. NG Comb
RACT (small)
367
67
$9
$7,130
$1,627
0.1%
0.6%
Area Source Ind. NG Comb
RACT (small)
371
61
$9
$38,564
$2,267
0.0%
0.4%
Area Source Ind. NG Comb
RACT (small)
372
14
$9
$80,938
$2,963
0.0%
0.3%
Area Source Ind. NG Comb
RACT (small)
386
12
$9
$18,748
$2,271
0.1%
0.4%
Area Source Ind. NG Comb
RACT (small)
391
6
$9
$2,468
$1,090
0.4%
0.8%
Area Source Ind. NG Comb
RACT (small)
399
89
$9
$1,858
$1,009
0.5%
0.9%
Area Source Ind. Oil Comb
RACT (small)
201
30
$17
$19,290
$5,527
0.1%
0.3%
Area Source Ind. Oil Comb
RACT (small)
203
13
$17
$11,814
$3,495
0.1%
0.5%
Area Source Ind. Oil Comb
RACT (small)
204
19
$17
$9,583
$3,428
0.2%
0.5%
Area Source Ind. Oil Comb
RACT (small)
205
30
$17
$6,172
$1,208
0.3%
1.4%
Area Source Ind. Oil Comb
RACT (small)
206
4
$17
$7,010
$2,669
0.2%
0.6%
Area Source Ind. Oil Comb
RACT (small)
207
2
$17
$43,948
$21,299
0.0%
0.1%
Area Source Ind. Oil Comb
RACT (small)
208
9
$17
$14,053
$3,686
0.1%
0.5%
Area Source Ind. Oil Comb
RACT (small)
209
29
$17
$10,134
$3,348
0.2%
0.5%
Area Source Ind. Oil Comb
RACT (small)
221
5
$17
$£>,356
$1,197
0.1%
1.4%
Area Source Ind. Oil Comb
RACT (small)
223
1
$17
$22,019
$2,238
0.1%
0.7%
Area Source Ind. Oil Comb
RACT (small)
224
4
$17
$6,649
$2,231
0.3%
0.7%
Area Source Ind. Oil Comb
RACT (small)
226
6
$17
$13,299
$2,913
0.1%
0.6%
Area Source Ind. Oil Comb
RACT (small)
229
10
$17
$8,724
$2,628
0.2%
0.6%
Area Source Ind. Oil Comb
RACT (small)
233
15
$17
$4,358
$1,950
0.4%
0.9%
Area Source Ind. Oil Comb
RACT (small)
249
28
$17
$3,325
$1,862
0.5%
0.9%
Area Source Ind. Oil Comb
RACT (small)
251
53
$17
$5,396
$1,773
0.3%
0.9%
Area Source Ind. Oil Comb
RACT (small)
262
2
$17
$145,607
$17,287
0.0%
0.1%
Area Source Ind. Oil Comb
RACT (small)
265
22
$17
$13,215
$5,965
0.1%
0.3%
Area Source Ind. Oil Comb
RACT (small)
267
19
$17
$17,201
$4,114
0.1%
0.4%
Area Source Ind. Oil Comb
RACT (small)
271
72
$17
$6,017
$1,303
0.3%
1.3%
Area Source Ind. Oil Comb
RACT (small)
275
316
$17
$2,058
$1,120
0.8%
1.5%
Area Source Ind. Oil Comb
RACT (small)
281
13
$17
$22,955
$7,204
0.1%
0.2%
Area Source Ind. Oil Comb
RACT (small)
282
3
$17
$111,791
$16,963
0.0%
0.1%
Area Source Ind. Oil Comb
RACT (small)
283
15
$17
$22,363
$3,008
0.1%
0.6%
Area Source ind. Oil Comb
RACT (small)
284
9
$17
$12,882
$2,980
0.1%
0.6%
Area Source Ind. Oil Comb
RACT (small)
286
1
$17
$90,160
$13,860
0.0%
0.1%
Area Source Ind. Oil Comb
RACT (small)
287
6
$17
$9,998
$3,481
0.2%
0.5%
Area Source Ind. Oil Comb
RACT (small)
289
23
$17
$8,863
$5,318
0.2%
0.3%
Area Source Ind. Oil Comb
RACT (small)
295
14
$17
$6,445
$4,657
0.3%
0.4%
Area Source Ind. Oil Comb
RACT (small)
301
4
$17
$99,723
$3,747
0.0%
0.4%
Area Source Ind. Oil Comb
RACT (small)
305
2
$17
$10,588
$3,246
0.2%
0.5%
Area Source Ind. Oil Comb
RACT (small)
306
11
$17
$9,416
$3,076
0.2%
0.5%
Area Source Ind. Oil Comb
RACT (small)
308
98
$17
$5,716
$2,556
0.3%
0.7%
Area Source Ind. Oil Comb
RACT (small)
311
4
$17
$6,984
$3,001
0.2%
0.6%
Area Source Ind. Oil Comb
RACT (small)
329
8
$17
$8,551
$2,894
0.2%
0.6%
Area Source Ind. Oil Comb
RACT (small)
331
9
$17
$49,452
$5,095
0.0%
0.3%
Area Source Ind. Oil Comb
RACT (small)
334
6
$17
$13,040
$8,343
0.1%
0.2%
Area Source Ind. Oil Comb
RACT (small)
335
6
$17
$36,514
$6,961
0.1%
0.2%
D-19
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
. ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Area Source Ind. 0
1 Comb
RACT (small)
339
11
$17
$3,490
$2,182
0.5%
0.8%
Area Source Ind. 0
1 Comb
RACT (small)
342
13
$17
$7,887
$2,003
0.2%
0.8%
Area Source Ind. 0
1 Comb
RACT (small)
343
6
$17
$8,638
$2,429
0.2%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
344
118
$17
$4,375
$2,469
0.4%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
348
9
$17
$11,888
$1,003
0.1%
1.7%
Area Source Ind. 0
1 Comb
RACT (small)
351
1
$17
$17,804
$1,779
0.1%
0.9%
Area Source Ind. 0
1 Comb
RACT (small)
353
20
$17
$6,416
$2,160
0.3%
0.8%
Area Source Ind. 0
1 Comb
RACT (small)
356
18
$17
$5,377
$2,069
0.3%
0.8%
Area Source Ind. 0
1 Comb
RACT (small)
357
11
$17
$15,064
$2,497
0.1%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
358
15
$17
$15,967
$2,683
0.1%
0.6%
Area Source Ind. 0
1 Comb
RACT (small)
359
146
$17
$1,171
$769
1.4%
2.2%
Area Source Ind. 0
1 Comb
RACT (small)
361
2
$17
$15,868
$2,716
0.1%
0.6%
Area Source Ind. 0
1 Comb
RACT (small)
362
16
$17
$10,107
$1,967
0.2%
0.8%
Area Source Ind. 0
1 Comb
RACT (small)
366
13
$17
$12,188
$2,437
0.1%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
367
33
$17
$7,130
$1,627
0.2%
1.0%
Area Source Ind. 0
1 Comb
RACT (small)
369
17
$17
$12,090
$1,472
0.1%
1.1%
Area Source Ind. 0
1 Comb
RACT (small)
371
49
$17
$38,564
$2,267
0.0%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
372
8
$17
$80,938
$2,963
0.0%
0.6%
Area Source Ind. 0
1 Comb
RACT (small)
373
57
$17
$9,088
$1,459
0.2%
1.1%
Area Source Ind. 0
1 Comb
RACT (small)
376
1
$17
$316,586
$5,142
0.0%
0.3%
Area Source Ind. 0
1 Comb
RACT (small)
384
30
$17
$10,100
$2,241
0.2%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
386
2
$17
$18,748
$2,271
0.1%
0.7%
Area Source Ind. 0
1 Comb
RACT (small)
391
7
$17
$2,468
$1,090
0.7%
1.5%
Area Source Ind. 0
1 Comb
RACT (small)
393
6
$17
$2,545
$1.225
0.7%
1.4%
Automobile refinish
ng
CARB
BARCT limits
753
2785
$1
$473
$454
0.1%
0.1%
Automobile refinishing
FIP Rule
(VOC Content
& TE)
753
17177
$13
$473
$454
2.7%
2.8%
Bulk Terminals
RACT
517
1204
$3
$9,839
$8,410
0.0%
0.0%
Marine Surface Coating
Add-on control
373
265
$693
$9,088
$1,459
7.6%
47.5%
Metal prod, surface coating
VOC limits
341
124
$1
$30,750
$10,316
0.0%
0.0%
Metal prod, surface coating
VOC limits
349
1919
$1
$4,404
$1,989
0.0%
0.1%
Metal prod, surface coating
VOC limits
371
734
$1
$38,564
$2,267
0.0%
0.1%
Metal prod, surface coating
VOC limits
375
34
$1
$7,336
$2,049
0.0%
0.1%
Metal prod, surface coating
VOC limits
376
31
$1
$316,586
$5,142
0.0%
0.0%
Metal prod, surface coating
VOC limits
381
197
$1
$50,989
$2,025
0.0%
0.1%
Metal prod, surface coating
VOC limits
382
860
$1
$9,496
$2,342
0.0%
0.0%
Metal prod, surface coating
VOC limits
384
745
$1
$10,100
$2,241
0.0%
0.1%
Metal prod, surface coating
VOC limits
385
104
$1
$12,731
$2,587
0.0%
0.0%
Metal prod, surface coating
VOC limits
386
205
$1
$18,748
$2,271
0.0%
0.1%
Metal prod, surface coating
VOC limits
387
33
$1
$18,684
$2,833
0.0%
0.0%
Metal prod, surface coating
VOC limits
391
654
$1
$2,468
$1.090
0.0%
0.1%
Metal prod, surface coating
VOC limits
393
90
$1
$2,545
$1,225
0.0%
0.1%
Metal prod, surface coating
VOC limits
394
525
$1
$4,191
$1,938
0.0%
0.1%
Metal prod, surface coating
VOC limits
395
219
$1
$3,227
$1,294
0.0%
0.1%
Metal prod, surface coating
VOC limits
396
413
$1
$2,604
$1,126
0.0%
0.1%
Metal prod, surface coating
VOC limits
399
1611
$1
$1,858
$1,009
0.1%
0.1%
Misc. surface coating
Add-on control
251
523
$934
$5,396
$1,773
17.3%
52.7%
Misc. surface coating
Add-on control
252
150
$934
$12,698
$2,271
7.4%
41.1%
Misc. surface coating
Add-on control
342
¦ 445
$934
$7,887
$2,003
11.8%
46.6%
Misc. surface coating
Add-on control
343
149
$934
$8,638
$2,429
10.8%
38.4%
D-20
-------
Number of
Average
Annual
Average
Annual
Total
Average
Sales per
Sales per
Cost-to-
Cost-to-
Establish-
Cost per
Establish-
Establish-
Sales
Sales
Control
SIC
ments
Establish-
ment
ment
Ratio
Ratio
Source Category
Measure
Code
Affected
ment
(All)
(Small)
(All)
(Small)
Misc. surface coating
Add-on control
344
2012
$934
$4,375
$2,469
21.3%
37.8%
Misc. surface coating
Add-on control
345
556
$934
$3,649
$2,234
25.6%
41.8%
Misc. surface coating
Add-on control
346
841
$934
$9,507
$2,730
9.8%
34.2%
Misc. surface coating
Add-on control
347
1139
$934
$2,015
$1,371
46.3%
68.1%
Misc. surface coating
Add-on control
348
51
$934
$11,888
$1,003
7.9%
93.1%
Misc. surface coating
Add-on control
349
1598
$934
$4,404
$1,989
21.2%
46.9%
Misc. surface coating
Add-on control
363
80
$934
$15,823
$1,850
5.9%
50.5%
Misc. surface coating
Add-on control
371
591
$934
$38,564
$2,267
2.4%
41.2%
Misc. surface coating
MACT control
351
34
$29
$17,804
$1,779
0.2%
1.7%
Misc. surface coating
MACT control
352
137
$29
$7,232
$1,480
0.4%
2.0%
Misc. surface coating
MACT control
353
473
$29
$6,416
$2,160
0.5%
1.4%
Misc. surface coating
MACT control
354
1795
$29
$2,260
$1,154
1.3%
2.6%
Misc. surface coating
MACT control
355
818
$29
$3,761
$1,743
0.8%
1.7%
Misc. surface coating
MACT control
356
698
$29
$5,377
$2,069
0.6%
1.4%
Misc. surface coating
MACT control
357
390
$29
$15,064
$2,497
0.2%
1.2%
Misc. surface coating
MACT control
358
401
$29
$15,967
$2,683
0.2%
1.1%
Misc. surface coating
MACT control
359
3338
$29
$1,171
$769
2.5%
3.8%
Misc. surface coating
MACT control
361
137
$29
$15,868
$2,716
0.2%
1.1%
Misc. surface coating
MACT control
362
369
$29
$10,107
$1,967
0.3%
1.5%
Misc. surface coating
MACT control
363
77
$29
$15,823
$1,850
0.2%
1.6%
Misc. surface coating
MACT control
364
345
$29
$13,071
$2,463
0.2%
1.2%
Misc. surface coating
MACT control
365
132
$29
$8,303
$1,766
0.4%
1.7%
Misc. surface coating
MACT control
366
386
$29
$12,188
$2,437
0.2%
1.2%
Misc. surface coating
MACT control
367
1102
$29
$7,130
$1,627
0.4%
1.8%
Misc. surface coating
MACT control
369
353
$29
$12,090
$1,472
0.2%
2.0%
Misc. surface coating
MACT control
374
48
$29
$23,567
$5,656
0.1%
0.5%
Oil and natural gas
production fields
RACT
(equipment /
maintenance)
131
1077
$0
$7,430
$3,265
0.0%
0.0%
Oil and natural gas
production fields
RACT
(equipment/
maintenance)
132
37
$0
$34,275
$33,078
0.0%
0.0%
Oil and natural gas
production fields
RACT
(equipment /
maintenance)
138
997
$0
$820
$501
0.0%
0.0%
Paper surface coating
Add-on control
267
497
$2,319
$17,201
$4,114
13.5%
56.4%
Pesticide Application
Reformulation
- FIP rule
287
99
$281
$9,998
$3,481
2.8%
8.1%
Pharmaceutical mfg.
RACT
283
42
$1
$22,363
$3,008
0.0%
0.0%
Serv. stns - stage 1-truck
P-V valves
554
17324
$0
$1,458
$1,191
0.0%
0.0%
SOCMI batch reactors
New CTG
286
9
$48
$90,160
$13,860
0.1%
0.4%
SOCMI fugitives
RACT
286
10
$1
$90,160
$13,860
0.0%
0.0%
Wood furniture surf coating
Reformulation
251
704
$16
$5,396
$1,773
0.3%
0.9%
Wood furniture surf coating
Reformulation
252
200
$16
$12,698
$2,271
0.1%
0.7%
Wood furniture surf coating
Reformulation
254
527
$16
$3,779
$1,958
0.4%
0.8%
Wood product surf coating
Reformulation
242
561
$1
$4,830
$2,310
0.0%
0.1%
Wood product surf coating
Reformulation
243
1500
$1
$4,640
$1,918
0.0%
0.1%
Wood product surf coating
Reformulation
244
288
$1
$1,666
$1,298
0.1%
0.1%
Wood product surf coating
Reformulation
245
152
$1
$9,840
$3,971
0.0%
0.0%
Wood product surf coating
Reformulation
249
550
$1
$3,325
$1,862
0.0%
0.1%
Nonroad Vehicles
Comm. Marine Vessels
Emission Fees
444
2
$757
$11,446
$5,081
6.6%
14.9%
D-21
-------
Source Category
Control
Measure
SIC
Code
Number of
Total
Establish-
ments
Affected
Average
Cost per
Establish-
ment
Average
Annual
Sales per
Establish-
ment
(All)
Average
Annual
Sales per
Establish-
ment
(Small)
Cost-to-
Sales
Ratio
(All)
Cost-to-
Sales
Ratio
(Small)
Nonroad Diesels
CARB Stds
for >175 HP
351
1
$4,104
$17,804
$1,779
23.1%
230.7%
Nonroad gasoline
Ref. gasoline
291
1
$1,626
$553,301
$42,456
0.3%
3.8%
Recreational vehicles
CARB stds
375
17
$51
$7,336
$2,049
0.7%
2.5%
Recreational vehicles
CARB stds
379
74
$51
$9,164
$2,426
0.6%
2.1%
Onroad Vehicles
Motor Vehicles
California LEV
371
406
$61
$38,564
$2,267
0.2%
2.7%
Motor Vehicles
Cal. Reform
291
18
$47,215
$553,301
$42,456
8.5%
111.2%
Motor Vehicles
Fed. Reform
291
8
$10,658
$553,301
$42,456
1.9%
25.1%
Motor Vehicles
Reform Diesel
291
3
$15,261
$553,301
$42,456
2.8%
36.0%
D-22
-------
APPENDIX E
SUMMARY OF HEALTH EFFECTS AND MONETIZED HEALTH BENEFITS
RESULTS
FOR ALTERNATIVE OZONE NAAQS
-------
Table E-l
Quantifiable Clinical Health End-Points
Health End-Point
Study
DFEV! ^10%; 15%; and 20%
Avol et al., 1984
Kulle et al., 1985
McDonnell et al., 1983
Seal et al., 1993
Folinsbee et al., 1988; Horstman et al., 1990; and
McDonnell et al., 1991
Any Lower Respiratory Symptom
Avol et al., 1984
Moderate/Severe Lower
Respiratory Symptom
Avol et al., 1984
Any Cough; Moderate/Severe
Cough; PDF; Moderate/Severe
PDI
Kulle et al., 1985
McDonnell et al., 1983
Seal et al., 1993
Folinsbee et al., 1988; Horstman et al., 1990; and
McDonnell et al., 1991
1 DFEV[ means forced expiratory volume (in 1 second) decrement
2 PDI = Pain Upon Deep Inhalation
E-2
-------
Table E-2
Quantifiable Epidemiological Health Endpoints
Health End-Point
Study
Mortality
Dockery et al., 1992
Dockery et al., 1992
Kinney et al., 1995
Moolgavkar et al., 1995
Hospital Admissions: All Respiratory
Elnesses
Schwartz, 1995
Daily Respiratory Admissions
Thurston et al., 1994
Hospital Admission: Pneumonia
Schwartz, 1994a
Schwartz, 1994b
Schwartz, 1994c
Hospital Admissions: COPD
Schwartz, 1994a
Schwartz, 1994b
Presence of Any of 19 Acute Respiratory
Symptoms
Krupnick et al., 1990
Self-Reported Asthma Attacks
Whittemore and Korn, 1980 and U.S. EPA,
1993
Respiratory and Non-Respiratory
Conditions Resulting in a Minor Restricted
Activity Day (MRAD)
Ostro and Rothschild, 1989
Respiratory Restricted Activity Days
Ostro and Rothschild, 1989
Sinusitis and Hay Fever
Portney and Mullahy, 1990
Worker Productivity (resulting in changes
in daily wages)
Estimated using data from Crocker and Horst
(1981) and U.S. EPA, 1994c
Development of Definite Asthma
Abbey et al., 1995a; 1993
E-3
-------
TABLE E-3
Clinical Health Effects Reductions Per Year (Year =.2007)
Regional Controls Strategies Baseline
.12 ppm, 1-Hour, 1 Exceedance Standard
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV a 10%
3,860,000
6,474,000
9,295,000
1,087,000
1,747,000
2,459,000
DFEV i 15%
1,936,000
4,962,000
8,234,000
551,000
1,334,000
2,184,000
DFEV 2 20%
1,188,000
2,601,000
4,188,000
339,000
711,000
1,134,000
Any Cough1
5,231,000
6,693,000
8,155,000
1,475,000
1,825,000
2,174,000
Moderate to Severe Cough
459,000
1,102,000
1,745,000
189,000
359,000
528,000
Pain Upon Deep
Inhalation1
7,246,000
12,662,000
18,077,000
1,972,000
3,375,000
4,777,000
Moderate to Severe Pain
Upon Deep Inhalation
747,000
1,404,000
2,059,000
300,000
436,000
571,000
Lower Respiratory
Symptoms1
870,000
242,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
includes moderate and severe lower respiratory symptoms.
E-4
-------
TABLE E-4
Clinical Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.12 ppm, 1-Hour, I Exceedance Standard
Health Endpolnt
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV 2 10%
4,520,000
7,559,000
10,839,000
1,498,000
2,421,000
3,418,000
DFEV a 15%
2,264,000
5,788,000
9,595,000
756,000
1,851,000
3,033,000
DFEV 2 20%
1,389,000
3,030,000
4,868,000
465,000
983,000
1,566,000
Any Cough1
6,103,000
7,832,000
9,561,000
2,018,000
2,532,000
3,046,000
Moderate to Severe Cough
520,000
1,285,000
2,049,000
234,000
477,000
720,000
Pain Upon Deep
Inhalation2
8,533,000
14,836,000
21,139,000
2,760,000
4,715,000
6,670,000
Moderate to Severe Pain
Upon Deep Inhalation
881,000
1,649,000
2,417,000
391,000
591,000
791,000
Lower Respiratory
Symptoms3
1,005,000
327,000
Moderate to Severe Lower
Respiratory Symptoms
126
126
'Includes moderate and severe cough.
includes moderate and severe PDI.
includes moderate and severe lower respiratory symptoms.
E-5
-------
TABLE E-S
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.12 ppm, 1-Hour, 1 Eiceedance Standard
Health Endpolnt
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NE2
510
0
NE
130
Hospital Admissions: All
Respiratory Illnesses3
230
430
620
60
120
170
Hospital Admissions:
Pneumonia
80
110
160
20
30
40
Hospital Admissions: COPD
40
100
170
10
30
40
Presence of Any of 19 Acute
Respiratory Symptoms
300,300
79,190
Self-Reported Asthma
Attacks
230
60
Sinusitis and Hay Fever
107,260
28,130
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-6
-------
TABLE E-6
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
• 12ppm, 1-Hour, 1 Exceedance Standard
Health Endpoint
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NE2
610
0
NE
190
Hospital Admissions: All
Respiratory Illnesses3
280
530
760
90
170
250
Hospital Admissions:
Pneumonia
100
130
190
30
40
60
Hospital Admissions: COPD
50
130
200
10
40
60
Presence of Any of 19 Acute
Respiratory Symptoms
357,440
112,790
Self-Reported Asthma
Attacks
280
90
Sinusitis and Hay Fever
127,780
40,280
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
3Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-7
-------
TABLE E-7
Clinical Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, S Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV i 10%
1,206,000
2,412,000
3,663,000
640,000
1,174,000
1,736,000
DFEV i 15%
571,000
1,822,000
3,107,000
312,000
901,000
1,519,000
DFEV i 20%
352,000
829,000
1,321,000
192,000
446,000
717,000
Any Cough1
1,476,000
2,183,000
2,891,000
826,000
1,163,000
1,499,000
Moderate to Severe Cough
8,000
240,000
471,000
39,000
163,000
287,000
Pain Upon Deep
Inhalation1
2,730,000
5,161,000
7,592,000
1,625,000
2,427,000
3,530,000
Moderate to Severe Pain
Upon Deep Inhalation
39,000
378,000
717,000
94,000
227,000
360,000
Lower Respiratory
Symptoms'
150,000
108,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
'Includes moderate and severe lower respiratory symptoms.
E-8
-------
TABLE E-8
Clinical Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV 2 10%
1,424,000
2,846,000
4,316,000
704,000
1,311,000
1,943,000
DFEV 2 15%
673,000
2,147,000
3,661,000
342,000
1,001,000
1,690,000
DFEV 2 20%
415,000
971,000
1,542,000
210,000
483,000
774,000
Any Cough1
1,738,000
2,574,000
3,411,000
902,000
1,274,000
1,647,000
Moderate to Severe Cough
10,000
284,000
559,000
40,000
177,000
313,000
Pain Upon Deep
Inhalation1
3,246,000
6,118,000
8,990,000
1,491,000
2,741,000
3,991,000
Moderate to Severe Pain
Upon Deep Inhalation
43,000
447,000
850,000
94,000
248,000
402,000
Lower Respiratory
Symptoms1
172,000
112,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
includes moderate and severe lower respiratory symptoms.
E-9
-------
TABLE E-9
Clinical Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 1 Exceedance Standard
(Estimates are Incremental from the current standard)
Health Endpolnt
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV i 10%
2,416,000
4,909,000
7,461,000
1,323,000
2,589,000
3,889,000
DFEV i 15%
1,136,000
3,702,000
6,323,000
631,000
1,966,000
3,341,000
DFEV k 20%
701,000
1,635,000
2,591,000
389,000
904,000
1,441,000
Any Cough1
2,734,000
4,381,000
6,028,000
1,580,000
2,419,000
3,257,000
Moderate to Severe Cough
11,000
484,000
956,000
42,000
302,000
563,000
Pain Upon Deep
Inhalation11
5,642,000
10,703,000
15,763,000
2,970,000
5,570,000
8,170,000
Moderate to Severe Pain
Upon Deep Inhalation
55,000
761,000
1,467,000
106,000
445,000
784,000
Lower Respiratory
Symptoms
252,000
167,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
includes moderate and severe lower respiratory symptoms.
E-10
-------
TABLE E-10
Clinical Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 5 Exceed a nee Standard
(Estimates are Incremental from the current standard)
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV a 10%
1,690,000
3,351,000
5,075,000
915,000
1,721,000
2,564,000
DFEV a 15%
801,000
2,544,000
4,338,000
444,000
1,326,000
2,247,000
DFEV 2 20%
493,000
1,178,000
1,883,000
273,000
654,000
1,058,000
Any Cough1
2,075,000
3,096,000
4,117,000
1,171,000
1,690,000
2,209,000
Moderate to Severe Cough
10,000
340,000
671,000
46,000
226,000
406,000
Pain Upon Deep
Inhalation"
3,804,000
7,151,000
10,499,000
1,925,000
3,573,000
5,221,000
Moderate to Severe Pain
Upon Deep Inhalation
60,000
530,000
1,000,000
114,000
317,000
520,000
Lower Respiratory
Symptoms
216,000
149,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
'Includes moderate and severe lower respiratory symptoms.
E-ll
-------
TABLE E-ll
Clinical Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Excecdance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV 2 10%
2,000,000
3,973,000
6,013,000
1,049,000
1,990,000
2,972,000
DFEV 2 15%
949,000
3,014,000
5,138,000
507,000
1,531,000
2,596,000
DFEV 2 20%
584,000
1,390,000
2,219,000
312,000
749,000
1,210,000
Any Cough1
2,454,000
3,672,000
4,890,000
1,337,000
1,943,000
2,550,000
Moderate to Severe Cough
12,000
405,000
798,000
48,000
255,000
462,000
Pain Upon Deep
Inhalation11
4,531,000
8,509,000
12,488,000
2,230,000
4,157,000
6,085,000
Moderate to Severe Pain
Upon Deep Inhalation
69,000
629,000
1,189,000
121,000
361,000
600
Lower Respiratory
Symptoms
250,000
165,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
'Includes moderate and severe lower respiratory symptoms.
E-12
-------
TABLE E-12
Clinical Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 1 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidence-Days Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
DFEV a 10%
3,366,000
6,778,000
10,283,000
1,795,000
3,519,000
5,302,000
DFEV a 15%
1,586,000
5,134,000
8,763,000
858,000
2,691,000
4,583,000
DFEV 2 20%
978,000
2,321,000
3,694,000
528,000
1,269,000
2,041,000
Any Cough1
3,995,000
6,185,000
8,375,000
2,324,000
3,340,000
4,356,000
Moderate to Severe Cough
15,000
679,000
1,343,000
50,000
407,000
765,000
Pain Upon Deep
Inhalation1
7,787,000
14,708,000
21,629,000
3,982,000
7,508,000
11,034,000
Moderate to Severe Pain
Upon Deep Inhalation
92,000
1,060,000
2,029,000
139,000
597,000
1,055,000
Lower Respiratory
Symptoms5
368,000
240,000
Moderate to Severe Lower
Respiratory Symptoms
0
0
'Includes moderate and severe cough.
includes moderate and severe PDI.
includes moderate and severe lower respiratory symptoms.
E-13
-------
TABLE E-13
Epidemiological Health EfTects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 5 Eiceedance Standard
(Estimates are incremental from the current standard)
Health Endpolnt
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NEl
220
0
NE
110
Hospital Admissions: AU
Respiratory Illnesses1
100
190
270
50
100
140
Hospital Admissions:
Pneumonia
40
50
70
20
20
40
Hospital Admissions: COPD
20
50
70
10
20
40
Presence of Any of 19 Acute
Respiratory Symptoms
131,960
59,530
Self-Reported Asthma
Attacks
100
50
Sinusitis and Hay Fever
46,030
22,290
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-14
-------
TABLE E-14
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NE2
260
0
NE
120
Hospital Admissions: All
Respiratory Illnesses3
120
230
320
60
110
160
Hospital Admissions:
Pneumonia
40
60
80
20
30
40
Hospital Admissions: COPD
20
60
90
10
30
40
Presence of Any of 19 Acute
Respiratory Symptoms
155,410
68,360
Self-Reported Asthma
Attacks
120
50
Sinusitis and Hay Fever
54,400
25,280
Development of Definite
Asthma
0
0
'Low estimate is result of Kenney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-15
-------
TABLE E-1S
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 1 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpolnt
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NE1
470
0
NE
250
Hospital Admissions: All
Respiratory Illnesses3
230
430
600
120
240
330
Hospital Admissions:
Pneumonia
80
110
160
40
60
80
Hospital Admissions: COPD
40
100
160
20
60
90
Presence of Any of 19 Acute
Respiratory Symptoms
275,430
141,720
Self-Reported Asthma
Attacks
210
110
Sinusitis and Hay Fever
96,790
51,640
Development of Definite
Asthma
0
0
lLow estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-16
-------
TABLE E-16
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 5 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NEJ
310
0
NE
160
Hospital Admissions: All
Respiratory Illnesses1
150
280
390
80
150
210
Hospital Admissions: COPD
50
70
100
30
40
50
Hospital Admissions:
Pneumonia
30
70
110
10
40
60
Presence of Any of 19 Acute
Respiratory Symptoms
179,070
85,480
Self-Reported Asthma
Attacks
140
70
Sinusitis and Hay Fever
64,060
32,400
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-17
-------
TABLE E-17
Epidemiological Health Effects Reductions Per Year (Year - 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Exceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NE2
370
0
NE
180
Hospital Admissions: All
Respiratory Illnesses1
180
340
480
90
170
250
Hospital Admissions:
Pneumonia
60
80
120
30
40
60
Hospital Admissions:
COPD
30
80
130
20
40
70
Presence of Any of 19 Acute
Respiratory Symptoms
214,290
99,930
Self-Reported Asthma
Attacks
170
80
Sinusitis and Hay Fever
76,760
37,870
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, High estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-18
-------
TABLE E-18
Epidemiological Health Effects Reductions Per Year (Year = 2007)
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 1 Esceedance Standard
(Estimates are incremental from the current standard)
Health Endpoint
Aggregated Total Incidences Reduced
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
0
NEl
660
0
NE
340
Hospital Admissions: All
Respiratory Illnesses1
330
630
890
175
330
480
Hospital Admissions:
Pneumonia
110
150
230
60
80
120
Hospital Admissions: COPD
60
150
240
30
80
130
Presence of Any of 19 Acute
Respiratory Symptoms
376,260
185,250
Self-Reported Asthma
Attacks
290
140
Sinusitis and Hay Fever
135,060
68,990
Development of Definite
Asthma
0
0
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-19
-------
TABLE E-19
Monetized Benefits for Clinical Approach
.12 ppm, 1-Hour, 1 Exceedance Standard
(1990 $)
Health Endpoint
REGIONAL CONTROL STRATEGIES BASELINE
Full Attainment Scenario
Partial Attainment Scenario
Cough
Low Estimate
$580,000
$240,000
Best Estimate
$7,710,000
$2,510,000
High Estimate
$24,150,000
$7,310,000
Pain Upon Deep Inhalation
Low Estimate
$9,130,000
$2,480,000
Best Estimate
$55,840,000
$14,880,000
High Estimate
$506,890,000
$1,333,960,000
Total Monetized Benefits
Low Estimate
$9,710,000
$2,720,000
Best Estimate
$63,550,000
$17,390,000
High Estimate
$531,030,000
$141,270,000
LI
DCAL CONTROL STRATEGIES BASELINE
Cough
Low Estimate
$7,690,000
$2,540,000
Best Estimate
$54,820,000
$17,720,000
High Estimate
$132,320,000
$42,160,000
Pain Upon Deep Inhalation
Low Estimate
$10,750,000
$3,480,000
Best Estimate
$65,430,000
$20,790,000
High Estimate
$592,730,000
$187,020,000
Total Monetized Benefits
Low Estimate
$18,440,000
$6,020,000
Best Estimate
$120,250,000
$38,520,000
High Estimate
$725,050,000
$229,180,000
E-20
-------
TABLE E-20
Monetized Benefits for Epidemiological Approach
Regional Controls Strategies Baseline
.12 ppm, 1-Hour, 1 Exceedance Standard
(1990 $)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
SO
NEJ
$2,459,973,000
SO
NE
$645,335,000
Hospital Admissions: All
Respiratory Illnesses1
$2,763,000
$5,198,000
$7,361,000
$736,000
$1,414,000
$2,018,000
Hospital Admissions:
Pneumonia
$1,182,000
$1,606,000
$2,373,000
$312,000
$425,000
$630,000
Hospital Admissions: COPD
$655,000
$1,611,000
$2,568,000
$173,000
$428,000
$683,000
Presence of Any of 19 Acute
Respiratory Symptoms
$1,117,000
$8,808,000
$16,498,000
$295,000
$2,323,000
$4,351,000
Self-Reported Asthma
Attacks
$3,000
$8,000
$12,000
$1,000
$2,000
$3,000
Worker Productivity
$860,000
$424,000
Total Monetized Benefits
$6,581,000
$18,091,000
$2,489,646,000
$1,941,000
$5,016,000
$653,444,000
"Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-21
-------
TABLE E-21
Monetized Benefits for Epidemiological Approach
Local Control Strategies Baseline
.12 ppm, 1-Hour, 1 Eiceedance Standard
(1990 $)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best. Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
SO
NE1
$2,938,005,000
$0
NE
$927,600,000
Hospital Admissions: All
Respiratory Illnesses3
$3,379,000
$6,398,000
$9,083,000
$1,072,000
$2,067,000
$2,956,000
Hospital Admissions:
Pneumonia
51,442,000
$1,960,000
$2,899,000
$454,000
$618,000
$917,000
Hospital Admissions: COPD
$799,000
$1,969,000
$3,138,000
$252,000
$622,000
$993,000
Presence of Any of 19 Acute
Respiratory Symptoms
$1,330,000
$10,484,000
$19,638,000
$420,000
$3,308,000
$6,197,000
Self-Reported Asthma
Attacks
$3,000
$9,000
$15,000
$1,000
$3,000
$5,000
Worker Productivity
$1,852,000
$1,172,000
Total Monetized Benefits
$8,806,000
$22,672,000
$2,974,629,000
$3,370,000
$7,791,000
$939,840,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-22
-------
TABLE E-22
Monetized Benefits for Clinical Approach
Regional Controls Strategies Baseline
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
.08 ppm, 8-Hour, S Exc.
.08 ppm, 8-Hour, 4 Exc.
.08 ppm, 8-Hour, 1 Exc.
Cough
Low Estimate
$10,000
$12,000
$14,000
Best Estimate
$1,680,000
$1,990,000
$3,380,000
High Estimate
$6,520,000
$7,740,000
$13,230,000
Pain Upon Deep
Inhalation
Low Estimate
$3,440,000
$4,090,000
$7,110,000
Best Estimate
$22,760,000
$26,980,000
$47,200,000
High Estimate
$212,880,000
$252,090,000
$442,000,000
Total Monetized
Benefits
Low Estimate
$3,450,000
$4,100,000
$7,120,000
Best Estimate
$24,440,000
$28,970,000
$50,580,000
High Estimate
$219,400,000
$259,830,000
$455,230,000
PA
RTIAL ATTAINMENT SCENAR
JO
Cough
Low Estimate
$49,000
$50,000
$50,000
Best Estimate
$1,140,000
$1,240,000
$2,120,000
High Estimate
$3,970,000
$4,340,000
$7,790,000
Pain Upon Deep
Inhalation
Low Estimate
$1,670,000
$1,880,000
$3,740,000
Best Estimate
$10,700,000
$12,090,000
$24,560,000
High Estimate
$98,970,000
$111,920,000
$229,070,000
Total Monetized
Benefits
Low Estimate
$1,720,000
$1,930,000
$3,800,000
Best Estimate
$11,850,000
$13,330,000
$26,680,000
High Estimate
$102,940,000
$116,260,000
$236,860,000
E-23
-------
TABLE E-23
Monetized Benefits for Clinical Approach
Local Controls Strategies Baseline
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
.08 ppm, 8-Hour, S Exc.
.08 ppm, 8-Hour, 4 Exc.
.08 ppm, 8-Hour, 1 Exc.
Cough
Low Estimate
$2,620,000
$3,090,000
$5,030,000
Best Estimate
$21,670,000
$25,700,000
$43,300,000
High Estimate
$56,980,000
$67,670,000
$115,920,000
Pain Upon Deep
Inhalation
Low Estimate
54,790,000
$5,710,000
$9,810,000
Best Estimate
$31,540,000
$37,530,000
$64,860,000
High Estimate
$294380,000
$350,160,000
$606,480,000
Total Monetized
Benefits
Low Estimate
$7,410,000
$8,800,000
$14,850,000
Best Estimate
$53,210,000
$63,230,000
$108,160,000
High Estimate
$351350,000
$417,840,000
$722,390,000
PA
RTIAL ATTAINMENT SCENAR
JO
Cough
Low Estimate
$1,480,000
$1,680,000
$2,930,000
Best Estimate
$11,830,000
$13,600,000
$23,380,000
High Estimate
$30,570,000
$35,300,000
$60,290,000
Pain Upon Deep
Inhalation
Low Estimate
$2,430,000
$2,810,000
$5,020,000
Best Estimate
$15,760,000
$18,330,000
$33,110,000
High Estimate
$1,466,400,000
$170,620,000
$309,380,000
Total Monetized
Benefits
Low Estimate
$3,900,000
$4,490,000
$7,950,000
Best Estimate
$27,590,000
$31,940,000
$56,490,000
High Estimate
$176,970,000
$205,910,000
$369,670,000
E-24
-------
TABLE E-24
Monetized Benefits for Epidemiological Approach
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 5 Exceedance Standard
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
$0
NE2
$1,070,989,000
$0
NE
$518,435,000
Hospital Admissions: All
Respiratory Illnesses3
$ 1,222,000
$2,270,000
$3,188,000
$608,000
$1,173,000
$1,664,000
Hospital Admissions:
Pneumonia
$533,000
$720,000
$1,056,000
$256,000
$358,000
$522,000
Hospital Admissions: COPD
$297,000
$716,000
$1,136,000
$147,000
$351,000
$570,000
Presence of Any of 19 Acute
Respiratory Symptoms
$491,000
$3,870,000
$7,250,000
$221,000
$1,746,000
$3,271,000
Self-Reported Asthma
Attacks
$1,000
$3,000
$5,000
$1,000
$1,000
$2,000
Worker Productivity
$1,179,000
$939,000
Total Monetized Benefits
$3,723,000
$8,759,000
$1,084,803,000
$2,172,000
$4,567,000
$525,402,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-25
-------
TABLE E-25
Monetized Benefits for Epidemiological Approach
Regional Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Exceedance Standard
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
SO
NE2
$1,266,681,000
$0
NE
$588,776,000
Hospital Admissions: All
Respiratory Illnesses3
$1,475,000
$2,752,000
$3,874,000
$683,000
$1,315,000
$1,865,000
Hospital Admissions:
Pneumonia
$640,000
$867,000
$1,273,000
$288,000
$401,000
$586,000
Hospital Admissions: COPD
$356,000
$863,000
$1,370,000
$165,000
$395,000
$640,000
Presence of Any of 19 Acute
Respiratory Symptoms
$578,000
$4,558,000
$8,538,000
$254,000
$2,005,000
$3,755,000
Self-Reported Asthma
Attacks
$1,000
$4,000
$6,000
$1,000
$2,000
$3,000
Worker Productivity
$1,582,000
$1,131,000
Total Monetized Benefits
$4,633,000
$10,626,000
$1,283,325,000
$2,523,000
$5,249,000
$596,757,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-26
-------
TABLE E-26
Monetized Benefits for Epidemiological Approach
Regional Controls Strategies Baseline
.08 ppnt, 8-Hour, 1 Exceedance Standard
(1990$)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
$0
NEJ
$2,257,144,000
$0
NE
$1,205,279,000
Hospital Admissions: All
Respiratory Illnesses3
$2,731,000
$5,117,000
$7,226,000
$1,470,000
$2,809,000
$3,989,000
Hospital Admissions:
Pneumonia
$1,177,000
$1,596,000
$2,350,000
$624,000
$858,000
$1,262,000
Hospital Admissions: COPD
$654,000
$1,595,000
$2,537,000
$351,000
$853,000
$1,371,000
Presence of Any of 19 Acute
Respiratory Symptoms
$1,025,000
$8,078,000
$15,132,000
$527,000
$4,157,000
$7,786,000
Self-Reported Asthma
Attacks
$3,000
$7,000
$11,000
$1,000
$4,000
$6,000
Worker Productivity
$4,573,000
$3,364,000
Total Monetized Benefits
$10,161,000
$20,967,000
$2,288,974,000
$6,338,000
$12,044,000
$1,223,055,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-27
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TABLE E-27
Monetized Benefits for Epidemiological Approach
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 5 Exceedance Standard
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
$0
NE2
$1,489,073,000
$0
NE
$752,269,000
Hospital Admissions: All
Respiratory Illnesses3
$1,768,000
$3,303,000
$4,654,000
$911,000
$1,747,000
$2,494,000
Hospital Admissions:
Pneumonia
$764,000
$1,024,000
$1,515,000
$390,000
$529,000
$781,000
Hospital Admissions: COPD
$413,000
$1,030,000
$1,648,000
$220,000
$536,000
$851,000
Presence of Any of 19 Acute
Respiratory Symptoms
$666,000
$5,252,000
$9,838,000
$318,000
$2,507,000
$4,696,000
Self-Reported Asthma
Attacks
$2,000
$4,000
$7,000
$1,000
$2,000
$4,000
Worker Productivity
$3,208,000
$2,438,000
Total Monetized Benefits
$6,820,000
$13,821,000
$1,509,943,000
$4,278,000
$7,759,000
$763,533,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates ar efor hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD
E-28
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TABLE E-28
Monetized Benefits for Epidemiological Approach
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 4 Exceedance Standard
(1990 $)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
SO
NEJ
$1,785,713,000
$0
NE
$880,132,000
Hospital Admissions: All
Respiratory Illnesses1
$2,153,000
$4,035,000
$5,696,000
$1,083,000
$2,076,000
$2,963,000
Hospital Admissions:
Pneumonia
$929,000
$1,248,000
$1,846,000
$463,000
$629,000
$928,000
Hospital Admissions: COPD
$504,000
$1,255,000
$2,006,000
$260,000
$635,000
$1,011,000
Presence of Any of 19 Acute
Respiratory Symptoms
$797,000
$6,285,000
$11,773,000
$372,000
$2,931,000
$5,490,000
Self-Reported Asthma
Attacks
$2,000
$5,000
$9,000
$1,000
$3,000
$4,000
Worker Productivity
$4,155,000
$3,084,000
Total Monetized Benefits
$8,540,000
$16,983,000
$1,811,198,000
$5,263,000
$9,357,000
$893,611,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
3Esitmates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-29
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TABLE E-29
Monetized Benefits for Epidemiological Approach
Local Controls Strategies Baseline
.08 ppm, 8-Hour, 1 Exceedance Standard
(1990 S)
(Estimates are incremental from the current standard)
Health Endpoint
FULL ATTAINMENT SCENARIO
PARTIAL ATTAINMENT SCENARIO
Low Estimate
Best Estimate
High Estimate
Low Estimate
Best Estimate
High Estimate
Mortality1
$0
NE2
$3,147,511,000
$0
NE
$1,606,999,000
Hospital Admissions: All
Respiratory Illnesses1
$3,988,000
$7,501,000
$10,612,000
$2,093,000
$3,996,000
$5,692,000
Hospital Admissions:
Pneumonia
$1,713,000
$2,313,000
$3,421,000
$893,000
$1,214,000
$1,794,000
Hospital Admissions: COPD
$939,000
$2,325,000
$3,711,000
$499,000
$1,224,000
$1,948,000
Presence of Any of 19 Acute
Respiratory Symptoms
$1,400,000
$11,036,000
$20,671,000
$689,000
$5,433,000
$10,177,000
Self-Reported Asthma
Attacks
$3,000
$9,000
$16,000
$2,000
$5,000
$8,000
Worker Productivity
$11,199,000
$8,161,000
Total Monetized Benefits
$19,242,000
$34,383,000
$3,197,141,000
$12,337,000
$20,032,000
$1,634,780,000
'Low estimate is result of Kinney et al. model, high estimate is result of Moolgavkar et al. model.
2NE = not estimated due to uncertainty considerations.
'Estimates are for hospital admissions for all respiratory illnesses excluding admissions for pneumonia or COPD.
E-30
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