September 2009
Regulatory Impact Analysis for the Proposed
Greenhouse Gas Tailoring Rule
Final Report
Linda M. Chappell PhD and Larry Sorrels
US Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Benefits and Cost Group
109 TW Alexander Drive
Research Triangle Park, NC 27711
RTI Institute
3040 Cornwallis Road
Research Triangle Park, NC 27709
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CONTENTS
Page
1. Introduction 3
1.1 Executive Summary 7
1.2 Organization of this Report 8
2. Regulatory Alternatives and Affected Entities 9
3. Information Collection Costs 14
3.1 Burden Costs for Title V 14
3.2 Information Collection Costs NSR Program 17
4. Impacts of Regulatory Relief 19
4-1. Method for Analyzing Avoided Economic and Small Entity Impacts 19
4-1.1 Identifying Affected Sectors and Entities 19
4-1.2 Data Used to Characterize Affected Entities by Size 20
4-2. Developing Economic and Small Entities Regulatory Relief Impact Measures 38
4-3. Implementing the Sales Test to measure Impacts on Industrial, Commercial, and
Multi-Family Residential Sources 38
4-4. Economic Relief to Permitting Authorities 39
5. Social Costs 53
6. References 57
7. Attachment A - Source Categories Affected by the Rule with Industry Detail
8. Attachment B - Technical Support Document for Greenhouse Gas Emissions Threshold
Evaluation
9. Attachment C - Summary of ICR-based Data Used to Estimate Avoided Burden and
Evaluate Resource Requirements at Alternative GHG Permitting Thresholds
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Section 1
Introduction
The Environmental Protection Agency (EPA) is proposing to phase-in the major source
applicability thresholds for greenhouse gas (GHG) emissions under the Prevention of Significant
Deterioration (PSD) and title V programs of the Clean Air Act (CAA or Act) and to set a PSD
significance level for GHG emissions (proposal also referred to as tailoring rule). This proposal
is necessary because of EPA's "Proposed Endangerment and Cause or Contribute Findings for
Greenhouse Gases Under Section 202(a) of the Clean Air Act" determining GHGs emissions to be an air
pollutant1, and because EPA expects soon to promulgate regulations under the CAA to control
GHG emissions from light-duty motor vehicles and, as a result, trigger PSD and title V
requirements for GHG emissions.2 If PSD and title V requirements apply at the applicability
levels provided under the CAA, State permitting authorities would be paralyzed by enormous
numbers of permit applications; the amounts are orders of magnitude greater than the current
inventory of permits and would vastly exceed the current administrative resources of the
permitting authorities. Given this circumstance, and relying on established legal doctrines as
described in the proposal notice, this proposed rule would phase-in PSD and title V applicability
by temporarily establishing revised applicability thresholds for both the PSD and title V
programs, and temporarily establishing a PSD significance level. Concurrently EPA will
conduct a study of the permitting authorities' ability to administer the programs going forward,
and conduct a rulemaking to establish revised applicability levels or other methods for
streamlining administration, all within six years of the effective date of final action of this
proposal. EPA also proposes to identify as the pollutant subject to PSD and title V the group of
up to six GHG emissions, each one weighted for its global warming potential, that are included
in regulations for their control under the CAA. EPA also proposes to conform its action on PSD
state implementation plans (SIPs) and title V programs to match the proposed Federal
applicability requirements.
1 Federal Register. April 24, 2009 (Volume 74, Number 78). Page 18885-18910. Docket ID No. EPA-HQ-OAR-
2009-0171-0137
2 EPA-HQ-OAR-2009-0472; NHTSA-2009-0059 http://www.epa.gov/otaq/climate/regulations/ghg-preamble-
regs.pdf
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This rule does not impose any new burden as it provides temporary regulatory relief for
sources of GHG emissions below a level of 25,000 tpy CC^e (carbon dioxide equivalents). The
primary GHGs of concern directly emitted by human activities include CO2, methane (CH4),
nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SFe). Different GHGs have different heat-trapping capacities. It is useful to
compare them to each other through the use of the CC^e metric. This metric incorporates both
the heat-trapping ability and atmospheric lifetime of each GHG and can be used to adjust the
quantities, in tpy, of all GHGs relative to the global warming potential (GWP) of CC>2. When
quantities of the different GHGs are multiplied by their GWPs, the different GHGs can be
summed and compared on a CC^e basis. Depending on which GWP values are used, the
calculated GHG emissions on a CO2e basis will vary. Throughout this document, we are
applying the GWP values established by the Intergovernmental Panel on Climate Change (IPCC)
in its Second Assessment Report (SAR) (IPCC 1996).3
In the U.S., the combustion of fossil fuels (e.g., coal, oil, gas) is the largest source of CC>2
emissions and accounts for 80 percent of total GHG emissions. More than half the energy-
related emissions come from large stationary sources such as power plants, while about a third
comes from transportation. Of the six primary GHGs, four (CC>2, CH4, N2O, and HFCs) are
emitted by motor vehicles. Industrial processes (such as the production of cement, steel, and
aluminum), agriculture, forestry, other land use, and waste management are also important
sources of GHG emissions in the U.S. These emissions are inventoried at a national level by
EPA in the Inventory of U.S. Greenhouse Gas Emissions and Sinks.4 The entities affected by this
rule are small stationary GHG emitting sources.
We have completed a Regulatory Impact Analysis (RIA) that estimates the cost savings
to sources and permitting authorities achieved by this rule. Because the need for the tailoring rule
is predicated on a separate action taken by the EPA to regulate GHG emissions under the CAA,
this analysis focuses on the effects of regulation assuming that such an action occurs. However,
3 "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2007," U.S. Environmental Protection Agency,
EPA 430-R-09-004, April 15, 2009. Table 1-2, p. 1-6.
http://www.epa.gov/climatechange/emissions/usinventoryreport.html.
4 For additional information about the Inventory of U.S. Greenhouse Gas Emissions and Sinks, and for more
information about GHGs, climate change, climate science, etc.. see EPA's climate change Web site at
www. epa. gov/climatechange/.
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because a triggering action may not yet have happened, there is at least some uncertainty about
when it will occur. This uncertainty has been directly considered in developing regulatory
alternatives considered in this RIA. Figure 1.0 below depicts alternative states of regulation
considered in analyzing the impacts of the tailoring rule in this RIA. As shown in Figure 1.0,
these states of the regulation may be initially divided into those where a triggering event has
occurred or has not. The left branch of the figure shows the case where a triggering event has
taken place. For purposes of this RIA, alternatives shown on the left branch of the figure (GHG
Permitting Triggered) are directly considered in the regulatory alternatives analyzed in this
report. Within these alternatives, the EPA will further consider regulatory relief threshold
alternatives, as well as, the consequences likely to occur if the EPA takes no regulatory relief
action. In contrast, those circumstances shown in the right branch (GHG Permitting Not
Triggered) require no action on the part of sources or permitting authorities and the state of the
regulation remains unchanged from the present. If GHG permitting is not triggered, there is no
immediate need for the tailoring rule. However, if the tailoring rule is advanced before any
triggering regulation, it would be in place in the event such an action takes place at some point in
the future. If the EPA does not pursue reduction of GHG emissions in a separate regulatory
action, the tailoring rule will have no impact.
While this RIA does not directly consider these alternative states of the regulation in the
analytics presented, it should be noted that the possibilities are feasible outcomes absent a
triggering mechanism. Because of the existence of these possibilities, the regulatory analysis
could plausibly have employed two baselines:
1) Estimation of cost savings of the tailoring rule assuming the triggered PSD and Title V
requirements as outlined in this RIA;
2) Estimation of total costs associated with the tailoring rule assuming that the statutory
requirements have not been triggered.
As noted above, this RIA examined the rule in detail using the Baseline 1 approach, but
did not examine Baseline 2 in detail due to the negligible impact the tailoring rule would have
prior to a GHG regulation triggering the statutory requirements. We seek comment on whether
EPA should further conduct analysis using Baseline 2.
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We also note that, under Baseline 1, for any of the thresholds analyzed, there is also a
class of very large sources and modifications that will remain subject to PSD and/or title V for
GHG following a GHG-triggering regulation. We do not analyze the magnitude of the costs and
benefits of PSD/Title V regulation for those sources because they are, by definition, sources that
are included in the baseline. The information in Appendix A indicates that at the proposed
25,000 tons/year CO2e threshold, about 14,000 sources would be classified as major for GHG,
and about 400 new sources and modifications each year would trigger PSD for GHG. We
estimate that all but about 3,000 of the sources and about 60 of the modifications likely would
already be major for other pollutants. The permitting burden for such sources is not attributable
to the tailoring rule. However, under our analysis of Baseline 1, we consider alternatives to the
25,000 threshold that could result in greater or lesser coverage compared to the baseline, within
the constraints imposed by the legal doctrines described in the preamble.
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Figure 1.0. Alternative States of Regulation Relating to the GHG Tailoring Rule
GHG
Permitting
Triggered
No
Tailoring
Rule
Tailoring
Rule
GHG
Permitting
Not
Triggered
No
Tailoring
Rule
zr\
Tailoring
Rule
V
No Action
Case
Baseline 1
* Statutory
limits become
effective
^Permitting
authorities
overwhelmed
with permit
applications,
millions of
new sources
required to
l
obtain permits
r^
*
Action Taken
With Permit
Trigger
*RIA analyzed
regulatory
alternatives
* Significant
reduction in
facilities required
to obtain permit
and permitting
authority burdens
*Limited foregone
GHG emission
reductions
*
No Action
Case
Baseline 2
*No impact on
permitting
authorities or
sources
Action Taken
Without
Permit
Trigger
^Process in
place in case
GHG permitting
is triggered in
the future
*No impact on
permitting
authorities or
sources
*No actions
required by
permitting
authorities or
sources
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1.1 Executive Summary
This RIA examines the benefits, costs, and economic impacts of the proposed rule for
affected entities and society as a whole. This proposed rule lifts, for a period of six years, the
burden to obtain a title V operating permit required by the CAA for smaller existing sources of
GHGs and the burden of NSR requirements for smaller new or modifying sources of GHGs.
Thus this rule may be viewed as providing regulatory relief rather than regulatory requirements
for these smaller GHG sources for a period of six years. For larger sources of GHGs, there are
no direct economic burdens or costs as a result of this proposed rule, because requirements to
obtain a title V operating permit or to adhere to NSR requirements of the CAA are already
mandated by the Act and by existing rules and are not imposed as a result of this proposed
rulemaking. The RIA conducted for this proposed rule may be considered illustrative of the
benefits in terms of regulatory relief that smaller GHG sources will experience in terms of costs
avoided as a result of this proposed rule.
This rulemaking provides proposed permitting thresholds for sources of GHGs that
exceed levels contained in the CAA. Specifically, sources with the potential to emit less than
25,000 tons per year (tpy) CC^e are not required to obtain an operating permit or PSD permit for
a period of at least five years at which time a study will be conducted and the decision revisited
after six years. In the six years following promulgation of this rule, the EPA estimates that,
compared to baseline estimates that do not include the effects of this rule, over six million
sources of GHG emissions will be allowed to operate without a title V operating permits and tens
of thousands of new sources or modifying sources will not be subject to NSR requirements for
GHGs. For this large number of smaller sources, this rule alleviates the regulatory burden
associated with obtaining an operating or PSD permit or complying with NSR B ACT
requirements. Therefore, this proposed action may be considered beneficial to these small
entities as it provides relief from regulation that would otherwise be required. However, this
decision does potentially have environmental consequences in the form of lesser emission
reductions during the six year period of time. Given that these smaller sources of GHG account
for an estimated 7 percent of the six directly emitted GHGs nationally from industrial,
commercial, and residential source categories, while representing over 95 percent of the total
number of sources potentially requiring a PSD permit for GHGs under current permitting
thresholds in the CAA, the EPA believes this is a prudent decision. Requiring such a large
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number of small sources to obtain permits for the first time would overtax the permitting
authorities' abilities to process new permits without commensurate benefits. Moreover,
reductions from these small sources will still be occurring, notwithstanding the fact that
permitting requirements would not apply to them. These smaller sources of GHG will be the
focus of voluntary emission reduction programs and energy efficiency measures that lead to
reductions in GHGs. The EPA will also reevaluate this decision after a six year period and a
study of the implications of permitting smaller GHG sources to those sources and permitting
authorities.
1.2 Organization of this Report
The remainder of this report supports and details the methodology and the results of this
illustrative Regulatory Impact Analysis.
Section 2 presents a discussion of regulatory alternatives and affected entities.
Section 3 describes the information collection costs.
Section 4 describes the methodology and the estimated economic impacts.
Section 5 provides a qualitative description of social costs.
Section 6 lists the references for the analyses included in this RIA.
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Section 2
Regulatory Alternatives and Affected Entities
As previously stated, this proposed rule is essentially providing regulatory relief and
does not include direct regulatory provisions for any industrial, commercial or residential
entities. An analysis is presented for smaller sources that experience regulatory relief. This
proposal increases the GHG threshold for title V applicability to obtain a title V operating permit
potential to emit levels from 100 tpy to 25,000 tpy CC^e or greater annual emissions or potential
emissions. In addition, under the proposal, new sources of GHG emissions with the potential to
emit 25,000 tpy CC^e or more emissions rather than the CAA mandated 250 tpy are subject to
NSR and are required to obtain a PSD permit and to comply with BACT regulatory requirements
by the CAA. Major modifications at sources of GHG emissions are also required to obtain a
PSD permit and to meet BACT regulatory requirements, when the projected emissions increase
from such modification exceeds the NSR significant level (with the promulgated level to be
selected from a proposed range of values between 10,000 and 25,000 tpy CC^e). Impacts on
new and modified sources of GHG emissions with the potential to emit 25,000 tpy CC^e or
greater annual emissions are not included in this RIA since these impacts are not associated with
this rule. In addition to consideration of the proposed threshold of 25,000 CC^e tpy potential to
emit, this RIA examines alternative regulatory thresholds of 10,000 tpy CC^e and 50,000 tpy
CO26 potential to emit, as well as, an alternative of no regulatory action that leaves the
permitting thresholds in the CAA unaltered for sources of GHG emissions.
The information on number of affected sources utilized in this RIA is based on emission
estimates that represent a facility's potential-to-emit (PTE). PTE is defined as the maximum
capacity of a stationary source to emit a pollutant under its physical and operational design,
including certain legal limitations, for example, on emissions or hours of operation. NSR and
title V programs both use PTE for defining major sources. This is particularly relevant concern
for determining the number of facilities in the commercial and residential sector that may be
affected, where CC>2 emissions are primarily due to space heating/appliance usage and the
combustion units are not likely to be used constantly at their maximum rated capacity. Our
basis for these PTE adjustments in the residential and commercial sectors are based on
information on heating equipment and appliance usage in these sectors, and resulted in a range of
10
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85 to 90 percent upwards adjustment in emissions from actual emission values. A full
description of the basis of these PTE adjustments can be found in Attachment B, Technical
Support Document for Greenhouse Gas Emissions Threshold Evaluation.
The rationale for proposing the 25,000 tpy CC^e threshold in the proposed tailoring rule
is based in part on our review of the costs and benefits associated with the different thresholds
evaluated and described in this RIA. However, the primary basis for choosing the 25,000 tpy
CO26 threshold was to ensure consistency with the legal doctrines set forth in the preamble of the
proposed tailoring rule. To apply the statutory PSD and title V applicability thresholds to
sources of GHG emissions would create immediate and insuperable administrative burdens for
permitting authorities. By establishing the applicability thresholds at the 25,000-tpy levels for
the first phase, we would avoid an administratively impossible scenario where each year tens of
thousands of new sources and modifications would become subject to PSD review; and, in total,
millions of sources would require title V operating permits. We used the results of this RIA to
support the decision on proposing a 25,000 tpy CC^e threshold, which we believe would result in
a variance from existing statutory permitting thresholds that would - consistent with the
supporting legal rationale - be as limited as possible and with consideration given to costs and
benefits as described in this RIA.
Table 2-1 describes qualitatively the benefits, costs and economic impacts analyzed for
regulatory alternatives in this RIA. As shown on Table 2-1, leaving the CAA thresholds
unchanged for sources of GHG emissions is the baseline or no action alternative that will render
this tailoring rule as having no impact on sources or permitting authorities beyond the current
CAA requirements. Thus this is a regulatory alternative with zero benefits and zero costs. Under
this alternative, small and large sources of GHG emissions will be required to obtain operating
and PSD permits as mandated by the Act. While this alternative is considered for analytical
completeness, its impact is essentially the same as no GHG tailoring rule and no further
discussion of this alternative is considered in this document.
The benefits of this proposed rule (and the alternatives considered) are the costs
avoided at smaller sources by increasing the threshold levels above current CAA requirements as
reflected on Table 2-1. Under this proposal, millions of title V sources and thousands of NSR
sources are afforded regulatory relief. For the proposed regulatory alternative increasing the
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2.1 Qualitative Description of Benefits and Cost of the Tailoring Rule
Description
Benefits
(Regulatory
relief-avoided
permitting
requirements and
associated costs)
Social Costs
(Foregone
emission
reductions due to
regulating GHG
sources)
Economic
Impacts
(Avoided costs
compared to
annual sales or
revenue data for
affected sources)
No Action
(Thresholds
Remain at
100/250 tpy)1
No avoided
permitting costs
(i.e., Over 6
million title V
sources and over
40 thousand PSD
small new and
modifying GHG
sources remain
subject to
programs.)
No foregone
emission
reductions
No avoided costs
10,000 tpy
GHG Emission
Threshold2
Avoid permitting
costs for 6.075
million title V
sources and for
40.0 thousand
new and
modifying PSD
sources
Foregone GHG
emission
reductions for
affected sources
(addressed
qualitatively)
Impact of
avoided costs
(benefits)
compared to
annual sales
revenues of
affected sources
Proposed
25,000 tpy
GHG Emission
Threshold2
Avoid permitting
costs for 6.089
million sources
and for 40.5
thousand new
and modifying
PSD sources
Foregone GHG
emission
reductions for
affected sources
(addressed
qualitatively)
Impact of
avoided costs
(benefits)
compared to
annual sales
revenues of
affected sources
50,000 tpy
GHG Emission
Threshold2
Avoid permitting
costs for 6.096
million sources
and for 40. 7
thousand new
and modifying
PSD sources
Foregone GHG
emission
reductions for
affected sources
(addressed
qualitatively)
Impact of
avoided costs
(benefits)
compared to
annual sales
revenues of
affected sources
1 This table assumes that a separate action has regulated GHG, triggering permitting for sources. When this
happens, sources with the potential to emit 100 tpy CO2e will be required to obtain a Title V permit and new or
modifying sources with the potential to emit 250 tpy will be required to obtain a PSD permit as required by the
CAA. If current threshold levels in the CAA remain unchanged for GHG emissions, the tailoring rule has no effect
on sources or permitting authorities and provides no regulatory relief to such sources.
2 Alternative regulatory thresholds analyzed in the RIA. Threshold levels represent potential to emit levels for
affected sources.
CAA threshold to the potential to emit threshold of 25,000 tpy CO2e and for the 10,000 tpy and
50,000 tpy regulatory alternatives, the benefits of this tailoring rule are primarily the avoided
permitting costs for affected small sources of GHG emissions. The information collection and
reporting costs (ICR) avoided by small sources are quantified for the proposal and each of the
regulatory alternatives in Section 3 of this document.
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The industry categories anticipated to experience regulatory relief at the threshold
levels proposed in this regulation are shown in Table 2-2. As Table 2-2 shows, this proposal lifts
permitting requirements for over 6 million potential title V sources and tens of thousands of
potential NSR new sources otherwise required by the CAA to obtain permits. For additional
industry details including applicable affected industry North American Classification System
(NAICS) codes see Attachment A, Table A-l.
Table 2-2. Estimated Number of Affected Sources Experiencing Regulatory Relief for
Proposal and Regulatory Alternatives1'2
Sector
Electricity
Industrial
Energy
Waste Treatment
Agriculture
Commercial
Resident! al-
Multifamily
Residential- Single
Family
Totals
% Emissions
Covered3
Number of Sources Experiencing Regulatory Relief
< 10,000 tov
Title V
42
151,100
2,275
866
37,351
1,350,261
609,100
3,925,000
6,075,995
New
PSD
7
274
22
0
299
11,945
6,380
515
19,442
5%
Proposal
< 25,000 tov
Title V
161
156,545
3,644
1,431
37,351
1,354,760
610,340
3,925,000
6,089,232
New
PSD
20
303
35
0
299
12,034
6,397
515
19,603
7%
< 50,000 tov
Title V
326
160,180
4,535
2,455
37,351
1,355,321
610,480
3,925,000
6,095,648
New
PSD
29
324
48
1
299
12,038
6,400
575
19,654
10%
1 Number of sources is determined on a potential to emit basis. Estimates for PSD sources are for newly constructed
facilities and do not include modifications at existing facilities that may also be subject to PSD requirements.
2 See Attachment B for more details of how thresholds and sources affected were developed. US Environmental
Protection Agency. July 7, 2009.
3 Percentage of emissions covered represent estimated actual emissions from sources expected to experience
regulatory relief as a percentage of total stationary source GHG emissions.
The EPA considered a number of factors involving administrative burden and necessity
in proposing a threshold of 25,000 tpy CO2e. When comparing the regulatory alternatives
discussed above, there is a non-trivial difference between them. The reason the 25,000 tpy
threshold is preferred to 10,000 tpy is because permitting authorities cannot immediately
accommodate a huge immediate increase in permitting. The proposed threshold of 25,000 tpy
CO26 is also superior to the 50,000 tpy CC^e because there is evidence that permitting authorities
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can run programs for the levels of permitting that would be required at 25,000 tpy CC^e, and the
EPA believes legal doctrine requires the threshold to be as low as administratively feasible. The
choice of a threshold is a balancing act of administrative considerations between threshold levels
that the EPA feels are not administratively feasible (i.e., 10,000 tpy CC^e potential to emit
threshold) compared to thresholds levels that are not impossible (i.e., 50,000 tpy CC^e potential
to emit threshold) with the proposed threshold of 25,000 tpy CC^e achieving a reasonable
balance. For more information on this issue see Attachment B.
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Section 3
Information Collection Costs
EPA estimated the costs for small sources of GHG that will be postponed as a result of
this rulemaking in the form of avoided information collection costs or burden costs associated
with obtaining a title V or PSD permit. This analysis focuses upon the burdens that are being
lifted for smaller sources as a result of this proposed rule. In addition, an accounting of the
avoided costs to State, local, and tribal permitting authorities is provided. These avoided costs
relate specifically to information collection costs or burden costs for sources of GHG emissions
that would have been required to obtain an operating permit under title V or required to modify
an existing permit to address GHGs if not for this rule. Avoided costs shown also include
information collection requirements for additional PSD permits required for new or modifying
sources of GHGs, as well as, the costs to state, local and tribal permitting authorities for
extending their existing permitting programs to include sources of GHGs.
Time and costs associated with permit activities are derived from existing Information
ICRs. Significant uncertainties exist in the following estimates due to the lack of historical
record and permitting experience upon which to base resource needs for including GHG sources.
3.1 Burden Costs for Title V
Major sources of GHGs with the potential to emit 25,000 tpy CC^e from the six directly
emitted GHGs are required to obtain a title V operating permit. Those sources emitting less than
25,000 tpy CO2e will experience regulatory relief under this proposal. Table 3-1 shows the
estimated first-year information collection costs for an industrial source subject to title V
postponed for small GHG sources.
As shown on Table 3-1, the cost for an industrial source to obtain an operating permit is
estimated to be approximately $46.4 thousand (2007$) per permit. Over 195 thousand industrial
sources are likely to benefit from this rule due to the postponement of permitting requirements.
The burden cost to obtain a new commercial or multi-family residential operating permit is
estimated to be approximately $5.0 thousand (2007$) per permit with approximately 6 million of
these sources benefitting from this rule by avoiding these costs for at least six years. The total
information collection costs postpones for smaller sources of GHGs amount to approximately
$38 billion (2007$).
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Table 3-1. Title V Avoided Costs for Sources of GHG - Regulatory Relief Estimates1'2
Program/Affected
Entities
Title V Sources:
New Industrial
New Commercial
Residential &
Significant Permit
Revisions
Permit Renewals
Subtotal Title V
Source Permits
Title V Permitting
Authority:
New Industrial
New Commercial
& Residential
Significant Permit
Revisions
Permit Renewals
Subtotal Title V
Permits
Total Title V
Permit Costs
% Emission
Covered
Small GHG Sources Under Alternative Threshold Levels
Per
Permit
Cost
(2007$)2
46,350
4,986
312
780
19,688
1,978
414
414
(< 10,000 tpy
Threshold)
Number of
Permits
Avoided2
192,442
5,950,668
0
0
6,143,110
192,442
5,950,668
0
0
6,143,110
Total Cost
Avoided
(millions
2007$)
8,919.69
29,670.03
0
0
38,589.72
3,788.80
11,770.42
0
0
15,559.22
54,148.94
5%
Proposed (< 25,000
tpy Threshold)
Number
of
Permits
Avoided2
195,895
5,956,513
0
0
6,152,408
195,895
5,956,513
0
0
6,152,408
Total
Cost
Avoided
(millions
2007$)
9,079.73
29,699.17
0
0
38,778.91
3,856.78
11,781.98
0
0
15,638.70
54,417.61
7%
(< 50,000 tpy
Threshold)
Number
of
Permits
Avoided2
197,679
5,957,221
0
0
6,154,900
197,679
5,957,221
0
0
6,154,900
Total
Cost
Avoided
(millions
2007$)
9,162.42
29,702.70
0
0
38,865.12
3,891.90
11,783.38
0
0
15,675.29
54,540.41
10%
1 Costs shown represent estimates of the regulatory burden relief proposed by this rule. Title V new operating permit
costs represents one time costs, but these permits are subject to renewals every five years. New and modified PSD
permits reflect the estimated annual number of new and modifying sources requiring permits and the associated ICR
costs. Sums in columns may not add due to rounding.
2 These estimates are explained in more detail in Attachment C "Summary of ICR-based Data Used to Estimate
Avoided Burden and Evaluate Resource Requirements at Alternative GHG Permitting Thresholds."
Percentage of emissions covered represent estimated actual emissions from sources expected to experience
regulatory relief as a percentage of total stationary source GHG emissions.
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Avoided costs for sources at alternative threshold levels of <10,000 tpy and <50,000 tpy are also
presented in Table 3-1. The avoided costs for title V represent initial costs expected to be
incurred by sources when the program is extended to sources of GHG emissions absent this rule.
Title V sources are required to obtain an operating permit and to renew this permit every five
years.
State, local and tribal permitting authorities will also benefit from this rule by avoiding
the administrative burden of processing over 6 million title V operating permits for small sources
of GHGs. ICR cost estimates for permitting authorities and sources are calculated based on
information obtained from the April 2007 Information Collection Request for State Operating
Permit Regulations5. Annual values are derived from Tables 7 and 8 of this document. For
consistency, the permitting authority labor costs are updated to 2007 dollars utilizing the 2007
General Schedule Salary Table from the Office of Personnel Management. For the purposes of
this analysis, we assumed that commercial/residential sources that exceed the major source
threshold due to GHG emissions will not likely have substantial applicable requirements in the
near term. We also assumed that permits for such sources will not require as much time to
prepare and issue as those for industrial sources, which have applicable requirements in addition
to GHG. Therefore, it is estimated that new commercial/residential permits require 10% of the
time needed for new industrial permits, or 43 hours compared to 428 hours for permitting
authorities. For significant revisions and permit renewals, it is assumed that incorporating GHG
information adds 9 hours, or an additional 10% to the current updating and processing time. For
more information on the methods used to calculate ICR costs for permitting authorities for title V
permitting, see Attachment C -"Summary of ICR-based Data Used to Estimate Avoided Burden
and Evaluate Resource Requirements at Alternative GHG Permitting Thresholds".
The cost savings for permitting authorities are summarized in Table 3-1 and are estimated to
exceed $15 billion (2007$). Costs avoided for permitting authorities at alternative threshold
levels are also shown on Table 3-1.
5 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.07,
OMB Control Number 2060-0243, 2007.
17
-------
3-2. Information Collection Costs Associated with the NSR Program
This proposed rulemaking limits the new sources requiring PSD permits to those that
meet a potential to emit threshold of 25,000 tpy CC^e with a significance level for modifications
from 10,000 to 25,000 tpy CO2e considered. (Note: a significance level of 25,000 tpy CO2e is
assumed for analysis purposes.) Table 3-2 summarizes the estimated avoided burden cost
afforded to small sources and permitting authorities by this proposed rule. The estimated burden
or reporting and recordkeeping costs avoided by small GHG sources amounts to over $900
million annually with the burden costs per permit expected to be $131 thousand for new sources,
$84.5 thousand for modified industrial sources, $21.9 thousand for new commercial or
residential sources and $16.9 thousand for modifying commercial or residential sources (2007$).
State, local and tribal permitting authorities are expected to avoid administrative costs of $249
million annually.
Burden estimates for the PSD program permitting authorities are calculated based on
listed values obtained from Tables 6-1 and 6-2 the August 2008 Information Collection Request
for Prevention of Significant Deterioration and Nonattainment New Source Review (NSR)6. NSR
ICR at 18-19. It is assumed that permit preparation and issuance for commercial/residential
permits requires only 20% of the time necessary to prepare and issue industrial source permits
since commercial/residential sources would likely be less complex in terms of numbers and types
of emission sources and control requirements. Estimates obtained are additional burden and costs
to those currently experienced by permitting authorities and sources. For more information on
the estimates of ICR costs for PSD permits see Attachment C. Avoided costs for regulatory
alternatives of <10,000 tpy and 50,000tpy CC^e potential to emit are also shown on Table 3-2.
The PSD estimated costs represent annual estimates of costs avoided for sources and permitting
authorities.
This rule also alleviates the regulatory burden associated with complying with NSR
BACT requirements for small new and modifying sources. The BACT costs foregone are not
estimated or shown in Table 3-2 due to the significant uncertainties involved in these
requirements for affected sources. Likewise the foregone emission reductions associated with
6 Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 123.23,
OMB Control Number 2060-0003, 2008.
18
-------
these BACT requirements for small sources are not estimated. This issue is discussed further in
Sections ofthisRIA.
Table 3-2. PSD Annual Avoided Costs for Sources of GHG - Regulatory Relief Estimates
1,2
Program/Affected
Entities
PSD Source
Permits:
New & Modified
Industrial
New & Modified
Commercial &
Residential
Subtotal PSD
Permits
PSD Permitting
Authority Permits:
New & Modified
Industrial
New & Modified
Commercial &
Residential
Subtotal PSD
Permits
Total PSD Source
and Permitting
Authority Costs
% Emission
Covered
Small GHG Sources Under Alternative Threshold Levels
Per
Permit
Cost
(2007$)2
84,530
16,887
23,243
4,633
(< 10,000 tpy
Threshold)
Number
of Permits
Avoided2
3,094
36,976
40,070
3,094
36,976
40,070
Total Cost
Avoided
(millions
2007$)
261.54
624.41
885.95
71.90
171.31
243.21
1129.16
5%
Proposed (< 25,000
tpy Threshold)
Number
of
Permits
Avoided2
3,299
37,197
40,496
3,299
37,197
40,496
Total
Cost
Avoided
(millions
2007$)
278.86
628.15
907.01
76.68
172.33
249.01
1156.02
7%
(< 50,000 tpy
Threshold)
Number
of
Permits
Avoided2
3,457
37,218
40,675
3,457
37,218
40,675
Total
Cost
Avoided
(millions
2007$)
292.22
628.5
920.72
80.35
172.43
252.78
1173.50
10%
1 Costs shown represent estimates of the annual regulatory burden relief for PSD proposed by this rule. Sums in
columns may not add due to rounding.
2 Attachment C - "Summary of ICR-based Data Used to Estimate Avoided Burden and Evaluate Resource
Requirements at Alternative GHG Permitting Thresholds."
3 Percentage of emissions covered represent estimated actual emissions from sources expected to experience
regulatory relief as a percentage of total stationary source GHG emissions.
19
-------
Section 4
Impacts of Regulatory Relief
This proposed rulemaking does not impose economic impacts on any sources or
permitting authorities, but should be instead be viewed as regulatory relief for smaller GHG
emission sources. This RIA illustrates the burden impacts avoided as a result of this proposed
rule. The avoided impacts of extending these programs for state, local, and tribal permitting
authorities are also reported. To estimate the avoided economic impacts, which include small
business impacts, EPA conducted an assessment estimating cost-to-sales ratios by comparing the
estimated total annualized compliance cost per permit per source avoided to industry average
revenues per establishment. The EPA also evaluated cost-to-sales ratios by comparing burden
costs to revenues of firms at different firm size categories recognizing that the sources required
to comply with these CAA provisions are larger emissions sources and more likely to be large
business entities.
4-1. Method for Analyzing Avoided Economic and Small Entity Impacts
EPA used cost-to-sales comparisons to evaluate the potential impacts to sources affected
by this rule. Since this regulatory action provides regulatory relief, these cost-to-sales ratios
represent the economic impacts that are avoided or postponed for small GHG sources as a result
of this rule. For all regulatory actions, EPA must determine whether a rule will have a
significant impact on a substantial number of small entities (SISNOSE). This rule provides
regulatory relief to small sources and thus does not have a significant impact to a substantial
number of small entities. The approach for estimating the postponed economic impacts and the
small entity analysis are the same for this analysis. The steps followed include, gathering data to
characterize the affected entities by size, selecting and describing the measures and economic
impact thresholds used in the analysis, and determining cost-to-sales ratios for the affected
industrial, commercial and residential categories.
4-1.1 Identifying Affected Sectors and Entities
The industrial, commercial and residential sectors covered by the rule were identified
during the development of the cost analysis for the rule. For the industrial sector, these sources
20
-------
are summarized with applicable NAICS codes in Table 4-1 through 4-4. For commercial and
residential sources, the sources are listed in Tables 4-5 through 4-8.
4-1.2. Data Used to Characterize Affected Entities by Size
The Census Bureau's Statistics of U.S. Businesses (SUSB) data provide national
information on the distribution of economic variables by industry and size.7 Specifically, the
tables report data for each industry on the number of firms (Table 4-1), number of establishments
(Table 4-2), employment (Table 4-3), and receipts (Table 4-4) by enterprise size category in
affected sectors. Similar results are shown for commercial and residential sources on Tables 4-5
through 4-8. The census definitions in these data elements are as follows:
• establishment: An establishment is a single physical location where business is
conducted or where services or industrial operations are performed.
• employment: Paid employment consists of full- and part-time employees, including
salaried officers and executives of corporations, who were on the payroll in the pay
period including March 12. Included are employees on sick leave, holidays, and
vacations; not included are proprietors and partners of unincorporated businesses.
• receipts: Receipts (net of taxes) are defined as the revenue for goods produced,
distributed, or services provided, including revenue earned from premiums,
commissions and fees, rents, interest, dividends, and royalties. Receipts exclude all
revenue collected for local, state, and federal taxes.
• enterprise: An enterprise is a business organization consisting of one or more
domestic establishments that were specified under common ownership or control. The
enterprise and the establishment are the same for single-establishment firms. Each
multi-establishment company forms one enterprise—the enterprise employment and
annual payroll are summed from the associated establishments. Enterprise size
designations are determined by the summed employment of all associated
establishments.8
The SBA small business size standard(s) is provided for each industry group in order to facilitate
comparisons and different thresholds.
7 These data were developed in cooperation with, and partially funded by, the Office of Advocacy of the Small
Business Administration (SBA).
8 Because the SBA's business size definitions (SBA, 2008c) apply to an establishment's "ultimate parent company,"
we assume in this analysis that the "enterprise" definition above is consistent with the concept of ultimate parent
company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening
analyses and the terms are used interchangeably.
21
-------
The receipt data are reported in 2002 dollars. Therefore, to adjust to 2007 dollars for
comparison to costs, the EPA utilized the U.S. Bureau of Labor Statistics' Consumer Price Index
(CPI). Using the annual U.S. city average price index for all consumer goods revenues are
adjusted to 2007 dollars.
Because the SBA's business size definitions (SBA, 2008c) apply to an establishment's
"ultimate parent company," we assume in this analysis that the "enterprise" definition above is
consistent with the concept of ultimate parent company that is typically used for Small Business
Regulatory Enforcement Fairness Act (SBREFA) screening analyses and the terms are used
interchangeably. We also report the SB A size standard(s) for each industry group, to facilitate
comparisons and different thresholds.
22
-------
Table 4-1. Number of Firms by Industry and Enterprise Size: 2002
Sector
Electricity
Generating Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source Category
Electricity Generating
Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement Production
Electronics
Manufacturing
Ferroalloy
Production
Glass Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead Production
Lime Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
Petroleum
Refineries
Phosphoric Acid
Production
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
325312
SBA Size
Standard
i
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
2
500
Total Firms
7,603
443
43
130
136
13,833
14
11,395
87
87
1,135
760
41
760
130
1,145
202
35
<20
employees
5,636
157
28
78
67
7,698
3
7,108
45
45
687
384
16
384
78
475
84
12
20 to 99
employees
901
95
2
18
21
3,291
NA
2,553
12
12
166
161
10
161
18
111
24
5
100 to 499
employees
288
59
3
6
12
1,149
5
590
8
8
53
74
4
74
6
131
23
6
500 to 749
employees
26
16
1
2
6
150
NA
57
NA
NA
9
14
1
14
2
29
6
1
750 to 999
employees
18
3
1
1
3
80
1
51
3
3
12
8
2
8
1
14
3
NA
1,000 to 1,499
employees
19
10
NA
7
4
86
1
32
2
2
11
5
1
5
7
20
3
2
23
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste Treatment
Waste Treatment
Source Category
Pulp and Paper
Manufacturing
Silicon Carbide
Production
Soda Ash
Manufacturing
Titanium Dioxide
Production
Zinc Production
Ethanol Production
Food Processing
Underground Coal
Mines
Oil and Natural Gas
Systems
Oil and Natural Gas
Systems
Landfills
MWCs
NAICS
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Total Firms
338
299
25
367
760
60
21,384
802
6,317
244
14,184
14,184
<20
employees
96
161
10
139
384
19
13,645
387
5,184
110
10,726
10,726
20 to 99
employees
55
94
5
92
161
16
3,935
246
354
22
1,616
1,616
100 to 499
employees
72
25
2
43
74
3
1,247
67
89
16
258
258
500 to 749
employees
7
2
NA
11
14
1
147
6
13
8
22
22
750 to 999
employees
12
NA
1
6
8
NA
63
6
11
3
11
11
1,000 to 1,499
employees
12
NA
1
3
5
3
96
3
5
2
15
15
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent with the
concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA size standards as of 8/11/08.
1: NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 -A firm is small if, including its affiliates, it is primarily engaged in the generation, transmission, and/or distribution of electric energy
for sale and its total electric output for the preceding fiscal year did not exceed 4 million megawatt hours.
2: 500 to 1,500. For NAICS code 324110 - For purposes of Government procurement, the petroleum refiner must be a concern that has 1,500 employees or less or has 125,000 barrels per calendar day or
less total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange
agreement or a throughput. The total product to be delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks.
3. NAICS Subsectors 333, 334, 335 and 336 - For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS code for a newly manufactured product. Concerns performing major
rebuilding or overhaul activities do not necessarily have to meet the criteria for being a "manufacturer" although the activities may be classified under a manufacturing NAICS code. Ordinary repair services
or preservation are not considered rebuilding.
4: Subsector 486 - Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natural Gas $7.0 million , 486910 Pipeline Transportation of Refined
Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million)
24
-------
Table 4-2. Number of Establishments by Affected Industry and Enterprise Size: 2002
Sector
Electricity
Generating Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source Category
Electricity Generating
Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement Production
Electronics
Manufacturing
Ferroalloy Production
Glass Production
HCFC-22 Production
Hydrogen Production
Iron and Steel
Production
Lead Production
Lime Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
Petroleum Refineries
Phosphoric Acid
Production
Pulp and Paper
Manufacturing
Silicon Carbide
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
325312
3221
327910
SBA Size
Standard
i
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
2
500
750
500
Total
Establishments
18,432
640
50
157
253
15,883
17
16,674
551
551
1,242
958
77
958
157
2,287
349
50
628
<20
employees
5,715
157
28
78
67
7,709
3
7,161
45
45
690
386
18
386
78
478
85
12
97
20 to 99
employees
1,423
99
2
18
29
3,435
NA
3,302
20
20
169
174
13
174
18
316
29
5
55
100 to 499
employees
1,126
78
4
15
22
1,497
7
1,788
20
20
62
108
6
108
15
231
28
6
88
500 to 749
employees
282
24
1
5
11
282
NA
306
NA
NA
9
24
7
24
5
68
10
2
13
750 to 999
employees
144
4
1
1
9
130
1
438
30
30
19
14
19
14
1
63
7
NA
34
NA
1,000 to 1,499
employees
209
17
NA
12
20
174
1
337
55
55
18
11
4
11
12
97
3
2
21
NA
25
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste Treatment
Waste Treatment
Source Category
Production
Soda Ash
Manufacturing
Titanium Dioxide
Production
Zinc Production
Ethanol Production
Food Processing
Underground Coal
Mines
Oil and Natural Gas
Systems
Oil and Natural Gas
Systems
Landfills
MWCs
NAICS
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Total
Establishments
347
38
611
958
66
25,698
1,194
7,629
2,701
17,698
17,698
<20
employees
161
10
141
386
20
13,719
390
5,239
110
10,775
10,775
20 to 99
employees
100
5
111
174
16
4,254
279
456
59
1,839
1,839
100 to 499
employees
42
4
69
108
5
1,951
138
292
79
612
612
500 to 749
employees
2
NA
38
24
1
370
23
60
115
86
86
750 to 999
employees
1
25
14
NA
211
20
64
5
63
63
1,000 to 1,499
employees
1
6
11
4
319
24
31
42
58
58
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent with the
concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA Small Entity standards as of 8/11/08.
1: NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 -A firm is small if, including its affiliates, it is primarily engaged in the generation, transmission, and/or
distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 million megawatt hours.
2: 500 to 1,500. For NAICS code 324110 - For purposes of Government procurement, the petroleum refiner must be a concern that has 1,500 employees or less and has 125,000 barrels or less per calendar
day total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange
agreement or a throughput. The total product to be delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks.
3. NAICS Subsectors 333, 334, 335 and 336 - For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS code for a newly manufactured product. Concerns performing major
rebuilding or overhaul activities do not necessarily have to meet the criteria for being a "manufacturer" although the activities may be classified under a manufacturing NAICS code. Ordinary repair services
or preservation are not considered rebuilding.
4: Subsector 486 - Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natural Gas $7.0 million , 486910 Pipeline Transportation of Refined
Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million)
26
-------
Table 4-3. Number of Employees by Affected Industry and Enterprise Size: 2002
Sector
Electricity
Generating Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source Category
Electricity Generating Units
Adipic Acid Production
Aluminum Production
Ammonia Manufacturing
Cement Production
Electronics Manufacturing
Ferroalloy Production
Glass Production
HCFC-22 Production
Hydrogen Production
Iron and Steel Production
Lead Production
Lime Manufacturing
Magnesium Production
Nitric Acid Production
Petrochemical Production
Petroleum Refineries
Phosphoric Acid
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
325312
SBA Size
Standard
i
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
'i
500
Total
Establishments
648,254
73,342
10,158
4,949
16,905
1,300,411
2,266
475,476
9,557
9,557
124,703
64,203
4,393
64,203
4,949
172,964
62,132
6,288
<20
employees
24,257
1,023
38
363
493
50,279
NA
47,315
88
88
1,434
2,421
33
2,421
363
3,171
454
27
20 to 99
employees
39,391
2,412
NA
210
418
139,966
NA
98,637
294
294
6,235
6,680
227
6,680
210
10,392
942
NA
100 to 499
employees
46,942
3,232
NA
NA
1,157
186,772
NA
85,569
510
510
3,227
10,407
NA
10,407
NA
16,525
2,870
NA
500 to 749
employees
12,042
NA
NA
NA
NA
53,138
NA
17,516
NA
NA
1,456
NA
NA
NA
NA
5,548
2,903
NA
750 to 999
employees
6,519
754
NA
NA
NA
33,589
NA
17,946
NA
NA
NA
NA
NA
NA
NA
3,354
NA
NA
1,000 to 1,499
employees
14,653
NA
NA
NA
2,051
43,361
NA
17,512
NA
NA
NA
1,337
NA
1,337
NA
5,001
NA
NA
27
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste Treatment
Waste Treatment
Source Category
Pulp and Paper
Silicon Carbide
Production
Soda Ash Manufacturing
Titanium Dioxide
Production
Zinc Production
Ethanol Production
Food Processing
Underground Coal Mines
Oil and Natural Gas
Systems
Oil and Natural Gas
Systems
Landfills
MWCs
NAICS
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Total
Establishments
162,988
16,079
4,483
49,845
64,203
64,203
1,735
1,443,766
74,915
88,280
300,580
300,580
<20
employees
537
1,237
56
566
2,421
2,421
NA
85,850
2,801
19,336
56,529
56,529
20 to 99
employees
2,279
3,637
NA
881
6,680
6,680
NA
156,158
10,205
12,113
59,245
59,245
100 to 499
employees
12,554
3,536
NA
1,839
10,407
10,407
NA
218,041
11,576
11,656
37,530
37,530
500 to 749
employees
2,782
NA
NA
NA
NA
NA
NA
67,104
NA
2,421
5,122
5,122
750 to 999
employees
7,707
NA
NA
NA
NA
NA
NA
30,099
1,773
3,551
3,401
3,401
1,000 to 1,499
employees
7,121
NA
NA
NA
1,337
1,337
NA
72,262
NA
1,061
3,645
3,645
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the establishment
are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size
designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent with the concept
of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA small entity definitions as of 8/11/08.
1: NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 - A firm is small if, including its affiliates, it is primarily engaged in the generation, transmission, and/or distribution of electric energy for sale
and its total electric output for the preceding fiscal year did not exceed 4 million megawatt hours.
2: 500 to 1,500. For NAICS code 324110 - For purposes of Government procurement, the petroleum refiner must be a concern that has 1,500 employees or less or 125,000 barrels or less per calendar day total
Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a
throughput. The total product to be delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks.
3. NAICS Subsectors 333, 334, 335 and 336 - For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS code for a newly manufactured product. Concerns performing major rebuilding
or overhaul activities do not necessarily have to meet the criteria for being a "manufacturer" although the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are
not considered rebuilding.
4: Subsector 486 - Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natural Gas $7.0 million , 486910 Pipeline Transportation of Refined Petroleum
Products 1,500, 486990 All Other Pipeline Transportation $34.5 million)
28
-------
Table 4-4: Receipts by Industry and Enterprise Size: 2002 (in millions of 2007$)
Sector
Electricity Generating
Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source Category
Electricity
Generating Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement Production
Electronics
Manufacturing
Ferroalloy
Production
Glass Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead Production
Lime
Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
Petroleum
Refineries
Phosphoric Acid
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
325312
SBA Size
Standard
i
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
2
500
Total
Receipts(S)
456,494
54,024
4,165
3,844
8,358
437,886
1,008
110,002
6,662
6,662
54,363
24,584
1,173
24,584
3,844
123,343
225,612
<20
employees
10,324
437
7
152
207
9,887
NA
7,430
25
25
275
582
7
582
152
1,603
538
20 to 99
employees
28,259
880
NA
60
120
26,268
NA
17,700
337
337
1,237
2,391
64
2,391
60
4,722
2,903
NA
100 to 499
employees
29,111
2,117
NA
NA
526
41,653
NA
16,967
82
82
1,192
3,007
NA
3,007
NA
7,974
5,186
NA
500 to 749
employees
8,522
NA
NA
NA
NA
14,340
NA
4,154
NA
NA
639
NA
NA
NA
NA
3,990
10,094
NA
750 to 999
employees
5,211
984
NA
NA
NA
8,589
NA
4,000
NA
NA
NA
NA
NA
NA
NA
2,048
NA
NA
1,000 to 1,499
employees
11,027
NA
NA
NA
992
12,994
NA
4,366
NA
NA
NA
364
NA
364
NA
3,819
NA
NA
29
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste Treatment
Waste Treatment
Source Category
Production
Pulp and Paper
Manufacturing
Silicon Carbide
Production
Soda Ash
Manufacturing
Titanium Dioxide
Production
Zinc Production
Ethanol Production
Food Processing
Underground Coal
Mines
Oil and Natural
Gas Systems
Oil and Natural
Gas Systems
Landfills
MWCs
NAICS
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Total
Receipts(S)
4,607
81,766
3,861
2,386
18,803
24,584
2,416
527,312
22,873
185,420
51,926
55,557
55,557
<20
employees
7
146
206
12
199
582
NA
14,597
501
8,465
1,163
7,451
7,451
20 to 99
employees
719
561
NA
267
2,391
NA
37,198
2,415
7,826
158
8,366
8,366
100 to 499
employees
5,269
715
NA
685
3,007
NA
65,304
3,328
11,075
258
5,940
5,940
500 to 749
employees
805
NA
NA
NA
NA
NA
26,627
NA
5,312
NA
965
965
750 to 999
employees
3,294
NA
NA
NA
NA
NA
11,533
506
4,600
NA
858
858
1,000 to 1,499
employees
2,833
NA
NA
NA
364
NA
25,216
NA
3,233
NA
586
586
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent with the
concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA Small Business categorization as of 8/11/08.
1: NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 - A firm is small if, including its affiliates, it is primarily engaged in the generation, transmission, and/or distribution of electric energy for
sale and its total electric output for the preceding fiscal year did not exceed 4 million megawatt hours.
2: 500 to 1,500. For NAICS code 324110 -For purposes of Government procurement, the petroleum refiner must be a concern that has 1,500 employees or less and 125,000 barrels or less per calendar day
total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a
throughput. The total product to be delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks.
3. NAICS Subsectors 333, 334, 335 and 336 - For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS code for a newly manufactured product. Concerns performing major
rebuilding or overhaul activities do not necessarily have to meet the criteria for being a "manufacturer" although the activities may be classified under a manufacturing NAICS code. Ordinary repair services or
preservation are not considered rebuilding.
4: Subsector 486 -Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natural Gas $7.0 million , 486910 Pipeline Transportation of Refined
Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million)
30
-------
Table 4-5: Number of Firms by Affected Industry and Enterprise Size in Commercial Sectors: 2002
Sector Source Category NAICS SBA Size Total <20 20 to 99 100 to 499 500 to 749 750 to 999 1,000 to 1,499
Standard in Firms employees employees employees employees employees employees
millions of dollars
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient health
care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious worship
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
49312
813110
$7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
25.5
7.0
65,933
28,241
NA
376,637
4,548
4,708
11,418
51,168
3,152
32,720
28,241
675,218
424,694
103,043
NA
608
172,311
40,824
22,509
NA
248,494
427
3,335
7,365
33,326
2,005
14,632
22,509
568,285
351,540
64,915
NA
358
147,505
12,379
1,077
NA
67,549
487
680
1,478
7,968
514
8,486
1,077
41,363
27,991
12,227
NA
138
15,942
3,071
329
NA
6,629
1,590
148
532
1,428
199
5,836
329
4,449
4,699
2,292
NA
34
1,213
289
43
NA
447
384
22
72
135
15
418
43
290
428
153
NA
3
39
174
32
NA
191
237
6
29
70
10
179
32
164
216
82
NA
2
21
187
30
NA
223
333
12
39
77
19
174
30
165
238
95
NA
4
19
31
-------
Sector Source Category NAICS SBA Size Total <20 20 to 99 100 to 499 500 to 749 750 to 999 1,000 to 1,499
Standard in Firms employees employees employees employees employees employees
millions of dollars
Commercial
Commercial
Commercial
Residential
Retail other than
mall
Service
Strip shopping
mall
Residential
44-45
81
531120
531110
7.0-29.0
7.0-25.0
7.0
7.0
736,130
675,218
28,241
52,190
579,905
568,285
22,509
44,477
59,639
41,363
1,077
1,799
8,723
4,449
329
441
577
290
43
55
289
164
32
29
338
165
30
30
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent
with the concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA size categories as of 8/11/08.
32
-------
Table 4-6: Number of Establishments by Affected Industry and Enterprise Size: 2002
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient health
care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious worship
Retail other than
mall
Service
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
49312
813110
44-45
81
SBA Size
Standard
7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
25.5
7.0
7.0-29.0
7.0-25.0
Total Firms
73,701
30,777
NA
503,354
7,569
5,962
13,944
61,795
4,893
67,900
30,777
740,118
487,747
110,375
NA
970
172,562
1,125,693
<20
employees
41,136
22,706
NA
249,889
441
3,371
7,462
33,613
2,057
14,824
22,706
573,318
357,221
65,195
NA
367
147,510
594,655
20 to 99
employees
13,925
1,313
NA
79,906
513
972
1,836
9,057
805
11,701
1,313
54,021
41,650
13,408
NA
204
16,009
98,116
100 to 499
employees
5,604
597
NA
31,769
1,725
488
996
2,962
529
18,516
597
16,431
19,182
3,715
NA
96
1,272
51,814
500 to 749
employees
864
123
NA
7,297
442
67
228
761
311
3,717
123
2,960
3,021
566
NA
20
115
12,028
750 to 999
employees
398
180
NA
4,524
294
41
112
249
97
1,898
180
1,850
2,087
591
NA
13
25
8,897
1,000 to 1,499
employees
501
141
NA
6,819
420
195
150
663
87
2,043
141
2,317
1,933
394
NA
36
27
13,004
33
-------
Sector
Commercial
Residential
Source Category
Strip shopping mall
Residential
NAICS
531120
531110
SBA Size
Standard
7.0
7.0
Total Firms
740,118
30,777
57,748
<20
employees
573,318
22,706
45,104
20 to 99
employees
54,021
1,313
2,992
100 to 499
employees
16,431
597
2,491
500 to 749
employees
2,960
123
479
750 to 999
employees
1,850
180
132
1,000 to 1,499
employees
2,317
141
205
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent
with the concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA small business categories as of
8/11//08.
34
-------
Table 4-7: Number of Employees by Affected Industry and Commercial Enterprise Size: 2002
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient health
care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious worship
Retail other than
mall
Service
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
49312
813110
44-45
81
SBA Size
Standard
7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
25.5
7.0
7.0-29.0
7.0-25.0
Total
Establishments
2,701,675
163,501
NA
8,352,174
5,121,584
100,797
399,213
1,696,701
94,316
2,770,665
163,501
5,420,087
4,917,156
1,800,991
NA
28,100
1,638,915
14,819,904
<20
employees
223,695
73,311
NA
1,622,740
2,374
18,415
35,669
202,509
11,294
92,274
73,311
2,547,460
1,829,546
315,475
NA
2,238
722,630
2,889,481
20 to 99
employees
516,135
32,364
NA
2,551,714
30,243
25,714
60,951
292,528
18,392
409,004
32,364
1,482,350
1,029,355
496,962
NA
5,427
607,209
2,204,104
100 to 499
employees
535,272
22,319
NA
1,184,119
389,501
19,918
84,936
232,976
21,859
965,200
22,319
640,068
751,711
380,688
NA
5,010
197,037
1,267,733
500 to 749
employees
148,370
5,066
NA
232,483
220,984
3,920
22,983
56,837
3,802
172,278
5,066
84,297
134,712
65,678
NA
NA
20,211
213,518
750 to 999
employees
121,656
3,583
NA
134,402
192,908
2,677
9,641
37,156
2,144
91,599
3,583
61,553
89,264
NA
NA
NA
13,453
138,205
1,000 to 1,499
employees
190,930
4,095
NA
216,606
385,312
4,786
15,808
53,296
2,654
132,119
4,095
74,082
107,577
72,282
NA
1,545
14,081
200,867
35
-------
Sector
Commercial
Residential
Source Category
Strip shopping
mall
Residential
NAICS
531120
531110
SBA Size
Standard
7.0
7.0
Total
Establishments
5,420,087
163,501
281,250
<20
employees
2,547,460
73,311
152,350
20 to 99
employees
1,482,350
32,364
59,796
100 to 499
employees
640,068
22,319
42,104
500 to 749
employees
84,297
5,066
7,627
750 to 999
employees
61,553
3,583
NA
1,000 to 1,499
employees
74,082
4,095
NA
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent
with the concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA small business sizes as of 8/11/08.
36
-------
Table 4-8: Receipts by Affected Industry and Enterprise Size: 2002 (Millions of 2007 $)
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient health
care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious worship
Retail other than
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
NA
49312
813110
44-45
SBA Size
Standard in
millions of dollars
7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
NA
25.5
7.0
7.0-29.0
Total
Receipts
207,779
52,796
NA
373,666
575,286
11,854
72,013
141,193
10,705
145,529
52,796
491,097
582,829
170,062
NA
4,889
95,558
<20
employees
15,586
21,467
NA
79,827
845
2,018
6,419
15,159
1,546
4,624
21,467
215,897
229,611
35,446
NA
325
37,076
20 to 99
employees
30,849
8,090
NA
98,916
2,892
2,763
10,785
18,413
2,199
18,714
8,090
120,283
118,216
31,146
NA
765
34,178
100 to 499
employees
38,207
6,609
NA
49,500
33,554
2,091
15,439
15,047
2,281
49,332
6,609
67,821
73,667
35,130
NA
586
13,933
500 to 749
employees
10,456
2,148
NA
9,774
20,075
478
4,422
4,287
508
9,058
2,148
10,225
12,923
6,972
NA
NA
1,681
750 to 999
employees
7,620
2,145
NA
5,742
18,448
319
1,942
2,869
286
4,989
2,145
5,946
8,277
NA
NA
NA
1,165
1,000 to 1,499
employees
11,997
3,281
NA
9,036
41,167
574
2,802
4,431
301
7,319
3,281
5,999
10,556
7,610
NA
233
1,025
37
-------
Sector
Commercial
Commercial
Residential
Source Category
mall
Service
Strip shopping
mall
Residential
NAICS
81
531120
531110
SBA Size
Standard in
millions of dollars
7.0-25.0
7.0
7.0
Total
Receipts
3,612,583
491,097
52,796
57,365
<20
employees
577,700
215,897
21,467
32,327
20 to 99
employees
662,037
120,283
8,090
9,943
100 to 499
employees
441,243
67,821
6,609
6,854
500 to 749
employees
65,923
10,225
2,148
1,366
750 to 999
employees
34,570
5,946
2,145
NA
1,000 to 1,499
employees
49,386
5,999
3,281
NA
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control. The enterprise and the
establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the associated
establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition above is consistent
with the concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses. SBA small business sizes as of 8/11.08.
38
-------
4-2. Developing Economic and Small Entity Regulatory Relief Impact Measures
We measured the postponed impacts of the rule on small entities in each sector using
methods presented in EPA's Final SBREFA Guidance. (EPA, 2006) Because the rule covers a
large number of sectors and primarily covers businesses, the analysis generated a set of sales tests
(represented as cost-to-receipt ratios)9 for NAICS codes associated with the affected sectors.
Although the appropriate SBA size definition should be applied at the parent company
(enterprise) level, data limitations allowed us only to compute and compare ratios for a model
establishment for six enterprise size ranges (i.e., all categories, enterprises with 1 to 20
employees, 20 to 99 employees, 100 to 499 employees, 500 to 999 employees, and 1,000 to 1,499
employees. This approach allows us to account for differences in establishment receipts between
large and small enterprises and differences in small business definitions across affected industries.
It is also a conservative approach, because an establishment's parent company (the "enterprise")
may have other economic resources that could be used to cover the costs of the reporting
program.
4-3. Implementing the Sales Test to Measure Impacts on Industrial, Commercial and Multi-
family Residential Sources
To implement the recommended sales test, EPA computed cost-to-sales ratios for affected
sectors at the establishment (or facility) level.10 The ratios examine the ratio of the average
establishment's total annualized mandatory reporting costs to the average establishment receipts
for enterprises within several employment categories11 . The average entity costs used to compute
the sales test are the same across all of these enterprise size categories. As a result, the sales-test
will overstate the cost-to-receipt ratio for establishments owned by small businesses, because the
reporting costs are likely lower than average entity estimates provided by the engineering cost
analysis.
9The following metrics for other small entity economic impact measures (if applicable) would potentially include
• Small governments (if applicable): "Revenue" test; annualized compliance cost as a percentage of annual
government revenues
• Small non-profits (if applicable): "Expenditure" test; annualized compliance cost as a percentage of annual
operating expenses
10 Typically, SBREFA impact assessments are conducted at the ultimate parent company level. As noted above, we
assume that Census definition of enterprise is equivalent to ultimate parent company. Theoretically, the
comparison of compliance costs to sales should be conducted at the enterprise level. Because Census only
provides data for typical establishments within various enterprise size categories, EPA chose to compute the
cost-to-sales ratio at the establishment (or facility level). The same ratio could be computed at the enterprise level
by multiplying both the numerator and the denominator by the typical number of establishments per enterprise in
the appropriate enterprise size categories. Using the SUSB data on typical establishments means that the cost-to-
sales ratios are identical, whether computed at the establishment level or at the enterprise level.
nFor the one to 20 employee category, we exclude SUSB data for enterprises with zero employees. These
enterprises did not operate the entire year.
39
-------
Cost-to-sales ratios for industrial categories are reported in Tables 4-9 through 4-11.
Table 4-9 shows impacts avoided for small sources of GHGs for title V. On Tables 4-10 and 4-11
impacts avoided for new and modifying PSD sources, respectively are presented. These ratios are
calculated using data on the average avoided cost of compliance per facility, and data on the
average sales per establishment obtained from the Census Bureau. Cost-to-sales or Revenue
ratios for commercial and residential categories are reported in Tables 4-12 through 4-14. Table
4-12 shows impacts avoided for small commercial and residential sources of GHGs for Title V.
Tables 4-13 and 4-14 shows impacts avoided for modifying and new PSD commercial and
residential sources, respectively.
The total national burden avoided per-entity costs of the rule are shown on Table 3-1.
For title V, the avoided burden costs associated with obtaining an operating permit is $46.4
thousand per source for industrial sources of GHG emissions and approximately $5 thousand for
commercial and residential sources. For modifying PSD sources, the avoided burden costs with
obtaining a permit is $84.5 thousand per source for industrial sources of GHG emissions and
$16.9 thousand per source for commercial and residential sources. Finally, for new PSD sources,
the avoided burden costs are the sum of the avoided title V and modifying PSD costs. Thus, the
avoided burden costs are approximately $130.8 thousand per source for industrial sources of
GHG emissions and approximately $22 thousand per source for commercial and residential
sources.
The cost-to-sales estimates show that the avoided costs for industrial sources typically are
up to 2 percent of their sales, but they can be as high as 53 percent for certain sources (e.g.,
aluminum plants with less than 20 employees). For commercial sources, the avoided costs are
typically up to 1 percent of their sales or revenues, but they can be as high as 9 percent for
certain sources (e.g., refrigerated warehouses).
4-4. Economic Relief to Permitting Authorities
In this proposal the thresholds for requiring title V and PSD permits are increased to
25,000 tpy CO2e potential to emit resulting in millions of potential title V sources and tens of
thousands of new and modifying PSD sources being able to postpone obtaining a permit for a
period of at least six years. This action will provide significant regulatory relief to States, local
government, and tribal permitting authorities. The magnitude of permits that would need to be
40
-------
addressed and the dollar estimate of the additional costs in labor and administrative costs
permitting authorities would otherwise incur if GHG are a regulated pollutant absent this
rulemaking are shown in Tables 3-1 and 3-2 above.
For title V permits, permitting authorities will experience avoided costs of approximately
$15.6 billion dollars relating to approximately 6 million new operating permits that otherwise
would need to be processed. While this administrative burden represents a huge burden to these
agencies, Part 70 of the CAA does provide for a mechanism for the affected permitting
authorities to recoup the costs of operation associated with administering this expanded permit
program. The EPA recognizes in this tailoring rule that the sheer magnitude and burden of these
additional small GHG sources cannot feasibly be met by these permitting authorities on
administrative burden grounds for a period of at least five years regardless of the ability to
include these increased costs in fees charged to sources. However, the economic consequences
to permitting authorities of this permitting program are offset in the fee structure these authorities
are allowed to charge sources obtaining title V permits.
For PSD permitting authorities no such mitigating fee structure currently exists. Thus,
the funding for administering a PSD permitting program to include tens of thousands additional
new and modifying PSD sources annually would need to be met by these permitting authorities
from current revenues sources. At present, there are approximately 58 State, local and tribal PSD
permitting programs operating in the U.S. and approximately 49 additional State, local or tribal
government authorities that are administering federal programs under delegation from the EPA.
It is difficult to estimate the economic consequences of the regulatory relief afforded to the
individual permitting authorities, because the number of PSD permits processed each year varies
by permitting authority over time depending upon the number of new and modifying sources
occurring in a given location. However, the National Association of Clean Air Agencies
(NACAA) has, through a member survey, broadly assessed the additional resource and burden
considerations of EPA treating GHG as a regulated pollutant. NACAA provided this
information to EPA to help improve our understanding of agencies' burdens.12 Under the current
PSD program requirements, these permitting authorities process an average of 8 PSD permits for
new and modifying sources each year (range of 0 to 56 for individual respondents). These
12 Memorandum from Mary Stewart Douglas NACAA, to Juan E. Santiago, Group Leader, Operating Permits
Group, U.S. EPA OAQPS. September 3, 2009.
41
-------
surveyed permitting authorities indicate they would need an average of 12 new full time
employees (range of 1 to 63) costing an average of $1.1 million annually (range $60 thousand to
$6.3 million) with a 10 fold increase in permits occurring due to including GHG as a regulated
pollutant. Some of these permitting authorities indicated that hiring new employees is not
possible at this time due to budget constraints and hiring freezes. All respondents indicated that
new training would be needed to address GHGs permitting. Rather than the 10 fold increase in
permits postulated in NACAA's survey, the EPA estimates the increase would more likely be
140 fold making these estimates a significant understatement of the potential impacts on
permitting authorities.
42
-------
Table 4-9: Avoided Title V Costs for Small Industrial Sources of GHG Emissions
Sector
Electricity
Generating
Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source
Category
Electricity
Generating Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement
Production
Electronics
Manufacturing
Ferroalloy
Production
Glass
Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead
Production
Lime
Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
SBA Size
Standard
i
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
Average
Cost Per
Entity
(2007$)
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46350
$46,350
$46,350
$46,350
$46,350
$46,350
Cost per entity
for All
Establishments
(%)
0.2%
0.1%
0.1%
0.2%
0.1%
0.2%
0.1%
0.7%
0.4%
0.4%
0.1%
0.2%
0.3%
0.2%
0.2%
0.1%
Cost per
entity for
<20
employees
(%)
2.6%
1.7%
19.0%
2.4%
1.5%
3.6%
NA
4.5%
8.3%
8.3%
11.6%
3.1%
12.8%
3.1%
2.4%
1.4%
Cost per
entity for 20
to 99
employees
(%)
0.2%
0.5%
NA
1.4%
1.1%
0.6%
NA
0.9%
0.3%
0.3%
0.6%
0.3%
0.9%
0.3%
1.4%
0.3%
Cost per
entity 100 to
499
employees
(%)
0.2%
0.2%
NA
NA
0.2%
0.2%
NA
0.5%
1.1%
1.1%
0.2%
0.2%
NA
0.2%
NA
0.1%
Cost per
entity for
500 to 749
employees
(%)
0.2%
NA
NA
NA
NA
0.1%
NA
0.3%
NA
NA
0.1%
NA
NA
NA
NA
0.1%
Cost per
entity for
750 to 999
employees
(%)
0.1%
0.0%
NA
NA
NA
0.1%
NA
0.5%
NA
NA
NA
NA
NA
NA
NA
0.1%
Cost per
entity for
1,000 to
1,499
employees
(%)
0.1%
NA
NA
NA
0.1%
0.1%
NA
0.4%
NA
NA
NA
0.1%
NA
0.1%
NA
0.1%
43
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste
Treatment
Waste
Treatment
Source
Category
Production
Petroleum
Refineries
Phosphoric
Acid
Production
Pulp and Paper
Manufacturing
Silicon Carbide
Production
Soda Ash
Manufacturing
Titanium
Dioxide
Production
Zinc Production
Ethanol
Production
Food
Processing
Underground
Coal Mines
Oil and Natural
Gas Systems
Oil and Natural
Gas Systems
Landfills
MWCs
NAICS
324110
325312
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
500
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Average
Cost Per
Entity
(2007$)
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
$46,350
Cost per entity
for All
Establishments
(%)
0.0%
0.1%
0.0%
0.4%
0.1%
0.2%
0.2%
0.1%
0.2%
0.2%
0.2%
0.2%
1.5%
1.5%
Cost per
entity for
<20
employees
(%)
0.7%
7.8%
3.1%
3.6%
3.8%
3.3%
3.1%
NA
4.4%
3.6%
2.9%
0.4%
6.7%
6.7%
Cost per
entity for 20
to 99
employees
(%)
0.0%
NA
0.4%
0.8%
NA
1.9%
0.3%
NA
0.5%
0.5%
0.3%
1.7%
1.0%
1.0%
Cost per
entity 100 to
499
employees
(%)
0.0%
NA
0.1%
0.3%
NA
0.5%
0.2%
NA
0.1%
0.2%
0.1%
1.4%
0.5%
0.5%
Cost per
entity for
500 to 749
employees
(%)
0.0%
NA
0.1%
NA
NA
NA
NA
NA
0.1%
NA
0.1%
NA
0.4%
0.4%
Cost per
entity for
750 to 999
employees
(%)
NA
NA
0.0%
NA
NA
NA
NA
NA
0.1%
0.2%
0.1%
NA
0.3%
0.3%
Cost per
entity for
1,000 to
1,499
employees
(%)
NA
NA
0.0%
NA
NA
NA
0.1%
NA
0.1%
NA
0.0%
NA
0.5%
0.5%
44
-------
Table 4-10. Avoided Costs to Small Modifying Industrial GHG PSD Emission Sources
Sector
Electricity
Generating
Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source
Category
Electricity
Generating Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement
Production
Electronics
Manufacturing
Ferroalloy
Production
Glass
Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead
Production
Lime
Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
SBA Size
Standard
(effective
August 11,
2008)
1
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
Average
Cost Per
Entity
(2007$)
$84,530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
Cost per Entity
for All
Establishments
(%)
0.3%
0.1%
0.1%
0.3%
0.3%
0.3%
0.1%
1.3%
0.7%
0.7%
0.2%
0.3%
0.6%
0.3%
0.3%
0.2%
Cost per
entity for
<20
employees
(%)
4.7%
3.0%
34.6%
4.3%
2.7%
6.6%
NA
8.1%
15.1%
15.1%
21.2%
5.6%
23.3%
5.6%
4.3%
2.5%
Cost per
entity for 20
to 99
employees
(%)
0.4%
1.0%
NA
2.5%
2.0%
1.1%
NA
1.6%
0.5%
0.5%
1.2%
0.6%
1.7%
0.6%
2.5%
0.6%
Cost per
entity 100 to
499
employees
(%)
0.3%
0.3%
NA
NA
0.4%
0.3%
NA
0.9%
2.1%
2.1%
0.4%
0.3%
NA
0.3%
NA
0.2%
Cost per
entity for
500 to 749
employees
(%)
0.3%
NA
NA
NA
NA
0.2%
NA
0.6%
NA
NA
0.1%
NA
NA
NA
NA
0.1%
Cost per
entity for
750 to 999
employees
(%)
0.2%
0.0%
NA
NA
NA
0.1%
NA
0.9%
NA
NA
NA
NA
NA
NA
NA
0.3%
Cost per
entity for
1,000 to
1,499
employees
(%)
0.2%
NA
NA
NA
0.2%
0.1%
NA
0.7%
NA
NA
NA
NA
0.3%
NA
0.3%
NA
45
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste
Treatment
Waste
Treatment
Source
Category
Petroleum
Refineries
Phosphoric
Acid
Production
Pulp and Paper
Manufacturing
Silicon Carbide
Production
Soda Ash
Manufacturing
Titanium
Dioxide
Production
Zinc
Production
Ethanol
Production
Food
Processing
Underground
Coal Mines
Oil and Natural
Gas Systems
Oil and Natural
Gas Systems
Landfills
MWCs
NAICS
324110
325312
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
(effective
August 11,
2008)
500
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Average
Cost Per
Entity
(2007$)
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
$84530
Cost per Entity
for All
Establishments
(%)
0.0%
0.1%
0.1%
0.8%
0.1%
0.3%
0.3%
0.2%
0.4%
0.4%
0.3%
0.4%
2.7%
2.7%
Cost per
entity for
<20
employees
(%)
1.3%
14.2%
5.6%
6.6%
6.9%
6.0%
5.6%
NA
7.9%
6.6%
5.2%
0.8%
12.2%
12.2%
Cost per
entity for 20
to 99
employees
(%)
0.1%
NA
0.6%
1.5%
NA
3.5%
0.6%
NA
1.0%
1.0%
0.5%
3.2%
1.9%
1.9%
Cost per
entity 100 to
499
employees
(%)
0.0%
NA
0.1%
0.5%
NA
0.9%
0.3%
NA
0.3%
0.4%
0.2%
2.6%
0.9%
0.9%
Cost per
entity for
500 to 749
employees
(%)
0.0%
NA
0.1%
NA
NA
NA
NA
NA
0.1%
NA
0.1%
NA
0.8%
0.8%
Cost per
entity for
750 to 999
employees
(%)
NA
NA
0.1%
NA
NA
NA
NA
NA
0.2%
0.3%
0.1%
NA
0.6%
0.6%
Cost per
entity for
1,000 to
1,499
employees
(%)
NA
NA
0.1%
NA
NA
NA
0.3%
NA
0.1%
NA
0.1%
NA
0.8%
0.8%
46
-------
Table 4-11. Avoided Costs to Small New PSD Industrial GHG Sources
Sector
Electricity
Generating
Units
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source
Category
Electricity
Generating Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement
Production
Electronics
Manufacturing
Ferroalloy
Production
Glass
Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead
Production
Lime
Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
Petroleum
NAICS
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
SBA Size
Standard
(effective
August 11,
2008)
1
1000
1000
1000
750
3
750
500-1000
1000
1000
1000
750-1000
500
750-1000
1,000
500-1000
2
Average
Cost per
Entity
(2007$)
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
Cost per
Entity for All
Enterprises
0.5%
0.2%
0.2%
0.5%
0.4%
0.5%
0.2%
2.0%
1.1%
1.1%
0.3%
0.5%
0.9%
0.5%
0.5%
0.2%
0.0%
Cost per
entity for
<20
employees
7.2%
4.7%
53.6%
6.7%
4.2%
10.2%
NA
12.6%
23.3%
23.3%
32.9%
8.7%
36.1%
8.7%
6.7%
3.9%
2.1%
Cost per
entity for 20
to 99
employees
0.7%
1.5%
NA
3.9%
3.2%
1.7%
NA
2.4%
0.8%
0.8%
1.8%
1.0%
2.7%
1.0%
3.9%
0.9%
0.1%
Cost per
entity 100 to
499
employees
0.5%
0.5%
NA
NA
0.5%
0.5%
NA
1.4%
3.2%
3.2%
0.7%
0.5%
NA
0.5%
NA
0.4%
0.1%
Cost per
entity for
500 to 749
employees
0.4%
NA
NA
NA
NA
0.3%
NA
1.0%
NA
NA
0.2%
NA
NA
NA
NA
0.2%
0.0%
Cost per
entity for
750 to 999
employees
0.4%
0.1%
NA
NA
NA
0.2%
NA
1.4%
NA
NA
NA
NA
NA
NA
NA
0.4%
NA
Cost per
entity for
1,000 to
1,499
employees
0.2%
NA
NA
NA
0.3%
0.2%
NA
1.0%
NA
NA
NA
0.4%
NA
0.4%
NA
0.3%
NA
47
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Energy
Waste
Treatment
Waste
Treatment
Source
Category
Refineries
Phosphoric
Acid
Production
Pulp and Paper
Manufacturing
Silicon Carbide
Production
Soda Ash
Manufacturing
Titanium
Dioxide
Production
Zinc Production
Ethanol
Production
Food
Processing
Underground
Coal Mines
Oil and Natural
Gas Systems
Oil and Natural
Gas Systems
Landfills
MWCs
NAICS
325312
3221
327910
325181
325188
3314
325193
311
21211
211
486
562
562
SBA Size
Standard
(effective
August 11,
2008)
500
750
500
1,000
1,000
750-1000
1,000
500-1000
500
500
4
$12.5
million
$12.5
million
Average
Cost per
Entity
(2007$)
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
$130,880
Cost per
Entity for All
Enterprises
0.1%
0.1%
1.2%
0.2%
0.4%
0.5%
0.4%
0.6%
0.7%
0.5%
0.7%
4.2%
4.2%
Cost per
entity for
<20
employees
22.0%
8.7%
10.2%
10.7%
9.3%
8.7%
NA
12.3%
10.2%
8.1%
1.2%
18.9%
18.9%
Cost per
entity for 20
to 99
employees
NA
1.0%
2.3%
NA
5.4%
1.0%
NA
1.5%
1.5%
0.8%
4.9%
2.9%
2.9%
Cost per
entity 100 to
499
employees
NA
0.2%
0.8%
NA
1.3%
0.5%
NA
0.4%
0.5%
0.3%
4.0%
1.3%
1.3%
Cost per
entity for
500 to 749
employees
NA
0.2%
NA
NA
NA
NA
NA
0.2%
NA
0.1%
NA
1.2%
1.2%
Cost per
entity for
750 to 999
employees
NA
0.1%
NA
NA
NA
NA
NA
0.2%
0.5%
0.2%
NA
1.0%
1.0%
Cost per
entity for
1,000 to
1,499
employees
NA
0.1%
NA
NA
NA
0.4%
NA
0.2%
NA
0.1%
NA
1.3%
1.3%
48
-------
Footnotes for Tables 4-9. through 4-11.
NA - Not available.
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were
specified under common ownership or control. The enterprise and the establishment are the same for single-establishment firms.
Each multi-establishment company forms one enterprise—the enterprise employment and annual payroll are summed from the
associated establishments. Enterprise size designations are determined by the summed employment of all associated
establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate
parent company, we assume in this analysis that the enterprise definition above is consistent with the
concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement
Fairness Act (SBREFA) screening analyses.
1: NAICS codes 221111, 221112,221113, 221119, 221121, 221122 - A firm is small if,
including its affiliates, it is primarily engaged in the generation, transmission, and/or
distribution of electric energy for sale and its total electric output for the preceding fiscal
year did not exceed 4 million megawatt hours.
2: 500 to 1,500. For NAICS code 324110 -Forpurposes of Government procurement, the petroleum refiner
must be a concern that has no more than 1,500 employees nor more than 125,000 barrels
per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Capacity
includes owned or leased facilities as well as facilities under a processing agreement or
an arrangement such as an exchange agreement or a throughput. The total product to be
delivered under the contract must be at least 90 percent refined by the successful bidder
from either crude oil or bona fide feedstocks.
3. NAICS Subsectors 333, 334, 335 and 336 - For rebuilding machinery or equipment on a factory basis, or equivalent,
use the NAICS code for a newly manufactured product. Concerns performing major rebuilding or overhaul activities do
not necessarily have to meet the criteria for being a "manufacturer" although the activities may be classified under a
manufacturing NAICS code. Ordinary repair services or preservation are not considered rebuilding.
4: Subsector 486 - Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500,
486210 Pipeline Transportation of Natural Gas $7.0 million , 486910 Pipeline Transportation of
Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million)
49
-------
Table 4-12: Avoided Title V Costs for Small New Commercial Sources of GHG Emissions
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Residential
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient
health care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious
worship
Retail other than
mall
Service
Strip shopping
mall
Residential
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
NA
49312
813110
44-45
81
531120
531110
SBA Size
Standard in
millions of
dollars as of
8/11/08
$7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
NA
25.5
7.0
7.0-29.0
7.0-25.0
7.0
7.0
Average
Cost Per
Entity
(2007$)
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
$4986
Average Cost
per Entity for
All
Enterprises
0.2%
0.3%
NA
0.7%
0.0%
0.3%
0.1%
0.2%
0.2%
0.2%
0.3%
0.8%
0.4%
0.3%
NA
0.1%
0.9%
0.2%
0.8%
0.3%
0.5%
Cost per
Entity for
<20
employees
1.3%
0.5%
NA
1.6%
0.3%
0.8%
0.6%
1.1%
0.7%
1.6%
0.5%
1.3%
0.8%
0.9%
NA
0.6%
2.0%
0.5%
1.3%
0.5%
0.7%
Cost per
Entity for
20 to 99
employees
0.2%
0.1%
NA
0.4%
0.1%
0.2%
0.1%
0.2%
0.2%
0.3%
0.1%
0.2%
0.2%
0.2%
NA
0.1%
0.2%
0.1%
0.2%
0.1%
0.2%
Cost per
Entity for
100 to 499
employees
0.1%
0.0%
NA
0.3%
0.0%
0.1%
0.0%
0.1%
0.1%
0.2%
0.0%
0.1%
0.1%
0.1%
NA
0.1%
0.0%
0.1%
0.1%
0.0%
0.2%
Cost per
Entity for
500 to 749
employees
0.0%
0.0%
NA
0.4%
0.0%
0.1%
0.0%
0.1%
0.3%
0.2%
0.0%
0.1%
0.1%
0.0%
NA
NA
0.0%
0.1%
0.1%
0.0%
0.2%
Cost per
Entity for
750 to 999
employees
0.0%
0.0%
NA
0.4%
0.0%
0.1%
0.0%
0.0%
0.2%
0.2%
0.0%
0.2%
0.1%
NA
NA
NA
0.0%
0.1%
0.2%
0.0%
NA
Cost per
Entity for
1,000 to 1,499
employees
0.0%
0.0%
NA
0.4%
0.0%
0.2%
0.0%
0.1%
0.1%
0.1%
0.0%
0.2%
0.1%
0.0%
NA
0.1%
0.0%
0.1%
0.2%
0.0%
NA
50
-------
Table 4-13: Avoided Costs to Small Modifying Commercial PSD GHG Emission Sources
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Residential
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient
health care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious
worship
Retail other than
mall
Service
Strip shopping
mall
Residential
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
NA
49312
813110
44-45
81
531120
531110
SBA Size
Standard in
millions of
dollars of
revenue
(8/11/08)
$7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
NA
25.5
7.0
7.0-29.0
7.0-25.0
7.0
7.0
Average
Cost per
Entity
(2007$)
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
$16887
Cost per
Entity for All
Enterprises
0.6%
1.0%
NA
2.3%
0.0%
0.8%
0.3%
0.7%
0.8%
0.8%
1.0%
2.5%
1.4%
1.1%
NA
0.3%
3.0%
0.5%
2.5%
1.0%
1.7%
Cost per
Entity for
<20
employees
4.5%
1.8%
NA
5.3%
0.9%
2.8%
2.0%
3.7%
2.2%
5.4%
1.8%
4.5%
2.6%
3.1%
NA
1.9%
6.7%
1.7%
4.5%
1.8%
2.4%
Cost per
Entity for
20 to 99
employees
0.8%
0.3%
NA
1.4%
0.3%
0.6%
0.3%
0.8%
0.6%
1.1%
0.3%
0.8%
0.6%
0.7%
NA
0.5%
0.8%
0.3%
0.8%
0.3%
0.5%
Cost per
Entity for
100 to 499
employees
0.2%
0.2%
NA
1.1%
0.1%
0.4%
0.1%
0.3%
0.4%
0.6%
0.2%
0.4%
0.4%
0.2%
NA
0.3%
0.2%
0.2%
0.4%
0.2%
0.6%
Cost per
Entity for
500 to 749
employees
0.1%
0.1%
NA
1.3%
0.0%
0.2%
0.1%
0.3%
1.0%
0.7%
0.1%
0.5%
0.4%
0.1%
NA
NA
0.1%
0.3%
0.5%
0.1%
0.6%
Cost per
Entity for
750 to 999
employees
0.1%
0.1%
NA
1.3%
0.0%
0.2%
0.1%
0.1%
0.6%
0.6%
0.1%
0.5%
0.4%
NA
NA
NA
0.0%
0.4%
0.5%
0.1%
NA
Cost per
Entity for
1,000 to
1,499
employees
0.1%
0.1%
NA
1.3%
0.0%
0.6%
0.1%
0.3%
0.5%
0.5%
0.1%
0.7%
0.3%
0.1%
NA
0.3%
0.0%
0.4%
0.7%
0.1%
NA
51
-------
Table 4-14: Avoided Costs to Small PSD New Commercial GHG Emission Sources
Sector
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Commercial
Residential
Source Category
Education
Enclosed mall
Food sales
Food service
Inpatient health
care
Laboratory
Laboratory
Lodging
Nonrefrigerated
warehouse
Nursing
Office
Other
Outpatient
health care
Public assembly
Public order and
safety
Refrigerated
warehouse
Religious
worship
Retail other than
mall
Service
Strip shopping
mall
Residential
NAICS
61
531120
722
622
541380
5417
721
49311
623
531120
81
621
71
NA
49312
813110
44-45
81
531120
531110
SBA Size
Standard in
millions of
dollars in
revenue
(8/11/08)
$7.0-35.0
7.0
7.0-20.5
34.5
12.0
7.0
7.0
25.5
7.0-13.5
7.0
7.0-25.0
7.0-34.5
7.0
NA
25.5
7.0
7.0-29.0
7.0-25.0
7.0
7.0
Average
Cost per
Entity
(2007$)
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
$21873
Average Cost
per Entity for
All
Enterprises
0.8%
1.3%
NA
3.0%
0.0%
1.1%
0.4%
1.0%
1.0%
1.0%
1.3%
1.8%
1.4%
NA
0.4%
4.0%
4.0%
0.7%
3.3%
1.3%
2.2%
Cost per
Entity for
<20
employees
5.8%
2.3%
NA
6.9%
1.1%
3.7%
2.6%
4.9%
2.9%
7.0%
2.3%
3.4%
4.0%
NA
2.5%
8.7%
8.7%
2.3%
5.8%
2.3%
3.1%
Cost per
Entity for
20 to 99
employees
1.0%
0.4%
NA
1.8%
0.4%
0.8%
0.4%
1.1%
0.8%
1.4%
0.4%
0.8%
0.9%
NA
0.6%
1.0%
1.0%
0.3%
1.0%
0.4%
0.7%
Cost per
Entity for
100 to 499
employees
0.3%
0.2%
NA
1.4%
0.1%
0.5%
0.1%
0.4%
0.5%
0.8%
0.2%
0.6%
0.2%
NA
0.4%
0.2%
0.2%
0.3%
0.5%
0.2%
0.8%
Cost per
Entity for
500 to 749
employees
0.2%
0.1%
NA
1.6%
0.0%
0.3%
0.1%
0.4%
1.3%
0.9%
0.1%
0.5%
0.2%
NA
NA
0.2%
0.2%
0.4%
0.6%
0.1%
0.8%
Cost per
Entity for
750 to 999
employees
0.1%
0.2%
NA
1.7%
0.0%
0.3%
0.1%
0.2%
0.7%
0.8%
0.2%
0.6%
NA
NA
NA
0.0%
0.0%
0.6%
0.7%
0.2%
NA
Cost per
Entity for
1,000 to
1,499
employees
0.1%
0.1%
NA
1.7%
0.0%
0.7%
0.1%
0.3%
0.6%
0.6%
0.1%
0.4%
0.1%
NA
0.3%
0.1%
0.1%
0.6%
0.8%
0.1%
NA
52
-------
Footnotes for Tables 4-12-4-14
The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under common ownership or control.
The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise employment and annual
payroll is summed from the associated establishments. Enterprise size designations are determined by the summed employment of all associated establishments.
Since the SBA's business size definitions (http://www.sba.gov/size) apply to an establishment's ultimate parent company, we assume in this analysis that the enterprise definition
above is consistent with the concept of ultimate parent company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening analyses.
NAICS code 611519 - Job Corps Centers. For classifying a Federal procurement, the purpose of the solicitation must be for the management and operation of a U.S. Department
of Labor Job Corps Center. The activities involved include admissions activities, life skills training, educational activities, comprehensive career preparation activities, career
development activities, career transition activities, as well as the management and support functions and services needed to operate and maintain the facility. For SBA assistance
as small business concern, other than for Federal Government procurements, a concern must be primarily engaged in providing the services to operate and maintain Federal Job
Corps Centers
NAICS code 541711 and 541712 - For research and development contracts requiring the delivery of a manufactured product, the appropriate size standard is that of the
manufacturing industry.
53
-------
Section 5
Social Costs
EPA examined the social costs of this proposed rule. For this proposal, the social costs
represent the foregone environmental benefits that would occur if regulatory relief were offered
to small sources of GHG emissions as proposed. This proposal is one of regulatory relief since it
increases the emissions thresholds for the title V and PSD programs, as they apply to sources of
GHGs, to levels above those in the CAA. Previous sections have discussed the avoided cost of
such relief, but there is also a social cost imposed by such relief because this rule may forego
some of the possible benefits associated with title V and PSD programs for sources of GHG
emissions below 25,000 tpy CC^e but above the statutory 100/250 tpy levels. These benefits are
those attributed to title V and PSD permitting programs in general. These benefits are based
upon the relevance of these programs to policymaking, transparency issues, and market
efficiency, and therefore are very difficult to quantify and monetize. For title V, they include the
benefits of improved compliance with CAA requirements that stem from (1) improved clarity
regarding applicability of requirements, (2) discovery and required correction of noncompliance
prior to receiving a permit, (3) improving monitoring, recordkeeping, and reporting concerning
compliance status, (4) self-certification of compliance with applicable requirements initially and
annually, and prompt reporting of deviations from permit requirements, (5) enhanced
opportunity for the public to understand and monitor sources' compliance obligations, and (6)
improved ability of EPA, permitting authorities, and the public to enforce CAA requirements.
However, it is important to remember that a title V permit does not add new requirements for
pollution control itself, but rather collects all of a facility's applicable requirements under the
CAA in one permit. Therefore, the compliance benefits above are less when title V permits
contains few or no CAA applicable requirements. During the first phase under this proposal,
when the title V threshold is 25,000 tpy, we expect that the vast majority of sources excluded
from title V would be sources that have no CAA applicable requirements for GHG emissions and
few or no requirements for other pollutants because their emissions of those pollutants are so
small. For this reason while it is extremely difficult to measure the degree of improved
compliance, if any, that would be foregone, or to quantify the social costs that would be imposed,
we expect that they would be negligible.
54
-------
For PSD, the primary social cost imposed by the tailoring rule stems from the foregone
benefit of applying BACT to the tens of thousands of small new sources and modifications that
will be below our proposed thresholds during the first phase. This social cost potentially weighs
against the cost savings described above that stem (in part) from avoiding the administrative and
control costs of applying BACT to these sources. The BACT requirement assures that new and
modified sources, when they increase their emissions are using state-of-the-art emission controls
and affords the public an opportunity to comment on the control decision. It does not prohibit
increases but it assures that such controls are applied. Delaying the BACT requirement for
numerous small sources during the first phase of this proposed rule could allow increases from
these smaller sources that are greater than they would be if BACT were applied. A detailed
analysis of this difference is beyond the scope of this rule because we do not have detailed
information on the universe of these tens of thousands of small PSD actions, the candidate
BACT technologies for each of them, how permitting authorities would make the BACT
decisions, and how the BACT limit would compare to what would otherwise be installed absent
BACT. Below we present an illustrative example of how BACT impacts might be determined
for sources that would be excluded from review under the tailoring rule. This example illustrates
the difficulty in quantifying the social costs of avoided BACT, but helps explain the nature of
such costs.
To assess the effect of avoided BACT, we would identify the universe of source types
that are affected by the tailoring rule. More specifically, we would have to project the number of
various source types (within those affected by the tailoring rule) that would actually be
constructing or modifying. We have generally characterized these sources as part of the tailoring
rule threshold evaluation, and have determined a large proportion of these to consist of small
commercial and residential sources. This determination was based on rough energy usage data,
but to assess BACT, we would require more specific information about the proposed equipment
that will actually be emitting GHG (e.g., water heaters, furnaces, cooking equipment, dryers,
etc.) and more specific characterization would be subject to a very high degree of uncertainty.
Following characterization of new and modified sources, we would need to determine,
for each category of source, what GHG control technologies are available for such equipment.
For commercial sources, we may have to determine commercial availability of a range of lower
emitting processes, more efficient technologies, and other techniques for improving energy
55
-------
efficiency. Next, we would assess affected sources capital and operating costs of control options
and determine energy and environmental impacts. Finally, we would need to apply judgment (as
the permitting authority would do in each case) to select the technology that represented the
maximum degree of control taking the costs, energy and environmental impacts into account.
The social cost component of the impact of foregoing BACT for sources that construct or
modify during the first phase would be represented by the difference between the increased
emissions that would result from such proposed sources absent BACT and the increase that
would be allowed under the BACT requirement. However, while we can point to the existence
of such differences, we cannot quantify them (though as explained below we expect that overall
they will be very limited in scope and magnitude). Since there has been no regulatory
experience with controlling GHG emissions from these sources, and limited permitting
experience of any kind with mandatory control requirements on smaller commercial and
residential sources, we are not in position at this point to identify the specific control
technologies and quantify this difference to estimate the greater increases that might occur in the
absence of applying the BACT process to these sources across the country. In addition, since the
PSD BACT review and selection process is implemented on a case-by-case basis, there is
additional uncertainty in predicting program-wide reductions because even for similar sources,
permitting authorities may, ultimately weigh the BACT factors differently and adopt different
control measures.
For all these reasons, it is not possible at this time to quantify the social costs of avoided
BACT. However we note that the universe of possible emissions that would be regulated by
sources excluded under the tailoring rule is small compared to those that would remain subject to
PSD. The sources excluded in the first phase of this proposal comprise only 7 percent of total
stationary source GHG emissions, while 68 percent remain subject to regulation. Furthermore,
we expect the emissions differences due to BACT controls for such sources to be relatively small
due to the lack of available capture and control technologies for GHG at such sources that are
akin to those that exist for conventional pollutants and sources, as well as the likelihood that
even in the absence of BACT such sources would already be installing relatively efficient GHG
technologies to save on fuel costs. Thus, while potential benefits would be foregone by
excluding smaller sources from the permitting programs, these benefits are likely to be small.
Under the tailoring rule, we will be working during the six-year period to greatly improve our
56
-------
understanding of both the administrative costs of regulating and the social costs of not regulating
smaller sources under PSD and Title V, and we will be relying on that information to support our
future threshold analyses called for under the proposal.
Since the EPA is unable to quantify these GHG emission reductions foregone at this time
due to these uncertainties involved in this estimation, it is also not possible to provide a
monetized estimate of the foregone benefits or social costs of this rule. If such emission
reductions foregone were quantified, the EPA could use a social cost of carbon benefit estimates
such as those used in the "Proposed Rulemaking to Establish Light Duty Vehicle Greenhouse
Gas Emission Standards and Corporate Average Fuel Economy Standards"13 recently published
to compute the dollar value associated with the social costs of this proposed rule. Nonetheless,
we expect that the value would be small because, as discussed above, the emissions differences
from which this value would be computed are small.
In reaching the decisions for this GHG tailoring rule, the EPA recognizes the GHG
emissions can remain in the atmosphere for decades to centuries, meaning that their
concentrations become well-mixed throughout the global atmosphere regardless of emission
origin, and their effects on climate are long lasting and significant. A detailed explanation of
climate change and its impact on health, society, and the environment is included in EPA's
technical support document for the endangerment finding proposal (Docket ID No. EPA-HQ-
OAR-2009-0171). The EPA recognizes the importance of reducing climate change emissions for
all sources of GHG emissions including those sources afforded regulatory relief in this rule and
plans to address potential emission reductions from these small sources using voluntary and
energy efficiency approaches. Elsewhere, we have discussed EPA's interest in continuing to use
regulatory and/or non-regulatory tools for reducing emissions from smaller GHG sources
because we believe that these tools will likely result in more efficient and cost-effective
regulation than would case-by-case permitting.
13 US EPA (2009). Proposed Rulemaking to Establish Light Duty Vehicle Greenhouse Gas Emission Standards and
Corporate Average Fuel Economy Standards. EPA-HQ-OAR-2009-0472.
http://www.epa.gov/otaq/climate/regulations/ghg-preamble-regs.pdf
57
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References
U.S. Census Bureau, Statistics of U.S. Businesses: 2002.
http://www.census.gov/econ/susb/data/download_susb2002.html.
U.S. Department of Labor, Bureau of Labor Statistics, Consumer Price Index 2002-2007.
http://www.bls. gov/cpi/
U.S. Environmental Protection Agency. July 7, 2009. Technical Support Document for
Greenhouse Gas Emissions Threshold Evaluation.
U.S. Environmental Protection Agency. November, 2006. Final Guidance for EPA Rulewriters:
Regulatory Flexibility Act as Amended by the Small Business Regulatory Enforcement
Fairness Act. http://www.epa.gov/sbrefa/documents/rfaguidance 11-00-06.pdf
U.S. Small Business Administration, Table of Small Business Size Standards. Accessed 8/11/08.
http://www.sba.gov/idc/groups/public/documents/sba homepage/serv sstd tablepdf.pdf
58
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Attachment A
Source Categories Affected by the Rule with Industry Detail
Table A-l. Proposed and Alternative GHG Source Categories Affected by the Rule with
Industry Detail
Sector
Electricity
Generation
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Source
Category
Electricity
Generating
Units
Adipic Acid
Production
Aluminum
Production
Ammonia
Manufacturing
Cement
Production
Electronics
Manufacturing
Ferroalloy
Production
Glass
Production
HCFC-22
Production
Hydrogen
Production
Iron and Steel
Production
Lead
Production
Lime
Manufacturing
Magnesium
Production
Nitric Acid
Production
Petrochemical
Production
Petroleum
Refineries
Phosphoric
Acid
Production
Pulp and
Paper
Manufacturing
NAICS
Code1
22
325199
331312
325311
327310
334
331112
327
325120
325120
331111
3314
327410
3314
325311
3251
324110
325312
3221
<1 0.000 tov
Title V
42
0
0
0
0
111
0
194
0
24
2
1
0
2
0
2
1
0
0
New
PSD
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Proposed <25.000
tov
Title V
161
0
0
0
0
134
0
265
0
33
7
4
3
2
1
2
4
0
0
New
PSD
20
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
<50,000 tov
Title V
326
0
0
0
0
145
0
348
0
37
14
5
23
4
2
4
13
0
3
New
PSD
29
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
59
-------
Sector
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Industrial
Energy
Energy
Waste
Treatment
Waste
Treatment
Agriculture
Commercial
Residential
Residential
All
Source
Category
Silicon
Carbide
Soda Ash
Manufacturing
Titanium
Dioxide
Production
Zinc
Production
Ethanol
Production
Food
Processing
Unspecified
Industrial
Stationary
Combustion
Underground
Coal Mines
Oil and
Natural Gas
Systems
Landfills
MWCs
Stationary
Combustion
Equipment
(Generators)
All
Commercial -
Stationary
Fuel
Combustion
Multi-Family
Fuel
Combustion
Single-Family
Fuel
Combustion
All
NAICS
Code1
327910
325181
325188
3314
325193
311
Multiple
21211
211,486
562
562
81
Multiple
531110
N/A
<1 0.000 tov
Title V
0
0
0
1
47
3,197
147,518
115
2,160
866
0
37,351
1,350,261
609,100
3,925,000
6,075,995
New
PSD
0
0
0
0
3
38
439
0
22
0
0
299
22,027
11,280
33,000
67,115
Proposed <25.000
tov
Title V
0
0
0
4
54
3,464
152,568
135
3,509
1,430
1
37,351
1,354,760
610,340
3,925,000
6,089,232
New
PSD
0
0
0
0
4
41
463
0
35
0
0
299
22,116
11,297
33,000
67,276
<50,000 tov
Title V
0
0
0
4
54
3,936
155,588
160
4,375
2,447
8
37,351
1,355,321
610,480
3,925,000
6,095,648
New
PSD
0
0
0
0
4
47
478
0
48
0
1
299
22,120
11,300
33,000
67,327
L American Industry Classification System. (NAICS) http://www.census.gov/eos/www/naics/.
2US Environmental Protection Agency. July 7, 2009. "Technical Support Document for Greenhouse Gas
Emissions Threshold Evaluation". See docket at EPA-HQ-OAR-2009-0517. Estimates for PSD sources are
for newly constructed facilities and do not include modifications at existing facilities that may also be subject
to PSD requirements.
60
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61
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Attachment B
Technical Support Document
for Greenhouse Gas Emissions Thresholds
Evaluation
Air Quality Policy Division
Office of Air Quality Policy and Standards
U.S. Environmental Protection Agency
July 7, 2009
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Table of Contents
1. Purpose 4
2. Overview 4
3. Emissions-based Threshold Analysis 5
3.1 General Description of Overall Approach 5
3.1.1 Threshold Levels 6
3.1.2 Greenhouse Gases 7
3.1.3 Source Sectors 8
3.1.4 Potential to Emit Methodology 8
3.1.5 New and Modified Sources 9
3.2 Threshold Summary Results 9
3.3 Electricity Generating Sector 12
3.4 Industrial Sector 15
3.4.1 Data Sources 17
3.4.2 Potential to Emit 17
3.4.3 Methodology for New Units 18
3.5 Methodology for Existing Unspecified Industrial Stationary Combustion
Source Category Emissions 18
3.6 Methodology for Existing Specific Industrial Sectors Considering Combustion,
Process and Fugitive Emissions 20
3.6.1 Adipic Acid Production 21
3.6.2 Aluminum Production 23
3.6.3 Ammonia Production 26
3.6.4 Cement Production 27
3.6.5 Electronic Production 28
3.6.6 Ethanol Production 29
3.6.7 Ferroalloy Production 31
3.6.8 Food Processing 33
3.6.9 Glass Manufacturing 34
3.6.10 HCFC-22 Production 35
3.6.11 Hydrogen Production 37
3.6.12 Iron and Steel Production 38
3.6.13 Lead Production 41
3.6.14 Lime 42
3.6.15 Magnesium Production and Processing 43
3.6.16 Nitric Acid Production 45
11
-------
Table of Contents (cont.)
3.6.17 Petrochemical Production 46
3.6.18 Petroleum Refineries 48
3.6.19 Phosphoric Acid Production 50
3.6.20 Pulp and Paper Manufacturing 51
3.6.21 Silicon Carbide Manufacturing 52
3.6.22 Soda Ash Production 54
3.6.23 Titanium Dioxide Production 55
3.6.24 Zinc Production 56
3.7 Energy Sector 57
3.7.1 Oil and Gas Systems 57
3.7.2 Underground Coal Mining 58
3.8 Waste Sector 61
3.8.1 Landfills 61
3.8.2 Municipal Solid Waste Combustors 62
3.9 Agriculture (Stationary Fuel Combustion) 63
3.10 Commercial Stationary Fuel Combustion 65
3.11 Residential Buildings 68
3.11.1 Single-Family Homes 69
3.11.2 Multi-Family Residential Buildings 70
References 75
Appendix A 80
Appendix B 81
in
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Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation
1. Purpose
The purpose of this document is to provide the background information that was used to
support EPA's decision process in evaluating and selecting proposed greenhouse gas (GHG)
major source applicability thresholds for the Prevention of Significant Deterioration (PSD) and
Title V permitting programs as part of its proposed rule "Prevention of Significant Deterioration
and Title V Greenhouse Gas Tailoring Rule" (GHG Tailoring Rule). The document describes
the methodology used to estimate the number of existing and new facilities (e.g., industrial plant
or commercial building) that would exceed different GHG emission threshold levels. The
document also summarizes the results of this analysis for each sector. The results of this analysis
served as one of the bases for evaluating administrative burdens at both existing permitting
thresholds under the Clean Air Act (CAA) and for evaluating and selecting proposed alternative
permitting thresholds to address administrative necessity concerns.
2. Overview
In order to support EPA's assessment of the administrative burden created by adding
GHGs to existing PSD and Title V permitting programs, it was necessary to develop information
on the number of affected facilities at both the current CAA permitting major source thresholds
(generally, 100 tons per year for Title V and 100 or 250 tons per year for PSD depending on the
source category classification) and at alternative higher thresholds. An affected facility would be
one who's annual emissions of the GHG equal or exceed the major source threshold being
evaluated.
Eight threshold levels ranging from 100 to 100,000 tons per year of GHG emissions were
evaluated. Some of the alternative thresholds evaluated are the same as ones (e.g., 25,000 tons
per year CO2-equivalents) considered in previous studies and in support of EPA's proposed GHG
Mandatory Reporting Rule (GHG MRR, 74 FR 68, Pages 16447 - 16731). One key difference
between the emissions data developed for this analysis and the emissions data developed to
support the proposed GHG MRR is that this analysis is based on a facility's "potential to emit"
(PTE) while the proposed GHG reporting rule is based on "actual" emissions (i.e., the emissions
a facility actually emits in a given year). PTE is defined as the maximum capacity of a stationary
source to emit a pollutant under its physical and operational design, including certain legal
limitations, for example, on emissions or hours of operation. PSD and Title V programs both use
PTE for defining major sources. The end result is generally that more facilities will exceed a
given threshold on a PTE basis than on an actual basis. This is an important differentiation in
terms of both evaluating the thresholds under this proposed rule and when comparing the results
to other threshold analysis, such as the supporting data for the EPA's proposed GHG MRR.
-------
Although the primary focus of this analysis was on the potential administrative burden
associated with different GHG permitting emission levels as represented in terms of number of
facilities potentially subject to permitting, information on GHG emissions from affected facilities
was also collected to assess the relative coverage of national stationary source GHG emissions at
the different threshold levels. While the environmental impact associated with the different
GHG permitting levels was not used as the basis for the proposed temporary GHG thresholds in
the proposed GHG Tailoring Rule, the information on national emissions coverage provides a
useful measure to consider the potential scope of the proposed alternative thresholds, their
coverage of key GHG emission source categories, and whether they promote the environmental
purposes of the PSD and Title V programs.
3. Emissions-based Threshold Analysis
3.1 General Description of Overall Approach
This section presents a general description of the overall approach EPA used to evaluate a
range of permitting thresholds in terms of the number of sources affected, and amount of
emissions covered.
EPA made use of earlier analyses performed to develop emission thresholds for the
proposed GHG MRR, or used the same data sources when additional analyses were required.
EPA did not conduct primary research for this analysis, but instead relied on published research
and publicly available government data, such as EPA's eGRTD database of electric generating
source emissions, Economic and Housing Census data, and Energy Information Agency (EIA)
data on energy consumption.
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3.1.1 Threshold Levels
EPA evaluated eight different potential to emit thresholds:
GHG Thresholds
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
The first two thresholds (100 and 250 tons per year) are the current Clean Air Act major
source criteria pollutant thresholds for the federal operating permit program under Title V, and
the PSD construction permit program under Title I.
The six additional thresholds cover the range of thresholds evaluated for the proposed
GHG MRR, and add two additional thresholds at 5,000 and 50,000 tons per year. Like the Clean
Air Act, the permit thresholds are based on U.S. short tons (tons) instead of metric tons (nitons).
There is a three-orders-of-magnitude range in the thresholds which reflects the much
higher quantity of GHG emissions compared to criteria pollutant emissions from the primary
source of GHG emissions, fossil fuel combustion. For example, an uncontrolled natural gas-
fired boiler that emits 100 tons of NOX annually would at the same time emit about 100,000 tons
ofCO2.
The threshold analysis of source counts and emissions was done on a "potential to emit"
basis, because that is the basis that is relevant for the permit rule. Potential emissions (in short
tons) from each source were evaluated against the threshold levels in order to determine whether
or not a source would be included in the threshold count. When a source was identified as being
covered by a given threshold level, the actual emissions from that source were included to
determine the emissions covered by the threshold. In other words, where summary tables present
"Tg GHG Emissions Covered per Year" these are the actual emissions that would be covered by
the threshold level, given the source count arrived at considering potential to emit emission
levels.
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3.1.2 Greenhouse Gases
EPA evaluated emissions of the major GHGs that are directly emitted by human activities
at the eight threshold levels. The GHGs evaluated are shown below in Table 1. For purposes of
this analysis emissions were evaluated on both an individual GHG mass basis and CCV
equivalent basis (CC^e). CC^e normalizes the different heat trapping capacities of the different
GHGs to that of CC>2. A quantity of a GHG is converted to a CC^e basis by multiplying the mass
of the compound emitted by its Global Warming Potential (GWP). The GWP is a metric that
incorporates both the heat-trapping ability and atmospheric lifetime of each GHG relative to
CO2.
Table 1
Major GHGs Directly Emitted by Human Activities
Greenhouse Gas
Carbon dioxide
Methane
Nitrous oxide
Perfluorocarbons
Hydrofluorocarbons
Sulfur hexafluoride
Chemical Formula
or Acronym
CO2
CH4
N2O
PFCs
MFCs
SF6
Global Warming
Potential (GWP)*
1
21
310
Varies by compound
Varies by compound
23,900
* EPA has chosen to use GWPs published in the Intergovernmental Panel on
Climate Change (IPCC) Second Assessment Report (SAR) published in
1996. For those fluorinated compounds that are not listed in the SAR, EPA
is using the most recent available GWPs, either the IPCC Third Assessment
Report (2001) or Fourth Assessment Report (2007). For more specific
information about the GWP of specific GHGs, please see Table A-l in the
proposed GHG MRR.
Sector descriptions contained in this document include a discussion of GHGs evaluated
for each sector. If the analysis included more than one GHG, the description includes gas-
specific counts as well as a CC^e count. The threshold analyses for stationary fossil fuel
combustion were simplified by excluding CH4 and N2O emissions, because CO2 comprises over
99 percent of GHG emissions from fossil fuel combustion.
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3.1.3 Source Sectors
In this analysis EPA evaluated the same range of stationary source types with direct GHG
emissions as identified in the proposed GHG MRR. The proposed GHG MRR source categories
were based on a comprehensive review of all U.S. source categories with GHG emissions, to
include the categories that emit the most significant amount of GHG emissions. The stationary
sources evaluated in this analysis can be grouped in the sectors shown below:
• Electricity Generation (facilities with fossil fuel-fired electric generating units);
• Industry (range of industries with process and combustion GHG emissions);
• Energy (oil and gas extraction, transport, and processing; underground coal mining);
• Waste Treatment (landfills and municipal solid waste incinerators);
• Agriculture (stationary fuel combustion);
• Commercial (stationary fuel combustion); and
• Residential (stationary fuel combustion).
A number of direct emission source types included in the proposed reporting rule analysis
were not included in the potential to emit analysis because the GHG emissions from these
sources were primarily fugitive emissions. Fugitive emissions are emissions which are not
released, or could not be reasonably released, through a stack or vent. Under the PSD rules,
fugitive emissions are only included in potential to emit estimates if the source is one of 28 listed
PSD source categories. Excluded fugitive emissions sources are listed below:
• Electrical equipment SF6 emissions;
• Wastewater treatment plants not associated with one of 28 listed PSD source categories
(combustion is captured in the commercial sector analysis); and
• Agricultural manure management.
3.1.4 Potential to Emit Methodology
As noted earlier, the potential to emit (PTE) is the amount of emissions that can be
emitted from a source operating at full capacity. The annual PTE is based on operation at full
equipment capacity, 24 hours per day, 365 days per year (8,760 hours per year). For example, if
a boiler has a maximum rated heat input capacity often million Btu per hour, the annual PTE for
that boiler is the amount of emissions from burning 87,600 million Btu of fuel:
10 mmBtu/hr x 8,760 hrs/yr = 87,600 mmBtu/yr
Capacity information and annual GHG emissions were available for some of the source
categories from analyses performed to support the proposed GHG MRR. In some cases the
supporting analyses had already calculated GHG emissions on a full capacity basis, in which
-------
case EPA directly used those estimates as PTE estimates. Alternatively, some data from the
supporting analysis estimated actual annual emissions using a baseline year. If capacity and
baseline year production information was provided in the supporting data, EPA adjusted the
source actual emissions estimate by the ratio of annual capacity to baseline production to
estimate PTE. If capacity information was not available, EPA used capacity factors from other
data sources to adjust actual emission estimates to PTE estimates. These capacity factors add
varying uncertainty to the PTE estimate. Detailed descriptions of the different PTE calculation
methodologies are included in the source descriptions in the following section.
Removal by pollution control equipment was considered in the PTE estimates, though
control equipment removal was relevant in only a few cases (thermal oxidation of HPCs and
CH4). Also, as noted earlier, fugitive emissions, were only included in the PTE estimates if the
source was one of the 28 listed PSD source categories. For example, fugitive CH4 emissions
from oil and gas processing plants were not included in CH4 or CC^e emissions when comparing
to the different thresholds, but were included for iron and steel plants.
3.1.5 New and Modified Sources
The source population data from the analyses supporting the proposed reporting rule
analyses, and other data sources provide information on existing sources and their emissions.
The PSD and NSR program construction permit requirements, however, apply to new or
modified sources.
The general approach for new sources was to apply growth rates in the number of units or
facilities in a source category to the number of existing facilities at the different thresholds.
Growth rates were available from a variety of sources including Economic Census data, EIA
energy survey data, and various EPA regulatory impact analyses and information collection
requests which require source population estimates. In some cases there was sufficient
information to distribute new sources to different thresholds based on emission information
specific to the new sources (electric generating, municipal solid waste combustors, and
commercial stationary fuel combustion). Otherwise EPA assumed the same size and threshold
distribution for new units as for existing units. For example, if the annual growth rate in a
category was one percent, the number of existing facilities above a threshold was multiplied by
the fractional growth rate to estimate the number of new facilities at that threshold per year.
EPA did not develop a method for estimating the number of modifications of existing
sources for the permit threshold analysis.
i.2 Threshold Summary Results
The resulting counts of affected stationary source facilities and the amount of actual
GHG emissions covered at different PTE thresholds for all sectors are shown in the tables below.
GHG emissions covered at each threshold are in Tg, which is equivalent to million metric tons.
-------
SI units were used for the covered emissions to be consistent with the U.S. GHG Inventory and
the proposed GHG MRR. The complete data for the sectors and subsectors are provided in
supporting spreadsheets that accompany this report. These spreadsheets are identified in
Appendices A and B.
Table 2
Threshold Summary — All Stationary Source Sectors
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
6,102,893
1,058,296
278,340
52,888
26,898
13,661
7,245
4,850
Number of New
Facilities Added
per Year
67,404
19,731
4,330
532
289
128
77
66
CO2e Emissions
Covered
(Tg per year)
3,865
3,782
3,708
3,602
3,545
3,464
3,310
3,240
Table 3
CO2 Threshold Summary — All Stationary Source Sectors
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
6,098,502
1,053,891
274,004
49,061
23,393
10,734
5,374
3,750
Number of New
Facilities Added
per Year
67,404
19,731
4,330
532
289
127
77
66
CO2 Emissions
Covered
(Tg per year)
3,649
3,566
3,498
3,393
3,338
3,264
3,134
3,088
10
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Table 4
CH4 Threshold Summary — All Stationary Source Sectors
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
4,201
3,851
2,887
1,042
466
138
34
o
J
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CH4 Emissions
Covered
(Tg per year)
7.807
7.759
7.321
4.740
3.697
2.234
1.185
0.211
Table 5
Threshold Summary — All Stationary Source Sectors
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
47
46
31
5
0
0
0
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
N2O Emissions
Covered
(Tg per year)
0.074
0.074
0.068
0.022
0
0
0
0
11
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Table 6
High GWP Gases Threshold Summary ~ All Stationary Source Sectors
GHG
HFC
HFC
HFC
HFC
PFC
SF6
GHG
Threshold*
(tons per year)
100
250
1,000
5,000 and above
100 and above
100 and above
Number of
Existing Sources
o
J
3
1
0
0
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
GHG Emissions
Covered
(Tg per year)
0.001
0.001
0.001
0
0
0
* Where a threshold is not listed for a particular GHG, threshold counts for that threshold and any higher
thresholds can be assumed to be zero.
3.3 Electricity Generating Sector
Data Sources
The latest version of EPA's eGRID database (2006) was used to estimate the PTE of
electricity generating facilities and counts of units above the different emission thresholds. The
eGRID database includes year 2004 characteristics, operating information, and annual emissions
(including CC^) for U.S. facilities that have a generation capacity greater than one MW, and sell
electric power to the grid.
A facility's PTE was estimated based on the eGRID generator table. The generator table,
which is based on the 2004 EIA form 860 database, provides prime mover, generator nameplate
capacity, and primary energy source (fuel type) for each generator down to 0.1 MW. To
calculate PTE, we combined the nameplate capacity and primary fuel for each of the fossil-fired
units with average fuel based prime mover heat rates (Btu/kWh) published by EIA (EIA, 2007).
12
-------
Table 7
ECU Prime Mover Heat Rates
(EIA Electric Power Annual, Table A7, 2007)
Prime Mover
Steam turbine
Simple
combustion turbine
Combined cycle
combustion turbine
Internal
combustion engine
Fuel
Coal
Gas
Oil
Gas
Oil
Gas
Oil
Gas
Oil
Average Heat Rate (Btu/kWh)
10,114
10,466
10,400
11,459
13,216
7,445
11,015
9,923
10,149
The eGRID database includes cogeneration plants and generating units at industrial
plants that primarily supply electric power and steam to a host facility. We eliminated these
units from the electric generation facility population based on North American Industry
Classification System (NAICS) code, so that the only facilities included were facilities with a
NAICS code beginning with 22 (Utilities).
The generator-nameplate-heat-rate approach potentially underestimates PTE for
cogeneration plants, where a portion of the burner heat input provides useful thermal energy in
addition to electric output. This potential to underestimate PTE affects 321 of 2,237 or 14
percent of facilities evaluated.
Methodology for Existing Facilities
Fuel combustion was the only source of GHG emissions considered for the electricity
generation sector. From the eGRID and EIA information EPA calculated a maximum annual
fuel heat input based on 8,760 hours of operation for the combustors associated with the
generator. This calculated maximum annual heat input was used with fuel combustion emission
factors from the proposed reporting rule for the primary fuel, to calculate the facility PTE. The
calculations covered 10,487 fossil fuel-fired generators with nameplate capacities down to 0.1
MW or 100,000 kW.
EPA also did not evaluate fugitive CFLi emissions from facility coal piles. Fossil fuel-
fired steam electric plants with heat input greater than 250 mmBtu/hr heat input are one of the 28
listed PSD source categories that include fugitive emissions when calculating PTE. However,
the CC>2 PTE from combustion alone for this size facility is about 225,000 tons per year. This is
13
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well over all of the emission thresholds considered in this analysis without consideration of the
contribution of fugitive CH4.
New Units
The eGRID generator table includes an online year field. To determine the number of
new units per year at different thresholds EPA counted generators online each year and totaled
the emissions associated with those generators at the facility level over the 15-year period from
1990 through 2004. Counts were made of the number of these facilities over the different PTE
thresholds, and averaged over the 15 years to arrive at the number of new or modified facilities
per year.
Threshold Summary
The table below shows the facilities and emissions covered at the different emission
thresholds based on the described methodology. There were a total of 2,237 facilities in the
electric generation population, so all facilities and all emissions are covered up to the 5,000 ton
PTE threshold. Almost all emissions (99.9 percent), and about 75 percent of facilities are
covered at the highest 100,000 ton PTE threshold.
Table 8
Threshold Summary Results — Electricity Generating Sector
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
2,237
2,237
2,237
2,237
2,195
2,076
1,911
1,721
Number of New
Facilities Added
per Year
93
93
93
91
86
73
64
60
CO2Emissions
Covered
(Tg per year)
2,373
2,373
2,373
2,373
2,373
2,373
2,373
2,371
14
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3.4 Industrial Sector
The industrial sector comprises establishments engaged in the mechanical, physical, or
chemical transformation of materials, substances, or components into new products, and
specifically includes businesses classified in Sectors 31-33 according to the North American
Industry Classification System (NAICS). Industrial source greenhouse gases result from
manufacturing processes as well as combustion processes. Because there is a great deal of
variability within the sector, this technical support document includes industry-specific
discussions after a general sector overview.
For the industrial sector, EPA considered the six individual greenhouse gases separately,
and also prepared an analysis considering CO2e. In preparation of the GHG MRR, EPA
identified 23 industrial sectors where the GHG emissions were significant; these sectors are
listed in Table 9.
15
-------
Table 9
Industrial Sectors and GHG Emissions
NAICS Code
325199
331312
325311
327310
334
325193
331112
3116
327
325120
331111
3314
327410
3314
325311
3251
324110
325312
3221
327910
325181
325188
3314
Industrial Sector
Adipic Acid Production
Aluminum Production
Ammonia Production
Cement Production
Electronics Manufacturing
Ethanol Production
Ferroalloy Production
Food Processing
Glass Production
HCFC-22 Production
Hydrogen Production
Iron and Steel Production
Lead Production
Lime Manufacturing
Magnesium Production
Nitric Acid Production
Petrochemical Production
Petroleum Refineries
Phosphoric Acid Production
Pulp and Paper Manufacturing
Silicon Carbide Production
Soda Ash Manufacturing
Titanium Dioxide Production
Zinc Production
CO2
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
CH4
X
X
X
X
X
N2O
X
X
SF6
X
X
HFC
X
X
PFC
X
X
In addition, there are a large number of industrial establishments across all industrial
sectors that emit less significant amounts of GHGs (primarily CC^) from stationary source fuel
combustion. Combustion emissions from these establishments were analyzed under the
Unspecified Industrial Stationary Combustion source category.
16
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3.4.1 Data Sources
There were several primary data sources used in preparation of the permit threshold
analysis. EPA consulted analyses prepared in support of the GHG MRR for the 23 industrial
sectors for which combustion, process and fugitive emissions were significant. These documents
can be found in the docket numbered EPA-HQ-OAR-2008-0508. The TSDs contain industry-
specific analyses of process, fugitive, and combustion emissions for industries. Supporting
analyses used to prepare the TSDs are found in entries 0046.7 and 0046.8 of the GHG MRR
docket. These emissions estimate details were helpful in breaking down TSD emission estimates
to compare facility-specific emissions against the additional threshold levels considered in the
permit threshold analysis, including 100, 250, 5,000, and 50,000 tons per year.
Combustion emissions analyses for the Unspecified Industrial Stationary Combustion
sectors used data from the 2002 Manufacturing Energy Combustion Survey (MECS) and the
U.S. Census Bureau's 2002 Economic Census. MECS is a survey of manufacturing and
industrial energy uses and costs prepared by the EIA (EIA, 2007). Data is collected by
manufacturing establishment through mailed questionnaires. The 2002 MECS data reflects
responses accounting for approximately 98 percent of the manufacturing payroll, and reports
separate energy use estimates for 48 NAICS industrial sector groups. The MECS provided
information on the amount of fuel burned in 2002 by sector on an employment basis. The 2002
Economic Census data provided information on the number of establishments sorted by three-
digit NAICS code and disaggregated into specific size categories based on employment (U.S.
Census, 2004).
3.4.2 Potential to Emit
As mentioned earlier in this document, permit threshold analyses considered both actual
emissions and PTE. When capacity information was not available, the analyses applied
utilization rates from the Industrial Production and Capacity Utilization, Federal Reserve
Statistical Release G-17 in order to adjust actual emissions to determine PTE emissions. These
utilization rates are prepared quarterly with annual revisions, and are published on the web
(http://www.federalreserve.gov/releases/gl7). The main data source for the industrial production
and capacity utilization rates is the U.S. Census Bureau's Census of Manufactures. Data
introduced from other Census Bureau publications include the Census of Services and the
Services Annual Survey (for publishing) and selected Current Industrial Reports. Additional
government source data include new annual data on minerals from the U.S. Geological Survey
(USGS) and updated deflators from the Bureau of Economic Analysis (BEA). In addition, the
annual revisions include monthly production estimates that reflect updated seasonal factors and
the inclusion of monthly source data that became available (or were revised) after the closing of
the regular four-month reporting window.
17
-------
3.4.3 Methodology for New Units
To determine the number of new units per year, EPA compared the number of
establishments by three-digitNAICS code in 1998 to the number of establishments by three-digit
NAICS code in 2002, and determined an average annual growth rate for each three-digit NAICS
code. The growth rates were applied to each threshold count to determine the number of annual
new establishments per industry per threshold. If the growth rate was determined to be negative,
EPA assumed that no new establishments would be added; however, establishments were not
reduced to reflect negative growth rates. EPA also supplemented these growth rates with agency
estimates of expected new sources from various information collection requests (ICR) and
regulatory impact analyses (RIA) efforts.
3.5 Methodology for Existing Unspecified Industrial Stationary Combustion Source
Category Emissions
In order to determine establishment counts and emissions totals for the unspecified
industrial stationary combustion sources, EPA used 2002 Economic Census data showing
manufacturing employment by NAICS code and Manufacturing Energy Consumption Survey
(MECS) data published by EIA. Calculating greenhouse gas emissions required determining
energy consumption per employee by industry and applying emission factors specific to the
consumption profile derived from MECS data.
The Economic Census data (2002) provide a count of establishments by employment
category, where employment category is defined by number of employees (e.g., 1-4,
5 - 9,... ,500 - 999,... ,more than 2,500). The MECS energy consumption data provide energy
consumption by industry. Both the employment data and the energy consumption data are
organized according to the NAICS codes.
As part of this analysis, EPA calculated industry-specific GHG emission factors. The
factors were calculated by considering actual fuel consumption in 2002, as determined by EIA.
Actual fuel consumed was multiplied by fuel-specific GHG emission factors to determine GHG
emissions by fuel type by industry. To simplify the analysis, EPA only included CC>2 emissions
and ignored CH4 and N2O in the CC^e calculations. CC>2 makes up between 99.7 to 99.3 percent
of estimated CC^e emissions. Emissions for each fuel type were combined to determine total
emissions for a sector. Total emissions per sector were divided by total energy consumption per
sector to determine a factor to calculate GHG emissions per mmBtu of energy consumption
specific to the industrial sector.
The GHG emission factors were then multiplied by the energy consumption per
employee in order to determine emissions per employee. Multiplying the result by the average
number employees per establishment, EPA determined total GHG emissions per establishment.
18
-------
The total emissions numbers were used to determine number of establishments and volume of
emissions that would be caught by each of the permit thresholds under consideration.
As discussed previously, a separate threshold analysis was conducted for 23 industrial
sectors determined to have significant GHG emissions in the GHG MRR analysis. In order to
quantify the unspecified industrial stationary combustion source emissions, the combustion
emissions and establishment counts from 19 of these sectors were subtracted from the total
industrial MECS analysis. For the remaining four industries, HCFC-22 production, hydrogen
production, magnesium production, and nitric acid production, EPA could not readily isolate
combustion emissions. For these industries, their establishment counts were subtracted from the
unspecified industrial source threshold counts based on process emission threshold evaluations,
assuming that any facility exceeding a threshold for process-based emissions would exceed the
threshold regardless of their combustion CC>2 emissions.
Potential to Emit
In order to determine potential to emit from the MECS and Economic Census numbers,
EPA applied the industry-specific Federal Reserve capacity utilization factors by NAICS
category detailed in the analysis.
New Units
EPA applied industry-specific growth rates to each sector and summed across sectors in
order to determine number of new units.
19
-------
Threshold Summary
Table 12
Threshold Summary ~ Unspecified Industrial Stationary Combustion
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
156,783
91,472
40,013
14,812
9,265
4,215
1,195
740
Number of New
Facilities Added
per Year
481
295
139
69
42
18
3
0
CO2e Emissions
Covered
(Tg per year)
370.834
363.825
343.367
299.910
273.575
223.894
153.344
132.847
3.6 Methodology for Existing Specific Industrial Sectors Considering Combustion, Process
and Fugitive Emissions
These analyses were based primarily on the GHG MRR TSDs and the supporting
analyses, including facility specific emission information. The estimates considered each
greenhouse gas separately. The GHG MRR TSDs included threshold counts and emissions
calculations for 1,000, 10,000, 25,000 and 100,000 metric tons per year. Two steps were
required for permit threshold consideration. First, emissions were recalculated in order to
conduct the analysis in short tons for comparison to the permit thresholds. Second, the emissions
were considered against the finer threshold stratification considered in the permit threshold
analysis.
For the permit threshold analysis, EPA determined that if the GHG MRR analysis
showed all of the establishments exceeded a threshold, after adjustment for short tons, all of the
establishments exceeded any lower thresholds. However, where fewer than 100 percent of the
establishments exceeded a threshold, additional analysis was required to compare emissions to
the permit thresholds of 100, 250, 5,000, and 50,000 tons per year. EPA used the supporting
summaries for the GHG MRR which included facility-specific consumption, process, and
fugitive emission reports in order to determine counts and emissions for each of the permit
thresholds.
20
-------
3.6.1 Adipic Acid Production
There are four Adipic Acid Production plants in the U.S., all of which are estimated to
exceed the highest 100,000 metric tons per year emission threshold for CO2e on an actual
emissions basis. Therefore all plants will also exceed all PTE thresholds on a CO2e basis. The
CO2e emission estimate includes N2O process emissions that total about 5.9 million metric tons
CO2e, and 3.4 million metric tons of CO2 from stationary fuel combustion sources.
N2O
Individual plant production and emission estimates were not made available because of
confidential business information (CBI) claims. However, from the Technical Support
Document for the Adipic Acid Production Sector: Proposed Rule for Mandatory Reporting of
Greenhouse Gases (EPA-HQ-OAR-2008-0508-0005), overall U.S. adipic acid production was
estimated to total approximately one million metric tons in 2006. The smallest U.S. plant only
produced about two percent of the total. This plant, however, is the only plant that is
uncontrolled. The three larger plants with the bulk of production have control equipment with
N2O control efficiencies that range from 90 to 99 percent.
The uncontrolled N2O emission factor is 300 kg N2O/mton adipic acid. Based on the two
percent production share, this uncontrolled plant emitted about 6,000 metric tons of N2O (no
GWP adjustment). This leaves about 13,100 metric tons of N2O from the three larger controlled
plants. Two plants representing about 64 percent of production have control efficiencies in the
range of 90 to 95 percent, and one plant with about 34 percent of production has control close to
99 percent (EPA, 2001).
Assuming similar production shares today, the share of national production (which is
assumed for this analysis to be equivalent to capacity) appears to range from 30 to 35 percent for
the three plants. Therefore, emissions and PTE for the controlled plants range from to 4,000
metric tons to 4,700 metric tons of N2O per year.
CO2
The CO2 emissions from fuel combustion can similarly be apportioned to the four plants.
The smallest plant, with only two percent of national production, is estimated at CO2 emissions
of 67,500 metric tons, and the next smallest, with 30 percent of national production, is estimated
at 101,300 metric tons.
Potential to Emit
The PTE for each facility was assumed to be equivalent to the emissions based on the
apportionment described above.
21
-------
New Units
EPA assumed that no new plants would be constructed for this sector.
Threshold Summary
Table 13
COi Threshold Summary ~ Adipic Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
4
4
4
4
4
4
4
4
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
3.376
3.376
3.376
3.376
3.376
3.376
3.376
3.376
Table 14
Threshold Summary ~ Adipic Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
4
4
4
1
0
0
0
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
N2O Emissions
Covered
(Tg per year)
0.019
0.019
0.019
0.006
0
0
0
0
22
-------
Table 15
COie Threshold Summary ~ Adipic Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
4
4
4
4
4
4
4
4
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
9.298
9.298
9.298
9.298
9.298
9.298
9.298
9.298
>.6.2 Aluminum Production
The primary aluminum production process results in emissions of CO2 and PFCs. The
reduction of the alumina occurs through electrolysis in a molten bath of natural or synthetic
cryolite (NasAlFe). The reduction cells contain a carbon lining that serves as the cathode.
Carbon is also contained in the anode, which can be a carbon mass of paste, coke briquettes, or
prebaked carbon blocks from petroleum coke. During reduction, most of the carbon in the anode
is oxidized and released to the atmosphere as CC»2.
Potential to Emit
CO2
The Technical Support Document for Process Emissions from Primary Production of
Aluminum: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-
2008-0508-0006) apportioned CO2 emission estimates from the U.S. GHG inventory to the 13
operating smelters based on each smelters share of total capacity. Operating smelter emissions
were all above 100,000 tons of CC>2, so no PTE estimate was required. Capacity information for
the two idle smelters shows that these smelters are also capable of emitting over 100,000 tons of
CC»2 per year.
PFCs
23
-------
The reduction cells also emit two PFCs: perfluoromethane (CF4) and perfluoroethane
(C2F6). The GWPs of the two PFCs are 6,500 and 9,200 respectively. During the smelting
process, when the alumina ore content of the electrolytic bath falls below critical levels required
for electrolysis, rapid voltage increases occur, which are termed "anode effects." Anode effects
cause carbon from the anode and fluorine from the dissociated molten cryolite bath to combine,
and produce fugitive emissions of CF4 and C2F6.
Anode effects released approximately 2.5 million metric tons of CF4 and C2F6in 2006 as
documented in the GHG MRR TSD. CF4 made up at least 85 percent of the combined emissions
in 2006 (Inventory of U.S. GHG Emissions and Sinks: 1990 - 2007). These emissions on a
CO26 basis are equivalent to about 410 short tons of combined emissions as PFC. The proposed
GHG MRR TSD estimated CO2e emissions from primary aluminum smelters at full capacity.
The largest smelter has 11 percent of U.S. operating capacity. Therefore the largest smelter has a
PTE of not more than 45 tons of PFC, and no facilities have a PTE greater than 100 tons.
New Units
No new primary aluminum facilities are expected to be built. The growth rate in primary
metals from the Economic Census data is only about 0.4 percent.
24
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Threshold Summary
Threshold summaries are displayed below for CO2 and CO2e. All facilities have a PFC
PTE less than 100 tons per year on a PFC basis.
Table 16
Threshold Summary ~ Primary Aluminum
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
15
15
15
15
15
15
15
15
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
GHG Emissions
Covered
(Tg per year)
3.800
3.800
3.800
3.800
3.800
3.800
3.800
3.800
Table 17
Threshold Summary ~ Primary Aluminum
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
15
15
15
15
15
15
15
15
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
GHG Emissions
Covered
(Tg per year)
3.951
3.951
3.951
3.951
3.951
3.951
3.951
3.951
25
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3.6.3 Ammonia Production
EPA reviewed the proposed Supporting Data for Threshold Analysis Subpart E- W,
Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-
0508-0046.7) to determine actual emissions and calculate the potential to emit for 24 ammonia
plants in operation. The analysis spreadsheet details CC>2 actual emission calculations for each
plant based on ammonia production and urea production, and CC>2, CH4 and N2O emission
calculations for stationary fuel combustion based on 2006 data. For purposes of permit threshold
analysis, the CH4 and N2O emissions from combustion were not significant.
Potential to Emit
Capacity information in the spreadsheet is based on the engineering design capacity
adjusted for 340 days per year of effective production capability, using information provided by
the United States Geological Survey (USGS). The PTE estimates were made by multiplying the
actual emission estimates by the ratio of annual ammonia capacity to annual ammonia
production adjusted to 365 days a year of operation instead of 340. EPA assumed that ratio also
held for stationary combustion units at the plant.
New Units
EPA assumed that no new plants would be constructed for this sector.
Threshold Summary
Table 18
COi Threshold Summary — Ammonia Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
24
24
24
24
24
24
24
22
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
14.543
14.543
14.543
14.543
14.543
14.543
14.543
14.450
26
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3.6.4 Cement Production
Process-related CC>2 emissions from cement production are the second largest source of
industrial CC>2 emissions in the United States. Cement production is done in two stages. The
first stage is clinker production. In clinker production, raw materials (primarily limestone) are
heated to induce calcination and produce lime. Lime reacts with silica-containing materials and
iron ore and aluminum to form clinker. During the process, CC>2 is generated as a byproduct and
released to the atmosphere. Also during clinker production, some of the clinker raw materials
form partially or fully calcinated cement kiln dust instead of forming clinker, resulting in
additional process-related CC>2 emissions. In the second stage of the production process, the
clinker is ground and mixed with gypsum and other materials to make cement.
Potential to Emit
The Technical Support Document for Process Emissions from Cement: Proposed Rule
for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0008) shows 107
cement facilities in the U.S., 106 of which exceed all permit thresholds for CO2 (according to the
TSD, the one facility that does not exceed the 100,000 tons per year threshold accounted for over
90,000 metric tons of CC^e and approximately one-tenth of one percent of the cement industry
emissions in 2006).
New Units
Growth for the industrial sector was estimated at 0.4 percent, and as such, no additional
facilities were included in this analysis.
Threshold Summary
Table 19
COi Threshold Summary ~ Cement Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
Number of
Existing Sources
107
107
107
107
107
107
107
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
81.462
81.462
81.462
81.462
81.462
81.462
81.462
27
-------
100,000
106
0
80.668
3.6.5 Electronic Production
The Technical Support Document for Process Emissions from Electronics Manufacture
(Semiconductors, MEMs, Liquid Crystal Displays, and Photovoltaics) (EPA-HQ-OAR-2008-
0508-0009) examined emissions of high GWP gases for semiconductor and related industry
plants. Emissions from stationary fuel combustion were not included in the source category
analysis, but were instead captured by the unspecified industrial stationary combustion analysis.
EPA has followed this approach here as well.
Approximately one million metric tons of SFe as CC^e were emitted from the
semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990
- 2007). This is equivalent to 46 short tons of SFe. The semiconductor industry uses multiple
long-lived fluorinated gases in plasma etching and plasma enhanced chemical vapor deposition
(PECVD) processes to produce semiconductor products. These include PFCs, which are also
used as heat transfer fluids. Approximately 3.5 million metric tons of PFCs as CC^e were
emitted from the semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions
and Sinks: 1990-2007).
Table 20
Electronic Production PFC Emissions
Semiconductor PFC
CF4
C2F6
C4F8
Total
2006 CO2e Emissions
(million nitons)
1.2
2.2
0.1
3.5
PFC GWP
6,500
9,200
8,700
-
2006 PFC Emissions
(tons)
204
264
13
481
Potential to Emit
The Federal Reserve capacity utilization factor for the electronics industry in 2006 was
79.8 percent. Based on this capacity utilization factor the PTE of all of the semiconductor plants
combined is estimated at 56 tons of SFe and 600 tons of PFC.
EPA identified 216 facilities in the semiconductor-electronics sector. Of these, the
largest facility emitted six percent of total semiconductor emissions on a CC^e basis (includes
non-PFCs), which is a maximum of 30 tons of PFC. On a PTE basis, the largest facility would
28
-------
emit 36 tons, based on an assumption that the industry capacity is distributed similarly to
emissions. Therefore no facility exceeds 100 tons per year on an actual or PTE basis for PFC.
New Units
Growth for the industrial sector was estimated at -1.8 percent, and as such, no additional
facilities were included in this analysis.
Threshold Summary
Electronics industry emissions from plant processes only exceed emission thresholds on a
CO2e basis. Facility stationary fuel combustion emissions are not included in the threshold
comparisons for the industry.
Table 21
Threshold Summary ~ Electronics Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
199
191
159
109
88
65
54
22
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
5.948
5.947
5.934
5.819
5.701
5.399
5.100
3.417
3.6.6 Ethanol Production
In the proposed GHG MRR, EPA determined that the sources of GHG emissions at
ethanol production facilities that must be reported under the proposed rule are stationary fuel
combustion, onsite landfills, and onsite wastewater treatment. For the GHG MRR supporting
analysis, data were unavailable to estimate facility emissions from these combined sources.
Instead, data on stationary fuel combustion requirements for different plant capacities were used
to estimate the minimum number of facilities that would meet each of the examined reporting
rule facility-level thresholds. CC>2 emissions from combustion constitute the majority of the
29
-------
GHG emissions from ethanol production and therefore provide an adequate measure for
determining threshold counts.
Table 22
Ethanol Fuel Combustion COie Emissions by Plant Size
(from the Proposed GHG MRR TSD Spreadsheet)
Ethanol Produced
(wet milling process)
(million gallons)
290
245
200
200
100
85
40
35
20
2.6
Coal Combustion Emissions
(nitons CO2e/year)
1,519,585
1,283,787
1,047,990
1,047,990
523,995
445,396
209,598
183,398
104,799
13,624
Natural Gas Combustion
Emissions
(nitons CO2e/year)
853,536
721,091
588,646
588,646
294,323
250,174
117,729
103,013
58,865
7,652
Table 23
Proposed Reporting Rule Threshold Analysis Results
Threshold CO2e
(tons per year)
1,000
10,000
25,000
100,000
Number of Existing
Sources ~ Actual Basis
101
93
86
43
Percent of Existing
National Sources*
72%
66%
61%
31%
National ethanol production source population was estimated at 140 plants nationwide.
Potential to Emit
The permit threshold PTE analysis relied on this same approach and data. Therefore CH4
emissions from onsite landfills and wastewater treatment plant digesters were not included in the
30
-------
PTE analysis, and we did not estimate emission coverage at each threshold. Also, the analysis
for the proposed GHG MRR did not evaluate thresholds of 100, 250, 5,000, and 50,000 tons per
year. EPA assumed that all existing plants would exceed the 100 and 250 ton per year thresholds
based on fuel combustion associated with the wet milling process. For the 5,000 and 50,000
thresholds, EPA included the number of sources exceeding the next highest threshold. For
example, the count of sources exceeding the 5,000 tons per year level only includes the sources
exceeding the 10,000 ton threshold in the Technical Support Document for Ethanol Facilities:
Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-
0010).
New Units
EPA estimates that ten new ethanol production facilities will be built per year.
Threshold Summary
Table 24
Threshold Summary ~ Ethanol
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
140
140
101
101
93
86
86
43
Number of New
Sources Added
per Year
10
10
7
7
7
6
6
o
3
3.6.7 Ferroalloy Production
In evaluating ferroalloy production in the U.S., EPA considered actual production at six
facilities, as published in the U.S. Inventory of Greenhouse Gas Emissions and Sinks: 1990 -
2007 for 2006, and the capacity to produce at three facilities for which production information
was not published due to competitive concerns.
-------
Potential to Emit
EPA's PTE calculations consider the Federal Reserve's 2006 monthly industrial capacity
utilization estimates for the primary metals industry classification which shows utilization at 85.9
percent for 2006. The PTE calculations do not affect the threshold analysis, because all facilities
emit over 100,000 metric tons of CC^e per year.
New Units
Applying the growth factor for the industrial sector, 0.4 percent, results in no additional
facilities for the analysis.
Threshold Summary
Table 25
Threshold Summary ~ Ferroalloy Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
9
9
9
9
9
9
9
9
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
1.717
1.717
1.717
1.717
1.717
1.717
1.717
1.717
Table 26
CH4 Threshold Summary ~ Ferroalloy Production
GHG Threshold
(tons per year)
100
250
Number of
Existing Sources
o
3
0
Number of New
Facilities Added
per Year
0
0
CH4 Emissions
Covered
(Tg per year)
0.0003
0
32
-------
Table 27
Threshold Summary ~ Ferroalloy Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
9
9
9
9
9
9
9
9
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
1.726
1.726
1.726
1.726
1.726
1.726
1.726
1.726
3.6.8 Food Processing
Food processing includes meat, poultry and fruit and vegetable processing. Emissions
derive from combustion and fugitive methane related to wastewater treatment. For purposes of
this permit threshold analysis, EPA did not consider the fugitive methane from wastewater
treatment because these are the only greenhouse gas emissions from the source category other
than combustion, and food processing is not a listed PSD source category. Consequently,
emissions from this subsector considered in this analysis were limited to combustion emissions
and were calculated using the MECS approach.
Potential to Emit
EPA used the Federal Reserve's 2004 capacity utilization factor of 79.3 percent for the
food industry to calculate PTE emissions.
New Units
In addition, new establishments were calculated assuming a continuation of the growth
rate of 1.2 percent, as calculated using the methodology described earlier in this document.
33
-------
Threshold Summary
Table 28
Threshold Summary — Food Processing
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
3946
2281
1499
1030
749
482
10
0
Number of New
Facilities Added
per Year
47
27
18
12
9
6
0
0
CO2e Emissions
Covered
(Tg per year)
16.848
16.709
16.379
15.723
14.354
12.568
0.596
0
3.6.9 Glass Manufacturing
EPA used the Supporting Data for Threshold Analysis SubpartE- W, Greenhouse Gas
Mandatory ReportingRulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7).to
analyze emissions for permit thresholds from glass manufacturing. Annual fuel combustion and
glass production are estimated for each plant based on 2004 estimated plant sales and 2002
MECS energy intensity (energy per sales dollars). The spreadsheet shows CC>2 emission
estimates from industrial processes and stationary fuel combustion, as well as CH4 and N2O
emission estimates from stationary fuel combustion.
Potential to Emit
Plant capacities are not available in the spreadsheet. To estimate PTE, EPA divided the
actual annual emissions by a capacity utilization factor of 0.79 or 79 percent, based on the
Federal Reserve's 2004 monthly industrial capacity utilization estimates for the non-metallic
minerals industry.
New Units
EPA used an estimated annual growth rate of 0.4 percent for the nonmetallic mineral
product manufacturing sector to determine the number of new units for this analysis.
34
-------
Threshold Summary
Table 29
COie Threshold Summary ~ Glass Manufacturing
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
368
362
222
200
171
87
16
1
Number of New
Facilities Added
per Year
1
1
1
1
1
0
0
0
CO2e Emissions
Covered
(Tg per year)
4.425
4.424
4.341
4.298
4.131
2.594
1.015
0.208
3.6.10 HCFC-22 Production
Chlorodifluoromethane (HCFC-22) is produced for use in refrigeration and air
conditioning systems and as a chemical feedstock for manufacturing synthetic polymers.
Because HCFC-22 depletes stratospheric ozone, its production for non-feedstock uses is
scheduled to be phased out by 2020 under the U.S. Clean Air Act. Feedstock production,
however, is permitted to continue indefinitely.
A high global warming potential (GWP) greenhouse gas, trifluoromethane (HFC-23), is
generated as a byproduct during the manufacture of HCFC-22. Emissions of HFC-23 in 2006
were estimated to be 13.8 million metric tons on a CC^e basis from three HCFC-22 production
plants. Estimates were based on the plants operating at capacity. Annual emissions in terms of
both metric tons CC^e and tons HFC-23 are summarized in Table 30 below.
35
-------
Table 30
HCFC-22 Production HFC-23 Emissions
HCFC-22 Production
HFC-23
2006 CO2e Emissions
(million metric tons)
13.8
HFC GWP
11,700
2006 HFC
Emissions
(short tons)
1,300
Source: Reporting Rule TSD
Potential to Emit
Confidential business information (CBI) claims on production information limited EPA's
PTE analysis. The Technical Support Document for Emissions of HFC-23 from Production of
HCFC-22: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-
2008-0508-0015) estimated that all three plants emit over 100,000 metric tons CO2e on a
capacity basis by a factor of 85 or more, or a minimum of 800 short tons of HFC-23. These
estimates did not account for HFC-23 capture and destruction at two of the three plants.
Therefore, actual emissions at two of the plants will be lower, and can be limited through
permitting. We assumed that all three plants exceed the 100 and 250 ton actual and PTE
thresholds, and that one plant (uncontrolled) exceeds the 1,000 ton PTE threshold.
Because the TSD did not include estimates of CC>2 emissions from fuel combustion, and
the CBI claims noted above, the PTE analysis does not quantify fuel combustion emissions
specifically for the three plants. Stationary fuel combustion emissions from the plants were
instead captured under the analysis for unspecified industrial stationary combustion.
New Units
U.S. production between 1990 and 2006 increased by 11 percent while emissions
declined by 62 percent. The declines in emissions from control equipment and process changes
offset the production increases. Therefore we did not estimate any new facilities or
modifications that would increase facility emissions more than 100 tons per year.
36
-------
Threshold Summary
Table 31
HFC Threshold Summary - HCFC-22 Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
Number of
Existing Sources
o
3
o
5
i
0
Number of New
Facilities Added
per Year
0
0
0
0
HFC Emissions
Covered
(Tg per year)
0.001
0.001
0.001
0
Table 32
CO2e Threshold Summary - HCFC-22 Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
3
3
o
J
3
o
J
3
3
o
J
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
13.848
13.848
13.848
13.848
13.848
13.848
13.848
13.848
3.6.11 Hydrogen Production
EPA estimated CC>2 emissions from merchant hydrogen production using the process and
combustion ratio of 8.62 tons of CC>2 emissions per ton of hydrogen production. About 95
percent of all hydrogen (not just merchant hydrogen) produced in the U.S. today is made from
natural gas via steam methane reforming. In steam methane reforming fueled by natural gas
combustion, the process and combustion emissions go up the same stack from the
37
-------
boiler/reformer unit. Because the emissions are predominately process emissions and because
the natural gas combustion products are emitted from the same stack, EPA has treated all the
emissions as process emissions.
Potential to Emit
EPA developed estimates assuming hydrogen production at capacity level. Therefore, no
adjustment to the emissions estimates is needed to account for PTE emissions.
New Units
Based on the industry growth factor of-0.1 percent for chemical manufacturing, EPA
assumed that no new plants would be constructed.
Threshold Summary
Table 33
Threshold Summary ~ Hydrogen Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
75
75
73
62
51
41
37
30
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
15.227
15.227
15.225
15.202
15.130
14.984
14.845
14.251
3.6.12 Iron and Steel Production
EPA used the Supporting Data for Threshold Analysis Subpart E - W, Greenhouse Gas
Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7) for the
proposed GHG MRR threshold analysis to determine process and combustion CC>2 and process
CH4. The iron and steel production source category includes taconite iron ore processing
facilities, integrated iron and steel making facilities, electric arc furnace (EAF) steelmaking
38
-------
facilities that are not located at integrated iron and steel facilities, and coke oven facilities that
are not located at integrated iron and steel facilities. Facility processes and facilities covered in
the spreadsheet are shown in the table below.
Table 34
Iron and Steel Processes, Facilities, and Capacity Information
Iron and Steel Process
Basic oxygen furnace (EOF)
Blast Furnace (BF)
Sintering
Coke ovens
Electric arc furnace (EAF)
Taconite furnace
Integrated steel plant fuel combustion*
Coke oven gas combustion*
EAF steel plant fuel combustion
Number of Facilities
18
17
5
18
92
8
19
9
92
Capacity Information
Yes
Yes
Yes
Yes
No
Yes
No
No
No
* Six plants had emissions from coke oven gas combustion was included in integrated steel plant fuel
combustion.
Potential to Emit
The analysis covered 130 plants, and in all cases, except for EAF plants, GHG emissions
were estimated based on operations at plant capacity. For EAF plants, EPA used the 2007
Federal Reserve industrial capacity utilization percentage of 86.6 percent for primary metal —
iron and steel production, to adjust estimated actual emissions to PTE.
The spreadsheet contained emission CC^e estimates which included CC>2, CH4, and N2O
emissions. Process CFLt emissions were backed out of the CC^e totals using the process CFLt
emissions reported in the U.S. GHG Inventory, and apportioning these emissions to the different
plants based on their capacity in those processes. N2O emissions are primarily related to fuel
combustion and were not backed out for separate treatment.
New Units
No new iron and steel facilities are expected to be built. The growth rate in primary
metals from the Economic Census data is only about 0.4 percent.
39
-------
Threshold Summary
Table 35
CO2 Threshold Summary — Iron and Steel Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
130
130
130
129
128
123
116
113
Number of New
Facilities Added
per year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
85.150
85.150
85.150
85.148
85.141
85.057
84.831
84.655
Table 36
Threshold Summary — Iron and Steel Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
Number of
Existing Sources
18
17
16
0
Number of New
Facilities Added
per Year
0
0
0
0
CH4 Emissions
Covered
(Tg per year)
0.034
0.033
0.032
0
40
-------
Table 37
COie Threshold Summary — Iron and Steel Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
130
130
130
129
128
123
116
113
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
85.151
85.151
85.151
85.149
85.141
85.058
84.832
84.656
3.6.13 Lead Production
According to the 2006 U.S. Geological Survey (USGS), lead production in the U.S.
includes both the primary, direct smelting (one facility) and secondary lead production (16
facilities). Process emissions of CC>2 are a byproduct of the coke consumed during the smelting
or reforming processes. EPA calculated total process emissions based on lead production as
reported in the USGS.
In the Supporting Data for Threshold Analysis SubpartE- W, Greenhouse Gas
Mandatory ReportingRulemaking (EPA-HQ-OAR-2008-0508-0046.7), combustion emissions
are combined with process emissions to determine total actual emissions.
Potential to Emit
In order to determine PTE emissions, EPA considered the Federal Reserve's 2006
monthly industrial capacity utilization estimates for primary metals industry classification which
shows utilization at 85.9 percent for 2006, and adjusted to achieve 100 percent utilization.
New Units
EPA assumed no new facilities would be added for the industry, given an expected
growth rate of 0.4 percent per year for primary metal manufacturing industry.
41
-------
Threshold Summary
Table 38
CO2e Threshold Summary ~ Lead Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
17
17
17
17
16
13
12
1
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
0.861
0.861
0.861
0.861
0.855
0.799
0.761
0.089
3.6.14 Lime
The Supporting Data for Threshold Analysis Subpart E - W, Greenhouse Gas Mandatory
Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7) was also used to
estimate GHG PTE for lime plants.
Potential to Emit
To estimate PTE, EPA divided annual actual CC>2 emissions from the calcining process
and fuel combustion emissions of CC>2, CJL; and N2O by regional capacity factors available in
the spreadsheet for each plant. The capacity factors ranged from 43 to 136 percent.
New Units
EPA assumed no new facilities would be added for the industry.
42
-------
Threshold Summary
Table 39
Threshold Summary — Lime Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
89
89
89
89
89
86
71
60
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
27.262
27.262
27.262
27.262
27.262
27.237
26.533
26.180
3.6.15 Magnesium Production and Processing
The magnesium metal production (primary and secondary) and casting industry typically
uses SF6 as a cover gas to prevent the rapid oxidation and burning of molten magnesium in the
presence of air. A dilute gaseous mixture of SF6 with dry air and/or CC>2 is blown over molten
magnesium metal to induce and stabilize the formation of a protective crust. A small portion of
the SFe reacts with the magnesium to form a thin molecular film of mostly magnesium oxide and
magnesium fluoride. The amount of SF6 reacting in magnesium production and processing is
being studied but presently assumed to be negligible, and therefore all SF6 used is assumed to be
emitted into the atmosphere.
For the proposed GHG MRR Technical Support Document for Process Emissions from
Magnesium Production and Processing: Proposed Rule for Mandatory Reporting of
Greenhouse Gases, EPA reported that national annual SFe emissions from magnesium
production and processing totaled approximately 3.2 million metric tons CC^e in 2006. The
facility population totaled 13 facilities that emitted 3.0 million metric tons CC^e. The SF6
emissions (no GWP adjustment) were 148 and 138 short tons respectively. Ten magnesium die
casting facilities accounted for 29 percent (44 tons), and primary and secondary production
accounted for 64 percent (96 tons) of the total emissions. Other small casting activities
accounted for the remaining 7 percent (ten tons).
43
-------
Potential to Emit
EPA used the analysis in the TSD for the proposed GHG MRR, where EPA had
evaluated thresholds of 1,000, 10,000, 25,000, and 100,000 metric tons per year. Facility-level
information is not made publicly available because of confidential business information (CBI)
claims. From that earlier analysis EPA estimated that the same number of facilities exceeded the
100, 250, and 1,000 tons CO2e per year PTE threshold as determined in the GHG MRR TSD for
the 1,000 metric tons per year threshold. In a similar fashion, EPA used the GHG MRR TSD
facility counts at 10,000 metric tons CC^e per year to estimate facilities at the 5,000 tons per year
PTE threshold, and 100,000 metric tons per year for the 50,000 tons CC^e per year PTE
threshold. The permit threshold analysis did not include CC>2 emissions from fuel combustion.
That information was not available in the TSD for the proposed GHG MRR.
On an SF6 mass basis, the average emissions per facility are only 11 tons of SF6, well
below 100 tons per year. Therefore we assumed that none of the facilities have a potential to
emit more than 100 tons per year of SF6.
New Units
EPA assumed no new units would be added for the sector.
Threshold Summary
Table 40
Threshold Summary ~ Magnesium Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
13
13
13
11
11
11
9
9
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
2.955
2.955
2.955
2.94
2.94
2.94
2.781
2.781
44
-------
3.6.16 Nitri c Aci d Product! on
EPA used the 2006 nameplate capacity (metric tons of HNOs 100 percent acid basis) for
45 nitric acid plants and 2006 acid production from the GHG MRR TSD supporting spreadsheet
(EPA-HQ-OAR-2008-0508-0046.7) to determine N2O emissions.
Potential to Emit
The GHG PTE was calculated by multiplying actual N2O emissions as CC^e by the ratio
of nameplate capacity to 2006 production. The permit threshold analysis, based on the GHG
MRR TSD, does not include GHG emissions from co-located stationary combustion units. Also
the permit threshold analysis does not account for overlap between facilities in the Nitric Acid
and Ammonia categories, which have both ammonia and nitric acid production processes.
New Units
EPA assumed no new units would be constructed for this sector.
Threshold Summary
Table 41
Threshold Summary — Nitric Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
43
42
27
4
0
0
0
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
N2O Emissions
Covered
(Tg per year)
0.055
0.055
0.049
0.016
0
0
0
0
45
-------
Table 42
Threshold Summary — Nitric Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
45
45
45
45
45
44
43
42
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
17.732
17.732
17.732
17.732
17.732
17.724
17.706
17.667
>.6.17 Petrochemical Production
EPA determined that the portion of the petrochemical production sector most relevant for
permit threshold analysis includes the manufacture and production of acrylonitrile, carbon black,
ethylene, ethylene dichloride, ethylene oxide, and methanol, because the IPCC considers
production of greenhouse gases from these processes significant compared to other
petrochemical processes.
Emissions from the manufacturing processes vary significantly, and process emissions
take many forms. Process emissions include direct oxidation of CC>2, off-gassing of CJLt and
CC>2, and the direct release of CC>2 and CH4 from equipment leaks. Process emissions are the
primary consideration for acrylonitrile, ethylene, and ethylene oxide processes. In addition,
some processes require combustion of supplemental fuel. Both process and combustion
emissions are significant for carbon black and methanol processes.
Potential to Emit
EPA's analysis assumed petrochemical production at the capacity level. Therefore, no
adjustment to the emissions estimates is needed to account for PTE.
New Units
Based on an industry growth factor of-0.1 percent for chemical manufacturing, EPA
assumed that no new plants would be constructed.
46
-------
Threshold Summary
Table 43
COi Threshold Summary ~ Petrochemical Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
98
98
98
97
96
96
94
91
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
52.081
52.081
52.081
52.080
52.073
52.073
52.005
51.806
Table 44
CH4 Threshold Summary ~ Petrochemical Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
55
52
37
5
1
0
0
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CH4 Emissions
Covered
(Tg per year)
0.130
0.129
0.121
0.035
0.010
0
0
0
47
-------
Table 45
Threshold Summary ~ Petrochemical Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
98
98
98
97
96
96
94
91
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
54.826
54.826
54.826
54.825
54.818
54.818
54.748
54.595
3.6.18 Petroleum Refineries
In developing the permit threshold analysis for petroleum refineries, EPA quantified CH4
process emissions from wastewater, fugitive, flares, and storage tanks. Process CC>2 emissions
derived from flares, hydrogen plant emissions, and sulfur plant emissions. In addition, on-site
combustion emissions were calculated considering fuel consumed by type.
Potential to Emit
EPA assumed that petroleum refineries were operating at capacity level. Therefore, no
adjustment to the emissions estimates was needed to account for PTE.
New Units
According to the ICR prepared for the New Source Performance Standard (NSPS), EPA
expects that no new refineries will be built over the next few years.
48
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Threshold Summary
Table 46
Threshold Summary — Petroleum Refineries
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
150
150
150
150
149
146
137
129
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
202.947
202.947
202.947
202.947
202.938
202.887
202.575
202.065
Table 47
CH4 Threshold Summary — Petroleum Refineries
GHG Threshold
(tons per year)
100
250
1,000
5,000
Number of
Existing Sources
129
109
31
0
Number of New
Facilities Added
per Year
0
0
0
0
CH4 Emissions
Covered
(Tg per year)
0.083
0.080
0.042
0
49
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Table 48
Threshold Summary — Petroleum Refineries
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
150
150
150
150
149
146
137
129
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
204.897
204.897
204.897
204.897
204.888
204.835
204.513
203.988
3.6.19 Phosphoric Acid Production
Phosphoric acid is produced by combining sulfuric acid and phosphate rock. CO2 is
emitted when the limestone component of phosphate rock reacts with the sulfuric acid.
Potential to Emit
When these process emissions are combined with combustion emissions, all 14 plants
have emissions that exceed the highest threshold level; consequently, no PTE analysis was
required.
New Units
Based on an industry growth factor of-0.1 percent for chemical manufacturing, EPA
assumed that no new plants would be constructed.
50
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Threshold Summary
Table 49
Threshold Summary ~ Phosphoric Acid Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
14
14
14
14
14
14
14
14
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
3.838
3.838
3.838
3.838
3.838
3.838
3.838
3.838
3.6.20 Pulp and Paper Manufacturing
Permit threshold analysis for this sector is focused on the energy intensive, fugitive
emitting pulp, paper, and paperboard manufacturing subsectors. Process emissions include CO2
which is emitted in the recovery cycle at kraft and soda facilities associated with the chemical
pulp process. The CC>2 emitted from kraft mill lime kilns originates from two sources: (1) fossil
fuels burned in the kiln, and (2) conversion of calcium carbonate (or "lime mud") generated in
the recovery process to calcium oxide.
The bulk of the emissions considered derive from combustion. Many boilers use biomass
fuel, and the burning of spent pulping liquors to produce steam for facility processes is
considered biomass combustion for the GHG MRR. The emissions numbers considered for the
permit threshold analysis are non-biogenic (net of any biogenic emissions). Considering only
non-biogenic emissions, 96.5 percent of the facilities and 99.7 percent of the emissions are
captured by all of the thresholds proposed for consideration of the permit threshold rule.
Potential to Emit
Because 99.7 percent of emissions were captured at even the highest threshold, no
additional PTE estimate was calculated in this analysis.
51
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New Units
Based on an industry growth factor of-2.5 percent for paper manufacturing, and previous
EPA analysis for the pulp and paper NSPS ICR, EPA assumed that no new plants would be
constructed.
Threshold Summary
Table 50
Threshold Summary — Pulp and Paper Manufacturing
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
425
425
425
425
425
425
422
410
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
57.700
57.700
57.700
57.700
57.700
57.700
57.688
57.527
3.6.21 Silicon Carbide Manufacturing
In 2006, one facility produced silicon carbide in the U.S. Silicon carbide is primarily an
industrial abrasive manufactured from silica sand or quartz and petroleum coke. Approximately
35 percent of the carbon from the petroleum coke is retained with the silicon carbide, and the rest
is emitted as both CC>2 and CH4. In addition, emissions from combustion account for
approximately ten percent of total emissions.
Potential to Emit
Emissions from this plant exceed all permit threshold levels; as a result, EPA did not
consider PTE calculations.
New Units
52
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EPA assumed there would be no new facilities constructed.
Threshold Summary
Table 51
Threshold Summary ~ Silicon Carbide Manufacturing
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
1
1
1
1
1
1
1
1
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
0.101
0.101
0.101
0.101
0.101
0.101
0.101
0.101
Table 52
Threshold Summary ~ Silicon Carbide Manufacturing
GHG Threshold
(tons per year)
100
250
1,000
Number of
Existing Sources
1
1
0
Number of New
Facilities Added
per Year
0
0
0
CH4 Emissions
Covered
(Tg per year)
0.0004
0.0004
0
53
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Table 53
COie Threshold Summary ~ Silicon Carbide Manufacturing
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
1
1
1
1
1
1
1
1
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
0.109
0.109
0.109
0.109
0.109
0.109
0.109
0.109
3.6.22 Soda Ash Production
Soda Ash production emissions were nearly evenly split between process and combustion
emissions. Process emissions result from calcining trona ore to produce soda ash.
Potential to Emit
PTE emissions were calculated based on the capacities of the production units.
New Units
In 2006, there was a glut of soda ash in the domestic market; EPA assumed no new units
would be constructed.
54
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Threshold Summary
Table 54
CO2e Threshold Summary — Soda Ash Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
5
5
5
5
5
5
5
5
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
3.121
3.121
3.121
3.121
3.121
3.121
3.121
3.121
3.6.23 Titanium Dioxide Production
EPA used USGS as the source for production capacity for the eight facilities that
produced titanium dioxide in 2006.
Potential to Emit
Emissions were assumed to represent PTE operating levels.
New Units
EPA assumed that no new plants would be constructed.
55
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Threshold Summary
Table 55
Threshold Summary ~ Titanium Dioxide Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
8
8
8
8
8
8
8
7
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
3.686
3.686
3.686
3.686
3.686
3.686
3.686
3.628
3.6.24 Zinc Production
The Zinc production emissions and facility count estimates include process and
combustion emissions associated with primary smelting and secondary recycling facilities.
Potential to Emit
For PTE estimates, EPA considered the Federal Reserve's 2006 monthly industrial
capacity utilization estimates for primary metals industry classification which shows utilization
at 85.9 percent for 2006, and adjusted to achieve 100 percent utilization.
New Units
EPA assumed that no new units would be constructed.
56
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Threshold Summary
Table 56
Threshold Summary — Zinc Production
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
9
9
9
9
8
5
5
5
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
0.852
0.852
0.852
0.852
0.843
0.802
0.802
0.802
3.7 Energy Sector
3.7.1 Oil and Gas Systems
In consideration of the permit thresholds, EPA considered the Fugitive Emissions
Reporting from the Petroleum and Natural Gas Industry: Background Technical Support
Document (EPA-HQ-OAR-2008-0508-0023). This document details combustion emissions and
fugitive emissions from offshore petroleum and natural gas facilities, onshore natural gas
processors, onshore natural gas transmission, underground natural gas storage, and liquid natural
gas storage. EPA determined that oil and gas exploration, development, transmission, and
distribution are not listed PSD source categories, and therefore fugitive emissions from these
activities were not considered for PSD applicability as it relates to major source thresholds.
EPA's analysis focused on combustion emissions from these sources.
Potential to Emit
EPA considered capacity utilization figure of 90 percent as published in the Federal
Reserve's capacity utilization data to determine PTE emission estimates and counts.
57
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New Units
EPA determined new units based on a growth factor of 1.0 percent for the sector.
Threshold Summary
Table 57
CO2e Threshold Summary ~ Oil and Gas Systems
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
4762
4762
4762
3443
2602
1253
387
129
Number of New
Facilities Added
per Year
48
48
48
34
26
13
0
0
CO2e Emissions
Covered
(Tg per year)
88.264
88.264
88.264
85.113
80.314
61.547
32.750
18.541
3.7.2 Underground Coal Mining
GHG emissions from underground coal mining include CH4 fugitive emissions released
from the coal seam and surrounding rock during mining and post-mining activities (coal bed
CH4), and fuel combustion emissions of CC>2, CH4, and N2O. Fugitive CH4, emissions are
captured and vented by ventilation systems and degassing systems. Captured and vented CH4
emissions from active mines were considered in the PTE analysis. Because underground coal
mining is not one of the 28 PSD source categories for which fugitive emissions were required to
be included in the emissions determination, fugitive emissions from post mining operations,
surface mines, and inactive mines were not included in the permit thresholds analysis.
The Technical Support Document for Under ground Coal Mines: Proposed Rule for
Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0032) identified 612
active underground coal mining facilities but analysis of CH4 emissions was limited to 128
"gassy" mines where CH4 monitoring was already in place (due to existing CH4 emissions above
Mine Safety and Health Administration (MSHA) threshold levels). The U.S. GHG Inventory
(EPA, 2008) reports that 233 underground coal mines (including 133 gassy mines) ventilated
58
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CH4 in 2007. Fuel combustion emission estimates for the GHG MRR TSD from all underground
coal mines, based on U.S. Census energy use data, were found to comprise between one and
three percent of total CC^e emissions, with coal bed CH4 accounting for the bulk of GHG
emissions.
In addition to the emissions data on the 128 gassy mines contained in the GHG MRR
TSD, EPA considered combustion emissions from 289 bituminous underground coal mines,
using U.S. Census data from 2002.
Potential to Emit
CH4
CH4 emission estimates that were developed for the GHG MRR TSD were used for both
actual emissions and PTE emissions permit threshold analysis. EPA assumed that venting and
degassing were continuous throughout the year; therefore, actual emission estimates equal PTE
emission estimates. The estimates considered 128 gassy mines, which were assumed to be the
largest emitters of vented CH4. The smallest mine of this group had annual CH4 emissions of 26
tons; therefore EPA assumed that the annual CH4 emissions from the 105 vented mines that were
not included in the TSD analysis were less than 26 tons.
CO2
CO2 emissions were estimated in the same manner as for other Unspecified Industrial
Stationary Combustion categories, based on the ICF analysis (ICF, 2007) using the MECS
approach. Emissions were estimated based on Census information including fuel consumption
per employee and the distribution of establishments by the number of employees. PTE was
estimated by using a capacity utilization factor of 86.3 percent as published by the Federal
Reserve.
New Units
The number of underground bituminous coal mines in the U.S. is on the decline. EIA
data show that only Colorado had an increase in the number of underground coal mines between
2006 and 2007 (EIA, 2008). The EIA data show that overall the number of underground coal
mines decreased from 2006 to 2007 by eight percent; consequently, EPA assumed no new
underground mines would be built, http://www.eia.doe.gov/cneaf/coal/page/acr/table 1 .html
59
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Threshold Summaries
Threshold summary tables are shown below for CJLt (vented fugitive emissions), CC>2
(fuel combustion), and CO2e (vented fugitive CH4 and combustion CO2).
Table 58
COi Threshold Summary — Underground Coal Mining
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
Number of
Existing Sources
238
202
63
30
30
0
Number of New
Facilities Added
per Year
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
0.783
0.778
0.692
0.577
0.577
0
Table 59
CH4 Threshold Summary — Underground Coal Mining
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
110
110
110
53
38
24
13
1
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
1.586
1.586
1.586
1.420
1.361
1.147
0.784
0.105
60
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Table 60
COie Threshold Summary — Underground Coal Mining
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
238
238
126
124
123
103
78
55
Number of New
Facilities Added
per Year
0
0
0
0
0
0
0
0
CO2e Emissions
Covered
(Tg per year)
39.520
39.520
33.945
33.943
33.936
33.606
32.800
31.241
3.8 Waste Sector
3.8.1 Landfills
The landfill PTE analysis includes both municipal solid waste (MSW) landfills and onsite
industrial landfills associated with pulp and paper and food processing. The analysis used a
modification of the landfill emission modeling approach used for the proposed GHG MRR
threshold analysis. Like the GHG MRR analysis, the permit threshold PTE analysis did not
include onsite industrial landfills for ethanol processing facilities or industrial land application
systems.
GHG Emissions
Decomposition of waste in landfills generates CH4 and CC>2. The amount of CH4
generated from a given landfill is a function of several factors: the total amount of waste
disposed in the landfill, the characteristics of the waste, and the climatic conditions. The amount
of CfL; emitted is the amount of CfL; generated minus the amount of CfL oxidized by aerobic
microorganisms in the landfill cover material. Also subtracted from the total is the amount of
CH4 that is destroyed by combustion of the vented gas. The CC>2 produced by decaying waste is
not considered an anthropogenic emission, and is not counted in GHG emission totals. Likewise,
CC>2 resulting from the combustion of landfill CH4 is not accounted for as an anthropogenic
emission under international accounting guidance.
61
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According to the 2008 U.S. Inventory, MSW landfills emitted 111.2 million metric tons
CH4 (CO26 basis) in 2006. The majority of the CH4 emissions from on-site industrial landfills
occurs at pulp and paper facilities and food processing facilities. In 2006, these landfills emitted
14.6 million metric tons CC^e
Potential to Emit
The methodology used for the proposed GHG MRR threshold analysis was also used to
estimate CH4 generation rates and emissions in 2006 for the PTE analysis. A landfill-specific
model developed by EPA to support its proposed GHG MRR was used to estimate CH4
generation and potential generation from municipal landfills. The generation estimate was
adjusted with assumptions on oxidation in landfill cover, and destruction by combustion for
energy recovery or flaring. The industrial landfill generation and emission estimates are based
on the U.S. GHG Inventory. Industrial landfills were assumed not to have energy recovery or
flaring, so there was no difference between generation and emissions.
New Units
EPA did not estimate the number of new facilities added each year with CH4 emissions
above the different thresholds due to the time delay between landfill construction and emission
generation.
3.8.2 Municipal Solid Waste Combustors
The threshold analysis for the proposed GHG MRR included municipal solid waste
combustors (MWC) in the general stationary fuel combustion category. The analysis used the
eGRTD database, which is discussed in the PTE methodology description for electric generating
units.
Data and Methodology
EPA used the latest version of the eGRTD database (2006) to estimate the PTE of MWC
facilities and counts of facilities above the different emission thresholds. The eGRID database
includes year 2004 characteristics, operating information, and annual CC>2 emissions for U.S.
facilities that have a generation capacity greater than one MW and sell electric power to the grid.
By using eGRID, EPA assumed that all MWC facilities sell power to the grid.
Potential to Emit
EPA identified 75 MWC facilities based on the generator primary fuel in the generator
table (primary fuel equals MSW) in the eGRID database. The eGRID database contains CC>2
annual emissions estimates for the facilities. For CC>2 emissions, eGRID uses a standard
assumption that 70 percent of the heat value of the waste stream comes from renewable materials
62
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and 30 percent comes from nonrenewable materials. The renewable fraction has a CC>2 emission
rate of zero; therefore, the PTE threshold analysis is based on the nonrenewable or fossil fraction
assumption. EPA estimated PTE by dividing the annual emissions from eGRTD by the eGRID
plant capacity factor.
New Units
To determine the number of new per year at different thresholds, EPA counted the
number of generators online each year, and totaled the nameplate capacity for each online year.
This information was compared to the total facility nameplate capacity, and the PTE for the
increased capacity was calculated by multiplying the facility PTE by the fraction of nameplate
capacity associated with the new generators. EPA counted the facilities that exceeded the PTE
thresholds during each period, and computed a 15-year average to determine the number of new
or modified facilities per year.
Threshold Summary
Table 61
COi Threshold Summary — Municipal Solid Waste Combustors -
GHG Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
75
75
75
75
75
74
67
40
Number of New
Facilities Added
per Year
2
2
2
2
2
2
1
1
CO2 Emissions
Covered
(Tg per year)
6.255
6.255
6.255
6.255
6.255
6.24
6.071
4.958
3.9 Agriculture (Stationary Fuel Combustion)
The analysis for the Agriculture sector was limited to stationary fuel combustion CC>2
emissions from internal combustion diesel engine generators. Fugitive emissions of CFLi from
enteric fermentation, and CC>2, CH4 and N2O from manure management were not included
because farms and related operations are not in the 28 PSD source categories that require
63
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quantification of fugitive emission PTE for determining major source status, and because of the
large uncertainties and lack of information on determining what component of the non-
combustion emissions at agricultural operations would be defined as non-fugitive for PSD
purposes. Fuel combustion for building space heating and other farm purposes were not
included in the estimates, but would be a component of farm PTE.
Data and Methodology
EPA used the 2007 ICF analysis to estimate the number of farms covered by the different
thresholds (ICF, 2007). Emissions from diesel generators on farms were estimated using data on
the average generator size in Delaware (EEA, 2004), and data on energy use on farms for non-
transport/non-machinery motors (Brown and Neal 2005). Using these data, EPA estimated the
number of diesel generators on farms and apportioned the generators across farm sizes, assuming
no farm has more than one generator.
Potential to Emit
EPA assumed that a high proportion of farms would run the generators infrequently, and
a smaller proportion would have a generator as the only power source, requiring nearly constant
operation. EPA used this distribution to determine actual and potential emissions, with PTE
emissions based on the assumption that the generators ran 24 hours per day, 365 days per year.
EPA recognizes that this approach underestimates the PTE for all farm stationary fuel
combustion sources, because it is limited to diesel engine generators used primarily to run pumps
and motors, and does not include additional sources such as fuel combustion for drying and
curing, space heating, and water heating.
New Units
New generator installations were estimated based on information in the Regulatory
Impact Analysis (RIA) for the spark ignition stationary combustion engine NSPS and area
NESHAPS (EPA, 2007). The on-farm engine population of diesel generators used for irrigation
increased four percent between 1998 and 2003, or about 0.8 percent annually.
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Threshold Summary
Table 62
CO2 Threshold Summary ~ Farm Stationary 1C Engines
CO2 Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
37,351
37,351
0
0
0
0
0
0
Number of New
Engines Added
per Year
299
299
0
0
0
0
0
0
CO2 Emissions
Covered
(Tg per year)
0.512
0.512
0
0
0
0
0
0
3.10 Commercial Stationary Fuel Combustion
Data Source
EPA used EIA's Commercial Building Energy Consumption Survey (CBECS) to estimate
commercial sector stationary fuel combustion GHG emissions and PTE. CBECS is a national
sample survey that collects information on the stock of U.S. commercial buildings, their energy-
related building characteristics, and their energy consumption and expenditures. Commercial
buildings include all buildings in which at least half of the floor space is used for a purpose that
is not residential, industrial, or agricultural; thus, the source category includes building types that
might not traditionally be considered "commercial," such as schools, correctional institutions,
and buildings used for religious worship. The CBECS survey is conducted every four years and
the most recent survey was completed for 2003.
The CBECS survey sample was designed so that survey responses could be used to
estimate characteristics of the entire nationwide commercial building stock. The 2003 survey
selected 6,955 potential case buildings for sampling. The sampling procedures resulted in 5,215
completed building interviews for a response rate of 82 percent. To make national estimates
from the sample data, EIA calculated base sampling weights for each building (the reciprocal of
the probability of that building being selected into the sample). In other words, the base
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sampling weight is the number of national buildings represented by the sampled building. The
base weight was further adjusted to account for nonresponsive bias.
EIA publishes summary tables from the survey, and posts "microdata" files on the EIA
website. The CBECS microdata consist of the 5,215 sampled building records, which each
correspond to a single sampled building. For each building, these files contain information such
as the building size, climatic region, census region, year constructed, types of energy used, and
energy consumption and expenditures. These individual building microdata records are also the
basis for the summary tables published by EIA.
Emissions Methodology
EPA used the CBECS microdata to estimate commercial building emissions and
populations above emission thresholds. Each of the 5,215 microdata records corresponds to a
single sampled building. EIA has made available 20 different data files of the microdata records
which contain a wide range of information on characteristics and energy use for each building.
EPA's analysis relied on guidance provided by EIA on how to use the data. As noted
above, the CBECS sample was designed so that survey responses could be used to estimate
characteristics of the entire commercial building stock nationwide. The table below provides
examples from EIA on how to calculate national commercial building characteristics from the
sample building data.
Table 63
EIA Website Examples
To Find the National
Estimate for:
Total number of buildings
Total number of office
buildings
Total floor space
Total floor space in buildings
with air conditioning
Total electricity consumption
inKWh
Do This...
Sum ADJWT8 (weight factor)
Sum ADJWT8 for cases where PBA8 (building
code) = "02"
Create a new variable (weighted square footage) by
multiplying ADJWT8 by SQFT8 (floor space) for each
case, then sum this new variable
Sum the new weighted square footage variable (see
above) for cases where COOLS (air conditioning) = "1"
Create a new variable (weighted electricity consumption)
by multiplying ADJWT8 by ELCNS8 (electricity
consumption) for each case, then sum this new variable
And You
Should Get...
4,858,749.82
(or 4,859 thousand)
823,805.47
(or 824 thousand)
71,657,900,522
(or 7 1,658 million ft2)
63,559,999,624
(or 63,560 million ft2)
1,043,175,710,751
(or 1,043 billion kWh)
Source: http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public use 2003/cbecs pudata2003.html
66
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EIA calculated base sampling weights for each surveyed building (these are the
reciprocal of the probability of that building being selected into the sample). Therefore, a
building with a base weight of 1,000 represents itself and 999 similar but unsampled buildings in
the total building stock. The base weight is further adjusted to account for non-response bias.
The variable "ADJWT8" in the data file is the final weight. The ADJWT8 weight factor is used
as described in Table 63 to extrapolate the survey sample to a national scale for any value. In
order to obtain a national value each sample building's value must be multiplied by the building's
weight (ADJWT8). All of the weighted values are then summed.
2003 CO2 Emissions
EPA calculated the CO2 emissions for each of the 5,215 buildings based on the annual
natural gas and oil consumption reported for the building. For national emission estimates and
counts of buildings with annual CC>2 emissions over any threshold, EPA multiplied the base
weights by the sample emission totals to determine the national estimate of buildings with
emissions over the threshold.
Potential to Emit
EPA estimates that commercial buildings operate at 15 percent of capacity. EPA
considered several sources in making the PTE factor determination:
• A report prepared by Energy and Environmental Analysis, Inc. for Oak Ridge National
Laboratory describing the industrial and commercial boiler population in the United
States (EEA, 2005). The report estimated an average commercial boiler capacity factor
of 16 percent.
• Reports on cooking equipment energy use by the Food Service Technology Center in
California suggesting that the cooking equipment in food service establishments operate
at about ten percent of a theoretical maximum capacity based on 8,760 hours per year
(Pechan, et.al, 2008).
• A study of Los Angeles dry cleaners performed by the Pollution Prevention Education
and Research Center (PPERC) in 2004 which demonstrates that dry cleaners operate
boilers at about ten to 15 percent of maximum capacity over a normal year (Pechan, et
al., 2008).
New Buildings
The CBECS data identifies the year the sampled buildings were constructed. We used
the construction year information to identify the number of new buildings built each year in the
1990 to 2003 period. Counts of the average number of these buildings built per year were then
made at the different emissions and PTE thresholds.
Threshold Summary
67
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The count of buildings and emissions at the threshold levels for the entire sector are
shown in the table below. Threshold results by commercial building categories (e.g., offices,
public assembly, schools) are provided in Appendix B.
Table 64
COi Threshold Summary — Commercial Sector Stationary Fuel Combustion
CO2 Threshold
(tons per year)
100
250
1,000
5,000
10,000
25,000
50,000
100,000
Number of
Existing Sources
1,355,921
731,477
172,654
18,167
5,660
1,161
600
51
Number of New
Facilities Added
per Year
22,123
12,041
2,922
196
96
7
3
2
CO2 Emissions
Covered
(Tg per year)
119.262
105.306
69.885
29.384
17.765
8.790
6.003
1.012
i. 11 Residential Buildings
Data Sources
EPA used residential fuel consumption data from EIA's Residential Energy Consumption
Survey, and multi-family building and unit data from U.S. Census (Census) surveys to estimate
CC>2 emissions and PTE for fuel combustion at single and multi-family residential properties.
The RECS is a national area-probability sample survey that collects energy-related data for
occupied primary housing units. The most recent 2005 survey collected data from 4,382
households in housing units statistically selected to represent the 111.1 million housing units in
the United States. RECS data are tabulated for the four Census regions, the nine Census
divisions, and for the four most populous States — California, Florida, New York, and Texas.
The RECS sample was designed so that survey responses could be used to estimate
characteristics of the national stock of occupied housing units. In order to arrive at national
estimates from the RECS sample, EPA calculated base sampling weights for each housing unit
as the reciprocal of the probability of that building being selected into the sample. Therefore, a
housing unit with a base weight of 10,000 represents itself and 9,999 similar, but not sampled
housing units in the total stock of occupied residential housing units. The base weight is further
adjusted to account for non-response bias. Ratio adjustments were also used to ensure that the
68
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RECS weights add up to Census Current Population Survey estimates of the number of
households.
The RECS data are provided at the housing unit level, and not at the building level. EPA
used additional data from the Census on multi-family building population characteristics to
estimate total property emissions and PTE for multi-unit properties. Census data were from two
sources: the Property Owner and Manager Survey (POMS, 1996) and the American Housing
Survey (AHS, 2005).
3.11.1 Single-Family Homes
The RECS data was used directly to estimate CO2 emissions from fossil fuel combustion
at single-family housing units for space heating, water heating, and appliances. EPA assumed
that each unit in an attached single-family building was a separate source, with combustion
equipment under different ownership.
The annual energy consumption by fuel (1,000 Btu's) for the surveyed unit was
multiplied by the fuel CO2 emission factor to estimate annual emissions. Total single-family unit
emissions for the entire country were calculated by multiplying CO2 emissions for each units by
the base sampling weight.
Potential to Emit
The PTE for a single-family unit was calculated by dividing the CO2 emissions from the
unit by a capacity factor of 0.1. This factor was estimated by comparing the average annual CO2
emissions per heated floor space area per hour by climate zone, to required heat input capacity.
The required heat input capacity was based on rule of thumb heating system requirements for the
different climate zones. The table below shows the average Btu/ft2-hour from the RECS data
and Heating Requirement (Btu/ft2) by climate zone. A heating system efficiency of 80 percent
was used to estimate the required space heating capacity.
Table 65
Single-Family Detached and Attached
Households with Fossil Fuel-Fired Space Heating
(from RECS, 2005)
Households
(millions)
6.8
16.7
17.0
Climate
Zone(s)
5
4
3
Heating Degree
Day Range
> 7,000
5,500 - 7,000
4,000 - 5,499
Average Annual Fuel
Consumption
(Btu/ft2-hour)
4.8
5.4
4.6
Space Heating
Requirement*
(Btu/ft2)
50-60
45-50
40-45
69
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18.9
land 2
< 4,000
3.8
Zone 2: 35-40
Zone 1: 30-35
* Heating requirement ranges are from www.acdirect.com/svstemsize.php
3.11.2 Multi-Family Residential Buildings
Emission Rates
As noted earlier in the Data Source section, the RECS data are on an individual unit
basis, not building or property basis, so a different approach was required for multi-family units
where EPA assumed common ownership of the property fuel combustion equipment. In order to
estimate property emissions and the number of properties above different emission and PTE
thresholds, EPA combined the RECS data with data from the POMS and AHS.
From the RECS data, EPA first calculated average residential unit CC>2 emissions for the
two most common fuels (natural gas and oil) by multi-family category. These are shown in the
table below.
Table 66
Multi-Family Residential Unit ~ Average Annual COi Emissions
(from RECS, 2005)
Multi-Family Category
(number of units)
2 to 4 units
5 or more units
Natural Gas Space Heating
(tons CO2/residential unit-year)
4.8
3.0
Fuel Oil Space Heating
(tons CO2/residential unit-year)
8.3
8.9
EPA also obtained annual CC>2 emission rates from an EPA analysis that was based on
Lawrence Berkeley National Lab (LBNL) modeling studies. Those rates were estimated for old
and new building units (see Table 67). The pre-1980 building estimate compares with the
overall average from the RECS data. The post-1980 building estimates are much lower,
particularly for units burning fuel oil.
70
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Table 67
Multi-Family Residential Unit ~ Average Annual COi Emissions
(from 2008 EPA Analysis based on LBNL, 1997)
Multi-Family Category
(building age)
Pre- 1980 building
Post-1980 building
Gas Serviced Units
(tons CO2/residential unit-year)
4.75
2.65
Fuel Oil Serviced Units
(tons CO2/residential unit-year)
7.17
3.87
Existing Property Characteristics
Information on the distribution of multi-family properties by number of units per property
was taken from the 1995 - 1996 POMS. The data are aggregated by different housing unit
ranges. The table below shows the property size distribution from unpublished POMS data
(NMHC Quick Facts — Apartment Stocks (http://www.nmhc.org)). The POMS data were for
privately owned housing only, and excluded public housing projects (about 13,500 buildings and
1,326,000 units). For our estimates, the building numbers were adjusted to current (2005) levels
based on the RECS unit data (unit ratio of RECS to POMS). EPA assumed the same unit
distribution in the adjustment.
Table 68
Multi-Family Residential Property Size Distribution
(from National Multi-Housing Council tabulation of unpublished POMS data 1995 - 1996)
Number of Rental
Units on Property
2
3
4
5-9
10-14
15-19
20-29
30-39
40-49
50-99
100 - 199
Number of Properties
(1995 - 1996)
1,558,700
336,030
341,350
281,500
70,390
36,780
38,000
18,166
14,431
26,694
19,804
Number of Units
(1995 - 1996)
3,093,200
1,025,900
1,436,800
1,897,700
862,280
602,260
916,750
604,240
702,790
2,009,400
2,952,300
Average Number
of Units per
Property
2
3
4
7
12
16
24
33
49
75
149
71
-------
200 - 299
300-399
400 - 499
500 - 749
Over 750
Total
7,775
2,966
1,307
723
307
2,754,923
1,948,400
1,058,800
605,130
431,360
437,670
20,584,980
251
357
463
597
1,426
The adjusted POMS size distribution and average number of units in each category were
combined with information from RECS on the percentage of units that use gas or oil for space
heating. The gas and oil emission factors from the previous tables were applied to the average
number of units in each property size category by fuel to estimate property annual CC>2
emissions.
For our final estimates we used the LBNL based emission factors for post-1980
buildings, over the RECS based factor. We found that these lower emission factors resulted in
total emissions more in line with the total based on all RECS units and residential sector
estimates in the U.S. Greenhouse Gas Inventory. The RECS-based factors combined with the
POMS property distribution data resulted in a larger overestimate in overall category annual
emissions. The lack of information on the building population over 50 units, and lack of
information on the correlation between unit emissions and the building/property size are large
sources of uncertainty in the estimates at thresholds above 1,000 tons.
Potential to Emit
PTE was estimated using the same ten percent capacity factor as used for the single
family residential units
New Properties
The AHS data provided information on new construction used to estimate the number of
new buildings and new units with natural gas space heating that were constructed in the 1999 -
2005 period. To simplify the analysis, EPA ignored the limited use of fuel oil for space heating
in new units.
The AHS data provided separately the number of new buildings with gas space heating
per year, and a size distribution for all new buildings per year. The AHS size distribution
stopped at 50 and larger, and was slightly different in other categories from the POMS data.
EPA adjusted the distribution based on the POMS distribution and then used the same emission
and capacity factor approach as used for existing units.
72
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Table 69
American Housing Survey New Building Data
Building Size:
Number of Units
per Building
2
3-4
5-9
10-19
20-29
30-49
50 or more
Total
Number of New
Buildings per Year
(1999 - 2005)
(thousands)
6.3
5.4
6.1
6.0
3.1
1.0
1.0
29.0
Fraction of All
New Buildings
per Year
(1999 - 2005)
0.22
0.19
0.21
0.21
0.11
0.03
0.03
1.00
New Gas Buildings
per Year
(1999 - 2005)
(thousands)
16.0
16.0
Number of New
Gas Buildings
per Year
3,468
2,995
3,389
3,310
1,734
552
552
16,000
73
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Threshold Summary
Table 70
CO2 Threshold Summaries — Residential Sectors
Threshold
(tons per year)
Number of
Existing Sources
Number of New
Facilities Added
per Year
CO2 Emissions
Covered
(Tg per year)
Multi-Family Residential
100
250
1,000
5,000
10,000
25,000
50,000
100,000
610,500
137,000
51,200
7,800
1,400
160
20
0
11,300
6,400
1,100
120
20
o
5
0
0
54.285
42.192
32.399
14.934
4.933
1.392
0.006
0
Single-Family Residential
100
250
1,000
3,925,000
45,350
0
33,000
515
0
51.408
1.670
0
Total Residential Sector
100
250
1,000
5,000
100,00
25,000
50,000
100,000
4,535,500
182,350
51,200
7,800
1,400
160
20
0
44,300
6,915
1,100
120
20
o
6
0
0
105.693
43.862
32.399
14.934
4.933
1.392
0.006
0
74
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78
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79
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Appendix A
Sector Permit Threshold Counts and Emissions by GHG
The listed electronic spreadsheet files contain the permit threshold counts and emissions
for each sector and subsector by GHG. These listed files are included in separate files in the
docket (EPA-HQ-OAR-2009-0517). Please refer to the following file names for additional
information on specific sectors and GHGs:
• GHG Data for Permitting Threshold Rule Development - CO2e.xls
• GHG Data for Permitting Threshold Rule Development - CO2.xls
• GHG Data for Permitting Threshold Rule Development - CH4.xls
• GHG Data for Permitting Threshold Rule Development - N2O.xls
• GHG Data for Permitting Threshold Rule Development - HFC.xls
• GHG Data for Permitting Threshold Rule Development - PFC.xls
• GHG Data for Permitting Threshold Rule Development - SF6.xls
80
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Appendix B
Commercial Building Sector — Permit Threshold Results by Commercial Category
Please refer to the electronic file "Commercial Building Category CO2 Permit Threshold
Results.xls." in the docket for EPA-HQ-OAR-2009-0517.
81
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Attachment C
Summary of ICR-based Data Used to Estimate Avoided Burden and Evaluate Resource
Requirements at Alternative GHG Permitting Thresholds
Prepared by EPA Staff
August 2009
1. Introduction
This paper summarizes an assessment of the potential resource requirements for
permitting authorities to include GHGs at different possible major source permitting thresholds
and the avoided burden and costs for permitting authorities and sources as a result of including
GHGs at a 25,000 tpy permitting threshold for Title V and Prevention of Significant
Deterioration (PSD) permitting programs. The analysis was performed using a GHG permitting
threshold metric based on CCVequivalents (CC^e), which represents the sum of the six primary
GHGs with their global warming potentials (GWP) applied. Time and costs associated with
permit activities are derived from existing Information Collection Requests (ICRs). Estimates
for the number of affected permits used in this analysis were obtained from two technical support
documents developed for the proposed GHG tailoring rule: Technical Support Document for
Greenhouse Gas Emissions Thresholds Evaluation (GHG Thresholds TSD) and Methodology for
Estimating New and Modified Sources that Would Be Subject to PSD Permitting for GHGs
(GHG PSD Sources TSD), both of which can be found atEPA-HQ-OAR-2009-0517.
Significant uncertainties exist in the following estimates due to the lack of historical record and
permitting experience upon which to base resource needs for including GHG sources.
2. Evaluation of ICR-based Resource Requirements for Permitting Authorities at Different
Possible GHG Permitting Thresholds
Title V Permits
Table 2-1 presents the estimated burden estimates for permitting authorities at different
possible Title V GHG major source applicability thresholds. Descriptions of the different
thresholds selected are provided below. Burden estimates are calculated based on information
obtained from the April 2007 Information Collection Request for State Operating Permit
-------
Regulations14. Annual values are derived from Tables 7 and 8 of the ICR. For consistency, the
permitting authority labor costs are updated to 2007 dollars utilizing the 2007 General Schedule
Salary Table from the Office of Personnel Management. For the purposes of this analysis, we
assumed that commercial/residential sources that exceed the major source threshold due to GHG
emissions will not likely have substantial applicable requirements in the near term. We also
assumed that permits for such sources will not require as much time to prepare and issue as those
for industrial sources, which have applicable requirements in addition to GHG. Therefore, it is
estimated that new commercial/residential permits require 10% of the time needed for new
industrial permits, or 43 hours compared to 428 hours for permitting authorities. For significant
revisions and permit renewals, it is assumed that incorporating GHG information adds 9 hours,
or an additional 10% to the current updating and processing time. Out of the 14,700 existing
Title V permits, the Title V ICR estimates that 3,267 permits annually undergo renewal. It is
estimated that the remaining 11,433 permits would need to undergo significant revision.
Baseline
To determine the impact under current Title V program conditions, baseline burden and
cost are calculated at the 100 tpy threshold level, which is the generally applied major source
applicability level under Title V. The GHG Thresholds TSD results indicate that 97% of the new
sources that would need to apply for a Title V permit will be commercial/residential. All existing
sources with operating permits will need to undergo significant revisions or permit renewals. The
estimated total additional burden for permitting authorities is 340,957,876 hours, which,
assuming 2000 hours per year per full time employee (FTE), equates to 170,479 new FTE's at a
cost of $15,684,062,296.
Alternate Threshold Scenarios
In addition to the baseline scenario, permitting authority burden was examined at three
different GHG permitting threshold levels (10,000 tpy, 25,000 tpy, and 50,000 tpy) to evaluate
the relative differences in impacts to permitting authorities. All assumptions for Title V listed
above remain the same for these scenarios.
14 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.07,
OMB Control Number 2060-0243, 2007.
-------
The GHG Thresholds TSD indicates that 12,487 new and existing sources will be
affected if the threshold is set at 10,000 tpy. All remaining existing sources have operating
permits and will need to undergo significant revisions or permit renewals. Of the new sources,
57% represent commercial/residential sources, while 43% represent industrial sources. Similar to
the baseline analysis, a weighted average was developed for newly permitted sources to reflect
differences between commercial/residential and industrial source permits. The total estimated
burden at this threshold for permitting authorities is 2,713,976 hours requiring 1,357 new FTEs
at a cost of $1,148,804.
The GHG Thresholds TSD indicates there will be 3,189 new and existing sources that
will need to obtain an operating permit at a threshold of 25,000 tpy. Of these new sources, 1331,
or 42% will require commercial/residential permits, with the remainder needing industrial
permits. The total estimated burden at this threshold for permitting authorities is 984,757 hours,
or 492 FTE's, at a cost of $45,298,822.
Finally, at a 50,000 tpy threshold, the GHG Thresholds TSD indicates there will be 697
new and existing affected sources that will need to apply for and obtain operating permits. The
total estimated burden at this threshold for permitting authorities is 190,761 hours, requiring 95
new FTEs at a cost of $8,775,006.
-------
Table 2-1 . Estimated Permitting Authority Title V Burden with GHG (First Year)
Activity
Burden
Hour
per
Permit3
Affected
Permits
Total
Burden
(hours)
Total Cost
($2007)b
1 00 tpy (Baseline)
New Permit Preparation and Issuance - Industrial
New Permit Preparation and Issuance - Commercial/Residential
Significant Revisions of Current Permits0
Permit Renewals01
Total Additional Burden
428
43
9
9
197,753
5,957,844
11,433
3,267
84,638,284
256,187,292
102,897
29,403
340,957,876
$3,893,361,064
$11,784,615,432
$4,733,262
$1,352,538
$15,684,062,296
1 0,000 tpy
New Permit Preparation and Issuance - Industrial
New Permit Preparation and Issuance - Commercial/Residential
Significant Revisions of Current Permits0
Permit Renewals01
Total Additional Burden
428
43
9
9
5,311
7,176
11,433
3,267
2,273,108
308,568
102,897
29,403
2,713,976
$104,562,968
$14,194,128
$4,733,262
$1,352,538
$124,842,896
25,000 tpy
New Permit Preparation and Issuance - Industrial
New Permit Preparation and Issuance - Commercial/Residential
Significant Revisions of Current Permits0
Permit Renewals01
Total Additional Burden
428
43
9
9
1,858
1,331
11,433
3,267
795,224
57,233
102,897
29,403
984,757
$36,580,304
$2,632,718
$4,733,262
$1,352,538
$45,298,822
50,000 tpy
New Permit Preparation and Issuance - Industrial
New Permit Preparation and Issuance - Commercial/Residential
Significant Revisions of Current Permits0
Permit Renewals01
Total Additional Burden
428
43
9
9
74
623
11,433
3,267
31,672
26,789
102,897
29,403
190,761
$1,456,912
$1,232,294
$4,733,262
$1,352,538
$8,775,006
aNew commercial/residential permits take 10% of the time needed for new industrial permits
bSalaries from Title V ICR adjusted to 2007 dollars using 2007 OPM General Schedule Salary Table available at: http://www.opm.gov/oca/07tables/index.asp
Incorporating GHG information/requirements into significant revisions and permit renewals adds an additional 10% of the current time (90 hours each)
dThe Title V ICR estimates that 3,267 permits annually undergo renewal, and the remaining 14,700 existing permits will need to undergo significant revisions.
-------
PSD Permits
Table 2-2 presents the estimated burden estimates for permitting authorities at different
possible PSD GHG major source applicability thresholds. Descriptions of the different
thresholds selected are provided below. Burden estimates for the PSD program are calculated
based on listed values obtained from Tables 6-1 and 6-2 the August 2008 Information Collection
Request for Prevention of Significant Deterioration and Nonattainment New Source Review
(NSR)15. NSRICR at 18-19. It is assumed that permit preparation and issuance for
commercial/residential permits requires only 20% of the time necessary to prepare and issue
industrial source permits since commercial/residential sources would likely be less complex in
terms of numbers and types of emission sources and control requirements. Estimates obtained are
additional burden and costs to those currently experienced by permitting authorities and sources.
In addition to utilizing the GHG Thresholds TSD to determine new sources, modification
numbers are derived from the GHG PSD Sources TSD. Both of these TSDs can be found at
EPA-HQ-OAR-2009-0517.
Baseline
In order to determine the impact under current PSD program conditions, baseline burden
and cost were calculated at the 250 tpy permitting threshold. The general 250 tpy PSD threshold,
rather than the 100 tpy PSD threshold for selected industries/sources, is selected for calculations
because it provides results more representative of the general population of sources that would
exceed the major stationary source GHG threshold and potentially be subject to PSD
requirements. At the 250 tpy threshold, the GHG Thresholds TSD indicates that 87% of all new
NSR permits for GHG will be commercial/residential, with the remaining 13% for industrial
sources. It is assumed for this analysis that a commercial/residential permit will be less complex
and generally limited to GHGs such that emission of additional pollutants is not expected and
therefore the permitting process is simplified. To account for the resource requirement
differences between the two categories of permits, it is assumed that preparing and issuing a
commercial/residential PSD permit requires only 20% of the time necessary for an industrial
15 Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 123.23,
OMB Control Number 2060-0003, 2008.
-------
permit. The additional annual permitting burden for permitting authorities is 3,336,844 hours,
which equates to approximately 1,668 new FTE's, at a cost of $257,671,094.
Alternate Threshold Scenarios
After determining the baseline, additional burden was determined at three different major
stationary source threshold levels (10,000 tpy, 25,000 tpy, and 50,000 tpy) to evaluate the
relative differences in impacts to permitting authorities. All assumptions for PSD permits listed
above remain the same for these scenarios.
The GHG Thresholds TSD and the PSD Sources TSD indicate that 827 sources will be
affected if the permitting applicability threshold is set at 10,000 tpy. Of these sources, it is
estimated that 69% would consist of industrial source categories, while 31% fall under the
commercial/residential categories. The total burden at this threshold for permitting authorities is
estimated at 186,990 hours, requiring ninety-three new FTE's at a cost of $14,439,368
The GHG Thresholds TSD and PSD Sources TSD indicate there will be 401 affected
sources at a threshold of 25,000 tpy. Of these new sources, approximately 9% will fall under the
commercial/residential source categories. For permitting authorities, the total estimate burden at
this threshold is 112,025 hours, or 56 new FTE's, at a cost of $8,650,571.
At a 50,000 tpy threshold, the GHG Thresholds TSD and PSD Sources TSD indicate
there will be 222 affected sources. Of these affected sources, we estimate that 15 will be
associated with commercial sources, while the remaining will be for industrial sources due to the
higher threshold applicability level. For permitting authorities, the total estimated additional
burden for permitting authorities will be 63,207 hours, requiring 32 new FTEs at a cost of
$4,880,845.
-------
Table 2-2. Estimated Permitting Authority PSD Burden with GHG (First Year)
Activity
Burden
Hours
per
Permit3
Affected
Permits
Total
Burden
(hours)
Total Cost
($2007)"
Baseline
PSD Permit Preparation and Issuance - Industrial
PSD Permit Preparation and Issuance - Commercial/Residential
Total Additional Burden
301
60
3,664
37,233
1,102,864
2,233,980
3,336,844
$85,163,158
$172,507,936
$257,671,094
1 0,000 tpy
PSD Permit Preparation and Issuance - Industrial
PSD Permit Preparation and Issuance - Commercial/Residential
Total Additional Burden
301
60
570
257
171,570
15,420
186,990
$13,248,635
$1,190,732
$14,439,368
25,000 tpy
PSD Permit Preparation and Issuance - Industrial
PSD Permit Preparation and Issuance - Commercial/Residential
Total Additional Burden
301
60
365
36
109,865
2,160
112,025
$8,483,775
$166,795
$8,650,571
50,000 tpy
PSD Permit Preparation and Issuance - Industrial
PSD Permit Preparation and Issuance - Commercial/Residential
Total Additional Burden
301
60
207
15
62,307
900
63,207
$4,811,347
$69,498
$4,880,845
aAssume permit preparation and issuance for commercial/residential permits takes 20% the amount of time needed to prepare and issue an industrial permit.
"Labor cost of $77.22/hr from Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 1 230.23, OMB Control
Number 2060-0003, 2008.
-------
3. Estimates of Avoided ICR-based Burden for Permitting Authorities and Sources at
Different Possible GHG Major Source Applicability Threshold for Title V and PSD
The following tables indicate the burden avoided from the baseline scenarios by
establishing a 10,000 tpy, 25,000 tpy, or 50,000 tpy major source applicability threshold for both
the Title V and PSD programs. In Tables 3-1 through 3-3, the first three columns indicate the
cost per permit and total cost to permitting authorities if the threshold level for carbon dioxide
equivalents was set at the current threshold levels for Title V and PSD (100 and 250 tpy,
respectively). The next three columns reflect the estimated costs for permitting authorities with
the threshold set at the specified tons per year CC^e. In the final three columns, the avoided
burden is estimated - the time and costs alleviated relative to the baseline scenario by
establishing a GHG major source applicability level of 10,000 tpy, 25,000 tpy, or 50,000 tpy
CO26 respectively. On average, permitting authorities would avoid an estimated $15 billion in
costs.
Set up similarly to the permitting authority table, Tables 3-4, 3-5, and 3-6 below indicate
the avoided burden for sources that emit less than 10,000 tpy, 25,000 tpy, or 50,000 tpy CC^e
respectively. On average, an estimated $39 billion in costs are avoided. Most of the sources that
will not be required to obtain Title V or PSD permits at this time are commercial or residential.
-------
Table 3-1. Estimated ICR-based Costs Avoided for Permitting Authorities at 10,000 tpy Threshold
Activity
All Title V 100tpy and PSD 250 tpy
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
10, 000 tpy or Greater
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$19,688
$1,978
$414
$414
197,753
5,957,844
11,433
3,267
6,170,297
$3,893,361,064
$11,784,615,432
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
5,311
7,176
11,433
3,267
27,187
$104,562,968
$14,194,128
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
192,442
5,950,668
0
0
6,143,110
$3,788,798,096
$11,770,421,304
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Permitting Authority Costs
$23,243
$4,633
3,664
37,233
40,897
$85,162,352
$172,500,489
$15,941,725,137
$23,243
$4,633
570
257
827
$13,248,510
$1,190,681
$139,282,087
$23,243
$4,633
3,094
36,976
40,070
$71,913,842
$171,309,808
$15,802,443,050
-------
Table 3-2. Estimated ICR-based Costs Avoided for Permitting Authorities at 25,000 tpy Threshold
Activity
Baseline
(Title V 100tpy and PSD 250 tpy)
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
25,000 tpy or Greater
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$19,688
$1,978
$414
$414
197,753
5,957,844
11,433
3,267
6,170,297
$3,893,361,064
$11,784,615,432
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
1,858
1,331
11,433
3,267
17,889
$36,580,304
$2,632,718
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
195,895
5,956,513
0
0
6,152,408
$3,856,780,760
$11,781,982,714
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Permitting Authority Costs
$23,243
$4,633
3,664
37,233
40,897
$85,162,352
$172,500,489
$15,941,725,137
$23,243
$4,633
365
36
401
$8,483,695
$166,788
$53,949,305
$23,243
$4,633
3,299
37,197
40,496
$76,678,657
$172,333,701
$15,887,775,832
10
-------
Table 3-3. Estimated ICR-based Costs Avoided for Permitting Authorities at 50,000 tpy Threshold
Activity
All Title V 100tpy and PSD 250 tpy
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
50,000 tpy or Greater
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$19,688
$1,978
$414
$414
197,753
5,957,844
11,433
3,267
6,170,297
$3,893,361,064
$11,784,615,432
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
74
623
11,433
3,267
15,397
$1,456,912
$1,232,294
$4,733,262
$1,352,538
$19,688
$1,978
$414
$414
197,679
5,957,221
0
0
6,154,900
$3,891,904,152
$11,783,383,138
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Permitting Authority Costs
$23,243
$4,633
3,664
37,233
40,897
$85,162,352
$172,500,489
$15,941,725,137
$23,243
$4,633
207
15
222
$4,811,301
$69,495
$13,655,802
$23,243
$4,633
3,457
37,218
40,675
$80,351,051
$172,430,994
$15,928,069,335
11
-------
Table 3-4. Estimated ICR-based Costs Avoided for Sources at 10,000 tpy Threshold
Activity
All Title V 100tpy and PSD 250 tpy
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
10
Cost
per
Permit
(2007$)
000 tpy or Greater
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$46,350
$4,986
$312
$780
197,753
5,957,844
11,433
3,267
6,170,297
$9,165,851,550
$29,705,810,184
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
5,311
7,176
11,433
3,267
27,187
$246,164,850
$35,779,536
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
192,442
5,950,668
0
0
6,143,110
$8,919,686,700
$29,670,030,648
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Source Costs
$84,530
$16,887
3,664
37,233
40,897
$309,717,920
$628,753,671
$39,816,248,681
$84,530
$16,887
570
257
827
$48,182,100
$4,339,959
$340,581,801
$84,530
$16,887
3,094
36,976
40,070
$261,535,820
$624,413,712
$39,475,666,880
12
-------
Table 3-5. Estimated ICR-based Costs Avoided for Sources at 25,000 tpy Threshold
Activity
Baseline
(Title V 100tpy and PSD 250 tpy)
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
25,000 tpy or Greater
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$46,350
$4,986
$312
$780
197,753
5,957,844
11,433
3,267
6,170,297
$9,165,851,550
$29,705,810,184
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
1,858
1,331
11,433
3,267
17,889
$86,118,300
$6,636,366
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
195,895
5,956,513
0
0
6,152,408
$9,079,733,250
$29,699,173,818
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Source Costs
$84,530
$16,887
3,664
37,233
40,897
$309,717,920
$628,753,671
$39,816,248,681
$84,530
$16,887
365
36
401
$30,853,450
$607,932
$130,331,404
$84,530
$16,887
3,299
37,197
40,496
$278,864,470
$628,145,739
$39,685,917,277
13
-------
Table 3-6. Estimated ICR-based Costs Avoided for Sources at 50,000 tpy Threshold
Activity
All Title V 100tpy and PSD 250 tpy
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
50,000 tpy or Greater
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Avoided Burden
Cost
per
Permit
(2007$)
Number
of
Permits
Total Cost
(2007$)
Title V Permits
New Industrial
New Commercial/Residential
Significant Permit Revisions
Permit Renewals
Total Permits Affected
$46,350
$4,986
$312
$780
197,753
5,957,844
11,433
3,267
6,170,297
$9,165,851,550
$29,705,810,184
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
74
623
11,433
3,267
15,397
$3,429,900
$3,106,278
$3,567,096
$2,548,260
$46,350
$4,986
$312
$780
197,679
5,957,221
0
0
6,154,900
$9,162,421,650
$29,702,703,906
$0
$0
PSD Permits
New Industrial
New Commercial/Residential
Total Permits Affected
Total Source Costs
$84,530
$16,887
3,664
37,233
40,897
$309,717,920
$628,753,671
$39,816,248,681
$84,530
$16,887
207
15
222
$17,497,710
$253,305
$30,402,549
$84,530
$16,887
3,457
37,218
40,675
$292,220,210
$628,500,366
$39,785,846,132
14
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