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Economic Impact Analysis for the Revisions to the
Prevention of Significant Deterioration and Title V
Greenhouse Gas Permitting Regulations and
Establishment of a Significant Emission Rate for
Greenhouse Gas Emissions Under the Prevention of
Significant Deterioration Program; Proposed Rule

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EPA-452/R-16-001
September 2015
Economic Impact Analysis for the Revisions to the Prevention of Significant
Deterioration and Title V Greenhouse Gas Permitting Regulations and
Establishment of a Significant Emissions Rate for Greenhouse Gas Emissions
under the Prevention of Significant Deterioration Program; Proposed Rule
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Health and Environmental Impacts Division
Research Triangle Park, NC 27711

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CONTACT INFORMATION
This document has been prepared by staff from the Office of Air and Radiation, U.S.
Environmental Protection Agency. Questions related to this document should be addressed to
Julia Gamas, U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air
Quality Planning and Standards, C439-02, Research Triangle Park, North Carolina 27711 (email:
gamas.julia@epa.gov).
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TABLE OF CONTENTS
Table of Contents	hi
List of Tables	iv
Executive summary	5
ES.l Introduction	5
ES.2 Summary of Results	6
1	BASELINE DESCRIPTION AND ESTIMATE OF INCREMENTAL PERMITS	7
2	Cost Savings of regulatory relief	9
2.1	Introduction	9
2.2	Regulatory Costs avoided Associated with the PSD Program	10
2.3	Savings for Title V	11
2.4	Total Cost Savings	11
3	Impacts of Cost Savings	14
4	LIMITATIONS AND UNCERTAINTIES	14
4.1	Uncertainties in Estimates Affected Sources	14
4.2	Uncertainties in Permitting Costs	15
ATTACHMENT A
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LIST OF TABLES
Table 1-1 Estimated Annual PSD and Title V Permitting Actions at Different SER Levels	9
Table 2-1 Summary of Savings to Sources from Adding GHG Requirements to Permits at Different SER Levels. 13
Table 2-2 Summary of Savings to Permitting Authorities from Adding GHG Requirements to Permits at Different
SER Levels	13
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EXECUTIVE SUMMARY
ES.l Introduction
This rule essentially provides regulatory relief and does not include direct regulatory
provisions for any industrial entities. The U.S. Supreme Court has limited the EPA's greenhouse
gas (GHG) regulatory authority for air permitting purposes to "anyway sources"; a facility or
emission source that is otherwise subject to Prevention of Significant Deterioration (PSD)
permitting based on its emissions of one or more non-GHG, regulated New Source Review
(NSR) air pollutants. EPA is proposing a significant emissions rate (SER) for GHGs under the
PSD program that would establish a de minimis threshold level below which Best Available
Control Technology (BACT) is not required for an "anyway" source's GHG emissions increase.
If not for provisions that remain in EPA's definition of "subject to regulation" at this time—
provisions which we are proposing to remove as part of this proposal—consistent with the
definition of "significant" under the PSD regulations, and in the absence of this proposed
rulemaking, any GHG emissions increase would require a newly constructed "anyway" source,
or a major modification at an existing "anyway" source, to undergo PSD GHG BACT review.
The resource requirements for GHG permitting would therefore consist of the additional,
incremental BACT review for GHG emissions increases above the GHG SER (Significant
Emissions Rate) at "anyway" PSD projects, and the resulting permit requirements from this
BACT review that would need to be added to the facilities' PSD and title V permits associated
with those "anyway" projects. The proposed rule would remove the requirement of conducting
GHG BACT analyses for sources with GHG emissions increases less than the proposed GHG
SER.
The EPA estimated the savings resulting from avoided PSD and title V permitting costs
for sources and permitting authorities as a result of this proposed rulemaking. This analysis
focuses on the savings related to "anyway" sources whose GHG emission increases will fall
below 30,000 tons per year (tpy), 45,000 tpy and the proposed 75,000 tpy carbon dioxide
equivalent (CChe) GHG SER levels.

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ES.2 Summary of Results
For affected sources, the avoided permitting cost or savings for PSD permits is
approximately $23,532 dollars per permit (in 2014 dollars). Total regulatory cost avoided
relative to no SER is about $870 thousand dollars at the 75,000 tpy CChe SER level for an
estimated 37 permits, close to $520 thousand dollars for 22 permits at the 45,000 tpy CChe level
and about $350 thousand dollars for 15 permits at the 30,000 tpy CChe level. State, local, and
tribal permitting authorities are estimated to expend $4,400 dollars per permit to add GHG
BACT requirements to an "anyway" industrial PSD permit. Thus, permitting authorities annual
savings are approximately $165 thousand dollars at the 75,000 tpy CChe SER level, about $100
thousand dollars at the 45,000 tpy CChe level, and over $65 thousand dollars at the 30,000 tpy
CChe level.
Avoided cost for sources subject to title V experiencing regulatory relief is approximately
$2,470 dollars per permit (in 2014 dollars) for adding GHG requirements to a new title V permit,
and $520 dollars per permit for adding a revision to an existing title V permit. Total annual
avoided cost at the proposed 75,000 tpy CChe SER level is in the order of $20 thousand dollars
for an estimated 37 permits, close to $10 thousand dollars for 22 permits at the 45,000 tpy CChe
level and about $10 thousand dollars for 15 permits at the 30,000 tpy CChe level. Regulatory cost
avoided relative to no SER to State, local, and tribal permitting authorities is estimated at $2,632
dollars per permit for adding GHG requirements to a new title V permit, and $504 dollars per
permit for revisions to existing title V permits. At the proposed level of 75,000 tpy CChe
permitting authorities avoided costs total about $20 thousand dollars, close to $10 thousand
dollars at the 45,000 tpy CChe level and in the order of $10 thousand dollars at the 30,000 tpy
CChe level.
Total annual avoided cost for sources for PSD and title V amounts to be approximately
$890 thousand dollars at the 75,000 tpy CChe GHG SER level, close to $530 thousand dollars at
the 45,000 tpy CChe level and about $360 thousand dollars at the 30,000 tpy CChe level. Total
annual avoided cost for permitting authorities is expected to be approximately $185 thousand
dollars at the 75,000 tpy CChe level, about $110 thousand dollars at the 45,000 tpy CChe level,
6

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and close to $75 thousand dollars at the 30,000 tpy CO2Q level. Because the costs of the
regulation are savings for potential sources, no market impacts were estimated.
1 BASELINE DESCRIPTION AND ESTIMATE OF INCREMENTAL PERMITS
This rule is providing regulatory relief and does not result in direct costs for any
industrial entities. Details regarding the history and background of this rule, as well as the legal
basis for this regulation can be found in the preamble.
The first step in estimating the cost savings of this rule is to estimate the number of
affected entities. The U.S. Supreme Court has limited the EPA's GHG regulatory authority for
air permitting purposes to "anyway sources"; a facility or emission source that is otherwise
subject to PSD permitting based on its emissions of one or more non-GHG, regulated NSR air
pollutants. Therefore, the resource requirements for GHG permitting will consist of the
additional, incremental BACT review for GHG emissions increases above the GHG SER at
"anyway" PSD projects, and the resulting permit requirements from this BACT review that will
need to be added to the facilities' PSD and title V permits associated with those "anyway"
projects. This Economic Impact Analysis (EIA) focuses on the cost savings for "anyway"
sources whose GHG emission increases will not exceed the SER.
It is difficult to estimate the number and characteristics of PSD permitting actions that
will occur in a given future year. This process is further complicated in this exercise by having
to determine which of those "anyway" PSD actions would include GHG emission increases
above a given GHG SER option. It is difficult to predict PSD permitting actions since these
actions are dependent on continuously evolving, case-by-case business decisions to build new
facilities, or modify existing ones, across various industry types. The exact make-up and extent
of these business decisions, and thus the form and make-up of potentially permitted projects,
varies from year to year and across different industry types. Therefore, this analysis begins with
an estimate of future annual permitting activity based on a review of past permitting activity and
on projections of the likely number of projects that will require GHG-related permitting actions
at different GHG SER options. See Attachment A for details on how these estimates were
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conducted and the related uncertainties involved. Given these uncertainties the results of this
analysis should be considered as illustrative and should not interpreted as a precise projection
Four options were considered in this analysis. The baseline option is a "No Action" case
where EPA does not take action to set a GHG SER. If not for provisions that remain in EPA's
definition of "subject to regulation" at this time, under the present definition of "significant"
under the PSD regulations, and in the absence of this proposed rulemaking, any GHG emissions
increase would require a newly constructed major source, or a major modification at an existing
facility, to undergo PSD GHG B ACT review. Thus, the "No Action" case scenario is equivalent
to setting a GHG SER of "0" tpy CChe or no SER1. Three additional cases were analyzed where
"anyway" facilities are required to incorporate GHG BACT review requirements into their
permits: the proposed GHG SER of 75,000 tpy CChe and evaluated alternatives of 30,000 tpy
and 45,000 tpy CChe potential to emit (PTE)2.
Table 1-1 shows our estimates of the number of PSD permitting actions involving GHG
BACT review for each SER level and by type of activity. As a consequence to these actions, we
assume an equal number of title V permits would be affected since the GHG BACT requirements
resulting from the PSD review will need to be added to each facility's title V permit: a newly
constructed major source will require a new title V permit, while a major modification at an
existing major source is assumed to result in a revision to an existing title V permit.
1	Carbon dioxide equivalent is a measure used to compare and summarize the emissions from various greenhouse
gases based upon their global warming potential.
2	A GHG SER level above 75,000 tpy CChe was not considered and is not included in this analysis because it would
not meet the fundamental principles for developing a de minimis level. Further details regarding the basis for the
GHG SER levels chosen for analysis can be found in the preamble or this rulemaking.
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Table 1-1 Estimated Annual PSD and Title V Permitting Actions at Different SER Levels3
Level
Total "anyway" PSD permits
subject to GHG BACT review
Newly
Constructed
Modified
Total



Baseline "No action"
103
28
75
30,000 tpy GHG SER
88
28
60
45,000 tpy GHG SER
81
28
53
75,000 tpy GHG SER
66
28
38
Avoided Action



Baseline "No action"
0
0
0
Avoided at 30,000 tpy GHG SER
15
0
15
Avoided at 45,000 tpy GHG SER
22
0
22
Avoided at 75,000 tpy GHG SER
37
0
37
Note: tpy = tons per year; SER = significant emission rate
2 COST SAVINGS OF REGULATORY RELIEF
2.1 Introduction
EPA estimated the regulatory relief, or avoided PSD and title V permitting costs, for
sources that will have cost savings from this rulemaking. This analysis focuses on the avoided
costs for "anyway" sources whose GHG emission increases will fall below the 30,000 tpy,
45,000 tpy and the proposed 75,000 tpy CChe levels, as compared to no SER. Details about
avoided costs are outlined in Attachment A and include:
•	Avoided costs to sources:
o information collection requirements to add GHG to PSD permits required for new
or modifying sources of GHG, and
o information collection costs to add GHG to new or existing title V permits if not
for this rule
•	Avoided costs to permitting authorities:
o information collection requirements to add GHG to PSD permits required for new
or modifying sources of GHG, and
3 For additional detail on the estimation of the permitting actions, please refer to Appendix A.
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o information collection costs to add GHG to new or existing title V permits if not
for this rule
Within this section of the EIA we are providing an illustrative monetary estimate of
statutory permitting requirements to show the savings that hypothetically result from this
rulemaking. For the sake of simplicity, we refer to this illustrative monetary estimate as the
monetized cost savings of this rulemaking. It is important to note that these estimates of cost
savings do not include the savings from the avoided costs for the GHG BACT control or
mitigation process that is ultimately adopted and implemented by the permitted facility as part of
the BACT decision since these decisions, and ultimately the costs, can vary widely from site to
site based on unique facility characteristics and operating conditions and cannot be predicted
with any certainty or specificity.
Attachment A contains information about how the time and costs associated with permit
activities are derived and the sources for that information. Significant uncertainties exist in the
following estimates because of the lack of an extensive historical record and permitting
experience on which to base resource needs to consider sources of GHG emissions in permitting.
These factors are discussed more fully in Section 4 of this EIA. It is important to note that, given
the uncertainty in estimates about future permitting actions that entities might take, these
estimates must be considered illustrative only.
2.2 Regulatory Costs Avoided Associated with the PSD Program
Table 2-1 shows a summary of the savings for sources at the proposed 75,000 tpy CChe
GHG SER level, as well as the two evaluated alternatives of 30,000 tpy, and 45,000 tpy CChe.
The avoided permitting cost for PSD permits is approximately $23,532 dollars per permit (in
2014 dollars). Total estimated annual savings is about $870 thousand dollars at the 75,000 tpy
CChe SER level, close to $520 thousand dollars at the 45,000 tpy CChe level and about $350
thousand dollars at the 30,000 tpy CChe level. Details of how these data were estimated can be
found in Attachment A: Tables 7.1, 7.2 and 7.3.
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State, local, and tribal permitting authorities will also benefit from this rule by avoiding
the administrative costs of processing permits that include GHGs for "anyway" sources annually.
Savings to State, local, and tribal permitting authorities are shown in Table 3. Permitting
authorities are estimated to expend an additional $4,400 dollars per permit to process a new
"anyway" PSD permit. Annual avoided permitting costs are $165 thousand dollars at the 75,000
tpy CChe SER level, about $100 thousand dollars at the 45,000 tpy CChe level, and over $65
thousand dollars at the 30,000 tpy CChe level. For more information on the estimates of avoided
regulatory costs for PSD permits, see Attachment A: Tables 6.1, 6.2 and 6.3.
2.3	Savings for Title V
Savings for sources subject to title V experiencing regulatory relief are summarized in
Table 2-1. The avoided permitting cost is around $2,470 dollars per permit for adding GHG
requirements to a new permit, and $520 dollars per permit for adding GHG requirements through
a revision to an existing permit. Total annual avoided cost for title V permits at the proposed
75,000 tpy CChe SER level are approximately $20 thousand dollars, slightly over $10 thousand
dollars at the 45,000 tpy CChe level and around $10 thousand dollars at the 30,000 tpy CChe
level. Details of how these data were estimated can be found in Attachment A: Tables 7.1, 7.2
and 7.3.
Savings for State, local, and tribal permitting authorities for title V permits are shown in
Table 2-2. Avoided title V permitting costs are estimated to be $2,632 dollars per permit for
adding GHG requirements to a new permit, and $504 dollars per permit for revisions to existing
permits. At the proposed SER level of 75,000 tpy CChe annual avoided title V permitting costs
total in the order of $20 thousand dollars, close to $10 thousand dollars at the 45,000 tpy CChe
level and about $10 thousand dollars at the 30,000 tpy CChe level. For more information on the
estimates of avoided costs for PSD permits, see Attachment A: Tables 6.1, 6.2 and 6.3.
2.4	Total Cost Savings
Total annual savings for sources for PSD and title V are estimated to be approximately
$890 thousand dollars at the 75,000 tpy CChe GHG SER level, close to $530 thousand dollars at
the 45,000 tpy CChe level and about $360 thousand dollars at the 30,000 tpy CChe level (see
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Table 2-1). Total annual avoided costs for permitting authorities are expected to be
approximately $185 thousand dollars at the 75,000 tpy CChe level, about $110 thousand dollars
at the 45,000 tpy CChe level, and close to $75 thousand dollars at the 30,000 tpy CChe level (See
Table 2-2).
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Table 2-1 Summary of Savings to Sources from Adding GHG Requirements to Permits at Different GHG SER Levels (Annual)

Regulatory Cost Avoided at 75,000 tpy SER
Regulatory Cost Avoided at 45,000 tpy SER
Regulatory Cost Avoided at 30,000 tpy SER
Activity
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
PSD Permits
$23,532
37
$870,684
$23,532
22
$517,704
$23,532
15
$352,980
Title V Permits









New Permit
$2,470
0
$-
$2,470
0
$-
$2,470
0
$-
Permit Revision
$520
37
$19,240
$520
22
$11,440
$520
15
$7,800
Total Title V


$19,240


$11,440


$7,800
Total Additional Costs


$889,924


$529,144


$360,780
Table 2-2 Summary of Savings to Permitting Authorities from Adding GHG Requirements to Permits at Different GHG SER
Levels (Annual)

Regulatory Cost Avoided at 75,000 tpy SER
Regulatory Cost Avoided at 45,000 tpy SER
Regulatory Cost Avoided at 30,000 tpy SER
Activity
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
Additional Cost per
Permit (2014$)
Number
of
Permits
Total
Avoided
Cost
(2014$)
PSD Permits
$4,400
37
$162,800
$4,400
22
$96,800
$4,400
15
$66,000
Title V Permits









New Permit
$2,632
0
$-
$2,632
0
$-
$2,632
0
$-
Permit Revision
$504
37
$18,648
$504
22
$11,088
$504
15
$7,560
Total Title V


$18,648


$11,088


$7,560
Total Additional Costs


$181,448


$107,888


$73,560
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3 IMPACTS OF COST SAVINGS
This rulemaking does not impose economic impacts on any sources or permitting
authorities, but should instead be viewed as cost savings for "anyway" emission sources.
Because no businesses or governmental entities are expected to incur positive costs as a result of
this rule, there is not a significant impact on a substantial number of small entities (SISNOSE).
Because the savings are small and spread among many sources, the market impacts of this rule
will be minimal.
4 LIMITATIONS AND UNCERTAINTIES
Uncertainties exist in the affected "anyway" source permit counts at different GHG SER
levels used to estimate regulatory relief due to the inability to accurately predict future PSD
permitting activity at "anyway" sources. These affected "anyway" source permit counts are
multiplied by the permit avoided cost estimates to add GHG requirements in order to derive the
benefits (regulatory relief) estimates for the rule. Specific uncertainties in the estimates of
affected "anyway" PSD permitting actions, avoided cost estimates and other limitations of the
benefits analysis are discussed below.
4.1 Uncertainties in Estimates of Affected Sources
It is difficult to predict with any certainty the number and characteristics of "anyway" PSD
permitting actions that will occur in a given future year, which is further complicated in this
exercise by having to determine which of those "anyway" PSD actions would include GHG
emission increases above a given GHG SER option. It is challenging to predict PSD permitting
actions since these actions are dependent on continuously evolving, case-by-case business
decisions to build new facilities, or modify and expand existing ones, across various industry
types. The exact make-up and extent of these business decisions, and thus the form and make-up
of potentially permitted projects, varies from year to year and across different industry types.
The methodology and estimates used to support this analysis are our best representation of future
annual permitting activity, based on review of past permitting activity and projections of the
likely number of projects that will require GHG-related permitting actions at different GHG SER
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options. A full description of the assumptions and uncertainties in the estimates of affected
sources is provided in Attachment A.
4.2	Uncertainties in Permitting Costs
The primary reference sources for our estimate of additional hours and costs for permitting
GHGs are the most recent Information Collection Requests (ICRs) for the PSD and title V
programs. Hours and costs associated with the addition of GHG permitting have been factored
into the ICRs and these same assumptions are used in this analysis for establishing a GHG SER
level. Both of these documents focus on the average resource requirements per permitting
activity for permitting authorities and sources. Thus, some permitting activities will inherently
require more time and cost while others will require less depending on the specific composition
of the project being permitted.
4.3	Additional Uncertainties
Historically we have not been able to predict what technologies and types of equipment
these sources will be using for production and emissions controls. It is also not possible to
predict whether permitting authorities would choose end-of-pipe emissions controls or seek
measures in line with energy efficiency, fuel switching and the use of renewable energy as
BACT. These decisions are made on a case by case basis and could be very different. Thus, it is
not possible to monetize the cost of BACT across the universe of permitted sources or even
develop a representative case. Because the level of reduction from applying BACT will be
determined on a case by case basis, it is also difficult to quantify the negative impacts from CO2
emissions over time for different thresholds.
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ATTACHMENT A
Documentation for Estimates of Permitting Actions for Economic Impact Analysis for
GHG SER Rulemaking
1. Introduction
This document summarizes an assessment of the estimated resource requirements for
permitting authorities to include GHG BACT review and permitting related requirements under
the Prevention of Significant Deterioration (PSD) and title V permitting programs based on
different GHG significant emission rate (SER) options for the PSD program. The analysis was
performed for GHG SER options based on a carbon dioxide equivalent (CChe) basis, which
represents the sum of the six primary GHG with their respective global warming potentials
(GWP) applied. Time and costs associated with permit activities are derived from existing ICRs
for the title V and PSD programs.
To estimate permitting resource requirements for both the PSD and title V programs, we needed
to first estimate the number of affected PSD permitting actions, namely "anyway" PSD
permitting actions that will require GHG BACT review at a given GHG SER. As discussed in
the proposal, the US Supreme Court has limited the EPA's GHG regulatory authority for air
permitting purposes to "anyway sources"; an "anyway source" refers to a facility or emission
source that is otherwise subject to PSD permitting based on its emissions of one or more non-
GHG, regulated NSR air pollutants. As a result of this ruling, the EPA also cannot require title
V permits based solely on a facility's GHG emissions alone. As a result, the resource
requirements for GHG permitting will consist of the additional, incremental BACT review for
GHG emissions increases above the GHG SER at "anyway" PSD projects, and the resulting
permit requirements from this BACT review that will need to be added to the facilities' title V
permits associated with those "anyway" projects. It is difficult to predict with any real certainty
the number and characteristics of PSD permitting actions that will occur in a given future year,
which is further complicated in this exercise by having to determine which of those "anyway"
PSD actions would include GHG emission increases above a given GHG SER option. It is
difficult to predict PSD permitting actions since these actions are dependent on continuously
evolving, case-by-case business decisions to build new facilities, or modify existing ones, across
various industry types. The exact make-up and extent of these business decisions, and thus the
form and make-up of potentially permitted projects, varies from year to year and across different
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industry types. The methodology and estimates provided below represent our best representation
of future annual permitting activity, based on review of past permitting activity and projections
of the likely number of projects that will require GHG-related permitting actions at different
GHG SER options.
2. Estimate of PSD Permitting Actions at Different GHG SER Option Levels
This section describes the basic methodology we used to estimate the different types and
quantities of permitting actions that would need to address GHGs under the PSD and title V
permitting programs. The estimated costs summarized in Section 3 are based on the inputs of
permitting actions estimated using the methodologies described in this section. In developing our
methodology, we established different applicability options under which "anyway" GHG
emission sources would be regulated. These GHG applicability thresholds reflect different
options for GHG SER values considered for the proposed rulemaking.
We developed our analysis around four major GHG SER options: 1) a "No Action"
baseline option, which refers to a scenario where EPA does not take action to set a GHG SER,
and per existing EPA PSD regulations the GHG SER value would default to 'any increase' in
emissions, essentially equating to a GHG SER of '0' tpy CChe; 2) a 30,000 tpy CChe level; 3) a
45,000 tpy CChe level; and, 4) a 75,000 tpy CChe level. We believe an analysis of these option
levels and associated GHG permitting activity provided a good representation of the relative and
incremental permitting costs across the range of options considered.
Since GHG permitting is limited to "anyway" projects, i.e., projects that would otherwise
require PSD permits for conventional pollutants, our analysis of GHG-impacted permitting
actions all have an inherent background constraint to the number of total PSD permitting actions
that would occur in a given year; i.e., the total number of PSD permitting actions that involve
GHGs cannot exceed the total number of PSD actions that would be occurring "anyway" for
conventional, non-GHG pollutants since permits cannot be triggered for GHG emissions alone.
Our review4 of recent PSD permitting activity over the four year period of 2011-2014, inclusive,
shows an annual average total PSD permitting activity level of 153 permits per year nationwide.
4 This review included permitting counts obtained from a review of State air permitting websites, EPA regional
office tracking data, and permit information reported to EPA's RACT/BACT/LAER Clearinghouse (RBLC).
Appendix A contains a listing of the overall PSD permit and GHG B ACT review counts used for this analysis.
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Therefore, there is a theoretical maximum number of "anyway" PSD permitting actions that
could even possibly involve GHG BACT review, which equates to approximately 153 permits
per year based on the annual average of the last four years. Over the same four year period our
review showed a total of 265 "anyway" permits containing a GHG BACT review, or an annual
average total of approximately 66 permits per year nationwide.
It is important to reiterate the uncertainty in estimating PSD actions again here; while we
believe this number of 153 annual permitting actions is a reasonably accurate representation of
recent PSD permitting activity nationwide, since it is based to a large extent on actual state-
reported permit data, annual permitting activity can fluctuate depending on prevailing economic
conditions and, even more importantly and difficult to predict, the individual status of facilities
in a given industrial sector. However, we note that the range across the 4-yr period on which the
average is based was a low of 127 to a high of 179 PSD permits per year. We do have confidence
in this general order-of-magnitude of permit activity based on our recent program experience and
we believe the 153 annual average value to be our best estimate of near-term, future annual PSD
permitting activity for use in the GHG SER option analysis.
Table 1 shows our estimates of PSD permitting actions at each of the analyzed GHG SER
option levels. The estimates of permitting actions show the total estimated "anyway" source
PSD permits that would be subject to GHG BACT review, along with the breakdown of this total
into those actions involving newly constructed facilities and those involving modifications at
existing facilities. Following the table is a description of the methodology and assumptions used
to estimate permitting actions at each of the option scenarios. Since the only actual historical
data we have on GHG permitting is related to the 75,000 tpy CChe option level, it is not possible
at lower level options to base these assumptions on an historical record. Therefore, a number of
assumptions are based on professional judgement of PSD program staff who have worked with
actual permit data. However, based on our level of confidence in the total possible number of
annual PSD permitting actions, and our knowledge of historical GHG "anyway" permitting
actions under the Tailoring Rule permitting level of 75,000 tpy GHG, we feel these two numbers
provide a well-defined boundary around the levels of permitting that would be expected at any
intermediate levels.
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Table 1. Estimates of PSD Permitting Actions Involving GHG BACT
leview (Annual)
Option/Scenario
Estimated annual
avg. "anyway" PSD
permits subject to
GHG BACT review
# of annul PSD
permits for newly
constructed
facilities
# of annual PSD
permits for
modifications at
major source
facilities
"No Action" baseline
103
28
75
30,000 tpy GHG SER
88
28
60
45,000 tpy GHG SER
81
28
53
75,000 tpy GHG SER
66
28
38
The "No Action" baseline option refers to a scenario where EPA does not take action to
set a GHG SER level. If not for provisions that remain in EPA's definition of "subject to
regulation" at this time, under the present definition of "significant" under the PSD regulations,
and in the absence of this proposed rulemaking, any GHG emissions increase would require a
newly constructed major source, or a major modification at an existing facility, to undergo PSD
GHG BACT review. Thus, the "No Action" case scenario is equivalent to setting a GHG SER of
"0" tpy CChe. As such, the values for permitting actions for the "No Action" baseline scenario
are the estimated "anyway" PSD actions that would involve any GHG emissions (for newly
constructed sources) or GHG emission increases for modification projects at existing major
sources. The value of 103 represents approximately 67% of the total estimated annual PSD
"anyway" source permitting actions (153). The value of 103 is the estimated PSD "anyway"
permits that would require a GHG BACT review at a 'zero' GHG significance level. The value
of 67% was estimated based on the assumption that 33% of "anyway" PSD permits involve
projects with strictly non-GHG emission sources, such as VOC or PM-only sources that would
not likely involve GHG emissions. For example, the construction and modification activities
associated with VOC or PM-only permits generally consist of non-GHG related emission
sources, such as PM dust or VOC's from coatings and tanks emissions. The other 67% of permits
would principally represent combustion-related equipment or processes where any fossil fuel
combustion could potentially result in non-zero GHG emissions. This assumption is based on a
review of the EPA's RACT/BACT/LAER Clearinghouse (RBLC) permitting database for 2011-
2014. This assumption is also consistent with our findings from sample reviews of "anyway"
permitting actions at likely GHG source categories over the last four years, where it is evident
A-4

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that combustion unit-related projects are responsible for the majority of PSD actions being
triggered.
For estimating the affected permitting actions at the GHG SER option levels of 30,000
and 45,000 tpy CChe, we applied a linear interpolation between the estimates for the "No
Action" baseline and the 75,000 tpy CChe level. Since our estimates of GHG affected permits at
these two end-points represent our best known levels of permitting activity since they are based
on a historical record, we believe the use of linear interpolation between these two points
provides our best estimate of the level of PSD permitting activity involving GHGs at other GHG
SER option points. As discussed above, the uncertainty in predicting future PSD permitting
actions in general, and additionally what actions might be involved at different GHG SER option
levels, makes it impossible to predict with any certainty how many GHG BACT reviews would
be involved at hypothetical GHG permitting levels. However, we have confidence that the two
end-point estimates (i.e., the scenarios for the "No Action" baseline and 75,000 tpy CChe
options), provide a reasonably well-defined boundary around the levels of permitting that would
be expected at any intermediate levels because they are based on actual permitting experience.
The use of linear interpolation assumes that the permitting activity involving GHGs would track
linearly between these option levels such that as the GHG SER level becomes lower, the number
of "anyway" PSD permits involving GHG BACT review increases. Appendix B shows the
derivation of the interpolated results for the GHG SER option levels of 30,000 tpy and 45,000
tpy CChe.
An overarching assumption for all scenarios is that we anticipate that all newly
constructed facilities that require "anyway" PSD permits, and which therefore must be 'major'
PSD sources for one or more non-GHG pollutants, will have sufficient GHG emissions to require
GHG BACT review at any of the alternative thresholds evaluated. Our program experience with
PSD permitting has shown that newly constructed, major source industrial facilities generally
included multiple combustion units as part of the overall facility design, which results in high
levels of combustion-related GHG emissions, often many times greater than 75,000 tpy CChe.
We assume for our analysis, therefore, that any additional GHG BACT reviews that would be
excluded from higher level GHG SER options are related to modification projects involving
existing major source facilities. Modifications can involve such activities as adding a combustion
unit to an existing facilities to expand production, or modifying an existing production process to
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increase its capacity. The number of permits for new facility construction used for each threshold
is based on a review of the GHG permits issued to date.
3. Estimate of Stakeholder Burden at Different GHG SER Option Levels
The permitting action estimates above, along with the current ICRs for both the PSD and
title V programs, were used to determine the associated burden at the GHG SER option levels. In
both programs, the ICRs identify the average burden hours per permit by activity as well as the
total national estimated hours required to operate the programs and issue permits annually. In
both programs, activities for permitting authorities include reviewing permit applications,
providing for public review of a proposed project, and issuing a permit based on consideration of
all technical factors and public input. Source activities involve conducting the necessary
research, performing the appropriate analyses, and preparing the permit application with
documentation to demonstrate that a project meets all the applicable statutory and regulatory
requirements. For the purpose of this analysis, the focus is on the additional time and cost
required to conduct GHG BACT review and incorporate the resulting requirements into permits.
a. PSD Permitting Burden Annual Estimates
The 2012 ICR for the New Source Review (NSR) program estimates the burden
associated with all aspects of preconstruction permit programs, including the time and cost
required to prepare and issue a PSD permit.5 The ICR uses a weighted average burden (in hours)
per permit for both permitting authorities and sources to determine the average national annual
burden for the NSR program. Since this analysis is concerned with the additional burden
imposed by the BACT review for GHGs in "anyway" PSD permits, it is important to distinguish
between the average burden (in hours) for permits with and without GHGs. Therefore, this
analysis relies on the ICR's supporting documentation that provides the calculations used to
arrive at the weighted averages identified in the ICR, along with the breakdown of the hours per
activity needed to issue PSD permits with and without GHGs.
5 Information Collection Request for Prevention of Significant Deterioration and Non-Attainment Area New Source
Review (Renewal), EPA ICR Number 123.29, OMB Control Number 2060-0003, 2012. A copy of this document
is available in the docket EPA-HQ-OAR-2011-0901.
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For permitting authorities, the estimated burden to issue an average PSD permit that does
not require GHGBACT review is 335 hours. An "anyway" PSD permit requires an additional 50
hours, or an average 385 hours total, to include GHGs. This additional time is divided among
permitting activities most closely associated with BACT, including answering respondent
questions, reviewing data submissions, and application approval. For a detailed breakdown of
permitting activity, please refer to Appendix C.
Table 2 depicts the additional permitting burden for permitting authorities to add GHG
requirements into "anyway" PSD permits at different GHG SER option levels. Using a staff
labor cost of $88 per hour, the additional burden at the "No Action" baseline option is estimated
to require permitting authorities to spend approximately $453,000 to include GHG requirements
in all "anyway" PSD permits. At the 30,000 tpy CChe option level the additional cost to
permitting authorities is anticipated to be around $387,000 nationally, while at the 45,000 tpy
CChe and 75,000 tpy CChe options the additional burden equates to approximate costs of
$356,000 and $290,000 respectively.
Table 2. Additional Permitting Authority Burden to
Add GHG Requirements to PSD Permits (Annual)

Burden


Total

Hours

Total
Additional

per
Affected
Burden
Cost

Permit
Permits
(hours)
($2014)a
"No Action" Baseline
Add GHG Requirements to 'Anyway' PSD Permit
50
103
5,150
$453,200
30,000 tpy GHG SER
Add GHG Requirements to 'Anyway' PSD Permit
50
88
4,400
$387,200
45,000 tpy GHG SER
Add GHG Requirements to 'Anyway' PSD Permit
50
81
4,050
$356,400
75,000 tpy GHG SER
Add GHG Requirements to 'Anyway' PSD Permit
50
66
3,300
$290,400
Salaries from the NSR ICR adjusted to 2014 dollars using "Employer Costs for Employee Compensation, Table 4: Employment Costs for
State and Local Government Workers" U.S. Dept. of Commerce, BLS, December 2014. (http://www.bls.gov/news release/pdf/ecec.pdf;
http://www.bls.gov/news release/ecec.t04.htm) 100% overhead assumed.
For sources, the estimated burden to issue an average PSD permit that does not require
GHG BACT review is 984 hours. An "anyway" permit requires a source to spend an additional
222 hours to include GHGs, or an average of 1,206 hours total. The background supporting
documentation indicates that sources spend, on average, 120 hours obtaining guidance on data
needs and 102 hours for the preparation of the BACT analysis for a non-GHG permit. It is
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expected that sources with activities exceeding the GHG SER level would need to spend an
equal amount of time for these two activities to conduct BACT review for GHGs. For a detailed
breakdown of permitting activity, please refer to Appendix C.
Table 3 compares the additional source burden required to conduct BACT review for
GHG emissions increases above different GHG SER level options for "anyway" PSD permits.
Using a wage rate of $106 per hour, the additional burden at the "No Action" baseline option is
estimated to require "anyway" sources to spend approximately $2.4 million to conduct BACT
review for GHGs all "anyway" PSD permits. At the 30,000 tpy CChe option level the additional
cost to "anyway" sources is anticipated to be under $2.1 million nationally, while at the 45,000
tpy CChe and 75,000 tpy CChe options the burden equates to approximate costs of $1.9 million
and $1.6 million respectively.
Table 3. Additional Source Burden to Add GH<
G Requirements to PSD Permits (Annual)

Burden


Total

Hours

Total
Additional

per
Affected
Burden
Cost
Activity
Permit
Permits
(hours)
($2014)a
"No Action" Baseline
Add GHG Requirements to Anyway' PSD Permit
222
103
22,866
$2,423,796
30,000 tpy GHG SER
Add GHG Requirements to Anyway' PSD Permit
222
88
19,536
$2,070,816
45,000 tpy GHG SER
Add GHG Requirements to 'Anyway' PSD Permit
222
81
17,982
$1,906,092
75,000 tpy GHG SER
Add GHG Requirements to "Anyway" PSD Permit
222
66
14,652
$1,553,112
aSalaries from the NSR ICR adjusted to 2014 dollars using "Employer Costs for Employee Compensation, Table 2: Employment Costs for
Civilian Workers by Occupational and Industry Group (Professional and Related)" U.S. Dept. of Commerce, BLS, December 2014.
(http://www.bls.gov/news release/pdfecec.pdf; http://www.bls.gov/news release/ecec.t02 htm). 110% overhead assumed.
b. Title V Burden Annual Estimates
The 2015 Title V ICR estimates burden associated with all aspects of the operating
permit program, including the time and cost required to prepare and issue an operating permit.6
6 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.12,
OMB Control Number 2060-0243, 2015. A copy of this document is available in the docket EPA-HQ-OAR-
2004-0015.
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Newly constructed major sources or sources designated newly major due to a modification are
required to apply for and be issued a title V permit in order to operate. If the new source is an
"anyway" source, additional time will be necessary to incorporate the GHG requirements from
the "anyway" PSD permit into the title V permit. If an existing source undergoes a modification
that requires BACT review for GHG emission increases above the GHG SER at "anyway" PSD
projects, the title V permit for the source would need to be revised in order to incorporate the
new GHG requirements.
According to the ICR, the average permitting authority burden to issue a new title V
permit is 474 hours. For a source needing to add GHG requirements from an "anyway" PSD
permit, the ICR estimates the incorporation into the title V permit will increase the average
burden by 10%, or by an additional 47 hours. A detailed breakdown of burden per permitting
activity is located in Appendix C. For a permitting authority to revise an existing title V permit to
incorporate requirements from a new PSD permit, a significant permit revision may be required,
which is estimated to take 94 hours. If the permit in question is an "anyway" PSD permit, this
analysis assumes a significant permit revision is required and will need an additional 10% of
time above the 94 hours, or 9 hours, to incorporate the GHG requirements into the title V permit.
Table 4 presents the additional permitting burden for permitting authorities to incorporate
the requirements resulting from GHG BACT review for "anyway" PSD permitting actions into
title V permits at different GHG SER option levels.7 Using a staff labor cost of $56 per hour, the
additional burden at the "No Action" baseline option is estimated to require permitting
authorities to spend approximately $112,000 to include GHG requirements from all "anyway"
PSD permits into title V permits. At the 30,000 tpy CChe option level the additional cost to
permitting authorities is anticipated to be around $104,000 nationally, while at the 45,000 tpy
CChe and 75,000 tpy CChe options the burden equates to approximate costs of $100,000 and
$93,000 respectively.
7 As a consequence of "anyway" PSD permitting actions involving GHG BACT review estimated in Table 1, an
equal number of title V permits are assumed to be affected since the GHG BACT requirements resulting from
the PSD review will need to be incorporated into a title V permit. For newly constructed major sources, this will
require adding GHG BACT requirements to a new title V permit; for existing major source, a PSD major
modification is assumed to result in a corresponding title V permit revision.
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Table 4. Additional Permitting Authority Burden to Incorporate GHG Requirements into Title V
Permits (Annual)


Burden





Hour

Total
Total Additional


per
Affected
Burden
Cost

Activity
Permit
Permits
(hours)
($2014)a
"No Action" Baseline

Add GHG Requirements to New Title V Permit
47
28
1,316
$73,696

Add GHG Requirements to Title V Permit Revision
9
75
675
$37,800

Total Additional Burden
1,991
$111,496
30,000 tpy (associated with 15,000 tpy PSD GHG SER)

Add GHG Requirements to New Title V Permit
47
28
1,316
$73,696

Add GHG Requirements to Title V Permit Revision
9
60
540
$30,240

Total Additional Burden
1,856
$103,936
45,000 tpy (associated with 45,000 tpy PSD GHG SER)

Add GHG Requirements to New Title V Permit
47
28
1,316
$73,696

Add GHG Requirements to Title V Permit Revision
9
53
477
$26,712

Total Additional Burden
1,793
$100,408
75,000 tpy (associated with 75,000 tpy PSD GHG SER)

Add GHG Requirements to New Title V Permit
47
28
1,316
73,696

Add GHG Requirements to Title V Permit Revision
9
38
342
19,152

Total Additional Burden
1,658
$92,848
aLabor cost for permitting authorities estimated at $56.00 per hour. Information Collection Request for State Operating Permit
Regulations (Renewal), EPA ICR Number 1587.12, OMB Control Number 2060-0243, 2015.
According to the ICR, the average source burden to obtain a new title V permit is 391
hours. For a source needing to add GHG requirements from an "anyway" PSD permit, the ICR
estimates the incorporation into the title V permit will increase the average burden by 10%, or by
an additional 39 hours. A detailed breakdown of burden per permitting activity is located in
Appendix C. For a source to incorporate requirements from a new PSD permit into its existing
title V permit, it may need to undergo a significant permit revision, which is estimated to take 84
hours. If the permit in question is an "anyway" PSD permit, this analysis assumes a significant
permit revision is required and will need an additional 10% of time above the 84 hours, or 8
hours, to incorporate the GHG requirements into the title V permit.
Table 5 compares the additional source burden associated with incorporating the
requirements resulting from GHG BACT review for "anyway" PSD permitting actions into title
V permits at different GHG SER option levels. Using a wage rate of $65 per hour, the additional
burden at the "No Action" baseline option is estimated to require "anyway" sources to spend
approximately $108,000 to incorporate GHG requirements from all "anyway" PSD permits into
title V permits. At the 30,000 tpy CChe option level the additional cost to "anyway" sources is
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anticipated to be around $100,000 nationally, while at the 45,000 tpy CO2Q and 75,000 tpy CChe
options the burden equates to approximate costs of $97,000 and $89,000 respectively.
Table 5. Additional Source Burden to Incorporate GHG Requirements into Title V Permits (Annual)


Burden


Total


Hour

Total
Additional


per
Affected
Burden
Cost

Activity
Permit
Permits
(hours)
($2014)
Actions Associated with "No Action" Baseline

Add GHG Requirements to New Title V Permit
38
28
1,064
$69,160

Add GHG Requirements to Title V Permit Revision
8
75
600
$39,000

Total Additional Burden
1,664
$108,160
Actions Associated with 30,000 tpy PSD GHG SER

Add GHG Requirements to New Title V Permit
38
28
1,064
$69,160

Add GHG Requirements to Title V Permit Revision
8
60
480
$31,200

Total Additional Burden
1,544
$100,360
Actions Associated with 45,000 tpy PSD GHG SER

Add GHG Requirements to New Title V Permit
38
28
1,064
$69,160

Add GHG Requirements to Title V Permit Revision
8
53
424
$27,560

Total Additional Burden
1,488
$96,720
Actions Associated with 75,000 tpy PSD GHG SER

Add GHG Requirements to New Title V Permit
38
28
1,064
$69,160

Add GHG Requirements to Title V Permit Revision
8
38
304
$19,760

Total Additional Burden
1,368
$88,920
aLabor cost for permitting authorities estimated at $65.00 per hour. Information Collection Request for State Operating Permit Regulations
(Renewal), EPA ICR Number 1587.12, OMB Control Number 2060-0243,2015.
The following tables indicate the estimated annual avoided cost when comparing the "No
Action" baseline to different GHG SER option levels. In Tables 6.1through 6.3, the first three
columns indicate the cost per permit and total cost to permitting authorities at the "No Action"
baseline for PSD and Title V. The next three columns reflect the estimated costs for permitting
authorities at the specified option level. In the final three columns, the avoided cost is estimated
- the time and costs alleviated relative to the "No Action" baseline level by establishing a
different GHG SER level.
The estimated annual avoided cost for sources at the different GHG SER option levels is
presented in Tables 7.1 through 7.3 below. This information on avoided cost was used to compile
the Economic Impact Analysis (EIA) for the proposed rule. Please see the EIA contained in the
public docket for this GHG SER rule for a full explanation and description of the avoided cost
that would be provided under the different GHG SER option levels.
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Table 6.1. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 30,000 tpy GHG SER level (Annual)

"No Action" S
ER
30,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
PSD Permits









Add GHG Requirements to Anyway' Permits
$4,400
103
$453,200
$4,400
88
$387,200
$4,400
15
$66,000
Title V Permits









Add GHG Requirements to New Permit
$2,632
28
$73,696
$2,632
28
$73,696
$2,632
0
$0
Add GHG Requirements to Permit Revision
$504
75
$37,800
$504
60
$30,240
$504
15
$7,560
Total Additional Permitting Authority Costs

$564,696

$491,136

$73,560

Table 6.2. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 45,000 tpy GHG SER level (Annual)

"No Action" S
ER
45,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
PSD Permits
Add GHG Requirements to Anyway' Permits
$4,400
103
$453,200
$4,400
81
$356,400
$4,400
22
$96,800
Title V Permits
Add GHG Requirements to New Permit
$2,632
28
$73,696
$2,632
28
$73,696
$2,632
0
$0
Add GHG Requirements to Permit Revision
$504
75
$37,800
$504
53
$26,712
$504
22
$11,088
Total Additional Permitting Authority Costs

$564,696

$456,808

$107,888
12

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Table 6.3. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 75,000 tpy GHG SER level (Annual)

"No Action" S
ER
75,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total
Cost
(2014$)
PSD Permits









Add GHG Requirements to Anyway' Permits
$4,400
103
$453,200
$4,400
66
$290,400
$4,400
37
$162,800
Title V Permits









Add GHG Requirements to New Permit
$2,632
28
$73,696
$2,632
28
$73,696
$2,632
0
$0
Add GHG Requirements to Permit Revision
$504
75
$37,800
$504
38
$19,152
$504
37
$18,648
Total Additional Permitting Authority Costs

$564,696

$383,248

$181,448
Table 7.1. Estimated Regulatory Cost Avoided for Sources Utilizing a 30,000 tpy GHG SER level (Annual)

"No Action" SER
30,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
PSD Permits









Add GHG Requirements to Anyway' Permits
$23,532
103
$2,423,796
$23,532
88
$2,070,816
$23,532
15
$352,980
Title V Permits
Add GHG Requirements to New Permit
$2,470
28
$2,498
$2,470
28
$69,160
$2,470
0
$0
Add GHG Requirements to Permit Revision
$520
75
$595
$520
60
$31,200
$520
15
$7,800
Total Additional Source Costs

$2,426,889

$2,171,176

$360,780
13

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Table 7.2. Estimated Regulatory Cost Avoided for Sources Utilizing a 45,000 tpy GHG SER level (Annual)

"No Action" SER
45,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
PSD Permits
Add GHG Requirements to Anyway' Permits
$23,532
103
$2,423,796
$23,532
81
$1,906,092
$23,532
22
$517,704
Title V Permits
Add GHG Requirements to New Permit
$2,470
28
$69,160
$2,470
28
$69,160
$2,470
0
$0
Add GHG Requirements in Permit Revision
$520
75
$39,000
$520
53
$27,560
$520
22
$11,440
Total Additional Source Costs

$2,531,956

$2,002,812

$529,144
Table 7.3. Estimated Regulatory Cost Avoided for Sources Utilizing a 75,000 tpy GHG SER level (Annual)

"No Action" SER
75,000 tpy GHG SER
Avoided Cost
Activity
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
Additional
Cost per
Permit
(2014$)
Number
of
Permits
Total Cost
(2014$)
PSD Permits









Add GHG Requirements to Anyway' Permits
$23,532
103
$2,423,796
$23,532
66
$1,553,112
$23,532
37
$870,684
Title V Permits
Add GHG Requirements to New Permit
$2,470
28
$69,160
$2,470
28
$69,160
$2,470
0
$0
Add GHG Requirements to Permit Revision
$520
75
$39,000
$520
38
$19,760
$520
37
$19,240
Total Additional Source Costs

$2,531,956

$1,642,032

$889,924
14

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Appendix A GHG BACT Review and PSD Permit Counts
A.l 2011-2014 "Anyway" PSD Permits with GHG BACT
Review
1.	NUCOR Corporation, St. James Parish, LA ml
2.	We Energies, Rothschild, WI. (biomass co-gen boiler at a paper
mill) el
3.	PacifiCorp Lake Side Power Plant, Utah County, UT e2
4.	Mid-American Energy, George Neal South, Salix, IA
(installation of pollution controls at a coal-fired power plant) e3
5.	Mid-American Energy, George Neal South, Salix, IA (same as £
6.	Wolverine Power, Rogers City, MI (biomass boilers) e5
7.	Lafarge Cement, Ravena, NY mnl
8.	Abengoa BioRefinery, Hugoton, KS cl
9.	Wolverine Power, Sumpter Energy, Carleton Farms, MI e6
10.	US Steel Keetac Iron & Taconite Plant, Keewatin, MN [DelegatedState Permit] m2
11.	Mid-American Energy, George Neal North, Sergeant Bluff, IA e7
12.	Palmdale Hybrid Energy Center, Antelope Valley, CA [EPA] e8
13.	Crawford Renewable Energy, Greenwood Township, PA e9
14.	Eni Holy Cross Drilling Project, OCS Eastern GOM [EPA] ol
15.	Hyperion Refinery and Energy Center, Union County, SD rl
16.	Lower Colorado River Authority - Ferguson, Horseshoe Bend, TX [EPA] elO
17.	Wolverine Power, Sumpter Power Plant, Belleville, Michigan ell
18.	Hoosier Energy - Merom Station, Sullivan, IN el2
19.	Port Dolphin Energy LNGPort, OCS Eastern GOM [EPA] o2
20.	IPL Ottumwa Generating, Ottumwa, IA el3
21.	Kennecott Utah Copper- Repowering, South Jordan, UT m3
22.	US Nitrogen - Midway, Green County, TN c2
23.	Beaver Wood Energy, Fairhaven, VT el4
24.	University of Wisconsin - Charter Street, Madison, WI el5
25.	Universal Cement, Chicago, IL [Delegated State] mn2
26.	Carolina Cement, Castle Hayne, NC mn3
27.	PyraMax Ceramics, Allendale, SC mn4
28.	PyraMax Ceramics, Wrens, GA mn5
29.	NRG Energy, Dover, DE el6
30.	York Plant Holding, Springettsbury, PA e 17
31.	Pioneer Valley Energy Center, Westfield, MA [EPA] el8
32.	Tenaska Christian County Generation IGCC, Taylorville, IL [Delegated State\e 19
33.	Entergy Louisiana LLC - Ninemile Point Plant, LA e20
Key:
Power Plant (including cogen) - e
Oil and Gas - o
Pulp, Paper and Wood Products- p
Chemicals Production- c
Metals - m
Refineries - r
Minerals - mn
but at different unit) e4
15

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34.	Sabine Pass LNG LP, Cameron, LA o3
35.	Westlake Vinyls, LA c3
36.	Pryor Chemical Company, OK c4
37.	Atlas Pipeline Mid-Continent West OK, LLC (WESTOK), OK o4
38.	ETC Texas Pipeline, Natural Gas Processing Plant, Jackson County, TX [EPA] o5
39.	Indiana Gasification, Spencer County, IN c6
40.	BHP Billiton Petroleum, Sake Exploratory Project, OCS Eastern GOM [EPA]o6
41.	Milwaukee Metropolitan Sewerage District, Milwaukee, WI e21
42.	Essar Steel, Nashwauk, MN [DelegatedState] m4
43.	CARBO Ceramics, Millen, GA mn6
44.	Effingham Power, Rincon, GA e22
45.	Showa Denko Carbon, Dorchester County, SC mn7
46.	Woodbridge Energy, NJ [DelegatedState\ e23
47.	Phillips 66 Alliance Refinery, Plaquemine, LA c7
48.	Williams Olefins, Geismar, LA c8
49.	JM Huber, Huber Engineered Woods, GA pi
50.	BASF FINA Petrochemical LP (BFLP), Port Arthur, TX [EPA] c9
51.	Black Hills Power - Cheyenne Prairie Generating Station, Cheyenne, WY [EPA]e24
52.	Cricket Valley Energy Center, Dover, NY e25
53.	Newark Energy Center, Newark, NJ [Delegated State\ e26
54.	Exxon Mobil Point Thomson, North Slope, AK - Issued 8/20/12 o7
55.	Sevier Power Project, UT e27
56.	Enterprise Products - Eagleford Fractionation/DIB, Mont Belvieu, TX [EPA] 08
57.	Next Generation Processing, LLC - Haven Gas Plant, KS olO
58.	Pio Pico Energy Center, San Diego, CA [EPA] e28
59.	Moxie Liberty, Asylum Township, PA oil
60.	Graymont Limestone - Pleasant Gap, Spring Township, Center County, PA mn8
61.	GSA Federal Research Center (White Oak), MD e29
62.	CPV Energy, St. Charles, MD e30
63.	Iowa Fertilizer Company, Wever, IA ell
64.	Klausner Holding, Enfield, NC p2
65.	North Springfield Sustainable Energy, North Springfield, VT e31
66.	Gateway Cogeneration, Prince George, VA e32
67.	Calpine, Deer Park, TX [EPA] e33
68.	WE Energies Elm Road, Milwaukee, WI e34
69.	Energy Answers (permit revision to include GHG), MD e35
70.	Chevron Phillips Chemical Co., Cedar Bayou Plant, Baytown, TX [EPA]c/2
71.	Capitol Power (PAL), Washington, DC [EPA] e36
72.	Moxie Patriot, Clinton Township, Lycoming County, PA o!2
73.	Calpine, Channel Energy Center, Pasadena, TX [EPA] e37
16

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74.	St. Joseph Energy Center, New Carlisle, IN e38
75.	RockTenn-Solvay LLC, NY m5
76.	Gerdau MACSTEEL, Monroe, MI m6
77.	Equistar Chemicals, Methanol Unit, Channelview, TX [EPA] cl3
78.	Mid-Kansas Electric Co. - Rubart Station, KS e39
79.	Sinclair Wyoming Refining, Sinclair, WY [EPA] r2
80.	WBI Energy, Dakota Prairie, ND r3
81.	Montana-Dakota Utilities, R.M. Heskett Station, Mandan, ND e40
82.	Equistar Chemicals, La Porte, TX [EPA] cl4
83.	Gibson County Generating, Rutherford, TN e41
84.	Magnetation, Reynolds, IN m7
85.	Cargill Ethanol Plant, Fort Dodge, IA cl6
86.	Alcoa, Davenport Works, IA m8
87.	Rio Grande Cement, Pueblo, CO mn9
88.	LADWP Scattergood Generating Station, CA e42
89.	Roxul USA, MS mnlO
90.	Energy Answers, Arecibo, PR [EPA] e43
91.	Equistar Chemicals, Olefins 1 Expansion, Channelview, TX [EPA] cl8
92.	Equistar Chemicals, Olefins 2 Expansion, Channelview, TX [EPA] cl9
93.	Oregon Clean Energy Center, Oregon, OH e44
94.	Green Bay Packaging, WIp3
95.	Empire District Electric, KS e45
96.	Hydrogen Electric California, Kern County, CA e46
97.	Basin Electric Power, Pioneer Generating Station, ND e47
98.	Kerr-McGee Gathering, CO ol6
99.	Consumers Energy, MI e48
100.	Midland Cogen Venture, Midland, MI e49
101.	Southern Minnesota Beet Sugar, MN [DelegatedState\c20
102.	Flint Hills Resources draft PSD permit- Rosemount, MN [DelegatedState\ r4
103.	I PL Eagle Valley Generating Station, Martinsville, IN e50
104.	Diamond Shamrock, Valero McKee Refinery, Sunray, TX [EPA] r5
105.	Virginia Power and Light, Brunswick Plant, VA e51
106.	Green Energy Partners - Stonewall Energy, VA e52
107.	EN-Tire, White Deer Energy, PA e53
108.	DSM Chemicals, GA c22
109.	Klausner Holding, SC p4
110.	Carroll County Energy, OH e55
111.	Big River Steel, AR mlO
112.	La Paloma Energy Center, Cameron, TX [EPA] e56
113.	Cargill-Blair, NE c23
17

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114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
Nucor Steel, NE mil
Anchorage Municipal Power and Light, Sullivan Plant Two, AK e57
Puget Sound Energy, Fredonia, WA e58
Air Liquide Large Industries, Bayou Generation Plant, TX [EPA] c25
Crosstex Processing Services, Eunice Gas Extraction Plant, LA ol8
Shintech Louisiana, LLC., Hydrochloric Acid Production Furnace, LA c26
Shintech Louisiana, LLC, Plaquemine PVC Plant, LA c27
Crosstex Proceesing Services, Plaquemine NGL Fractionation Plant, LA ol9
Basin Electric Power, Lonesome Creek Generating, ND e59
Kraton Polymers U.S. LLC, OH c28
BP-Husky Refining, LLC, OH r6
TECO Polk Station, FL [EPA] e60
Frontier El Dorado Refining, LLC, KS r7
Holly Corporation SLC Refinery, UT r8
CPV Valley, NJ [Delegated State] e61
Texas Eastern Transmission, PA o20
Garrison Energy Center, DE e62
Berks Hollow Energy, Berks, PA e63
Hickory Run Energy, Lawrence, PA e64
Frederick County Waste to Energy, MD e65
Future Power of PA, PA e66
Progress Energy Carolinas, NC e67
DuPont Johnsonville, TN c29
Ohio Valley Resources, Spencer, IN c30
Nucor Steel, Montgomery County, IN ml2
Renaissance Power, MI e68
Lima Refinery, OH r9
PCS Nitrogen Ohio, OH c31
Mid America Midstream, Rose Valley, OK o21
Rohm and Haas, Deer Park, TX [EPA] c32
Occidental Chemical, Chemical Plant, Ingleside, TX [EPA] c33
Celanese Clear Lake, TX [EPA] c34
CF Industries Nitrogen, Port Neal, IA c35
TradeWind Energy, Lacey Randall Station, KS e70
Dyno Nobel Ammonia Plant, Jefferson Co., LA c36
Sunbury Generation LLC, Sunbury, PA e71
Equistar Chemical, Olefins, Corpus Christi, TX [EPA] c37
FGE Power, Westbrook, TX [EPA] e75
Lenzing Fibers, Mobile, Alabamap5
University of Alaska, Fairbanks, Alaska e76
18

-------
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
Troutdale Energy Center, Multnomah County, OR e77
EFS Shady Hills Generating Station, FL [EPA] e78
New Hope Power Company Okeelanta Cogeneration [EPA] e79
Dow Chemical Freeport, TX [EPA] c38
Golden Spread Electric Cooperative, Antelope, TX [EPA] e80
Indeck Wharton Energy Center, TX [EPA] e81
Occidental Chemical Corporation, Ethylene Plant, Ingleside, TX [EPA] c39
PSEG Sewaren Generating, NJ [DelegatedState] e82
Global Foundries, NY ml3
Novelis Corporation, NY ml4
C3 Petrochemicals, TX [EPA] o25
ONEOK Hydrocarbon, Mont Belvieu NGL Frac -3 & 4 [EPA] o26
Voestelpine, Portland, TX [EPA] ml5
Formosa Plastics Corporation LDPE Plant, Point Comfort, TX [EPA] c40
Formosa Plastics Corporation Olefins Expansion, Point Comfort, TX [EPA] c41
Formosa Plastics Corporation Gas Turbines, Point Comfort, TX [EPA] e83
Invenergy Thermal Development, Goldsmith, TX [EPA] e84
OCI Beaumont, Nederland, TX [EPA] e85
Pinecrest Energy Center, Lufkin, TX [EPA] e86
Tenaska Roans Prairie Generating Station, Shiro, TX [EPA] e87
Green River Soda Ash , Green River, WY [EPA] mnll
Austin Energy Sand Hill Energy Center, Austin, TX [EPA] e88
CCI Corpus Christi, LLC, Nueces County, TX [EPA] o27
Natgasoline, LLC, Nederland TX [EPA] c42
Victoria Power Station, Victoria, TX [EPA e89\
Lon C. Hill Power Station, Corpus Christi, TX [EPA] e90
M&G Resins, PET Plant, Corpus Christi, TX [EPA] c43
M&G Resins, Utility Plant, Corpus Christi, TX [EPA] e91
Nuevo Midstream, Ramsey Gas Plant, TX [EPA] o28
Footprint Power, MA [Delegated State] e92
West Deptford Energy II, NJ [Delegated State] e93
FPL Lauderdale, FL e94
MS Silicon, MS mnl2
Ember Clear, Adams Co., MS c44
Duke Energy, Lee Steam, SC e95
Cronus Chemicals Tuscola, IL [Delegated State] c45
Abengoa Bioenergy, Ethanol Expansion, IN c46
Jet Corr, Porter County, INp6
Midwest Fertilizer, IN c47
Valero Renewables, MN [Delegated State] c48
19

-------
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
Middletown Energy, OH e96
Linde Gas North America, OH c49
DTE Marietta, OH e97
Packaging Corp of America, WIp7
El Dorado Chemical Company, AR c50
Hobbs Generating Station, NM e98
Iowa State University Power Plant, Story, IA e99
IPL Allant Energy, Marshalltown Generating Station, IA el 00
Iowa Fertilizer Company (major mod to original permit), IA c51
Mid-American Energy, Walter Scott Energy Center, Unit 3, IA elOl
Solvay Chemicals, WY c52
Berry Petroleum (permit 1), SJV District, CA o28
Berry Petroleum (permit 2), SJV District, CA o29
Berry Petroleum (permit 3), SJV District, CA o30
Vintage Petroleum (permit 1), SJV District, CA o31
Vintage Petroleum (permit 2), SJV District, CA o32
E&B Natural Resources, SJV District, CA o33
McPherson Oil Company, SJV District, CA o34
Wild Horse GeoPower, Northern Sonoma district, CA el02
Sierra Pacific, Anderson, CA [EPA] p8
PGE Coyote Springs, OR el03
Guadalupe Power Partners, LP, Marion, TX [EPA] el04
Magellan Terminal Holdings, LP, Corpus Christi, TX [EPA] o35
Agrium, Kenai Nitrogen Operations, AK
Black Hills Power, Pueblo Airport Generating Station, CO
DCP Midstream, Lucerne Gas Processing Plant, Weld, CO
Boise White Paper, Clark County, AL (major?)
Georgia Pacific Breton LLC, Escambia County, AL
Kerr-McGee Gathering, Lancaster Plant, Weld, CO
Montville Power, CT - 2010?
Exxon Mobil Point Thomson, North Slope, AK - Issued 6/12/13
Exxon Mobil Point Thomson, North Slope, AK - Issued 1/23/15
Nucor, Decatur, AL
Corpus Christi Liquefaction Plant, TX
Colorado Bend Energy Center, Wharton Co., TX
Jacksonville Lime, Duval County, FL
Phillips 66 Lake Charles Refinery, Calcasieu, LA
Holland Board of Public Works, Ottawa, MI
Wolverine Power, Presque Isle Co., MI
CHS, Spiritwood Nitrogen Plant, Stutsman, ND
20

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234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
Abengoa BioRefinery, Ravenna, NE
Abengoa BioRefinery, York, NE
General Electric Aviation, Evendale Plant, Hamilton, OH
Koch Nitrogen, Enid Nitrogen Plant, Garfield, OK
Oiltanking Appelt Terminal, Harris Co., TX
Moundsville Power, Marshall Co., WV
FMC Granger Facility, Sweetwater Co., WV
Simplot Phosphates, Rock Springs Fertilizer Complex, WY
DAKOTA PRAIRIE REFINERY, DAKOTA PRAIRIE REFINING, Stark, ND
MAG PELLET LLC, White, IN
Magnolia Nitrogen Idaho LLC, American Falls, ID c
Phillips 66 Company, Roxana, IL r
Huber Engineered Woods LLC - Broken Bow OSB Mill, McCurtain, OK p
Mid America Midstream Gas Services LLC - Buffalo Creek Processing Plant, Beckham,
OKo
Western Farmers Elec Coop - Mooreland Generating Station, Woodward, OK e
Northstar Agri Ind Enid, Garfield, OK canola oil production
Jordan Cove Energy Project, L.P., OR e
SunCoke Energy South Shore, Inc., Greenup, KY coke production w/ elec gen
Cash Creek Generating Station, Henderson,KY e
Cameron Interstate Pipeline LLC - Holbrook Compressor Station, Calcasieu Parish, LA o
Sundrop Fuels Louisiana - Rapides Station Facility, Boyce, LA biofuels
CCI Port Nickel - Braithwaite Methanol Plant, Plaquemine Parrish, LA c
South Louisiana Methanol - St. James Methanol Plant, St. James Parish, LA c
Methanex USA - Geismar Methanol Plant, Geismar, LA c
AM Agrigen Industries Fertilizer Plant, Kilona, LA c
Cheniere Creole Trail Pipeline LP - Gillis Compressor Station, Ragley, LA o
CF Industries - Donaldsonville Nitrogen Complex (Permit 772), Donaldsonville, LA c
Big Lake Fuels -Natural Gas to Gasoline Plant, Lake Charles, LA c
Cameron LNG - Cameron LNG Liquefaction project, Hackberry, LA o
Sasol North America - Lake Charles Cracker Project, Westlake, LA c
Columbia Gulf Transmission - Alexandria Compressor Station, Rapides Parish, LA o
Trunkline LNG - Lake Charles LNG Export Terminal, Lake Charles, LA o
21

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A.2 RBLC and State Web Site Permit Data

2011 Summary Data
2012 Summary Data
2013 Summary Data
2014 Summary Data
State
PSD
Data Source
PSD
Data Source
PSD
Data Source
PSD
Data Source

only
Chosen
only
Chosen
only
Chosen
only
Chosen
AK
2
RBLC
3
RBLC
1
RBLC
1
RBLC
AL
3
State
1
State
3
State
1
State
AR
1
State
1
RBLC
4
State
2
State
AZ
1
State
1
RBLC
0
State
0
State
CA
6
State
3
State
1
State
2
State
CO
1
State
1
State
1
RBLC
3
RBLC
CT
1
State
0
State
0
State
0
State
DE
1
State
1
RBLC
1
State
0
State
FL
5
State
6
State
4
State
5
State
GA
3
State
6
State
4
State
3
State
HI
0
State
0
State
0
State
0
State
IA
1
RBLC
6
RBLC
2
State
1
RBLC
ID
0
State
0
State
0
State
1
State
IL
0
State
0
State
0
State
4
State
IN
3
State
6
State
10
State
12
State
KS
6
State
3
State
8
State
2
State
KY
0
State
0
State
1
State
1
RBLC
LA
32
State
24
State
35
State
26
State
MA
1
State
0
State
0
State
1
State
MD
1
State
1
State
2
State
4
State
ME
0
State
0
State
0
State
0
State
Ml
6
State
4
State
9
State
6
State
MN
3
State
4
State
4
State
4
State
MO
0
State
1
State
0
State
0
State
MS
2
State
5
State
1
State
2
State
MT
0
State
0
State
0
State
0
State
NC
7
State
7
State
7
State
2
State
ND
2
State
2
RBLC
4
RBLC
1
RBLC
NE
0
State
5
State
7
State
2
State
NY
0
State
6
State
6
State
3
RBLC
NJ
0
State
2
State
0
State
0
State
NH
1
RBLC
0
State
0
State
0
State
NM
1
State
0
State
2
State
2
State
NV
1
State
0
State
1
State
0
State
OH
4
State
4
State
7
State
4
State
OK
1
State
8
State
10
State
3
State
OR
2
State
0
State
1
State
1
State
PA
1
State
1
State
6
State
1
State
Rl
3
State
0
State
0
State
0
State
SC
2
State
6
State
3
State
6
State
SD
0
State
0
State
0
State
0
State
TN
0
State
6
State
1
State
0
State
TX
11
State
15
State
17
State
30
State
UT
2
State
0
State
1
State
0
State
VA
0
State
5
State
2
State
2
State
VT
0
State
1
State
1
State
1
State
WA
3
State
1
State
5
State
2
State
Wl
7
State
7
State
4
State
7
State
WY
0
State
2
RBLC
3
RBLC
4
RBLC
WVA
0
State
0
State
0
State
1
State
Total
127
155
179
153

Four Year Annual Avg. = 153 PSD permits/yr
22

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Appendix B. Calculation for "Anyway" Permits Requiring GHG BACT Review
GHGSER
(tpy C02e)
0
30,000
45,000
75,000
Number of
"Anyway" Permits
Requiring GHG
BACT review
103
88
81
66
# of Newly
Constructed
Facilities
28
28
28
28
# of
Modifications
75
60
53
38
Note: Total PSD permits/yr=153
Total "anyway" permits with possible GHGs= 103 (153 X .67)
Based on assumption that 33% of permits do not involve GHGs
Number of "Anyway" Permits Requiring GHG
BACT review
10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000
GHGSER (tpy C02e)
Background Permit Info for Input to Excel Forecast Function:
GHG SER	Number of "Anyway" Permits Requiring GHG BACT review
0	103
75,000	66
Linear interpolation Excel Forecast Function results:
0	103
30,000	88
45,000	81
23

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Appendix C. PSD and Title V Permitting Burden for Permitting Authorities and Sources
Table C-l. Average Permitting Authority Burden per PSD Permit
Permitting Authority PSD Activity
Hours per Permit
PSD Permits
Non-GHGs
Only"
Anyway
Permits with
GHGs"
A. Attend Preapplication Meetings
49
54
B. Answer Respondent Questions
27
37
C. Log In and Review Data Submissions
21
31
D. Request Additional Information
8
13
E. Analyze for and Provide Confidentiality for Processing
24
24
F. Prepare Completed Applications for Processing
40
40
G. File and Transmit Copies
8
8
H. Prepare Preliminary Determination
38
48
I. Prepare Notices for and Attend Public Hearings
43
43
J. Application Approval
50
55
K. Notification of Applicant of PA Determination
8
8
L. Submittal of Information of B ACT/L AER to RBLC
19
24
Total
335
385
aHours per permit reflecting the effects of the Flexible Air Permitting (FAP) Rule (ICR 1230.26) and the PM2.5 Increments,
SILs, and SMC Rule (ICRs 2276.02; 1230.31). These ICRs were approved before the onset of permitting for GHGs.
bA permitting authority will need 50 additional hours for the GHG-related activities for a PSD permit for an "anyway" source.
These 50 hours have been divided among the activities, emphasizing those most likely to be associated with BACT.
24

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Table C-2. Average Source Burden per PSD Permit
Source PSD Activity
Hours per Permit
PSD Permits
Non-GHGs
Only3
Anyway
Permits with
GHGsb
A. Preparation and Planning
Determination of Compliance Requirements
170
170
Obtain Guidance on Data Needs
120
240
Preparation of BACT Analysis
112
214
B. Data Collection and Analysis
Air Quality Modeling
260
260
Determination of Impact on Air Quality Related Values
130
130
Post-construction Air Quality Monitoring
65
65
C. Permit Application
Preparation and Submittal of Permit Application
60
60
Public Hearings
27
27
Revisions to Permit
40
40
Total Burden Hours
984
1206
aHours per permit reflecting the effects of the Flexible Air Permitting (FAP) Rule (ICR 1230.26) and the PM2.5 Increments,
SILs, and SMC Rule (ICRs 2276.02; 1230.31). These ICRs were approved before the onset of permitting for GHGs.
bA source will spend an additional 222 hours for the GHG-related activities for an "anyway" PSD permit. Anyway sources need
an additional "120 hours to 'obtain guidance on data needs' and 102 hours for the 'preparation of BACT analysis."'
Table C-3. Average Permitting Authority Burden per Title V Permit3
Permitting Authority Title V Activity
Hours per Permit
Title V Permit
Non-GHGs Only
Title V Permit
Adding GHGs
Permit Application Review
110
121
Draft Permit Preparation
170
187
Comment Period Notification
11
12
Hold Public Hearings (2% of permits)
110
121
Interaction with the EPA
20
22
Analyze Public Comments and Prepare Final Permit (2% of permits)
44
48
Permit Issuance
9
10
Total Hours to Issue New Title V Permit
474
521
Significant Permit Revision
94
103
aAdapted from Table 2 and Attachment 2. Information Collection Request for State Operating Permit Regulations (Renewal), EPA
ICR Number 1587.12, OMB Control Number 2060-0243, 2015.
25

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Table C-4. Average Source Burden per Title V Permit3
Source Title V Activity
Hours per Permit
Title V Permit
Non-GHGs Only
Title V Permit
Adding GHGs
Prepare Application
330
363
Draft permits Interaction
50
55
Public Hearing Participation (2% of permits)
11
12
Total Hours to Obtain a New Title V Permit
391
430
Significant Permit Revision
84
92
aAdapted from Table 2 and Attachment 2. Information Collection Request for State Operating Permit Regulations (Renewal), EPA
ICR Number 1587.12, OMB Control Number 2060-0243, 2015.
26

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United States	Office of Air Quality Planning and Standards	Publication No. EPA-452/R-16-001
Environmental Protection	Health and Environmental Impacts Division	September, 2015
Agency	Research Triangle Park, NC

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