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Hutson, Nick

From: Culligan, Kevin

Sent: Thursday, September 19, 2013 3:57 PM

To: Frey, Nathan J.; Hutson, Nick; Wayland, Robertj

Cc: Tsirigotis, Peter

Subject: RE: EGU NSPS -- Summary of Interagency Comments under EO 12866 13563

Nathan, 

We can accept the DOE text with the following edits (and intend to move forward 

with the package with this language unless we here that you’d prefer the earlier 

language we sent or believe the issue should be sent). 

“It should be noted that there is often can be “technology optimism” or 

technology pessimism associated with early cost estimates for emerging 

technologies, and successful RD&D can lead to lower costs and improved 

performance for future technology generations.” 

Also note that the revisions you sent did not include the two revisions to an 

earlier paragraph in this section. We also plan to make those changes. 

The DOE/NETL reports cite an accuracy range of -15% to +30% for the central point estimates shown in Table 6, which 

are based on many a number of assumptions, including: an EPCM contracting methodology, ISO ambient conditions, 

Midwest merit-shop labor costs, and a level greenfield site in the United States Midwest with no unusual characteristics 

(e.g., flood plain, seismic zones, environmental remediation). For specific sites that differ from this generic description, 

plant costs could exceed differ from the quoted range. 

- Kevin 

From: Frey, Nathan J. [mailto:Nathan_J._Frey@omb.eop.gov] 

Sent: Thursday, September 19, 2013 3:29 PM 
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To: Culligan, Kevin; Hutson, Nick; Wayland, Robertj 

Cc: Tsirigotis, Peter 

Subject: RE: EGU NSPS -- Summary of Interagency Comments under EO 12866 13563 

Please see attached for the latest summary of interagency comments under EO 12866 13563. Please let me know if you 

would like to discuss. 

From: Frey, Nathan J. 

Sent: Thursday, September 19, 2013 11:50 AM 

To: Culligan, Kevin; Hutson, Nick; Wayland, Robertj 

Cc: Tsirigotis, Peter 

Subject: RE: EGU NSPS -- Summary of Interagency Comments under EO 12866 13563 

Thanks – I have a minor suggestion if you second to give me a quick call. Almost there! 

From: Culligan, Kevin [mailto:Culligan.Kevin@epa.gov] 

Sent: Thursday, September 19, 2013 11:26 AM 

To: Frey, Nathan J.; Hutson, Nick; Wayland, Robertj 

Cc: Tsirigotis, Peter 

Subject: RE: EGU NSPS -- Summary of Interagency Comments under EO 12866 13563 

Nathan, 

After we spoke, I got further direction from Peter. We believe that the text starting with “despite the application.....” 

should be deleted because it is conjecture and not factual (and ignores the other side of the story, because it is often 

shown that projections like this are un-necessarily pessimistic and costs 

- Kevin 

From: Frey, Nathan J. [mailto:Nathan_J._Frey@omb.eop.gov] 

Sent: Thursday, September 19, 2013 9:44 AM 

To: Culligan, Kevin; Hutson, Nick; Wayland, Robertj 

Subject: EGU NSPS -- Summary of Interagency Comments under EO 12866 13563 

Hello all, 

Attached please find a summary of interagency comments under EO 12866 and 13563 regarding the issue(s) discussed 

yesterday. Please let me know ASAP if you would like to arrange a call to discuss. 

Thanks, 

Nathan