----- Original Message ----- 

 From: "Lacey, Pam" [PLacey@aga.org] 

 Sent: 06/04/2010 02:35 PM AST 

 To: Roger Fernandez 

 Cc: Akachi Imegwu; "Plotkin, Victoria" <vplotkin@aga.org> 

 Subject: RE: Subpart W - Additional Cost Impact Data - for 

Distribution M&R Annual Leak Surveys Docket EPA-HQ-OAR-2009-0923 

Roger - I am sorry about the misunderstanding. I am also working on 

getting an answer to your question about state and federal leak 

detection requirements. - Pam 

-----Original Message----- 

From: Fernandez.Roger@epamail.epa.gov 

[mailto:Fernandez.Roger@epamail.epa.gov] 

Sent: Friday, June 04, 2010 2:09 PM 

To: Lacey, Pam 

Cc: Imegwu.Akachi@epamail.epa.gov; Plotkin, Victoria 

Subject: Re: Subpart W - Additional Cost Impact Data - for Distribution 

M&R Annual Leak Surveys Docket EPA-HQ-OAR-2009-0923 

Pam 

While we appreciate this information and we will consider it in our 

analysis, for the record, this is not the information that I requested 

in the email I sent yesterday of which I also placed in the docket. 

If there is any confusion, I suggest we speak on Monday. 

Thanks 

Roger 

----- Original Message ----- 

From: "Lacey, Pam" [PLacey@aga.org] 

Sent: 06/04/2010 01:32 PM AST 

To: Roger Fernandez 

Cc: Akachi Imegwu; "Plotkin, Victoria" <vplotkin@aga.org> 

Subject: Subpart W - Additional Cost Impact Data - for Distribution 

M&R Annual Leak Surveys Docket EPA-HQ-OAR-2009-0923 

Roger -- In response to your request for additional cost data showing 

our estimated costs for leak detection under the proposed Subpart W 

broken out by type of metering and regulating (M&R) station and meter, I 

am providing the attached spreadsheet provided by one of our larger 

member companies (with company-identifying information removed). This 

is a rough estimate, but is more likely to underestimate than 

overestimate costs. Please forward this email and attachment to the 

rulemaking docket number EPA-HQ-OAR-2009-0923. 

AGA is gathering additional cost data from members through a survey that 

should provide a broader view of costs. The survey data will also be 

broken out by type of M&R station (city gates, custody transfer 

stations, district regulating stations, industrial customer M&R, 

commercial customer M&R, and residential customer meters). I will also 

forward the summary of survey results as soon as possible, in addition 

to including it in AGA’s comments to be filed June 11, 2010. 
Note: The member that provided the attached spreadsheet data explained 

they estimated that the incremental cost for conducting the annual leak 

detection called for in Subpart W would be $40.51 per inspection per 

city gate station or district regulator station or per industrial or 

commercial customer meter if infrared cameras are not required – roughly 

one hour of technician time. In contrast, they estimate it would cost 

about $16,125 per city gate to conduct the annual inspection using an 

infrared camera. The costs of using infrared cameras at other M&R 

locations varies by type – 

· $16,125 per city gate 

· $860 per district M&R station from transmission (custody 

transfer other than at city gate) 

· $244 per district M&R station (stepping down pressure within 

distribution system) 

· $377 per industrial meter 

· $30 per commercial meter 

· No figure given for residential – but likely to be roughly the 

same as for commercial – i.e. $30 per meter 

You can multiply the per location estimates by the total number of city 

gates, custody transfer stations, industrial meters, commercial meters 

and residential meters in the U.S. (based on the DOE EIA numbers of 

meters) to determine total cost for requiring infrared cameras at each 

type of metering and regulating location. Similarly, you can multiply 

$40.51 times the number of each type of M&R station or meter to 

determine the cost of requiring annual leak surveys under Subpart W, 

without requiring infrared cameras. 

There are more than 70 million residential, commercial and industrial 

customers in the U.S. If leak surveys were required at each meter, but 

not infrared cameras, the cost would be $2,835,700,000 – nearly $3 

billion per year, and that is without requiring infrared cameras. AGA 

requests that EPA clarify that the term M&R station excludes industrial, 

commercial and residential customer meters. 

Thank you for the opportunity to provide comments and data regarding the 

Subpart W proposal. 

Respectfully, 

Pamela 

(Embedded image moved to file: pic16590.jpg) 

Pamela A. Lacey| Sr. Managing Counsel, Environment 
American Gas Association 

400 N. Capitol St., NW | Washington DC 20001 202.824.7340 | 

placey@aga.org | Fax 202.824.7082 | www.aga.org 

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[attachment "AGA Member GHG Reporting Subpart W Potential Impacts June 

2010.xlsx" deleted by Roger Fernandez/DC/USEPA/US]