Questions for Potential Small Entity Representatives to help us estimate the impacts

of potential new requirements the Agency is considering

Management Practices

Tune-ups and boiler operator requirements:

1. Does your state or local authority require an annual or periodic tune-up of the 

boiler?

2. If not, do you perform an annual or periodic tune-up as part of routine 

maintenance, and what is your estimate of the cost to perform it? What 

percentage of the cost of performing routine maintenance is the annual tune-up? 

3. Does your state or local authority require any training or certification (licensing)

of the boiler operator?

4. If so (a certified (licensed) boiler operator is required), what is your estimate of 

the cost of either certifying the current boiler operator or adding a certified 

(licensed) boiler operator? What percentage of your facility’s or organization’s 

budget will this cost be? 

Energy audit (assessment):

1. Does your state or local electric power company offer any assistance, incentive, or 

discount in conducting an energy audit (assessment) for your facility?

2. If a requirement for implementation of the energy conservation measures 

identified by the energy audit is imposed, what rate-of-return (in percent terms, 

not payback period) would be the minimum required for you to implement any 

identified energy conservation measures for your type of operation?

Good Combustion Practices:

1. Do you use any monitors, emissions parameters, or process parameters to monitor 

the operation of the boiler? 

2. If you use monitors, what kind and how many? If monitors are used, are these 

monitors in place for environmental regulatory reasons? Insurance reasons? Are 

there other reasons, and if so, what are they?

Compliance Demonstration

1. Does your state require any continuous monitoring of emissions or process 

parameter(s)? If so, what are the costs to the facility? What percentage of overall 

facility costs do these represent? 

2. Does your state require any periodic testing or monitoring of emissions or process 

parameter(s)? If so, what are the costs to the facility? What percentage of overall 

facility costs do these represent? 
3. Do your boilers have testing ports available for conducting compliance tests? If 

not, what do you estimate the costs to be of modifying the stack for testing?

4. If your boilers were subject to emission limits, are there alternatives to monitoring 

emissions or to stack testing that would be less costly to demonstrate compliance? 

How much less costly are these alternatives? 

Permitting:

1. Are your boilers required to be permitted by the state or a local authority? If so, 

what is the cost for permitting? If not, what would you estimate the burden to be 

in terms of costs and hours if the boilers are required to be permitted? What is the 

size of these costs compared to the costs of boiler operation and the facility as a 

whole? If your boilers require permitting, are your permitting activities done by 

in-house staff or by outside contractors? 

2. Are your boilers required to be inspected for safety, insurance or other reasons? 

If so, have often is this performed? What is the cost of these inspections? What is 

the size of these costs compared to the cost of boiler operation and the facility as a 

whole? 

Compliance:

1. How do you know if your boilers are properly operated and maintained, and how 

do you ensure good combustion?

2. How much burden (in terms of cost and hours) would it be for you to maintain a 

file with daily operation and each inspection and maintenance conducted?

3. If your boiler was subject an emission limitation would you consider switching to 

a less polluting fuel and much additional burden (in terms of cost and hours) 

would it add? What fuel would your facility switch to (or blends of fuels), and 

what benefits outside of reduced emissions could your facility experience? 

Capital Availability and Regulatory Impact:

1. Are your firm’s or organizations expenses for the activities listed above largely 

paid for out of equity, earnings, or debt?

2. Considered together, how much of your firm’s or organization’s revenues or 

budget are the costs of the activities listed above in percentage terms?