1

King, Melanie

From: Higgins, Cortney <Cortney_Higgins@omb.eop.gov>

Sent: Thursday, October 23, 2014 11:02 AM

To: CurryBrown, Amanda

Cc: King, Melanie; Elman, Barry; Weatherhead, Darryl

Subject: RE: 111d Supplemental RIA Costs

Ok – please make the changes to Tables 1 and 2.  Thanks for clarifying this is different than the June NPRM.

Regards,

Cortney

From: CurryBrown, Amanda [mailto:CurryBrown.amanda@epa.gov] 

Sent: Thursday, October 23, 2014 7:15 AM 

To: Higgins, Cortney 

Cc: King, Melanie; Elman, Barry; Weatherhead, Darryl 

Subject: RE: 111d Supplemental RIA Costs 

Hi Cortney,

We can definitely update Table 1 and Table 2 to show the same level of detail as the cost table in the RIA. One thing to

note just for reference – this is more detail than we were able to show in the June proposal because we had to use a

simple spreadsheet analysis for the territories rather than IPM, which doesn’t include the territorial units. It’s not

possible to clearly parse out the impacts of the individual cost components in IPM due to the nature of the optimization

model. I know there was extensive discussion of this at proposal, so wanted to flag the reason for the difference in

approach here.

Amanda  

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov]  

Sent: Wednesday, October 22, 2014 4:38 PM

To: CurryBrown, Amanda

Cc: King, Melanie; Elman, Barry; Weatherhead, Darryl

Subject: RE: 111d Supplemental RIA Costs

Hi all,

Thanks Amanda!    Comment A4 in the RIA and A3 in the NPRM requested that the fuel savings be listed as a benefit, not

as a cost.  While the fuel savings are broken out in the RIA (thank you!) they are listed in the cost tables, rather than in

the benefits table, as well as in the NPRM Table 1 as a cost savings, and further, the summary statement in the NPRM

about the cost of the rule is as follows:

The illustrative annual compliance costs and monitoring and reporting 

costs are a savings of approximately $170 million (2011$) in 2020. 

If EPA is not willing to move the fuel savings to the benefits column, can Table 1 in the NPRM be changed to breakout

the costs out into subcategories: (1) Annualized Capital, MRR, and EE Costs and (2) Fuel Cost Change.  That way the

presentation in the NPRM is more clear about how EPA arrived at the negative cost estimate.

Regards,

Cortney
2

From: CurryBrown, Amanda [mailto:CurryBrown.amanda@epa.gov] 

Sent: Tuesday, October 21, 2014 5:08 PM 

To: Higgins, Cortney 

Cc: King, Melanie; Elman, Barry; Weatherhead, Darryl 

Subject: 111d Supplemental RIA Costs 

Hi Cortney,

I just spoke with Melanie and she relayed your question about costs in the RIA. In the cost tables for each scenario

(starting on page 11 ‐ Table 5, 6, 7, and 8), we present the capital and energy efficiency costs, change in fuel

expenditures, and monitoring/reporting/recordkeeping costs as separate entries. These are then used to calculate the

total cost which is used in the summary tables elsewhere in the document.

I hope that helps – please let me know if there are any other questions I can answer.  

Amanda  

Amanda Curry Brown

Health and Environmental Impacts Division

U.S. EPA Office of Air Quality Planning and Standards

919.541.3808

CurryBrown.Amanda@epa.gov