1

Summary of Methodology and Data Used to Estimate Burden Relief and 

Evaluate Resource Requirements at Alternative Greenhouse Gas (GHG)

Permitting Thresholds

March 2010

1. Introduction

This paper summarizes an assessment of the estimated resource requirements for 

permitting authorities to include GHG at several possible major source permitting thresholds and 

the burden reduction and costs savings for permitting authorities and sources as a result of

requiring the inclusion of GHG in the title V and Prevention of Significant Deterioration (PSD) 

permitting programs at thresholds greater than the current statutory requirements. A preliminary

analysis to support the tailoring rule proposal resulted in an earlier version of this Technical 

Support Document, found at EPA-HA-OAR-2009-0517.1 Based on comments received on the 

proposal and updates to key assumptions, this revised summary presents the updated 

methodology and burden reduction estimates resulting from several permitting threshold 

alternatives considered for the final tailoring rule. The analysis was performed considering GHG 

emissions on a carbon dioxide equivalent (CO2e) 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 Information Collection Requests 

(ICRs) for the title V and PSD programs. Estimates for the number of affected sources used in 

this analysis were obtained from the GHG thresholds evaluation, which can be found at EPAHQ-OAR-2009-0517.

2

 

1

“Summary of ICR-based Data Used to Estimate Avoided Burden and Evaluate Resource

Requirements at Alternative GHG Permitting Thresholds;” Prepared by EPA Staff; August 2009.

2

“Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air Quality 

Policy and Standards; March 29, 2010.
2

2. Methodology for Estimating Permitting Burden Due to GHG Emission Sources

This section describes the basic methodology we used to estimate the different types and 

quantities of permitting actions that would be affected by addressing GHGs under the PSD and 

title V permitting programs. The final burden results summarized in Section 3 are based on the 

methodologies described in this section. In developing our methodology, we established

different applicability options under which GHG emission sources would be regulated. These 

GHG applicability thresholds range from the statutory threshold levels (100 and 250 tpy) to 

different combinations of major source and significance levels based on GHG emissions, and 

finally, applicability based on GHG-related additions to otherwise occurring permitting actions 

for non-GHGs (also referred to here and in the preamble for this action as the ‘anyway’ source 

approach). We considered several different major source/major modification threshold 

combinations. We chose the combinations to reflect representative, incremental steps along the 

possible range. Because it is time- and resource- intensive to develop estimates for a given step, 

we chose intervals that best reflect representative points within the range given those time and 

resource constraints. For example, as it became evident from the analysis that the 100,000 tpy

CO2e major source threshold would be a viable option under one of the phase-in steps in the 

GHG tailoring rule, we needed to then evaluate different GHG significance level options in 

combination with the 100,000 tpy CO2 major source level to determine the ultimate impact on 

PSD and title V permitting activity. 
3

PSD Permits

Table 2-1 summarizes EPA’s estimate of modifications and new construction PSD 

permitting actions potentially affected by the addition of GHG as a regulated air pollutant at 

different GHG threshold options for PSD applicability. These actions are broken down by type 

of modification and new construction activity. Three types of modifications are included in this 

analysis: major modifications at major sources that are triggered by increased conventional 

pollutant emissions, but also exceed the significance level for GHG; modifications previously

considered minor that become major modifications due to GHG emissions occurring at existing 

major sources; and modifications at newly major GHG sources due solely to emissions 

exceeding the significance level threshold for GHG. For new construction, two types of sources 

are listed – those that are major sources due solely to the emissions of GHG, and those which are 

classified as major due to conventional pollutant emissions, but also exceed the GHG 

significance level (or ‘anyway’ sources). 

The first line items in Table 2-1 for modifications and new construction present estimates 

of GHG-related permitting actions that would occur at ‘anyway’ sources ; these are labeled in the 

table as “Current Modifications – Add Additional GHG” and “Newly Constructed Major 

Sources – Add Additional GHG.” The August 2008 ICR for the New Source Review (NSR) 

program estimates that 282 PSD and 519 non-attainment NSR permits are issued annually.

3

EPA’s initial burden analysis concentrated solely on the 282 annual PSD actions. If a source is 

major for a pollutant for which an area is designated non-attainment, all significant emissions or 

significant emissions increases of pollutants for which the area is in attainment are still subject to 

 

3

Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR 

Number 123.23, OMB Control Number 2060-0003, 2008. A copy of this document is available in the docket for the 

final Tailoring Rule.
4

Table 2-1. Estimated Number of PSD Permit Actions Exceeding GHG4Threshold Options

Threshold

100/250 

tpy 

major; 

100/250 

tpy sig. 

level

25,000 

tpy 

major; 

25,000 

tpy sig. 

level

50,000 

tpy 

major; 

50,000 

tpy sig. 

level

100,000 tpy 

major; 

50,000 tpy 

sig. level

100,000 tpy 

major; 

75,000 tpy 

sig. level

100,000 tpy 

major; 

100,000 tpy 

sig. level

NonGHG

Current Modifications – Add Additional GHG 448 448 448 448 448 448 448

Minor Modifications Becoming Newly Major 17,894 8,947 1,789 1,789 895 0 0

Modifications at Newly Major Sources 43,942 250 117 20 20 20 0

Modifications Total 62,284 9,645 2,354 2,257 1,363 468 448

Newly Constructed Major Sources - Add Additional GHG 240 240 240 240 240 240 240

Newly Constructed Major Sources 19,649 10 3 2 2 2 0

Newly Constructed Sources Total 19,889 250 243 242 242 242 240

Total 82,173 9,895 2,597 2,499 1,605 710 688

 

4 GHG threshold options are all based on tpy CO2e. The Non-GHG option is based on a PSD action being triggered for a non-GHG, conventional pollutant (e.g., 

nitric oxides), where a GHG-related PSD review is only necessary when associated GHG emissions for the project exceed 75,000 tpy CO2e.
5

PSD review. Thus, some of the facilities applying for nonattainment permits may also undergo 

PSD actions at the same time. Although there is no way of accurately predicting which of the

519 nonattainment actions might also coincide with a PSD action related to GHG emissions, we 

believe it is likely that most will since they typically involve large emission sources; thus, it is 

assumed all nonattainment actions from the ICR annual estimate will also need a PSD permit. 

Therefore, in this final analysis, to more accurately depict the number of PSD permitting actions 

occurring annually, it is assumed that all 801 permitting actions above involve a PSD action. We 

estimate that 70% of these permit actions are modifications, or 560 of the 801, based on feedback 

received from the National Association of Clean Air Agencies (which estimated that some 65% 

of these permitting actions involve modifications); other commenters on the proposed tailoring 

rule (who generally said that most permitting actions involve modifications); and EPA program 

staff experience.

5

Further, 80% of these modifications are expected to involve combustion

activities with GHG emission levels exceeding the statutory thresholds and any of the 

significance levels we considered, up to an including the 100,000 tpy CO2e level, thus requiring 

the inclusion of GHG related requirements in a PSD permit.6This equates to 448 modifications 

annually. We believe that any of the modifications that would be subject to PSD due to the 

conventional emissions would also be large enough to increase GHGs by at least 100,000 tpy of 

CO2e.

The 240 remaining annual permit actions—labeled in Table 2-1 as “Newly Constructed 

Major Source- Add Additional GHG”—are assumed to be construction of new major sources as 

 

5

“NACAA Summary on Permitting GHGs Under the Clean Air Act”; Memorandum from Mary Stewart Douglas, 

National Association of Clean Air Agencies to Juan Santiago, EPA/OAQPS, September 3, 2009.

6 The 80% estimate was obtained by reviewing a sample of PSD modification permits to determine the number 

involving combustion that would emit GHGs. This review showed that approximately 80% of PSD permitting 

actions involve combustion units of all types. These permitting actions are being permitted for, or taking limits for, 

NOx or some other combustion-related emission. These run the gamut of industrial activity, from power generators 

to manufacturing facilities, and many other types.
6

determined by emissions of one or more NAAQS pollutants. Due to the size and emissions of 

sources currently subject to the PSD permitting program, it is believed all of these newly 

constructed major sources will exceed each of the GHG thresholds we considered, including the 

100,000 tpy CO2e, and will also need to include GHG-related requirements in the PSD permit. In 

total, all 688 major permitting actions mentioned above will need to factor in GHG requirements

as indicated in Table 2-1. For permitting authorities, 50 additional burden hours are estimated to 

include the GHG requirements in a permit.

7

For affected sources, approximately 222 additional 

burden hours are needed, based on the two line items in the current NSR ICR we expect to be 

impacted by the addition of GHG – approximately 120 hours to “obtain guidance on data needs” 

and 102 hours for the “preparation of BACT analysis.” That is, the current NSR ICR indicates 

that on average, affected sources spend 222 hours for these two activities for their conventional 

pollutants. We expect that they will need to spend an equal amount of time for these two 

activities for their GHG emissions. The sources will need to “obtain guidance on data needs”

because they will be analyzing their emissions from GHG units and will need to prepare a 

separate BACT analysis for their GHG emissions, or else expand the BACT analysis they would 

otherwise do for their conventional pollutants to account for their GHG emissions. We believe 

that the remaining activities that the affected sources must undertake would not be appreciably 

lengthened by their need to include GHG emissions. 

 

7 A well-known gas with a familiar BACT process, such as NOx, requires an average of 20-30 burden hours to be 

included in a permit. As less is known regarding GHGs and the BACT decision process, expert staff judgment set 

the burden for permitting authorities to add GHG to permits at 50 hours. This is because determining BACT entails 

review and analysis of the available control techniques. For a well-known pollutant, the experience of the 

permitting authority allows it to efficiently consider the various options and narrow them down promptly to the one 

that should be considered BACT. Because no BACT determinations have ever been made, permitting authorities 

will need to invest additional time into reviewing the available technologies and selecting which one should be 

considered the best for the particular source. In the absence of any previous experience selecting BACT for GHG 

sources, we estimate that twice as much time will be necessary as for conventional pollutants. 
7

According to the NSR ICR, approximately 74,591 minor permitting actions occur 

annually, including the following: 30% involve new minor sources, new synthetic minor 

sources, and synthetic-based modifications; 30% involve true minor modifications; 20% involve

netting-based minor modifications; and 20% involve minor/administrative permit revisions.

8 We 

believe that a number of projects that could have taken limits or netted out of PSD review and

thereby obtain a minor permit will now be required to apply for a major PSD permit, depending 

on the significance threshold set for GHG. These projects are identified in Table 2-1 under 

“Minor Modifications Becoming Newly Major.” Combining the number of synthetic-based 

modifications (7,459) and netting-based modifications (14,909) identified in the ICR, 

approximately 22,368 of these actions could potentially become major modifications subject to 

PSD review if their associated GHG emissions increases exceed the selected GHG significance 

level option. We did not count ‘new minor sources’ and ‘new synthetic minors’ because we 

have already accounted for them as potential major GHG sources if their PTE emissions exceed 

the selected GHG major source threshold option. 

Based on staff review of samples of minor source permits, it is estimated that 80% of the 

current minor modification actions likely involve combustion sources – totaling 17,894 actions 

of the total 22,368 minor modification actions.9Some of these actions may trigger the 

requirements of the PSD program depending on their GHG emission increases and the selected 

GHG significance threshold. In the absence of any experience involving GHG sources and any 

sufficient quantitative data from commenters, we determined the number of these actions on the 

following basis: We assumed the following percentage of the total 17,984 actions would move 

to a major modification status due to GHG increases for each of the GHG significance level 

 

8

See NSR ICR at page 11.

9

 See footnote 6, above (basis for 80% calculation).
8

options considered in this analysis: 50% at 25,000 tpy CO2e; 10% at 50,000 tpy CO2e; 5% at 

75,000 tpy CO2e; and zero at 100,000 tpy CO2e. To determine these percentages, we considered 

the relative emissions of CO2 emissions to NOx emissions at the current major modification 

significance level threshold for NOx (40 tpy). For example, for an average natural gas 

combustion boiler (a common industrial combustion unit that is part of many modification 

projects), a 40 tpy NOx emissions would coincide with a 56,000 tpy CO2e level. Since many 

combustion related projects keep just under the 40 tpy NOx level to avoid major modification 

status, we assume that the CO2e emissions for a similar project will be around the 50,000 tpy

CO2e level. Based on the relationship in combustion-related emission levels between NOx and 

CO2e just described, we believe it is reasonable to expect that all these currently minor 

modification projects involving combustion units will exceed the 100 tpy GHG significance level

under the baseline scenario. This is because we do not believe that the sources at which these 

projects occur will be able to structure their operations so as to limit their GHG emissions to less 

than 100 tpy GHGs. However, at higher GHG significance level options, we assume that a 

decreasing proportion of projects will be significantly large enough, or they may emit GHGs 

close enough to the GHG significance level to be able to limit their operations or net-out for 

GHGs like they can for NOx. In the absence of experience and quantitative information from 

commenters we made the following assumptions regarding how many of these formerly minor 

modification projects would be subject to major PSD review at the different GHG significance 

level options: at the 25,000 tpy CO2e significance level, we estimate that half of the 

modifications will be able to limit their operations to avoid PSD ; at the 50,000 tpy CO2e 

significance level, we estimate that 10% of these previously minor now major modifications will 

be covered by PSD; at the 75,000 tpy CO2e significance level we estimate that only 5% of these 
9

currently minor modification projects move into a major modification status for GHGs; and

lastly, at the 100,000 tpy CO2e significance level, we assume that none of these projects will be 

large enough by themselves to trigger major PSD review.

In addition to sources becoming subject to PSD requirements because of GHG emissions 

related to modifications, new construction will occur that will require a PSD permit solely due to 

the source’s potential GHG emission levels, identified in Table 2-1 as “Newly Constructed 

Major Sources.” Based on the source data obtained from the GHG thresholds evaluation, these 

newly constructed major sources involve both industrial and commercial/residential facilities.

10

The current NSR ICR notes that permitting authorities spend approximately 300 hours 

processing and issuing a new construction industrial source PSD permit. Sources spend almost 

870 hours on average preparing for the same permit. In the previous burden analysis, 

commercial/residential permits were assumed to require only 20% of the time necessary for an 

industrial permit. While it is still believed that these sources are less complex than their industrial 

counterparts in terms of numbers and types of emissions sources and control requirements, EPA 

now estimates the commercial/residential permits to take 70% of the time required to complete

an industrial permit, resulting in approximately 210 hours and 866 hours for permitting 

authorities and sources respectively.

11 This is based on comments received, which stated that we 

had significantly underestimated the amount of time needed. These commenters emphasized that 

commercial and residential sources will generally be located in populated areas, and therefore 

may elicit significant amounts of public input, which in turn will increase the amount of time 

needed compared to our initial estimates. However, the commenters generally did not provide 

quantitative information. As a result, we conducted further evaluation of the additional support 

 

10 “Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air Quality 

Policy and Standards; March 29, 2010.

11 See Tables 2-2 and 2-3.
10

and outreach activities for permitting authorities to assist with applicability determinations and 

emissions calculations, as virtually all commercial/residential sources will have no experience 

with the PSD permitting process. There are also many permit preparation activities that represent 

a fixed cost, such as preparation of notices and public hearings. Of the sources falling in this 

category, the number requiring PSD permitting will vary depending on where the thresholds for 

triggering PSD review (both major source and modifications thresholds) are established.

Table 2-2. Average Permitting Authority Burden per GHG PSD Permit Type

Activity

Burden 

Hours per 

Permit -

Industrial

Burden Hours 

per Permit -

Commercial/ 

Residentiala

Attend Preapplication Meetings 36 27

Answer Respondent Questions 20 15

Log In and Review Data Submissions 16 12

Request Additional Information 8 6

Analyze for and Provide Confidentiality Protection 24 2

Prepare Completed Applications for Processing 38 29

File and Transmit Copies 8 6

Prepare Preliminary Determination 36 27

Prepare Notices for and Attend Public Hearings 40 30

Application Approval 48 36

Notification of Applicant of PA Determination 8 6

Submittal of Information on BACT/LAER to RBLC 19 14

Total Burden Hours per Permit 301 210

a

In general, to process commercial/residential permits, permitting authorities will have to spend 75% of the amount of time 

they spend on industrial permits, except they will have to spend even less time on confidentiality due to the fact that most 

residential sources are not likely to be concerned about confidentiality. Commercial/residential permits will be much 

simpler than industrial permits, but a large part of the permitting costs are fixed costs. For example, organizing and holding 

a hearing for a much simpler permit, compared to a more complex permit, nevertheless take almost as long because of the 

document preparation, travel, and organizational details.
11

Table 2-3. Average Source Burden per GHG PSD Permit Type

Activity

Burden Hours 

per Permit -

Industrial

Burden Hours per 

Permit - Commercial/ 

Residentiala

Preparation and Planning

Determination of Compliance Requirements 170 170

Obtain Guidance on Data Needs 120 120

Preparation of BACT Analysis 102 102

Data Collection and Analysis

Air Quality Modeling 200 40

Determination of Impact on Air Quality 

Related Values 100 30

Post-construction Air Quality Monitoring 50 20

Permit Application

Preparation and Submittal of Permit 

Application 60 60

Public Hearings 24 24

Revisions to Permit 40 40

Total Burden 866 606

a

PSD permit applications for commercial/residential sources will be significantly simpler than industrial source PSD 

permit applications. However, due to their inexperience, we estimate commercial/residential sources will take as long to 

complete their steps for their permit application as it will for industrial sources to complete their steps.

Commercial/residential sources will, on average, have much less work for data collection and analysis. We estimate that 

they will have approximately 25% as much work in these areas (90 hours) compared to industrial sources (350 hours). 

However, commercialresidential sources will have to spend some time on data collection analysis is because some of 

them will have conventional pollutants that they emit in amounts that exceed the “significance” levels, but not the 

“major” levels, and they will have to analyze those conventional pollutants. Our 25% estimate is based, in the absence of 

actual experience or quantitative data from commenters, on our judgment that significantly less than 50% of 

commercial/residential sources emit conventional pollutants in amounts that equal or exceed the significance levels, but 

those that do may have to spend more time than industrial sources on data collection because they are unfamiliar with the 

tasks and therefore will face a learning curve.

Finally, an existing, but newly classified major source for GHG, may undergo a 

modification for which it will then be subject to PSD permitting requirements. This category of 

PSD permitting activity is listed on Table 2-1 as “Modifications at Newly Major Sources.” With 

this new major source status, these facilities must apply for and be issued a PSD permit, if they

undergo a major modification. See Appendix A for a list of newly major sources at different 

major source GHG thresholds. We estimate that 4% of these newly major sources will undergo 

modifications. This rate was obtained by dividing the current 560 annual PSD modificationrelated permit actions (i.e., 70% of 801 actions identified in the NSR ICR) by the existing major 
12

source population of 14,700 major source title V permits. This represents our best available 

estimate of the rate of PSD modification activity at major sources, and we make the assumption 

that this rate will also apply for newly major GHG sources. We recognize that there is some 

level of uncertainty in applying this rate to GHG-only sources, particularly for sources in 

unconventional sectors such as commercial and residential categories, however we believe at 

higher GHG threshold levels, where large industrial sources predominate, that this modification 

rate provides a reasonable estimate of modification activity. As no data are yet available for 

commercial/residential sources and because we cannot conclude that they will differ from 

industrial sources, we select the same 4% rate for modification activity.

Title V Permits

Title V programs also complete several types of permitting actions annually, 

including processing and issuing new permits, permit revisions, and permit renewals. 

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. In 

addition to sources new to title V, permitting authorities must add GHG terms to permits 

for sources exceeding the threshold set for GHG emissions. Permitting authorities may 

face burdens to update existing title V permits for GHG under two possible scenarios: (1) 

EPA promulgates or approves any applicable requirements for GHGs that would apply to 

such a source, which would generally require a permit reopening or renewal application, 

or (2) the source makes a change that would result in an applicable requirement for GHG

to newly apply to the source, such as PSD review, which would generally require an 

application for a permit revision. Permitting authorities will also need to process permit 
13

renewal applications, generally on a five-year cycle, and such renewals would need to 

assure that the permit properly addresses GHG. 

The April 2007 Title V ICR estimates that 50 permits are completed every year for new 

sources.

12 For this analysis, it is assumed that all 50 of these typically large industrial-type

sources will be capable of potentially emitting GHG and will need to add GHG-related 

requirements to the permit. The estimated burden per title V permit in the ICR represents an 

average of multiple pollutants; we estimate the addition of GHGs will add an additional 10% of 

the time currently estimated for a new title V permit. We believe that 10% is the appropriate 

amount because for the most part, these sources will simply need to add information concerning 

inventory, reporting, or monitoring of their GHG emissions, as appropriate, which they can 

readily do. 

The ICR also identifies 3,267 permit renewals conducted on an annual basis. As not all 

sources potentially emit GHG above a determined threshold, this analysis examines the 

estimated 80% involving combustion activities that most likely have the potential to emit GHG 

above the series of potential thresholds evaluated.

13 Therefore, approximately 2,614 sources will 

need to address GHG in the new version of the permit.

Revisions to title V permits will also be necessary based on the number of modifications 

calculated for this analysis. Revisions occurring specifically due to GHG may involve significant 

revisions, minor revisions, or administrative actions to operating permits. EPA estimates that this 

activity will require 40 hours per permit on average for permitting authorities to complete.14 The 

 

12 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.07, 

OMB Control Number 2060-0243, 2007. A copy of this document is available in the docket for the final Tailoring 

Rule.

13 The 80% estimate was obtained through a review of existing title V permit source categorization. 

14 The Title V ICR indicates the burdens associated with revisions are as follows: 90 hours for a significant revision, 

30 hours for a minor revision, and 5 hours for an administrative action. See Table 8 at 23. It is not known which 
14

number of operating permit revisions will vary based on the number of previously minor 

modifications now qualifying as major modifications, and modifications at newly major sources, 

both listed in Table 2-1. At any level, it is assumed that the 448 modifications involving 

combustion that occur annually will need to include any GHG requirements in the revision of 

their respective title V permits. EPA estimates that permitting authorities will spend, in addition 

to the current burden to issue a title V permit revision, an additional 10% of the 40 hours needed 

to complete this process, or four hours per action.

Finally, new industrial and commercial/residential sources will be entering title V 

permitting programs annually due solely to their GHG emissions. These commercial/residential 

sources that exceed the major source threshold solely due to their GHG emissions will not likely

have substantial applicable requirements in the near term and/or will not require as much time to 

process as those for industrial sources, which have other applicable requirements in addition to 

those related to their GHG emissions. However, upon further evaluation and in response to 

comments from permitting authorities, EPA believes its initial estimate of one-tenth of the 

burden hours required was considered too low. Permitting authorities would confront substantial 

challenges as they have little experience with such sources and their GHG emissions. 

Commercial/residential sources themselves will have no experience with the title V permitting 

process, which will increase the time needed to assess GHG emissions, complete the application, 

and respond to permitting authority comments. We also expect that in many cases the draft 

permits will undergo high levels of public participation through public comment periods, public 

hearings, and petitions for reconsideration. Therefore, EPA assumes preparing a permit for 

 

revision will be required for any modification that exceeds the GHG significance level threshold; therefore, EPA 

averages the three permitting burdens to obtain a value of 40 hours per permit.
15

affected commercial/residential sources will take 50% of the time a permitting authority 

currently spends on issuing a title V permit for an industrial source.

Table 2-4. Average Permitting Authority Burden per GHG Title V Permit

Activity

Burden 

Hours per 

Permit -

Industrial

Burden Hours 

per Permit -

Commercial/ 

Residentiala

Permit Application Review 100 33

Draft Permits Preparation 150 50

Comment Period Notification 10 10

Hold Public Hearings 100 90

Interaction with EPA 20 5

Analyze Public Comments 40 20

Permits Issuance 8 6

Total Burden 428 214

aCommercial/residential permits will be simpler, so that it would take the permitting authority about 1/3 of the 

time to review the permit application and draft the permit than it would for an industrial source permit. The 

comment period notification and time for public hearings, however, would be about the same because of the 

fixed time burdens necessary to provide notice and hold hearings. The amount of time interacting with EPA 

would be much less because of the relative simplicity of the permits. Analyzing public comments would take 

half as long as for an industrial permit because although the permits are much simpler, there could be a fair 

amount of public interest because of the location of the source. Permit issuance would take a less time than for 

an industrial source because most of the costs are fixed, although the permit is simpler.

Table 2-5. Average Source Burden per GHG Title V Permit

Activity

Burden 

Hours per 

Permit -

Industrial

Burden Hours 

per Permit -

Commercial/ 

Residentiala

Prepare Application 300 150

Draft Permits Interaction 40 20

Public Hearing Participation 10 10

Total Burden 350 180

aCommercial/residential permit applications will be significantly simpler than industrial source title V permit 

applications. However, due to their inexperience, we estimate commercial/residential sources will take half as 

long to complete their steps for their permit application as it will for industrial sources to complete their steps. 

Less interaction, again 50% less time, will be needed with permitting authorities during the permit drafting 

process. However, public hearing participation will likely require the same amount of time because of the fixed 

time burdens necessary to complete hearings.
16

Uncertainties in Estimates of Affected Sources

In order to estimate the number of facilities that exceed a given GHG threshold (such as a 

100 or 250 tpy CO2e emission threshold for baseline analysis), it is necessary to have emissions 

inventory data at the facility or building level, including, and particularly for lower threshold 

scenarios, numerous small sources in the residential and commercial sectors (e.g., apartment 

buildings and office buildings). Historically, however, EPA has not collected sector-wide, 

facility-level information for GHG emissions under the CAA (with the exception of information 

from electric generating units required to report CO2 emissions under the Acid Rain Program 

reporting requirements). To date, national EPA inventories of GHG sources have primarily 

focused on ‘top-down’ estimates of GHG emissions from sectors and sources, and not facilitylevel estimates. As a result, many of the uncertainties described here result from the absence of a 

comprehensive data set of facility-level GHG emissions across all sectors. A full description of 

the methodology used for determining facility level emissions is provided in our GHG thresholds 

evaluation study, which can be found at EPA-HQ-OAR-2009-0517.15

For residential, commercial, and smaller manufacturing operations, our current analysis 

relies on sample facility datasets and ‘top-down’ sector data (e.g., national fuel consumption 

statistics and/or building characteristics). There are inherent uncertainties in developing source 

counts from the allocation of these nationally aggregated statistics. The allocation factors we 

used, based on U.S. Energy Information Administration statistical sampling procedures and 

energy consumption statistics, are likely the best available to estimate the population of 

residential, commercial, and small manufacturing sources exceeding different GHG thresholds. 

However, uncertainties may result in either overestimating or underestimating GHG emissions 

 

15 “Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air Quality 

Policy and Standards; March 29, 2010.
17

for a given individual facility. It is worth noting that our estimates for the largest GHG emitting 

sources, such as electric utilities and refineries, are derived from bottom-up calculations of 

individual facility/building emissions so that there is increased certainty in evaluating and 

comparing the facility counts at the higher GHG threshold scenarios where residential and 

commercial sources are not highly affected. Although there are different levels of uncertainty in 

our facility level estimates across sectors, we do believe that the data are sufficiently robust to 

use in the aggregate to assess national permitting level impacts. 

EPA’s estimate of affected sources is based on their potential to emit (PTE) emissions, as 

opposed to actual emission levels. PTE is defined as the maximum capacity of a stationary

source to emit a pollutant under its physical and operational design, including certain legal 

limitations, for example, on emissions or hours of operation. NSR and Title V programs both 

use PTE for defining and identifying major sources. Although we have attempted to identify

reasonable adjustments to account for PTE in our methodology, there are significant 

uncertainties in our PTE-based estimates, particularly for the commercial, residential and small 

manufacturing sectors that have not traditionally been subject to any form of air permitting. In 

practice, for example, for the residential sector and for many of the facilities in the commercial 

sector, where CO2 emissions are primarily due to space heating/appliance usage, the combustion 

units are not likely to be used constantly at their maximum rated capacity because heating is not 

needed year-round and heating systems have thermostats. However, for our analysis we do 

assume full PTE-based estimates for the residential and commercial sectors, using PTE 

adjustment factors of 10 and 6.6, respectively to adjust actual emissions to PTE level. Absent 

industry specific data, for small manufacturing source categories we assume a PTE adjustment 

factor of 2; individual manufacturing facilities may operate their combustion equipment at levels 
18

above and below this capacity utilization rate, but we believe this PTE adjustment reflects a 

reasonable average rate across the variety of small manufacturing facilities included in the 

threshold analysis. Ultimately, the number of sources brought into either the NSR or Title V 

programs due solely to their PTE would depend on how EPA interprets PTE for various types of 

emitting equipment (e.g., space-heating furnaces in residential and commercial buildings), and 

the extent to which streamlined mechanisms are made available for sources to obtain legal limits 

on their PTE so that the programs are not applicable. No such decisions or interpretations have 

been made at this point and, as mentioned in the preamble, they will require significant time to 

develop. As a result, our threshold analysis uniformly assumes that no PTE limits are in place 

for any of the affected sectors, which may likely be the case in the immediate stages of GHG 

permitting for affected sources.

There is significant uncertainty in both our modification rate for newly major GHG 

sources and in our estimate of modification activity at existing major sources that will become 

subject to PSD review for GHG emission increases. The general uncertainty results from 

predicting not only how many major sources will undergo physical or operational changes in any 

given year, but also which of those changes would result in GHG emissions increases that would 

exceed a proposed GHG significance level. First, information is not available across sectors and 

source categories on the types and numbers of specific physical and operational changes that 

would result in GHG emissions increases in amounts that can be estimated and that therefore can 

be compared to various GHG emissions significance levels. Second, there is uncertainty in how 

many project modifications will occur within any given year because decisions on these projects 

are driven by facility- and sector-based growth patterns and business planning decisions. Lastly, 

some source categories and units that emit GHGs have not previously been subject to any type of 
19

permitting or reporting requirements; as a result, for these sources, there is very little historical 

record for use in estimating the number and types of projects that would occur at these sources 

and, in turn, establish an appropriate significance level for GHGs. 

Uncertainties in Permitting Costs

The primary reference sources for our estimate of burden hours and costs for permitting 

GHGs are the most recent ICRs for the PSD and title V programs. There a number of 

uncertainties introduced in using these references for costing GHG permitting activities. First, 

we are assuming that the average, conventional pollutant per-permit costs will be similar for 

GHGs. We do recognize the likelihood that residential and commercial permits would be 

simpler and have a lower per-permit burden than traditional industrial sources, and have made 

adjustments for this: however, for industrial sources we assume per-permit costs on par with 

what are estimated in the latest ICRs for PSD and title V programs. There is uncertainty in 

applying these average ICR-based costs to GHG permitting, even for industrial sources, because 

there is no historical track record for permitting these GHG sources and thus any cost 

efficiencies that have been realized over the years for conventional pollutant permitting, and thus 

reflected in the current ICRs, may not be initially realized for GHG permitting. For example, we 

assume the same public hearing estimate as included in the ICR for current PSD permits (i.e., 

that 1 in 50 major PSD permits require a hearing)—for GHG sources this number may be higher 

initially if there ends up being significantly more public interest in these permits. We do believe 

overall, however, that larger facilities, especially those affected at higher threshold levels, will 

have had sufficient permitting experience such that out ICR-based costs should reasonably 

reflect the added burden of including GHGs. 
20

As mentioned above, in our burden scenario analyses we do discount the ICR-based perpermit costs for residential and commercial sources to reflect what we believe will generally be 

simpler permits, involving primarily uniform combustion type equipment. For PSD we discount 

the per-permit cost by 30%, and for title V we discount the per-permit cost by 50%. There is 

significant uncertainty in these estimated discounts since we have no track record for permitting 

these smaller commercial and residential sources. However, we do believe that, based solely on 

the type and uniformity of the GHG emission units that would be subject to permitting at these 

facilities under lower GHG threshold scenarios, that average per-permit costs would be less than 

those currently experienced by more complex industrial facilities, with numerous emission units, 

for currently regulated pollutants. 

3. Evaluation of ICR-based Resource Requirements for Permitting Authorities at Different 

 Possible GHG Permitting Thresholds

For the proposal, EPA examined resource requirements at the statutory-based 100/250 

tpy CO2e emission levels—referred to as the ‘baseline’ analysis in the following tables—as well 

as at 10,000 tpy, 25,000 tpy, and 50,000 tpy CO2e levels. Due to comments received on the 

proposal and this improved burden analysis, the 10,000 tpy threshold was eliminated as not being 

a viable alternative since it did not adequately address administrative necessity concerns. In this 

analysis, in addition to the baseline analysis, EPA broadened the options to consider thresholds 

ranging from a 25,000 tpy CO2e major source applicability level for PSD and title V up to a 

100,000 tpy CO2e level, with associated PSD GHG significant levels of equal magnitude. EPA 

also considered the impact on burden of different PSD GHG significance levels combined with 

the 100,000 tpy major source level, including 50,000 CO2e, 75,000 CO2e, and 100,000 CO2e.
21

The choice of a PSD significance level also has a direct impact on title V burdens since a greater 

number of PSD permit requirements that result from modification activities will result in a 

greater number of necessary title V revisions.

PSD Permits

Table 3-1 presents the estimated burden for permitting authorities at different possible 

PSD GHG major source applicability thresholds. Descriptions of the different thresholds 

selected are provided below. Burden estimates for the PSD program are calculated based on 

listed values obtained from Tables 6-1 and 6-2 the NSR ICR. The ICR does not distinguish 

between new construction and modification actions; therefore, Table 3-1 combines the actions 

into permit preparation issuance based solely on GHG emissions or the addition of GHG 

requirements to permits being issued for conventional sources, or “anyway” permits. PSD permit 

preparation and issuance is further divided into industrial and commercial/residential sources 

since less time is required for commercial/residential sources.

Baseline

After receiving comments on the proposal and reevaluating the initial estimates, EPA has 

determined the impact of regulating GHG emissions under current PSD statutory thresholds for 

applicability. Baseline burden and cost were calculated at the 100 tpy and 250 tpy major source 

permitting threshold (the 100 tpy threshold applies to the 28 source categories identified in the 

Clean Air Act section 169(1)). At these thresholds, the additional annual permitting burden for 

permitting authorities is estimated at 19.5 million hours at a cost of $1.5 billion.
22

Table 3-1. Additional Permitting Authority PSD Burden with GHG (Annual)

Activity

Burden 

Hours 

per 

Permit

Affected 

Permits

Total 

Burden 

(hours)

Total Cost 

($2007)a

100/250 tpy Major /100 tpy Significance Threshold (“Baseline”)

PSD Permit Preparation and Issuance - Industrial 301 26,089 7,852,789 $606,392,367

PSD Permit Preparation and Issuance - Commercial/Residentialb210 55,509 11,656,890 $900,145,046

Additions to Current PSD Applicationsc50 688 34,400 $2,656,368

Total Additional Burden 19,544,079 $1,509,193,780

25,000 tpy Major/ 25,000 tpy Significance Threshold

PSD Permit Preparation and Issuance - Industrial 301 9197 2,768,297 $213,767,894

PSD Permit Preparation and Issuance - Commercial/Residential 210 63 13,230 $1,021,621

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 2,815,927 $217,445,883

50,000 tpy Major/ 50,000 Significance Threshold

PSD Permit Preparation and Issuance - Industrial 301 1906 573,706 $44,301,577

PSD Permit Preparation and Issuance - Commercial/Residential 210 28 5,880 $454,054

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 613,986 $47,411,999

100,000 tpy Major/ 50,000 tpy Significance Threshold

PSD Permit Preparation and Issuance - Industrial 301 1809 544,509 $42,046,985

PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 579,749 $44,768,218

100,000 tpy Major/ 75,000 tpy Significance Threshold

PSD Permit Preparation and Issuance - Industrial 301 915 275,415 $21,267,546

PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 310,655 $23,988,779

100,000 tpy Major/ 100,000 tpy Significance Threshold

PSD Permit Preparation and Issuance - Industrial 301 20 6020 $464,864

PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 41,260 $3,186,097

Non-GHG-Based Threshold

PSD Permit Preparation and Issuance - Industrial 301 0 0 $0

PSD Permit Preparation and Issuance - Commercial/Residential 210 0 0 $0

Additions to Current PSD Applications 50 688 34,400 $2,656,368

Total Additional Burden 34,400 $2,656,368

aLabor cost of $77.22/hr from Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 1230.23, OMB 

Control Number 2060-0003, 2008. 

bAssume permit preparation and issuance for commercial/residential permits takes 70% the amount of time needed to prepare and issue an industrial permit. 

c

For current permit applications, assume it takes an additional 50 hours to include GHG requirements in the permit.
23

Alternate Threshold Scenarios

After determining the baseline, additional annual burden was determined at six different 

major stationary source threshold levels in order to evaluate the relative differences in impacts to 

permitting authorities. Estimates represent the additional burden and costs due to GHG 

permitting beyond to the burden currently experienced by permitting authorities and sources.

The first scenario is the threshold proposed in the GHG Tailoring Rule of 25,000 tpy

CO2e. Results of this analysis indicate a total of 9,260 new permits, plus 688 permit actions to 

include GHG related requirements into current PSD permitting actions (including both new 

construction and modifications). This additional workload equates to 2.8 million hours for 

permitting authorities at a cost of $217 million. Note this is an increase over our initial results at 

proposal of over 185,000 burden hours and $8.7 million. Again, increases are due to more 

accurate estimates of annual modifications and burden associated with commercial/residential 

permits.

Increasing the emission threshold to 50,000 tpy will lead to an estimated 614,000 hours 

additional burden at a cost of $47.4 million. This scenario estimates 1,934 new construction or 

modification activities will be subject to PSD permitting annually due to GHG.

Setting a threshold of 100,000 tpy with a significance level of 50,000 tpy, permitting authorities 

will spend an estimated 580,000 hours preparing and issuing permits, at a cost of $44.8 million. 

At this level, EPA estimates 1,813 new actions require PSD permits.

Next, at the 100,000 tpy threshold with a 75,000 tpy significance level, the annual 

permitting authority burden will increase by 311,000 hours at a cost of $24 million. In this 

scenario, 919 new permit actions will occur annually.
24

At a 100,000 tpy threshold, with a 100,000 tpy significance level for modifications, EPA

estimates there are 20 new industrial PSD permit actions and four commercial/residential. 

Permitting authorities will spend an estimated 41,000 additional hours on permits at a cost of 

$3.2 million.

The final scenario involves only sources that are required to get a PSD permit due to their 

non-GHG emissions and then are further required to add GHG related requirements as a result of 

GHG emissions increases from modifications, or GHG emissions at newly constructed facilities,

exceeding a significance threshold of 75,000 tpy GHG. In this scenario, only the annual 688 PSD 

permit actions derived from the NSR ICR are expected to need the inclusion of GHG related 

requirements to the permits. The additional burden to permitting authorities under this scenario is 

estimated at 34,000 hours at a cost of $2.7 million.

Title V Permits

Table 3-2 presents the estimated burden for permitting authorities at different possible 

title V GHG major source applicability thresholds. Descriptions of the different thresholds 

selected are provided below. Burden estimates are calculated and annual values derived from

Tables 7 and 8 of the current Title V ICR.16

Baseline

EPA reevaluated our estimates of the additional administrative burden and cost of 

including GHG emitters in the title V program at the current 100 tpy statutory threshold level. To 

determine the impact of regulating GHG emissions under current title V program, baseline 

 

16 For consistency, the permitting authority labor costs are updated to 2007 dollars utilizing the 2007 

General Schedule Salary Table from the Office of Personnel Management. 
25

Table 3-2. Additional Permitting Authority Title V Burden with GHG (Annual)

Activity

Burden 

Hour per 

Permit

Affected 

Permits

Total Burden 

(hours) Total Cost ($2007)b

100 tpy (associated with PSD 100/250 tpy maj./100 tpy sig.)

New Permit Preparation and Issuance – Industrial 428 71,829 30,742,812 $1,414,169,352

Add GHG component to new Non-GHG Permitb43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residentialc214 1,985,948 424,992,872 $19,549,672,112

Permit Revisions - due to GHG 40 61,836 2,473,440 $113,778,240

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewalsd9 2,614 23,526 $1,082,196

Total Additional Burden 458,236,592 $21,078,883,232

25,000 tpy (associated with PSD 25,000 tpy maj./25,000 tpy sig.)

New Permit Preparation and Issuance – Industrial 428 2,103 899,941 $41,397,301

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 214 444 94,945 $4,367,455

Permit Revisions - due to GHG 40 9,197 367,880 $16,922,480

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 1,390,234 $63,950,764

50,000 tpy (associated with PSD 50,000 tpy maj./50,000 tpy sig.)

New Permit Preparation and Issuance – Industrial 428 981 419,868 $19,313,928

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 214 208 44,441 $2,044,271

Permit Revisions - due to GHG 40 1,906 76,240 $3,507,040

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 568,017 $26,128,767

100,000 tpy (associated with PSD 100,000 tpy maj./50,000 tpy sig.) 

New Permit Preparation and Issuance – Industrial 428 172 73,473 $3,379,773

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 214 18 3,781 $173,911

Permit Revisions - due to GHG 40 1,809 72,360 $3,328,560

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 177,082 $8,145,772
26

Table 3-2 cont’d. Additional Permitting Authority Title V Burden with GHG (Annual)

Activity

Burden 

Hour per 

Permit

Affected 

Permits

Total Burden 

(hours) Total Cost ($2007)b

100,000 tpy (associated with PSD 100,000 tpy maj./75,000 tpy sig.) 

New Permit Preparation and Issuance – Industrial 428 172 73,473 3,379,773

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 214 18 3,781 $173,911

Permit Revisions - due to GHG 40 915 36,600 $1,683,600

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 141,322 $6,500,812

100,000 tpy (associated with 100,000 tpy maj./ 100,000 tpy sig.)

New Permit Preparation and Issuance – Industrial 428 172 73,473 $3,379,773

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 214 18 3,781 $173,911

Permit Revisions - due to GHG 40 20 800 $36,800

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 105,522 $4,854,012

Non-GHG Based Threshold 

New Permit Preparation and Issuance – Industrial 428 0 0 0

Add GHG component to new Non-GHG Permit 43 50 2,150 $98,900

New Permit Preparation and Issuance - Commercial/Residential 21 0 0 $0

Permit Revisions - due to GHG 40 0 0 $0

Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,792 $82,432

Permit Renewals 9 2,614 23,526 $1,082,196

Total Additional Burden 27,468 $1,263,528

a

Salaries from Title V ICR adjusted to 2007 dollars using 2007 OPM General Schedule Salary Table available at: http://www.opm.gov/oca/07tables/index.asp

b

Incorporating GHG information/requirements into significant revisions and permit renewals adds an additional 10% of the current time (90 hours each)

cNew commercial/residential permits require half the time needed for new industrial permits

dThe Title V ICR estimates that 3,267 permits annually undergo renewal - assume 80% of these involve combustion
27

burden and cost are calculated at the 100 tpy threshold level, which is the generally applied 

major source applicability level under title V. At the statutory threshold level, it is estimated that 

over six million sources will become newly subject to title V. A source generally must apply for 

a title V permit within one year of becoming subject to permitting, then the permitting authority 

must take final action (issue or deny) on the permit applications within 18 months of receipt. We 

expect these new permits will not be issued all at once, but rather will come in over a three-year 

time frame based on the statutory requirements listed above. Therefore, we assume that onethird of the newly subject sources will apply for and obtain a permit annually, requiring almost 

460 million burden hours to prepare and issue over two million new operating permits at an 

additional cost of $21.1 billion.

Alternate Threshold Scenarios

After determining the baseline, additional burden was determined at six different major 

stationary source threshold levels in order to evaluate the relative differences in impacts to 

permitting authorities. Estimates represent the additional annual burden and costs due to GHG 

permitting beyond the burden and costs currently experienced by permitting authorities and 

sources. 

The first scenario is the threshold proposed in the GHG Tailoring Rule of 25,000 tpy

CO2e. Results of this analysis indicate a total of 2,547 new permits, as well as 50 permits that 

would need to include GHG requirements in their permits. This additional workload equates to 

1.4 million hours for permitting authorities at a cost of $64 million. Note that this is an increase 

over our initial results at proposal of approximately 985,000 burden hours and $45 million. As 
28

with PSD programs, increases are due to more complete estimates of annual modifications and 

the revised burden associated with commercial/residential permits.

Increasing the emission threshold to 50,000 tpy will lead to an estimated 568,000 hours 

additional burden at a cost of $26.1 million. This scenario estimates 1,189 new sources will be 

subject to title V permitting annually due to GHG.

To examine the impact of significance levels on the overall burden, EPA considered the 

impact on burden of different PSD GHG significance levels of 50,000 CO2e, 75,000 CO2e, and 

100,000 CO2e combined with the 100,000 tpy major source level The choice of a PSD 

significance level has a direct impact on title V burdens since a greater number of PSD permit 

requirements that result from modification activities will result in a greater number of necessary

title V revisions. This effect is apparent in Table 3-2. Note that for all three scenarios, EPA 

estimates there are 172 industrial and 18 commercial/residential new title V permit actions due to 

GHG. 

Setting a threshold of 100,000 tpy with a PSD significance level of 50,000 tpy, permitting 

authorities will spend an estimated 177,000 hours preparing and issuing permits, at a cost of $8.1

million. Note that under this scenario, 1,809 revisions are estimated annually to update existing 

operating permits due to modification activities. Utilizing a 75,000 tpy PSD significance level, 

the annual permitting authority burden is estimated to increase by 161,000 hours at a cost of $7.4 

million. At this significance level, 915 operating permit revisions will be necessary due to GHG. 

This decrease from the previous scenario is due to fewer modifications exceeding the higher 

significance level threshold and requiring revisions to an operating permit. At a 100,000 tpy

threshold, with a 100,000 tpy PSD significance level for modifications, EPA estimates there are 
29

only 20 permit revisions annually. Permitting authorities will spend an estimated 106,000 

additional hours on permits at a cost of $4.9 million.

The final scenario involves only sources that are required to get a title V permit for 

emissions other than GHG and that are required to add GHG related requirements. Under this 

scenario, only the annual issuance of 50 permits noted in the Title V ICR are expected to need 

the inclusion of GHG related requirements to the permits. The additional burden to permitting 

authorities under this scenario is estimated at 27 million hours at a cost of $1.3 million.

4. Burden Relief Estimates for Permitting Authorities and Sources at Several Possible 

GHG Major Source Applicability Thresholds for Title V and PSD

The following tables indicate the estimated burden relief when comparing the baseline 

levels with several threshold levels for GHG applicability as described in the previous sections. 

In Tables 4-1 through 4-4, the first three columns indicate the cost per permit and total cost to 

permitting authorities at a GHG threshold level equal to the statutory threshold levels for title V 

and PSD (100 and 100/250 tpy, respectively). The next three columns reflect the estimated costs 

for permitting authorities with the permitting thresholds (both for PSD and title V) set at the 

specified levels. In the final three columns, the burden relief is estimated – the time and costs 

alleviated relative to the baseline levels by establishing several GHG permitting thresholds as 

previously described.

The burden relief for sources at the different permitting thresholds is presented in Tables 

4-5, 4-6, and 4-7 below. Table 4-8 estimates the cost savings if a non-GHG based related trigger 

is used. This information on burden relief was used to compile the final Regulatory Impact 

Analysis (RIA) for the final GHG tailoring rule. Please see the final RIA contained in the public 
30

docket for this GHG tailoring rule for a full explanation and description of the burden relief

provided by the final GHG tailoring rule actions. 
31

Table 4-1. Estimated Burden Relief for Permitting Authorities Utilizing a 25,000 tpy Major/ 25,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 25,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,688 2,103 $41,403,864 $19,688 69,726 $1,372,772,051

Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978 0 $0

New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,844 444 $4,370,736 $9,844 1,985,504 $19,545,301,376

Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 9,197 $16,922,480 $1,840 52,639 $96,855,760

Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184 0 $0

Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414 0 $0

Total Permits Affected 2,122,725 14,856 2,107,869

PSD Permits

New Industrial $23,243 26,089 $606,386,627 $23,243 9,197 $213,765,871 $23,243 16,892 $392,620,756

New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 63 $1,021,608 $16,216 55,446 $899,112,336

Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861 0 $0

Total Permits Affected 82,286 9,948 72,338

Total Permitting Authority Costs $22,588,066,734 $281,404,455 $22,306,662,279
32

Table 4-2. Estimated Burden Relief for Permitting Authorities Utilizing a 50,000 tpy Major/50,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 50,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,688 981 $19,313,928 $19,688 70,848 $1,394,861,987

Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978 0 $0

New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,844 208 $2,047,552 $9,844 1,985,740 $19,547,624,560

Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 1,906 $3,507,040 $1,840 59,930 $110,271,200

Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184 0 $0

Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414 0 $0

Total Permits Affected 2,122,725 6,207 2,116,518

PSD Permits

New Industrial $23,243 26,089 $606,386,627 $23,243 1,906 $44,301,158 $23,243 24,183 $562,085,469

New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 28 $454,048 $16,216 55,481 $899,679,896

Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861 0 $0

Total Permits Affected 82,286 2,622 79,664

Total Permitting Authority Costs $22,588,066,734 $73,543,622 $22,514,523,112
33

Table 4-3. Estimated Burden Relief for Permitting Authorities Utilizing a 100,000 tpy Major/75,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 100,000 tpy; 75,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,688 172 $3,386,336 $19,688 71,657 $1,410,789,579

Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978 0 $0

New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,844 18 $177,192 $9,844 1,985,930 $19,549,494,920

Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 915 $1,683,600 $1,840 60,921 $112,094,640

Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184 0 $0

Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414 0 $0

Total Permits Affected 2,122,725 4,217 2,118,508

PSD Permits

New Industrial $23,243 26,089 $606,386,627 $23,243 915 $21,267,345 $23,243 25,174 $585,119,282

New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 4 $64,864 $16,216 55,505 $900,069,080

Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861 0 $0

Total Permits Affected 82,286 1,607 80,679

Total Permitting Authority Costs $22,588,066,734 $30,499,233 $22,557,567,501
34

Table 4-4. Estimated Burden Relief for Permitting Authorities Utilizing a Non-GHG Trigger

All Title V 100tpy and PSD 250 tpy Non-GHG Trigger Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,688 0 $0 $19,688 71,829 $1,414,175,915

Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978 0 $0

New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,844 0 $0 $9,844 1,985,948 $19,549,672,112

Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 0 $0 $1,840 61,836 $113,778,240

Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184 0 $0

Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414 0 $0

Total Permits Affected 2,122,725 3,112 2,119,613

PSD Permits

New Industrial $23,243 26,089 $606,386,627 $23,243 0 $0 $23,243 26,089 $606,386,627

New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 0 $0 $16,216 55,509 $900,133,944

Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861 0 $0

Total Permits Affected 82,286 688 81,598

Total Permitting Authority Costs $22,588,066,734 $3,919,896 $22,584,146,838
35

Table 4-5. Estimated Burden Relief for Sources Utilizing a 25,000 tpy Major/25,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 25,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 2,103 $97,474,050 $46,350 69,726 $3,231,815,550

Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440 0 $0

New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 444 $10,289,700 $23,175 1,985,504 $46,014,055,200

Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 9,197 $15,423,369 $1,677 52,639 $88,275,603

Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156 0 $0

Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780 0 $0

Total Permits Affected 2,122,725 14,856 2,107,869

PSD Permits

New Industrial $84,530 26,089 $2,205,303,170 $84,530 9,197 $777,422,410 $84,530 16,892 $1,427,880,760

New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 63 $3,726,576 $59,152 55,446 $3,279,741,792

Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669 0 $0

Total Permits Affected 82,286 9,948 72,338

Total Source Costs $54,963,344,090 $921,575,185 $54,041,768,905
36

Table 4-6. Estimated Burden Relief for Sources Utilizing a 50,000 tpy Major/50,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 50,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 981 $45,469,350 $46,350 70,848 $3,283,820,250

Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440 0 $0

New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 208 $4,820,400 $23,175 1,985,740 $46,019,524,500

Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 1,906 $3,196,362 $1,677 59,930 $100,502,610

Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156 0 $0

Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780 0 $0

Total Permits Affected 2,122,725 6,207 2,116,518

PSD Permits

New Industrial $84,530 26,089 $2,205,303,170 $84,530 1,906 $161,114,180 $84,530 24,183 $2,044,188,990

New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 28 $1,656,256 $59,152 55,481 $3,281,812,112

Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669 0 $0

Total Permits Affected 82,286 2,622 79,664

Total Source Costs $54,963,344,090 $233,495,628 $54,729,848,462
37

Table 4-7. Estimated Burden Relief for Sources Utilizing a 100,000 tpy Major/75,000 tpy PSD Significance Threshold

All Title V 100tpy and PSD 250 tpy 100,000 tpy; 75,000 tpy or Greater Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 172 $7,972,200 $46,350 71,657 $3,321,317,400

Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440 0 $0

New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 18 $417,150 $23,175 1,985,930 $46,023,927,750

Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 915 $1,534,455 $1,677 60,921 $102,164,517

Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156 0 $0

Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780 0 $0

Total Permits Affected 2,122,725 4,217 2,118,508

PSD Permits

New Industrial $84,530 26,089 $2,205,303,170 $84,530 915 $77,344,950 $84,530 25,174 $2,127,958,220

New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 4 $236,608 $59,152 55,505 $3,283,231,760

Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669 0 $0

Total Permits Affected 82,286 1,607 80,679

Total Source Costs $54,963,344,090 $104,744,443 $54,858,599,647
38

Table 4-8. Estimated Burden Relief for Sources Utilizing a Non-GHG Trigger

All Title V 100tpy and PSD 250 tpy Non-GHG Trigger Avoided Burden

Activity

Cost per 

Permit 

(2007$)

Number 

of Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Cost 

per 

Permit 

(2007$)

Number 

of 

Permits

Total Cost 

(2007$)

Title V Permits

New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 0 $0 $46,350 71,829 $3,329,289,600

Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440 0 $0

New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 0 $0 $23,175 1,985,948 $46,024,344,900

Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 0 $0 $1,677 61,836 $103,698,972

Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156 0 $0

Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780 0 $0

Total Permits Affected 2,122,725 3,112 2,119,613

PSD Permits

New Industrial $84,530 26,089 $2,205,303,170 $84,530 0 $0 $84,530 26,089 $2,205,303,170

New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 0 $0 $59,152 55,509 $3,283,468,368

Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669 0 $0

Total Permits Affected 82,286 688 81,598

Total Source Costs $54,963,344,090 $17,239,080 $54,946,105,010
39

APPENDIX A

Table A-1. Newly Major Affected Source Estimates Based on Threshold Level

Source Type 100/250 tpy PSD 100 tpy Title V 25,000 tpy 50,000 tpy 100,000 tpy

EGUs 285 285 124 0 0

Industrial 141,160 170,910 4,002 1,934 256

Oil/Gas/Coal production 2,588 2,588 187 75 52

Waste Treatment 3,344 3,358 1,927 910 193

Commercial 731,477 1,355,921 1,161 600 51

Residential 182,350 4,535,500 160 20 0

Total 1,061,204 6,068,562 7,561 3,539 552

Based on information contained in the “Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air

Quality Policy and Standards; March 29, 2010 and information retrieved from EPA's enforcement and compliance history online (ECHO) 

database during January 2010. ECHO is a computer-data based created and maintained by the EPA that contains source-specific data submitted 

primarily by state and local environmental agencies. See http://www.epa-echo.gov/echo/index.html.