### 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 inclu sion of GHG in the title V and Prevention of Significant Deterioration (PSD) permitting programs at thresholds greater than the current statutory requirements
. A preliminary anal ys is to support the tailoring rule proposal resulted in an earlier version of this Te chnical 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 considere d for the final tailoring rule. The anal ys is was performed considering GHG emissions on a carbon dioxide equivalent (CO 2 

### e) basis , which represents the sum of the six primary GHG with their respective global warming potentials (GWP) applied. Time and cost s associated with permit activities are derived from existing Information Collection Requests (I CRs) for the title V and PSD programs . Estimates for the number of affected sources used in this analy sis were obtained from the GHG thresholds evaluation , wh ich can be found at EPA
HQ
- 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 “T echnical 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 ty pes 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. Indeveloping our methodology , we establish ed different applicability options under which GHG emission sources would be regulated. These GH G 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 fin ally , 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 ‘any way ’ source approach). We considered several different major source/major modi fication 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 repr esentative points within the range given those time and resource constraints. For example, as it became evident from the anal ys is that the 100,000 tpy CO 2 

### e 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 CO 2 

### major source level to determine the ultimate impact on PSD and title V permitting activity
.

### 3

PSD Permits Table 2
- 1 summarizes EPA’s es timate of modifications and new co nstruction 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 ty pe of modification and new construction activity
. Three types of modifications are included in this anal ys is: major modifications at major sources that are triggered b y 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 newl y major GHG sources due solel y to emissions exceeding the significance level threshold for GHG . For new constructio n, two ty pes 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 ‘any way ’ 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 ‘anyw ay ’ source s ; these are labeled in the table as “Current Modifications

– Add Additional GHG” and “Newly Constru cted Major Sources

– Add Additional GHG.” The August 2008 IC R for the New Source Review (NSR) program estimates that 282 PSD and 519 non
- attainment NSR permits are issued annuall y . 3 

### EPA’s initial burden analy sis concentrated solely on the 282 annual PSD a ctions
. 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 Re view (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 Numbe r of PSD Permit Actions Exceeding GHG 4 Threshold 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; 75,00 0 tpy sig. level 100,000 tpy

major; 100,000 tpy sig. level Non GHG 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 43,9 42 250 117 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 CO 2 e. The Non
- GHG option is based on a PSD action bein g 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 CO 2 e.

### 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 accuratel y 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 analy sis, t o more accuratel y depict the number of PSD permitting actions occurring annuall y, it is assumed that all 801 permitting actions above involve a PSD action
. We estimate that 70% of the se 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 propos ed tailo ring rule (who generall y 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 thresh olds and any

of the significance levels we considered, up to an including the 100,000 tp y CO 2 

### e level , thus requiring the inclusion of GHG related requirements in a PSD permit. 6 

### This equates to 448 modifications annually
. We believe that any of the modific ations that would be subject to PSD due to the conventional emissions would also be large enough to increase GHGs b y at least 100,000 tpy of CO 2 

### e. The 240 remaining annual permit actions

—labeled in Table 2
- 1 as “Newl y Constructed Major Source
- Add Addition al GHG”

—are assumed to be construction of new major sources as
5 “NACAA Summary on Permitting GHGs Under the Clean Air Act”; Me morandum 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 th at would emit GHGs. This revie w 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 r un the gamut of industrial activity, from power generators to manufacturing facilities, and many other types.

### 6

determined b y emissions of one or more NAAQS pollutant s . Due to the size and emissions of
sources currently

subject to the PSD permitting program , it is believed all of these newl y constructed major sources will exceed each of the GHG threshold s we considered, including the 100,000 tpy

CO 2 

### e, 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 p ermit
. 7 

### For affected sources, approximately 222 additional burden hours are needed , based on the two lin e items in the current NSR I CR we expect to be impacted b y the addition of GHG

– approximately 120 hours to “obtain guidance on data needs” and 102 hours for the “preparation of BACT anal ysis.” That is, the current NSR I CR indicates that on average, affec ted source s 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 nee ds ” because they

will be analyzing their emissions from GHG units and will need to prepare a separate BACT anal ys is for their GHG emissions, or else expand the BACT anal ys is 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 appreciabl y lengthened b y 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 sy nthetic minor sources, and sy

nthetic
- 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 thereb y obtain a minor permit will now be required to apply for a major PSD permit, depending on the significance threshold set for GHG. These pro jects are identified in Table 2
- 1 under “Minor Modifications Becoming Newl y Major.” Combining the number of sy nthetic
- based modifications (7,459) and netting
- based modification s (14,909) identified in the I CR , approximately

22,368 of these actions could p otentially 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 sy nthetic minors’ because we have already accounted fo r 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 estimate d that 80% of the current minor modification actions likely involve combustion sources

– totaling 17,894 actions of the total 22,368 minor modification actions. 9 

### Some of these actions may trigger the requirements of the PSD program depending on their GHG emission increases and the selected GHG significance threshold
. Inthe 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 analy sis : 50% at 25,000 tpy CO 2 

### e; 10% at 50,000 tpy CO 2 

### e; 5% at 75,000 tpy

CO 2 

### e; and zero at 100,000 tpy CO 2 

### e. To determine these percentages, w e considered the relative emissions of CO 2 

### emissions to NOx emissions at the current major modification significance level threshold for NOx (40 tpy). For example, for an average natural gas combustio n boiler ( a common industrial combustion unit that is part of many modification projects), a 40 tp y NOx emissions would coincide with a 56,000 tpy CO 2 

### e level. Since many combustion related projects keep just under the 40 tpy NOx level to avoid major modification status, we assume that the CO 2 

### e emissions for a sim i lar project will be around the 50,000 tpy CO 2 

### e level. Based on the relationship in combustion
- related emission levels between NOx and CO 2 

### e 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 emiss ions 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. Inthe absence of experience and quantitative information from commenters we made the following assumptions regarding how many of these formerl y minor modification projects would be subject to ma jor PSD review at the different GHG significance level options : at the 25,000 tpy CO 2 

### e significance level, we estimate that half of the modifications will be able to limit their operations to avoid PSD ; at the 50,000 tpy CO 2 

### e significance level, we esti mate that 10% of these previously minor now major modifications will be covered b y PSD ; at the 75,000 tpy CO 2 

### e significance level we estimate that only 5% of these

### 9

currentl y minor modification projects move into a major modification status for GHGs ; and lastly , at the 100,000 tp y CO 2 

### e significance level, we assume that none of these projects will be large enough b y themselves to trigger major PSD review. In addition to sources becoming subject to PSD requirements because of GHG emissions related to modif

ications, n ew 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 evaluatio n , these newly co nstructed major sources involve both industrial and commercial/residential facilities
. 10 

### The current NSR I CR notes that permitting authorities spend approximately 300 hours processing and issuing a new construction industrial source PSD per mit. Sources spend almost 870 hours on average preparing for the same permit. In the previous burden anal ys is, commercial/residential permits were assumed to require onl y 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 estimate s 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 generall y 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 comm enters generally did not provide quantitative information. As a result, we conducted further evaluation of the additional support

10 “T echnical 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.

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and outreach activities for permitting authorities to assist with applicability determinations and emissions calculations , a s 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
. O f the sources fallin g 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 Perm it Type
Activity Burden Hours per Permit - Industrial Burden Hours

per Permit - Commercial/ Residential a 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 Ingeneral, 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/ Residential a 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

aPSD permit applications for commerci al/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/re sidential 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 f

ace 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 “Modifi cations at Newl y 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 newl y major sources at different major source GHG thresholds
. We estimate that 4% of these newl y major sources will undergo modifications. This rate was obtained b y dividing the current 560 annual PSD modification
related permit actions ( i.e., 70% of 801 actions identified in the NSR I CR) by the existing major

### 12

s ource 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 newl y major GHG sources. We recognize that there is some level of uncertainty in applying this rate to GHG
- only sources, particularl y 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 s elect the same 4% rate for modification activity
.
Title V Permits Title V programs also complete several ty pes of permitting actions annually , including processing and issuing new permits, permit revisions, and permit renewals. Newl y constructed major so urces or sources designated newl y major due to a
m odification 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 th e threshold set for GHG emissions. P ermitting 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 generall y 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, generall y on a five
- ye ar cycle, and such renewals would need to assure that the permit properly addresses GHG. The April 2007 T itle V ICR estimates that 50 permits are completed every year for new
sources . 12 

### For this anal ys is, it is assumed that all 50 of these ty picall y large industrial
- ty pe sources will be capable of potentially emitting GHG and will need to add GHG
- related requirements to the permit . The es timated 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 currentl y 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 readil y do. The I CR also identifies 3,267 permit renewals conducted on an annual basis. As not all
sources potentiall y emit GHG above a determined threshold, this analy sis examines the estimated 80% involving combustion activities that most likely have the potential to emit GHG above the series of potential threshold s 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 anal ys is. Revisions occurring specificall y 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 

### Th e

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 T able 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 estimate s that p ermitting 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 solel y to their GHG emissions. These commercial/residential
so urces 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 appli cable requirements in addition to those related to their GHG emissions
. However, upon further evaluation and in response to comments from permitting authorities , EP A believes its initial estimate of one
- tenth of the burden hours required was considered to o 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 permitti ng burdens to obtain a value of 40 hours per permit.

### 15

affected c ommercial/residential sources will take 50% of the time a permitting a uthority currentl y 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/ Residential a Permit Application Review 100 33 Draft Permits Preparation 150 50 Comment Period No tification 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

a Commercial/residential permits will be simpler, so that it would take the permitting authority about 1/3 o f 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 p rovide 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/ Residential a Prepare Application 300 150 Draft Permits Interaction 40 20 Public Hearing Participation 10 10 Total Burden 35 0 180

a Commercial/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 like ly 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 t

py CO 2 

### e emission threshold for baseline anal ys is) , it is necessary to have emissions inventory data at the facility

or building level, including , and particularl y for lower threshold scenarios, numerous small sources in the residential and commercial secto rs (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 CO 2 

### emissions under the Acid Rain Program reporting requirements). To date, national EPA inventories of GHG sources have primaril y focused on ‘top
- down’ estimates of GHG emissions from sectors and sources, and not facility
level 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 anal ys is 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 nationall y aggregated statistics
. The allocation factors we used, based on U.S. Energy Information Administration statistical sampling procedures and energy consumption statistics , are likel y the best available to estimate the population of residential , commercial , and small manufacturing sources exceeding different GHG thresholds. However, uncertainties may result in ei ther overestimating or underestimating GHG emissions

15 “T echnical 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 individ ual 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 leve ls of uncertainty in our facility level estimates across sectors, we do believe that the data are sufficientl y 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 es timates, particularly for the commercial, residential and small manufacturing sectors that have not traditionall y 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 CO 2 

### 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 ye ar - round and heating s ys tems have thermostats. However, for our anal ys is we do assume full PTE
- based estimates for the residential and commercial sectors, using PTE adjustment factors of 10 and 6.6, respectivel y to adjust actual emissions to PTE level. Absent industry specific data, for small manufact uring 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 av erage rate across the variety of small manufacturing facilities included in the threshold anal ys is. Ultimately , the number of sources brought into either the NSR or Title V programs due solel y to their PTE would depend on how EPA interprets PTE for variou s 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 anal ys is uniformly assumes that no PTE limits are in place for any of the aff

ected sectors, which may likel y be the case in the immediate stages of GHG permitting for affected sources. There is significant uncertainty in both our modification rate for newl y 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 onl y how many major sources will undergo phys ical or operational changes in any given ye ar, 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 phys ical 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 ye ar because decisions on these projects are driven b y facility
- and sector
- based growth patterns and business planning decisions. L astl y, some source categories and units that emit GHGs have not previousl y been subject to any typ e 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 C osts The primary

reference sources for our estimate of burden hours and costs for permitting GHGs are the most recent I CRs for the PSD and title V programs. There a number of uncertainties introduced in using these references for costing GHG permitting a ctivities. 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 traditi onal 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 I CRs for PSD and title V programs. There is uncertainty in applying these average ICR
- base d 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 ye ars for conventional pollutant permitting, and thus refle cted 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 I CR for current PSD permits (i.e., that 1 in 50 major PSD permits require a hearing)

—for GHG sources th is 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, especiall y those affected at higher threshold levels, will have had sufficient permitting experience such that out I CR
- based costs should reasonabl y reflect the added burden of including GHGs.

### 20

As mentioned above, in our burden scenario analyses we do discount the ICR
- based per
permit costs for residential and commercial sources to reflect what we believe will generally be simpler permits, involving primarily uniform combustion ty

pe 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 estim ated discounts since we have no track record for permitting these smaller commercial and residential sources. However, we do believe that, based solel y on the ty pe and uniformity of the GHG emission units that would be subject to permitting at these faci lities under lower GHG threshold scenarios, that average per
- permit costs would be less than those currentl y experienced by more complex industrial facilities, with numerous emission units, for currentl y regulated pollutants.

3. Evaluation of ICR- base d 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 CO 2 

### e emission levels

—

referred to as the ‘baseline’ anal ys is in the following tables

— as well as at 10,000 tpy , 25,000 tpy , and 50,000 tp y CO 2 

### e levels. Due to comments received on the proposal and this improved burden anal ys is, the 10,000 tpy threshold was eliminated as not being a viable alternative since it did not adequately address administrative necessity concerns . In this anal ys is, in addition to the baseline anal ys is, EPA broadened the options to consider thresholds ranging from a 25,000 tpy CO 2 

### e major source applicability level for PSD and title V up to a 100,0 00 tpy

CO 2 

### e 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 CO 2 

### e, 75,000 CO 2 

### e, and 10 0,000 CO 2 

### e.

### 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 P ermits 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 c alculated based on listed values obtained from Tables 6
- 1 and 6
- 2 the NSR I CR. The ICR does not distinguish between new construction and modification actions; therefore, Table 3
- 1 combines the actions into permit preparation issuance based solel y on GHG em issions or the addition of GHG requirements to permits being issued for conventional sources, or “anyw ay” 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 determine d the impact of regulating GHG emissions under current PSD statutory thresholds for applicability . B aseline 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/Residentialb 210 55,509 11,656,890 $900,145,046 Addition s to Current PSD Applications c 50 688 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 P SD 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 Ma

jor/ 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 Ma

jor/ 75,000 tpy Significance Threshold PSD Permit Preparation and Issuance
- Industrial 301 915 275,415 $21,267,546 PSD Permit Prepar ation 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 Ma

jor/ 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 T hreshold 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 34,4 00 $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 cost s due to GHG permitting beyond to the burden currentl y experienced b y permitting authorities and sources. The first scenario is the threshold proposed in the GHG Tailoring Rule of 25,000 tpy CO 2 

### e. Results of this analy sis 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 mi llion. 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. In cre asing 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 tp y, 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 b y 311,000 hours at a cost of $24 million. Inthis scenario, 919 new permit actions will occur annually
.

### 24

At a 100,000 t

py threshold, with a 100,000 tpy significance level for modifications, EPA estimate s there are 20 new industrial PSD permit actions and four commercial/residential. Permitting authoriti es will spend an estimated 41,00 0 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 newl y 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 I CR 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 Pe rmitting 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 Permitb 43 50 2,150 $98,900 New Permit Preparation and Issuance
- Commercial/Residential c 214 1,985,948 424,992,872 $19,549,672,112 Permit Revisions
- due to GHG 40 61,836 2,47 3,440 $113,778,240 Permit Revisions
- add GHG to Current Non
- GHG Permits 4 448 1,792 $82,432 Permit Renewals d 9 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 $26,128,767 100,00 0 tpy (associated with PSD 100,000 tpy m aj./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 m aj./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 m aj./ 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 In corporating GHG information/requirements into significant revisions and permit renewals adds an additional 10% of the current time (90 hours each) c New 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 tp y threshold level, which is the generall y applied major source applicability level under title V. At the statutory threshold level, it is estimated that over six million sources will become newl y subject to title V. A source generall y 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
- ye ar time frame based on the statutory requirement s listed above. Therefore, we assume that one
third of the newl y subject sources will appl y 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 $2 1.1 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. Estim ates 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 CO 2 

### e . Results of this analy sis indicate a total of 2,547 n ew 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. In creasing the emission threshold to 50,000 t py will lead to an estimated 568 ,000 hours addi tional 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 CO 2 

### e, 75,000 CO 2 

### e, and 100,000 CO 2 

### e combined with the 100,000 tpy major source level The choi ce 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 Tabl e 3
- 2. Note that for all three scenarios, EPA estimates there are 172 indu strial 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 authori ties wi ll spend an estimated 177 ,000 hours preparing and iss uing 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 autho rity burden is estimated to increase b y 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 sc enario 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 mo difications, EPA estimate s there are

### 29

only 20 permit revisions annually
. Permitting authorities will spend an estimated 106 ,000 additional ho urs 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, onl y the annual issuance of 50 permits noted in the Title V I CR are expected to need the inclusion of GHG related requirements to the permits. The additional burden to permitting autho rities 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 Threshold s for Title V and PSD The following table s 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 c ost to permitting authorities at a GHG threshold level equal to the statutory threshold levels for title V and PSD (100 and 100/250 tpy , respectivel y). The next three columns reflect the estimated costs for permitting authorities with the permitting thresh old s (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

describe d. 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 n on - GHG b ased related trigger is used. This information on burden relief was used to compile the final Regulatory Impact Analy sis (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 b y the final GHG tailoring rule actions.

### 31 Table 4 - 1. Estim ated 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 Per mit (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 $22,30 6,662,279

### 32 Table 4 - 2. Estim ated 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 $19,3 13,928 $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 A ffected 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 $8 99,679,896 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. Estim ated 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$) Nu mber

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 $3,386,33 6 $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. Estim ated 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 Pe rmits 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 Revisio ns - 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 $2 3,243 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. Estim ated 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 1,985,94 8 $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 $1,427,88 0,760 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 9,9 48 72,338 Total Source Costs $54,963,344,090 $921,575,185 $54,041,768,905

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

All Title V 100tpy and PSD 250 tpy 50,0 00 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 $7 80 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/Res idential $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 Sour ce Costs $54,963,344,090 $233,495,628 $54,729,848,462

### 37 Table 4 - 7. Estim ated 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 o r 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
- D ue 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 $2,03 8,920 $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. Estim ated 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 $14,908,2 72 $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 A ffected Source Estimates Based on T hreshold 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 Wa ste Treatment 3,344 3,358 1,927 910 193 Comm ercial 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.