San Joaquin Valley d AIR POLLUTION CONTROL DISTRICT 

GOVERNING BOAR0 

Leroy Ornellas, Chair 

Supervisor, San Joaquin County 

DATE : December 18,2008 

Chris Vierra, Vice Chair TO: SJVUAPCD Governing Board 

Councilmember, City of Ceres 

Tony Barba FROM: Seyed Sad redin, Executive ~irector1~~~0 

Supervisor, Kings County Project Coordinator: Scott Nester 

Judith G. Case 

Supervisor, Fresno County RE: ECONOMIC FEASIBILITY ANALYSIS AND RELATED 

Ronn Oominici CONSIDERATIONS FOR NEW REGULATIONS 

Supervisor, Madera County 

Henry Jay Forman, Ph.0. 

Appointed by Governor RECOMMENDATION: 

Michael G. Nelson 

Supervisor, Merced County Consider the staff report detailing the methodologies used by the 

District to assess economic feasibility of new regulations and provide 

William O'Brien 

Supervisor, Stanislaus County guidance on any changes deemed necessary for future regulations. 

Henry T. Perea 

Councilmember, City of Fresno 

John 6. Telles, M.O. 

Appointedby Governor 

Raymond A. Watson 

Supervisor, Kern County 

J. Steven Worthley 

Supervisor, Tulare County 

vacant. 

Large City 

Vacant 

Small City, Central Region 

Vacant 

Small City. Southern Region 

Seyed Sadredin 

Executive Director 

Air Pollution Control Officer 

Northern Region Office 

4800 Enterprise Way 

M~desto, CA 95356-8718 

(209) 557.6400 FAX (2091 557.6475 

Central Region Office 

1990 East Gettysburg Avenue 

Fresno, CA 93726-0244 

(559) 230-6000 * FAX (559) 230-6061 

Southern Region Office 

2700 M Street Suite 275 

Bakersfield, CA 93301-2373 

.(661) 326-6900 FAX (661) 326-6985 

BACKGROUND: 

The degree of difficulty and the enormity of the challenge that the San 

Joaquin Valley faces in meeting the federal ambient air quality 

standards are unmatched by any other region in the nation. The 

Valley's challenging geography and meteorology combined with the 

ever-increasing difficulty in meeting the new federal ambient air quality 

standards have demanded the imposition of some of the toughest air 

pollution control measures in the San Joaquin Valley. 

While the District staff always endeavors to find the most costeffective measures that accomplish the goals established by your 

Board, new regulations continue to come at increasing cost to Valley - 

businesses. Most stationary sources in the Valley have already been 

subject to several generations of rules and regulations and have made 

great investments in reducing air pollution. 

On October 16, 2008, your Board after adopting several regulations - 

with broad applicability and great cost to affected sources, asked for a 

detailed report on the economic feasibility analysis which is conducted 

by the District in devising new regulations in order to determine if any 

adjustments might be necessary. This report describes the 

comprehensive process utilized by District staff to provide the Board 

and the public with the most accurate economic information possible 

including the manner by which those concerns affect the formulation 

of new regulations. 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

DISCUSSION: 

As a public health agency, with a mission to "improve the health and quality of life for all 

Valley residents through efficient, effective and entrepreneurial air qiality-management 

strategies," the District makes every effort, using a fair and consistent methodology, to 

analyze and report the socioeconon-~ic irr~pacts of changes to regulations. 

Given the fiscal realities of achieving cleaner air in the San Joaquin Valley, and realizing 

that a strong economy gncJ healthy air are vital to the success of the region, the District 

makes every effort to complete accurate and useful cost effectiveness and 

socioeconomic analyses on new or amended rules that reduce emissions. Working with 

all stakeholders, we always exercise utmost innovation and creativity to devise cutting 

edge measures that effectively reduce err~issions in a cost-effective fashion. 

In addition to maintaining a high level of transparency in the rule development process, 

our analysis, which includes estimations of costs and cost effectiveness, serve as a 

major guiding factor in constructing reasonable control requirements in proposed 

regulations. The following discussion details all factors and all considerations that play 

a role in crafting regulations that are developed and adopted by the District. 

A. Legal Mandates for Rulemaking 

District rulemaking is not an arbitrary process. The Federal Clean Air Act (CAA) 

requires that EPA set health-based national ambient air quality standards (NAAQS). 

Areas that violate such standards are in non-attainment of the NAAQS and must subrrlit 

an attainment plan to €PA detailing the strategy by which the area will control emissions 

to the point that the area is in attainment of the NAAQS. Section 172(c)(l) of the CAA 

requires such attainment plans to "provide for the implementation of all reasonably 

available control measures as expeditiously as practicable ..." including emission 

reductions from existing sources following Reasonably Available Control Technology 

(RACT) requirements in order to "reach national primary ambient air quality standards." 

The cor~trol strategy indentified in the attainment plan contains specific control 

measures to reduce emissions. When such plans are adopted, the District is 

responsible for obtaining the total emissions reductions commitment in the plan. 

Additionally, areas in non-attainment must demonstrate Reasonable Further Progress 

(RFP) is being made toward meeting VOC and NOx emission reductions as specified in 

the CAA. Individual control measures typically result in new rules or amendments to 

current rules. When all of the control measures identified in the plan have been 

implemented, the area sho~lld be in attainment of the NAAQS. 

The State of California has its own version of the Clean Air Act, which mandates that 

individual air districts also meet state standards in addition to any federal requirements. 

Any new rules or amendments to current rules must require that existing emission 

sources meet "best available retrofit control technology1' (BARCT). Each state nonattainment area must also incorporate "all feasible measures" to control sources. The 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

California Air Resources Board (ARB) interprets "every feasible measure" to mean that, 

"at a minimum, a district considers regulations that have been successfully implemented 

elsewhere. They should also consider going beyond what has already been 

accomplished by evaluating new technologies and ir~novative approaches that may offer 

potential emission reductions. Further, districts should consider not only technological 

factors, but also social, environment, economic (e.g., cost effectiveness), and energy 

factors which prevail in the district, along with the resources realistically available to the 

district to adopt, implement, and enforce the measures." 

Despite the fact that the San Joaquin Valley has a lower eniission density than other 

areas in the state, because of the geographic and meteorological challenges, significant 

emission reductions are still needed to meet the state and federal health-based 

standards. Computer models are used to estimate the reductions needed to meet the 

state and federal standards. The models suggest that the San Joaquin Valley needs 

oxides of nitrogen (NOx) emissions to be no higher than about 160 tons per day to meet 

the 1997 8-hour ozone standard. In 2005, Valley NOx err~issions were approximately 

624 tons per day; attainment of the ozone standard requires a Valley-wide reduction of 

approximately 75% from the 2005 level. Particulate matter (PM) and reactive gases 

(VOC) also need to be reduced significantly in order for the Valley to reach attainment 

of all health-based standards. 

The District, therefore, must satisfy all applicable state and federal mandates in District 

rules. Within this legal framework, District staff manages the development, 

implementation, and enforcement of emission control measures, including the analyses 

used to determine if such actions are cost effective in light of health considerations. 

B. Economic Feasibility of Emissions Reductions 

I. Cost Effectiveness Analysis 

Pursuant to the California Health and Safety Code (CH&SC), the District is required to 

analyze the cost effectiveness of new or amended rules implementing Best Available 

Retrofit Control Technology (BARCT). District staff follow an exhaustive and 

standardized methodology to prepare a cost effectiveness analysis of emission 

reductions and the estimated costs incurred .by industry in order to comply with rule 

provisions. The cost effectiveness of a control option is the added cost, in dollars per 

year, of the control technology or technique, divided by the emissions reductions 

:achieved, in tons per year. 

Compliance Cost 

Cost Eflectiveness ( tons ) Emissions Reductions - 
SJVUA PCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

Cost effectiveness by itself does not reveal business impacts for a specific business or 

industry; it serves only to evaluate the costs of obtaining specific emission reductions. 

The standardization of the methodology allows not only for the comparative analyses of 

different rule changes across different industry sectors, but also comparisons over time 

of progressive emissions reductions for a specific rule or industry sector. 

Estimating compliance costs of a potential rule or rule amendment is no trivial task. 

Once an emission limit is proposed, staff must make reasoned judgments, with input 

from affected industry, as to the likely equipment or process changes that would be 

necessary to meet the proposed emission limit. 

Once one or more likely control technologies are identified, District staff gather cost 

information for the control equipment. The accuracy of a cost estimate can vary greatly 

depending on the source of the information and variability of equipment within the 

industry being regulated. ~stimates obtained by staff can have as much as a 230% 

level of accuracy for a single source. Occasionally, staff is able to obtain more accurate 

cost estimates from equipment vendors or operators, but this becomes difficult where 

the technical specifications of a system are unknown, or if such costs are considered 

proprietary by operators. Many of the stringent emission controls specified by new 

District rules have not been widely implemented, so well-documented costs are 

becoming increasingly rare. 

-The initial capital expenditure for air pollution controls can be significant. As a general 

business accounting practice, operators amortize over the expected life of the 

equipment for accounting and tax purposes. In a similar manner, the cost effectiveness 

calculation used by the District and other pollution control agencies is based on 

annualized costs; such capital expenditures are figlrred into the compliance cost based 

on a similar annualization methodology. In an effort to standardize the analysis for rules 

that affect many units, District staff routinely calculate the annual costs based on a 10 

percent interest rate and 10-year project life. While the actual finance charge incurred 

by an operator for such a large capital expenditure is rarely as high as. 10 percent, the 

District uses these values to standardize the calculation so that comparisons can be 

made across industries and over time. While the standardization is good for analytical 

reasons, the generalized costs may not be a completely accurate representation of the 

final true cost incurred by the industry; in many cases the tnre cost of rules to industry 

are much less than the District estimates. -The table in Attachment A demonstrates the 

use of cost effectiveness to compare the impact of rule changes over time. 

2. Socioeconomic Analysis 

In order to further analyze the economic impact of a rule on industry, the total costs, 

cost-effectiveness and other data specific to the rule are provided to an independent 

economist for analysis. -The California Health & Safety Code, Section 40728.5 requires 

District staff to analyze the socioeconomic impacts of any proposed rule or rule 

aniendment that significantly affects air quality or strengthens an emission limitation. 

Per the CH&SC, District staff will evaluate the following indicators relative to the 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

proposed rule or regulation: the type of industry affected, including small business; the 

impact of the rule on errlploynient and the regional economy; the range of probable 

costs to industry andlor small business; the availability and cost-effectiveness of 

alternative controls; the emission reduction potential; and the necessity of adopting, 

amending or repealing the rule to attain state and federal ambient air standards. Based 

in part on the socioeconomic analysis, the Governing Board has the ultimate 

responsibility and authority to make decisions regarding the balance between air quality 

improvement, public health, and economic impact. 

The District retains an independent economic consultant to evaluate the socioeconomic 

impact for Rule Development projects. District staff supply the consultant with 

estimated compliance costs, lists of the affected businesses, and the general industrial 

classifications of the affected businesses. The consultant, using generally accepted 

economic analytical methodologies, gathers information about the specific businesses 

and the general economy. The information includes the number of employees, total 

payroll costs, total revenue or sales, and the pre-tax profit margin as a percent of total 

revenue or sales. 

The consultant relies on a variety of information sources, incll~ding the: 2002 Economic 

Census; US Bureau of Census' Annual Survey of Manufacturers; Minnesota IMPLAN ' 

Group; and the State of California's Employment Development Department (EDD) 

Labor Market Information Division. For profits estimations, the consultant relies on: 

Dun and Bradstreet; the US Internal Revenue Service; and corporate annual reports of 

applicable companies. The consultant may be able to obtain information from local 

operators regarding their particular finances; however, these instances are rare given 

that such information may be considered proprietary, exposing operating information to 

competitors. 

With the above information, the consultant estimates net after tax profit ratios for 

sources affected by the proposed regulations. The consultant calci~lates ratios of profit 

per dollar of revenue for affected industries. The result of the socioeconomic analysis 

shows what proportion of profits the compliance costs represent. Based on assumed ' 

thresholds of significance, the consultant reports whether the affected sources are likely 

to reduce jobs or reduce business operations to accommodate the cost of rule 

compliance. 

-The compliance costs in dollars per year for the rule project are compared to the 

estimated annual pretax profit calculated by the consultant. If the ratio of the 

compliance cost to the pretax profit is less than lo%, the impact is deemed to be less 

than significant and no fl-~rther economic analysis is done. If the ratio is 10% or greater, 

the impact is deemed to be "significant" and further analysis is required. In such cases, 

the IMPLAN' economic model is used to estimate the number of indirect and induced 

1 IMPLAN (IMpact analysis for PLANning) is a classic input-output analysis software package developed by 

Minnesota IMPLAN Group, Inc. The program utilizes regional-specific Social ~ccounting~atrices and Multiplier 

5 
SJVUAPCD Governing Board 

ECONOMIC FEASlBlLlNANALYSlS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

job losses in addition to the direct job losses from the subject sources. Indirect jobs are 

those typically associated with s~~ppliers to the affected industry. If the sources affected 

by the rule reduce their orders for raw materials because they are not producing as 

much, the supplier may have to trim its workforce to reflect the lower demand for its 

products. To the extent possible, District staff work to minimize significant economic 

impacts by adjusting proposed emission limits or extending proposed conipliance 

schedules. It is the role of the Governing Board to ultimately determine the balance 

between air quality improvement and economic impact. 

3. Application of Cost Effectiveness and Socioeconomic Impact Analyses 

As a stand-alone analysis, cost effectiveness does not reveal the full impact of a lower 

emission limit on an affected industry. Cost effectiveness is a valuable comparison tool; 

however, it is the socioeconomic impact analysis that provides the means to balance 

cleaner air and the regional economy during the rulemaking process. However, there is 

a caveat -- the balance attained for an individual rule or industry, especially if the 

balance tips toward with lesser regulation, needs to be considered within the larger 

spectrum of District attainment. If emission reductions are relaxed for one rule or 

industry, those reductions must be made up in other rules or industries in order to reach 

attainment within the attainment plan timeframe. . 

During the analysis phase of the rulemaking process, staff utilizes the socioeconomic 

impact analysis to determine if the corrlpliance costs are "reasonable" in light of a 

source category or industry-wide net profit. Industries with a high profit margin are 

better able to withstand the fiscal impact of reduced emissions than industries with a 

lower profit margin. -The socioeconomic impact analysis is also able to break out 

relafive fiscal impacts to large versus small operators. Where the cost effectiveness 

analysis would show the "simple" costs of dollars per ton for a given pollutant, the 

socioeconorr~ic impact analysis puts the costs into a realistic perspective for an entire 

industry or source category. Heavy f scal impacts to industries with low to no profit 

margin may require job cuts or decreases in service if forced to comply with proposed . rules. In these cases, District staff can make adjustments to the stringency or timing of 

the proposed rule to help balance the need for emission reductions with the costs to 

operators for implementing the reductions. 

An example of such an instance was during the recent process to amend Rule 4354 

(Glass Melting Furnaces). The February 2008 draft version of the rule proposed a NOx 

limit for container glass furnaces that was the lowest achieved by a single furnace. 

Under the rule, prior to amendment, operators of container glass furnaces were allowed 

to average emissions across multiple furnaces to meet the NOx limit. In an attempt to 

reduce costs, operators connected multiple furnaces to a single add-on control device. 

During the adoption phase of the proposed rule, operators stated that if the February 

Models for highly accurate and adaptable models to estimate the effects of a proposed change in a specific economic 

region. The IMPLAN database contains county, state, zip code, and federal economic statistics that are specialized 

by region, not estimated from national averages. pikipedia, 2008) 

6 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18, 2008 

2008 NOx limits were adopted, they would be forced to install individual controls for 

each furnace. An independent economic consultant calculated the costs for the 

additional systems and determined that container glass manufacturers would be 

severely impacted and would most likely be forced to shut down their operations. 

District staff made several changes to the proposed rule, including adjusting the 

proposed SOX limit to accommodate glass recycling, adjusting the NOx limit to allow for 

less expensive controls, and delaying the compliance date for NOx emission reductions 

by 2 to 3 years. The ultimate NOx reduction for container glass furnaces was 

approximately 92% of the reduction in the February draft. The rule was adopted in 

October 2008 reflecting the changes made in light of the socioeconomic impact 

analysis, 

While it is easier and more efficient to modify proposed rules as a result of the 

socioeconomic impact .analysis prior to final adoption, there are times when specific 

problems with implementation are not realized until after adoption. When amendments 

to Rule 4306 (Boilers, Steam Generators, and Process Heaters > 5 MMBtuIhr) were 

adopted in 2005, there were NOx emission limits for load-following units that were 

problematic for food processors to meet. Staff worked with operators to find 

alternatives, presented revisions to the Governing Board and a subsequent amendment 

was adopted in 2006. The rule revision allowed an 18-month compliance delay for 

three out of nine source categories in return for 0.1 tons per day additional NOx 

emission reductions than the original rule. 

Despite serious efforts to evaluate the socioeconomic impact of emissions reductions 

and not excessively burden any one industry, there are instances when the District, by 

law, must adopt rule amendments without regard to cost or economic impact. From 

time to time, EPA issues Control ~echni~ues Guidelines (CTGs), which are documents 

outlining emission limits and work practices that must be adopted by the District. The 

District has one year after the issuance of the CTGs to enact the limits within the 

document. The Governing Board recently approved two such rule projects. Rule 4603 

(Metal Parts and Products Coating Operations) and Rule 4606 (Wood Products Coating 

Operations) were amended to reflect new CTGs and were approved by the District 

Governing Board at its October 2008 meeting. 

The State of California also occasionally requires rule changes regardless of cost or 

economic impact. When the California Air Resources Board (ARB) adopts an air toxics 

control measure (ATCM), state law provides that individual air districts must revise their 

rules to reflect the ATCM within 120 days. A recent ATCM for chromium plating was 

adopted by the District Governing Board in January 2008 

C. Historical Perspective of Rule Impacts 

Every Valley industry has been affected financially and has stepped up to the plate, 

investing significant capital and increasing operating costs in order to assist the Valley 

in reaching attainment. The District has adopted a number of new rules or rule 

amendments with the goal of reducing emissions to make Valley air cleaner and 

7 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONS FOR NEW REGULATIONS 

December 18,2008 

healthier. The table in Attachment A lists such rule charrges and identifies costs, cost 

effectiveness, and emission reductions, by industry, for all rule projects that were 

adopted as part of District commitments identified in attainment plans. Rules that were 

amended for administrative changes or to implement RACT have not been included. 

The table in Attachment B identifies similar information as Attachment A, but the data is 

grouped by rule number rather than by industry. Within each industry, the rules are 

arranged by date of amendment. As can be seen in these two tables, every industry in 

the Valley has been affected by the rules and regulations adopted as part of District 

attainment plans, and many of the industries have been affected more than once 

Generally, sources and industries are affected by the rule development process in two 

main ways: the applicability is broadened or the emission limit is lowered. The 

applicability of the rule can be increased in scope so that previously unregulated 

sources are included in the rule, which happened with Rule 470114702 (Internal 

Combustion Engines). Each time the rule was amended, more types of engines were 

included within the rule applicability. Alternatively, sources can be affected by 

progressively lower limits on the same units. Rule 4703 (Stationary Gas Turbines) 

follows this model -the number of turbines subject to the rule has not appreciably 

increased, yet the emission limits for these units decreased. Generally, refinements of 

rules include both strategies -the applicability is broadened and the emission limits are 

lowered for a given source or group of sources. 

D. What Lies Ahead? 

The challenges that face the District with regard to emissions reductions are great, but 

not insurmountable. In order to reach attainment of the Federal 8-hour ozone standard, 

the District must continue to refine the existing emission control r1.1les and regulations, 

provide emission reduction incentives and develop innovative emissions reduction 

programs. The District is focused on feasible measures that will achieve the most 

reductions; control measures expected to yield the greatest health benefit will be 

undertaken first. In scheduling rule development projects, the District is giving priority to 

controls that reduce NOx, which are those reductions that are most beneficial in 

reducing both PM2.5 and ozone in the San Joaquin Valley. 

The District demonstrates its commitment to emissions reductions in the form of 

attainment plans, specifically the 2007 Ozone Plan and the 2008 PM2.5 Plan. These 

plans identify control measures for further emissions reductions, which are to be 

developed and implemented by 2010. The total remaining emission reductions from 

rules to be adopted between November 2008 and the December 2010 will result in 2014 

emission reductions of 4.0 tons per day of NOx, 21 tons per day of VOC, and 5.7 tons 

per day of PM2.5. The bulk of the reductions for the major pollutant types will be 

attained from revisions to two rules: 2007 and 2010 refinements to Rule 4103 (Open 

Burning) is expected to result in a con~bined total of 2.4 tons per day of NOx reductions; 

Rule 4570 (Confined Animal Facilities) is expected to reduce nearly all VOC emissions 

and half of the PM2.5 emissions sought in the District attainment plans. 
SJVUAPCD Governing Board 

ECONOMIC FEASIBILI7YANALYSlS AND RELATED CONSIDERATIONS FOR NEWREGULATIONS 

December 18, 2008 

Despite significant emission reductions being achieved through District attainment 

plans, the total identified reductions are not enough to fully meet Federal arr~bient 

standards for NOx; in fact there remains a substantial "attainment gap" of 82 tons per 

day by 2023, which is documented in the 2007 Ozone Plan. For areas classified as 

extreme non-attainment, such as the Valley, those future emission, or "Black Box" 

reductions can be assigned to future technologies and not specifically identified at the 

time that the plan is developed and submitted to EPA. In accordance with federal Clean 

Air Act requirements, the District corr~mits to identifying such contingent measures no 

later than three years before implementation of the new technologies needed to provide 

the Black Box reductions. 

Future plan development is an ongoing process. Since the Valley is classified as 

extreme non-attainment, both the 2007 Ozone Plan and the 2008 PM2.5 Plan require 

mid-course review, or revisions, every three years until attainment is reached; the 2007 

Ozone Plan and 2008 PM2.5 Plans require mid-course review in 201 0 and 201 1, 

respectively. Additionally, the EPA continues to issue new standards, for which 

attainment plans are required. The District is already scheduled to commence with two 

of these plans: a 2012 PM2.5 Plan for the 2006 NAAQS; and a 201 3 Ozone Plan for the 

2008 NAAQS. Between required mid-course reviews, new major plans, and 

unanticipated EPA standards changes, the District expects to produce a new plan or 

major revision starting in 201 0 until 201 3. 

Although modeling demonstrated that the entire San Joaquin Valley would reach 

attainment of the 1997 PM2.5 NAAQS by 2014, the Valley needs errrission reductions 

above and beyond attainment levels in order to demonstrate attainment of the 2008 

Federal 8-ho~.rr ozone standard and 2006 PM2.5 standard. Additional work on source 

categories will continue through the development of feasibility studies, which will provide 

the backgroundmeeded in determining what sol.rrce categories might be viable control 

measures for additional reductions. These studies are in addition to the specific control 

measures identified in the attainment plans. In such cases, demonstration of significant 

emission reductions could initiate the development of a new rule or rule amendment. 

The iterative rule and plan amendment process, along with continual efforts to provide 

emission reduction incentives and develop innovative emissions reduction programs, 

are the tools that are utilized by the District in its rrrission to irr~prove the air quality in the 

San Joaquin Valley. 

Attachments: 

A. Table I - lmpacts of Emission Control Rules BY INDUSTRY. (3 pages) 

B. Table 2 - lmpacts of Emission Control Rules BY RULE. (3 pages) 
Table 1 - Impacts of Emission Control Rules BY INDUSTRY 

Glass Furnaces 

'Advanced Emission Reduction Options (AERO) imRule 4320 

effectively limit costs to less than $20,000 per ton reduced. 

1 Table 1 - Impacts of Emission Control Rules BY INDUSTRY 
Table 1 - lmpacts of Emission Control Rules BY INDUSTRY I I I I I I I I 

Compliance Emission Total Annual Cost Cost Effectiveness 

-Rule Name 1 RULE. ( Pollutant 1 I ,. 1 reduction / Range I range 

(tonsldafl (million $lyr) ($/ton) 

-- 

Conservation Management Practices 4550 PM 2004 2004 34.0 $26.1' $3.400 

Open Buming 4103 PM 2005 2005-201 0 0.2 $0 to $68 per acre Not BARCT 

Confined Animal Facilities 4570 VOC 2006 2006 15.8 $26.0 $3 to $4,800 per 

Open Burning 4103 I PM 1 2007 1 2007-2015 1 2.5 1 $0 to $350 per acre I Not BARCT 

Biosolids. Manure. and Litter I 4565 I VOC 1 2007 1 2608-2012 1 3.9 1 584 to $294 1 89.800-$870.000 

- - 

Boilers > 5 MMBtulhr 1 43051430614320 1 NOx 1 1993 ( 1995-1997 1 18.2 1 $3.0 to$177-1 $460 to$2,700 

Boilers > 5 MMBtulhr 1 43051430614320 1 NOx 1 1996 1 1996 1 0 7 1 94 2 to 95 1 I L16 400 to S70 000 

I Boilers > 5 MMBtulhr 1 43051430614320 1 NOx ( 2008 1 2008 1 3.3 ( $67.7to $177.0 \$56,200 to $147,600' 

Coating of Aerospace Parts 4605 VOC 1996 1996 0.020 $0 $0 

Graphic Arts 4607 VOC 1997 1998 08 , $0 $0 

Adhesives . 4653 VOC 2000 2001 not stated not BARCT not BARCT 

Solvent Cleaning - 46xx VOC 2001 2001-2005 9.2 $8.0 $2.400 

Glass Coating 4610 I VOC 1 2002 1 2004 1 0.2 I $0.06 to $0.16 I $1,050 to $2,900 

Can and Coil Coating 4604 ( VOC 1 2004 1 2006 1 0.4 I $0.34 to $0.39 1 $2,270 to $2,670 

I Boilers > 5 MMBtulhr 1 43051430614320 1 NOx 1 2003 1 2003 1 7.7 ( $18.0 to $46.3 1 $6,40010$16.500 

I Boilers > 5 MMBtulhr 1 43051430614320 1 NOx ( 2008 1 2008 1 3.3 ( $67.7 6 $177.8 1$56.200 to $147.600 

'Advanced Emission Reduction Options (AERO) in Rule 4320 

effectively limit costs to less than $20.000 per ton reduced. 

2 Table I - Impacts of Emission Control Rules BY INDUSTRY 
Table 1 - Impacts of Emission Control Rules BY INDUSTRY 

Rule Name 

Compliance Emission Total Annual Cost Cost Effectiveness 1 RULE' 1 Pollutant 1 6,1 ,. 1 reduction 

(tonslday) (million 

1 Range 

$lyr) 

I 1 

- - 1 Boilers > 5 MMBtulhr 1 43051430614320 1 NOx 1 2008 1 2008 1 3.3 1 $67.7 to $177.8 I$56.200 t0$147.600'1 

'Advanced Emission Reduction Options (AERO) in Rule 4320 

effectively limit costs to less than $20.000 per ton reduced. 

3 Table 1 - lmpacts of Emission Control Rules BY INDUSTRY 
Table 2 - lrn~acts of Emission Control Rules BY RULE 

Open. Burning 

Prescribed Burn & 

Hazard Reduction 

Cotton Gin 

Boilers > 5 MMBtulhr 

Boilers 2-5 MMBtulhr 

Boilers 0.075 - 2 

MMBtulhr 

Dryers 

Lime Kilns 

Glass Furnaces 

Oil Production Wells 

Oil & Gas Production 

Fugitives 

Glycol Dehydration 

RefinerylChemical Plant 

Fugitives 

Table 2 - Impacts of Emission Control Rules BY RULE 

41 03 

4104 

4106 

4204 

4305'430614320 

4307 

4308 

4309 

4313 

4354 

4401 

440314409 

4408 

44511445214455 

Agricultural operations and 

individuals 

Agricultural operations and 

individuals 

Forest Service (state & 

federal), individuals 

Cotton processors 

Crude oil & gas production, 

public utilities, food 

processing, government 

buildings 

Manufacturing, refineries, 

retail stores, eating 

Crude oil &gas production, 

public utilities, food 

processing, government 

buildings 

Asphalt and concrete 

makers, printers, can 

makers, food processors, 

dehydrators 

Sugar beet processing 

Glass manufacturers 

Crude oil & gas production 

Crude oil & gas production 

Crude oil & gas production 

Refineries, chemical plants 

PM 

NOx 

PM 

NOx 

PM 

NOx 

N Ox 

NOX 

NOX 

NOx 

NOx 

SOX 

NOx 

SOX 

PM 

VOC 

VOC 

VOC 

VOC 

12.8 

9 5 

0.18 

0.81 

2.8 

7.9 

5 

40 

1.9 

0.2 

8.6 

3.1 

8.6 

3.1 

0.05 

34 

15.7 

1.7 

15.7 

2005 

2007 

2005 

2007 

2001 

2001 

2005 

1993 

1996 

2003 

2008 

2005 

2008 

2005 

2005 

2003 

1998 

2006 

2008 

2008 

2008 

2006 

2005 

2002 

2005 

2005-201 0 

2007-201 5 

2005-201 1 

2007-2015 

2001 

2001 

2006-2008 

1995-1 997 

1996 

2003 

2008 

2008-2009 

201 0-201 8 

2007 

2005-2009 

2003 

1998-2008 

2008 

2010-2018 

201 1 

201 1 

2009 

2006 

2003 . 

2006 

0.22 

2 5 

0.05 

1.76 

0 

0 

1.7 

18.2 

0.7 

7.7 

3.3 

2.2 

1.2 

0.7 

0.05 

4.7 

0.6 

2.2 

0.9 

0.1 

0.9 

7.4 

1.5 

0.6 

$0 to $68 per 

acre 

$0 to $350 per 

acre 

$0 to $68 per 

acre 

$0 to $68 per 

acre 

0 

0 

$1.56 to 1.81 

$3.0 to $17.7 

$4.2 to $5.1 

$18.0 to $46.3 

$67.7 to $177.8 

$5.2 to $7.4 

5 5 

-$480.00 to 

+$2.00 per unit 

$1.7 to $12.5 

0.008 

$10.0 to $1 1.9 

0.2 

$1 8 to $22.0 

$1.9 to $3.6 

0.94 

$2.9 to $5 0 

3.3 

0 007 

$0.18 to $0.42 

** 

tt 

$5,400 to $6,300 

$460 to $2,700 

$16,400 to $20,000 

$6,400 to $16,500 

$56,200 to $147,600 

$6,500 to $9,220 

11 900 

-1 900 

$7,300 to $22,000 

420 

$5,800 to $6,900 

270000 

$2,180 to $27,100 

$18,900 to $35,300 

142800 

$8,800-$28,900 

570 

$280 to $570 

$800 to $1,830 
Soil Decontamination 

Table'2 - Impacts of Emission Control Rules BY RULE 
Gas Turbines 

Costs attributed to state law.(SB 705). 

"Annual emissions not reduced but allocation of burning minimizes emissions on bad air days. 

Table 2 - Impacts of Emission Control Rules BY RULE