# San 

# Joaquin Valley 

# dAIR 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 Sadredin, 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 HenryJay Forman, Ph.0. Appointed by Governor RECOMMENDATION:
Michael G. Nelson Supervisor, Merced County Consider the staff report detailing the methodologies used by the Districtto assess economic feasibility of new regulations and provide William O'Brien Supervisor, Stanislaus County guidance on any changes deemed necessary for future regulations.
HenryT. 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 (2091557.6475

Central Region Office 1990 East GettysburgAvenue Fresno, CA 93726-0244 (559)230-6000* FAX (559)230-6061
Southern RegionOffice 2700 MStreet 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 meetingthe 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 inthe 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 providethe 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 CONSIDERATIONSFOR NEW REGULATIONS December 18, 2008

DISCUSSION: As a public health agency, with a missionto "improvethe health and quality of lifefor 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 vitalto 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 inthe rule development process, our analysis, which includesestimations of costs and cost effectiveness, serve as a major guiding factor in constructing reasonable control requirements in proposed regulations. The following discussiondetails all factors and all considerations that play a role in crafting regulationsthat 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 planto €PA detailing the strategy by which the area will control emissions to the pointthat the area is in attainment of the NAAQS. Section 172(c)(l) of the CAA requires such attainment plansto "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 responsiblefor obtaining the total emissions reductions commitment inthe plan. Additionally, areas in non-attainment must demonstrate Reasonable Further Progress (RFP) is being made toward meetingVOC 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 inthe plan have been implemented, the area sho~lld be in attainment of the NAAQS. The State of California has its own version of the CleanAir Act, which mandatesthat individual air districts also meet state standards in addition to any federal requirements. Any new rules or amendmentsto current rules must requirethat existing emission sources meet "best available retrofit control technology1'(BARCT). Each state nonattainment area must also incorporate "all feasible measures"to control sources. TheSJVUAPCD GoverningBoard ECONOMIC FEASIBILITYANALYSIS AND RELATED CONSIDERATIONSFOR NEW REGULATIONS December 18, 2008

CaliforniaAir Resources Board (ARB) interprets "every feasible measure" to meanthat, "at a minimum, a district considers regulationsthat 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 potentialemission reductions. Further, districts should consider not only technological factors, but also social, environment, economic (e.g., cost effectiveness), and energy factors which prevail inthe 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 neededto meetthe state andfederal health-based standards. Computer models are used to estimate the reductions neededto meetthe state and federal standards. The models suggest that the San JoaquinValley needs oxides of nitrogen (NOx) emissionsto be no higherthan about 160tons 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 reductionof 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 legalframework, District staff managesthe 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 EffectivenessAnalysis Pursuant to the California Health and Safety Code (CH&SC), the District is required to analyzethe cost effectiveness of new or amended rules implementing Best Available Retrofit Control Technology (BARCT). District staff followan 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 CostEflectiveness 

# (tons

# ) Emissions Reductions -SJVUAPCD GoverningBoard ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONSFOR NEWREGULATIONS December 18, 2008

Cost effectiveness by itself does

## not reveal business impacts for a specific business or industry; it serves only to evaluatethe costs of obtaining specific emission reductions. The standardization of the methodology allows not only for the comparativeanalyses 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 trivialtask. Once an emission limit is proposed, staff must make reasoned judgments, with input from affected industry, as to the likely equipment or process changesthat would be necessaryto meetthe proposed emission limit. Once one or more likely controltechnologies are identified, District staff gather cost informationfor the control equipment. The accuracy of a cost estimate can vary greatly depending on the source of the information and variability of equipmentwithin 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 equipmentvendors or operators, but this becomes difficultwhere the technical specificationsof 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 initialcapital expenditure for air pollutioncontrols can be significant. As a general business accounting practice, operators amortize over the expected life of the equipment for accounting and tax purposes. Ina 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 compliancecost based on a similar annualization methodology. In an effort to standardizethe 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 inAttachment A demonstrates the use of cost effectivenessto compare the impact of rule changes over time. 2. 

### Socioeconomic Analysis Inorder to further analyzethe economic impact of a rule on industry,the total costs, cost-effectivenessand other data specificto 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 relativeto theSJVUAPCD Governing Board ECONOMIC FEASIBILITY ANALYSISAND RELATED CONSIDERATIONSFOR 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 regionaleconomy; the range of probable costs to industry andlor small business;the availability and cost-effectivenessof alternative controls;the emission reduction potential; and the necessityof adopting, amending or repealingthe rule to attain state and federal ambient air standards. Based in part on the socioeconomicanalysis, the Governing Board has the ultimate responsibilityand authorityto make decisions regarding the balance between air quality improvement, public health, and economic impact. The District retains an independent economic consultantto evaluatethe socioeconomic impact for Rule Developmentprojects. District staff supply the consultantwith estimated compliancecosts, 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 andthe general economy. The information includes the number of employees, total payroll costs, total revenue or sales, and the pre-tax profit margin as a percentof total revenue or sales. The consultant relies on a variety of informationsources, incll~ding the: 2002 Economic Census; US Bureauof 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 InternalRevenue Service; and corporate annual reports of applicable companies. The consultant may be able to obtain informationfrom local operators regarding their particularfinances; however, these instances are rare given that such information may be considered proprietary, exposing operating informationto competitors. With the above information,the consultant estimates net after tax profit ratios for sources affected by the proposed regulations. The consultant calci~lates ratiosof profit per dollar of revenue for affected industries.The result of the socioeconomicanalysis shows what proportionof profits the compliance costs represent. Based on assumed ' thresholds of significance,the consultant reports whether the affected sources are likely to reducejobs 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 costto the pretax profit is lessthan lo%,the impact is deemedto be less than significant and no fl-~rther economic analysis is done. Ifthe 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 usedto 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 

### 5SJVUAPCD GoverningBoard ECONOMIC FEASlBlLlNANALYSlSAND RELATED CONSIDERATIONSFOR NEW REGULATIONS December 18, 2008
job losses in addition to the directjob losses from the subject sources. Indirect jobs are those typically associatedwith 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 lowerdemandfor its products. To the extent possible, District staffwork 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 determinethe balance between air quality improvement and economic impact. 3. Application of Cost Effectiveness and Socioeconomic ImpactAnalyses As a stand-alone analysis, cost effectiveness does not revealthe full impact of a lower emission limit on an affected industry. Cost effectiveness is a valuable comparisontool; however, it is the socioeconomic impact analysis that provides the meansto balance cleaner air and the regional economy duringthe 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, needsto be consideredwithin the larger spectrum of District attainment. If emission reductions are relaxedfor one rule or industry, those reductions must be made up in other rules or industries in order to reach attainment within the attainment plantimeframe.

. Duringthe analysis phase of the rulemaking process, staff utilizesthe socioeconomic impact analysis to determine if the corrlpliance costs are "reasonable" in light of a source category or industry-wide net profit. Industrieswith 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 relafivefiscal impactsto 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 putsthe costs into a realistic perspectivefor an entire industry or source category. Heavy

### fscal impacts to industrieswith lowto no profit margin may require job cuts or decreases in service if forced to comply with proposed 

## . rules. Inthese cases, District staff can make adjustmentsto the stringency or timing of the proposed rule to help balancethe need for emission reductions with the costs to operators for implementing the reductions. An example of such an instance was duringthe 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. Underthe rule, priorto amendment, operators of container glass furnaces were allowed to average emissions across multiplefurnaces to meetthe NOx limit. In an attemptto reduce costs, operators connected multiple furnaces to a single add-on control device. Duringthe adoption phase of the proposed rule, operators stated that if the February

Modelsfor highly accurate and adaptable modelsto estimate the effects of a proposed change in a specific economic region. The IMPLANdatabasecontains county,state, zip code, and federal economic statisticsthat are specialized by region, not estimatedfrom nationalaverages. pikipedia, 2008) 

### 6SJVUAPCD Governing Board ECONOMIC FEASIBILITY ANALYSISAND RELATED CONSIDERATIONSFOR NEW REGULATIONS December 18, 2008

2008 NOx limits were adopted, they would be forced to install individual controls for each furnace. An independent economic consultantcalculated the costs for the additional systems and determined that container glass manufacturers would be severely impacted and would most likely beforced to shut down their operations. District staff made several changes to the proposed rule, including adjusting the proposed SOXlimitto accommodate glass recycling, adjusting the NOx limitto allow for less expensive controls, and delayingthe compliance date for NOx emission reductions by 2 to 3 years. The ultimate NOx reductionfor container glass furnaces was approximately 92% of the reduction inthe February draft. The rule was adopted in October 2008 reflectingthe 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 priorto final adoption, there are times when specific problemswith 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 processorsto meet. Staff worked with operators to find alternatives, presented revisionsto the Governing Board and a subsequentamendment was adopted in 2006. The rule revision allowed an 18-monthcompliance delay for three out of nine source categories in return for 0.1 tons per day additional NOx emission reductionsthan the original rule. Despite serious effortsto 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 bythe District. The District has one year after the issuance of the CTGs to enact the limits within the document. The Governing Board recently approvedtwo such rule projects. Rule4603 (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 regardlessof cost or economic impact. When the California Air Resources Board (ARB) adopts an air toxics control measure (ATCM), state law provides that individualair districts must revisetheir rulesto reflect the ATCM within 120days. A recent ATCM for chromium platingwas adopted by the District Governing Board in January 2008 C. 

### Historical Perspective of 

### Rule Impacts EveryValley industry has been affected financially and has stepped up to the plate, investing significant capital and increasingoperating costs in order to assistthe Valley in reachingattainment. The District has adopted a number of new rules or rule amendments with the goal of reducing emissions to makeValley air cleaner and 

### 7SJVUAPCD GoverningBoard ECONOMIC FEASIBILITY ANALYSIS AND RELATED CONSIDERATIONSFOR NEWREGULATIONS December 18,2008

healthier. The table inAttachment 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 inAttachment B identifiessimilar 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 inthese 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 intwo mainways: 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 inthe rule, which happenedwith Rule 470114702 (Internal Combustion Engines). Each time the rulewas amended, more types of engines were includedwithin 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 subjectto 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 loweredfor 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 Federal8-hour ozone standard, the District must continue to refinethe existing emission control r1.1lesand regulations, provide emission reduction incentives and develop innovative emissions reduction programs. The District is focused on feasible measuresthat will achieve the most reductions; control measuresexpected to yield the greatest health benefitwill be undertaken first. In scheduling rule development projects, the District is giving priority to controls that reduce NOx, which are those reductionsthat are most beneficial in reducing both PM2.5 and ozone inthe San Joaquin Valley. The District demonstrates its commitmentto emissions reductions inthe 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 rulesto be adopted between November 2008 and the December2010 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 pollutanttypes will be attained from revisionsto two rules: 2007 and 2010 refinementsto 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 expectedto reduce nearly all VOC emissions and half of the PM2.5 emissions sought in the District attainment plans.SJVUAPCD Governing Board ECONOMIC FEASIBILI7YANALYSlSAND RELATED CONSIDERATIONS FOR NEWREGULATIONS December 18, 2008
Despite significant emission reductions being achieved through District attainment plans, the total identified reductionsare not enough to fully meet Federalarr~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, boththe 

### 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 2010 and 2011, 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 2013 Ozone Planfor the 2008 NAAQS. Between required mid-course reviews, new major plans, and unanticipated EPA standards changes, the Districtexpects to produce a new plan or major revision starting in 201 0 until 2013. Although modeling demonstrated that the entire San JoaquinValley 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 Federal8-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 initiatethe development of a new rule or rule amendment. The iterative rule and plan amendment process, along with continual effortsto provide emission reduction incentives and develop innovative emissions reduction programs, are the tools that are utilized by the District in its rrrissionto irr~prove the air quality in the San Joaquin Valley.



### Attachments: A. 

### Table I - 

### lmpacts ofEmission Control Rules 

### BY INDUSTRY. (3pages) B. 

### Table 2 - 

### lmpacts ofEmission Control Rules 

### BY RULE. (3pages)Table 1

## - Impacts of Emission Control Rules BY INDUSTRY

Glass Furnaces

'Advanced Emission ReductionOptions (AERO) imRule 4320 effectively limit costs to less than $20,000per ton reduced.

1 Table 1 - Impacts of Emission ControlRules BY INDUSTRYTable 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 $0to $68 per acre Not BARCT Confined Animal Facilities 4570 VOC 2006 2006 15.8 $26.0 $3to $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 $460to$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 \$56,200to $147,600'
Coating of Aerospace Parts 4605 VOC 1996 1996 0.020 $0 $0 GraphicArts 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$56.200to $147.600

'Advanced Emission Reduction Options (AERO) in Rule4320 effectively limitcosts to less than $20.000 per ton reduced.

2 Table I - Impacts ofEmission ControlRules BY INDUSTRYTable 1

## - Impactsof Emission Control Rules BY INDUSTRY

Rule Name Compliance Emission Total Annual Cost Cost Effectiveness 

# 1

RULE' 

# 1

Pollutant

# 1 6,1

# ,. 

# 1

reduction

# 1
Range 

# I 

# 1
(tonslday) (million $lyr)

- - 

## 1 Boilers > 5 MMBtulhr 

## 1 43051430614320 

## 1 NOx 

## 1 2008 

## 1 2008 

## 1 3.3 

## 1 $67.7 to $177.8 I$56.200t0$147.600'1

'Advanced Emission ReductionOptions (AERO) in Rule 4320 effectively limit costs to less than $20.000 per ton reduced.

3 Table 1

### - lmpacts ofEmission ControlRules BYINDUSTRYTable 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 ProductionWells Oil & Gas Production Fugitives Glycol Dehydration RefinerylChemical Plant Fugitives

Table 2

### - Impacts of Emission Control Rules BYRULE 4103

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

NOx

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 2005-2010
2007-201 5
2005-2011
2007-2015 2001 2001 2006-2008 1995-1 997 1996 2003 2008 2008-2009 201 0-2018

2007

2005-2009

2003 1998-2008

2008 2010-2018 201 1 2011 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 $11.9 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 $5,400to $6,300 $460 to $2,700 $16,400to $20,000 $6,400 to $16,500 $56,200 to $147,600

$6,500to $9,220 11 900

-1

900

$7,300to $22,000

420 $5,800 to $6,900 270000 $2,180 to $27,100 $18,900to $35,300 142800 $8,800-$28,900 570 $280 to $570 $800 to $1,830Soil Decontamination

Table'2

### - Impacts of Emission Control Rules BY RULEGasTurbines

Costs attributed to state law.(SB 705). "Annual emissions not reduced but allocation of burning minimizesemissions on bad air days.

Table2

### - Impacts of Emission Control Rules BY RULE