Economic Impact Analysis for the Revisions to the 

Prevention of Significant Deterioration and Title V 

Greenhouse Gas Permitting Regulations and 

Establishment of a Significant Emission Rate for 

Greenhouse Gas Emissions Under the Prevention of 

Significant Deterioration Program; Proposed Rule 
This page intentionally left blank.
EPA-452/R-16-001 

September 2015

Economic Impact Analysis for the Revisions to the Prevention of Significant 

Deterioration and Title V Greenhouse Gas Permitting Regulations and 

Establishment of a Significant Emissions Rate for Greenhouse Gas Emissions 

under the Prevention of Significant Deterioration Program; Proposed Rule

U.S. Environmental Protection Agency

Office of Air and Radiation

Office of Air Quality Planning and Standards

Health and Environmental Impacts Division

Research Triangle Park, NC 27711
ii

CONTACT INFORMATION

This document has been prepared by staff from the Office of Air and Radiation, U.S. 

Environmental Protection Agency. Questions related to this document should be addressed to 

Julia Gamas, U.S. Environmental Protection Agency, Office of Air and Radiation, Office of Air 

Quality Planning and Standards, C439-02, Research Triangle Park, North Carolina 27711 (email: 

gamas.julia@epa.gov). 
iii

TABLE OF CONTENTS

TABLE OF CONTENTS .................................................................................................................... III

LIST OF TABLES ............................................................................................................................. IV

EXECUTIVE SUMMARY ................................................................................................................... 5

ES.1 INTRODUCTION ................................................................................................................................................ 5

ES.2 SUMMARY OF RESULTS.................................................................................................................................... 6

1 BASELINE DESCRIPTION AND ESTIMATE OF INCREMENTAL PERMITS ................................... 7

2 COST SAVINGS OF REGULATORY RELIEF ............................................................................... 9

2.1 INTRODUCTION ................................................................................................................................................ 9

2.2 REGULATORY COSTS AVOIDED ASSOCIATED WITH THE PSD PROGRAM ........................................................10

2.3 SAVINGS FOR TITLE V ....................................................................................................................................11

2.4 TOTAL COST SAVINGS ...................................................................................................................................11

3 IMPACTS OF COST SAVINGS ................................................................................................. 14

4 LIMITATIONS AND UNCERTAINTIES ...................................................................................... 14

4.1 UNCERTAINTIES IN ESTIMATES AFFECTED SOURCES .....................................................................................14

4.2 UNCERTAINTIES IN PERMITTING COSTS .........................................................................................................15

ATTACHMENT A
iv

LIST OF TABLES

Table 1-1 Estimated Annual PSD and Title V Permitting Actions at Different SER Levels ......................................9

Table 2-1 Summary of Savings to Sources from Adding GHG Requirements to Permits at Different SER Levels . 13

Table 2-2 Summary of Savings to Permitting Authorities from Adding GHG Requirements to Permits at Different 

SER Levels..................................................................................................................................................................13
EXECUTIVE SUMMARY

ES.1 Introduction

This rule essentially provides regulatory relief and does not include direct regulatory 

provisions for any industrial entities. The U.S. Supreme Court has limited the EPA’s greenhouse 

gas (GHG) regulatory authority for air permitting purposes to “anyway sources”; a facility or 

emission source that is otherwise subject to Prevention of Significant Deterioration (PSD) 

permitting based on its emissions of one or more non-GHG, regulated New Source Review 

(NSR) air pollutants. EPA is proposing a significant emissions rate (SER) for GHGs under the 

PSD program that would establish a de minimis threshold level below which Best Available 

Control Technology (BACT) is not required for an “anyway” source’s GHG emissions increase. 

If not for provisions that remain in EPA’s definition of “subject to regulation” at this time—

provisions which we are proposing to remove as part of this proposal—consistent with the 

definition of “significant” under the PSD regulations, and in the absence of this proposed 

rulemaking, any GHG emissions increase would require a newly constructed “anyway” source, 

or a major modification at an existing “anyway” source, to undergo PSD GHG BACT review. 

The resource requirements for GHG permitting would therefore consist of the additional, 

incremental BACT review for GHG emissions increases above the GHG SER (Significant 

Emissions Rate) at “anyway” PSD projects, and the resulting permit requirements from this 

BACT review that would need to be added to the facilities’ PSD and title V permits associated 

with those ”anyway” projects. The proposed rule would remove the requirement of conducting 

GHG BACT analyses for sources with GHG emissions increases less than the proposed GHG 

SER. 

The EPA estimated the savings resulting from avoided PSD and title V permitting costs 

for sources and permitting authorities as a result of this proposed rulemaking. This analysis 

focuses on the savings related to “anyway” sources whose GHG emission increases will fall 

below 30,000 tons per year (tpy), 45,000 tpy and the proposed 75,000 tpy carbon dioxide 

equivalent (CO2e) GHG SER levels. 
6 

ES.2 Summary of Results 

For affected sources, the avoided permitting cost or savings for PSD permits is 

approximately $23,532 dollars per permit (in 2014 dollars). Total regulatory cost avoided 

relative to no SER is about $870 thousand dollars at the 75,000 tpy CO2e SER level for an 

estimated 37 permits, close to $520 thousand dollars for 22 permits at the 45,000 tpy CO2e level

and about $350 thousand dollars for 15 permits at the 30,000 tpy CO2e level. State, local, and 

tribal permitting authorities are estimated to expend $4,400 dollars per permit to add GHG 

BACT requirements to an “anyway” industrial PSD permit. Thus, permitting authorities annual 

savings are approximately $165 thousand dollars at the 75,000 tpy CO2e SER level, about $100 

thousand dollars at the 45,000 tpy CO2e level, and over $65 thousand dollars at the 30,000 tpy 

CO2e level. 

Avoided cost for sources subject to title V experiencing regulatory relief is approximately 

$2,470 dollars per permit (in 2014 dollars) for adding GHG requirements to a new title V permit, 

and $520 dollars per permit for adding a revision to an existing title V permit. Total annual 

avoided cost at the proposed 75,000 tpy CO2e SER level is in the order of $20 thousand dollars 

for an estimated 37 permits, close to $10 thousand dollars for 22 permits at the 45,000 tpy CO2e 

level and about $10 thousand dollars for 15 permits at the 30,000 tpy CO2e level. Regulatory cost 

avoided relative to no SER to State, local, and tribal permitting authorities is estimated at $2,632 

dollars per permit for adding GHG requirements to a new title V permit, and $504 dollars per 

permit for revisions to existing title V permits. At the proposed level of 75,000 tpy CO2e 

permitting authorities avoided costs total about $20 thousand dollars, close to $10 thousand 

dollars at the 45,000 tpy CO2e level and in the order of $10 thousand dollars at the 30,000 tpy 

CO2e level. 

Total annual avoided cost for sources for PSD and title V amounts to be approximately

$890 thousand dollars at the 75,000 tpy CO2e GHG SER level, close to $530 thousand dollars at 

the 45,000 tpy CO2e level and about $360 thousand dollars at the 30,000 tpy CO2e level. Total 

annual avoided cost for permitting authorities is expected to be approximately $185 thousand 

dollars at the 75,000 tpy CO2e level, about $110 thousand dollars at the 45,000 tpy CO2e level, 
7 

and close to $75 thousand dollars at the 30,000 tpy CO2e level. Because the costs of the 

regulation are savings for potential sources, no market impacts were estimated. 

1 BASELINE DESCRIPTION AND ESTIMATE OF INCREMENTAL PERMITS

This rule is providing regulatory relief and does not result in direct costs for any 

industrial entities. Details regarding the history and background of this rule, as well as the legal 

basis for this regulation can be found in the preamble. 

The first step in estimating the cost savings of this rule is to estimate the number of 

affected entities. The U.S. Supreme Court has limited the EPA’s GHG regulatory authority for 

air permitting purposes to “anyway sources”; a facility or emission source that is otherwise 

subject to PSD permitting based on its emissions of one or more non-GHG, regulated NSR air 

pollutants. Therefore, the resource requirements for GHG permitting will consist of the 

additional, incremental BACT review for GHG emissions increases above the GHG SER at 

“anyway” PSD projects, and the resulting permit requirements from this BACT review that will 

need to be added to the facilities’ PSD and title V permits associated with those “anyway” 

projects. This Economic Impact Analysis (EIA) focuses on the cost savings for “anyway” 

sources whose GHG emission increases will not exceed the SER.

It is difficult to estimate the number and characteristics of PSD permitting actions that 

will occur in a given future year. This process is further complicated in this exercise by having 

to determine which of those “anyway” PSD actions would include GHG emission increases 

above a given GHG SER option. It is difficult to predict PSD permitting actions since these 

actions are dependent on continuously evolving, case-by-case business decisions to build new 

facilities, or modify existing ones, across various industry types. The exact make-up and extent 

of these business decisions, and thus the form and make-up of potentially permitted projects, 

varies from year to year and across different industry types. Therefore, this analysis begins with 

an estimate of future annual permitting activity based on a review of past permitting activity and 

on projections of the likely number of projects that will require GHG-related permitting actions 

at different GHG SER options. See Attachment A for details on how these estimates were 
8 

conducted and the related uncertainties involved. Given these uncertainties the results of this 

analysis should be considered as illustrative and should not interpreted as a precise projection 

Four options were considered in this analysis. The baseline option is a “No Action” case 

where EPA does not take action to set a GHG SER. If not for provisions that remain in EPA’s 

definition of “subject to regulation” at this time, under the present definition of “significant” 

under the PSD regulations, and in the absence of this proposed rulemaking, any GHG emissions 

increase would require a newly constructed major source, or a major modification at an existing 

facility, to undergo PSD GHG BACT review. Thus, the “No Action” case scenario is equivalent 

to setting a GHG SER of “0” tpy CO2e or no SER1

. Three additional cases were analyzed where 

“anyway” facilities are required to incorporate GHG BACT review requirements into their 

permits: the proposed GHG SER of 75,000 tpy CO2e and evaluated alternatives of 30,000 tpy 

and 45,000 tpy CO2e potential to emit (PTE)2. 

Table 1-1 shows our estimates of the number of PSD permitting actions involving GHG 

BACT review for each SER level and by type of activity. As a consequence to these actions, we 

assume an equal number of title V permits would be affected since the GHG BACT requirements 

resulting from the PSD review will need to be added to each facility’s title V permit: a newly 

constructed major source will require a new title V permit, while a major modification at an 

existing major source is assumed to result in a revision to an existing title V permit. 

 

1 Carbon dioxide equivalent is a measure used to compare and summarize the emissions from various greenhouse 

gases based upon their global warming potential. 2 A GHG SER level above 75,000 tpy CO2e was not considered and is not included in this analysis because it would 

not meet the fundamental principles for developing a de minimis level. Further details regarding the basis for the 

GHG SER levels chosen for analysis can be found in the preamble or this rulemaking. 
9 

Table 1-1 Estimated Annual PSD and Title V Permitting Actions at Different SER Levels3

Level Total “anyway” PSD permits 

subject to GHG BACT review

Newly 

Constructed Modified

Total

Baseline “No action” 103 28 75

30,000 tpy GHG SER 88 28 60

45,000 tpy GHG SER 81 28 53

75,000 tpy GHG SER 66 28 38

Avoided Action

Baseline “No action” 0 0 0

Avoided at 30,000 tpy GHG SER 15 0 15

Avoided at 45,000 tpy GHG SER 22 0 22

Avoided at 75,000 tpy GHG SER 37 0 37

Note: tpy = tons per year; SER = significant emission rate

2 COST SAVINGS OF REGULATORY RELIEF

2.1 Introduction 

EPA estimated the regulatory relief, or avoided PSD and title V permitting costs, for 

sources that will have cost savings from this rulemaking. This analysis focuses on the avoided 

costs for “anyway” sources whose GHG emission increases will fall below the 30,000 tpy, 

45,000 tpy and the proposed 75,000 tpy CO2e levels, as compared to no SER. Details about 

avoided costs are outlined in Attachment A and include: 

• Avoided costs to sources: 

o information collection requirements to add GHG to PSD permits required for new 

or modifying sources of GHG, and 

o information collection costs to add GHG to new or existing title V permits if not 

for this rule 

• Avoided costs to permitting authorities: 

o information collection requirements to add GHG to PSD permits required for new 

or modifying sources of GHG, and 

 

3 For additional detail on the estimation of the permitting actions, please refer to Appendix A.
10 

o information collection costs to add GHG to new or existing title V permits if not 

for this rule 

Within this section of the EIA we are providing an illustrative monetary estimate of 

statutory permitting requirements to show the savings that hypothetically result from this 

rulemaking. For the sake of simplicity, we refer to this illustrative monetary estimate as the 

monetized cost savings of this rulemaking. It is important to note that these estimates of cost 

savings do not include the savings from the avoided costs for the GHG BACT control or 

mitigation process that is ultimately adopted and implemented by the permitted facility as part of 

the BACT decision since these decisions, and ultimately the costs, can vary widely from site to 

site based on unique facility characteristics and operating conditions and cannot be predicted 

with any certainty or specificity.

Attachment A contains information about how the time and costs associated with permit 

activities are derived and the sources for that information. Significant uncertainties exist in the 

following estimates because of the lack of an extensive historical record and permitting 

experience on which to base resource needs to consider sources of GHG emissions in permitting. 

These factors are discussed more fully in Section 4 of this EIA. It is important to note that, given 

the uncertainty in estimates about future permitting actions that entities might take, these 

estimates must be considered illustrative only.

2.2 Regulatory Costs Avoided Associated with the PSD Program

Table 2-1 shows a summary of the savings for sources at the proposed 75,000 tpy CO2e 

GHG SER level, as well as the two evaluated alternatives of 30,000 tpy, and 45,000 tpy CO2e. 

The avoided permitting cost for PSD permits is approximately $23,532 dollars per permit (in 

2014 dollars). Total estimated annual savings is about $870 thousand dollars at the 75,000 tpy 

CO2e SER level, close to $520 thousand dollars at the 45,000 tpy CO2e level and about $350 

thousand dollars at the 30,000 tpy CO2e level. Details of how these data were estimated can be 

found in Attachment A: Tables 7.1, 7.2 and 7.3. 
11 

State, local, and tribal permitting authorities will also benefit from this rule by avoiding 

the administrative costs of processing permits that include GHGs for “anyway” sources annually. 

Savings to State, local, and tribal permitting authorities are shown in Table 3. Permitting 

authorities are estimated to expend an additional $4,400 dollars per permit to process a new 

“anyway” PSD permit. Annual avoided permitting costs are $165 thousand dollars at the 75,000 

tpy CO2e SER level, about $100 thousand dollars at the 45,000 tpy CO2e level, and over $65 

thousand dollars at the 30,000 tpy CO2e level. For more information on the estimates of avoided 

regulatory costs for PSD permits, see Attachment A: Tables 6.1, 6.2 and 6.3. 

2.3 Savings for Title V

Savings for sources subject to title V experiencing regulatory relief are summarized in 

Table 2-1. The avoided permitting cost is around $2,470 dollars per permit for adding GHG 

requirements to a new permit, and $520 dollars per permit for adding GHG requirements through 

a revision to an existing permit. Total annual avoided cost for title V permits at the proposed 

75,000 tpy CO2e SER level are approximately $20 thousand dollars, slightly over $10 thousand 

dollars at the 45,000 tpy CO2e level and around $10 thousand dollars at the 30,000 tpy CO2e 

level. Details of how these data were estimated can be found in Attachment A: Tables 7.1, 7.2 

and 7.3. 

Savings for State, local, and tribal permitting authorities for title V permits are shown in 

Table 2-2. Avoided title V permitting costs are estimated to be $2,632 dollars per permit for 

adding GHG requirements to a new permit, and $504 dollars per permit for revisions to existing 

permits. At the proposed SER level of 75,000 tpy CO2e annual avoided title V permitting costs 

total in the order of $20 thousand dollars, close to $10 thousand dollars at the 45,000 tpy CO2e 

level and about $10 thousand dollars at the 30,000 tpy CO2e level. For more information on the 

estimates of avoided costs for PSD permits, see Attachment A: Tables 6.1, 6.2 and 6.3. 

2.4 Total Cost Savings 

Total annual savings for sources for PSD and title V are estimated to be approximately

$890 thousand dollars at the 75,000 tpy CO2e GHG SER level, close to $530 thousand dollars at 

the 45,000 tpy CO2e level and about $360 thousand dollars at the 30,000 tpy CO2e level (see 
12 

Table 2-1). Total annual avoided costs for permitting authorities are expected to be 

approximately $185 thousand dollars at the 75,000 tpy CO2e level, about $110 thousand dollars 

at the 45,000 tpy CO2e level, and close to $75 thousand dollars at the 30,000 tpy CO2e level (See 

Table 2-2). 
13 

Table 2-1 Summary of Savings to Sources from Adding GHG Requirements to Permits at Different GHG SER Levels (Annual)

Regulatory Cost Avoided at 75,000 tpy SER Regulatory Cost Avoided at 45,000 tpy SER Regulatory Cost Avoided at 30,000 tpy SER

Activity Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

PSD Permits $23,532 37 $870,684 $23,532 22 $517,704 $23,532 15 $352,980 

Title V Permits

New Permit $2,470 0 $- $2,470 0 $- $2,470 0 $- 

Permit Revision $520 37 $19,240 $520 22 $11,440 $520 15 $7,800 

Total Title V $19,240 $11,440 $7,800 

Total Additional Costs $889,924 $529,144 $360,780 

Table 2-2 Summary of Savings to Permitting Authorities from Adding GHG Requirements to Permits at Different GHG SER 

Levels (Annual)

Regulatory Cost Avoided at 75,000 tpy SER Regulatory Cost Avoided at 45,000 tpy SER Regulatory Cost Avoided at 30,000 tpy SER

Activity Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

Additional Cost per 

Permit (2014$)

Number 

of 

Permits 

Total 

Avoided 

Cost 

(2014$)

PSD Permits $4,400 37 $162,800 $4,400 22 $96,800 $4,400 15 $66,000 

Title V Permits

New Permit $2,632 0 $- $2,632 0 $- $2,632 0 $- 

Permit Revision $504 37 $18,648 $504 22 $11,088 $504 15 $7,560 

Total Title V $18,648 $11,088 $7,560 

Total Additional Costs $181,448 $107,888 $73,560 
14 

3 IMPACTS OF COST SAVINGS

This rulemaking does not impose economic impacts on any sources or permitting 

authorities, but should instead be viewed as cost savings for “anyway” emission sources. 

Because no businesses or governmental entities are expected to incur positive costs as a result of 

this rule, there is not a significant impact on a substantial number of small entities (SISNOSE). 

Because the savings are small and spread among many sources, the market impacts of this rule 

will be minimal.

4 LIMITATIONS AND UNCERTAINTIES

Uncertainties exist in the affected “anyway” source permit counts at different GHG SER 

levels used to estimate regulatory relief due to the inability to accurately predict future PSD 

permitting activity at “anyway” sources. These affected “anyway” source permit counts are 

multiplied by the permit avoided cost estimates to add GHG requirements in order to derive the 

benefits (regulatory relief) estimates for the rule. Specific uncertainties in the estimates of 

affected “anyway” PSD permitting actions, avoided cost estimates and other limitations of the 

benefits analysis are discussed below.

4.1 Uncertainties in Estimates of Affected Sources

It is difficult to predict with any certainty the number and characteristics of “anyway” PSD 

permitting actions that will occur in a given future year, which is further complicated in this 

exercise by having to determine which of those “anyway” PSD actions would include GHG 

emission increases above a given GHG SER option. It is challenging to predict PSD permitting 

actions since these actions are dependent on continuously evolving, case-by-case business 

decisions to build new facilities, or modify and expand existing ones, across various industry 

types. The exact make-up and extent of these business decisions, and thus the form and make-up 

of potentially permitted projects, varies from year to year and across different industry types. 

The methodology and estimates used to support this analysis are our best representation of future 

annual permitting activity, based on review of past permitting activity and projections of the 

likely number of projects that will require GHG-related permitting actions at different GHG SER 
15 

options. A full description of the assumptions and uncertainties in the estimates of affected 

sources is provided in Attachment A. 

4.2 Uncertainties in Permitting Costs

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

GHGs are the most recent Information Collection Requests (ICRs) for the PSD and title V 

programs. Hours and costs associated with the addition of GHG permitting have been factored 

into the ICRs and these same assumptions are used in this analysis for establishing a GHG SER 

level. Both of these documents focus on the average resource requirements per permitting 

activity for permitting authorities and sources. Thus, some permitting activities will inherently 

require more time and cost while others will require less depending on the specific composition 

of the project being permitted. 

4.3 Additional Uncertainties

Historically we have not been able to predict what technologies and types of equipment 

these sources will be using for production and emissions controls. It is also not possible to 

predict whether permitting authorities would choose end-of-pipe emissions controls or seek 

measures in line with energy efficiency, fuel switching and the use of renewable energy as 

BACT. These decisions are made on a case by case basis and could be very different. Thus, it is 

not possible to monetize the cost of BACT across the universe of permitted sources or even 

develop a representative case. Because the level of reduction from applying BACT will be 

determined on a case by case basis, it is also difficult to quantify the negative impacts from CO2

emissions over time for different thresholds. 
A-1 

ATTACHMENT A

Documentation for Estimates of Permitting Actions for Economic Impact Analysis for 

GHG SER Rulemaking

1. Introduction

This document summarizes an assessment of the estimated resource requirements for 

permitting authorities to include GHG BACT review and permitting related requirements under 

the Prevention of Significant Deterioration (PSD) and title V permitting programs based on 

different GHG significant emission rate (SER) options for the PSD program. The analysis was 

performed for GHG SER options based on a carbon dioxide equivalent (CO2e) basis, which 

represents the sum of the six primary GHG with their respective global warming potentials 

(GWP) applied. Time and costs associated with permit activities are derived from existing ICRs 

for the title V and PSD programs. 

To estimate permitting resource requirements for both the PSD and title V programs, we needed 

to first estimate the number of affected PSD permitting actions, namely “anyway” PSD 

permitting actions that will require GHG BACT review at a given GHG SER. As discussed in 

the proposal, the US Supreme Court has limited the EPA’s GHG regulatory authority for air 

permitting purposes to “anyway sources”; an “anyway source” refers to a facility or emission 

source that is otherwise subject to PSD permitting based on its emissions of one or more nonGHG, regulated NSR air pollutants. As a result of this ruling, the EPA also cannot require title 

V permits based solely on a facility’s GHG emissions alone. As a result, the resource 

requirements for GHG permitting will consist of the additional, incremental BACT review for 

GHG emissions increases above the GHG SER at “anyway” PSD projects, and the resulting 

permit requirements from this BACT review that will need to be added to the facilities’ title V 

permits associated with those “anyway” projects. It is difficult to predict with any real certainty 

the number and characteristics of PSD permitting actions that will occur in a given future year, 

which is further complicated in this exercise by having to determine which of those “anyway” 

PSD actions would include GHG emission increases above a given GHG SER option. It is 

difficult to predict PSD permitting actions since these actions are dependent on continuously 

evolving, case-by-case business decisions to build new facilities, or modify existing ones, across 

various industry types. The exact make-up and extent of these business decisions, and thus the 

form and make-up of potentially permitted projects, varies from year to year and across different 
A-2 

industry types. The methodology and estimates provided below represent our best representation 

of future annual permitting activity, based on review of past permitting activity and projections 

of the likely number of projects that will require GHG-related permitting actions at different 

GHG SER options. 

2. Estimate of PSD Permitting Actions at Different GHG SER Option Levels 

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

quantities of permitting actions that would need to address GHGs under the PSD and title V 

permitting programs. The estimated costs summarized in Section 3 are based on the inputs of 

permitting actions estimated using the methodologies described in this section. In developing our 

methodology, we established different applicability options under which “anyway” GHG 

emission sources would be regulated. These GHG applicability thresholds reflect different 

options for GHG SER values considered for the proposed rulemaking. 

We developed our analysis around four major GHG SER options: 1) a “No Action” 

baseline option, which refers to a scenario where EPA does not take action to set a GHG SER, 

and per existing EPA PSD regulations the GHG SER value would default to 'any increase' in 

emissions, essentially equating to a GHG SER of ‘0’ tpy CO2e; 2) a 30,000 tpy CO2e level; 3) a 

45,000 tpy CO2e level; and, 4) a 75,000 tpy CO2e level. We believe an analysis of these option 

levels and associated GHG permitting activity provided a good representation of the relative and 

incremental permitting costs across the range of options considered. 

Since GHG permitting is limited to “anyway” projects, i.e., projects that would otherwise 

require PSD permits for conventional pollutants, our analysis of GHG-impacted permitting 

actions all have an inherent background constraint to the number of total PSD permitting actions 

that would occur in a given year; i.e., the total number of PSD permitting actions that involve 

GHGs cannot exceed the total number of PSD actions that would be occurring “anyway” for 

conventional, non-GHG pollutants since permits cannot be triggered for GHG emissions alone. 

Our review4

 of recent PSD permitting activity over the four year period of 2011-2014, inclusive, 

shows an annual average total PSD permitting activity level of 153 permits per year nationwide. 

 

4 This review included permitting counts obtained from a review of State air permitting websites, EPA regional 

office tracking data, and permit information reported to EPA’s RACT/BACT/LAER Clearinghouse (RBLC). 

Appendix A contains a listing of the overall PSD permit and GHG BACT review counts used for this analysis.
A-3 

Therefore, there is a theoretical maximum number of “anyway” PSD permitting actions that 

could even possibly involve GHG BACT review, which equates to approximately 153 permits 

per year based on the annual average of the last four years. Over the same four year period our 

review showed a total of 265 “anyway” permits containing a GHG BACT review, or an annual 

average total of approximately 66 permits per year nationwide. 

It is important to reiterate the uncertainty in estimating PSD actions again here; while we 

believe this number of 153 annual permitting actions is a reasonably accurate representation of 

recent PSD permitting activity nationwide, since it is based to a large extent on actual statereported permit data, annual permitting activity can fluctuate depending on prevailing economic 

conditions and, even more importantly and difficult to predict, the individual status of facilities 

in a given industrial sector. However, we note that the range across the 4-yr period on which the 

average is based was a low of 127 to a high of 179 PSD permits per year. We do have confidence 

in this general order-of-magnitude of permit activity based on our recent program experience and 

we believe the 153 annual average value to be our best estimate of near-term, future annual PSD 

permitting activity for use in the GHG SER option analysis. 

Table 1 shows our estimates of PSD permitting actions at each of the analyzed GHG SER 

option levels. The estimates of permitting actions show the total estimated “anyway” source 

PSD permits that would be subject to GHG BACT review, along with the breakdown of this total 

into those actions involving newly constructed facilities and those involving modifications at 

existing facilities. Following the table is a description of the methodology and assumptions used 

to estimate permitting actions at each of the option scenarios. Since the only actual historical 

data we have on GHG permitting is related to the 75,000 tpy CO2e option level, it is not possible 

at lower level options to base these assumptions on an historical record. Therefore, a number of 

assumptions are based on professional judgement of PSD program staff who have worked with 

actual permit data. However, based on our level of confidence in the total possible number of 

annual PSD permitting actions, and our knowledge of historical GHG “anyway” permitting 

actions under the Tailoring Rule permitting level of 75,000 tpy GHG, we feel these two numbers 

provide a well-defined boundary around the levels of permitting that would be expected at any 

intermediate levels. 
A-4 

Table 1. Estimates of PSD Permitting Actions Involving GHG BACT Review (Annual)

Option/Scenario

Estimated annual 

avg. “anyway” PSD 

permits subject to 

GHG BACT review

# of annul PSD 

permits for newly 

constructed 

facilities 

# of annual PSD 

permits for 

modifications at 

major source 

facilities 

"No Action" baseline 103 28 75

30,000 tpy GHG SER 88 28 60

45,000 tpy GHG SER 81 28 53

75,000 tpy GHG SER 66 28 38

The "No Action" baseline option refers to a scenario where EPA does not take action to 

set a GHG SER level. If not for provisions that remain in EPA’s definition of “subject to 

regulation” at this time, under the present definition of “significant” under the PSD regulations, 

and in the absence of this proposed rulemaking, any GHG emissions increase would require a 

newly constructed major source, or a major modification at an existing facility, to undergo PSD 

GHG BACT review. Thus, the “No Action” case scenario is equivalent to setting a GHG SER of 

“0” tpy CO2e. As such, the values for permitting actions for the “No Action” baseline scenario 

are the estimated “anyway” PSD actions that would involve any GHG emissions (for newly 

constructed sources) or GHG emission increases for modification projects at existing major 

sources. The value of 103 represents approximately 67% of the total estimated annual PSD 

“anyway” source permitting actions (153). The value of 103 is the estimated PSD “anyway” 

permits that would require a GHG BACT review at a ‘zero’ GHG significance level. The value 

of 67% was estimated based on the assumption that 33% of “anyway” PSD permits involve 

projects with strictly non-GHG emission sources, such as VOC or PM-only sources that would 

not likely involve GHG emissions. For example, the construction and modification activities 

associated with VOC or PM-only permits generally consist of non-GHG related emission 

sources, such as PM dust or VOC’s from coatings and tanks emissions. The other 67% of permits 

would principally represent combustion-related equipment or processes where any fossil fuel 

combustion could potentially result in non-zero GHG emissions. This assumption is based on a 

review of the EPA’s RACT/BACT/LAER Clearinghouse (RBLC) permitting database for 2011-

2014. This assumption is also consistent with our findings from sample reviews of “anyway” 

permitting actions at likely GHG source categories over the last four years, where it is evident 
A-5 

that combustion unit-related projects are responsible for the majority of PSD actions being 

triggered. 

For estimating the affected permitting actions at the GHG SER option levels of 30,000 

and 45,000 tpy CO2e, we applied a linear interpolation between the estimates for the “No 

Action” baseline and the 75,000 tpy CO2e level. Since our estimates of GHG affected permits at 

these two end-points represent our best known levels of permitting activity since they are based 

on a historical record, we believe the use of linear interpolation between these two points 

provides our best estimate of the level of PSD permitting activity involving GHGs at other GHG 

SER option points. As discussed above, the uncertainty in predicting future PSD permitting 

actions in general, and additionally what actions might be involved at different GHG SER option 

levels, makes it impossible to predict with any certainty how many GHG BACT reviews would 

be involved at hypothetical GHG permitting levels. However, we have confidence that the two 

end-point estimates (i.e., the scenarios for the “No Action” baseline and 75,000 tpy CO2e 

options), provide a reasonably well-defined boundary around the levels of permitting that would 

be expected at any intermediate levels because they are based on actual permitting experience. 

The use of linear interpolation assumes that the permitting activity involving GHGs would track 

linearly between these option levels such that as the GHG SER level becomes lower, the number 

of “anyway” PSD permits involving GHG BACT review increases. Appendix B shows the 

derivation of the interpolated results for the GHG SER option levels of 30,000 tpy and 45,000 

tpy CO2e. 

An overarching assumption for all scenarios is that we anticipate that all newly 

constructed facilities that require “anyway” PSD permits, and which therefore must be ‘major’ 

PSD sources for one or more non-GHG pollutants, will have sufficient GHG emissions to require 

GHG BACT review at any of the alternative thresholds evaluated. Our program experience with 

PSD permitting has shown that newly constructed, major source industrial facilities generally 

included multiple combustion units as part of the overall facility design, which results in high 

levels of combustion-related GHG emissions, often many times greater than 75,000 tpy CO2e. 

We assume for our analysis, therefore, that any additional GHG BACT reviews that would be 

excluded from higher level GHG SER options are related to modification projects involving 

existing major source facilities. Modifications can involve such activities as adding a combustion 

unit to an existing facilities to expand production, or modifying an existing production process to 
A-6 

increase its capacity. The number of permits for new facility construction used for each threshold 

is based on a review of the GHG permits issued to date. 

3. Estimate of Stakeholder Burden at Different GHG SER Option Levels

The permitting action estimates above, along with the current ICRs for both the PSD and 

title V programs, were used to determine the associated burden at the GHG SER option levels. In 

both programs, the ICRs identify the average burden hours per permit by activity as well as the 

total national estimated hours required to operate the programs and issue permits annually. In 

both programs, activities for permitting authorities include reviewing permit applications, 

providing for public review of a proposed project, and issuing a permit based on consideration of 

all technical factors and public input. Source activities involve conducting the necessary 

research, performing the appropriate analyses, and preparing the permit application with 

documentation to demonstrate that a project meets all the applicable statutory and regulatory 

requirements. For the purpose of this analysis, the focus is on the additional time and cost 

required to conduct GHG BACT review and incorporate the resulting requirements into permits.

a. PSD Permitting Burden Annual Estimates

The 2012 ICR for the New Source Review (NSR) program estimates the burden 

associated with all aspects of preconstruction permit programs, including the time and cost 

required to prepare and issue a PSD permit.5 The ICR uses a weighted average burden (in hours) 

per permit for both permitting authorities and sources to determine the average national annual 

burden for the NSR program. Since this analysis is concerned with the additional burden 

imposed by the BACT review for GHGs in “anyway” PSD permits, it is important to distinguish 

between the average burden (in hours) for permits with and without GHGs. Therefore, this 

analysis relies on the ICR’s supporting documentation that provides the calculations used to 

arrive at the weighted averages identified in the ICR, along with the breakdown of the hours per 

activity needed to issue PSD permits with and without GHGs.

 

5 Information Collection Request for Prevention of Significant Deterioration and Non-Attainment Area New Source 

Review (Renewal), EPA ICR Number 123.29, OMB Control Number 2060-0003, 2012. A copy of this document 

is available in the docket EPA-HQ-OAR-2011-0901. 
A-7 

For permitting authorities, the estimated burden to issue an average PSD permit that does 

not require GHG BACT review is 335 hours. An “anyway” PSD permit requires an additional 50 

hours, or an average 385 hours total, to include GHGs. This additional time is divided among 

permitting activities most closely associated with BACT, including answering respondent 

questions, reviewing data submissions, and application approval. For a detailed breakdown of 

permitting activity, please refer to Appendix C. 

Table 2 depicts the additional permitting burden for permitting authorities to add GHG 

requirements into “anyway” PSD permits at different GHG SER option levels. Using a staff 

labor cost of $88 per hour, the additional burden at the “No Action” baseline option is estimated 

to require permitting authorities to spend approximately $453,000 to include GHG requirements 

in all “anyway” PSD permits. At the 30,000 tpy CO2e option level the additional cost to 

permitting authorities is anticipated to be around $387,000 nationally, while at the 45,000 tpy 

CO2e and 75,000 tpy CO2e options the additional burden equates to approximate costs of 

$356,000 and $290,000 respectively.

Table 2. Additional Permitting Authority Burden to Add GHG Requirements to PSD Permits (Annual)

Burden 

Hours 

per 

Permit

Affected 

Permits

Total 

Burden 

(hours)

Total 

Additional 

Cost 

($2014)a

"No Action" Baseline

Add GHG Requirements to 'Anyway' PSD Permit 50 103 5,150 $453,200

30,000 tpy GHG SER

Add GHG Requirements to 'Anyway' PSD Permit 50 88 4,400 $387,200

45,000 tpy GHG SER

Add GHG Requirements to 'Anyway' PSD Permit 50 81 4,050 $356,400

75,000 tpy GHG SER

Add GHG Requirements to 'Anyway' PSD Permit 50 66 3,300 $290,400 a

Salaries from the NSR ICR adjusted to 2014 dollars using "Employer Costs for Employee Compensation, Table 4: Employment Costs for 

State and Local Government Workers" U.S. Dept. of Commerce, BLS, December 2014. (http://www.bls.gov/news release/pdf/ecec.pdf; 

http://www.bls.gov/news release/ecec.t04.htm) 100% overhead assumed.

For sources, the estimated burden to issue an average PSD permit that does not require 

GHG BACT review is 984 hours. An “anyway” permit requires a source to spend an additional 

222 hours to include GHGs, or an average of 1,206 hours total. The background supporting 

documentation indicates that sources spend, on average, 120 hours obtaining guidance on data 

needs and 102 hours for the preparation of the BACT analysis for a non-GHG permit. It is 
A-8 

expected that sources with activities exceeding the GHG SER level would need to spend an 

equal amount of time for these two activities to conduct BACT review for GHGs. For a detailed 

breakdown of permitting activity, please refer to Appendix C. 

Table 3 compares the additional source burden required to conduct BACT review for 

GHG emissions increases above different GHG SER level options for “anyway” PSD permits. 

Using a wage rate of $106 per hour, the additional burden at the “No Action” baseline option is 

estimated to require “anyway” sources to spend approximately $2.4 million to conduct BACT 

review for GHGs all “anyway” PSD permits. At the 30,000 tpy CO2e option level the additional 

cost to “anyway” sources is anticipated to be under $2.1 million nationally, while at the 45,000 

tpy CO2e and 75,000 tpy CO2e options the burden equates to approximate costs of $1.9 million 

and $1.6 million respectively. 

Table 3. Additional Source Burden to Add GHG Requirements to PSD Permits (Annual)

Activity

Burden 

Hours 

per 

Permit

Affected 

Permits

Total 

Burden 

(hours)

Total 

Additional 

Cost 

($2014)a

"No Action" Baseline

Add GHG Requirements to 'Anyway' PSD Permit 222 103 22,866 $2,423,796

30,000 tpy GHG SER 

Add GHG Requirements to 'Anyway' PSD Permit 222 88 19,536 $2,070,816

45,000 tpy GHG SER

Add GHG Requirements to 'Anyway' PSD Permit 222 81 17,982 $1,906,092

75,000 tpy GHG SER

Add GHG Requirements to “Anyway” PSD Permit 222 66 14,652 $1,553,112 a

Salaries from the NSR ICR adjusted to 2014 dollars using "Employer Costs for Employee Compensation, Table 2: Employment Costs for 

Civilian Workers by Occupational and Industry Group (Professional and Related)" U.S. Dept. of Commerce, BLS, December 2014. 

(http://www.bls.gov/news release/pdf/ecec.pdf; http://www.bls.gov/news release/ecec.t02 htm). 110% overhead assumed.

b. Title V Burden Annual Estimates 

The 2015 Title V ICR estimates burden associated with all aspects of the operating 

permit program, including the time and cost required to prepare and issue an operating permit.6

 

6 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.12, 

OMB Control Number 2060-0243, 2015. A copy of this document is available in the docket EPA-HQ-OAR2004-0015.
A-9 

Newly constructed major sources or sources designated newly major due to a modification are 

required to apply for and be issued a title V permit in order to operate. If the new source is an 

“anyway” source, additional time will be necessary to incorporate the GHG requirements from 

the “anyway” PSD permit into the title V permit. If an existing source undergoes a modification 

that requires BACT review for GHG emission increases above the GHG SER at “anyway” PSD 

projects, the title V permit for the source would need to be revised in order to incorporate the 

new GHG requirements.

According to the ICR, the average permitting authority burden to issue a new title V 

permit is 474 hours. For a source needing to add GHG requirements from an “anyway” PSD 

permit, the ICR estimates the incorporation into the title V permit will increase the average 

burden by 10%, or by an additional 47 hours. A detailed breakdown of burden per permitting 

activity is located in Appendix C. For a permitting authority to revise an existing title V permit to 

incorporate requirements from a new PSD permit, a significant permit revision may be required, 

which is estimated to take 94 hours. If the permit in question is an “anyway” PSD permit, this 

analysis assumes a significant permit revision is required and will need an additional 10% of 

time above the 94 hours, or 9 hours, to incorporate the GHG requirements into the title V permit. 

Table 4 presents the additional permitting burden for permitting authorities to incorporate 

the requirements resulting from GHG BACT review for “anyway” PSD permitting actions into 

title V permits at different GHG SER option levels.7

 Using a staff labor cost of $56 per hour, the 

additional burden at the “No Action” baseline option is estimated to require permitting 

authorities to spend approximately $112,000 to include GHG requirements from all “anyway” 

PSD permits into title V permits. At the 30,000 tpy CO2e option level the additional cost to 

permitting authorities is anticipated to be around $104,000 nationally, while at the 45,000 tpy 

CO2e and 75,000 tpy CO2e options the burden equates to approximate costs of $100,000 and 

$93,000 respectively. 

 

7 As a consequence of “anyway” PSD permitting actions involving GHG BACT review estimated in Table 1, an 

equal number of title V permits are assumed to be affected since the GHG BACT requirements resulting from 

the PSD review will need to be incorporated into a title V permit. For newly constructed major sources, this will 

require adding GHG BACT requirements to a new title V permit; for existing major source, a PSD major 

modification is assumed to result in a corresponding title V permit revision.
A-10 

Table 4. Additional Permitting Authority Burden to Incorporate GHG Requirements into Title V Permits (Annual)

Activity

Burden 

Hour 

per 

Permit

Affected 

Permits

Total 

Burden 

(hours)

Total Additional 

Cost 

($2014)a

"No Action" Baseline

Add GHG Requirements to New Title V Permit 47 28 1,316 $73,696

Add GHG Requirements to Title V Permit Revision 9 75 675 $37,800

Total Additional Burden 1,991 $111,496

30,000 tpy (associated with 15,000 tpy PSD GHG SER)

Add GHG Requirements to New Title V Permit 47 28 1,316 $73,696

Add GHG Requirements to Title V Permit Revision 9 60 540 $30,240

Total Additional Burden 1,856 $103,936

45,000 tpy (associated with 45,000 tpy PSD GHG SER )

Add GHG Requirements to New Title V Permit 47 28 1,316 $73,696

Add GHG Requirements to Title V Permit Revision 9 53 477 $26,712

Total Additional Burden 1,793 $100,408

75,000 tpy (associated with 75,000 tpy PSD GHG SER)

Add GHG Requirements to New Title V Permit 47 28 1,316 73,696

Add GHG Requirements to Title V Permit Revision 9 38 342 19,152

Total Additional Burden 1,658 $92,848

a

Labor cost for permitting authorities estimated at $56.00 per hour. Information Collection Request for State Operating Permit 

Regulations (Renewal), EPA ICR Number 1587.12, OMB Control Number 2060-0243, 2015.

According to the ICR, the average source burden to obtain a new title V permit is 391 

hours. For a source needing to add GHG requirements from an “anyway” PSD permit, the ICR 

estimates the incorporation into the title V permit will increase the average burden by 10%, or by 

an additional 39 hours. A detailed breakdown of burden per permitting activity is located in 

Appendix C. For a source to incorporate requirements from a new PSD permit into its existing 

title V permit, it may need to undergo a significant permit revision, which is estimated to take 84 

hours. If the permit in question is an “anyway” PSD permit, this analysis assumes a significant 

permit revision is required and will need an additional 10% of time above the 84 hours, or 8 

hours, to incorporate the GHG requirements into the title V permit. 

Table 5 compares the additional source burden associated with incorporating the 

requirements resulting from GHG BACT review for “anyway” PSD permitting actions into title 

V permits at different GHG SER option levels. Using a wage rate of $65 per hour, the additional 

burden at the “No Action” baseline option is estimated to require “anyway” sources to spend 

approximately $108,000 to incorporate GHG requirements from all “anyway” PSD permits into 

title V permits. At the 30,000 tpy CO2e option level the additional cost to “anyway” sources is 
A-11 

anticipated to be around $100,000 nationally, while at the 45,000 tpy CO2e and 75,000 tpy CO2e 

options the burden equates to approximate costs of $97,000 and $89,000 respectively.

Table 5. Additional Source Burden to Incorporate GHG Requirements into Title V Permits (Annual)

Activity

Burden 

Hour 

per 

Permit

Affected 

Permits

Total 

Burden 

(hours)

Total 

Additional 

Cost 

($2014)

Actions Associated with "No Action" Baseline

Add GHG Requirements to New Title V Permit 38 28 1,064 $69,160

Add GHG Requirements to Title V Permit Revision 8 75 600 $39,000

Total Additional Burden 1,664 $108,160

Actions Associated with 30,000 tpy PSD GHG SER

Add GHG Requirements to New Title V Permit 38 28 1,064 $69,160

Add GHG Requirements to Title V Permit Revision 8 60 480 $31,200

Total Additional Burden 1,544 $100,360

Actions Associated with 45,000 tpy PSD GHG SER 

Add GHG Requirements to New Title V Permit 38 28 1,064 $69,160

Add GHG Requirements to Title V Permit Revision 8 53 424 $27,560

Total Additional Burden 1,488 $96,720

Actions Associated with 75,000 tpy PSD GHG SER

Add GHG Requirements to New Title V Permit 38 28 1,064 $69,160

Add GHG Requirements to Title V Permit Revision 8 38 304 $19,760

Total Additional Burden 1,368 $88,920

a

Labor cost for permitting authorities estimated at $65.00 per hour. Information Collection Request for State Operating Permit Regulations 

(Renewal), EPA ICR Number 1587.12, OMB Control Number 2060-0243, 2015. 

The following tables indicate the estimated annual avoided cost when comparing the “No 

Action” baseline to different GHG SER option levels. In Tables 6.1through 6.3, the first three 

columns indicate the cost per permit and total cost to permitting authorities at the “No Action” 

baseline for PSD and Title V. The next three columns reflect the estimated costs for permitting 

authorities at the specified option level. In the final three columns, the avoided cost is estimated 

– the time and costs alleviated relative to the “No Action” baseline level by establishing a 

different GHG SER level.

The estimated annual avoided cost for sources at the different GHG SER option levels is 

presented in Tables 7.1 through 7.3 below. This information on avoided cost was used to compile 

the Economic Impact Analysis (EIA) for the proposed rule. Please see the EIA contained in the 

public docket for this GHG SER rule for a full explanation and description of the avoided cost 

that would be provided under the different GHG SER option levels.
12 

Table 6.1. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 30,000 tpy GHG SER level (Annual)

"No Action" SER 30,000 tpy GHG SER Avoided Cost

Activity

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $4,400 103 $453,200 $4,400 88 $387,200 $4,400 15 $66,000

Title V Permits

Add GHG Requirements to New Permit $2,632 28 $73,696 $2,632 28 $73,696 $2,632 0 $0

Add GHG Requirements to Permit Revision $504 75 $37,800 $504 60 $30,240 $504 15 $7,560

Total Additional Permitting Authority Costs $564,696 $491,136 $73,560

Table 6.2. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 45,000 tpy GHG SER level (Annual)

"No Action" SER 45,000 tpy GHG SER Avoided Cost

Activity

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $4,400 103 $453,200 $4,400 81 $356,400 $4,400 22 $96,800

Title V Permits

Add GHG Requirements to New Permit $2,632 28 $73,696 $2,632 28 $73,696 $2,632 0 $0

Add GHG Requirements to Permit Revision $504 75 $37,800 $504 53 $26,712 $504 22 $11,088

Total Additional Permitting Authority Costs $564,696 $456,808 $107,888
13 

Table 6.3. Estimated Regulatory Cost Avoided for Permitting Authorities Utilizing a 75,000 tpy GHG SER level (Annual)

"No Action" SER 75,000 tpy GHG SER Avoided Cost

Activity

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total 

Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $4,400 103 $453,200 $4,400 66 $290,400 $4,400 37 $162,800

Title V Permits

Add GHG Requirements to New Permit $2,632 28 $73,696 $2,632 28 $73,696 $2,632 0 $0

Add GHG Requirements to Permit Revision $504 75 $37,800 $504 38 $19,152 $504 37 $18,648

Total Additional Permitting Authority Costs $564,696 $383,248 $181,448

Table 7.1. Estimated Regulatory Cost Avoided for Sources Utilizing a 30,000 tpy GHG SER level (Annual)

"No Action" SER 30,000 tpy GHG SER Avoided Cost

Activity

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $23,532 103 $2,423,796 $23,532 88 $2,070,816 $23,532 15 $352,980

Title V Permits

Add GHG Requirements to New Permit $2,470 28 $2,498 $2,470 28 $69,160 $2,470 0 $0

Add GHG Requirements to Permit Revision $520 75 $595 $520 60 $31,200 $520 15 $7,800

Total Additional Source Costs $2,426,889 $2,171,176 $360,780
14 

Table 7.2. Estimated Regulatory Cost Avoided for Sources Utilizing a 45,000 tpy GHG SER level (Annual)

"No Action" SER 45,000 tpy GHG SER Avoided Cost

Activity

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $23,532 103 $2,423,796 $23,532 81 $1,906,092 $23,532 22 $517,704

Title V Permits

Add GHG Requirements to New Permit $2,470 28 $69,160 $2,470 28 $69,160 $2,470 0 $0

Add GHG Requirements in Permit Revision $520 75 $39,000 $520 53 $27,560 $520 22 $11,440

Total Additional Source Costs $2,531,956 $2,002,812 $529,144

Table 7.3. Estimated Regulatory Cost Avoided for Sources Utilizing a 75,000 tpy GHG SER level (Annual)

"No Action" SER 75,000 tpy GHG SER Avoided Cost

Activity

 Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

 Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

Additional 

Cost per 

Permit 

(2014$) 

Number 

of 

Permits

Total Cost 

(2014$) 

PSD Permits

Add GHG Requirements to 'Anyway' Permits $23,532 103 $2,423,796 $23,532 66 $1,553,112 $23,532 37 $870,684

Title V Permits

Add GHG Requirements to New Permit $2,470 28 $69,160 $2,470 28 $69,160 $2,470 0 $0

Add GHG Requirements to Permit Revision $520 75 $39,000 $520 38 $19,760 $520 37 $19,240

Total Additional Source Costs $2,531,956 $1,642,032 $889,924
15 

Appendix A GHG BACT Review and PSD Permit Counts

A.1 2011-2014 “Anyway” PSD Permits with GHG BACT 

Review 

1. NUCOR Corporation, St. James Parish, LA m1

2. We Energies, Rothschild, WI. (biomass co-gen boiler at a paper 

mill) e1

3. PacifiCorp Lake Side Power Plant, Utah County, UT e2

4. Mid-American Energy, George Neal South, Salix, IA 

(installation of pollution controls at a coal-fired power plant) e3

5. Mid-American Energy, George Neal South, Salix, IA (same as #4 but at different unit) e4

6. Wolverine Power, Rogers City, MI (biomass boilers) e5

7. Lafarge Cement, Ravena, NY mn1

8. Abengoa BioRefinery, Hugoton, KS c1

9. Wolverine Power, Sumpter Energy, Carleton Farms, MI e6

10. US Steel Keetac Iron & Taconite Plant, Keewatin, MN [Delegated State Permit] m2

11. Mid-American Energy, George Neal North, Sergeant Bluff, IA e7

12. Palmdale Hybrid Energy Center, Antelope Valley, CA [EPA] e8

13. Crawford Renewable Energy, Greenwood Township, PA e9

14. Eni Holy Cross Drilling Project, OCS Eastern GOM [EPA] o1

15. Hyperion Refinery and Energy Center, Union County, SD r1

16. Lower Colorado River Authority - Ferguson, Horseshoe Bend, TX [EPA] e10

17. Wolverine Power, Sumpter Power Plant, Belleville, Michigan e11

18. Hoosier Energy - Merom Station, Sullivan, IN e12

19. Port Dolphin Energy LNG Port, OCS Eastern GOM [EPA] o2

20. IPL Ottumwa Generating, Ottumwa, IA e13

21. Kennecott Utah Copper- Repowering, South Jordan, UT m3

22. US Nitrogen - Midway, Green County, TN c2

23. Beaver Wood Energy, Fairhaven, VT e14

24. University of Wisconsin - Charter Street, Madison, WI e15

25. Universal Cement, Chicago, IL [Delegated State] mn2

26. Carolina Cement, Castle Hayne, NC mn3

27. PyraMax Ceramics, Allendale, SC mn4

28. PyraMax Ceramics, Wrens, GA mn5

29. NRG Energy, Dover, DE e16

30. York Plant Holding, Springettsbury, PA e17

31. Pioneer Valley Energy Center, Westfield, MA [EPA] e18

32. Tenaska Christian County Generation IGCC, Taylorville, IL [Delegated State]e19

33. Entergy Louisiana LLC - Ninemile Point Plant, LA e20

Key:

Power Plant (including cogen) - e 

Oil and Gas - o 

Pulp, Paper and Wood Products- p 

Chemicals Production- c 

Metals – m 

Refineries – r 

Minerals - mn
16 

34. Sabine Pass LNG LP, Cameron, LA o3

35. Westlake Vinyls, LA c3

36. Pryor Chemical Company, OK c4

37. Atlas Pipeline Mid-Continent West OK, LLC (WESTOK), OK o4

38. ETC Texas Pipeline, Natural Gas Processing Plant, Jackson County, TX [EPA] o5

39. Indiana Gasification, Spencer County, IN c6

40. BHP Billiton Petroleum, Sake Exploratory Project, OCS Eastern GOM [EPA]o6

41. Milwaukee Metropolitan Sewerage District, Milwaukee, WI e21

42. Essar Steel, Nashwauk, MN [Delegated State] m4

43. CARBO Ceramics, Millen, GA mn6

44. Effingham Power, Rincon, GA e22

45. Showa Denko Carbon, Dorchester County, SC mn7

46. Woodbridge Energy, NJ [Delegated State] e23

47. Phillips 66 Alliance Refinery, Plaquemine, LA c7

48. Williams Olefins, Geismar, LA c8

49. JM Huber, Huber Engineered Woods, GA p1

50. BASF FINA Petrochemical LP (BFLP), Port Arthur, TX [EPA] c9

51. Black Hills Power – Cheyenne Prairie Generating Station, Cheyenne, WY [EPA]e24

52. Cricket Valley Energy Center, Dover, NY e25

53. Newark Energy Center, Newark, NJ [Delegated State] e26

54. Exxon Mobil Point Thomson, North Slope, AK – Issued 8/20/12 o7

55. Sevier Power Project, UT e27

56. Enterprise Products – Eagleford Fractionation/DIB, Mont Belvieu, TX [EPA] o8

57. Next Generation Processing, LLC - Haven Gas Plant, KS o10

58. Pio Pico Energy Center, San Diego, CA [EPA] e28

59. Moxie Liberty, Asylum Township, PA o11

60. Graymont Limestone - Pleasant Gap, Spring Township, Center County, PA mn8

61. GSA Federal Research Center (White Oak), MD e29

62. CPV Energy, St. Charles, MD e30

63. Iowa Fertilizer Company, Wever, IA c11

64. Klausner Holding, Enfield, NC p2

65. North Springfield Sustainable Energy, North Springfield, VT e31

66. Gateway Cogeneration, Prince George, VA e32

67. Calpine, Deer Park, TX [EPA] e33

68. WE Energies Elm Road, Milwaukee, WI e34

69. Energy Answers (permit revision to include GHG), MD e35

70. Chevron Phillips Chemical Co., Cedar Bayou Plant, Baytown, TX [EPA]c12

71. Capitol Power (PAL), Washington, DC [EPA] e36

72. Moxie Patriot, Clinton Township, Lycoming County, PA o12

73. Calpine, Channel Energy Center, Pasadena, TX [EPA] e37
17 

74. St. Joseph Energy Center, New Carlisle, IN e38

75. RockTenn-Solvay LLC, NY m5

76. Gerdau MACSTEEL, Monroe, MI m6

77. Equistar Chemicals, Methanol Unit, Channelview, TX [EPA] c13

78. Mid-Kansas Electric Co. – Rubart Station, KS e39

79. Sinclair Wyoming Refining, Sinclair, WY [EPA] r2

80. WBI Energy, Dakota Prairie, ND r3

81. Montana-Dakota Utilities, R.M. Heskett Station, Mandan, ND e40

82. Equistar Chemicals, La Porte, TX [EPA] c14

83. Gibson County Generating, Rutherford, TN e41

84. Magnetation, Reynolds, IN m7

85. Cargill Ethanol Plant, Fort Dodge, IA c16

86. Alcoa, Davenport Works, IA m8

87. Rio Grande Cement, Pueblo, CO mn9

88. LADWP Scattergood Generating Station, CA e42

89. Roxul USA, MS mn10

90. Energy Answers, Arecibo, PR [EPA] e43

91. Equistar Chemicals, Olefins 1 Expansion, Channelview, TX [EPA] c18

92. Equistar Chemicals, Olefins 2 Expansion, Channelview, TX [EPA] c19

93. Oregon Clean Energy Center, Oregon, OH e44

94. Green Bay Packaging, WI p3

95. Empire District Electric, KS e45

96. Hydrogen Electric California, Kern County, CA e46

97. Basin Electric Power, Pioneer Generating Station, ND e47

98. Kerr-McGee Gathering, CO o16

99. Consumers Energy, MI e48

100. Midland Cogen Venture, Midland, MI e49

101. Southern Minnesota Beet Sugar, MN [Delegated State]c20

102. Flint Hills Resources draft PSD permit- Rosemount, MN [Delegated State] r4

103. IPL Eagle Valley Generating Station, Martinsville, IN e50

104. Diamond Shamrock, Valero McKee Refinery, Sunray, TX [EPA] r5

105. Virginia Power and Light, Brunswick Plant, VA e51

106. Green Energy Partners – Stonewall Energy, VA e52

107. EN-Tire, White Deer Energy, PA e53

108. DSM Chemicals, GA c22

109. Klausner Holding, SC p4

110. Carroll County Energy, OH e55

111. Big River Steel, AR m10

112. La Paloma Energy Center, Cameron, TX [EPA] e56

113. Cargill –Blair, NE c23
18 

114. Nucor Steel, NE m11

115. Anchorage Municipal Power and Light, Sullivan Plant Two, AK e57

116. Puget Sound Energy, Fredonia, WA e58

117. Air Liquide Large Industries, Bayou Generation Plant, TX [EPA] c25

118. Crosstex Processing Services, Eunice Gas Extraction Plant, LA o18

119. Shintech Louisiana, LLC., Hydrochloric Acid Production Furnace, LA c26

120. Shintech Louisiana, LLC, Plaquemine PVC Plant, LA c27

121. Crosstex Proceesing Services, Plaquemine NGL Fractionation Plant, LA o19

122. Basin Electric Power, Lonesome Creek Generating, ND e59

123. Kraton Polymers U.S. LLC, OH c28

124. BP-Husky Refining, LLC, OH r6

125. TECO Polk Station, FL [EPA] e60

126. Frontier El Dorado Refining, LLC, KS r7

127. Holly Corporation SLC Refinery, UT r8

128. CPV Valley, NJ [Delegated State] e61

129. Texas Eastern Transmission, PA o20

130. Garrison Energy Center, DE e62

131. Berks Hollow Energy, Berks, PA e63

132. Hickory Run Energy, Lawrence, PA e64

133. Frederick County Waste to Energy, MD e65

134. Future Power of PA, PA e66

135. Progress Energy Carolinas, NC e67

136. DuPont Johnsonville, TN c29

137. Ohio Valley Resources, Spencer, IN c30

138. Nucor Steel, Montgomery County, IN m12

139. Renaissance Power, MI e68

140. Lima Refinery, OH r9

141. PCS Nitrogen Ohio, OH c31

142. Mid America Midstream, Rose Valley, OK o21

143. Rohm and Haas, Deer Park, TX [EPA] c32

144. Occidental Chemical, Chemical Plant, Ingleside, TX [EPA] c33

145. Celanese Clear Lake, TX [EPA] c34

146. CF Industries Nitrogen, Port Neal, IA c35

147. TradeWind Energy, Lacey Randall Station, KS e70

148. Dyno Nobel Ammonia Plant, Jefferson Co., LA c36

149. Sunbury Generation LLC, Sunbury, PA e71

150. Equistar Chemical, Olefins, Corpus Christi, TX [EPA] c37

151. FGE Power, Westbrook, TX [EPA] e75

152. Lenzing Fibers, Mobile, Alabama p5

153. University of Alaska, Fairbanks, Alaska e76
19 

154. Troutdale Energy Center, Multnomah County, OR e77

155. EFS Shady Hills Generating Station, FL [EPA] e78

156. New Hope Power Company Okeelanta Cogeneration [EPA] e79

157. Dow Chemical Freeport, TX [EPA] c38

158. Golden Spread Electric Cooperative, Antelope, TX [EPA] e80

159. Indeck Wharton Energy Center, TX [EPA] e81

160. Occidental Chemical Corporation, Ethylene Plant, Ingleside, TX [EPA] c39

161. PSEG Sewaren Generating, NJ [Delegated State] e82

162. Global Foundries, NY m13

163. Novelis Corporation, NY m14

164. C3 Petrochemicals, TX [EPA] o25

165. ONEOK Hydrocarbon, Mont Belvieu NGL Frac -3 & 4 [EPA] o26

166. Voestelpine, Portland, TX [EPA] m15

167. Formosa Plastics Corporation LDPE Plant, Point Comfort, TX [EPA] c40

168. Formosa Plastics Corporation Olefins Expansion, Point Comfort, TX [EPA] c41

169. Formosa Plastics Corporation Gas Turbines, Point Comfort, TX [EPA] e83

170. Invenergy Thermal Development, Goldsmith, TX [EPA] e84

171. OCI Beaumont, Nederland, TX [EPA] e85

172. Pinecrest Energy Center, Lufkin, TX [EPA] e86

173. Tenaska Roans Prairie Generating Station, Shiro, TX [EPA] e87

174. Green River Soda Ash , Green River, WY [EPA] mn11

175. Austin Energy Sand Hill Energy Center, Austin, TX [EPA] e88

176. CCI Corpus Christi, LLC, Nueces County, TX [EPA] o27

177. Natgasoline, LLC, Nederland TX [EPA] c42

178. Victoria Power Station, Victoria, TX [EPA e89]

179. Lon C. Hill Power Station, Corpus Christi, TX [EPA] e90

180. M&G Resins, PET Plant, Corpus Christi, TX [EPA] c43

181. M&G Resins, Utility Plant, Corpus Christi, TX [EPA] e91

182. Nuevo Midstream, Ramsey Gas Plant, TX [EPA] o28

183. Footprint Power, MA [Delegated State] e92

184. West Deptford Energy II, NJ [Delegated State] e93

185. FPL Lauderdale, FL e94

186. MS Silicon, MS mn12

187. Ember Clear, Adams Co., MS c44

188. Duke Energy, Lee Steam, SC e95

189. Cronus Chemicals Tuscola, IL [Delegated State] c45

190. Abengoa Bioenergy, Ethanol Expansion, IN c46

191. Jet Corr, Porter County, IN p6

192. Midwest Fertilizer, IN c47

193. Valero Renewables, MN [Delegated State] c48
20 

194. Middletown Energy, OH e96

195. Linde Gas North America, OH c49

196. DTE Marietta, OH e97

197. Packaging Corp of America, WI p7

198. El Dorado Chemical Company, AR c50

199. Hobbs Generating Station, NM e98

200. Iowa State University Power Plant, Story, IA e99

201. IPL Allant Energy, Marshalltown Generating Station, IA e100

202. Iowa Fertilizer Company (major mod to original permit), IA c51

203. Mid-American Energy, Walter Scott Energy Center, Unit 3, IA e101

204. Solvay Chemicals, WY c52

205. Berry Petroleum (permit 1), SJV District, CA o28

206. Berry Petroleum (permit 2), SJV District, CA o29

207. Berry Petroleum (permit 3), SJV District, CA o30

208. Vintage Petroleum (permit 1), SJV District, CA o31

209. Vintage Petroleum (permit 2), SJV District, CA o32 

210. E&B Natural Resources, SJV District, CA o33

211. McPherson Oil Company, SJV District, CA o34

212. Wild Horse GeoPower, Northern Sonoma district, CA e102

213. Sierra Pacific, Anderson, CA [EPA] p8

214. PGE Coyote Springs, OR e103

215. Guadalupe Power Partners, LP, Marion, TX [EPA] e104

216. Magellan Terminal Holdings, LP, Corpus Christi, TX [EPA] o35

217. Agrium, Kenai Nitrogen Operations, AK 

218. Black Hills Power, Pueblo Airport Generating Station, CO 

219. DCP Midstream, Lucerne Gas Processing Plant, Weld, CO 

220. Boise White Paper, Clark County, AL (major?) 

221. Georgia Pacific Breton LLC, Escambia County, AL 

222. Kerr-McGee Gathering, Lancaster Plant, Weld, CO

223. Montville Power, CT – 2010? 

224. Exxon Mobil Point Thomson, North Slope, AK – Issued 6/12/13 

225. Exxon Mobil Point Thomson, North Slope, AK – Issued 1/23/15 

226. Nucor, Decatur, AL 

227. Corpus Christi Liquefaction Plant, TX 

228. Colorado Bend Energy Center, Wharton Co., TX 

229. Jacksonville Lime, Duval County, FL 

230. Phillips 66 Lake Charles Refinery, Calcasieu, LA

231. Holland Board of Public Works, Ottawa, MI 

232. Wolverine Power, Presque Isle Co., MI 

233. CHS, Spiritwood Nitrogen Plant, Stutsman, ND 
21 

234. Abengoa BioRefinery, Ravenna, NE 

235. Abengoa BioRefinery, York, NE

236. General Electric Aviation, Evendale Plant, Hamilton, OH 

237. Koch Nitrogen, Enid Nitrogen Plant, Garfield, OK

238. Oiltanking Appelt Terminal, Harris Co., TX 

239. Moundsville Power, Marshall Co., WV 

240. FMC Granger Facility, Sweetwater Co., WV

241. Simplot Phosphates, Rock Springs Fertilizer Complex, WY 

242. DAKOTA PRAIRIE REFINERY, DAKOTA PRAIRIE REFINING, Stark, ND 

243. MAG PELLET LLC, White, IN 

244. Magnolia Nitrogen Idaho LLC, American Falls, ID c

245. Phillips 66 Company, Roxana, IL r

246. Huber Engineered Woods LLC - Broken Bow OSB Mill, McCurtain, OK p

247. Mid America Midstream Gas Services LLC - Buffalo Creek Processing Plant, Beckham, 

OK o

248. Western Farmers Elec Coop - Mooreland Generating Station, Woodward, OK e

249. Northstar Agri Ind Enid, Garfield, OK canola oil production

250. Jordan Cove Energy Project, L.P., OR e

251. SunCoke Energy South Shore, Inc., Greenup, KY coke production w/ elec gen

252. Cash Creek Generating Station, Henderson,KY e 

253. Cameron Interstate Pipeline LLC - Holbrook Compressor Station, Calcasieu Parish, LA o

254. Sundrop Fuels Louisiana - Rapides Station Facility, Boyce, LA biofuels

255. CCI Port Nickel - Braithwaite Methanol Plant, Plaquemine Parrish, LA c

256. South Louisiana Methanol - St. James Methanol Plant, St. James Parish, LA c

257. Methanex USA - Geismar Methanol Plant, Geismar, LA c

258. AM Agrigen Industries Fertilizer Plant, Kilona, LA c

259. Cheniere Creole Trail Pipeline LP - Gillis Compressor Station, Ragley, LA o

260. CF Industries - Donaldsonville Nitrogen Complex (Permit 772), Donaldsonville, LA c

261. Big Lake Fuels -Natural Gas to Gasoline Plant, Lake Charles, LA c

262. Cameron LNG - Cameron LNG Liquefaction project, Hackberry, LA o

263. Sasol North America - Lake Charles Cracker Project, Westlake, LA c

264. Columbia Gulf Transmission - Alexandria Compressor Station, Rapides Parish, LA o

265. Trunkline LNG - Lake Charles LNG Export Terminal, Lake Charles, LA o
22 

A.2 RBLC and State Web Site Permit Data 

State

2011 Summary Data 2012 Summary Data 2013 Summary Data 2014 Summary Data

PSD 

only

Data Source 

Chosen

PSD 

only

Data Source 

Chosen

PSD 

only

Data Source 

Chosen

PSD 

only

Data Source 

Chosen

AK 2 RBLC 3 RBLC 1 RBLC 1 RBLC

AL 3 State 1 State 3 State 1 State

AR 1 State 1 RBLC 4 State 2 State

AZ 1 State 1 RBLC 0 State 0 State

CA 6 State 3 State 1 State 2 State

CO 1 State 1 State 1 RBLC 3 RBLC

CT 1 State 0 State 0 State 0 State

DE 1 State 1 RBLC 1 State 0 State

FL 5 State 6 State 4 State 5 State

GA 3 State 6 State 4 State 3 State

HI 0 State 0 State 0 State 0 State

IA 1 RBLC 6 RBLC 2 State 1 RBLC

ID 0 State 0 State 0 State 1 State

IL 0 State 0 State 0 State 4 State

IN 3 State 6 State 10 State 12 State

KS 6 State 3 State 8 State 2 State

KY 0 State 0 State 1 State 1 RBLC

LA 32 State 24 State 35 State 26 State

MA 1 State 0 State 0 State 1 State

MD 1 State 1 State 2 State 4 State

ME 0 State 0 State 0 State 0 State

MI 6 State 4 State 9 State 6 State

MN 3 State 4 State 4 State 4 State

MO 0 State 1 State 0 State 0 State

MS 2 State 5 State 1 State 2 State

MT 0 State 0 State 0 State 0 State

NC 7 State 7 State 7 State 2 State

ND 2 State 2 RBLC 4 RBLC 1 RBLC

NE 0 State 5 State 7 State 2 State

NY 0 State 6 State 6 State 3 RBLC

NJ 0 State 2 State 0 State 0 State

NH 1 RBLC 0 State 0 State 0 State

NM 1 State 0 State 2 State 2 State

NV 1 State 0 State 1 State 0 State

OH 4 State 4 State 7 State 4 State

OK 1 State 8 State 10 State 3 State

OR 2 State 0 State 1 State 1 State

PA 1 State 1 State 6 State 1 State

RI 3 State 0 State 0 State 0 State

SC 2 State 6 State 3 State 6 State

SD 0 State 0 State 0 State 0 State

TN 0 State 6 State 1 State 0 State

TX 11 State 15 State 17 State 30 State

UT 2 State 0 State 1 State 0 State

VA 0 State 5 State 2 State 2 State

VT 0 State 1 State 1 State 1 State

WA 3 State 1 State 5 State 2 State

WI 7 State 7 State 4 State 7 State

WY 0 State 2 RBLC 3 RBLC 4 RBLC

WVA 0 State 0 State 0 State 1 State

Total 127 155 179 153

Four Year Annual Avg. = 153 PSD permits/yr
23 

Appendix B. Calculation for “Anyway” Permits Requiring GHG BACT Review 

GHG SER 

(tpy CO2e)

Number of 

"Anyway" Permits 

Requiring GHG 

BACT review 

# of Newly 

Constructed 

Facilities

# of 

Modifications 

0 103 28 75

30,000 88 28 60

45,000 81 28 53

75,000 66 28 38

Note: Total PSD permits/yr=153

 Total "anyway" permits with possible GHGs= 103 (153 X .67)

 Based on assumption that 33% of permits do not involve GHGs

Background Permit Info for Input to Excel Forecast Function:

GHG SER Number of "Anyway" Permits Requiring GHG BACT review 

0 103

75,000 66

Linear interpolation Excel Forecast Function results:

0 103

30,000 88

45,000 81

0

20

40

60

80

100

120

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

# of GHG BACT reviews

GHG SER (tpy CO2e) 

Number of "Anyway" Permits Requiring GHG 

BACT review 
24 

Appendix C. PSD and Title V Permitting Burden for Permitting Authorities and Sources

Table C-1. Average Permitting Authority Burden per PSD Permit

Permitting Authority PSD Activity

Hours per Permit

PSD Permits 

Non-GHGs 

Onlya

Anyway 

Permits with 

GHGsb

A. Attend Preapplication Meetings 49 54

B. Answer Respondent Questions 27 37

C. Log In and Review Data Submissions 21 31

D. Request Additional Information 8 13

E. Analyze for and Provide Confidentiality for Processing 24 24

F. Prepare Completed Applications for Processing 40 40

G. File and Transmit Copies 8 8

H. Prepare Preliminary Determination 38 48

I. Prepare Notices for and Attend Public Hearings 43 43

J. Application Approval 50 55

K. Notification of Applicant of PA Determination 8 8

L. Submittal of Information of BACT/LAER to RBLC 19 24

Total 335 385 a

Hours per permit reflecting the effects of the Flexible Air Permitting (FAP) Rule (ICR 1230.26) and the PM2.5 Increments, 

SILs, and SMC Rule (ICRs 2276.02; 1230.31). These ICRs were approved before the onset of permitting for GHGs. b

A permitting authority will need 50 additional hours for the GHG-related activities for a PSD permit for an “anyway” source. 

These 50 hours have been divided among the activities, emphasizing those most likely to be associated with BACT. 
25 

Table C-2. Average Source Burden per PSD Permit

Source PSD Activity

Hours per Permit

PSD Permits 

Non-GHGs 

Onlya

Anyway 

Permits with 

GHGsb

A. Preparation and Planning

Determination of Compliance Requirements 170 170

Obtain Guidance on Data Needs 120 240

Preparation of BACT Analysis 112 214

B. Data Collection and Analysis

Air Quality Modeling 260 260

Determination of Impact on Air Quality Related Values 130 130

Post-construction Air Quality Monitoring 65 65

C. Permit Application

Preparation and Submittal of Permit Application 60 60

Public Hearings 27 27

Revisions to Permit 40 40

Total Burden Hours 984 1206 a

Hours per permit reflecting the effects of the Flexible Air Permitting (FAP) Rule (ICR 1230.26) and the PM2.5 Increments, 

SILs, and SMC Rule (ICRs 2276.02; 1230.31). These ICRs were approved before the onset of permitting for GHGs.

b

A source will spend an additional 222 hours for the GHG-related activities for an “anyway” PSD permit. Anyway sources need 

an additional "120 hours to 'obtain guidance on data needs' and 102 hours for the 'preparation of BACT analysis.'” 

Table C-3. Average Permitting Authority Burden per Title V Permita

Permitting Authority Title V Activity

Hours per Permit

Title V Permit 

Non-GHGs Only

Title V Permit 

Adding GHGs

Permit Application Review 110 121

Draft Permit Preparation 170 187

Comment Period Notification 11 12

Hold Public Hearings (2% of permits) 110 121

Interaction with the EPA 20 22

Analyze Public Comments and Prepare Final Permit (2% of permits) 44 48

Permit Issuance 9 10

Total Hours to Issue New Title V Permit 474 521

Significant Permit Revision 94 103 a

Adapted from Table 2 and Attachment 2. Information Collection Request for State Operating Permit Regulations (Renewal), EPA 

ICR Number 1587.12, OMB Control Number 2060-0243, 2015.
26 

Table C-4. Average Source Burden per Title V Permita

Source Title V Activity

Hours per Permit

Title V Permit 

Non-GHGs Only

Title V Permit 

Adding GHGs

Prepare Application 330 363

Draft permits Interaction 50 55

Public Hearing Participation (2% of permits) 11 12

Total Hours to Obtain a New Title V Permit 391 430

Significant Permit Revision 84 92 a

Adapted from Table 2 and Attachment 2. Information Collection Request for State Operating Permit Regulations (Renewal), EPA 

ICR Number 1587.12, OMB Control Number 2060-0243, 2015.
United States

Environmental Protection 

Agency 

Office of Air Quality Planning and Standards

Health and Environmental Impacts Division 

Research Triangle Park, NC

Publication No. EPA-452/R-16-001 

September, 2015