Fw: RE: draft tailoring rule RIA 

Michael Ling 

to: 

Pam Long 

05/13/2010 10:57 AM 

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OMB docket item #1 

 

Michael Ling 

Associate Director 

Air Quality Policy Division 

U.S. EPA - OAQPS 

(919) 541-4729 

-----Forwarded by Michael Ling/RTP/USEPA/US on 05/13/2010 10:57AM ----- 

To: Ron Evans/RTP/USEPA/US@EPA 

From: "King, Heidi R." <Heidi_R._King@omb.eop.gov> 

Date: 05/06/2010 06:05PM 

cc: Joseph Mangino/RTP/USEPA/US@EPA, Carrie Wheeler/RTP/USEPA/US@EPA, Linda 

Chappell/RTP/USEPA/US@EPA, Michael Ling/RTP/USEPA/US@EPA 

Subject: RE: draft tailoring rule RIA 

Linda et al,

I’m very impressed with the revisions to the structure of the RIA.

In case it helps, I know this is work in progress, but I’ll note a few things here (less to discuss next week, right?)

 This rule is Economically Significant, may want to make that clear in Section 7.  EO12866 “impacts” includes

benefits and transfers, not just costs.

 Baseline Section 2: Could we insert some bullets to explain simply how we estimated baseline?  For example,

the estimation steps might have been   1) Used ?? data to estimate sources for each category, categories are

defined by ?, then 2) calculated PTE from ? for each source category by ??, then 3) modified estimates (how?)

based on public comment.  Are there potentially other source categories omitted (worth mentioning)   Then,

uncertainties in this estimate:  perhaps that PTE is not defined for some of these sources?  Looks like this is in

Appendix B, but a summary would be very helpful in this chapter for folks to understand the baseline as they

read the RIA.

 Labeling the tables clearly:  Recommend we be very careful with this.  A threshold is a number, not an

inequality, right?  However if we’re talking about a set of sources above or below a threshold or level, then the

inequality is a good label for those sources higher or lower than the threshold (careful that we label with the

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equality in the right direction, depends on whether we’re talking about who is “relieved” or not relieved)

 Table 1 is very important; we may want to work to make this a little clearer (for example, eliminate

inequalities and parens and the words “final rule” since these are thresholds and this is the ria for final rule)

Wonderful revisions –thank you for your work on this, and for sharing an early draft to make sure we’re all

aligned as well as possible ‐‐  

heidi

From: Evans.Ron@epamail.epa.gov [mailto:Evans.Ron@epamail.epa.gov] 

Sent: Thursday, May 06, 2010 2:47 PM 

To: King, Heidi R. 

Cc: Mangino.Joseph@epamail.epa.gov; Wheeler.Carrie@epamail.epa.gov; Chappell.Linda@epamail.epa.gov; 

Ling.Michael@epamail.epa.gov 

Subject: draft tailoring rule RIA

 

Heidi, 

Enclosed is a revised version of the Tailoring rule RIA. Our team has taken your email request of last week to 

restructure the presentation significantly. Consistent with your request to Michael earlier this week, this version 

of the RIA is being sent to you now for a quick scan by you to assure that it's structure is in accordance with the 

flow you outlined in the email request. I think this version does show that. 

This draft still needs editing, there are some inconsistencies in the tables and prose in terms of specific 

numbers, we are looking at making those consistent now. There is some editing still to be done (some odd 

formatting of pages) and polishing of some discussions. This turned into a larger effort than we anticipated, as 

a result, we are likely to continue working on some of the explanations and characterizations over the next day 

or so. 

Please scan this version as soon as you can and let us know if we are on target in the restructuring. In the 

meantime, we will continue to work on the items I outlined above. 

Ron Evans 

Leader, Air Benefit & Cost Group 

HEID/OAQPS/OAR/EPA 

Mail Drop C-439-02 

919-541-5488 

919-541-0839 fax 

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