### 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, Mi chael 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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5/13/2010 file://C:\Documents and Settin g s\ p lon g \Local Settin g s\Tem p \notesFCBCEE\~web5610.htme quality 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.ep a.gov; Wheeler.Carrie@epamail.epa.go v; 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 wi th your request to Michael ear lier this week, this version

of the RIA is being sent to you now for a quick scan by y ou 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 ar e some inconsistencies in the tables and prose in te rms of specific

numbers, we are looking at making t hose 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 charac terizations over the next day

or so.

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

meantime, we will continue to wo rk 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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