Fw: URGENT: Need to get full RIA over to OMB

Michael Ling 

to: 

Pam Long 

05/13/2010 11:06 AM 

Show Details 

OMB docket item 

 

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 11:05AM ----- 

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

From: Michael Ling/RTP/USEPA/US 

Date: 04/27/2010 12:15PM 

Subject: Fw: URGENT: Need to get full RIA over to OMB 

Ok Heidi - this is the RIA file I have. I verified that all three attachments are present - A, B, and 

C. The only thing that is not present are two "Appendices" to Attachment B. These Appendices 

are spreadsheets that only exist electronically (they are too large to print) and are highly 

technical in nature. If you want them we can send them, but I suspect what is here should 

suffice. 

(See attached file: RIAghgtailoring 041910 report_draft.doc)

Michael Ling 

Associate Director 

Air Quality Policy Division 

U.S. EPA - OAQPS 

(919) 541-4729 

Page 1 of 1

file://C:\Documents and Settings\plong\Local Settings\Temp\notesFCBCEE\~web5976.htm 5/13/2010
REGULATORY IMPACT ANALYSIS FOR 

THE FINAL GREENHOUSE GAS 

TAILORING RULE 

DRAFT - Final Report 

April 2010 

Linda M. Chappell, PhD 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Air Benefits and Cost Group 

109 TW Alexander Drive 

Research Triangle Park, NC 27711 

RTI International 

3040 Cornwallis Road 

Research Triangle Park, NC 27709 
 EPA 452/R-10-003 

 April 2010 

Regulatory Impact Analysis for the Final Greenhouse Gas Tailoring Rule 

Final Report 

Linda M. Chappell, PhD 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Air Benefits and Cost Group 

109 TW Alexander Drive 

Research Triangle Park, NC 27711 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Health and Environmental Impacts Division 

Research Triangle Park, NC 
iii 

CONTENTS 

Page 

1. Introduction .............................................................................................................................. 1 

1.1 Executive Summary......................................................................................................... 5

1.2 Organization of this Report.............................................................................................. 7

2. Regulatory Alternatives and Affected Entities ......................................................................... 8 

3. Regulatory Relief: Avoided Information Collection Costs .................................................... 14

3.1 Avoided Burden Costs for Title V................................................................................. 14

3.2 Avoided Information Collection Costs Associated with the NSR Program.................. 18

4 Impacts of Regulatory Relief.................................................................................................. 24

4.1 Method for Analyzing Avoided Economic and Small Entity Impacts .......................... 24

4.1.1 Identifying Affected Sectors and Entities ........................................................... 24 

4.1.2 Data Used to Characterize Affected Entities by Size.......................................... 25

4.2 Developing Economic and Small Entity Regulatory Relief Impact Measures.............. 39

4.3 Implementing the Sales Test to Measure Impacts on Industrial, Commercial, and 

Multifamily Residential Sources ................................................................................... 39

4.4 Economic Relief to Permitting Authorities.................................................................... 41

5. Social Costs............................................................................................................................. 59

6. References............................................................................................................................... 63

Attachment A: Source Categories Affected by the Rule with Industry Detail........................... 64

Attachment B: Technical Support Document for Greenhouse Gas Emissions Threshold 

Evaluation 

Attachment C: Summary of Methodology and Data Used to Estimate Burden Relief and 

Evaluate Resource Requirements at Alternative Greenhouse Gas Permitting 

Thresholds 
iv 

List of Tables 

Page 

1.0. Phase-In Steps for Large Sources for the Final GHG Tailoring Rule ................................ 2

2.0. Phase-In Steps for Large Sources for the Final GHG Tailoring Rule ................................ 8

2.1. Qualitative Description of Benefits and Cost of the Tailoring Rule................................. 11

2.2. Estimated Number of Affected Sources Experiencing Regulatory Relief for Final 

Rule and Regulatory Alternatives..................................................................................... 12

3.0. Annual Title V Regulatory Relief (Avoided Cost) Estimates for Affected Sources 

of GHG and Permitting Authorities at Alternative Thresholds ........................................ 15

3.1 Steps 1 and 2 Title V Regulatory Relief (Avoided Cost) Estimates for Affected Sources 

of GHG and Permitting Authorities at Alternative Thresholds.........................................19 

3.2. Annual PSD Regulatory Relief (Avoided Costs) for Sources of GHG and 

Permitting Authorities at Alternative Thresholds............................................................. 20 

3.3 Steps 1 and 2 PSD Regulatory Relief (Avoided Cost) Estimates for Affected 

Sources of GHG and Permitting Authorities at Alternative Thresholds ...........................23 

4.0. Number of Firms by Industry and Enterprise Size: 2002 ................................................. 26

4.1. Number of Establishments by Affected Industry and Enterprise Size: 2002 .................. 28

4.2. Number of Employees by Affected Industry and Enterprise Size: 2002......................... 30

4.3. Receipts by Industry and Enterprise Size: 2002 (in millions of 2007$).......................... 32

4.4. Number of Firms by Affected Industry and Enterprise Size in Commercial Sectors: 

2002................................................................................................................................... 34

4.5. Number of Establishments by Affected Industry and Enterprise Size: 2002 .................. 35

4.6. Number of Employees by Affected Industry and Commercial Enterprise Size: 

2002................................................................................................................................... 37

4.7. Receipts by Affected Industry and Enterprise Size: 2002 (Millions of 2007 $).............. 38

4.8. Avoided Title V Costs to Sales for Small Industrial Sources of GHG Emissions ........... 43

4.9. Avoided Costs to Sales for Small Modifying Industrial GHG PSD Emission 

Sources.............................................................................................................................. 46

4.10. Avoided Costs to Sales for Small New PSD Industrial GHG Sources............................. 48

4-11. Avoided Title V Permitting Costs to Sales for Permit Revisions Due to GHG ............... 50

4.12. Title V Avoided Costs for Small New Commercial Sources of GHG Emissions 

Compared to Annual Sales Revenue................................................................................. 53

4.13. Avoided Costs for Small Modifying Commercial PSD GHG Emission Sources 

Compared to Annual Sales Revenue................................................................................. 55

4.14. Avoided Costs to Small PSD New Commercial GHG Emission Sources........................ 57

A-1. Title V Sources Expected to Experience Regulatory Relief at Alternative Threshold 

Levels by Industry Category............................................................................................. 64

A-2. New PSD Sources Expected to Experience Regulatory Relief ........................................ 66

List of Figures 

Page 

1.0. Alternative States of Regulation Relating to the GHG Tailoring Rule .............................. 4
v 
1 

Section 1 

Introduction 

The Environmental Protection Agency (EPA) is finalizing a rule to phase in the major 

source applicability thresholds for greenhouse gas (GHG) emissions under the Prevention of 

Significant Deterioration (PSD) and title V programs of the Clean Air Act (CAA or Act) and to 

set a PSD significance level for GHG emissions (also referred to as the tailoring rule. EPA 

promulgated regulations under the CAA to control GHG emissions from light-duty motor 

vehicles (LDVR) that will result in PSD and title V requirements for GHG emissions taking 

effect on January 2, 2011.1

 

In the proposal to this rulemaking, EPA found that if PSD and title V requirements apply 

at the applicability levels provided under the CAA, State permitting authorities would be 

paralyzed by enormous numbers of permit applications; the amounts are orders of magnitude 

greater than the current inventory of permits and would vastly exceed the current administrative 

resources of the permitting authorities. Given this circumstance and relying on established legal 

doctrines published in the proposal notice, the proposal phased in PSD and title V applicability 

by temporarily establishing revised applicability thresholds for both the PSD and title V 

programs and temporarily establishing a PSD significance level. Concurrently EPA plans to 

conduct a study of the permitting authorities’ ability to administer the programs going forward 

and conduct a rulemaking to establish revised applicability levels or other methods for 

streamlining administration, all within 6 years of the effective date of this final action. 

At proposal, EPA identified as the pollutants subject to PSD and title V the group of up to 

six GHG emissions, each one weighted for its global warming potential (GWP), that are included 

in regulations for their control under the CAA. EPA also proposed to conform its action on PSD 

state implementation plans (SIPs) and title V programs to match the proposed Federal 

applicability requirements. In its proposed rule, EPA provided temporary regulatory relief for 

sources of GHG emissions below a level of 25,000 tons per year (tpy) CO2e (carbon dioxide 

equivalents) potential to emit (PTE). 

 

1

 EPA–HQ–OAR–2009–0472; NHTSA-2010-0059 RIN 2060-AP58; RIN 2127-AK50. April 1, 2010 Light-Duty 

Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards; Final Rule 

http://www.epa.gov/otaq/climate/regulations/ldv-ghg-final-rule.pdf 
2 

Public comments and other information received by EPA during the comment period 

following proposal confirmed EPA’s findings that applying the statutory PSD and title V 

thresholds for greenhouse gases (GHGs) may produce absurd results and is administratively 

infeasible during the next 6 years. After careful consideration of the numerous public comments 

and other information on the excessive burden of the proposal regulatory relief threshold for 

sources of GHGs and permitting authorities, this final rule establishes a stepped phase-in plan 

establishing thresholds and significance levels for title V and PSD applicability as follows in 

Table 1.0. 

Table 1.0. Phase-In Steps for Large Sources for the Final GHG Tailoring Rule1

PSD Title V 

Step 1: Phase in of Large Sources

(January 2, 2011 – June 30, 2011) 

(referred to as non-GHG trigger) 

Permitting based on emissions 

of non-GHG pollutants and, 

for BACT applicability with 

GHG emissions or GHG 

emission increases above 

75,000 tpy CO2e 

Sources with title V permits for nonGHG pollutants will address GHG 

as part of title V permitting 

Step 2: Phase In for Large Sources 

(July 1, 2011 – June 30, 2013) 

(referred to as 100,000 tpy CO2e threshold) 

Sources above 100,000 tpy 

(new) and 75,000 tpy (major 

modifications) of CO2e (and 

not already subject to PSD 

based on non-GHG) 

Sources that exceed 100,000 tpy 

GHG threshold will be required to 

obtain a title V permit if they do not 

already have one 

Step 3: Phase In for Large Sources 

(July 1, 2013 – April 30, 2016) 

Effective only after regulatory process 

An enforceable commitment 

to assess experience from 

Steps 1 and 2; commit to 

propose, consider comments, 

and promulgate potential Step 

3 (level will not go below 

50,000 tpy CO2e [new] and 

50,000 tpy CO2e [major 

modifications]) 

An enforceable commitment to 

assess experience from Steps 1 and 

2; commit to propose, consider 

comments, and promulgate potential 

Step 3 (level will not go below 

50,000 tpy CO2e) 

Final Phase 

Effective only after regulatory process 

EPA will take rulemaking 

action in 2016 or before to 

address small sources in light 

of the 5-year study 

EPA will take rulemaking action in 

2016 or before to address small 

sources in light of the 5-year study 

1

 Thresholds and significance levels are based on PTE. Best Available Control Technology (BACT) 

The primary GHG of concern directly emitted by human activities include CO2, methane 

(CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur 

hexafluoride (SF6). Different GHGs have different heat-trapping capacities. It is useful to 

compare them to each other through the use of the CO2e metric. This metric incorporates both 
3 

the heat-trapping ability and atmospheric lifetime of each GHG and can be used to adjust the 

quantities, in tons per year, of all GHGs relative to the GWP of CO2. When quantities of the 

different GHG are multiplied by their GWP, the different GHG can be summed and compared on 

a CO2e basis. Depending on which GWP values are used, the calculated GHG emissions on a 

CO2e basis will vary. 

In the United States, the combustion of fossil fuels (e.g., coal, oil, gas) is the largest 

source of CO2 emissions and accounts for 80 percent of total GHG emissions. More than half 

the energy-related emissions come from large stationary sources such as power plants, while 

about a third come from transportation. Of the six primary GHGs, four (CO2, CH4, N2O, and 

HFCs) are emitted by motor vehicles. Industrial processes (such as the production of cement, 

steel, and aluminum), agriculture, forestry, other land use, and waste management are also 

important sources of GHG emissions in the United States. These emissions are inventoried at a 

national level by EPA in the Inventory of U.S. Greenhouse Gas Emissions and Sinks.2 The 

entities affected by this rule are stationary GHG-emitting sources. 

We have completed a Regulatory Impact Analysis (RIA) that estimates the cost savings 

to sources and permitting authorities achieved by this rule. Figure 1.0 below depicts alternative 

states of regulation considered in analyzing the impacts of the tailoring rule in this RIA. As 

shown in Figure 1.0, the triggering event has occurred with the promulgation of the the LDVR 

and will become effective January 2, 2011. In this RIA, EPA considers alternative regulatory 

relief thresholds, as well as the consequences likely to occur if EPA takes no regulatory relief 

action in a state of regulation where GHG permit triggering exists. 

 

2

 For additional information about the Inventory of U.S. Greenhouse Gas Emissions and Sinks, and for more 

information about GHG, climate change, climate science, etc., see EPA’s climate change Web site at 

www.epa.gov/climatechange/. 
4 

Figure 1.0. Alternative States of Regulation Relating to the GHG Tailoring Rule 

We also note that for any of the thresholds analyzed, there is also a class of very large 

GHG-emitting sources and sources making modifications that will remain subject to PSD and/or 

title V for GHGs. We do not analyze the magnitude of the costs and benefits of PSD/title V 

regulation for those sources because they are, by definition, sources that are included in the 

baseline. Information in Appendix A shows that for title V, 50 new source permits, 448 permit 

revisions, and 2,614 permit renewals annually would need to modify these permits to include 

GHG emissions under Steps 1 and 2 of this final rule. Note that these sources would already be 

seeking a permit, revision, or renewal and are required to add GHG requirements to those 

GHG 

Permitting 

Triggered 

No 

Tailoring 

Rule 

Tailoring 

Rule 

No Action 

Case 

Baseline 

*Statutory 

limits become 

effective 

*Permitting 

authorities 

overwhelmed 

with permit 

applications, 

millions of 

new sources 

required to 

obtain permits 

Action Taken 

With Permit 

Trigger 

*RIA analyzed 

regulatory 

alternatives

*Significant 

reduction in 

facilities required 

to obtain permit 

and permitting 

authority burdens 

*Limited foregone 

GHG emission 

reductions 
5 

permits. Under Steps 1 and 2 of the phase-in, about 688 sources and modifications each year 

would trigger PSD for GHG. All of these sources would already be major for other pollutants. 

Under Step 2 of the phase-in, 172 new industrial and 18 new commercial and residential sources 

would require title V permits annually. Additionally, it is estimated that 20 industrial sources 

would require title V permit revisions due to GHG annually during Step 2. For PSD, under Step 

2, 20 new industrial sources and 4 commercial or residential sources are expected to trigger PSD 

permitting on an annual basis. These previously enumerated large GHG sources expected to 

trigger title V and PSD permitting during the period July 1, 2011, through June 30, 2013, are 

considered a part of the baseline for this RIA. Impacts to these sources are not addressed in this 

RIA, since these sources are not required to obtain permits because of the tailoring rule, but 

rather by the CAA and other regulatory actions. Likewise, these sources are not obtaining 

regulatory relief because of this final tailoring rule and are not analyzed as a part of this RIA. 

1.1 Executive Summary 

This RIA examines the benefits, costs, and economic impacts of the final rule for affected 

entities and society as a whole. This rule lifts, for a period of 6 years, the burden to obtain a title 

V operating permit required by the CAA for smaller existing sources of GHG and the burden of 

New Source Review (NSR) requirements for smaller new or modifying sources of GHG. Thus, 

this rule may be viewed as providing regulatory relief rather than regulatory requirements for 

these smaller GHG sources for a period of 6 years. For larger sources of GHG, there are no 

direct economic burdens or costs as a result of this rule, because requirements to obtain a title V 

operating permit or to adhere to NSR requirements of the CAA are already mandated by the Act 

and by existing rules and are not imposed as a result of this rulemaking. 

This rulemaking provides permitting thresholds for sources of GHG exceeding levels 

contained in the CAA, and these levels are phased in steps based on legal considerations of 

absurd results and administrative necessity. For Step 1 that occurs from January 2, 2011, 

through June 30, 2011, only sources required to undergo title V or PSD permitting based on nonGHG air pollutants are required to obtain an operating permit or PSD permit to include GHG 

emissions (referred to as Step 1 or Non-GHG Based threshold). Also, for PSD under Step 1, 

only those GHG emissions or emissions increases that equal or exceed 75,000 tpy CO2e at those 

non-GHG permitted projects are required to be subject to PSD review. Step 2, effective from 

July 1, 2011, until such time as EPA acts on a rule to replace it (which for reasons described 
6 

above in Table 1, we assume is June 30, 2013, for the purposes of this analysis), requires larger 

sources with GHG emissions equal or exceeding 100,000 CO2e tpy PTE to obtain a title V 

permit (if they do not already have one) and to comply with PSD requirements (100,000 CO2e 

tpy PTE major source applicability threshold and 75,000 CO2e tpy PTE significance level). 

Thereafter, EPA makes an enforceable commitment to consider a possible Step 3 to further lower 

thresholds below 100,000 CO2e tpy, but only after a regulatory process is conducted addressing 

administrative necessity and absurd results considerations based on the actual permitting 

experiences in the first two steps of the phase-in. In addition, EPA provides a deferral of 

permitting until April 2016 for sources and modifications that emit below 50,000 CO2e tpy PTE. 

The deferral will end when a required study is conducted of the permitting process for sources of 

GHG and EPA acts, based on the study, to promulgate a rule that describes the additional GHG 

permitting requirements beyond 2016. In the 6 years following promulgation of this rule, we 

estimate that, compared to baseline estimates that do not include the effects of this rule, over six 

million sources of GHG emissions will be allowed to operate without a title V operating permit 

and tens of thousands of new sources or modifying sources per year will not be subject to PSD 

requirements for GHG. The emissions from these sources amount to approximately 11 percent 

of all GHG from stationary sources (<100,000 CO2e tpy PTE threshold), but represent 95 percent 

of the total number of stationary sources. For this large number of smaller sources, this rule 

alleviates the regulatory burden associated with obtaining an operating or PSD permit or 

complying with NSR BACT requirements. Therefore, this final action may be considered 

beneficial to these small sources as it provides relief from regulation that would otherwise be 

required. 

The benefits associated with this rulemaking in terms of avoided information collection 

and permitting costs for sources and permitting authorities amount to approximately $77 billion 

annually for the period January 2, 2011, through June 30, 2013, for Steps 1 and 2 of the phase-in 

period. Thereafter, EPA will conduct another rulemaking to determine the threshold levels based 

on the experience gained during the initial Steps 1 and 2. However, EPA has committed that this 

threshold will not decline below 50,000 tpy CO2e PTE for the period until 2016. We also plan to 

complete a further analysis of the implications of reducing the thresholds for GHG for permitting 

authorities and sources and to conduct a regulatory process prior to reducing this threshold below 

50,000 tpy CO2e PTE after 2016. The costs to society of this rulemaking relate to potential GHG 
7 

emission reductions that are foregone during this phase-in period, and these costs are discussed 

qualitatively in this RIA.

1.2 Organization of this Report 

The remainder of this report supports and details the methodology and the results of this 

illustrative RIA. 

 Section 2 presents a discussion of regulatory alternatives and affected entities. 

 Section 3 describes the regulatory relief or avoided information collection costs. 

 Section 4 describes the methodology and the estimated economic impacts of the 

regulatory relief. 

 Section 5 provides a qualitative description of social costs of the rule. 

 Section 6 lists the references for the analyses included in this RIA. 
8 

Section 2 

Regulatory Alternatives and Affected Entities 

As previously stated, this final rule is essentially providing regulatory relief and does not 

include direct regulatory provisions for any industrial, commercial, or residential entities. An 

analysis is presented for smaller sources that experience regulatory relief. This rule increases the 

GHG applicability threshold for title V from 100 CO2e tpy and for new and modifying sources of 

GHG emissions from the CAA mandated 100 or 250 tpy CO2e3

 major source applicability 

threshold in a phased-in step process described in Table 2.0. 

Table 2.0. Phase-In Steps for Large Sources for the Final GHG Tailoring Rule1

PSD Title V 

Step 1: Phase-in of Large Sources

(January 2, 2011 – June 30, 2011) 

(referred to as non-GHG trigger) 

Permitting based on emissions 

of non-GHG pollutants and, 

for BACT applicability with 

GHG emissions or GHG 

emission increases above 

75,000 tpy CO2e 

Sources with title V permits for nonGHG pollutants will address GHG 

as part of title V permitting 

Step 2: Phase in for Large Sources 

(July 1, 2011 – June 30, 2013) 

(referred to as 100,000 tpy CO2e threshold) 

Sources above 100,000 tpy 

(new) and 75,000 tpy (major 

modifications) of CO2e (and 

not already subject to PSD 

based on non-GHG) 

Sources that exceed 100,000 tpy 

GHG threshold will be required to 

obtain a title V permit if they do not 

already have one 

Step 3: Phase in for Large Sources 

(July 1, 2013 – April 30, 2016) 

Effective only after regulatory process 

An enforceable commitment 

to assess experience from 

Steps 1 and 2; commit to 

propose, consider comments, 

and promulgate potential Step 

3 (level will not go below 

50,000 tpy CO2e [new] and 

50,000 tpy CO2e [major 

modifications]) 

An enforceable commitment to 

assess experience from Steps 1 and 

2; commit to propose, consider 

comments, and promulgate potential 

Step 3 (level will not go below 

50,000 tpy CO2e) 

Final Phase 

Effective only after regulatory process

EPA will take rulemaking 

action in 2016 or before to 

address small sources in light 

of the 5-year study 

EPA will take rulemaking action in 

2016 or before to address small 

sources in light of the 5-year study 

1

 Thresholds/significance levels are based on PTE. 

The rules also sets GHG significance levels for each step under PSD to determine applicability 

as it relates to GHG emissions or emission increases for projects at major sources. 

 

3

 The relevant CAA thresholds for PSD major source applicability are 250 tpy of pollutant for general source 

categories and 100 tpy for 28 specifically listed PSD source categories. 
9 

For the initial phase-in Step 1, only title V and new PSD sources already applying for 

permits due to air pollutants other than GHG emissions are required to obtain a permit. New 

PSD sources required to obtain permits for GHG must also comply with BACT requirements for 

GHG. However, under Step 1, only modification projects or sources with GHG emissions or 

emission increases that equal or exceed 75,000 tpy CO2e PTE are required to comply with BACT 

requirements for GHG emissions. During Step 2 of the phase-in, sources at or above 100,000 

tpy CO2e PTE are required to a obtain title V permit. Likewise, new sources at or above the 

100,000 tpy CO2e PTE and modifying sources with PTE at or above 75,000 tpy CO2e are 

required to comply with the requirements of NSR. After the initial two steps of the phase-in, 

EPA will determine whether a Step 3 lowering thresholds below 100,000 tpy CO2e PTE 

beginning July 2013 is feasible. However, in this final rule, the Agency is making an 

enforceable commitment to conduct a regulatory-setting process to consider the experience 

during the initial steps prior to lowering the threshold in a further Step 3. EPA also commits to 

not lowering the threshold below 50,000 tpy CO2e PTE until 2016. EPA will also conduct a 

study of permitting processes at existing levels in the next 5 years and determine whether 

thresholds cans be lowered below 50,000 tpy CO2e PTE after another regulatory process. 

The information on the number of affected sources enumerated in this RIA is based on 

emission estimates that represent a facility’s PTE. PTE is defined as the maximum capacity of a 

stationary source to emit a pollutant under its physical and operational design, including certain 

legal limitations, for example, on emissions or hours of operation. NSR and title V programs 

both use PTE for defining major sources. This is a particularly relevant concern for determining 

the number of facilities in the commercial and residential sectors that may be affected, where 

CO2 emissions are primarily due to space heating/appliance usage and the combustion units are 

not likely to be used constantly at their maximum rated capacity. Our basis for these PTE 

adjustments in the residential and commercial sectors is information on heating equipment and 

appliance usage in these sectors, and resulted in a range of upwards adjustment of six to ten 

times the actual-based emission values. A full description of the basis of these PTE adjustments 

can be found in Attachment B, Technical Support Document for Greenhouse Gas Emissions 

Threshold Evaluation. In all cases where thresholds and significance levels are discussed in this 

report, these emission levels are based on PTE. 
10 

The rationale for finalizing the previously described thresholds in the tailoring rule is 

based in part on our review of the costs and benefits associated with the different thresholds 

evaluated and described in this RIA. However, the primary basis for choosing the threshold 

enumerated in Table 2.0 is to ensure consistency with the legal doctrines set forth in the 

preamble of the tailoring rule. To apply the statutory PSD and title V applicability thresholds to 

sources of GHG emissions would create immediate and insuperable administrative burdens for 

permitting authorities and perhaps absurd results. By establishing the applicability thresholds at 

the levels for the first and second steps of the phase-in period, we would avoid an 

administratively impossible scenario where each year tens of thousands of new sources and 

modifications would become subject to PSD review, and, in total, millions of sources would 

require title V operating permits. We used the results of this RIA to support the threshold 

decisions, which we believe would result in a variance from existing statutory permitting 

thresholds that would—consistent with the supporting legal rationale—be as limited as possible 

and with consideration given to costs and benefits as described in this RIA. 

Table 2.1 describes qualitatively the benefits, costs, and economic impacts analyzed for 

regulatory alternatives in this RIA. As shown in Table 2.1, leaving the CAA thresholds 

unchanged for sources of GHG emissions is the baseline or no action alternative that will render 

this tailoring rule as having no impact on sources or permitting authorities beyond the current 

CAA requirements. Thus, this is a regulatory alternative with zero benefits and zero costs. Under 

this alternative, small and large sources of GHG emissions will be required to obtain title V 

operating and PSD permits as mandated by the Act. Although this alternative is considered for 

analytical completeness, its impact is essentially the same as no GHG tailoring rule and no 

further discussion of this alternative is considered in this document. In addition to the ”no 

tailoring rule” alternative, this RIA examines Step 1 and 2 thresholds of the phase-in final rule, 

as well as a less than 50,000 tpy CO2e threshold (minimum level for potential Step 3) and a less 

than 25,000 tpy CO2e threshold (proposal threshold level) regulatory alternatives. 

The benefits of this rule (and the alternatives considered) are the costs avoided at smaller 

sources by increasing the threshold levels above current CAA requirements as reflected in 

Table 2.1. Under this final rule, millions of title V sources in total and thousands of NSR 

sources annually are afforded regulatory relief. For each of the regulatory alternatives increasing 

the threshold above statutory levels, the benefits of this tailoring rule are primarily the avoided 
11 

permitting costs for affected small sources of GHG emissions. The permitting costs avoided by 

small sources are quantified for the final rule Step 1 and 2 thresholds and each of the regulatory 

alternatives in Section 3 of this document. The avoided costs associated with compliance with 

Table 2.1. Qualitative Description of Benefits and Cost of the Tailoring Rule 

Description 

No Action 

Alternative 

(Thresholds 

Remain at 

100/250 tpy)1

Alternative 

(Proposal) 

<25,000 tpy 

GHG Emission 

Threshold2

Alternative 

<50,000 tpy 

GHG Emission 

Threshold2

Step 2 <100,000 

tpy 

GHG Emission 

Threshold2

Step 1 

Non-GHG 

Based 

Threshold2 

Benefits 

(Regulatory 

relief—avoided 

permitting 

requirements 

and associated 

costs) 

No avoided 

permitting costs 

(i.e., over 6 

million title V 

sources in total 

and over 80 

thousand PSD 

small new and 

modifying GHG 

sources annually 

(over 240 

thousand PSD 

sources during 

Steps 1 and 2) 

remain subject to 

programs) 

Avoid 

permitting costs 

for 6.098 

million title V 

sources in total 

and for 72.3 

thousand new 

and modifying 

PSD sources 

annually 

(or 216.9 

thousand PSD 

sources during 

the Steps 1 and 

2 time period) 

Avoid 

permitting costs 

for 6.102 

million sources 

in total and for 

79.7 thousand 

new and 

modifying PSD 

sources annually 

(or 239.1 

thousand PSD 

sources during 

the Steps 1 and 

2 time period) 

Avoid 

permitting costs 

for 6.105 

million sources 

in total and for 

80.7 thousand 

new and 

modifying PSD 

sources annually 

(or 242.1 

thousand PSD 

sources during 

the Steps 1 and 

2 time period) 

Avoid 

permitting costs 

for 6.106 

million sources 

in total and for 

81.6 thousand 

new and 

modifying PSD 

sources annually 

(or 244.8 

thousand PSD 

sources during 

the Steps 1 and 

2 time period) 

Social Costs 

(Foregone 

emission 

reductions due 

to regulating 

GHG sources) 

No foregone 

emission 

reductions 

Foregone GHG 

emission 

reductions for 

affected sources 

(addressed 

qualitatively) 

Foregone GHG 

emission 

reductions for 

affected sources 

(addressed 

qualitatively) 

Foregone GHG 

emission 

reductions for 

affected sources 

(addressed 

qualitatively) 

Foregone GHG 

emission 

reductions for 

affected sources 

(addressed 

qualitatively) 

Economic 

Impacts 

(Avoided costs 

compared to 

annual sales or 

revenue data for 

affected 

sources)

No avoided costs Impact of 

avoided costs 

(benefits) 

compared to 

annual sales 

revenues of 

affected sources 

Impact of 

avoided costs 

(benefits) 

compared to 

annual sales 

revenues of 

affected sources 

Impact of 

avoided costs 

(benefits) 

compared to 

annual sales 

revenues of 

affected sources 

Impact of 

avoided costs 

(benefits) 

compared to 

annual sales 

revenues of 

affected sources 

1 This table recognizes that triggering for GHG permitting has occurred with promulgation of the LDVR. Because 

of this event, sources with the potential to emit 100 tpy CO2e are required to obtain a title V permit and new or 

modifying sources with the potential to emit 250 tpy are required to obtain a PSD permit as mandated by the CAA. 

If current threshold levels in the CAA remain unchanged for GHG emissions, the tailoring rule has no effect on 

sources or permitting authorities and provides no regulatory relief to sources or permitting authorities. 2 Promulgated Steps 1 and 2 thresholds and alternative regulatory thresholds are shown. Threshold levels represent 

PTE levels for affected sources. Sources affected, enumerated above, represent sources, permits, or actions. 

Alternative <50,000 tpy CO2e is the minimum threshold level to be considered for a possible Step 3. 
12 

BACT requirements for PSD new and modifying sources are not addressed in this RIA because 

of lack of sufficient data to estimate BACT requirements for affected GHG sources. 

The industry categories for sources anticipated to experience regulatory relief at the 

threshold levels finalized in this regulation are shown in Table 2.2. As Table 2.2 shows, this 

action lifts permitting requirements for over 6 million potential title V sources in total and tens of 

thousands of potential NSR new and modifying sources annually otherwise required by the CAA 

Table 2.2. Estimated Number of Affected Sources Experiencing Regulatory Relief for 

Final Rule and Regulatory Alternatives1, 2, 3

Number of Sources Experiencing Regulatory Relief 

< 25,000 CO2e tpy <50,000 CO2e tpy

Final Rule: Step 2

<100,000 CO2e tpy

Final Rule: Step 1

Non-GHG Based

Sector Title V New PSD Title V New PSD Title V New PSD Title V New PSD

Electricity 161 20 285 29 285 33 285 93 

Industrial 166,908 574 168,976 586 170,654 599 170,910 604 

Energy 2,401 23 2,513 38 2,536 44 2,588 48 

Waste Treatment 1,431 0 2,448 1 3,165 1 3,358 2 

Agriculture 37,351 299 37,351 299 37,351 299 37,351 299 

Commercial 1,354,760 12,034 1,355,321 12,038 1,355,870 12,039 1,355,921 12,041 

Residential 4,535,340 6,912 4,535,480 6,915 4,535,500 6,915 4,535,500 6,915 

Totals 6,098,352 19,862 6,102,374 19,906 6,105,361 19,930 6,105,913 20,002 

% Emissions Covered4 3% 8% 11% 13% 1

 Number of sources is determined on a PTE basis. Estimates for PSD sources are for newly constructed facilities 

and do not include modifications at existing facilities that may also be subject to PSD requirements. Sources’ 

estimates shown above represent the total number of title V sources potentially afforded regulatory relief during 

Step 1 and 2 of the phase-in period. In contrast, for new PSD sources, the estimates shown are the annual estimates 

of permits avoided for new small PSD GHG sources.

2 See Attachment B for more details of how thresholds and sources affected were developed. 

3

 The “no tailoring rule” alternative is not included since the number of sources experiencing regulatory relief for 

this regulatory alternative is by definition zero. 

4 Percentage of emissions covered represents estimated actual emissions from sources expected to experience 

regulatory relief as a percentage of total stationary source GHG emissions. 

to obtain permits. The estimates for title V sources represent the total number of sources afforded 

regulatory relief by this rule and for regulatory alternatives. In contrast, the estimates shown for 

PSD represent the annual estimate of new PSD sources expected to experience regulatory relief 

from this rule. For additional industry details including applicable affected industry North 

American Classification System (NAICS) codes see Attachment A “Source Categories Affected 

by the Rule with Industry Detail.” 

EPA considered a number of factors involving administrative burden and necessity in 

finalizing the thresholds for this rule, including comments received in response to the proposed 
13 

rule. After considering the comments regarding the number of affected sources at various 

thresholds, EPA revised its estimates of sources potentially required to obtain permits 

significantly increasing the number of affected sources at the alternative threshold/significance 

levels. 

When comparing the regulatory alternatives for revised affected sources at alternative 

thresholds as discussed above, there are differences between them. The reason the thresholds 

and significance levels are chosen as shown in Table 2.0 for Steps 1 and 2 of the phase-in period 

with an additional Step 3 to be considered only after a subsequent regulatory process is because 

permitting authorities cannot immediately accommodate a huge increase in permitting. The 

thresholds chosen for Steps 1 and 2 are chosen over the proposal level of 25,000 tpy CO2e, 

because evidence suggests that permitting authorities can run programs for the levels of 

permitting that would be required Steps 1 and 2, and EPA believes legal doctrine requires the 

threshold to be as low as administratively feasible. The choice of a threshold is a balancing act 

of administrative considerations between threshold levels that EPA feels are not administratively 

feasible at this time (i.e., 25,000 tpy CO2e potential to emit threshold) compared to threshold 

levels that are not impossible such as the Step 1 non-GHG based threshold and the Step 2 

<100,000 tpy CO2e threshold achieving a reasonable balance. For more information on the 

process used to determine the appropriate thresholds/significance levels for Steps 1 and 2 of the 

phase-in period, see Attachment B. 
14 

Section 3 

Regulatory Relief: Avoided Information Collection Costs 

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

sources of GHG that will be postponed as a result of this rulemaking. This analysis focuses on 

the burdens that are being lifted for smaller sources as a result of this rule. In addition, an 

accounting of the avoided costs to State, local, and tribal permitting authorities is provided. 

These avoided costs relate specifically to information collection costs or burden costs for sources 

of GHG emissions that would have been required to obtain an operating permit under title V or 

required to modify an existing permit to address GHG if not for this rule. Avoided costs shown 

also include information collection requirements for additional PSD permits required for new or 

modifying sources of GHG, as well as the costs to State, local, and tribal permitting authorities 

for extending their existing permitting programs to include sources of GHG. These avoided 

costs do not include the cost of modifying and new source compliance with BACT because of 

the lack of available data. 

Time and costs associated with permit activities are derived from existing Information 

Collection and Reporting (ICR) EPA documents for title V and NSR as described below. 

Significant uncertainties exist in the following estimates because of the lack of historical record 

and permitting experience on which to base resource needs to consider sources of GHG 

emissions in permitting. 

3.1 Avoided Burden Costs for Title V 

Under Step 1 of the phase-in, major sources of GHG that would otherwise be required to 

obtain an operating permit due to emissions of non-GHG pollutants are required to include GHG 

in permit requests. During this period, sources other than those obtaining permits for non-GHG 

pollutants will experience regulatory relief. Under Step 2, sources below 100,000 tpy CO2 e PTE 

will experience regulatory relief, while sources above this threshold will be required to obtain 

operating permits. Table 3.0 shows the estimated annual permitting cost or burden cost avoided 

for sources subject to title V experiencing regulatory relief during the period January 2, 2011, 

through June 30, 2013, as well as for two other regulatory alternatives. The alternatives shown 

are a threshold of <50,000 tpy CO2 e PTE (the minimum threshold for a possible Step 3) and 

<25,000 tpy CO2 e PTE (the proposal threshold level). Estimates shown are 
15 

Table 3.0. Annual Title V Regulatory Relief (Avoided Cost) Estimates for Affected Sources of GHG and PAuthorities at Alternative Thresholds1,2,3 

Regulatory Alternative 

<25,000 CO2e tpy 

Regulatory Alternative 

<50,000 CO2e tpy 

Final Rule: Step 2 

<100,000 CO2e tpy 

Activity

Cost per 

Permit 

(2007$)

Number 

of 

Permits 

Avoided 

Costs 

(millions 

2007$) 

Number 

of 

Permits 

Avoided 

Costs 

(millions 

2007$) 

Number of 

Permits 

Avoided 

Costs 

(millions 

2007$) 

Sources New Industrial $46,350 69,726 $3,231.8 70,848 $3,283.8 71,829 $3,329.3 New Commercial/Residential $23,175 1,985,504 $46,014.1 1,985,740 $46,019.5 1,985,930 $46,023.9 Permit Revisions due to GHG $1,677 52,639 $88.3 59,930 $100.5 60,921 $102.2 Source Total 2,107,869 $49,334.1 2,116,518 $49,403.8 2,118,508 $49,455.4 Permitting Authority New Industrial $19,678 69,726 $1,372.1 70,848 $1,394.2 71,829 $1,410.1 New Commercial/Residential $9,839 1,985,504 $19,535.4 1,985,740 $19,537.7 1,985,930 $19,539.6 Permit Revisions due to GHG $1,840 52,639 $96.9 59,930 $110.3 60,921 $112.1 Permitting Authority Total 2,107,869 $21,004.3 2,116,518 $21,042.1 2,118,508 $21,061.7 Total Title V Regulatory Relief $70,338.4 $70,446.0 $70,517.1 Percentage of Emissions Covered3 3% 8% 11% 

1 Avoided costs shown represent the annual estimates of the regulatory burden relief from this rule and for regulatory alternatives for ov

GHGs (about 1/3 of the total number of title V sources expected to obtain regulatory relief. See Appendix B and C for more details.) S

rounding. 

2 These estimates are explained in more detail in Attachment C “Summary of Methodology and Data Used to Estimate Burden Relief an

Requirements at Alternative Greenhouse Gas Permitting Thresholds.” 

3 Percentage of emissions covered represents estimated actual emissions from sources expected to experience regulatory relief as a perc

source GHG emissions. 
16 

the annual portion of regulatory relief expected to occur for small GHG sources and permitting 

authorities due to this final rule and equate to regulatory relief for approximately 2 million title V 

sources.

As shown on Table 3.0, the cost for a new industrial source to obtain an operating permit 

for GHG is $46,350 per permit. Over 71,000 industrial sources are likely to benefit from this 

rule because of the postponement of permitting requirements under Steps 1 and 2 of the phase-in 

period annually. Approximately 61,836 industrial sources annually will be allowed to postpone 

permit revisions for GHG at an avoided cost of $1,677 per permit revision under the non-GHG 

based Step 1. The estimate of industrial sources avoiding permit revisions becomes 60,921 

annually under Step 2, the less than 100,000 tpy CO2e threshold. The burden cost to obtain a 

new commercial or multifamily residential operating permit is approximately $23,175 per permit 

with about 2.0 million of these sources annually benefiting from this rule by avoiding these costs 

for a period of at least 6 years. The total regulatory relief or benefits for smaller sources of GHG 

amount to approximately $49.5 billion per year under Steps 1 and 2 of the phase-in period. All 

estimates are shown in 2007 dollars. Avoided costs for sources at regulatory alternative threshold 

levels of <50,000 tpy and <25,000 tpy CO2e are also presented in Table 3.0. 

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

the administrative burden of processing over 2 million title V operating permits for small 

industrial, commercial, and residential sources of GHG annually. Avoided permitting cost 

estimates for permitting authorities and sources are calculated based on information obtained 

from the April 2007 Information Collection Request for State Operating Permit Regulations,4

Annual values are derived from Tables 7 and 8 of this document. For consistency, the permitting 

authority labor costs are updated to 2007 dollars using the 2007 General Schedule Salary Table

from the Office of Personnel Management. For the purposes of this analysis, we assume that 

commercial/residential sources that exceed the major source threshold due to GHG emissions 

will not likely have as substantial applicable permitting cost requirements as industrial 

sources. We assumed that permits for such sources will require only one half the time to prepare 

and issue as those for industrial sources, which have applicable requirements in addition to GHG. 

Therefore, it is estimated that new commercial/residential permits require 50 percent of the time 

 

4

 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.07, 

OMB Control Number 2060-0243, 2007. 
17 

needed for new industrial permits, or 214 hours compared to 428 hours for permitting authorities. 

For significant revisions and permit renewals, it is assumed that incorporating GHG information 

adds 40 hours, or an additional 10 percent to the current updating and processing time. For more 

information on the methods used to calculate permit processing costs for permitting authorities 

for title V permitting, see Attachment C, “Summary of Methodology and Data Used to Estimate 

Burden Relief and Evaluate Resource Requirements at Alternative Greenhouse Gas Permitting 

Thresholds.” 

The cost savings for permitting authorities relating to title V are summarized in Table 3.0 

and are estimated to exceed $21 billion annually. Costs avoided annually for permitting 

authorities at alternative threshold levels other than Steps 1 and 2 are also shown on Table 3.0. 

All avoided cost estimates are stated in 2007 dollars. 

This rule specifies a phased-in step approach to establish title V and PSD thresholds. For 

this reason, it is appropriate to assess the regulatory relief during the various steps of the phase-in 

period in addition to looking at regulatory relief on an annual basis as previously discussed. 

Since thresholds for only Steps 1 and 2 are promulgated in this rulemaking with a potential Step 

3 to be considered only after subsequent rulemaking, we calculate the regulatory relief possible 

for a three year period, the approximate time period covered by Steps 1 and 2 of this tailoring 

rule. Considering the regulatory relief for a three year period allows us to evaluate alternative 

regulatory relief based not only on threshold levels, but also based upon the timing of the steps of 

the phase-in period. Table 3-1 presents the three-year regulatory relief for title V based upon 

alternative regulatory thresholds and the timing of the phase-in steps. Alternatives of <25,000 

tpy CO2e, <50,000 tpy CO2e, <100,000 tpy CO2e, and the non-GHG based thresholds are 

evaluated as if they were implemented for the entire three year period. The <25,000 tpy CO2e 

and the non-GHG based threshold regulatory relief shown represent the bounding estimates for 

regulatory relief for these threshold alternatives as well as alternative timings of the steps. If the 

<25,000 tpy CO2e threshold were imposed for Steps 1 and 2 of the phase-in, regulatory relief or 

avoided title V permitting costs for sources and permitting authorities would amount to 

approximately $211,015.2 million for a three year period. Alternatively if the non-GHG based 

threshold were imposed for a three year period, the regulatory relief would be $211,572.9 for 

sources and permitting authorities during the first three years of the phase-in period. The final 

tailoring rule promulgated, establishes the non-GHG based threshold for Step 1 and <100,000 
18 

tpy CO2e threshold for Step 2. The total regulatory relief for the final rule for the three year 

period for title V is estimated to be $211,554.9 million. Altering Step 2 to be <25,000 tpy CO2e 

and <50,000 tpy CO2e with Step 1 as the non-GHG based threshold would result regulatory 

relief estimates for the three year period of $211,108.2 million and $211,377.2 million, 

respectively. All estimates are in 2007$.

3.2 Avoided Information Collection Costs Associated with the NSR Program 

This rulemaking limits the new sources requiring PSD permits for Step 1 to those that 

would be required to comply with PSD for non-GHG emissions. For modifying sources, the 

significance level requiring permits is 75,000 or greater tpy CO2e PTE. In Step 2 of the phase-in 

period, the threshold becomes 100,000 tpy CO2e PTE or greater for new sources and the 

significance level for modifying sources remains at 75,000 or greater tpy CO2e. Table 3.2 

summarizes the estimated benefits to small GHG sources resulting from this final rule. Annual 

regulatory relief for Steps 1 and 2 of the phase-in period, as well as additional alternative 

regulatory thresholds, are depicted on Table 3.2. The estimated annual burden or permit-related 

costs avoided by small GHG sources amount to around $5.5 billion annually during Step 1 and 

$5.4 billion during Step 2 with the burden costs per permit expected to be $131 thousand for new 

sources, $84.5 thousand for modified industrial sources, $82.3 thousand for new commercial or 

residential sources, and $59.2 thousand for modifying commercial and residential sources. State, 

local, and tribal permitting authorities are expected to avoid administrative costs of $1.5 billion 

under Step 1 and $1,485 million under Step 2 annually. 

Burden estimates for the PSD program permitting authorities are calculated based on 

listed values obtained from Tables 6-1 and 6-2 on pages 18-19 in the Information Collection 

Request for Prevention of Significant Deterioration and Nonattainment New Source Review 

August 2008 (ICR).5

 As shown in Table 3.2, State, local, and tribal permitting authorities are 

estimated to expend $23,243 per permit to process a new GHG industrial PSD 

 

5 Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 123.23, 

OMB Control Number 2060-0003, 2008.
19 

 Table 3-1. Steps 1 and 2 Title V Regulatory Relief (Avoided Cost) Estimates for Affected Sources of GHG 

Authorities at Alternative Thresholds1,2 

Total Three Year Estimates Regulatory Relief (Avoided Permitting Costs in millio

Activity Regulatory Alternatives 

Sources <25,000 CO2e tpy <50,000 CO2e tpy <100,000 CO2e tpy Non-GHG Based Non-GHG/< 50K Non-GNew Industrial $9,695.4 $9,851.4 $9,987.9 $9,987.9 $9,874.2 New Commercial/Residential $138,042.3 $138,058.5 $138,071.7 $138,072.9 $138,060.9 Permit revisions due to GHG $264.9 $301.5 $306.6 $311.1 $303.1 Source Total $148,002.3 $148,211.4 $148,366.2 $148,371.9 $148,238.2 Permitting Authority New Industrial $4,116.3 $4,182.6 $4,230.3 $4,240.5 $4,192.3 New Commercial/Residential $58,606.2 $58,613.1 $58,618.8 $58,619.1 $58,614.1 Permit revisions due to GHG $290.7 $330.9 $336.3 $341.4 $332.7 Permitting Authority Total $63,012.9 $63,126.3 $63,185.1 $63,201.0 $63,138.8 Total Title V Regulatory Relief $211,015.2 $211,338.0 $211,551.3 $211,572.9 $211,377.2 

1 Avoided costs shown represent the three year estimates of the regulatory burden relief from this rule and for regulatory alternatives f

the three year phase-in period. Alternatives <25,000 CO2e tpy, <50,000 CO2e tpy, <100,000 CO2e tpy, and non-GHG based assume 

remain in effect for three years. Alternatives Non-GHG/<50K and Non-GHG/<25K assume the Non GHG based threshold for Step 1 tpy and <25,000 CO2e tpy thresholds for Step 2, respectively. Finally the final rule estimates shown in the last column of the table as

GHG based threshold for Step 1 (one half year) and the <100,000 CO2e tpy threshold for Step 2 (two and one-half years). Sums may not add due to rounding. 

2 These estimates are explained in more detail in Attachment C “Summary of Methodology and Data Used to Estimate Burden Relief 
20 

Table 3.2. Annual PSD Regulatory Relief (Avoided Costs) for Sources of GHG and Permitting Authoritie

Thresholds1,2 

Regulatory Alternative 

<25,000 CO2e tpy 

Regulatory Alternative 

<50,000 CO2e tpy 

Step 2 

<100,000 CO2e tpy 

Threshold, 

<75,000 CO2e tpy 

Significance Level 

Activity 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Avoided 

Costs 

(millions 

2007$) 

Number 

of 

Permits 

Avoided 

Costs 

(millions 

2007$) 

Number 

of Permits 

Avoided 

Costs 

(millions 

2007$) 

Sources New Industrial $84,530 16,892 $1,427.9 24,183 $2,044.2 25,174 $2,128.0 New Commercial/Residential $59,152 55,446 $3,279.7 55,481 $3,281.8 55,505 $3,283.2 Source Total 72,338 $4,707.6 79,664 $5,326.0 80,679 $5,411.2 Permitting Authority New Industrial $23,243 16,892 $392.6 24,183 $562.1 25,174 $585.1 New Commercial/Residential $16,216 55,446 $899.1 55,481 $899.7 55,505 $900.1 Permitting Authority Total 72,338 $1,291.7 79,664 $1,461.8 80,679 $1,485.2 Total PSD Regulatory Relief $5,999.4 $6,787.8 $6,896.4 

1 Avoided costs shown represent annual estimates of the regulatory burden relief for this rule and for regulatory alternatives. Sums may 2 Attachment C: “Summary of Methodology and Data Used to Estimate Burden Relief and Evaluate Resource Requirements at Alterna

Permitting Thresholds . 
21 

permit and $16,216 per permit for a new commercial or residential PSD permit. It is assumed 

that permit preparation and issuance for commercial/residential permits require less time to 

prepare and issue than industrial source permits since commercial/residential sources would 

likely be somewhat less complex in terms of numbers and types of emission sources and control 

requirements. Estimates obtained are additional burden and costs to those currently experienced 

by permitting authorities and sources. For more information on the estimates of burden costs for 

PSD permits, see Attachment C. Avoided costs estimates for regulatory alternatives of <25,000 

tpy (proposal level) and <50,000tpy CO2e PTE are also shown in Table 3.2. The PSD estimated 

costs on Table 3.2 represent annual estimates of costs avoided for sources and permitting 

authorities. 

 Regulatory relief alternatives for Steps 1 and 2 for PSD are shown on Table 3.3. 

Evaluating regulatory alternatives for the approximate three year time period covered by Steps 1 

and 2 provides comparisons of the threshold levels and the impacts of timing choices for the 

steps. As shown on Table 3.3, regulatory alternatives of <25,000 tpy CO2e, <50,000 tpy CO2e, 

<100,000 tpy CO2e, and the non-GHG based thresholds are evaluated as if they were 

implemented for the entire three year period. The <25,000 tpy CO2e and the non-GHG based 

thresholds represent the bounding alternatives over the three year period with the <25,000 tpy 

CO2e alternative providing the least regulatory relief and the non-GHG based threshold the 

greatest. If the <25,000 tpy CO2e were implemented for Steps 1 and 2, the regulatory relief for 

PSD sources would amount to approximately $17,998.2 million during the three year period. 

This regulatory relief would be $20,985.9 million over the same period with the non-GHG based 

threshold. All other alternatives shown and combinations of regulatory alternatives within the 

three year time frame lie within the <25,000 tpy CO2e threshold and the non-GHG based 

threshold. The final rule choice of the non-GHG based threshold for Step 1 and <100,000 tpy 

CO2e threshold for Step 2 results in avoided costs PSD regulatory relief of $20,738.7 million for 

the three year period. 

This rule also alleviates the regulatory burden associated with complying with NSR 

BACT requirements for small new and modifying sources. The BACT costs foregone are not 

estimated or shown in Tables 3.2 or 3.3 because of the significant uncertainties involved in these 

requirements for affected sources and lack of sufficient information to estimate these costs 
22 

currently. Likewise, the foregone emission reductions associated with these BACT requirements 

for small sources are not estimated. This issue is discussed further in Section 5 of this RIA.
23 

Table 3.3 Step 1 and 2 PSD Regulatory Relief (Avoided Costs) for Sources of GHG and Permitting Autho

Thresholds1,2 

1 Avoided costs shown represent the three year estimates of the regulatory burden relief from this rule and for regulatory alternatives fo

year phase-in period. Alternatives <25,000 CO2e tpy, <50,000 CO2e tpy, <100,000 CO2e tpy, and non-GHG based assume these thres

three years. Alternatives Non-GHG/<50K and Non-GHG/<25K assume the Non GHG based threshold for Step 1 and <50,000 CO2e tp

thresholds for Step 2, respectively. Finally the final rule estimates shown in the last column of the table show the Non-GHG based thre

year) and the <100,000 CO2e tpy threshold for Step 2 (two and one-half years). Sums may not add due to rounding. 

2 Attachment C: “Summary of Methodology and Data Used to Estimate Burden Relief and Evaluate Resource Requirements at Alterna

Permitting Thresholds.”

Total Three Year Regulatory Relief (Avoided Costs in millions 2007$

Regulatory Alternatives 

Activity <25,000 CO2e tpy <50,000 CO2e tpy <100,000 CO2e tpy

Non-GHG 

Based Non-GHG/< 50K Non-G

Sources New Industrial $4,283.7 $6,132.6 $6,384.0 $6,615.9 $6,213.2 New Commercial/Residential $9,839.1 $9,845.4 $9,849.6 $9,850.5 $9,846.3 Source Total $14,122.8 $15,978.0 $16,233.6 $16,466.4 $16,059.4 Permitting Authority New Industrial $1,177.8 $1,686.3 $1,755.3 $1,819.2 $1,708.5 New Commercial/Residential $2,697.3 $2,699.1 $2,700.3 $2,700.3 $2,699.3 Permitting Authority Total $3,875.1 $4,385.4 $4,455.6 $4,519.5 $4,407.8 Total PSD Regulatory Relief $17,998.2 $20,363.4 $20,689.2 $20,985.9 $20,467.2 
24 

Section 4 

Impacts of Regulatory Relief 

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

authorities but should instead be viewed as regulatory relief for smaller GHG emission sources. 

This RIA illustrates the burden impacts avoided as a result of this rule. The avoided impacts of 

extending these programs for State, local, and tribal permitting authorities are also reported. To 

estimate the avoided economic impacts, which include small business impacts, EPA estimated 

cost-to-sales ratios by comparing the estimated total annualized compliance cost per permit per 

source avoided to industry average revenues per establishment. EPA also evaluated cost-to-sales 

ratios by comparing avoided burden costs to revenues of firms at different firm size categories, 

recognizing that the sources required to comply with these CAA permit provisions during the 

phase-in period are larger emissions sources and more likely to be large business entities. 

4.1 Method for Analyzing Avoided Economic and Small Entity Impacts 

EPA used cost-to-sales comparisons to evaluate the potential impacts to sources affected 

by this rule. Since this regulatory action provides regulatory relief, these cost-to-sales ratios 

represent the economic impacts that are avoided or postponed for small GHG sources as a result 

of this rule. For all regulatory actions, EPA must determine whether a rule will have a 

significant impact on a substantial number of small entities (SISNOSE). This rule provides 

regulatory relief to small sources and thus does not have a significant impact on a substantial 

number of small entities. The approach for estimating the postponed or avoided economic 

impacts and the small entity analysis are the same for this analysis. The steps followed include 

gathering data to characterize the affected entities by size, selecting and describing the measures 

and economic impact thresholds used in the analysis, and determining cost-to-sales ratios for the 

affected industrial, commercial, and residential categories. 

4.1.1 Identifying Affected Sectors and Entities

The industrial, commercial, and residential sectors covered by the rule were identified 

during the development of the cost analysis for the rule. For the industrial sector, these sources 

are summarized with applicable NAICS codes in Tables 4.0 through 4.3. For commercial and 

residential sources, the sources are listed in Tables 4.4 through 4.7. 
25 

4.1.2 Data Used to Characterize Affected Entities by Size

The Census Bureau’s Statistics of U.S. Businesses (SUSB) data provide national 

information on the distribution of economic variables by industry and size.6

 Specifically, the 

tables report data for each industry on the number of firms (Table 4.0), number of establishments 

(Table 4.1), employment (Table 4.2), and receipts (Table 4.3) by enterprise size category in 

affected sectors. Similar results are shown for commercial and residential sources in Tables 4.4 

through 4.7. The census definitions in these data elements are as follows: 

 establishment: An establishment is a single physical location where business is 

conducted or where services or industrial operations are performed. 

 employment: Paid employment consists of full- and part-time employees, including 

salaried officers and executives of corporations, who were on the payroll in the pay 

period including March 12. Included are employees on sick leave, holidays, and 

vacations; not included are proprietors and partners of unincorporated businesses. 

 receipts: Receipts (net of taxes) are defined as the revenue for goods produced, 

distributed, or services provided, including revenue earned from premiums, 

commissions and fees, rents, interest, dividends, and royalties. Receipts exclude all 

revenue collected for local, state, and federal taxes. 

 enterprise: An enterprise is a business organization consisting of one or more 

domestic establishments that were specified under common ownership or control. The 

enterprise and the establishment are the same for single-establishment firms. Each 

multiestablishment company forms one enterprise—the enterprise employment and 

annual payroll are summed from the associated establishments. Enterprise size 

designations are determined by the summed employment of all associated 

establishments.7

The SBA small business size standard(s) is provided for each industry group in order to facilitate 

comparisons and different thresholds. 

The receipt data are reported in 2002 dollars. Therefore, to adjust to 2007 dollars for 

comparison to costs, EPA used the U.S. Bureau of Labor Statistics’ consumer price index (CPI). 

Using the annual U.S. city average price index for all consumer goods, EPA adjusted revenues to 

2007 dollars. 

 

6

 These data were developed in cooperation with, and partially funded by, the Office of Advocacy of the Small 

Business Administration (SBA). 7

 Because the SBA’s business size definitions (SBA, 2008c) apply to an establishment’s “ultimate parent company,” 

we assume in this analysis that the “enterprise” definition above is consistent with the concept of ultimate parent 

company that is typically used for Small Business Regulatory Enforcement Fairness Act (SBREFA) screening 

analyses and the terms are used interchangeably. 
26 

Table 4.0. Number of Firms by Industry and Enterprise Size: 2002 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Firms 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Electricity Generating Units 

Electricity Generating Units 22 1 7,603 5,636 901 288 26 

Industrial Adipic Acid Production 325199 1,000 443 157 95 59 16 Industrial Aluminum Production 331312 1,000 43 28 2 3 1 Industrial Ammonia Manufacturing 325311 1,000 130 78 18 6 2 Industrial Cement Production 327310 750 136 67 21 12 6 Industrial Electronics Manufacturing 334 2 13,833 7,698 3,291 1,149 150 Industrial Ferroalloy Production 331112 750 14 3 NA 5 NA Industrial Glass Production 327 500–1,000 11,395 7,108 2,553 590 57 Industrial HCFC-22 Production 325120 1,000 87 45 12 8 NA Industrial Hydrogen Production 325120 1,000 87 45 12 8 NA Industrial Iron and Steel Production 331111 1,000 1,135 687 166 53 9 Industrial Lead Production 3314 750–1,000 760 384 161 74 14 Industrial Lime Manufacturing 327410 500 41 16 10 4 1 Industrial Magnesium Production 3314 750–1,000 760 384 161 74 14 Industrial Nitric Acid Production 325311 1,000 130 78 18 6 2 Industrial Petrochemical Production 3251 500–1,000 1,145 475 277 131 29 Industrial Petroleum Refineries 324110 3 202 84 24 23 6 Industrial Phosphoric Acid Production 325312 500 35 12 5 6 1 Industrial Pulp and Paper Manufacturing 3221 750 338 96 55 72 7 Industrial Silicon Carbide Production 327910 500 299 161 94 25 2 Industrial Soda Ash Manufacturing 325181 1,000 25 10 5 2 NA Industrial Titanium Dioxide Production 325188 1,000 367 139 92 43 11 Industrial Zinc Production 3314 750–1,000 760 384 161 74 14 Industrial Ethanol Production 325193 1,000 60 19 16 3 1 Industrial Food Processing 311 500–1,000 21,384 13,645 3,935 1,247 147 Energy Underground Coal Mines 21211 500 802 387 246 67 6 Energy Oil and Natural Gas Systems 211 500 6,317 5,184 354 89 13 
27 

Table 4.0. Number of Firms by Industry and Enterprise Size: 2002 (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Firms 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Energy Oil and Natural Gas Systems 486 4 244 110 22 16 8 Waste Treatment 

Landfills 562 $12.5 

million 

14,184 10,726 1,616 258 22 

Waste Treatment 

MWCs 562 $12.5 

million 

14,184 10,726 1,616 258 22 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multiestablishment compathe enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations are determiemployment of all associated establishments. Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening analy

as of 8/11/08. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122: A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mil

2 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS co

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

3 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has 1

or has 125,000 barrels per calendar day or less total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. The total product to be deliv

must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natura

486910 Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million). 
28 

Table 4.1. Number of Establishments by Affected Industry and Enterprise Size: 2002 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Establishments <20 Employees 20 to 99 Employees 100 to 499 Employees 500 to 749 Employees 

Electricity Generating Units 

Electricity Generating Units 22 1 18,432 5,715 1,423 1,126 282 

Industrial Adipic Acid Production 325199 1,000 640 157 99 78 24 Industrial Aluminum Production 331312 1,000 50 28 2 4 1 Industrial Ammonia Manufacturing 325311 1,000 157 78 18 15 5 Industrial Cement Production 327310 750 253 67 29 22 11 Industrial Electronics Manufacturing 334 2 15,883 7,709 3,435 1,497 282 Industrial Ferroalloy Production 331112 750 17 3 NA 7 NA Industrial Glass Production 327 500–1,000 16,674 7,161 3,302 1,788 306 Industrial HCFC-22 Production 325120 1,000 551 45 20 20 NA Industrial Hydrogen Production 325120 1,000 551 45 20 20 NA Industrial Iron and Steel Production 331111 1,000 1,242 690 169 62 9 Industrial Lead Production 3314 750–1,000 958 386 174 108 24 Industrial Lime Manufacturing 327410 500 77 18 13 6 7 Industrial Magnesium Production 3314 750–1,000 958 386 174 108 24 Industrial Nitric Acid Production 325311 1,000 157 78 18 15 5 Industrial Petrochemical Production 3251 500–1,000 2,287 478 316 231 68 Industrial Petroleum Refineries 324110 3 349 85 29 28 10 Industrial Phosphoric Acid Production 325312 500 50 12 5 6 2 Industrial Pulp and Paper Manufacturing 3221 750 628 97 55 88 13 Industrial Silicon Carbide Production 327910 500 347 161 100 42 2 Industrial Soda Ash Manufacturing 325181 1,000 38 10 5 4 NA Industrial Titanium Dioxide Production 325188 1,000 611 141 111 69 38 Industrial Zinc Production 3314 750–1,000 958 386 174 108 24 Industrial Ethanol Production 325193 1,000 66 20 16 5 1 Industrial Food Processing 311 500–1,000 25,698 13,719 4,254 1,951 370 Energy Underground Coal Mines 21211 500 1,194 390 279 138 23 
29 

Table 4.1. Number of Establishments by Affected Industry and Enterprise Size: 2002 (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Establishments <20 Employees 20 to 99 Employees 100 to 499 Employees 500 to 749 Employees 

Energy Oil and Natural Gas Systems 211 500 7,629 5,239 456 292 60 Energy Oil and Natural Gas Systems 486 4 2,701 110 59 79 115 Waste Treatment 

Landfills 562 $12.5 

million 

17,698 10,775 1,839 612 86 

Waste Treatment 

MWCs 562 $12.5 

million 

17,698 10,775 1,839 612 86 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multiestablishment compa

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

standards as of 8/11/08. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122: A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS c

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

3 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has 1

and has 125,000 barrels or less per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned o

well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. The total product to 

contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natur

486910 Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million). 
30 

Table 4.2. Number of Employees by Affected Industry and Enterprise Size: 2002 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Establishments <20 Employees 20 to 99 Employees 100 to 499 Employees 500 to 749 Employees 

Electricity Generating Units 

Electricity Generating Units 22 1 648,254 24,257 39,391 46,942 12,042 

Industrial Adipic Acid Production 325199 1,000 73,342 1,023 2,412 3,232 NA Industrial Aluminum Production 331312 1,000 10,158 38 NA NA NA Industrial Ammonia Manufacturing 325311 1,000 4,949 363 210 NA NA Industrial Cement Production 327310 750 16,905 493 418 1,157 NA Industrial Electronics Manufacturing 334 2 1,300,411 50,279 139,966 186,772 53,138 Industrial Ferroalloy Production 331112 750 2,266 NA NA NA NA Industrial Glass Production 327 500–1,000 475,476 47,315 98,637 85,569 17,516 Industrial HCFC-22 Production 325120 1,000 9,557 88 294 510 NA Industrial Hydrogen Production 325120 1,000 9,557 88 294 510 NA Industrial Iron and Steel Production 331111 1,000 124,703 1,434 6,235 3,227 1,456 Industrial Lead Production 3314 750–1,000 64,203 2,421 6,680 10,407 NA Industrial Lime Manufacturing 327410 500 4,393 33 227 NA NA Industrial Magnesium Production 3314 750–1,000 64,203 2,421 6,680 10,407 NA Industrial Nitric Acid Production 325311 1,000 4,949 363 210 NA NA Industrial Petrochemical Production 3251 500–1,000 172,964 3,171 10,392 16,525 5,548 Industrial Petroleum Refineries 324110 3 62,132 454 942 2,870 2,903 Industrial Phosphoric Acid 325312 500 6,288 27 NA NA NA Industrial Pulp and Paper 3221 750 162,988 537 2,279 12,554 2,782 Industrial Silicon Carbide Production 327910 500 16,079 1,237 3,637 3,536 NA Industrial Soda Ash Manufacturing 325181 1,000 4,483 56 NA NA NA Industrial Titanium Dioxide Production 325188 1,000 49,845 566 881 1,839 NA Industrial Zinc Production 3314 750–1,000 64,203 2,421 6,680 10,407 NA Industrial Ethanol Production 325193 1,000 64,203 2,421 6,680 10,407 NA Industrial Food Processing 311 500–1,000 1,735 NA NA NA NA Energy Underground Coal Mines 21211 500 1,443,766 85,850 156,158 218,041 67,104 
31 

Table 4.2. Number of Employees by Affected Industry and Enterprise Size: 2002 (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Establishments <20 Employees 20 to 99 Employees 100 to 499 Employees 500 to 749 Employees 

Energy Oil and Natural Gas Systems 211 500 74,915 2,801 10,205 11,576 NA Energy Oil and Natural Gas Systems 486 4 88,280 19,336 12,113 11,656 2,421 Waste Treatment 

Landfills 562 $12.5 

million 

300,580 56,529 59,245 37,530 5,122 

Waste Treatment 

MWCs 562 $12.5 

million 

300,580 56,529 59,245 37,530 5,122 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

definitions as of 8/11/08. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122: A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS c

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

3 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has 

fewer or 125,000 barrels or less per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned 

well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. The total product to 

contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natur

486910 Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million). 
32 

Table 4.3. Receipts by Industry and Enterprise Size: 2002 (in millions of 2007$) 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Receipts 

($) 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Electricity Generating Units 

Electricity Generating Units 22 1 456,494 10,324 28,259 29,111 8,522 

Industrial Adipic Acid Production 325199 1,000 54,024 437 880 2,117 NA Industrial Aluminum Production 331312 1,000 4,165 7 NA NA NA Industrial Ammonia Manufacturing 325311 1,000 3,844 152 60 NA NA Industrial Cement Production 327310 750 8,358 207 120 526 NA Industrial Electronics Manufacturing 334 2 437,886 9,887 26,268 41,653 14,340 Industrial Ferroalloy Production 331112 750 1,008 NA NA NA NA Industrial Glass Production 327 500–1,000 110,002 7,430 17,700 16,967 4,154 Industrial HCFC-22 Production 325120 1,000 6,662 25 337 82 NA Industrial Hydrogen Production 325120 1,000 6,662 25 337 82 NA Industrial Iron and Steel Production 331111 1,000 54,363 275 1,237 1,192 639 Industrial Lead Production 3314 750–1,000 24,584 582 2,391 3,007 NA Industrial Lime Manufacturing 327410 500 1,173 7 64 NA NA Industrial Magnesium Production 3314 750–1,000 24,584 582 2,391 3,007 NA Industrial Nitric Acid Production 325311 1,000 3,844 152 60 NA NA Industrial Petrochemical Production 3251 500–1,000 123,343 1,603 4,722 7,974 3,990 Industrial Petroleum Refineries 324110 3 225,612 538 2,903 5,186 10,094 Industrial Phosphoric Acid Production 325312 500 4,607 7 NA NA NA Industrial Pulp and Paper Manufacturing 3221 750 81,766 146 719 5,269 805 Industrial Silicon Carbide Production 327910 500 3,861 206 561 715 NA Industrial Soda Ash Manufacturing 325181 1,000 2,386 12 NA NA NA Industrial Titanium Dioxide Production 325188 1,000 18,803 199 267 685 NA Industrial Zinc Production 3314 750–1000 24,584 582 2,391 3,007 NA Industrial Ethanol Production 325193 1,000 2,416 NA NA NA NA Industrial Food Processing 311 500–1000 527,312 14,597 37,198 65,304 26,627 
33 

Table 4.3. Receipts by Industry and Enterprise Size: 2002 (in Millions of 2007$) (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Receipts 

($) 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Energy Underground Coal Mines 21211 500 22,873 501 2,415 3,328 NA Energy Oil and Natural Gas Systems 211 500 185,420 8,465 7,826 11,075 5,312 Energy Oil and Natural Gas Systems 486 4 51,926 1,163 158 258 NA Waste Treatment 

Landfills 562 $12.5 

million 

55,557 7,451 8,366 5,940 965 

Waste Treatment 

MWCs 562 $12.5 

million 

55,557 7,451 8,366 5,940 965 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

Business categorization as of 8/11/08. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122: A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS c

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

3 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has 

and 125,000 barrels or less per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Capacity includes owned or le

facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. The total product to be deliv

must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natur

486910 Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million) 
34 

Table 4.4. Number of Firms by Affected Industry and Enterprise Size in Commercial Sectors: 2002 

Sector Source Category NAICS 

SBA Size 

Standard 

in Millions 

of Dollars 

Total 

Firms 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Commercial Education 61 $7.035.0 65,933 40,824 12,379 3,071 289 Commercial Enclosed Mall 531120 7.0 28,241 22,509 1,077 329 43 Commercial Food Sales NA NA NA NA NA Commercial Food Service 722 7.020.5 376,637 248,494 67,549 6,629 447 Commercial Inpatient Health C are 622 34.5 4,548 427 487 1,590 384 Commercial Laboratory 541380 12.0 4,708 3,335 680 148 22 Commercial Laboratory 5417 7.0 11,418 7,365 1,478 532 72 Commercial Lodging 721 7.0 51,168 33,326 7,968 1,428 135 Commercial Nonrefrigerated Warehouse 49311 25.5 3,152 2,005 514 199 15 Commercial Nursing 623 7.013.5 32,720 14,632 8,486 5,836 418 Commercial Office 531120 7.0 28,241 22,509 1,077 329 43 Commercial Other 81 7.025.0 675,218 568,285 41,363 4,449 290 Commercial Outpatient Health Care 621 7.034.5 424,694 351,540 27,991 4,699 428 Commercial Public Assembly 71 7.0 103,043 64,915 12,227 2,292 153 Commercial Public Order and Safety NA NA NA NA NA Commercial Refrigerated Warehouse 49312 25.5 608 358 138 34 3 Commercial Religious Worship 813110 7.0 172,311 147,505 15,942 1,213 39 Commercial Retail Other than Mall 44-45 7.029.0 736,130 579,905 59,639 8,723 577 Commercial Service 81 7.025.0 675,218 568,285 41,363 4,449 290 Commercial Strip Shopping Mall 531120 7.0 28,241 22,509 1,077 329 43 Residential Residential 531110 7.0 52,190 44,477 1,799 441 55 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

as of 8/11/08. 
35 

Table 4.5. Number of Establishments by Affected Industry and Enterprise Size: 2002 

Sector Source Category NAICS 

SBA Size 

Standard Total Firms

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees

Commercial Education 61 7.0–35.0 73,701 41,136 13,925 5,604 864 Commercial Enclosed Mall 531120 7.0 30,777 22,706 1,313 597 123 Commercial Food Sales NA NA NA NA NA Commercial Food Service 722 7.0–20.5 503,354 249,889 79,906 31,769 7,297 Commercial Inpatient Health Care 622 34.5 7,569 441 513 1,725 442 Commercial Laboratory 541380 12.0 5,962 3,371 972 488 67 Commercial Laboratory 5417 7.0 13,944 7,462 1,836 996 228 Commercial Lodging 721 7.0 61,795 33,613 9,057 2,962 761 Commercial Nonrefrigerated 

Warehouse 

49311 25.5 4,893 2,057 805 529 311 

Commercial Nursing 623 7.0–13.5 67,900 14,824 11,701 18,516 3,717 Commercial Office 531120 7.0 30,777 22,706 1,313 597 123 Commercial Other 81 7.0–25.0 740,118 573,318 54,021 16,431 2,960 Commercial Outpatient Health 

Care 

621 7.0–34.5 487,747 357,221 41,650 19,182 3,021 

Commercial Public Assembly 71 7.0 110,375 65,195 13,408 3,715 566 Commercial Public Order and 

Safety 

 NA NA NA NA NA 

Commercial Refrigerated 

Warehouse 

49312 25.5 970 367 204 96 20 

Commercial Religious Worship 813110 7.0 172,562 147,510 16,009 1,272 115 Commercial Retail Other than Mall 44-45 7.0–29.0 1,125,693 594,655 98,116 51,814 12,028 Commercial Service 81 7.0–25.0 740,118 573,318 54,021 16,431 2,960 Commercial Strip Shopping Mall 531120 7.0 30,777 22,706 1,313 597 123 
36 

Table 4.5. Number of Establishments by Affected Industry and Enterprise Size: 2002 (continued) 

Sector Source Category NAICS 

SBA Size 

Standard Total Firms

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees

Residential Residential 531110 7.0 57,748 45,104 2,992 2,491 479 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

categories as of 8/11//08. 
37 

Table 4.6. Number of Employees by Affected Industry and Commercial Enterprise Size: 2002 

Sector Source Category NAICS 

SBA Size 

Standard 

Total 

Establishments <20 Employees 20 to 99 Employees 100 to 499 Employees 500 to 749 Employees 

Commercial Education 61 7.0–35.0 2,701,675 223,695 516,135 535,272 148,370 Commercial Enclosed Mall 531120 7.0 163,501 73,311 32,364 22,319 5,066 Commercial Food Sales NA NA NA NA NA Commercial Food Service 722 7.0–20.5 8,352,174 1,622,740 2,551,714 1,184,119 232,483 Commercial Inpatient Health Care 622 34.5 5,121,584 2,374 30,243 389,501 220,984 Commercial Laboratory 541380 12.0 100,797 18,415 25,714 19,918 3,920 Commercial Laboratory 5417 7.0 399,213 35,669 60,951 84,936 22,983 Commercial Lodging 721 7.0 1,696,701 202,509 292,528 232,976 56,837 Commercial Nonrefrigerated 

Warehouse 

49311 25.5 94,316 11,294 18,392 21,859 3,802 

Commercial Nursing 623 7.0–13.5 2,770,665 92,274 409,004 965,200 172,278 Commercial Office 531120 7.0 163,501 73,311 32,364 22,319 5,066 Commercial Other 81 7.0–25.0 5,420,087 2,547,460 1,482,350 640,068 84,297 Commercial Outpatient Health Care 621 7.0–34.5 4,917,156 1,829,546 1,029,355 751,711 134,712 Commercial Public Assembly 71 7.0 1,800,991 315,475 496,962 380,688 65,678 Commercial Public Order and Safety NA NA NA NA NA Commercial Refrigerated 

Warehouse 

49312 25.5 28,100 2,238 5,427 5,010 NA 

Commercial Religious Worship 813110 7.0 1,638,915 722,630 607,209 197,037 20,211 Commercial Retail Other than Mall 44–45 7.0–29.0 14,819,904 2,889,481 2,204,104 1,267,733 213,518 Commercial Service 81 7.0–25.0 5,420,087 2,547,460 1,482,350 640,068 84,297 Commercial Strip Shopping Mall 531120 7.0 163,501 73,311 32,364 22,319 5,066 Residential Residential 531110 7.0 281,250 152,350 59,796 42,104 7,627 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume i

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening anal

sizes as of 8/11/08. 
38 

Table 4.7. Receipts by Affected Industry and Enterprise Size: 2002 (Millions of 2007 $) 

Sector Source Category NAICS 

SBA Size 

Standard 

in Millions 

of Dollars 

Total 

Receipts 

<20 

Employees 

20 to 99 

Employees 

100 to 499 

Employees 

500 to 749 

Employees 

Commercial Education 61 7.0–35.0 207,779 15,586 30,849 38,207 10,456 Commercial Enclosed Mall 531120 7.0 52,796 21,467 8,090 6,609 2,148 Commercial Food Sales NA NA NA NA NA Commercial Food Service 722 7.0–20.5 373,666 79,827 98,916 49,500 9,774 Commercial Inpatient Health Care 622 34.5 575,286 845 2,892 33,554 20,075 Commercial Laboratory 541380 12.0 11,854 2,018 2,763 2,091 478 Commercial Laboratory 5417 7.0 72,013 6,419 10,785 15,439 4,422 Commercial Lodging 721 7.0 141,193 15,159 18,413 15,047 4,287 Commercial Nonrefrigerated 

Warehouse 

49311 25.5 10,705 1,546 2,199 2,281 508 

Commercial Nursing 623 7.0–13.5 145,529 4,624 18,714 49,332 9,058 Commercial Office 531120 7.0 52,796 21,467 8,090 6,609 2,148 Commercial Other 81 7.0–25.0 491,097 215,897 120,283 67,821 10,225 Commercial Outpatient Health Care 621 7.0–34.5 582,829 229,611 118,216 73,667 12,923 Commercial Public Assembly 71 7.0 170,062 35,446 31,146 35,130 6,972 Commercial Public Order and Safety NA NA NA NA NA NA NA Commercial Refrigerated Warehouse 49312 25.5 4,889 325 765 586 NA Commercial Religious Worship 813110 7.0 95,558 37,076 34,178 13,933 1,681 Commercial Retail Other than Mall 44–45 7.0–29.0 3,612,583 577,700 662,037 441,243 65,923 Commercial Service 81 7.0–25.0 491,097 215,897 120,283 67,821 10,225 Commercial Strip Shopping Mall 531120 7.0 52,796 21,467 8,090 6,609 2,148 Residential Residential 531110 7.0 57,365 32,327 9,943 6,854 1,366 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specif

ownership or control. The enterprise and the establishment are the same for single-establishment firms. Each multi-establishment comp

enterprise—the enterprise employment and annual payroll are summed from the associated establishments. Enterprise size designations 

summed employment of all associated establishments. Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening analy

sizes as of 8/11.08. 
39 

Because the SBA’s business size definitions (SBA, 2008c) apply to an establishment’s 

“ultimate parent company,” we assume in this analysis that the “enterprise” definition above is 

consistent with the concept of ultimate parent company that is typically used for SBREFA 

screening analyses, and the terms are used interchangeably. We also report the SBA size 

standard(s) for each industry group to facilitate comparisons and different thresholds. 

4.2 Developing Economic and Small Entity Regulatory Relief Impact Measures 

We measured the postponed impacts of the rule on small entities in each sector using 

methods presented in EPA’s Final SBREFA Guidance (EPA, 2006). Because the rule covers a 

large number of sectors and primarily covers businesses, the analysis generated a set of sales tests 

(represented as cost-to-receipt ratios)8

 for NAICS codes associated with the affected sectors. 

Although the appropriate SBA size definition should be applied at the parent company 

(enterprise) level, data limitations allowed us only to compute and compare ratios for a model 

establishment for six enterprise size ranges (i.e., all categories, enterprises with 1 to 20 

employees, 20 to 99 employees, 100 to 499 employees, 500 to 999 employees, and 1,000 to 1,499 

employees). This approach allowed us to account for differences in establishment receipts 

between large and small enterprises and differences in small business definitions across affected 

industries. It is also a conservative approach, because an establishment’s parent company (the 

“enterprise”) may have other economic resources that could be used to cover the costs of the 

reporting program. 

4.3 Implementing the Sales Test to Measure Impacts on Industrial, Commercial, and 

Multifamily Residential Sources 

To implement the recommended sales test, EPA computed cost-to-sales ratios for affected 

sectors at the establishment (or facility) level.9

 The ratios examine the ratio of the average 

 

8

 The following metrics for other small entity economic impact measures (if applicable) would potentially include 

 Small governments (if applicable): “Revenue” test—annualized compliance cost as a percentage of annual 

government revenues 

 Small nonprofits (if applicable): “Expenditure” test—annualized compliance cost as a percentage of annual 

operating expenses 9

 Typically, SBREFA impact assessments are conducted at the ultimate parent company level. As noted above, we 

assume that Census definition of enterprise is equivalent to ultimate parent company. Theoretically, the 

comparison of compliance costs to sales should be conducted at the enterprise level. Because Census only 

provides data for typical establishments within various enterprise size categories, EPA chose to compute the 

cost-to-sales ratio at the establishment (or facility level). The same ratio could be computed at the enterprise level 

by multiplying both the numerator and the denominator by the typical number of establishments per enterprise in 
40 

establishment’s total annualized mandatory reporting costs to the average establishment receipts 

for enterprises within several employment categories.10 The average entity costs used to compute 

the sales test are the same across all of these enterprise size categories. As a result, the sales test 

will overstate the cost-to-receipt ratio for establishments owned by small businesses, because the 

reporting costs are likely lower than average entity estimates provided by the engineering cost 

analysis. 

Cost-to-sales ratios for industrial categories are reported in Tables 4.9 through 4.12. 

Table 4.8 shows impacts avoided for small sources of GHG for title V. In Tables 4.9 and 4.10, 

impacts avoided for new and modifying PSD sources, respectively, are presented. Table 4.11 

shows the avoided costs compared to sales for title V permitting. These ratios are calculated 

using data on the average avoided cost of compliance per facility and data on the average sales 

per establishment obtained from the Census Bureau. Cost-to-sales or revenue ratios for 

commercial and residential categories are reported in Tables 4.12 through 4.14. Table 4-.12 shows 

impacts avoided for small commercial and residential sources of GHG for title V. Tables 4.13 

and 4.14 show impacts avoided for modifying and new PSD commercial and residential sources, 

respectively. 

The burden avoided per-entity costs of the rule are shown in Table 3.0 for title V. The 

avoided burden cost associated with obtaining an operating permit is $46.4 thousand per source 

for industrial sources of GHG emissions and approximately $23 thousand for commercial and 

residential sources. An avoided cost of $1,677 is estimated for sources requiring title V 

permitting revision. For modifying PSD sources, the avoided burden costs with obtaining a 

permit is $84.5 thousand per source for industrial sources of GHG emissions and approximately 

59 thousand per source for commercial and residential sources. Finally, for new PSD sources, 

the avoided burden costs are the sum of the avoided title V and modifying PSD costs. Thus, the 

avoided burden costs are approximately $130.8 thousand per source for new industrial sources of 

GHG emissions and approximately $82 thousand per source for new commercial and residential 

sources. 

 

the appropriate enterprise size categories. Using the SUSB data on typical establishments means that the cost-tosales ratios are identical, whether computed at the establishment level or at the enterprise level. 10 For the one to 20 employee category, we excluded SUSB data for enterprises with zero employees. These 

enterprises did not operate the entire year. 
41 

The cost-to-sales estimates show that the avoided costs for industrial sources typically are 

zero up to 1.5 percent of their sales, but they can be as high as 19 percent for certain sources 

(e.g., aluminum plants with less than 20 employees). For PSD, the avoided ICR cost-to-sales 

ratios range from zero to2.7 percent for modifying and from zero to 4.2 percent of sales for new 

industrial sources. These avoided cost-to-sales ratio for PSD do not consider avoided BACT 

costs due to lack of sufficient data currently. 

For commercial sources, the average avoided cost to sales ratios range from 0.5 to 4.2 

percent for title V. These average avoided cost-to-sales ranges increase for PSD to 

approximately from 1.2 to 10.7 percent of their sales or revenues for modifying commercial and 

multifamily residential sources and 1.6 to 14.9 for new commercial and residential PSD sources. 

4.4 Economic Relief to Permitting Authorities 

In this final rule, the thresholds for requiring title V and PSD permits are increased above 

statutory CAA levels resulting in millions of potential title V sources and tens of thousands of 

new and modifying PSD sources being able to postpone obtaining a permit for a period of at 

least 6 years. This action will provide significant regulatory relief to States, local government, 

and tribal permitting authorities. The magnitude of permits that would need to be addressed and 

the dollar estimate of the additional costs in labor and administrative costs permitting authorities 

would otherwise incur if GHG are a regulated pollutant absent this rulemaking are shown in 

Tables 3.0 and 3.1 in Section 3. 

For title V permits, permitting authorities will experience avoided costs of approximately 

$21 billion relating to approximately 2 million new operating permits annually that otherwise 

would need to be processed. Although this administrative burden represents a huge burden to 

these agencies, Part 70 of the CAA does provide for a mechanism for the affected permitting 

authorities to recoup the costs of operation associated with administering this expanded permit 

program. EPA recognizes in this tailoring rule that the sheer magnitude and burden of these 

additional small GHG sources cannot feasibly be met by these permitting authorities on 

administrative burden grounds for a period of at least 5 years regardless of the ability to include 

these increased costs in fees charged to sources. However, the economic consequences to 

permitting authorities of this permitting program are offset in the fee structure these authorities 

are allowed to charge sources obtaining title V permits. 
42 

For PSD permitting authorities, no such mitigating fee structure currently exists. Thus, 

the funding for administering a PSD permitting program to include tens of thousands of 

additional new and modifying PSD sources annually would need to be met by these permitting 

authorities from current revenue sources. At present, there are approximately 58 State, local, and 

tribal PSD permitting programs operating in the United States and approximately 49 additional 

State, local, or tribal government authorities that are administering federal programs under 

delegation from EPA. It is difficult to estimate the economic consequences of the regulatory 

relief afforded to the individual permitting authorities, because the number of PSD permits 

processed each year varies by permitting authority over time depending on the number of new 

and modifying sources occurring in a given location. However, the National Association of 

Clean Air Agencies (NACAA) has, through a member survey, broadly assessed the additional 

resource and burden considerations of EPA treating GHG as a regulated pollutant. NACAA 

provided this information to EPA to help improve our understanding of agencies’ burdens.11 

Under the current PSD program requirements, these permitting authorities process an average of 

8 PSD permits for new and modifying sources each year (range of 0 to 56 for individual 

respondents). These surveyed permitting authorities indicate they would need an average of 12 

new full-time employees (range of 1 to 63) costing an average of $1.1 million annually (range 

$60 thousand to $6.3 million) with a 10-fold increase in permits occurring as a result of 

including GHG as a regulated pollutant. Some of these permitting authorities indicated that 

hiring new employees is not possible at this time because of budget constraints and hiring 

freezes. All respondents indicated that new training would be needed to address GHG 

permitting. Rather than the 10-fold increase in permits postulated in NACAA’s survey, EPA 

estimates the increase would more likely be 100-fold making these estimates a significant 

understatement of the potential impacts on permitting authorities. For more information about 

the sources affected by alternative thresholds and currently covered by title V and PSD, see 

Appendices B and C. 

 

11 Memorandum from Mary Stewart Douglas NACAA, to Juan E. Santiago, Group Leader, Operating Permits 

Group, U.S. EPA OAQPS. September 3, 2009. 
43 

Table 4.8. Avoided Title V Costs to Sales for Small Industrial Sources of GHG Emissions 

Sector Source Category NAICS 

SBA Size 

Standard 

Average 

Cost Per 

Entity 

(2007$) 

Cost per entity 

for All 

Establishments 

(%) 

Cost per 

Entity for 

<20 

Employees 

(%) 

Cost per 

Entity for 

20 to 99 

Employees 

(%) 

Cost per 

Entity 100 

to 499 

Employees 

(%) 

Cost pe

Entity f

500 to 7

Employ

(%) 

Electricity Generating Units 

Electricity Generating Units 

22 1 $46,350 0.2% 2.6% 0.2% 0.2% 0.2% 

Industrial Adipic Acid 

Production 

325199 1,000 $46,350 0.1% 1.7% 0.5% 0.2% NA 

Industrial Aluminum 

Production 

331312 1,000 $46,350 0.1% 19.0% NA NA NA 

Industrial Ammonia 

Manufacturing 

325311 1,000 $46,350 0.2% 2.4% 1.4% NA NA 

Industrial Cement Production 327310 750 $46,350 0.1% 1.5% 1.1% 0.2% NA Industrial Electronics 

Manufacturing 

334 2 $46,350 0.2% 3.6% 0.6% 0.2% 0.1% 

Industrial Ferroalloy 

Production 

331112 750 $46,350 0.1% NA NA NA NA 

Industrial Glass Production 327 500–1,000 $46,350 0.7% 4.5% 0.9% 0.5% 0.3% Industrial HCFC-22 

Production 

325120 1,000 $46,350 0.4% 8.3% 0.3% 1.1% NA 

Industrial Hydrogen 

Production 

325120 1,000 $46,350 0.4% 8.3% 0.3% 1.1% NA 

Industrial Iron and Steel 

Production 

331111 1,000 $46350 0.1% 11.6% 0.6% 0.2% 0.1% 

Industrial Lead Production 3314 750–1,000 $46,350 0.2% 3.1% 0.3% 0.2% NA Industrial Lime 

Manufacturing 

327410 500 $46,350 0.3% 12.8% 0.9% NA NA 

Industrial Magnesium 

Production 

3314 750–1,000 $46,350 0.2% 3.1% 0.3% 0.2% NA 

Industrial Nitric Acid 

Production 

325311 1,000 $46,350 0.2% 2.4% 1.4% NA NA 

Industrial Petrochemical 

Production 

3251 500–1,000 $46,350 0.1% 1.4% 0.3% 0.1% 0.1% 

Industrial Petroleum 

Refineries 

324110 3 $46,350 0.0% 0.7% 0.0% 0.0% 0.0% 
44 

Table 4.8. Avoided Title V Costs to Sales for Small Industrial Sources of GHG Emissions (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

Average 

Cost Per 

Entity 

(2007$) 

Cost per entity 

for All 

Establishments 

(%) 

Cost per 

Entity for 

<20 

Employees 

(%) 

Cost per 

Entity for 

20 to 99 

Employees 

(%) 

Cost per 

Entity 100 

to 499 

Employees 

(%) 

Cost pe

Entity f

500 to 7

Employ

(%) 

Industrial Phosphoric Acid 

Production 

325312 500 $46,350 0.1% 7.8% NA NA NA 

Industrial Pulp and Paper 

Manufacturing 

3221 750 $46,350 0.0% 3.1% 0.4% 0.1% 0.1% 

Industrial Silicon Carbide 

Production 

327910 500 $46,350 0.4% 3.6% 0.8% 0.3% NA 

Industrial Soda Ash 

Manufacturing 

325181 1,000 $46,350 0.1% 3.8% NA NA NA 

Industrial Titanium Dioxide 

Production 

325188 1,000 $46,350 0.2% 3.3% 1.9% 0.5% NA 

Industrial Zinc Production 3314 750–1,000 $46,350 0.2% 3.1% 0.3% 0.2% NA Industrial Ethanol Production 325193 1,000 $46,350 0.1% NA NA NA NA Industrial Food Processing 311 500–1,000 $46,350 0.2% 4.4% 0.5% 0.1% 0.1% Energy Underground Coal 

Mines 

21211 500 $46,350 0.2% 3.6% 0.5% 0.2% NA 

Energy Oil and Natural Gas 

Systems 

211 500 $46,350 0.2% 2.9% 0.3% 0.1% 0.1% 

Energy Oil and Natural Gas 

Systems 

486 4 $46,350 0.2% 0.4% 1.7% 1.4% NA 

Waste Treatment 

Landfills 562 $12.5 

million 

$46,350 1.5% 6.7% 1.0% 0.5% 0.4% 

Waste Treatment 

MWCs 562 $12.5 

million 

$46,350 1.5% 6.7% 1.0% 0.5% 0.4% 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for Small Business Regulato

Act (SBREFA) screening analyses. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 – A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has n

employees nor production greater than 125,000 barrels per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Ca

leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. Th

delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

3 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS co

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for bein
45 

Sector Source Category NAICS 

SBA Size 

Standard 

Average 

Cost Per 

Entity 

(2007$) 

Cost per entity 

for All 

Establishments 

(%) 

Cost per 

Entity for 

<20 

Employees 

(%) 

Cost per 

Entity for 

20 to 99 

Employees 

(%) 

Cost per 

Entity 100 

to 499 

Employees 

(%) 

Cost pe

Entity f

500 to 7

Employ

(%) 

although the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natura

Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million) 
46 

Table 4.9. Avoided Costs to Sales for Small Modifying Industrial GHG PSD Emission Sources 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average 

Cost Per 

Entity 

(2007$) 

Cost per 

Entity for 

All 

Establishments (%) 

Cost per 

Entity for 

<20 

Employees 

(%) 

Cost per 

Entity for 

20 to 99 

Employees 

(%) 

Cost per 

Entity 100 

to 499 

Employees 

(%) 

Cost per 

Entity for 

500 to 74

Employee

(%) 

Electricity Generating Units 

Electricity Generating Units 

22 1 $84,530 0.3% 4.7% 0.4% 0.3% 0.3% 

Industrial Adipic Acid 

Production 

325199 1,000 $84,530 0.1% 3.0% 1.0% 0.3% NA 

Industrial Aluminum Production 331312 1,000 $84,530 0.1% 34.6% NA NA NA Industrial Ammonia 

Manufacturing 

325311 1,000 $84,530 0.3% 4.3% 2.5% NA NA 

Industrial Cement Production 327310 750 $84,530 0.3% 2.7% 2.0% 0.4% NA Industrial Electronics 

Manufacturing 

334 2 $84,530 0.3% 6.6% 1.1% 0.3% 0.2% 

Industrial Ferroalloy Production 331112 750 $84,530 0.1% NA NA NA NA Industrial Glass Production 327 500–1,000 $84,530 1.3% 8.1% 1.6% 0.9% 0.6% Industrial HCFC-22 Production 325120 1,000 $84,530 0.7% 15.1% 0.5% 2.1% NA Industrial Hydrogen Production 325120 1,000 $84,530 0.7% 15.1% 0.5% 2.1% NA Industrial Iron and Steel 

Production 

331111 1,000 $84,530 0.2% 21.2% 1.2% 0.4% 0.1% 

Industrial Lead Production 3314 750–1,000 $84,530 0.3% 5.6% 0.6% 0.3% NA Industrial Lime Manufacturing 327410 500 $84,530 0.6% 23.3% 1.7% NA NA Industrial Magnesium 

Production 

3314 750–1,000 $84,530 0.3% 5.6% 0.6% 0.3% NA 

Industrial Nitric Acid Production 325311 1,000 $84,530 0.3% 4.3% 2.5% NA NA Industrial Petrochemical 

Production 

3251 500–1,000 $84,530 0.2% 2.5% 0.6% 0.2% 0.1% 

Industrial Petroleum Refineries 324110 3 $84,530 0.0% 1.3% 0.1% 0.0% 0.0% Industrial Phosphoric Acid 

Production 

325312 500 $84,530 0.1% 14.2% NA NA NA 

Industrial Pulp and Paper 

Manufacturing 

3221 750 $84,530 0.1% 5.6% 0.6% 0.1% 0.1% 

Industrial Silicon Carbide 

Production 

327910 500 $84,530 0.8% 6.6% 1.5% 0.5% NA 

Industrial Soda Ash 

Manufacturing 

325181 1,000 $84,530 0.1% 6.9% NA NA NA 
47 

Table 4.9. Avoided Costs to Sales for Small Modifying Industrial GHG PSD Emission Sources (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average 

Cost Per 

Entity 

(2007$) 

Cost per 

Entity for 

All 

Establishments (%) 

Cost per 

Entity for 

<20 

Employees 

(%) 

Cost per 

Entity for 

20 to 99 

Employees 

(%) 

Cost per 

Entity 100 

to 499 

Employees 

(%) 

Cost per 

Entity for 

500 to 74

Employee

(%) 

Industrial Titanium Dioxide 

Production 

325188 1,000 $84,530 0.3% 6.0% 3.5% 0.9% NA 

Industrial Zinc Production 3314 750–1,000 $84,530 0.3% 5.6% 0.6% 0.3% NA Industrial Ethanol Production 325193 1,000 $84,530 0.2% NA NA NA NA Industrial Food Processing 311 500–1,000 $84,530 0.4% 7.9% 1.0% 0.3% 0.1% Energy Underground Coal 

Mines 

21211 500 $84,530 0.4% 6.6% 1.0% 0.4% NA 

Energy Oil and Natural Gas 

Systems 

211 500 $84,530 0.3% 5.2% 0.5% 0.2% 0.1% 

Energy Oil and Natural Gas 

Systems 

486 4 $84,530 0.4% 0.8% 3.2% 2.6% NA 

Waste Treatment 

Landfills 562 $12.5 

million 

$84,530 2.7% 12.2% 1.9% 0.9% 0.8% 

Waste Treatment 

MWCs 562 $12.5 

million 

$84,530 2.7% 12.2% 1.9% 0.9% 0.8% 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for Small Business Regulato

Act (SBREFA) screening analyses. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 – A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has n

employees nor production greater than 125,000 barrels per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Ca

leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. Th

delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

3 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS co

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natura

Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million) 
48 

Table 4.10. Avoided Costs to Sales for Small New PSD Industrial GHG Sources 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average 

Cost per 

Entity 

(2007$) 

Cost per 

Entity for 

All 

Enterprises 

Cost per 

Entity for 

<20 

Employees 

Cost per 

Entity for 

20 to 99 

Employees 

Cost per 

Entity 100 

to 499 

Employees

Cost per 

Entity for 

500 to 749 

Employees

Electricity Generating Units 

Electricity Generating Units 

22 1 $130,880 0.5% 7.2% 0.7% 0.5% 0.4% 

Industrial Adipic Acid Production 325199 1,000 $130,880 0.2% 4.7% 1.5% 0.5% NA Industrial Aluminum Production 331312 1,000 $130,880 0.2% 53.6% NA NA NA Industrial Ammonia 

Manufacturing 

325311 1,000 $130,880 0.5% 6.7% 3.9% NA NA 

Industrial Cement Production 327310 750 $130,880 0.4% 4.2% 3.2% 0.5% NA Industrial Electronics 

Manufacturing 

334 2 $130,880 0.5% 10.2% 1.7% 0.5% 0.3% 

Industrial Ferroalloy Production 331112 750 $130,880 0.2% NA NA NA NA Industrial Glass Production 327 500–1,000 $130,880 2.0% 12.6% 2.4% 1.4% 1.0% Industrial HCFC-22 Production 325120 1,000 $130,880 1.1% 23.3% 0.8% 3.2% NA Industrial Hydrogen Production 325120 1,000 $130,880 1.1% 23.3% 0.8% 3.2% NA Industrial Iron and Steel 

Production 

331111 1,000 $130,880 0.3% 32.9% 1.8% 0.7% 0.2% 

Industrial Lead Production 3314 750–1,000 $130,880 0.5% 8.7% 1.0% 0.5% NA Industrial Lime Manufacturing 327410 500 $130,880 0.9% 36.1% 2.7% NA NA Industrial Magnesium Production 3314 750–1,000 $130,880 0.5% 8.7% 1.0% 0.5% NA Industrial Nitric Acid Production 325311 1,000 $130,880 0.5% 6.7% 3.9% NA NA Industrial Petrochemical 

Production 

3251 500–1,000 $130,880 0.2% 3.9% 0.9% 0.4% 0.2% 

Industrial Petroleum Refineries 324110 3 $130,880 0.0% 2.1% 0.1% 0.1% 0.0% Industrial Phosphoric Acid 

Production 

325312 500 $130,880 0.1% 22.0% NA NA NA 

Industrial Pulp and Paper 

Manufacturing 

3221 750 $130,880 0.1% 8.7% 1.0% 0.2% 0.2% 

Industrial Silicon Carbide 

Production 

327910 500 $130,880 1.2% 10.2% 2.3% 0.8% NA 

Industrial Soda Ash 

Manufacturing 

325181 1,000 $130,880 0.2% 10.7% NA NA NA 

Industrial Titanium Dioxide 

Production 

325188 1,000 $130,880 0.4% 9.3% 5.4% 1.3% NA 

Industrial Zinc Production 3314 750–1,000 $130,880 0.5% 8.7% 1.0% 0.5% NA 
49 

Table 4.10. Avoided Costs to Sales for Small New PSD Industrial GHG Sources (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average 

Cost per 

Entity 

(2007$) 

Cost per 

Entity for 

All 

Enterprises 

Cost per 

Entity for 

<20 

Employees 

Cost per 

Entity for 

20 to 99 

Employees 

Cost per 

Entity 100 

to 499 

Employees

Cost per 

Entity for 

500 to 749 

Employees

Industrial Ethanol Production 325193 1,000 $130,880 0.4% NA NA NA NA Industrial Food Processing 311 500–1,000 $130,880 0.6% 12.3% 1.5% 0.4% 0.2% Energy Underground Coal 

Mines 

21211 500 $130,880 0.7% 10.2% 1.5% 0.5% NA 

Energy Oil and Natural Gas 

Systems 

211 500 $130,880 0.5% 8.1% 0.8% 0.3% 0.1% 

Energy Oil and Natural Gas 

Systems 

486 4 $130,880 0.7% 1.2% 4.9% 4.0% NA 

Waste Treatment 

Landfills 562 $12.5 

million

$130,880 4.2% 18.9% 2.9% 1.3% 1.2% 

Waste Treatment 

MWCs 562 $12.5 

million

$130,880 4.2% 18.9% 2.9% 1.3% 1.2% 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for Small Business Regulato

Act (SBREFA) screening analyses. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 – A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has n

employees nor production greater than 125,000 barrels per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Ca

leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. Th

delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

3 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS co

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natura

Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million) 
50 

Table 4-11. Avoided Title V Permitting Costs to Sales for Permit Revisions Due to GHG 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

(2007$/entity) 

Cost per 

Entity for 

All 

Enterprises 

Cost per 

Entity for 

Size 

<20 

Employees 

Cost per 

Entity for 

Size 

20 to 99 

Employees

Cost per 

Entity for 

Size 

100 to 499 

Employees

Cost per 

Entity for 

Size 

500 to 749 

Employees

Electricity Generating Unites 

Electricity Generating Units 

22 1 $1,677 0.0% 0.1% 0.0% 0.0% 0.0% 

Industrial Adipic Acid 

Production 

325199 1,000 $1,677 0.0% 0.1% 0.0% 0.0% NA 

Industrial Aluminum Production 331312 1,000 $1,677 0.0% 0.7% NA NA NA Industrial Ammonia 

Manufacturing 

325311 1,000 $1,677 0.0% 0.1% 0.1% NA NA 

Industrial Cement Production 327310 750 $1,677 0.0% 0.1% 0.0% 0.0% NA Industrial Electronics 

Manufacturing 

334 2 $1,677 0.0% 0.1% 0.0% 0.0% 0.0% 

Industrial Ferroalloy Production 331112 750 $1,677 0.0% NA NA NA NA Industrial Glass Production 327 500–1,000 $1,677 0.0% 0.2% 0.0% 0.0% 0.0% Industrial HCFC-22 Production 325120 1,000 $1,677 0.0% 0.3% 0.0% 0.0% NA Industrial Hydrogen Production 325120 1,000 $1,677 0.0% 0.3% 0.0% 0.0% NA Industrial Iron and Steel 

Production 

331111 1,000 $1,677 0.0% 0.4% 0.0% 0.0% 0.0% 

Industrial Lead Production 3314 750–1,000 $1,677 0.0% 0.1% 0.0% 0.0% NA Industrial Lime Manufacturing 327410 500 $1,677 0.0% 0.5% 0.0% NA NA Industrial Magnesium 

Production 

3314 750–1,000 $1,677 0.0% 0.1% 0.0% 0.0% NA 

Industrial Nitric Acid Production 325311 1,000 $1,677 0.0% 0.1% 0.1% NA NA Industrial Petrochemical 

Production 

3251 500–1,000 $1,677 0.0% 0.0% 0.0% 0.0% 0.0% 

Industrial Petroleum Refineries 324110 3 $1,677 0.0% 0.0% 0.0% 0.0% 0.0% 
51 

Table 4.11. Avoided Title V Permitting Costs to Sales for Permit Revisions Due to GHG (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

(2007$/entity) 

Cost per 

Entity for 

All 

Enterprises 

Cost per 

Entity for 

Size 

<20 

Employees 

Cost per 

Entity for 

Size 

20 to 99 

Employees

Cost per 

Entity for 

Size 

100 to 499 

Employees

Cost per 

Entity for 

Size 

500 to 749 

Employees

Industrial Phosphoric Acid 

Production 

325312 500 $1,677 0.0% 0.3% NA NA NA 

Industrial Pulp and Paper 

Manufacturing 

3221 750 $1,667 0.0% 0.1% 0.0% 0.0% 0.0% 

Industrial Silicon Carbide 

Production 

327910 500 $1,677 0.0% 0.1% 0.0% 0.0% NA 

Industrial Soda Ash 

Manufacturing 

325181 1,000 $1,677 0.0% 0.1% NA NA NA 

Industrial Titanium Dioxide 

Production 

325188 1,000 $1,677 0.0% 0.1% 0.1% 0.0% NA 

Industrial Zinc Production 3314 750–1,000 $1,677 0.0% 0.1% 0.0% 0.0% NA Industrial Ethanol Production 325193 1,000 $1,677 0.0% NA NA NA NA Industrial Food Processing 311 500–1,000 $1,677 0.0% 0.2% 0.0% 0.0% 0.0% Energy Underground Coal 

Mines 

21211 500 $1,677 0.0% 0.1% 0.0% 0.0% NA 

Energy Oil and Natural Gas 

Systems 

211 500 $1,677 0.0% 0.1% 0.0% 0.0% 0.0% 

Energy Oil and Natural Gas 

Systems 

486 4 $1,677 0.0% 0.0% 0.1% 0.1% NA 

Waste Treatment 

Landfills 562 $12.5

 million

$1,677 0.1% 0.2% 0.0% 0.0% 0.0% 
52 

Table 4.11. Avoided Title V Permitting Costs to Sales for Permit Revisions Due to GHG (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

(2007$/entity) 

Cost per 

Entity for 

All 

Enterprises 

Cost per 

Entity for 

Size 

<20 

Employees 

Cost per 

Entity for 

Size 

20 to 99 

Employees

Cost per 

Entity for 

Size 

100 to 499 

Employees

Cost per 

Entity for 

Size 

500 to 749 

Employees

Waste Treatment 

MWCs 562 $12.5 

million

$1,677 0.1% 0.2% 0.0% 0.0% 0.0% 

Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in 

enterprise definition above is consistent with the concept of ultimate parent company that is typically used for Small Business Regulato

Act (SBREFA) screening analyses. 

1 NAICS codes 221111, 221112, 221113, 221119, 221121, 221122 – A firm is small if, including its affiliates, it is primarily engaged in 

transmission, and/or distribution of electric energy for sale and its total electric output for the preceding fiscal year did not exceed 4 mi

2 500 to 1,500. For NAICS code 324110: For purposes of Government procurement, the petroleum refiner must be a concern that has n

employees nor production greater than 125,000 barrels per calendar day total Operable Atmospheric Crude Oil Distillation capacity. Ca

leased facilities as well as facilities under a processing agreement or an arrangement such as an exchange agreement or a throughput. Th

delivered under the contract must be at least 90 percent refined by the successful bidder from either crude oil or bona fide feedstocks. 

3 NAICS Subsectors 333, 334, 335 and 336: For rebuilding machinery or equipment on a factory basis, or equivalent, use the NAICS co

manufactured product. Concerns performing major rebuilding or overhaul activities do not necessarily have to meet the criteria for beinalthough the activities may be classified under a manufacturing NAICS code. Ordinary repair services or preservation are not considere

4 Subsector 486: Pipeline Transportation (486110 Pipeline Transportation of Crude Oil 1,500, 486210 Pipeline Transportation of Natura

Pipeline Transportation of Refined Petroleum Products 1,500, 486990 All Other Pipeline Transportation $34.5 million) 
53 

Table 4.12. Title V Avoided Costs for Small New Commercial Sources of GHG Emissions Compared to A

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1,000/entity)

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

Employees 

Avoided 

Cost to 

Sales 

Revenues

Size 

20 to 99 

Employees

Avoided 

Cost to 

Sales 

Revenues

Size 

100 to 499 

Employees

Avoided 

Cost to 

Sales 

Revenues

Size 

500 to 749 

Employee

Commercial Education 61 7.0–35.0 $23,175 0.82% 6.12% 1.05% 0.34% 0.19% Commercial Enclosed Mall 531120 7 $23,175 1.35% 2.45% 0.38% 0.21% 0.13% Commercial Food Sales $23,175 NA NA NA NA NA Commercial Food Service 722 7.0–20.5 $23,175 3.12% 7.25% 1.87% 1.49% 1.73% Commercial Inpatient Health Care 622 34.5 $23,175 0.03% 1.21% 0.41% 0.12% 0.05% Commercial Laboratory 541380 12 $23,175 1.17% 3.87% 0.82% 0.54% 0.32% Commercial Laboratory 5417 7 $23,175 0.45% 2.69% 0.39% 0.15% 0.12% Commercial Lodging 721 7 $23,175 1.01% 5.14% 1.14% 0.46% 0.41% Commercial Nonrefrigerated 

Warehouse 

49311 25.5 $23,175 1.06% 3.08% 0.85% 0.54% 1.42% 

Commercial Nursing 623 7.0–13.5 $23,175 1.08% 7.43% 1.45% 0.87% 0.95% Commercial Office 531120 7 $23,175 1.35% 2.45% 0.38% 0.21% 0.13% Commercial Other 81 7.0–25.0 $23,175 3.49% 6.15% 1.04% 0.56% 0.67% Commercial Outpatient Health Care 621 7.0–34.5 $23,175 1.94% 3.61% 0.82% 0.60% 0.54% Commercial Public Assembly 71 7 $23,175 1.50% 4.26% 1.00% 0.25% 0.19% Commercial Public Order and 

Safety 

 $23,175 NA NA NA NA NA 

Commercial Refrigerated 

Warehouse 

49312 25.5 $23,175 0.46% 2.62% 0.62% 0.38% NA 

Commercial Religious Worship 813110 7 $23,175 4.19% 9.22% 1.09% 0.21% 0.16% Commercial Retail Other than Mall 44–45 7.0–29.0 $23,175 0.72% 2.39% 0.34% 0.27% 0.42% Commercial Service 81 7.0–25.0 $23,175 3.49% 6.15% 1.04% 0.56% 0.67% Commercial Strip Shopping Mall 531120 7 $23,175 1.35% 2.45% 0.38% 0.21% 0.13% 
54 

Table 4.12. Title V Avoided Costs for Small New Commercial Sources of GHG Emissions Compared to A(continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1,000/entity)

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

Employees 

Avoided 

Cost to 

Sales 

Revenues

Size 

20 to 99 

Employees

Avoided 

Cost to 

Sales 

Revenues

Size 

100 to 499 

Employees

Avoided 

Cost to 

Sales 

Revenues

Size 

500 to 749 

Employee

Residential Residential 531110 7 $23,175 2.33% 3.23% 0.70% 0.84% 0.81% 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under commThe enterprise and the establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterp

payroll is summed from the associated establishments. Enterprise size designations are determined by the summed employment of all associated estabSince the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in this analysis t

above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening analyses. NAICS code 611519: Job Corps Centers. For classifying a Federal procurement, the purpose of the solicitation must be for the management and opera

Labor Job Corps Center. The activities involved include admissions activities, life skills training, educational activities, comprehensive career prepara

development activities, career transition activities, as well as the management and support functions and services needed to operate and maintain the fa

small business concern, other than for Federal Government procurements, a concern must be primarily engaged in providing the services to operate an

Centers. NAICS code 541711 and 541712: For research and development contracts requiring the delivery of a manufactured product, the appropriate size stand

manufacturing industry. 
55 

Table 4.13. Avoided Costs for Small Modifying Commercial PSD GHG Emission Sources Compared to A

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1,000/entity) 

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

Employees 

Avoided 

Cost to 

Sales 

Revenues Size 20 to 

99 

Employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 100 to 

499 

Employees

Avoided 

Cost to 

Sales 

Revenues 

Size 

500 to 749 

Employee

Commercial Education 61 7.0–35.0 $59,152 2.10% 15.61% 2.67% 0.87% 0.49% Commercial Enclosed Mall 531120 7 $59,152 3.45% 6.26% 0.96% 0.53% 0.34% Commercial Food Sales $59,152 NA NA NA NA NA Commercial Food Service 722 7.0–20.5 $59,152 7.97% 18.52% 4.78% 3.80% 4.42% Commercial Inpatient Health Care 622 34.5 $59,152 0.08% 3.09% 1.05% 0.30% 0.13% Commercial Laboratory 541380 12 $59,152 2.98% 9.88% 2.08% 1.38% 0.83% Commercial Laboratory 5417 7 $59,152 1.15% 6.88% 1.01% 0.38% 0.31% Commercial Lodging 721 7 $59,152 2.59% 13.12% 2.91% 1.16% 1.05% Commercial Nonrefrigerated 

Warehouse 

49311 25.5 $59,152 2.70% 7.87% 2.17% 1.37% 3.62% 

Commercial Nursing 623 7.0–13.5 $59,152 2.76% 18.96% 3.70% 2.22% 2.43% Commercial Office 531120 7 $59,152 3.45% 6.26% 0.96% 0.53% 0.34% Commercial Other 81 7.0–25.0 $59,152 8.91% 15.71% 2.66% 1.43% 1.71% Commercial Outpatient Health Care 621 7.0–34.5 $59,152 4.95% 9.20% 2.08% 1.54% 1.38% Commercial Public Assembly 71 7 $59,152 3.84% 10.88% 2.55% 0.63% 0.48% Commercial Public Order and Safety $59,152 NA NA NA NA NA Commercial Refrigerated Warehouse 49312 25.5 $59,152 1.17% 6.69% 1.58% 0.97% NA Commercial Religious Worship 813110 7 $59,152 10.68% 23.53% 2.77% 0.54% 0.40% Commercial Retail Other than Mall 44-45 7.0–29.0 $59,152 1.84% 6.09% 0.88% 0.69% 1.08% Commercial Service 81 7.0–25.0 $59,152 8.91% 15.71% 2.66% 1.43% 1.71% Commercial Strip Shopping Mall 531120 7 $59,152 3.45% 6.26% 0.96% 0.53% 0.34% 
56 

Table 4.13. Avoided Costs for Small Modifying Commercial PSD GHG Emission Sources Compared to A(continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1,000/entity) 

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

Employees 

Avoided 

Cost to 

Sales 

Revenues Size 20 to 

99 

Employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 100 to 

499 

Employees

Avoided 

Cost to 

Sales 

Revenues 

Size 

500 to 749 

Employee

Residential Residential 531110 7 $59,152 5.95% 8.25% 1.78% 2.15% 2.07% 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under commThe enterprise and the establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterp

payroll is summed from the associated establishments. Enterprise size designations are determined by the summed employment of all associated estabSince the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in this analysis t

above is consistent with the concept of ultimate parent company that is typically used for SBREFA screening analyses. NAICS code 611519: Job Corps Centers. For classifying a Federal procurement, the purpose of the solicitation must be for the management and opera

Labor Job Corps Center. The activities involved include admissions activities, life skills training, educational activities, comprehensive career prepara

development activities, career transition activities, as well as the management and support functions and services needed to operate and maintain the fa

small business concern, other than for Federal Government procurements, a concern must be primarily engaged in providing the services to operate an

Centers. NAICS code 541711 and 541712: For research and development contracts requiring the delivery of a manufactured product, the appropriate size stand

manufacturing industry. 
57 

Table 4.14. Avoided Costs to Small PSD New Commercial GHG Emission Sources 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1000/entity) 

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

20 to 99 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

100 to 499 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

500 to 749 

employee

Commercial Education 61 7.0–35.0 $82,327 2.92% 21.74% 3.72% 1.21% 0.68% Commercial Enclosed Mall 531120 7 $82,327 4.80% 8.71% 1.34% 0.74% 0.47% Commercial Food Sales $82,327 NA NA NA NA NA Commercial Food Service 722 7.0–20.5 $82,327 11.09% 25.78% 6.65% 5.29% 6.15% Commercial Inpatient Health Care 622 34.5 $82,327 0.11% 4.30% 1.46% 0.42% 0.18% Commercial Laboratory 541380 12 $82,327 4.14% 13.76% 2.90% 1.92% 1.15% Commercial Laboratory 5417 7 $82,327 1.59% 9.57% 1.40% 0.53% 0.42% Commercial Lodging 721 7 $82,327 3.60% 18.26% 4.05% 1.62% 1.46% Commercial Nonrefrigerated 

Warehouse 

49311 25.5 $82,327 3.76% 10.96% 3.02% 1.91% 5.04% 

Commercial Nursing 623 7.0–13.5 $82,327 3.84% 26.40% 5.15% 3.09% 3.38% Commercial Office 531120 7 $82,327 4.80% 8.71% 1.34% 0.74% 0.47% Commercial Other 81 7.0–25.0 $82,327 12.41% 21.87% 3.70% 2.00% 2.38% Commercial Outpatient Health Care 621 7.0–34.5 $82,327 6.89% 12.81% 2.90% 2.14% 1.93% Commercial Public Assembly 71 7 $82,327 5.35% 15.15% 3.55% 0.87% 0.67% Commercial Public Order and Safety $82,327 NA NA NA NA NA Commercial Refrigerated Warehouse 49312 25.5 $82,327 1.63% 9.31% 2.20% 1.35% NA Commercial Religious Worship 813110 7 $82,327 14.87% 32.77% 3.86% 0.75% 0.56% Commercial Retail Other than Mall 44-45 7.0–29.0 $82,327 2.57% 8.48% 1.22% 0.97% 1.50% Commercial Service 81 7.0–25.0 $82,327 12.41% 21.87% 3.70% 2.00% 2.38% Commercial Strip Shopping Mall 531120 7 $82,327 4.80% 8.71% 1.34% 0.74% 0.47% 
58 

Table 4.14. Avoided Costs to Small PSD New Commercial GHG Emission Sources (continued) 

Sector Source Category NAICS 

SBA Size 

Standard 

(effective 

August 11, 

2008) 

Average Cost 

Per Entity 

($1000/entity) 

Avoided 

Cost to 

Average 

Sales 

Revenues 

for All 

Enterprises 

Avoided 

Cost to 

Sales 

Revenues 

Size <20 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

20 to 99 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

100 to 499 

employees 

Avoided 

Cost to 

Sales 

Revenues 

Size 

500 to 749 

employee

Residential Residential 531110 7 $82,327 8.29% 11.49% 2.48% 2.99% 2.89% 

The Census Bureau defines an enterprise as a business organization consisting of one or more domestic establishments that were specified under commoenterprise and the establishment are the same for single-establishment firms. Each multi-establishment company forms one enterprise—the enterprise em

summed from the associated establishments. Enterprise size designations are determined by the summed employment of all associated establishments. Since the SBA’s business size definitions (http://www.sba.gov/size) apply to an establishment’s ultimate parent company, we assume in this analysis tha

is consistent with the concept of ultimate parent company that is typically used for SBREFA screening analyses. NAICS code 611519: Job Corps Centers. For classifying a Federal procurement, the purpose of the solicitation must be for the management and operatio

Labor Job Corps Center. The activities involved include admissions activities, life skills training, educational activities, comprehensive career preparatio

activities, career transition activities, as well as the management and support functions and services needed to operate and maintain the facility. For SBA 

concern, other than for Federal Government procurements, a concern must be primarily engaged in providing the services to operate and maintain Federa

NAICS code 541711 and 541712: For research and development contracts requiring the delivery of a manufactured product, the appropriate size standar

industry. 
59 

Section 5 

Social Costs 

EPA examined the social costs of this final rule. For this rule, the social costs represent 

the foregone environmental benefits that would occur if regulatory relief was not offered to small 

sources of GHG emissions. This action is one of regulatory relief since it increases the emissions 

thresholds for the title V and PSD programs, as they apply to sources of GHG, to levels above 

those in the CAA. Previous sections have discussed the avoided cost of such relief, but there is 

also a social cost imposed by such relief because this rule may forego some of the possible 

benefits associated with title V and PSD programs for sources of GHG emissions below Step 1 

and 2 phase-in thresholds but above the statutory 100/250 tpy levels. These benefits are those 

attributed to title V and PSD permitting programs in general. These benefits are based on the 

relevance of these programs to policymaking, transparency issues, and market efficiency and, 

therefore, are very difficult to quantify and monetize. For title V, they include the benefits of 

improved compliance with CAA requirements that stem from (1) improved clarity regarding 

applicability of requirements; (2) discovery and required correction of noncompliance prior to 

receiving a permit; (3) improving monitoring, recordkeeping, and reporting concerning 

compliance status; (4) self-certification of compliance with applicable requirements initially and 

annually, and prompt reporting of deviations from permit requirements; (5) enhanced 

opportunity for the public to understand and monitor sources’ compliance obligations; and (6) 

improved ability of EPA, permitting authorities, and the public to enforce CAA requirements. 

However, it is important to remember that a title V permit does not add new requirements 

for pollution control itself but rather collects all of a facility’s applicable requirements under the 

CAA in one permit. Therefore, the compliance benefits above are less when title V permits 

contain few or no CAA applicable requirements. During the first two steps of this phase-in 

period, we expect that the vast majority of sources excluded from title V would be sources that 

have no CAA applicable requirements for GHG emissions and few or no requirements for other 

pollutants because their emissions of those pollutants are so small. For this reason, although it is 

extremely difficult to measure the degree of improved compliance, if any, that would be 

foregone or to quantify the social costs that would be imposed, we expect that they would be 

negligible. 
60 

For PSD, the primary social cost imposed by the tailoring rule stems from the foregone 

benefit of applying BACT to the tens of thousands of small new sources and modifications that 

will be below our thresholds during the first phase. This social cost potentially weighs against 

the cost savings described above that stem (in part) from avoiding the administrative and control 

costs of applying BACT to these sources. The BACT requirement ensures that when new and 

modified sources increase their emissions they are using state-of-the-art emission controls and 

afford the public an opportunity to comment on the control decision. It does not prohibit 

increases, but it ensures that such controls are applied. Delaying the BACT requirement for 

numerous small sources during the first phase of this rule could allow increases from these 

smaller sources that are greater than they would be if BACT were applied. A detailed analysis of 

this difference is beyond the scope of this rule because we do not have detailed information on 

the universe of these tens of thousands of small PSD actions, the candidate BACT technologies 

for each of them, how permitting authorities would make the BACT decisions, and how the 

BACT limit would compare to what would otherwise be installed absent BACT. Below we 

present an illustrative example of how BACT impacts might be determined for sources that 

would be excluded from review under the tailoring rule. This example illustrates the difficulty in 

quantifying the social costs of avoided BACT but helps explain the nature of such costs. 

To assess the effect of avoided BACT, we would identify the universe of source types 

that are affected by the tailoring rule. More specifically, we would have to project the number of 

various source types (within those affected by the tailoring rule) that would actually be 

constructing or modifying. We have generally characterized these sources as part of the tailoring 

rule threshold evaluation and have determined a large proportion of these to consist of small 

commercial and residential sources. This determination was based on rough energy usage data, 

but to assess BACT, we would require more specific information about the proposed equipment 

that will actually be emitting GHG (e.g., water heaters, furnaces, cooking equipment, dryers), 

and more specific characterization would be subject to a very high degree of uncertainty. 

Following characterization of new and modified sources, we would need to determine, 

for each category of source, what GHG control technologies are available for such equipment. 

For commercial sources, we may have to determine commercial availability of a range of lower 

emitting processes, more efficient technologies, and other techniques for improving energy 

efficiency. Next, we would assess affected sources’ capital and operating costs of control 
61 

options and determine energy and environmental impacts. Finally, we would need to apply 

judgment (as the permitting authority would do in each case) to select the technology that 

represented the maximum degree of control taking the costs, energy, and environmental impacts 

into account. 

The social cost component of the impact of foregoing BACT for sources that construct or 

modify during the first phase would be represented by the difference between the increased 

emissions that would result from such sources absent BACT and the increase that would be 

allowed under the BACT requirement. However, although we can point to the existence of such 

differences, we cannot quantify them (though as explained below we expect that overall they will 

be very limited in scope and magnitude). Since there has been no regulatory experience with 

controlling GHG emissions from these sources, and limited permitting experience of any kind 

with mandatory control requirements on smaller commercial and residential sources, we are not 

in a position at this point to identify the specific control technologies and quantify this difference 

to estimate the greater increases that might occur in the absence of applying the BACT process to 

these sources across the country. In addition, since the PSD BACT review and selection process 

is implemented on a case-by-case basis, there is additional uncertainty in predicting programwide reductions because even for similar sources, permitting authorities may ultimately weigh 

the BACT factors differently and adopt different control measures. 

For all these reasons, it is not possible at this time to quantify the social costs of avoided 

BACT. However, we note that the universe of possible emissions that would be regulated by 

sources excluded under the tailoring rule is small compared to those that would remain subject to 

PSD. The sources excluded in the first steps of this phased-in rule comprise only 11 percent of 

total stationary source GHG emissions, while 68 percent remain subject to regulation. The 

remaining fraction of stationary GHG source emissions come from sources below statutory CAA 

thresholds of 100/250 tons per year. Furthermore, we expect the emissions differences due to 

BACT controls for such sources to be relatively small because of the lack of available capture 

and control technologies for GHG at such sources that are akin to those that exist for 

conventional pollutants and sources, as well as the likelihood that even in the absence of BACT 

such sources would already be installing relatively efficient GHG technologies to save on fuel 

costs. Thus, although potential benefits would be foregone by excluding smaller sources from 

the permitting programs, these benefits are likely to be small. Under the tailoring rule, we will 
62 

work during the 6-year period to greatly improve our understanding of both the administrative 

costs of regulating and the social costs of not regulating smaller sources under PSD and title V, 

and we will rely on that information to support our future threshold analyses called for under the 

rule. 

Since EPA is unable to quantify these GHG emission reductions foregone at this time 

because of these uncertainties involved in this estimation, it is also not possible to provide a 

monetized estimate of the foregone benefits or social costs of this rule. If such emission 

reductions foregone were quantified, EPA could use the social cost of carbon benefit estimates 

such as those used in the “Rulemaking to Establish Light Duty Vehicle Greenhouse Gas 

Emission Standards and Corporate Average Fuel Economy Standards”12 recently published to 

compute the dollar value associated with the social costs of this rule. Nonetheless, we expect 

that the value would be small because, as discussed above, the emissions differences from which 

this value would be computed are small. 

In reaching the decisions for this GHG tailoring rule, EPA recognizes the GHG emissions 

can remain in the atmosphere for decades to centuries, meaning that their concentrations become 

well mixed throughout the global atmosphere regardless of emission origin, and their effects on 

climate are long lasting and significant. A detailed explanation of climate change and its impact 

on health, society, and the environment is included in EPA’s technical support document for the 

endangerment finding (Docket ID No. EPA-HQ-OAR-2009-0171). EPA recognizes the 

importance of reducing climate change emissions for all sources of GHG emissions, including 

those sources afforded regulatory relief in this rule, and plans to address potential emission 

reductions from these small sources using voluntary and energy efficiency approaches. 

Elsewhere, we have discussed EPA’s interest in continuing to use regulatory and/or 

nonregulatory tools for reducing emissions from smaller GHG sources because we believe that 

these tools will likely result in more efficient and cost-effective regulation than would case-bycase permitting. 

 

12 U.S. EPA 2010. Rulemaking to Establish Light Duty Vehicle Greenhouse Gas Emission Standards and Corporate 

Average Fuel Economy Standards. EPA-HQ-OAR-2009-0472. 

http://www.epa.gov/otaq/climate/regulations/ghg-preamble-regs.pdf. 
63 

Section 6 

References 

U.S. Census Bureau. Statistics of U.S. Businesses: 2002. 

U.S. Department of Labor, Bureau of Labor Statistics. Consumer Price Index 2002-2007. 

http://www.bls.gov/cpi/. 

U.S. Environmental Protection Agency. April 2010. Summary of Methodology and Data Use to 

Estimate Burden Relief and Evaluate Resource Requirements at Alternative Greenhouse 

Gas Permitting Thresholds. (Appendix C) 

U.S. Environmental Protection Agency. April 2010. Technical Support Document for 

Greenhouse Gas Emissions Threshold Evaluation. (Appendix B) 

U.S. Environmental Protection Agency. November 2006. Final Guidance for EPA Rulewriters: 

Regulatory Flexibility Act as Amended by the Small Business Regulatory Enforcement 

Fairness Act. http://www.epa.gov/sbrefa/documents/rfaguidance11-00-06.pdf. 

U.S. Small Business Administration. Table of Small Business Size Standards. Accessed 8/11/08. 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 
64 

Attachment A 

Source Categories Affected by the Rule with Industry Detail 

Table A-1. Title V Sources Expected to Experience Regulatory Relief at Alternative 

Threshold Levels by Industry Category 

Title V Sources Experiencing Regulatory Relief at Alternative Thresholds 

Source 

Category <25,000 tpy <50,000 tpy 

Final Rule 

Step 2 

<100,000 tpy 

Final Rule 

Step 1 

Non-GHG Based 

Electricity Generating Units 161 285 285 285 

Adipic Acid Production 0 0 0 0 

Aluminum Production 0 0 0 0 

Ammonia Manufacturing 0 0 0 0 

Cement Production 0 0 0 0 

Electronics Manufacturing 134 145 177 190 

Ferroalloy Production 0 0 0 0 

Glass Production 247 247 247 247 

HCFC-22 Production 0 0 0 3 

Hydrogen Production 33 37 43 61 

Iron and Steel Production 0 0 0 0 

Lead Production 4 4 4 4 

Lime Manufacturing 3 23 29 37 

Magnesium Production 0 0 0 0 

Nitric Acid Production 1 2 3 18 

Petrochemical Production 0 0 0 0 

Petroleum Refineries 3 3 3 3 

Phosphoric Acid Production 0 0 0 0 

Pulp and Paper Manufacturing 0 3 15 160 

Silicon Carbide Production 0 0 0 0 

Soda Ash Manufacturing 0 0 0 0 

Titanium Dioxide Production 0 0 0 0 

Zinc Production 3 3 3 3 

Ethanol Production 54 54 97 119 

Food Processing 3,438 3,438 3,438 3,438 

Unspecified Industrial Stationary 

Combustion (Other Manufacturing 

and Industrial Facilities) 

163,054 165,083 166,661 166,693 

Underground Coal Mines 135 160 183 235 

Oil and Natural Gas Systems 2,266 2,353 2,353 2,353 

Landfills 1,430 2,447 3,164 3,357 

MWCs 1 1 1 1 

(continued) 
65 

Table A-1. Title V Sources Expected to Experience Regulatory Relief at Alternative 

Threshold Levels by Industry Category (continued) 

Title V Sources Experiencing Regulatory Relief at Alternative Thresholds 

Source 

Category <25,000 tpy <50,000 tpy 

Final Rule 

Step 2 

<100,000 tpy 

Final Rule 

Step 1 

Non-GHG Based 

Stationary Combustion Equipment 

(Generators) 

37,351 37,351 37,351 37,351 

All Commercial—Stationary Fuel 

Combustion 

1,354,760 1,355,321 1,355,870 1,355,921 

Multi-Family Fuel Combustion 610,340 610,480 610,500 610,500 

Single-Family Fuel Combustion 3,925,000 3,925,000 3,925,000 3,925,000 

Total 6,098,352 6,102,374 6,105,361 6,105,913 

1

 North American Industry Classification System (NAICS). http://www.census.gov/eos/www/naics/. 

2

 U.S. Environmental Protection Agency. April 2010. “Technical Support Document for Greenhouse Gas Emissions 

Threshold Evaluation.” See docket at EPA-HQ-OAR-2009-0517. 
66 

Table A-2. New PSD Sources Expected to Experience Regulatory Relief 

at Alternative Threshold Levels by Industry Category 

New PSD Sources Sources Experiencing Regulatory Relief at Alternative Thresholds1,2

Source 

Category <25,000 tpy <50,000 tpy 

Final Rule 

Step 2 

<100,000 tpy 

Final Rule 

Step 1 

Non-GHG Based 

Electricity 

Generating Units 

20 29 33 93 

Adipic Acid 

Production 

0 0 0 0 

Aluminum 

Production 

0 0 0 0 

Ammonia 

Manufacturing 

0 0 0 0 

Cement Production 0 0 0 0 

Electronics 

Manufacturing 

0 0 0 0 

Ferroalloy 

Production 

0 0 0 0 

Glass Production 1 1 1 1 

HCFC-22 Production 0 0 0 0 

Hydrogen Production 0 0 0 0 

Iron and Steel 

Production 

0 0 0 0 

Lead Production 0 0 0 0 

Lime Manufacturing 0 0 0 0 

Magnesium 

Production 

0 0 0 0 

Nitric Acid 

Production 

0 0 0 0 

Petrochemical 

Production 

0 0 0 0 

Petroleum Refineries 0 0 0 0 

Phosphoric Acid 

Production 

0 0 0 0 

Pulp and Paper 

Manufacturing 

0 0 0 0 

Silicon Carbide 

Production 

0 0 0 0 

Soda Ash 

Manufacturing 

0 0 0 0 

(continued) 
67 

Table A-2. New PSD Sources Expected to Experience Regulatory Relief 

at Alternative Threshold Levels by Industry Category (continued) 

New PSD Sources Sources Experiencing Regulatory Relief at Alternative Thresholds1,2

Source 

Category <25,000 tpy <50,000 tpy 

Final Rule 

Step 2 

<100,000 tpy 

Final Rule 

Step 1 

Non-GHG Based 

Titanium Dioxide 

Production 

0 0 0 0 

Zinc Production 0 0 0 0 

Ethanol Production 4 4 7 10 

Food Processing 41 47 47 47 

Unspecified 

Industrial Stationary 

Combustion (Other 

Manufacturing and 

Industrial Facilities) 

529 534 544 546 

Underground Coal 

Mines 

0 0 0 0 

Oil and Natural Gas 

Systems 

23 38 44 48 

Landfills 0 0 0 0 

MWCs 0 1 1 2 

Stationary 

Combustion 

Equipment 

(Generators) 

299 299 299 299 

All Commercial - 

Stationary Fuel 

Combustion 

12,034 12,038 12,039 12,041 

Multi-Family Fuel 

Combustion 

6,397 6,400 6,400 6,400 

Single-Family Fuel 

Combustion 

515 515 515 515 

All 19,863 19,906 19,930 20,002 

1

Regulatory alternatives reflect tons per year CO2e potential to emit. 

2

Modifying PSD sources are also expected to experience regulatory relief, but these estimates are not reflected in 

this table. 
Attachment B 

Technical Support Document 

for Greenhouse Gas Emissions Thresholds 

Evaluation 
Attachment B 

Technical Support Document 

for Greenhouse Gas Emissions Thresholds 

Evaluation 

Air Quality Policy Division 

Office of Air Quality Policy and Standards 

U.S. Environmental Protection Agency 

March 29, 2010 
i 

Table of Contents

Page

1. Purpose....................................................................................................................................... 1

2. Overview.................................................................................................................................... 1

3. Emissions-based Threshold Analysis ........................................................................................ 2

3.1 General Description of Overall Approach ......................................................................... 2

3.1.1 Threshold Levels ................................................................................................... 2

3.1.2 Greenhouse Gases ................................................................................................. 3

3.1.3 Source Sectors....................................................................................................... 4

3.1.4 Potential to Emit Methodology ............................................................................. 5

3.1.5 New and Modified Sources ................................................................................... 6

3.2 Threshold Summary Results.............................................................................................. 6

3.3 Electricity Generating Sector............................................................................................. 9

3.4 Industrial Sector............................................................................................................... 11

3.4.1 Data Sources........................................................................................................ 14

3.4.2 Potential to Emit.................................................................................................. 14

3.4.3 Methodology for New Units ............................................................................... 14

3.5 Methodology for Existing Unspecified Industrial Stationary Combustion Source 

Category Emissions ....................................................................................................... 15

3.6 Methodology for Existing Specific Industrial Sectors Considering Combustion, 

Process, and Fugitive Emissions.................................................................................... 17
ii 

3.6.1 Adipic Acid Production....................................................................................... 18

3.6.2 Aluminum Production ......................................................................................... 20

3.6.3 Ammonia Production .......................................................................................... 22

3.6.4 Cement Production.............................................................................................. 23

3.6.5 Electronic Production.......................................................................................... 24

3.6.6 Ethanol Production.............................................................................................. 26

3.6.7 Ferroalloy Production.......................................................................................... 28

3.6.8 Food Processing .................................................................................................. 30

3.6.9 Glass Manufacturing ........................................................................................... 31

3.6.10 HCFC-22 Production......................................................................................... 32

3.6.11 Hydrogen Production ........................................................................................ 34

Table of Contents (cont.)

Page

3.6.12 Iron and Steel Production.................................................................................. 35

3.6.13 Lead Production ................................................................................................ 38

3.6.14 Lime .................................................................................................................. 39

3.6.15 Magnesium Production and Processing ............................................................ 40

3.6.16 Nitric Acid Production ...................................................................................... 42

3.6.17 Petrochemical Production ................................................................................. 43

3.6.18 Petroleum Refineries ......................................................................................... 45

3.6.19 Phosphoric Acid Production.............................................................................. 47

3.6.20 Pulp and Paper Manufacturing.......................................................................... 48

3.6.21 Silicon Carbide Manufacturing ......................................................................... 49

3.6.22 Soda Ash Production......................................................................................... 51

3.6.23 Titanium Dioxide Production............................................................................ 52

3.6.24 Zinc Production................................................................................................. 53

3.7 Energy Sector................................................................................................................... 54

3.7.1 Oil and Gas Systems ........................................................................................... 54
iii 

3.7.2 Underground Coal Mining .................................................................................. 55

3.8 Waste Sector .................................................................................................................... 58

3.8.1 Landfills .............................................................................................................. 58

3.8.2 Municipal Solid Waste Combustors.................................................................... 60

3.9 Agriculture (Stationary Fuel Combustion) ...................................................................... 61

3.10 Commercial Stationary Fuel Combustion...................................................................... 63

3.11 Residential Buildings..................................................................................................... 66

3.11.1 Single-Family Homes........................................................................................ 67

3.11.2 Multi-Family Residential Buildings.................................................................. 68

References..................................................................................................................................... 73

Appendix A................................................................................................................................... 78

Appendix B ................................................................................................................................... 79
1

Technical Support Document for Permit Thresholds for Greenhouse Gases 

1. Purpose 

The purpose of this document is to provide the background information that was used to 

support EPA's decision process on evaluating and selecting greenhouse gas (GHG) major source 

applicability thresholds for Prevention of Significant Deterioration (PSD) and Title V permitting 

for EPA’s final rule “Prevention of Signficant Deterioration and Title V Greenhouse Gas 

Tailoring Rule”. The document describes the analysis used to estimate the number of existing 

and new facilities (e.g., industrial plant or commercial building) that would exceed different 

GHG emission threshold levels. The document also summarizes the results of this analysis for 

each sector. The results of this analysis served as one of the fundamental bases for evaluating 

administrative burdens at both existing permitting thresholds and for evaluating and selecting 

proposed alternative permitting thresholds to address administrative necessity concerns. 

2. Overview 

In order to support EPA's assessment of the administrative burden created by adding 

GHGs to existing Prevention of Significant Deterioration (PSD) and Title V permitting 

programs, it was necessary to develop information on the number of affected facilities at both the 

current permitting major source thresholds (generally, 100 tons per year for Title V and 100 or 

250 tons per year for PSD depending on the source category classification) and at alternative 

higher thresholds. An affected facility would be one who's annual emissions of the GHG equal 

or exceed the major source threshold being evaluated. 

 Eight threshold levels ranging from 100 to 100,000 tons per year of GHG emissions were 

evaluated. Some of the alternative thresholds evaluated are the same as ones (e.g., 25,000 tons 

per year CO2-equivalents) considered in previous studies and in support of EPA's proposed and 

final GHG mandatory reporting rules (GHG MRR, 74 FR 68, pp. 16447 – 16731 and 74 FR 209, 

pp. 56260-56519, respectively). One key difference between the emissions data developed for 

this analysis and the emissions data developed to support the proposed GHG MRR is that this 

analysis is based on a facility's "potential to emit" (PTE) while the proposed GHG reporting rule 

was based on "actual" emissions (i.e., the emissions a facility actually emits in a given year). 

PTE is defined as the maximum capacity of a stationary source to emit a pollutant under its 

physical and operational design, including certain legal limitations, for example, on emissions or 

hours of operation. NSR and Title V programs both use PTE for defining major sources. The 

end result is generally that more facilities will exceed a given threshold on a PTE basis than on 

an actual basis. This is an important differentiation in terms of both evaluating the thresholds 

under this rule and when comparing the results to other threshold analysis, such as the supporting 

data for the EPA's GHG MRR. 
2

 Although the primary focus of this analysis was on the potential administrative burden 

associated with different GHG permitting emission levels as represented in terms of number of 

facilities potentially subject to permitting, information on GHG emissions from affected facilities 

was also collected to assess the relative coverage of national stationary source GHG emissions at 

the different threshold levels. While the environmental impact associated with the different 

GHG permitting levels was not used as the basis for the GHG applicability thresholds identified 

in the final GHG tailoring rule, the information on national emissions coverage provides a useful 

measure to consider the potential scope of the proposed alternative thresholds, their coverage of 

key GHG emission source categories, and whether they promote the environmental purposes of 

the PSD and Title V programs. 

3. Emissions-based Threshold Analysis 

3.1 General Description of Overall Approach 

This section presents a general description of the overall approach EPA used to evaluate a 

range of permitting thresholds in terms of the number of sources affected, and amount of 

emissions covered. 

EPA made use of earlier analyses performed to develop emission thresholds for the 

proposed and final GHG MRR, or used the same data sources when additional analyses were 

required. EPA did not conduct primary research for this analysis, but instead relied on published 

research and publicly available government data, such as EPA's eGRID database of electric 

generating source emissions, Economic and Housing Census data, and Energy Information 

Agency (EIA) data on energy consumption. 

3.1.1 Threshold Levels

 EPA evaluated eight different GHG emission thresholds: 

 GHG Thresholds 

 (tons per year) 

100 

250 

1,000 

5,000 

10,000 

25,000 

50,000 

100,000 

The first two thresholds are the current Clean Air Act major source criteria pollutant 

thresholds for the federal operating permit program under Title V (generally, 100 tpy for major 
3

source applicability), and the PSD construction permit program under Title I. Under PSD, a 

"major stationary source" is any source belonging to a specified list of 28 source categories 

which emits or has a PTE of 100 tpy or more, or any other source type which emits or has the 

potential to emit such pollutants in amounts equal to or greater than 250 tpy. 

The six additional thresholds cover the range of thresholds evaluated for the proposed 

GHG MRR, and add two additional thresholds at 5,000 and 50,000 tons per year. Like the Clean 

Air Act, the permit thresholds are based on U.S. short tons (tons) instead of metric tons (mtons). 

There is a three-orders-of-magnitude range in the thresholds which reflects the much 

higher quantity of GHG emissions compared to criteria pollutant emissions from the primary 

source of GHG emissions, fossil fuel combustion. For example, an uncontrolled natural gasfired boiler that emits 100 tons of NOx annually would at the same time emit about 100,000 tons 

of CO2. 

 The threshold analysis of source counts and emissions was done on a "potential to emit" 

basis, because that is the basis that is relevant for the permitting requirements under PSD and 

title V. Potential emissions (in short tons) from each source were evaluated against the threshold 

levels in order to determine whether or not a source would be included in the threshold count. 

When a source was identified as being covered by a given threshold level, the actual emissions 

from that source were included to determine the emissions covered by the threshold. In other 

words, where summary tables present "Tg GHG Emissions Covered per Year" these are the 

actual emissions that would be covered by the threshold level, given the source count arrived at 

considering potential to emit emission levels. 

3.1.2 Greenhouse Gases

EPA evaluated emissions of the major GHGs that are directly emitted by human activities 

at the eight threshold levels. The GHGs evaluated are shown below in Table 1. For purposes of 

this analysis emissions were evaluated on both an individual GHG mass basis and CO2-

equivalent basis (CO2e). CO2e normalizes the different heat trapping capacities of the different 

GHGs to that of CO2. A quantity of a GHG is converted to a CO2e basis by multiplying the mass 

of the compound emitted by its Global Warming Potential (GWP). The GWP is a metric that 

incorporates both the heat-trapping ability and atmospheric lifetime of each GHG relative to 

CO2. 
4

Table 1 

Major GHGs Directly Emitted by Human Activities 

Greenhouse Gas 

Chemical Formula 

or Acronym 

Global Warming 

Potential (GWP)* 

Carbon dioxide CO2 1 

Methane CH4 21 

Nitrous oxide N2O 310 

Perfluorocarbons PFCs Varies by compound 

Hydrofluorocarbons HFCs Varies by compound 

Sulfur hexafluoride SF6 23,900 

* GWP values as codified in the EPA’s final GHG mandatory 

reporting rule: Table A-1 to Subpart A of Part 98 – Global 

Warming Potentials, FR, Vol.74, No. 209, p. 56395. 

 Sector descriptions contained in this document include a discussion of GHGs evaluated 

for each sector. If the analysis included more than one GHG, the description includes gasspecific counts as well as a CO2e count. The threshold analyses for stationary fossil fuel 

combustion were simplified by excluding CH4 and N2O emissions, because CO2 comprises over 

99 percent of GHG emissions from fossil fuel combustion. 

3.1.3 Source Sectors 

In this analysis EPA evaluated the same range of stationary source types with direct GHG 

emissions as identified in the proposed and final GHG MRR. The proposed GHG MRR source 

categories were based on a comprehensive review of all U.S. source categories with GHG 

emissions, to include the categories that emit the most significant amount of GHG emissions. 

The stationary sources evaluated in this analysis can be grouped in the sectors shown below: 

● Electricity Generation (facilities with fossil fuel-fired electric generating units); 

● Industry (range of industries with process and combustion GHG emissions); 

● Energy (oil and gas extraction, transport, and processing; underground coal mining); 

● Waste Treatment (landfills and municipal solid waste incinerators); 

● Agriculture (stationary fuel combustion); 

● Commercial (stationary fuel combustion); and 

● Residential (stationary fuel combustion). 
5

 A number of direct emission source types included in the GHG MRR analysis were not 

included in the potential to emit analysis because the GHG emissions from these sources were 

primarily fugitive emissions. Fugitive emissions are emissions which are not released, or could 

not be reasonably released, through a stack or vent. Under the PSD rules, fugitive emissions are 

only included in potential to emit estimates if the source is one of 28 listed PSD source 

categories. Excluded fugitive emissions sources are listed below: 

● Electrical equipment SF6 emissions; 

● Wastewater treatment plants not associated with one of 28 listed PSD source categories 

(combustion is captured in the commercial sector analysis); and 

● Agricultural manure management. 

3.1.4 Potential to Emit Methodology

As noted earlier, the potential to emit (PTE) is the amount of emissions that can be 

emitted from a source operating at full capacity. The annual PTE is based on operation at full 

equipment capacity, 24 hours per day, 365 days per year (8,760 hours per year). For example, if 

a boiler has a maximum rated heat input capacity of ten million Btu per hour, the annual PTE for 

that boiler is the amount of emissions from burning 87,600 million Btu of fuel: 

10 mmBtu/hr x 8,760 hrs/yr = 87,600 mmBtu/yr 

Capacity information and annual GHG emissions were available for some of the source 

categories from analyses performed to support the GHG MRR. In some cases the supporting 

analyses had already calculated GHG emissions on a full capacity basis, in which case EPA 

directly used those estimates as PTE estimates. Alternatively, some data from the supporting 

analysis estimated actual annual emissions using a baseline year. If capacity and baseline year 

production information was provided in the supporting data, EPA adjusted the source actual 

emissions estimate by the ratio of annual capacity to baseline production to estimate PTE. If 

capacity information was not available, EPA used capacity factors from other data sources to 

adjust actual emission estimates to PTE estimates. These capacity factors add varying 

uncertainty to the PTE estimate. Detailed descriptions of the different PTE calculation 

methodologies are included in the source descriptions in the following section. 

 Removal by pollution control equipment was considered in the PTE estimates, though 

control equipment removal was relevant in only a few cases (thermal oxidation of HPCs and 

CH4). Also, as noted earlier, fugitive emissions, were only included in the PTE estimates if the 

source was one of the 28 listed PSD source categories. For example, fugitive CH4 emissions 

from oil and gas transmission stations were not included in CH4 or CO2e emissions when 

comparing to the different thresholds, but were included for iron and steel plants. 
6

3.1.5 New Construction

The source population data from the analyses supporting the GHG MRR, and other data 

sources provide information on existing sources and their emissions. The PSD and title V 

program requirements and applicability determinations, however, also apply to newly 

constructed sources. 

The general approach for estimating the annual number of newly constructed sources was 

to apply growth rates in the number of units or facilities in a source category to the number of 

existing facilities at the different thresholds. Growth rates were available from a variety of 

sources including Economic Census data, EIA energy survey data, and various EPA regulatory 

impact analyses and information collection requests which require source population estimates. 

In some cases there was sufficient information to distribute new sources to different thresholds 

based on emission information specific to the new sources (electric generating, municipal solid 

waste combustors, and commercial stationary fuel combustion). Otherwise EPA assumed the 

same size and threshold distribution for new units as for existing units. For example, if the 

annual growth rate in a category was one percent, the number of existing facilities above a 

threshold were multiplied by the fractional growth rate to estimate the number of new facilities at 

that threshold per year. 

EPA did not develop estimates for modifications to exsiting sources (which can be 

potentially subject to PSD requirements) as part of this threshold study; estimates for 

modifications were prepared under a separate burden analysis prepared for the final GHG 

tailoring rule and located in the final docket for the rulemaking13. 

3.2 Threshold Summary Results 

The resulting counts of affected stationary source facilities and the amount of actual 

GHG emissions covered at different PTE thresholds for all sectors are shown in the tables below. 

GHG emissions covered at each threshold are in Tg, which is equivalent to million metric tons. 

SI units were used for the covered emissions to be consistent with the EPA’s official U.S. GHG 

Inventory so that comparions could be made to the inventory in terms of emissions coverage at 

different applicability thresholds. The complete data for the sectors and subsectors are provided 

in supporting spreadsheets that accompany this report. These spreadsheets are identified in 

Appendices A and B. 

 

13 See “Summary of Methodology and Data Used to Estimate Burden Relief and Evaluate Resource Requirements at 

Alternative Greenhouse Gas (GHG) Permitting Thresholds” contained in the public docket for the final tailoring 

rule at EPA-HQ-OAR-2009-0517. 
7

Table 2 

CO2e Threshold Summary -- All Stationary Source Sectors 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year)

100 6,118,252 67,469 3,867 

250 1,079,483 19,755 3,786 

1,000 302,863 4,430 3,723 

5,000 59,140 549 3,622 

10,000 30,341 313 3,564 

25,000 16,564 140 3,493 

50,000 9,980 96 3,387 

100,000 5,326 72 3,267 

Table 3 

CO2 Threshold Summary -- All Stationary Source Sectors 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year)

100 6,113,861 67,469 3,651 

250 1,075,078 19,755 3,570 

1,000 298,527 4,430 3,513 

5,000 55,313 549 3,413 

10,000 26,836 313 3,357 

25,000 13,637 139 3,293 

50,000 8,109 96 3,212 

100,000 4,226 72 3,114 
8

Table 4 

CH4 Threshold Summary -- All Stationary Source Sectors 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year) 

100 4,201 0 7.807 

250 3,851 0 7.759 

1,000 2,887 0 7.321 

5,000 1,042 0 4.740 

10,000 466 0 3.697 

25,000 138 0 2.234 

50,000 34 0 1.185 

100,000 3 0 0.211 

Table 5 

N2O Threshold Summary -- All Stationary Source Sectors 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

N2O Emissions 

Covered 

(Tg per year) 

100 47 0 0.074 

250 46 0 0.074 

1,000 31 0 0.068 

5,000 5 0 0.022 

10,000 0 0 0 

25,000 0 0 0 

50,000 0 0 0 

100,000 0 0 0 
9

Table 6 

High GWP Gases Threshold Summary -- All Stationary Source Sectors 

GHG 

GHG 

Threshold* 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

GHG Emissions 

Covered 

(Tg per year) 

HFC 100 3 0 0.001 

HFC 250 3 0 0.001 

HFC 1,000 1 0 0.001 

HFC 5,000 and above 0 0 0 

PFC 100 and above 0 0 0 

SF6 100 and above 0 0 0 

* Where a threshold is not listed for a particular GHG, threshold counts for that threshold and any higher 

thresholds can be assumed to be zero. 

3.3 Electricity Generating Sector 

Data Sources 

The latest version of EPA's eGRID database (2006) was used to estimate the PTE of 

electricity generating facilities and counts of units above the different emission thresholds. The 

eGRID database includes year 2004 characteristics, operating information, and annual emissions 

(including CO2) for U.S. facilities that have a generation capacity greater than one MW, and sell 

electric power to the grid. 

 A facility's PTE was estimated based on the eGRID generator table. The generator table, 

which is based on the 2004 EIA form 860 database, provides prime mover, generator nameplate 

capacity, and primary energy source (fuel type) for each generator down to 0.1 MW. To 

calculate PTE, we combined the nameplate capacity and primary fuel for each of the fossil-fired 

units with average fuel based prime mover heat rates (Btu/kWh) published by EIA (EIA, 2007). 
10

Table 7 

EGU Prime Mover Heat Rates 

(EIA Electric Power Annual, Table A7, 2007) 

Prime Mover Fuel Average Heat Rate (Btu/kWh) 

Coal 10,114 

Steam turbine Gas 10,466 

Oil 10,400 

Simple Gas 11,459 

combustion turbine Oil 13,216 

Combined cycle Gas 7,445 

combustion turbine Oil 11,015 

Gas 9,923 Internal 

combustion engine Oil 10,149 

 The eGRID database includes cogeneration plants and generating units at industrial 

plants that primarily supply electric power and steam to a host facility. We eliminated these 

units from the electric generation facility population based on North American Industry 

Classification System (NAICS) code, so that the only facilities included were facilities with a 

NAICS code beginning with 22 (Utilities). 

 The generator-nameplate-heat-rate approach potentially underestimates PTE for 

cogeneration plants, where a portion of the burner heat input provides useful thermal energy in 

addition to electric output. This potential to underestimate PTE affects 321 of 2,237 or 14 

percent of facilities evaluated. 

Methodology for Existing Facilities 

 Fuel combustion was the only source of GHG emissions considered for the electricity 

generation sector. From the eGRID and EIA information EPA calculated a maximum annual 

fuel heat input based on 8,760 hours of operation for the combustors associated with the 

generator. This calculated maximum annual heat input was used with fuel combustion emission 

factors from the GHG MRR for the primary fuel, to calculate the facility PTE. The calculations 

covered 10,487 fossil fuel-fired generators with nameplate capacities down to 0.1 MW or 

100,000 kW. 

 EPA also did not evaluate fugitive CH4 emissions from facility coal piles. Fossil fuelfired steam electric plants with heat input greater than 250 mmBtu/hr heat input are one of the 28 

listed PSD source categories that include fugitive emissions when calculating PTE. However, 

the CO2 PTE from combustion alone for this size facility is about 225,000 tons per year. This is 
11

well over all of the emission thresholds considered in this analysis without consideration of the 

contribution of fugitive CH4. 

New Units 

 The eGRID generator table includes an online year field. To determine the number of 

new units per year at different thresholds EPA counted generators online each year and totaled 

the emissions associated with those generators at the facility level over the 15-year period from 

1990 through 2004. Counts were made of the number of these facilities over the different PTE 

thresholds, and averaged over the 15 years to arrive at the number of new or modified facilities 

per year. 

Threshold Summary 

 The table below shows the facilities and emissions covered at the different emission 

thresholds based on the described methodology. There were a total of 2,237 facilities in the 

electric generation population, so all facilities and all emissions are covered up to the 5,000 ton 

PTE threshold. Almost all emissions (99.9 percent), and about 75 percent of facilities are 

covered at the highest 100,000 ton PTE threshold. 

Table 8 

CO2 Threshold Summary Results -- Electricity Generating Sector 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2Emissions 

Covered 

(Tg per year)

100 2,237 93 2,373 

250 2,237 93 2,373 

1,000 2,237 93 2,373 

5,000 2,237 91 2,373 

10,000 2,195 86 2,373 

25,000 2,076 73 2,373 

50,000 1,911 64 2,373 

100,000 1,721 60 2,371 

3.4 Industrial Sector 

The industrial sector comprises establishments engaged in the mechanical, physical, or 

chemical transformation of materials, substances, or components into new products, and 

specifically includes businesses classified in Sectors 31 – 33 according to the North American 
12

Industry Classification System (NAICS). Industrial source greenhouse gases result from 

manufacturing processes as well as combustion processes. Because there is a great deal of 

variability within the sector, this technical support document includes industry-specific 

discussions after a general sector overview. 

For the industrial sector, EPA considered the six individual greenhouse gases separately, 

and also prepared an analysis considering CO2e. In preparation of the GHG MRR, EPA 

identified 23 industrial sectors where the GHG emissions were significant; these sectors are 

listed in Table 9. 
13

Table 9 

Industrial Sectors and GHG Emissions 

NAICS Code Industrial Sector CO2 CH4 N2O SF6 HFC PFC 

325199 Adipic Acid Production X X 

331312 Aluminum Production X X 

325311 Ammonia Production X 

327310 Cement Production X 

334 Electronics Manufacturing X X X X 

325193 Ethanol Production X 

331112 Ferroalloy Production X X 

3116 Food Processing X 

327 Glass Production X 

325120 HCFC-22 Production X X 

 Hydrogen Production X 

331111 Iron and Steel Production X X 

3314 Lead Production X 

327410 Lime Manufacturing X 

3314 Magnesium Production X X 

325311 Nitric Acid Production X X 

3251 Petrochemical Production X X 

324110 Petroleum Refineries X X 

325312 Phosphoric Acid Production X 

3221 Pulp and Paper Manufacturing X 

327910 Silicon Carbide Production X X 

325181 Soda Ash Manufacturing X 

325188 Titanium Dioxide Production X 

3314 Zinc Production X 

In addition, there are a large number of industrial establishments across all industrial 

sectors that emit less significant amounts of GHGs (primarily CO2) from stationary source fuel 

combustion. Combustion emissions from these establishments were analyzed under the 

Unspecified Industrial Stationary Combustion source category. 
14

3.4.1 Data Sources

There were several primary data sources used in preparation of the permit threshold 

analysis. EPA consulted analyses prepared in support of the GHG MRR for the 23 industrial 

sectors for which combustion, process and fugitive emissions were significant. These documents 

can be found in the docket numbered EPA-HQ-OAR-2008-0508. The TSDs contain industryspecific analyses of process, fugitive, and combustion emissions for industries. Supporting 

analyses used to prepare the TSDs are found in entries 0046.7 and 0046.8 of the GHG MRR 

docket. These emissions estimate details were helpful in breaking down TSD emission estimates 

to compare facility-specific emissions against the additional threshold levels considered in the 

permit threshold analysis, including 100, 250, 5,000, and 50,000 tons per year. 

Combustion emissions analyses for the Unspecified Industrial Stationary Combustion 

sectors used data from the 2002 Manufacturing Energy Combustion Survey (MECS) and the 

U.S. Census Bureau's 2002 Economic Census. MECS is a survey of manufacturing and 

industrial energy uses and costs prepared by the EIA (EIA, 2007). Data is collected by 

manufacturing establishment through mailed questionnaires. The 2002 MECS data reflects 

responses accounting for approximately 98 percent of the manufacturing payroll, and reports 

separate energy use estimates for 48 NAICS industrial sector groups. The MECS provided 

information on the amount of fuel burned in 2002 by sector on an employment basis. The 2002 

Economic Census data provided information on the number of establishments sorted by threedigit NAICS code and disaggregated into specific size categories based on employment (U.S. 

Census, 2004). 

3.4.2 Potential to Emit

As mentioned earlier in this document, permit threshold analyses considered both actual 

emissions and PTE. When capacity information was not available, the analyses applied 

utilization rates from the Industrial Production and Capacity Utilization, Federal Reserve 

Statistical Release G-17 in order to adjust actual emissions to determine PTE emissions. These 

utilization rates are prepared quarterly with annual revisions, and are published on the web 

(http://www.federalreserve.gov/releases/g17). The main data source for the industrial production 

and capacity utilization rates is the U.S. Census Bureau's Census of Manufactures. Data 

introduced from other Census Bureau publications include the Census of Services and the 

Services Annual Survey (for publishing) and selected Current Industrial Reports. Additional 

government source data include new annual data on minerals from the U.S. Geological Survey 

(USGS) and updated deflators from the Bureau of Economic Analysis (BEA). In addition, the 

annual revisions include monthly production estimates that reflect updated seasonal factors and 

the inclusion of monthly source data that became available (or were revised) after the closing of 

the regular four-month reporting window. 

3.4.3 Methodology for New Units
15

 To determine the number of new units per year, EPA compared the number of 

establishments by three-digit NAICS code in 1998 to the number of establishments by three-digit 

NAICS code in 2002, and determined an average annual growth rate for each three-digit NAICS 

code. The growth rates were applied to each threshold count to determine the number of annual 

new establishments per industry per threshold. If the growth rate was determined to be negative, 

EPA assumed that no new establishments would be added; however, establishments were not 

reduced to reflect negative growth rates. EPA also supplemented these growth rates with agency 

estimates of expected new sources from various information collection requests (ICR) and 

regulatory impact analyses (RIA) efforts. 

3.5 Methodology for Existing Unspecified Industrial Stationary Combustion Source 

Category Emissions 

 In order to determine establishment counts and emissions totals for the unspecified 

industrial stationary combustion sources, EPA used 2002 Economic Census data showing 

manufacturing employment by NAICS code and Manufacturing Energy Consumption Survey 

(MECS) data published by EIA. Calculating greenhouse gas emissions required determining 

energy consumption per employee by industry and applying emission factors specific to the 

consumption profile derived from MECS data. 

The Economic Census data (2002) provide a count of establishments by employment 

category, where employment category is defined by number of employees (e.g., 1 – 4, 

5 – 9,...,500 – 999,...,more than 2,500). The MECS energy consumption data provide energy 

consumption by industry. Both the employment data and the energy consumption data are 

organized according to the NAICS codes. 

As part of this analysis, EPA calculated industry-specific GHG emission factors. The 

factors were calculated by considering actual fuel consumption in 2002, as determined by EIA. 

Actual fuel consumed was multiplied by fuel-specific GHG emission factors to determine GHG 

emissions by fuel type by industry. To simplify the analysis, EPA only included CO2 emissions 

and ignored CH4 and N2O in the CO2e calculations. CO2 makes up between 99.3 and 99.7 

percent of estimated CO2e emissions. Emissions for each fuel type were combined to determine 

total emissions for a sector. Total emissions per sector were divided by total energy 

consumption per sector to determine a factor to calculate GHG emissions per mmBtu of energy 

consumption specific to the industrial sector. 

The GHG emission factors were then multiplied by the energy consumption per 

employee in order to determine emissions per employee. Multiplying the result by the average 

number employees per establishment, EPA determined total GHG emissions per establishment. 

The total emissions numbers were used to determine number of establishments and volume of 

emissions that would be caught by each of the permit thresholds under consideration. 

As discussed previously, a separate threshold analysis was conducted for 23 industrial 

sectors determined to have significant GHG emissions in the GHG MRR analysis. In order to 

quantify the unspecified industrial stationary combustion source emissions, the combustion 
16

emissions and establishment counts from 19 of these sectors were subtracted from the total 

industrial MECS analysis. For the remaining four industries, HCFC-22 production, hydrogen 

production, magnesium production, and nitric acid production, EPA could not readily isolate 

combustion emissions. For these industries, their establishment counts were subtracted from the 

unspecified industrial source threshold counts based on process emission threshold evaluations, 

assuming that any facility exceeding a threshold for process-based emissions would exceed the 

threshold regardless of their combustion CO2 emissions. 

Potential to Emit 

In order to determine potential to emit from the MECS and Economic Census numbers, 

EPA assumed a capacity utilization factor of 50%. There is a wide variety of generally smaller 

manufacturing sources included under this general source category. Based on comments we 

received on the proposed GHG tailoring rule, we are using a 50% capacity utilization rate for this 

final analysis to better reflect what can be deemed reasonable operation under normal conditions 

for facilities in these source categories. Sources may operate their combustion equipment at 

levels above and below this capacity utilization rate, but we believe the 50% utilization rate 

reflects a reasonable average rate across the variety of facilities represented in this category. 

New Units 

EPA applied industry-specific growth rates to each sector and summed across sectors in 

order to determine number of new units. 

Threshold Summary 
17

Table 10 

CO2e Threshold Summary -- Unspecified Industrial Stationary Combustion 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 172,142 546 372.307 

250 112,659 319 367.636 

1,000 64,535 239 357.855 

5,000 20,785 83 318.759 

10,000 12,215 61 289.198 

25,000 5,875 18 245.579 

50,000 3,272 12 206.881 

100,000 958 2 145.106 

3.6 Methodology for Existing Specific Industrial Sectors Considering Combustion, 

Process, and Fugitive Emissions 

These analyses were based primarily on the GHG MRR TSDs and the supporting 

analyses, including facility specific emission information. The estimates considered each 

greenhouse gas separately. The GHG MRR TSDs included threshold counts and emissions 

calculations for 1,000, 10,000, 25,000, and 100,000 metric tons per year. Two steps were 

required for permit threshold consideration. First, emissions were recalculated in order to 

conduct the analysis in short tons for comparison to the permit thresholds. Second, the emissions 

were considered against the finer threshold stratification considered in the permit threshold 

analysis. 

For the permit threshold analysis, EPA determined that if the GHG MRR analysis 

showed all of the establishments exceeded a threshold, after adjustment for short tons, all of the 

establishments exceeded any lower thresholds. However, where fewer than 100 percent of the 

establishments exceeded a threshold, additional analysis was required to compare emissions to 

the permit thresholds of 100, 250, 5,000, and 50,000 tons per year. EPA used the supporting 

summaries for the GHG MRR which included facility-specific consumption, process, and 

fugitive emission reports in order to determine counts and emissions for each of the permit 

thresholds. 
18

3.6.1 Adipic Acid Production

 There are four Adipic Acid Production plants in the U.S., all of which are estimated to 

exceed the highest 100,000 metric tons per year emission threshold for CO2e on an actual 

emissions basis. Therefore all plants will also exceed all PTE thresholds on a CO2e basis. The 

CO2e emission estimate includes N2O process emissions that total about 5.9 million metric tons 

CO2e, and 3.4 million metric tons of CO2 from stationary fuel combustion sources. 

N2O 

Individual plant production and emission estimates were not made available because of 

confidential business information (CBI) claims. However, from the Technical Support 

Document for the Adipic Acid Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases (EPA-HQ-OAR-2008-0508-0005), overall U.S. adipic acid production was 

estimated to total approximately one million metric tons in 2006. The smallest U.S. plant only 

produced about two percent of the total. This plant, however, is the only plant that is 

uncontrolled. The three larger plants with the bulk of production have control equipment with 

N2O control efficiencies that range from 90 to 99 percent. 

The uncontrolled N2O emission factor is 300 kg N2O/mton adipic acid. Based on the two 

percent production share, this uncontrolled plant emitted about 6,000 metric tons of N2O (no 

GWP adjustment). This leaves about 13,100 metric tons of N2O from the three larger controlled 

plants. Two plants representing about 64 percent of production have control efficiencies in the 

range of 90 to 95 percent, and one plant with about 34 percent of production has control close to 

99 percent (EPA, 2001). 

 Assuming similar production shares today, the share of national production (which is 

assumed for this analysis to be equivalent to capacity) appears to range from 30 to 35 percent for 

the three plants. Therefore, emissions and PTE for the controlled plants range from to 4,000 

metric tons to 4,700 metric tons of N2O per year. 

CO2

The CO2 emissions from fuel combustion can similarly be apportioned to the four plants. 

The smallest plant, with only two percent of national production, is estimated at CO2 emissions 

of 67,500 metric tons, and the next smallest, with 30 percent of national production, is estimated 

at 101,300 metric tons. 

Potential to Emit 

 The PTE for each facility was assumed to be equivalent to the emissions based on the 

apportionment described above. 

New Units 

EPA assumed that no new plants would be constructed for this sector. 
19

Threshold Summary 

Table 11 

CO2 Threshold Summary -- Adipic Acid Production

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year)

100 4 0 3.376 

250 4 0 3.376 

1,000 4 0 3.376 

5,000 4 0 3.376 

10,000 4 0 3.376 

25,000 4 0 3.376 

50,000 4 0 3.376 

100,000 3 0 3.309 

Table 12 

N2O Threshold Summary -- Adipic Acid Production

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

N2O Emissions 

Covered 

(Tg per year)

100 4 0 0.019 

250 4 0 0.019 

1,000 4 0 0.019 

5,000 1 0 0.006 

10,000 0 0 0 

25,000 0 0 0 

50,000 0 0 0 

100,000 0 0 0 

Table 13 

CO2e Threshold Summary -- Adipic Acid Production 
20

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 4 0 9.298 

250 4 0 9.298 

1,000 4 0 9.298 

5,000 4 0 9.298 

10,000 4 0 9.298 

25,000 4 0 9.298 

50,000 4 0 9.298 

100,000 4 0 9.298 

3.6.2 Aluminum Production

The primary aluminum production process results in emissions of CO2 and PFCs. The 

reduction of the alumina occurs through electrolysis in a molten bath of natural or synthetic 

cryolite (Na3AlF6). The reduction cells contain a carbon lining that serves as the cathode. 

Carbon is also contained in the anode, which can be a carbon mass of paste, coke briquettes, or 

prebaked carbon blocks from petroleum coke. During reduction, most of the carbon in the anode 

is oxidized and released to the atmosphere as CO2. 

Potential to Emit 

CO2

 The Technical Support Document for Process Emissions from Primary Production of 

Aluminum: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR2008-0508-0006) apportioned CO2 emission estimates from the U.S. GHG inventory to the 13 

operating smelters based on each smelters share of total capacity. Operating smelter emissions 

were all above 100,000 tons of CO2, so no PTE estimate was required. Capacity information for 

the two idle smelters shows that these smelters are also capable of emitting over 100,000 tons of 

CO2 per year.

PFCs 

 The reduction cells also emit two PFCs: perfluoromethane (CF4) and perfluoroethane 

(C2F6). The GWPs of the two PFCs are 6,500 and 9,200 respectively. During the smelting 

process, when the alumina ore content of the electrolytic bath falls below critical levels required 

for electrolysis, rapid voltage increases occur, which are termed "anode effects." Anode effects 
21

cause carbon from the anode and fluorine from the dissociated molten cryolite bath to combine, 

and produce fugitive emissions of CF4 and C2F6. 

Anode effects released approximately 2.5 million metric tons of CF4 and C2F6 in 2006 as 

documented in the GHG MRR TSD. CF4 made up at least 85 percent of the combined emissions 

in 2006 (Inventory of U.S. GHG Emissions and Sinks: 1990 – 2007). These emissions on a 

CO2e basis are equivalent to about 410 short tons of combined emissions as PFC. The proposed 

GHG MRR TSD estimated CO2e emissions from primary aluminum smelters at full capacity. 

The largest smelter has 11 percent of U.S. operating capacity. Therefore the largest smelter has a 

PTE of not more than 45 tons of PFC, and no facilities have a PTE greater than 100 tons. 

New Units 

No new primary aluminum facilities are expected to be built. The growth rate in primary 

metals from the Economic Census data is only about 0.4 percent. 

Threshold Summary 

Threshold summaries are displayed below for CO2 and CO2e. All facilities have a PFC 

PTE less than 100 tons per year on a PFC basis. 

Table 14 

CO2 Threshold Summary -- Primary Aluminum 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

GHG Emissions 

Covered 

(Tg per year)

100 15 0 3.800 

250 15 0 3.800 

1,000 15 0 3.800 

5,000 15 0 3.800 

10,000 15 0 3.800 

25,000 15 0 3.800 

50,000 15 0 3.800 

100,000 15 0 3.800 
22

Table 15 

CO2e Threshold Summary -- Primary Aluminum 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

GHG Emissions 

Covered 

(Tg per year) 

100 15 0 3.951 

250 15 0 3.951 

1,000 15 0 3.951 

5,000 15 0 3.951 

10,000 15 0 3.951 

25,000 15 0 3.951 

50,000 15 0 3.951 

100,000 15 0 3.951 

3.6.3 Ammonia Production

 EPA reviewed the proposed Supporting Data for Threshold Analysis Subpart E – W, 

Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-

0508-0046.7) to determine actual emissions and calculate the potential to emit for 24 ammonia 

plants in operation. The analysis spreadsheet details CO2 actual emission calculations for each 

plant based on ammonia production and urea production, and CO2, CH4, and N2O emission 

calculations for stationary fuel combustion based on 2006 data. For purposes of permit threshold 

analysis, the CH4 and N2O emissions from combustion were not significant. 

Potential to Emit 

Capacity information in the spreadsheet is based on the engineering design capacity 

adjusted for 340 days per year of effective production capability, using information provided by 

the United States Geological Survey (USGS). The PTE estimates were made by multiplying the 

actual emission estimates by the ratio of annual ammonia capacity to annual ammonia 

production adjusted to 365 days a year of operation instead of 340. EPA assumed that ratio also 

held for stationary combustion units at the plant. 

New Units 

EPA assumed that no new plants would be constructed for this sector. 
23

Threshold Summary 

Table 16 

CO2e Threshold Summary -- Ammonia Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 24 0 14.543 

250 24 0 14.543 

1,000 24 0 14.543 

5,000 24 0 14.543 

10,000 24 0 14.543 

25,000 24 0 14.543 

50,000 24 0 14.543 

100,000 22 0 14.540 

3.6.4 Cement Production

Process-related CO2 emissions from cement production are the second largest source of 

industrial CO2 emissions in the United States. Cement production is done in two stages. The 

first stage is clinker production. In clinker production, raw materials (primarily limestone) are 

heated to induce calcination and produce lime. Lime reacts with silica-containing materials and 

iron ore and aluminum to form clinker. During the process, CO2 is generated as a byproduct and 

released to the atmosphere. Also during clinker production, some of the clinker raw materials 

form partially or fully calcinated cement kiln dust instead of forming clinker, resulting in 

additional process-related CO2 emissions. In the second stage of the production process, the 

clinker is ground and mixed with gypsum and other materials to make cement. 

Potential to Emit 

The Technical Support Document for Process Emissions from Cement: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0008) shows 107 

cement facilities in the U.S., 106 of which exceed all permit thresholds for CO2 (according to the 

TSD, the one facility that does not exceed the 100,000 tons per year threshold accounted for over 

90,000 metric tons of CO2e and approximately one-tenth of one percent of the cement industry 

emissions in 2006). 

New Units 
24

Growth for the industrial sector was estimated at 0.4 percent, and as such, no additional 

facilities were included in this analysis. 

Threshold Summary 

Table 17 

CO2e Threshold Summary -- Cement Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 107 0 86.83 

250 107 0 86.83 

1,000 107 0 86.83 

5,000 107 0 86.83 

10,000 107 0 86.83 

25,000 107 0 86.83 

50,000 107 0 86.83 

100,000 106 0 86.74 

3.6.5 Electronic Production

The Technical Support Document for Process Emissions from Electronics Manufacture 

(Semiconductors, MEMs, Liquid Crystal Displays, and Photovoltaics) (EPA-HQ-OAR-2008-

0508-0009) examined emissions of high GWP gases for semiconductor and related industry 

plants. Emissions from stationary fuel combustion were not included in the source category 

analysis, but were instead captured by the unspecified industrial stationary combustion analysis. 

EPA has followed this approach here as well. 

Approximately one million metric tons of SF6 as CO2e were emitted from the 

semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 

– 2007). This is equivalent to 46 short tons of SF6. The semiconductor industry uses multiple 

long-lived fluorinated gases in plasma etching and plasma enhanced chemical vapor deposition 

(PECVD) processes to produce semiconductor products. These include PFCs, which are also 

used as heat transfer fluids. Approximately 3.5 million metric tons of PFCs as CO2e were 

emitted from the semiconductor industry in 2006 (Inventory of U.S. Greenhouse Gas Emissions 

and Sinks: 1990 – 2007). 
25

Table 18 

Electronic Production PFC Emissions 

Semiconductor PFC 

2006 CO2e Emissions

(million mtons) PFC GWP 

2006 PFC Emissions 

(tons) 

CF4 1.2 6,500 204 

C2F6 2.2 9,200 264 

C4F8 0.1 8,700 13 

Total 3.5 -- 481 

Potential to Emit 

The Federal Reserve capacity utilization factor for the electronics industry in 2006 was 

79.8 percent. Based on this capacity utilization factor the PTE of all of the semiconductor plants 

combined is estimated at 56 tons of SF6 and 600 tons of PFC. 

 EPA identified 216 facilities in the semiconductor-electronics sector. Of these, the 

largest facility emitted six percent of total semiconductor emissions on a CO2e basis (includes 

non-PFCs), which is a maximum of 30 tons of PFC. On a PTE basis, the largest facility would 

emit 36 tons, based on an assumption that the industry capacity is distributed similarly to 

emissions. Therefore no facility exceeds 100 tons per year on an actual or PTE basis for PFC. 

New Units 

Growth for the industrial sector was estimated at -1.8 percent, and as such, no additional 

facilities were included in this analysis. 

Threshold Summary 

 Electronics industry emissions from plant processes only exceed emission thresholds on a 

CO2e basis. Facility stationary fuel combustion emissions are not included in the threshold 

comparisons for the industry. 
26

Table 19 

CO2e Threshold Summary -- Electronics Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 199 0 5.948 

250 191 0 5.947 

1,000 159 0 5.934 

5,000 109 0 5.819 

10,000 88 0 5.701 

25,000 65 0 5.399 

50,000 54 0 5.100 

100,000 22 0 3.417 

3.6.6 Ethanol Production

In the proposed GHG MRR, EPA determined that the sources of GHG emissions at 

ethanol production facilities that must be reported under the proposed rule are stationary fuel 

combustion, onsite landfills, and onsite wastewater treatment. For the GHG MRR supporting 

analysis, data were unavailable to estimate facility emissions from these combined sources. 

Instead, data on stationary fuel combustion requirements for different plant capacities were used 

to estimate the minimum number of facilities that would meet each of the examined reporting 

rule facility-level thresholds. CO2 emissions from combustion constitute the majority of the 

GHG emissions from ethanol production and therefore provide an adequate measure for 

determining threshold counts. 
27

Table 20 

Ethanol Fuel Combustion CO2e Emissions by Plant Size 

(from the Proposed GHG MRR TSD Spreadsheet) 

Ethanol Produced 

(wet milling process) 

(million gallons) 

Coal Combustion Emissions 

(mtons CO2e/year) 

Natural Gas Combustion 

Emissions 

(mtons CO2e/year) 

290 1,519,585 853,536 

245 1,283,787 721,091 

200 1,047,990 588,646 

200 1,047,990 588,646 

100 523,995 294,323 

85 445,396 250,174 

40 209,598 117,729 

35 183,398 103,013 

20 104,799 58,865 

2.6 13,624 7,652 

Table 21 

Proposed Reporting Rule Threshold Analysis Results 

Threshold CO2e 

(tons per year) 

Number of Existing 

Sources -- Actual Basis 

Percent of Existing 

National Sources* 

1,000 101 72% 

10,000 93 66% 

25,000 86 61% 

100,000 43 31% 

* National ethanol production source population was estimated at 140 plants nationwide. 

Potential to Emit 

The permit threshold PTE analysis relied on this same approach and data. Therefore CH4 

emissions from onsite landfills and wastewater treatment plant digesters were not included in the 

PTE analysis, and we did not estimate emission coverage at each threshold. Also, the analysis 

for the proposed GHG MRR did not evaluate thresholds of 100, 250, 5,000, and 50,000 tons per 

year. EPA assumed that all existing plants would exceed the 100 and 250 ton per year thresholds 
28

based on fuel combustion associated with the wet milling process. For the 5,000 and 50,000 

thresholds, EPA included the number of sources exceeding the next highest threshold. For 

example, the count of sources exceeding the 5,000 tons per year level only includes the sources 

exceeding the 10,000 ton threshold in the Technical Support Document for Ethanol Facilities: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-

0010). 

New Units 

 EPA estimates that ten new ethanol production facilities will be built per year. 

Threshold Summary 

Table 22 

CO2e Threshold Summary -- Ethanol 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Sources Added 

per Year 

100 140 10 

250 140 10 

1,000 101 7 

5,000 101 7 

10,000 93 7 

25,000 86 6 

50,000 86 6 

100,000 43 3 

3.6.7 Ferroalloy Production

 In evaluating ferroalloy production in the U.S., EPA considered actual production at six 

facilities, as published in the U.S. Inventory of Greenhouse Gas Emissions and Sinks: 1990 – 

2007 for 2006, and the capacity to produce at three facilities for which production information 

was not published due to competitive concerns. 

Potential to Emit 

 EPA's PTE calculations consider the Federal Reserve's 2006 monthly industrial capacity 

utilization estimates for the primary metals industry classification which shows utilization at 85.9 
29

percent for 2006. The PTE calculations do not affect the threshold analysis, because all facilities 

emit over 100,000 metric tons of CO2e per year. 

New Units 

Applying the growth factor for the industrial sector, 0.4 percent, results in no additional 

facilities for the analysis. 

Threshold Summary 

Table 23 

CO2 Threshold Summary -- Ferroalloy Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 9 0 1.717 

250 9 0 1.717 

1,000 9 0 1.717 

5,000 9 0 1.717 

10,000 9 0 1.717 

25,000 9 0 1.717 

50,000 9 0 1.717 

100,000 9 0 1.717 

Table 24 

CH4 Threshold Summary -- Ferroalloy Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year)

100 3 0 0.0003 

250 0 0 0 
30

Table 25 

CO2e Threshold Summary -- Ferroalloy Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 9 0 1.726 

250 9 0 1.726 

1,000 9 0 1.726 

5,000 9 0 1.726 

10,000 9 0 1.726 

25,000 9 0 1.726 

50,000 9 0 1.726 

100,000 9 0 1.726 

3.6.8 Food Processing

Food processing includes meat, poultry and fruit and vegetable processing. Emissions 

derive from combustion and fugitive methane related to wastewater treatment. For purposes of 

this permit threshold analysis, EPA did not consider the fugitive methane from wastewater 

treatment because these are the only greenhouse gas emissions from the source category other 

than combustion, and food processing is not a listed PSD source category. Consequently, 

emissions from this subsector considered in this analysis were limited to combustion emissions 

and were calculated using the MECS approach. 

Potential to Emit 

EPA used the Federal Reserve's 2004 capacity utilization factor of 79.3 percent for the 

food industry to calculate PTE emissions. 

New Units 

In addition, new establishments were calculated assuming a continuation of the growth 

rate of 1.2 percent, as calculated using the methodology described earlier in this document. 
31

Threshold Summary 

Table 26 

CO2 Threshold Summary -- Food Processing 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year)

100 3946 47 16.848 

250 2281 27 16.709 

1,000 1499 18 16.379 

5,000 1030 12 15.723 

10,000 749 9 14.354 

25,000 482 6 12.257 

50,000 10 0 0.596 

100,000 0 0 0 

3.6.9 Glass Manufacturing

EPA used the Supporting Data for Threshold Analysis Subpart E – W, Greenhouse Gas 

Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7), to 

analyze emissions for permit thresholds from glass manufacturing. Annual fuel combustion and 

glass production are estimated for each plant based on 2004 estimated plant sales and 2002 

MECS energy intensity (energy per sales dollars). The spreadsheet shows CO2 emission 

estimates from industrial processes and stationary fuel combustion, as well as CH4 and N2O 

emission estimates from stationary fuel combustion. 

Potential to Emit 

Plant capacities are not available in the spreadsheet. To estimate PTE, EPA divided the 

actual annual emissions by a capacity utilization factor of 0.50 or 50 percent. 

New Units 

EPA used an estimated annual growth rate of 0.4 percent for the nonmetallic mineral 

product manufacturing sector to determine the number of new units for this analysis. 
32

Threshold Summary 

Table 27 

CO2e Threshold Summary -- Glass Manufacturing

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2eEmissions 

Covered 

(Tg per year)

100 369 1 4.425 

250 364 1 4.425 

1,000 222 1 4.341 

5,000 201 1 4.302 

10,000 175 1 4.162 

25,000 104 0 3.277 

50,000 21 0 1.208 

100,000 3 0 0.366 

3.6.10 HCFC-22 Production

 Chlorodifluoromethane (HCFC-22) is produced for use in refrigeration and air 

conditioning systems and as a chemical feedstock for manufacturing synthetic polymers. 

Because HCFC-22 depletes stratospheric ozone, its production for non-feedstock uses is 

scheduled to be phased out by 2020 under the U.S. Clean Air Act. Feedstock production, 

however, is permitted to continue indefinitely. 

 A high global warming potential (GWP) greenhouse gas, trifluoromethane (HFC-23), is 

generated as a byproduct during the manufacture of HCFC-22. Emissions of HFC-23 in 2006 

were estimated to be 13.8 million metric tons on a CO2e basis from three HCFC-22 production 

plants. Estimates were based on the plants operating at capacity. Annual emissions in terms of 

both metric tons CO2e and tons HFC-23 are summarized in Table 30 below. 
33

Table 28 

HCFC-22 Production HFC-23 Emissions 

HCFC-22 Production 

2006 CO2e Emissions 

(million metric tons) HFC GWP 

2006 HFC 

Emissions 

(short tons) 

HFC-23 13.8 11,700 1,300 

Source: Reporting Rule TSD 

Potential to Emit 

Confidential business information (CBI) claims on production information limited EPA's 

PTE analysis. The Technical Support Document for Emissions of HFC-23 from Production of 

HCFC-22: Proposed Rule for Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR2008-0508-0015) estimated that all three plants emit over 100,000 metric tons CO2e on a 

capacity basis by a factor of 85 or more, or a minimum of 800 short tons of HFC-23. These 

estimates did not account for HFC-23 capture and destruction at two of the three plants. 

Therefore, actual emissions at two of the plants will be lower, and can be limited through 

permitting. We assumed that all three plants exceed the 100 and 250 ton actual and PTE 

thresholds, and that one plant (uncontrolled) exceeds the 1,000 ton PTE threshold. 

 Because the TSD did not include estimates of CO2 emissions from fuel combustion, and 

the CBI claims noted above, the PTE analysis does not quantify fuel combustion emissions 

specifically for the three plants. Stationary fuel combustion emissions from the plants were 

instead captured under the analysis for unspecified industrial stationary combustion. 

New Units 

 U.S. production between 1990 and 2006 increased by 11 percent while emissions 

declined by 62 percent. The declines in emissions from control equipment and process changes 

offset the production increases. Therefore we did not estimate any new facilities or 

modifications that would increase facility emissions more than 100 tons per year. 
34

Threshold Summary 

Table 29 

HFC Threshold Summary -- HCFC-22 Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

HFC Emissions 

Covered 

(Tg per year)

100 3 0 0.001 

250 3 0 0.001 

1,000 1 0 0.001 

5,000 0 0 0 

Table 30 

CO2e Threshold Summary -- HCFC-22 Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 3 0 13.848 

250 3 0 13.848 

1,000 3 0 13.848 

5,000 3 0 13.848 

10,000 3 0 13.848 

25,000 3 0 13.848 

50,000 3 0 13.848 

100,000 3 0 13.848 

3.6.11 Hydrogen Production

EPA estimated CO2 emissions from merchant hydrogen production using the process and 

combustion ratio of 8.62 tons of CO2 emissions per ton of hydrogen production. About 95 

percent of all hydrogen (not just merchant hydrogen) produced in the U.S. today is made from 

natural gas via steam methane reforming. In steam methane reforming fueled by natural gas 

combustion, the process and combustion emissions go up the same stack from the 

boiler/reformer unit. Because the emissions are predominately process emissions and because 
35

the natural gas combustion products are emitted from the same stack, EPA has treated all the 

emissions as process emissions. 

Potential to Emit 

EPA developed estimates assuming hydrogen production at capacity level. Therefore, no 

adjustment to the emissions estimates is needed to account for PTE emissions. 

New Units 

Based on the industry growth factor of -0.1 percent for chemical manufacturing, EPA 

assumed that no new plants would be constructed. 

Threshold Summary 

Table 31 

CO2 Threshold Summary -- Hydrogen Production

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 75 0 15.227 

250 75 0 15.227 

1,000 74 0 15.226 

5,000 62 0 15.202 

10,000 51 0 15.130 

25,000 42 0 15.007 

50,000 38 0 14.890 

100,000 32 0 14.441 

3.6.12 Iron and Steel Production

 EPA used the Supporting Data for Threshold Analysis Subpart E – W, Greenhouse Gas 

Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7) for the 

proposed GHG MRR threshold analysis to determine process and combustion CO2 and process 

CH4. The iron and steel production source category includes taconite iron ore processing 

facilities, integrated iron and steel making facilities, electric arc furnace (EAF) steelmaking 

facilities that are not located at integrated iron and steel facilities, and coke oven facilities that 
36

are not located at integrated iron and steel facilities. Facility processes and facilities covered in 

the spreadsheet are shown in the table below. 

Table 32 

Iron and Steel Processes, Facilities, and Capacity Information 

Iron and Steel Process Number of Facilities Capacity Information 

Basic oxygen furnace (BOF) 18 Yes 

Blast Furnace (BF) 17 Yes 

Sintering 5 Yes 

Coke ovens 18 Yes 

Electric arc furnace (EAF) 92 No 

Taconite furnace 8 Yes 

Integrated steel plant fuel combustion* 19 No 

Coke oven gas combustion* 9 No 

EAF steel plant fuel combustion 92 No 

* Six plants had emissions from coke oven gas combustion was included in integrated steel plant fuel 

combustion. 

Potential to Emit 

The analysis covered 130 plants, and in all cases, except for EAF plants, GHG emissions 

were estimated based on operations at plant capacity. For EAF plants, EPA used the 2007 

Federal Reserve industrial capacity utilization percentage of 86.6 percent for primary metal -- 

iron and steel production, to adjust estimated actual emissions to PTE. 

 The spreadsheet contained emission CO2e estimates which included CO2, CH4, and N2O 

emissions. Process CH4 emissions were backed out of the CO2e totals using the process CH4

emissions reported in the U.S. GHG Inventory, and apportioning these emissions to the different 

plants based on their capacity in those processes. N2O emissions are primarily related to fuel 

combustion and were not backed out for separate treatment. 

New Units 

No new iron and steel facilities are expected to be built. The growth rate in primary 

metals from the Economic Census data is only about 0.4 percent. 
37

Threshold Summary 

Table 33 

CO2 Threshold Summary -- Iron and Steel Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per year 

CO2 Emissions 

Covered 

(Tg per year) 

100 130 0 85.150 

250 130 0 85.150 

1,000 130 0 85.150 

5,000 129 0 85.148 

10,000 128 0 85.141 

25,000 123 0 85.057 

50,000 116 0 84.831 

100,000 113 0 84.655 

Table 34 

CH4 Threshold Summary -- Iron and Steel Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year)

100 18 0 0.034 

250 17 0 0.033 

1,000 17 0 0.033 

5,000 3 0 0.011 

10,000 0 0 0 
38

Table 35 

CO2e Threshold Summary -- Iron and Steel Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 130 0 85.151 

250 130 0 85.151 

1,000 130 0 85.151 

5,000 130 0 85.151 

10,000 128 0 85.141 

25,000 123 0 85.058 

50,000 116 0 84.832 

100,000 114 0 84.656 

3.6.13 Lead Production

According to the 2006 U.S. Geological Survey (USGS), lead production in the U.S. 

includes both the primary, direct smelting (one facility) and secondary lead production (16 

facilities). Process emissions of CO2 are a byproduct of the coke consumed during the smelting 

or reforming processes. EPA calculated total process emissions based on lead production as 

reported in the USGS. 

In the Supporting Data for Threshold Analysis Subpart E – W, Greenhouse Gas 

Mandatory Reporting Rulemaking (EPA-HQ-OAR-2008-0508-0046.7), combustion emissions 

are combined with process emissions to determine total actual emissions. 

Potential to Emit 

In order to determine PTE emissions, EPA considered the Federal Reserve's 2006 

monthly industrial capacity utilization estimates for primary metals industry classification which 

shows utilization at 85.9 percent for 2006, and adjusted to achieve 100 percent utilization. 

New Units 

EPA assumed no new facilities would be added for the industry, given an expected 

growth rate of 0.4 percent per year for primary metal manufacturing industry. 
39

Threshold Summary 

Table 36 

CO2e Threshold Summary -- Lead Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 17 0 0.861 

250 17 0 0.861 

1,000 17 0 0.861 

5,000 17 0 0.861 

10,000 16 0 0.855 

25,000 13 0 0.799 

50,000 12 0 0.761 

100,000 1 0 0.089 

3.6.14 Lime

 The Supporting Data for Threshold Analysis Subpart E – W, Greenhouse Gas Mandatory 

Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR-2008-0508-0046.7) was also used to 

estimate GHG PTE for lime plants. 

Potential to Emit 

To estimate PTE, EPA divided annual actual CO2 emissions from the calcining process 

and fuel combustion emissions of CO2, CH4, and N2O by regional capacity factors available in 

the spreadsheet for each plant. The capacity factors ranged from 43 to 136 percent. 

New Units 

EPA assumed no new facilities would be added for the industry. 
40

Threshold Summary 

Table 37 

CO2 Threshold Summary -- Lime Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 89 0 27.262 

250 89 0 27.262 

1,000 89 0 27.262 

5,000 89 0 27.262 

10,000 89 0 27.262 

25,000 86 0 27.237 

50,000 66 0 26.533 

100,000 60 0 26.180 

3.6.15 Magnesium Production and Processing

The magnesium metal production (primary and secondary) and casting industry typically 

uses SF6 as a cover gas to prevent the rapid oxidation and burning of molten magnesium in the 

presence of air. A dilute gaseous mixture of SF6 with dry air and/or CO2 is blown over molten 

magnesium metal to induce and stabilize the formation of a protective crust. A small portion of 

the SF6 reacts with the magnesium to form a thin molecular film of mostly magnesium oxide and 

magnesium fluoride. The amount of SF6 reacting in magnesium production and processing is 

being studied but presently assumed to be negligible, and therefore all SF6 used is assumed to be 

emitted into the atmosphere.

 For the proposed GHG MRR Technical Support Document for Process Emissions from 

Magnesium Production and Processing: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, EPA reported that national annual SF6 emissions from magnesium 

production and processing totaled approximately 3.2 million metric tons CO2e in 2006. The 

facility population totaled 13 facilities that emitted 3.0 million metric tons CO2e. The SF6

emissions (no GWP adjustment) were 148 and 138 short tons respectively. Ten magnesium die 

casting facilities accounted for 29 percent (44 tons), and primary and secondary production 

accounted for 64 percent (96 tons) of the total emissions. Other small casting activities 

accounted for the remaining 7 percent (ten tons). 
41

Potential to Emit 

EPA used the analysis in the TSD for the proposed GHG MRR, where EPA had 

evaluated thresholds of 1,000, 10,000, 25,000, and 100,000 metric tons per year. Facility-level 

information is not made publicly available because of confidential business information (CBI) 

claims. From that earlier analysis EPA estimated that the same number of facilities exceeded the 

100, 250, and 1,000 tons CO2e per year PTE threshold as determined in the GHG MRR TSD for 

the 1,000 metric tons per year threshold. In a similar fashion, EPA used the GHG MRR TSD 

facility counts at 10,000 metric tons CO2e per year to estimate facilities at the 5,000 tons per year 

PTE threshold, and 100,000 metric tons per year for the 50,000 tons CO2e per year PTE 

threshold. The permit threshold analysis did not include CO2 emissions from fuel combustion. 

That information was not available in the TSD for the proposed GHG MRR. 

On an SF6 mass basis, the average emissions per facility are only 11 tons of SF6, well 

below 100 tons per year. Therefore we assumed that none of the facilities have a potential to 

emit more than 100 tons per year of SF6. 

New Units 

EPA assumed no new units would be added for the sector. 

Threshold Summary 

Table 38 

CO2e Threshold Summary -- Magnesium Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 13 0 2.955 

250 13 0 2.955 

1,000 13 0 2.955 

5,000 11 0 2.94 

10,000 11 0 2.94 

25,000 11 0 2.94 

50,000 9 0 2.781 

100,000 9 0 2.781 
42

3.6.16 Nitric Acid Production

EPA used the 2006 nameplate capacity (metric tons of HNO3 100 percent acid basis) for 

45 nitric acid plants and 2006 acid production from the GHG MRR TSD supporting spreadsheet 

(EPA-HQ-OAR-2008-0508-0046.7) to determine N2O emissions. 

Potential to Emit 

The GHG PTE was calculated by multiplying actual N2O emissions as CO2e by the ratio 

of nameplate capacity to 2006 production. The permit threshold analysis, based on the GHG 

MRR TSD, does not include GHG emissions from co-located stationary combustion units. Also 

the permit threshold analysis does not account for overlap between facilities in the Nitric Acid 

and Ammonia categories, which have both ammonia and nitric acid production processes. 

New Units 

EPA assumed no new units would be constructed for this sector. 

Threshold Summary 

Table 39 

N2O Threshold Summary -- Nitric Acid Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

N2O Emissions 

Covered 

(Tg per year) 

100 43 0 0.055 

250 42 0 0.055 

1,000 27 0 0.049 

5,000 4 0 0.016 

10,000 0 0 0 

25,000 0 0 0 

50,000 0 0 0 

100,000 0 0 0 
43

Table 40 

CO2e Threshold Summary -- Nitric Acid Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 45 0 17.732 

250 45 0 17.732 

1,000 45 0 17.732 

5,000 45 0 17.732 

10,000 45 0 17.732 

25,000 44 0 17.724 

50,000 43 0 17.706 

100,000 42 0 17.667 

3.6.17 Petrochemical Production 

EPA determined that the portion of the petrochemical production sector most relevant for 

permit threshold analysis includes the manufacture and production of acrylonitrile, carbon black, 

ethylene, ethylene dichloride, ethylene oxide, and methanol, because the IPCC considers 

production of greenhouse gases from these processes significant compared to other 

petrochemical processes. 

Emissions from the manufacturing processes vary significantly and process emissions 

take many forms. Process emissions include direct oxidation of CO2, off-gassing of CH4 and 

CO2, and the direct release of CO2 and CH4 from equipment leaks. Process emissions are the 

primary consideration for acrylonitrile, ethylene, and ethylene oxide processes. In addition, 

some processes require combustion of supplemental fuel. Both process and combustion 

emissions are significant for carbon black and methanol processes. 

Potential to Emit 

EPA's analysis assumed petrochemical production at the capacity level. Therefore, no 

adjustment to the emissions estimates is needed to account for PTE. 

New Units 

Based on an industry growth factor of -0.1 percent for chemical manufacturing, EPA 

assumed that no new plants would be constructed. 
44

Threshold Summary 

Table 41 

CO2 Threshold Summary -- Petrochemical Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 98 0 52.081 

250 98 0 52.081 

1,000 98 0 52.081 

5,000 97 0 52.080 

10,000 96 0 52.073 

25,000 96 0 52.073 

50,000 94 0 52.005 

100,000 91 0 51.806 

Table 42 

CH4 Threshold Summary -- Petrochemical Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year) 

100 55 0 0.130 

250 52 0 0.129 

1,000 37 0 0.121 

5,000 5 0 0.035 

10,000 1 0 0.010 

25,000 0 0 0 

50,000 0 0 0 

100,000 0 0 0 
45

Table 43 

CO2e Threshold Summary -- Petrochemical Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 98 0 54.826 

250 98 0 54.826 

1,000 98 0 54.826 

5,000 97 0 54.825 

10,000 96 0 54.818 

25,000 96 0 54.818 

50,000 94 0 54.748 

100,000 91 0 54.595 

3.6.18 Petroleum Refineries

In developing the permit threshold analysis for petroleum refineries, EPA quantified CH4

process emissions from wastewater, fugitive, flares, and storage tanks. Process CO2 emissions 

derived from flares, hydrogen plant emissions, and sulfur plant emissions. In addition, on-site 

combustion emissions were calculated considering fuel consumed by type. 

Potential to Emit 

EPA assumed that petroleum refineries were operating at capacity level. Therefore, no 

adjustment to the emissions estimates was needed to account for PTE. 

New Units 

According to the ICR prepared for the New Source Performance Standard (NSPS), EPA 

expects that no new refineries will be built over the next few years.
46

Threshold Summary 

Table 44 

CO2 Threshold Summary -- Petroleum Refineries 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 150 0 202.947 

250 150 0 202.947 

1,000 150 0 202.947 

5,000 150 0 202.947 

10,000 149 0 202.938 

25,000 146 0 202.887 

50,000 137 0 202.575 

100,000 129 0 202.065 

Table 45 

CH4 Threshold Summary -- Petroleum Refineries 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year) 

100 129 0 0.083 

250 109 0 0.080 

1,000 31 0 0.042 

5,000 0 0 0 
47

Table 46 

CO2e Threshold Summary -- Petroleum Refineries 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 150 0 204.897 

250 150 0 204.897 

1,000 150 0 204.897 

5,000 150 0 204.897 

10,000 149 0 204.888 

25,000 146 0 204.835 

50,000 137 0 204.513 

100,000 129 0 203.988 

3.6.19 Phosphoric Acid Production

Phosphoric acid is produced by combining sulfuric acid and phosphate rock. CO2 is 

emitted when the limestone component of phosphate rock reacts with the sulfuric acid. 

Potential to Emit 

When these process emissions are combined with combustion emissions, all 14 plants 

have emissions that exceed the highest threshold level; consequently, no PTE analysis was 

required. 

New Units 

Based on an industry growth factor of -0.1 percent for chemical manufacturing, EPA 

assumed that no new plants would be constructed. 
48

Threshold Summary 

Table 47 

CO2 Threshold Summary -- Phosphoric Acid Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 14 0 3.838 

250 14 0 3.838 

1,000 14 0 3.838 

5,000 14 0 3.838 

10,000 14 0 3.838 

25,000 14 0 3.838 

50,000 14 0 3.838 

100,000 14 0 3.838 

3.6.20 Pulp and Paper Manufacturing

Permit threshold analysis for this sector is focused on the energy intensive, fugitive 

emitting pulp, paper, and paperboard manufacturing subsectors. Process emissions include CO2

which is emitted in the recovery cycle at kraft and soda facilities associated with the chemical 

pulp process. The CO2 emitted from kraft mill lime kilns originates from two sources: (1) fossil 

fuels burned in the kiln; and (2) conversion of calcium carbonate (or "lime mud") generated in 

the recovery process to calcium oxide. 

The bulk of the emissions considered derive from combustion. Many boilers use biomass 

fuel, and the burning of spent pulping liquors to produce steam for facility processes is 

considered biomass combustion for the GHG MRR. The emissions numbers considered for the 

permit threshold analysis are non-biogenic (net of any biogenic emissions). Considering only 

non-biogenic emissions, 96.5 percent of the facilities and 99.7 percent of the emissions are 

captured by all of the thresholds proposed for consideration of the permit threshold rule. 

Potential to Emit 

Because 99.7 percent of emissions were captured at even the highest threshold, no 

additional PTE estimate was calculated in this analysis. 
49

New Units 

Based on an industry growth factor of -2.5 percent for paper manufacturing, and previous 

EPA analysis for the pulp and paper NSPS ICR, EPA assumed that no new plants would be 

constructed. 

Threshold Summary 

Table 48 

CO2e Threshold Summary -- Pulp and Paper Manufacturing 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 425 0 57.700 

250 425 0 57.700 

1,000 425 0 57.700 

5,000 425 0 57.700 

10,000 425 0 57.700 

25,000 425 0 57.700 

50,000 422 0 57.688 

100,000 410 0 57.527 

3.6.21 Silicon Carbide Manufacturing

In 2006, one facility produced silicon carbide in the U.S. Silicon carbide is primarily an 

industrial abrasive manufactured from silica sand or quartz and petroleum coke. Approximately 

35 percent of the carbon from the petroleum coke is retained with the silicon carbide, and the rest 

is emitted as both CO2 and CH4. In addition, emissions from combustion account for 

approximately ten percent of total emissions. 

Potential to Emit 

Emissions from this plant exceed all permit threshold levels; as a result, EPA did not 

consider PTE calculations. 

New Units 

EPA assumed there would be no new facilities constructed. 
50

Threshold Summary 

Table 49 

CO2 Threshold Summary -- Silicon Carbide Manufacturing 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 1 0 0.101 

250 1 0 0.101 

1,000 1 0 0.101 

5,000 1 0 0.101 

10,000 1 0 0.101 

25,000 1 0 0.101 

50,000 1 0 0.101 

100,000 1 0 0.101 

Table 50 

CH4 Threshold Summary -- Silicon Carbide Manufacturing 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CH4 Emissions 

Covered 

(Tg per year) 

100 1 0 0.0004 

250 1 0 0.0004 

1,000 0 0 0 
51

Table 51 

CO2e Threshold Summary -- Silicon Carbide Manufacturing 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 1 0 0.109 

250 1 0 0.109 

1,000 1 0 0.109 

5,000 1 0 0.109 

10,000 1 0 0.109 

25,000 1 0 0.109 

50,000 1 0 0.109 

100,000 1 0 0.109 

3.6.22 Soda Ash Production

Soda Ash production emissions were nearly evenly split between process and combustion 

emissions. Process emissions result from calcining trona ore to produce soda ash. 

Potential to Emit 

PTE emissions were calculated based on the capacities of the production units. 

New Units 

In 2006, there was a glut of soda ash in the domestic market; EPA assumed no new units 

would be constructed. 
52

Threshold Summary 

Table 52 

CO2e Threshold Summary -- Soda Ash Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 5 0 3.121 

250 5 0 3.121 

1,000 5 0 3.121 

5,000 5 0 3.121 

10,000 5 0 3.121 

25,000 5 0 3.121 

50,000 5 0 3.121 

100,000 5 0 3.121 

3.6.23 Titanium Dioxide Production

EPA used USGS as the source for production capacity for the eight facilities that 

produced titanium dioxide in 2006. 

Potential to Emit 

Emissions were assumed to represent PTE operating levels. 

New Units 

EPA assumed that no new plants would be constructed. 
53

Threshold Summary 

Table 53 

CO2e Threshold Summary -- Titanium Dioxide Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 8 0 3.686 

250 8 0 3.686 

1,000 8 0 3.686 

5,000 8 0 3.686 

10,000 8 0 3.686 

25,000 8 0 3.686 

50,000 8 0 3.686 

100,000 7 0 3.628 

3.6.24 Zinc Production

 The Zinc production emissions and facility count estimates include process and 

combustion emissions associated with primary smelting and secondary recycling facilities. 

Potential to Emit 

For PTE estimates, EPA considered the Federal Reserve's 2006 monthly industrial 

capacity utilization estimates for primary metals industry classification which shows utilization 

at 85.9 percent for 2006, and adjusted to achieve 100 percent utilization. 

New Units 

EPA assumed that no new units would be constructed. 
54

Threshold Summary 

Table 54 

CO2e Threshold Summary -- Zinc Production 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 9 0 0.852 

250 9 0 0.852 

1,000 9 0 0.852 

5,000 9 0 0.852 

10,000 8 0 0.843 

25,000 5 0 0.802 

50,000 5 0 0.802 

100,000 5 0 0.802 

3.7 Energy Sector 

3.7.1 Oil and Gas Systems

 In consideration of the permit thresholds, EPA considered the Fugitive Emissions 

Reporting from the Petroleum and Natural Gas Industry: Background Technical Support 

Document (EPA-HQ-OAR-2008-0508-0023). This document details combustion emissions and 

fugitive emissions from offshore petroleum and natural gas facilities, onshore natural gas 

processors, onshore natural gas transmission, underground natural gas storage, and liquid natural 

gas storage. EPA determined that oil and gas exploration, development, transmission, and 

distribution are not listed PSD source categories, and therefore fugitive emissions from these 

activities were not considered for PSD applicability as it relates to major source thresholds. 

EPA's analysis focused on combustion emissions from these sources. 

Potential to Emit 

EPA used a capacity utilization figure of 50 percent to determine PTE emission estimates 

and counts. This rate is meant to reasonably represent an average utilization rate across a variety 

of combustion equipment types used in the oil and gas industry subsectors described above. 

New Units 
55

EPA determined new units based on a growth factor of 1.0 percent for the sector. 

Threshold Summary 

Table 55 

CO2e Threshold Summary -- Oil and Gas Systems 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 4762 48 88.264 

250 4762 48 88.264 

1,000 4762 48 88.264 

5,000 3722 37 86.192 

10,000 3095 31 83.619 

25,000 2496 25 79.386 

50,000 1045 10 56.949 

100,000 387 4 32.750 

3.7.2 Underground Coal Mining

 GHG emissions from underground coal mining include CH4 fugitive emissions released 

from the coal seam and surrounding rock during mining and post-mining activities (coal bed 

CH4), and fuel combustion emissions of CO2, CH4, and N2O. Fugitive CH4, emissions are 

captured and vented by ventilation systems and degassing systems. Captured and vented CH4

emissions from active mines were considered in the PTE analysis. Because underground coal 

mining is not one of the 28 PSD source categories for which fugitive emissions were required to 

be included in the emissions determination, fugitive emissions from post mining operations, 

surface mines, and inactive mines were not included in the permit thresholds analysis. 

 The Technical Support Document for Underground Coal Mines: Proposed Rule for 

Mandatory Reporting of Greenhouse Gases (EPA-HQ-OAR-2008-0508-0032) identified 612 

active underground coal mining facilities but analysis of CH4 emissions was limited to 128 

"gassy" mines where CH4 monitoring was already in place (due to existing CH4 emissions above 

Mine Safety and Health Administration (MSHA) threshold levels). The U.S. GHG Inventory 

(EPA, 2008) reports that 233 underground coal mines (including 133 gassy mines) ventilated 

CH4 in 2007. Fuel combustion emission estimates for the GHG MRR TSD from all underground 

coal mines, based on U.S. Census energy use data, were found to comprise between one and 
56

three percent of total CO2e emissions, with coal bed CH4 accounting for the bulk of GHG 

emissions. 

 In addition to the emissions data on the 128 gassy mines contained in the GHG MRR 

TSD, EPA considered combustion emissions from 289 bituminous underground coal mines, 

using U.S. Census data from 2002. 

Potential to Emit

CH4

CH4 emission estimates that were developed for the GHG MRR TSD were used for both 

actual emissions and PTE emissions permit threshold analysis. EPA assumed that venting and 

degassing were continuous throughout the year; therefore, actual emission estimates equal PTE 

emission estimates. The estimates considered 128 gassy mines, which were assumed to be the 

largest emitters of vented CH4. The smallest mine of this group had annual CH4 emissions of 26 

tons; therefore EPA assumed that the annual CH4 emissions from the 105 vented mines that were 

not included in the TSD analysis were less than 26 tons. 

CO2 

CO2 emissions were estimated in the same manner as for other Unspecified Industrial 

Stationary Combustion categories, based on the ICF analysis (ICF, 2007) using the MECS 

approach. Emissions were estimated based on Census information including fuel consumption 

per employee and the distribution of establishments by the number of employees. PTE was 

estimated by using a capacity utilization factor of 86.3 percent as published by the Federal 

Reserve. 

New Units 

The number of underground bituminous coal mines in the U.S. is on the decline. EIA 

data show that only Colorado had an increase in the number of underground coal mines between 

2006 and 2007 (EIA, 2008). The EIA data show that overall the number of underground coal 

mines decreased from 2006 to 2007 by eight percent; consequently, EPA assumed no new 

underground mines would be built. http://www.eia.doe.gov/cneaf/coal/page/acr/table1.html. 
57

Threshold Summaries 

Threshold summary tables are shown below for CH4 (vented fugitive emissions), CO2 

(fuel combustion), and CO2e (vented fugitive CH4 and combustion CO2). 

Table 56 

CO2 Threshold Summary -- Underground Coal Mining 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 238 0 0.783 

250 202 0 0.778 

1,000 63 0 0.692 

5,000 30 0 0.577 

10,000 30 0 0.577 

25,000 0 0 0 

Table 57 

CH4 Threshold Summary -- Underground Coal Mining 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 110 0 1.586 

250 110 0 1.586 

1,000 110 0 1.586 

5,000 53 0 1.420 

10,000 38 0 1.361 

25,000 24 0 1.147 

50,000 13 0 0.784 

100,000 1 0 0.105 
58

Table 58 

CO2e Threshold Summary -- Underground Coal Mining 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2e Emissions 

Covered 

(Tg per year) 

100 238 0 39.520 

250 238 0 39.520 

1,000 126 0 33.945 

5,000 124 0 33.943 

10,000 123 0 33.936 

25,000 103 0 33.606 

50,000 78 0 32.800 

100,000 55 0 31.241 

3.8 Waste Sector 

3.8.1 Landfills

 The landfill PTE analysis includes both municipal solid waste (MSW) landfills and onsite 

industrial landfills associated with pulp and paper and food processing. The analysis used a 

modification of the landfill emission modeling approach used for the proposed GHG MRR 

threshold analysis. Like the GHG MRR analysis, the permit threshold PTE analysis did not 

include onsite industrial landfills for ethanol processing facilities or industrial land application 

systems. 

GHG Emissions 

 Decomposition of waste in landfills generates CH4 and CO2. The amount of CH4

generated from a given landfill is a function of several factors: the total amount of waste 

disposed in the landfill; the characteristics of the waste; and the climatic conditions. The amount 

of CH4 emitted is the amount of CH4 generated minus the amount of CH4 oxidized by aerobic 

microorganisms in the landfill cover material. Also subtracted from the total is the amount of 

CH4 that is destroyed by combustion of the vented gas. The CO2 produced by decaying waste is 

not considered an anthropogenic emission, and is not counted in GHG emission totals. Likewise, 

CO2 resulting from the combustion of landfill CH4 is not accounted for as an anthropogenic 

emission under international accounting guidance. 
59

 According to the 2008 U.S. Inventory, MSW landfills emitted 111.2 million metric tons 

CH4 (CO2e basis) in 2006. The majority of the CH4 emissions from on-site industrial landfills 

occurs at pulp and paper facilities and food processing facilities. In 2006, these landfills emitted 

14.6 million metric tons CO2e 

Potential to Emit 

 The methodology used for the proposed GHG MRR threshold analysis was also used to 

estimate CH4 generation rates and emissions in 2006 for the PTE analysis. A landfill-specific 

model developed by EPA to support its proposed GHG MRR was used to estimate CH4

generation and potential generation from municipal landfills. The generation estimate was 

adjusted with assumptions on oxidation in landfill cover, and destruction by combustion for 

energy recovery or flaring. The industrial landfill generation and emission estimates are based 

on the U.S. GHG Inventory. Industrial landfills were assumed not to have energy recovery or 

flaring, so there was no difference between generation and emissions. 

New Units 

EPA did not estimate the number of new facilities added each year with CH4 emissions 

above the different thresholds due to the time delay between landfill construction and emission 

generation. 

Threshold Summary 

Table 59 

CO2e Threshold Summary -- Landfills 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

CO2e Emissions 

Covered 

(Tg per year) 

100 4,131 125.621 

250 4,117 125.619 

1,000 4,053 125.592 

5,000 3,564 124.552 

10,000 3,265 122.788 

25,000 2,701 115.937 

50,000 1,684 92.340 

100,000 967 72.722 
60

Table 60 

CH4 Threshold Summary -- Landfills 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

CH4 Emissions 

Covered 

(Tg per year) 

100 3,885 5.973 

250 3,562 5.931 

1,000 2,692 5.539 

5,000 981 3.274 

10,000 427 2.326 

25,000 114 1.087 

50,000 21 0.401 

100,000 2 0.106 

3.8.2 Municipal Solid Waste Combustors

The threshold analysis for the proposed GHG MRR included municipal solid waste 

combustors (MWC) in the general stationary fuel combustion category. The analysis used the 

eGRID database, which is discussed in the PTE methodology description for electric generating 

units. 

Data and Methodology 

EPA used the latest version of the eGRID database (2006) to estimate the PTE of MWC 

facilities and counts of facilities above the different emission thresholds. The eGRID database 

includes year 2004 characteristics, operating information, and annual CO2 emissions for U.S. 

facilities that have a generation capacity greater than one MW and sell electric power to the grid. 

By using eGRID, EPA assumed that all MWC facilities sell power to the grid. 

Potential to Emit 

 EPA identified 75 MWC facilities based on the generator primary fuel in the generator 

table (primary fuel equals MSW) in the eGRID database. The eGRID database contains CO2

annual emissions estimates for the facilities. For CO2 emissions, eGRID uses a standard 

assumption that 70 percent of the heat value of the waste stream comes from renewable materials 

and 30 percent comes from nonrenewable materials. The renewable fraction has a CO2 emission 

rate of zero; therefore, the PTE threshold analysis is based on the nonrenewable or fossil fraction 

assumption. EPA estimated PTE by dividing the annual emissions from eGRID by the eGRID 

plant capacity factor. 
61

New Units 

 To determine the number of new per year at different thresholds, EPA counted the 

number of generators online each year, and totaled the nameplate capacity for each online year. 

This information was compared to the total facility nameplate capacity, and the PTE for the 

increased capacity was calculated by multiplying the facility PTE by the fraction of nameplate 

capacity associated with the new generators. EPA counted the facilities that exceeded the PTE 

thresholds during each period, and computed a 15-year average to determine the number of new 

or modified facilities per year. 

Threshold Summary 

Table 61 

CO2 Threshold Summary -- Municipal Solid Waste Combustors - 

GHG Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 75 2 6.255 

250 75 2 6.255 

1,000 75 2 6.255 

5,000 75 2 6.255 

10,000 75 2 6.255 

25,000 74 2 6.24 

50,000 67 1 6.071 

100,000 40 1 4.958 

3.9 Agriculture (Stationary Fuel Combustion) 

 The analysis for the Agriculture sector was limited to stationary fuel combustion CO2

emissions from internal combustion diesel engine generators. Fugitive emissions of CH4 from 

enteric fermentation, and CO2, CH4, and N2O from manure management were not included 

because farms and related operations are not in the 28 PSD source categories that require 

quantification of fugitive emission PTE for determining major source status, and because of the 

large uncertainties and lack of information on determining what component of the noncombustion emissions at agricultural operations would be defined as non-fugitive for PSD 

purposes. Fuel combustion for building space heating and other farm purposes were not 

included in the estimates, but would be a component of farm PTE. 
62

Data and Methodology 

 EPA used the 2007 ICF analysis to estimate the number of farms covered by the different 

thresholds (ICF, 2007). Emissions from diesel generators on farms were estimated using data on 

the average generator size in Delaware (EEA, 2004), and data on energy use on farms for nontransport/non-machinery motors (Brown and Neal 2005). Using these data, EPA estimated the 

number of diesel generators on farms and apportioned the generators across farm sizes, assuming 

no farm has more than one generator. 

Potential to Emit 

 EPA assumed that a high proportion of farms would run the generators infrequently, and 

a smaller proportion would have a generator as the only power source, requiring nearly constant 

operation. EPA used this distribution to determine actual and potential emissions, with PTE 

emissions based on the assumption that the generators ran 24 hours per day, 365 days per year. 

 EPA recognizes that this approach underestimates the PTE for all farm stationary fuel 

combustion sources, because it is limited to diesel engine generators used primarily to run pumps 

and motors, and does not include additional sources such as fuel combustion for drying and 

curing, space heating, and water heating. 

New Units 

 New generator installations were estimated based on information in the Regulatory 

Impact Analysis (RIA) for the spark ignition stationary combustion engine NSPS and area 

NESHAPS (EPA, 2007). The on-farm engine population of diesel generators used for irrigation 

increased four percent between 1998 and 2003, or about 0.8 percent annually. 
63

Threshold Summary

Table 62 

CO2 Threshold Summary -- Farm Stationary IC Engines 

CO2 Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Engines Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 37,351 299 0.512 

250 37,351 299 0.512 

1,000 0 0 0 

5,000 0 0 0 

10,000 0 0 0 

25,000 0 0 0 

50,000 0 0 0 

100,000 0 0 0 

3.10 Commercial Stationary Fuel Combustion 

Data Source 

 EPA used EIA's Commercial Building Energy Consumption Survey (CBECS) to estimate 

commercial sector stationary fuel combustion GHG emissions and PTE. CBECS is a national 

sample survey that collects information on the stock of U.S. commercial buildings, their energyrelated building characteristics, and their energy consumption and expenditures. Commercial 

buildings include all buildings in which at least half of the floor space is used for a purpose that 

is not residential, industrial, or agricultural; thus, the source category includes building types that 

might not traditionally be considered "commercial," such as schools, correctional institutions, 

and buildings used for religious worship. The CBECS survey is conducted every four years and 

the most recent survey was completed for 2003. 

 The CBECS survey sample was designed so that survey responses could be used to 

estimate characteristics of the entire nationwide commercial building stock. The 2003 survey 

selected 6,955 potential case buildings for sampling. The sampling procedures resulted in 5,215 

completed building interviews for a response rate of 82 percent. To make national estimates 

from the sample data, EIA calculated base sampling weights for each building (the reciprocal of 

the probability of that building being selected into the sample). In other words, the base 

sampling weight is the number of national buildings represented by the sampled building. The 

base weight was further adjusted to account for nonresponsive bias. 
64

 EIA publishes summary tables from the survey, and posts "microdata" files on the EIA 

website. The CBECS microdata consist of the 5,215 sampled building records, which each 

correspond to a single sampled building. For each building, these files contain information such 

as the building size, climatic region, census region, year constructed, types of energy used, and 

energy consumption and expenditures. These individual building microdata records are also the 

basis for the summary tables published by EIA. 

Emissions Methodology 

EPA used the CBECS microdata to estimate commercial building emissions and 

populations above emission thresholds. Each of the 5,215 microdata records corresponds to a 

single sampled building. EIA has made available 20 different data files of the microdata records 

which contain a wide range of information on characteristics and energy use for each building. 

 EPA's analysis relied on guidance provided by EIA on how to use the data. As noted 

above, the CBECS sample was designed so that survey responses could be used to estimate 

characteristics of the entire commercial building stock nationwide. The table below provides 

examples from EIA on how to calculate national commercial building characteristics from the 

sample building data. 

Table 63 

EIA Website Examples 

To Find the National 

Estimate for: Do This... 

And You 

Should Get... 

Total number of buildings Sum ADJWT8 (weight factor) 4,858,749.82 

(or 4,859 thousand) 

Total number of office 

buildings 

Sum ADJWT8 for cases where PBA8 (building code) = "02" 823,805.47 

(or 824 thousand) 

Total floor space Create a new variable (weighted square footage) by 

multiplying ADJWT8 by SQFT8 (floor space) for each case, 

then sum this new variable 

71,657,900,522 

(or 71,658 million ft2

) 

Total floor space in 

buildings with air 

conditioning 

Sum the new weighted square footage variable (see above) 

for cases where COOL8 (air conditioning) = "1" 

63,559,999,624 

(or 63,560 million ft2

) 

Total electricity 

consumption in KWh 

Create a new variable (weighted electricity consumption) by 

multiplying ADJWT8 by ELCNS8 (electricity consumption) 

for each case, then sum this new variable 

1,043,175,710,751 

(or 1,043 billion kWh) 

Source: http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.html. 

 EIA calculated base sampling weights for each surveyed building (these are the 

reciprocal of the probability of that building being selected into the sample). Therefore, a 

building with a base weight of 1,000 represents itself and 999 similar but unsampled buildings in 
65

the total building stock. The base weight is further adjusted to account for non-response bias. 

The variable "ADJWT8" in the data file is the final weight. The ADJWT8 weight factor is used 

as described in Table 63 to extrapolate the survey sample to a national scale for any value. In 

order to obtain a national value each sample building's value must be multiplied by the building's 

weight (ADJWT8). All of the weighted values are then summed. 

2003 CO2 Emissions 

 EPA calculated the CO2 emissions for each of the 5,215 buildings based on the annual 

natural gas and oil consumption reported for the building. For national emission estimates and 

counts of buildings with annual CO2 emissions over any threshold, EPA multiplied the base 

weights by the sample emission totals to determine the national estimate of buildings with 

emissions over the threshold. 

Potential to Emit 

 EPA estimates that commercial buildings operate at 15 percent of capacity. EPA 

considered several sources in making the PTE factor determination: 

● A report prepared by Energy and Environmental Analysis, Inc. for Oak Ridge National 

Laboratory describing the industrial and commercial boiler population in the United 

States (EEA, 2005). The report estimated an average commercial boiler capacity factor 

of 16 percent. 

● Reports on cooking equipment energy use by the Food Service Technology Center in 

California suggesting that the cooking equipment in food service establishments operate 

at about ten percent of a theoretical maximum capacity based on 8,760 hours per year 

(Pechan, et.al, 2008). 

● A study of Los Angeles dry cleaners performed by the Pollution Prevention Education 

and Research Center (PPERC) in 2004 which demonstrates that dry cleaners operate 

boilers at about 10 to 15 percent of maximum capacity over a normal year (Pechan, et al., 

2008). 

New Buildings 

 The CBECS data identifies the year the sampled buildings were constructed. We used 

the construction year information to identify the number of new buildings built each year in the 

1990 to 2003 period. Counts of the average number of these buildings built per year were then 

made at the different emissions and PTE thresholds. 

Threshold Summary 

 The count of buildings and emissions at the threshold levels for the entire sector are 

shown in the table below. Threshold results by commercial building categories (e.g., offices, 

public assembly, schools) are provided in Appendix B. 
66

Table 64 

CO2 Threshold Summary -- Commercial Sector Stationary Fuel Combustion 

CO2 Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

100 1,355,921 22,123 119.262 

250 731,477 12,041 105.306 

1,000 172,654 2,922 69.885 

5,000 18,167 196 29.384 

10,000 5,660 96 17.765 

25,000 1,161 7 8.790 

50,000 600 3 6.003 

100,000 51 2 1.012 

3.11 Residential Buildings 

Data Sources 

EPA used residential fuel consumption data from EIA's Residential Energy Consumption 

Survey, and multi-family building and unit data from U.S. Census (Census) surveys to estimate 

CO2 emissions and PTE for fuel combustion at single and multi-family residential properties. 

The RECS is a national area-probability sample survey that collects energy-related data for 

occupied primary housing units. The most recent 2005 survey collected data from 4,382 

households in housing units statistically selected to represent the 111.1 million housing units in 

the United States. RECS data are tabulated for the four Census regions, the nine Census 

divisions, and for the four most populous States -- California, Florida, New York, and Texas. 

 The RECS sample was designed so that survey responses could be used to estimate 

characteristics of the national stock of occupied housing units. In order to arrive at national 

estimates from the RECS sample, EPA calculated base sampling weights for each housing unit 

as the reciprocal of the probability of that building being selected into the sample. Therefore, a 

housing unit with a base weight of 10,000 represents itself and 9,999 similar, but not sampled 

housing units in the total stock of occupied residential housing units. The base weight is further 

adjusted to account for non-response bias. Ratio adjustments were also used to ensure that the 

RECS weights add up to Census Current Population Survey estimates of the number of 

households. 

 The RECS data are provided at the housing unit level, and not at the building level. EPA 

used additional data from the Census on multi-family building population characteristics to 

estimate total property emissions and PTE for multi-unit properties. Census data were from two 
67

sources: the Property Owner and Manager Survey (POMS, 1996) and the American Housing 

Survey (AHS, 2005). 

3.11.1 Single-Family Homes

The RECS data was used directly to estimate CO2 emissions from fossil fuel combustion 

at single-family housing units for space heating, water heating, and appliances. EPA assumed 

that each unit in an attached single-family building was a separate source, with combustion 

equipment under different ownership. 

 The annual energy consumption by fuel (1,000 Btus) for the surveyed unit was multiplied 

by the fuel CO2 emission factor to estimate annual emissions. Total single-family unit emissions 

for the entire country were calculated by multiplying CO2 emissions for each units by the base 

sampling weight. 

Potential to Emit 

The PTE for a single-family unit was calculated by dividing the CO2 emissions from the 

unit by a capacity factor of 0.1. This factor was estimated by comparing the average annual CO2

emissions per heated floor space area per hour by climate zone, to required heat input capacity. 

The required heat input capacity was based on rule of thumb heating system requirements for the 

different climate zones. The table below shows the average Btu/ft2-hour from the RECS data 

and Heating Requirement (Btu/ft2

) by climate zone. A heating system efficiency of 80 percent 

was used to estimate the required space heating capacity. 

Table 65 

Single-Family Detached and Attached 

Households with Fossil Fuel-Fired Space Heating 

(from RECS, 2005) 

Households 

(millions) 

Climate 

Zone(s) 

Heating Degree 

Day Range 

Average Annual Fuel 

Consumption 

(Btu/ft2-hour) 

Space Heating 

Requirement* 

(Btu/ft2) 

6.8 5 > 7,000 4.8 50 – 60 

16.7 4 5,500 – 7,000 5.4 45 – 50 

17.0 3 4,000 – 5,499 4.6 40 – 45 

18.9 1 and 2 < 4,000 3.8 Zone 2: 35 – 40 

Zone 1: 30 – 35 

* Heating requirement ranges are from www.acdirect.com/systemsize.php. 
68

3.11.2 Multi-Family Residential Buildings

Emission Rates 

As noted earlier in the Data Source section, the RECS data are on an individual unit 

basis, not building or property basis, so a different approach was required for multi-family units 

where EPA assumed common ownership of the property fuel combustion equipment. In order to 

estimate property emissions and the number of properties above different emission and PTE 

thresholds, EPA combined the RECS data with data from the POMS and AHS. 

 From the RECS data, EPA first calculated average residential unit CO2 emissions for the 

two most common fuels (natural gas and oil) by multi-family category. These are shown in the 

table below. 

Table 66 

Multi-Family Residential Unit -- Average Annual CO2 Emissions 

(from RECS, 2005) 

Multi-Family Category 

(number of units) 

Natural Gas Space Heating 

(tons CO2/residential unit-year) 

Fuel Oil Space Heating 

(tons CO2/residential unit-year) 

2 to 4 units 4.8 8.3 

5 or more units 3.0 8.9 

 EPA also obtained annual CO2 emission rates from an EPA analysis that was based on 

Lawrence Berkeley National Lab (LBNL) modeling studies. Those rates were estimated for old 

and new building units (see Table 67). The pre-1980 building estimate compares with the 

overall average from the RECS data. The post-1980 building estimates are much lower, 

particularly for units burning fuel oil. 

Table 67 

Multi-Family Residential Unit -- Average Annual CO2 Emissions 

(from 2008 EPA Analysis based on LBNL, 1997) 

Multi-Family Category 

(building age) 

Gas Serviced Units 

(tons CO2/residential unit-year) 

Fuel Oil Serviced Units 

(tons CO2/residential unit-year) 

Pre-1980 building 4.75 7.17 

Post-1980 building 2.65 3.87 
69

Existing Property Characteristics 

Information on the distribution of multi-family properties by number of units per property 

was taken from the 1995 – 1996 POMS. The data are aggregated by different housing unit 

ranges. The table below shows the property size distribution from unpublished POMS data 

(NMHC Quick Facts -- Apartment Stocks (http://www.nmhc.org)). The POMS data were for 

privately owned housing only and excluded public housing projects (about 13,500 buildings and 

1,326,000 units). For our estimates, the building numbers were adjusted to current (2005) levels 

based on the RECS unit data (unit ratio of RECS to POMS). EPA assumed the same unit 

distribution in the adjustment. 

Table 68 

Multi-Family Residential Property Size Distribution 

(from National Multi-Housing Council tabulation of unpublished POMS data 1995 – 1996) 

Number of Rental 

Units on Property 

Number of Properties 

(1995 – 1996) 

Number of Units 

(1995 – 1996) 

Average Number 

of Units per 

Property 

2 1,558,700 3,093,200 2 

3 336,030 1,025,900 3 

4 341,350 1,436,800 4 

5 – 9 281,500 1,897,700 7 

10 – 14 70,390 862,280 12 

15 – 19 36,780 602,260 16 

20 – 29 38,000 916,750 24 

30 – 39 18,166 604,240 33 

40 – 49 14,431 702,790 49 

50 – 99 26,694 2,009,400 75 

100 – 199 19,804 2,952,300 149 

200 – 299 7,775 1,948,400 251 

300 – 399 2,966 1,058,800 357 

400 – 499 1,307 605,130 463 

500 – 749 723 431,360 597 

Over 750 307 437,670 1,426 

Total 2,754,923 20,584,980 
70

 The adjusted POMS size distribution and average number of units in each category were 

combined with information from RECS on the percentage of units that use gas or oil for space 

heating. The gas and oil emission factors from the previous tables were applied to the average 

number of units in each property size category by fuel to estimate property annual CO2

emissions. 

 For our final estimates we used the LBNL based emission factors for post-1980 

buildings, over the RECS based factor. We found that these lower emission factors resulted in 

total emissions more in line with the total based on all RECS units and residential sector 

estimates in the U.S. Greenhouse Gas Inventory. The RECS-based factors combined with the 

POMS property distribution data resulted in a larger overestimate in overall category annual 

emissions. The lack of information on the building population over 50 units, and lack of 

information on the correlation between unit emissions and the building/property size are large 

sources of uncertainty in the estimates at thresholds above 1,000 tons. 

Potential to Emit 

 PTE was estimated using the same ten percent capacity factor as used for the single 

family residential units 

New Properties 

The AHS data provided information on new construction used to estimate the number of 

new buildings and new units with natural gas space heating that were constructed in the 1999 – 

2005 period. To simplify the analysis, EPA ignored the limited use of fuel oil for space heating 

in new units. 

 The AHS data provided separately the number of new buildings with gas space heating 

per year, and a size distribution for all new buildings per year. The AHS size distribution 

stopped at 50 and larger, and was slightly different in other categories from the POMS data. 

EPA adjusted the distribution based on the POMS distribution and then used the same emission 

and capacity factor approach as used for existing units. 
71

Table 69 

American Housing Survey New Building Data 

Building Size: 

Number of Units 

per Building 

Number of New 

Buildings per Year 

(1999 – 2005) 

(thousands) 

Fraction of All 

New Buildings 

per Year 

(1999 – 2005) 

New Gas Buildings 

per Year 

(1999 – 2005) 

(thousands) 

Number of New 

Gas Buildings 

per Year 

2 6.3 0.22 3,468 

3 – 4 5.4 0.19 2,995 

5 – 9 6.1 0.21 3,389 

10 – 19 6.0 0.21 3,310 

20 – 29 3.1 0.11 1,734 

30 – 49 1.0 0.03 552 

50 or more 1.0 0.03 

16.0 

552 

Total 29.0 1.00 16.0 16,000 
72

Threshold Summary 

Table 70 

CO2 Threshold Summaries -- Residential Sectors 

Threshold 

(tons per year) 

Number of 

Existing Sources 

Number of New 

Facilities Added 

per Year 

CO2 Emissions 

Covered 

(Tg per year) 

Multi-Family Residential

100 610,500 11,300 54.285 

250 137,000 6,400 42.192 

1,000 51,200 1,100 32.399 

5,000 7,800 120 14.934 

10,000 1,400 20 4.933 

25,000 160 3 1.392 

50,000 20 0 0.006 

100,000 0 0 0 

Single-Family Residential

100 3,925,000 33,000 51.408 

250 45,350 515 1.670 

1,000 0 0 0 

Total Residential Sector

100 4,535,500 44,300 105.693 

250 182,350 6,915 43.862 

1,000 51,200 1,100 32.399 

5,000 7,800 120 14.934 

100,00 1,400 20 4.933 

25,000 160 3 1.392 

50,000 20 0 0.006 

100,000 0 0 0 
73

References 

Brown, E., and Elliott, R.N., On-Farm Energy Use Characterizations, Report Number IE052, 

©American Council for an Energy-Efficient Economy, Washington, D.C., March 2005. 

http://www.aceee.org/pubs/ie052full.pdf

E.H. Pechan & Associates, Inc., Perrin Quarles Associates, Inc., and Alpine Geophysics, LLC, 

Greenhouse Gas (GHG) Emissions and New Source Review, Work Assignment No. 1-06, EPA 

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74

U.S. Census Bureau (1998), 1995 Property Owners and Managers Survey, 1998. 

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July 1, 2006. 

U.S. Energy Information Administration (EIA), 2005 Residential Energy Consumption Survey, 

February 2009. 

http://www.eia.doe.gov/emeu/recs/recspubuse05/pubuse05.html

U.S. Energy Information Administration (EIA), 2003 Commercial Building Energy Consumption 

Survey, December 2006. 

http://www.eia.doe.gov/emeu/cbecs/cbecs2003/public_use_2003/cbecs_pudata2003.html

U.S. Energy Information Administration (EIA), 2002 Manufacturing Energy Consumption 

Survey, January 2007. 

http://www.eia.doe.gov/emeu/mecs/contents.html

U.S. Environmental Protection Agency (EPA), Inventory of U.S. Greenhouse Gas Emissions and 

Sinks: 1990 – 2007, April 2009, US EPA 430-R-09-004. 

http://www.epa.gov/climatechange/emissions/usinventoryreport.html

U.S. Environmental Protection Agency (EPA), Supporting Data for Threshold Analysis Subpart 

E – W, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR2008-0508-0046.7). 

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X – PP, Greenhouse Gas Mandatory Reporting Rulemaking, March 10, 2009 (EPA-HQ-OAR2008-0508-0046.8). 

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Database (eGRID) 2004, May 2007. 

http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html

U.S. Environmental Protection Agency (EPA), Regulatory Impact Analysis for the Stationary 

Spark-Ignition New Source Performance Standard (SI NSPS) and New Area Source NESHAP, 

December 2007, US EPA 452/R-07-015. 

http://www.epa.gov/ttn/atw/nsps/sinsps/sinspspg.html

U.S. Environmental Protection Agency (EPA), Draft U.S. Adipic Acid and Nitric Acid N2O 

Emissions 1990 – 2020: Inventories, Projections and Opportunities for Reductions, November 

2001. 

http://www.epa.gov/nitrousoxide/pdfs/adipic_nitric_n2o.pdf
75

U.S. Environmental Protection Agency (EPA), Climate Change Division, Fugitive Emissions 

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Document for the Adipic Acid Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0005). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Process Emissions from Primary Production of Aluminum: Proposed Rule for 

Mandatory Reporting of Greenhouse Gases, February 4, 2009 (EPA-HQ-OAR-2008-0508-

0006). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Ammonia Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0007). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Process Emissions from Cement: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 28, 2009 (EPA-HQ-OAR-2008-0508-0008). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Process Emissions From Electronics Manufacture (Semiconductors, MEMs, 

Liquid Crystal Displays, and Photovoltaics), January 29, 2009 (EPA-HQ-OAR-2008-0508-

0009). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Ethanol Facilities: Proposed Rule for Mandatory Reporting of Greenhouse 

Gases, February 4, 2009 (EPA-HQ-OAR-2008-0508-0010). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Ferroalloy Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0011). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Glass Manufacturing Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0014). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Emissions of HFC-23 from Production of HCFC-22: Proposed Rule for 

Mandatory Reporting of Greenhouse Gases, February 06, 2009 (EPA-HQ-OAR-2008-0508-

0015). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Hydrogen Production: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, August 5, 2008 (EPA-HQ-OAR-2008-0508-0016). 
76

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

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Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0017). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Lead Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0018). 

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Document for the Lime Manufacturing Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0019). 

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for Mandatory Reporting of Greenhouse Gases, February 10, 2009 (EPA-HQ-OAR-2008-0508-

0020). 

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Document for the Petrochemical Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0024). 

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Document for the Petroleum Refining Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, September 9, 2008 (EPA-HQ-OAR-2008-0508-0025). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Phosphoric Acid Production Sector: Proposed Rule for Mandatory Reporting 

of Greenhouse Gases, February 20, 2009 (EPA-HQ-OAR-2008-0508-0026). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Pulp and Paper Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, February 11, 2009 (EPA-HQ-OAR-2008-0508-0027). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Silicon Carbide Production Sector: Proposed Rule for Mandatory Reporting 

of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0028). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Soda Ash Manufacturing Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0029). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Titanium Dioxide Production Sector: Proposed Rule for Mandatory Reporting 

of Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0031). 
77

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for Underground Coal Mines: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, February 4, 2009 (EPA-HQ-OAR-2008-0508-0032). 

U.S. Environmental Protection Agency (EPA), Office of Air and Radiation, Technical Support 

Document for the Zinc Production Sector: Proposed Rule for Mandatory Reporting of 

Greenhouse Gases, January 22, 2009 (EPA-HQ-OAR-2008-0508-0033). 
78

Appendix A 

Sector Permit Threshold Counts and Emissions by GHG 

 The listed electronic spreadsheet files contain the permit threshold counts and emissions 

for each sector and subsector by GHG. These listed files are included in separate files in the 

docket (EPA-HQ-OAR-2009-0517). Please refer to the following file names for additional 

information on specific sectors and GHGs: 

● GHG Data for Final Tailoring Rule Development - CO2e.xls 

● GHG Data for Final Tailoring Rule Development - CO2.xls 

● GHG Data for Final Tailoring Rule Development - CH4.xls 

● GHG Data for Final Tailoring Rule Development - N2O.xls 

● GHG Data for Final Tailoring Rule Development - HFC.xls 

● GHG Data for Final Tailoring Rule Development - PFC.xls 

● GHG Data for Final Tailoring Rule Development - SF6.xls 
79

Appendix B 

Commercial Building Sector -- Permit Threshold Results by Commercial Category 

 Please refer to the electronic file "Commercial Building Category CO2 Permit Threshold 

Results.xls." in the docket for EPA-HQ-OAR-2009-0517
1

Attachment C 

Summary of Methodology and Data Used to Estimate Burden Relief and 

Evaluate Resource Requirements at Alternative Greenhouse Gas (GHG) 

Permitting Thresholds 

March 2010 

1. Introduction 

This paper summarizes an assessment of the estimated resource requirements for 

permitting authorities to include GHG at several possible major source permitting thresholds and 

the burden reduction and costs savings for permitting authorities and sources as a result of 

requiring the inclusion of GHG in the title V and Prevention of Significant Deterioration (PSD) 

permitting programs at thresholds greater than the current statutory requirements. A preliminary 

analysis to support the tailoring rule proposal resulted in an earlier version of this Technical 

Support Document, found at EPA-HA-OAR-2009-0517.14 Based on comments received on the 

proposal and updates to key assumptions, this revised summary presents the updated 

methodology and burden reduction estimates resulting from several permitting threshold 

alternatives considered for the final tailoring rule. The analysis was performed considering GHG 

emissions 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 Information Collection Requests 

(ICRs) for the title V and PSD programs. Estimates for the number of affected sources used in 

 

14 “Summary of ICR-based Data Used to Estimate Avoided Burden and Evaluate Resource 

Requirements at Alternative GHG Permitting Thresholds;” Prepared by EPA Staff; August 2009. 
2

this analysis were obtained from the GHG thresholds evaluation, which can be found at EPAHQ-OAR-2009-0517.15

2. Methodology for Estimating Permitting Burden Due to GHG Emission Sources 

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

quantities of permitting actions that would be affected by addressing GHGs under the PSD and 

title V permitting programs. The final burden results summarized in Section 3 are based on the 

methodologies described in this section. In developing our methodology, we established 

different applicability options under which GHG emission sources would be regulated. These 

GHG applicability thresholds range from the statutory threshold levels (100 and 250 tpy) to 

different combinations of major source and significance levels based on GHG emissions, and 

finally, applicability based on GHG-related additions to otherwise occurring permitting actions 

for non-GHGs (also referred to here and in the preamble for this action as the ‘anyway’ source 

approach). We considered several different major source/major modification threshold 

combinations. We chose the combinations to reflect representative, incremental steps along the 

possible range. Because it is time- and resource- intensive to develop estimates for a given step, 

we chose intervals that best reflect representative points within the range given those time and 

resource constraints. For example, as it became evident from the analysis that the 100,000 tpy 

CO2e major source threshold would be a viable option under one of the phase-in steps in the 

GHG tailoring rule, we needed to then evaluate different GHG significance level options in 

 

15 “Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air Quality 

Policy and Standards; July 7, 2009. 
3

combination with the 100,000 tpy CO2 major source level to determine the ultimate impact on 

PSD and title V permitting activity. 

PSD Permits 

Table 2-1 summarizes EPA’s estimate of modifications and new construction PSD 

permitting actions potentially affected by the addition of GHG as a regulated air pollutant at 

different GHG threshold options for PSD applicability. These actions are broken down by type 

of modification and new construction activity. Three types of modifications are included in this 

analysis: major modifications triggered by increased conventional pollutant emissions, which 

also exceed the significance level for GHG; modifications at exiting non-GHG major sources 

previously considered minor but now are major modifications due to GHG emissions; and major 

modifications due solely to GHG emissions exceeding the significance level threshold. For new 

construction, two types of sources are listed – those that are major sources due solely to the 

emissions of GHG, and those which are classified as major due to conventional pollutant 

emissions, but also exceed the GHG significance level (or ‘anyways’ sources). 

The first line items in Table 2-1 for modifications and new construction present estimates 

of GHG-related permitting actions that would occur at ‘anyways’ sources ; these are labeled in 

the table as “Current Modifications – Add Additional GHG” and “Newly Constructed Major 

Sources – Add Additional GHG.” The August 2008 ICR for the New Source Review (NSR) 

program estimates that 282 PSD and 519 non-attainment NSR permits are issued annually.16

EPA’s initial burden analysis concentrated solely on the 282 annual PSD actions. If a source is 

major for a pollutant for which an area is designated non-attainment, all significant emissions or 

 

16 Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR 

Number 123.23, OMB Control Number 2060-0003, 2008. 
4

significant emissions increases of pollutants for which the area is in attainment are still subject to 

PSD review. Thus, some of the facilities applying for nonattainment permits may also undergo 

PSD actions at the same time. Although there is no way of accurately predicting which of the

519 nonattainment actions might also coincide with a PSD action related to GHG emissions, we 

believe it is likely that most will since they typically involve large emission sources; thus, it is 

assumed all nonattainment actions from the ICR annual estimate will also need a PSD permit. 

Therefore, in this final analysis, to more accurately depict the number of PSD permitting actions 

occurring annually, it is assumed that all 801 permitting actions above involve a PSD action. 

Based on feedback received from the National Association of Clean Air Agencies (NACAA) and 

other commenters on the proposed tailoring rule and EPA program staff experience, 70% of 

these permit actions are assumed to be modifications. Further, 80% of these modifications are 

expected to involve combustion activities with GHG emission levels exceeding the statutory 

thresholds, thus requiring the inclusion of GHG related requirements in a PSD permit.17 This 

equates to 448 modifications annually. 

The 240 remaining annual permit actions—labeled in Table 2-1. as “Newly Constructed 

Major Source- Add Additional GHG”—are assumed to be construction of new major sources as 

determined by emissions of one or more NAAQS pollutants. Due to the size and emissions of 

sources currently subject to the PSD permitting program, it is believed all of these newly 

constructed major sources will exceed a GHG threshold and will also need to include GHGrelated requirements in the PSD permit. In total, all 688 major permitting actions mentioned 

 

17 The 80% estimate was obtained by reviewing a sample of PSD modification permits to determine the number 

involving combustion that would emit GHGs. 
Table 2-1. Estimated Number of PSD Permit Actions Exceeding GHG18 Threshold Options 

Threshold 

100/250 

tpy 

major; 

100/250 

tpy sig. 

level 

25,000 

tpy 

major; 

25,000 

tpy sig. 

level 

50,000 

tpy 

major; 

50,000 

tpy sig. 

level 

100,000 tpy 

major; 

50,000 tpy 

sig. level 

100,000 tp

major; 

75,000 tpy 

sig. level 

Current Modifications - Add Additional GHG 448 448 448 448 44Minor Modifications Becoming Newly Major 17,894 8,947 1,789 1,789 89Modifications at Newly Major Sources 43,942 250 117 20 2Modifications Total 62,284 9,645 2,354 2,257 1,36Newly Constructed Major Sources - Add Additional GHG 240 240 240 240 24Newly Constructed Major Sources 19,649 10 3 2 Newly Constructed Sources Total 19,889 250 243 242 24Total 82,173 9,895 2,597 2,499 1,60

18 GHG threshold options are all based on tpy CO2e. The Non-GHG option is based on a PSD action being triggered for a non-GHG, c

(e.g., nitric oxides), where a GHG-related PSD review is only necessary when associated GHG emissions for the project exceed 75,
6

mentioned above will need to factor in GHG requirements as indicated in Table 2-1. For 

permitting authorities, 50 additional burden hours are estimated to include the GHG 

requirements in a permit.19 For affected sources, approximately 222 additional burden hours are 

needed to obtain guidance and prepare the BACT analysis for GHG. 

According to the NSR ICR, approximately 74,600 minor permitting actions occur 

annually.20 For this analysis, it is assumed that a number of projects that traditionally could take 

limits or net out of review and obtain a minor permit will now be required to apply for a major 

PSD permit, depending on the significance threshold set for GHG. These projects are identified 

in Table 2-1 under “Minor Modifications Becoming Newly Major.” Combining the number of 

netting-based modifications and synthetic-based modifications (which was calculated from the 

ICR as one-third of the entry for “new minor sources, new synthetic minor sources, and 

synthetic-based modifications”) identified in the ICR, approximately 22,368 of these actions 

could potentially become major modifications subject to PSD review if their associated GHG 

emissions increases exceed the selected GHG significance level option. We did not count ‘new 

minor sources’ and ‘new synthetic minors’ because we have already accounted for them as 

potential major GHG sources if their PTE emissions exceed the selected GHG major source 

threshold option. 

Based on staff review of samples of minor source permits, it is estimated that 80% of the 

current minor modification actions likely involve combustion sources - totaling 17,894 actions of 

the total 22,368 minor modification actions. Some of these actions may trigger the requirements 

 

19 A well-known gas with a familiar BACT process, such as NOx, requires an average of 20-30 burden hours to be 

included in a permit. As less is known regarding GHGs and the BACT decision process, expert staff judgment 

set the burden for permitting authorities to add GHG to permits at 50 hours. 

20 The 74,591 minor modifications are broken down as follows: 30% involving new minor sources, new synthetic 

minor sources, and synthetic-based modifications; 30% involving true minor modifications; 20% involving 

netting-based minor modifications; and 20% minor/administrative permit revisions. See NSR ICR at 11.
7

of the PSD program depending on their GHG emission increases and the selected GHG 

significance threshold. We assumed the following % of the total 17,984 actions would move to 

a major modification status due to GHG increases for each of the GHG significance level options 

considered in this analysis: 50% at 25,000 tpy CO2e; 10% at 50,000 tpy CO2e; 5% at 75,000 tpy 

CO2e; and zero at 100,000 tpy CO2e. We considered the relative emissions of CO2 emissions to 

NOx emissions at the current major modification significance level threshold for NOx (40 tpy). 

For example, for an average natural gas combustion boiler (a common industrial combustion unit 

that is part of many modification projects), a 40 tpy NOx emissions would coincide with a 

56,000 tpy CO2e level. Since many combustion related projects keep just under the 40 tpy NOx 

level to avoid major modification status, we assume that the CO2e emissions for a similar project 

will be around the 50,000 tpy CO2e level. Therefore, we believe it is reasonable to expect that 

all these currently minor modification projects involving combustion units to exceed the 100 tpy 

GHG significance level under the baseline scenario, and progressively less as the GHG 

significance level increases. We assume that decreasing proportion of projects will be 

significantly large enough, or may not be able to net-out for GHGs like they can for NOx, as the 

significance level options rises from 25,000 tpy to 75,000 tpy CO2e. Ultimately, at a 100,000 

tpy CO2e significance level we assume none of these currently minor modification projects move 

into a major modification status for GHGs. 

In addition to sources becoming subject to PSD requirements because of GHG emissions 

related to modifications, new construction will occur that will require a PSD permit solely due to 

the source’s potential GHG emission levels, identified in Table 2-1 as “Newly Constructed 

Major Sources.” Based on the source data obtained from the GHG thresholds evaluation, these 

newly constructed major sources involve both industrial and commercial/residential facilities.
8

The current NSR ICR notes that permitting authorities spend approximately 300 hours 

processing and issuing a new construction industrial source PSD permit. Sources spend almost 

870 hours on average preparing for the same permit. In the previous burden analysis, 

commercial/residential permits were assumed to require only 20% of the time necessary for an 

industrial permit. While it is still believed that these sources are less complex than their industrial 

counterparts in terms of numbers and types of emissions sources and control requirements, EPA 

now estimates the commercial/residential permits to take 70% of the time required to complete 

an industrial permit. This is due to comments received and further evaluation of the additional 

support and outreach activities for permitting authorities to assist with applicability 

determinations and emissions calculations. Of the sources falling in this category, the number 

requiring PSD permitting will vary depending on where the thresholds for triggering PSD review 

(both major source and modifications thresholds) are established. 

Finally, an existing, but newly classified major source for GHG, may undergo a 

modification for which it will then be subject to PSD permitting requirements. This category of 

PSD permitting activity is listed on Table 2-1 as “Modifications at Newly Major Sources.” With 

this new major source status, these facilities must apply for and be issued a PSD permit, if they 

undergo a major modification. See Appendix A for a list of newly major sources at different 

major source GHG thresholds. We estimate that 4% of these newly major sources will undergo 

modifications. This rate was obtained by dividing the current 560 annual PSD modificationrelated permit actions (i.e., 70% of 801 actions identified in the NSR ICR) by the existing major 

source population of 14,700 major source title V permits. This represents our best available 

estimate of the rate of PSD modification activity at major sources, and we make the assumption 

that this rate will also apply for newly major GHG sources. We recognize that there is some 
9

level of uncertainty in applying this rate to GHG-only sources, particularly for sources in 

unconventional sectors such as commercial and residential categories, however we believe at 

higher GHG threshold levels, where large industrial sources predominate, that this modification 

rate provides a reasonable estimate of modification activity. 

Title V Permits

Title V programs also complete several types of permitting actions annually, 

including processing and issuing new permits, permit revisions, and permit renewals. 

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. In 

addition to sources new to title V, permitting authorities must add GHG terms to permits 

for sources exceeding the threshold set for GHG emissions. Permitting authorities may 

face burdens to update existing title V permits for GHG under two possible scenarios: (1) 

EPA promulgates or approves any applicable requirements for GHGs that would apply to 

such a source, which would generally require a permit reopening or renewal application, 

or (2) the source makes a change that would result in an applicable requirement for GHG 

to newly apply to the source, such as PSD review, which would generally require an 

application for a permit revision. Permitting authorities will also need to process permit 

renewal applications, generally on a five-year cycle, and such renewals would need to 

assure that the permit properly addresses GHG. 

The April 2007 Title V ICR estimates that 50 permits are completed every year 
10

for new sources.21 For this analysis, it is assumed that all 50 of these typically large 

industrial-type sources will be capable of potentially emitting GHG and will need to add 

GHG-related requirements to the permit, an action estimated to require an additional 10% 

of the time currently estimated for a new title V permit. 

The ICR also identifies 3,267 permit renewals conducted on an annual basis. As not all 

sources potentially emit GHG above a determined threshold, this analysis examines the 

estimated 80% involving combustion activities that most likely have the potential to emit GHG 

above the series of potential thresholds evaluated. Therefore, approximately 2,614 sources will 

need to address GHG in the new version of the permit. 

Revisions to title V permits will also be necessary based on the number of modifications 

calculated for this analysis. Revisions occurring specifically due to GHG may involve significant 

revisions, minor revisions, or administrative actions to operating permits. EPA estimates that this 

activity will require 40 hours per permit on average for permitting authorities to complete.22 The 

number of operating permit revisions will vary based on the number of previously minor 

modifications now qualifying as major modifications, and modifications at newly major sources, 

both listed in Table 2-1. At any level, it is assumed that the 448 modifications involving 

combustion that occur annually will need to include any GHG requirements in the revision of 

their respective title V permits. EPA estimates that permitting authorities will spend, in addition 

to the current burden to issue a title V permit revision, an additional 10% of the needed time to 

complete this process, or four hours per action. 

 

21 Information Collection Request for State Operating Permit Regulations (Renewal), EPA ICR Number 1587.07, 

OMB Control Number 2060-0243, 2007. 22 The Title V ICR indicates the burdens associated with revisions are as follows: 90 hours for a significant revision, 

30 hours for a minor revision, and 5 hours for an administrative action. See Table 8 at 23. It is not known which 

revision will be required for any modification that exceeds the GHG significance level threshold; therefore, EPA 

averages the three permitting burdens to obtain a value of 40 hours per permit. 
11

Finally, new industrial and commercial/residential sources will be entering title V 

permitting programs annually due solely to their GHG emissions. These commercial/residential 

sources that exceed the major source threshold solely due to their GHG emissions will not likely 

have substantial applicable requirements in the near term and/or will not require as much time to 

process as those for industrial sources, which have other applicable requirements in addition to 

those related to their GHG emissions. However, upon further evaluation and in response to 

comments from permitting authorities, EPA believes its initial estimate of one-tenth of the 

burden hours required was considered too low. Permitting authorities would confront substantial 

challenges as they have little experience with such sources and their GHG emissions. Therefore, 

EPA assumes preparing a permit for affected commercial/residential sources will take 50% of 

the time a permitting authority currently spends on issuing a title V permit. 

3. Evaluation of ICR-based Resource Requirements for Permitting Authorities at Different 

 Possible GHG Permitting Thresholds 

 For the proposal, EPA examined resource requirements at the statutory-based 100/250 

tpy CO2e emission levels—referred to as the ‘baseline’ analysis in the following tables—as well 

as at 10,000 tpy, 25,000 tpy, and 50,000 tpy CO2e levels. Due to comments received on the 

proposal and this improved burden analysis, the 10,000 tpy threshold was eliminated as not being 

a viable alternative since it did not adequately address administrative necessity concerns. In this 

analysis, in addition to the baseline analysis, EPA broadened the options to consider thresholds 

ranging from a 25,000 tpy CO2e major source applicability level for PSD and title V up to a 

100,000 tpy CO2e level, with associated PSD GHG significant levels of equal magnitude. EPA 

also considered the impact on burden of different PSD GHG significance levels combined with 
12

the 100,000 tpy major source level, including 50,000 CO2e, 75,000 CO2e, and 100,000 CO2e. 

The choice of a PSD significance level also has a direct impact on title V burdens since a greater 

number of PSD permit requirements that result from modification activities will result in a 

greater number of necessary title V revisions. 

PSD Permits

Table 3-1 presents the estimated burden for permitting authorities at different possible 

PSD GHG major source applicability thresholds. Descriptions of the different thresholds 

selected are provided below. Burden estimates for the PSD program are calculated based on 

listed values obtained from Tables 6-1 and 6-2 the NSR ICR. The ICR does not distinguish 

between new construction and modification actions; therefore, Table 3-1 combines the actions 

into permit preparation issuance based solely on GHG emissions or the addition of GHG 

requirements to permits being issued for conventional sources, or “anyway” permits. PSD permit 

preparation and issuance is further divided into industrial and commercial/residential sources 

since less time is required for commercial/residential sources. 

Baseline

After receiving comments on the proposal and reevaluating the initial estimates, EPA has 

determined the impact of regulating GHG emissions under current PSD statutory thresholds for 

applicability. Baseline burden and cost were calculated at the 100 tpy and 250 tpy major source 

permitting threshold (the 100 tpy threshold applies to the 28 source categories identified in the 

Clean Air Act section 169(1)). At these thresholds, the additional annual permitting burden for 

permitting authorities is estimated at 19.5 million hours at a cost of $1.5 billion.
13

Table 3-1. Additional Permitting Authority PSD Burden with GHG (Annual) 

Activity 

Burden 

Hours 

per 

Permit 

Affected 

Permits 

Total 

Burden 

(hours) 

Total Cost 

($2007)a

100/250 tpy Major /100 tpy Significance Threshold (“Baseline”) 

 PSD Permit Preparation and Issuance - Industrial 301 26,089 7,852,789 $606,392,367

 PSD Permit Preparation and Issuance - Commercial/Residentialb

 210 55,509 11,656,890 $900,145,046

 Additions to Current PSD Applicationsc

 50 688 34,400 $2,656,368

 Total Additional Burden 19,544,079 $1,509,193,780

25,000 tpy Major/ 25,000 tpy Significance Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 9197 2,768,297 $213,767,894

 PSD Permit Preparation and Issuance - Commercial/Residential 210 63 13,230 $1,021,621

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 2,815,927 $217,445,883

50,000 tpy Major/ 50,000 Significance Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 1906 573,706 $44,301,577

 PSD Permit Preparation and Issuance - Commercial/Residential 210 28 5,880 $454,054

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 613,986 $47,411,999

100,000 tpy Major/ 50,000 tpy Significance Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 1809 544,509 $42,046,985

 PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 579,749 $44,768,218

100,000 tpy Major/ 75,000 tpy Significance Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 915 275,415 $21,267,546

 PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 310,655 $23,988,779

100,000 tpy Major/ 100,000 tpy Significance Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 20 6020 $464,864

 PSD Permit Preparation and Issuance - Commercial/Residential 210 4 840 $64,865

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 41,260 $3,186,097

Non-GHG-Based Threshold 

 PSD Permit Preparation and Issuance - Industrial 301 0 0 $0

 PSD Permit Preparation and Issuance - Commercial/Residential 210 0 0 $0

 Additions to Current PSD Applications 50 688 34,400 $2,656,368

 Total Additional Burden 34,400 $2,656,368

a

Labor cost of $77.22/hr from Prevention of Significant Deterioration and Non-Attainment Area New Source Review (Renewal), EPA ICR Number 1230.23, OMB 

Control Number 2060-0003, 2008. 

b

Assume permit preparation and issuance for commercial/residential permits takes 70% the amount of time needed to prepare and issue an industrial permit. 

c

For current permit applications, assume it takes an additional 50 hours to include GHG requirements in the permit. 
14

Alternate Threshold Scenarios

After determining the baseline, additional annual burden was determined at six different 

major stationary source threshold levels in order to evaluate the relative differences in impacts to 

permitting authorities. Estimates represent the additional burden and costs due to GHG 

permitting beyond to the burden currently experienced by permitting authorities and sources. 

The first scenario is the threshold proposed in the GHG Tailoring Rule of 25,000 tpy 

CO2e. Results of this analysis indicate a total of 9,260 new permits, plus 688 permit actions to 

include GHG related requirements into current PSD permitting actions (including both new 

construction and modifications). This additional workload equates to 2.8 million hours for 

permitting authorities at a cost of $217 million. Note this is an increase over our initial results at 

proposal of over 185,000 burden hours and $8.7 million. Again, increases are due to more 

accurate estimates of annual modifications and burden associated with commercial/residential 

permits. 

Increasing the emission threshold to 50,000 tpy will lead to an estimated 614,000 hours 

additional burden at a cost of $47.4 million. This scenario estimates 1,934 new sources will be 

subject to PSD permitting annually due to GHG. 

Setting a threshold of 100,000 tpy with a significance level of 50,000 tpy, permitting 

authorities will spend an estimated 580,000 hours preparing and issuing permits, at a cost of 

$44.8 million. At this level, EPA estimates 1,813 new sources must obtain PSD permits. 

Next, at the 100,000 tpy threshold with a 75,000 tpy significance level, the annual 

permitting authority burden will increase by 311,000 hours at a cost of $24 million. 
15

At a 100,000 tpy threshold, with a 100,000 tpy significance level for modifications, EPA 

estimates there are 20 industrial PSD permit actions and four commercial/residential. Permitting 

authorities will spend an estimated 41,000 additional hours on permits at a cost of $3.2 million. 

The final scenario involves only sources that are required to get a PSD permit due to their 

non-GHG emissions and then are further required to add GHG related requirements as a result of 

GHG emissions increases from modifications, or GHG emissions at newly constructed facilities, 

exceeding a significance threshold of 75,000 tpy GHG. In this scenario, only the annual 688 PSD 

permit actions derived from the NSR ICR are expected to need the inclusion of GHG related 

requirements to the permits. The additional burden to permitting authorities under this scenario is 

estimated at 34,000 hours at a cost of $2.7 million. 

Title V Permits

Table 3-2 presents the estimated burden for permitting authorities at different possible 

title V GHG major source applicability thresholds. Descriptions of the different thresholds 

selected are provided below. Burden estimates are calculated and annual values derived from 

Tables 7 and 8 of the current Title V ICR.23 

Baseline

EPA reevaluated our estimates of the additional administrative burden and cost of 

including GHG emitters in the title V program at the current 100 tpy statutory threshold level. To 

determine the impact of regulating GHG emissions under current title V program, baseline 

 

23 For consistency, the permitting authority labor costs are updated to 2007 dollars utilizing the 2007 

General Schedule Salary Table from the Office of Personnel Management. 
16

burden and cost are calculated at the 100 tpy threshold level, which is the generally applied 

major source applicability level under title V. At the statutory threshold level, it is estimated that 

almost 460 million burden hours are needed to prepare and issue over two million new operating 

permits at an additional cost of $21.1 billion annually. 

Alternate Threshold Scenarios

After determining the baseline, additional burden was determined at six different major 

stationary source threshold levels in order to evaluate the relative differences in impacts to 

permitting authorities. Estimates represent the additional annual burden and costs due to GHG 

permitting beyond the burden and costs currently experienced by permitting authorities and 

sources. 

The first scenario is the threshold proposed in the GHG Tailoring Rule of 25,000 tpy 

CO2e. Results of this analysis indicate a total of 2,547 new permits, as well as 50 permits that 

would need to include GHG requirements in their permits. This additional workload equates to 

1.4 million hours for permitting authorities at a cost of $64 million. Note that this is an increase 

over our initial results at proposal of approximately 985,000 burden hours and $45 million. As 

with PSD programs, increases are due to more complete estimates of annual modifications and 

the revised burden associated with commercial/residential permits. 

Increasing the emission threshold to 50,000 tpy will lead to an estimated 568,000 hours 

additional burden at a cost of $26.1 million. This scenario estimates 1,189 new sources will be 

subject to title V permitting annually due to GHG. 

To examine the impact of significance levels on the overall burden, EPA considered the 

impact on burden of different PSD GHG significance levels of 50,000 CO2e, 75,000 CO2e, and 

100,000 CO2e combined with the 100,000 tpy major source level The choice of a PSD 
Table 3-2. Additional Permitting Authority Title V Burden with GHG (Annual) 

Activity 

Burden 

Hour per 

Permit 

Affected 

Permits 

Total Burden 

(hours) 

100 tpy (associated with PSD 100/250 tpy maj./100 tpy sig.) 

New Permit Preparation and Issuance - Industrial 428 71,829 30,742,81Add GHG component to new Non-GHG Permitb 43 50 2,15New Permit Preparation and Issuance - Commercial/Residentialc 214 1,985,948 424,992,87Permit Revisions - due to GHG 40 61,836 2,473,44Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79Permit Renewalsd 9 2,614 23,52

 Total Additional Burden 458,236,5925,000 tpy (associated with PSD 25,000 tpy maj./25,000 tpy sig.)  New Permit Preparation and Issuance - Industrial 428 2,103 899,94 Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 214 444 94,94 Permit Revisions - due to GHG 40 9,197 367,88 Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 1,390,23

50,000 tpy (associated with PSD 50,000 tpy maj./50,000 tpy sig.)  New Permit Preparation and Issuance - Industrial 428 981 419,86 Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 214 208 44,44 Permit Revisions - due to GHG 40 1,906 76,24 Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 568,01

100,000 tpy (associated with PSD 100,000 tpy maj./50,000 tpy sig.)  New Permit Preparation and Issuance - Industrial 428 172 73,47 Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 214 18 3,78 Permit Revisions - due to GHG 40 1,809 72,36 Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 177,08
Table 3-2 cont’d. Additional Permitting Authority Title V Burden with GHG (Annual) 

Activity 

Burden 

Hour per 

Permit 

Affected 

Permits 

Total Burden 

(hours) 

100,000 tpy (associated with PSD 100,000 tpy maj./75,000 tpy sig.)  New Permit Preparation and Issuance - Industrial 428 172 73,47 Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 214 18 3,78 Permit Revisions - due to GHG 40 915 36,60 Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 141,32

100,000 tpy (associated with 100,000 tpy maj./ 100,000 tpy sig.)  New Permit Preparation and Issuance - Industrial 428 172 73,47 Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 214 18 3,78 Permit Revisions - due to GHG 40 20 80 Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 105,52

Non-GHG Based Threshold  New Permit Preparation and Issuance - Industrial 428 0  Add GHG component to new Non-GHG Permit 43 50 2,15 New Permit Preparation and Issuance - Commercial/Residential 21 0  Permit Revisions - due to GHG 40 0  Permit Revisions - add GHG to Current Non-GHG Permits 4 448 1,79 Permit Renewals 9 2,614 23,52

Total Additional Burden 27,46

aSalaries from Title V ICR adjusted to 2007 dollars using 2007 OPM General Schedule Salary Table available at: http://www.opm.gov/oca/07tables/index.asp bIncorporating GHG information/requirements into significant revisions and permit renewals adds an additional 10% of the current time (90 hours each) cNew commercial/residential permits require half the time needed for new industrial permits dThe Title V ICR estimates that 3,267 permits annually undergo renewal - assume 80% of these involve combustion 
19

significance level has a direct impact on title V burdens since a greater number of PSD permit 

requirements that result from modification activities will result in a greater number of necessary 

title V revisions. This effect is apparent in Table 3-2. 

Setting a threshold of 100,000 tpy with a PSD significance level of 50,000 tpy, permitting 

authorities will spend an estimated 177,000 hours preparing and issuing permits, at a cost of $8.1 

million. Utilizing a 75,000 tpy PSD significance level, the annual permitting authority burden is 

estimated to increase by 161,000 hours at a cost of $7.4 million. This decrease from the previous 

scenario is due to fewer modifications exceeding the higher significance level threshold and 

requiring revisions to an operating permit. At a 100,000 tpy threshold, with a 100,000 tpy PSD 

significance level for modifications, EPA estimates there are 172 industrial and 18 

commercial/residential new title V permit actions due to GHG. Permitting authorities will spend 

an estimated 106,000 additional hours on permits at a cost of $4.9 million. 

The final scenario involves only sources that are required to get a title V permit for 

emissions other than GHG and that are required to add GHG related requirements. Under this 

scenario, only the annual issuance of 50 permits noted in the Title V ICR are expected to need 

the inclusion of GHG related requirements to the permits. The additional burden to permitting 

authorities under this scenario is estimated at 27 million hours at a cost of $1.3 million. 

4. Burden Relief Estimates for Permitting Authorities and Sources at Several Possible 

GHG Major Source Applicability Threshold for Title V and PSD 

The following tables indicate the estimated burden relief when comparing the baseline 

levels with several threshold levels for GHG applicability as described in the previous sections. 

In Tables 4-1 through 4-4, the first three columns indicate the cost per permit and total cost to 
20

permitting authorities at a GHG threshold level equal to the statutory threshold levels for title V 

and PSD (100 and 100/250 tpy, respectively). The next three columns reflect the estimated costs 

for permitting authorities with the permitting thresholds (both for PSD and title V) set at the 

specified levels. In the final three columns, the burden relief is estimated – the time and costs 

alleviated relative to the baseline levels by establishing several GHG permitting thresholds as 

previously described. 

The burden relief for sources at the different permitting thresholds is presented in Tables 

4-5, 4-6, and 4-7 below. Table 4-8 estimates the cost savings if a non-GHG based related trigger 

is used. This information on burden relief was used to compile the final Regulatory Impact 

Analysis (RIA) for the final GHG tailoring rule. Please see the final RIA contained in the public 

docket for this GHG tailoring rule for a full explanation and description of the burden relief 

provided by the final GHG tailoring rule actions. 
Table 4-1. Estimated Burden Relief for Permitting Authorities Utilizing a 25,000 tpy Major/ 25,000 tpy PSD Significa

 All Title V 100tpy and PSD 250 tpy 25,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,678 2,103 $41,382,834 $19,678  Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978  New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,839 444 $4,368,516 $9,839  Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 9,197 $16,922,480 $1,840  Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184  Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414  Total Permits Affected 2,122,725 14,856 PSD Permits  New Industrial $23,243 26,089 $606,386,627 $23,243 9,197 $213,765,871 $23,243  New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 63 $1,021,608 $16,216  Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861  Total Permits Affected 82,286 9,948 Total Permitting Authority Costs $22,588,066,734 $281,381,205 
Table 4-2. Estimated Burden Relief for Permitting Authorities Utilizing a 50,000 tpy Major/50,000 tpy PSD Significa

 All Title V 100tpy and PSD 250 tpy 50,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,678 981 $19,304,118 $19,678  Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978  New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,839 208 $2,046,512 $9,839  Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 1,906 $3,507,040 $1,840  Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184  Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414  Total Permits Affected 2,122,725 6,207 PSD Permits  New Industrial $23,243 26,089 $606,386,627 $23,243 1,906 $44,301,158 $23,243  New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 28 $454,048 $16,216  Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861  Total Permits Affected 82,286 2,622 Total Permitting Authority Costs $22,588,066,734 $73,532,772 
Table 4-3. Estimated Burden Relief for Permitting Authorities Utilizing a 100,000 tpy Major/75,000 tpy PSD Significa

 All Title V 100tpy and PSD 250 tpy 100,000 tpy; 75,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,678 172 $3,384,616 $19,678  Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978  New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,839 18 $177,102 $9,839  Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 915 $1,683,600 $1,840  Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184  Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414  Total Permits Affected 2,122,725 4,217 PSD Permits  New Industrial $23,243 26,089 $606,386,627 $23,243 915 $21,267,345 $23,243  New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 4 $64,864 $16,216  Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861  Total Permits Affected 82,286 1,607 Total Permitting Authority Costs $22,588,066,734 $30,497,423 
Table 4-4. Estimated Burden Relief for Permitting Authorities Utilizing a Non-GHG Trigger 

 All Title V 100tpy and PSD 250 tpy Non-GHG Trigger 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $19,688 71,829 $1,414,175,915 $19,678 0 $0 $19,678  Current Industrial - Add GHG $1,978 50 $98,900 $1,978 50 $98,900 $1,978  New Commercial/Residential $9,844 1,985,948 $19,549,672,112 $9,839 0 $0 $9,839  Permit Revisions - Due to GHG $1,840 61,836 $113,778,240 $1,840 0 $0 $1,840  Permit Revisions - Add GHG $184 448 $82,432 $184 448 $82,432 $184  Permit Renewals $414 2,614 $1,082,196 $414 2,614 $1,082,196 $414  Total Permits Affected 2,122,725 3,112 PSD Permits  New Industrial $23,243 26,089 $606,386,627 $23,243 0 $0 $23,243  New Commercial/Residential $16,216 55,509 $900,133,944 $16,216 0 $0 $16,216  Current Applications - Add GHG $3,861 688 $2,656,368 $3,861 688 $2,656,368 $3,861  Total Permits Affected 82,286 688 Total Permitting Authority Costs $22,588,066,734 $3,919,896 
Table 4-5. Estimated Burden Relief for Sources Utilizing a 25,000 tpy Major/25,000 tpy PSD Significance Thr

 All Title V 100tpy and PSD 250 tpy 25,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 2,103 $97,474,050 $46,350  Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440  New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 444 $10,289,700 $23,175  Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 9,197 $15,423,369 $1,677  Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156  Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780  Total Permits Affected 2,122,725 14,856 PSD Permits  New Industrial $84,530 26,089 $2,205,303,170 $84,530 9,197 $777,422,410 $84,530  New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 63 $3,726,576 $59,152  Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669  Total Permits Affected 82,286 9,948 Total Source Costs $54,963,344,090 $921,575,185 
Table 4-6. Estimated Burden Relief for Sources Utilizing a 50,000 tpy Major/50,000 tpy PSD Significance Thr

 All Title V 100tpy and PSD 250 tpy 50,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 981 $45,469,350 $46,350  Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440  New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 208 $4,820,400 $23,175  Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 1,906 $3,196,362 $1,677  Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156  Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780  Total Permits Affected 2,122,725 6,207 PSD Permits  New Industrial $84,530 26,089 $2,205,303,170 $84,530 1,906 $161,114,180 $84,530  New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 28 $1,656,256 $59,152  Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669  Total Permits Affected 82,286 2,622 Total Source Costs $54,963,344,090 $233,495,628 
Table 4-7. Estimated Burden Relief for Sources Utilizing a 100,000 tpy Major/75,000 tpy PSD Significance Th

 All Title V 100tpy and PSD 250 tpy 100,000 tpy; 75,000 tpy or Greater 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 172 $7,972,200 $46,350  Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440  New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 18 $417,150 $23,175  Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 915 $1,534,455 $1,677  Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156  Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780  Total Permits Affected 2,122,725 4,217 PSD Permits  New Industrial $84,530 26,089 $2,205,303,170 $84,530 915 $77,344,950 $84,530  New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 4 $236,608 $59,152  Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669  Total Permits Affected 82,286 1,607 Total Source Costs $54,963,344,090 $104,744,443 
Table 4-8. Estimated Burden Relief for Sources Utilizing a Non-GHG Trigger 

 All Title V 100tpy and PSD 250 tpy Non-GHG Trigger 

Activity 

Cost per 

Permit 

(2007$) 

Number 

of Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Number 

of 

Permits 

Total Cost 

(2007$) 

Cost 

per 

Permit 

(2007$) 

Title V Permits  New Industrial - Due to GHG $46,350 71,829 $3,329,289,600 $46,350 0 $0 $46,350  Current Industrial - Add GHG $4,440 50 $222,000 $4,440 50 $222,000 $4,440  New Commercial/Residential $23,175 1,985,948 $46,024,344,900 $23,175 0 $0 $23,175  Permit Revisions - Due to GHG $1,677 61,836 $103,698,972 $1,677 0 $0 $1,677  Permit Revisions - Add GHG $156 448 $69,888 $156 448 $69,888 $156  Permit Renewals $780 2,614 $2,038,920 $780 2,614 $2,038,920 $780  Total Permits Affected 2,122,725 3,112 PSD Permits  New Industrial $84,530 26,089 $2,205,303,170 $84,530 0 $0 $84,530  New Commercial/Residential $59,152 55,509 $3,283,468,368 $59,152 0 $0 $59,152  Current Applications - Add GHG $21,669 688 $14,908,272 $21,669 688 $14,908,272 $21,669  Total Permits Affected 82,286 688 Total Source Costs $54,963,344,090 $17,239,080 
1 

APPENDIX A 

Table A-1. Newly Major Affected Source Estimates Based on Threshold Level 

Source Type 100/250 tpy PSD 100 tpy Title V 25,000 tpy 50,000 tpy 100,000 tpy 

EGUs 285 285 124 0 0

Industrial 141,160 170,910 4,002 1,934 256

Oil/Gas/Coal production 2,588 2,588 187 75 52

Waste Treatment 3,344 3,358 1,927 910 193

Commercial 731,477 1,355,921 1,161 600 51

Residential 182,350 4,535,500 160 20 0

Total 1,061,204 6,068,562 7,561 3,539 552

Based on information contained in the “Technical Support Document for Greenhouse Gas Emissions Thresholds Evaluation;” Office of Air 

Quality Policy and Standards; March 2010