From: "Lacey, Pam" <PLacey@aga.org>

To: Roger Fernandez/DC/USEPA/US@EPA
Cc: Akachi Imegwu/DC/USEPA/US@EPA, "Plotk in, Victoria" <vpl otkin@aga.org>

Date: 06/04/2010 01:32 PM Subject: Subpart W - Additional Cost Impact Data - for Distri bution M&R Annual Leak Su rveys Docket EPA-HQ-OAR-200 9

Roger -- In response to your request for addi tional cost data showing our estimated costs for leak detection under the proposed Subpart W broken out by type of metering and regulating (M&R) station and me ter, I am providing the attached spreadsheet provided by one of our larger member companies (with company-identifying information removed). This is a rough estimate, but is more likely to underestimate than overestimate costs.

Please forward this email and attach ment to the rulemaking docket number EPA-HQOAR-2009-0923

.

AGA is gathering additional cost data fr om members through a survey that should provide a broader view of costs. The survey data will also be broken out by type of M&R station (city gates, custody transfer stat ions, district regulati ng stations, industrial customer M&R, commercial customer M&R, an d residential customer meters). I will also forward the summary of survey results as soon as possible, in addition to including it in AGA’s comments to be filed June 11, 2010.

Note: The member that provided the attached spreadsheet data explained they estimated that the incremental cost for conducting the a nnual leak detection called for in Subpart W would be $40.51 per inspection per city gate stat ion or district regulator station or per

industrial or commercial customer meter if infrared cameras are not required – roughly

one hour of technician time. In contrast , they estimate it would cost about $16,125 per city gate to conduct the annual inspection using an infrared camera. The costs of using

infrared cameras at other M&R locations varies by type –

· $16,125 per city gate

· $860 per district M&R station from transmission (c ustody transfer other than at city gate)

· $244 per district M&R station (stepping down pressu re within distribution system)

· $377 per industrial meter

· $30 per commercial meter· No figure given for residentia l – but likely to be roughly the same as for commercial – i.e. $30 per meter

You can multiply the per location estimates by the total number of city gates, custody transfer stations, industrial meters, commercial meters and residential meters in the U.S. (based on the DOE EIA numbers of meters) to determine total cost for requiring infrared cameras at each type of metering and re gulating location. Similarly, you can multiply $40.51 times the number of each type of M&R station or meter to determine the cost of requiring annual leak surveys under Subpart W, without requiring infrared cameras.

There are more than 70 million residential, commercial and industrial customers in the U.S. If leak surveys were required at each meter, but not infrared cameras, the cost would be $2,835,700,000 – nearly $3 billion per year, and that is without requiring infrared cameras. AGA requests that EPA cl arify that the term M&R station excludes industrial, commercial and resi dential customer meters.

Thank you for the opportunity to provide comm ents and data regarding the Subpart W proposal.

Respectfully,

Pamela

Pamela A. Lacey| Sr. Managing Counsel, Environment

American Gas Association

400 N. Capitol St., NW | Washington DC 20001 202.824.7340 | placey@aga.org | Fax 202.824.7082 | www.aga.org

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AGA Member GHG Reporting Subpart W Potential Impacts June 2010.xlsx