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

To: Roger Fernandez/DC/USEPA/US@EPA 

Cc: Akachi Imegwu/DC/USEPA/US@EPA, "Plotkin, Victoria" <vplotkin@aga.org> 

Date: 06/04/2010 01:32 PM 

Subject: Subpart W - Additional Cost Impact Data - for Distribution M&R Annual Leak Surveys Docket EPA-HQ-OAR-2009

Roger -- In response to your request for additional 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 meter, 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 attachment to the rulemaking docket number EPA-HQOAR-2009-0923. 

 

AGA is gathering additional cost data from 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 stations, district regulating stations, industrial 

customer M&R, commercial customer M&R, and 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 annual leak detection called for in Subpart W 

would be $40.51 per inspection per city gate station 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 (custody transfer other than at 

city gate) 

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

· $377 per industrial meter 

· $30 per commercial meter 
· No figure given for residential – 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 regulating 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 clarify that the term M&R station excludes 

industrial, commercial and residential customer meters. 

 

Thank you for the opportunity to provide comments 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