From: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Keith Barnett/RTP/USEPA/US@EPA

Cc: Tom Walton/RTP/USEPA/US@EPA

Date: 08/06/2010 11:05 AM

Subject: RE: Plant language / High mercury facilities

How about this:

“EPA notes that since conducting this analysis, one high mercury

‐ emitting plant has invested in control

technology estimated to reduce emissions by approximately 85 percent. The current analysis does not

include these actual costs in the baseline but rather estimates aggregate compliance costs based on the

averaging methodologies applied to all other modeled plants. In addition, because this investment

occurred after the analysis was conducted, the baseline benefits likewise do not include the

approximately 85% emissions reduction.

Finally, EPA did not estimate the change in social costs that would occur if the 2 high mercury

‐ emitting

plants were to shut down, because the Agency believes these plants will ultimately be able to meet the

emissions limit by applying multiple mercury controls, which were accounted for in the cost analysis.

EPA also acknowledges that if these 2 high mercury

‐ emitting plants ultimately are able to meet the

emissions limit, they will not likely be able to do so by the required compliance date."

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: Barnett.Keith@epamail.epa.gov [

mailto: Barnett.Keith@epamail.epa.gov]

Sent: Thursday, August 05, 2010 9:06 PM

To: Higgins, Cortney

Cc: Walton.Tom@epamail.epa.gov

Subject: Re: Plant language / High mercury facilities

How about a little more info.

“EPA notes that since conducting this analysis, one high mercury

‐ emitting plant has invested in control

technology estimated to reduce emissions by approximately 85 percent. The current analysis does not

include these actual costs in the baseline but rather estimates aggregate compliance costs based on

the averaging methodologies applied to all other modeled plants. In addition, because this investment

occurred after the analysis was conducted, the baseline benefits likewise do not include the

approximately 85% emissions reduction.

Finally, EPA did not estimate the change in social costs that would occur if the 2 high mercury

‐ emitting

plants were to shut down, because the Agency believes these plants will ultimately be able to meet the

emissions limit by applying multiple mercury controls, which were accounted for in the cost

analysis. “

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243

‐ 02

Research Triangle Park, NC 27711

919

‐ 541

‐ 5605

barnett.keith@epa.govFrom: "Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To: Keith Barnett/RTP/USEPA/US@EPA, Tom Walton/RTP/USEPA/US@EPA

Cc: Charlotte Bertrand/DC/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA

Date: 08/05/2010 07:16 PM

Subject: Plant language / High mercury facilities

Hi Tom,

Here is our proposed language related to the Durkee plant and the high mercury facilities

– please let

me know if you have any questions or comments:

Suggested for the RIA; should be in Chapter 3, preferably around Table 3

‐ 11 where social costs are

summarized.

“EPA notes that since conducting this analysis, one high mercury

‐ emitting plant has invested in control

technology estimated to reduce emissions by approximately 85 percent. The current analysis does not

include these actual costs in the baseline but rather estimates aggregate compliance costs based on

the averaging methodologies applied to all other modeled plants. In addition, because this investment

occurred after the analysis was conducted, the baseline benefits likewise do not include the

approximately 85% emissions reduction.

Finally, EPA did not estimate the change in social costs that would occur if the 2 high mercury

‐ emitting

plants were to shut down. “