Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 1

memorandum

Environment and Resources

55 Wheeler Street, Cambridge, MA  Tel: 617 492-7100  www.abtassociates.com

Date April 4, 2011

To Erik Helm

From Tatiana Melnikova and Michael Fisher

Subject Cost and Economic Impact Analysis Using Alternative IPM Unit Closure Definition and

New Unit Cost Estimates

As described in Chapter 6: Assessing the Impact of the Existing Facilities Regulatory Options in the

Context of National Electricity Markets of Economic and Benefits Analysis for Proposed Section 316(b)

Existing Facilities Rule (the EA report), EPA used ICF International’s Integrated Planning Model (IPM)

to assess the economic impact of the existing facilities rule regulatory options within the context of

regional and national electricity markets. The IPM analysis requires a baseline projection of operations by

plant and generating unit, which is aggregated to the market level, over the relevant analysis period,

independent of the effect of the existing facilities rule regulatory options (the IPM baseline). The

information projected by IPM for this baseline includes operating statistics such as total electricity

generated by individual plants and units, available capacity for electric generation, fuel consumption and

electricity production cost, electricity price at the NERC regional market level, and the occurrence of

capacity retirements and capacity additions1.

The IPM baseline provides the foundation for assessing the effects of alternative regulatory options, most

directly in the IPM-based analysis of market-level effects but also for the cost and economic impact

analysis that is performed apart from the IPM market-level analysis. In particular, information from the

IPM baseline that is used for the more general cost and economic impact analysis includes the projection

of baseline operations for plants and generating units within the scope of the existing facilities rule,

including a projection that some of these plants and units may cease operation during the period of

analysis before consideration of the existing facilities rule compliance requirements. These plants and

generating units that are projected to close independent of rule requirements are referred to as baseline

closures, and are removed from the analysis of the cost and economic impact of the existing facilities rule

regulatory options. Another part of the IPM baseline that is used in the general cost and economic impact

analysis is the projection of capacity additions, which is used in estimating the potential cost of installing

cooling tower technology at new generating units at existing facilities as specified in the existing facilities

rule regulatory options.

For these two items of information from the IPM baseline – projection of baseline closures and projection

of new generating capacity – we received and processed information from the IPM baseline in accordance

with certain interpretations of this information. However, we learned in the course of our analysis that the

information on baseline closures and projection of new generating capacity could be interpreted

differently. Implementing these alternative data interpretations within the cost and economic impact

analysis would led to slightly different estimates of the total cost and economic impact of the regulatory

options. This memorandum summarizes these differences of IPM baseline interpretation and the

differences in cost and economic impact analysis findings. These alternative interpretations and the

1

See Chapter 6 of the EA report for additional information on the data items for which IPM develops a baseline projection.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 2

general effect on the analysis are summarized in the following section. Following this overview, we

provide summary results for the cost and economic impact analysis, using the same organization and table

formats as documented in the EA report.

1 Differences in Interpretation IPM Baseline Information

1.1 Projection of Baseline Closures

The IPM baseline includes projections of retired units (“early retirement” is the IPM baseline

designation), which are generally taken to mean that the generating unit will be completely unavailable

for electric power generation and thus would not be expected to incur compliance costs as a result of

regulatory requirements. In the course of our work with the IPM baseline, we observed that a few

generating units identified in the IPM baseline run as early retirements – and built into the rule analysis as

baseline closures – in fact had some level of ongoing expenses suggesting that the units were not “truly

closed.” In follow-up with ICF, we learned that these early retirement units are “partial closures,”

meaning that their operation was limited to generation levels below their reported generating capacity but

that, technically speaking, the units could remain available for electric power generation.

In the primary analyses as documented in the EA report, we treated these partial closure units as full unit

closures. In some cases, these partial closure units would lead to the interpretation that the entire steam

generating capacity at a plant was closed in the baseline (and thus would constitute a baseline closure

plant); in others, the partial closure units reflected only a part of the steam generating capacity otherwise

operating at a plant and so were interpreted as a closure of specific generating units, but with the plant

remaining subject to regulatory requirements. Accordingly, in the analysis presented in the EA report,

these units and, in some instances, the total plant received no compliance costs. Including these

generating units and plants in the analysis would have led to higher estimates of compliance cost and

potentially higher estimates of plant-level impacts.

As reported in Table 1-1, below, if the partial closure units had not been treated as full early retirements,

the number of baseline closure units would have declined from 381 to 353.

Table 1-1: Summary of Different Baseline Closure Estimates Under

Alternative Interpretations of IPM Baseline Closure Information

Unit Type Number of Retired Units

(Steam Generating Only) Original Alternative Change

Coal Steam 22 16 -6

Combined Cycle 60 52 -8

Nuclear 5 3 -2

O/G Steam 294 282 -12

Total 381 353 -28

Source: U.S. EPA analysis, 2011

As reported in detail in the following sections, the effect on total costs and impacts is comparatively small

given the small number of plants and/or units affected by the alternative analytic treatment. For example,

total annualized cost to complying facilities for the proposed rule option, Option 1, increases from

approximately $475.0 million to $479.1 million (pre-tax cost at 7 percent discount rate), or less than a one

percent change (0.8%). For some cost metrics, the estimated cost declines slightly due to the use of
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 3

modestly different sample weights based on including additional facilities in the analysis.2Similarly,

impact metrics record small changes. For example, for Option 1, the estimated number of facilities

incurring costs between one and three percent of revenue increases by 2 facilities, and the number

exceeding three percent of revenue is unchanged. For Option 2, the number of facilities incurring costs

between one and three percent of revenue is unchanged, and the number exceeding three percent of

revenue increases by 3 facilities. For Option 3, the number of facilities incurring costs between one and

three percent of revenue declines by 1 facility, while the number exceeding three percent of revenue

increases by 3 facilities. As another illustration of the small effect on analysis findings, in terms of small

entity impacts, the number of small entities estimated to incur an adverse effect at either the 1 percent or 3

percent of revenue thresholds under the proposed Option 1 does not change.

1.2 Projection of New Capacity at Existing Facilities Subject to Regulatory

Requirements

The IPM analysis is based on run-years that generally represent additional years beyond the designated

run-year, as described in Chapter 6 of the EA report. For example, the run-year 2020 represents the 5-year

period, 2017-2022. In using the results from the IPM baseline analysis, we interpreted that each of the

five run-years, 2012, 2015, 2020, 2025, and 2028, represented specific years as follows:

 2012 – represents 2012

 2015 – represents 2013-2017

 2020 – represents 2018-2022

 2025 – represents 2023-2027

 2028 – represents 2028-2035.

In developing the estimates of new generating capacity potentially subject to the new generating units at

existing facilities requirement of the proposed rule, we summed the IPM-projected capacity additions in

each of the specified run-year periods, over the entire IPM baseline analysis period and then divided this

total by the number of years in the total baseline period. This calculation led to an estimated annual

average capacity addition that would be subject to the requirement to install cooling towers at new

generating units. Using the run-year specifications as outlined above, we divided the total estimated

capacity addition by 24 years. We later learned that the new capacity addition reported for the 2028 runyear represented only one year in the IPM run and that the annual average of new capacity would have

been better calculated by dividing by 17 years instead of 24 years. Based on this recalculation, the

estimated annual addition of capacity in new generating units subject to the cooling tower requirement

increases as reported in Table 1-1, below. These capacity values refer only to new units constructed at

existing facilities and were developed following the same calculation methodology as described in

Chapter 3, Section 3.3: Development of Costs for New Units of the EA report,

Table 1-2: Estimated Annual New Capacity Installation

Subject to Cooling Tower Requirement (MW)

Capacity Type Original Alternative Change

Coal 482 681 199

Combined Cycle 34 47 13

Nuclear - - -

Source: U.S. EPA analysis, 2011

2 The weights used for calculation of results reported in this memorandum are slightly different from the weights used to

generate the cost and economic results presented in the EA report because they were developed for a slightly different set of

facilities; specifically, the in-scope facility universe includes facilities previously identified as baseline IPM closures and

excluded from the development of weights applicable to facilities in the cost and economic impact analysis. See EA report

Appendix 3A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses for additional information on

development of sample weights for the cost and economic impact analysis.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 4

As a result of the increased rate of new capacity installation at existing facilities, the estimated annualized

compliance cost increases proportionately to the increase in capacity, with pre-tax annualized cost

increasing from $11.3 million to $16.4 million.

1.3 Overall Effect

As highlighted in the preceding sections, the effect of reducing the number of baseline closures in the

analysis is very small, with slight changes in costs and very little change, if any, in impact findings. As

stated above, the estimated numbers of facilities incurring a given cost-to-revenue impact changes by very

small amounts, and the number of small entities estimated to incur costs exceeding either the one or three

percent of revenue threshold does not change at all.

The effect of changing the calculation of new capacity at existing facilities subject to the cooling tower

installation requirement is more substantial as a percentage effect – approximately a 45 percent increase

in related costs – but the consequence of this increase in the overall rule analysis is small. For example,

total social cost (including accounting for the new units compliance provision) would increase by $7

million (3 percent discount rate) or less than 2 percent of the current estimated total social cost, including

accounting for the new units compliance provision.

2 EA Report Results Tables with Alternative Baseline Closures and New Units

at Existing Facilities Calculations

The following pages contain the summary tables from the EA report using the alternative baseline

closures and new units at existing facilities calculations, as outlined above. These tables have the same

table numbering and format as those presented in the EA report. Because the alternative calculations do

not apply to the Manufacturers in-scope industry segment, only tables and results for Electric Generators

are presented below, except in those instances (e.g., UMRA and social cost analysis) where results are

tabulated across the Electric Generators and Manufacturers segments in the EA report.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 5

Chapter 3: Development of Costs for Regulatory Options

Table 3-7: Annualized Compliance Costs by NERC Region (in millions, $2009, at 2012)a

One-Time Costs Recurring Costs

NERC

Region

Capital

Technology

Connection

Outage

Initial Permit

Application O&M

Monitoring,

Record

Keeping, and

Reporting

Energy

Penalty

Permit

Renewal Total

Option 1: IM Everywhere

Pre-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $12.11 $3.62 $0.11 $15.08 $1.79 $0.00 $0.10 $32.81

FRCC $15.35 $5.91 $0.06 $10.14 $1.00 $0.00 $0.06 $32.52

HICC $1.38 $0.00 $0.01 $1.91 $0.17 $0.00 $0.01 $3.48

MRO $7.01 $5.78 $0.12 $9.91 $2.14 $0.00 $0.11 $25.06

NPCC $14.31 $0.00 $0.16 $24.89 $2.66 $0.00 $0.15 $42.16

RFC $47.02 $6.15 $0.42 $56.03 $7.86 $0.00 $0.39 $117.88

SERC $36.80 $6.71 $0.40 $49.29 $6.92 $0.00 $0.38 $100.51

SPP $6.56 $31.17 $0.09 $12.62 $1.57 $0.00 $0.08 $52.09

WECC $1.05 $0.44 $0.06 $0.83 $0.85 $0.00 $0.06 $3.28

Total $141.58 $59.79 $1.42 $180.70 $24.96 $0.00 $1.34 $409.79

After-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $8.46 $2.35 $0.08 $11.16 $1.33 $0.00 $0.07 $23.45

FRCC $9.45 $3.63 $0.04 $6.25 $0.65 $0.00 $0.04 $20.06

HICC $0.84 $0.00 $0.00 $1.16 $0.11 $0.00 $0.00 $2.12

MRO $5.59 $5.71 $0.08 $7.23 $1.45 $0.00 $0.07 $20.13

NPCC $8.54 $0.00 $0.10 $14.82 $1.61 $0.00 $0.09 $25.16

RFC $28.25 $3.72 $0.26 $33.90 $4.97 $0.00 $0.25 $71.35

SERC $26.09 $4.07 $0.28 $35.45 $4.83 $0.00 $0.27 $70.99

SPP $4.22 $19.05 $0.06 $8.14 $1.03 $0.00 $0.05 $32.55

WECC $0.72 $0.26 $0.04 $0.55 $0.56 $0.00 $0.04 $2.17

Total $92.15 $38.80 $0.94 $118.65 $16.54 $0.00 $0.89 $267.98

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Pre-Tax Compliance Costsb

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $303.99 $12.27 $0.08 $34.44 $0.19 $144.88 $0.07 $495.91

FRCC $137.06 $10.85 $0.05 $16.38 $0.18 $81.21 $0.04 $245.77

HICC $17.82 $1.44 $0.01 $2.02 $0.00 $4.90 $0.01 $26.19

MRO $120.89 $10.60 $0.10 $14.01 $0.89 $65.26 $0.09 $211.84

NPCC $332.23 $34.23 $0.12 $38.33 $0.55 $202.34 $0.12 $607.93

RFC $814.39 $61.58 $0.33 $93.86 $2.49 $451.55 $0.32 $1,424.53

SERC $852.02 $135.85 $0.32 $97.92 $2.05 $583.37 $0.30 $1,671.83

SPP $183.97 $14.59 $0.07 $21.30 $0.37 $65.54 $0.07 $285.90

WECC $2.98 $0.44 $0.06 $0.99 $0.74 $0.39 $0.05 $5.66

Total $2,765.35 $281.84 $1.13 $319.26 $7.46 $1,599.44 $1.07 $4,975.55

After-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $214.74 $8.99 $0.06 $24.33 $0.12 $101.91 $0.05 $350.20

FRCC $86.06 $6.71 $0.03 $10.27 $0.11 $50.19 $0.03 $153.41

HICC $10.84 $0.88 $0.00 $1.23 $0.00 $2.98 $0.00 $15.93

MRO $89.19 $7.51 $0.06 $10.30 $0.53 $46.42 $0.06 $154.07

NPCC $197.67 $20.31 $0.08 $22.82 $0.36 $120.47 $0.07 $361.78

RFC $489.09 $37.09 $0.21 $56.49 $1.72 $271.26 $0.20 $856.06

SERC $624.12 $105.83 $0.22 $71.71 $1.48 $428.18 $0.21 $1,231.75

SPP $117.20 $9.07 $0.05 $13.66 $0.27 $41.07 $0.04 $181.36

WECC $1.92 $0.26 $0.04 $0.65 $0.50 $0.24 $0.04 $3.65

Total $1,830.82 $196.65 $0.75 $211.46 $5.10 $1,062.72 $0.71 $3,308.22
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 6

Table 3-7: Annualized Compliance Costs by NERC Region (in millions, $2009, at 2012)a

One-Time Costs Recurring Costs

NERC

Region

Capital

Technology

Connection

Outage

Initial Permit

Application O&M

Monitoring,

Record

Keeping, and

Reporting

Energy

Penalty

Permit

Renewal Total

Option 3: I&E Mortality Everywhere

Pre-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $303.99 $12.27 $0.08 $34.44 $0.19 $144.88 $0.07 $495.91

FRCC $138.35 $11.69 $0.04 $16.49 $0.07 $84.44 $0.04 $251.13

HICC $17.82 $1.44 $0.01 $2.02 $0.00 $4.90 $0.01 $26.19

MRO $129.86 $11.60 $0.09 $14.84 $0.22 $70.70 $0.08 $227.40

NPCC $345.15 $37.42 $0.11 $39.12 $0.00 $223.94 $0.10 $645.86

RFC $826.49 $63.91 $0.32 $94.28 $1.46 $467.57 $0.30 $1,454.35

SERC $866.66 $144.67 $0.30 $98.94 $1.23 $616.39 $0.29 $1,728.48

SPP $183.97 $14.59 $0.07 $21.30 $0.37 $65.54 $0.07 $285.90

WECC $4.01 $0.54 $0.05 $0.93 $0.53 $0.93 $0.05 $7.05

Total $2,816.31 $298.13 $1.07 $322.37 $4.07 $1,679.31 $1.01 $5,122.27

After-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $214.74 $8.99 $0.06 $24.33 $0.12 $101.91 $0.05 $350.20

FRCC $86.85 $7.23 $0.03 $10.34 $0.04 $52.18 $0.03 $156.70

HICC $10.84 $0.88 $0.00 $1.23 $0.00 $2.98 $0.00 $15.93

MRO $94.56 $8.15 $0.06 $10.79 $0.13 $49.77 $0.05 $163.51

NPCC $205.80 $22.25 $0.07 $23.33 $0.00 $133.69 $0.06 $385.20

RFC $498.13 $38.71 $0.20 $56.85 $0.93 $283.13 $0.19 $878.14

SERC $636.46 $113.41 $0.21 $72.58 $0.80 $455.56 $0.20 $1,279.22

SPP $117.20 $9.07 $0.05 $13.66 $0.27 $41.07 $0.04 $181.36

WECC $2.70 $0.32 $0.04 $0.60 $0.33 $0.60 $0.04 $4.62

Total $1,867.28 $209.00 $0.71 $213.71 $2.63 $1,120.89 $0.67 $3,414.89

Option 4: IM for Facilities with DIF>50MGD

Pre-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $11.84 $3.62 $0.11 $15.07 $1.68 $0.00 $0.10 $32.43

FRCC $15.35 $5.91 $0.06 $10.14 $1.00 $0.00 $0.06 $32.52

HICC $1.38 $0.00 $0.01 $1.91 $0.17 $0.00 $0.01 $3.48

MRO $6.66 $5.78 $0.12 $9.60 $1.71 $0.00 $0.11 $23.98

NPCC $14.21 $0.00 $0.16 $24.84 $2.51 $0.00 $0.15 $41.87

RFC $46.15 $3.17 $0.42 $55.78 $7.23 $0.00 $0.39 $113.15

SERC $36.34 $6.39 $0.40 $49.13 $6.24 $0.00 $0.38 $98.88

SPP $5.96 $31.03 $0.09 $12.60 $1.44 $0.00 $0.08 $51.20

WECC $0.26 $0.00 $0.06 $0.16 $0.21 $0.00 $0.06 $0.75

Total $138.16 $55.89 $1.42 $179.24 $22.19 $0.00 $1.34 $398.24

After-Tax Compliance Costs

ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

ERCOT $8.28 $2.35 $0.08 $11.15 $1.26 $0.00 $0.07 $23.20

FRCC $9.45 $3.63 $0.04 $6.25 $0.65 $0.00 $0.04 $20.06

HICC $0.84 $0.00 $0.00 $1.16 $0.11 $0.00 $0.00 $2.12

MRO $5.38 $5.71 $0.08 $7.05 $1.19 $0.00 $0.07 $19.49

NPCC $8.46 $0.00 $0.10 $14.78 $1.49 $0.00 $0.09 $24.92

RFC $27.69 $1.87 $0.26 $33.70 $4.50 $0.00 $0.25 $68.28

SERC $25.78 $3.87 $0.28 $35.33 $4.28 $0.00 $0.27 $69.82

SPP $3.86 $18.96 $0.06 $8.13 $0.95 $0.00 $0.05 $32.01

WECC $0.23 $0.00 $0.04 $0.14 $0.17 $0.00 $0.04 $0.61

Total $89.97 $36.40 $0.94 $117.69 $14.61 $0.00 $0.89 $260.50

a. EPA data indicate that no DQ in-scope facilities are located in the ASCC NERC region; an STQ facility in ASCC facility was grouped with

STQ facilities in the WECC region (see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses).

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 7

Table 3-8: Annualized Compliance Costs For Manufacturers and Electric Generators (in millions,

$2009, at 2012)a

One-Time Costs Recurring Costs

Facility Group

Capital

Technology

Connection

Outage

Initial

Permit

Application O&M

Monitoring,

Record

Keeping,

and

Reporting

Energy

Penalty

Permit

Renewal Total

Option 1: IM Everywhere

Pre-Tax Compliance Costs

Manufacturers $22.76 $1.34 $1.31 $21.91 $20.71 $0.00 $1.24 $69.26

Generators $141.58 $59.79 $1.42 $180.70 $24.96 $0.00 $1.34 $409.79

Total $164.34 $61.13 $2.73 $202.61 $45.67 $0.00 $2.58 $479.05

After-Tax Compliance Costs

Manufacturers $13.79 $0.80 $0.79 $13.25 $12.53 $0.00 $0.75 $41.92

Generators $92.15 $38.80 $0.94 $118.65 $16.54 $0.00 $0.89 $267.98

Total $105.94 $39.60 $1.73 $131.90 $29.07 $0.00 $1.64 $309.90

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Pre-Tax Compliance Costs

Manufacturers $97.69 $1.31 $1.24 $14.04 $18.97 $47.03 $1.17 $181.44

Generators $2,765.35 $281.84 $1.13 $319.26 $7.46 $1,599.44 $1.07 $4,975.55

Total $2,863.04 $283.15 $2.37 $333.30 $26.43 $1,646.47 $2.24 $5,156.99

After-Tax Compliance Costs

Manufacturers $58.89 $0.78 $0.75 $8.50 $11.48 $29.14 $0.71 $110.24

Generators $1,830.82 $196.65 $0.75 $211.46 $5.10 $1,062.72 $0.71 $3,308.22

Total $1,889.71 $197.43 $1.50 $219.96 $16.58 $1,091.86 $1.42 $3,418.46

Option 3: I&E Mortality Everywhere

Pre-Tax Compliance Costs

Manufacturers $161.45 $0.72 $0.76 $10.91 $6.46 $65.86 $0.72 $246.88

Generators $2,816.31 $298.13 $1.07 $322.37 $4.07 $1,679.31 $1.01 $5,122.27

Total $2,977.76 $298.85 $1.83 $333.28 $10.53 $1,745.17 $1.73 $5,369.15

After-Tax Compliance Costs

Manufacturers $97.57 $0.43 $0.46 $6.61 $3.90 $40.45 $0.44 $149.86

Generators $1,867.28 $209.00 $0.71 $213.71 $2.63 $1,120.89 $0.67 $3,414.89

Total $1,964.85 $209.43 $1.17 $220.32 $6.53 $1,161.34 $1.11 $3,564.75

Option 4: IM for Facilities with DIF>50MGD

Pre-Tax Compliance Costs

Manufacturers $16.11 $0.23 $0.35 $16.62 $5.93 $0.00 $0.33 $39.58

Generators $138.16 $55.89 $1.42 $179.24 $22.19 $0.00 $1.34 $398.24

Total $154.27 $56.12 $1.77 $195.86 $28.12 $0.00 $1.67 $437.82

After-Tax Compliance Costs

Manufacturers $9.78 $0.14 $0.21 $10.05 $3.60 $0.00 $0.20 $23.98

Generators $89.97 $36.40 $0.94 $117.69 $14.61 $0.00 $0.89 $260.50

Total $99.75 $36.54 $1.15 $127.74 $18.21 $0.00 $1.09 $284.48

Source: U.S. EPA analysis, 2011

Table 3-10: Annual Capacity Installation Subject to New Units EM Technology Requirement in

New Generating Units (MW)

Projected

Annual

Average New

Capacity

Subject to

Phase I New

Facility

Requirements

Residual

Subject to

Existing

Facilities Rule

Requirements

Install EM

Technology

Independent

of Rule

Requirements

Residual

Incurring Cost

due to Existing

Facilities Rule

Requirements

Capacity

Increase in

Existing

Units

Capacity

Increase in

New Units

Coal 5,044 3,531 1,513 757 757 76 681

Combined Cycle 2,106 1,074 632 316 316 269 47

Nuclear 1,938 - 1,938 969 969 969 -

Source: U.S. EPA analysis, 2011

The resulting annualized cost values for the new units EM technology requirement at new generating

units are $16.41 million pre-tax and $10.89 million after-tax ($2009, at 2012).
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 8

Chapter 5: Cost and Economic Impact Analysis – Electric Generators

Cost-to-Revenue Analysis: Facility-Level Screening Analysis

Table 5-1: Facility-Level Cost-to-Revenue Analysis Results by NERC Region and Regulatory

Optiona,b

Number of Facilities with a Ratio of

NERC Region

Total Number of

Facilitiesc No Revenued

<1% 1-3% >3%

Minimum

Ratio

Maximum

Ratio

Option 1: IM Everywhere

ASCC 0 0 0 0 0 0.00% 0.00%

ERCOT 42 5 28 7 2 0.00% 3.28%

FRCC 24 0 17 4 4 0.00% 3.49%

HICC 3 0 2 2 0 0.34% 1.04%

MRO 47 0 41 6 0 0.00% 1.80%

NPCC 63 0 49 14 0 0.00% 2.64%

RFC 165 0 149 13 3 0.00% 3.58%

SERC 160 0 149 6 5 0.00% 3.61%

SPP 34 0 28 6 0 0.00% 2.38%

WECC 23 0 19 0 4 0.00% 3.38%

Total 562 5 482 57 18 0.00% 3.61%

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

ASCC 0 0 0 0 0 0.00% 0.00%

ERCOT 42 5 5 1 31 0.00% 43.40%

FRCC 24 0 5 4 15 0.00% 35.37%

HICC 3 0 0 0 3 3.88% 8.48%

MRO 47 0 20 6 22 0.00% 25.35%

NPCC 63 0 15 10 38 0.00% 37.53%

RFC 165 0 47 15 103 0.00% 12.51%

SERC 160 0 44 14 103 0.00% 24.24%

SPP 34 0 11 6 17 0.00% 49.66%

WECC 23 0 19 0 4 0.00% 40.10%

Total 562 5 166 55 336 0.00% 49.66%

Option 3: I&E Mortality Everywhere

ASCC 0 0 0 0 0 0.00% 0.00%

ERCOT 42 5 5 1 31 0.00% 43.40%

FRCC 24 0 5 4 15 0.00% 35.37%

HICC 3 0 0 0 3 3.88% 8.48%

MRO 47 0 6 7 34 0.00% 25.35%

NPCC 63 0 0 9 55 1.22% 37.53%

RFC 165 0 38 8 119 0.00% 51.38%

SERC 160 0 29 22 108 0.00% 28.48%

SPP 34 0 11 6 17 0.00% 49.66%

WECC 23 0 17 0 6 0.00% 40.10%

Total 562 5 112 56 389 0.00% 51.38%

Option 4: IM for Facilities with DIF>50MGD

ASCC 0 0 0 0 0 0.00% 0.00%

ERCOT 42 5 28 7 2 0.00% 3.28%

FRCC 24 0 17 4 4 0.00% 3.49%

HICC 3 0 2 2 0 0.34% 1.04%

MRO 47 0 41 6 0 0.00% 1.80%

NPCC 63 0 52 11 0 0.00% 2.64%

RFC 165 0 151 12 2 0.00% 3.54%

SERC 160 0 150 5 5 0.00% 3.61%

SPP 34 0 28 6 0 0.00% 2.38%

WECC 23 0 19 0 4 0.00% 3.38%

Total 562 5 489 51 17 0.00% 3.61%
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 9

a. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see

Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses.

b. Facility counts may not add up due to rounding.

c. Facility counts exclude baseline closures.

d. IPM and EIA report no revenue for 2 facilities (5 on a weighted basis); consequently, the facility-level cost-to-revenue analysis is performed

for 257 facilities (559 on a weighted basis).

Source: U.S. EPA analysis, 2011

Cost-to-Revenue Screening Analysis: Parent Entity-Level Analysis

Table 5-3: Entity-Level Cost-to-Revenue Analysis Results, Using Facility-Level Weights

Number of Facilities with a Ratio of

Entity Type

Total Number of

Facilitiesa

Total Number of

Entities <1% 1-3% >3% Unknownb

Minimum

Ratio

Maximum

Ratio

Option 1: IM Everywhere

Cooperative 25 11 10 0 1 0 0.00% 3.88%

Federal 17 1 1 0 0 0 0.22% 0.22%

Investor-owned 305 39 39 0 0 0 0.00% 0.65%

Municipality 25 13 9 4 0 0 0.00% 2.55%

Nonutility 171 29 22 0 1 6 0.00% 47.84%

Other Political

Subdivision 2 1 1 0 0 0 0.45% 0.45%

State 17 4 4 0 0 0 0.00% 0.67%

Total 562 98 86 4 2 6 0.00% 47.84%

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Cooperative 25 11 7 1 3 0 0.00% 21.02%

Federal 17 1 0 0 1 0 9.19% 9.19%

Investor-owned 305 39 22 14 3 0 0.00% 10.97%

Municipality 25 13 6 5 2 0 0.01% 17.08%

Nonutility 171 29 17 2 4 6 0.00% 519.67%

Other Political

Subdivision 2 1 0 0 1 0 6.61% 6.61%

State 17 4 3 0 1 0 0.00% 13.40%

Total 562 98 55 22 15 6 0.00% 519.67%

Option 3: I&E Mortality Everywhere

Cooperative 25 11 4 3 4 0 0.00% 21.02%

Federal 17 1 0 0 1 0 9.19% 9.19%

Investor-owned 305 39 21 15 3 0 0.00% 10.97%

Municipality 25 13 2 5 6 0 0.57% 17.08%

Nonutility 171 29 17 2 4 6 0.00% 519.67%

Other Political

Subdivision 2 1 0 0 1 0 6.61% 6.61%

State 17 4 2 1 1 0 0.00% 13.40%

Total 562 98 46 26 20 6 0.00% 519.67%

Option 4: IM for Facilities with DIF>125MGD

Cooperative 25 11 10 0 1 0 0.00% 3.88%

Federal 17 1 1 0 0 0 0.22% 0.22%

Investor-owned 305 39 39 0 0 0 0.00% 0.65%

Municipality 25 13 10 3 0 0 0.00% 1.46%

Nonutility 171 29 22 0 1 6 0.00% 22.44%

Other Political

Subdivision 2 1 1 0 0 0 0.45% 0.45%

State 17 4 4 0 0 0 0.00% 0.67%

Total 562 98 87 3 2 6 0.00% 22.44%

a. Facility counts exclude baseline closures.

b.EPA was unable to determine revenues for 6 parent entities (8 weighted).

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 10

Table 5-4: Entity-Level Cost-to-Revenue Analysis Results, Using Entity-Level Weights

Number of Facilities with a Ratio of

Entity Type

Total Number of

Facilitiesa

Total Number of

Entitiesb

<1% 1-3% >3% Unknownc

Minimum

Ratio

Maximum

Ratio

Option 1: IM Everywhere

Cooperative 13 20 18 2 0 0 0.00% 1.78%

Federal 7 1 1 0 0 0 0.09% 0.09%

Investor-owned 138 43 43 0 0 0 0.00% 0.16%

Municipality 13 35 35 0 0 0 0.00% 0.82%

Nonutility 78 37 28 0 1 8 0.00% 22.74%

Other Political

Subdivision 1 3 3 0 0 0 0.20% 0.20%

State 8 4 4 0 0 0 0.00% 0.29%

Total 258 143 132 2 1 8 0.00% 22.74%

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Cooperative 13 20 13 5 2 0 0.00% 9.63%

Federal 7 1 0 0 1 0 3.83% 3.83%

Investor-owned 138 43 36 6 1 0 0.00% 5.28%

Municipality 13 35 24 8 3 0 0.00% 8.22%

Nonutility 78 37 24 4 1 8 0.00% 229.17%

Other Political

Subdivision 1 3 0 0 3 0 3.03% 3.03%

State 8 4 3 0 1 0 0.00% 5.86%

Total 258 143 101 23 12 8 0.00% 229.17%

Option 3: I&E Mortality Everywhere

Cooperative 13 20 9 9 2 0 0.00% 9.63%

Federal 7 1 0 0 1 0 3.83% 3.83%

Investor-owned 138 43 36 6 1 0 0.00% 5.28%

Municipality 13 35 13 11 11 0 0.26% 8.22%

Nonutility 78 37 24 4 1 8 0.00% 229.17%

Other Political

Subdivision 1 3 0 0 3 0 3.03% 3.03%

State 8 4 3 0 1 0 0.00% 5.86%

Total 258 143 86 29 20 8 0.00% 229.17%

Option 4: IM for Facilities with DIF>50MGD

Cooperative 13 20 18 2 0 0 0.00% 1.78%

Federal 7 1 1 0 0 0 0.09% 0.09%

Investor-owned 138 43 43 0 0 0 0.00% 0.16%

Municipality 13 35 35 0 0 0 0.00% 0.76%

Nonutility 78 37 28 0 1 8 0.00% 10.04%

Other Political

Subdivision 1 3 3 0 0 0 0.20% 0.20%

State 8 4 4 0 0 0 0.00% 0.29%

Total 258 143 132 2 1 8 0.00% 10.04%

a. Facility counts exclude baseline closures.

c. EPA was unable to determine revenue for 6 parent entities (8 weighted).

b. There are a total of 143 parent entities on an unweighted basis, 3 of which are other political subdivision entities. These entities own only

implicitly analyzed facilities; consequently, there is no explicitly analyzed other political subdivision parent entity to represent these implicitly

analyzed parent entities and total weighted entity counts do not include 3 other political subdivision entities.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 11

Impact of Compliance Costs on Household Electricity Costs

Table 5-5: Average Annual Cost per Household in 2015 by NERC Region and Regulatory Option

($2009)a

NERC

Regionb

Total Annual

Compliance

Cost (at 2015;

Million; $2009)

Total

Electricity

Sales (at 2015;

MWh)

Compliance

Cost per Unit of

Sales

($2009/MWh)

Residential

Electricity

Sales (at

2015; MWh)

Number of

Households

(at 2015)

Residential Sales

per Residential

Consumer

(MWh)

Compliance

Cost per

Household

($2009)

Option 1: IM Everywhere

ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00

ECAR $60,951,195 569,849,487 $0.11 190,477,670 16,899,104 11.27 $1.21

ERCOT $40,192,064 313,395,966 $0.13 91,064,812 6,603,322 13.79 $1.77

FRCC $39,839,838 242,320,908 $0.16 110,173,004 7,923,249 13.91 $2.29

HICC $4,259,468 10,585,038 $0.40 3,200,675 407,140 7.86 $3.16

MAAC $61,918,789 294,365,234 $0.21 104,073,139 10,285,013 10.12 $2.13

MAIN $42,651,542 275,415,009 $0.15 86,988,500 8,939,201 9.73 $1.51

MAPP $29,804,875 165,189,056 $0.18 55,172,815 5,146,199 10.72 $1.93

NPCC $51,647,619 284,990,412 $0.18 95,584,731 12,557,410 7.61 $1.38

SERC $102,914,657 887,073,303 $0.12 332,332,257 22,705,585 14.64 $1.70

SPP $63,811,175 204,172,272 $0.31 68,368,566 5,439,270 12.57 $3.93

WECC $4,015,273 701,826,043 $0.01 240,757,548 26,073,156 9.23 $0.05

U.S. $502,006,495 3,960,424,805 $0.13 1,380,308,173 123,244,098 11.20 $1.42

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00

ECAR $994,314,819 569,849,487 $1.74 190,477,670 16,899,104 11.27 $19.67

ERCOT $607,506,688 313,395,966 $1.94 91,064,812 6,603,322 13.79 $26.73

FRCC $301,083,642 242,320,908 $1.24 110,173,004 7,923,249 13.91 $17.28

HICC $32,085,172 10,585,038 $3.03 3,200,675 407,140 7.86 $23.83

MAAC $555,717,454 294,365,234 $1.89 104,073,139 10,285,013 10.12 $19.10

MAIN $555,136,480 275,415,009 $2.02 86,988,500 8,939,201 9.73 $19.61

MAPP $258,612,305 165,189,056 $1.57 55,172,815 5,146,199 10.72 $16.78

NPCC $744,738,535 284,990,412 $2.61 95,584,731 12,557,410 7.61 $19.89

SERC $1,688,899,692 887,073,303 $1.90 332,332,257 22,705,585 14.64 $27.87

SPP $350,239,021 204,172,272 $1.72 68,368,566 5,439,270 12.57 $21.56

WECC $6,930,361 701,826,043 $0.01 240,757,548 26,073,156 9.23 $0.09

U.S. $6,095,264,168 3,960,424,805 $1.54 1,380,308,173 123,244,098 11.20 $17.24

Option 3: I&E Mortality Everywhere

ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00

ECAR $1,018,436,899 569,849,487 $1.79 190,477,670 16,899,104 11.27 $20.14

ERCOT $607,506,688 313,395,966 $1.94 91,064,812 6,603,322 13.79 $26.73

FRCC $307,648,969 242,320,908 $1.27 110,173,004 7,923,249 13.91 $17.65

HICC $32,085,172 10,585,038 $3.03 3,200,675 407,140 7.86 $23.83

MAAC $565,635,134 294,365,234 $1.92 104,073,139 10,285,013 10.12 $19.44

MAIN $583,584,581 275,415,009 $2.12 86,988,500 8,939,201 9.73 $20.62

MAPP $274,653,131 165,189,056 $1.66 55,172,815 5,146,199 10.72 $17.83

NPCC $791,203,354 284,990,412 $2.78 95,584,731 12,557,410 7.61 $21.13

SERC $1,735,362,189 887,073,303 $1.96 332,332,257 22,705,585 14.64 $28.63

SPP $350,239,021 204,172,272 $1.72 68,368,566 5,439,270 12.57 $21.56

WECC $8,641,891 701,826,043 $0.01 240,757,548 26,073,156 9.23 $0.11

U.S. $6,274,997,028 3,960,424,805 $1.58 1,380,308,173 123,244,098 11.20 $17.75

Option 4: IM for Facilities with DIF>50MGD

ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00

ECAR $60,212,067 569,849,487 $0.11 190,477,670 16,899,104 11.27 $1.19

ERCOT $39,723,901 313,395,966 $0.13 91,064,812 6,603,322 13.79 $1.75

FRCC $39,839,838 242,320,908 $0.16 110,173,004 7,923,249 13.91 $2.29

HICC $4,259,468 10,585,038 $0.40 3,200,675 407,140 7.86 $3.16

MAAC $57,199,454 294,365,234 $0.19 104,073,139 10,285,013 10.12 $1.97

MAIN $41,377,323 275,415,009 $0.15 86,988,500 8,939,201 9.73 $1.46

MAPP $28,983,847 165,189,056 $0.18 55,172,815 5,146,199 10.72 $1.88

NPCC $51,290,663 284,990,412 $0.18 95,584,731 12,557,410 7.61 $1.37

SERC $101,339,678 887,073,303 $0.11 332,332,257 22,705,585 14.64 $1.67

SPP $62,721,433 204,172,272 $0.31 68,368,566 5,439,270 12.57 $3.86

WECC $913,556 701,826,043 $0.00 240,757,548 26,073,156 9.23 $0.01
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 12

U.S. $487,861,228 3,960,424,805 $0.12 1,380,308,173 123,244,098 11.20 $1.38

a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers.

b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see

Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

Source: U.S. EPA analysis, 2011; U.S. DOE, 2009b; U.S. DOE, 2007c
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 13

Impact of Compliance Costs on Electricity Prices

Table 5-6: Compliance Cost per KWh of Sales by NERC Region and Regulatory Option in 2015

($2009) a

NERC Region b

Annualized Pre-Tax

Compliance Costs (at 2015;

$2009; million)

Total Electricity Sales

(at 2015; KWh)

Costs per Unit of Sales

(2009¢/KWh Sales)

Option 1: IM Everywhere

ASCC $0 6,326,610,000 0.000

ECAR $60,951,195 569,849,487,305 0.011

ERCOT $40,192,064 313,395,965,576 0.013

FRCC $39,839,838 242,320,907,593 0.016

HICC $4,259,468 10,585,038,000 0.040

MAAC $61,918,789 294,365,234,375 0.021

MAIN $42,651,542 275,415,008,545 0.015

MAPP $29,804,875 165,189,056,396 0.018

NPCC $51,647,619 284,990,412,176 0.018

SERC $102,914,657 887,073,303,223 0.012

SPP $63,811,175 204,172,271,729 0.031

WECC $4,015,273 701,826,043,025 0.001

U.S. c$502,006,495 3,960,424,804,688 0.013

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

ASCC $0 6,326,610,000 0.000

ECAR $994,314,819 569,849,487,305 0.174

ERCOT $607,506,688 313,395,965,576 0.194

FRCC $301,083,642 242,320,907,593 0.124

HICC $32,085,172 10,585,038,000 0.303

MAAC $555,717,454 294,365,234,375 0.189

MAIN $555,136,480 275,415,008,545 0.202

MAPP $258,612,305 165,189,056,396 0.157

NPCC $744,738,535 284,990,412,176 0.261

SERC $1,688,899,692 887,073,303,223 0.190

SPP $350,239,021 204,172,271,729 0.172

WECC $6,930,361 701,826,043,025 0.001

U.S. $6,095,264,168 3,960,424,804,688 0.154

Option 3: I&E Mortality Everywhere

ASCC $0 6,326,610,000 0.000

ECAR $1,018,436,899 569,849,487,305 0.179

ERCOT $607,506,688 313,395,965,576 0.194

FRCC $307,648,969 242,320,907,593 0.127

HICC $32,085,172 10,585,038,000 0.303

MAAC $565,635,134 294,365,234,375 0.192

MAIN $583,584,581 275,415,008,545 0.212

MAPP $274,653,131 165,189,056,396 0.166

NPCC $791,203,354 284,990,412,176 0.278

SERC $1,735,362,189 887,073,303,223 0.196

SPP $350,239,021 204,172,271,729 0.172

WECC $8,641,891 701,826,043,025 0.001

U.S. $6,274,997,028 3,960,424,804,688 0.158

Option 4: IM for Facilities with DIF>50MGD

ASCC $0 6,326,610,000 0.000

ECAR $60,212,067 569,849,487,305 0.011

ERCOT $39,723,901 313,395,965,576 0.013

FRCC $39,839,838 242,320,907,593 0.016

HICC $4,259,468 10,585,038,000 0.040

MAAC $57,199,454 294,365,234,375 0.019

MAIN $41,377,323 275,415,008,545 0.015

MAPP $28,983,847 165,189,056,396 0.018

NPCC $51,290,663 284,990,412,176 0.018

SERC $101,339,678 887,073,303,223 0.011

SPP $62,721,433 204,172,271,729 0.031

WECC $913,556 701,826,043,025 0.000

U.S. $487,861,228 3,960,424,804,688 0.012
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 14

a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers.

b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see

Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses.

Source: U.S. EPA analysis, 2011; U.S. DOE 2009b; U.S. DOE 2007c
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 15

Table 5-7: Projected 2015 Price (Cents per KWh of Sales) and Potential Price Increase Due to

Compliance Costs by NERC Region and Regulatory Option ($2009) a

Residential Commercial Industrial Transportation All Sector Average

NERC

Region b

Compliance

Cost

(¢/KWh)

Baseline

Price

%

Change

Baseline

Price

%

Change

Baseline

Price

%

Change

Baseline

Price

%

Change

Baseline

Price

%

Change

Option 1: IM Everywhere

ASCC 0.000 15.69 0.00% 12.59 0.00% 13.06 0.00% NA NA 13.73 0.00%

ECAR 0.011 9.83 0.11% 8.97 0.12% 6.15 0.17% 7.90 0.14% 8.21 0.13%

ERCOT 0.013 13.28 0.10% 9.37 0.14% 7.47 0.17% 10.59 0.12% 10.39 0.12%

FRCC 0.016 13.38 0.12% 11.28 0.15% 9.16 0.18% 8.94 0.18% 12.19 0.13%

HICC 0.040 24.93 0.16% 22.64 0.18% 18.99 0.21% NA NA 22.00 0.18%

MAAC 0.021 13.09 0.16% 11.35 0.19% 8.14 0.26% 11.06 0.19% 11.32 0.19%

MAIN 0.015 10.15 0.15% 8.24 0.19% 5.64 0.27% 7.52 0.21% 7.99 0.19%

MAPP 0.018 8.02 0.23% 7.45 0.24% 5.68 0.32% 6.84 0.26% 7.04 0.26%

NPCC 0.018 18.23 0.10% 14.42 0.13% 9.69 0.19% 15.84 0.11% 14.92 0.12%

SERC 0.012 9.04 0.13% 7.67 0.15% 5.56 0.21% 5.97 0.19% 7.60 0.15%

SPP 0.031 9.71 0.32% 8.25 0.38% 6.15 0.51% 7.56 0.41% 8.23 0.38%

WECC 0.001 11.37 0.01% 9.63 0.01% 7.00 0.01% 8.87 0.01% 9.64 0.01%

U.S. 0.013 11.20 0.11% 9.57 0.13% 6.46 0.20% 10.64 0.12% 9.35 0.14%

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

ASCC 0.000 15.69 0.00% 12.59 0.00% 13.06 0.00% NA NA 13.73 0.00%

ECAR 0.174 9.83 1.77% 8.97 1.95% 6.15 2.84% 7.90 2.21% 8.21 2.13%

ERCOT 0.194 13.28 1.46% 9.37 2.07% 7.47 2.59% 10.59 1.83% 10.39 1.87%

FRCC 0.124 13.38 0.93% 11.28 1.10% 9.16 1.36% 8.94 1.39% 12.19 1.02%

HICC 0.303 24.93 1.22% 22.64 1.34% 18.99 1.60% NA NA 22.00 1.38%

MAAC 0.189 13.09 1.44% 11.35 1.66% 8.14 2.32% 11.06 1.71% 11.32 1.67%

MAIN 0.202 10.15 1.99% 8.24 2.45% 5.64 3.57% 7.52 2.68% 7.99 2.52%

MAPP 0.157 8.02 1.95% 7.45 2.10% 5.68 2.76% 6.84 2.29% 7.04 2.22%

NPCC 0.261 18.23 1.43% 14.42 1.81% 9.69 2.70% 15.84 1.65% 14.92 1.75%

SERC 0.190 9.04 2.11% 7.67 2.48% 5.56 3.42% 5.97 3.19% 7.60 2.50%

SPP 0.172 9.71 1.77% 8.25 2.08% 6.15 2.79% 7.56 2.27% 8.23 2.08%

WECC 0.001 11.37 0.01% 9.63 0.01% 7.00 0.01% 8.87 0.01% 9.64 0.01%

U.S. 0.154 11.20 1.37% 9.57 1.61% 6.46 2.38% 10.64 1.45% 9.35 1.65%

Option 3: I&E Mortality Everywhere

ASCC 0.000 15.69 0.00% 12.59 0.00% 13.06 0.00% NA NA 13.73 0.00%

ECAR 0.179 9.83 1.82% 8.97 1.99% 6.15 2.91% 7.90 2.26% 8.21 2.18%

ERCOT 0.194 13.28 1.46% 9.37 2.07% 7.47 2.59% 10.59 1.83% 10.39 1.87%

FRCC 0.127 13.38 0.95% 11.28 1.13% 9.16 1.39% 8.94 1.42% 12.19 1.04%

HICC 0.303 24.93 1.22% 22.64 1.34% 18.99 1.60% NA NA 22.00 1.38%

MAAC 0.192 13.09 1.47% 11.35 1.69% 8.14 2.36% 11.06 1.74% 11.32 1.70%

MAIN 0.212 10.15 2.09% 8.24 2.57% 5.64 3.75% 7.52 2.82% 7.99 2.65%

MAPP 0.166 8.02 2.07% 7.45 2.23% 5.68 2.93% 6.84 2.43% 7.04 2.36%

NPCC 0.278 18.23 1.52% 14.42 1.92% 9.69 2.87% 15.84 1.75% 14.92 1.86%

SERC 0.196 9.04 2.16% 7.67 2.55% 5.56 3.52% 5.97 3.28% 7.60 2.57%

SPP 0.172 9.71 1.77% 8.25 2.08% 6.15 2.79% 7.56 2.27% 8.23 2.08%

WECC 0.001 11.37 0.01% 9.63 0.01% 7.00 0.02% 8.87 0.01% 9.64 0.01%

U.S. 0.158 11.20 1.41% 9.57 1.66% 6.46 2.45% 10.64 1.49% 9.35 1.69%

Option 4: IM for Facilities with DIF>50MGD

ASCC 0.000 15.69 0.00% 12.59 0.00% 13.06 0.00% NA NA 13.73 0.00%

ECAR 0.011 9.83 0.11% 8.97 0.12% 6.15 0.17% 7.90 0.13% 8.21 0.13%

ERCOT 0.013 13.28 0.10% 9.37 0.14% 7.47 0.17% 10.59 0.12% 10.39 0.12%

FRCC 0.016 13.38 0.12% 11.28 0.15% 9.16 0.18% 8.94 0.18% 12.19 0.13%

HICC 0.040 24.93 0.16% 22.64 0.18% 18.99 0.21% NA NA 22.00 0.18%

MAAC 0.019 13.09 0.15% 11.35 0.17% 8.14 0.24% 11.06 0.18% 11.32 0.17%

MAIN 0.015 10.15 0.15% 8.24 0.18% 5.64 0.27% 7.52 0.20% 7.99 0.19%

MAPP 0.018 8.02 0.22% 7.45 0.24% 5.68 0.31% 6.84 0.26% 7.04 0.25%

NPCC 0.018 18.23 0.10% 14.42 0.12% 9.69 0.19% 15.84 0.11% 14.92 0.12%

SERC 0.011 9.04 0.13% 7.67 0.15% 5.56 0.21% 5.97 0.19% 7.60 0.15%

SPP 0.031 9.71 0.32% 8.25 0.37% 6.15 0.50% 7.56 0.41% 8.23 0.37%

WECC 0.000 11.37 0.00% 9.63 0.00% 7.00 0.00% 8.87 0.00% 9.64 0.00%

U.S. 0.012 11.20 0.11% 9.57 0.13% 6.46 0.19% 10.64 0.12% 9.35 0.13%
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 16

a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers.

b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see

Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses.

Source: U.S. EPA analysis, 2011; U.S. DOE, 2009b; U.S. DOE, 2007c

Chapter 7: Assessing the Potential Impact of the Proposed Existing Facilities

Rule on Small Entities – Regulatory Flexibility Act (RFA) Analysis – Electric

Generators

Table 7-6: Unique Parent Entities and Facilities for Electric Generators (by Entity Type and Size)

Number of Parent Entitiesa,b Number of Facilities

Parent Entity Type

Small Entity Size

Standard Large Small Total Large Small Total

Parent Entities Owning at Least One Explicitly Analyzed Facility

Rural Electric Cooperative4,000 MWh output 9 2 11 11 2 13

Federal assumed large 1 0 1 7 0 7

Investor-Owned Utilities 4,000 MWh output 38 1 39 137 1 138

Municipality 50,000 population served 7 6 13 7 6 13

Nonutility 4,000 MWh output 26 3 29 73 5 82

Other Political

Subdivision 50,000 population served 1 0 1 1 0 1

State assumed large 4 0 4 8 0 8

Total 86 12 98 244 14 262

Parent Entities Owning Only Implicitly Analyzed Facilities or Owning at Least One Explicitly Analyzed Facilityc,d

Rural Electric Cooperative4,000 MWh output 12 8 20 23 8 31

Federal assumed large 1 0 1 14 0 14

Investor-Owned Utilities 4,000 MWh output 41 2 43 282 3 285

Municipality 50,000 population served 18 17 35 26 17 43

Nonutility 4,000 MWh output 32 5 37 153 8 161

Other Political

Subdivision 50,000 population served 2 1 3 7 1 8

State assumed large 4 0 4 9 0 9

Total 110 33 143 514 37 551

a. For 8 entities, EPA was unable to find entity revenue necessary to determine the size of these entities; consequently, EPA used the total

revenue for all facilities owned by these entities to determine entity size.

b. In three instances, a facility is owned by a joint venture of two entities.

c. 548 facilities include (1) explicitly analyzed facilities and (2) implicitly analyzed facilities that responded to the 316(b) 2000 Surveys. For a

discussion of explicitly and implicitly analyzed facilities refer to Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule

Analyses.

d. These counts are unweighted and reflect the known universe of facilities and their parent entities expected to be in scope of Proposed Existing

Facilities Rule.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 17

Table 7-7: Number of Small Electric Generators Parent Entities (Industry Total and Entities

with In-Scope Facilities)

Small Entities Owning In-Scope Facilities

Parent Entity Type Total Small Entitiesa

Numberb

Percentage of Total Small

Entities

Rural Electric Cooperative 848 8 0.94%

Federal 0 0 0.00%

Investor-Owned Utilities 18 2 10.87%

Municipality 968 17 1.76%

Nonutility 131 5 3.81%

Other Political Subdivision 113 1 0.88%

State 0 0 0.00%

All Entity Types 2,078 33 1.59%

a. Form EIA-861 does not provide data on nonutilities. The reported number of total small nonutilities is the total of non-regulated

operators from the 2007 EIA-860 database; the number of small parent entities owning 316(b) facilities for non-regulated operators

was determined using the 2007 EIA-906/920/923 database. State and federal entities are considered large.

b. Entity counts include entities owning explicitly and implicitly analyzed facilities and are not weighted estimates. For a discussion on

explicitly and implicitly owned facilities see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses.

c. Industry non-regulated operators with no electricity sales/generation data were excluded from this analysis.

Source: U.S. EPA analysis, 2011; U.S. DOE, 2007b; U.S. DOE, 2007c; U.S. DOE, 2007d

Table 7-8: Estimated Cost-to-Revenue Impact on Small Electric Generators

Entities, by Entity Type – Using Facility-Level Weightsa

Cost Impact Category

Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Typeb

Number of

Small

Entities

% of All

Small

Entities

Number of

Small

Entities

% of All

Small

Entities

Option 1: IM Everywhere

Rural Electric Cooperative 1 12.5% 1 12.5%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 2 11.8% 0 0.0%

Nonutility 1 20.0% 1 20.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 4 12.1% 2 6.1%

Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD

Rural Electric Cooperative 1 12.5% 1 12.5%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 2 11.8% 0 0.0%

Nonutility 1 20.0% 1 20.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 4 12.1% 2 6.1%

Option 3: I&E Mortality Everywhere

Rural Electric Cooperative 2 25.0% 1 12.5%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 6 35.3% 4 23.5%

Nonutility 1 20.0% 1 20.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 9 27.3% 6 18.2%

Option 4: IM for Facilities with DIF>50MGD

Rural Electric Cooperative 1 12.5% 1 12.5%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 2 11.8% 0 0.0%

Nonutility 1 20.0% 1 20.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 4 12.1% 2 6.1%

a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with

such ratios exceeding 1 percent.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 18

Table 7-9: Estimated Cost-to-Revenue Impact on Small Electric Generators

Entities, by Entity Type – Using Entity-Level Weightsa

Cost Impact Category

Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Typeb

Number of

Small

Entities

% of All

Small

Entities

Number of

Small

Entities

% of All

Small

Entities

Option 1: IM Everywhere

Rural Electric Cooperative 4 50.0% 0 0.0%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 0 0.0% 0 0.0%

Nonutility 2 40.0% 2 40.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 6 18.2% 2 6.1%

Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD

Rural Electric Cooperative 4 50.0% 4 50.0%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 0 0.0% 0 0.0%

Nonutility 2 40.0% 2 40.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 6 18.2% 6 18.2%

Option 3: I&E Mortality Everywhere

Rural Electric Cooperative 8 100.0% 4 50.0%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 11 64.7% 9 52.9%

Nonutility 2 40.0% 2 40.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 21 63.6% 14 42.4%

Option 4: IM for Facilities with DIF>50MGD

Rural Electric Cooperative 4 50.0% 0 0.0%

Investor-Owner Utility 0 0.0% 0 0.0%

Municipality 0 0.0% 0 0.0%

Nonutility 2 40.0% 2 40.0%

Other Political Subdivision 0 0.0% 0 0.0%

Total 6 18.2% 2 6.1%

a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with

such ratios exceeding 1 percent.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 19

Table 7-10: Estimated Cost-to-Revenue Impact on Small Entities – Comparing

Findings from the Facility-Level Weights and Entity-Level Weights Analysesa

Cost Impact Category

Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Type

Number of

Small

Entities

% of All

Small

Entities

Number of

Small

Entities

% of All

Small

Entities

Using Facility-Level Weights

Option 1: IM Everywhere 4 12.1% 2 6.1%

Option 2: IM Everywhere and EM for

Facilities with DIF>125 MGD 4 12.1% 2 6.1%

Option 3: I&E Mortality Everywhere 9 27.3% 6 18.2%

Option 4: IM for Facilities with

DIF>50MGD 4 12.1% 2 6.1%

Using Entity-Level Weights

Option 1: IM Everywhere 6 18.2% 2 6.1%

Option 2: IM Everywhere and EM for

Facilities with DIF>125 MGD 6 18.2% 6 18.2%

Option 3: I&E Mortality Everywhere 21 63.6% 14 42.4%

Option 4: IM for Facilities with

DIF>50MGD 6 18.2% 2 6.1%

a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with

such ratios exceeding 1 percent.

Source: U.S. EPA analysis, 2011

Chapter 8: Unfunded Mandates Reform Act (UMRA)

Table 8-1: Government-Owned Electric Generators and Their Parent

Entities

Entity Type Parent Entitiesa Electric Generatorsb

Municipality 35 43

State 4 9

Other Political Subdivision 3 8

Total 42 60

a. Counts of entities owning explicitly and implicitly analyzed Electric Generators; these are not weighted entity

counts.

b. Counts of explicitly and implicitly analyzed Electric Generators; these are not weighted estimates.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 20

Table 8-2: Compliance Costs to Government-Owned Electric Generators (Millions;

$2009)

Ownership Type

Number of In-scope

Facilities (weighted)

a

Total Weighted,

Annualized Pretax Compliance

Cost

Average Annual

Compliance Cost

(per facility)

Maximum

Annualized Facility

Compliance Costb

Option 1: IM Everywhere

Municipality 25 $4.6 $0.2 $0.5

State 17 $6.1 $0.4 $1.0

Other Political Subdivision 2 $3.2 $1.5 $1.4

Total 44 $13.9 $0.3 $1.4

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Municipality 25 $29.6 $1.2 $5.6

State 17 $72.8 $4.3 $17.9

Other Political Subdivision 2 $21.7 $10.0 $9.3

Total 44 $124.1 $2.8 $17.9

Option 3: I&E Mortality Everywhere

Municipality 25 $42.2 $1.7 $5.6

State 17 $78.0 $4.6 $17.9

Other Political Subdivision 2 $21.7 $10.0 $9.3

Total 44 $141.9 $3.3 $17.9

Option 4: IM for Facilities with DIF>50MGD

Municipality 25 $3.8 $0.2 $0.5

State 17 $5.7 $0.3 $1.0

Other Political Subdivision 2 $3.2 $1.5 $1.4

Total 44 $12.7 $0.3 $1.4

a. Facility counts are weighted estimates and differ from the values reported in Table 8-1 and Table 8-4, which are un-weighted

values. This table presents sample weighted facility counts because costs were developed only for the explicitly analyzed Electric

Generators facilities. See Appendix A.3: Used of Sample Weights in the Proposed Existing Facilities Rule Analysis for discussion

on explicitly and implicitly analyzed facilities and facility sample weights.

b. Reflects maximum of un-weighted costs to explicitly analyzed facilities only.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 21

Table 8-3: Annualized Government Administrative Costs (Millions; $2009)

Activity

Annualized Cost,

Electric Generators

Annualized Cost,

Manufacturers Total Annualized Cost

Option 1: IM Everywhere

Start-Up Activities $0.02 $0.02 $0.04

First Permit Issuance Activities $0.23 $0.24 $0.47

Annual Monitoring Activities $1.18 $1.12 $2.30

Entrainment Study $1.20 $0.97 $2.17

Permit Reissuance Activities $0.18 $0.18 $0.36

Total $2.82 $2.52 $5.34

Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD

Start-Up Activities $0.02 $0.02 $0.04

First Permit Issuance Activities $0.17 $0.23 $0.40

Annual Monitoring Activities $0.36 $1.07 $1.43

Entrainment Study $0.00 $0.00 $0.00

Permit Reissuance Activities $0.14 $0.17 $0.31

Total $0.69 $1.48 $2.17

Option 3: IM&EM Everywhere

Start-Up Activities $0.02 $0.02 $0.04

First Permit Issuance Activities $0.16 $0.13 $0.29

Annual Monitoring Activities $0.20 $0.52 $0.72

Entrainment Study $0.00 $0.00 $0.00

Permit Reissuance Activities $0.13 $0.10 $0.23

Total $0.51 $0.77 $1.28

Option 4: IM for Facilities with DIF>50MGD

Start-Up Activities $0.02 $0.02 $0.04

First Permit Issuance Activities $0.23 $0.06 $0.29

Annual Monitoring Activities $1.05 $0.31 $1.36

Entrainment Study $1.20 $0.97 $2.17

Permit Reissuance Activities $0.18 $0.05 $0.23

Total $2.68 $1.41 $4.09

a. These costs reflect the assumption that all facilities will comply in one year, and were discounted accordingly because

individual components of costs were not distributed over the 5-year compliance window, as described in Chapter 11, Section

1.

Source: U.S. EPA analysis, 2011

Table 8-4: Government-Owned Electric Generators and Their Parent Entities, by Size

Entitiesa Electric Generatorsb

Entity Type Large Small Total Large Small Total

Municipality 18 17 35 26 17 43

State 4 0 4 9 0 9

Other Political

Subdivision 2 1 3 7 1 7

Total 24 18 42 42 18 60

a. Counts of entities owning explicitly and implicitly analyzed Electric Generators; these are not weighted entity counts.

b. Counts of explicitly and implicitly analyzed Electric Generators; these are not weighted estimates.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 22

Table 8-5: Compliance Costs for Electric Generators by Ownership Type and Size (Millions;

$2009)

Ownership Type

Entity

Size

Number of

Facilities

(weighted)a

Total Annualized PreTax Compliance Costs

Average Annualized

Pre-tax Compliance

Cost per Facility

Maximum Facility

Annualized Pre-tax

Compliance Costc

Option 1: IM Everywhere

Government (excludingSmall 10 $1.5 $0.1 $0.2

Federal) Large 33 $12.4 $0.4 $1.4

Small 16 $7.5 $0.5 $2.6 Private Large 486 $354.6 $0.7 $7.4

All Facilitiesb

562 $398.2 $0.7 $7.4

Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD

Government (excludingSmall 10 $1.5 $0.1 $0.2

Federal) Large 33 $122.6 $3.7 $17.9

Small 16 $30.5 $1.9 $10.7 Private Large 486 $4,177.2 $8.6 $58.1

All Facilitiesb

562 $4,851.4 $8.6 $58.1

Option 3: I&E Mortality Everywhere

Government (excluding Small 10 $12.5 $1.2 $2.1

Federal) Large 33 $129.4 $3.9 $17.9

Small 16 $32.2 $2.1 $10.7 Private Large 486 $4,306.6 $8.9 $58.1

All Facilitiesb

562 $5,000.2 $8.9 $58.1

Option 4: IM for Facilities with DIF>50MGD

Government (excludingSmall 10 $1.4 $0.1 $0.2

Federal) Large 33 $11.2 $0.3 $1.4

Small 16 $5.8 $0.4 $2.6 Private Large 486 $346.3 $0.7 $7.4

All Facilitiesb

562 $387.0 $0.7 $7.4

a. Facility counts are weighted estimates and differ from the values reported in Table 8-1 and Table 8-4, which are un-weighted values. This

table presents sample weighted facility counts because costs were developed only for the explicitly analyzed Electric Generators facilities.

See Appendix A.3: Used of Sample Weights in the Proposed Existing Facilities Rule Analysis for discussion on explicitly and implicitly

analyzed facilities and facility sample weights.

b. Facility counts and cost estimates reported for All Facilities include 17 federal government-owned facilities and costs estimated for these

facilities.

c. Reflects maximum of un-weighted costs to explicitly analyzed facilities only.

Source: U.S. EPA analysis, 2011
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 23

Table 8-6: Summary of UMRA Costs (Millions; $2009)

Total Annualized Cost Maximum One-Year Cost

Sector Incurring

Costs

Facility

Compliance

Costsa

Government

Administrative

Costsb Total

Facility

Compliance

Costs

Government

Administrative

Costs Total

Option 1: IM Everywhere

Electric Generators

Government

(excluding Federal) $13.9 $2.5 $16.5 $25.2 $4.1 $29.3

Private $362.1 N/A $362.1 $755.8 N/A $755.8

Manufacturers

Government

(excluding Federal) $0.0 $1.2 $1.2 $0.0 $1.6 $1.6

Private $65.3 N/A $65.3 $371.3 N/A $371.3

Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD

Electric Generators

Government

(excluding Federal) $124.1 $0.6 $124.7 $334.8 $0.8 $335.6

Private $4,207.7 N/A $4,207.7 $10,736.3 N/A $10,736.3

Manufacturers

Government

(excluding Federal) $0.0 $1.1 $1.1 $0.0 $1.4 $1.4

Private $139.3 N/A $139.3 $832.5 N/A $832.5

Option 3: I&E Mortality Everywhere

Electric Generators

Government

(excluding Federal) $141.9 $0.4 $142.4 $388.9 $0.7 $389.6

Private $4,338.7 N/A $4,338.7 $11,113.4 N/A $11,113.4

Manufacturers

Government

(excluding Federal) $0.0 $0.4 $0.4 $0.0 $1.0 $1.0

Private $164.8 N/A $164.8 $1,438.8 N/A $1,438.8

Option 4: IM for Facilities with DIF>50MGD

Electric Generators

Government

(excluding Federal) $12.7 $2.4 $15.1 $23.9 $4.0 $27.8

Private $352.2 N/A $352.2 $734.0 N/A $734.0

Manufacturers

Government

(excluding Federal) $0.00 $0.8 $0.8 $0.0 $2.5 $2.5

Private $34.8 N/A $34.8 $239.7 N/A $239.7

a. Cost values for Electric Generators are lower than those presented in Table 8-5 because they reflect a distribution over the compliance window, as

described in Chapter 11: Assessment of Total Social Costs, thus changing the amount discounted in each year.

b. These values are slightly lower than those presented in Table 8-3 because they reflect a distribution over the compliance window, as described in

Chapter 11: Assessment of Total Social Costs, thus changing the amount discounted in each year.

Source: U.S. EPA analysis, 2011

Chapter 11: Assessment of Total Social Costs

Table 11-1: Summary of Annualized Costs of Compliance (Millions; $2009)

Discount

Rate Option 1: IM Everywhere

Option 2: IM Everywhere

and EM for Facilities with

DIF > 125 MGD

Option 3: I&E Mortality

Everywhere

Option 4: IM for Facilities

with DIF>50MGD

3% $365.56 $4,491.89 $4,659.23 $330.80

7% $428.42 $4,726.87 $4,886.61 $389.66

Source: U.S. EPA analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 24

Table 11-2: Summary of Annualized Government Administrative Costs (Millions; $2009)

Discount

Rate

Government

Level

Option 1: IM

Everywhere

Option 2: IM

Everywhere and EM

for Facilities with

DIF > 125 MGD

Option 3: I&E

Mortality

Everywhere

Option 4: IM for Facilities

with DIF>50MGD

State/Territory $3.70 $1.59 $0.89 $2.79

3% Federal $0.03 $0.03 $0.03 $0.02

Totala

$3.73 $1.62 $0.92 $2.79

State/Territory $4.20 $1.68 $0.87 $3.24

7% Federal $0.06 $0.05 $0.04 $0.04

Totala

$4.26 $1.73 $0.91 $3.26

a. Values may not sum to the reported total to due independent rounding.

Source: U.S. EPA Analysis, 2011.

Table 11-3: Summary of Total Social Costs (Millions; $2009)

Discount

Rate Cost Category

Option 1: IM

Everywhere

Option 2: IM

Everywhere and EM for

Facilities with DIF > 125

MGD

Option 3: I&E

Mortality Everywhere

Option 4: IM for

Facilities with

DIF>50MGD

Compliance Cost $365. 56 $4,491.89 $4,659.23 $330.80

3% Gov. Admin. $3.73 $1.62 $0.92 $2.81

Totala

$369.29 $4,493.51 $4,660.14 $333.61

Compliance Cost $428.42 $4,726.87 $4,886.61 $389.66

7% Gov. Admin. $4.26 $1.73 $0.91 $3.28

Totala

$432.67 $4,728.60 $4,887.52 $392.94

a. Values may not sum to the reported total to due independent rounding.

Source: U.S. EPA Analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 25

Table 11-4: Time Profile of Costs to Society for Option 1: IM

Everywhere (Millions; $2009)

Year Compliance Costs

Administrative

Costs Total

2012 $7.51 $0.48 $7.99

2013 $704.24 $4.54 $708.78

2014 $763.27 $7.13 $770.40

2015 $811.42 $7.63 $819.05

2016 $681.21 $5.35 $686.56

2017 $703.08 $3.66 $706.74

2018 $374.22 $5.34 $379.56

2019 $216.12 $4.76 $220.88

2020 $203.69 $2.63 $206.32

2021 $374.22 $5.34 $379.56

2022 $216.12 $2.63 $218.75

2023 $203.69 $2.63 $206.32

2024 $374.22 $5.34 $379.56

2025 $216.12 $2.63 $218.75

2026 $203.69 $2.63 $206.32

2027 $374.22 $5.34 $379.56

2028 $216.12 $2.63 $218.75

2029 $203.69 $2.63 $206.32

2030 $374.22 $5.34 $379.56

2031 $216.12 $2.63 $218.75

2032 $203.69 $2.63 $206.32

2033 $690.72 $5.34 $696.06

2034 $532.61 $2.63 $535.24

2035 $520.19 $2.63 $522.82

2036 $690.72 $5.34 $696.06

2037 $532.61 $2.63 $535.24

2038 $268.76 $2.63 $271.39

2039 $439.29 $5.34 $444.63

2040 $281.18 $2.63 $283.81

2041 $268.76 $2.63 $271.39

2042 $439.29 $5.34 $444.63

2043 $220.61 $2.63 $223.23

2044 $208.18 $2.63 $210.81

2045 $378.71 $5.34 $384.05

2046 $220.61 $2.63 $223.23

2047 $208.18 $2.63 $210.81

2048 $374.22 $5.34 $379.56

2049 $216.12 $2.63 $218.75

2050 $203.69 $2.63 $206.32

2051 $374.22 $5.34 $379.56

2052 $214.49 $2.63 $217.12

2053 $160.24 $1.73 $161.97

2054 $177.02 $2.20 $179.23

2055 $80.12 $0.87 $80.99

2056 $40.06 $0.43 $40.49

2057 $0.00 $0.00 $0.00

2058 $0.00 $0.00 $0.00

2059 $0.00 $0.00 $0.00

2060 $0.00 $0.00 $0.00

2061 $0.00 $0.00 $0.00

2062 $0.00 $0.00 $0.00

Present Value,

3% $9,405.79 $95.97 $9,501.76

Annualized, 3% $365.56 $3.73 $369.29

Present Value,

7% $5,912.48 $58.73 $5,971.21

Annualized, 7% $428.42 $4.26 $432.67

Source: U.S. EPA analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 26

Table 11-5: Time Profile of Costs to Society for Option 2: IM

Everywhere and EM for Facilities with DIF > 125 MGD (Millions;

$2009)

Year Compliance Costs

Administrative

Costs Total

2012 $4.55 $0.48 $5.03

2013 $79.20 $1.12 $80.32

2014 $89.51 $1.36 $90.87

2015 $100.05 $1.62 $101.67

2016 $109.69 $1.86 $111.55

2017 $4,641.02 $2.10 $4,643.12

2018 $9,919.51 $1.90 $9,921.41

2019 $10,390.33 $1.91 $10,392.24

2020 $10,863.61 $1.91 $10,865.52

2021 $11,325.03 $1.92 $11,326.94

2022 $9,006.20 $1.92 $9,008.12

2023 $6,271.58 $1.77 $6,273.35

2024 $6,588.28 $1.79 $6,590.07

2025 $6,921.82 $1.80 $6,923.62

2026 $7,254.60 $1.82 $7,256.41

2027 $5,855.96 $1.83 $5,857.79

2028 $4,025.95 $1.75 $4,027.69

2029 $4,052.98 $1.75 $4,054.72

2030 $4,083.69 $1.75 $4,085.44

2031 $4,083.69 $1.75 $4,085.44

2032 $4,083.69 $1.75 $4,085.44

2033 $4,117.74 $1.75 $4,119.49

2034 $4,117.74 $1.75 $4,119.49

2035 $4,117.74 $1.75 $4,119.49

2036 $4,117.74 $1.75 $4,119.49

2037 $4,117.74 $1.75 $4,119.49

2038 $4,096.70 $1.75 $4,098.44

2039 $4,096.70 $1.75 $4,098.44

2040 $4,096.70 $1.75 $4,098.44

2041 $4,096.70 $1.75 $4,098.44

2042 $4,096.70 $1.75 $4,098.44

2043 $4,095.50 $1.75 $4,097.25

2044 $4,095.50 $1.75 $4,097.25

2045 $4,095.50 $1.75 $4,097.25

2046 $4,095.50 $1.75 $4,097.25

2047 $4,095.50 $1.75 $4,097.25

2048 $4,084.05 $1.75 $4,085.80

2049 $4,084.05 $1.75 $4,085.80

2050 $4,084.05 $1.75 $4,085.80

2051 $4,084.05 $1.75 $4,085.80

2052 $4,082.43 $1.75 $4,084.17

2053 $3,264.24 $1.04 $3,265.28

2054 $2,448.18 $0.78 $2,448.96

2055 $1,632.12 $0.52 $1,632.64

2056 $816.06 $0.26 $816.32

2057 $0.00 $0.00 $0.00

2058 $0.00 $0.00 $0.00

2059 $0.00 $0.00 $0.00

2060 $0.00 $0.00 $0.00

2061 $0.00 $0.00 $0.00

2062 $0.00 $0.00 $0.00

Present Value,

3% $115,575.27 $41.74 $115,617.01

Annualized, 3% $4,491.89 $1.62 $4,493.51

Present Value,

7% $65,234.38 $23.81 $65,258.19

Annualized, 7% $4,726.87 $1.73 $4,728.60

Source: U.S. EPA analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 27

Table 11-6: Time Profile of Costs to Society for Option 3: I&E

Mortality Everywhere (Millions; $2009)

Year Compliance Costs Administrative Costs Total

2012 $1.31 $0.48 $1.79

2013 $24.92 $0.31 $25.23

2014 $27.62 $0.38 $27.99

2015 $30.39 $0.44 $30.84

2016 $32.92 $0.50 $33.42

2017 $4,674.24 $0.56 $4,674.80

2018 $10,172.29 $0.91 $10,173.20

2019 $10,672.51 $0.92 $10,673.43

2020 $11,175.32 $0.92 $11,176.25

2021 $11,665.38 $0.93 $11,666.31

2022 $9,369.53 $0.93 $9,370.47

2023 $6,615.72 $1.24 $6,616.96

2024 $6,946.90 $1.31 $6,948.21

2025 $7,295.40 $1.38 $7,296.78

2026 $7,642.72 $1.45 $7,644.18

2027 $6,151.12 $1.52 $6,152.64

2028 $4,208.79 $1.11 $4,209.90

2029 $4,237.03 $1.11 $4,238.14

2030 $4,269.12 $1.11 $4,270.22

2031 $4,269.12 $1.11 $4,270.22

2032 $4,269.12 $1.11 $4,270.22

2033 $4,278.38 $1.11 $4,279.49

2034 $4,278.38 $1.11 $4,279.49

2035 $4,278.38 $1.11 $4,279.49

2036 $4,278.38 $1.11 $4,279.49

2037 $4,278.38 $1.11 $4,279.49

2038 $4,275.67 $1.11 $4,276.78

2039 $4,275.67 $1.11 $4,276.78

2040 $4,275.67 $1.11 $4,276.78

2041 $4,275.67 $1.11 $4,276.78

2042 $4,275.67 $1.11 $4,276.78

2043 $4,282.97 $1.11 $4,284.08

2044 $4,282.97 $1.11 $4,284.08

2045 $4,282.97 $1.11 $4,284.08

2046 $4,282.97 $1.11 $4,284.08

2047 $4,282.97 $1.11 $4,284.08

2048 $4,269.48 $1.11 $4,270.59

2049 $4,269.48 $1.11 $4,270.59

2050 $4,269.48 $1.11 $4,270.59

2051 $4,269.48 $1.11 $4,270.59

2052 $4,267.85 $1.11 $4,268.96

2053 $3,412.58 $0.55 $3,413.13

2054 $2,559.43 $0.41 $2,559.84

2055 $1,706.29 $0.27 $1,706.56

2056 $853.14 $0.14 $853.28

2057 $0.00 $0.00 $0.00

2058 $0.00 $0.00 $0.00

2059 $0.00 $0.00 $0.00

2060 $0.00 $0.00 $0.00

2061 $0.00 $0.00 $0.00

2062 $0.00 $0.00 $0.00

Present Value, 3% $119,880.81 $23.60 $119,904.41

Annualized, 3% $4,659.23 $0.92 $4,660.14

Present Value, 7% $67,438.81 $12.56 $67,451.37

Annualized, 7% $4,886.61 $0.91 $4,887.52

Source: U.S. EPA analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 28

Table 11-4: Time Profile of Costs to Society for Option 4: IM

for Facilities with DIF>50MGD (Millions; $2009)

Year Compliance Costs

Administrative

Costs Total

2012 $4.88 $0.48 $5.35

2013 $661.00 $3.86 $664.86

2014 $713.76 $6.27 $720.03

2015 $755.47 $6.60 $762.08

2016 $619.30 $4.15 $623.45

2017 $636.72 $2.29 $639.00

2018 $343.27 $4.34 $347.61

2019 $185.17 $3.75 $188.92

2020 $172.74 $1.62 $174.37

2021 $343.27 $4.34 $347.61

2022 $185.17 $1.62 $186.79

2023 $172.74 $1.62 $174.37

2024 $343.27 $4.34 $347.61

2025 $185.17 $1.62 $186.79

2026 $172.74 $1.62 $174.37

2027 $343.27 $4.34 $347.61

2028 $185.17 $1.62 $186.79

2029 $172.74 $1.62 $174.37

2030 $343.27 $4.34 $347.61

2031 $185.17 $1.62 $186.79

2032 $172.74 $1.62 $174.37

2033 $646.06 $4.34 $650.40

2034 $487.96 $1.62 $489.58

2035 $475.53 $1.62 $477.16

2036 $646.06 $4.34 $650.40

2037 $487.96 $1.62 $489.58

2038 $233.01 $1.62 $234.64

2039 $403.54 $4.34 $407.88

2040 $245.44 $1.62 $247.06

2041 $233.01 $1.62 $234.64

2042 $403.54 $4.34 $407.88

2043 $187.64 $1.62 $189.26

2044 $175.22 $1.62 $176.84

2045 $345.74 $4.34 $350.08

2046 $187.64 $1.62 $189.26

2047 $175.22 $1.62 $176.84

2048 $343.27 $4.34 $347.61

2049 $185.17 $1.62 $186.79

2050 $172.74 $1.62 $174.37

2051 $343.27 $4.34 $347.61

2052 $184.73 $1.62 $186.35

2053 $136.43 $1.06 $137.49

2054 $159.17 $1.70 $160.87

2055 $68.22 $0.53 $68.75

2056 $34.11 $0.27 $34.37

2057 $0.00 $0.00 $0.00

2058 $0.00 $0.00 $0.00

2059 $0.00 $0.00 $0.00

2060 $0.00 $0.00 $0.00

2061 $0.00 $0.00 $0.00

2062 $0.00 $0.00 $0.00

Present Value,

3% $8,511.51 $72.23 $8,583.74

Annualized, 3% $330.80 $2.81 $333.61

Present Value,

7% $5,377.63 $45.25 $5,422.89

Annualized, 7% $389.66 $3.28 $392.94

Source: U.S. EPA analysis, 2011.
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 29

Table 11-7: Annualized Costs of

Compliance for New Generating

Units (Millions; $2009)

Discount

Rate Annualized Costs

3% $20.69

7% $15.45

Source: U.S. EPA analysis, 2011.

Chapter 12: Social Costs and Benefits of the Proposed Rule

Table 12-2: Total Benefits and Social Costs by Option (Millions; $2009)

Total Monetized Benefitsa Total Social Costsb

Option 3% 7% 3% 7%

Option 1 $17.63 $16.04 $369.29 $432.67

Option 2 $120.79 $92.20 $4,493.51 $4,728.60

Option 3 $125.65 $95.71 $4,660.14 $4,887.52

Option 4 $17.33 $15.76 $333.61 $392.94

a. The benefit values presented in this table are the estimated “mean” values. Additional “low” and “high”

value estimates are presented in Chapter 11 of the EEBA.

b. Total Social Costs include compliance costs to facilities and government administrative costs.

Source: U.S. EPA analysis, 2011.

Table 12-3: Time Profile of Benefits and Social Costs (Millions; $2009)

Option 1 Option 2 Option 3 Option 4

Year

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

2012 $0.00 $7.99 $0.00 $5.03 $0.00 $1.79 $0.00 $5.35

2013 $0.48 $708.78 $0.03 $80.32 $0.01 $25.23 $0.48 $664.86

2014 $1.39 $770.40 $0.09 $90.87 $0.02 $27.99 $1.37 $720.03

2015 $4.55 $819.05 $0.29 $101.67 $0.08 $30.84 $4.47 $762.08

2016 $8.40 $686.56 $0.52 $111.55 $0.14 $33.42 $8.25 $623.45

2017 $12.48 $706.74 $0.76 $4,643.12 $0.21 $4,674.80 $12.26 $639.00

2018 $16.29 $379.56 $17.25 $9,921.41 $17.21 $10,173.20 $16.00 $347.61

2019 $19.70 $220.88 $34.67 $10,392.24 $35.19 $10,673.43 $19.35 $188.92

2020 $20.86 $206.32 $56.26 $10,865.52 $57.56 $11,176.25 $20.49 $174.37

2021 $21.33 $379.56 $80.22 $11,326.94 $82.40 $11,666.31 $20.96 $347.61

2022 $21.57 $218.75 $104.80 $9,008.12 $107.88 $9,370.47 $21.19 $186.79

2023 $21.59 $206.32 $119.08 $6,273.35 $122.82 $6,616.96 $21.22 $174.37

2024 $21.59 $379.56 $133.20 $6,590.07 $137.63 $6,948.21 $21.22 $347.61

2025 $21.59 $218.75 $144.72 $6,923.62 $149.94 $7,296.78 $21.22 $186.79

2026 $21.59 $206.32 $156.68 $7,256.41 $162.72 $7,644.18 $21.22 $174.37

2027 $21.59 $379.56 $168.55 $5,857.79 $175.43 $6,152.64 $21.22 $347.61

2028 $21.59 $218.75 $174.76 $4,027.69 $182.09 $4,209.90 $21.22 $186.79

2029 $21.59 $206.32 $180.39 $4,054.72 $188.12 $4,238.14 $21.22 $174.37

2030 $21.59 $379.56 $184.33 $4,085.44 $192.23 $4,270.22 $21.22 $347.61

2031 $21.59 $218.75 $185.42 $4,085.44 $193.38 $4,270.22 $21.22 $186.79

2032 $21.59 $206.32 $185.96 $4,085.44 $193.95 $4,270.22 $21.22 $174.37

2033 $21.59 $696.06 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $650.40

2034 $21.59 $535.24 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $489.58

2035 $21.59 $522.82 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $477.16

2036 $21.59 $696.06 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $650.40

2037 $21.59 $535.24 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $489.58

2038 $21.59 $271.39 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $234.64

2039 $21.59 $444.63 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $407.88

2040 $21.59 $283.81 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $247.06

2041 $21.59 $271.39 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $234.64

2042 $21.59 $444.63 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $407.88

2043 $21.59 $223.23 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $189.26
Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 30

Table 12-3: Time Profile of Benefits and Social Costs (Millions; $2009)

Option 1 Option 2 Option 3 Option 4

Year

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

Monetized

Benefits

Total Social

Costs

2044 $21.59 $210.81 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $176.84

2045 $21.59 $384.05 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $350.08

2046 $21.59 $223.23 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $189.26

2047 $21.59 $210.81 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $176.84

2048 $21.59 $379.56 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $347.61

2049 $21.59 $218.75 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $186.79

2050 $21.59 $206.32 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $174.37

2051 $21.59 $379.56 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $347.61

2052 $21.59 $217.12 $186.18 $4,084.17 $194.18 $4,268.96 $21.22 $186.35

2053 $21.59 $161.97 $186.18 $3,265.28 $194.18 $3,413.13 $21.22 $137.49

2054 $21.59 $179.23 $186.18 $2,448.96 $194.18 $2,559.84 $21.22 $160.87

2055 $21.59 $80.99 $186.18 $1,632.64 $194.18 $1,706.56 $21.22 $68.75

2056 $21.59 $40.49 $186.18 $816.32 $194.18 $853.28 $21.22 $34.37

2057 $19.39 $0.00 $160.24 $0.00 $167.09 $0.00 $19.06 $0.00

2058 $17.20 $0.00 $135.35 $0.00 $141.09 $0.00 $16.90 $0.00

2059 $4.49 $0.00 $68.61 $0.00 $71.71 $0.00 $4.42 $0.00

2060 $2.29 $0.00 $42.67 $0.00 $44.62 $0.00 $2.26 $0.00

2061 $1.15 $0.00 $21.86 $0.00 $22.86 $0.00 $1.13 $0.00

2062 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

PV 3% $453.68 $9,501.76 $3,108.23 $115,617.01 $3,232.89 $119,904.41 $445.83 $8,583.74

Annualized at 3% $17.63 $369.29 $120.79 $4,493.51 $125.65 $4,660.14 $17.33 $333.61

PV 7% $221.34 $5,971.21 $1,272.59 $65,258.19 $1,320.89 $67,451.37 $217.50 $5,422.89

Annualized at 7% $16.04 $432.67 $92.20 $4,728.60 $95.71 $4,887.52 $15.76 $392.94

Source: U.S. EPA analysis, 2011