afdust
                                      397
                                      63
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                       9
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      41
                                       5
                                       -
                                       -
                                       -
                                       -
                                       -
Grant County, WA
Kittitas County, WA
Okanogan County, WA
Yakima County, WA
                                    afdust
                                     3,242
                                      169
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      78
                                      13
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptagfire
                                      264
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      68
                                      43
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      109
                                      10
                                       -
                                       -
                                       -
                                       -
                                       -

Kittitas County, WA
Yakima County, WA
                                    afdust
                                      472
                                      47
                                      47
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      51
                                       8
                                       8
                                       -
                                       -
                                       -
                                       -

                                   ptagfire
                                       9
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      113
                                      13
                                      13
                                       -
                                       -
                                       -
                                       -
Klickitat County, WA
Yakima County, WA
                                    afdust
                                      568
                                      54
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      20
                                       1
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptagfire
                                      14
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      44
                                       8
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      55
                                       6
                                       -
                                       -
                                       -
                                       -
                                       -
Lewis County, WA
Yakima County, WA
                                    afdust
                                      550
                                      65
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      82
                                      15
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      94
                                      20
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      226
                                      24
                                       -
                                       -
                                       -
                                       -
                                       -
Lincoln County, WA
Okanogan County, WA
                                    afdust
                                     2,537
                                      130
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      10
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptagfire
                                      40
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      26
                                       3
                                       -
                                       -
                                       -
                                       -
                                       -
Okanogan County, WA
-
                                    afdust
                                      771
                                      113
                                       -
                                       -
                                      113
                                       -
                                       -

                                     nonpt
                                      42
                                       9
                                       -
                                       -
                                       9
                                       -
                                       -

                                   ptagfire
                                      12
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      154
                                      17
                                       -
                                       -
                                      17
                                       -
                                       -
Pierce County, WA
Kittitas County, WA
Yakima County, WA
                                    afdust
                                     1,540
                                       7
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      574
                                      103
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      200
                                      99
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                     1,047
                                      93
                                       -
                                       -
                                       -
                                       -
                                       -
Skagit County, WA
Okanogan County, WA
                                    afdust
                                      626
                                      67
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      131
                                      24
                                       -
                                       -
                                       -
                                       -
                                       -

                                   pt_oilgas
                                       6
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      252
                                      137
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      237
                                      26
                                       -
                                       -
                                       -
                                       -
                                       -
Skamania County, WA
Yakima County, WA
                                    afdust
                                      122
                                      18
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                       8
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      57
                                       6
                                       -
                                       -
                                       -
                                       -
                                       -

Whatcom County, WA
Okanogan County, WA
                                    afdust
                                      874
                                      69
                                       -
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      227
                                      48
                                       -
                                       -
                                       -
                                       -
                                       -

                                   pt_oilgas
                                       8
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      851
                                      762
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      365
                                      35
                                       -
                                       -
                                       -
                                       -
                                       -
Yakima County, WA
Kittitas County, WA
                                    afdust
                                     1,845
                                      100
                                      100
                                       -
                                       -
                                       -
                                       -

                                     nonpt
                                      193
                                      41
                                      41
                                       -
                                       -
                                       -
                                       -

                                   ptagfire
                                      177
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      345
                                      39
                                      39
                                       -
                                       -
                                       -
                                       -
Brooke County, WV
-
                                    afdust
                                      90
                                      12
                                       -
                                       -
                                       -
                                       -
                                      12

                                     nonpt
                                      44
                                      19
                                       -
                                       -
                                       -
                                       -
                                      19

                                   ptnonipm
                                      127
                                      76
                                       -
                                       -
                                       -
                                       -
                                      76

                                      rwc
                                      103
                                      13
                                       -
                                       -
                                       -
                                       -
                                      13
Hancock County, WV
Brooke County, WV
                                    afdust
                                      58
                                       8
                                       -
                                       -
                                       -
                                       -
                                       8

                                     nonpt
                                      51
                                       9
                                       -
                                       -
                                       -
                                       -
                                       9

                                   ptnonipm
                                      32
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      122
                                      15
                                       -
                                       -
                                       -
                                       -
                                      15
Marshall County, WV
-
                                    afdust
                                      179
                                      24
                                       -
                                       -
                                       -
                                       -
                                      24

                                     nonpt
                                      46
                                      13
                                       -
                                       -
                                       -
                                       -
                                      13

                                   np_oilgas
                                      14
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   pt_oilgas
                                      13
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   ptnonipm
                                      109
                                      92
                                       -
                                       -
                                       -
                                       -
                                      92

                                      rwc
                                      158
                                      19
                                       -
                                       -
                                       -
                                       -
                                      19
Ohio County, WV
Brooke County, WV
Marshall County, WV
                                    afdust
                                      238
                                      40
                                       -
                                       -
                                       -
                                       -
                                      40

                                     nonpt
                                      97
                                      38
                                       -
                                       -
                                       -
                                       -
                                      38

                                   np_oilgas
                                      26
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      143
                                      18
                                       -
                                       -
                                       -
                                       -
                                      18
Wetzel County, WV
Marshall County, WV
                                    afdust
                                      77
                                      12
                                       -
                                       -
                                       -
                                       -
                                      12

                                     nonpt
                                      41
                                      22
                                       -
                                       -
                                       -
                                       -
                                      22

                                   np_oilgas
                                      35
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                   pt_oilgas
                                       8
                                       -
                                       -
                                       -
                                       -
                                       -
                                       -

                                      rwc
                                      82
                                      11
                                       -
                                       -
                                       -
                                       -
                                      11

ENGINEERING COST ANALYSIS AND QUALITATIVE DISCUSSION OF SOCIAL COSTS
 Overview
This chapter provides estimates of the engineering costs of the illustrative control strategies identified in Chapter 3 for the proposed annual and current 24-hour alternative standard levels of 10/35 g/ - m - [3] -  and 9/35 g/m[3], as well as the following two more stringent alternative standard levels: 8/35 g/ - m - [3] -  and 10/30 g/ - m - [3] - . Because the EPA is proposing that the current secondary PM standards be retained, we did not evaluate alternative secondary standard levels in this RIA. The chapter summarizes the methods, tools, and data sources used to estimate the engineering costs presented. As discussed in Chapter 3, for the alternative standards analyzed we applied control measures to sources in the following emissions inventory sectors: non-electric generating unit (non-EGU) point, oil and gas point, non-point (area), residential wood combustion, and area fugitive dust.
The estimated costs for the alternative standard levels are a function of (i) assumptions used in the analysis, including assumptions about which areas will require emissions controls and the sources and controls available in those areas; (ii) the level of sufficient, detailed information on emissions sources and control measures needed to estimate engineering costs; and (iii) the future year baseline emissions from which the emissions reductions are measured.
For the proposed alternative standard level of 10/35 g/ - m - [3] - , because 15 of the 24 counties that need emissions reductions are counties in California, the majority of the estimated costs are incurred in California. In addition, as the alternative standard levels become more stringent, more counties in the northeast and southeast need emissions reductions. As additional controls are applied in those areas (and less so in the west and California because availability of additional controls is limited), those areas account for a relatively higher proportion of estimated costs. For example, for alternative standard levels of 9/35 g/ - m - [3] -  and 8/35 g/ - m - [3] - , more controls are available to apply in the northeast and their adjacent counties and the southeast and their adjacent counties. The estimated costs for those areas are higher than the estimated costs for the west and California. Note that in the northeast and southeast we identified control measures and associated emissions reductions from adjacent counties and used a ppb/ton PM2.5 air quality ratio that was four times less responsive than the ratio used when applying in-county emissions reductions (i.e., applied four tons of PM2.5 emissions reductions from an adjacent county for one ton of emissions reduction needed in a given county); the cost of the additional reductions from adjacent counties also contributes to the higher proportion of the estimated costs. Lastly, for the more stringent alternative standard level of 8/35 g/m[3], across all areas the largest share of estimated costs is from controls for area fugitive dust emissions.
The remainder of the chapter is organized as follows. Section 4.1 presents the engineering costs associated with the application of controls identified in EPA's national-scale analysis. Section 4.2 provides a discussion of the uncertainties and limitations associated with the engineering cost estimates. Section 4.3 includes a qualitative discussion on social costs. Section 4.4 includes references.
Estimating Engineering Costs
The engineering costs described in this chapter generally include the costs of purchasing, installing, operating, and maintaining the control technologies applied. The costs associated with monitoring, testing, reporting, and recordkeeping for potentially affected sources are not included in the annualized cost estimates. These cost estimates are presented for 2032 but reflect the annual cost that is expected to be incurred each year over a longer time horizon. We calculate the present value of these annual costs over 20 years in Chapter 8 using 3 and 7 percent discount rates.
This analysis focuses on emissions reductions needed for the proposed and more stringent alternative standard levels. As discussed in this analysis, the control technologies and strategies selected for analysis were from information available in EPA's control measures database; these control strategies illustrate one way in which nonattainment areas could work toward meeting a revised standard. There are many ways to construct and evaluate potential control programs for a revised standard, and the EPA anticipates that state and local governments will consider programs best suited for local conditions.
The EPA understands that some states will incur costs both designing State Implementation Plans (SIPs) and implementing new control strategies to meet a revised standard. However, the EPA does not know what specific actions states will take to design their SIPs to meet a revised standard. Therefore, we do not present estimated costs that government agencies may incur for managing the requirement or implementing these (or other) control strategies.
Methods, Tools, and Data
The EPA uses the Control Strategy Tool (CoST) (U.S. EPA, 2019a) to estimate engineering control costs. CoST models emissions reductions and control costs associated with the application of control technologies or measures by matching the controls in the control measures database (CMDB) to emissions sources in the future year projected emissions inventory by source classification code (SCC).[,] CoST was used in two ways in the analysis. First, CoST was used to identify controls and related potential PM2.5 emissions reductions in counties projected to exceed the proposed and more stringent alternative annual and 24-hour standard levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] -  in the analytical baseline (see Chapter 3, Section 3.2.1 for a discussion of the counties and areas). Second, CoST was used to estimate the control costs for the measures identified. As indicated in Chapter 3, Section 3.2.2., for the control strategy analyses in this RIA, to maximize the number of emissions sources included we applied controls to emissions sources with greater than 5 tons per year of PM2.5 emissions at a marginal cost threshold of up to a $160,000/ton.
CoST calculates engineering costs using one of two different methods: (1) an equation that incorporates key operating unit information, such as unit design capacity or stack flow rate, or (2) an average annualized cost-per-ton factor multiplied by the total tons of reduction of a pollutant. Most control cost information within CoST was developed based on the cost-per-ton approach because (1) parameters used in the engineering equations are not readily available or broadly representative across emissions sources within the emissions inventory and (2) estimating engineering costs using an equation requires data from the emissions inventory, which may not be available. The cost equations used in CoST estimate annual, capital and/or operating and maintenance (O&M) costs and are used primarily for some larger emissions sources such as industrial, commercial, and institutional (ICI) boilers, glass manufacturing furnaces, and cement kilns.
CoST gets key operating unit information from the emissions inventory data submitted by state, local, and tribal air agencies (S/L/T), including detailed information by source on emissions, installed control devices, and control device efficiency. Much of this underlying emissions inventory data serves as key inputs into CoST and the control strategy analyses. The information on whether a source is currently controlled, by what control device, and control device efficiency is required under the Air Emissions Reporting Rule (AERR) used to collect the emissions inventory data. However, control information may not be fully reported by S/L/T agencies and would not be available for purposes of the control strategy analyses, introducing the possibility that CoST applies controls to already controlled emissions sources.
When sufficient information is available to estimate control costs using equations, the capital costs of the control equipment must be annualized. Capital costs are converted to annual costs using the capital recovery factor (CRF). The engineering cost analysis uses the equivalent uniform annual costs (EUAC) method, in which annualized costs are calculated based on the equipment life for the control measure and the interest rate incorporated into the CRF. Annualized costs represent an equal stream of yearly costs over the period the control technology is expected to operate. For more information on the EUAC method, refer to the EPA Air Pollution Control Cost Manual (U.S. EPA, 2017a).
Cost Estimates for the Control Strategies
In this section, we provide engineering cost estimates for the control technologies and measures presented in Chapter 3 that include control technologies for non-EGU point sources, oil and gas point, non-point (area) sources, residential wood combustion sources, and area fugitive dust emissions. The cost estimates presented in Table 4-1 through Table 4-5 reflect the engineering costs annualized at 7 percent, to the extent possible. When calculating the annualized costs we would like to use the interest rates faced by firms; however, we do not know what those rates are. As such we use 7 percent as a conservative estimate.
By area, Table 4-1 includes a summary of estimated control costs from control applications for the alternative standard levels analyzed. Tables 4A-1 through 4A-6 in Appendix 4A include detailed information on estimated costs by area and by county.
Table 4-1	By Area, Summary of Annualized Control Costs for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/m - [3] - , and 8/35 g/ - m - [3] -  for 2032 (millions of 2017$)
Area
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Northeast
                                     $7.3
                                     $12.8
                                    $183.5
                                    $560.2
Northeast (Adjacent Counties)
                                      $0
                                      $0
                                     $22.3
                                    $539.7
Southeast
                                     $4.1
                                     $4.1
                                     $50.4
                                    $250.6
Southeast (Adjacent Counties)
                                      $0
                                      $0
                                     $18.2
                                    $186.5
West
                                     $19.0
                                    $150.0
                                     $34.2
                                    $121.8
CA
                                     $64.1
                                     $90.4
                                     $84.7
                                    $162.9
Total
                                     $94.5
                                    $257.2
                                    $393.3
                                   $1,821.7

For the proposed alternative standard level of 10/35 g/ - m - [3] - , the majority of the estimated costs are incurred in California because 15 of the 24 counties that need emissions reductions are located in California. Looking at the more stringent alternative standard level of 10/30 g/m - [3] -  in the west, an additional 20 counties need emissions reductions, and the estimated costs increase significantly; estimated costs for the proposed alternative standard level of 9/35 g/ - m - [3] -  -  are higher than for 10/35 g/ - m - [3] -  -  but lower than for 10/30 g/ - m - [3] -  -  in this area. For alternative standard levels of 9/35 g/ - m - [3] -  and 8/35 g/m - [3] - , more controls are available to apply in the northeast and the southeast as compared to in California and the west. Therefore, the estimated costs for the northeast and the southeast are significantly higher for 9/35 g/ - m - [3] -  and 8/35 g/m - [3]. See Tables 3A.2 through 3A.7 for more details on emissions reductions available by area and county.
As discussed in Chapter 3, in the northeast and southeast when we applied the emissions reductions from adjacent counties, we applied a ratio of 4:1. That is, it is assumed that four tons of PM2.5 emissions reductions from an adjacent county are needed to produce the equivalent air quality change of one ton of emissions reduction if it had occurred within the county needing the reduction. Application of this ratio contributes to the higher cost estimates for alternative standard levels of 9/35 g/ - m - [3] -  and 8/35 g/m - [3] - .  Naturally, it is anticipated that states will first attempt to find emissions reductions within the counties that actually need the reductions. To the extent that states are able to identify control opportunities within those counties beyond the reductions identified by CoST, the need for reductions from adjacent counties will be reduced. Also, depending on local air quality factors, the resulting air quality impact may be greater than a 4:1 ratio suggests. As a result, the estimate of costs for adjacent counties may be an overestimate.
By emissions inventory sector, Table 4-2 includes a summary of the estimated costs from control applications for the alternative standard levels analyzed. For all of the alternative standard levels analyzed, controls for area fugitive dust emissions comprise the largest share of the estimated costs, ranging from 49 to 81 percent of the cost estimates. Non-EGU point and non-point (area) controls represent the next largest shares of the cost estimates.
By area and by emissions inventory sector, Table 4-3 includes a summary of the estimated costs from control applications for the alternative standard levels analyzed. For the more stringent alternative standard level of 8/35 g/m[3] across all areas the largest share of estimated costs is from controls for area fugitive dust emissions. In addition, as the alternative standard levels become more stringent, more counties in the northeast and southeast need emissions reductions and controls are applied in those areas (and less so in the west and California because availability of additional controls is limited), resulting in a relatively higher proportion of estimated costs for those areas.
Table 4-2	By Emissions Inventory Sector, Summary of Annualized Control Costs for Alternative Primary Standard Levels of 10/35g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] -  for 2032 (millions of 2017$)
Sector
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Non-EGU Point
                                     $10.2
                                     $21.2
                                    $144.3
                                    $423.7
Oil & Gas Point
                                      $0
                                      $0
                                      $0
                                     $5.0
Non-Point (Area)
                                     $15.8
                                     $21.4
                                     $46.3
                                    $189.2
Residential Wood Combustion
                                     $3.1
                                     $5.6
                                     $11.3
                                     $36.7
Area Source Fugitive Dust
                                     $65.4
                                    $209.1
                                    $191.5
                                   $1,167.0
Total
                                     $94.5
                                    $257.2
                                    $393.3
                                   $1,821.7

Table 4-3	By Area and by Emissions Inventory Sector, Summary of Annualized Control Costs for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] -  for 2032 (millions of 2017$)
Area
Sector
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Northeast
Non-EGU Point
                                     $1.7
                                     $7.3
                                    $125.0
                                    $232.8

Non-Point (Area)
                                     $4.6
                                     $4.6
                                     $16.8
                                     $56.4

Residential Wood Combustion
                                     $1.0
                                     $1.0
                                     $4.1
                                     $10.5

Area Source Fugitive Dust
                                      $0
                                      $0
                                     $37.7
                                    $260.5
Northeast (Adjacent Counties)
Non-EGU Point
                                      $0
                                      $0
                                     $4.0
                                     $65.3

Oil & Gas Point
                                      $0
                                      $0
                                      $0
                                     $5.0

Non-Point (Area)
                                      $0
                                      $0
                                     $4.4
                                     $50.5

Residential Wood Combustion
                                      $0
                                      $0
                                     $0.8
                                     $10.6

Area Source Fugitive Dust
                                      $0
                                      $0
                                     $13.1
                                    $408.4
Southeast
Non-EGU Point
                                     $1.2
                                     $1.2
                                     $6.2
                                     $81.4

Oil & Gas Point
                                      $0
                                      $0
                                      $0
                                     $0.02

Non-Point (Area)
                                     $2.0
                                     $2.0
                                     $10.1
                                     $37.7

Residential Wood Combustion
                                     $0.3
                                     $0.3
                                     $0.6
                                     $2.4

Area Source Fugitive Dust
                                     $0.7
                                     $0.7
                                     $33.6
                                    $129.0
Southeast (Adjacent Counties)
Non-EGU Point
                                      $0
                                      $0
                                      $0
                                     $17.9

Non-Point (Area)
                                      $0
                                      $0
                                     $0.1
                                     $10.0

Residential Wood Combustion
                                      $0
                                      $0
                                      $0
                                     $1.4

Area Source Fugitive Dust
                                      $0
                                      $0
                                     $18.1
                                    $157.3
West
Non-EGU Point
                                      $0
                                     $5.4
                                     $0.6
                                     $11.9

Non-Point (Area)
                                     $0.06
                                     $3.6
                                     $2.1
                                     $13.4

Residential Wood Combustion
                                     $0.03
                                     $1.1
                                     $0.4
                                     $2.8

Area Source Fugitive Dust
                                     $19.0
                                    $139.9
                                     $31.0
                                     $93.7
CA
Non-EGU Point
                                     $7.3
                                     $7.3
                                     $8.4
                                     $14.5

Non-Point (Area)
                                     $9.2
                                     $11.2
                                     $12.8
                                     $21.2

Residential Wood Combustion
                                     $1.9
                                     $3.3
                                     $5.5
                                     $9.0

Area Source Fugitive Dust
                                     $45.8
                                     $68.5
                                     $58.0
                                    $118.2
Total

                                     $94.5
                                    $257.2
                                    $393.3
                                   $1,821.7

By control technology, Table 4-4 includes a summary of the estimated costs from control applications for the alternative standard levels analyzed. Across all of the alternative standard levels analyzed, the control technologies that comprise more than 80 percent of the cost estimates include Pave Existing Shoulders at 25% rule penetration (RP) (area fugitive dust inventory sector), Pave Unpaved Roads at 25% RP (area fugitive dust inventory sector), Fabric Filter-All Types (non-EGU point inventory sector), and Electrostatic Precipitator at 25% RP (non-point (area) inventory sector).
By emissions inventory sector and by control technology, Table 4-5 includes a summary of the cost estimates. Across all of the alternative standard levels analyzed, for the non-EGU point sector, the application of Fabric Filter-All Types results in the highest portion of estimated costs for that inventory sector; for the non-point (area) sector, the application of Electrostatic Precipitator at 25% RP and Substitute Chipping for Burning result in the highest portion of estimated costs for that inventory sector; for the residential wood combustion sector, the application of Convert to Gas Logs at 25% RP results in the highest portion of estimated costs for that inventory sector; and for the area fugitive dust sector, the application of Pave Existing Shoulders at 25% and Pave Unpaved Roads at 25% result in the highest portion of estimated costs for that inventory sector.

Table 4-4	By Control Technology, Summary of Annualized Control Costs for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] -  for 2032 (millions of 2017$)
Control Technology
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Add-on Scrubber at 25% RP
                                     $0.06
                                     $0.06
                                      $0
                                      $0
Annual tune-up at 10% RP
                                      $0
                                     $0.01
                                     $0.01
                                     $0.01
Annual tune-up at 25% RP
                                     $0.6
                                     $0.7
                                     $3.4
                                     $12.0
Biennial tune-up at 10% RP
                                     $0.0
                                     $0.0
                                     $0.0
                                     $0.3
Biennial tune-up at 25% RP
                                     $0.1
                                     $0.3
                                     $0.3
                                     $2.0
Catalytic oxidizers at 25% RP
                                     $0.3
                                     $0.4
                                     $1.1
                                     $1.4
Chemical Stabilizer at 10% RP
                                     $0.7
                                     $2.2
                                     $1.3
                                     $46.8
Chemical Stabilizer at 25% RP
                                      $0
                                      $0
                                     $1.6
                                     $49.8
Convert to Gas Logs at 25% RP
                                     $2.6
                                     $4.4
                                     $9.5
                                     $29.0
Dust Suppressants at 10% RP
                                      $0
                                      $0
                                      $0
                                     $0.02
Dust Suppressants at 25% RP
                                      $0
                                      $0
                                      $0
                                     $5.4
Electrostatic Precipitator-All Types
                                     $0.4
                                      $0
                                     $0.4
                                     $0.7
Electrostatic Precipitator at 10% RP
                                      $0
                                      $0
                                     $0.1
                                     $0.01
Electrostatic Precipitator at 25% RP
                                     $10.7
                                     $13.1
                                     $20.4
                                     $80.6
EPA-certified wood stove at 10% RP
                                      $0
                                      $0
                                      $0
                                     $0.01
EPA Phase 2 Qualified Units at 10% RP
                                      $0
                                      $0
                                     $0.2
                                     $0.03
EPA Phase 2 Qualified Units at 25% RP
                                     $0.2
                                     $0.2
                                      $0
                                     $0.7
Fabric Filter-All Types
                                     $9.0
                                     $18.9
                                    $129.1
                                    $397.2
HEPA filters at 10% RP
                                     $0.01
                                     $0.01
                                     $0.01
                                     $0.02
HEPA filters at 25% RP
                                     $0.02
                                      $0
                                     $0.09
                                     $0.4
Install Cleaner Hydronic Heaters at 10% RP
                                      $0
                                     $0.0
                                      $0
                                      $0
Install Cleaner Hydronic Heaters at 25% RP
                                     $0.02
                                     $0.03
                                     $0.2
                                     $0.7
Install new drift eliminator at 10% RP
                                      $0
                                      $0
                                     $0.02
                                     $0.01
Install new drift eliminator at 25% RP
                                     $0.5
                                     $0.5
                                     $0.6
                                     $1.3
Install Retrofit Devices at 10% RP
                                      $0
                                      $0
                                     $0.1
                                     $0.06
Install Retrofit Devices at 25% RP
                                     $0.1
                                     $0.1
                                      $0
                                     $0.08
New gas stove or gas logs at 10% RP
                                     $0.03
                                     $0.4
                                     $0.4
                                     $0.7
New gas stove or gas logs at 25% RP
                                     $0.2
                                     $0.5
                                     $0.9
                                     $5.4
Pave existing shoulders at 10% RP
                                      $0
                                      $0
                                      $0
                                     $7.6
Pave existing shoulders at 25% RP
                                     $31.1
                                     $95.0
                                    $119.6
                                    $755.0
Pave Unpaved Roads at 25% RP
                                     $33.7
                                    $111.8
                                     $69.0
                                    $302.5
Smokeless Broiler at 10% RP
                                     $0.4
                                     $0.6
                                     $1.1
                                     $0.3
Smokeless Broiler at 25% RP
                                      $0
                                      $0
                                     $3.1
                                     $1.3
Substitute chipping for burning
                                     $3.5
                                     $6.1
                                     $16.6
                                     $90.6
Venturi Scrubber
                                     $0.3
                                     $1.7
                                     $14.3
                                     $29.7
Total
                                     $94.5
                                    $257.2
                                    $393.3
                                   $1,821.7
Note - The 10% RP and 25% RP indicate the rule penetration percent, or the percent of the non-point (area), residential wood combustion, or area fugitive dust inventory emissions that the control measure is applied to at a specified percent control efficiency.

Table 4-5	By Emissions Inventory Sector and Control Technology, Summary of Annualized Control Costs for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] -  for 2032 (millions of 2017$)
Inventory Sector
Control Technology
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Non-EGU Point
Electrostatic Precipitator-All Types
                                     $0.4
                                      $0
                                     $0.4
                                     $0.7

Fabric Filter-All Types
                                     $9.0
                                     $18.9
                                    $129.0
                                    $392.0

Install new drift eliminator at 10% RP
                                      $0
                                      $0
                                     $0.02
                                     $0.01

Install new drift eliminator at 25% RP
                                     $0.5
                                     $0.5
                                     $0.6
                                     $1.3

Venturi Scrubber
                                     $0.3
                                     $1.7
                                     $14.3
                                     $29.7
Oil & Gas Point
Fabric Filter-All Types
                                      $0
                                      $0
                                      $0
                                     $5.0

Install new drift eliminator at 25% RP
                                      $0
                                      $0
                                      $0
                                     $0.02
Non-Point (Area)
Add-on Scrubber at 25% RP
                                     $0.06
                                     $0.06
                                      $0
                                      $0

Annual tune-up at 10% RP
                                      $0
                                     $0.01
                                     $0.01
                                     $0.01

Annual tune-up at 25% RP
                                     $0.6
                                     $0.7
                                     $3.4
                                     $12.0

Biennial tune-up at 10% RP
                                     $0.0
                                     $0.0
                                     $0.0
                                     $0.3

Biennial tune-up at 25% RP
                                     $0.1
                                     $0.3
                                     $0.3
                                     $2.0

Catalytic oxidizers at 25% RP
                                     $0.3
                                     $0.4
                                     $1.1
                                     $1.4

Electrostatic Precipitator at 10% RP
                                      $0
                                      $0
                                     $0.1
                                     $0.01

Electrostatic Precipitator at 25% RP
                                     $10.7
                                     $13.1
                                     $20.4
                                     $80.6

Fabric Filter-All Types
                                      $0
                                      $0
                                     $0.09
                                     $0.2

HEPA filters at 10% RP
                                     $0.01
                                     $0.01
                                     $0.01
                                     $0.02

HEPA filters at 25% RP
                                     $0.02
                                      $0
                                     $0.09
                                     $0.4

Smokeless Broiler at 10% RP
                                     $0.4
                                     $0.6
                                     $1.1
                                     $0.3

Smokeless Broiler at 25% RP
                                      $0
                                      $0
                                     $3.1
                                     $1.3

Substitute chipping for burning
                                     $3.5
                                     $6.1
                                     $16.6
                                     $90.6
Residential Wood Combustion
Convert to Gas Logs at 25% RP
                                     $2.6
                                     $4.4
                                     $9.5
                                     $29.0

EPA-certified wood stove at 10% RP
                                      $0
                                      $0
                                      $0
                                     $0.01

EPA Phase 2 Qualified Units at 10% RP
                                      $0
                                      $0
                                     $0.2
                                     $0.03

EPA Phase 2 Qualified Units at 25% RP
                                     $0.2
                                     $0.2
                                      $0
                                     $0.7

Install Cleaner Hydronic Heaters at 10% RP
                                      $0
                                     $0.0
                                      $0
                                      $0

Install Cleaner Hydronic Heaters at 25% RP
                                     $0.02
                                     $0.03
                                     $0.2
                                     $0.7

Install Retrofit Devices at 10% RP
                                      $0
                                      $0
                                     $0.1
                                     $0.06

Install Retrofit Devices at 25% RP
                                     $0.1
                                     $0.1
                                      $0
                                     $0.08

New gas stove or gas logs at 10% RP
                                     $0.03
                                     $0.4
                                     $0.4
                                     $0.7

New gas stove or gas logs at 25% RP
                                     $0.2
                                     $0.5
                                     $0.9
                                     $5.4
Area Source Fugitive Dust
Chemical Stabilizer at 10% RP
                                     $0.7
                                     $2.2
                                     $1.3
                                     $46.8

Chemical Stabilizer at 25% RP
                                      $0
                                      $0
                                     $1.6
                                     $49.8

Dust Suppressants at 10% RP
                                      $0
                                      $0
                                      $0
                                     $0.02

Dust Suppressants at 25% RP
                                      $0
                                      $0
                                      $0
                                     $5.4

Pave existing shoulders at 10% RP
                                      $0
                                      $0
                                      $0
                                     $7.6

Pave existing shoulders at 25% RP
                                     $31.1
                                     $95.0
                                    $119.6
                                    $755.0

Pave Unpaved Roads at 25% RP
                                     $33.7
                                    $111.8
                                     $69.0
                                    $302.5
Total

                                     $94.5
                                    $257.2
                                    $393.3
                                   $1,821.7
Note - The 10% RP and 25% RP indicate the rule penetration percent, or the percent of the non-point (area), residential wood combustion, or area fugitive dust inventory emissions that the control measure is applied to at a specified percent control efficiency.

     As discussed in Chapter 2, Section 2.4 and Chapter 3, Section 3.2.6, for the proposed alternative standard levels of 10/35 g/ - m - [3] -  and 9/35 g/ - m - [3] there are remaining air quality challenges for areas in the northeast and southeast, as well as in the west and California - ; the areas include a county in Pennsylvania affected by local sources, 3 counties in border areas, 5 counties in small western mountain valleys, and 13 counties in California's air basins and districts. The characteristics of the air quality challenges for these areas include features of local source-to-monitor impacts, cross-border transport, effects of complex terrain in the west and California, and identifying wildfire influence on projected PM2.5 DVs that could qualify for exclusion as atypical, extreme, or unrepresentative events (U.S. EPA, 2019b). To the extent that state and local areas are able to find alternative lower-cost approaches to reducing emissions, the annualized control costs above may be overestimated. To the extent that additional PM2.5 emissions reductions are required that were not identified in our analysis of these areas, the annualized control costs above may be underestimated.
Limitations and Uncertainties in Engineering Cost Estimates
The EPA acknowledges several important limitations of this analysis, which include the following:
 Exclusions from the cost analysis: As mentioned above, recordkeeping, reporting, testing and monitoring costs are not included. The costs some states will incur both designing SIPs and implementing new control strategies to meet a revised standard are also not included.
 Cost and effectiveness of control measures: We are not able to account for regional or local variation in capital and annual cost items such as energy, labor, or materials. Our estimates of control measure costs may over- or under-estimate the costs depending on how the difficulty of actual retrofitting and equipment life compares with our control assumptions. In addition, our estimates of control efficiencies for the controls assume that the control devices are properly installed and maintained. Further, our estimates of control efficiencies do not account for differences in individual applications as we use a single value for each control that does not account for differences in individual applications  -  sometimes a control operates more or less effectively than the specified efficiency. There is also variability in scale of application that is difficult to reflect for small area sources of emissions.
 Interest rate: Because we obtain control cost data from many sources, we are not always able to obtain consistent data across original data sources. If disaggregated control cost data is available (i.e., where capital, equipment life value, and O&M costs are separated out) we can calculate costs using a specified percent interest rate. The EPA may not know the interest rates used to calculate costs if disaggregated control cost data is unavailable (i.e., where we only have a $/ton value and where capital, equipment life value, and O&M costs are not separated out). In general, we have some disaggregated data available for non-EGU point source controls, but we do not have any disaggregated control cost data for non-point (area) source controls.
 Differences between ex ante and ex post compliance cost estimates: In comparing regulatory cost estimates before and after regulation, ex ante cost estimate predictions may differ from actual costs. Harrington et al. (2000) surveyed the predicted and actual costs of 28 federal and state rules, including 21 issued by the U.S. Environmental Protection Agency and the Occupational Safety and Health Administration (OSHA). In 14 of the 28 rules, predicted total costs were overestimated, while analysts underestimated costs in three of the remaining rules. In EPA rules where per-unit costs were specifically evaluated, costs of regulations were overestimated in five cases, underestimated in four cases, and accurately estimated in four cases (Harrington et al., 2000). The collection of literature regarding the accuracy of cost estimates seems to reflect these splits. A recent EPA report, the "Retrospective Study of the Costs of EPA Regulations" that examined the compliance costs of five EPA regulations in four case studies, found that several of the case studies suggested that cost estimates were over-estimated ex ante and did not find the evidence to be conclusive. The EPA stated in the report that the small number of regulatory actions covered, as well as significant data and analytical challenges associated with the case studies limited the certainty of this conclusion (U.S. EPA, 2014).
Social Costs
As discussed in EPA's Guidelines for Preparing Economic Analyses, social costs are the total economic burden of a regulatory action (U.S. EPA, 2010). This burden is the sum of all opportunity costs incurred due to the regulatory action, where an opportunity cost is the value lost to society of any goods and services that will not be produced and consumed as a result of reallocating some resources toward pollution mitigation. Estimates of social costs may be compared to the social benefits expected as a result of a regulation to assess its net impact on society.
Computable General Equilibrium (CGE) models are analytical tools that can be used to evaluate the broad impacts of a regulatory action and are therefore often used to estimate social costs. While this section includes a qualitative discussion of social costs and economic impact modeling, CGE modeling was not conducted for this analysis because EPA's current CGE model, discussed later in this section, does not have the resolution needed to accurately model the emissions inventory sectors being controlled (e.g., area fugitive dust inventory sector, residential wood combustion inventory sector). However, the EPA continues to be committed to the use of CGE models to evaluate the economy-wide effects of its regulations.
Economic impacts focus on the behavioral response to the costs imposed by a policy being analyzed. The responses typically analyzed are market changes in prices, quantities produced and purchased, changes in international trade, changes in profitability, facility closures, and employment. Sometimes these behavioral changes can be used to estimate social costs if there is indication that the social costs differ from the estimate of control costs because behavioral change results in other ways of meeting the requirements (e.g., facilities choosing to reduce emissions by producing less rather than adding pollution control devices).
      Changes in production in a directly regulated sector may have indirect effects on a myriad of other markets when output from that is used as an input in the production of many other goods. It may also affect upstream industries that supply goods and services to the sector, along with labor and capital markets, as these suppliers alter production processes in response to changes in factor prices. In addition, households may change their demand for particular goods and services due to changes in the price of those goods.
      When new regulatory requirements are expected to result in effects outside of regulated and closely related sectors, a key challenge is determining whether they are of sufficient magnitude to warrant explicit evaluation (Hahn and Hird 1990). It is not possible to estimate the magnitude and direction of all of these potential effects outside of the regulated sector(s) without an economy-wide modeling approach. For example, studies of air pollution regulations for the power sector have found that the social costs and benefits may be greater or lower than when secondary market impacts are taken into account, and that the direction of the estimates may depend on the form of the regulation (e.g., Goulder et al. 1999, Williams 2002, Goulder et al. 2016).
The alternative standard levels analyzed are anticipated to impact multiple markets in many places over time. CGE models are one possible tool for evaluating the impacts of a regulation on the broader economy because this class of models explicitly captures interactions between markets across the entire economy. While a CGE model captures the effects of behavioral responses on the part of consumers or other producers to changes in price that are missed by an engineering estimate of compliance costs, most CGE models do not model the environmental externality or the benefits that accrue to society from mitigating the externality. When benefits from a regulation are expected to be substantial, social cost cannot be interpreted as a complete characterization of economic welfare. To the extent that the benefits affect behavioral responses in markets, the social cost measure may also be potentially biased.
 A CGE-based approach to cost estimation concurrently considers the effect of a regulation across all sectors in the economy. It is structured around the assumption that, for some discrete period of time, an economy can be characterized by a set of equilibrium conditions in which supply equals demand in all markets. When the imposition of a regulation alters conditions in one market, a general equilibrium approach will determine a new set of prices for all markets that will return the economy to equilibrium. These prices in turn determine the outputs and consumption of goods and services in the new equilibrium. In addition, a new set of prices and demands for the factors of production (labor, capital, and land), the returns to which compose the income of businesses and households, will be determined in general equilibrium. The social cost of the regulation can then be estimated by comparing the value of variables in the pre-regulation "baseline" equilibrium with those in the post-regulation, simulated equilibrium.
In 2015, the EPA established a Science Advisory Board (SAB) panel to consider the technical merits and challenges of using economy-wide models to evaluate costs, benefits, and economic impacts in regulatory development. In its final report (U.S. EPA, 2017b), the SAB recommended that the EPA begin to integrate CGE modeling into regulatory analysis to offer a more comprehensive assessment of the effects of air regulations. The SAB noted that CGE models can provide insight into the likely social costs of a regulation even when they do not include a characterization of the likely social benefits of the regulation. CGE models may also offer insights into the ways costs are distributed across regions, industry sectors, or households.
The SAB also noted that the case for using CGE models to evaluate a regulation's effects is strongest when the industry sector has strong linkages to the rest of the economy. The report also noted that the extent to which CGE models add value to the analysis depends on data availability. CGE models provide aggregated representations of the entire economy and are designed to capture substitution possibilities between production, consumption, and trade; interactions between economic sectors; and interactions between a policy shock and pre-existing distortions, such as taxes. However, one also needs to adequately represent a regulation in the model to estimate its effects.
In response to the SAB's recommendations, the EPA built a new CGE model called SAGE. A second SAB panel performed a peer review of SAGE, and the review concluded in 2020. While the EPA now has a peer-reviewed CGE model for analyzing the potential economy-wide effects of regulations, we did not use the model in the RIA for this proposal, but the EPA continue to be committed to the use of CGE models to evaluate the economy-wide effects of its regulations.
Lastly, the EPA included specific types of health benefits in a CGE model for the prospective analysis -- The Benefits and Costs of the Clean Air Act from 1990 to 2020 (EPA 2011) -- and demonstrated the importance of their inclusion when evaluating the economic welfare effects of policy. However, while the external Council on Clean Air Compliance Analysis (Council) peer review of this the EPA report (Hammitt, 2010) stated that inclusion of benefits in an economy-wide model, specifically adapted for use in that study, "represent[ed] a significant step forward in benefit-cost analysis", serious technical challenges remain when attempting to evaluate the benefits and costs of potential regulatory actions using economy-wide models.

References
Goulder, L., I. Parry, R. Williams, and D. Burtraw (1999). The cost-effectiveness of alternative instruments for environmental protection in a second-best setting. Journal of Public Economics, 72(3): 329-360. 144
Goulder, L., M. Hafstead, and R. Williams III (2016). General equilibrium impacts of a federal clean energy standard. American Economic Journal  -  Economic Policy 8(2): 186 - 218.
Hahn, R., and J. Hird (1990). The costs and benefits of regulation: review and synthesis. Yale Journal of Regulation 8: 233-278.
Hammitt, J.K. (2010). Review of the final integrated report for the second section 812 prospective study of the benefits and costs of the clean air act. Available at: https://council.epa.gov/ords/sab/apex_util.get_blob?s=3667362893551&a=104&c=45494121954152467&p=18&k1=946&k2=&ck=7rX81JLu6VlfAmvI_4bpsKFHvLUkoKf4dqoGFPV89m2l6Y5SNmFm10LePlqgIx1BH1u8weBKnW7yvfsOXfV25Q&rt=IR.
Harrington, W., R.D. Morgenstern, and P. Nelson (2000). On the accuracy of regulatory cost estimates. Journal of Policy Analysis and Management 19, 297-322.
U.S. EPA (2010). EPA Guidelines for Preparing Economic Analyses. Available at: https://www.epa.gov/sites/default/files/2017-08/documents/ee-0568-50.pdf.
U.S. EPA (2011). The Benefits and Costs of the Clean Air Act from 1990 to 2020. Final Report. Office of Air and Radiation, Washington, DC. Available at: https://www.epa.gov/sites/default/files/2015-07/documents/fullreport_rev_a.pdf.
U.S. EPA (2014). Retrospective Study of the Costs of EPA Regulations: A Report of Four Case Studies. Available at http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0575.pdf/$file/EE-0575.pdf.
U.S. EPA (2017a). EPA Air Pollution Control Cost Manual, Section 1, Chapter 2. Office of Air Quality Planning and Standards, Research Triangle Park, NC. Available at https://www.epa.gov/sites/default/files/2017-12/documents/epaccmcostestimationmethodchapter_7thedition_2017.pdf.
U.S. EPA (2017b). SAB Advice on the Use of Economy-Wide Models in Evaluating the Social Costs, Benefits, and Economic Impacts of Air Regulations. EPA-SAB-17-012.
U.S. EPA (2019a). CoST v3.7 User's Guide. Office of Air Quality Planning and Standards, Research Triangle Park, NC. November 2019. Available at: https://www.cmascenter.org/help/documentation.cfm?model=cost&version=3.7.
U.S. EPA (2019b). Additional Methods, Determinations, and Analyses to Modify Air Quality Data Beyond Exceptional Events. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, EPA-457/B-19-002. Available: https://www.epa.gov/sites/default/files/2019-04/documents/clarification_memo_on_data_modification_methods.pdf.
Williams III, R. (2002). Environmental tax interactions when pollution affects health or productivity. Journal of Environmental Economics and Management 44(2): 261-270.
 APPENDIX 4A: ENGINEERING COST ANALYSIS
 Overview
Chapter 4 describes the engineering cost analysis approach that EPA used to analyze the following alternative annual and 24-hour standard levels in this regulatory impact analysis (RIA) -- 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/ - m - [3] - . This Appendix contains more detailed information about the estimated costs from application of controls by area and by county for the northeast and their adjacent counties, the southeast and their adjacent counties, the west, and California.
 4A.1	Estimated Costs by County for Alternative Standard Levels
The cost estimates presented in Table 4A-1 through Table 4A-6 reflect the engineering costs annualized at 7 percent, to the extent possible. When calculating the annualized costs we would like to use the interest rates faced by firms; however, we do not know what those rates are. As such we use 7 percent as a conservative estimate.
Table 4A-1 and Table 4A-2 present the cost estimates for the northeast counties and their adjacent counties. Table 4A-3 and Table 4A-4 present the cost estimates for the northeast counties and their adjacent counties. Table 4A-5 presents the cost estimates for the counties in the west, and Table 4A-6 presents the cost estimates for the counties in California, organized by air district.
Table 4A-1	Summary of Estimated Annual Control Costs for the Northeast (57 counties) for Alternative Primary Standard Levels of 10/35 g/m[3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/m[3] for 2032 (millions of 2017$)
County
                                     10/35
                                     10/30
                                     9/35
                                     8/35
New Castle County, DE
                                      $0
                                      $0
                                      $0
                                     $0.8
Cook County, IL
                                      $0
                                      $0
                                     $2.1
                                     $13.7
Madison County, IL
                                      $0
                                      $0
                                      $0
                                     $23.8
St. Clair County, IL
                                      $0
                                      $0
                                      $0
                                     $48.8
Allen County, IN
                                      $0
                                      $0
                                      $0
                                     $0.2
Clark County, IN
                                      $0
                                      $0
                                      $0
                                     $1.9
Elkhart County, IN
                                      $0
                                      $0
                                      $0
                                     $9.7
Floyd County, IN
                                      $0
                                      $0
                                      $0
                                     $0.2
Lake County, IN
                                      $0
                                      $0
                                      $0
                                     $0.7
Marion County, IN
                                      $0
                                      $0
                                     $31.1
                                     $31.1
St. Joseph County, IN
                                      $0
                                      $0
                                      $0
                                     $10.0
Vanderburgh County, IN
                                      $0
                                      $0
                                      $0
                                     $7.4
Vigo County, IN
                                      $0
                                      $0
                                      $0
                                     $6.6
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $22.0
Baltimore city, MD
                                      $0
                                      $0
                                      $0
                                     $0.3
Howard County, MD
                                      $0
                                      $0
                                      $0
                                     $10.0
Kent County, MI
                                      $0
                                      $0
                                      $0
                                     $1.3
Wayne County, MI
                                     $0.02
                                     $0.02
                                     $15.1
                                     $15.1
Buchanan County, MO
                                      $0
                                      $0
                                      $0
                                     $0.9
Jackson County, MO
                                      $0
                                      $0
                                      $0
                                     $0.07
Jefferson County, MO
                                      $0
                                      $0
                                      $0
                                     $1.4
St. Louis city, MO
                                      $0
                                      $0
                                      $0
                                     $10.5
St. Louis County, MO
                                      $0
                                      $0
                                      $0
                                     $11.0
Camden County, NJ
                                      $0
                                      $0
                                     $6.6
                                     $6.6
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $8.3
New York County, NY
                                      $0
                                      $0
                                      $0
                                     $4.0
Butler County, OH
                                      $0
                                      $0
                                     $13.3
                                     $31.8
Cuyahoga County, OH
                                     $0.4
                                     $0.4
                                     $23.5
                                     $23.5
Franklin County, OH
                                      $0
                                      $0
                                      $0
                                     $0.5
Hamilton County, OH
                                      $0
                                      $0
                                      $0
                                     $16.9
Jefferson County, OH
                                      $0
                                      $0
                                     $1.0
                                     $1.0
Lucas County, OH
                                      $0
                                      $0
                                      $0
                                     $11.5
Mahoning County, OH
                                      $0
                                      $0
                                      $0
                                     $0.6
Stark County, OH
                                      $0
                                      $0
                                      $0
                                     $18.4
Summit County, OH
                                      $0
                                      $0
                                      $0
                                     $11.5
Allegheny County, PA
                                     $6.8
                                     $12.3
                                     $60.3
                                     $65.8
Armstrong County, PA
                                      $0
                                      $0
                                     $4.1
                                     $4.1
Beaver County, PA
                                      $0
                                      $0
                                      $0
                                     $7.5
Berks County, PA
                                      $0
                                      $0
                                      $0
                                     $0.4
Cambria County, PA
                                      $0
                                      $0
                                     $0.2
                                     $5.5
Chester County, PA
                                      $0
                                      $0
                                      $0
                                     $17.1
Dauphin County, PA
                                      $0
                                      $0
                                      $0
                                     $1.4
Delaware County, PA
                                      $0
                                      $0
                                     $15.8
                                     $15.8
Lackawanna County, PA
                                      $0
                                      $0
                                      $0
                                     $0.08
Lancaster County, PA
                                     $0.08
                                     $0.08
                                     $8.1
                                     $27.2
Lebanon County, PA
                                      $0
                                      $0
                                     $0.2
                                     $5.6
Lehigh County, PA
                                      $0
                                      $0
                                      $0
                                     $0.4
Mercer County, PA
                                      $0
                                      $0
                                      $0
                                     $6.3
Philadelphia County, PA
                                      $0
                                      $0
                                     $2.2
                                     $22.5
Washington County, PA
                                      $0
                                      $0
                                      $0
                                     $1.2
York County, PA
                                      $0
                                      $0
                                      $0
                                     $1.6
Providence County, RI
                                      $0
                                      $0
                                      $0
                                     $1.0
Davidson County, TN
                                      $0
                                      $0
                                      $0
                                     $0.4
Knox County, TN
                                      $0
                                      $0
                                      $0
                                     $1.3
Berkeley County, WV
                                      $0
                                      $0
                                      $0
                                     $0.5
Brooke County, WV
                                      $0
                                      $0
                                      $0
                                     $6.4
Marshall County, WV
                                      $0
                                      $0
                                      $0
                                     $6.0
Total
                                     $7.3
                                     $12.8
                                    $183.5
                                    $560.2

Table 4A-2	Summary of Estimated Annual Control Costs for Adjacent Counties in the Northeast (75 counties) for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/m[3] for 2032 (millions of 2017$)
County
Adjacent Counties
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Clinton County, IL
Madison County, IL
St. Clair County, IL
                                      $0
                                      $0
                                      $0
                                     $7.1
DuPage County, IL
Cook County, IL
                                      $0
                                      $0
                                      $0
                                     $1.5
Kane County, IL
Cook County, IL
                                      $0
                                      $0
                                      $0
                                     $1.1
Lake County, IL
Cook County, IL
                                      $0
                                      $0
                                      $0
                                     $11.3
McHenry County, IL
Cook County, IL
                                      $0
                                      $0
                                      $0
                                     $0.9
Monroe County, IL
St. Clair County, IL
                                      $0
                                      $0
                                      $0
                                     $6.7
Randolph County, IL
St. Clair County, IL
                                      $0
                                      $0
                                      $0
                                     $4.8
Washington County, IL
St. Clair County, IL
                                      $0
                                      $0
                                      $0
                                     $6.7
Will County, IL
Cook County, IL
                                      $0
                                      $0
                                      $0
                                     $11.7
Boone County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.0
                                     $3.9
Clay County, IN
Vigo County, IN
                                      $0
                                      $0
                                      $0
                                     $2.2
Gibson County, IN
Vanderburgh County, IN
                                      $0
                                      $0
                                      $0
                                     $0.2
Hamilton County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.01
                                     $11.1
Hancock County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.0
                                     $3.8
Hendricks County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.02
                                     $10.3
Johnson County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.0
                                     $5.8
LaPorte County, IN
St. Joseph County, IN
                                      $0
                                      $0
                                      $0
                                     $8.9
Marshall County, IN
Elkhart County, IN
St. Joseph County, IN
                                      $0
                                      $0
                                      $0
                                     $5.8
Morgan County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.01
                                     $7.4
Parke County, IN
Vigo County, IN
                                      $0
                                      $0
                                      $0
                                     $1.3
Posey County, IN
Vanderburgh County, IN
                                      $0
                                      $0
                                      $0
                                     $3.9
Shelby County, IN
Marion County, IN
                                      $0
                                      $0
                                     $0.0
                                     $10.1
Starke County, IN
St. Joseph County, IN
                                      $0
                                      $0
                                      $0
                                     $1.5
Sullivan County, IN
Vigo County, IN
                                      $0
                                      $0
                                      $0
                                     $2.8
Vermillion County, IN
Vigo County, IN
                                      $0
                                      $0
                                      $0
                                     $0.06
Warrick County, IN
Vanderburgh County, IN
                                      $0
                                      $0
                                      $0
                                     $4.8
Bullitt County, KY
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $0.08
Hardin County, KY
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $0.1
Oldham County, KY
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $0.06
Shelby County, KY
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $0.07
Spencer County, KY
Jefferson County, KY
                                      $0
                                      $0
                                      $0
                                     $0.06
Montgomery County, MD
Howard County, MD
                                      $0
                                      $0
                                      $0
                                     $0.0
Macomb County, MI
Wayne County, MI
                                      $0
                                      $0
                                     $0.3
                                     $15.8
Monroe County, MI
Wayne County, MI
                                      $0
                                      $0
                                     $0.9
                                     $14.4
Oakland County, MI
Wayne County, MI
                                      $0
                                      $0
                                     $0.2
                                     $30.5
Washtenaw County, MI
Wayne County, MI
                                      $0
                                      $0
                                     $0.2
                                     $14.9
Atlantic County, NJ
Camden County, NJ
                                      $0
                                      $0
                                     $0.01
                                     $6.4
Burlington County, NJ
Camden County, NJ
                                      $0
                                      $0
                                     $0.02
                                     $10.3
Essex County, NJ
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $8.0
Gloucester County, NJ
Camden County, NJ
                                      $0
                                      $0
                                     $0.03
                                     $8.1
Hudson County, NJ
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $4.3
Middlesex County, NJ
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $13.5
Morris County, NJ
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $8.7
Somerset County, NJ
Union County, NJ
                                      $0
                                      $0
                                      $0
                                     $1.5
Bronx County, NY
New York County, NY
                                      $0
                                      $0
                                      $0
                                     $5.3
Kings County, NY
New York County, NY
                                      $0
                                      $0
                                      $0
                                     $10.4
Queens County, NY
New York County, NY
                                      $0
                                      $0
                                      $0
                                     $12.6
Belmont County, OH
Jefferson County, OH
                                      $0
                                      $0
                                     $0.7
                                     $7.1
Carroll County, OH
Jefferson County, OH
Stark County, OH
                                      $0
                                      $0
                                     $0.3
                                     $4.7
Clermont County, OH
Hamilton County, OH
                                      $0
                                      $0
                                      $0
                                     $9.2
Columbiana County, OH
Jefferson County, OH
Mahoning County, OH
Stark County, OH
                                      $0
                                      $0
                                     $1.6
                                     $7.6
Geauga County, OH
Cuyahoga County, OH
Summit County, OH
                                      $0
                                      $0
                                     $0.01
                                     $10.8
Harrison County, OH
Jefferson County, OH
                                      $0
                                      $0
                                     $0.05
                                     $9.1
Lake County, OH
Cuyahoga County, OH
                                      $0
                                      $0
                                     $0.01
                                     $6.0
Lorain County, OH
Cuyahoga County, OH
                                      $0
                                      $0
                                     $0.6
                                     $11.8
Medina County, OH
Cuyahoga County, OH
Summit County, OH
                                      $0
                                      $0
                                     $0.01
                                     $13.0
Montgomery County, OH
Butler County, OH
                                      $0
                                      $0
                                      $0
                                     $14.2
Portage County, OH
Cuyahoga County, OH
Mahoning County, OH
Stark County, OH
Summit County, OH
                                      $0
                                      $0
                                     $0.04
                                     $11.7
Preble County, OH
Butler County, OH
                                      $0
                                      $0
                                      $0
                                     $5.9
Warren County, OH
Butler County, OH
Hamilton County, OH
                                      $0
                                      $0
                                      $0
                                     $9.6
Bedford County, PA
Cambria County, PA
                                      $0
                                      $0
                                      $0
                                     $4.9
Blair County, PA
Cambria County, PA
                                      $0
                                      $0
                                      $0
                                     $8.3
Bucks County, PA
Lehigh County, PA
Philadelphia County, PA
                                      $0
                                      $0
                                      $0
                                     $14.1
Butler County, PA
Allegheny County, PA
Armstrong County, PA
Beaver County, PA
Mercer County, PA
                                      $0
                                      $0
                                     $0.03
                                     $14.5
Clarion County, PA
Armstrong County, PA
                                      $0
                                      $0
                                     $0.0
                                     $3.4
Clearfield County, PA
Cambria County, PA
                                      $0
                                      $0
                                      $0
                                     $5.6
Indiana County, PA
Armstrong County, PA
Cambria County, PA
                                      $0
                                      $0
                                     $0.06
                                     $6.8
Jefferson County, PA
Armstrong County, PA
                                      $0
                                      $0
                                     $0.0
                                     $6.9
Montgomery County, PA
Berks County, PA
Chester County, PA
Delaware County, PA
Lehigh County, PA
Philadelphia County, PA
                                      $0
                                      $0
                                     $17.2
                                     $17.2
Schuylkill County, PA
Berks County, PA
Dauphin County, PA
Lebanon County, PA
Lehigh County, PA
                                      $0
                                      $0
                                      $0
                                     $7.2
Somerset County, PA
Cambria County, PA
                                      $0
                                      $0
                                      $0
                                     $5.2
Westmoreland County, PA
Allegheny County, PA
Armstrong County, PA
Cambria County, PA
Washington County, PA
                                      $0
                                      $0
                                     $0.03
                                     $17.4
Hancock County, WV
Brooke County, WV
                                      $0
                                      $0
                                      $0
                                     $0.9
Ohio County, WV
Brooke County, WV
Marshall County, WV
                                      $0
                                      $0
                                      $0
                                     $4.4
Wetzel County, WV
Marshall County, WV
                                      $0
                                      $0
                                      $0
                                     $1.4
Total

                                      $0
                                      $0
                                     $22.3
                                    $539.7

Table 4A-3	Summary of Estimated Annual Control Costs for the Southeast (35 counties) for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/m[3] for 2032 (millions of 2017$)
County
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Jefferson County, AL
                                      $0
                                      $0
                                     $0.7
                                     $4.5
Talladega County, AL
                                      $0
                                      $0
                                      $0
                                     $0.3
Pulaski County, AR
                                      $0
                                      $0
                                      $0
                                     $12.8
Union County, AR
                                      $0
                                      $0
                                      $0
                                     $0.3
District of Columbia
                                      $0
                                      $0
                                      $0
                                     $7.1
Bibb County, GA
                                      $0
                                      $0
                                      $0
                                     $7.8
Clayton County, GA
                                      $0
                                      $0
                                      $0
                                     $5.4
Cobb County, GA
                                      $0
                                      $0
                                      $0
                                     $0.3
DeKalb County, GA
                                      $0
                                      $0
                                      $0
                                     $0.3
Dougherty County, GA
                                      $0
                                      $0
                                      $0
                                     $2.4
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $15.4
Fulton County, GA
                                      $0
                                      $0
                                     $3.1
                                     $29.9
Gwinnett County, GA
                                      $0
                                      $0
                                      $0
                                     $0.1
Muscogee County, GA
                                      $0
                                      $0
                                      $0
                                     $8.5
Richmond County, GA
                                      $0
                                      $0
                                      $0
                                     $5.6
Wilkinson County, GA
                                      $0
                                      $0
                                      $0
                                     $14.0
Wyandotte County, KS
                                      $0
                                      $0
                                      $0
                                     $0.2
Caddo Parish, LA
                                      $0
                                      $0
                                     $2.9
                                     $16.7
East Baton Rouge Parish, LA
                                      $0
                                      $0
                                      $0
                                     $2.9
Iberville Parish, LA
                                      $0
                                      $0
                                      $0
                                     $0.02
St. Bernard Parish, LA
                                      $0
                                      $0
                                      $0
                                     $0.9
West Baton Rouge Parish, LA
                                      $0
                                      $0
                                      $0
                                     $11.7
Hinds County, MS
                                      $0
                                      $0
                                      $0
                                     $0.2
Davidson County, NC
                                      $0
                                      $0
                                      $0
                                     $3.3
Mecklenburg County, NC
                                      $0
                                      $0
                                      $0
                                     $0.5
Wake County, NC
                                      $0
                                      $0
                                      $0
                                     $0.3
Tulsa County, OK
                                      $0
                                      $0
                                      $0
                                     $0.4
Greenville County, SC
                                      $0
                                      $0
                                      $0
                                     $0.6
Cameron County, TX
                                      $0
                                      $0
                                     $11.2
                                     $11.2
Dallas County, TX
                                      $0
                                      $0
                                      $0
                                     $0.2
El Paso County, TX
                                      $0
                                      $0
                                     $0.2
                                     $4.7
Harris County, TX
                                     $1.4
                                     $1.4
                                     $5.5
                                     $25.0
Hidalgo County, TX
                                     $2.7
                                     $2.7
                                     $26.6
                                     $26.6
Nueces County, TX
                                      $0
                                      $0
                                      $0
                                     $25.4
Travis County, TX
                                      $0
                                      $0
                                     $0.2
                                     $4.9
Total
                                     $4.1
                                     $4.1
                                     $50.4
                                    $250.6

Table 4A-4	Summary of Estimated Annual Control Costs for Adjacent Counties in the Southeast (32 counties) for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/m[3] for 2032 (millions of 2017$)
County
Adjacent Counties
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Bartow County, GA
Cobb County, GA
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $8.4
Carroll County, GA
Fulton County, GA
                                      $0
                                      $0
                                      $0
                                     $11.1
Chattahoochee County, GA
Muscogee County, GA
                                      $0
                                      $0
                                      $0
                                     $1.9
Chattooga County, GA
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $4.0
Cherokee County, GA
Cobb County, GA
Fulton County, GA
                                      $0
                                      $0
                                      $0
                                     $10.3
Coweta County, GA
Fulton County, GA
                                      $0
                                      $0
                                      $0
                                     $7.8
Crawford County, GA
Bibb County, GA
                                      $0
                                      $0
                                      $0
                                     $3.0
Douglas County, GA
Cobb County, GA
Fulton County, GA
                                      $0
                                      $0
                                      $0
                                     $5.0
Fayette County, GA
Clayton County, GA
Fulton County, GA
                                      $0
                                      $0
                                      $0
                                     $4.1
Forsyth County, GA
Fulton County, GA
Gwinnett County, GA
                                      $0
                                      $0
                                      $0
                                     $6.8
Gordon County, GA
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $5.3
Harris County, GA
Muscogee County, GA
                                      $0
                                      $0
                                      $0
                                     $7.0
Henry County, GA
Clayton County, GA
DeKalb County, GA
                                      $0
                                      $0
                                      $0
                                     $5.9
Houston County, GA
Bibb County, GA
                                      $0
                                      $0
                                      $0
                                     $11.0
Jones County, GA
Bibb County, GA
Wilkinson County, GA
                                      $0
                                      $0
                                      $0
                                     $6.1
Monroe County, GA
Bibb County, GA
                                      $0
                                      $0
                                      $0
                                     $6.1
Polk County, GA
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $4.1
Spalding County, GA
Clayton County, GA
                                      $0
                                      $0
                                      $0
                                     $4.0
Talbot County, GA
Muscogee County, GA
                                      $0
                                      $0
                                      $0
                                     $2.9
Twiggs County, GA
Bibb County, GA
Wilkinson County, GA
                                      $0
                                      $0
                                      $0
                                     $5.9
Walker County, GA
Floyd County, GA
                                      $0
                                      $0
                                      $0
                                     $4.8
Bossier Parish, LA
Caddo Parish, LA
                                      $0
                                      $0
                                      $0
                                     $8.0
De Soto Parish, LA
Caddo Parish, LA
                                      $0
                                      $0
                                      $0
                                     $8.2
East Feliciana Parish, LA
East Baton Rouge Parish, LA
West Baton Rouge Parish, LA
                                      $0
                                      $0
                                      $0
                                     $4.2
Pointe Coupee Parish, LA
Iberville Parish, LA
West Baton Rouge Parish, LA
                                      $0
                                      $0
                                      $0
                                     $5.9
Red River Parish, LA
Caddo Parish, LA
                                      $0
                                      $0
                                      $0
                                     $5.4
West Feliciana Parish, LA
West Baton Rouge Parish, LA
                                      $0
                                      $0
                                      $0
                                     $7.8
Brooks County, TX
Hidalgo County, TX
                                      $0
                                      $0
                                     $6.6
                                     $6.6
Hudspeth County, TX
El Paso County, TX
                                      $0
                                      $0
                                      $0
                                     $3.3
Kenedy County, TX
Hidalgo County, TX
                                      $0
                                      $0
                                     $4.3
                                     $4.3
Starr County, TX
Hidalgo County, TX
                                      $0
                                      $0
                                     $5.1
                                     $5.1
Willacy County, TX
Cameron County, TX
Hidalgo County, TX
                                      $0
                                      $0
                                     $2.3
                                     $2.3
Total

                                      $0
                                      $0
                                     $18.2
                                    $186.5

Table 4A-5	Summary of Estimated Annual Control Costs for the West (36 counties) for Alternative Primary Standard Levels of 10/35 g/ - m - [3] - , 10/30 g/ - m - [3] - , 9/35 g/ - m - [3] - , and 8/35 g/m[3] for 2032 (millions of 2017$)
County
                                     10/35
                                     10/30
                                     9/35
                                     8/35
Maricopa County, AZ
                                      $0
                                      $0
                                     $1.4
                                     $7.4
Pinal County, AZ
                                      $0
                                     $1.0
                                      $0
                                     $0.3
Santa Cruz County, AZ
                                      $0
                                      $0
                                      $0
                                     $0.09
Denver County, CO
                                      $0
                                      $0
                                      $0
                                     $2.2
Weld County, CO
                                      $0
                                      $0
                                      $0
                                     $0.05
Benewah County, ID
                                      $0
                                     $12.1
                                     $12.1
                                     $12.1
Canyon County, ID
                                      $0
                                     $1.1
                                      $0
                                     $9.7
Lemhi County, ID
                                      $0
                                      $0
                                      $0
                                      $0
Shoshone County, ID
                                      $0
                                      $0
                                      $0
                                      $0
Lewis and Clark County, MT
                                      $0
                                     $3.1
                                      $0
                                      $0
Lincoln County, MT
                                     $19.0
                                     $19.0
                                     $19.0
                                     $19.0
Missoula County, MT
                                      $0
                                      $0
                                     $1.1
                                     $15.8
Ravalli County, MT
                                      $0
                                     $3.0
                                      $0
                                     $0.1
Silver Bow County, MT
                                      $0
                                     $0.03
                                      $0
                                     $7.8
Douglas County, NE
                                      $0
                                      $0
                                      $0
                                     $0.02
Sarpy County, NE
                                      $0
                                      $0
                                      $0
                                     $0.1
Dona Ana County, NM