SAB C-VPESS Subcommittee on Valuation for National Rulemaking

April 18, 2006

Participants: Rick Freeman, Hal Mooney, Bill Ascher, Doug MacLean Bob
Huggett; by phone: Paul Slavic, Kerry Smith, Rob Stavins

Action items

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  **Timetable for Next steps**                    

  Rick -- send out revised annotated outline      4/20

  Subcommittee comments to Rick and Angela        4/27

  Completed draft to AN                           5/1
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1.  Hal will develop on stressors to add to Bob's bullets summarizing
    ecological impacts to include/highlight discussion of additional

2.  Hal will revise bullets to address importance of using model like
    Aquatox to identify potential effects and quantify effects of
    concern

3.  Hal will work up salmon as well as trout examples of how stressors
    impact a species and the related ecological effects

4.  Bob and Hal will work up bullets describing how Agency might
    sort/characterize ecological effects (e.g., irreversibility, scale);
    how to use benefit assessments used for other kinds of effects in
    the case of this rule

5.  Bill and Doug will develop list of potential impacts and concerns \~
    ecological services

6.  Bill and Paul will develop bullets on social science options for how
    to identify and quantify relevant human values associated with
    ecosystem services for national rulemaking

7.  Hal will survey state and international regulations to see if values
    related to aquaculture can be revealed from those sources.

8.  Bob and Hall will address issue of excluding some categories (e.g.,
    ponds, shellfish) and discuss their potential ecological impacts

9.  Kerry will draft 1-page analysis plan suggesting how to use
    region-specific economic models of different types (e.g., conjoint
    analysis, random utility models) with both Qual2E and Aquatox, as
    well as Mitchell and Carson with both model results, and how such an
    analysis plan might be used strategically by the Agency

10. Angela will

    a.  Follow-up to get list of inputs and outputs of Aquatox for fish
        pond default case

    b.  Ask: Why were ponds excluded -- b/c they don't have continuous
        outflow?

    c.  Ask: Would OMB PRA review be required for negotiated rulemaking?

    d.  Ask: How do EPA and the courts see aquaculture effluent
        guidelines fitting with state and local regulations?

    e.  Why were mollusks excluded?

Other points of discussion

-   Aquaculture is a new issue -- opinions may still be forming

-   Actual rule has minor impact on environmental problems associated
    with Aquaculture

-   Source example should focus on how EPA can do benefit assessments
    more effectively

-   Focus might be: if aquaculture was a bigger issue -- could you value
    environmental protection

-   Economic analysis needs baseline hazards and how changes in the rule
    would affect those hazards

-   Qual2E focused on very limited set of outputs -- Total Suspended
    Solids

-   Some concern that WTP measures what people are willing to do, not
    what people "ought to do" -- general discussion of difference
    between normative view and willingness; WTP information only one
    datum that feeds into decision making

-   Are there ways to characterize ecological effects so that the most
    significant effects are apparent to the reader

-   How would one combine quantitative and non-quantitative approaches,
    show their usefulness, their deficiencies

-   Economic discussion could focus on

    1.  how to monetize recreational benefits fully; whether Agency's
        approach could be improved

    2.  How to monetize controls on metals, PCBs, drug uses, damage and
        failure of containment systems, drugs, pesticide and feed

    3.  How to assess benefits of controlling escapes

-   Email comments provided by Kerry Smith

    1.  agrees with Rob\'s point on the role of limited ecological
        modeling and results as a limit to the analysis

    2.  felt that in the national rules there was a tendency to use
        \'national\" benefit models because they provide the national
        coverage \--Mitchell/Carson then that has a cascading effect it
        filters the ecological outcomes that can be linked to that
        benefit measure \--one could use multiple models in the spirit
        of Rick\'s comment \--a national model and a regional model with
        more outcome measures \--compare the results of the national
        model for the regional model to gauge the types of errors in
        what is missed as a result of the decision for national coverage

    3.  this is part of a general point \--what are the strategic
        decisions that had to made for quantification of monetary values
        and which ones appear especially important based on the
        information available

> link between water quality and the outcomes of ecological models
>
> failure to take account of feedbacks
>
> scale of effects
>
> link between detail of the rule and the quantification of effects
>
> nature of the response functions to small changes in activities
>
> definition of what is an effect

-   Suggests lessons from the Section 812 "Prospective Study" where new
    methods, departures from established approaches are encouraged by
    case studies or sensitivity analyses done on pilot scale.

-   Experience with the 316b benefit analysis might offer suggestions
    for how to deal with escapements. Ecologists reviewing that rule
    were very uncomfortable with the Water Quality approach. Possibility
    to use model for renewable resources and examining impacts of
    potential escapements on native and non-native fish

-   Uncertainty analysis -- is there a role for "Benefits
    Characterization" along the lines of EPA's own guidance for "Risk
    Characterization" to clarify data quality and uncertainty issues.