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December 18, 2012

MEMORANDUM

SUBJECT: Regulatory Impact Results for the Reconsideration Final Rule for Standards of 

Performance for New Stationary Sources and Emission Guidelines for Existing 

Sources: Commercial and Industrial Solid Waste Incineration Units

FROM: Tom Walton

Economist

AEG (C439-02)

TO: Toni Jones

 Environmental Engineer

FIG ( E143-03)

The EPA analyzed the economic impacts and benefits of this reconsideration final rule 

using the methodology that was discussed in the original final rule RIA and in the preamble to 

the original final rule. See FR 76 15704.

Changes Since 2010 Final Rule to Emission Reductions and Engineering Costs 

The changes in emission reductions and annual engineering costs in the final CISWI 

reconsideration are the result of revisions made to the CISWI unit inventory since promulgation 

of the March 2011 final rule. Since the March 2011 final rule, some units were identified that 

were not previously in the CISWI inventory database, some units were removed from the 

inventory, and one unit was moved from one subcategory to another . Making these changes 

resulted in 1 additional incinerator, 14 additional small remote incinerators, 8 fewer energy 

recovery units burning solid waste, no change in the number of energy recovery units burning 

liquid waste, and 11 additional waste-burning kilns. Altogether, the current CISWI inventory 

comprises 18 more units than the inventory at the time the March 2011 final rule was 

promulgated. If all units choose to comply with the rule, the resulting incremental cost impact for 

the revised inventory of CISWI units to comply with the final amended rule is approximately 

184 million dollars in capital expenditures and 42 million dollars per year in total annual costs. 

The changes in emission reductions and annual engineering costs in the final CISWI 

reconsideration are mainly the result of revisions made to the emission limits due to receiving 

new data, subcategory inventory changes, and changes to the emissions monitoring provisions. 

Incremental annual engineering costs for liquid/gas burning energy recover units decreased by 

approximately $219,000 because a lower baseline CO emission concentration was determined 
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for one of the units, thus eliminating the need for an oxidation catalyst to meet the new CO limit. 

Incremental annual engineering costs for energy recover units burning solids decreased by about 

$70 million because eight units were cut from the inventory and a revised activated carbon 

injection cost algorithm was used in estimating costs. Incremental annual engineering costs for 

incinerators increased by about $340,000 because of a more stringent CO limit, which prompted 

the need for afterburner retrofits on units that can’t meet the revised limit. Incremental annual 

engineering costs for small remote units increased by approximately $3.2 million; although 

limits became less stringent and fewer controls were required per unit, the additional annual 

costs required for an additional 14 units to comply ($3.7 million) outweighed the cost reduction 

from decreased control requirements ($498,000). Incremental annual engineering costs for 

waste-burning kilns increased by about $109 million because additional wet scrubbers, activated 

carbon injection, regenerative thermal oxidizers, and fabric filter improvements were required 

for the original 12 units to meet revised limits, and an additional 11 units were added to the 

inventory, many of which require similar controls to meet the revised limits. 

Table 1 shows the changes in emission reductions of directly emitted PM2.5, SO2, and 

NOx. Table 2 shows an estimate of the changes in monetized benefits associated with the 

emission reductions and engineering costs in the final CISWI reconsideration.

Table 1. Changes in Emission Reductions for the Final CISWI Reconsiderationa

Direct PM2.5 

(tons per year)

SO2

(tons per year)

NOx

(tons per year)

Final CISWI Rule (March 2011) 759 5,259 5,734

Changes due to increase in scope 

(addition of 18 units)

+98 +970 -8

Changes due to provision changes in this final reconsideration +60 +33 -327

Net changes since final rule +158 +1,003 -335

Final CISWI Reconsideration 917 6,262 5,399

a We provide only the emission changes associated with these 2 pollutants in this table because the other pollutants 

(e.g., Cd, CO, HCl, Pb, Hg, D/F) were not monetized in the RIA.
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Table 2. Changes in Benefits and Costs for the Final CISWI Reconsideration

Monetized Benefits in 2015a Annual Engineering 

Costsb

3% discount rate 7% discount rate (considering fuel savings)

Final CISWI Rule (March 2011) $360 to $870 million $320 to $790 million $218 million

Changes due to increase in scope 

(addition of 18 units)

+$51 to $120 million +$46 to $110 million +$30 million

Changes due to provision changes in this 

final reconsideration +$13 to $32 million +12 to $29 million +$10 million

Net changes since final rule +$64 to $160 million +58 to $140 million $40 million

Final CISWI Reconsideration $420 to $1,000 

million $380 to $930 million $258 million

a These benefits do not include benefits associated with reduced exposure to HAP, direct exposure to SO2, visibility 

impairment, or ecosystem effects. These benefits reflect the final rule, which were 4% higher than shown in the 

RIA.

b Minimum and maximum fuel savings reflect a range of fuel prices for the final reconsideration. These costs reflect 

the final rule, which were 22% lower than shown in the RIA.

We estimated the total monetized benefits for the final CISWI RIA (March 2011) to be 

$340 million to $830 million at 3 percent discount rate and $310 million to $750 million at 7 

percent discount rate. However, EPA noted that the RIA did not incorporate the final engineering 

costs and emission reductions, which would decrease the engineering costs by approximately 

22% and increase the monetized benefits by approximately 4%. For this final reconsideration, we 

estimate the total monetized benefits to be $420 million to $1 billion at 3 percent discount rate 

and $380 million to $930 million at 7 percent discount rate. All estimates are in 2008$.

Revised Economic Impacts

The market impact results are very similar to the results in the final rule RIA. The 

Agency’s economic model suggests average national price increases for industrial sectors are 

less than 0.001 percent, while average annual domestic production may fall by less than 0.001 

percent. Because of higher domestic prices, imports slightly rise by 0.001 percent and exports 

fall by 0.001 percent. The change in US surplus is now -258 million dollars (2006$). For the 

final rule RIA, the change in surplus was -283 million dollars (2006$). Table 3 provides the 

price, production, import, and export changes for this final reconsideration rule, which are very 

close to the estimated changes for the final rule RIA.
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Table 3. Price, Production, Import, and Export Changes Resulting from the Final CISWI 

Reconsideration

Industry Sector U.S. Prices U.S. Production Imports U.S. Consumption Exports

Energy 0.001% -0.001% 0.002% 0.000% 0.000%

Nonmanufacturing 0.004% -0.001% 0.003% 0.000% -0.003%

Manufacturing

 Food, beverages, and textiles 0.001% -0.001% 0.001% 0.000% 0.000%

 Lumber, paper, and printing 0.020% -0.009% 0.021% -0.005% -0.014%

 Chemicals 0.000% -0.001% 0.000% -0.001% 0.000%

 Plastics and Rubber 0.000% -0.001% 0.000% -0.001% 0.000%

 Nonmetallic Minerals 0.087% -0.020% 0.032% -0.012% -0.072%

 Primary Metals 0.001% -0.001% 0.001% -0.001% -0.001%

 Fabricated Metals 0.000% 0.000% 0.000% 0.000% 0.000%

 Machinery and Equipment 0.000% 0.000% 0.000% 0.000% 0.000%

 Electronic Equipment 0.000% 0.000% 0.000% 0.000% 0.000%

 Transportation Equipment 0.000% 0.000% 0.000% 0.000% 0.000%

Other 0.000% -0.001% 0.001% 0.000% 0.000%

Wholesale and Retail Trade 0.000% 0.000% 0.000% 0.000% 0.000%

Transportation Services 0.000% -0.001% 0.000% 0.000% 0.000%

Other Services 0.000% 0.000% 0.000% 0.000% 0.000%

The results for sales tests for small businesses are lower for the reconsideration final than 

those calculated for the final rule. The number of small entities affected by the rule dropped from 

nine to five. For the final rule, four of the nine had cost-to-sales percentages of more than 3 

percent. For the reconsideration final only one of the five had a cost-to-sales percentage of more 

than 3 percent and the other four had small savings. This is not a significant impact on a 

substantial number of small entities.

The change in employment estimates between the final rule RIA and the reconsideration 

final is small. The estimated employment changes range between −500 to +1000 employees, 

with a central estimate of +300 employees for the final rule RIA. For the reconsideration final, 

the estimated employment changes range between −400 to +800 employees, with a central 

estimate of +200.

Revised Benefits

The health benefits were calculated using the methodology described in the final CISWI 

RIA (U.S. EPA, 2011) 1 using the revised emission reductions estimated for the final 

reconsideration. We were unable to estimate the benefits from reducing exposure to HAPs and 

ozone, ecosystem impairment, and visibility impairment, including reducing 20,000 tons of 

carbon monoxide, 780 tons of HCl, 2.5 tons of lead, 1.8 tons of cadmium, 680 pounds of 

 

1 U.S. Environmental Protection Agency (U.S. EPA). 2011. Regulatory Impact Analysis: Standards of Performance 

for New Stationary Sources and Emission Guidelines for Existing Sources: Commercial and Industrial Solid 

Waste Incineration Units. February. Available at 

http://www.epa.gov/ttnecas1/regdata/RIAs/CISWIRIAfinal110221_psg2.pdf
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mercury, and 58 grams of dioxins/furans. Please refer to the full description in the final CISWI 

RIA of the unquantified benefits as well as analysis limitations and uncertainties. These 

monetized benefits are approximately 18% higher than the final CISWI NSPS due to the 

increased emission reductions of PM2.5 and SO2. Since the reconsideration proposal, we have 

made several updates to the approach we use to estimate mortality and morbidity benefits in the 

PM NAAQS RIAs (U.S. EPA, 2012a,b)2,3, including updated epidemiology studies, health 

endpoints, and population data. Although we have not re-estimated the benefits for this rule to 

apply this new approach, these updates generally offset each other, and we anticipate that the 

rounded benefits estimated for this rule are unlikely to be different than those provided below. 

More information on these updates can be found in the PM NAAQS proposal RIA. We provide 

the benefits results in Tables 4 and 5 and Figure 2. We also provide the breakdown of monetized 

benefits by subcategory in Figure 1.

Table 4: Summary of Monetized Benefits Estimates for the Final CISWI Reconsideration 

in 2015 (2008$)

Pollutant

Emissions 

Reductions 

(tons)

Benefit 

per ton 

(Pope, 

3%)

Benefit 

per ton 

(Laden, 

3%)

Benefit 

per ton 

(Pope, 

7%)

Benefit 

per ton 

(Laden, 

7%)

Total Monetized 

Benefits (millions 

2008$ at 3%)

Total Monetized 

Benefits (millions 

2008$ at 7%)

Direct 

PM2.5 

917 $230,000 $560,

000

$210,

000

$500,

000

$

210

t

o

$5

10

$

190

t

o

$

460

PM2.5 Precursors

SO2 6,262 $29,000 $72,000 $27,000 $65,000 $180 to $450 $170 to $410

NO2 5,399 $4,900 $12,000 $4,400 $11,000 $26 to $64 $24 to $58

Total $420 to $1,000 $380 to $930

*All estimates are for the implementation year (2015), and are rounded to two significant figures so numbers may 

not sum across columns. These models assume that all fine particles, regardless of their chemical composition, are 

equally potent in causing premature mortality because the scientific evidence is not yet sufficient to allow 

differentiation of effect estimates by particle type. The benefit per ton estimates vary because each ton of precursor 

reduced has a different propensity to become PM2.5. The monetized benefits incorporate the conversion from 

precursor emissions to ambient fine particles. These estimates do not include benefits from reducing HAP emissions 

or ozone benefits. 

 

2 U.S. Environmental Protection Agency (U.S. EPA). 2012a. Regulatory Impact Analysis for the Proposed Revisions 

to the National Ambient Air Quality Standards for Particulate Matter. EPA-452/R-12-003. Office of Air Quality 

Planning and Standards, Health and Environmental Impacts Division. June. Available at 

http://www.epa.gov/ttnecas1/regdata/RIAs/PMRIACombinedFile_Bookmarked.pdf.

3 U.S. Environmental Protection Agency (U.S. EPA). 2012b. Regulatory Impact Analysis for the Final Revisions to 

the National Ambient Air Quality Standards for Particulate Matter. EPA-452/R-12-003. Office of Air Quality 

Planning and Standards, Health and Environmental Impacts Division. December. Available at 

http://www.epa.gov/pm/2012/finalria.pdf.
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Table 5: Summary of Estimated Reductions in Health Incidences from PM2.5 for the Final

CISWI Reconsideration in 2015*

Avoided Premature Mortality

Pope et al. 47

Laden et al. 120

Avoided Morbidity

Chronic Bronchitis 32

Acute Myocardial Infarction 75

Hospital Admissions, Respiratory 11

Hospital Admissions, Cardiovascular 24

Emergency Room Visits, Respiratory 45

Acute Bronchitis 76

Work Loss Days 6,200

Asthma Exacerbation 830

MRAD 37,000

Lower Respiratory Symptoms 910

Upper Respiratory Symptoms 680

*All estimates are for the analysis year (2015) and are rounded to whole numbers with two significant figures. These 

models assume that all fine particles, regardless of their chemical composition, are equally potent in causing 

premature mortality because the scientific evidence is not yet sufficient to allow differentiation of effect estimates 

by particle type. These estimates do not include benefits from reducing HAP emissions and ozone exposure, nor 

energy disbenefits associated with the increased emissions from additional energy usage. 
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Figure 1: Breakdown of Monetized Benefits by Subcategory

Energy recover 

unit - solids

55%

Energy recovery 

unit - liquid/gas

11%

Incinerator

1%

Waste-burning 

kiln

33%
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Figure 2: Total Monetized PM2.5 Benefits Estimates for the Final CISWI Reconsideration 

in 2015

Revised Net Benefits

Table 6 shows the estimated costs and benefits for the reconsideration final. The 

estimated net benefits are higher than the final rule RIA, which was $30 million to $470 million 

at 7 percent and was $60 million to $550 million at 3 percent.

Table 6. Summary of Estimated Social Costs and Benefits

Category Primary 

Estimate

Low 

Estimate

High 

Estimate

Year 

Dollar

Discount 

Rate

Period 

Covered

Benefits

Annualized Monetized 

($millions/year)

$380 $930 2008 7% 2015

$420 $1,000 2008 3% 2015

Costs

Annualized Monetized 

($millions/year)

$258 2008 7% 2015

$258 2008 3% 2015

Net Benefits

Annualized Monetized 

($millions/year)

$120 $670 2008 7% 2015

$160 $770 2008 3% 2015

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

Pope et al.

Laden et al.

Millions (2008$)

Benefits estimates derived from 2 epidemiology functions and 12 expert 

functions

3% DR

7% DR