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MEMORANDUM

TO: CISWI RECONSIDERATION DOCKET

FROM: AMY LAMSON, RISK AND BENEFITS GROUP

SUBJECT: HEALTH BENEFITS FOR CISWI RECONSIDERATION PROPOSAL

DATE: 12/9/2011

Due to time limitations under the court-ordered schedule, we were unable to fully update the RIA for 

the CISWI reconsideration proposal. We provide this memo to the docket as documentation of the estimated 

health benefits to support the preamble and the communication materials. These health benefits were 

calculated using the methodology described in the final CISWI RIA, which is available at

http://www.epa.gov/ttnecas1/regdata/RIAs/CISWIRIAfinal110221_psg2.pdf, using the revised emission 

reductions estimated for the reconsideration proposal. We were unable to estimate the benefits from reducing 

exposure to HAPs and ozone, ecosystem impairment, and visibility impairment, including reducing 22,000 tons 

of carbon monoxide, 590 tons of HCl, 3.1 tons of lead, 1.6 tons of cadmium, 290 pounds of mercury, and 94 

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 4% lower than the 

final CISWI NSPS due to the slight decrease in emission reductions of PM2.5, SO2, and NOx.

Table 1: Summary of Monetized Benefits Estimates for CISWI Reconsideration Proposal

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 PM2.5 670 $230,000 $560,000 $210,000 $500,000 $150 to $370 $140 to $340

PM2.5 Precursors

SO2 5,033 $29,000 $72,000 $27,000 $65,000 $150 to $360 $130 to $330

NO2 5,405 $4,900 $12,000 $4,400 $11,000 $26.0 to $64.0 $24.0 to $58.0

Total $330 to $800 $300 to $720

*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.
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Table 2: Summary of Estimated Reductions in Health Incidences from PM2.5 for the

CISWI Reconsideration Proposal in 2015*

Avoided Premature Mortality

Pope et al. 37

Laden et al. 94

Avoided Morbidity

Chronic Bronchitis 25

Acute Myocardial Infarction 59

Hospital Admissions, Respiratory 9

Hospital Admissions, Cardiovascular 19

Emergency Room Visits, Respiratory 35

Acute Bronchitis 59

Work Loss Days 4,900

Asthma Exacerbation 650

MRAD 29,000

Lower Respiratory Symptoms 710

Upper Respiratory Symptoms 530

*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. 

Figure 1: Breakdown of Monetized Benefits by Subcategory

Energy recover unit 

- solids

71%

Energy recovery 

unit - liquid/gas

13% Incinerator

3%

Small, remote unit

0.02%

Waste-burning kiln

13%
Figure 2: Total Monetized PM2.5 Benefits Estimates for the 

$0

$200

$400

$600

$800

$1,000

$1,200

Pope et al.

Millions (2008$)

Benefits estimates derived from 2 epidemiology functions and 12 expert functions

3% DR

7% DR

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Benefits Estimates for the CISWI Reconsideration Proposal in 2015

Laden et al.

Benefits estimates derived from 2 epidemiology functions and 12 expert functions