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November 7, 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.

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 -270 million dollars (2006$). For the final rule 

RIA, the change in surplus was -283 million dollars (2006$). Table 1 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 1. Price, Production, Import, and Export Changes Resulting from the CISWI 

Proposed Reconsideration

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

Energy 0.001% -0.001% 0.002% -0.001% 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 0.022% -0.009% 0.022% -0.005% -0.015%

 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 -0.001% -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 +900 employees, with a central estimate 

of +200.

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, 2.6 tons of lead, 1.8 tons of cadmium, 690 pounds of mercury, and 58 grams of 

dioxins/furans. Please refer to the full description in the final CISWI RIA of the unquantified 

 

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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benefits as well as analysis limitations and uncertainties. These monetized benefits are 

approximately 25% higher than the final CISWI NSPS due to the increased emission reductions 

of PM2.5 and SO2. Since the reconsideration proposal, we have updated the epidemiology studies 

used to calculate mortality and morbidity benefits in the PM NAAQS proposal RIA (U.S. EPA, 

2012)2If we were to incorporate these updates, the monetized benefits would likely decrease by 

less than 4 percent. More information on these updates can be found in the PM NAAQS proposal 

RIA. We provide the benefits results in Tables 2 and 3 and Figure 2. We also provide the 

breakdown of monetized benefits by subcategory in Figure 1

Table 2: 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 PM2.5 941 $230,000 $560,000 $210,000 $500,000 $210 to $520 $190 to $470

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 $390 to $940

*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). 2012. 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.
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Table 3: Summary of Estimated Reductions in Health Incidences from PM2.5 for the Final

CISWI Reconsideration in 2015*

Avoided Premature Mortality

Pope et al. 48

Laden et al. 120

Avoided Morbidity

Chronic Bronchitis 32

Acute Myocardial Infarction 76

Hospital Admissions, Respiratory 11

Hospital Admissions, Cardiovascular 24

Emergency Room Visits, Respiratory 45

Acute Bronchitis 77

Work Loss Days 6,300

Asthma Exacerbation 840

MRAD 37,000

Lower Respiratory Symptoms 920

Upper Respiratory Symptoms 690

*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

59%

Energy 

recovery unit 

- liquid/gas

11%

Incinerator

1%

Waste-burning 

kiln

29%
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Figure 2: Total Monetized PM2.5 Benefits Estimates for the Final CISWI Reconsideration in 

2015

Table 4 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 4. 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)

$390 $940 2008 7% 2015

$420 $1,000 2008 3% 2015

Costs

Annualized Monetized 

($millions/year)

$271 2008 7% 2015

$271 2008 3% 2015

Net Benefits

Annualized Monetized 

($millions/year)

$120 $670 2008 7% 2015

$150 $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