### 1



### November 7

, 201 2

MEMORANDUM

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

P erformance 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 result s in the final rule RIA. The A genc y’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.

### 2



### 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

- t o

- 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 + 1 000 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 + 2 00

.

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 2 0 ,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

### 3



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

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

of PM 2.5 

### and SO 2



### . 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) 2 

### If we were to incorporate t hese 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 mo netized 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 PM 2.5 941 $230,000 $560,000 $210,000 $500,000 $210 to $520 $190 to $470

PM 2.5 Precursors

SO 2 6,262 $29,000 $72,000 $27,000 $65,000 $180 to $450 $170 to $410

NO 2 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 PM 2.5 . 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, H ealth and Environmental Impacts Division. June. Available at

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

### 4



### Table 3 : Summary of Estimated Reductions in Health Incidences from PM 2.5 

### 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 emissi ons from additional energy usage.

### 5 

### 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%

### 6



### Figure 2: Total Monetized PM 2.5 

### Benefits Estimates for the Final CISWI Reconsideration in

2015

Table 4 shows the estimated costs and benefits for the reconsideration final

. T he 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) $1 20 $670 2008 7% 2015

$15 0 $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