OMB EMAIL CORRESPONDENCE (4 of 4) 

*Note, Attached memo is a draft version only. The final is available separately in the CISWI docket. 

From:

Amy Hambrick/RTP/USEPA/US

To:

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

Cc:

David Cozzie/RTP/USEPA/US@EPA, Teresa Clemons/RTP/USEPA/US@EPA

Date:

05/21/2012 04:39 PM

Subject:

RE: RIA for CISWI

HI Cortney, 

I have the word version of the reconsideration RIA memo. 

(See attached file: CISWImemo050118c.docx)

Best,

Amy

Amy Hambrick 

Fuels and Incineration Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964 

"Higgins, Cortney" ---05/21/2012 11:02:13 AM---Is it possible to get a word version of this document? There’s no size limit on files 

we can recei

From:

"Higgins, Cortney" <Cortney_Higgins@omb.eop.gov>

To:

Amy Hambrick/RTP/USEPA/US@EPA

Cc:

David Cozzie/RTP/USEPA/US@EPA, Teresa Clemons/RTP/USEPA/US@EPA

Date:

05/21/2012 11:02 AM

Subject:
RE: RIA for CISWI

Is it possible to get a word version of this document? There’s no size limit on files we can receive, if that’s the reason you sent a pdf.

Thanks,

Cortney

From: Amy Hambrick [mailto:Hambrick.Amy@epamail.epa.gov]

Sent: Monday, May 21, 2012 10:58 AM

To: Higgins, Cortney

Cc: David Cozzie; Teresa Clemons

Subject: Fw: RIA for CISWI

HI Cortney, 

Please see the attached CISWI RIA. Please note that we caught a few revisions that were just updated in this document, thus I am 

also including the corresponding update that we will need to change in the preamble to reflect these minor changes in net benefits. 

We can reflect this in a red line version.

(See attached file: RIACISWIrecon051812.pdf)

TABLE X. SUMMARY OF THE MONETIZED BENEFITS, SOCIAL COSTS AND NET BENEFITS FOR THE FINAL 

CISWI NSPS and EG IN 2015 (MILLIONS OF 2008$)1

3 percent Discount Rate

7 percent Discount Rate

Total Monetized Benefits2$460

to

$1,100

$420

to

$1,000

Total Social Costs3$270

$270

Net Benefits$190

to

$830

$150

to

$730

Non-monetized BenefitsHealth effects from exposure to HAP (790 tons of HCl, 2.6 tons of 

lead, 1.8 tons of cadmium, 740 pounds of mercury, and 93 grams of dioxins/furans)

Health effects from exposure to criteria pollutants (23,000 tons of CO, 7,300 tons of SO2, 

7,200 tons of NO2, and secondary formation of ozone) 

Ecosystem effects 

Visibility impairment 

1 All estimates are for the implementation year (2015), and are rounded to two significant 

figures. These results reflect the lowest cost disposal assumption.

2 The total monetized benefits reflect the human health benefits associated with reducing 

exposure to PM2.5 through reductions of PM2.5 precursors such as directly emitted particles, 

SO2, and NOx. It is important to note that the monetized benefits include many but not all 

health effects associated with PM2.5 exposure. Monetized benefits are shown as a range from 

Pope et al. (2002) to Laden et al. (2006). These models assume that all fine particles, 

regardless of their chemical composition, are equally potent in causing premature mortality 

because there is no clear scientific evidence that would support the development of 

differential effects estimates by particle type. These estimates include the energy 

disbenefits valued at $3.8 million (using the 3 percent discount rate), which do not change 

the rounded totals. CO2-related disbenefits were calculated using the “social cost of 

carbon”, which is discussed further in the RIA.
3 The methodology used to estimate social costs for one year in the multimarket model using 

surplus changes results in the same social costs for both discount rates.

Regards,

Amy

Amy Hambrick 

Fuels and Incineration Group 

US EPA / OAQPS / Sector Policies and Programs Division 

Phone: 919-541-0964 

From: "Higgins, Cortney" [Cortney_Higgins@omb.eop.gov]

Sent: 05/18/2012 09:02 PM GMT

To: David Cozzie

Cc: Amy Hambrick

Subject: RIA for CISWI

Hi Dave, 

Can you send me the RIA for the CISWI rule (cited as ““Regulatory Impact Analysis: Standards of Performance for New Stationary Sources and 

Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration Units.”)?

Thanks, 

Cortney

________________________________________________

Cortney Higgins 

Policy Analyst 

OMB/OIRA/NRE 

202.395.7856

chiggins@omb.eop.gov 
1 

April 26, 2012 

MEMORANDUM

SUBJECT: Regulatory Impact Results for the Reconsideration Final 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: Amy Hambrick 

 Environmental Engineer 

FIG ( E143-08) 

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

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

0.0006 percent, while average annual domestic production may fall by less than 0.0004 percent. 

Because of higher domestic prices, imports slightly rise by 0.0005 percent and exports fall by 

0.0005 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 shows the price, 

production, import, and export changes for this final reconsideration, 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 

Reconsideration Final 

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

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

Nonmanufacturing 0.003% 0.000% 0.002% 0.000% -0.002%

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 0.054% -0.013% 0.020% -0.008% -0.045%

 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% 0.000% 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 six. For the final rule, four of the nine had cost-to-sales percentages of more than 3 percent. 

For the reconsideration final only two of the six had cost-to-sales percentages of more than 3 

percent and three 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, 

which is available at 

http://www.epa.gov/ttnecas1/regdata/RIAs/CISWIRIAfinal110221_psg2.pdf, 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 23,000 tons of carbon monoxide, 790 tons of HCl, 2.6 tons of 

lead, 1.8 tons of cadmium, 740 pounds of mercury, and 93 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 35% higher than the 

final CISWI NSPS due to the increased emission reductions of PM2.5, SO2, and NOx. We 
3 

provide these results in Tables 2 to 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 PM2.5 915 $230,000 $560,000 $210,000 $500,000 $210 to $510 $190 to $460 

PM2.5 Precursors

SO2 7,338 $29,000 $72,000 $27,000 $65,000 $220 to $530 $200 to $480 

NO2 7,234 $4,900 $12,000 $4,400 $11,000 $35 to $86 $32 to $78 

 Total $460 to $1,100 $420 to $1,000

*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. 

 
4 

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. 51 

Laden et al. 130 

Avoided Morbidity 

Chronic Bronchitis 35 

Acute Myocardial Infarction 82 

Hospital Admissions, Respiratory 12 

Hospital Admissions, Cardiovascular 26 

Emergency Room Visits, Respiratory 49 

Acute Bronchitis 83 

Work Loss Days 6,800 

Asthma Exacerbation 910 

MRAD 40,000 

Lower Respiratory Symptoms 990 

Upper Respiratory Symptoms 750 

*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. 
5 

Figure 1: Breakdown of Monetized Benefits by Subcategory 

Energy recover unit 

- solids

51%

Energy recovery 

unit - liquid/gas

10%

Incinerator

1%

Small, remote unit

0.02%

Waste-burning kiln

38%
6 

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 almost the same as for 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) 

$420 $1,000 2008 7% 2015 

$460 $1,100 2008 3% 2015 

Costs 

Annualized Monetized 

($millions/year) 

$272 2008 7% 2015 

$272 2008 3% 2015 

Net Benefits 

Annualized Monetized 

($millions/year) 

$150 $730 2008 7% 2015 

$190 $830 2008 3% 2015 

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

$1,600

Pope et al.

Laden et al.

Millions (2008$)

Benefits estimates derived from 2 epidemiology functions and 12 expert functions

3% DR

7% DR