OMB EMAIL CORRESPONDENCE (4 of 4)

*Note, Attached memo is a draft version only. The f inal 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/U SEPA/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 Divis ion Phone: 919-541-0964

"Higgins, Cortney" ---05/21/2012 11:02:13 AM---Is i t 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/U SEPA/US@EPA

Date: 05/21/2012 11:02 AM

Subject:RE: RIA for CISWI

Is it possible to get a word version of this docume nt? 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 i n this document, thus I am also including the corresponding update that we wil l need to change in the preamble to reflect these m inor 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 Benefits 2 $460

to $1,100 $420

to $1,000

Total Social Costs 3 $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, a nd 93 grams of dioxins/furans) Health effects from exposure to criteria pollutants (23,000 tons of CO

, 7,300 tons of SO 2 , 7,200 tons of NO 2 , 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 disp osal assumption.

2 The total monetized benefits reflect the human hea lth benefits associated with reducing
exposure to PM 2.5 through reductions of PM 2.5 precursors such as directly emitted particles,

SO 2 , and NOx. It is important to note that the monetiz ed benefits include many but not all

health effects associated with PM 2.5 exposure. Monetized benefits are shown as a range from Pope et al. (2002) to Laden et al. (2006). These mo dels assume that all fine particles, regardless of their chemical composition, are equal ly potent in causing premature mortality
because there is no clear scientific evidence that would support the development of differential effects estimates by particle type. Th ese estimates include the energy disbenefits valued at $3.8 million (using the 3 per cent discount rate), which do not change

the rounded totals. CO 2 -related disbenefits were calculated using the “soc ial 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 fo r both discount rates.

Regards,

Amy

Amy Hambrick Fuels and Incineration Group US EPA / OAQPS / Sector Policies and Programs Divis ion
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 a s ““Regulatory Impact Analysis: Standards of Perfor mance for New Stationary Sources and Emission Guidelines for Existing Sources: Commercia l 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 G uidelines for Existing
Sources: Commercial and Industrial Solid Waste Incinerat ion 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 t his 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 resu lts in the final rule RIA. The Agency’s economic model suggests average national price increases fo r 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 do llars (2006$). For the final rule RIA, the change in surplus was -283 million dollars (2006$). T able 1 shows the price, production, import, and export changes for this final recon sideration, which are very close to the estimated changes for the final rule RIA.

### 2



### Table 1. Price, Production, Import, and Export Changes Resu lting 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 ent ities 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 co st-to-sales percentages of more than 3 percent and three had small savings. This is not a signifi cant impact on a substantial number of

small entities.

The change in employment estimates between the final r ule 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 R IA. For the reconsideration final, the estimated employment changes range between −400 to +900 emplo yees, with a central estimate

of +200.

The health benefits were calculated using the methodolo gy described in the final CISWI RIA,

which is available at http://www.epa.gov/ttnecas1/regdata/RIAs/CISWIRIAfinal110221_psg2.pd f, using the revised

emission reductions estimated for the final reconsiderat ion. We were unable to estimate the benefits from reducing exposure to HAPs and ozone, ecosyste m impairment, and visibility impairment, including reducing 23,000 tons of carbon monoxide, 790 ton s 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 un quantified 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 PM 2.5 

### , SO 2 

### , 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 PM 2.5 915 $230,000 $560,000 $210,000 $500,000 $210 to $510 $190 to $460

PM 2.5 Precursors

SO 2 7,338 $29,000 $72,000 $27,000 $65,000 $220 to $530 $200 to $480

NO 2 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 f ine particles, regardless of their chemical compositio n, are equally potent in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by particle type. T he 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 f rom precursor emissions to ambient fine particles. These estimates do not include benefits from reducing HAP emi ssions

or ozone benefits.

### 4



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

### 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. The se models assume that all fine particles, regardless of th eir chemical composition, are equally potent in causing premature mortality because the scientific evidence is n ot yet sufficient to allow differentiation of effect e stimates 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 Subcate gory

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 PM 2.5 

### Benefits Estimates for the Final CISWI Reconsiderat ion 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 pe rcent.

Table 4. Summary of Estimated Social Costs and Bene fits

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 func tions and 12 expert functions

3% DR
7% DR