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### November 7 , 2011
**MEMORANDUM SUBJECT:**  Regulatory Impact Results for the Reconsideration Proposal 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 anal yz ed the economic impacts and benefits of this proposed rule 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 result s in the final rule RIA. The A genc y’s economic model sugge sts average national price increases for industrial sectors are less than 0.0 008 percent , while average annual domestic production may fall by less than 0.0 005 percent . Because of higher domestic prices, imports slightly rise by 0.0006 percent and exports fall by 0.0006 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 proposed 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 CI SWI Proposed Reconsideration **Industry Sector U.S. Prices**  **U.S. Production Imports**  **U.S. Consumption Exports**  Energy 0.001%
- 0.001% 0.003%
- 0.001% 0.000% Nonmanufacturing 0.003%
- 0.001% 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 0.024%
- 0.010% 0.024%
- 0.006%
- 0.017% Chemicals 0.000%
- 0.001% 0.000%
- 0.001% 0.000% Plastics and Rubber 0.000%
- 0.001% 0.001%
- 0.001% 0.000% Nonmetallic Minerals 0.071%
- 0.017% 0.026%
- 0.010%
- 0.059% 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% 0.000% 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 propos al 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 cos t - to - sales percentages of more than 3 percent. For the reconsideration propos al onl y two of the five had cost
- to - sales percentages of more than 3 percent and the other three had small savings. This is not a significant impact on a substantial number of s mall entities. The change in employ

ment estimates between the final rule RI A and the reconsideration proposal is small . The estimated employ ment changes range between

− 500 to + 1000 employ ees, with a central estimate of + 300 employ ees for the final rule RI A. For the reconsideration proposal, the estimated employ ment changes range between

− 400 to + 900 employ ees, with a central estimate of + 2 00
. The health benefits were calculated using the methodology described in the final CI SWIRIA, 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, ecos ys tem impairmen t, 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 CI SWIRIA of the unquantified benefits as well as anal ys is limitations and uncertainties. These monetized benefits are approximately 4% lower than the final CI SWINSPS due to the slight decrease in emission reductions of PM 2.5 

### , SO 2 

### , and NOx.

### 3 **Table 2**  **: Summary of Monetized Benefits Estim ates for CISWI Reconsideration Proposal**  **in 2015 (2008$)**

**Pollutant Em** **issions**

**Reductio ns (tons)**  **Benefit**

**per ton (Pope,**  **3% )**  **Benefit**

**per ton (Laden,**  **3% )**  **Benefit per**

**ton (Pope, 7%**  **) Benefit** 

**per ton (Laden,**  **7% )**  **Total Monetized** 

**Benefits (m illions**  **2008$ at 3% )**  **Total Monetized**

**Benefits (m illions**  **2008$ at 7% )**  Direct PM 2.5 670 $230,000 $560,000 $210,000 $500,000 $150 to $370 $140 to $340 PM 2.5 Precursors SO 2 5,033 $29,000 $72,000 $27,000 $65,000 $150 to $360 $130 to $330 NO 2 5,405 $4,900 $12,000 $4,400 $11,000 $ 26.0 o $

64.0 $

24.0 o $

58.0 **Total $** 

**330 o**  **$**

**800 $** 

**300 o**  **$**

**720** *All estimates are for the implementation year (2015), and are rounded to tw o 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 particl e 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 includ e benefits from reducing HAP emissions or ozone benefits.

### 4 **Table 3 :**  **Summary of Estimated Reductions in Health Incidences from PM 2.5**  **for the**

**CISWI Reconsideration Proposal in 2015** ***** **Avoided Prem ature Mortality**  Pope et al. 37 Laden et al. 94 **Avoided Morbidity**  Chronic Bronchitis 25 Ac ute Myocardial Infarction 59 Hospital Admissions, Respiratory 9 Hospital Admissions, Cardiovascular 19 Em ergency Room Visits, Respiratory 35 Ac ute Bronchitis 59 Work Loss Days 4,900 Asthma Exacerbation 650 MRAD 29,000 Lo wer 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 mo dels 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** 

**Figure 2: Total Monetized PM 2.5**  

### Benefits Estimates for the **CISWI Reconsideration Proposal in 2015**  Energy recover unit

- solids 71% Energy recovery unit
- liquid/gas 13% Incinerator

3% Small, remote unit 0.02% Waste
- burning kiln 13%

### Table 4 shows the estimated costs and benefits for the reconsideration proposal.

net benefits are almost the same as at 7 percent and was $ 60 million

Table 4 . Summary

of Estimated Social Costs and Benefits **Category Primary**  **Estimate Benefits**  Annualized Monetized ($millions/year) **Costs** Annualized Monetized ($millions/year) $ 271 $ 271 **Net Benefits** Annualized Monetized ($millions/year) $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



### 6 

### shows the estimated costs and benefits for the reconsideration proposal. almost the same as for the final rule RI A, which was $ 30 million 60 million to $ 550 million at 3 percent. . Summary

of Estimated Social Costs and Benefits **Primary Estimate**  **Low**

**Estimate High** 

**Estimate Year** 

**Dollar Discount** 

**Rate** $ 300 $ 720 2008 $ 330 $ 800 2008 271 2008 271 2008

$ 30 $ 450 2008 $ 60 $ 530 2008 

### Laden et al.

Benefits estimates derived from 2 epidemiology functions and 12 expert functions


### T he estimated 30 million to $470 million

**Discount Rate**  **Period**

**Covered** 7% 2015 3% 2015 7% 2015 3% 2015 7% 2015 3% 2015 

### Laden et al.

Benefits estimates derived from 2 epidemiology functions and 12 expert functions