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November 7, 2011

MEMORANDUM

SUBJECT: Regulatory Impact Results for the Reconsideration Proposal 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 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 results in the final rule RIA. The Agency’s

economic model suggests average national price increases for industrial sectors are less than 

0.0008 percent, while average annual domestic production may fall by less than 0.0005 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.
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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% 0.003% -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 proposal 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 proposal only 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 small entities.

The change in employment estimates between the final rule RIA and the reconsideration 

proposal 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 

proposal, 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 reconsideration proposal. We were unable to estimate the 

benefits from reducing exposure to HAPs and ozone, ecosystem impairment, 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 CISWI RIA of the unquantified benefits as well as analysis 

limitations and uncertainties. These monetized benefits are approximately 4% lower than the 

final CISWI NSPS due to the slight decrease in emission reductions of PM2.5, SO2, and NOx.
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Table 2: Summary of Monetized Benefits Estimates for CISWI Reconsideration Proposal 

in 2015 (2008$)

Pollutant

Emissions 

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 (millions 

2008$ at 3%)

Total Monetized 

Benefits (millions 

2008$ at 7%)

Direct 

PM2.5 

670 $230,000 $560,000 $210,000 $500,000 $150 to $370 $140 to $340

PM2.5

Precursors

SO2 5,033 $29,000 $72,000 $27,000 $65,000 $150 to $360 $130 to $330

NO2 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 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. 
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Table 3: Summary of Estimated Reductions in Health Incidences from PM2.5 for the

CISWI Reconsideration Proposal in 2015*

Avoided Premature Mortality

Pope et al. 37

Laden et al. 94

Avoided Morbidity

Chronic Bronchitis 25

Acute Myocardial Infarction 59

Hospital Admissions, Respiratory 9

Hospital Admissions, Cardiovascular 19

Emergency Room Visits, Respiratory 35

Acute Bronchitis 59

Work Loss Days 4,900

Asthma Exacerbation 650

MRAD 29,000

Lower 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 

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

Figure 2: Total Monetized PM2.5 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

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shows the estimated costs and benefits for the reconsideration proposal.

almost the same as for the final rule RIA, 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

The 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