September 28, 1995
EPA-SAB-CAACAC-ADV-95-001
Ms. Carol Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Subject: Clean Air Act Compliance Analysis Council
(CAACAC) Advisory on Issues Associated with the
Section 812 Retrospective Study
Dear Ms. Browner:
On June 12-13, 1995, the Clean Air Act Compliance Analysis Council (CAACAC,
or the Council) of the Science Advisory Board (SAB) met at the Courtyard Marriott
Hotel in Crystal City, Virginia to address a number of issues associated with the
"Section 812 Retrospective Study", as described in the Clean Air Act Amendments of
1990. [This meeting included discussion of issues that were the subject of a May 18,
1995 meeting of its Physical Effects Review Subcommittee]. The goal of the "Study" is
to determine the costs and benefits which have accrued as a result of the original
Clean Air Act from 1970 through 1990. In a subsequent effort, the Agency will estimate
the future costs and benefits that are expected from the implementation of the 1990
amendments (i.e, the "Prospective Study").
Because this meeting was held at an ongoing stage in the development of the
Study, the Council has prepared this Advisory which summarizes the Council's views of
certain aspects of the "Study." An Advisory responds to the Agency's need for advice
on whether an effort is on the right track and whether alternatives need to be
considered at a critical stage, rather than at the end of a developmental effort. The
scope of an Advisory is intended to be narrowly drawn. This minimizes the potential
impact of providing early Council advice on an issue or program that will later be
reviewed by the Council as a final product.
Therefore, at the suggestion of the Physical Effects Review Subcommittee
(hereafter, the Subcommittee), the Agency provided its incomplete drafts of the costs
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and benefits of ecological and welfare effects, which were the basis for discussion at
the Subcommittee meeting on May 18, 1995. Because written documents existed, the
Council's activity could not be called a "consultation" per se. Because the documents
were not final and no formal charge had been agreed to, the exercise was not covered
by the rubric "review"; hence, we are transmitting an Advisory to you.
The Subcommittee has been reviewing the methods and results of the Agency's
analyses of the costs and benefits associated with health, ecological, and welfare
effects that will appear in the Retrospective Study. Under separate cover, the CAACAC
is submitting the Subcommittee's review of the exposure-response relationships
associated with health effects of criteria pollutants alone (EPA-SAB-CAACAC-095-022,
September 1995).
During the course of the review of the health effects of criteria pollutants, the
Subcommittee urged the Agency to come forward with the admittedly incomplete
analysis of the costs and benefits associated with ecological and welfare effects and
the health effects of air toxics. The intent was to provide in progress advice that could
be utilized immediately in preparing the documents for formal review by the Council.
The partial review of the health effects suggested to the Subcommittee that important
issues in the ecological and welfare effects analyses likely needed to be addressed as
soon as possible in order for the Agency to successfully complete its ecological and
welfare assessments. The Subcommittee also noted that there may be benefits that
are difficult to monetize and as a consequence, benefits may be underestimated.
Additionally, the Subcommittee observed that the methodology for conducting the
retrospective analysis for ecological and/or welfare effects has not been adequately
developed and prepared, so that the procedure by which welfare consequences will be
evaluated is unknown.
In short, the Subcommittee identified a number of issues during the public
meeting that would benefit from additional consideration by the Agency. Given the
early draft stage of the Agency documents, it does not seem fruitful or appropriate for
us to document all of our concerns/suggestions in this advisory. In general, the
discussion focused on a number of issues including the following:
a) The need to review, evaluate, and incorporate much more of the recent
years' literature
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b) The need to broadly address terrestrial (including agricultural and urban
areas) ecological impacts other than in forests
c) The need to more thoroughly address known effects, even when they
cannot now be monetized.
d) The need to address impacts of episodic peak loadings on ecosystems in
addition to cumulative loadings.
During the course of the meeting, the specifics of these concerns/suggestions
were conveyed clearly and forcefully to Agency personnel. We believe that our
remarks were well-received and appreciated. However, we wish to stress that during
our discussion (and the earlier physical effects review), it was obvious that there is a
pressing need for the allocation of more resources if the Agency is to properly meet the
demands of this Congressionally mandated study.
We trust that this advisory and particularly the exchange that took place at the
meeting will result in a tighter, more technically sound document for CAACAC review in
the coming months. We appreciate the openness with which the Agency personnel
participated in the exchange and look forward to a formal indication of their intent to
use this information and to arrange for a formal review by the Council at a later date.
Sincerely,
Dr. Morton Lippmaryn, /Chair
Physical Effects Review Subcommittee,
Clean Air Act Compliance
Analysis Council
r. Richard Schmalensee, Chair
Clean Air Act Compliance
Analysis Council
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