A  v
     &,
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON, D.C, 20460
                             November 19,1993
                                                            OFFICE OF THE ADMINISTRATOR
                                                             SCIENCE ADVISORY BOARD
EPA-SAB-EEAC-LTR-94-001

Honorable Carol M; Browner
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460

Subject:    Review of Economic Aspects of the proposed RIA for the RCRA
           Corrective Action Rule by the Environmental Economics Advisory
           Committee (also referred to as  CV-2)

Dear Ms. Browner:

      At the October,  1992 meeting of the SAB's Executive Committee (EC) the
Board was asked by the Office of Solid Waste  and Emergency Response (OSWER) to
review the methodology for the draft Regulatory Impact Analysis (RIA).  This
cost/benefit analysis is required prior to promulgation of the Agency's final Resource
Conservation and Recovery Act Corrective Action Rule.  The EC, recognizing the
importance, complexity, and novelty of OSWER's work and its multi-disciplinary
character, established  an ad hoc RCRA-RIA  Steering Committee (RRSC) to assure
that certain aspects of the RIA - In both methodology and application - received
appropriate attention from the relevant SAB committees.

      At a public meeting on January 29,1993, the RRSC concluded, on the basis of
presentations by and discussions with OSWER personnel, that four SAB individual
committees should review the major segments of the RCRA-RIA. Specifically, the
RRSC agreed to review: a) the contingent valuation fCV) methodology used in the
RCRA RIA analysis (CV-1, by the Environmental  Economics Advisory Committee
(EEAC)); b) the application of CV in the RCRA-RIA (CV-2, by the EEAC); c) the princi-
pal fate and transport model fMMSOILS). used in the RCRA-RIA (by the Environmen-
tal Engineering Committee (EEC));  d) the ecological risk assessment portion of the
RCRA-RiA (by the Ecological Processes and Effects Committee (EPEC)); and f) the
human health risk assessment portion of the RCRA-RIA (by the  Environmental Health
Committee (EHC)).

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      This letter comprises the report of the EEAC, which completed its review of the
analytical methodology for the draft RIA at its meeting of September 23, 1993,  The
Committee evaluated four aspects of the proposed economic methodologies, includ-
ing;

      a)    the desirability of disaggregate information as part of the development
            and presentation of benefit-cost  information in the RIA for a large,
            complex national rule

      b)    the exploration and presentation of "human health benefits," including
            both the cancer and non-cancer health effects associated with the
            proposed rule

      c)    the possibility of using the McClelland et al (1992) CV analysis as the
            basis for estimating the non-use values for groundwater cleanup on a
            national scale

      d)    the application of hedonic methods to evaluate the effects of contaminat-
            ed sites on residential property values (Hedonic models recognize that
            many commodities within the same broad categories, like houses and
            automobiles, for example, have different features. The models imply that
            the prices of products within each category should be related to the mix
            of features that each type of commodity has. The models are sometimes
            used to estimate people's willingness to pay for dimensions of environ-
            mental quality  that are location specific, such as air or water quality.)

      Overall, EPA staff are to be commended for a number of innovations in the
methodologies outlined for use in the full RIA  and illustrated with the examples in the
draft report. Especially notable from the perspective of the economic analysis were;

      a)    the recognition, as part of the human health benefit analysis (and associ-
            ated risk computations), that policies are not always effective

      b)    careful descriptions of both baseline  and "with-policy" effects in al!
            aspects of the  evaluation

      c)    attempting  to separate the effects of the sub-part  S rule from those of
            other initiatives

      d)    recognition of the  importance of  the extent of the market for benefits
            transfer

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      e)    full documentation of the econometric analysis associated with the
            hedonic property value models

      With respect to the development and presentation of national benefit-cost esti-
mates, the Committee recognizes that the RIA must, to the extent possible, represent
the aggregate benefits estimated to be associated with the proposed regulatory
alternative. Nonetheless, this goal does not preclude EPA staff from presenting
disaggregate information for the benefits and costs associated with different compo-
nents of the aggregate. For example, it should be possible to classify Solid Waste
Management Units (SWMU) by size, location, and other characteristics and to develop
the estimates according to these categories. This practice would facilitate evaluation
of the methods  used and improve the transferability of disaggregate results to the
aggregate level

      Classification of SWMU would also permit evaluation of the likely distributional
impacts of policy alternatives across different types of facilities and types of communi-
ties impacted.  The Committee recognizes that the limits implied by confidentiality
requires such disaggregation be conducted at levels that assure sites cannot be
identified.  However, this requirement does not preclude substantive effort to develop
informative decompositions for the policy alternatives.

      The Committee also recommends that in developing the benefit-cost analysis,
EPA staff should provide a more detailed description of the role of each type of
analysis, as well as more complete perspectives on the judgements made in develop-
ing estimates of benefits and oasts. For example, the Executive Summary of the draft
RIA notes that benefits estimates would likely be larger if the health effects were
monetized. In an apparent contradiction to the Summary, the Health Benefits chapter
(Chapter 7) indicates that monetizatfon was not undertaken because it was judged to
overlap the monetary measures developed using the avoiding cost model; no discus-
sion or explanation of these differing views are offered. Similarly, the hedonic esti-
mates are provided without developing their role in the comprehensive  benefit-oast
analysis nor their implications for further RIA analyses.

      These descriptions would permit a second type of evaluation associated with
the aggregations that must accompany an RIA evaluation at a national level. Moneti-
zation of multiple components of benefits can lead to double counting if the concepts
being measured and the rationale underlying each method are not well-understood
and well-documented. Discussion  of these concepts and rationale can provide a
means of avoiding this. Together with the presentation of the estimates, such a
discussion often allows plausibility  checks, particularly if one approach produces

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estimates that can be expected to provide an upper or lower bound on the estimates
of an alternative approach.

      The second major element of our review addressed the RIA's evaluation of the
benefits from avoiding adverse human health effects (the Committee prefers the term
"effects" to the term "benefits" as noted in the Technical Appendix). The RIA offers an
innovative analysis of exceptionally difficult issues.  The analysis is to be commended
for recognizing and developing methods to reflect the fact that regulatory policies are
not always completely effective.  While there are also notable features in this compo-
nent of the RIA, the Committee believes that there are also three important limitations.
First the Committee concludes that efforts to monetize the mortality risks reduction
(e.g., reduction in statistical lives) should be included in the RIA,  The Agency's
Guidelines for Preparing Regulatory Impact Analyses discusses these procedures and
recommends monetization, but the  RIA does not do so.  Monetizing of health effects is
also an Integral part of the benefit-cost analyses  being undertaken for the Clean Air
Act evaluation currently under way.

      The argument that averting cost and monetized health effects would imply
double counting is correct,  but it ignores the role these estimates could serve as
bounds on estimates of benefits.  The inability to monetize ail health effects should not
preclude this effort.  It may be possible to offer better resolution about how benefits
might vary across different classes  of facilities, regions,  or other characteristics of the
SWMU through quantification of the health effects than by using  information on
averting expenditures (because the exposed population and response estimates seem
more firmly grounded in  scientific evidence than the averting  expenditure information),

      Aggregation of non-cancer health effects based on exeeedances of the chronic
reference  dose provides an index that is no more than informative.  The Committee
has been advised that there are a number of judgements used in developing the
hazard indexes from hazard quotients (i.e., estimates of individual exposures to the
chronic reference dose) for specific substances.  The Committee recommends that
efforts to aggregate across substances be avoided and  disaggregated information for
classes of substances be reported instead.

      Finally, the cost effectiveness analysis and presentation of overall impacts
aggregates effects over a 128 year time horizon. The Committee recommends that
alternative strategies be  investigated for dealing with the effects of this Jong time
horizon, including: discounting the measures of physical effects before gauging cost
effectiveness; calculating cost effectiveness based on a year-by-year cost effective-
ness and these ratios then discounted to a base  period or an annualization of all
factors relevant to a comparison.

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      (The Committee also identified some further technical issues on the health
benefits topic, as well as on the next two aspects of our review; a detailed summary is
enclosed as a Technical Appendix to this letter,}

      The EEAC devoted considerable effort to the issue of using the McClelland et
a/. CV estimates as a basis for making national estimates of non-use values for
ground water cleanup.  Because the focus of the McClelland et al. effort was to
develop per-household estimates of these non-use values, a number of issues would
need to be addressed to use the results for national estimates relevant to the RIA.
The Committee's detailed findings on these issues are provided in the Technical
Appendix.

      Based on our earlier review of the McClelland ef a/, study itself, and two further
issues raised by the methodology proposed for adopting the McClelland et al results
for use in the RIA, the Committee believes that the  McClelland et al. estimates cannot
be used for the intended purposes.  The RIA's evaluation primarily deals with benefits
from cleaning up over a long  period of time (and in  some cases partially) groundwater
contaminated by industrial facilities.  The McClelland et al. study focuses on municipal
sources and describes a situation with instantaneous cleanup.  Both issues are very
important features of the problem and past literature suggests that they are likely to be
important to people's willingness to pay for cleanup. Unfortunately, simple adjust-
ments do not appear to be possible.

      Last, a key element  in the development of aggregate estimates is the determi-
nation of the number of households which would be willing to pay (a non-use value)
for cleanup of the groundwater.  This factor is the key determinant of the wide range
of estimates of aggregate non-use values.  No specific evidence has been developed
on how to determine the number of these households.  The original  McClelland el a/.
study focused on per-household values. Subsequent work appears  very preliminary
based on the information made available to the Committee.

      EPA is to be commended for recognizing the extent of the market question.
Nonetheless, the McClelland  et a/, methodology does not offer an approach to deal
with the problem.

      Overall,  the Committee recommends against using the specific approach
proposed in the draft RIA for  developing the aggregate estimates of non-use values.
Unfortunately, there is no other information in the literature to be used to meet the
needs of the RIA effort.

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      The Committee found the hedonic analysis to be a careful and systematic
evaluation of the effect of proximity of a contaminated site on the prices of nearby
residential properties. The Committee has some technical suggestions described in
the Appendix, and recommends that if the results of the hedonic analysis are included
in the RIA, two additions be made to the discussion. First, the relevant chapter should
describe dearly the analysis as providing a record of studies undertaken and summa-
rize in greater detail the reasons for not using the results in the benefit measurement.

      Lastly, a brief discussion of the potential (at a conceptual level) for using
hedonic estimates to bound valuation estimates would be desirable.

      In summary, from the perspective of its economic methodology, the draft RIA
reflects considerable creativity by EPA staff.  Although the Committee had a number
of detailed suggestions, these can, with the exception of the estimates of aggregate
non-use values, be addressed with revisions and extensions to existing methods.

      We look forward to receiving your response to our comments.

                                  Sincerely,
                        Dr. Raymond C. Loehr, Chair
                        Science Advisory Board
      Dr, Allen Kneese, Co-Chair
      Environmental Economics
      Advisory Committee
                                         *"%,_ t\ §
                                                             L
Dr.'V, T^fry'Smith, Co-Chair
Environmental Economics
Advisory Committee
ENCLOSURES

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                            TECHNICAL APPENDIX

      The purpose of this Appendix is to summarize some detailed further sugges-
tions elaborating on the Committee's comments regarding human health benefits
estimates, the use of the McClelland et al. findings as a basis for national non-use
value estimates,  and  the hedonic analyses.

                          a) Human Health "Benefits"

      The Agency constructed two alternative baseline scenarios as descriptions of
conditions in the absence of the Proposed Rule:

      1)    human exposures would NOT be capped through existing MCLs and
            taste/odor limits
      2}    exposures would be capped through existing MCLs and taste/odor limits.

The agency then estimated the reductions in the numbers of total cancer cases and
non-cancer health effects associated with the Proposed Rule assuming that the rule
would be less than 100 per cent effective in eliminating risks.  The  reductions in health
effects are listed as the human health benefits,

      A positive feature of this analysis is the recognition that policies are not always
100 per cent effective and that realistic estimates of benefits should be based on the
expected level of effectiveness rather than the theoretical ideal.   However, the
reported numbers are not particularly informative for policy purposes for several
reasons:

      1)    there is  no economic  valuation of the reductions in either cancer cases
            or non-cancer health  effects. This is puzzling, since the Agency's
            Guidelines for Performing Regulatory Impact Analysis discusses ap-
            proaches for estimating economic values for reductions in both morbidity
            and mortality and other Agency RIAs have utilized these approaches to
            monetize health effects.

      2)    the measure of non-cancer health effects involves a difficuit-to-interpret
            aggregate index that consists of the sum of the numbers of individuals
            with daily intakes in excess of the chronic reference doses (RfD) for the
            substances analyzed  plus numbers of Individuals whose exposure to
            lead results in blood lead levels above the threshold.  Two important
            pieces of information  are obscured by this form of aggregations:
            i)     Different chemicals cause different types of health effects; and not
                  all health effects are of the same severity.  Thus mild and severe
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                  adverse effects are lumped together and given the same weight in
                  this analysis.

            ii)    This form of aggregation treats a small exceedance of the RfD as
                  equivalent to a large exceedance. Also, using the number of
                  exceedances as an indicator of adverse health effects involves the
                  implicit assumption that all exceedances cause an adverse effect.
                  But in general, one would expect that as the average dose in-
                  creases above the RfD, the percentage of the exposed population
                  experiencing adverse health effects would rise, or,the severity of
                  the effects would increase, or both.

      3}    there is no systematic effort to describe and quantify the uncertainties in
            the analysis.  In Chapter  13 a range of effects is reported.  But this
            range reflects only the two alternative baseline exposure scenarios.

      In addition to these limitations, the Committee also has reservations about
several features of the analysis;

      1}    The uncapped scenario is not plausible as a matter of public poHcy. It
            assumes, in effect, that existing regulations affecting human exposures
            through a variety of pathways are ignored.  This scenario undoubtedly
            seriously overstates the number of cases of cancer and non-cancer
            health effects in the absence of the rule and therefore overstates the
            health benefits of the rule.

      2)    The report estimates baseline risks for people who move onto sites after
            they are closed (p, 7-3i to 40).  Apparently these risks were not used in
            the calculations for Table 7-23 (see the first line on p. 7-41).  But this
            raises the question of why these calculations were done and reported in
            the first place.  In any case, it seems unlikely that in the absence of the
            rule, sites would be used in this way, given the high calculated risks.

      3)    The report states that one big facility dominates the risk estimates,   ft
            would be useful to see the results with this facility omitted.  It also
            suggests a policy design  issue;  should the regulations have two tiers
            with stricter regulations for facilities like the one big one included in tie
            sample?

      4}    The report uses IRIS cancer slope factors which are mostly 95 percent
            UCLs, not maximum likelihood estimates.  The report is also based on
            other standard "conservative" practices in risk assessment. Thus, the
            estimated health benefits cannot be considered to be expected values or
            most likely values.  Given the level of effort devoted to  other parts of the


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            analysis, and given the potential economic impact of the Proposed Rule,
            more effort should be devoted to both expected values and upper and
            lower bounds for the health benefits.

      This decision to measure effects with count variables leads to the failure to take
account of the temporal distribution of health effects. One hundred twenty-eight years
of health effects are aggregated as if they were equally important and measured with
equal precision. This is especially  troublesome when it is recognized that these
aggregates (over 128 years) provide the basis for the cost effectiveness analysis -
comparing discounted costs to undiscounted  physical effects.  At a minimum, the
comparison should be made year by year and then discounted.

   b)  Feasibility of Using McClelland et al Estimates for National Estimates
                 of Non-use Values for Groundwater Cleanup

      Our earlier report (CV-1) raised a number of questions with the results of the
McClelland et al contingent valuation study.  The focus of that review was on the per
household estimates of nonuse values for complete cleanup of contaminated ground-
water.  The overall judgment of the Committee was that we had no confidence that the
respondents to the McClelland et al survey were clear about the commodity they were
being asked to value. This basic failing called into question the  usefulness of the
willingness to pay (VYTP) estimates as indications of a typical household value for
complete cleanup of contaminated  groundwater.

      There are also a number of  problems with adopting this perspective, including
serious discrepancies between the  context of the commodities to be evaluated as part
of the effects of the planned RIA and what has been described to the respondents in
the McClelland et'al survey.  Equally important, there are significant unresolved
issues in the benefit transfer procedures used.  These problems are independent of
our review of the McClelland et al  report and relate exclusively to the use of their
estimate in the draft methodology document for the RIA. The most important of our
concerns are;

      1) Technical Questions

      i) At the close of our review  of the survey procedures, questionnaire and esti-
      mates, it was suggested that the Committee might consider the feasibility of
      using the estimates as an approximate upper bound on the per household WTP
      to meet the goal of an upper bound evaluation of this source of aggregate
      benefits generated by the Rule. There is no basis in the McClelland et al
      study, related literature (see  Boyle [1993]) or the analysis presented in the RIA
      to assume the estimates are upper bounds for per household WTP.  The RIA
      does not use the full range of estimates developed by McClelland et al but
      focuses instead on a comparison of two of the five  scenarios, arguing ineoireci-


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ty, that such comparisons were judged to be the most reliable in the NOAA
panel report on contingent valuation (see pp 10-14 to 10-15). Nonuse values
were measured by the difference between the complete cleanup and the public
treatment scenarios.  No recommendation of this type was part of the NOAA
panel's report,

ii) The analysis did not rely on the primary data from the survey. The analysis
uses predictions from the Box-Cox model for WTP as if they were primary  data,
performs a subsequent linear regression treating these predictions as depen-
dent variables and income plus regional dummy variables as independent
variables. Based  on the McClelland et al report, these variables were argu-  -
ments of the original Box-Cox models.  This exercise has no basis in statistical
methods.  Predictions from this model were adjusted by a single (for all esti-
mates) adjustment factor of .503 to compute the WTP for public treatment.  The
difference was then the basis for the nonuse values.  It is hard to  understand
why this strategy was adopted when primary data on the difference that is
sought are  available in version 0 of the McClelland et. al survey questionnaires.

These are not the only technical problems associated with the economic
methodology used in the benefit transfer.  They are examples and reinforce the
need for appropriate peer review of methods prior to the presentation of materi-
als  to committees of the SAB.

2)  Benefit Transfer

i) The most fundamental problem arises with the source of the contamination.
All of the McClelland ef. al questionnaire variations identify the source of
contamination  as a public landfill. The majority of the sites affected by the
RCRA rule  would  not fit this description. The pretest and design work from the
McClelland et a/ study suggest this distinction is very important. Virtually all of
the literature on people's responses to contamination of groundwater finds
similar results.  The source matters to people's evaluation of the problem and to
the character of the response.

ii) The extent and  timing of cleanup activities presented in the McClelland et al
survey are completely different from all of the potential RCRA actions and there
is no basis  for gauging the temporal properties of the nonuse estimates in
response to changes identified as critical in the McClelland et al pretest as well
as in the  earlier Mitchell-Carson focus group analyses.

iii) The most fundamental issue giving rise to the  range in  estimates of the
aggregate nonust values is the extent of the market.  Estimates range from
$170 million to $18 billion for aggregate nonuse values depending on the
assumption about extent of the market.  This variation does not relate to the


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      variability in contingent valuation estimates or to the Committee's concerns
      about the commodity understood by survey respondents, It results exclusively
      from assumptions about which households are actually concerned about each
      site.

      The RIA presents alternative estimates, identifies the fact that McClelland et al
      use the phrase "in your community" to describe how households were Intended
      to infer responsibility. Subsequent research is sketched in four pages of a later
      McClelland ef. a/ [1993] report where it is suggested that the concept of
      community was examined in March 1993 post-testing of the survey. The
      authors describe a question added to the survey to elicit information about how
      respondents would evaluate their community.  No information was provided in
      that report about how the results used to propose a definition for the community
      (as a proxy measure for the extent of the market) were derived - sample size,
      implementation, and correspondence of other variables for the new survey with
      the original survey were not discussed.

      These  comments are intended to illustrate the substantive questions in the
      development of the nonuse benefit estimates. Taken together with the ques-
      tions about interpreting the per household estimates of nonuse values, we are
      forced  to conclude that there is no basis for accepting any of the EPA estimates
      of nonuse values.

                             c) Hedonic Analyses

      The hedonic chapter and "sanitized" companion report provide an analysis of
residential property values  using a hedonic framework where housing prices are
related to the home and site characteristics including the distance from hazardous
waste treatment, storage and disposal facilities (TSDF) at three distinct sites,

      In each case study,  a notable "event" took place at the TSDF during the
observation period.  For two of the studies, distance from the TSDF became a
significant explanatory variable in the hedonic price  equation only after the publicizing
of the "event," In the third  case study, distance from the site was strongly significant
throughout the entire period. The results from this study are qualitatively reasonable
and promising. They are based on large samples of housing prices.  But, the authors
and the Committee caution against adoption of the quantitative estimates of benefits
of remediation based on these studies at this time.  We  reiterate that list adding
additional reasons to those reported and introducing some new concerns:

      1)    Functional form.  The report relies primarily on a linear hedonic model,
            although it employs a semi-log and a piece-wise (in distance from site)
            linear form. The "benefit" estimates (see point § below) obtained seem
            quite sensitive to functional form and the authors admit the need to


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      investigate.  Additionally, the implication of linear in characteristics
      models, i.e.  constant marginal prices of characteristics, has not been
      found especially satisfactory in other studies. The fact that housing
      prices are being underestimated in some house size ranges and overes-
      timated in others suggests to them and to us the need to experiment with
      more flexible functional forms with respect to housing characteristics as
      well.

2}    Explanatory power. Little of the variation in  housing prices is explained  .
      by the model probably because data are not available on important
      housing characteristics (especially neighborhood characteristics). Both
      the report and the  Committee agree on this  point.  This is a particularly
      difficult problem in  one case study where the effects of one TSDF are
      being estimated, when in fact several such facilities exist in the surround-
      ing area.

      While it should be  possible to incorporate some additional neighborhood
      characteristics, others may pose more complicated problems than the
      authors anticipate.  Some neighborhood characteristics might themselves
      be endogenous - brought about by the location of the facility.  The
      report suggests using socio-demographic characteristics of the neighbor-
      hood to explain price differences but these, too, may pose an
      endogeneity problem.

3)    Outliers.  The  report suggests that outliers (i.e. houses that sell for  less
      than $50,000 and over $500,000) are quite influential in their estimates.
      Clearly the model is not explaining these very well. If, in addressing
      problems 1 and 2 above, this outlier problem is not resolved, the Com-
      mittee suggests the authors adopt some  of tie numerous available
      statistical techniques for dealing with outliers rather than relying on  ad
      hoc procedures.

4)    Distance as a  proxy variable.  The authors use distance from a TSDF as
      a proxy for the relative damage due to the site.  But, all effects from a
      site are not radially symmetric. Prevailing winds and topographical
      features can increase/decrease the impact of noxious fumes and other
      aesthetic effects. The significance of these will be case specific.

5)    Benefit measurement  Without any discussion, the report takes the
      change in the  hedonic price function (as if each affected house were
      moved farther from the site) as a measure of benefits. Welfare measure-
      ment in hedonic models is extremely complicated and depends on such
      factors as the  extent  of the market, whether the market could be consid-
      ered closed  or open,  the heterogeneity of participants, etc.  Even if one


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      considers only a short run, when individuals (and therefore the hedonic
      price functions) do not adjust, the hedonic price function is a locus of
      equilibrium points and not a demand function.

      Under certain circumstances, McDonnell (In Kopp and Smith, Valuing
      Natural Assets [1993]} has suggested that the change in the hedonic
      price as predicted by the change in policy could serve as an approximate
      welfare measure. However, the report shows no appreciation for this
      complex problem and needs to consider the factors that would make this
      a good or bad approximation, or an upper or lower bound.  From our
      understanding of the problem, this predicted change is likely to be an
      upper bound on the welfare measure sought, but this needs to be
      examined. Other literature of interest on the subject includes Palmquist
      (in Braden and Kolstad,  eds., Measuring Demand for Environmental
      Commodities. |1991J; Kanemoto Econometric® [1988]; Cropper, Deck
      and McConnell REStat [1988]; Bartik and Smith in Mills, eds,, Handbook
      of Urban Economics. [1987].

6)    Repeat sales/time series. In addition to the hedonic study described
      above, the report analyzed some time series data in a "repeat sales"
      analysis for a small sample of houses that were sold more than once
      during the time period.  Little came of that analysis and, for a number of
      reasons, we do not recommend that they pursue  this part of the study.
                               A-7

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                              REFERENCES

Boyle, K, J. A Review of Contingent Valuation Studies of the Benefits of Groundwater
      Protection (report to U.S. Environmental Protection Agency), Research Triangle
      Institute, April 1993).

McClelland, G.H., Schulze, W.D. Lazo, J.K., Waldman, D.M., Doyle, J.K., Elliott, S.R.
      and Irwin, J.R,  Methods for Measuring Non-Use Values: A Contingent Valua-
      tion Study of Groundwater Cleanup (Draft report to the U.S. EPA), University of
      Colorado, Center for Economic Analysis, October, 1992.
                                    R-1

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             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           SCIENCE ADVISORY BOARD
               ENVIRONMENTAL ECONOMICS ADVISORY COMMITTEE
                               RCRA RIA REVIEW

CO-CHAIRS
Dr. Allen V. Kneese, Resources for the Future, Washington DC

Dr. V. Kerry Smith, Department of Economics, North Carolina State University, Raleigh NC

MEMBERS
Dr. Nancy E.  Bockstael, Department of Agricultural and Resource Economics, University of
Maryland, College Park, MD

Dr. A. Myrick Freeman, Department of Economics, Bowdoin College, Brunswick, ME

Dr. Charles D. Kolstad, Department of Economics, University of Illinois, Urbana, IL

Or, William Nordhaus, Department, of Economics, Yale University, New Haven CT

Dr. Bryan Norton, School of Public Policy, Georgia Institute of Technology, Atlanta GA

Dr, Wallace E, Dates, Department of Economics, University of Maryland.CoIIege Park, MD

Dr, Paul R. Portney, Resources for the Future, Washington DC

Dr. Robert Repetto, World Resources Institute, Washington, DC

Dr. Richard Schmalensee, Massachusetts Institute of Technology, Cambridge MA

Dr. Robert N. Stavins, Kennedy School of Government, Harvard University, Cambridge, MA

Dr. Thomas H. Tietenberg, Department of Economics, Colby College, Waterville, ME

Dr. W. Kip Viscusi, Department of Economics, Duke University, Durham, NC

SAB COMMITTEE LIAISONS
Dr. William Cooper (EPEC), University of Michigan
Mr. Richard Conway (EEC), Union Carbide Corporation
Dr. Morton Lippmann (IAQC), Nelson Environmental Institute, New Yorfc University
Dr. Roger McClellan (CASAC), Chemical Industry Institute of Toxicology

DESIGNATED FEDERAL OFFICER
Mr, Samuel Rondberg, Environmental Health Committee, Science Advisory Board (1400F),
U.S.  Environmental Protection Agency, Washington, DC 20460

STAFF SECRETARY
Ms. Mary L Winston, Environmental Protection Agency, Science Advisory Board (1400F),
Washington, DC 20460

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                                   NOTICE

    This report has been written as a part of the activities of the Science Advisory
Board, a public advisory group providing extramural scientific information and advice
to the Administrator and other officials of the Environmental Protection Agency.  The
Board is structured to provide balanced, expert assessment of scientific matters
related to problems facing the Agency.  This report has not been reviewed for
approval by the Agency and, hence, the contents of this report do not necessarily
represent the views and policies of the Environmental Protection Agency, nor of other
agencies in the Executive Branch of the Federal  government, nor does mention of
trade names or commercial products constitute a recommendation for use.

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                                Distribution List

Administrator
Deputy Administrator
Assistant Administrators
Deputy Assistant Administrator for Research and Development
Deputy Assistant Administrator for Water
EPA Regional Administrators
EPA Laboratory Directors
EPA Headquarters Library
EPA Regional Libraries
EPA Laboratory Libraries

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