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Regulatory Impact Analysis for the Proposed
Industrial, Commercial, and Institutional Boilers
and Process Heaters NESHAP Reconsideration

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EP A-452/P-20-001
June 2020
Regulatory Impact Analysis of the Industrial, Commercial, and Institutional Boilers and Process
Heaters NESHAP Reconsideration Proposed Rule
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Health and Environmental Impacts Division
Research Triangle Park, NC
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CONTACT INFORMATION
This document has been prepared by staff from the Office of Air and Radiation, U.S.
Environmental Protection Agency. Questions related to this document should be addressed to
Larry Sorrels, U.S. Environmental Protection Agency, Office of Air and Radiation, Research
Triangle Park, North Carolina 27711 (email: sorrels.larry@epa.gov).
The U.S. EPA acknowledges that the Eastern Research Group (ERG) provided analysis and
support for the information in this document.
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Contents
List of Tables	6
1	INTRODUCTION	7
1.1	Summary of RIA Results	11
1.2	Organization of this Report	14
2	INDUSTRY PROFILE	16
2.1	Electric, Gas, and Sanitary Services	17
2.2	Sawmills and Wood Preservation	17
2.3	Converted Paper Product Manufacturing	18
2.4	Merchant Wholesalers, Dur able Goods	18
2.5	Merchant Wholesales, Nondurable Goods	18
2.6	Professional, Scientific and Technical Services	19
3	EMISSION REDUCTIONS, ENGINEERING COST AND ECONOMIC IMPACT
ESTIMATES	20
3.1	National Emissions Reductions and Other Emissions Changes	20
3.2	Compliance Costs	23
3.3	Economic Impact and Small Business Analysis	25
3.4	Employment Impacts	29
3.5	Social Welfare Considerations	30
4	BENEFIT ANALYSIS	32
4.1	Approach to Estimating Human Health Benefits	33
4.2	Estimating PM2.5, Ozone, and HAP Related Health Impacts	33
4.3	Quantifying Cases of PM2.5-Attributable Premature Death	41
4.4	Economic Valuation	43
4.5	Benefit-per-Ton Estimates	45
4.6	PM2.5-Co-benefits Results	47
4.7	Climate Co-Disbenefits	49
5	Benefit-Cost Comparison	51
5.1	Results	51
5.2	Uncertainties and Limitations	53
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LIST OF TABLES
Table 1-1 Summary of Changes to Emissions Limits In the Proposed Action	8
Table 1-2 Summary of Present Values and Equivalent Annualized Values for Annual Costs,
Monetized Ancillary Co-Benefits, and Monetized Net Co-Benefits (Including Co-
Disbenefits) for the Proposed Rule (millions of 2016 dollars)a b	14
Table 2-1 Source Categories Affected By This Proposed Action	16
Table 3-1 Nationwide Annual Emission Reductions from ICI Boilers affected by the Proposed
Rule	22
Table 3-2 Pollution Control Costs by Technology Type ($2016)*	23
Table 3-3 Undiscounted Costs, Discounted Costs, and 2020 Present Value Analysis for the
Proposed Rule (2016$)*	25
Table 3-4 2020 Present Value (PV) of Costs and Equivalent Annualized Values (EAV) for the
Proposed Rule for E.O. 12866 (2016$)*	25
Table 3-5 Impacts for Affected Ultimate Parent Businesses	28
Table 4-1 Human Health Effects of Ambient PM2.5, Ozone, and HAP	39
Table 4-2 Estimated PM2.5 -related Ancillary Co-benefits of Proposed Reconsideration (2016$)..
	48
Table 4-3 Summary of Estimated PM2.5 and SCh-related Ancillary Co-benefits of Proposed
Reconsideration (millions of 2016$)	48
Table 5-1 Summary of Present Values and Equivalent Annualized Values for Annual Costs,
Monetized Ancillary Co-Benefits, and Monetized Net Benefits (Including Ancillary
Co-Disbenefits) for the Proposed Rule (millions of 2016 dollars)a'b	52
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1 INTRODUCTION
This report is the regulatory impact analysis (RIA) for the proposed reconsideration of
the Industrial, Commercial, and Institutional (ICI) Boilers and Process Heaters NESHAP. The
U.S. Environmental Protection Agency (EPA) is proposing national emission standards for
hazardous air pollutants (NESHAP) for new and existing industrial, commercial, and
institutional boilers and process heaters. On January 31, 2013, the EPA finalized amendments to
the national emission standards for the control of hazardous air pollutants at major sources from
new and existing industrial, commercial, and institutional boilers and process heaters.
Subsequently, the U.S. Court of Appeals for the District of Columbia Circuit remanded several
of the emission standards to the EPA based on the court's review of the EPA's approach to
setting those standards. On July 29, 2016, the U.S. Court of Appeals for the District of Columbia
Circuit issued its decision remanding emission standards where it held that the EPA had
improperly excluded certain units in establishing the emission standards and remanded the use of
carbon monoxide (CO) as a surrogate for organic HAP for further explanation. In March 2018,
the court in a separate case remanded the EPA's decision to set a limit of 130 parts per million
(ppm) CO as a minimum standard for certain subcategories for further explanation. In response
to these remands, this action proposes to amend several numeric emission limits for new and
existing boilers and process heaters and set compliance dates for these new emission limits.
The proposed revisions to the emission limits are solely to respond to the remands issued
by the U.S. Court of Appeals for the District of Columbia Circuit. As part of its response, the
EPA changed how co-fired (i.e., ICI boilers that can use more than one fuel type) units are
ranked and assessed from previous Maximum Achievable Control Technology (MACT)
rulemakings, changed how small datasets are assessed, and made decisions to propose certain
emissions limits as beyond the MACT floor.1 For the MACT-based emission limits calculated
for this particular response to the remands, the revisions were very narrowly scoped. The EPA's
response to the remands was to revise the rankings to address the co-firing issue, which required
the EPA to identify a new set of best performing units, by including previously excluded co-fired
units in the rankings and then re-calculate the limits based on the new set of best performer data
1 We reviewed the recalculated MACT floor emission limits that were less stringent than those in the January 2013
final rule in order to assess whether a beyond-the-floor option was technically achievable and cost-effective. Further
discussion is available in section III.B of the proposal preamble.
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while using the existing data set (including any necessary corrections). Given the direction
provided by the remand, the only available alternative standard was to select standards that were
beyond the MACT floor, which the EPA selected in limited circumstances as discussed above
and in more detail in the docketed memorandum.2
These changes yield 34 different emission limits that we are proposing to change. Of
these 34 emission limits, 28 of the limits became more stringent. Six of the limits became
modestly less stringent, with no more than a 25 percent decrease in the stringency of the
emission limit compared to the 2013 ICI Boilers MACT standard. Twenty-one of these
emissions limits change as a result of including previously excluded units (co-fired). The other
seven emissions limits change as a result of the small dataset issue or adjustments to CO data. A
complete list of all the proposed emission limits, for new and existing units, and with pollutant
indicated for each emissions limit, and a summary of proposed changes to the current limits is
shown in Table 1-1. We note that particulate matter (PM) and CO are the most common
pollutants for these emissions limits, and these pollutants serve as surrogates for the HAPs that
are regulated. More information on these emissions limits and the rationale for changes can be
found in section IV. A of the proposal preamble.
Table 1-1 Summary of Changes to Emissions Limits In the Proposed Action	
Current Emission Proposed Emission
Limit	Limit
(lb/MMBtu of heat (lb/MMBtu of heat
Subcategory	Pollutant input or ppm ® 3 input or ppm ® 3
"	percent oxygen tor percent oxygen tor
CO)	CO)
New-Solid
HC1
2.20E-02
3.00E-04
New-Dry Biomass Stoker
TSM8
4.00E-03
5.00E-03
New-Biomass Fluidized Bed
CO
230
130

PM
9.80E-03
4.10E-03
New- Biomass Fluidized Bed




TSM
8.30E-05
8.40E-06
New-Biomass Suspension Burner
CO
2,400
220
New-Biomass Suspension Burner
TSM
6.50E-03
8.00E-03
New-Biomass Hybrid Suspension Grate
CO
1,100
180
New-Biomass Dutch Oven/Pile Burner
PM
3.20E-03
2.50E-03
New-Biomass Fuel Cell
PM
2.00E-02
1.10E-02
New- Wet Biomass Stoker
CO
620
590
2 Eastern Research Group (ERG). Memorandum, Revised MACT Floor Analysis (2019) for the Industrial,
Commercial, and Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air
Pollutants - Major Source. May, 2020.
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New- Wet Biomass Stoker
PM
0.03
0.013
New-Liquid
HC1
4.40E-04
7.00E-05

PM
1.30E-02
1.90E-03
New-Heavy Liquid
TSM


7.50E-05
6.40E-06
New-Process Gas
PM
6.70E-03
7.30E-03
Existing-Solid
HC1
2.20E-02
2.00E-02
Existing-Solid
Hg
5.70E-06
5.40E-06
Existing-Coal
PM
4.00E-02
3.90E-02
Existing-Coal Stoker
CO
160
150
Existing-Dry Biomass Stoker
TSM
4.00E-03
5.00E-03
Existing-Wet Biomass Stoker
CO
1,500
1,100

PM
3.70E-02
3.40E-02
Existing- Wet Biomass Stoker
TSM


2.40E-04
2.00E-04
Existing-Biomass Fluidized Bed
CO
470
210

PM
1.10E-01
2.10E-02
Existing-Biomass Fluidized Bed



TSM
1.20E-03
6.40E-05

PM
5.10E-02
4.10E-02
Existing-Biomass Suspension Burners
TSM
6.50E-03
8.00E-03
Existing-Biomass Dutch Oven/Pile Burner
PM
2.80E-01
1.80E-01
Existing-Liquid
Hg
2.00E-06
7.30E-07
Existing-Heavy Liquid
PM
6.20E-02
5.90E-02
Existing-Non-continental Liquid
PM
2.70E-01
2.20E-01
Existing-Process Gas
PM
6.70E-03
7.30E-03
This rule affects a range of facilities in the ICI sector that are located at major sources of
HAP and have a boiler or process heater as defined in the final Boiler MACT. The 2013
Emission Database for Boilers and Process Heaters estimated there were approximately 14,000
existing boilers and process heaters currently operating at 1,702 different facilities that are major
sources of HAP and subject to the Boiler MACT. The vast majority of these combustion units
(nearly 12,000 units) were gas-fired and in the Gas 1 subcategory, which are subject to the rule
but are not subject to numeric emission limits.
To identify potentially affected facilities for this proposal, the EPA reviewed compliance
data submitted to CEDRI and WebFIRE and data available from trade associations, such as the
Council for Industrial Boiler Operators (CIBO). These data show 533 existing boilers and
process heaters, of which 443 remain operational, belonging to one of the subcategories that are
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subject to numeric emission limits, the subject of this action.3 We then reviewed the compliance
data for hydrogen chloride (HC1), mercury (Hg), filterable particulate matter (PM), and CO
emissions and compared these data to the proposed emission limits to evaluate which boilers
were not currently meeting the more stringent proposed emission limits. Based on this effort, the
EPA determined that this proposed regulation could likely affect 33 boilers, 28 boilers of which
are classified as existing sources and five of which are classified as new sources. The EPA notes
that 16 of these boilers (13 existing, 3 new) are not expected to incur any compliance costs
associated with the proposal because they already meet the proposed emissions limits. After
applying all these filters, the EPA expects that 17 boilers (15 existing, 2 new) would likely be
affected by this proposed rule in that they would likely have to perform additional compliance
actions to meet the new proposed limits.
The impacts estimated for this proposal are all additional to the reductions already
accounted for in the January 2013 final ICI boiler rule for both new and existing sources. Thus,
the baseline for this proposal includes the impacts, and hence the installation and operation of
HAP control devices at ICI boilers associated with the 2013 boilers rule.
The proposed changes to the emissions limits shown in Table 1 will protect air quality
and promote public health by reducing emissions of the HAP listed in section 112(b)(1) of the
Clean Air Act. This action also addresses the two issues remanded to the EPA for further
explanation and makes several technical clarifications and corrections.
In addition to controlling HAP, primarily metal HAP, this action yields co-benefits such
as reduced emissions of fine particulate matter (PM2.5) and sulfur dioxide (SO2) that are co-
benefits (that is, benefits from reductions of non-targeted emissions) of this action. There are also
minimal increases in carbon dioxide (CO2) emissions associated with this action, and these
increases are treated as a co-disbenefit. Our estimate of benefits includes those monetized
estimates for non-targeted emission reductions and increases. There are no monetized benefits
from the targeted HAP reductions due to lack of necessary input data. More information on the
benefits, ancillary co-benefits, and co-disbenefits can be found in Chapter 4 of the RIA.
s This count excludes any shutdown boilers, boilers that have switched to the natural gas subcategory and are
therefore no longer impacted by changes to emission limits, or boilers that are classified as small or limited use.
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This proposed rule is economically significant according to Executive Order 12866 (i.e.,
an annual effect of $100 million or greater in any one year or adversely affect in a material way
the economy, a sector of the economy, productivity, competition, jobs, the environment, public
health or safety, or State, local, or tribal governments or communities), and the EPA is therefore
required to develop a RIA. This RIA documents all methods and provides the results of the
economic impact analysis (EIA), small business impacts analysis, and benefits analysis. With the
purpose of this proposal being to provide necessary, non-discretionary changes in emissions
limits to ICI boilers and process heaters in response to the decision by the U.S. Court of Appeals
for the D.C. Circuit, the RIA presents an analysis of the regulatory impacts resulting from the
changes in emissions limits.
1.1 Summary of RIA Results
This reconsideration will likely impose costs and economic impacts on several industries
and their consumers, while producing beneficial improvements in air quality. The key results of
this RIA are as follows:
•	Engineering Compliance Costs: Total annual costs are those costs incurred by affected
industries that include pollution control and administrative (monitoring, recordkeeping, and
reporting) costs. The EPA estimates that the facilities that will need to implement
compliance measures to meet the proposed limits will incur $83.7 million in total capital
costs (2016). The facilities are also projected to incur about $14 million in annual operating
and maintenance expenditures once the proposed limits are in effect. In addition, the PV of
these costs is $103.7 million at a 7 percent discount rate, and $128.1 million at a 3 percent
discount rate. Finally, consistent with the present value estimate, the annualized value of
the costs, expressed as an equivalent annualized value (EAV), is $17.4 million at a 7
percent discount rate and $18.3 million at a 3 percent discount rate.
•	Economic Impacts and Small Businesses: The EPA prepared an analysis of economic
impacts in which the annualized costs for affected companies are compared to their annual
revenues, and consider these results in light of market information (e.g., price elasticities of
demand). We find that these impacts are relatively low, and minimal impacts are expected
to affected companies and consumers of their products. In compliance with the Regulatory
Flexibility Act (RFA) as amended by the Small Business Regulatory Enforcement Fairness
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Act (SBREFA), the EPA used the economic impact analysis to estimate impacts on
affected small businesses by analyzing annual compliance costs as a share of annual
ultimate parent company revenues. Of the 26 affected parent companies, only one is a
small business according to Small Business Administration (SBA) small business size
guidelines. The EPA estimates that the single potentially affected small business owns two
affected ICI boilers subject to the requirements in this proposal but will not incur any
compliance costs, so there are no small business impacts associated with this proposal.
Therefore, the EPA can certify that this proposal will not have a significant economic
impact on a substantial number of small entities (SISNOSE).
•	Emissions Impacts: For targeted HAP emissions, the proposed amendments are expected
to result in an additional 34 tons per year (tpy) of reductions in HC1 emissions. The
proposed amendments are also expected to have a modest effect on mercury, with an
estimated additional reduction of 3.96 pounds per year. Emissions of non-mercury metals
(i.e., antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel,
and selenium) would decrease by 2.3 tpy. For non-targeted emissions, filterable PM
emissions would decrease by 333 tpy, of which 251 tpy is fine PM (PM2.5), due to the
proposed amendments. In addition, the proposed amendments are estimated to result in an
additional 393 tpy of reductions in sulfur dioxide (SO2) emissions. Finally, carbon dioxide
(CO2) emissions increase by 14,700 short tons as a result of operation of the additional
control devices expected as a result of the proposal.
•	Benefits: Benefits associated with reductions in the targeted HAP emission reductions are
not estimated in this RIA due to lack of appropriate valuation estimates. Estimated
monetized ancillary co-benefits of this proposal are from reduced mortality and morbidity
attributed to lower emissions of from non-targeted pollutants such as PM2.5 and SO2
achieved with the operation of the compliance technologies associated with the proposed
HAP standards.4 The benefits estimates also account for ancillary climate co-disbenefits,
4 To facilitate the estimation of the stream of potential ancillary co-benefits flowing from this rulemaking, we use
available air quality modeling to estimate ancillary co-benefits in 2025, then assume that the level of impacts
estimated for 2025 recurs annually during the years within the time horizon under analysis that facilities are
expected to be in compliance and reducing emissions, or 2024 to 2028. The EPA estimates the ancillary co-benefits
from reductions in non-targeted pollutants such as PM2 5 and SO2 in 2016 dollars of this proposed major source
NESHAP are $110 million to $250 million at a 3 percent discount rate and $95 million to $210 million at a 7 percent
discount rate for the snapshot year of 2025.
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which result from increased emissions of CO2.5 The present value (PV) of the benefits in
2016 dollars and discounted to 2020, is $630 million to $1,100 million when using a 7
percent discount rate and $730 million to $1,650 million when using a 3 percent discount
rate, all plus C to represent the present value of the unmonetized HAP benefits. The
equivalent annualized values (EAV), an estimate of the annualized value of the net benefits
considering ancillary co-benefits and co-disbenefits consistent with the present values, is
$90 million to $180 million per year when using a 7 percent discount rate and $100 million
to $240 million per year when using a 3 percent discount rate, all plus D to represent the
equivalent annualized value of the unmonetized HAP benefits. The calculation of benefits
as PV and EAV can be found in a set of spreadsheets available in the docket for this
rulemaking.6
• Cost-Benefit Comparison: The present value (PV) of the net benefits considering
ancillary co-benefits and co-disbenefits, in 2016 dollars and discounted to 2020, is $530
million to $1,000 million when using a 7 percent discount rate and $600 million to $1,520
million when using a 3 percent discount rate, all plus C to represent the present value of the
unmonetized HAP benefits. The equivalent annualized values (EAV), an estimate of the
annualized value of the net benefits considering ancillary co-benefits and co-disbenefits
consistent with the present values, is $70 million to $160 million per year when using a 7
percent discount rate and $80 million to $220 million per year when using a 3 percent
discount rate, all plus D to represent the equivalent annualized value of the unmonetized
HAP benefits. Table 1-2 summarizes the costs, monetized co-benefits, and net benefits of
the proposal, all of which are shown as PV and EAV. Estimates in the table are presented
as rounded values.
5 The annualized value of the ancillary climate co-disbenefits for 2025 from this proposed NESHAP is $0.09 million
at a 3 percent discount rate and $0.01 million at a 7 percent discount rate.
6U.S. EPA. OAQPS. WorkbookICIboilersMACTrecon_BenefitsUpperbound3%_PVandEAV.xls,
WorkbookICIboilersMACTrecon_BenefitsUpperbound7%_P VandEAV.xls,
WorkbookICIboilersMACTrecon_BenefitsLowerbound3%_PVandEAV.xls,
WorkbookICIboilersMACTrecon_BenefitsLowerbound7%_PVandEAV.xls,
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Table 1-2 Summary of Present Values and Equivalent Annualized Values for Annual
Costs, Monetized Ancillary Co-Benefits, and Monetized Net Co-Benefits (Including Co-
Disbenefits) for the Proposed Rule (millions of 2016 dollars)a'b	
	3% Discount Rate	7% Discount Rate
Targeted Benefits0	C	C
Ancillary Co-Benefits	$730 to $1,650	$630 to $1,100
Present Value	Ancillary Co-Disbcncfils	<$1	<$1
	Cos?			sni)	$100	
	Net Benefits6	$600 to $1,520 + C	$530 to $1,000 + C
Targeted Benefitsf	D	D
Ancillary Co-Benefits	$100 to 240	$90 to 180
Equivalent Annualized Value Ancillary Co-Disbcncfils	<$0.1	<$0.1
Co sis		$1.8	SJ7
	Net Benefits	$80 to 220 + D	$70 to 160 +D	
" All estimates in this table are rounded to one decimal point, so numbers may not sum due to independent rounding.
b All estimates reflect the amendments to the ICI Boilers MACT standard included in this proposal from a baseline
that includes the control technologies applied to meet the MACT standard.
0 C represents the present value of unquantified benefits from reductions in targeted HAP emissions.
d The annualized present value of costs and benefits are calculated over an 8 year period from 2021 to 2028.
e The total monetized ancillary co-benefits reflect the human health benefits associated with reducing exposure to
PM2 5 through reductions of directly emitted PM2 5 and SO2. Monetized ancillary co-benefits include many, but not
all, health effects associated with PM2 5 exposure. Co-benefits are shown as a range from Krewski et al. (2009) to
Lepeule et al. (2012). We do not report the total monetized ancillary co-benefits by PM2 5 species. The ancillary
climate co-disbenefits from additional CO2 emissions resulting from control device operations are included in the
results given the rounding convention employed in this table as stated in footnote a. The net benefits calculation
consists of the sum of the targeted benefits and ancillary co-benefits minus the costs and ancillary climate co-
disbenefits.
f D represents the equivalent annualized value of unquantified benefits from reductions in targeted HAP emissions.
Given these results, the EPA expects that implementation of this proposed rule, based
solely on an economic efficiency criterion, will provide society with a substantial net gain in
welfare, notwithstanding the expansive set of health and environmental benefits and co-benefits
or other impacts we were unable to quantify. Further quantification of directly emitted PM2.5-,
mercury-, acidification-, and eutrophication-related impacts would increase the estimated net co-
benefits of the rule.
1.2 Organization of this Report
This report presents the EPA's analysis of the potential benefits, costs, and other economic
effects of the proposed standards for ICI boilers. This RIA includes the following sections:
•	Section 2 presents a profile of the affected industries, developed for the economic impact
analysis.
•	Section 3 describes the estimated costs and impacts of the regulation, providing a summary
of the analysis inputs and methodology for assessing the economic impacts of the proposed
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regulation. The section provides the analysis results, including impacts on industry overall
and impacts on small businesses.
•	Section 4 describes the benefits and ancillary co-benefits of this regulation for both targeted
HAP and non-targeted emission reductions and the inputs and methods used for estimating
and valuing reduced environmental and human exposure to air emissions. The section also
describes the climate co-disbenefits of this proposed regulation.
•	Section 5 presents the overall comparison of the benefits (including ancillary co-benefits
and co-disbenefits) and costs.
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2 INDUSTRY PROFILE
This proposed rule will affect facilities and companies using ICI boilers, based on the
National Emission Standards for Hazardous Air Pollutants (NESHAP) source category (i.e., 40
CFR part 63, subpart D) standards. Of the 90 different emission limits included in the ICI boilers
MACT standard, the EPA is proposing to revise 34 of them depending on the type of boilers and
fuel used. Of these 34 emission limits, 28 of the limits became more stringent and six of the
limits became less stringent. Facilities would have up to three years after the effective date of the
final rule to demonstrate compliance with these revised emission limits.
ICI boilers are found in many manufacturing sectors and other industries. The EPA used
the North American Industrial Classification System (NAICS) code identified for the parent
company owning each facility using an impacted ICI boiler to conduct this brief industry profile.
This section summarizes in a high-level fashion the profiles of these industries using the NAICS
codes for the ultimate parent companies that own affected boilers. The proposed rule only affects
a subset of facilities using ICI boilers within each industry identified. This proposal does not
impact all types of ICI boilers. The ICI boilers identified as having impacts from this proposal
fall in the following categories: existing biomass-fired, existing coal-fired, new biomass-fired,
and new coal-fired. The EPA identified 28 existing ICI boilers that will be affected by this
proposed rule and expects five new boilers to be added to the industry in the future, which are
fired or expected to be fired by biomass (e.g., wood) or coal as fuels. None of the affected ICI
boilers are oil-fired or gas-fired. Table 2-1 provides a list of the industries by NAICS code with
source categories affected by the proposed rule.
Table 2-1 Source Categories Affected By This Proposed Action	
NAICS code1	Examples of potentially regulated entities
221
Electric, gas, and sanitary services
321
Manufacturers of lumber and wood products
322
Pulp and paper mills
423
Merchant Trade, Durable Goods
424
Merchant Trade, Nondurable Goods
541
Professional, Scientific and Technical Services
1 North American Industry Classification System.
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The industry profile provided here is based on 2016 data from U.S. Census Bureau and
U.S. Census Bureau American Fact Finder.7 For some NAICS codes, 2016 data were not
available, and in those instances the most up-to-date data available were used. This profile is not
meant to serve as an exhaustive treatment for each affected industry and any sub sectors of note,
but is meant to serve as a high-level summary of useful information for these industries. It is
important to note that only a small fraction of the facilities in each industry own ICI boilers.
Thus, only a small fraction of facilities in these industries are impacted by this proposed
regulation.
2.1	Electric, Gas, and Sanitary Services
Activities in this sector, NAICS 221, include providing electric power, natural gas, steam
supply, water supply, and sewage removal through a permanent infrastructure of lines, mains,
and pipes. This proposed rule is anticipated to affect four ultimate parent companies owning four
boilers in this sector. According to the U.S. Census Bureau American Fact Finder, in 2016,
NAICS 221 had 5,893 ultimate parent companies that own 18,159 establishments. The sector
employed 638,917 people, with payroll of around $654 billion.
2.2	Sawmills and Wood Preservation
This sector includes establishments whose primary production process begins with logs
or bolts that are transformed into boards, dimension lumber, beams, timbers, poles, ties, shingles,
shakes, siding, and wood chips. This industry also includes establishments that cut and treat
round wood and/or treat wood products to prevent rotting by impregnation with creosote or other
chemical compounds.
This proposed rule is anticipated to affect nine ultimate parent companies owning 12
boilers in this sector. According to the U.S. Census Bureau American Fact Finder, in 2016, the
sawmills and wood preservation industry (NAICS 321) was comprised of 3,213 establishments
employing 77,200 people and had a payroll of around $3.7 billion. The total value of shipments
and receipts for services from this sector was around $30.5 billion.
7 US Census Bureau, Dept. of Commerce, https://www.census.gov/eos/www/naics/. and US Census Bureau
American Fact Finder, Dept. of Commerce,
https://factfinder.census.gov/faces/nav/isf/pages/searchresults.xhtml7refreslFt
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2.3	Converted Paper Product Manufacturing
This industry includes establishments primarily engaged in converting paper or
paperboard, but they do not manufacture paper or paperboard. According to the U.S. Census
Bureau American Fact Finder, in 2016 the converted paper product manufacturing industry
(NAICS 322) had 3,638 establishments employing 233,866 people, with a payroll of around $13
billion. The total value of shipments and receipts for services was around $105 billion.
Paper bag and coated and treated paper manufacturing, NAICS 322220, is a subsector in
this industry. It includes establishments primarily engaged in cutting and coating paper and
paperboard, and/or cutting and laminating paper, paperboard, and other flexible materials (except
plastics film to plastics film). There are 13 boilers owned by 12 ultimate parent companies with
this NAICS code anticipated to be affected by this proposal. In 2016, this industry employed
45,700 employees, and had a payroll of around $2.6 billion. The total value of shipments and
receipts from this sector was around $20.6 billion.
2.4	Merchant Wholesalers, Durable Goods
Firms in this sector, NAICS 423, sell capital or durable goods to other businesses.
Merchant wholesalers generally take title to the goods that they sell; in other words, they buy and
sell goods on their own account. Durable goods are new or used items with a useful life of three
years or more. Durable goods merchant wholesale trade establishments are engaged in
wholesaling products, such as motor vehicles, furniture, construction materials, machinery and
equipment (including household-type appliances), metals and minerals (except petroleum),
sporting goods, toys and hobby goods, recyclable materials, and parts.
There are two boilers owned by two ultimate parent companies under this NAICS code
identified as having impacts from this proposal. According to the American Fact Finder (U.S.
Census Bureau), in 2016 the sector was comprised of 164,328 parent companies that own
237,789 establishments. The sector had 3,464,046 employees, with a payroll of around $257.6
billion.
2.5	Merchant Wholesales, Nondurable Goods
Firms in this sector, NAICS 424, sell nondurable goods to other businesses. Nondurable
goods are items generally with a useful life of less than three years. Nondurable goods merchant
18

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wholesale trade establishments are engaged in wholesaling products, such as paper and paper
products, chemicals and chemical products, drugs, textiles and textile products, apparel,
footwear, groceries, farm products, petroleum and petroleum products, alcoholic beverages,
books, magazines, newspapers, flowers and nursery stock, and tobacco products.
There is one boiler owned by an ultimate parent company under this NAICS code
identified as having impacts from this proposal. According to the American Fact Finder (U.S.
Census Bureau), in 2016 the sector had 96,817 parent companies that own 129,133
establishments. The sector had 2,341,135 employees, with a payroll of around $153.9 billion.
2.6 Professional, Scientific and Technical Services
Firms in this sector, NAICS 541, are engaged in processes where human capital is the
major input. These establishments offer the knowledge and skills of their employees, often on an
assignment basis, where an individual or team is responsible for the delivery of services to the
client. The individual industries of this subsector are defined on the basis of the particular
expertise and training of the services provider.
There is one boiler with an ultimate parent company under this NAICS identified as
affected by this proposal. According to the American Fact Finder (U.S. Census Bureau), in 2016
the sector had 805,745 parent companies that own 903,534 establishments. The sector had
8,799,893 employees, with a payroll of around $720.3 billion.
19

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3 EMISSION REDUCTIONS, ENGINEERING COST AND ECONOMIC
IMPACT ESTIMATES
This section presents the EPA's estimates of the emission reductions and compliance
costs associated with the proposed reconsideration NESHAP. As discussed in Section 1, this
proposed reconsideration is expected to affect 33 boilers (28 existing, 5 new). The EPA notes
that 16 of these boilers (13 existing, 3 new) are not expected to incur any compliance costs
associated with the proposal because they are expected to meet the proposed emissions limits. As
a result, the EPA expects that 17 boilers (15 existing, 2 new) would likely be affected by this
proposed action in that they would likely have to perform additional compliance actions to meet
the new proposed limits. The emission reductions are used to estimate the benefits and co-
benefits shown in Chapter 4 of this RIA, and the costs are used to estimate the economic and
small business impacts presently later in this RIA chapter.
The analysis in this RIA reflects proposed amendments to the current MACT standard,
including revisions to emissions limits for a variety of different source types and other revisions
to appropriately respond to the instructions within the U.S. Court of Appeals for the D.C. Circuit's
decisions. This analysis presents incremental emission reductions and costs separate from those
already accounted for in the January 2013 final ICI boilers MACT rule RIA. For existing units,
the EPA conducted a review to see if the impacts of the control strategy expected to be necessary
to meet the proposed emission limit had been used in the previous RIA. If so, the same control was
not accounted for in this revised analysis to avoid double counting of the emission reductions and
costs.
3.1 National Emissions Reductions and Other Emissions Changes
The EPA's estimates of emission reductions in tons per year (tpy) for the proposed
reconsideration NESHAP are shown in Table 3-1 below. The baseline emissions are primarily
based on compliance data available through two EPA databases: Compliance and Emissions
Data Reporting Interface (CEDRI) and WebFIRE. Data are also sourced from reported emission
test results collected for the previous industrial boilers MACT, and from fuel and control devices
installed on affected units. The proposed reconsideration standard would result in reductions of
HAP emissions. The HAP emissions reduced include hydrochloric acid (HC1), mercury (Hg),
20

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hydrogen fluoride (HF), and total non-mercury selected metals (TSM).8 We show these targeted
emission reductions by type of source and fuel type.
In addition, the proposed reconsideration standard will yield reductions in emissions of
non-targeted pollutants such as fine particulate matter (PM2.5) and sulfur dioxide (SO2) that are
concurrent with the HAP emission reductions. In each case where there is an exceedance of the
HC1, Hg, or PM emissions limits, the compliance cost analysis compares the baseline emissions
to the corresponding proposed emission limit for the unit's subcategory. The control device cost
for a unit was estimated if its baseline emissions exceeded their applicable proposed emission
limit for each pollutant requiring control. For PM and Hg, there is only one control technology
that can be applied to meet the proposed emissions limits for each pollutant. For HC1, there is
more than one control technology available.
Most of the Hg emissions reductions are expected to be achieved through the installation
of new fabric filters. Where baseline Hg emissions are found to be greater than the MACT floor
estimate, the cost of a fabric filter was estimated for an individual boiler or process heater unless
the unit already had a fabric filter.
When baseline PM emissions exceeded the proposed emissions limits, reductions are
expected to be achieved by the installation of new ESPs unless the unit already had a fabric filter
in the analysis for Hg reduction or unless an ESP was already reported to be installed as a
baseline control and the unit still required more than 5 percent PM emission reductions.
When HC1 baseline emissions are greater than the MACT floor estimate, increasing the
sorbent rate on an existing scrubber, adding a new scrubber, or installing a combination fabric
filter and dry injection (DIFF) system is applied to achieve the necessary HC1 emissions
reductions. Of these options, Scrubbers and DIFF systems are estimated to attain similar levels of
HC1 control.
Our analysis of the costs of compliance options listed above finds that the choice of
options is insensitive to nominal interest rates of 10% and 15%, which are much higher rates
than that for our main cost analysis (5.5%). The discussion and presentation of these cost
8 Metals include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium.
21

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sensitivity analysis results can be found in the Impacts and Cost Methodology memos for this
proposal.9
In total, including existing and new ICI boilers, the emission controls listed above yield
HAP emission reductions of about 34 tpy of HC1, 1 tpy of HF, and 0.002 tpy of Hg. Reductions
in PM2.5 from this proposal are estimated at 251 tpy (out of 333 tpy of total PM, which includes
PM10), and SO2 reductions are estimated at 393 tpy.
Table 3-1 Nationwide Annual Emission Reductions from ICI Boilers affected by the
Proposed Rule	



Annual Reductions, tons/year (tpy)


Source Type
Hg
HC1
HF
SO2
PM
PM25
TSM
Existing-Biomass
1.80E-03
14.5
0.11
43.8
333
251
2.3
Existing-Coal
1.90E-04
9.8
0.67
336
0
0
0
Total Existing
1.80E-04
24.3
0.78
379.8
333
251
2.3
New-Biomass
0
9.8
0.21
13.2
0
0
0
Total
1.80E-03
34.1
0.99
393
333
251
2.3
This proposed rule is also expected to lead to an increase in the non-targeted pollutant
carbon dioxide (CO2) emissions incremental to the baseline for this proposal as a result of
increased electricity consumption associated with operating existing and new control devices to
meet the proposed standards. The EPA estimates an increase in CO2 emissions of 14,550 tons
from existing sources, and 190 tons from new sources, thus leading to a total increase in CO2
emissions of 14,740 short tons per year.10 These calculations use the same baseline as that for the
9	The sensitivity analyses were done to explore the concept of hurdle rates as applied to investments in control
technologies included in the cost analysis for this proposal. In this analysis, the limited effects of hurdle rate may be
in part due to limited number of facilities that are affected by this decision variable. More discussion can be found in
the cost methodology memo for this proposal.
10	In order to calculate these values, it is necessary to convert tons (short) of emissions to metric tons. These values
may be converted to $/short ton using the conversion factor 0.90718474 metric tons per short ton for application to
the short ton CO2 emissions impacts provided in this rulemaking. We note that these estimates become 13,200, 170,
and 13,370 when converted from short tons to metric tons. Such conversion is needed to facilitate calculation of the
climate-related co-disbenefits, as discussed in Chapter 4 of this RIA.
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other analyses presented in this RIA, and are thus incremental from those already accounted for
in the January 2013 final ICI boilers MACT rule RIA as mentioned earlier in this chapter.
Details on the emission reductions estimates and other emissions changes in this RIA,
including emissions and control device data, can be found in the impacts methodology
memorandum prepared by the Eastern Research Group (ERG).11
3.2 Compliance Costs
Estimated compliance costs associated with meeting the proposed requirements include
the costs of pollution control capital as well as operating and maintenance costs, such as
additional labor, materials, or energy used for compliance activities and monitoring. No testing
costs are included because the proposed amendments do not change the requirements for testing
Table 3-2 Pollution Control Costs by Technology Type ($2016)*	
Operating and Maintenance
Cost type	Total Capital Investment	(O&M)	
Electrostatic Precipitators (ESP)
$7,623,000
$1,471,000
Fabric Filter and Dry Injection (DIFF)
$1,910,000
$951,000
Fabric Filter
$63,513,000
$9,304,000
Packed Bed Scrubber
$8,136,000
$2,181,000
Monitoring Costs
$1,790,000
$546,000
Total
$83,750,000
$13,723,000*
*This value is the highest O&M estimate for any year for which an annual cost estimate is provided. See Table 3-3
and Appendix E for the impacts memorandum. The O&M value is equivalent to those for 2027 and 2028.
The present value (PV) is a single estimate of costs (or other impacts) that reflect a
stream of annual compliance costs that are discounted to get an estimate for a specific date,
which can be in the present, past, or future. Values are discounted to reflect the impact of time
preferences. Guidance for E.O. 12866 requests impact estimates using a PV metric. To
implement E.O. 12866, the U.S. Office of Management and Budget (OMB) has requested
Federal agencies calculate the PV of the costs or cost savings of an action using both 7 percent
11 Eastern Research Group (ERG). Prepared for the US EPA/OAQPS/SPPD. Revised (2019) Methodology for
Estimating Impacts for Industrial, Commercial, Institutional Boilers and Process Heaters National Emission
Standards for Hazardous Air Pollutants. August 2019.
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and 3 percent end-of-period discount rates for those actions, including actions not deemed
economically significant.12
For this analysis an eight-year time period was selected as a measure of the full duration
of the expected effects of this action, as section 112 of the Clean Air Act (CAA) requires
Maximum Achievable Control Technology (MACT) standards such as this one to be reviewed
every eight years. We consider an eight-year time period for this analysis to be appropriate given
the CAA statutory review requirement. Given a compliance period of three years from
promulgation, compliance is projected to begin in 2021 as this rule is expected to be finalized in
late 2020. The eight years over which these calculations are made thus includes 2021-2028.
Table 3-3 below shows the undiscounted stream of annual costs for the proposal, as well
as their present values discounted to 2020. As seen below, the PV at a real discount rate of 3
percent is $128.1 million and $103.7 million at a real discount rate of 7 percent. Total capital
costs are expected to be incurred up to the date of full implementation of the promulgated rule
(late in 2023). Thus, we assumed total capital costs are incurred in equal shares across 2021,
2022, and 2023 as affected firms approach the compliance period. Additional capital
requirements are incurred in 2025 and 2027 by affected new units that are expected to install
pollution control devices and monitors.13
We assume operating and maintenance (O&M) costs are incurred beginning in 2024 and
continue until the final year of this analysis (2028). These annual costs start at about $13.5
million in 2021 with increments in 2026 and 2028 that are associated with the pollution control
devices and monitors expected to be installed in 2025 and 2027. More information on these
costs can be found in the impacts memorandum14 and the workbook for generating these
estimates.15
12	U.S. Office of Management and Budget. Memorandum. Executive Order 12866, "Regulatory Planning and
Review." September 30, 1993. Federal Register, Vol. 58, No. 190. Available on the Internet at
https://www.archives.gov/files/federal-register/executive-orders/pdf/12866.pdf.
13	Eastern Research Group (ERG). Revised (2019) Methodology for Estimating Costs for Industrial, Commercial,
Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants. August 2019.
Appendix E.
14	ERG. Revised (2019) Methodology for Estimating Costs for Industrial, Commercial, Institutional Boilers and
Process Heaters National Emission Standards for Hazardous Air Pollutants. August 2019.
15	U.S. EPA. E.O. 13771WorkbookICIBoilerseconofficial8-l-19.xls. Available in the docket for the proposed rule.
24

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Table 3-3 Undiscounted Costs, Discounted Costs, and 2020 Present Value Analysis for
the Proposed Rule (2016$)*	
	Undiscounted (Annual) Cost	Total Discounted Costs	
Year
Capital
O&M
3%
7%
2021
$27,789,600
$0
$25,431,400
$22,684,000
2022
27,789,600
0
24,690,700
21,201,000
2023
27,789,600
0
23,971,600
19,813,600
2024
0
13,499,100
11,305,300
8,995,000
2025
190,500
13,499,100
11,130,900
8,525,200
2026
0
13,601,900
10,744,600
7,921,700
2027
190,500
13,722,800
10,663,400
7,567,900
2028
0
13,722,800
10,211,000
6,976,000

2020 Present Value

128,148,900
103,684,500
*Total estimates may differ due to rounding conventions. Estimates are for 2021 through 2028. EPA has assumed
that capital for compliance purposes will be expended in an equal amount each year between promulgation and the
implementation deadline (3 years) due to a lack of information on precisely when affected facilities could be
expected to install control technologies and monitors in response to this proposal.
Table 3-4 summarizes the present value of the costs in 2016, accounting for the
additional compliance costs to industry, as well as the equivalent annualized value (EAV) over
the selected 8-year time frame. The EAV is the annualized present value of the costs. As seen
below, the EAV for the proposal in 2016 dollars at a discount rate of 3 percent is approximately
$18.3 million and $17.4 million at a discount rate of 7 percent.
Table 3-4 2020 Present Value (PV) of Costs and Equivalent Annualized Values (EAV)
for the Proposed Rule for E.O. 12866 (2016$)*	

2020 Present Value of_Costs
Equivalent Annualized Value of
Costs
7% Discount Rate
3% Discount Rate
$103,684,500
$128,148,000
$17,363,800
$18,255,600
*PV and EAV are calculated over an eight-year period from 2021 to 2028.
3.3 Economic Impact and Small Business Analysis
Although facility-specific economic impacts (e.g. closures) cannot be estimated by this
analysis, the EPA did conduct a screening analysis to quantify some economic impacts on
individual firms. For economic impact analyses of rules that directly affect one or several
industries, such as this proposal, the EPA often prepares a partial equilibrium analysis. In this
type of economic analysis, the focus of the effort is on estimating impacts to a single affected
industry or several affected industries, and all impacts of this rule to industries outside of those
25

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affected are assumed to be zero or inconsequential.16 If the compliance costs, which are key
inputs to an economic impact analysis, are small relative to the receipts of the affected industries,
then the impact analysis could consist of a calculation of annual (or annualized) costs as a
percent of sales for affected parent companies. This latter type of analysis is called a screening
analysis and is applied when a partial equilibrium or more complex economic impact analysis
approach is deemed unnecessary given the expected size of the impacts.
We conduct a screening analysis to estimate the economic impacts of this proposal, given
that the annualized total compliance costs are about $23 million in 2016 dollars, a very small
amount relative to the size of the affected industries listed in Section 2. This estimate of annual
total compliance costs is much less than those of previous NESHAP rules for this source
category.17 The analysis employed here is a "sales test", which determines annualized
compliance costs as a share of annual sales for each impacted parent company. The annualized
cost per sales for a company represents the maximum price increase in the affected product or
service needed for the company to completely recover the annualized costs imposed by the
regulation.
The EPA prefers a "sales test" as the impact methodology in economic impact analyses
as opposed to a "profits test", in which annualized compliance costs are calculated as a share of
profits.18 This is consistent with guidance published by the U.S. Small Business Administration
(SBA)'s Office of Advocacy, which suggests that cost as a percentage of total revenues is a
metric for evaluating cost impacts on small entities relative to large entities.19 This is because
revenues or sales data are commonly available for entities impacted by the EPA regulations and
profits data are often private or tend to misrepresent true profits earned by firms after
undertaking accounting and tax considerations. Firms and entities have incentive to minimize
16	U.S. EPA. Guidelines for Preparing Economic Analyses. May 2016. p. 9-17. Available at
https://www.epa.gov/sites/production/files/2017-09/documents/ee-0568-09.pdf.
17	For example, the total annual compliance costs estimated by the EPA for the December 2012 final ICI boiler
MACT reconsideration were $1.4 to $1.6 billion (2008 dollars). Adjusting to 2016 dollars would make the reduction
in costs even larger in a real sense. See https://www3.epa.gov/ttn/ecas/docs/ria/ici-boilers ria reconsider-
neshap 2012-12.pdf. p. 3 of cover memo for the RIA.
18	More information on sales and profit tests as used in analyses done by U.S. EPA can be found at
http://www.epa.gov/sbrefa/documents/rfaguidancell-00-06.pdf. pp. 32-33.
19	U.S. SBA, Office of Advocacy. 2010. A Guide for Government Agencies, How to Comply with the Regulatory
Flexibility Act, Implementing the President's Small Business Agenda and Executive Order 13272.
26

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their reported profits; thus, using reported profits may generate misleading estimates of the
economic impacts of a regulation on an affected firm or entity and their consumers.
While screening analyses are often employed to estimate impacts to small businesses or
entities as part an analysis in compliance with the Regulatory Flexibility Act (RFA) as amended
by the Small Business Regulatory Enforcement Fairness Act (SBREFA), a screening analysis
can also be employed in an economic impact analysis such as this one whose focus is on all
regulated companies, big and small. In addition, we also include a brief discussion of measures
of producer and consumer responsiveness to price changes (i.e., supply and demand elasticities)
to further characterize the economic impacts of these rules.
It should be noted that the compliance costs for the proposal were estimated in 2016
dollars. Hence, we use 2016 revenues to the extent possible for affected firms in this report in
order to be consistent in estimating economic impacts. We find that the great majority of the 26
companies affected are large, U.S.-owned multinational companies with substantial revenues
from paper, timber, and milling operations. Among such companies impacted by this proposal
are Louisiana Pacific, Weyerhaeuser, and Boise Cascade.
Using the current SBA small business size definitions, which is defined using employee
size or annual revenues depending on the sector to which a given parent company belongs, only
one of the affected companies is small according to the SBA small business size standards.20
These small business size standards for the industries in which these boilers operate range from
200 to 1,250 employees, or $15.0 to $32.5 million in annual revenues, where appropriate. We
generally find that the cost imposed on these companies is a very small fraction of the parent
companies' revenues and should yield small economic impacts on wood products producers and
the wood products market. The revenue estimate for these ultimate parent companies reflects all
product sales worldwide. In turn, such small economic impacts should yield small impacts on
customers (regardless of whether they are consumers of intermediate or end-use goods).
Based on the fact that the small businesses subject to this proposal will not incur any
compliance costs, we can certify that there is no significant economic impact on a substantial
20 SBA's small business size standards can be found on the Internet at https://www. sba. gov/document/support--
table-size-standards. These standards were updated on October I, 2017.
27

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number of small entities (SISNOSE) for either option of this proposed rule. Details on the
impacts by ultimate parent company can be found in the spreadsheet that accompanies the
economic impact analysis report.21 The annualized compliance costs are less than 0.7 percent of
2016 revenues for each impacted parent company. The median cost to sales ratio is 0.003
percent. Thus, the economic impacts should be minimal for these firms. A listing of affected
ultimate parent businesses and their economic impacts is found in Table 3-5. More information
on these impacts can be found in the spreadsheet for these calculations.22 No confidential
business information (CBI) was used in preparing these estimates.
Table 3-5 Impacts for Affected Ultimate Parent Businesses

Total Annualized Costs
Annualized Cost to Sales
Ultimate Parent Business
(2016$)
(%)
Koch Industries, Inc.
$0
0
Ameresco, Inc.
0
0
Anthony Timberlands, Inc
978,300
0.59
IHI Corp.
2,095,800
0.02
Coastal Forest Resources Company*
0
0
Hood Companies, Inc.
80,900
0.01
Resolute Forest Products
4,927,900
0.14
Kaluz, S.A. de C.V.
300,000
0.01
Packaging Corporation of America
3,982,100
0.07
Nine Dragons Paper
3,185,300
0.07
CMS Energy/Fortistar LLC
3,312,200
0.05
Louisiana Pacific Corp.
574,400
0.03
Hankins Lumber Company
0
0
International Paper
644,800
0.003
Paperweight Development Corp.
0
0
Marsh Furniture Company
651,200
0.70
P.H. Glatfelter Company
0
0
Domtar Corp.
702,400
0.01
Dominion Energy
0
0
WestRock
29,200
0.0002
Nippon Paper Industries Co., Ltd.
64,600
0.0007
Sonoco, Inc.
0
0
Weyerhaeuser Company
40,400
0.0006
West Fraser Timber Co., Ltd.
42,600
0.0014
Idaho Forest Group LLC
42,600
0.02
Boise Cascade
127,900
0.0033
* Small business.
21	Ibid.
22	U.S. EPA. IndBoilersMACTEconDataSheet.xls. Available in the docket for the proposed rule.
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Regarding possible impacts to markets, it should be noted that available estimates of
long-run responsiveness of price changes show that the price elasticity of demand for two of the
most impacted industries, wood products (NAICS 321) is -0.81,23 and for paper products
(NAICS 322) is -0.85. The price elasticity of supply for wood products is 3.0 to 5.0,24 and 0.28 to
1.65 for paper products.25 Assuming the affected industries are imperfectly competitive, based on
this information, one can conclude that demand will respond close to 1:1 to a change in output
price, and that supply is fairly elastic (i.e., will respond more than 1:1) to a change in output
price. The direct economic impact of this rule as measured by changes in price and output
appears relatively minor based on the low annualized cost to sales estimates and these
elasticities, and thus it is reasonable to infer that the price impacts on consumers from this
proposed rule should also be relatively minor. In addition, any other economic impacts, such as
changes in firm concentration within the affected industries, should be relatively minor.
3.4 Employment Impacts
Regarding employment impacts, environmental regulation may affect groups of workers
differently, as changes in abatement and other compliance activities cause labor and other
resources to shift. Standard benefit-cost analyses have not typically included a separate analysis
of regulation-induced employment impacts.26 In this section we discuss qualitatively the
potential employment impacts of this proposed rule.
An environmental regulation affecting these sectors is expected to have a variety of
transitional employment impacts, which may include reduced employment at facilities, as well as
increased employment for the manufacture, installation, and operation of pollution control
23ICF International. U.S. LNG Exports: Impacts on Energy Markets and the Economy. May 15, 2013. Submitted to
the American Petroleum Institute. Table 3-4. Estimate is prepared for NAICS 321. Available on the Internet at
https://fossil.energy.gov/ng regulation/sites/default/files/programs/gasregulation/authorizations/2013/orders/Ex Par
te07 03 13.pdf. Accessed July 25, 2019.
24	U.S. International Trade Commission. Hardwood Plywood from China. Investigation Nos. 701-TA-565 and 731-
TA-1341 (Final). Publication 4747. December 2017. Available on the Internet at
https://www.usitc. gov/publications/701 73 l/pub4747.pdf.
25	U.S. EPA. Economic Impact Analysis. Proposed Revisions to the National Emissions Standards for Hazardous
Air Pollutants, Subpart MM for the Pulp and Paper Industry. October 2016. p. 4-8. Available on the Internet at
https://www.epa.gov/sites/production/files/2016-12/documents/subpart mm eia 10 31 2016 final.pdf.
26	Labor costs associated with regulatory compliance activities are included as part of total costs in EPA's standard
benefit-cost analyses. See Section 3.1 of this RIA, for a discussion of operating, supervisory, and maintenance labor
hours for the operation of control devices, other labor costs associated with operation and maintenance, and labor
expenses required for monitoring, reporting, and record keeping.
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equipment.27 Labor costs and the amount of labor needed for operation of control devices, and
installation and operation of monitoring equipment and recordkeeping procedures can be found
in the control cost memorandum and related appendices and reports for this proposal as
discussed earlier in this RIA chapter. As one example of these impacts, the annual labor costs for
operation and maintenance of monitoring and recordkeeping procedures is $180,000 (2016$),
based on an estimate of 1,080 labor hours needed for these compliance categories.28 For this
proposed rule, the EPA expects some potential for small changes in the amount of labor needed
in different parts of the affected sectors.29 These employment impacts, both negative and
positive, are likely to be small or de minimus, particularly when considering the relatively small
economic impacts to affected sectors and firms as discussed earlier in Chapter 3 of this RIA.
3.5 Social Welfare Considerations
As stated in E.O. 12866, when a proposed regulatory action is deemed "significant", an
estimate of the regulation's social cost is compared to its social benefits to determine whether the
benefits justify the costs. The value of a regulatory action is traditionally measured by the change
in economic welfare that it generates. The regulation's welfare impacts, or the social costs
required to achieve environmental improvements, will extend to consumers and producers.
Consumers experience welfare impacts due to changes in market prices and consumption levels
associated with the rule. Producers experience welfare impacts resulting from changes in profits
corresponding with the changes in production costs, output levels, and market prices. However,
it is important to emphasize that these welfare impacts or social costs do not include benefits (or
disbenefits) that occur outside markets directly impacted by this action, that is, the value of
reduced or increased levels of air pollution with the regulation. These benefits are estimated
separately, and those for this proposed action can be found in Chapter 4. The net benefits of this
proposal account for both the social costs presented in this chapter and the social benefits (both
27	Schmalansee, R. and R. Stavins (2011). "A Guide to Economic and Policy Analysis for the Transport Rule."
White Paper. Boston, MA. Exelon Corp.
28	U.S. EPA. Information Collection Request for the Proposed National Emission Standards for Hazardous Air
Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters: Amendments.
ICR #2028.10. January, 2020.
29	The employment analysis in this RIA is part of EPA's ongoing effort to "conduct continuing evaluations of
potential loss or shifts of employment which may result from the administration or enforcement of [the Act]"
pursuant to CAA section 321(a).
30

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ancillary co-benefits from reduced PM2.5 and SO2 emissions and co-disbenefits from increased
CO2 emissions) presented in Chapter 4. Net benefits are presented in Chapter 5.
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4 BENEFITS ANALYSIS
Implementing emissions controls required by this NESHAP is expected to reduce HAP
emissions, including emissions of mercury (Hg), hydrochloric acid (HC1), and other HAPs. The
emission controls are also expected to reduce emissions of non-HAP pollutants, such as
particulate matter (including PM2.5) and SO2. In this section, we provide the benefits analysis for
this proposal. Data, resource, and methodological limitations prevented the EPA from
monetizing the human health benefits from reduced exposure to mercury, HC1, and other HAP
directly targeted by this proposal. In addition, the potential ancillary co-benefits from reduced
ecosystem effects and reduced visibility impairment from the reduction in PM2.5 and SO2
emissions are also not monetized here. The EPA provides a qualitative discussion of mercury,
HC1, and other HAP benefits later in this chapter. This discussion can also be found in section
4.7 of the recently promulgated Affordable Clean Energy (ACE) rule.30
In this section, we quantify the economic value of co-benefits of this proposal such as
those associated with potential reduction in PM2.5-related premature deaths and illnesses
expected to occur as a result of implementing this rule. PM2.5 and SO2 emissions reductions occur
as a result of implementing the proposed HAP emission controls described earlier in the RIA.
We estimate the total annual monetized co-benefits of the proposed rule to be $110
million to $250 million at a 3 percent discount rate and $95 million to $210 million at a 7 percent
discount rate in 2025, a snapshot year used to approximate the impacts in 2023 (the year of full
implementation).31 All estimates are reported in 2016 dollars and reflect the co-benefits
associated with reductions in both directly emitted PM2.5 and SO2. In addition, the climate co-
disbenefits resulting from additional emissions of CO2 are included in these monetized estimates.
The climate co-disbenefits in 2025 are estimated at $0.09 million at a 3 percent discount rate and
$0.01 million at a 7 percent discount rate.
30	U.S. EPA. Regulatory Impact Analysis for the Repeal of the Clean Power Plan, and the Emissions Guidelines for
Greenhouse Gases from Existing Electric Energy Generating Units. EPA-452/R-19-003. June 2019. Available at
https://www.epa.gov/sites/production/files/2019-06/documents/utilities ria final cpp repeal and ace 2019-06.pdf.
31	Benefit per ton estimates are available in five-year intervals (2020, 2025, 2030, and 2035). With 2025 as the
closest year to the year of full implementation (2023), we apply benefit per ton estimates for that year to best
approximate the monetized benefits of the proposal.
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4.1	Approach to Estimating Human Health Benefits
This section summarizes the EPA's approach to estimating the incidence and economic
value of the PIVh.s-related ancillary co-benefits estimated for this rule. The Regulatory Impact
Analysis (RIA) for the Particulate Matter (PM) National Ambient Air Quality Standards
(NAAQS)32 and the user manual for the BenMAP-CE program33 provide a full discussion of the
EPA's approach for quantifying the incidence and value of estimated air pollution-related health
impacts. In these documents, the reader can find the rationale for selecting the health endpoints
quantified; the demographic, health and economic data applied in the environmental Benefits
Mapping and Analysis Program—Community Edition (BenMAP-CE); modeling assumptions;
and the EPA's techniques for quantifying uncertainty.
Implementing this rule will affect the distribution of PM2.5 concentrations throughout the
U.S.; this includes locations both meeting and exceeding the NAAQS for PM and ozone. This
RIA estimates avoided PM2.5—related health impacts that are distinct from those reported in the
RIAs for the PM NAAQS.34 The PM2.5 NAAQS RIAs hypothesize, but do not predict, the
benefits and costs of strategies that States may choose to enact when implementing a revised
NAAQS; these costs and benefits are illustrative and cannot be added to the costs and benefits of
policies that prescribe specific emission control measures.
4.2	Estimating PM2.5, Ozone, and HAP Related Health Impacts
We estimate the quantity and economic value of air pollution-related effects by
estimating counts of air pollution-attributable cases of adverse health outcomes, assigning dollar
values to these counts, and assuming that each outcome is independent of one another. We
construct these estimates by adapting primary research—specifically, air pollution epidemiology
studies and economic value studies—from similar contexts. This approach is sometimes referred
to as "benefits transfer." Below we describe the procedure we follow for: (1) selecting air
pollution health endpoints to quantify; (2) calculating counts of air pollution effects using a
32	U.S. EPA. 2012b. Regulatory Impact Assessment for the Particulate Matter National Ambient Air Quality
Standards.
33	U.S. EPA. 2018. User Manual for Environmental Benefits Mapping and Analysis Program (BenMAP).
34	U.S. EPA. 2012a. Regulatory Impact Analysis for the Proposed Revisions to the National Ambient Air Quality
Standards for Particulate Matter. Available at https://www3.epa.gov/ttn/ecas/docs/ria/naaas-pm ria final 2012-
12.pdf.
33

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health impact function; (3) specifying the health impact function with concentration-response
parameters drawn from the epidemiological literature.
4.2.1 Selecting air pollution health endpoints to quantify
As a first step in quantifying PIVh.s-related human health impacts, the EPA consults the
Integrated Science Assessment for Particulate Matter (PM ISA).35 This document synthesizes
the toxicological, clinical and epidemiological evidence to determine whether each pollutant is
causally related to an array of adverse human health outcomes associated with either acute (i.e.,
hours or days-long) or chronic (i.e. years-long) exposure. For each outcome, the ISA reports this
relationship to be causal, likely to be causal, suggestive of a causal relationship, inadequate to
infer a causal relationship, or not likely to be a causal relationship.
The ISA for PM2.5 found acute exposure to PM2.5 to be causally related to cardiovascular
effects and mortality (i.e., premature death), and respiratory effects as likely-to-be-causally
related. The ISA identified cardiovascular effects and total mortality as being causally related to
long-term exposure to PM2.5 and respiratory effects as likely-to-be-causal; and the evidence was
suggestive of a causal relationship for reproductive and developmental effects as well as cancer,
mutagenicity and genotoxicity.
The EPA estimates the incidence of air pollution effects for those health endpoints listed
above where the ISA classified the impact as either causal or likely-to-be-causal. Table 4-1
reports the effects we quantified and those we did not quantify in this RIA. The list of benefit
categories not quantified shown in that table is not exhaustive. And, among the effects we
quantified, we might not have been able to completely quantify either all human health impacts
or economic values. The table below omits health effects associated with SO2 and NO2, and any
welfare effects such as acidification and nutrient enrichment. These effects are described in
Chapters 5 and 6 of the PMNAAQS RIA.36 Table 4-1 includes health effects associated with
HAP that were qualitatively evaluated: Hg, HC1, HF, and TSM.
35U.S. EPA. 2009. Integrated Science Assessment for Particulate Matter. EPA/600/R-08/139F.
36 U.S. EPA. 2012b. Regulatory Impact Assessment for the Particulate Matter National Ambient Air Quality
Standards.
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4.2.2 Health Effects from exposure to HAP
4.2.2.1 Mercury
Mercury (Hg) in the environment is transformed into a more toxic form, methylmercury
(MeHg). Because Hg is a persistent pollutant, MeHg accumulates in the food chain, especially
the tissue of fish. When people consume these fish, they consume MeHg. In 2000, the NAS
Study was issued which provides a thorough review of the effects of MeHg on human health
(NRC 2000).37 Many of the peer-reviewed articles cited in this section are publications originally
cited in the Mercury Study.38 In addition, the EPA has conducted literature searches to obtain
other related and more recent publications to complement the material summarized by the NRC
in 2000.
In its review of the literature, the NAS found neurodevelopmental effects to be the most
sensitive and best documented endpoints and appropriate for establishing a reference dose (RfD)
(NRC 2000); in particular NAS supported the use of results from neurobehavioral or
neuropsychological tests. The NAS report noted that studies on animals reported sensory effects
as well as effects on brain development and memory functions and supported the conclusions
based on epidemiology studies. The NAS noted that their recommended endpoints for a RfD are
associated with the ability of children to learn and to succeed in school. They concluded the
following: "The population at highest risk is the children of women who consumed large
amounts of fish and seafood during pregnancy. The committee concludes that the risk to that
population is likely to be sufficient to result in an increase in the number of children who have to
struggle to keep up in school."
The NAS summarized data on cardiovascular effects available up to 2000. Based on these
and other studies, the NRC concluded that "Although the data base is not as extensive for
cardiovascular effects as it is for other end points (i.e., neurologic effects), the cardiovascular
system appears to be a target for MeHg toxicity in humans and animals." The NRC also stated
that "additional studies are needed to better characterize the effect of methylmercury exposure on
blood pressure and cardiovascular function at various stages of life."
37	National Research Council (NRC). 2000. Toxicological Effects of Methylmercury. Washington, DC: National Academies
Press.
38	U.S. Environmental Protection Agency (U.S. EPA). 1997. Mercury Study Report to Congress, EPA-HQ-OAR-2009-0234-
3054. December. Available at http://www.epa.gov/hg/report.htm.
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Additional cardiovascular studies have been published since 2000. The EPA did not
develop a quantitative dose-response assessment for cardiovascular effects associated with
MeHg exposures, as there is no consensus among scientists on the dose-response functions for
these effects. In addition, there is inconsistency among available studies as to the association
between MeHg exposure and various cardiovascular system effects. The pharmacokinetics of
some of the exposure measures (such as toenail Hg levels) are not well understood. The studies
have not yet received the review and scrutiny of the more well-established neurotoxicity data
base.
The Mercury Study noted that MeHg is not a potent mutagen but is capable of causing
chromosomal damage in a number of experimental systems. The NAS concluded that evidence
that human exposure to MeHg caused genetic damage is inconclusive; they note that some earlier
studies showing chromosomal damage in lymphocytes may not have controlled sufficiently for
potential confounders. One study of adults living in the Tapajos River region in Brazil (Amorim
et al. 2000) reported a direct relationship between MeHg concentration in hair and DNA damage
in lymphocytes, as well as effects on chromosomes.39 Long-term MeHg exposures in this
population were believed to occur through consumption of fish, suggesting that genotoxic effects
(largely chromosomal aberrations) may result from dietary and chronic MeHg exposures similar
to and above those seen in the Faroes and Seychelles populations.
Although exposure to some forms of Hg can result in a decrease in immune activity or an
autoimmune response (ATSDR 1999), evidence for immunotoxic effects of MeHg is limited
(NRC 2000).40 Based on limited human and animal data, MeHg is classified as a "possible"
human carcinogen by the International Agency for Research on Cancer (IARC 1994)41 and in
IRIS (U.S. EPA 2002).42 The existing evidence supporting the possibility of carcinogenic effects
39	Amorim, M.I.M., D. Mergler, M.O. Bahia, H. Dubeau, D. Miranda, J. Lebel, R.R. Burbano, and M. Lucotte.
2000. Cytogenetic damage related to low levels of methyl mercury contamination in the Brazilian Amazon. An.
Acad. Bras. Cienc. 72(4): 497-507.
40	Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological Profile for Mercury. U.S.
Department of Health and Human Services, Public Health Service, Atlanta, GA.
41	International Agency for Research on Cancer (IARC). 1994. IARC Monographs on the Evaluation of
Carcinogenic Risks to Humans and their Supplements: Beryllium, Cadmium, Mercury, and Exposures in the Glass
Manufacturing Industry. Vol. 58. Jalili, H.A., and A.H. Abbasi. 1961. Poisoning by ethyl mercury toluene
sulphonanilide. Br. J. Indust. Med. 18(0ct.):303-308 (as cited in NRC, 2000).
42	U.S. Environmental Protection Agency (EPA). 2002. Integrated Risk Information System (IRIS) on
Methylmercury. National Center for Environmental Assessment. Office of Research and Development. Available at
http://www.epa.gov/iris/subst/0073.htm.
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in humans from low-dose chronic exposures is tenuous. Multiple human epidemiological studies
have found no significant association between Hg exposure and overall cancer incidence,
although a few studies have shown an association between Hg exposure and specific types of
cancer incidence (e.g., acute leukemia and liver cancer) (NRC 2000).
There is also some evidence of reproductive and renal toxicity in humans from MeHg
exposure. However, overall, human data regarding reproductive, renal, and hematological
toxicity from MeHg are very limited and are based on either studies of the two high-dose
poisoning episodes in Iraq and Japan or animal data, rather than epidemiological studies of
chronic exposures at the levels of interest in this analysis.
4.2.2.2 Hydrogen Chloride
Hydrogen chloride (HC1) is a gas that forms corrosive hydrochloric acid when it comes
into contact with water. It can cause irritation of the mucous membranes of the nose, throat, and
respiratory tract. Brief exposure to 35 ppm causes throat irritation, and levels of 50 to 100 ppm
are barely tolerable for 1 hour.43 Concentrations in typical human exposure environments are
much lower than these levels and rarely exceed the reference concentration.44 The greatest
impact is on the upper respiratory tract; exposure to high concentrations can rapidly lead to
swelling and spasm of the throat and suffocation. Most seriously exposed persons have
immediate onset of rapid breathing, blue coloring of the skin, and narrowing of the bronchioles.
Exposure to HC1 can lead to Reactive Airways Dysfunction Syndrome (RADS), a chemically, or
irritant-induced type of asthma. Children may be more vulnerable to corrosive agents than adults
because of the relatively smaller diameter of their airways. Children may also be more
vulnerable to gas exposure because of increased minute ventilation per kg and failure to evacuate
an area promptly when exposed. Hydrogen chloride has not been classified for carcinogenic
effects.45
43Agency for Toxic Substances and Disease Registry (ATSDR). Medical Management Guidelines for Hydrogen
Chloride. Atlanta, GA: U.S. Department of Health and Human Services. Available at
http://www.atsdr.cdc.gov/mmg/mmg.asp?id=758&tid=147#bookmark02.
44Table of Prioritized Chronic Dose-Response Values: http://www2.epa.gov/sites/production/files/2014-
05/documents/table 1 .pdf.
45U.S. Environmental Protection Agency (U.S. EPA). 1995. "Integrated Risk Information System File of Hydrogen
Chloride." Washington, DC: Research and Development, National Center for Environmental Assessment. This
material is available at http://www.epa.gov/iris/subst/0396.htm.
37

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4.2.2.3 Hydrogen Fluoride
Hydrogen fluoride (HF) is a gas that forms corrosive hydrofluoric acid when it comes in
contact with water. HF can cause eye irritation and irritation and congestion of the nose, throat,
and lungs.46 Exposure to 0.5 ppm for one hour causes upper respiratory tract irritation. Brief
inhalation exposure to high concentrations of gaseous HF can cause severe respiratory damage in
humans, including severe irritation and lung edema. Severe eye irritation and skin burns may
occur following eye or skin exposure in humans. Chronic (long-term) exposure in workers has
resulted in skeletal fluorosis, a bone disease. Animal studies have reported effects on the lungs,
liver, and kidneys from acute and chronic inhalation exposure to HF. Studies investigating the
carcinogenic potential of HF are inconclusive. The EPA has not classified HF for
carcinogenicity.
4.2.2.4. Total non-mercury selected metals (TSM)
TSM include antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead,
manganese, nickel, and selenium. The acute health effects associated with inhalation of these
metals are primarily respiratory system effects that include respiratory irritation, shortness of
breath, coughing and wheezing, inflammation of the lungs, pneumonia, lung congestion, lung
edema, and hemorrhage of the lung.47 Other organs and organ systems affected by acute
inhalation exposure to some TSM include skin, eyes, gastrointestinal system, and central nervous
system. Chronic effects of inhalation exposure to TSM include respiratory system effects such as
respiratory irritation, inflammation of the lungs, chronic bronchitis, chronic emphysema,
wheezing, asthma, and lung fibrosis. Effects of chronic inhalation exposure on other organs or
organ systems include irritation of the skin and mucous membranes, central nervous system
effects, kidney disease, and effects on the liver and immune system. Some TSM are also known
to be human carcinogens or reasonably anticipated to be human carcinogens. Lead is a TSM that
is of particular concern due to its developmental toxicity. While ingestion is usually the primary
46Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological Profile for Fluorides, Hydrogen
Fluoride and Fluorine. U.S. Public Health Service, U.S. Department of Health and Human Services, Atlanta, GA.
2003. http://www.atsdr.cdc.gov/ToxProfiles/tp.asp?id=212&tid=38
47 The main sources of information for the TSM health effects information are EPA's Integrated Risk Information
System (IRIS) the Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological Profiles.
Information on individual chemicals can be found at https://cfpub.epa.gov/ncea/iris drafts/atoz.cfm?list tvpe=alpha
and https://www.atsdr.cdc. gov/toxprofiledocs/index.html
38

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route of exposure for children, the health effects are the same for both oral and inhalation routes
of exposure. Early childhood and prenatal exposures to lead are associated with slowed cognitive
development, learning deficits and other effects.
Table 4-1 Human Health Effects of Ambient PM2.5, Ozone, and II\P
39

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Category
Effect
Effect
Effect
More


Quantified
Monetized
Information
Premature
mortality from
Adult premature mortality based on cohort
study estimates and expert elicitation estimates
~
~
PM ISA
exposure to PM2 5
(age >25 or age >30)




Infant mortality (age <1)
~
~
PM ISA
Morbidity from
Non-fatal heart attacks (age >18)
~
~
PM ISA
exposure to PM2 5
Hospital admissions—respiratory (all ages)
~
~
PM ISA

Hospital admissions—cardiovascular (age
~
~
PM ISA

>20)




Emergency room visits for asthma (all ages)
~
~
PM ISA

Acute bronchitis (age 8-12)
~
~
PM ISA

Lower respiratory symptoms (age 7-14)
~
~
PM ISA

Upper respiratory symptoms (asthmatics age
9-11)
~
~
PM ISA

Exacerbated asthma (asthmatics age 6-18)


PM ISA

Lost work days (age 18-65)
¦/
¦/
PM ISA

Minor restricted-activity days (age 18-65)
¦/
¦/
PM ISA

Chronic Bronchitis (age >26)
—
—
PM ISA1

Emergency room visits for cardiovascular
—
—
PM ISA1

effects (all ages)




Strokes and cerebrovascular disease (age 50-
—
—
PM ISA1

79)




Other cardiovascular effects (e.g., other ages)
—
—
PM ISA2

Other respiratory effects (e.g., pulmonary
function, non-asthma ER visits, non-bronchitis
—
—
PM ISA2

chronic diseases, other ages and populations)




Reproductive and developmental effects (e.g.,
low birth weight, pre-term births, etc.)
—
—
PM ISA2-3

Cancer, mutagenicity, and genotoxicity effects
—
—
PM ISA2-3
Mortality from
Premature mortality based on short-term study
—
—
Ozone ISA
exposure to ozone
estimates (all ages)




Premature mortality based on long-term study
—
—
Ozone ISA1

estimates (age 30-99)



Morbidity from
Hospital admissions—respiratory causes (age
—
—
Ozone ISA
exposure to ozone
>65)




Emergency department visits for asthma (all
ages)
—
—
Ozone ISA

Exacerbated asthma (asthmatics age 6-18)
—
—
Ozone ISA

Minor restricted-activity days (age 18-65)
—
—
Ozone ISA

School absence days (age 5-17)
—
—
Ozone ISA

Decreased outdoor worker productivity (age
18-65)
—
—
Ozone ISA1

Other respiratory effects (e.g., premature
aging of lungs)
—
—
Ozone ISA2

Cardiovascular and nervous system effects
—
—
Ozone ISA2

Reproductive and developmental effects
—
—
Ozone ISA2-3
Morbidity from
exposure to methyl
Neurologic effects - IQ loss
—
—
IRIS; NRC,
20001
mercury
Other neurologic effects (e.g., developmental
delays, memory, behavior
—
—
IRIS; NRC,
20002

Cardiovascular effects
—
—
IRIS; NRC,
20002-3
40

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Genotoxic, immunologic, and other toxic
effects
—
—
IRIS; NRC,
20002,3
Morbidity from
exposure to
hydrogen chloride
Upper respiratory tract irritation
—
—
ATSDR
Asthma
—
—
ATSDR
Morbidity from
exposure to
hydrogen fluoride
Eye irritation
—
—
ATSDR
Upper respiratory tract irritation and
inflammation
—
—
ATSDR
Bone disease
—
—
ATSDR
Damage to liver, kidney, or lungs
—
—
ATSDR
Morbidity from
exposure to total
non-mercury
selected metals
(TSM)
Respiratory system effects such as irritation,
inflammation of the lungs, chronic bronchitis,
and pneumonia


IRIS; ATSDR
Cancer - lung, nasal, and potentially other
sites
—
—
IRIS; ATSDR
Neurologic effects - learning disabilities, brain
damage, other central nervous system effects
—
—
IRIS; ATSDR
Effects on skin, eye, kidney, liver, and
immune system
—
—
IRIS; ATSDR
1 We assess these benefits qualitatively due to data and resource limitations for this analysis. In other analyses we
quantified these effects as a sensitivity analysis.
2 We assess these benefits qualitatively because we do not have sufficient confidence in available data or methods.
We assess these benefits qualitatively because current evidence is only suggestive of causality or there are other
significant concerns over the strength of the association.
4.3 Quantifying Cases of PM2.5-Attributable Premature Death
For adult PM-related mortality, we use the effect coefficients from two epidemiology
studies examining two large population cohorts: the American Cancer Society (ACS) cohort48
and the Harvard Six Cities cohort ).49 The ISA concluded that the analyses of the ACS and Six
Cities cohorts provide the strongest evidence of an association between long-term PM2.5
exposure and premature mortality, with support from additional cohort studies. The Scientific
Advisory Board's Health Effects Subcommittee (SAB-HES) also supported using effect
estimates from these two analyses to estimate the benefits of PM reductions.50 There are distinct
attributes of both the ACS and Six Cities cohort studies that make them well-suited for use in
48	Krewski D, Jerrett M, Burnett RT, Ma R, Hughes E, Shi Y, et al. 2009. Extended follow-up and spatial analysis of
the American Cancer Society study linking particulate air pollution and mortality. Res Rep Health Eff Inst 5-114;
discussion 115-36.
49	Lepeule J, Laden F, Dockery D, Schwartz J. 2012. Chronic exposure to fine particles and mortality: an extended
follow-up of the Harvard Six Cities study from 1974 to 2009. Environ Health Perspect 120:965-970;
doi: 10.1289/ehp. 1104660.
50	U.S. EPA-SAB. 2010. Review of EPA's Draft Health Benefits of the Second Section 812 Prospective Study of the
CAA.
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PM benefits (or co-benefits) assessments and thus we present PM2.5 related effects derived using
relative risk estimates from both cohorts.
The PM ISA, which was twice reviewed by the Clean Air Scientific Advisory Committee
of the EPA's Science Advisory Board (SAB-CASAC),51'52 concluded that there is a causal
relationship between mortality and both long-term and short-term exposure to PM2.5 based on the
body of scientific evidence. The PM ISA also concluded that the scientific literature supports the
use of a no-threshold log-linear model to portray the PM-mortality concentration-response
relationship while recognizing potential uncertainty about the exact shape of the concentration-
response function. The PM ISA, which informed the setting of the 2012 PM NAAQS, reviewed
available studies that examined the potential for a population-level threshold to exist in the
concentration-response relationship. Based on such studies, the ISA concluded that the evidence
supports the use of a "no-threshold" model and that "little evidence was observed to suggest that
a threshold exists." 53 Consistent with this evidence, the EPA historically has estimated health
impacts above and below the prevailing NAAQS.54
Following this approach, we report the estimated PM2.5-related benefits (in terms of both
health impacts and monetized values) calculated using a log-linear concentration-response
function that quantifies risk from the full range of simulated PM2.5 exposures.55 When setting the
2012 PM NAAQS, the Administrator also acknowledged greater uncertainty in specifying the
"magnitude and significance" of PM-related health risks at PM concentrations below the
NAAQS. As noted in the preamble to the 2012 PM NAAQS final rule, the "EPA conclude[d]
51	U.S. EPA-SAB. 2008. Review of EPA's Integrated Science Assessment for Particulate Matter (First External
Review Draft, December 2008).
52	U.S. EPA-SAB. 2009. Review of Integrated Science Assessment for Particulate Matter (Second External Review
Draft, July 2009).
53	U.S. EPA-SAB. 2009. Review of Integrated Science Assessment for Particulate Matter (Second External Review
Draft, July 2009).
54	The Federal Register Notice for the 2012 PM NAAQS notes that "[i]n reaching her final decision on the
appropriate annual standard level to set, the Administrator is mindful that the CAA does not require that primary
standards be set at a zero-risk level, but rather at a level that reduces risk sufficiently so as to protect public health,
including the health of at-risk populations, with an adequate margin of safety. On balance, the Administrator
concludes that an annual standard level of 12 ug/m3 would be requisite to protect the public health with an
adequate margin of safety from effects associated with long- and short-term PM2.5 exposures, while still
recognizing that uncertainties remain in the scientific information."
55	U.S. EPA-SAB. 2009. Review of Integrated Science Assessment for Particulate Matter (Second External Review
Draft, July 2009), and NRC. 2002. Estimating the Public Health Benefits of Proposed Air Pollution Regulations.
Washington, D.C.
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that it [was] not appropriate to place as much confidence in the magnitude and significance of the
associations over the lower percentiles of the distribution in each study as at and around the long-
term mean concentration."56 The preamble separately noted that "[a]s both the EPA and CASAC
recognize, in the absence of a discernible threshold, health effects may occur over the full range
of concentrations observed in the epidemiological studies." 57 In general, we are more confident
in the size of the risks we estimate from simulated PM2.5 concentrations that coincide with the
bulk of the observed PM concentrations in the epidemiological studies that are used to estimate
the benefits. Likewise, we are less confident in the risk we estimate from simulated PM2.5
concentrations that fall below the bulk of the observed data in these studies.58 In the RIA
developed for the recently promulgated Affordable Clean Energy (ACE) rule, the EPA reported
the number of estimated PM-related premature death occurring at or above various concentration
levels. As described further below, we lacked the air quality modeling simulations to perform
such an analysis for this proposed rule and thus report the total number of avoided PM2.5-related
premature deaths using the traditional log-linear no-threshold model noted above.
4.4 Economic Valuation
After quantifying the change in adverse health impacts, we estimate the economic value
of these avoided impacts. Reductions in ambient concentrations of air pollution generally lower
the risk of future adverse health effects by a small amount for a large population. Therefore, the
appropriate economic measure is willingness to pay (WTP) for changes in risk of a health effect.
For some health effects, such as hospital admissions, WTP estimates are generally not available,
so we use the cost of treating or mitigating the effect. These cost-of-illness (COI) estimates
generally (although not necessarily in every case) understate the true value of reductions in risk
of a health effect. They tend to reflect the direct expenditures related to treatment but not the
56	78 FR 3154, 15 January 2013.
57	78 FR 3149, 15 January 2013.
58	The Federal Register Notice for the 2012 PM NAAQS indicates that "[i]n considering this additional population
level information, the Administrator recognizes that, in general, the confidence in the magnitude and significance of
an association identified in a study is strongest at and around the long-term mean concentration for the air quality
distribution, as this represents the part of the distribution in which the data in any given study are generally most
concentrated. She also recognizes that the degree of confidence decreases as one moves towards the lower part of
the distribution."
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value of avoided pain and suffering from the health effect. The unit values applied in this
analysis are provided in Table 5-9 of the PM NAAQS RIA for each health endpoint.59
Avoided premature deaths account for 98 percent of monetized PM-related benefits. The
economics literature concerning the appropriate method for valuing reductions in premature
mortality risk is still developing. The value for the projected reduction in the risk of premature
mortality is the subject of continuing discussion within the economics and public policy analysis
community. Following the advice of the SAB's Environmental Economics Advisory Committee
(SAB-EEAC), the EPA currently uses the value of statistical life (VSL) approach in calculating
estimates of mortality benefits, because we believe this calculation provides the most reasonable
single estimate of an individual's WTP for reductions in mortality risk (U.S. EPA-SAB, 2000).60
The VSL approach is a summary measure for the value of small changes in mortality risk
experienced by a large number of people.
The EPA continues work to update its guidance on valuing mortality risk reductions and
consulted several times with the SAB-EEAC on the issue. Until updated guidance is available,
the EPA determined that a single, peer-reviewed estimate applied consistently best reflects the
SAB-EEAC advice it has received. Therefore, the EPA applies the VSL that was vetted and
endorsed by the SAB in the Guidelines for Preparing Economic Analyses (U.S. EPA, 2016)
while the EPA continues its efforts to update its guidance on this issue.61 This approach
calculates a mean value across VSL estimates derived from 26 labor market and contingent
valuation studies published between 1974 and 1991. The mean VSL across these studies is $6.3
million (2000$).62
The EPA is committed to using scientifically sound, appropriately reviewed evidence in
valuing changes in the risk of premature death and continues to engage with the SAB to identify
scientifically sound approaches to update its mortality risk valuation estimates. Most recently,
the Agency proposed new meta-analytic approaches for updating its estimates which were
59	U.S. EPA. 2012a. Regulatory Impact Analysis for the Proposed Revisions to the National Ambient Air Quality
Standards for Particulate Matter.
60	U.S. EPA-SAB. 2000. An SAB Report on EPA's White Paper Valuing the Benefits of Fatal Cancer Risk
Reduction.
61	U.S. EPA. Guidelines for Preparing Economic Analyses. 2016.
62	In 1990$, this base VSL is $4.8 million. In 2016$, this base VSL is $10.7 million.
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subsequently reviewed by the SAB-EEAC. The EPA is taking the SAB's formal
recommendations under advisement (U.S. EPA 2017).63
4.5 Benefit-per-Ton Estimates
EPA did not conduct air quality modeling for this rule. Specifically, EPA believes that
the emissions reductions due to this rule are small and EPA did not expect full air quality
modeling to show a significant difference between the policy and baseline model runs. Instead,
we used a "benefit-per-ton" (BPT) approach to estimate the co-benefits of this rulemaking.
These BPT estimates provide the total monetized human health co-benefits (the sum of
premature mortality and premature morbidity) of reducing one ton of PM2.5 (or PM2.5 precursor
such as NOx or SO2) from a specified source. Specifically, in this analysis, we multiplied the
estimates from the "Industrial Point Sources" sector by the corresponding emission reductions.
The method used to derive these estimates is described in the Technical Support Document
(TSD) on estimating the benefits-per-ton of reducing PM2.5 and its precursors from 17 sectors.64
One limitation of using the BPT approach is an inability to provide estimates of the health
benefits associated with exposure to HAP, CO, NO2, or ozone.
As noted below in the characterization of uncertainty, all BPT estimates have inherent
limitations. Specifically, all national-average BPT estimates reflect the geographic distribution of
the modeled emissions, which may not exactly match the emission reductions that would occur
due to rulemaking, and they may not reflect local variability in population density, meteorology,
exposure, baseline health incidence rates, or other local factors for any specific location. The
photochemical modeled emissions of the industrial point source sector-attributable PM2.5
concentrations used to derive the BPT values may not match the change in air quality resulting
from the emissions controls described in Section 3. For this reason, the health co-benefits
reported here may be larger, or smaller, than those realized through this rule. However, when
choosing to utilize the EPA's BPT approach for this analysis, the spatial distribution of
emissions for this particular sector is similar to that of the inventory used to derive the BPT.
EPA confirmed that the spatial distribution of the industrial boiler facility locations were not
63	U.S. EPA. SAB Review of EPA's Proposed Methodology for Updating Mortality Risk Valuation Estimates for
Policy Analysis. 2017.
64	U.S. EPA. 2018. Estimating the Benefit per Ton of Reducing PM2.5 Precursors from 17 Sectors. Technical
Support Document.
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unusually concentrated in one particular region of the country and tend to be located in areas
with industrial point sources.
Thus, EPA assumed that although PM2.5 emission reductions resulting from this rule are
approximately 0.4% of the PM2.5 annual emissions and 0.04% of the SO2 emissions attributable
to the BPT Industrial Point Sources category, the emission changes due to this rule scale
linearly relative to the BPT Industrial Point Sources category. Combining the spatial
representativeness of the sector with the small changes in emissions considered in this
rulemaking, the difference in the quantified health benefits that result from the BPT approach
compared with if EPA had used a full-form air quality model should be minimal. We are taking
comment on the above assumptions as well as the utility of performing full-form modeling for
the final rule.
Even though we assume that all fine particles have equivalent health effects, the BPT
estimates vary across precursors depending on the location and magnitude of their impact on
PM2.5 levels, which drive population exposure. The sector-specific modeling does not provide
estimates of the PM2.5-related co-benefits associated with reducing VOC emissions, but these
unquantified co-benefits are generally small compared to other PM2.5 precursors.65
Over the last year and a half, the EPA systematically compared the changes in benefits,
and concentrations where available, from its BPT technique and other reduced-form techniques
to the changes in benefits and concentrations derived from full-form photochemical model
representation of a few different specific emissions scenarios. Reduced form tools are less
complex than the full air quality modeling, requiring less agency resources and time. That work,
in which we also explore other reduced form models is referred to as the "Reduced Form Tool
Evaluation Project" (Project), began in 2017, and the initial results were available at the end of
2018. The Agency's goal was to create a methodology by which investigators could better
understand the suitability of alternative reduced-form air quality modeling techniques for
estimating the health impacts of criteria pollutant emissions changes in the EPA's benefit-cost
analysis, including the extent to which reduced form models may over- or under-estimate
65 U.S. EPA. 2012a. Regulatory Impact Analysis for the Proposed Revisions to the National Ambient Air Quality
Standards for Particulate Matter.
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benefits (compared to full-scale modeling) under different scenarios and air quality
concentrations. The EPA Science Advisory Board (SAB) recently convened a panel to review
this report.66 In particular, the SAB will assess the techniques the Agency used to appraise these
tools; the Agency's approach for depicting the results of reduced-form tools; and, steps the
Agency might take for improving the reliability of reduced-form techniques for use in future
Regulatory Impact Analyses.
The scenario-specific emission inputs developed for this project are currently available
online. The study design and methodology are described in the final report summarizing the
results of the project, available here. Results of this project found that total PM2.5 BPT values
were within approximately 10 percent of the health benefits calculated from full-form air quality
modeling when analyzing the Pulp and Paper sector. The ratios for individual species varied,
and the report found that the ratio for the directly emitted PM2.5 for the pulp and paper sector
was 0.7 for the BPT approach compared to 1.0 for full air quality modeling combined with
BenMAP. As the Pulp and Paper sector and the Industrial Boilers sector share a similar spatial
distribution, we have greater confidence that this ratio reflected in the pulp and paper sector
would also apply to the Boiler sector. This provides some initial understanding of the
uncertainty which is associated with using the BPT approach instead of full air quality
modeling.
4.6 PM2.5-Co-benefits Results
Table 4-2 summarizes the monetized PM and S02-related health co-benefits, including
the emission reductions and BPT estimates using discount rates of 3 percent and 7 percent. Table
4-3 presents the total health related co-benefits of reducing emissions of PM2.5 and SO2.
66 85 FR 23823. April 29, 2020.
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Table 4-2 Estimated PM2.5-related Ancillary Co-benefits of Proposed Reconsideration
(2016$)	
Epidemiologic study used to quantify PM-relatedpremature deaths
Krewski et al. (2009)	Lepeule et al. (2012)
Pollutant	Benefit per ton	Benefit per ton	Benefit per ton	Benefit per ton
(3% discount rate) (7% discount rate) (3% discount rate) (7% discount rate)
PM25	$330,000	$300,000	$790,000	$690,000
S02	$52,000	$47,000	$120,000	$100,000
Table 4-3 Summary of Estimated PlVb.sand SCh-related Ancillary Co-benefits of Proposed
Reconsideration (millions of 2016$)	

Epidemiologic study used to quantify PM and SO 2-
-relatedpremature deaths


Krewski et al. (2009)
Lepeule et al. (2012)
Pollutant
Benefits
Benefits
Benefits
Benefits

(3% discount rate)
(7% discount rate)
(3% discount rate) (7% discount rate)
PM25
$84
$76
$200
$170
S02
$21
$19
$49
$40
Total
$110
$95
$250
$210
* Columns may not sum due to rounding.
Characterizing Uncertainty in the Estimated PM2.5 Co-Benefits
In any complex analysis using estimated parameters and inputs from a variety of models,
there are likely to be many sources of uncertainty. This analysis is no exception. This analysis
includes many data sources as inputs, including emission inventories, air quality data from
models (with their associated parameters and inputs), population data, population estimates,
health effect estimates from epidemiology studies, economic data for monetizing benefits, and
assumptions regarding the future state of the world (i.e., regulations, technology, and human
behavior). Each of these inputs are uncertain and generate uncertainty in the co-benefits
estimate. When the uncertainties from each stage of the analysis are compounded, even small
uncertainties can have large effects on the total quantified co-benefits. Therefore, the estimates
of annual co-benefits should be viewed as representative of the magnitude of co-benefits
expected, rather than the actual co-benefits that would occur every year.
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This RIA does not include the type of detailed uncertainty assessment found in the 2012
PM NAAQS RIA because we lack the necessary air quality input and monitoring data. Also,
emissions reductions were not significant enough to make performing an air quality model run
worthwhile. As a result, we did not have the inputs to run the benefits model. However, the
results of the uncertainty analyses presented in the PM NAAQS RIA can provide some
information regarding the uncertainty inherent in the co-benefits results presented in this
analysis. Sensitivity analyses conducted for the PM NAAQS RIA indicate that alternate
cessation lag assumptions could change the PM2.5-related mortality benefits discounted at 3
percent by between 10 percent and -27 percent and that alternate income growth adjustments
could change the PM2.5-related mortality benefits by between 33 percent and -14 percent.
4.7 Climate Co-Disbenefits
With the additional operation of control devices associated with the proposed rule, CO2
emissions will be generated as a result of the additional electricity required to operate them. The
estimate of additional CO2 emissions is presented in Chapter 3. We calculate the co-disbenefit
associated with these additional CO2 emissions using an interim measure of the domestic social
cost of carbon (SC-CO2). The SC-CChis an estimate of the monetary value of impacts associated
with marginal changes in CO2 emissions in a given year. It includes a wide range of anticipated
climate impacts, such as net changes in agricultural productivity and human health, property
damage from increased flood risk, and changes in energy system costs, such as reduced costs for
heating and increased costs for air conditioning. It is typically used to assess the avoided
damages as a result of regulatory actions (i.e., benefits of rulemakings that lead to an incremental
reduction in cumulative global CO2 emissions). The SC-CO2 estimates used in this analysis focus
on the direct impacts of climate change that are anticipated to occur within U.S. borders.
The SC-CO2 estimates presented here are interim values developed under E.O. 13783 for
use in regulatory analyses until improved domestic estimates can be developed, which will take
into consideration the recent recommendations from the National Academies of Sciences,
Engineering, and Medicine (2017) for a comprehensive update to the current methodology to
ensure that the social cost of greenhouse gas estimates reflect the best available science.67 The
67 See National Academies of Sciences, Engineering, and Medicine, Valuing Climate Damages: Updating
Estimation of the Social Cost of Carbon Dioxide, Washington, D.C., January 2017.
http://www.nap.edu/catalog/24651/valuing-climate-changes-updating-estimation-of-the-social-cost-of.
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climate co-disbenefits associated with the additional 14,700 short tons of CO2 emissions
generated as a result of the requirements of this proposed rule are $93,600 at a 3 percent discount
rate and $13,400 at a 7 percent discount rate, all in 2016 dollars.68 These co-disbenefits are
estimated for 2025 using the domestic social cost of carbon (SC-CO2) ranging from $1/ metric
ton and $7/metric ton (2016 dollars) to be consistent with the year for the PM2.5 and SO2 BPTs
applied to generate those monetized co-benefits.69'70'71 The procedure for this calculation,
background on its methodology, and a discussion of limitations and assumptions associated with
the calculation of SC-CO2 can be found in detail in Chapter 4 of the RIA for the recently
promulgated ACE rule.72
68	In order to calculate these values, it is necessary to convert tons (short) of emissions to metric tons. These values
may be converted to $/short ton using the conversion factor 0.90718474 metric tons per short ton for application to
the short ton CO2 emissions impacts provided in this rulemaking. Hence, 15,000 short tons of emissions becomes
13,300 metric tons of emissions.
69	These SC-CO2 values are stated in $/metric ton CO2 and rounded to the nearest dollar. Such a conversion does not
change the underlying methodology, nor does it change the meaning of the SC-CO2 estimates. For both metric and
short tons denominated SC-CO2 estimates, the estimates vary depending on the year of CO2 emissions and are
defined in real terms, i.e., adjusted for inflation using the Gross Domestic Product (GDP) implicit price deflator.
70	To account for ethical considerations of future generations and potential uncertainty in the discount rate over long
time horizons, Circular A-4 suggests "further sensitivity analysis using a lower but positive discount rate in addition
to calculating net benefit using discount rates of 3 and 7 percent" (page 36) and notes that research from the 1990s
suggests intergenerational rates "from 1 to 3 percent per annum" (OMB, 2003). We consider the uncertainty in this
key assumption by calculating the domestic SC- CO2 based on a 2.5 percent discount rate, in addition to the 3 and 7
percent used in the main analysis. Based on a 2.5 percent discount rate, the domestic climate co-disbenefits of the
proposed action in 2025 is $ $0.14 million in 2016 dollars, with a value of $10/metric ton applied to generate the
estimate. Additional discussion of discounting and other quantified sources of uncertainty is provided in the RIA for
the recently promulgated ACE rule.
71	In addition to requiring reporting of domestic impacts, Circular A-4 states that when an agency "evaluate[s] a
regulation that is likely to have effects beyond the borders of the United States, these effects should be reported
separately" (page 15). This guidance is relevant to the valuation of damages from CO2 and other GHGs, given that
GHGs contribute to damages around the world independent of the country in which they are emitted. The global
climate co-disbenefits of the proposed action in 2025 using global SC- CO2 estimates based on both 3 and 7 percent
discount rates are $0.08 million and 0.71 million in 2016 dollars, respectively.
72	U.S. EPA. Regulatory Impact Analysis for the Repeal of the Clean Power Plan, and the Emissions Guidelines for
Greenhouse Gases from Existing Electric Energy Generating Units. EPA-452/R-19-003. June 2019. Available at
https://www.epa.gov/sites/production/files/2019-06/documents/utilities ria final cpp repeal and ace 2019-06.pdf.
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5 BENEFIT-COST COMPARISON
In this section, we present a comparison of the benefits and costs of this regulation. As
explained in the previous sections, all costs and benefits outlined in this RIA are estimated as the
change from the baseline, which reflects the requirements already promulgated in the January
2013 final ICI boilers MACT standard. As stated earlier in this RIA, there is no monetized
estimate of the benefits for the HAP emission reductions expected to occur as a result of this
proposal. We do present monetized estimates for other impacts of this proposal, such as ancillary
co-benefits from reductions in PM2.5 and SO2 emissions, and ancillary co-disbenefits from
increases in CO2 emissions.
5.1 Results
As shown in Chapter 4, the estimated monetized benefits from the HAP emission
reductions of targeted pollutants are not quantified, but the total estimated monetized ancillary
co-benefits due to reductions in non-targeted pollutants such as PM2.5 and SO2 from
implementation of the proposed rule are approximately $110 million to $250 million in 2025
(2016 dollars) at a 3 percent discount rate, where 2025 is a year used to approximate impacts in
the year of full MACT implementation (2023). Estimates of benefits including co-benefits and
costs for 2025 and for co-benefits discounted at 3 percent and 7 percent are found in Table 5-1.
The climate disbenefits from additional CO2 emissions presented in section 4.7 are accounted for
in these estimates.
The EPA presents estimates of the present value of the ancillary co-benefits (including
co-disbenefits) and costs, assuming an eight year period from expected promulgation of the rule
beginning in 2021. These estimates reflect that there is not an estimate of monetized benefits
from affected HAP emission reductions that occur as a result of this proposal. The present value
(PV) of the net benefits considering ancillary co-benefits and co-disbenefits, in 2016 dollars and
discounted to 2020, is $530 million to $1,000 million when using a 7 percent discount rate and
$600 million to $1,520 million when using a 3 percent discount rate. We represent the present
value of unmonetized benefits from affected HAP emission reductions as a C, and this is part of
the net benefits estimate. The equivalent annualized values (EAV), an estimate of the annualized
value of the net benefits considering ancillary co-benefits and co-disbenefits consistent with the
present values, is $70 million to $160 million per year when using a 7 percent discount rate and
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$80 million to $220 million per year when using a 3 percent discount rate. We represent the
equivalent annualized value of unmonetized benefits from affected HAP emission reductions as a
D, and this is part of the net benefits estimate. The EAV represents a flow of constant annual
values that, had they occurred in each year from 2021 to 2028, would yield an equivalent PV.
The EAV represents the value of a typical cost or benefit (including ancillary co-benefits and co-
disbenefits) for each year of the analysis, in contrast to the year-specific estimates mentioned
earlier for the snapshot year of 2025. The comparison of benefits and costs in PV and EAVs
terms can be found in Table 5-1. Estimates in the table are presented as rounded values.
Table 5-1 Summary of Present Values and Equivalent Annualized Values for Annual
Costs, Monetized Ancillary Co-Benefits, and Monetized Net Benefits (Including Ancillary
Co-Disbenefits) for the Proposed Rule (millions of 2016 dollars)a'b	
3% Discount Rate	7% Discount Rate
Targeted Benefits0	C	C
Ancillary Co-Benefits	$730 to $1,650	$630 to $1,100
Costd	$130	$100
Net Benefits®	$600 to $1,520 + C	$530 to $1,000 + C
Targeted Benefitsf	D	D
Ancillary Co-Benefits	$100 to 240	$90 to 180
Costs	18	17
Net Benefits	$80 to 220 + D	$70 to 160 + D
a All estimates in this table are rounded to one decimal point, so numbers may not sum due to independent rounding.
b All estimates reflect the amendments to the ICI Boilers MACT standard included in this proposal from a baseline
that includes the control technologies applied to meet the MACT standard.
0 C represents the present value of unqualified benefits from reductions in targeted HAP emissions
d The annualized present value of costs and benefits are calculated over an 8 year period from 2021 to 2028.
e The total monetized ancillary co-benefits reflect the human health benefits associated with reducing exposure to
PM2 5 through reductions of directly emitted PM2 5 and SO2. Monetized ancillary co-benefits include many, but not
all, health effects associated with PM2 5 exposure. Co-benefits are shown as a range from Krewski et al. (2009) to
Lepeule et al. (2012). We do not report the total monetized ancillary co-benefits by PM2 5 species. The ancillary
climate co-disbenefits from additional CO2 emissions resulting from control device operations are included in the
results given the rounding convention employed in this table as stated in footnote a. The net benefits calculation
consists of the targeted benefits and ancillary co-benefits minus the social costs and ancillary climate co-disbenefits.
f D represents the equivalent annualized value of unqualified benefits from reductions in targeted HAP emissions.
Therefore, given these results, the EPA expects that implementation of this rule, based
solely on an economic efficiency criterion, will provide society with a substantial net gain in
welfare, notwithstanding the expansive set of health and environmental benefits and ancillary co-
benefits or other impacts we were unable to quantify. Further quantification of directly emitted
PM2.5-, mercury-, acidification-, and eutrophication-related impacts would increase the estimated
net benefits, including ancillary co-benefits, of the rule.
Present Value
Equivalent Annualized
Value
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5.2 Uncertainties and Limitations
Throughout the RIA, we considered a number of sources of uncertainty, both
quantitatively and qualitatively, regarding the benefits and co-benefits, and costs of the proposed
rule. We summarize the key elements of our discussions of uncertainty here:
•	Projection methods and assumptions: Over time, more facilities are newly
established or modified in each year, and to the extent the facilities remain in
operation in future years, the total number of facilities subject to the proposed rule
could change. We assume 100 percent compliance with the rule, starting from when
the source becomes affected. If sources do not comply with the rule, at all or as
written, the cost impacts may be overestimated. Additionally, new control technology
may become available in the future at lower cost, and we are unable to predict exactly
how industry will comply with the proposed standards in the future.
•	Years of analysis: The years of the cost analysis are 2021, to represent the first-year
facilities are affected by this reconsideration, through 2028, to represent impacts of
the rule over a longer period, as discussed in Chapter 3. Extending the analysis
beyond 2028 would introduce substantial and increasing uncertainties in projected
impacts of the proposed regulation. We also note that the "snapshot" benefit estimates
for 2025 are used as an approximation of such estimates in 2023, the year the rule
will be fully implemented. This approximation is done because 2025 is the closest
year to 2023 for which the EPA has benefits-per-ton estimates available to monetize
the societal ancillary co-benefits of this action.
•	BPT estimates: All national-average BPT estimates reflect the geographic
distribution of the modeled emissions, which may not exactly match the emission
reductions that would occur due to rulemaking, and they may not reflect local
variability in population density, meteorology, exposure, baseline health incidence
rates, or other local factors for any specific location. Over the last year and a half, the
EPA systematically compared the changes in benefits, and concentrations where
available, from its BPT technique and other reduced-form techniques to the changes
in benefits and concentrations derived from full-form photochemical model
representation of a few different specific emissions scenarios. Reduced form tools are
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less complex than the full air quality modeling, requiring less agency resources and
time. That work, in which we also explore other reduced form models is referred to as
the "Reduced Form Tool Evaluation Project" (Project), began in 2017, and the initial
results were available at the end of 2018. The Agency's goal was to better understand
the suitability of alternative reduced-form air quality modeling techniques for
estimating the health impacts of criteria pollutant emissions changes in the EPA's
benefit-cost analysis. The EPA continues to work to develop refined reduced-form
approaches for estimating PM2.5 benefits. The scenario-specific emission inputs
developed for this project are currently available online. The study design and
methodology are described in the final report summarizing the results of the project,
available at https://www.epa. gov/sites/production/files/2019-
11/documents/rft combined report 10.31.19 final.pdf.
•	Non-monetized benefits and ancillary co-benefits: Numerous categories of health
and welfare benefits and ancillary co-benefits are not quantified and monetized in this
RIA. These unquantified benefits, including benefits from reductions in emissions of
targeted pollutants such as mercury, HC1 and other HAP, are described in detail in
Chapter 4 of this RIA, various PM2.5 NAAQS RIAs and in Chapter 4 of the RIA for
the promulgated ACE rule.
•	PM health impacts: In this RIA, we quantify an array of adverse health impacts
attributable to emissions of PM2.5. The Integrated Science Assessment for Particulate
Matter ("PM ISA") (U.S. EPA, 2009) identifies the human health effects associated
with ambient particles, which include premature death and a variety of illnesses
associated with acute and chronic exposures.
•	Monetized climate co-disbenefits: The EPA considered the uncertainty associated
with the social cost of carbon (SC-CO2) estimates, which were used to calculate the
domestic climate co-disbenefits from the increase in CO2 emissions projected under
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the proposed action. Some uncertainties are captured within the analysis, while other
areas of uncertainty have not yet been quantified in a way that can be modeled.73
73 For more information on the uncertainty associated with SC-CO2 please see the RIA associated with the final
ACE rule. Section 4.3 and Chapter 7 of the ACE RIA provides a detailed discussion of the ways in which the
modeling underlying the development of the SC-CO2 estimates used in this analysis addresses quantified sources of
uncertainty and presents a sensitivity analysis to show consideration of the uncertainty surrounding discount rates
over long time horizons.
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United States	Office of Air Quality Planning and
Environmental Protection Standards
Agency	Health and Environmental Impacts
Division
	Research Triangle Park, NC	
Publication No. EPA-452/P-20-001
June 2020
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