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Regulatory Impact Analysis for the Proposed
Standards of Performance for New Stationary
Sources and Emission Guidelines for Existing
Sources: Large Municipal Waste Combustors
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EPA-452/R-24-007
January 2024
Regulatory Impact Analysis for the Proposed Standards of Performance for New Stationary
Sources and Emission Guidelines for Existing Sources: Large Municipal Waste Combustors
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 the
Air Economics Group in the Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, Office of Air and Radiation, Research Triangle Park, North Carolina 27711
(email: OAQPSeconomics@epa.gov).
ACKNOWLEDGEMENTS
In addition to U.S. Environmental Protection Agency staff, personnel from the Eastern Research
Group (ERG) contributed research, data, and analysis to this document.
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TABLE OF CONTENTS
Table of Contents 1-5
List of Tables 1-7
List of Figures 1-8
1 Executive Summary 1-1
1.1 Introduction 1-1
1.1.1 Legal Basis for this Rulemaking 1-2
1.1.2 Regulatory Background 1-7
1.1.3 Proposed Requirements 1-8
1.2 Market Failure 1-9
1.3 Results for Proposed Action 1-10
1.3.1 Baseline for the Regulation 1-10
1.4 Organization of the Report 1-14
2 Industry Profile 2-1
2.1 Introduction 2-1
2.2 Generators 2-1
2.3 Collection and Disposal 2-3
2.4 MSW Mass Burn Process 2-9
2.5 MSW as Compared to Landfills 2-11
3 Emissions and Engineering Costs Analysis 3-1
3.1 Introduction 3-1
3.2 Choosing Controls Needed for Each Unit to Meet Potential Emissions Limits 3-2
3.2.1 Particulates (Cd, Pb, PM) 3-3
3.2.2 Mercury, Dioxins and Furans 3-3
3.2.3 Acid Gases (HC1 and SO2) 3-4
3.2.4 Nitrous Oxides (NOx) 3-5
3.2.5 Carbon Monoxide (CO) 3-5
3.3 Engineering Cost Analysis 3-6
3,3,1 Detailed Cost Impacts Tables 3-6
4 Human Health Benefits of Emissions Reductions 4-1
4.1 Introduction 4-1
4.2 Human Health Effects from Exposure to Hazardous Air Pollutants (HAP) 4-2
4.2.1 Hydrogen Chloride 4-2
4.2.2 Lead 4-3
4.2.3 Dioxins and Furans 4-4
4.2.4 Cadmium 4-5
4.2.5 Mercury 4-5
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4.3 Approach to Estimating PM2 5-Related Human Health Benefits 4-7
4.3.1 Selecting Air Pollution Health Endpoints to Quantify 4-8
4.3.2 Quantifying Cases of PM2.5-Attributable Premature Death 4-11
4.4 Ozone-related Human Health Benefit 4-12
4.4.1 Estimating Ozone-related Health Impacts 4-13
4.4.2 Selecting Air Pollution Health Endpoints to Quantify 4-14
4.4.3 Quantifying Cases of Ozone-Attributable Premature Mortality 4-17
4.5 Economic Valuation 4-18
4.5.1 Benefit-per-Ton Estimates 4-21
4.6 Unquantified Welfare Benefits 4-23
4.6.1 PM, NOx and SOx Ecosystem Effects 4-23
4.6.2 Ozone Vegetation Effects 4-24
4.6.3 Climate Effects of PM2.5 4-24
4.6.4 Ozone Climate Effects 4-26
4.6.5 Total Health Benefits - PM2 5 - and Ozone- Related Benefits Results 4-26
4.7 Characterization of Uncertainty in Monetized Benefits 4-32
5 Economic Impact Analysis and Distributional Assessments 5-1
5.1 Introduction 5-1
5.2 Economic Impact Analysis 5-1
5.3 Employment Impacts Analysis 5-3
5.4 Small Business Impact Analysis 5-5
6 Comparison of Benefits and CostS 6-1
6.1 Results 6-1
6.2 Uncertainties and Limitations 6
7 References 11
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LIST OF TABLES
Table 1-1: Projected Monetized Benefits, Compliance Costs, and Net Benefits of the Proposed Rule, 2025 to
2044: • : 1-12
Table 2-1: Industries Potentially Affected by Proposal 2-2
Table 3-1: Summary of Total Capital Investment and Annualized Costs per Year for Particulate Sources (2022$)a3-7
Table 3-2: Summary of Total Capital Investment and Annualized Costs per Year for Mercury and Dioxins/Furans
(2022S) 3-7
Table 3-3: Summary of Total Capital Investment and Annualized Costs per Year for Acid Gases (2022$)a 3-7
Table 3-4: Summary of Total Capital Investment and Annualized Costs per Year for Nitrous Oxides (2022$)a 3-8
Table 3-5: Summary of Total Capital Investment and Annualized Costs per Year for Continuous Emissions
Monitoring (2022$)a 3-8
Table 3-6: Summary of Total Capital Investment and Annualized Costs per Year For the Proposal (2022$)a 3-8
Table 3-7: Costs by Year for the Proposed Option (2022$)a 3-10
Table 3-8: Present-Value, Equivalent Annualized Value, and Discounted Costs for Proposed Option, 2025-2034
(million 2022$)a 3-11
Table 4-1: Human Health Effects of PM2.5 and whether they were Quantified and/or Monetized in this RIA 4-10
Table 4-2: Human Health Effects of Ambient Ozone and whether they were Quantified and/or Monetized in this
RIA 4-16
Table 4-3: Pulp and Paper: Benefit per Ton Estimates of PM2 5-Attributable Premature Mortality and Illness for the
Proposal, 2025-2044 (2022$) 4-28
Table 4-4: Pulp and Paper: Benefit per TonEstimates of NOx Precursor to PM2 s-Attributable Premature Mortality
and Illness for the Proposal, 2025-2044 (2022$) 4-28
Table 4-5: Pulp and Paper: Benefit per TonEstimates of S02 Precursor to PM2 5-Attributable Premature Mortality
and Illness for the Proposal, 2025-2044 (2022$) 4-28
Table 4-6: Pulp and Paper: Benefit per TonEstimates of NOx Precursor to Ozone-Attributable Premature Mortality
and Illness for the Proposal, 2025-2044 (2022$) 4-28
Table 4-7: Large Municipal Waste Combustors: Monetized Benefits Estimates of PM2.5 - and Ozone-Attributable
Premature Mortality and Illness for Proposal Options (million 2022$)a b 4-29
Table 4-8: Undiscounted Monetized Benefits Estimates of PM2 s-Attributable Premature Mortality and Illness for the
Proposed Option (million 2022$), 2025-2044ab 4-30
Table 4-9: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature Mortality and Illness for
the Less Stringent Alternative (million 2022$), 2025-2044a b 4-31
Table 4-10: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature Mortality and Illness for
the More Stringent Alternative (million 2022$), 2025-2044ab 4-32
Table 6-1: Summary of Monetized Benefits, Compliance Costs, Net Benefits, and Non-Monetized Benefits
PV/EAV, 2025-2044 (million 2022$, discounted to 2023)- 6-2
Table 6-2: Undiscounted Net Benefits Estimates for the Proposed Option (million 2022$), 2025-2044ab 4
Table 6-3: Undiscounted Net Benefits Estimates for the Less Stringent Alternative Option (million 2022$), 2025-
2044: 5
Table 6-4: Undiscounted Net Benefits Estimates for the More Stringent Alternative Option (million 2022$), 2025-
2044: 6
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LIST OF FIGURES
Figure 2-1: Waste to Energy Plant Diagram
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1 EXECUTIVE SUMMARY
1.1 Introduction
The U.S. Environmental Protection Agency (EPA) is proposing amendments to the New
Source Performance Standards (NSPS) and Emissions Guidelines (EG) for Large Municipal
Waste Combustors (40 CFR Part 60, Subparts Cb, Ea, and Eb), as required by section 129 of the
Clean Air Act (CAA). Section 129 of the CAA requires the EPA to establish NSPS and EG
pursuant to sections 111 and 129 of the CAA for new and existing solid waste incineration units,
including "incineration units with capacity greater than 250 tons per day combusting municipal
waste." This action amends the large MWC standards under such authority. In addition, CAA
section 129(a)(5) specifically requires the EPA to periodically review and revise the standards
and the requirements for solid waste incineration units, including large MWC units.
The North American Industry Classification System (NAICS) codes for the large
municipal waste industry are 562213 and 924110. This list of categories and NAICS codes is not
intended to be exhaustive, but rather provides a guide for readers regarding the entities that this
proposed action is likely to affect. The proposed standards, once promulgated, will be directly
applicable to the affected sources. A portion of large municipal waste combustors are owned and
may be operated by local or municipal governments, and thus would be affected by this proposed
action. Under Section 129(a)(1)(B) of the Clean Air Act Amendments of 1990 (see Pub. L 101 -
549, title III, §305(a), November 15, 1990, 104 Stat. 2577), the large municipal waste combustor
source category comprises units with a capacity greater than 250 tons per day of municipal solid
waste (MSW).
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In accordance with E.O. 12866 (as amended by E.O. 14094) and E.O. 13563, the
guidelines of OMB Circular A-4 and EPA's Guidelines for Preparing Economic Analyses (U.S.
EPA, 2016), the RIA analyzes the benefits and costs associated with the projected emissions
reductions under the proposed requirements, a less stringent set of alternative requirements, and
a more stringent set of alternative requirements to inform the EPA and the public about these
projected impacts. The benefits and costs of the proposed rule and regulatory alternatives are
presented for the 2025 to 2044 time period.
1,1.1 Legal Basis for this Rulemaking
Section 129 of the CAA requires the EPA to establish NSPS and EG pursuant to sections
111 and 129 of the CAA for new and existing solid waste incineration units, including
"incineration units with capacity greater than 250 tons per day combusting municipal waste."
This action amends the large MWC standards under such authority. In addition, CAA section
129(a)(5) specifically requires the EPA to periodically review and revise the standards and the
requirements for solid waste incineration units, including large MWC units.
The EPA has substantial discretion to distinguish among classes, types, and sizes of
incinerator units within a category while setting standards. CAA section 129(a)(2) provides that
standards "applicable to solid waste incineration units promulgated under . . . [section 111] and
this section shall reflect the maximum degree of reduction in emissions of. . . [certain listed air
pollutants] that the Administrator, taking into consideration the cost of achieving such emission
reduction and any non-air quality health and environmental impacts and energy requirements,
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determines is achievable for new and existing units in each category." This level of control is
referred to as a maximum achievable control technology, or MACT standard. CAA section
129(a)(4) further directs the EPA to set numeric emission limits for certain enumerated
pollutants (Cd, CO, DF, HC1, Pb, Hg, NOX, PM, and SO2). In addition, the standards "shall be
based on methods and technologies for removal or destruction of pollutants." CAA section
129(a)(3).
In promulgating a MACT standard, the EPA must first calculate the minimum stringency
levels for new and existing solid waste incineration units in a category, generally based on levels
of emissions control achieved in practice by the subject units. The minimum level of stringency
is called the MACT "floor," and there are different approaches to determining the floors for new
and/or existing sources. For new (and reconstructed sources), CAA section 129(a)(2) provides
that the "degree of reduction in emissions that is deemed achievable . . . shall not be less
stringent than the emissions control that is achieved in practice by the best controlled similar
unit, as determined by the Administrator." Emissions standards for existing units may be less
stringent than standards for new units, but CAA section 129(a)(2) requires that the standards
"shall not be less stringent than the average emissions limitation achieved by the best performing
12 percent of units in the category." The MACT floors form the least stringent regulatory option
the EPA may consider in the determination of MACT standards for a source category. The EPA
must also determine whether to control emissions "beyond-the-floor," after considering the costs,
non-air quality health and environmental impacts, and energy requirements of such more
stringent control.
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In general, all MACT analyses involve an assessment of the emissions from the best
performing units in a source category. The assessment can be based on actual emissions data,
knowledge of the air pollution control in place in combination with actual emissions data, or on
other information, such as state regulatory requirements, that enables the EPA to estimate the
actual performance of the regulated units. For each source category, the assessment involves a
review of actual emissions data with an appropriate accounting for emissions variability. Other
methods of estimating emissions can be used provided that the methods can be shown to provide
reasonable estimates of the actual emissions performance of a source or sources. Where there is
more than one method or technology to control emissions, the analysis may result in several
potential regulations (called regulatory options), one of which is selected as MACT for each
pollutant. Each regulatory option the EPA considers must be at least as stringent as the minimum
stringency "floor" requirements. The EPA must examine, but is not necessarily required to adopt,
more stringent "beyond-the-floor" regulatory options to determine MACT. Unlike the floor
minimum stringency requirements, the EPA must consider various impacts of the more stringent
regulatory options in determining whether MACT standards are to reflect "beyond-the-floor"
requirements. If the EPA concludes that the more stringent regulatory options have unreasonable
impacts, the EPA selects the "floor-based" regulatory option as MACT. If the EPA concludes
that impacts associated with "beyond-the-floor" levels of control are acceptable in light of
additional emissions reductions achieved, the EPA selects those levels as MACT.
Under CAA section 129(a)(2), for new sources, the EPA determines the best control
currently in use for a given pollutant and establishes one potential regulatory option at the
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emission level achieved by that control with an appropriate accounting for emissions variability.
More stringent potential beyond-the-floor regulatory options might reflect controls used on other
sources that could be applied to the source category in question. For existing sources, the EPA
determines the average emissions limitation achieved by the best performing 12 percent of units
to form the floor regulatory option. More stringent beyond-the-floor regulatory options reflect
other or additional controls capable of achieving better performance.
As noted above, CAA section 129(a)(5) requires the EPA to conduct a review of the
standards at 5-year intervals and, in accordance with CAA sections 129 and 111, revise the
standards. In conducting periodic reviews under CAA section 129(a)(5), the EPA attempts to
assess the performance of and variability associated with control measures affecting emissions
performance at sources in the subject source category (including the installed emissions control
equipment), along with recent developments in practices, processes, and control technologies,
and determines whether it is appropriate to revise the NSPS and EG. This approach is consistent
with the requirement that standards under CAA section 129(a)(3) "shall be based on methods and
technologies for removal or destruction of pollutants before, during or after combustion." We do
not interpret CAA section 129(a)(5), together with CAA section 111, as requiring the EPA to
recalculate MACT floors in connection with this periodic review. This general approach is
similar to the approach taken by the EPA in periodically reviewing CAA section 111 standards,
which, under CAA section 111(b)(1)(B), requires the EPA, except in specified circumstances, to
review NSPS promulgated under that section every 8 years and to revise the standards if the EPA
determines that it is appropriate to do so.
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For major sources and any area source categories subject to MACT standards, the second
stage in the standard-setting process focuses on identifying and addressing any remaining {i.e.,
"residual") risk pursuant to CAA section 112(f) and concurrently conducting a technology
review pursuant to CAA section 112(d)(6). The EPA is required under CAA section 112(f)(2) to
evaluate residual risk within eight years after promulgating a NESHAP to determine whether
risks are acceptable and whether additional standards beyond the MACT standards are needed to
provide an ample margin of safety to protect public health or prevent adverse environmental
effects. 1 For area sources subject to GACT standards, there is no requirement to address residual
risk, but technology reviews are required. Technology reviews assess developments in practices,
processes, or control technologies and revise the standards as necessary without regard to risk,
considering factors like cost and cost-effectiveness. The EPA is required to conduct a technology
review every eight years after a NESHAP is promulgated. Thus, the first review after a NESHAP
is promulgated is a residual risk and technology review (RTR) and the subsequent reviews are
just technology reviews.
The EPA is also required to address regulatory gaps {i.e., "gap-filling") when conducting
NESHAP reviews, meaning it must establish missing standards for listed HAP that are known to
be emitted from the source category. {Louisiana Environmental Action Network v. EPA, 955
F.3d 1088 (D.C. Cir. 2020) {LEAN)). Any new MACT standards related to gap-filling must be
1 If risks are unacceptable, the EPA must determine the emissions standards necessary to reduce risk to an
acceptable level without considering costs. In the second step of the approach, the EPA considers whether the
emissions standards provide an ample margin of safety to protect public health in consideration of all health
information as well as other relevant factors, including costs and economic impacts, technological feasibility, and
other factors relevant to each particular decision.
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established under CAA sections 112(d)(2) and (d)(3) or, in specific circumstances, under CAA
sections 112(d)(4) or (h).
1.1.2 Regulatory Background
In December 1995, EPA adopted emission guidelines (40 CFR part 60, subpart Cb) and
an NSPS (40 CFR part 60, subpart Eb)2 for large MWC units pursuant to CAA section 129.
Large MWC units are units with a combustion capacity greater than 250 tons per day (tpd) of
municipal type solid waste. Both the emission guidelines and NSPS require compliance with
emission limitations that reflect the performance of maximum achievable control technology
(MACT). The 1995 NSPS apply to new large MWC units for which construction commenced
after September 20, 1994. The 1995 emission guidelines apply to existing large MWC units for
which construction commenced on or before September 20, 1994. The 1995 emission guidelines
required that emission control retrofits be completed by December 2000. Retrofits of controls at
existing large MWC units were completed on time (December 2000) and were highly effective in
reducing emissions of most CAA section 129 pollutants. Relative to a 1990 baseline, the
emission guidelines reduced organic emissions (dioxin/furan) by more than 99 percent, metal
emissions (cadmium, lead, and mercury) by more than 93 percent, and acid gas emissions
(hydrogen chloride and sulfur dioxide) by more than 91 percent. While NOx is also regulated
under the 1995 emission guidelines and NSPS, the emissions reductions for NOx were relatively
modest compared to the other CAA section 129 pollutants. In this proposal, we are noting some
2 Note that on February 11, 1991, Subpart Ea was promulgated that applies Standards of Performance to MWCs
which commenced construction after December 20, 1989 and on or before September 20, 1994.
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significant potential improvements in performance of existing control technologies as well as
new applications of different technology that could impact the NOx standards for existing and
new large MWC units.
Following promulgation of the 2006 rulemaking, environmental groups filed a petition
for review in the D.C. Circuit challenging the rulemaking. In relevant part, the petitioners
challenged the MACT floor limits which the EPA promulgated in 1995, and which were kept in
place in the 2006 rulemaking. In light of then-recent precedents casting doubt on the soundness
of MACT floors derived in part from state-issued air permits, as the 1995 MACT floors for large
municipal waste combustors were, the EPA sought a voluntary remand of the 2006 rule. In its
remand motion, the EPA announced its intention to grant the environmental groups'
administrative petition to revisit the 1995 MACT floors and re-evaluate the 2006 rule as
necessary to comport with any revisions. This regulatory action is to fulfill the EPA's intention
in its remand motion.
1.1.3 Proposed Requ irements
These proposed amendments reflect the results from a reevaluation of the maximum
achievable control technology (MACT) floor levels, a 5-year review, and remove startup,
shutdown and malfunction exclusions and exceptions. These proposed amendments also
streamline regulatory language, revise recordkeeping and electronic reporting requirements; re-
establish new source and existing source applicability dates; clarify requirements for air curtain
incinerators; correct certain typographical errors; make certain technical corrections and clarify
certain provisions in the new source performance standards and emissions guidelines. These
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proposed amendments would revise eight or nine of the nine emission limits in the emission
guidelines, depending on combustor subcategory, and all nine emission limits in the new source
performance standards. The EPA is reevaluating the maximum achievable control technology
floors in response to the EPA's voluntary remand of the large municipal waste combustion rules
following a petitioner's request that the EPA review the maximum achievable control technology
floors for large municipal waste combustion units in consideration of a D.C. Circuit Court
decision on maximum achievable control technology floor issues. The 5-year technical review is
required by the Clean Air Act.
1.2 Market Failure
Many regulations are promulgated to correct market failures, which otherwise lead to a
suboptimal allocation of resources within a market. Air quality and pollution control regulations
address "negative externalities" whereby the market does not internalize the full opportunity cost
of production borne by society as public goods such as air quality are unpriced.
While recognizing that the optimal social level of pollution may not be zero, HAP,
PM2.5, S02, and NOx emissions impose costs on society, such as negative health and welfare
impacts, that are not reflected in the market price of the output produced through the polluting
process. If processes that burn MSW produce pollution emitted into the atmosphere, the social
costs imposed by the pollution will not be borne by the polluting firms but rather by society as a
whole. Thus, according to standard economic theory on the subject, the producers are imposing a
negative externality, or a social cost from these emissions, on society. Those municipalities or
other entities that are users of large MWCs and pay fees for their use may fail to incorporate the
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full opportunity cost in what is being paid for the burning of MSW. Consequently, absent a
regulation or some other action to limit such emissions, owners of large MWCs will not
internalize the negative externality of pollution due to emissions and social costs will be higher
as a result. This proposed regulation will serve to address this market failure by causing affected
producers to begin internalizing the negative externality associated with HAP and other
emissions also affected by this proposal such as PM2.5, SO2, and NOx.
1.3 Results for Proposed Action
1.3.1 Baseline for the Regulation
The impacts of regulatory actions are evaluated relative to a baseline that represents to
the extent possible the world without the regulatory action. In addition to control technologies
necessary to meet the current EG and NSPS for large MWCs, this baseline includes the impact of
the Good Neighbor rule, a rule to reduce interstate transport of NOx emissions for purposes of
implementing the current ozone (O3) National Ambient Air Quality Standard (NAAQS), where
NOx is an O3 precursor. If a large MWC is subject to the Good Neighbor rule, then that unit is
expected to not require additional NOx control to comply with the proposed NOx amendments to
the large MWC EG and NSPS. In this RIA, the EPA presents analysis results for the proposed
amendments to the large MWC EG and NSPS. Throughout this document, the EPA focuses the
analysis on the proposed requirements that result in quantifiable compliance cost or emissions
changes compared to the baseline as identified above. For each rule and most emissions sources,
EPA assumed each facility achieved emissions control meeting current standards, and estimated
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emissions reductions and cost relative to this baseline. We calculate cost and emissions
reductions relative to the baseline for the period 2025-2044. This time frame spans the time
period from when the NSPS takes effective (given that the action should be finalized in 2024)
through the lifetime of the typical capital equipment (20 years) expected to be installed as a
result of the proposed EG and NSPS amendments if finalized.
The summaries of impact results below are for the proposed options. In accordance with
OMB Circular A-4 (US OMB, 2003),3 we also present impact results for a more stringent and
less stringent set of options as defined by that circular, which is the guidance for regulatory
analysis to be followed by Federal agencies preparing an RIA such as this one. These alternatives
are defined in section 3.
1.3.1.1 Overview of Costs and Benefits for the Proposed Options
The proposed amendments to the large MWC EG and NSPS constitute a significant
regulatory action. This action is significant according to Executive Order 12866 as amended by
Executive Order 14094, because it likely to have an annual effect on the economy of $200
million or more or adversely affect in a material way the economy, a sector of the economy,
productivity, competition, jobs, the environment, public health or safety, or state, local, or tribal
governments or communities. The EPA monetized the projected benefits of reducing PM2.5, SO2,
3 U.S. Office of Management and Budget. Circular A-4, "Regulatory Analysis." September 17, 2003. Available at
https://www.whitehouse.gov/wp-content/uploads/legacY drupal files/omb/circulars/A4Za-4.pdf.
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and NOx emissions in terms of the value of avoided PM2.5 and ozone-attributable deaths and
illnesses, both short- and long-term.
Error! Reference source not found, also presents projected (benefits, compliance costs,
and net benefits, and emission reductions from the proposed amendments to the EG and NSPS.
Net compliance costs are calculated as total compliance costs minus product recovery credits.
Monetized net benefits are projected using short- and long-term estimates of PM2.5 and ozone
health benefits and both 3 percent and 7 percent social discount rates. The unmonetized effects
include benefits from HAP and dioxin/furan emission reductions. As mentioned earlier, we
calculate cost and emissions reductions relative to the baseline for the period 2025-2044, with
costs discounted to 2023. All estimates are in 2022 dollars.
Table 1-1: Projected Monetized Benefits, Compliance Costs, and Net Benefits of the
Proposed Rule, 2025 to 2044a'b'c'd (millions of 2022$, discounted to 2023)
3% Discount Rate
7% Discount Rate
Health Benefits c
$5,100 and $16,000
$3,100 and $9,800
Present Value
Compliance Costs
$1,700
$1,200
Net Benefits
$3,400 and $14,000
$1,800 and $8,500
Health Benefits c
$340 and $1,100
$290 and $920
Equivalent
Compliance Costs
$110
$120
i LllllUUiUi^U ~ ill 11
Net Benefits
$230 and $970
$170 and $800
a Values have been rounded to two significant figures. Rows may not appear to sum correctly due to rounding.
b The annualized present value of costs and benefits are calculated over the 20-year period from 2025 to 2044. The
choice of this analysis period is explained in the proposal RIA.
0 The projected monetized benefits include those related to public health associated with reductions in PM25 and
ozone concentrations that result from the reductions in PM, SO2, and NOx emissions. The projected health benefits
are associated with several point estimates and are presented at real discount rates of 3 and 7 percent.
d Several categories of benefits remain unmonetized and are thus not reflected in the table. Non-monetized benefits
include important benefits from reductions in HAP including cadmium, lead and dioxin/furan emissions. In addition,
benefits to provision of ecosystem services associated with reductions in N and S deposition and ozone
concentrations are not monetized.
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As shown in Table 1-1, at a 3 percent discount rate, this proposed rule is projected to
reduce PM2.5 and ozone concentrations, producing a projected PV of monetized health benefits
of $5.1 billion to $16 billion, with an EAV of $340 million to $1.1 billion discounted at 3
percent. The PV of the projected compliance costs are $1,700 million, with an EAV of about
$110 million discounted at 3 percent. Combining the projected benefits with the compliance
costs yields a net benefit PV estimate of $3.4 billion to $14 billion and EAV of $230 to $970
million.
At a 7 percent discount rate, this proposed rule is expected to generate projected PV of
monetized health benefits of $3.1 billion to $9.8 billion, with an EAV of about $290 million to
$920 million. The PV of the projected compliance costs are $1,200 million, with an EAV of
$120 million discounted at 7 percent. Combining the projected benefits with the projected
compliance costs yields a net benefit PV estimate of $1.8 billion to $8.5 billion and an EAV of
$170 million to $800 million.
The potential benefits from reducing Hg and non-Hg metal HAP were not monetized
and are therefore not reflected in the benefit-cost estimates associated with this proposal.
Potential benefits from dioxin/furan emission reductions and reduced nitrogen and sulfur
deposition are not monetized in this analysis and are therefore not directly reflected in the
quantified benefit-cost comparisons. We anticipate that taking these non-monetized effects into
account would show the proposal to have a greater net benefit. Finally, results for a less
stringent and a more stringent alternative are presented in section 6 of this RIA.
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1.4 Organization of the Report
The remainder of this report details the methodology and the results of the RIA. Section 2
presents a profile of the large MWC source category. Section 3 describes emissions, emissions
control options, and engineering costs. Section 4 presents the benefits analysis, including the
monetized health benefits from PM2.5, SO2, NOx, a qualitative discussion of the unmonetized
benefits associated with HAP and dioxin/furan emissions reductions. Section 5 presents analyses
of economic impacts, impacts on small entities, and a narrow analysis of employment impacts.
Section 6 presents a comparison of the benefits and costs. Section 7 contains the references for
this RIA.
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2 INDUSTRY PROFILE
2.1 Introduction
This industry profile supports the regulatory impact analysis (RIA) of the proposed
amendments to the EG and NSPS for MWCs. Regulation of emissions from MWCs directly
impacts suppliers of combustion services as well as households, businesses, institutions, and
communities that are either served by MWCs, would experience changes in landfill usage, or
located where changes in emissions would be observed. This section begins with a discussion of
the characterization of demand for MSW collection and disposal services. What follows is a
discussion of the supply side of the market, including combustion technology and air pollution
control technologies available to MWCs, characteristics of MWCs, and baseline flows to MWCs.
The section concludes by introducing the inventory of MWCs used to analyze the impacts of the
proposed regulation.
2.2 Generators
MSW generators require collection and disposal services resulting in them providing
most of the potential demand for MWC services. This demand is a derived demand because the
generators of MSW generally do not directly purchase MWC services; the purchase of MWC
services is left to the collectors of MSW directly or indirectly contracted by MSW generators.
MSW generators can be partitioned into four broad categories: residential, commercial,
industrial, and a residual other. The residential category includes waste from single- and
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multiple-family homes. The commercial category includes waste from retail stores, shopping
centers, office buildings, restaurants, hotels, airports, wholesalers, auto garages, and other
commercial establishments. The industrial category includes waste such as corrugated boxes and
other packaging, cafeteria waste, and paper towels from factories and other industrial buildings,
but it does not include waste from industrial processes, whether hazardous or nonhazardous. The
residual other category includes waste from public works such as street sweepings and tree/brush
trimmings, and institutional waste from schools and colleges, hospitals, prisons, and similar
public or quasi-public buildings. Infectious and hazardous waste from these residual generators
are managed separately from MSW.
Households are the primary direct source of MSW, followed by the commercial sector.
The commercial, industrial, and other sectors each directly generate smaller portions of MSW
than households. The industrial sector manages most of its own solid residuals, whether MSW or
industrial process waste, by recycling, reuse, or self-disposal. For this reason, industry directly
contributes only a small share of the MSW flow, although some industrial process wastes do end
up as MSW. Industries that are affected by this proposal are listed in Table 2-1.
Table 2-1: Industries Potentially Affected by Proposal
Category
NAICS Code
SIC Code
Examples of Potentially
Regulated Entities
Industry: air and water
resource and solid waste
management
924110
9511
Solid waste landfills
Industry: refuse systems -
solid waste landfills
562212
4953
Solid waste landfills
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State, local, and tribal 562212 4953 Solid waste landfills, air and
government agencies 924110 water resource and solid waste
management
Various underlying factors influence the trends in the quantity of MSW generated over
time. These factors include changes in population, individual purchasing power and disposal
patterns, trends in product packaging, and technological changes that affect disposal habits and
the nature of materials disposed.
2.3 Collection and Disposal
Governments -local, state, and federal-continue to play a large role in regulating andoperating
MSW management systems. Governmental influence, however, is limited. Material, engineering,
geographic, cost, and other technical and economic conditions spell out some of the limits.
In addition, all MSW management systems ultimately involve private decision makers.
Households and private firms generate most MSW, collect and transport MSW, build and
operate MSW disposal systems, provide financing, and provide markets for recycled material. In
some settings these private activities compete with public operations; in others, they provide
factors of production and demand for outputs from public operations. Whatever the case, these
technical and market relationships are important factors in conditioning the influence of local
governments on MSW management generally.
Local governments, especially in more urbanized areas, often take the lead in organizing
MSW management and, in many cases, providing collection and disposal services. This is
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particularly true in the Eastern United States (Chartwell, 1998). A wide variety of reasons
explain this involvement: concern for the public health threat of uncollected or improperly
disposed MSW, natural economies of scale in organizing and performing MSW collection and
disposal, and a concern for the negative externalities-litter, noise, smells, traffic sometimes
associated with private collection and disposal. These negative externalities are not necessarily
unhealthy, but they are detractions from public welfare.
Four market structures for MSW collection predominate: public monopoly (public
agency collects all MSW), private monopoly (private firm(s) collect(s) all MSW in a specific
area under a franchise agreement and is (are) reimbursed by the local government), competitive
(public agency and private firm(s) both collect MSW), and self-service (generators haul their
MSW to disposal sites).
Most residential refuse is collected under the first three market structures A large fraction
of private service is provided by contractors selected by local governments. In such cases, the
government plays a role in selecting the private collection firm, specifying the terms and
conditions of collection, and paying the private collector for the service.
Many factors justify the interest of government institutions, and local communities in
playing a large role in leading MSW management. These factors include that MSW may pose a
threat to the public health, improperly disposed waste may result in adverse environmental
impacts, and problems such as noise, traffic, and odor may results from the disposal of MSW.
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The most common owners of landfill facilities are county and city governments. State
governments own less than one percent of landfills. The greatest proportion of public ownership
is generally found in the Northeast, while the greatest proportion of private ownership is
generally found in the West (Reason Public Policy Institute, 2000).
Fourty-eight percent of all U.S. landfills are now privately operated, a sign that
privatization is becoming a common choice of governments in dealing with the operation of
landfills. This is particularly true among communities with more than 100,000 residents. Larger
facilities are generally more efficient, regardless of whether they are publicly or privately owned,
and can utilize economies of scale that enable operators to charge lower tipping fees. Cost
savings appears to be a clear reason for governments to move toward privatization. According to
a 1998 R.W. Beck survey, forty-four percent of respondents said that cost savings was the major
reason for privatizing a landfill; with efficiency being the choice of 19 percent of the respondents
(Burgiel, 1998).
As of 2022, the largest landfill owner was Waste Management, Inc., which handles 30
percent of all intake volume for landfills nationwide. The next largest firm in terms of intake
volume is Republic Services, with 19 percent of all intake volume nationally.4 Revenue
Generation
The costs of building and operating large MWCs are financed through various blends of
debt and equity and public versus private investment. In the U.S., most facilities are built with
4 Statista, 2023. "Market Share of Landfill Waste Volume Managed in the U.S. in 2022, by Company." Available at
https://www.statista.com/statistics/1098982/us-market-share-of-landfill-volume-by-company/
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financial backing from municipal bonds, which is a form of debt security that has a low risk of
defaulting. A few facilities with private partners also opt to partially finance facilities with
private equity, but this is a less common practice. Overall, municipal waste combustors rely
primarily on tipping fees and secondarily on electricity sales for revenues. As an example, the
Palm Beach Country (FL) Solid Waste Authority, that operates the most recently built large
MWC subject to the current EG/NSPS, is funded primarily through a system of user fees. The
primary funding mechanism is a special assessment that is included on the annual property tax
bill of all Palm Beach County property owners. Additional revenue sources include tipping fees,
electric sales, recycling revenue and interest income. 5 Covanta, which owns many of the large
MWCs affected by this proposal, indicates in their 2020 Form 10-K filing with the Securities and
Exchange Commission (SEC), that revenues for their MWCs (or WTE projects) come from the
following three routes: (1) fees charged for operating facilities or processing waste received;
(2) the sale of electricity and/or steam; and (3) the sale of ferrous and non-ferrous metals that are
recovered from the waste stream as part of the WTE process. 6 These revenue sources are from
the communities that these large MWCs serve, which are the official service areas for each
authority that manage the large MWCs. These official service areas can vary from a single city
or municipality to a broader geographic scope.
5 Solid Waste Authority for Palm Beach County, FL. About Us I Solid Waste Authority of Palm Beach County. FL
(sw a.org). Accessed on July 27, 2023.
6 Covanta Corporation. Form 10-K, filed for the fiscal year ending December 31, 2020. p. 7. Available at
https ://app. quotemedia. com/data/do wnloadFiling?webmasterId= 101533 &ref= 115653122&tvpe=HTML&svmbol
=CVA&companvName=Covanta+Holding+Corporation&formType=10-K&dateFiled=2021-02-
19&CK=225648. Accessed on July 27, 2023.
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The costs of developing and operating MSW landfills are ultimately covered by tipping
fees, general tax revenues, or a combination of the two. Tipping fees ultimately reflect many
aspects of MSW disposal. Population and economic growth, recycling rates, operating and
transportation costs, land values, and legislation all contribute to how much waste disposal
facilities charge for the privilege of waste disposal (Chartwell, 1998). As of 2022, the nationwide
average tipping fee for MSW landfills was $58.47/ton waste volume. This represents an increase
of 8 percent compared to the nationwide average tipping fee from 2021. The range of average
tipping fees is from a high of $75.92/ton in the Northeast to a low of $44.75/ton in the
Southeast.7 This rate is more than that for materials recovery stations, but less than that charged
by incinerators, mixed waste sites, and transfer stations. Approximately 30 percent of landfills
receive all their revenues from tipping fees, and approximately 35 percent of landfills receive all
their revenues from taxes. The remaining 35 percent of landfills cover the costs of waste disposal
through a combination of tipping fees and taxes. The use of taxes as a revenue source rather than
tipping fees has implications on waste disposal services. First, when disposal costs are included
in taxes, most people are not aware of the actual costs involved. Without an effective mechanism
for transmitting cost information, waste generators have no incentive to reduce their generation
rates. Second, tax-supported facilities are typically underfunded relative to actual disposal costs,
resulting in poorer operation than fully funded landfills supported by tipping fees (U.S. EPA,
1989).
7 Waste Today, "EREF Study Shows MSW Tip Fees Rose Sharply In 2022," June 8, 2023. Available at
https://www.wastetodaYmagazine.com/news/eref-studY-shows-msw-landfill-tip-fees-rose-sharplY-in-2022/.
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Factors that influence the choice of revenue sources include landfill size and ownership.
Landfills receiving small quantities of waste are likely to rely heavily on taxes for their revenue
while larger landfills rely on both taxes and tipping fees. Not surprisingly, private owners of
landfills rely heavily on tipping fees relative to other landfill owners. It remains unclear whether
private landfills rely on tipping fees because they are larger, or larger landfills rely heavily on
tipping fees because they are private.
A distinction must be drawn between tipping fees and the actual costs of landfilling.
Communities often set tipping fees to cover current operating costs without regard to
amortization of capital expenditures (capital equipment, land, closure, and long-term care costs).
Similarly, the cost of disposal for landfills supplementing tipping fee revenues with taxes is
usually much higher than the fee charged.
In addition to tax subsidies, tipping fees do not cover the actual costs to society of
disposal because landfill costs usually do not include three important social costs (U.S. EPA,
1991): depletion costs of existing landfills (i.e., discounted present value of the difference in
landfill costs today and the future costs of a replacement landfill), opportunity costs of land used
in landfills, and environmental costs (risk of environmental damage from landfills).
It is important to note that given the lesser amount of land normally needed to operate a
bioreactor instead of a conventional landfill, the opportunity costs of land as reflected in its
potential value for other purposes (e.g., real estate, commercial office buildings, etc.) becomes
less of an issue for bioreactor siting and operation. According to an analysis of bioreactor costs
done by ERG, "bioreactor landfills require 15 to 20 percent less land than standard landfills
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storing the same quantity of waste as a result of greater decay and compaction rates" (ERG,
October 2001). Given the expense of land, particularly in large urban areas, this is an important
and beneficial difference between these two types of MSW treatment. However, specific
jurisdictions may experience little real competition for landfill services.
2.4 MSW Mass Burn Process
Mass burn facilities are the most common types of municipal solid waste combustion
facilities in the United States, and they are fueled by waste that may or may not be sorted before
it enters the combustion chamber as some municipalities separate the waste on the front end to
extract recyclable products, while others do not. These units are designed to burn MSW in a
single combustion chamber under conditions of excess air. This excess air must be used to
promote mixing and turbulence to ensure that air can reach all parts of the waste, which is
necessary due to the inconsistent nature of solid waste. This process is further encouraged by
burning MSW on a sloping, moving grate that is vibrated or otherwise moved to agitate the
waste and mix it with air.
At an MSW combustion facility, MSW is unloaded from collection trucks into a storage
bunker, where an overhead crane is then used to sort the waste and lift it into a combustion
chamber. The heat released from combustion is used to convert water to steam that is then sent to
a turbine generator to produce electricity. The remaining ash is collected and taken to a landfill.
Particulates are captured by a high-efficiency baghouse filtering system. As the gas stream
travels through these filters, more than 99 percent of particulate matter is removed. Captured fly
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ash particles fall into funnel-shaped hopper receptacles and are transported by an enclosed
conveyor system to the ash discharger where they are wetted to prevent dust and mixed with the
bottom ash from the grate. This ash residue is then conveyed to an enclosed building where it is
loaded into covered, leak-proof trucks to be taken to a landfill designed to protect against
groundwater contamination. Ash residue from the furnace can be processed for removal of
recyclable scrap metals. Figure 2-1 illustrates how this energy recovery process works.
Figure 2-1: Waste to Energy Plant Diagram
POLLUTION CONTROL SYSTEM
O 0 ©
NITROGEN
OXIDE
REMOVAL
SYSTEM
MERCURY
& DIOXIN
REMOVAL
SYSTEM
ACID GAS
REMOVAL
SYSTEM
PARTICULATE
REMOVAL
SYSTEM
~ POLLUTION
CONTROL
TESTS
*From the EPA archive, supplied by ecomaine.
The amount of ash generated ranges from 15 to 25 percent by weight of the MSW
processed and from 5 to 15 percent of the volume of the MSW processed.
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2.5 MSW as Compared to Landfills
As an alternative to combustion by large MWCS, conventional landfills are typically
operated as "dry tombs" by minimizing the infiltration of liquids into the landfill. This can be
accomplished by placement of bottom and side liners and by placement of a low permeability
final cap over the waste. In addition, many sites install and operate leachate collection systems to
remove leachate and thus, minimize groundwater contamination. This method also results in a
slower biodegradation process and a reduced rate of landfill gas generation. Some conventional
landfills recirculate a portion of the collected leachate. A typical moisture content of the waste in
a conventional landfill is approximately 20 percent, but it may be lower in arid areas or where all
collected leachate is removed and infiltration.
A bioreactor is an MSW landfill or portion of an MSW landfill where any liquid other
than leachate is added in a controlled fashion into the waste mass (often in combination with
recirculating leachate) to reach a moisture content of 40 percent by weight to accelerate or
enhance the anaerobic (without oxygen) biodegradation of the waste. This includes hybrid
bioreactors, which are managed so that the waste undergoes a short (e.g., 60 day) aerobic stage,
after which the waste is covered over and operated as an anaerobic bioreactor for several years.
The long-term operation, emissions pattern, and applicable control techniques for hybrid
bioreactors are similar to anaerobic bioreactors. The rapid biodegradation of waste in a
bioreactor leads to more rapid generation of landfill gas compared to a conventional landfill. The
vast majority of bioreactors are anaerobic or hybrid bioreactors.
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Operating a landfill as a bioreactor extends the use of current sites and reduces the need
for new sites, reducing land use, environmental impacts, and land purchase costs. Bioreactors
improve the quality of leachate resulting in reduced environmental impacts if any groundwater
contamination were to occur. Economic benefits include avoiding the costs of leachate treatment,
transport, and disposal. In addition, because bioreactors emit a similar total amount of gas as
conventional landfills but emit it more quickly over a shorter amount of time, owners and
operators can convert landfill gas to energy more economically.
In aerobic bioreactors, air and liquids promote aerobic decomposition of waste. The
waste decomposes rapidly due to the presence of oxygen and moisture. The aerobic
decomposition produces large amounts of gases including carbon dioxide. Compared to
conventional landfills, the increased temperature and increased air flow through the waste may
result in increased emission rates of organic compounds (including organic HAP) soon after the
aerobic bioreactor begins operation. However, aerobic landfill data is insufficient to characterize
HAP emissions from this type of operation. The gas composition from aerobic bioreactors is
expected to have higher levels of carbon dioxide, nitrogen, and oxygen, and significantly lower
levels of methane. This may result in the gas being more difficult to safely combust. In addition,
the lower levels of methane generated in aerobic bioreactors make them less economic compared
to anaerobic bioreactors since methane gas can be easily used in waste-to-energy projects, while
the gases formed in aerobic bioreactors cannot. Aerobic bioreactors are not included in the
bioreactor subcategory in the supplemental proposal. EPA is not expecting a significant number
of aerobic bioreactors to be built in the next several years. Concerns over the increased potential
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for landfill fires and added power costs have deterred use of this technology. Some pilots have
had odor concerns, and in some cases are no longer being operated. Given the lack of
information on controls for aerobic bioreactors, and the fact that very few are in operation or
expected to start-up in the near future, EPA has concluded that it is not necessary for this
supplemental proposal to address aerobic bioreactors. Portions of a landfill that are operated as
aerobic bioreactors would continue to be subject to the NSPS/EG and the landfill NESHAP
requirements. If a landfill that includes an aerobic bioreactor meets the design capacity and
uncontrolled NMOC emission rate criteria in the NSPS/EG, a collection and control system must
be installed in the landfill, including the aerobic bioreactor area, according to the schedule in the
NSPS/EG. Landfills with pilot scale aerobic bioreactors have had success in routing emissions
from aerobic bioreactor and other landfill areas together for control in flares.
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3 EMISSIONS AND ENGINEERING COSTS ANALYSIS
3.1 Introduction
In this chapter, we present estimates of the projected emissions reductions and
engineering compliance costs associated with the proposed NSPS and EG amendments for the
2025 to 2044 period. As mentioned in Section 1, we present these impacts over this 20-year
analysis period since all of the control equipment that large MWCs are likely to apply to meet
the proposed emission limits have an equipment life of 20 years, and 2025 is the first year in
which impacts from this proposal if finalized will be incurred. The projected costs and emissions
impacts are based on facility-level estimates of the costs of meeting the proposed emission limits
and the expected emissions reduction of installing the necessary controls. The baseline emissions
and emission reduction estimates are based on the best available information on emissions and
activities for each source of emissions as described in the emission reductions memo for this
proposal.
These estimates are provided for not only the proposed option in this RIA, but also less
and more stringent alternative regulatory options in adherence to OMB Circular A-4. The less
stringent option is the option in which all large MWCs meet the MACT floor emission limits.
The most stringent option is the option in which all large MWCs meet beyond the MACT floor
emission limits and also requirements determined in the 5th year review of emissions limits
necessary as part of this proposal. More information on the less and more stringent alternative
regulatory options can be found in the Emission Reduction Estimates for Existing Large MWCs
Memorandum prepared for this proposal.
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3.2 Choosing Controls Needed for Each Unit to Meet Potential Emissions Limits
A significant portion of the total cost for industry compliance comes from the cost of
installing new or improving existing air pollution control devices (APCDs) for units not
currently meeting the potential proposed limits. In order to determine the control costs, it was
necessary to evaluate, for each large MWC, how much improvement for each pollutant would be
needed to meet the potential proposed emissions limits. To do this, the average of available stack
test and CEMS data from 2000 through 2015 was compared to the corresponding emissions
limit. For CEMS pollutants, each datapoint included in the average reflects a unit's highest
CEMS reading for a given year. Data gaps were filled first by using the measured data from
similar units operated by the corporate entity. If these data were not available, then the means of
available data for similar combustion and control types were used. Once every unit was assigned
a concentration value, percentages were calculated to quantify the amount of improvement
needed for each unit to meet each limit.
Control measures were then assigned for each pollutant grouping, depending on the level
of control required and the control configurations already in place. In cases where one unit at a
facility cannot meet a given limit but a similar unit at the facility can, it is assumed the facility
will be able to adjust operational parameters to bring the non-complying unit into compliance.
The assumptions for that analysis follows.
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3.2.1 Particulates (Cd, Pb, PM)
As explained in the cost memorandum for this proposal, existing control options include
fabric filter (FF) retrofit, FF improvement, a combination of retrofit and improvement, and
complete FF replacement. 8
ESP-equipped units that cannot meet the MACT Floor limits for at least one of the three
pollutants will likely need to be retrofitted with FF. It is assumed they would need even further
control (i.e., FF retrofit + improvement) to meet BTF/TR limits. This would entail a better filter
bag beyond the retrofit alone.
Several units have already retrofit or are currently retrofitting to FF; in those cases, no FF
retrofit costs are included for the unit. FF-equipped units that cannot meet the new limits for at
least one of the three pollutants will need equipment improvements. It is assumed upgraded FF
bag replacements would be sufficient and that ID fan replacement would not be necessary. For
FF-equipped units needing more than 33 percent improvement to meet a BTF/TR limit, a
conservative assumption that the FF will need to be replaced is used.
3.2.2 Mercury, Dioxins and Furans
Existing control options include activated carbon injection (ACI), increasing carbon
injection (CI) rates, or a combination of the two.
8 Eastern Research Group, for U.S. EPA. Compliance Cost Analyses for Proposed Large MWC Rule Amendments.
September 18, 2023.
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Units that do not currently have ACI installed and cannot meet the MACT Floor limit for
one or both pollutants will need to be retrofitted with ACI. It is assumed they would need further
control (ACI + increased CI rate) to meet BTF/TR limits. For units that can meet the MACT
Floor limit but not the corresponding BTF/TR limit, ACI installation alone is assumed sufficient
to meet the BTF/TR limit. For units that already have ACI installed but cannot meet the
proposed limits, assumed an increased rate of carbon injection.
3,2,3 Acid Gases (HCl and SO2)
Existing control options include increasing lime injection rates and circulating fluidized
bed scrubbers (CFBS).
All units have spray dryer absorbers or dry sorbent injection towers, so it's assumed units
that cannot meet the MACT Floor limit for one or both pollutants will increase their lime
injection rate. These units could possibly require further control to meet the BTF/TR limits, so a
conservative assumption that they would install circulating fluidized bed scrubber (CFBS) to
comply with that option is used. The capital cost for this control device is considerably more
expensive than for spray dryer absorbers or dry sorbent injection towers, as presented in the
control memorandum for this proposal.
Units that can meet the MACT Floor limit but not the corresponding BTF/TR limit are
assumed to require only increased lime injection to comply with the BTF/TR limit.
The most recently built MWC units are assumed to have state of the art spray dryer
absorbers and need no further controls to meet either limit.
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3.2.4 Nitrous Oxides (N0X)
Existing control options include advanced selective non-catalytic reduction (ASNCR)
and low-NOx technology (Covanta LN™).
It is assumed that units located in the Ozone Transport Region and covered under the
final Good Neighbor Plan rule, published in May 2023 and requiring NOx control to occur by
May 1, 2026, will be able to meet the large MWC MACT Floor or BTF/TR limit for NOx and
that associated impacts and burden estimates will already be accounted for in that rulemaking.
To avoid double counting, EPA is not including costs for these units to come into compliance.
For both the MACT Floor and BTF/TR based limits, units unable to comply are assumed
to require retrofit with either ASNCR or low NOx technology. Specifically, it is assumed
Covanta units will be equipped with their LNTM technology as needed. Several of these units
have already been equipped with LN TM, in which case no NOx control costs were included for
compliance with either limit option. Non-Covanta units requiring additional control were
assigned ASNCR.
3.2.5 Carbon Monoxide (CO)
No add-on controls are specified for CO. Most of the CO data, which comprise annual
highest CEMS readings, are likely reported during operational transition periods and may be
artificially inflated due to the 7% O2 correction. The proposed removal of the 7% O2 correction
(and averaging using data reported at stack O2) during warmup, startup/shutdown periods will
likely abate the non-compliant readings to a large degree.
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3.3 Engineering Cost Analysis
3.3.1 Detailed Cost Impacts Tables
This section presents detailed cost tables for each section of the proposed amendments.
All tables contain per-year figures with the exception of total capital investment (which
represents one-time or initial costs). Total annualized costs include capital costs annualized using
the bank prime rate in accord with the guidance of the EPA Air Pollution Control Cost Manual
(U.S. EPA, 2017a), operating and maintenance costs, and costs of additional monitoring,
recordkeeping, and reporting (MRR) (when necessary). To estimate these annualized costs, the
EPA uses a conventional and widely accepted approach, called equivalent uniform annual cost
(EUAC) that applies a capital recovery factor (CRF) multiplier to capital investments and adds
that to the annual incremental operating expenses to estimate annual costs. This cost estimation
approach is described in the EPA Air Pollution Control Cost Manual (U.S. EPA, 2017a). These
annualized costs are the costs to directly affected firms and facilities (or "private investment"),
and thus are not true social costs. Detailed discussion of these costs, including all calculations
and assumptions made in conducting estimates of total capital investment, annual O&M, and
compliance testing/MRR costs, can be found in the "Compliance Cost Analyses for Proposed
Large MWC Rule Amendments" memorandum and its Appendices A, B, and C , in the docket
for the proposal. These costs incorporate impacts such as increased water usage and waste
disposal, and other effects such as those to electricity generation at affected facilities. The bank
prime rate was 7.5 percent at the time of the analysis. All cost figures are in 2022$.
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Table 3-1 through Table 3-5 provide a summary of the total capital investment and
annualized costs for control of the different types of pollutants affected by this proposal EG and
NSPS. Table 3-6 provides a summary of the total capital investment and annualized costs for the
whole of the proposal.
Table 3-1: Summary of Total Capital Investment and Annualized Costs per Year for
Particulate Sources (2022$)a
Less Stringent
Proposal
More Stringent
Total Capital Investment
$41,000,000
$41,000,000
$120,000,000
Annual O&M
$2,400,000
$2,400,000
$2,400,000
Annualized Capital
$4,800,000
$4,800,000
$12,000,000
Total Annualized Cost
$7,200,000
$7,200,000
$15,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-2: Summary of Total Capital Investment and Annualized Costs per Year for
Mercury and Dioxins/Furans (2022$)a
Less Stringent
Proposal
More Stringent
Total Capital Investment
$50,000,000
$50,000,000
$98,000,000
Annual O&M
$37,000,000
$37,000,000
$19,000,000
Annualized Capital
$8,800,000
$8,800,000
$19,000,000
Total Annualized Cost
$45,000,000
$45,000,000
$140,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-3: Summary of Total Capital Investment and Annualized Costs per Year for Acid
Gases (2022$)a
Less Stringent
Proposal
More Stringent
Total Capital Investment
$15,000,000
$15,000,000
$1,100,000,000
Annual O&M
$17,000,000
$17,000,000
$260,000,000
Annualized Capital
$2,200,000
$2,200,000
$270,000,000
Total Annualized Cost
$19,000,000
$19,000,000
$530,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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Table 3-4: Summary of Total Capital Investment and Annualized Costs per Year for
Nitrous Oxides (2022$)a
Less Stringent
Proposal
More Stringent
Total Capital Investment
$51,000,000
$260,000,000
$260,000,000
Annual O&M
$5,800,000
$34,000,000
$34,000,000
Annualized Capital
$5,000,000
$25,000,000
$25,000,000
Total Annualized Cost
$11,000,000
$59,000,000
$59,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-5: Summary of Total Capital Investment and Annualized Costs per Year for
Continuous Emissions Monitoring (2022$)a
Mercury (Hg)
Hydrogen Chloride (HC1)
Particulates (PM)
Total Capital Investment
$33,000,000
$15,000,000
$5,400,000
Annual O&M
$11,000,000
$2,200,000
$390,000
Annualized Capital
$4,800,000
$2,200,000
$790,000
Total Annualized Cost
$16,000,000
$4,000,000
$1,200,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-6: Summary of Total Capital Investment and Annualized Costs per Year (2022$)a
Less Stringent
Proposal
More Stringent
Total Capital Investment
$210,000,000
$420,000,000
$1,600,000,000
Annual O&M
$76,000,000
$100,000,000
$330,000,000
Annualized Capital
$29,000,000
$49,000,000
$330,000,000
Total Annualized Cost
$100,000,000
$150,000,000
$770,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-7 provides a breakdown of the composition of undiscounted compliance costs
incurred in each year of analysis. An important assumption for this composition is that the capital
costs are presumed to be incurred entirely in one year, 2025. Thus, for purposes of this analysis,
all control equipment is presumed to be ready for operation by the end of that year, just about
one year after the rule's effective date. Given that compliance is not required until 3 years after
the effective date of the final rule, this assumption may potentially overstate the costs of this rule
3-8
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as estimated in this analysis. As this assumption similarly shifts the timing of benefits to be in
line with the timing of the costs, benefits would be potentially overestimated, with the ratio of
discounted benefits with this assumption to those from a delayed, 2027 operational status being
similar to the ratio of discounted costs under the two alternative assumptions. The ratio of
discounted costs to discounted benefits should therefore remain unchanged. Table 3-8 discounts
the sum of those annual costs to 2023 using 3% and 7% discount rates and provides an
equivalent annualized value (EAV), which represents a flow of constant annual values that
would yield a sum equivalent to the PV. This EAV represents the value of a typical cost for each
year of the analysis, consistent with the estimate of the PV, in contrast to year-specific estimates.
Similar values are provided for the benefits in Section 1 of this RIA. The estimated present-value
of compliance costs in 2023 is about $1.7 billion ($110 million EAV) using a 3 percent social
discount rate and about $1.2 billion ($120 million EAV) using a 7 percent social discount rate
from 2025-2044. Compliance costs are similarly summarized for the more stringent and less
stringent alternatives in Table 6-1. Additional information and calculations to support those
summary values appear in the LMWC Cost workbook in the docket for this proposal.
3-9
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Table 3-7: Costs by Year for the Proposed Option (2022$)a
Year
Capital
Annual O&M
Total
2025
$360,000,000
$90,000,000
$450,000,000
2026
$0
$90,000,000
$90,000,000
2027
$0
$90,000,000
$90,000,000
2028
$0
$90,000,000
$90,000,000
2029
$0
$90,000,000
$90,000,000
2030
$0
$90,000,000
$90,000,000
2031
$0
$90,000,000
$90,000,000
2032
$0
$90,000,000
$90,000,000
2033
$0
$90,000,000
$90,000,000
2034
$0
$90,000,000
$90,000,000
2035
$54,000,000
$90,000,000
$140,000,000
2036
$0
$90,000,000
$90,000,000
2037
$0
$90,000,000
$90,000,000
2038
$0
$90,000,000
$90,000,000
2039
$0
$90,000,000
$90,000,000
2040
$36,000,000
$90,000,000
$130,000,000
2041
$0
$90,000,000
$90,000,000
2042
$0
$90,000,000
$90,000,000
2043
$0
$90,000,000
$90,000,000
2044
$0
$90,000,000
$90,000,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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Table 3-8: Present-Value, Equivalent Annualized Value, and Discounted Costs for
Proposed Option, 2025-2044 (million 2022$)a
Year
Discount Rate (Discounted to 2023)
3%
7%
2025
$430
$400
2026
$83
$74
2027
$80
$69
2028
$78
$64
2029
$76
$60
2030
$73
$56
2031
$71
$53
2032
$69
$49
2033
$67
$46
2034
$65
$43
2035
$100
$64
2036
$62
$37
2037
$60
$35
2038
$58
$33
2039
$56
$31
2040
$76
$40
2041
$53
$27
2042
$52
$25
2043
$50
$23
2044
$49
$22
PV
$1,700
$1,200
EAV
$110
$120
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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4 HUMAN HEALTH BENEFITS OF EMISSIONS REDUCTIONS
4.1 Introduction
The emissions controls installed to comply with this action are expected to reduce
emissions of HAPs including HC1, mercury, lead, cadmium, dioxins/furans. The EPA provides a
qualitative discussion of the benefits of reducing HAP emissions later in this chapter. The
emission controls are also expected to reduce emissions of PM2.5, precursors NOx and SO2 and
summer season NOx. Summer NOx, in conjunction with volatile organic compounds (VOC) and
in the presence of sunlight, form ground-level ozone (O3). This chapter reports the estimated
PM2.5- and ozone-related benefits of reducing emissions in terms of the number and value of
avoided ozone-attributable deaths and illnesses. The potential benefits from reduced ecosystem
effects from the reduction in NOx and SOx deposition and O3 concentrations are not quantified
or monetized here. Time and data limitations for quantifying the effect of this action on aquatic
and terrestrial ecosystems, biomass loss and foliar injury and the ensuing change in the provision
of ecosystem services prevent an assessment of the benefits to ecosystems.
The PV of the low estimate of the benefits for the proposed rulemaking is $5.1 billion at a
3 percent discount rate to $3.1 billion at a 7 percent discount rate with an EAV of $340 million to
$290 million, respectively. The PV of the high estimate of the benefits for the proposed
rulemaking is $16 billion at a 3 percent discount rate to $9.8 billion at a 7 percent discount rate
with an EAV of $1.1 billion and $920 million, respectively. All estimates are reported in 2022
dollars and are calculated over the 2025-2044 analytical timeframe described earlier in this RIA.
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4.2 Human Health Effects from Exposure to Hazardous Air Pollutants (HAP)
In the subsequent sections, we describe the health effects associated with the main HAP
of concern from the LMWC source category: HC1, mercury, lead, cadmium, dioxins/furans. As
stated in our cost analysis, this proposal is projected to reduce HC1 from LMWC by
approximately 344 tons per year (tpy) and reduce mercury emissions by approximately 0.0285
tpy. We also estimate that the proposed rule would reduce other HAP emissions by
approximately 0.225 tpy. More information on the size of these HAP emission reductions and
how they are estimated can be found in the Emission Reduction Estimates for Existing Large
MWCs Memorandum and its Appendix A for this proposal that is available in the docket for this
action.
Quantifying and monetizing the economic value of reducing the risk of cancer and non-
cancer effects is made difficult by the lack of a central estimate of estimate of cancer and non-
cancer risk and estimates of the value of an avoided case of cancer (fatal and non-fatal) and
morbidity effects. Due to methodology and data limitations, we did not attempt to monetize the
health benefits of reductions in HAP in this analysis. Instead, we are providing a qualitative
discussion of the health effects associated with HAP emitted from sources subject to control
under the proposed action.
4.2.1 Hydrogen Chloride
Hydrogen chloride is a corrosive gas that can cause irritation of the mucous membranes
of the nose, throat, and respiratory tract. Brief exposure to 35 ppm causes throat irritation, and
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levels of 50 to 100 ppm are barely tolerable for 1 hour (ATSDRa). 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 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 (U.S. EPA, 1995).
4,2.2 Lead
Lead is found naturally in ore deposits. A major source of lead in the U.S. environment
has historically been from combustion of leaded gasoline, which was phased out of use after
1973. Other sources of lead have included mining and smelting of ore; manufacture of and use of
Pb-containing products (e.g., Pb-based paints, pigments, and glazes; electrical shielding;
plumbing; storage batteries; solder; and welding fluxes); manufacture and application of Pb-
containing pesticides; combustion of coal and oil; and waste incineration. Lead is associated with
toxic effects in every organ system including adverse renal, cardiovascular, hematological,
reproductive, and developmental effects. However, the major target for Pb toxicity is the
nervous system, both in adults and children. Long-term exposure of adults to Pb at work has
resulted in decreased performance in some tests that measure functions of the nervous system.
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Lead exposure may also cause weakness in fingers, wrists, or ankles. Lead exposure also causes
small increases in blood pressure, particularly in middle-aged and older people and may also
cause anemia. Children are more sensitive to the health effects of Pb than adults. No safe blood
Pb level in children has been determined. At lower levels of exposure, Pb can affect a child's
mental and physical growth. Fetuses exposed to Pb in the womb may be born prematurely and
have lower weights at birth. Exposure in the womb, in infancy, or in early childhood also may
slow mental development and cause lower intelligence later in childhood. There is evidence that
these effects may persist beyond childhood (ATSDR, 2020). EPA has determined that Pb is a
probable human carcinogen (Group 2B) (U.S. EPA, 2004).
4.2,3 Dioxins and Furans
Dioxins and furans are a group of chemicals formed as unintentional byproducts of
incomplete combustion. They are released to the environment during the combustion of fossil
fuels and wood, and during the incineration of municipal and industrial wastes (ATSDR, 1998).
Dioxins and furans are generally compared to 2,3,7,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-
TCDD) as a reference (or index) chemical because it is relatively well-studied and the most toxic
compound within the group.2 Out of all HAPs for which a health benchmark has been assigned,
2,3,7,8-TCDD is the most potent for both cancer and non-cancer hazard. 2,3,7,8-TCDD causes
chloracne in humans, a severe acne-like condition. It is known to be a developmental toxicant in
animals, causing skeletal deformities, kidney defects, and weakened immune responses in the
offspring of animals exposed to 2,3,7,8-TCDD during pregnancy. Human studies have shown an
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association between 2,3,7,8-TCDD and soft-tissue sarcomas, lymphomas, and stomach
carcinomas.1 EPA has classified 2,3,7,8- TCDD as a probable human carcinogen (Group B2)
(U.S.EPA, 1985).
4.2.4 Cadmium
The main sources of cadmium in air are the burning of fossil fuels and the incineration of
municipal waste. Acute inhalation in humans causes adverse effects in the lung, such as
pulmonary irritation. Chronic inhalation in humans can result in a build-up of Cd in the kidney,
and if sufficiently high, may result in kidney disease. Animal studies indicate that cadmium may
cause adverse developmental effects, including reduced body weight, skeletal malformation, and
altered behavior and learning (ATSDR, 2012). Lung cancer has been found in some studies of
workers exposed to Cd in the air and studies of rats that inhaled Cd. EPA has classified cadmium
as a probable human carcinogen (Group Bl) (U.S. EPA, 1987).
4.2.5 Mercury
Mercury exists in three forms: elemental mercury (Hg, oxidation state 0); inorganic
mercury compounds (oxidation state +1, univalent; or +2, divalent); and organic mercury
compounds. Elemental mercury can exist as a shiny silver liquid, but readily vaporizes into air.
All forms of mercury are toxic, and each form exhibits different health effects. Acute (short-
term) exposure to high levels of elemental mercury vapors results in central nervous system
(CNS) effects such as tremors, mood changes, and slowed sensory and motor nerve function.
Chronic (long-term) exposure to elemental mercury in humans also affects the CNS, with effects
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such as erethism (increased excitability), irritability, excessive shyness, and tremors. The kidney
is also affected by mercury. There is consistent evidence that chronic ingestion or inhalation of
inorganic mercury (across a range of concentrations/doses) leads to kidney damage via induction
of an immune response. Methylmercury (CH3Hg+) is the most common organic mercury
compound in the environment. Methylmercury is formed by microbial action in the top layers of
sediment and soils, after oxidized or particle-bound mercury forms have precipitated from the air
and deposited into waterbodies or land. Once formed, methylmercury is taken up by aquatic
organisms and bioaccumulates up the aquatic food web. Larger predatory fish may have
methylmercury concentrations many times, typically on the order of one million times, that of
the concentrations in the freshwater body in which they live. Acute exposure of humans to very
high levels of methyl mercury results in profound CNS effects such as blindness and spastic
quadriparesis. Chronic exposure to methyl mercury, most commonly by consumption of fish,
also affects the CNS with symptoms such as paresthesia (a sensation of pricking on the skin),
blurred vision, malaise, speech difficulties, and constriction of the visual field. Ingestion of
methyl mercury can lead to significant developmental effects. Infants born to women who
ingested high levels of methyl mercury exhibited mental retardation, ataxia, constriction of the
visual field, blindness, and cerebral palsy (ATSDR, 1999). EPA has concluded that mercuric
chloride and methyl mercury are possibly carcinogenic to humans (U.S. EPA, 1995, U.S. EPA,
2001).
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4.3 Approach to Estimating PM2.s-related Human Health Benefits
This section summarizes the EPA's approach to estimating the incidence and economic
value of the PIVh.s-related benefits estimated for this rule. The Regulatory Impact Analysis for
the Proposed National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired
Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review
(U.S. EPA, 2023a) and its corresponding Technical Support Document Estimating PM2.5 -and
Ozone - Attributable Health Benefits (TSD) (U.S. EPA, 2023b) 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
RIA for the PM NAAQS (U.S. EPA, 2022). The PM2.5 NAAQS RIA hypothesizes, but does 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.
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
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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
health impact function; (3) specifying the health impact function with concentration-response
parameters drawn from the epidemiological literature.
4,3.1 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) (U.S. EPA, 2019a) as
summarized in the Technical Support Document (TSD) for the 2022 PM NAAQS
Reconsideration Proposal RIA: Estimating PM2.5- and Ozone-Attributable Health Benefits (U.S.
EPA, 2023d). 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
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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 4-2
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. 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 the TSD,
which details the approach EPA followed for selecting and quantifying PM-attributable effects
(U.S. EPA, 2023d).
In December of 2022, EPA published the Regulatory Impact Analysis (RIA) for the
proposed Particulate Matter National Ambient Air Quality Standards (U.S.EPA, 2022). EPA
quantified the PM-related benefits of this rule after publication of the proposed PM NAAQS
RIA. The PM-related benefits reported in this RIA reflect methods consistent with the TSD (U.S.
EPA, 2023d). We estimate PM-related benefits using methods consistent with the proposed PM
NAAQS RIA. Specifically, we quantify PM-attributable deaths using concentration-response
parameters from the Pope et al. (2019) and Wu et al. (2020) long-term exposure studies of the
Medicare and National Health Interview Survey cohorts, respectively.
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Table 4-1: Human Health Effects of PM^sand whether they were Quantified and/or
Monetizec
in this RIA
Category
Effect
Effect
Quantified
Effect
Monetized
More
Information
Premature
mortality
from
exposure
to PM25
Adult premature mortality from long-term exposure (age 65-99
or age 30-99)
V
S
PM ISA
[nfant mortality (age <1)
S
~
PM ISA
Nonfatal
morbidity
from
exposure
to PM25
Heart attacks (age >18)
S
~
PM ISA
Hospital admissions—cardiovascular (ages 65-99)
y
~
PM ISA
Emergency department visits— cardiovascular (age 0-99)
PM ISA
Hospital admissions—respiratory (ages 0-18 and 65-99)
~
~
PM ISA
Emergency room visits—respiratory (all ages)
V
~
PM ISA
Cardiac arrest (ages 0-99; excludes initial hospital and/or
emergency department visits)
S
PM ISA
Stroke (ages 65-99)
y
~
PM ISA
Asthma onset (ages 0-17)
V
V
PM ISA
Asthma symptoms/exacerbation (6-17)
S
S
PM ISA
Lung cancer (ages 30-99)
y
S
PM ISA
Allergic rhinitis (hay fever) symptoms (ages 3-17)
S
PM ISA
Lost work days (age 18-65)
y
V
PM ISA
Minor restricted-activity days (age 18-65)
V
S
PM ISA
Hospital admissions—Alzheimer's disease (ages 65-99)
S
S
PM ISA
Hospital admissions—Parkinson's disease (ages 65-99)
V
V
PM ISA
Other cardiovascular effects (e.g., other ages)
—
—
PM ISA2
Other respiratory effects (e.g., pulmonary function, non-asthma
ER visits, non-bronchitis chronic diseases, other ages and
populations)
—
—
PM ISA2
Other nervous system effects (e.g., autism, cognitive decline,
dementia)
—
—
PM ISA2
Metabolic effects (e.g., diabetes)
—
—
PM ISA2
Reproductive and developmental effects (e.g., low birth weight,
pre-term births, etc.)
—
—
PM ISA2
Cancer, mutagenicity, and genotoxicity effects
—
—
PM ISA2
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.
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4.3.2 Quantifying Cases of PM2.5-Attributable Premature Death
This section summarizes our approach to estimating the incidence and economic value of
the PM2.5 benefits estimated for this rule. A full discussion of EPA's approach to selecting
human health endpoints, epidemiologic studies and economic unit values can be found in the
Technical Support Document (TSD) supporting the final Cross-State Update rule (U.S. EPA,
2021b). The user manual for the environmental Benefits Mapping and Analysis Program-
Community Edition (BenMAP-CE) program1 separately details EPA's approach for quantifying
and monetizing PM-attributable effects in the BenMAP-CE program. In these documents the
reader can find the rationale for selecting health endpoints to quantify; the demographic, health
and economic data we apply within BenMAP-CE; modeling assumptions; and our techniques for
quantifying uncertainty.
The PM ISA, which was reviewed by the Clean Air Scientific Advisory Committee of the
EPA's Science Advisory Board (U.S. EPA-SAB-CASAC, 2019), 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 identified epidemiologic 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 from recent studies reduce uncertainties related
to potential co-pollutant confounding and continues to provide strong support for a linear, no-
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threshold concentration-response relationship" (U.S. EPA, 2019a). Consistent with this evidence,
the EPA historically has estimated health impacts above and below the prevailing NAAQS.2
Following this approach, we report the estimated PIVh.s-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 (U.S. EPA, 2021b).
As noted in the preamble to the 2020 PM NAAQS final rule, the "health effects can occur over
the entire distributions of ambient PM2.5 concentrations evaluated, and epidemiological studies
do not identify a population-level threshold below which it can be concluded with confidence
that PM-associated health effects do not occur."3 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 (U.S. EPA, 2021b). 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 Ozone-related Human Health Benefit
This section summarizes the EPA's approach to estimating the incidence and economic
value of the ozone-related benefits estimated for this action. The Regulatory Impact Analysis
(RIA) Final Revised Cross-State Air Pollution Rule (U.S. EPA, 2021) and its corresponding
Technical Support Document Estimating PM2.5 -and Ozone - Attributable Health Benefits
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(TSD) (U.S. EPA, 2021) 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 action will affect the distribution of ozone concentrations throughout
the U.S.; this includes locations both meeting and exceeding the NAAQS for O3. This RIA
estimates avoided Cb-related health impacts that are distinct from those reported in the RIAs for
the O3 NAAQS (U.S. EPA, 2015). The O3 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.
4,4.1 Estimating Ozone-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
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health impact function; (3) specifying the health impact function with concentration-response
parameters drawn from the epidemiological literature.
4,4.2 Selecting Air Pollution Health Endpoints to Quantify
As a first step in quantifying Cb-related human health impacts, the EPA consults the
Integrated Science Assessment for Ozone (Ozone ISA) (U.S. EPA, 2020) as summarized in the
TSD for the Final Revised Cross State Air Pollution Rule Update (U.S. EPA, 2021). 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.
In brief, the ISA for ozone found short-term (less than one month) exposures to ozone to
be causally related to respiratory effects, a "likely to be causal" relationship with metabolic
effects and a "suggestive of, but not sufficient to infer, a causal relationship" for central nervous
system effects, cardiovascular effects, and total mortality. The ISA reported that long-term
exposures (one month or longer) to ozone are "likely to be causal" for respiratory effects
including respiratory mortality, and a "suggestive of, but not sufficient to infer, a causal
relationship" for cardiovascular effects, reproductive effects, central nervous system effects,
metabolic effects, and total mortality.
The EPA estimates the incidence of air pollution effects for those health endpoints listed
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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 any welfare effects such as biomass loss and foliar
injury. These effects are described in Chapter 7 of the Ozone NAAQS RIA (EPA, 2015).
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Table 4-2: Human Health Effects of Ambient Ozone and whether they were Quantified
and/or Monetized in this RIA
Category
Effect
Effect
Quantified
Effect
Monetized
More
Information
Premature
mortality
from
exposure
to PM25
Adult premature mortality from long-term exposure (age 65-99
or age 30-99)
y
V
PM ISA
Infant mortality (age <1)
y
S
PM ISA
Nonfatal
morbidity
from
exposure
to PM25
Heart attacks (age >18)
y
S
PM ISA
Hospital admissions—cardiovascular (ages 65-99)
V
V
PM ISA
Emergency department visits— cardiovascular (age 0-99)
S
S
PM ISA
Hospital admissions—respiratory (ages 0-18 and 65-99)
V
y
PM ISA
Emergency room visits—respiratory (all ages)
V
V
PM ISA
Cardiac arrest (ages 0-99; excludes initial hospital and/or
emergency department visits)
S
V
PM ISA
Stroke (ages 65-99)
S
S
PM ISA
Asthma onset (ages 0-17)
S
S
PM ISA
Asthma symptoms/exacerbation (6-17)
y
S
PM ISA
Lung cancer (ages 30-99)
s
y
PM ISA
Allergic rhinitis (hay fever) symptoms (ages 3-17)
V
PM ISA
Lost work days (age 18-65)
V
y
PM ISA
Minor restricted-activity days (age 18-65)
s
PM ISA
Hospital admissions—Alzheimer's disease (ages 65-99)
s
~
PM ISA
Hospital admissions—Parkinson's disease (ages 65-99)
V
PM ISA
Other cardiovascular effects (e.g., other ages)
—
—
PM ISA2
Other respiratory effects (e.g., pulmonary function, non-asthma
ER visits, non-bronchitis chronic diseases, other ages and
populations)
—
—
PM ISA2
Other nervous system effects (e.g., autism, cognitive decline,
dementia)
—
—
PM ISA2
Metabolic effects (e.g., diabetes)
—
—
PM ISA2
Reproductive and developmental effects (e.g., low birth weight,
pre-term births, etc.)
—
—
PM ISA2
Cancer, mutagenicity, and genotoxicity effects
—
—
PM ISA2
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.
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4.4.3 Quantifying Cases of Ozone-Attributable Premature Mortality
Mortality risk reductions account for the majority of monetized ozone-related benefits.
For this reason, this subsection and the following provide a brief background of the scientific
assessments that underly the quantification of these mortality risks and identifies the risk studies
used to quantify them in this RIA for ozone. As noted above, the Estimating PM2.5- and Ozone-
Attributable Health Benefits TSD describes fully the Agency's approach for quantifying the
number and value of ozone air pollution-related impacts, including additional discussion of how
the Agency selected the risk studies used to quantify them in this RIA. The TSD also includes
additional discussion of the assessments that support quantification of these mortality risk than
provide here.
In 2008, the National Academies of Science (NRC 2008) issued a series of
recommendations to EPA regarding the procedure for quantifying and valuing ozone-related
mortality due to short-term exposures. Chief among these was that"... short-term exposure to
ambient ozone is likely to contribute to premature deaths" and the committee recommended that
"ozone-related mortality be included in future estimates of the health benefits of reducing ozone
exposures..." The NAS also recommended that".. .the greatest emphasis be placed on the
multicity and [National Mortality and Morbidity Air Pollution Studies (NMMAPS)] ... studies
without exclusion of the meta-analyses" (NRC 2008). Prior to the 2015 Ozone NAAQS RIA, the
Agency estimated ozone-attributable premature deaths using an NMMAPS-based analysis of
total mortality (Bell et al. 2004), two multi-city studies of cardiopulmonary and total mortality
(Huang et al. 2004; Schwartz 2005) and effect estimates from three meta-analyses of non-
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accidental mortality (Bell et al. 2005; Ito et al. 2005; Levy et al. 2005). Beginning with the 2015
Ozone NAAQS RIA, the Agency began quantifying ozone-attributable premature deaths using
two newer multi-city studies of non-accidental mortality (Smith et al. 2009; Zanobetti and
Schwartz 2008) and one long-term cohort study of respiratory mortality (Jerrett et al. 2009). The
2020 Ozone ISA included changes to the causality relationship determinations between short-
term exposures and total mortality, as well as including more recent epidemiologic analyses of
long-term exposure effects on respiratory mortality (U.S. EPA, 2020). In this RIA, as described
in the corresponding TSD, two estimates of ozone-attributable respiratory deaths from short-term
exposures are estimated using the risk estimate parameters from Zanobetti et al. (2008) and
Katsouyanni et al. (2009). Ozone-attributable respiratory deaths from long-term exposures are
estimated using Turner et al. (2016). Due to time and resource limitations, we were unable to
reflect the warm season defined by Zanobetti et al. (2008) as June-August. Instead, we apply this
risk estimate to our standard warm season of May-September.
4.5 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
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of a health effect. They tend to reflect the direct expenditures related to treatment but not the
value of avoided pain and suffering from the health effect. The unit values applied in this
analysis are provided in the TSD for the 2022 PM NAAQS Reconsideration Proposal RIA:
Estimating PM2.5- and Ozone-Attributable Health Benefits (U.S. EPA, 2023d).
Avoided premature deaths account for 95 percent of monetized ozone-related benefits
and 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 Scientific Advisory Board's (SAB) 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).
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 while the EPA
continues its efforts to update its guidance on this issue (U.S. EPA, 2016). This approach
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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 $12.8
million ($2022).
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
subsequently reviewed by the SAB-EEAC. The EPA is taking the SAB's formal
recommendations under advisement (U.S. EPA, 2017b).
Because short-term ozone-related premature mortality occurs within the analysis year, the
estimated ozone-related benefits are identical for all discount rates. When valuing changes in
ozone-attributable deaths using the Turner et al. (2016) study, we follow advice provided by the
Health Effects Subcommittee of the SAB, which found that".. .there is no evidence in the
literature to support a different cessation lag between ozone and particulate matter. The HES
therefore recommends using the same cessation lag structure and assumptions as for particulate
matter when utilizing cohort mortality evidence for ozone" (U.S. EPA-SAB 2010).
These estimated health benefits do not account for the influence of future changes in the
climate on ambient concentrations of pollutants (USGCRP 2016). For example, recent research
suggests that future changes to climate may create conditions more conducive to forming ozone.
The estimated health benefits also do not consider the potential for climate-induced changes in
temperature to modify the relationship between ozone and the risk of premature mortality (Jhun
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et al. 2014; Ren et al. 2008a, 2008b).
4.5.1 Benefit-per- Ton Estimates
The EPA did not conduct air quality modeling for this proposed rule. Rather, we
quantified the value of reducing PM and ozone concentrations using a "benefit-per-ton"
approach, due to the relatively small number of facilities and the fact that these facilities are
located in a discrete location. Specifically, EPA believes that the emissions reductions due to this
rule are small and because we cannot be confident of the location of new facilities under the
NSPS, EPA elected to use the benefit-per-ton approach. 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 benefits of this rulemaking. These
BPT estimates provide the total monetized human health benefits (the sum of premature
mortality and premature morbidity) of reducing one ton of the PM2.5, NOx and SO2 precursor for
PM2.5 and the NOx precursor for ozone from a specified source. Specifically, in this analysis, we
multiplied the estimates from the "Pulp and Paper" sector by the corresponding emission
reductions. We chose the Pulp and Paper sector as a surrogate for the LMWC sector due to the
similarity of the spatial distribution of the emissions from these sectors. The method used to
derive these estimates is described in the BPT Technical Support Document (BPT TSD) on
Estimating the Benefit per Ton of Reducing Directly-Emitted PM2.5, PM2.5 Precursors and Ozone
Precursors from 21 Sectors (U.S. EPA, 2023). As noted above, we were unable to quantify the
value of changes in exposure to HAP and dioxin/furans.
As noted below in the characterization of uncertainty, all BPT estimates have inherent
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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 the action, and they may not reflect local variability in population density, meteorology,
exposure, baseline health incidence rates, or other local factors for any specific location. Given
sector specific air quality modeling and the small changes in emissions considered in this action,
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.
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 benefits (compared to full-scale modeling)
under different scenarios and air quality concentrations. The EPA Science Advisory Board
(SAB) convened a panel to review this report.5 In particular, the SAB assessed the techniques the
Agency used to appraise these tools; the Agency's approach for depicting the results of reduced-
4-22
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form tools; and steps the Agency might take for improving the reliability of reduced-form
techniques for use in future Regulatory Impact Analyses (RIAs).
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 (IEc, 2019. Evaluating Reduced-Form Tools for Estimating Air Quality
Benefits. Final Report). 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, a sector used as an example for evaluating the
application of the new methodology in the final report. The ratios for individual PM 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-form air quality modeling
combined with BenMAP. This provides some initial understanding of the uncertainty which is
associated with using the BPT approach instead of full-form air quality modeling.
4.6 Unquantified Welfare Benefits
The Clean Air Act definition of welfare effects includes, but is not limited to, effects on
soils, water, wildlife, vegetation, visibility, weather, and climate, as well as effects on man-made
materials, economic values, and personal comfort and well-being.
4.6.1 PM, NOx and SOx Ecosystem Effects
Detailed information regarding the ecological effects of nitrogen and sulfur deposition is
available in the Integrated Science Assessment for Oxides of Nitrogen, Oxides of Sulfur, and
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Particulate Matter— Ecological Criteria (ISA) (U.S. EPA, 2020b).
Particulate matter (PM) is composed of some or all of the following components: nitrate
(NO3-), sulfate (SO42-), ammonium (NH4+), metals, minerals (dust), and organic and elemental
carbon. Nitrate, sulfate, and ammonium contribute to nitrogen (N) and sulfur (S) deposition,
which causes substantial ecological effects. The ecological effects of deposition are grouped into
three main categories: acidification, N enrichment/N driven eutrophication, and S enrichment.
Ecological effects are further subdivided into terrestrial, wetland, freshwater, and estuarine/near-
coastal ecosystems. These ecosystems and effects are linked by the connectivity of terrestrial and
aquatic habitats through biogeochemical pathways of N and S.
4.6.2 Ozone Vegetation Effects
Exposure to ozone has been found to be associated with a wide array of vegetation and
ecosystem effects in the published literature (U.S. EPA, 2020). Sensitivity to ozone is highly
variable across species, with over 66 vegetation species identified as "ozone-sensitive," many of
which occur in state and national parks and forests. These effects include those that cause
damage to, or impairment of, the intended use of the plant or ecosystem. Such effects are
considered adverse to public welfare and can include reduced growth and/or biomass production
in sensitive trees, reduced yield and quality of crops, visible foliar injury, changed to species
composition, and changes in ecosystems and associated ecosystem services.
4.6.3 Climate Effects of PM2.5
In the climate section of Chapter 5 of the 2020 PM2.5 Primary NAAQS Policy
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Assessment it states "Thus, as in the last review, the data remain insufficient to conduct
quantitative analyses for PM effects on climate in the current review." (U.S. EPA, 2020d)
Pollutants that affect the energy balance of the earth are referred to as climate forcers. A
pollutant that increases the amount of energy in the Earth's climate system is said to exert
"positive radiative forcing," which leads to warming and climate change. In contrast, a pollutant
that exerts negative radiative forcing reduces the amount of energy in the Earth's system and
leads to cooling.
Atmospheric particles influence climate in multiple ways: directly absorbing light,
scattering light, changing the reflectivity ("albedo") of snow and ice through deposition, and
interacting with clouds. Depending on the particle's composition, the timing of emissions, and
where it is in the atmosphere determine if it contributes to cooling or warming. The short
atmospheric lifetime of particles, lasting from days to weeks, and the mechanisms by which
particles affect climate, distinguish it from long-lived greenhouse gases like CO2. This means
that actions taken to reduce PM2.5 will have near term effects on climate change. The
Intergovernmental Panel on Climate Change Sixth Assessment Report concludes that for forcers
with short lifetimes, "the response in surface temperature occurs 5-26 strongly, as soon as a
sustained change in emissions is implemented". The potential to affect near-term climate change
and the rate of climate change with policies to address these emissions is gaining attention
nationally and internationally (e.g., Black Carbon Report to Congress, Arctic Council, Climate
and Clean Air Coalition, and Convention on Long-Range Transboundary Air Pollution of the
United Nations Economic Commission for Europe). Recent reports have concluded that short-
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lived compounds play a prominent role in keeping global warming below 1.5° C (IPCC, 2018),
and are especially important in the rapidly warming Arctic (AMAP, 2021).
4.6.4 Ozone Climate Effects
Ozone is a well-known short-lived climate forcing GHG (IPCC, 2014). Stratospheric
ozone (the upper ozone layer) is beneficial because it protects life on Earth from the sun's
harmful ultraviolet (UV) radiation. In contrast, tropospheric ozone (ozone in the lower
atmosphere) is a harmful air pollutant that adversely affects human health and the environment
and contributes significantly to regional and global climate change. The IPCC AR5 estimated
that the contribution to current warming levels of increased tropospheric ozone concentrations
resulting from human methane, NOx, and VOC emissions was 0.5 W/m2, or about 30 percent as
large a warming influence as elevated CO2 concentrations. This quantifiable influence of ground
level ozone on climate leads to increases in global surface temperature and changes in
hydrological cycles.
4.6.5 Total Health Benefits - PM2.5 - and Ozone- Related Benefits Results
Tables 4-3, 4-4, 4-5 and 4-6 list the estimated PM2.5- and ozone- related benefits per ton
applied in this national level analysis. These estimates are used to generate the total health
benefits of the proposal, which represent the total monetized benefits of this proposal since there
are no benefits from climate pollutant changes or other benefits or disbenefits as mentioned
earlier in this section. The total health benefits are presented for the less and more stringent
alternatives as well. These total health benefits are presented in Table 4-7. Benefits are
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estimated using two alternative concentration-response parameters from three epidemiologic
studies when quantifying both PM2.5 and ozone-related mortality (Di et al. 2017, Turner et al.
2016 and Katsouyanni et al. 2009) These results are discounted at 3 and 7 percent for a 2022
currency year. For all estimates, we summarize the monetized health benefits using discount
rates of 3 percent and 7 percent for the 20-year analysis period of this proposed rule discounted
back to 2023 rounded to 2 significant figures as presented in Table 4-7. The PV of the low
estimate of the benefits for the proposed rulemaking is $5.1 billion at a 3 percent discount rate
and $3.1 billion at a 7 percent discount rate with an EAV of $340 million and $290 million,
respectively. The PV of the high estimate of the benefits for the proposed rulemaking is $16
billion at a 3 percent discount rate and $9.8 billion at a 7 percent discount rate with an EAV of
$1.1 billion and $920 million, respectively. All estimates are reported in 2022 dollars.
Undiscounted (that is, values not discounted to 2023) benefits are presented by year for the
proposed, less stringent and more stringent alternative options in Tables 4-8, 4-9, and 4-10. For
the full set of underlying calculations see the "LMWC Benefits workbook," an Excel spreadsheet
that is available in the docket for the proposal.
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Table 4-3: Pulp and Paper: Benefit per Ton Estimates of PM2.5-Attributable
Premature Mortality and Illness for the Proposal, 2025-2044 (2022$)
Discount Rate
Year
3 Percent
7 Percent
2025
$158,702
and
$343,292
$142,945 and $308,400
2030
$174,460
and
$363,552
$157,577 and $327,535
2035
$199,222
and
$402,646
$178,962 and $362,427
2040
$220,607
and
$438,964
$198,097 and $395,067
Table 4-4: Pulp and Paper: Benefit per Ton Estimates of NOx Precursor to PM2.5-
Attributable Premature Mortality and Illness for the Proposal, 2025-2044 (2022$)
Discount Rate
Year
3 Percent
7 Percent
2025
$12,268
and
$26,338
$11,008 and $23,749
2030
$13,507
and
$27,914
$12,043 and $25,100
2035
$15,195
and
$30,953
$13,732 and $27,801
2040
$16,883
and
$33,541
$15,195 and $30,277
Table 4-5: Pulp and Paper: Benefit per Ton Estimates of SO2 Precursor to PM2.5-
Attributable Premature Mortality and Illness for the Proposal, 2025-2044 (2022$)
Discount Rate
Year
3 Percent
7 Percent
2025
$42,996
and
$92,970
$38,719 and $83,628
2030
$47,498
and
$98,823
$42,658 and $88,918
2035
$54,139
and
$109,854
$48,624 and $98,823
2040
$60,329
and
$120,434
$54,251 and $108,165
Table 4-6: Pulp and Paper: Benefit per Ton Estimates of NOx Precursor to Ozone-
Attributable Premature Mortality and Illness for the Proposal, 2025-2044 (2022$)
Discount Rate
Year
3 Percent
7 Percent
2025
$10,749
and
$90,494
$9,646 and $81,309
2030
$11,481
and
$100,399
$10,389 and $90,044
2035
$12,268
and
$111,317
$11,087 and $99,724
2040
$12,944
and
$120,434
$11,706 and $108,503
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Table 4-7: Large Municipal Waste Combustors: Monetized Benefits Estimates of PM2.5-
and Ozone-Attributable Premature Mortality and Illness for Proposal Options (million
2022$)a'b
Less Stringent Regulatory
Option
Proposed Regulatory
Option
More Stringent Regulatory
Option
Discount Rate
Discount Rate
Discount Rate
3 Percent
7 Percent
3 Percent
7 Percent
3 Percent
7 Percent
$2,500
$1,500
$5,100
$3,100
$6,700
$4,100
PV
and
and
and
and
and
and
$6,300
$3,800
$16,000
$9,800
$20,000
$12,000
$170
$140
$340
$290
$450
$380
EAV
and
and
and
and
and
and
$420
$360
$1,100
$920
$1,300
$1,100
Non-Monetized Benefits
Emissions reductions of 340 tpy of HAPs including hydrogen chloride, cadmium, mercury and
dioxin/furan.c
Benefits to provision of ecosystem services associated with reductions in N and S deposition and
ozone concentrations.
¦Discounted to 2023. Calculations of PV and EAV reflect benefits estimates for the 2025-2044 analysis timeframe described in
Chapter 1 of this RIA.
bRounded to 2 significant figures.
deductions in hydrogen chloride (HC1) emissions dominate the HAP reductions (340 tpy) occurring from this proposal.
Emission reductions for individual HAP species are found in Section 4.2 of this RIA and the Emission Reduction Estimates for
Existing Large MWCs Memo for this proposal.
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Table 4-8: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature
Mortality and Illness for the Proposed Option (million 2022$), 2025-2044a'b
Year
3%
7%
2025
$300 and $970
$270 and $870
2026
$300 and $970
$270 and $870
2027
$300 and $970
$270 and $870
2028
$330 and $1,000
$290 and $940
2029
$330 and $1,000
$290 and $940
2030
$330 and $1,000
$290 and $940
2031
$330 and $1,000
$290 and $940
2032
$330 and $1,000
$290 and $940
2033
$370 and $1,200
$330 and $1,000
2034
$370 and $1,200
$330 and $1,000
2035
$370 and $1,200
$330 and $1,000
2036
$370 and $1,200
$330 and $1,000
2037
$370 and $1,200
$330 and $1,000
2038
$410 and $1,300
$370 and $1,100
2039
$410 and $1,300
$370 and $1,100
2040
$410 and $1,300
$370 and $1,100
2041
$410 and $1,300
$370 and $1,100
2042
$410 and $1,300
$370 and $1,100
2043
$410 and $1,300
$370 and $1,100
2044
$410 and $1,300
$370 and $1,100
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
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Table 4-9: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature
Mortality and Illness for the Less Stringent Alternative (million 2022$), 2025-2044a'b
Year
3%
7%
2025
$150 and $380
$130 and $340
2026
$150 and $380
$130 and $340
2027
$150 and $380
$130 and $340
2028
$160 and $400
$140 and $360
2029
$160 and $400
$140 and $360
2030
$160 and $400
$140 and $360
2031
$160 and $400
$140 and $360
2032
$160 and $400
$140 and $360
2033
$180 and $450
$160 and $400
2034
$180 and $450
$160 and $400
2035
$180 and $450
$160 and $400
2036
$180 and $450
$160 and $400
2037
$180 and $450
$160 and $400
2038
$200 and $490
$180 and $440
2039
$200 and $490
$180 and $440
2040
$200 and $490
$180 and $440
2041
$200 and $490
$180 and $440
2042
$200 and $490
$180 and $440
2043
$200 and $490
$180 and $440
2044
$200 and $490
$180 and $440
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
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Table 4-10: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature
Mortality and Illness for the More Stringent Alternative (million 2022$), 2025-2044a'b
Year
3%
7%
2025
$390 and $1
200
$350 and $1
000
2026
$390 and $1
200
$350 and $1
000
2027
$390 and $1
200
$350 and $1
000
2028
$430 and $1
300
$390 and $1
100
2029
$430 and $1
300
$390 and $1
100
2030
$430 and $1
300
$390 and $1
100
2031
$430 and $1
300
$390 and $1
100
2032
$430 and $1
300
$390 and $1
100
2033
$490 and $1
400
$440 and $1
300
2034
$490 and $1
400
$440 and $1
300
2035
$490 and $1
400
$440 and $1
300
2036
$490 and $1
400
$440 and $1
300
2037
$490 and $1
400
$440 and $1
300
2038
$540 and $1
500
$480 and $1
400
2039
$540 and $1
500
$480 and $1
400
2040
$540 and $1
500
$480 and $1
400
2041
$540 and $1
500
$480 and $1
400
2042
$540 and $1
500
$480 and $1
400
2043
$540 and $1
500
$480 and $1
400
2044
$540 and $1
500
$480 and $1
400
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
4.7 Characterization of Uncertainty in Monetized 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
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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 benefits estimate.
When the uncertainties from each stage of the analysis are compounded, even small uncertainties
can have large effects on the total quantified benefits. Therefore, the estimates of annual benefits
should be viewed as representative of the magnitude of benefits expected, rather than the actual
benefits that would occur every year.
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5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS
5.1 Introduction
The proposed amendments are projected to result in environmental control expenditures
and work practice adjustments to comply with the rule. The national-level compliance cost
analysis in Section 3 does not speak directly to potential economic and distributional impacts of
the proposed rule, which may be important consequences of the action. This section is directed
towards complementing the compliance cost analysis and includes an analysis of potential firm-
and entity-level impacts of regulatory costs and a discussion of potential employment and small
entity impacts.
5.2 Economic Impact Analysis
Although facility-specific economic impacts (production changes or closures, for
example) cannot be estimated by this analysis, the EPA conducted a screening analysis of
compliance costs compared to the revenue of firms or government bodies owning MWC
facilities. The EPA often performs a partial equilibrium analysis to estimate impacts on
producers and consumers of the products or services provided by the regulated firms. This type
of economic analysis estimates impacts on a single affected industry or several affected
industries, and all impacts of this rule on industries outside of those affected are assumed to be
zero or inconsequential (U.S. EPA, 2016).
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 may consist of a
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calculation of annual (or annualized) costs as a percent of sales for affected parent companies.
This type of analysis is often applied when a partial equilibrium or more complex economic
impact analysis approach is deemed unnecessary given the expected size of the impacts. 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. We conducted a cost-to-sales analysis to estimate the economic impacts of this
proposal, given that the EAV of the compliance costs range are $120 million using a 7 percent or
$110 million using a 3 percent discount rate in 2022 dollars, which is small relative to the
revenues of the MWC industry.
The EPA prefers as stated in its guidance for implementing the RFA as amended by
SBREFA 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. 9 This is
consistent with guidance published by the U.S. Small Business Administration (SBA) 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. 10 This is because revenues or sales data
are commonly available for entities impacted by the EPA regulations and profits data may often
9 More information on sales and profit tests as used in analyses done by U.S. EPA can be found in the Final
Guidance for EPA Rulewriters: Regulatory Flexibility Act as Amended by the Small Business Regulatory
Enforcement Fairness Act, November 2006, pp. 32-33. Available at
https://19ianuarv2017snapshot.epa.gov/sites/production/files/2015-06/documents/guidance-regflexact.pdf.
10 U.S. SB A, Office of Advocacy. August 2017. A Guide for Government Agencies, How to Comply with the
Regulatory Flexibility Act, Implementing the President's Small Business Agenda and Executive Order 13272.
Available at https://www.sba.gov/sites/default/files/advocacv/How-to-Complv-with-the-RFA-WEB.pdf.
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be private or tend to misrepresent true economic profits earned by firms after undertaking legally
available accounting and tax considerations.
While a "sales test" can provide some insight as to the economic impact of an action such
as this one, it assumes that the impacts of a rule are solely incident on a directly affected firm
(therefore, no impact to consumers of an affected product), or solely incident on consumers of
output directly affected by this action (therefore, no impact to companies that are producers of
affected product). Thus, an analysis such as this one is best viewed as providing insight on the
polar examples of economic impacts: maximum impact to either directly affected companies or
their consumers. A "sales test" analysis does not consider shifts in supply and demand curves to
reflect intermediate economic outcomes such as output adjustments in response to increased
costs.
5.3 Employment Impacts Analysis
This section presents a qualitative overview of the various ways that environmental
regulation can affect employment. Employment impacts of environmental regulations are
generally composed of a mix of potential declines and gains in different areas of the economy
over time. Regulatory employment impacts can vary across occupations, regions, and industries;
by labor and product demand and supply elasticities; and in response to other labor market
conditions. Isolating such impacts is a challenge, as they are difficult to disentangle from
employment impacts caused by a wide variety of ongoing, concurrent economic changes. The
EPA continues to explore the relevant theoretical and empirical literature and to seek public
5-3
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comments in order to ensure that the way the EPA characterizes the employment effects of its
regulations is reasonable and informative. 11
Environmental regulation "typically affects the distribution of employment among
industries rather than the general employment level" (Arrow, et al., 1996). Even if impacts are
small after long-run market adjustments to full employment, many regulatory actions have
transitional effects in the short run (Office of Management and Budget, 2015). These movements
of workers in and out of jobs in response to environmental regulation are potentially important
and of interest to policymakers. Transitional job losses have consequences for workers that
operate in declining industries or occupations, have limited capacity to migrate, or reside in
communities or regions with high unemployment rates.
As indicated by the potential impacts to MWC facilities discussed in Section 5.2, the
proposed requirements are unlikely to cause large shifts in electricity production or MWC
disposal costs. As a result, demand for labor employed in MWC activities and associated
industries is unlikely to see large changes but might experience adjustments as there may be
increases in compliance-related labor requirements such as labor associated with the
manufacture, installation, and operation of pollution control devices as well as either consume
the power generated by MWC facilities or communities using MWC services. For this proposal,
11 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).
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however, we do not have the data and analysis available to quantify these potential labor
impacts.
5.4 Small Business Impact Analysis
To determine the possible impacts of the proposed amendments on small businesses,
parent companies or entities of MWC facilities are categorized as small or large using the Small
Business Administration's (SBA's) general size standards definitions for affected NAICS codes,
and a definition for small municipalities of 50,000 or less in population. Based on the SBA
definitions and the definition for small municipalities just mentioned, this proposed rule does not
affect any small businesses or entities. Hence, there is no significant impact on a substantial
number of small entities (SISNOSE) for this proposed rule.
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6 COMPARISON OF BENEFITS AND COSTS
In this chapter, we present a comparison of the benefits and costs of this proposed action
and the more and less stringent alternative regulatory options. As explained previously in the
sections document, all costs and benefits outlined in this RIA are estimated as the change from
the baseline, which reflects the requirements already promulgated. 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 proposed action. Further, the monetized benefits associated with PM2.5, SO2,
and NOx include health benefits associated with reduced premature mortality and morbidity
associated with exposure to PM2.5, and do not include other health and environmental impacts
associated with reduced PM emissions, such as ecosystem effects (such as reduced N and S
deposition). EPA expects these benefits are positive, and as a result the net benefits presented in
this section are likely understated.
6.1 Results
As part of fulfilling analytical guidance with respect to E.O. 12866, EPA presents
estimates of the present value (PV) of the benefits and costs over the period 2025 to 2044. To
calculate the present value of the social net benefits of the proposed action, annual benefits and
costs are in 2022 dollars and are discounted to 2023 at 3 percent and 7 percent discount rates as
directed by OMB's Circular A-4. The EPA also presents the equivalent annualized value (EAV),
which represents a flow of constant annual values that would yield a sum equivalent to the PV.
The EAV represents the value of a typical cost or benefit for each year of the analysis, consistent
with the estimate of the PV, in contrast to year-specific estimates.
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Table 6-1 presents a summary of the monetized benefits, compliance costs, and net
benefits of the proposed EG and NSPS amendments, and the more and less stringent alternative
regulatory options, in terms of present value (PV) and equivalent annualized value (EAV). Table
6-1 lists benefits using two alternative concentration-response from Di et al. (2016) and Turner et
al. (2017).
Table 6-1: Summary of Monetized Benefits, Compliance Costs, Net Benefits, and Non-
Monetized Benefits PV/EAV, 2025-2044 (million 2022$, discounted to 2023)a'b
Less Stringent More Stringent
Alternative Alternative
3%
PV
EAV
PV
EAV
PV
EAV
Health Benefits
$5,100
and
$16,00
0
$340
and
$1,10
0
$2,500
and
$6,300
$170
and
$420
$6,700
and
$20,000
$450
and
$1,300
Compliance
Costs
$1,700
$110
$1,100
$74
$6,900
$460
Net Benefits
$3,400
and
$14,00
0
$230
and
$970
$1,400
and
$5,200
$95
and
$350
-$120
and
$13,000
-$8
and
$850
7%
Health Benefits
Compliance
Costs
$3,100
and
$9,800
$1,200
$290
and
$920
$120
$1,500
and
$3,800
$780
$140
and
$360
$74
$4,100
and
$12,000
$4,900
$380
and
$1,100
$470
Net Benefits
$1,800
and
$8,500
$170
and
$800
$730
and
$3,000
$69
and
$280
-$890
and
$6,800
-$84
and
$640
a Rounded to two significant figures. Rows may not appear to add correctly due to rounding.
b Monetized benefits include health benefits associated with reductions in PM2.5 emissions. The health benefits are associated
with several point estimates and are presented at real discount rates of 3 and 7 percent. The monetized health benefits are
quantified using two alternative concentration-response relationships from the Di et al. (2016) and Turner et al. (2017) studies
and presented at real discount rates of 3 and 7 percent. Benefits from HAP reductions remain unmonetized and are thus not
reflected in the table. Rows may not appear to add correctly due to rounding.
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c For details on HAP health effects associated with the rule, see Section Error! Reference source not found..
d Adverse effects include terrestrial and aquatic acidification, terrestrial nitrogen enrichment and aquatic eutrophication.
Given these results, the EPA expects that implementation of the proposed amendments,
based solely on an economic efficiency criterion, will provide society with a substantial net gain
in welfare, notwithstanding the set of health and environmental benefits and other impacts we
were unable to quantify such as monetization of benefits from HAP emission reductions. Further
quantification of directly-emitted PM2.5 and HAP benefits would increase the estimated net
benefits of the proposed action. In addition to providing discounted net benefits in accordance
with OMB Circular A-4, we also provide net benefits that are undiscounted. These values are
discounted to 2023 later in Section 6 of this RIA. The undiscounted net benefits of the proposed
amendments are presented in Table 6-2, Table 6-3, and 2025-2044a,b
6-3
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Year
3%
7%
2025
-$120 and $110
-$130 and $76
2026
$81 and $310
$67 and $270
2027
$81 and $310
$67 and $270
2028
$96 and $340
$79 and $300
2029
$96 and $340
$79 and $300
2030
$96 and $340
$79 and $300
2031
$96 and $340
$79 and $300
2032
$96 and $340
$79 and $300
2033
$120 and $380
$99 and $340
2034
$120 and $380
$99 and $340
2035
$58 and $330
$40 and $280
2036
$120 and $380
$99 and $340
2037
$120 and $380
$99 and $340
2038
$140 and $420
$120 and $380
2039
$140 and $420
$120 and $380
2040
$65 and $350
$45 and $300
2041
$140 and $420
$120 and $380
2042
$140 and $420
$120 and $380
2043
$140 and $420
$120 and $380
2044
$140 and $420
$120 and $380
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
Table 6-4 below.
4
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Table 6-2: Undiscounted Net Benefits Estimates for the Proposed Option (million 2022$),
2025-2044a'b
Year
3%
7%
2025
-$150 and $510
-$180 and $420
2026
$210 and $880
$180 and $780
2027
$210 and $880
$180 and $780
2028
$240 and $960
$200 and $850
2029
$240 and $960
$200 and $850
2030
$240 and $960
$200 and $850
2031
$240 and $960
$200 and $850
2032
$240 and $960
$200 and $850
2033
$280 and $1,100
$240 and $950
2034
$280 and $1,100
$240 and $950
2035
$220 and $1,000
$190 and $900
2036
$280 and $1,100
$240 and $950
2037
$280 and $1,100
$240 and $950
2038
$320 and $1,200
$280 and $1,000
2039
$320 and $1,200
$280 and $1,000
2040
$280 and $1,100
$240 and $1,000
2041
$320 and $1,200
$280 and $1,000
2042
$320 and $1,200
$280 and $1,000
2043
$320 and $1,200
$280 and $1,000
2044
$320 and $1,200
$280 and $1,000
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
5
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Table 6-3: Undiscounted Net Benefits Estimates for the Less Stringent Alternative Option
(million 2022$), 2025-2044a b
Year
3%
7%
2025
-$120 and $110
-$130 and $76
2026
$81 and $310
$67 and $270
2027
$81 and $310
$67 and $270
2028
$96 and $340
$79 and $300
2029
$96 and $340
$79 and $300
2030
$96 and $340
$79 and $300
2031
$96 and $340
$79 and $300
2032
$96 and $340
$79 and $300
2033
$120 and $380
$99 and $340
2034
$120 and $380
$99 and $340
2035
$58 and $330
$40 and $280
2036
$120 and $380
$99 and $340
2037
$120 and $380
$99 and $340
2038
$140 and $420
$120 and $380
2039
$140 and $420
$120 and $380
2040
$65 and $350
$45 and $300
2041
$140 and $420
$120 and $380
2042
$140 and $420
$120 and $380
2043
$140 and $420
$120 and $380
2044
$140 and $420
$120 and $380
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
6
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Table 6-4: Undiscounted Net Benefits Estimates for the More Stringent Alternative Option
(million 2022$), 2025-2044a b
Year
3%
7%
2025
-$1,500 and -$730
-$1,600 and -$930
2026
$74 and $880
$34 and $680
2027
$74 and $880
$34 and $680
2028
$110 and $980
$74 and $780
2029
$110 and $980
$74 and $780
2030
$110 and $980
$74 and $780
2031
$110 and $980
$74 and $780
2032
$110 and $980
$74 and $780
2033
$170 and $1,100
$120 and $980
2034
$170 and $1,100
$120 and $980
2035
$120 and $1,000
$71 and $930
2036
$170 and $1,100
$120 and $980
2037
$170 and $1,100
$120 and $980
2038
$220 and $1,200
$160 and $1,100
2039
$220 and $1,200
$160 and $1,100
2040
-$1,000 and -$53
-$1,100 and -$150
2041
$220 and $1,200
$160 and $1,100
2042
$220 and $1,200
$160 and $1,100
2043
$220 and $1,200
$160 and $1,100
2044
$220 and $1,200
$160 and $1,100
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
6.2 Uncertainties and Limitations
Throughout the RIA, we considered a number of sources of uncertainty, both
quantitatively and qualitatively, regarding the benefits, and costs of the proposed amendments.
We summarize the key elements of our discussions of uncertainty here:
Projection methods and assumptions: The number of facilities in operation is assumed to be
constant over the course of the analysis period. Unexpected facility closure or idling
7
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affects the number of facilities subject to the proposed amendments. We also assume 100
percent compliance with these proposed rules and existing rules, starting from when the
source becomes affected. If sources do not comply with these rules, at all or as written, or
choose to close rather than comply, the cost impacts and emission reductions, and other
impacts, may be overestimated. Historically, 1.2% of facilties have closed each year. The
rule will not prevent the future emissions of facilities that would close regardless of the
rule. If facilities close during the period of analysis, the assumption that the number of
facilities will be constant could result in an overestimate of the future costs and a larger
overestimate of the future benefits of the rule. Additionally, new control technologies
may become available in the future at lower cost, and we are unable to predict exactly
how industry will comply with the proposed rules in the future.
• Years of analysis: The years of the cost analysis are 2025, to represent the first-year
facilities are fully compliant with the proposed amendments, through 2044, to present
20 years of potential regulatory impacts, as discussed in Chapter 3. Extending the
analysis beyond 2044 would introduce substantial and increasing uncertainties in the
projected impacts of the proposed amendments.
• Compliance Costs: There is uncertainty associated with the costs required to install
and operate the equipment and perform the work practices necessary to meet the
proposed emissions limits. There is also uncertainty associated with the exact controls
8
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a facility may install to comply with the requirements, and the interest rate they are
able to obtain if financing capital purchases. There may be an opportunity cost
associated with the installation of environmental controls (for purposes of mitigating
the emission of pollutants) that is not reflected in the compliance costs included in
Chapter 3. If environmental investment displaces investment in productive capital, the
difference between the rate of return on the marginal investment (which is
discretionary in nature) displaced by the mandatory environmental investment is a
measure of the opportunity cost of the environmental requirement to the regulated
entity. To the extent that any opportunity costs are not included in the control costs,
the compliance costs presented above for this proposed action may be
underestimated.
• Emissions Reductions: Baseline emissions and projected emissions reductions are
based on emissions from monitors, assumptions about current emissions controls, and
facility stack testing. To the extent that any of these data or assumptions are
unrepresentative, the emissions reductions (and therefore benefits) associated with the
proposed amendments could be over or underestimated.
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 the action, and they may not reflect local variability in population density,
meteorology, exposure, baseline health incidence rates, or other local factors for any
9
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specific location. Recently, 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
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 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
.
Non-monetized benefits: Numerous categories of health and welfare benefits are not quantified
and monetized in this RIA. These unquantified benefits, including benefits from
reductions in emissions of pollutants such as HAP and dioxin/furan which are to be
reduced by this proposed action, are described in detail in Section 4 of this RIA.
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PM health impacts: In this RIA, we quantify an array of adverse health impacts attributable to
emissions of PM. The Integrated Science Assessment for Particulate Matter (U.S. EPA,
2019) identifies the human health effects associated with ambient particles, which include
premature death and a variety of illnesses associated with acute and chronic exposures.
As described in the TSD "Estimating PM2.5 and Ozone-Attributable Health Benefits"
(U.S. EPA, 2023b), EPA did not quantify endpoints classified in the ISA as being "less
than causally" related to PM2.5.
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7 REFERENCES
Agency for Toxic Substances and Disease Registry (ATSDR) 1998. Toxicological Profile for
Chlorinated Dibenzop-Dioxins. Public Health Service, U.S. Department of Health and
Human Services, Atlanta, GA.
Agency for Toxic Substances and Disease Registry (ATSDR, 1999). Toxicological Profile for
Mercury. Public Health Service, U.S. Department of Health and Human Services,
Atlanta, GA. https://www.atsdr.cdc.gov/toxprofiles/tp46.pdf
Agency for Toxic Substances and Disease Registry (ATSDR). 2012. Toxicological profile for
Cadmium. Atlanta, GA: U.S. Department of Health and Human Services, Public Health
Service.
Agency for Toxic Substances and Disease Registry (ATSDR). 2020. Toxicological profile for
Lead. Atlanta, GA: U.S. Department of Health and Human Services, Public Health
Service.
Agency for Toxic Substances and Disease Registry (ATSDRa). Medical Management Guidelines
for Hydrogen Chloride. Atlanta, GA: U.S. Department of Health and Human
Services. Available
at:https://wwwn.cdc.gov/TSP/MMG/MMGDetails.aspx?mmgid=758&toxid=147 last
reviewed October, 2014.
12
-------
AMAP, (2021). AMAP Assessment 2021: Impacts of Short-lived Climate Forcers in Arctic
Climate, Air Quality, and Human Health. Arctic Monitoring and Assessment Programme
(AMAP). Tromso, Norway. Available at: https://www.amap.no/documents/doc/amap-
assessment-2021-impacts-of-short-lived-climate-forcers-on-arctic-climate-air-quality-
and-human-health/3 614.
Arrow, K. J.; M. L. Cropper; G. C. Eads; R. W. Hahn; L. B. Lave; R. G. Noll; Paul R. Portney;
M. Russell; R. Schmalensee; V. K. Smith and R. N. Stavins (1996). "Benefit-Cost
Analysis in Environmental, Health, and Safety Regulation: A Statement of Principles. "
American Enterprise Institute, the Annapolis Center, and Resources for the Future; AEI
Press
IPCC, 2014: Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and
III to the Fifth Assessment Report of the Intergovernmental Panel on Climate
Change [Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva,
Switzerland, 151 pp.
IPCC, 2023: Climate Change 2023: Synthesis Report. A Report of the Intergovernmental Panel
on Climate Change. Contribution of Working Groups I, II and III to the Sixth Assessment
Report of the Intergovernmental Panel on Climate Change [Core Writing Team, H. Lee
and J. Romero (eds.)]. IPCC, Geneva, Switzerland, (in press)
13
-------
Bell, M.L., A. McDermott, S.L. Zeger, J.M. Sarnet, and F. Dominici. (2004). "Ozone and Short-
Term Mortality in 95 U.S. Urban Communities, 1987-2000. " Journal of the American
Medical Association. 292(19):2372-8.
Bell, M.L., F. Dominici, and J.M. Samet. (2005). "A Meta-Analysis of Time-Series Studies of
Ozone and Mortality with Comparison to the National Morbidity, Mortality, and Air
Pollution Study." Epidemiology. 16(4):436-45.
BenMAP-CE Manual and Appendices, (2022). https://www.epa.gov/benmap/benmap-ce-
manual-and-appendices
Burgiel, Jonathan (1998). "Trends in Privatization and Managed Competition: National Survey
Results," R.W. Beck, Seattle.
Chartwell Information Publishers, Inc (1998). Chartwell's Directory and Atlas of Solid Waste
Disposal Facilities, 1997-98.
Di, Q, Wang, Y, Zanobetti, A, Wang, Y, Koutrakis, P, Choirat, C, Dominici, F and Schwartz, JD
(2017). Air pollution and mortality in the Medicare population. New England Journal of
Medicine 376(26): 2513-2522.
Eastern Research Group (1999). "Database Development. " Prepared for the U.S. Environmental
Protection Agency, Emission Standards Division.
14
-------
Eastern Research Group (2001). "Cost Analysis of Bioreactor Supplemental Proposal for the
Landfills NESHAP." Prepared for the U.S. Environmental Protection Agency, Emission
Standards Division.
Huang Y, Dominici F, Bell M. (2004). Bayesian Hierarchical Distributed Lag Models for
Summer Ozone Exposure and Cardio-Respiratory Mortality. Johns Hopkins Univ Dept
Biostat Work Pap Ser.
IEc. (2019). Evaluating Reduced-form Tools for Estimating Air Quality Benefits. Available at:
https://www.epa.gov/sites/default/files/2020-09/documents/iec_rft_report_9.15.19.pdf.
IPCC. (2018). Global Warming of 1.5°C. An IPCC Special Report on the impacts of global
warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission
pathways, in the context of strengthening the global response to the threat of climate
change. (Masson-Delmotte, V., P. Zhai, H.-O. Portner, D. Roberts, J. Skea, . . . T.
Waterfield, Eds.)
IPCC. (2023): Climate Change 2023: Synthesis Report. A Report of the Intergovernmental Panel
on Climate Change. Contribution of Working Groups I, II and III to the Sixth Assessment
Report of the Intergovernmental Panel on Climate Change [Core Writing Team, H. Lee
and J. Romero (eds.)]. IPCC, Geneva, Switzerland, (in press)
Ito, K., S.F. De Leon, and M. Lippmann. (2005). "Associations Between Ozone and Daily
15
-------
Mortality: Analysis andMeta-Analysis. " Epidemiology. 16(4):446-57.
Jerrett M, Burnett RT, Pope CA, Ito K, Thurston G, Krewski D, et al. (2009). Long-term ozone
exposure and mortality. NEngl J Med 360:1085-95; doi:10.1056/NEJMoa0803894.
Jhun I, Fann N, Zanobetti A, Hubbell B. (2014). Effect modification of ozone-related mortality
risks by temperature in 97 US cities. Environment International. 73:128-34.
Katsouyanni, K, Samet, JM, Anderson, HR, Atkinson, R, Le Tertre, A, Medina, S, Samoli, E,
Touloumi, G, Burnett, RT, Krewski, D, Ramsay, T, Dominici, F, Peng, RD, Schwartz, J,
Zanobetti, A and Committee, HEIHR (2009). Air pollution and health: a European and
North American approach (APHENA). Res Rep Health Eff Inst(142): 5-90.
Levy, J.I., S.M. Chemerynski, and J.A. Sarnat (2005). "Ozone Exposure andMortality: An
Empiric BayesMetaregression Analysis. " Epidemiology. 16(4):458-68.
NRC (2002). Estimating the public health benefits of proposed air pollution regulations.
0309086094. National Academies Press.
National Research Council. (NRC). (2008). Estimating Mortality Risk Reduction and Economic
Benefits from Controlling Ozone Air Pollution. Washington, DC: The National
Academies Press, https://doi.org/10.17226/12198. Available at:
https://nap.nationalacademies.org/catalog/12198/estimating-mortality-risk-reduction-and-
-------
economic-benefits-from-controlling-ozone-air-pollution.
Pope III, CA, Lefler, JS, Ezzati, M, Higbee, JD, Marshall, JD, Kim, S-Y, Bechle, M, Gilliat, KS,
Vernon, SE and Robinson, AL (2019). Mortality risk andfine particulate air pollution in
a large, representative cohort of US adults. Environmental health perspectives 127(7):
077007.
Reason Public Policy Institute (2000). "Privatizing Landfills: Market Solutions for Solid-Waste
Disposal. " Written by Segal, Geoffrey F. and Moore, Adrian T. Policy Study No. 267.
Ren, C., G.M. William, L. Morawska, K. Mengensen, and S. Tong. (2008b). "OzoneModifies
Associations between Temperature and Cardiovascular Mortality: Analysis of the
NMMAPSData. " Occupational and Environmental Medicine. 65:255-260.
Ren, C., G.M. Williams, K. Mengersen, L. Morawska, and S. Tong. (2008a). "Does Temperature
Modify Short-Term Effects of Ozone on Total Mortality in 60 Large Eastern U.S.
Communities? An Assessment Using the NMMAPS Data." Environment International.
34:451-458.
Schwartz, J. (2005). "How Sensitive is the Association between Ozone and Daily Deaths to
Control for Temperature? " American Journal of Respiratory and Critical Care Medicine.
171(6): 627-31.
17
-------
Smith RL, Xu B, Switzer P (2009). Reassessing the relationship between ozone and short-term
mortality in U.S. urban communities. Inhal Toxicol 21 Suppl 2:37-61;
doi:10.1080/08958370903161612.
Turner, MC, Jerrett, M, Pope, A, III, Krewski, D, Gapstur, SM, Diver, WR, Beckerman, BS,
Marshall, JD, Su, J, Crouse, DL and Burnett, RT (2016). Long-term ozone exposure and
mortality in a large prospective study. Am J Respir Crit Care Med 193(10): 1134-1142.
U.S. Environmental Protection Agency), (1985). U.S. EPA. Health Assessment Document for
Poly chlorinated Dibenzo-P-Dioxins, Washington, D.C., EPA/600/8-84/014F (NTIS
PB86122546.
U.S. Environmental Protection Agency, (1987). Integrated Risk Information System (IRIS) on
Cadmium. National Center for Environmental Assessment, Office of Research and
Development, Washington, DC.
U.S. Environmental Protection Agency (1989). In three parts: Final Report of the Municipal
Solid Waste Task Force, EPA/530-SW-89-019. Background Document, EPA/530-SW-
88-054a. Appendices A-B-C, EPA/530-SW-88-054b.
U.S. Environmental Protection Agency (1991). Regulatory Impact Analysis of Air Pollutant
Emission Standards and Guidelines for Municipal Solid Waste Landfills.
18
-------
U.S. Environmental Protection Agency, (1995/ Integrated Risk Information System (IRIS) on
Mercuric Chloride. National Center for Environmental Assessment, Office of Research
and Development, Washington, DC.
https://cfpub.epa.gov/ncea/iris/iris_documents/documents/subst/0692_summary.pdf
U.S. Environmental Protection Agency (U.S.EPA). (1995). Integrated Risk Information System
File of Hydrogen Chloride. Research and Development, National Center for
Environmental Assessment, Washington, DC
U.S. Environmental Protection Agency, (2001). Integrated Risk Information System (IRIS) on
Methylmercury. National Center for Environmental Assessment, Office of Research and
Development, Washington, DC.
https://cfpub.epa.gov/ncea/iris/iris_documents/documents/subst/0073_summary.pdf
U.S. Environmental Protection Agency, (2004). IRIS Summary on Lead and compounds
(inorganic). National Center for Environmental Assessment, Office of Research and
Development, Washington, DC.
U.S. EPA (2015). Regulatory Impact Analysis of the Final Revisions to the National Ambient Air
Quality Standards for Ground-Level Ozone. Office of Air Quality Planning and
Standards, Health and Environmental Impacts Division. Research Triangle Park, NC.
U.S. EPA. EPA-452/R-15-007. September 2015. Available at:
19
-------
https://www3.epa.gov/ttnecasl/docs/20151001ria.pdf
U.S. EPA. (2016). Guidelines for Preparing Economic Analyses. Available at:
https://www.epa.gov/environmental-economics/guidelines-preparing-economic-analyses.
U.S. EPA (2020a). Integrated Science Assessment for Ozone and Related Photochemical
Oxidants. U.S. Environmental Protection Agency. Washington, DC. Office of Research
and Development. EPA/600/R-20/012. Available at: https://www.epa.gov/isa/integrated-
science-assessment-isa-ozone-and-related-photochemical-oxidants.
U.S. EPA (2020b). U.S. EPA. Integrated Science Assessment (ISA) for Oxides of Nitrogen,
Oxides of Sulfur and Particulate Matter Ecological Criteria (Final Report, 2020). U.S.
Environmental Protection Agency, Washington, DC, EPA/600/R-20/278. Available at:
https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=349473.
U.S. EPA (2021). Technical Support Document (TSD) for the Final Revised Cross-State Air
Pollution Rule Update for the 2008 Ozone Season NAAQS: Estimating PM2.5- and
Ozone Attributable Health Benefits U.S. Environmental Protection Agency. Durham,
NC. Office of Air Quality Planning and Standards. EPA-HQ-OAR-2020-0272. Available
at: https://www.epa.gov/sites/default/files/2021-03/documents/estimating_pm2.5-
_and_ozone-attributable_health_benefits_tsd.pdf.
U.S. EPA (2022a). Regulatory Impact Analysis for the Proposed Reconsideration of the National
20
-------
Ambient Air Quality Standards for Particulate Matter. Office of Air Quality Planning and
Standards, Health and Environmental Impacts Division, Research Triangle Park, NC.
Docket number: EPA-HQ-OAR-2019-0587. Available at:
https://www.epa.gOv/system/files/documents/2023-01/naaqs-pm_ria_proposed_2022-
12.pdf.
U.S. EPA (2022b). Policy Assessment for the Reconsideration of the National Ambient Air
Quality Standards for Particulate Matter. Office of Air Quality Planning and Standards,
Health and Environmental Impacts Division, Research Triangle Park, NC. EPA-452/R-
22-004. Available at: https://www.epa.gov/system/files/documents/2022-
5/Final%20Policy%20Assessment%20for%20the%20Reconsideration%20of%20the%20
PM%20N AAQS_May2022_0.pdf.
U.S. EPA (2023a). Regulatory Impact Analysis for the Proposed National Emission Standards
for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating
Units Review of the Residual Risk and Technology Review. EPA-452/R-23-002
U.S. EPA (2023b). Technical Support Document Estimating the Benefit per Ton of Reducing
Directly-Emitted PM2.5, PM2.5 Precursors and Ozone Precursors from 21 Sectors.
Research Triangle Park, NC: U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Health and Environmental Impact Division. Available
at: https://www.epa.gov/system/files/documents/2021-10/source-apportionment-tsd-oct-
-------
2021_0.pdf
U.S. EPA (2023d). Technical Support Document (TSD) for the 2022 PM NAAQS
Reconsideration Proposal RIA: Estimating PM2.5- and Ozone-Attributable Health
Benefits. U.S. Environmental Protection Agency, Office of Air and Radiation. Docket ID
No. EPA-HQ-0AR-2019-0587. Available at:
https://www.epa.gov/system/files/documents/2023-01/Estimating%20PM2.5-
%20and%200zone-Attributable%20Health%20Benefits%20TSD_0.pdf.
U.S. EPA, (2016). Guidelines for Preparing Economic Analyses.
U.S. EPA, (2017a). Control Cost Manual.
U.S. EPA, (2017b). SAB Review of EPA's Proposed Methodology for Updating Mortality Risk
Valuation Estimates for Policy Analysis.
U.S. EPA, (2019c). Reduced Form Evaluation Project Report. Available at:
https://www.epa.gov/benmap/reduced-form-evaluation-project-report.
U.S. EPA. (2015) Regulatory Impact Analysis of the Final Revisions to the National Ambient
Air Quality Standards for Ground-Level Ozone.
U.S. EPA. (2023b). EstimatingPM2.5- and Ozone-Attributable Health Benefits. Research
Triangle Park, NC: U.S. Environmental Protection Agency, Office of Air Quality
22
-------
Planning and Standards, Health and Environmental Impact Division. Available at:
https://www.regulations.gov/docket/EPA-HQ-OAR-2018-0794
U.S. EPA. (2012). Regulatory Impact Assessment for the Particulate Matter National Ambient
Air Quality Standards.
U.S. EPA. (2019b). Integrated Science Assessment for Particulate Matter. EPA/600/R-08/139F.
U.S. EPA-SAB. (2000). An SAB Report on EPA's White Paper Valuing the Benefits of Fatal
Cancer Risk Reduction.
U.S. -SAB (U.S. EPA-SAB). (2010). Review of EPA's Draft Health Benefits of the Second
Section 812 Prospective Study of the CAA
U.S. EPA-SAB-C AS AC, ( 2019a). CASAC Review of the EPA's Integrated Science Assessment
for Particulate Matter. Available at:
https://casac.epa.gov/ords/sab/f?p=105:18:34242723037117: ::RP,18:P18_ID:2461
USGCRP. (2016). The Impacts of Climate Change on Human Health in the United States: A
Scientific Assessment.; doi:http://dx.doi.org/10.7930/J0R49NQX.
Wu, X, Braun, D, Schwartz, J, Kioumourtzoglou, M and Dominici, F (2020). Evaluating the
impact of long-term exposure to fine particulate matter on mortality among the elderly.
Science advances 6(29): eaba5692.
23
-------
Zanobetti A, Schwartz J. (2008). Mortality displacement in the association of ozone with
mortality: an analysis of 48 cities in the United States. Am J Respir Crit Care Med
177:184-9; doi: 10.1164/rccm.200706-8230C.
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United States Office of Air Quality Planning and Standards Publication No. EPA-452/R-24-007
Environmental Protection Health and Environmental Impacts Division January 2024
Agency Research Triangle Park, NC
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