Clean
Air
Visibility
Rule
 
Regulatory
Impact
Analysis
Comments
from
CEA
March
31,
2005
Note:
Comments
are
on
RIA
without
Chapter
3
 
Page
1­
8
and
4­
75:
Here
and
elsewhere
we
describe
the
Monte
Carlo
approach
to
characterizing
the
uncertainty
around
the
benefits
of
the
BART
rule.
Since
these
benefits
are
defined
in
terms
of
increments
beyond
the
CAIR
rule,
how
do
we
address
the
uncertainty
associated
with
those
benefits?
Do
we
Monte
Carlo
the
CAIR
benefits
before
estimating
the
incremental
benefits
of
BART?
This
could
produce
results
that
are
considerably
different
than
estimates
produced
holding
CAIR
impacts
at
their
average.
If
we
do
not
Monte
Carlo
CAIR,
we
should.
If
we
do,
then
that
should
be
made
clear
in
the
document.

 
Page
2­
7:
The
control
scenarios
seem
ad
hoc.
What
is
the
significance
of
$
1000,
$
4000,
and
$
10,000
per
ton?
Can
we
relate
to
the
marginal
costs
of
abatement
seen
elsewhere
in
this
rule
or
in
others?

 
Page
4­
22:
Why
can
we
only
quantify
visibility
benefits
for
a
subset
of
Class
I
areas?
Since
this
rule
is
designed
to
improve/
maintain
visibility,
this
merits
some
additional
explanation.

 
Page
4­
32
and
4­
59:
The
discussion
of
nonfatal
heart
attacks
here
and
elsewhere
in
the
RIA
is
unclear
about
the
treatment
of
downstream
health
impacts.
Heart
attacks
lead
to
many
future
health
complications,
including
additional
heart
attacks.
Are
these
averted
impacts
included
in
the
benefits
measure?
Does
the
analysis
address
whether
the
MI
avoided
through
CAVR
is
a
first
or
subsequent
MI?
This
is
potentially
important
since
the
costs
and
downstream
impacts
will
be
different.
Moreover,
it
seems
plausible
that
the
CAVR
rules
might
affect
initial
versus
recurrence
MIs
differently.
Much
of
this
may
be
beyond
the
scope
of
our
analysis,
but
a
brief
discussion
would
be
helpful.

 
Page
4­
65:
Why
are
we
limiting
our
attention
to
WTP
for
visibility
improvements
in
the
Southeast
and
Southwest?
If
it
is
because
we
do
not
see
improvements
in
other
areas,
then
this
should
be
made
explicit.

 
Page
6­
14:
Significant
importation
of
cement
would
seem
to
contradict
the
earlier
claim
that
prohibitively
large
transport
costs
lead
to
local
monopolies.
Please
explain.

 
Page
7­
4:
We
should
make
clear
that
designating
CAIR
as
better
than
BART
only
applies
for
EGUs
in
the
CAIR­
effected
region.

 
Chapter
8:
The
results
presented
on
the
costs
and
effectiveness
of
each
regulatory
option
for
non­
EGUs
should
be
accompanied
by
some
explanation
about
what
is
driving
these
results.
Can
we
at
least
describe
the
sets
of
technologies
that
achieve
each
of
these
outcomes?
