  SEQ CHAPTER \h \r 1 

MEMORANDUM

TO:		Toni Jones, U.S. Environmental Protection Agency

FROM:  	Eastern Research Group, Inc.	

DATE:  	November 21, 2011

SUBJECT:  	Economic Impact Analysis: Reconsideration Proposal Inputs
Comparison

An economic impact analysis for existing CISWI units was conducted at
promulgation, using inputs presented previously in a separate
memorandum.1 During the reconsideration process, changes were made to
the CISWI inventory, emission limits, and control cost calculations.
Almost all of these changes occurred within the energy recovery unit and
waste-burning kiln subcategories of CISWI units. Consequently, the
inputs used for analyzing economic impacts have changed as well. This
memorandum compares the economic impact inputs used at promulgation to
the inputs used for the reconsideration analyses.

Changes in Economic Inputs

Table 1 shows the list of facilities in the CISWI inventory and their
corresponding lowest cost compliance options at the final rule (February
2011), reconsideration proposal, and the difference between both
estimates. For reconsideration, five facilities (14 units) were added to
the inventory (these are indicated in red text), and five facilities (7
units) were removed from the inventory (these are indicated in gray).
Three of the facilities removed from the inventory were small entities.

Over all existing units, the total cost of the lowest cost option
increased by $268 million in capital costs and $53 million in annual
costs. As shown in Table 1, much of this increase can be attributed to
the compliance costs for the 14 units that were added to the inventory
(none of which belong to small entities).

For small entities that remain in the CISWI inventory, costs are the
same at reconsideration as they were at promulgation. The three small
entities that were removed from the inventory decreased the overall
small entity costs by $43 million in capital costs and $20 million in
annual costs.

References

1.  “Revised Economic Impact Analysis Inputs for Existing CISWI
Units” Memorandum from Eastern Research Group, Inc. to Toni Jones,
U.S. Environmental Protection Agency.  January 12, 2011.

 PAGE   

 PAGE   1 

