memorandum
to:	CISWI Reconsideration Docket
from:	Amy Lamson, Risk and Benefits Group
subject:	Health Benefits for CISWI Reconsideration Proposal
--------------------------------------------------------------------------------
date:	12/8/2011

      Due to time limitations under the court-ordered schedule, we were unable to fully update the RIA for the CISWI reconsideration proposal. We provide this memo to the docket as documentation of the estimated health benefits to support the preamble and the communication materials. These health benefits were calculated using the methodology described in the final CISWI RIA, which is available at http://www.epa.gov/ttnecas1/regdata/RIAs/CISWIRIAfinal110221_psg2.pdf, using the revised emission reductions estimated for the reconsideration proposal. We were unable to estimate the benefits from reducing exposure to HAPs and ozone, ecosystem impairment, and visibility impairment, including reducing 22,000 tons of carbon monoxide, 590 tons of HCl, 3.1 tons of lead, 1.6 tons of cadmium, 290 pounds of mercury, and 94 grams of dioxins/furans. Please refer to the full description in the final CISWI RIA of the unquantified benefits as well as analysis limitations and uncertainties. These monetized benefits are approximately 4% lower than the final CISWI NSPS due to the slight decrease in emission reductions of PM2.5, SO2, and NOx.
      
Table 1: Summary of Monetized Benefits Estimates for CISWI Reconsideration Proposal 
                                in 2015 (2008$)
                                   Pollutant
                          Emissions Reductions (tons)
                          Benefit per ton (Pope, 3%)
                          Benefit per ton (Laden, 3%)
                          Benefit per ton (Pope, 7%)
                          Benefit per ton (Laden, 7%)
                Total Monetized Benefits (millions 2008$ at 3%)
                Total Monetized Benefits (millions 2008$ at 7%)
Direct PM2.5 
                                      670
                                   $230,000
                                   $560,000
                                   $210,000
                                   $500,000
                                                                           $150
                                      to
$370
                                                                           $140
                                      to
$340
PM2.5 Precursors
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       

                                                                               
                                       

SO2 
                                     5,033
                                    $29,000
                                    $72,000
                                    $27,000
                                    $65,000
                                                                           $150
                                      to
$360
                                                                           $130
                                      to
$330
NO2
                                     5,405
                                    $4,900
                                    $12,000
                                    $4,400
                                    $11,000
                                                                          $26.0
                                      to
$64.0
                                                                          $24.0
                                      to
$58.0
 
                                       
                                       
                                       
                                       
                                     Total
                                                                           $330
                                      to
$800
                                                                           $300
                                      to
$720
*All estimates are for the implementation year (2015), and are rounded to two significant figures so numbers may not sum across columns. These models assume that all fine particles, regardless of their chemical composition, are equally potent in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by particle type. The benefit per ton estimates vary because each ton of precursor reduced has a different propensity to become PM2.5. The monetized benefits incorporate the conversion from precursor emissions to ambient fine particles. These estimates do not include benefits from reducing HAP emissions or ozone benefits. 


Table 2: Summary of Estimated Reductions in Health Incidences from PM2.5 for the
                    CISWI Reconsideration Proposal in 2015*
Avoided Premature Mortality
Pope et al.
                                      37
Laden et al.
                                      94
Avoided Morbidity
Chronic Bronchitis
                                      25
Acute Myocardial Infarction
                                      59
Hospital Admissions, Respiratory
                                       9
Hospital Admissions, Cardiovascular
                                      19
Emergency Room Visits, Respiratory
                                      35
Acute Bronchitis
                                      59
Work Loss Days
                                     4,900
Asthma Exacerbation
                                      650
MRAD
                                    29,000
Lower Respiratory Symptoms
                                      710
Upper Respiratory Symptoms
                                      530
                                       
*All estimates are for the analysis year (2015) and are rounded to whole numbers with two significant figures. These models assume that all fine particles, regardless of their chemical composition, are equally potent in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation of effect estimates by particle type. These estimates do not include benefits from reducing HAP emissions and ozone exposure, nor energy disbenefits associated with the increased emissions from additional energy usage. 

           Figure 1: Breakdown of Monetized Benefits by Subcategory
                                       
                                       
Figure 2: Total Monetized PM2.5 Benefits Estimates for the CISWI Reconsideration Proposal in 2015
                                       
