Chapter 5- Benefits RIA Comments

Substantive Concerns:

a) in general: i.e, akin to the discussion in the PM benefits chapter
that emphasized the sources of uncertainty,

b) associated with non-attainment – akin to discussion in the PM
benefits chapter regarding increasing uncertainty in achieving benefits
as the ‘controls’ being applied become theoretical (there were some
pie charts also showing the shift in which sectors were covered as
theoretical controls were added – is this the case for ozone also)?

c) please discuss uncertainties (e.g., feasibility of achieving
standards, uncertainty associated with PRB, etc.) associated with
benefits assumptions for monitor rollbacks. 

2)  Please add a copy of the discussion regarding the baseline  (e.g.,
that ozone benefits are incremental to regs in full implementation or
whatever is the correct stmt and

that the PM co-benefits are incremental to assumptions of full
attainment of the 2006 PM2.5 NAAQS).  This should come early in the
Chapter – maybe after 5.2 or as part of 5.1

1)  whenever the term ‘PM benefits’ is used, please change it to
‘PM co-benefits’

2)  Let’s make a decision re: use of ppm vs. ppb.  There are places,
e.g., page 40 where you switch between the two.

3) Please add “premature” before each use of the term “mortality.

4)  For pages pgs 40-42:  please insert ‘full’ or ‘partial’
before each use of the word ‘attainment’ for clarity.

5) We request that you treat each chapter as a new document from the
perspective of abbreviations and definitions of acronyms because some
readers will not be reading the entire document.

6) Page 2: footnote 1 – pls make separate footnotes for each document.

 

Clarify in the table name whether the numbers address ‘ozone only’
or ‘PM co-benefits only’ or ‘ozone and PM co-benefits’

For all PM tables, add a footnote indicating that these numbers are
incremental to  2006 PM NAAQS [this also needs to be added to the text
discussion]

For all PM tables, add a footnote as to whether these are assuming full
attainment of 0.084 and full attainment of 0.070 (or other std)

The footnotes are in lower case in the table and in upper case
underneath the tables. Pls be consistent.

Please adopt a convention for how many decimal places (one or none).  
Dropping decimals for total column is fine, as long as there is a
consistent rounding convention.

; also change the title to read morbidity and welfare (or just remove
the ‘worker productivity’ estimate from this table and talk about it
separately (or in its own separate table).   Also, add footnote
explaining why no confidence intervals are provided. 

Tables 5-19 an 5-20 are missing ‘units’

Table 5-2: has numbered and letter footnotes

Table 5-22: add several blank lines between each of the alternative
standards.

Table 5-21: last row 

I have added a fuller discussion of uncertainty at the end of the
chapter. Please let me know if this is more consistent with what you
were looking for.

We used a precursor-specific benefit per ton estimate and so did not
make this assumption.

I have added this discussion. 

Regarding welfare effects—please see e-mail from Bryan Hubbell dated
5/30. I have added new language describing how worker productivity was
estimated. 

I have attached a separate write-up, to be either an appendix or a TSD,
that describes this approach. Traditionally, we do not include the
rollback write-up in the benefits chapter because this is really an air
quality modeling technique. 

I have made these changes. 

Incorporated edits except where noted below

Numbers may not sum due to rounding to 2 sig figs.  

Incorporated edits except where noted below

See e-mail from Bryan Hubbell dated 5/30.

Did my best, but I can’t shrink the font much more before it becomes
completely illegible

