"Johansson, Robert" <Robert_C._Johansson@omb.eop.gov> 

10/18/2007 04:30 PM

	

To

Ron Evans/RTP/USEPA/US@EPA, Jim DeMocker/DC/USEPA/US@EPA

cc

Subject

FW: Jim DeMocker's response to your question about 812









Hi Ron and Jim,

Thanks for getting back to me.  I had a couple thoughts/questions on

your responses especially after re-reading the Section 812 amendments to

the CAA, SAB's charge, and SAB's responses:

(1)  Do you consider an RIA to be a "scientifically reviewed study"?

(2)  Did the charge questions to SAB March 15th council refer to the 812

report Second Propective Study or to individual RIA's?

(3)  Because RIA's and section 812 reports have different guidelines and

may use different methods/data, please comment on the relevance of SAB's

responses to the methods used in the Second Prospective Study to methods

used in independent ongoing and future RIA's.

(4)  Was the SAB asked to comment on the merits of using multiple

methods to estimate costs of unknown controls vs. the merits of the

methods independently?

(5)  From SAB letter on the 812 report Second Propective Study,

"Emission reductions attributed to unidentified measures appear to

account for a large share of emission reductions required for a few

lasrge metropolitan areas but a relatively small share of emission

reductions in other locations and nationwide..."  (page 6). This

statement seems based on the current naaqs std and not the proposed

stds.  Do you agree with this interpretation?

(6)  Reading further (on page 6), SAB does acknowledge the possibility,

in the 812 report Second Propective Study, of there being some value to

assigning costs to unidentified measures, however SAB suggests taking

great care in reporting these costs.  SAB also acknowledges the

possibility, in the 812 report Second Propective Study, in some cases it

may be preferable to quantify these costs rather than to just report the

quantity and share of emissions reductions attributed to these measures.

In fact, section 812 states "The Administrator shall consider the

effects of such a standard on employment, productivity, cost of living,

economic growth, and the overall economy of the United States." Both of

these point to there being a value at portraying "all" costs of a

standard. Do you agree with this interpretation?

(7)  SAB does acknowledge the possibility, in the 812 report Second

Propective Study, that if costs are assigned to unidentified measures, a

simple transparent method that is sensitive to the degree of uncertainty

about these costs is best.  Do you agree with this interpretation?

(8)  Of the individual approaches presented (i.e., SAB was not asked the

merits to using more than one method), SAB does acknowledge the

possibility, in the 812 report Second Propective Study that the fixed

cost/ton appears to be the most straightforward.  However, they did not

say that the other methods were not simple or transparent. Do you agree

with this interpretation?

(9) SAB does acknowledge the possibility, in the 812 report Second

Propective Study, that uncertainty might be represented using

alternative fixed costs per ton of emissions avoided, but they

implicitly acknowledge that uncertainty might be represented using other

methods.  Do you agree with this interpretation?

Cheers,

Rob 

