"King, Heidi R." <Heidi_R._King@omb.eop.gov> 

04/07/2008 05:48 PM

	

To

Lydia Wegman/RTP/USEPA/US@EPA, Kathy Kaufman/RTP/USEPA/US@EPA

cc

Ron Evans/RTP/USEPA/US@EPA, "Beck, Nancy" <Nancy_Beck@omb.eop.gov>

Subject

Pb NAAQS RIA follow up questions









Good afternoon, Pb NAAQS RIA team,

 

Thank you for briefing OMB last week on your approach to completing the
Regulatory Impact Analysis under EO 12866 for the Pb NAAQS proposed
rule.  Below are my follow up questions, which we might begin to address
through email (sharing references, for example) and perhaps in a brief
follow up meeting.  My apologies for failing to get these questions to
you by this morning, as promised!

 

Thanks, and best regards,

 

heidi

 

 

For both Costs and Benefits Analysis:

 

1.	Confirm baseline (which MACTs are in the baseline?)

Benefits Analysis questions: 

 

2.	Where can I get further information on methods for 

a.	Buffer concentrations

b.	VNA interpolation

3.	Which peer-reviewed studies support Air-to-blood ratios among adults?

4.	Could you provide references for peer-reviewed studies used to
support quantification of adult health effects:

a.	Relationship of Pb and Hypertension, including both endpoint and
sequelae – including clarification of direction of causality, and
which are endpoints vs which are risk factors (hypertension is a CV risk
factor; are we quantifying HT as an endpoint, and if so, based on what? 
Risk reduction?)

b.	Link from BP to Chronic Heart Disease, Stroke and Premature Mortality

c.	Which studies were considered and *not* used for quantifying these
relationships?

5.	Valuations – both methodology and studies supporting values used

a.	What studies were considered and *not* used to support alternative
valuations?

Cost Analysis questions:

 

6.	Please clarify time period for analysis, why that time period was
selected over alternatives, key assumptions in the analysis, scope of
cost estimates (engineering/control only?)

7.	Please clarify “unidentified controls” (unidentified sources vs
unknown control methods vs other)

8.	To assess costs to achieve attainment for each alternative NAAQS
standard, does EPA intend to use an extrapolated cost approach?  Other?

9.	We discussed labels etc on the tables to make sure they clearly
communicate which standard is repres

