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

04/18/2008 02:57 PM

	

To

Lydia Wegman/RTP/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA, Nathalie
Simon/DC/USEPA/US@EPA, Charlotte Bertrand/DC/USEPA/US@EPA, Mike
Clark/DC/USEPA/US@EPA

cc

"Fraas, Arthur G." <Arthur_G._Fraas@omb.eop.gov>, "Beck, Nancy"
<Nancy_Beck@omb.eop.gov>, "Skidmore, Charlotte T."
<Charlotte_T._Skidmore@omb.eop.gov>, "Fishpaw, Marie K."
<Marie_K._Fishpaw@ovp.eop.gov>, "Rodan, Bruce D."
<Bruce_D._Rodan@ostp.eop.gov>, "Griffiths, Charles W."
<Charles_W._Griffiths@cea.eop.gov>, <Daniel.Cohen@hq.doe.gov>,
<David.R.Hill@hq.doe.gov>, <GC-71energyregs@hq.doe.gov>,
<Cruz.Ubay@HQ.DOE.GOV>, "Grahame, Thomas" <Thomas.Grahame@HQ.DOE.GOV>,
"Daniels, Jarad" <Jarad.Daniels@hq.doe.gov>,
<salo.zelermyer@hq.doe.gov>, <Indur_Goklany@ios.doi.gov>,
<Burleson.Smith@usda.gov>, "Baer, Mitchell" <Mitchell.Baer@hq.doe.gov>,
"Serebrov, Job" <Job.Serebrov@OGC.USDA.GOV>, "Heavner, Ron - Washington,
DC" <Ron.Heavner@wdc.usda.gov>, "Holman, Keith W."
<Keith.Holman@sba.gov>, "Mestey, Felix CIV \(NAVFACHQ\)"
<felix.mestey@navy.mil>, "Newton, Drek CIV NFESC"
<drek.newton@navy.mil>, <Cecilia.Ho@dot.gov>,
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<tsinks@cdc.gov>, "Ashley, Kevin E. \(CDC/NIOSH/DART\)" <kea0@cdc.gov>,
"Whalen, Mary Kate" <MaryKate.Whalen@dhs.gov>, "Stein, Lesley"
<Lesley.Stein@dhs.gov>, <michele.laur@wdc.usda.gov>, "Lee, Amanda I."
<Amanda_I._Lee@omb.eop.gov>

Subject

First pass: Pb NAAQS draft RIA questions & comments









Lydia, Ron et al,

 

Below are the first round of questions from the interagency reviewers of
the Pb NAAQS Proposal RIA.  Please let me know if there is need for
clarification, and we look forward to following up on Monday.

 

Best regards,

 

heidi

 

 

Costs

 

The draft RIA under interagency review shows that attainment will not be
achievable for all areas for all proposed alternatives using known
technologies.  This suggests that States might be exploring  alternative
implementation measures other than those categorized as “known” to
EPA, but also to sources not included in the analysis.

 

1.  How recently has NEI been validated to be an accurate reflection of
source contribution?  That is, how certain are we that these “known”
sources in fact are contributing to this magnitude and may be
controllable, so that other more costly controls (dust, Gen aviation)
will not be as likely to be required?

 

2.  Several commenters would like fuller discussion on the subject of
pre-existing lead in dust.  During the conference call on the RIA costs
chapters last week, there was mention of an assessment of re-entrained
highway dust.  Is there a draft or final document?  How else can we
learn more about this work and its conclusions, such as  a) How much is
there (it’s not in NEI, is it?) b) What technologies will be used to
reach attainment with respect to lead in dust c) How much will it cost? 


 

3.  Similar to question #1 for general aviation gas and potential
implementation measures that States might adopt for attainment

 

4.  Slide 18 in the  RIA Cost presentation last week, appears to say
that whatever the level of controls, the vast majority of control costs
are for control methods and technologies not yet identified, roughly 90%
at the low end to 95% at the high end.  

- Is this interpreted correctly?

- Do we know of other EPA regulations where this high a percentage of
the costs of control was unknown because the control technologies were
unknown?

 

Benefits

 

5.     The cost analysis represents 2020; do benefits estimates
similarly reflect a baseline that takes into account continued decline
of blood lead levels through 2020 associated with continued decline in
exposure due to retired housing, Federal and Local policy interventions,
etc?

 

6.     Air-to-blood ratios – The rule seems to be relying on a study
of a teenage population (Lanphear, 2000) with a ratio of 1:5, but the
RIA is quantifying benefits to a younger population using the same
ratio.  Shouldn't the ratio be different, given the importance of
hand-mouth behavior as an exposure route?  See attached public comment 
(EPA - we might address this comment in the ratio follow up conversation
that we agreed upon)

 

7.     Valuation of IQ points – Were other studies were considered and
*not* used to support alternative valuations?

 

8.     Concentration/Response function:  Why not assess the alternative
cutpoint@10 in the Lanphear model, as used in Pb R&R rule?  We’ve
agreed to follow up conversation

 

9. Results provided at 3% should be accompanied by analogous numbers at
7% 

 

10. PM results based on Laden et al should not be carried through to the
executive summary or any communication materials

 

11. Can we include a relevant version of the graphic used for the ozone
rule which showed PM co-benefits relative to the primary benefits
(vertical bars, as I recall)

 

