Ron Evans/RTP/USEPA/US

04/30/2008 05:30 PM

	

To

"Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov>

cc

"King, Heidi R." <Heidi_R._King@omb.eop.gov>, Kathy
Kaufman/RTP/USEPA/US@EPA, Tricia Crabtree/RTP/USEPA/US@EPA, Lydia
Wegman, fann.neal@epa.gov, darryl weatherhead, walton.tom@epa.gov,
Tricia Crabtree/RTP/USEPA/US@EPA

Subject

RE: Updated lead benefits chapter--exec summary









Amanda, I got your e-mail.   I see 3 changes as outlined below.   I am
enclosing my initial response, what I am trying to do is find a middle
ground in some places to give some more flexibility for the final.  The
bold is my suggestion for replacement language, I am certianly open to
edits if we can agree in concept.

page 1

For the RIA to be issued with the final rulemaking, the agency will also
examine other alternative standards, including a standard of 0.50
ìg/m3.  

I would prefer to not prejudge the exact other standard to be 0.50
micrograms/m3.   However I am willing to commit to following the
guidelines of A-4 and indicate that the final RIA will analyze at least
one more stringent and one less stringent alternative than the selected
standard.   Will this construct work? 

 For the RIA to be issued with the final rulemaking, the agency will
examine will analyze at least one more stringent and one less stringent
alternative than the selected standard consistent with the OMB A-4
Guidelines.

page 2

This RIA is intended to inform the public about the potential costs and
benefits associated with a hypothetical scenario that may result when a
new lead standard is implemented, but is not relevant to establishing
the standards themselves.  

OK

page 2

This analysis is preliminary and only attempts to assess a hypothetical
scenario.  In addition  to the data limitations discussed earlier in
this summary, the methods limitations affect the usefulness of this
analysis.  For the RIA to be issued with the final rulemaking, the
agency will be refining the analysis presented in this RIA and
undertaking additional analyses, including cost assessments not limited
to a constant dollar-per-ton for unidentified sources,
cost-effectiveness analysis and uncertainty analysis.   

I can not commit to doing a cost-effectiveness analysis for the Pb
endpoints, I don't have a methodology available.   I am willing to
consider doing one but I can not commit to it happening.   I am not sure
what you mean by uncertainty analysis.   I can do sensitivity analyses
(similar to some of those already in this draft of the RIA) on portions
of the benefits and costs analyses but a formal uncertainty analysis
which would combine several of the elements is probably not feasible.  
My final point is more of a quibble, I am willing to attempt multiple
approaches to estimating costs, but I would prefer not to refer to our
existing approach as a constant dolllar-per-ton for unidentified
sources, that is not quite right.

This analysis is preliminary and only attempts to assess a hypothetical
scenario.  In addition to the data limitations discussed earlier in this
summary, the methods limitations affect the usefulness of this analysis.
 For the RIA to be issued with the final rulemaking, the agency will be
refining the analysis presented in this RIA and undertaking additional
analyses, including multiple approaches to estimating the cost of needed
reductions when the sources are not clearly identified.   While the
final RIA will not specifically quantify effects of changing the ambient
air Pb on adults, it will contain suggestions on where additional
information and data would be useful to help characterize the adult
benefits for the next 5 year review.   EPA will also investigate doing a
cost-effectiveness analysis and more formal uncertainty analysis as part
of the final RIA.

Ron Evans

Leader, Air Benefit & Cost Group

HEID/OAQPS/OAR/EPA

Mail Drop C-439-02

919-541-5488

919-541-0839 fax

"Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov> 

04/30/2008 04:47 PM

	

To

"King, Heidi R." <Heidi_R._King@omb.eop.gov>, Kathy
Kaufman/RTP/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA

cc

Subject

RE: Updated lead benefits chapter--exec summary









Please see for suggested edits.  More to come.  If you want to discuss,

please call (202-395-5129).  Thanks, Amanda

-----Original Message-----

From: King, Heidi R. 

Sent: Wednesday, April 30, 2008 4:11 PM

To: 'Kaufman.Kathy@epamail.epa.gov'; 'Evans.Ron@epamail.epa.gov'

Cc: Lee, Amanda I.

Subject: FW: Updated lead benefits chapter

Ron and Kathy, 

Thanks !!  Amanda is also working to get us across the finish line; I

copy her on this email.

h

-----Original Message-----

From: Kaufman.Kathy@epamail.epa.gov

[mailto:Kaufman.Kathy@epamail.epa.gov]

Sent: Wednesday, April 30, 2008 4:06 PM

To: King, Heidi R.

Cc: Evans.Ron@epamail.epa.gov; Fann.Neal@epamail.epa.gov;

Weatherhead.Darryl@epamail.epa.gov; Walton.Tom@epamail.epa.gov;

Wegman.Lydia@epamail.epa.gov

Subject: Fw: Updated lead benefits chapter

Heidi -- attached are new versions of chapters 1 through  7, plus the

executive summary, of the Pb RIA.  Changes in response to your comments

and the interagency comments you compiled are highlighted or colored in

blue or red.

In terms of the assembled interagency comments from yesterday -- we've

made changes in response to as many as we could. Some seem to be

clarification questions that don't necessarily require changes to the

document, and we can talk through those with you tomorrow.

WeI've also attached the Schwartz 1994 article used to estimate the $/IQ

as well as a CDC report for which a commenter indicated that they

couldn't find a particular page.

Note this is also being sent formally through OPEI; in the interest of

time we are transmitting it informally directly to you.

Thanks!

-- Kathy

(See attached file: Schwartz1994.pdf)(See attached file:

PrevLeadPoisoning.pdf)(See attached file: Ch 5 Benefits Analysis

Approach and Results 4-30-08.doc)(See attached file: Pb RIA Exec Summ

Draft 4-29-08.doc)(See attached file: Pb RIA Chapter 1 draft

4-29-08.doc)

(See attached file: Pb RIA Chapter 2 Draft 4-29-08.doc)(See attached

file: Pb RIA Chapter 3 Draft 4-29-08.doc)(See attached file: Pb RIA

Chapter 4 Draft 4-29-08.doc)(See attached file: Pb RIA Chapter 6 Draft

4-29-08.doc)(See attached file: Pb RIA Chapter 7 Draft 4-29-08.doc)

Kathy Kaufman

EPA/OAQPS Mail Code C539-03

Research Triangle Park, NC 27711

Phone 919 541 0102

Fax  919 541 5489

[attachment "Pb RIA Exec Summ Draft 4-29-08 (2).doc" deleted by Ron
Evans/RTP/USEPA/US] 

