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

05/09/2008 04:14 PM

	

To

Ron Evans/RTP/USEPA/US@EPA

cc

Lydia Wegman/RTP/USEPA/US@EPA, Kathy Kaufman/RTP/USEPA/US@EPA, Tricia
Crabtree/RTP/USEPA/US@EPA, Neal Fann/RTP/USEPA/US@EPA, "Beck, Nancy"
<Nancy_Beck@omb.eop.gov>, "Lee, Amanda I." <Amanda_I._Lee@omb.eop.gov>

Subject

RE: status?









Hi Ron,

I apologize; I was waiting for language from you that would address most

of the line-by-line comments.  And while I was looking for solutions

from my end, I also understood that you were also looking for solutions

on your end.

Here's where I thought we are:

EPA Action Items: 

EPA Action Item #1:  EPA would edit/make consistent the characterization

of attainment.  Recall that cost chapters did not take the analysis to

full attainment in this draft, but other chapters represent the analysis

as "for purposes of this analysis, we assess attainment by 2020 for all

areas"; similar language appears in a few places.  (Note:  This should

be consistent with how we address the issue of addressing the difference

between estimates of benefits assuming roll-back of lead all the way to

attainment in all counties, and the estimates of costs only as far as

sources are identified, leaving some areas out of attainment in the cost

section, resulting in a mis-matching of costs and benes in cost-bene

section.)

EPA Action Item #2:  There were 2 or 3 lines that Neal was drafting for

insertion at the beginning of Exec Summ, Chap 1, (poss Chap 5 too), and

Chap 7.  The para should reinforce the characterization we've agreed to

in Chap 6 so that readers of Exec Summ, Intro, Bene's and Net Bene's

correctly interpret the results in the context of what was feasible and

why they might see changes in final draft (Chap 6 discussions were meant

to derive example language)  The 2 or 3 lines should characterize

analysis as :  1) illustrative estimates 2) draft analysis to be

advanced before final 3) analysis of only a subset of 36 counties in the

US 4) using capped cost-per-ton approach, but EPA intends to explore inc

marginal costs in final and 5) EPA intends to explore appropriate

baseline for 2020 blood lead levels in US, rather than 2002 blood lead

levels

Issues to be resolved

Issue #1: Addressing the difference between bene assessment of all

counties to attainment, with costs assessment only to feasible control

level.  Following the analysis you shared this week comparing roll-back

to control approaches, I need to get back to you on whether this

satisfies a-4 requirements that costs and benes are both assessed on the

same magnitude of change.  

It appears at this point that it is problematic to assume that

over-control in some areas where sources are identifiable would

appropriately compensate for other areas where attainment is not

achieved due to failure to identify sources.  I have not yet identified

a solution other than the one I proposed: listing the incremental air

qual improvement needed to attain each standard, and simply identify

costs as infinite (which is most consistent with my knowledge of Econ

Theory)

Does EPA have a suggestion?

Issue #2: Presentation of both Conc Resp functions

OMB Action Items

Here are the last edits:

-- (I believe there is discussion with one of my colleagues around an

edit on control technologies? )

-- Could we call out in a separate section the cost of deploying network

and monitoring in the RIA - I thought I had read estimates somewhere,

perhaps it was not in this document but in a draft ICR or Budget

document.  In any case, the estimated costs of monitoring network and

activities, including costs to States, should be included here, but I

don't recall where I had seen the numbers -- if they are there already,

maybe we could give them a para header.

-- Page number needed throughout (makes it difficult to describe these

suggested edits; thanks for your patience)

-- Exec Summ p 2 last sent of second para:  Confirming that CAA allows

EPA to postpone compliance for 20 years, even for Pb?  I thought Pb was

different.

-- p 6 of Exec Summ:  2 paras following Table ES1 seem to be more

helpful if they were before Table ES1

-- On attainment tables, pls add appropriate column or rows to identify

what is required to achieve full attainment with that standard (tons, or

as you showed me, incremental reduction in concentration required in

that county/monitor location)

-- Instead of "areas", could we say "counties" to make it clear that we

have not broken the entire US into 36 areas?

-- Please strike "and welfare" throughout .. there are several mentions

of "monetizing human health and welfare" benefits, for example, but the

term welfare in CAA context can be confusing, and I did not see

monetization of any but health benefits.  (If I missed an estimate of

welfare benefits in CAA context, pls correct me)

-- Chapt 7 p 10 last bullet on air:blood ratio for adults didn't make

any sense to us.  We could delete or discuss.

heidi

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

From: Evans.Ron@epamail.epa.gov [mailto:Evans.Ron@epamail.epa.gov] 

Sent: Friday, May 09, 2008 9:50 AM

To: King, Heidi R.

Cc: Wegman.Lydia@epamail.epa.gov; Kaufman.Kathy@epamail.epa.gov;

Crabtree.Tricia@epamail.epa.gov

Subject: status?

Good morning Heidi.

The .5 analysis is proceeding, we expect to see tables of results today.

We will incorporate them into the next round of chapters we send to you.

The RIA team is working on all the comments you have given us so far.

Did you ever get a chance to send the line edits which you referenced

the other day?  If so, I never got the e-mail or fax.

I have raised the issue of changing the CR and air:blood functions in

the proposal and final as opposed to just the final.   Lydia is talking

to Steve Page about it, I am not sure of the timing for the next step.

At this point, I am not sure if it makes sense to send you all the

revised chapters until this is resolved since changing the functions

will casaded thru chapters 5, 7 and the Ex Summ at a minimum.   However,

I am open to chatting about this.

Please let me know where things stand.  Thanks

Ron

