Lydia Wegman/RTP/USEPA/US 

06/17/2008 06:07 PM

	

To

afraas@omb.eop.gov, hking@omb.eop.gov

cc

Ron Evans/RTP/USEPA/US@EPA, kaufman.kathy@epa.gov, Neal
Fann/RTP/USEPA/US@EPA, Charles Fulcher/RTP/USEPA/US@EPA, Darryl
Weatherhead/RTP/USEPA/US@EPA, Tom Walton/RTP/USEPA/US@EPA, Tricia
Crabtree/RTP/USEPA/US@EPA, wegman.lydia@epa.gov

Subject

Re: Fw: Draft draft note to Art's fax on Pb NAAQS RIA.









Art and Heidi,

Thanks for your comments on the Pb RIA.  Here are our responses to the
comments you faxed to us:

--We will eliminate the net benefits calculations throughout the
document.

--We will incorporate your specific edits to the Executive Summary,
including deletion of the table summarizing costs and benefits, with two
very minor exceptions.

	For clarity for the reader, we are keeping the headers that appear
to have been deleted in the list of uncertainties (“Air Quality Data,
Modeling and Emissions”, “Costs”, and “Benefits.”)

	We would like to retain the following parenthetical to the third
bullet in Section 4 of the Executive Summary, which provides the reader
with important information:

EPA received a petition from Friends of the Earth requesting that the
Agency find that aircraft lead emissions may reasonably be anticipated
to endanger the public health or welfare, and to take action to control
lead emissions from piston-engine aircraft.  EPA, in coordination with
FAA, is analyzing the petition.

--We are fine with citing the use of 2002 blood lead levels as one of
several inconsistencies, and saying that those inconsistencies, taken
together, were the reason for not directly comparing costs and benefits.
 We propose adding the following paragraph, adapted from the first page
of Chapter 5 (benefits) to the Executive Summary and Chapter 7:

In addition, this RIA seeks to estimate both costs and benefits for the
year 2020; however this draft represents initial estimates using a 2002
baseline blood lead level, resulting in a possible overestimate of
benefits in the year 2020.  Prior to completion of the final RIA, EPA
will investigate updating the baseline to reflect expected effects on
blood lead levels of other rules that may reduce emissions of lead, to
the extent technically feasible.

In addition, here is our proposed language, starting from the material
in your fax, addressing the decision not to provide net benefits
calculations:

As a result of some of the methodological considerations and
uncertainties outlined above, this proposed RIA does not present a
comparison of the estimated benefits and costs, or a net benefits
calculation associated with each of the standard level alternatives
under consideration.  EPA has activities underway to make improvements
to both cost and benefit calculations  for the final RIA, recognizing
that there will remain
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--In the second line in the opening paragraph of the Executive Summary,
we would insert your language to address your concern about identifying
the uncertainties in this analysis in the beginning of the ES:   "There
are important overall data limitations and uncertainties in these
estimates.  These limitations and uncertainties are described in detail
in section ES 4, below." 

We hope these changes address all of your concerns.  Please let us know.


Lydia

