August 31, 2018
MEMORANDUM
TO:	Docket for rulemaking, "Regulatory Impact Analysis for the Proposed Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units; Revisions to Emission Guideline Implementing Regulations; Revisions to New Source Review Program" (EPA-HQ-OAR-2017-0355)
SUBJECT:	No CPP Alternative Baseline Results Tables for the Regulatory Impact Analysis for the ACE (Affordable Clean Energy) Rule

      The Agency understands the public may be interested in comparing the estimated benefits and costs of the three illustrative policy scenarios against an alternative baseline that does not include the Clean Power Plan (CPP). In the interest of transparency, we report the estimated impacts of each Affordable Clean Energy (ACE) rule policy scenario compared to a baseline in which the CPP does not exist; we term this the No CPP alternative baseline. Presenting an alternative baseline is consistent with Circular A-4, which states, "When more than one baseline is reasonable and the choice of baseline will significantly affect estimated benefits and costs, you should consider measuring benefits and costs against alternative baselines"  We present portions of this analysis in the Executive Summary to the Regulatory Impact Analysis conducted for the ACE rule proposal.  This memo builds upon that discussion by providing the same tables appearing in the Executive Summary and a few additional results tables that may be of interest to readers.
      EPA estimates the avoided costs under the three illustrative scenarios relative to the No CPP alternative baseline as shown in Table 1.
      
Table 1. Compliance Costs, Relative to No CPP Alternative Baseline (billions of 2016$)
 
                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
                                     2025
                                      0.7
                                      0.1
                                      1.3
                                     2030
                                      0.5
                                     (0.2)
                                      0.9
                                     2035
                                      0.5
                                     (0.2)
                                      0.8
Notes: Negative costs indicate that, on net, the illustrative scenario reduces costs relative to the No CPP alternative baseline. Compliance costs equal the projected change in total power sector generating costs, plus the costs of monitoring, reporting, and recordkeeping.
	
      Table 2 shows the projected CO2 emissions impacts of each scenario, relative to the No CPP alternative baseline.
Table 2. Projected CO2 Emission Impacts, Relative to No CPP Alternative Baseline
 
                                 CO2 Emissions
                                (MM Short Tons)
                     CO2 Emissions Change (MM Short Tons)
                      CO2 Emissions Change Percent Change
 
                                     2025
                                     2030
                                     2035
                                     2025
                                     2030
                                     2035
                                     2025
                                     2030
                                     2035
                                                    No CPP Alternative Baseline
                                     1,829
                                     1,811
                                     1,794
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                                               2% HRI at $50/kW
                                     1,816
                                     1,798
                                     1,783
                                      -13
                                      -13
                                      -11
                                      -1%
                                      -1%
                                      -1%
                                                             4.5% HRI at $50/kW
                                     1,812
                                     1,797
                                     1,787
                                      -18
                                      -14
                                      -7
                                      -1%
                                      -1%
                                      0%
                                                            4.5% HRI at $100/kW
                                     1,799
                                     1,785
                                     1,772
                                      -30
                                      -27
                                      -22
                                      -2%
                                      -1%
                                      -1%

      Table 3 shows projected emission changes of NOx and SOx, as well as CO2, relative to the No CPP alternative baseline. Table 4, Table 5 and Table 6 report the estimated number of avoided PM2.5 and ozone-related premature deaths and illnesses for the years 2025, 2030 and 2035, as compared to the No-CPP alternative baseline. We also report the estimated number of PM2.5-related premature deaths according to alternative concentration cut-points (Table 7).
       The magnitude and direction of the projected change in SO2 and NOx differ across the scenarios and years. For example, we project SO2 emissions to decrease for the 4.5% HRI Scenario at $100/kW across each of three years, but to increase in the year 2025 for the 4.5% HRI Scenario at $50/kW.  We project SO2 emissions to remain unchanged in 2025 for the 2% HRI Scenario at $50/kW. By contrast, we project that under each of the three policy scenarios in all projection years, NOx emissions will decrease by varying degrees. This variability in the levels of SO2 and NOx emissions in turn affects both the modeled change in PM2.5 and ozone and the estimated PM2.5 and ozone-attributable health benefits.  Depending on the emissions change (increase or decrease) projected, and the geographic location of the change, both the size and the distribution of downstream air quality changes will be impacted. Since the downstream populations affected by these air quality changes have different age structures and different underlying rates of morbidity and mortality, the resulting impacts on benefits estimates -- including estimated incidence of specific health endpoints as well as the total magnitude of the benefits -- can vary among the scenarios even with relatively small changes in emissions. This helps explain certain results that some readers may find counterintuitive. For example:
 For some scenarios and some years, we estimated an increase in the number of premature death and illness ("excess" cases), as shown by negative numbers in the avoided incidence tables. For example, the 2035 4.5% HRI scenario at $50/kW yields small PM2.5 and ozone disbenefits. While this scenario reduces NOx and SO2 on net by a small margin, increases in some locations yielded a modest disbenefit overall. 
 Differences in the spatial distribution of air quality impacts can yield excess cases of some health impacts (e.g. acute bronchitis) while there are avoided cases of others (e.g. cardiovascular hospital admissions). Such directional differences in effects may be explained by the spatial distribution of the baseline health status and age of the population affected by the change in pollution.
    
Finally, the overall change in emissions across the projected years and among the policy scenarios is relatively small. For this reason, the readers should interpret differences in estimated benefits among the scenarios with caution. 
       

Table 3. Projected CO2, SO2, and NOx Electricity Sector Emission Changes, Relative to the No CPP Alternative Baseline (2025-2035)
 
                                       
                                      CO2
                             (million short tons)
                                      SO2
                             (thousand short tons)
                                      NOX
                             (thousand short tons)

Base Case (CPP)
 
 
2025
                                       
                                      -50
                                      -36
                                      -32
2030
                                       
                                      -74
                                      -60
                                      -47
2035
                                       
                                      -66
                                      -44
                                      -43

2% HRI Scenario at $50/kW
2025
                                       
                                      -13
                                       0
                                      -8
2030
                                       
                                      -13
                                      -7
                                      -8
2035
                                       
                                      -11
                                      -11
                                      -5

4.5% HRI Scenario at $50/kW
 
2025
                                       
                                      -18
                                       4
                                      -11
2030
                                       
                                      -14
                                      -7
                                      -8
2035
                                       
                                      -7
                                      -1
                                      -1

4.5% HRI Scenario at $100/kW
 
2025
                                       
                                      -30
                                      -3
                                      -18
2030
                                       
                                      -27
                                      -15
                                      -15
2035
                                       
                                      -22
                                      -16
                                      -11
Source: Integrated Planning Model, 2018. 




Table 4. Estimated Number of Avoided PM2.5 and Ozone-Related Premature Deaths and Illnesses in 2025, Relative to the No CPP Alternative Baseline


                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Avoided premature death among adults
  PM2.5
Krewski et al. (2009)
                                 22
(15 to 29)
                                  5
(3 to 6)
                                 58
(39 to 76)
  
Lepeule et al. (2012)
                                 50
(25 to 75)
                                 11
(5 to 16)
                                130
(65 to 200)
  Ozone
Smith et al. (2009) 
                                  6
(3 to 9)
                                 15
(8 to 23)
                                 13
(6 to 20)
  
Jerrett et al. (2009)
                                 21
(7 to 35)
                                 57
(19 to 94)
                                 47
(16 to 79)
Non-fatal heart attacks among adults 
 Peters et al. (2001)
                                 24
(6 to 41)
                                  2
(1 to 4)
                                59
(14 to 100)
 Pooled estimate
                                  3
(1 to 7)
                                  0
(0 to 1)
                                  6
(2 to 17)
All other morbidity effects
  Hospital admissions -- cardiovascular (PM2.5)
                                  6
(3 to 11)
                                  1
(0 to 1)
                                 15
(6 to 27)
  Hospital admissions -- respiratory (PM2.5 & O3)
                                 15
(0 to 31)
                                 27
(-6 to 61)
                                 35
(2 to 72)
 ED visits for asthma 
  (PM2.5 & O3)
                                 41
(0 to 110)
                                 86
(8 to 250)
                                100
(54 to 220)
  Exacerbated asthma 
  (PM2.5 & O3)
                           11,000
(-9,400 to 27,000)
                          33,000
(-28,000 to 80,000)
                           26,000
(3,400 to 38,000)
  Minor restricted-activity days (PM2.5 & O3)
                           37,000
(20,000 to 54,000)
                          68,000
(28,000 to 110,000)
                          90,000
(50,000 to 130,000)
 Acute bronchitis 
 (PM2.5)
                                 21
(-5 to 46)
                                 -5
(1 to -12)
                                60
(-14 to 130)
  Upper resp. symptoms (PM2.5)
                                380
(68 to 680)
                               -92
(-17 to -170)
                             1,100
(200 to 2,000)
  Lower resp. symptoms 
  (PM2.5)
                               260
(100 to 430)
                               -66
(-25 to -110)
                              770
(290 to 1,200)
 Lost work days 
  (PM2.5)
                            2,000
(1,700 to 2,300)
                              -130
(-110 to -150)
                            5,700
(4,800 to 6,500)
 School absence days 
  (O3)
                            8,000
(2,800 to 18,000)
                           24,000
(8,600 to 54,000)
                           18,000
(17,000 to 30,000)

Table 5. Estimated Number of Avoided PM2.5 and Ozone-Related Premature Deaths and Illnesses in 2030, Relative to the No CPP Alternative Baseline


                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Avoided premature death among adults
  PM2.5
Krewski et al. (2009)
                                 60
(40 to 79)
                                 59
(40 to 78)
                                120
(82 to 160)
  
Lepeule et al. (2012)
                                140
(68 to 200)
                                130
(67 to 200)
                               280
(140 to 410)
  Ozone
Smith et al. (2009) 
                                      -14
                                  (-7 to -22)
                                  7
(4 to 11)
                                 12
(6 to 18)
  
Jerrett et al. (2009)
                                      -53
                                 (-18 to -87)
                                 26
(9 to 44)
                                 43
(14 to 71)
Avoided non-fatal heart attacks among adults 
 Peters et al. (2001)
                                63
(15 to 110)
                                60
(15 to 110)
                                130
(31 to 220)
 Pooled estimate
                                  7
(3 to 18)
                                  7
(2 to 17)
                                 14
(5 to 37)
All other avoided morbidity effects
  Hospital admissions -- cardiovascular (PM2.5)
                                 16
(7 to 29)
                                 15
(6 to 28)
                                 32
(14 to 59)
  Hospital admissions -- respiratory (PM2.5 & O3)
                                 15
(0 to 31)
                                 27
(-6 to 61)
                                 35
(2 to 72)
 ED visits for asthma 
  (PM2.5 & O3)
                                 41
(0 to 110)
                                86
(8.1 to 250)
                                100
(54 to 220)
  Exacerbated asthma 
  (PM2.5 & O3)
                           11,000
(-9,400 to 27,000)
                          33,000
(-28,000 to 80,000)
                           26,000
(3,400 to 38,000)
  Minor restricted-activity days (PM2.5 & O3)
                           37,000
(20,000 to 54,000)
                          68,000
(28,000 to 110,000)
                          90,000
(50,000 to 130,000)
 Acute bronchitis 
 (PM2.5)
                                71
(-17 to 160)
                                70
(-17 to 160)
                               150
(-34 to 330)
  Upper resp. symptoms (PM2.5)
                             1,300
(-240 to 2,400)
                             1,300
(230 to 2,300)
                             2,700
(480 to 4,800)
  Lower resp. symptoms 
  (PM2.5)
                              910
(350 to 1,500)
                              900
(340 to 1,500)
                             1,900
(710 to 3,000)
 Lost work days 
  (PM2.5)
                            6,000
(5,100 to 6,900)
                            5,800
(4,900 to 6,700)
                           12,000
(10,000 to 14,000)
 School absence days 
  (O3)
                                    -29,000
                              (-10,00 to -64,000)
                           10,000
(3,600 to 23,000)
                           16,000
(5,700 to 36,000)










Table 6. Estimated Number of Avoided PM2.5 and Ozone-Related Premature Deaths and Illnesses in 2035, Relative to the No CPP Alternative Baseline


                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Avoided premature death among adults
  PM2.5
Krewski et al. (2009)
                                80
(54 to 110)
                               -18
(-12 to -23)
                                120
(79 to 150)
  
Lepeule et al. (2012)
                                180
(90 to 270)
                               -60
(-20 to -60)
                               260
(130 to 400)
  Ozone
Smith et al. (2009) 
                                  1
(1 to 2)
                               -3.3
(-2 to -4.9)
                                  7
(3 to 10)
  
Jerrett et al. (2009)
                                  4
(1 to 6)
                                -12
(-4 to -20)
                                 23
(8 to 39)
Avoided non-fatal heart attacks among adults 
 Peters et al. (2001)
                                81
(20 to 140)
                                -21
(-5 to -37)
                                120
(30 to 210)
 Pooled estimate
                                  9
(3 to 23)
                                 -2
(-1 to -6)
                                 13
(5 to 35)
All other avoided morbidity effects
  Hospital admissions -- cardiovascular (PM2.5)
                                 20
(9 to 38)
                                -6
(-2 to -11)
                                 30
(13 to 57)
  Hospital admissions -- respiratory (PM2.5 & O3)
                                 22
(8 to 42)
                                -11
(-1 to -23)
                                 42
(10 to 83)
 ED visits for asthma 
  (PM2.5 & O3)
                                 42
(-4 to 93)
                                -25
(1 to -66)
                                86
(-16 to 210)
  Exacerbated asthma 
  (PM2.5 & O3)
                           4,300
(-2,100 to 10,000)
                           -4,400
(3,600 to -11,000)
                          15,000
(-11,000 to 37,000)
  Minor restricted-activity days (PM2.5 & O3)
                           53,000
(41,000 to 64,000)
                          -17,000
(-9,600 to -25,000)
                          95,000
(67,000 to 120,000)
 Acute bronchitis 
 (PM2.5)
                                98
(-23 to 220)
                                 -8
(2 to -19)
                               140
(-33 to 310)
  Upper resp. symptoms (PM2.5)
                             1,800
(320 to 3,200)
                              -150
(-28 to -280)
                             2,500
(460 to 4,600)
  Lower resp. symptoms 
  (PM2.5)
                             1,200
(470 to 2,000)
                              -110
(-40 to -170)
                             1,800
(670 to 2,900)
 Lost work days 
  (PM2.5)
                            8,200
(7,000 to 9,500)
                            -1,100
(-920 to -1,300)
                           12,000
(9,900 to 13,000)
 School absence days 
  (O3)
                             1,700
(590 to 3,700)
                           -3,10
(-1,100 to -6,900)
                            9,200
(3,300 to 21,000)


Table 7. Estimated Number of Avoided PM2.5-Related Deaths According to Alternative Concentration Cut-points, Relative to the No CPP Alternative Baseline


2% HRI at $50/kW
4.5% HRI at $50/kW
4.5% HRI at $100/kW
2025



Log-Linear no-threshold model
Krewski et al. (2009) 
                                 22
(15 to 29)
                                  5
(3 to 6)
                                 58
(39 to 76)
Lepeule et al. (2012) 
                                 50
(25 to 75)
                                 11
(5 to 16)
                                130
(65 to 200)
Assuming PM effects below the LML of each study fall to zero
 Krewski et al. (2009) 
(LML= 5.8 ug/m[3])
                                 19
(13 to 25)
                                  3
(2 to 3)
                                 48
(3 to 63)
 Lepeule et al. (2012) 
(LML=8ug/m[3])
                                  8
(4 to 12)
                                -12
(-6 to -18)
                                 20
(10 to 31)
2030



Log-Linear no-threshold model
Krewski et al. (2009) 
                                 60
(40 to 79)
                                 59
(40 to 78)
                                120
(82 to 160)
Lepeule et al. (2012) 
                                140
(68 to 200)
                                130
(67 to 200)
                               280
(140 to 410)
Assuming PM effects below the LML of each study fall to zero
 Krewski et al. (2009) 
(LML= 5.8 ug/m[3])
                                 52
(35 to 69)
                                 53
(36 to 70)
                                110
(72 to 140)
 Lepeule et al. (2012) 
(LML=8ug/m[3])
                                 35
(17 to 52)
                                 33
(16 to 49)
                                71
(36 to 110)
2035



Log-Linear no-threshold model
Krewski et al. (2009) 
                                80
(54 to 110)
                               -18
(-12 to -23)
                                120
(79 to 150)
Lepeule et al. (2012) 
                                180
(90 to 270)
                               -40
(-20 to -59)
                               260
(130 to 400)
Assuming PM effects below the LML of each study fall to zero
 Krewski et al. (2009) 
(LML= 5.8 ug/m[3])
                                 69
(46 to 91)
                                -11
(-8 to -15)
                                100
(68 to 130)
 Lepeule et al. (2012) 
 (LML=8ug/m[3])
                                 52
(26 to 78)
                                  5
(2 to 7)
                                71
(35 to 110)


      The size of the monetized benefits range from hundreds of millions to billions of dollars, depending on the analytical year and the assumption one makes regarding the relationship between PM2.5 exposure and the risk of premature death (Table 8, Table 9, Table 10).
Table 8. Estimated Economic Value of Avoided PM2.5 and Ozone-Attributable Deaths and Illnesses for Illustrative Scenarios & Three Alternative Approaches to Quantifying PM Effects in 2025, Relative to the No CPP Alternative Baseline (95% Confidence Interval; Billions of 2016$)[A]
                                       
                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Ozone benefits summed with PM benefits using three approaches: 
                                3% Discount Rate
                                        
No-threshold model[B]
                             $0.28
($.03 to $0.76)
                                      to
                             $0.71
($.06 to $2.00)
                             $0.14
($.01 to $0.38)
                                      to
                             $0.41
($.03 to $1.20)
                             $0.70
($.13 to $1.90)
                                      to
                             $1.80
($.36 to $4.90)
 
Effects above LML[C]
                            $0.25
(-$.11 to $0.68)
                                      to
                            $0.30
(-$.05 to $0.89)
                            $0.11
(-$.13 to $0.32)
                                      to
                            $0.19
(-$.06 to $0.59)
                            $0.61
(-$.02 to $1.60)
                                      to
                             $0.71
($.20 to $1.90
                                       
 
Effects above NAAQS[D]
                             $0.07
($.01 to $0.18)
                                      to
                             $0.22
($.02 to $0.67)
                             $0.09
($.01 to $0.25)
                                      to
                             $0.31
($.03 to $0.92)
                             $0.15
($.07 to $0.35)
                                      to
                             $0.50
($.25 to $1.30)
Ozone benefits summed with PM benefits using three approaches: 
                               7% Discount Rate 
No-threshold model[B]
                             $0.26
($.03 to $0.71)
                                      to
                             $0.67
($.06 to $1.90)
                             $0.13
($.01 to $0.37)
                                      to
                             $0.40
($.03 to $1.20)
                             $0.66
($.12 to $1.70)
                                      to
                             $1.70
($.35 to $4.60)
 
Effects above LML[C]
                            $0.23
(-$.10 to $0.64)
                                      to
                            $0.30
(-$.04 to $0.87)
                            $0.11
(-$.11 to $0.31)
                                      to
                            $0.20
(-$.05 to $0.62)
                            $0.57
(-$.01 to $1.50)
                                      to
                             $0.70
($.20 to $1.80)
 
Effects above NAAQS[D]
                             $0.07
($.01 to $0.18)
                                      to
                             $0.22
($.02 to $0.67)
                             $0.09
($.01 to $0.25)
                                      to
                             $0.31
($.03 to $0.92)
                             $0.15
($.07 to $0.35)
                                      to
                             $0.50
($.25 to $1.30)
[A] Values rounded to two significant figures
[B] PM effects quantified using a no-threshold model. Low end of range reflects dollar value of effects quantified using concentration-response parameter from Krewski et al. (2009) and Smith et al. (2008) studies; upper end quantified using parameters from Lepeule et al. (2012) and Jerrett et al. (2009). 
[C] PM effects quantified at or above the Lowest Measured Level of each long-term epidemiological study. Low end of range reflects dollar value of effects quantified down to LML of Lepeule et al. (2012) study (8 ug/m[3]); high end of range reflects dollar value of effects quantified down to LML of Krewski et al. (2009) study (5.8 ug/m[3]). 
D PM effects only quantified at or above the annual mean of 12 to provide insight regarding the fraction of benefits occurring above the NAAQS. Range reflects effects quantified using concentration-response parameters from Smith et al. (2008) study at the low end and Jerrett et al. (2009) at the high end. 




Table 9. Estimated Economic Value of Avoided PM2.5 and Ozone-Attributable Deaths and Illnesses for Illustrative Scenarios & Three Alternative Approaches to Quantifying PM Effects in 2030, Relative to the No CPP Alternative Baseline (95% Confidence Interval; Billions of 2016$)[A]
                                       
                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Ozone benefits summed with PM benefits using three approaches: 
                                3% Discount Rate
                                        
No-threshold model[B]
                             $0.42
($.04 to $1.10)
                                      to
                             $0.75
($.07 to $2.10)
                             $0.66
($.06 to $1.80)
                                      to
                             $1.60
($.14 to $4.60)
                             $1.30
($.13 to $3.60)
                                      to
                             $3.10
($.28 to $9.00)
 
Limited to above LML[C]
                             $0.34
($.04 to $0.92)
                                      to
                           -$0.22
(-$.01 to -$0.70)
                             $0.60
($.06 to $1.60)
                                      to
                             $0.61
($.06 to $1.80)
                             $1.20
($.11 to $3.20)
                                      to
                             $1.20
($.11 to $3.40)
 
Effects above NAAQS[D]
                           -$0.17
(-$.02 to -$0.46)
                                      to
                           -$0.57
(-$.05 to -$1.70)
                             $0.08
($.01 to $0.23)
                                      to
                             $0.28
($.02 to $0.85)
                             $0.13
($.01 to $0.37)
                                      to
                             $0.46
($.04 to $1.40)
Ozone benefits summed with PM benefits using three approaches: 
                               7% Discount Rate 
No-threshold model[B]
                             $0.37
($.04 to $0.98)
                                      to
                             $0.64
($.06 to $1.70)
                             $0.61
($.06 to $1.70)
                                      to
                             $1.50
($.13 to $4.20)
                             $1.20
($.12 to $3.30)
                                      to
                             $2.90
($.26 to $8.30)
 
LML model[C]
                             $0.30
($.03 to $0.80)
                                      to
                           -$0.25
(-$.02 to -$0.79)
                             $0.55
($.05 to $1.50)
                                      to
                             $0.59
($.05 to $1.70)
                             $1.10
($.10 to $2.90)
                                      to
                             $1.10
($.10 to $3.20)
 
Effects above NAAQS[D]
                           -$0.17
(-$.02 to -$0.46)
                                      to
                           -$0.57
(-$.05 to -$1.70)
                             $0.08
($.01 to $0.23)
                                      to
                             $0.28
($.02 to $0.85)
                             $0.13
($.01 to $0.37)
                                      to
                             $0.46
($.04 to $1.40)
[A] Values rounded to two significant figures
[B] PM effects quantified using a no-threshold model. Low end of range reflects dollar value of effects quantified using concentration-response parameter from Krewski et al. (2009) and Smith et al. (2008) studies; upper end quantified using parameters from Lepeule et al. (2012) and Jerrett et al. (2009). 
[C] PM effects quantified at or above the Lowest Measured Level of each long-term epidemiological study. Low end of range reflects dollar value of effects quantified down to LML of Lepeule et al. (2012) study (8 ug/m[3]); high end of range reflects dollar value of effects quantified down to LML of Krewski et al. (2009) study (5.8 ug/m[3]). 
D PM effects only quantified at or above the annual mean of 12 to provide insight regarding the fraction of benefits occurring above the NAAQS. Range reflects effects quantified using concentration-response parameters from Smith et al. (2008) study at the low end and Jerrett et al. (2009) at the high end. 









Table 10. Estimated Economic Value of Avoided PM2.5 and Ozone-Attributable Deaths and Illnesses for Illustrative Scenarios & Three Alternative Approaches to Quantifying PM Effects in 2035, Relative to the No CPP Alternative Baseline (95% Confidence Interval; Billions of 2016$)[A]
                                       
                               2% HRI at $50/kW
                              4.5% HRI at $50/kW
                              4.5% HRI at $100/kW
Ozone benefits summed with PM benefits using three approaches: 
                                3% Discount Rate
                                        
No-threshold model[B]
                             $0.79
($.08 to $2.10)
                                      to
                             $1.80
($.16 to $5.10)
                           -$0.21
(-$.02 to -$0.56)
                                      to
                           -$0.51
(-$.05 to -$1.50)
                             $1.20
($.12 to $3.30)
                                      to
                             $2.80
($.26 to $8.10)
 
Limited to above LML[C]
                             $0.68
($.07 to $1.80)
                                      to
                             $0.56
($.05 to $1.60)
                           -$0.14
(-$.01 to -$0.39)
                                      to
                           -$0.09
(-$.01 to -$0.28)
                             $1.10
($.10 to $2.90)
                                      to
                             $0.96
($.09 to $2.80)
 
Effects above NAAQS[D]
                             $0.01
($.00 to $0.03)
                                      to
                             $0.04
($.00 to $0.12)
                            -$0.04
($.00 to -$0.10)
                                      to
                           -$0.13
(-$.01 to -$0.39)
                             $0.07
($.01 to $0.20)
                                      to
                             $0.25
($.02 to $0.75)
Ozone benefits summed with PM benefits using three approaches: 
                               7% Discount Rate 
No-threshold model[B]
                             $0.72
($.07 to $2.00)
                                      to
                             $1.60
($.15 to $4.70)
                           -$0.19
(-$.02 to -$0.52)
                                      to
                           -$0.48
(-$.04 to -$1.40)
                             $1.10
($.11 to $3.00)
                                      to
                             $2.60
($.24 to $7.40)
 
LML model[C]
                             $0.62
($.06 to $1.70)
                                      to
                             $0.51
($.05 to $1.50)
                           -$0.13
(-$.01 to -$0.37)
                                      to
                           -$0.10
(-$.01 to -$0.29)
                             $0.97
($.09 to $2.60)
                                      to
                             $0.90
($.08 to $2.60)
 
Effects above NAAQS[D]
                             $0.01
($.00 to $0.03)
                                      to
                             $0.04
($.00 to $0.12)
                            -$0.04
($.00 to -$0.10)
                                      to
                           -$0.13
(-$.01 to -$0.39)
                             $0.07
($.01 to $0.20)
                                      to
                             $0.25
($.02 to $0.75)
[A] Values rounded to two significant figures
[B] PM effects quantified using a no-threshold model. Low end of range reflects dollar value of effects quantified using concentration-response parameter from Krewski et al. (2009) and Smith et al. (2008) studies; upper end quantified using parameters from Lepeule et al. (2012) and Jerrett et al. (2009). 
[C] PM effects quantified at or above the Lowest Measured Level of each long-term epidemiological study. Low end of range reflects dollar value of effects quantified down to LML of Lepeule et al. (2012) study (8 ug/m[3]); high end of range reflects dollar value of effects quantified down to LML of Krewski et al. (2009) study (5.8 ug/m[3]). 
D PM effects only quantified at or above the annual mean of 12 to provide insight regarding the fraction of benefits occurring above the NAAQS. Range reflects effects quantified using concentration-response parameters from Smith et al. (2008) study at the low end and Jerrett et al. (2009) at the high end. 

      We report the combined domestic climate benefits, and health co-benefits discounted at rates of 3 percent and 7 percent for the three illustrative policy scenarios evaluated for each analysis year: 2025, 2030, and 2035 (Table 11, Table 12 and Table 13).
Table 11. Climate Benefits and Ancillary Health Co-Benefits, Relative to No CPP Alternative Baseline (billion 2016$)
                   Values Calculated using 3% Discount Rate
                   Values Calculated using 7% Discount Rate
                                       
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
 
Illustrative 2% HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.3
                                      to
                                      0.7
                                      0.4
                                      to
                                      0.8
                                      0.0
                                      0.3
                                      to
                                      0.7
                                      0.3
                                      to
                                      0.7
                                     2030
                                      0.1
                                      0.4
                                      to
                                      0.8
                                      0.5
                                      to
                                      0.8
                                      0.0
                                      0.4
                                      to
                                      0.6
                                      0.4
                                      to
                                      0.7
                                     2035
                                      0.1
                                      0.8
                                      to
                                      1.8
                                      0.9
                                      to
                                      1.9
                                      0.0
                                      0.7
                                      to
                                      1.6
                                      0.7
                                      to
                                      1.7
Illustrative 4.5% HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.1
                                      to
                                      0.4
                                      0.2
                                      to
                                      0.5
                                      0.0
                                      0.1
                                      to
                                      0.4
                                      0.1
                                      to
                                      0.4
                                     2030
                                      0.1
                                      0.7
                                      to
                                      1.6
                                      0.8
                                      to
                                      1.7
                                      0.0
                                      0.6
                                      to
                                      1.5
                                      0.6
                                      to
                                      1.5
                                     2035
                                      0.1
                                    (0.2) 
                                      to
                                    (0.5) 
                                    (0.2) 
                                      to
                                    (0.5) 
                                      0.0
                                    (0.2) 
                                      to
                                    (0.5) 
                                    (0.2) 
                                      to
                                    (0.5) 
Illustrative 4.5% HRI at $100/kW Scenario
                                     2025
                                      0.2
                                      0.7
                                      to
                                      1.8
                                      0.9
                                      to
                                      2.0
                                      0.0
                                      0.7
                                      to
                                      1.7
                                      0.7
                                      to
                                      1.7
                                     2030
                                      0.2
                                      1.3
                                      to
                                      3.1
                                      1.5
                                      to
                                      3.3
                                      0.0
                                      1.2
                                      to
                                      2.9
                                      1.2
                                      to
                                      2.9
                                     2035
                                      0.2
                                      1.2
                                      to
                                      2.8
                                      1.4
                                      to
                                      3.0
                                      0.0
                                      1.1
                                      to
                                      2.6
                                      1.1
                                      to
                                      2.6
Notes: Estimates rounded to one decimal point, so figures may not sum due to independent rounding The climate benefit estimates in this table reflect the value of domestic impacts from CO2 emission changes and do not account for changes in non-CO2 GHG emissions. Ozone co-benefits occur in analysis year, so they are the same for all discount rates. The health co-benefits reflect the sum of the PM2.5 and ozone co-benefits and reflect the range based on adult mortality functions (e.g., from Krewski et al. (2009) with Smith et al. (2009) to Lepeule et al. (2012) with Zanobetti & Schwartz. (2008)). The health co-benefits do not account for direct exposure to NO2, SO2, and HAP; ecosystem effects; or, visibility impairment.

Table 12. Climate Benefits and Ancillary Health Co-Benefits, showing only PM2.5 Related Benefits above the Lowest Measured Level of Each Long-Term PM2.5 Mortality Study, Relative to No CPP Alternative Baseline (billion 2016$)
                   Values Calculated using 3% Discount Rate
                   Values Calculated using 7% Discount Rate
                                       
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
 
Illustrative 2%HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.2
                                      to
                                      0.3
                                      0.3
                                      to
                                      0.4
                                      0.0
                                      0.2
                                      to
                                      0.3
                                      0.2
                                      to
                                      0.3
                                     2030
                                      0.1
                                      0.3
                                      to
                                    (0.2) 
                                      0.4
                                      to
                                    (0.1) 
                                      0.0
                                      0.3
                                      to
                                    (0.2) 
                                      0.3
                                      to
                                    (0.2) 
                                     2035
                                      0.1
                                      0.7
                                      to
                                      0.6
                                      0.8
                                      to
                                      0.6
                                      0.0
                                      0.6
                                      to
                                      0.5
                                      0.6
                                      to
                                      0.5
Illustrative 4.5%HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.1
                                      to
                                      0.2
                                      0.2
                                      to
                                      0.3
                                      0.0
                                      0.1
                                      to
                                      0.2
                                      0.2
                                      to
                                      0.2
                                     2030
                                      0.1
                                      0.6
                                      to
                                      0.6
                                      0.7
                                      to
                                      0.7
                                      0.0
                                      0.6
                                      to
                                      0.6
                                      0.6
                                      to
                                      0.6
                                     2035
                                      0.1
                                    (0.1) 
                                      to
                                    (0.1) 
                                    (0.1) 
                                      to
                                     0.0 
                                      0.0
                                    (0.1) 
                                      to
                                    (0.1) 
                                    (0.1) 
                                      to
                                    (0.1) 
Illustrative 4.5% HRI at $100/kW Scenario
                                     2025
                                      0.2
                                      0.6
                                      to
                                      0.7
                                      0.8
                                      to
                                      0.9
                                      0.0
                                      0.6
                                      to
                                      0.7
                                      0.6
                                      to
                                      0.7
                                     2030
                                      0.2
                                      1.2
                                      to
                                      1.2
                                      1.4
                                      to
                                      1.4
                                      0.0
                                      1.1
                                      to
                                      1.1
                                      1.1
                                      to
                                      1.1
                                     2035
                                      0.2
                                      1.1
                                      to
                                      1.0
                                      1.2
                                      to
                                      1.1
                                      0.0
                                      1.0
                                      to
                                      0.9
                                      1.0
                                      to
                                      0.9
Notes: Estimates rounded to one decimal point, so figures may not sum due to independent rounding. The climate benefit estimates in this table reflect the value of domestic impacts from CO2 emission changes and do not account for changes in non-CO2 GHG emissions. Ozone co-benefits occur in analysis year, so they are the same for all discount rates. The health co-benefits reflect the sum of the PM2.5 and ozone co-benefits and reflect the range based on adult mortality functions (e.g., from Krewski et al. (2009) with Smith et al. (2009) to Lepeule et al. (2012) with Zanobetti & Schwartz. (2008)). The health co-benefits do not account for direct exposure to NO2, SO2, and HAP; ecosystem effects; or, visibility impairment.
      
Table 13. Climate Benefits and Ancillary Health Co-Benefits, Showing only PM2.5 Related Benefits above PM2.5 National Ambient Air Quality Standard, Relative to No CPP Alternative Baseline (billion 2016$)
                   Values Calculated using 3% Discount Rate
                   Values Calculated using 7% Discount Rate
                                       
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
                           Domestic Climate Benefits
                              Health 
Co-Benefits
                                Total 
Benefits
 
Illustrative 2% HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.1
                                      to
                                      0.2
                                      0.2
                                      to
                                      0.3
                                      0.0
                                      0.1
                                      to
                                      0.2
                                      0.1
                                      to
                                      0.2
                                     2030
                                      0.1
                                    (0.2) 
                                      to
                                    (0.6) 
                                    (0.1) 
                                      to
                                    (0.5) 
                                      0.0
                                    (0.2) 
                                      to
                                    (0.6) 
                                    (0.1) 
                                      to
                                    (0.5) 
                                     2035
                                      0.1
                                      0.0
                                      to
                                      0.0
                                      0.1
                                      to
                                      0.1
                                      0.0
                                      0.0
                                      to
                                      0.0
                                      0.0
                                      to
                                      0.1
Illustrative 4.5% HRI at $50/kW Scenario
                                     2025
                                      0.1
                                      0.1
                                      to
                                      0.3
                                      0.2
                                      to
                                      0.4
                                      0.0
                                      0.1
                                      to
                                      0.3
                                      0.1
                                      to
                                      0.3
                                     2030
                                      0.1
                                      0.1
                                      to
                                      0.3
                                      0.2
                                      to
                                      0.4
                                      0.0
                                      0.1
                                      to
                                      0.3
                                      0.1
                                      to
                                      0.3
                                     2035
                                      0.1
                                     0.0 
                                      to
                                    (0.1) 
                                      0.0
                                      to
                                    (0.1) 
                                      0.0
                                     0.0 
                                      to
                                    (0.1) 
                                     0.0 
                                      to
                                    (0.1) 
Illustrative 4.5% HRI at $100/kW Scenario
                                     2025
                                      0.2
                                      0.1
                                      to
                                      0.5
                                      0.3
                                      to
                                      0.7
                                      0.0
                                      0.1
                                      to
                                      0.5
                                      0.2
                                      to
                                      0.5
                                     2030
                                      0.2
                                      0.1
                                      to
                                      0.5
                                      0.3
                                      to
                                      0.6
                                      0.0
                                      0.1
                                      to
                                      0.5
                                      0.2
                                      to
                                      0.5
                                     2035
                                      0.2
                                      0.1
                                      to
                                      0.3
                                      0.2
                                      to
                                      0.4
                                      0.0
                                      0.1
                                      to
                                      0.3
                                      0.1
                                      to
                                      0.3
Notes: Estimates rounded to one decimal point, so figures may not sum due to independent rounding. The climate benefit estimates in this table reflect the value of domestic impacts from CO2 emission changes and do not account for changes in non-CO2 GHG emissions. Ozone co-benefits occur in analysis year, so they are the same for all discount rates. The health co-benefits reflect the sum of the PM2.5 and ozone co-benefits and reflect the range based on adult mortality functions (e.g., from Krewski et al. (2009) with Smith et al. (2009) to Lepeule et al. (2012) with Zanobetti & Schwartz. (2008)). The health co-benefits do not account for direct exposure to NO2, SO2, and HAP; ecosystem effects; or, visibility impairment.

      Table 14 provides the PV and EAV of costs, benefits, and net benefits relative to the No CPP alternative baseline associated with the targeted pollutant, CO2. Table 15 presents the costs, benefits, and net benefits associated with the targeted pollutant for specific years.



      
     

Table 14. Present Value and Equivalent Annualized Value of Compliance Costs, Climate Benefits, and Net Benefits Associated with Targeted Pollutant (CO2), Relative to the No CPP Alternative Baseline, 3 and 7 Percent Discount Rates, 2023-2037 (billions of 2016$)
                                       
                                     Costs
                          Domestic 
Climate Benefits
          Net Benefits associated with 
the Targeted Pollutant (CO2)
                                       
                                      3%
                                      7%
                                      3%
                                      7%
                                      3%
                                      7%
Present Value
2% HRI at $50/kW
                                     4.8 
                                     2.8 
                                     0.8 
                                     0.1 
                                     (4.1)
                                     (2.8)
4.5% HRI at $50/kW
                                     (1.2)
                                     (0.6)
                                     0.7 
                                     0.1 
                                     2.0 
                                     0.7 
4.5% HRI at $100/kW
                                     8.2 
                                     4.8 
                                     1.6 
                                     0.2 
                                     (6.6)
                                     (4.7)
Equivalent Annualized Value
2% HRI at $50/kW
                                     0.4 
                                     0.3 
                                     0.1 
                                     0.0 
                                     (0.3)
                                     (0.3)
4.5% HRI at $50/kW
                                     (0.1)
                                     (0.1)
                                     0.1 
                                     0.0 
                                     0.2 
                                     0.1 
4.5% HRI at $100/kW
                                     0.7 
                                     0.5 
                                     0.1 
                                     0.0 
                                     (0.6)
                                     (0.5)
Notes: Negative costs indicate avoided costs, negative benefits indicate forgone benefits, and negative net benefits indicate forgone net benefits. All estimates are rounded to one decimal point, so figures may not sum due to independent rounding. Climate benefits reflect the value of domestic impacts from CO2 emissions changes. This table does not include estimates of ancillary health co-benefits from changes in electricity sector SO2 and NOX emissions.
 

Table 15. Compliance Costs, Climate Benefits, and Net Benefits Associated with Targeted Pollutant (CO2), Relative to the No CPP Alternative Baseline, 3 and 7 Percent Discount Rates, 2025, 2030, and 2035 (billions of 2016$)
                                       
                                     Costs
                          Domestic 
Climate Benefits 
          Net Benefits 
associated with the 
Targeted Pollutant (CO2)
                                       
                                      3%
                                      7%
                                      3%
                                      7%
                                      3%
                                      7%
2% HRI at $50/kW
                                       
                                       
                                       
2025
                                     0.7 
                                     0.7 
                                     0.1 
                                     0.0 
                                     (0.7)
                                     (0.7)
2030
                                     0.5 
                                     0.5 
                                     0.1 
                                     0.0 
                                     (0.4)
                                     (0.5)
2035
                                     0.5 
                                     0.5 
                                     0.1 
                                     0.0 
                                     (0.4)
                                     (0.5)
4.5% HRI at $50/kW
                                       
                                       
                                       
2025
                                     0.1 
                                     0.1 
                                     0.1 
                                     0.0 
                                     0.0 
                                     (0.1)
2030
                                     (0.2)
                                     (0.2)
                                     0.1 
                                     0.0 
                                     0.3 
                                     0.3 
2035
                                     (0.2)
                                     (0.2)
                                     0.1 
                                     0.0 
                                     0.3 
                                     0.2 
4.5% HRI at $100/kW
                                       
                                       
2025
                                     1.3 
                                     1.3 
                                     0.2 
                                     0.0 
                                     (1.1)
                                     (1.2)
2030
                                     0.9 
                                     0.9 
                                     0.2 
                                     0.0 
                                     (0.7)
                                     (0.9)
2035
                                     0.8 
                                     0.8 
                                     0.2 
                                     0.0 
                                     (0.7)
                                     (0.8)
Notes: Negative costs indicate avoided costs, negative benefits indicate forgone benefits, and negative net benefits indicate forgone net benefits. All estimates are rounded to one decimal point, so figures may not sum due to independent rounding. Climate benefits reflect the value of domestic impacts from CO2 emissions changes. This table does not include estimates of ancillary health co-benefits from changes in electricity sector SO2 and NOX emissions.


      Table 16 provides the estimated costs, benefits, and net benefits, inclusive of the ancillary health-co benefits for the No CPP alternative baseline in PV and EAV forms.  Table 17 presents the estimates for the specific years of 2025, 2030, and 2035.
      
Table 16. Present Value and Equivalent Annualized Value of Compliance Costs, Total Benefits, and Net Benefits, Relative to the No CPP Alternative Baseline, 3 and 7 Percent Discount Rates, 2023-2037 (billions of 2016$)
                                       
                                     Costs
                                   Benefits
                                 Net Benefits 
                                       
                                      3%
                                      7%
                                      3%
                                      7%
                                      3%
                                      7%
Present Value
2% HRI at $50/kW
                                     4.8 
                                     2.8 
                                  4.5 to 9.2
                                  2.0 to 4.3
                                 (0.3) to 4.3
                                 (0.9) to 1.5
4.5% HRI at $50/kW
                                     (1.2)
                                     (0.6)
                                  2.9 to 6.3
                                  1.4 to 1.9
                                  4.1 to 7.5
                                  2.0 to 2.6
4.5% HRI at $100/kW
                                     8.2 
                                     4.8 
                                 10.0 to 21.3
                                  4.1 to 9.4
                                  1.8 to 13.2
                                 (0.8) to 4.5
Equivalent Annualized Value
2% HRI at $50/kW
                                     0.4 
                                     0.3 
                                  0.4 to 0.8
                                  0.2 to 0.5
                                 (0.0) to 0.4
                                 (0.1) to 0.2
4.5% HRI at $50/kW
                                     (0.1)
                                     (0.1)
                                  0.2 to 0.5
                                  0.1 to 0.2
                                  0.3 to 0.6
                                  0.2 to 0.3
4.5% HRI at $100/kW
                                     0.7 
                                     0.5 
                                  0.8 to 1.8
                                  0.4 to 1.0
                                  0.1 to 1.1
                                 (0.1) to 0.5
Notes: Negative costs indicate avoided costs, negative benefits indicate forgone benefits, and negative net benefits indicate forgone net benefits. All estimates are rounded to one decimal point, so figures may not sum due to independent rounding. Total benefits include both climate benefits and ancillary health co-benefits. Climate benefits reflect the value of domestic impacts from CO2 emissions changes. The ancillary health co-benefits reflect the sum of the PM2.5 and ozone benefits from changes in electricity sector SO2 and NOX emissions and reflect the range based on adult mortality functions (e.g., from Krewski et al. (2009) with Smith et al. (2009) to Lepeule et al. (2012) with Jerrett et al. (2009)).
      
      

Table 17. Compliance Costs, Total Benefits, and Net Benefits, Relative to the No CPP Alternative Baseline, 3 and 7 Percent Discount Rates, 2025, 2030, and 2035 (billions of 2016$)
                                       
                                     Costs
                                   Benefits
                                 Net Benefits
                                       
                                      3%
                                      7%
                                      3%
                                      7%
                                      3%
                                      7%
2% HRI at $50/kW
                                     2025
                                     0.7 
                                     0.7 
                                  0.4 to 0.8
                                  0.3 to 0.7
                                 (0.4) to 0.0
                                (0.5) to (0.1)
                                     2030
                                     0.5 
                                     0.5 
                                  0.5 to 0.8
                                  0.4 to 0.7
                                  0.0 to 0.4
                                 (0.1) to 0.2
                                     2035
                                     0.5 
                                     0.5 
                                  0.9 to 1.9
                                  0.7 to 1.7
                                  0.4 to 1.4
                                  0.2 to 1.1
4.5% HRI at $50/kW
                                     2025
                                     0.1 
                                     0.1 
                                  0.2 to 0.5
                                  0.1 to 0.4
                                  0.2 to 0.4
                                  0.1 to 0.3
                                     2030
                                     (0.2)
                                     (0.2)
                                  0.8 to 1.7
                                  0.6 to 1.5
                                  1.0 to 1.9
                                  0.9 to 1.7
                                     2035
                                     (0.2)
                                     (0.2)
                                (0.2) to (0.5)
                                (0.2) to (0.5)
                                 0.1 to (0.2)
                                 0.0 to (0.2)
4.5% HRI at $100/kW
                                     2025
                                     1.3 
                                     1.3 
                                  0.9 to 2.0
                                  0.7 to 1.7
                                 (0.4) to 0.7
                                 (0.6) to 0.4
                                     2030
                                     0.9 
                                     0.9 
                                  1.5 to 3.3
                                  1.2 to 2.9
                                  0.6 to 2.4
                                  0.3 to 2.0
                                     2035
                                     0.8 
                                     0.8 
                                  1.4 to 3.0
                                  1.1 to 2.6
                                  0.5 to 2.2
                                  0.3 to 1.8
Notes: Negative costs indicate avoided costs, negative benefits indicate forgone benefits, and negative net benefits indicate forgone net benefits. All estimates are rounded to one decimal point, so figures may not sum due to independent rounding. Total benefits include both climate benefits and ancillary health co-benefits. Climate benefits reflect the value of domestic impacts from CO2 emissions changes. The ancillary health co-benefits reflect the sum of the PM2.5 and ozone benefits from changes in electricity sector SO2 and NOX emissions and reflect the range based on adult mortality functions (e.g., from Krewski et al. (2009) with Smith et al. (2009) to Lepeule et al. (2012) with Jerrett et al. (2009)).


References
Jerrett M, Burnett RT, Pope CA, Ito K, Thurston G, Krewski D, et al. 2009. Long-term ozone exposure and mortality. N Engl J Med 360:1085 - 95; doi:10.1056/NEJMoa0803894.
Krewski D, Jerrett M, Burnett RT, Ma R, Hughes E, Shi Y, et al. 2009. Extended follow-up and spatial analysis of the American Cancer Society study linking particulate air pollution and mortality. Res Rep Health Eff Inst 5-114; discussion 115 - 36.
Lepeule J, Laden F, Dockery D, Schwartz J. 2012. Chronic exposure to fine particles and mortality: an extended follow-up of the Harvard Six Cities study from 1974 to 2009. Environ Health Perspect 120:965 - 970; doi:10.1289/ehp.1104660.
Smith RL, Xu B, Switzer P. 2009. Reassessing the relationship between ozone and short-term mortality in U.S. urban communities. Inhal Toxicol 21 Suppl 2:37 - 61; doi:10.1080/08958370903161612.

