The Benefits of Public Protections: Ten Rules That Save Lives and Protect the Environment

8/11/2019 The Benefits of Public Protections: Ten Rules That Save Lives and Protect the Environment

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The Benefts o Public Protections:Ten Rules That Save Lives and Protect the Environment

JULY 20


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AUTHORS

July ran, Regulatory Policy Intern

Ronald White, Director o Regulatory Policy

CONTRIBUTORS

Katherine McFate, President and CEO

Brian Gumm, Communications DirectorJustin Santopietro, Regulatory Policy Intern

ABOUT THE CENTER FOR EFFECTIVE GOVERNMENT

Te Center or Effective Government works to build an open, accountable government that invests in the common

good, protects people and the environment, and advances the national priorities dened by an active, in ormed

citizenry.

Individuals and organizations wishing to quote, post, reprint, or otherwise redistribute this report, in whole or

in part, are permitted to do so i they provide attribution to the Center or Effective Government as the original

publisher. o contribute to the Center or Effective Government, please visit http://www. oreffectivegov.org/donate
http://www.foreffectivegov.org/donatehttp://www.foreffectivegov.org/donatehttp://www.foreffectivegov.org/donate


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The Benefts o Public Protections:Ten Rules That Save Lives and Protect the Environment


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TABLE OF CONTENTSExecutive SummaryIntroduction

The Mandate to Use Beneft-Cost AnalysisCalculating the Benefts and Costs o Public ProtectionsThe Social and Economic Benefts o RegulationsReport MethodologyFindingsConclusionAppendix A -- Summary o Rules Examined

1. Proposed Rule: Occupational Exposure to Respirable Crystalline Silica2. Final Rule: Federal Motor Vehicle Sa ety Standards, Ejection Mitigation3. Proposed Rule: Federal Motor Vehicle Sa ety Standards; Electronic

Stability Control Systems or Heavy Vehicles4. Final Rule: Nutrition Labeling o Single-Ingredient Products and Ground or

Chopped Meat and Poultry Products5. Final Rule: Prevention o Salmonella Enteritidis in Shell Eggs During

Production, Storage, and Transportation6. Final Rule: National Ambient Air Quality Standards or Particulate Matter7. Final Rule: Mercury and Air Toxics Standards

8. Final Rule: Control o Air Pollution rom Motor Vehicles: Tier 3 MotorVehicle Emission and Fuel Standards

9. Proposed Rule: Hazardous and Solid Waste Management System;Identifcation and Listing o Special Wastes; Disposal o Coal CombustionResiduals rom Electric Utilities

10. Proposed Rule: E uent Limitations Guidelines and Standards or theSteam Electric Power Generating Point Source Category

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7

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101415151617

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2123

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INTRODUCTIONIn a democracy, citizens expect their government to protect their health and well-being since both lawmakers

and public servants are ultimately accountable to the people. Starting with the Progressive Era in the early

1900s, this meant ensuring that unsa e drugs and ood could not be marketed to unsuspecting consumers and

that workers in industrial work settings were not orced to labor in unhealthy or high-risk workplaces. Te NewDeal brought more oversight o nancial institutions and the associational and workplace rights o workers. With

the growth o the consumer and environmental movements o the 1960s and 1970s, government responded to

citizen concerns about industrial pollution and chemical toxins by establishing rules limiting the emissions and

contaminants that businesses are allowed to use or produce. Over time, as our expanding knowledge o medicine

and science has improved our ability to evaluate the health risks o hazardous substances, public pressure to

regulate their use has also grown.

In practice, however, demands or better protections or human health and the environment have always been

contested. Tere are costs to complying with new health and sa ety standards, and some rms in some industries

have bitterly ought rules that increase their costs or constrain their activities. Even afer the catastrophic oil spill

in the Gul o Mexico, the explosion in West, exas, the contamination o the Elk River in West Virginia, and

the housing and economic collapse that resulted rom deregulating nancial institutions, some observers argue

that private rms are able to sel -regulate and will respond to the discipline o the market and so need no

collective standards or external en orcement o responsible standards o corporate behavior.

In our democracy, the balance between the publics interest in health and sa ety and commercial interests desire

or prots is hashed out in the political square rst, through laws passed by elected representatives o the

people (Congress and the president) that prioritize the value o human health and workplace sa ety, and next,

through the specic, detailed rules that allow executive branch agencies to implement and en orce the priorities

already written into law. For example, rules establish limits on the emissions or contaminants that commercial

enterprises are allowed to produce, the workplace conditions that employers are required to maintain or their

workers, and the in ormation a bank has to provide a borrower.

Rules are created utilizing the expertise o agency scientists and technical staff and afer extensive research and

consultation with scientists, engineers, industry-specic experts, workers, business owners and managers, and

the public. Congress allocates the unds to enact the rules that agencies establish in order to implement the laws

it passes. Rules are a critical mani estation o the democratic response to public demand. Tey are a reection o

societys values and are designed to achieve and protect the common good.


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Rulemaking is our democracys way o balancing the interests o the publics sa ety and well-being with the

prot-maximizing goals o the private sector. In act, regulatory standards benet private businesses as well. Tey

create a stable commercial environment, set the rules o competition, prevent a race to the bottom, and increase

consumer condence in products. I a rule is contested, it is almost always because a particular private business

or industrial sector has a vested interest in maintaining the status quo.

Regulations are needed to provide the public with essential protections that we as individuals cannot secure

ourselves. Without regulations, we would not have the cleaner air and water quality or sa er workplaces and

products that we now take or granted. In a society with no or too little regulation, only the wealthy and

privileged would be able to afford protections. Tis is not how a democratic society should unction. Our

national duty is to ensure equitable protections or everyone, and rules that provide those protections are a vital

component o achieving that objective.

Tis report examines the public health, worker sa ety, and environmental benets projected rom ten proposedor nal regulations issued between 2009 and 2014 by ve ederal agencies (the U.S. Environmental Protection

Agency, Occupational Sa ety and Health Administration, National Highway raffic Sa ety Administration,

Food and Drug Administration, and Department o Agricultures Food Sa ety and Inspection Service). Tese

rules range rom reducing toxic air pollutants rom power plants and other large industrial sources to reducing

workers exposure to disease-causing silica.

THE MANDATE TO USE BENEFIT-COSTANALYSISTe use o benet-cost analysis in the rulemaking process originated with an executive order issued by President

Ronald Reagan in 1981. Te executive order required the development o a regulatory impact analysis (RIA) or

any signicant regulatory action undertaken by executive branch agencies. 1 A signicant rule was dened

in a previous Carter administration executive order as having an annual economic impact, either positively or

negatively, o $100 million or more. 2 In todays dollars, the equivalent impact on the nations gross domestic

product would be $713 million. 3 Since this gure has not been adjusted to reect its relationship to the current

national economy, executive agencies are conducting impact analyses or rules that have substantially less impact

than they did more than 30 years ago. Rules that lead to a notable change in, or inconsistency with, existing

national policy are also considered signicant regulatory actions. Under Reagans executive order, a rules1 Executive Order 12291, issued by President Ronald Reagan. Exec Order No. 12291 (Feb. 17, 1981). Available athttp://www.presidency.ucsb.edu/ws/?pid=43424.2 Executive Order 12044, issued by President Jimmy Carter, established the denition o a signicant regulation as one having $100 million or moreeconomic impact on the economy. Exec. Order No. 12044 (March 23, 1978). Available at http://www.presidency.ucsb.edu/ws/?pid=30539 .3 Based on the ratio o $100 million to the 1978 U.S. GDP o $2.357 trillion as applied to the 2013 U.S. GDP o $16.803 trillion. Data source: http://useconomy.about.com/od/GDP-by-Year/a/US-GDP-History.htm .
http://www.presidency.ucsb.edu/ws/?pid=43424http://www.presidency.ucsb.edu/ws/?pid=43424http://www.presidency.ucsb.edu/ws/?pid=30539http://useconomy.about.com/od/GDP-by-Year/a/US-GDP-History.htmhttp://useconomy.about.com/od/GDP-by-Year/a/US-GDP-History.htmhttp://useconomy.about.com/od/GDP-by-Year/a/US-GDP-History.htmhttp://useconomy.about.com/od/GDP-by-Year/a/US-GDP-History.htmhttp://www.presidency.ucsb.edu/ws/?pid=30539http://www.presidency.ucsb.edu/ws/?pid=43424http://www.presidency.ucsb.edu/ws/?pid=43424


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monetized societal benets had to outweigh the compliance costs to industry in order or the rule to go orward. 4

In 1993, President Bill Clinton issued an executive order replacing the Reagan executive order and establishing

that the benets o rules should justi y their compliance costs. Clintons executive order notes that these rules

should be designed to maximize their cost effectiveness while recognizing that some costs and benets are

difficult to quanti y. 5 Tis approach to designing rules and assessing their benets and costs was reaffirmed by

President Barack Obama in 2011. 6

Te regulatory impact analysis or every major proposed rule prepared by an executive branch agency

identies the issue being addressed, possible regulatory options, and the costs and benets o each option. It

also establishes a baseline point or comparison and includes consideration o any side effects o the rule. Te

proposed rule and RIA are submitted to the Office o Management and Budgets (OMB) Office o In ormation

and Regulatory Affairs (OIRA) or review; this office can send the rule back or urther analysis or reject the rule

and require the agency to substantially revise its proposal and/or RIA. 7

CALCULATING THE BENEFITS AND COSTS OFPUBLIC PROTECTIONSTough benet-cost analysis has become a staple o regulatory analysis, its current methodology has signicant

aws and limitations. In addition to the ethical concerns about putting a price on human li e or suffering rom

disease, these analyses are highly dependent on the assumptions upon which projections are based.

Benets are ofen underestimated or the ollowing reasons: First, improvements in public health and the

environment are diffuse and ofen difficult to quanti y. Additionally, there is ofen sufficient scientic evidence to

indicate a signicant causal link between a problem and its impact (e.g., exposure to methylmercury and adverse

cardiovascular effects), but not enough in ormation to quanti y or monetize that relationship. When benets are

too difficult to quanti y, they are ofen dropped rom the analysis entirely, meaning a signicant societal benet

is simply omitted. 8 Agency analyses o the societal benets o a new rule or standard ofen list the benets that

are not able to be quantied and monetized, but it is essential that these unquantiable benets be considered in

estimating the level o protection provided by a regulatory action.

4 Op. Cit.5 Executive Order 12866, issued by President Bill Clinton, established the current cost-benet analysis requirements, 58 FR 51735 (Oct. 4, 1993).Available at http://www.regin o.gov/public/jsp/Utilities/EO_12866.pd .6 Executive Order 13563, issued by President Barack Obama, 76 FR 3821 (Jan. 18, 2011). Available at http://www.gpo.gov/ dsys/pkg/FR-2011-01-21/pd /2011-1385.pd . 7 Office o Management and Budget Circular A-4, denes best practices or regulatory analysis. (Sept. 17, 2003), Available at http://www.whitehouse.gov/sites/de ault/les/omb/assets/omb/circulars/a004/a-4.pd .See also OMB Circular A-4 Regulatory Impact Analysis: A Primer. (Aug. 15, 2011). Available athttp://www.whitehouse.gov/sites/de ault/les/omb/in oreg/regpol/circular-a-4_regulatory-impact-analysis-a-primer.pd . 8 Center or Progressive Re orm Saving Lives, Preserving the Environment, Growing the Economy: Te ruth about Regulation. White Paper #1109(July 2011). Available at http://www.progressivere orm.org/articles/RegBenets_1109.pd .
http://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdfhttp://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdfhttp://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/regpol/circular-a-4_regulatory-impact-analysis-a-primer.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/regpol/circular-a-4_regulatory-impact-analysis-a-primer.pdfhttp://www.progressivereform.org/articles/RegBenefits_1109.pdfhttp://www.progressivereform.org/articles/RegBenefits_1109.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/regpol/circular-a-4_regulatory-impact-analysis-a-primer.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/regpol/circular-a-4_regulatory-impact-analysis-a-primer.pdfhttp://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdfhttp://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a004/a-4.pdfhttp://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdf


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Societal benets are urther underestimated due to the practice o discounting uture benets. Discounting

is used to convert uture costs and benets into present values so that they are comparable (e.g., a business

would need to invest in new control equipment in the near term to adhere to a new pollution emissions

standard, but the benets o a cleaner environment would accrue to the public over a long period o time in

the uture). Discounting places greater value on benets that are received closer to the present than those that

occur arther in the uture. Te choice o a discount rate is subjective, but ederal agency economists usually

discount the uture value o benets and compliance costs by three percent or seven percent per year, as these

are the guidelines set by the Office o Management and Budget. 9 For rules whose societal benets emerge afer

a long period o time ( or example, rules that reduce the amount o greenhouse gases in the atmosphere to

address climate change), discounting the value o the benet over long periods o time means that its estimated

benets will eventually disappear, when o course the real benets may in act grow over time. 10 Tis concern is

acknowledged by OMB as well.11

As societal benets are ofen underestimated, compliance costs are ofen exaggerated. Estimates o the costs o

compliance typically come rom survey data that regulatory agencies collect rom the companies that will be

affected by a regulation. Tis practice introduces an incentive or companies to inate their cost projections

in order to increase the estimated costs o a new rule. Companies typically claim condentiality or their

cost in ormation, which limits the ability o the public to veri y the accuracy o the data. 12 Moreover, i cost

in ormation rom these surveys is inadequate, agencies have to make educated estimates. In these situations,

agency staff tend to use high estimates o costs in order to avoid litigation by regulated companies asserting that

the cost in ormation is inaccurate. 13

In sum, benet-cost analysis is an imper ect practice based on many assumptions and estimates that can alter

outcomes. Acknowledging that some benets and costs are difficult to quanti y, the executive orders governing9 Environmental Protection Agency Guidelines or Preparing Economic Analyses Ch 6 Discounting Future Benets and Costs. (December 2010).Available at http://yosemite.epa.gov/ee/epa/eerm.ns /vwAN/EE-0568-06.pd /$le/EE-0568-06.pd . Also see OMB Circular A-4, op. cit. 10 Center or Progressive Re orm Saving Lives, Preserving the Environment, Growing the Economy: Te ruth about Regulation. (July 2011). Alsosee Ben rachtenberg, Health Ination, Wealth Ination, and the Discounting o Human Li e 89 Or. L. Rev. (2011) available at http://law.uoregon.edu/org/olrold/archives/89/rachtenberg.pd . 11 OMB Circular A-4 Regulatory Impact Analysis: A Primer noting Discounting the wel are o uture generations at 7 percent or even 3 percentcould create serious ethical problems.12 Public Citizen Foundation Not oo Costly, Afer All: An Examination o the Inated Cost Estimates o Health, Sa ety and EnvironmentalProtections. (February 2004).13 Center or Progressive Re orm Saving Lives, Preserving the Environment, Growing the Economy: Te ruth about Regulation. (July 2011). able6, page 13 shows several studies that ound overestimated costs or numerous regulations.See also Eban Goodstein & Hart Hodges, Polluted Data: Overestimating Environmental Costs, 8 Am. Prospect 64 (Nov./Dec. 1997) and WinstonHarrington, Richard D. Morgenstern, & Peter Nelson, On the Accuracy o Regulatory Cost Estimates (Resources or the Future, Discussion Paper99-18, 1999) available at http://www.rff.org/documents/RFF-DP-99-18.pd .

Benet-cost analysis is an imperfect practice based on many assumptionsand estimates that can alter outcomes.
http://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0568-06.pdf/$file/EE-0568-06.pdfhttp://law.uoregon.edu/org/olrold/archives/89/Trachtenberg.pdfhttp://law.uoregon.edu/org/olrold/archives/89/Trachtenberg.pdfhttp://www.rff.org/documents/RFF-DP-99-18.pdfhttp://www.rff.org/documents/RFF-DP-99-18.pdfhttp://law.uoregon.edu/org/olrold/archives/89/Trachtenberg.pdfhttp://law.uoregon.edu/org/olrold/archives/89/Trachtenberg.pdfhttp://yosemite.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0568-06.pdf/$file/EE-0568-06.pdf


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the development o regulations require that the benets rom the regulations justi y the costs, but do not

require that the public benets that can be monetized have to outweigh estimated costs to industry. 14

Nonetheless, the monetary societal benets rom public protections almost always exceed compliance costs to

industry, 15 and these monetary benets are supplemented by substantial unquantiable benets in improvements

to health, wel are, and the environment. Even when public protections result in a small increase in costs to

consumers, both the monetary and societal benets resulting rom the rules ar outweigh the minimal cost

increases.

THE SOCIAL AND ECONOMIC BENEFITS OFREGULATIONSTe ten regulations reviewed in this report have no signicant impact on jobs and the economy, despite

conservative rhetoric about regulations killing jobs. 16 None o the rules were projected to have a signicant

negative impact on the economy; in act, three o the rules are projected to create net new jobs. Overall, thecollective estimated impact o these rules on jobs is to slightly increase the overall number o jobs, as a result

o increased labor demand to comply with the rules. Tree o the ten rules have the potential to affect small

businesses, but exemptions and provisions are included in the rules to alleviate these effects. Also, three o the

ten rules examined may slightly increase costs to consumers, but these increases are either negligible or very

small, especially compared to the size o the economy.

14 Executive Order 12866 (Oct. 4, 1993).See also Executive Order 13563, issued by President Barack Obama, Improving Regulation and Regulatory Review. Exec Order No. 13563. F.R 2011-1385. (Jan. 18, 2011). Available athttp://www.gpo.gov/ dsys/pkg/FR-2011-01-21/pd /2011-1385.pd . 15 Center or Progressive Re orm Saving Lives, Preserving the Environment, Growing the Economy: Te ruth about Regulation. (July 2011).16 Eric Cantor, Memo on Upcoming Jobs Agenda. (Aug. 29, 2011). Available at http://majorityleader.gov/blog/2011/08/memo-on-upcoming-jobs-agenda.html.

Te executive orders governing the development of regulations require thatthe benets from the regulations justify the costs, but do not require thatthe public benets that can be monetized have to outweigh estimated costs toindustry.
http://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdfhttp://majorityleader.gov/blog/2011/08/memo-on-upcoming-jobs-agenda.htmlhttp://majorityleader.gov/blog/2011/08/memo-on-upcoming-jobs-agenda.htmlhttp://majorityleader.gov/blog/2011/08/memo-on-upcoming-jobs-agenda.htmlhttp://majorityleader.gov/blog/2011/08/memo-on-upcoming-jobs-agenda.htmlhttp://www.gpo.gov/fdsys/pkg/FR-2011-01-21/pdf/2011-1385.pdf


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Numerous studies negate the claim that regulations lead to signicant job loss 17 and stall the economy. 18 No

evidence shows that regulations lead to signicant overall losses in employment or that regulations cause

companies to move overseas. In act, rules may increase employment and competitiveness by encouraging

industry to become more productive and innovative in response to the regulations. 19 Pollution control

regulations result in jobs in areas such as construction and technology. For instance, the Manu acturers o

Emission Controls Association (MECA) estimated that in 2010, the economic activity that resulted rom

emission control technology or new cars and trucks in the U.S. totaled $12 billion. Additionally, MECA member

companies provided 65,000 green jobs in the U.S. 20 Te Institute o Clean Air Companies (ICAC) orecasts

that the overall U.S. market or air pollution control and monitoring technology is around $5 billion a year (in

constant 2012 dollars) and is expected to increase to almost $6 billion by 2016. 21 Te EPAs Mercury and Air

oxics rule, which requires the installation o pollution control systems on power plants and large industrial

acilities, is projected to result in 46,000 short-term job years, 22 as well as 8,000 long-term jobs.

A large body o literature exists demonstrating that regulations do not have a signicant impact on the overall

economy and job availability. Although specic regulations may lead to job gains or losses in a particular

industry, the jobs effect o regulations overall is slightly positive or neutral. 23 Key studies have shown that

environmental regulations in particular do not have a signicant effect on employment. Berman and Buiexamined the impact that local air pollution regulations in Southern Cali ornia had on local manu acturing

jobs, compared to other rms in the region over time and to rms outside the region. Tey ound no signicant

effect on employment. 24 Morgenstern, et. al., urther ound that increased spending due to compliance with17 See National Journal, John Boehners Remarks at Economic Club o Washington. (Sept. 15, 2011). Available at http://www.nationaljournal.com/congress/text-john-boehner-s-remarks-at-economic-club-o -washington-20110915 See also Eric Cantor, Memo on Upcoming Jobs Agenda. (Aug. 29, 2011).18 Since 2007, the Bureau o Labor Statistics has asked rms that have had a mass layoff the reasons behind these layoffs. Only 0.2% to 0.4% o allmass layoffs were due to government regulation, as reported by the rms. Bureau o Labor Statistics (2012) Extended Mass Layoffs in 2011. UnitedStates Department o Labor, Report 1039. Also, randomized surveys o small business owners show that at most, 25% o small business owners areconcerned about excessive government regulation. See also American Sustainable Business Council et al . (2012) Small Business Owners Opinionson Regulations and Job Creation (1 Feb). Hall, Kevin (2011) Regulation, axes Arent Killing Small Business, Owners Say, McClatchy Newspapers(Sept. 1). Dunkelberg, William C., and Holly Wade (2011) NFIB Small Business Economic rends (August).19 Center or Progressive Re orm Saving Lives, Preserving the Environment, Growing the Economy: Te ruth about Regulation. (July 2011).20 Manu acturers o Emission Controls Association, MECA Highlights Economic Benets o Mobile Source Emission Control Industry. (March2011). http://www.meca.org/galleries/les/MECA_economic_benets_press_release_031111.pd .See also Institute o Clean Air Companies Re: New Source Review Impact on Air Pollution Control (APC) Industry. (February 2004). http://www.icac.com/?page=jobs&terms=%22re+and+new+and+source+and+review+and+impact+and+air+and+pollution+and+cont%22 .21 Institute o Clean Air Companies. September 2013. Available at http://c.ymcdn.com/sites/www.icac.com/resource/resmgr/market_ orecast/press_release_2013_market_ o.pd . 22 A job-year is one job or one year. See http://www.whitehouse.gov/assets/documents/Job-Years_Revised5-8.pd .23 Economic Policy Institute, Regulation, Employment, and the Economy: Fears o job loss are overblown. (April 12, 2011). Available at http://www.epi.org/publication/regulation_employment_and_the_economy_ ears_o _job_loss_are_overblown/ . 24 Berman and Bui. (2001) Environmental Regulation and Labor Demand: Evidence rom the South Coast Air Basin, Journal of Public Economics 79: 265-95.

Overall, the collective estimated impact of these rules on jobs is to slightlyincrease the overall number of jobs, as a result of increased labor demand tocomply with the rules.
http://www.nationaljournal.com/congress/text-john-boehner-s-remarks-at-economic-club-of-washington-20110915http://www.nationaljournal.com/congress/text-john-boehner-s-remarks-at-economic-club-of-washington-20110915http://www.meca.org/galleries/files/MECA_economic_benefits_press_release_031111.pdfhttp://www.icac.com/?page=jobs&terms=%22re+and+new+and+source+and+review+and+impact+and+air+and+pollution+and+cont%22http://www.icac.com/?page=jobs&terms=%22re+and+new+and+source+and+review+and+impact+and+air+and+pollution+and+cont%22http://c.ymcdn.com/sites/www.icac.com/resource/resmgr/market_forecast/press_release_2013_market_fo.pdfhttp://c.ymcdn.com/sites/www.icac.com/resource/resmgr/market_forecast/press_release_2013_market_fo.pdfhttp://www.whitehouse.gov/assets/documents/Job-Years_Revised5-8.pdfhttp://www.epi.org/publication/regulation_employment_and_the_economy_fears_of_job_loss_are_overblown/http://www.epi.org/publication/regulation_employment_and_the_economy_fears_of_job_loss_are_overblown/http://www.epi.org/publication/regulation_employment_and_the_economy_fears_of_job_loss_are_overblown/http://www.epi.org/publication/regulation_employment_and_the_economy_fears_of_job_loss_are_overblown/http://www.whitehouse.gov/assets/documents/Job-Years_Revised5-8.pdfhttp://c.ymcdn.com/sites/www.icac.com/resource/resmgr/market_forecast/press_release_2013_market_fo.pdfhttp://c.ymcdn.com/sites/www.icac.com/resource/resmgr/market_forecast/press_release_2013_market_fo.pdfhttp://www.icac.com/?page=jobs&terms=%22re+and+new+and+source+and+review+and+impact+and+air+and+pollution+and+cont%22http://www.icac.com/?page=jobs&terms=%22re+and+new+and+source+and+review+and+impact+and+air+and+pollution+and+cont%22http://www.meca.org/galleries/files/MECA_economic_benefits_press_release_031111.pdfhttp://www.nationaljournal.com/congress/text-john-boehner-s-remarks-at-economic-club-of-washington-20110915http://www.nationaljournal.com/congress/text-john-boehner-s-remarks-at-economic-club-of-washington-20110915


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environmental regulations was not correlated with changes in employment levels across our sectors o industry

rom 1979 to 1991. 25 Official data rom the Bureau o Labor Statistics additionally illustrates this point with data

rom their extended mass layoffs program. From 2007 to 2012, the bureau asked employers who have had mass

layoffs the reasons or those layoffs. During this time period, only 0.2 percent to 0.4 percent o all mass layoffs

were reported as due to government regulation. 26 Given these pieces o evidence and numerous other studies, it

is clear that the overall effect o regulation on jobs is minimal.

REPORT METHODOLOGYTis report examined the regulatory impact analyses o ten rules that were proposed or nalized between

2009 and 2014. o provide a broad scope o ederal agencies and public protections, rules issued by ve ederal

agencies covering a variety o public and worker health and sa ety issues were selected or review. In ormation

on the rule costs and benets, as well as unquantiable or non-monetized benets and economic impacts, was

obtained rom the proposed or nal rules as published in the Federal Register or rom the regulatory impactanalysis document prepared by the agency in conjunction with development o the rule. Annualized costs over

time using a seven percent discount rate and annualized benets over time based on a three percent discount

rate are included in this report where both rates were provided, unless otherwise noted. Point estimates and

midpoint values were reported and used in calculations i they were given. Otherwise, ranges were used.

In calculating the total impact o the rules, all dollar amounts were converted to 2014 values using the GDP

deator. 27 Te National Ambient Air Quality Standards or Particulate Matter rule was excluded rom the cost

and benet totals in order to avoid double-counting the costs and benets associated with the reduction o

particulate matter rom other rules examined. 28

For proposed rules with multiple regulatory options or calculation methodologies, the lowest cost/benet value

o all options was used as the low end o the cost and benet ranges. Similarly, the highest cost/benet value o

all options was used as the high end o the cost and benet ranges. Te net benet o the option with the lowest

net benet was used as the amount or the low end o the net benet range, and the net benet o the option with

the highest net benet was used as the value or the high end o the net benet range. otal low and high endcosts, economic benets, and net benets were calculated by summation o individual low and high end costs,

economic benets, and net benets or each o the nine rules in the combined analysis.

25 Morgenstern, et al. (2002) Jobs Versus the Environment: An Industry-Level Perspective, Journal of Environmental Economics and Management 43: 412-36.26 Bureau o Labor Statistics, Mass Layoff Statistics. Available athttp://www.bls.gov/mls/ . See also Economic Policy Institute, A Quick guide to theEvidence on Regulations and Jobs. (Nov. 22, 2011). Available at http://www.epi.org/publication/quick-guide-evidence-regulations-jobs/ .27 GDP deator calculator. Available at http://stats.areppim.com/calc/calc_usdlrxdeator.php . 28 Tis approach was used in OMBs 2014 draf annual report to Congress. OMB, 2014 Draf Report to Congress on the Benets and Costs o FederalRegulations and Un unded Mandates on State, Local, and ribal Entities. (May, 2014). Available at http://www.whitehouse.gov/sites/de ault/les/omb/in oreg/2014_cb/draf_2014_cost_benet_report-updated.pd .
http://www.bls.gov/mls/http://www.epi.org/publication/quick-guide-evidence-regulations-jobs/http://stats.areppim.com/calc/calc_usdlrxdeflator.phphttp://www.whitehouse.gov/sites/default/files/omb/inforeg/2014_cb/draft_2014_cost_benefit_report-updated.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/2014_cb/draft_2014_cost_benefit_report-updated.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/2014_cb/draft_2014_cost_benefit_report-updated.pdfhttp://www.whitehouse.gov/sites/default/files/omb/inforeg/2014_cb/draft_2014_cost_benefit_report-updated.pdfhttp://stats.areppim.com/calc/calc_usdlrxdeflator.phphttp://www.epi.org/publication/quick-guide-evidence-regulations-jobs/http://www.bls.gov/mls/


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FINDINGSWhen ully implemented, these rules will result in over 10,000 ewer deaths and almost 300,000 avoided disease

cases, illnesses, or injuries each year.29 Based on the benet-cost analyses prepared or these rules, the monetized

societal benets are expected to be between $60 billion and $138 billion, while the total annual compliance costs

are estimated to be $14 billion to $16 billion, generating a net monetized benet to society o between $46 billionto $122 billion. As noted in able 1, nine o the ten regulations projected greater monetized social benets than

compliance costs. Te one rule with a negative net benet, EPAs proposed Effluent Limitations Guidelines rule,

is projected to result in a multitude o signicant ecological and health impacts critical to protecting public

health and conserving sensitive ecosystems, but agency analysts were unable to quanti y and monetize these

benets.

Tese rules will prevent a signicant number o diseases, injuries, deaths, and lost worker productivity.

Additionally, substantial improvements in ecosystems, the climate, and the publics health and wel are will also

result rom these rules but cannot be adequately monetized. able 2 summarizes the unquantiable benets

associated with ve o the rules that provided this in ormation. Overall, the total benets substantially outweigh

their costs, and this net benet would be even greater i all the benets that are projected to accrue rom these

rules were able to be monetized.

29 Includes data only rom rules or which annual benets were available.


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Table 1. Annual Monetized Benefts, Costs, Net Benefts,and Economic Impacts o Ten Rules (2014$)

Rule Estimated AnnualMonetized Benefts*Estimated Annual

Compliance Costs**Estimated Annual

Net Benefts

EstimatedEconomic or Jobs

Impact

Occupational Exposureto Respirable Crystalline

Silica OSHA, proposed9/12/2013

$5.65 billion $707.6 million $4.94 billion Increase o 8,625 job-years rom 2014

- 2023

Federal Motor VehicleSa ety Standards,Ejection Mitigation

NHTSA, fnalized1/19/2011

$2.45 billion $545.2 million $1.91 billion No impact on smallbusinesses, smallorganizations,small governmental

jurisdictions, andsmall vehiclemanu acturers

Federal Motor VehicleSa ety Standards;Electronic StabilityControl Systems orHeavy Vehicles

NHTSA, proposed5/23/2012

$363.3 million to$449.3 million

$120.7 million $242.3 million to$329.4 million

No impact on smallbusinesses, smallorganizations,small governmental


Nutrition Labelingo Single-IngredientProducts and Groundor Chopped Meat and

Poultry Products FSIS, fnalized12/29/2010

$115.4 million $13.8 million $101.7 million No signifcantimpact on asubstantial numbero small entities

National Ambient AirQuality Standards orParticulate Matter

EPA, fnalized1/14/2013

$4.25 billion to $9.67billion

$56.3 million to $371.9million

$3.93 billion to$9.56 billion

Mercury and Air ToxicsStandards



$10.6 billion $29.8 billion to$88.4 billion

Increase o 8,000long-term jobs

Increase o 46,000 job-years in shortterm

Slight increase inutility rates

Potential signifcantimpact on smallentities


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Control o Air Pollutionrom Motor Vehicles: Tier3 Motor Vehicle Emissionand Fuel Standards



$1.6 billion(No discount)


Negligible increasein product andpossible consumercosts

Negligible decreasein vehicle sales

Small jobs impact

Potential signifcantimpact on smallentities.

Hazardous and SolidWaste ManagementSystem; Identifcationand Listing o SpecialWastes; Disposal o CoalCombustion ResidualsFrom Electric Utilities

EPA, proposed

6/21/2010

$1.1 billion to $7.96billion (7% discount)

$253.8 million to $1.59billion

$821.6 million to$6.15 billion

Less than 1%increase inelectricity prices

No signifcantimpact on smallbusinesses

E uent LimitationsGuidelines and Standardsor the Steam ElectricPower Generating PointSource Category

EPA, proposed6/7/2013

$148.1 million to $512.7million

$174.8 million to$971.9 million

-$459.2 million to-$26.7 million

Increase o 168 to865 jobs

Minimal ornegligible impactson electricity market

Increase inconsumer costs rom1 cent to $3.89

*Based on 3% discount rate**Based on 7% discount rate


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Table 2. Unquantifable (and Non-monetized) Benefts o Five Rules

Rule Benefts

National Ambient Air QualityStandards or Particulate Matter

EPA, fnalized 1/14/2013

Improved visibility Improved ecosystem health Reduction o negative e ects on climate Reduction o other adverse health e ects

Mercury and Air Toxics Standards EPA, fnalized 2/16/2012

Improved visibility Improved ecological health Reduction o other neurological e ects o mercury Reduction o non-neurological adverse health e ects o mercury Reduction o health e ects due to ozone and direct exposure to sul ur

dioxide and nitrogen dioxide Reduction o health e ects rom commercial and non- reshwater fsh

consumption Reduction o health risks rom exposure to non-mercury hazardous air

pollutants

Control o Air Pollution rom MotorVehicles: Tier 3 Motor VehicleEmission and Fuel Standards

EPA, fnalized 4/28/2014

Improved visibility Improved ecological and vegetation health Reduction in materials damage Reduction o negative e ects on climate

Hazardous and Solid WasteManagement System; Identifcationand Listing o Special Wastes;Disposal o Coal CombustionResiduals From Electric Utilities

EPA, proposed 6/21/2010

Prevention o non-cancer health e ects Prevention o ambient air pollution Ecological protection Sur ace water protection

E uent Limitations Guidelines andStandards or the Steam ElectricPower Generating Point SourceCategory

EPA, proposed 6/7/2013

Human health benefts Reduced e ects rom exposure to lead rom fsh consumption Reduced health e ects rom pollutants in recreational water

Ecological benefts Reduced sediment contamination Reduced bioaccumulation o metals Reduction o other sub-lethal chronic e ects o toxic metals on aquatic li e Reduced adverse e ects on wildli e population diversity and community

dynamics Reduction o potential or the ormation o hazardous algal blooms Enhanced recovery o endangered species vulnerable to change in water

quality

Market benefts Reduced water treatment costs Improved commercial fsheries yields Increased tourism and water-based recreation Increased property values rom water quality improvement


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wo o these rules, Mercury and Air oxics Standards and ier 3 Motor Vehicle Emission and Fuel Standards,

have the potential to affect small businesses. One rule, Prevention o Salmonella in Shell Eggs, will signicantly

impact small business chicken armers, but this is due to the act that the majority o egg arms all under

the legal denition o a small business, even though most are part o a large-scale poultry processing and

distribution system. Tree rules may slightly increase consumer costs, but the increases are either minimal or

negligible. Effluent Limitations Guidelines have the potential to slightly increase jobs, while compliance with

Mercury and Air oxics Standards has the potential to add almost 50,000 short-term job-years and 8,000 long-

term jobs. Data on job impacts were not available or every rule.

Tese results contribute to the body o evidence showing that the costs o regulations pale in comparison to

the magnitude o the societal benets they provide, even given the limitations o current benet-cost analysis

practices, which generally overestimate the costs o regulations and underestimates their benets. Tis

observation is especially signicant given that unquantied and non-monetized benets also substantially

contribute to the societal benets o a regulation.

CONCLUSIONTe rules examined in this report represent only a ew examples o the obvious benets that society receives

rom public standards and sa eguards. Moreover, some regulations may actually result in a small net increase in

jobs. In our modern, globalized world, we should expect to see the decline or phase-out o some industries as

technological innovation and the human imagination create new growth areas. Workers in declining industries

need to be aided in the transition to new kinds o jobs, but society has a clear interest in encouraging cleaner

orms o energy and sa er products. Tese priorities receive broad public support in survey afer survey.30

Public rulemaking is the way we operationalize these priorities. Te process o rulemaking allows us to gather

new scientic evidence and the input o affected industries, workers, and citizens to weigh the risks and

rewards o various paths orward. Te in ormation that goes into our assessments is imper ect, but the only

institution in society with the mission and capacity to protect the common good is government. Te processes

o democratic deliberation and governance are our best hopes or ensuring that the public interest prevails.30 Seehttp://environment.yale.edu/climate-communication/les/Climate-Policy-Support-April-2013.pd and http://pos.org/documents/12368_national_key_ndings_nal.pd as examples.

Te costs of regulations pale in comparison to the magnitude of thesocietal benets they provide, even given the limitations of currentbenet-cost analysis practices, which generally overestimate the costsof regulations and underestimates their benets.
http://environment.yale.edu/climate-communication/files/Climate-Policy-Support-April-2013.pdfhttp://pos.org/documents/12368_national_key_findings_final.pdfhttp://pos.org/documents/12368_national_key_findings_final.pdfhttp://pos.org/documents/12368_national_key_findings_final.pdfhttp://pos.org/documents/12368_national_key_findings_final.pdfhttp://environment.yale.edu/climate-communication/files/Climate-Policy-Support-April-2013.pdf


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APPENDIX A SUMMARY OF RULES EXAMINEDProposed Rule: Occupational Exposure to Respirable Crystalline Silica

Agency: Occupational Sa ety and Health Administration (OSHA)

Date Proposed: September 12, 2013

Te current permissible exposure level or crystalline silica in occupational settings, adopted in 1971 based on

now-obsolete methods, ranges rom 50 g/m 3 to 250 g/m3 depending on the industry and the orm o silica.

Exposure to silica at levels below these standards leads to a signicant increased risk o lung cancer, silicosis,

kidney disease, autoimmune disease, chronic obstructive pulmonary disease, and other respiratory diseases.

Tis proposed rule will lower the current permissible exposure level to 50 g/m 3 or all types o crystalline

silica in order to reduce the signicant health risks that workers currently ace rom exposure to silica. Te

proposal provides or improved worker protections through the use o exposure controls, exposure assessments,

respiratory protection, medical surveillance, hazard communication, and record keeping.

Te yearly projected compliance costs total $708 million, with midpoint estimated monetized benets totaling

$5.7 billion, resulting in a net monetized benet o $5 billion. Tese monetary benets reect substantial annual

reductions in silica-related disease. Tese include 1,585 cases o moderate to severe silicosis, 162 cases o lung

cancer, 151 cases o end-stage renal disease, and 375 cases o silicosis and other respiratory disease, totaling 688

atal illnesses that will be prevented each year. Additionally, there may be a slight increase in jobs.31

Not only willthis proposed rule lead to a large net monetary benet, but it will also reap signicant benets in public health

through the prevention o numerous diseases.

Occupational Exposure to Silica

Annual Monetized Benefts, Compliance Costs, and Estimated Jobs Impact (2014$)Estimated Monetized

Benefts (3% discount)

Estimated Compliance

Costs (7% discount)Estimated Net Benefts Estimated Jobs Impact

$5.65 billion $707.6 million $4.94 billionIncrease o 8,625 job-years

rom 2014-2023

31 Occupational Sa ety and Health Administration, Occupational Exposure to Respirable Crystalline Silica. F.R. 2013-20997 (Sept. 12, 2013).Available at http://www.regulations.gov/#!documentDetail;D=OSHA-2010-0034-1721 .
http://www.regulations.gov/#!documentDetail;D=OSHA-2010-0034-1721http://www.regulations.gov/#!documentDetail;D=OSHA-2010-0034-1721http://www.regulations.gov/#!documentDetail;D=OSHA-2010-0034-1721http://www.regulations.gov/#!documentDetail;D=OSHA-2010-0034-1721


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Monetized Benefts

Cases Annual Number o Cases Prevented Total Number o Cases Preventedover a 45-Year Working Li etime

Lung Cancers High Midpoint Low

271162

53

12,1737,2892,404

Silicosis & Other Non-MalignantRespiratory Diseases 375 16,878

End-Stage Renal Disease 151 6,774

Total Number o Fatal IllnessesPrevented High Midpoint Low

796

688

579

35,82530,94026,055

Total Number o Moderate to SevereSilicosis Cases Prevented 1,585 71,307

Final Rule: Federal Motor Vehicle Safety Standards, Ejection Mitigation

Agency: National Highway raffic Sa ety Administration (NH SA)

Date Finalized: January 19, 2011

An average o about 10,000 deaths rom rollover car crashes occur each year, making rollover crashes second

only to rontal crashes, which average 11,600 deaths annually, as the leading source o crash atalities in light

vehicles. Tough rollover crashes result in ewer annual atalities than rontal crashes, occupants in a rollover

crash are 14 times more likely to be killed than those who are in a rontal crash. Tis higher risk o death is dueto ejection rom the vehicle. From 2000-2009, 47 percent o people who were killed in rollover crashes were

completely ejected rom their vehicles. Tis rule will prevent an estimated 373 atalities and 476 injuries each

year by reducing partial or complete ejection o occupants through side windows in rollover and other crashes.

o comply with this rule, the agency expects that cars will include side curtain air bags that will cover more

o the window opening, remain inated longer, be employed in side impacts and rollovers, and be made to

both cushion and prevent ejection, regardless o the position or presence o the window glazing. Te estimated

compliance costs total $545 million a year, while the projected yearly monetized benets total $2.5 billion, with

a net monetized benet o $1.9 billion. Furthermore, there will be no signicant economic impact on small

businesses or small vehicle manu acturers. 32 Tis rule will generate large net monetized benets while saving

lives through the reduction o occupant ejection in rollover and other crashes.

32 National Highway raffic Sa ety Administration, Federal Motor Vehicle Sa ety Standards, Ejection Mitigation. F.R. 2013-21605 (Feb. 25, 2011).Available at http://www.regulations.gov/#!documentDetail;D=NH SA-2011-0004-0001 .
http://www.regulations.gov/#!documentDetail;D=NHTSA-2011-0004-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2011-0004-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2011-0004-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2011-0004-0001


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Federal Motor Vehicle Sa ety Standards, Ejection Mitigation

Annual Monetized Benefts, Compliance Costs, and Estimated Economic Impact (2014$)Estimated Monetized

Benefts (3%discount)

EstimatedCompliance Costs

(7% discount)

Estimated NetBenefts

Estimated QuantifedBenefts

Estimated EconomicImpact

$2.45 billion $545.2 million $1.91 billion Fatalities prevented:373

Serious injuriesprevented: 476

No impact on smallbusinesses, smallorganizations,small governmental


Proposed Rule: Federal Motor Vehicle Safety Standards; Electronic Stability Control Systems for Heavy

Vehicles

Agency: National Highway raffic Sa ety Administration (NH SA)

Date Proposed: May 23, 2012

Every year, crashes involving tractor trailer combination vehicles contribute to 72 percent o atal crashes

involving large trucks. O the 150,000 annual crashes associated with these vehicles, 29,000 o them involve

injury. raffic resulting rom these crashes also leads to the loss o millions o dollars through lost productivity

and excess energy consumption. Tis proposed rule would reduce the number o heavy vehicle crashes by

requiring electronic stability control systems on truck tractors and certain buses that have a gross vehicle weight

o greater than 26,000 pounds. An electronic stability control system uses automatic computer-controlled

braking and engine torque control to correct severe understeer or oversteer that leads to loss o control o the vehicle.

Te agency estimates that this rule will prevent 1,807 to 2,329 crashes, 649 to 858 injuries, 49 to 60 atalities, and

1,187 to 1,499 crashes resulting in only property damage each year. Te annual cost o installing an electronic

stability control system or upgrading a similar system or affected vehicles is estimated to be $121 million, while

the benets incurred each year include $363 million to $449 million in the monetized benets o preventing

injuries, property damage, and travel delays. Tis results in an annual net monetized benet o $242 million to

$329 million. Tere will be no impact on small entities as a result o this rule. 33 Requiring electronic stability

control systems on these vehicles will generate signicant net benets rom the prevention o injury, property

damage, travel delays, and atalities.

33 National Highway raffic Sa ety Administration, Federal Motor Vehicle Sa ety Standards; Electronic Stability Control Systems or Heavy Vehicles.F.R. 2012-12212 (May 23, 2012). Available athttp://www.regulations.gov/#!documentDetail;D=NH SA-2012-0065-0001 .
http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001http://www.regulations.gov/#!documentDetail;D=NHTSA-2012-0065-0001


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resulting rom the use o the nutritional in ormation. Small businesses that employ statements o percent at

and percent lean on the label o their ground products are exempt rom this rule i they do not make any other

nutrition claims or include other nutrition in ormation on the product labels. Tis exemption ensures that

small businesses that produce a low amount o the product do not risk going out o business or reducing their

consumers options in order to comply with the rule. With the exemption, this rule will generate $102 million in

net monetized benets without a signicant impact on small businesses. 35

Nutrition Labeling o Single-Ingredient Productsand Ground or Chopped Meat and Poultry Products

Annual Monetized Benefts, Compliance Costs, and Estimated Economic Impact (2014$)Estimated Monetized



(7% discount)


EstimatedQuantitative Benefts


$115.4 million $13.8 million $101.7 million Prevention o : 5.5 deaths rom

breast cancer 7.2 deaths romprostate cancer

10.8 deaths romcolorectal cancer

97.8 deaths romcoronary heartdisease

No signifcant impacton a substantial

number o smallentities

Final Rule: Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and

TransportationAgency: Food and Drug Administration (FDA)

Date Finalized: July 9, 2009

Salmonella Enteritidis (SE) is one o the most common causes o oodborne illness in the United States.

In ection with Salmonella leads to diarrhea, ever, abdominal cramps, headache, nausea, and vomiting, and

may subsequently lead to hospitalization. In vulnerable populations, such as children, the elderly, and those

with a weak immune system, in ection can cause death afer spreading to the bone marrow or brain lining via

the bloodstream. In addition, two percent o those who recover rom in ection may develop reactive arthritisor recurring joint pain later on as a result o in ection. In 2004, there were 1,376,514 cases o salmonellosis,

resulting in 14,264 hospitalizations and 427 deaths. SE, the most common type o Salmonella contributing

to disease, led to 193,463 illnesses, 2,004 hospitalizations, and 60 deaths in 2001. Seventy-eight percent o

SE outbreaks where a contamination origin was identied were due to eggs. Since shell eggs are the primary

source through which humans contract SE, this rule will reduce the risk that eggs are contaminated with SE35 Food Sa ety and Inspection Service, Nutrition Labeling o Single-Ingredient Products and Ground or Chopped Meat and Poultry Products. F.R.2010-32485 (Dec. 29, 2010). Available athttp://www.regulations.gov/#!documentDetail;D=FSIS-2005-0018-0036 .
http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018http://www.regulations.gov/#!documentDetail;D=FSIS-2005-0018-0036http://www.regulations.gov/#!documentDetail;D=FSIS-2005-0018-0036http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018http://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018


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by establishing programs regarding biosecurity, pest control, environmental and egg testing, re rigeration and

storage practices, and the diversion o potentially in ected eggs rom the market. Te rule additionally requires

producers to register with the FDA and maintain records regarding compliance.

Since some o the controls outlined in the rule, especially rodent and pest control measures, will take up to

our years to become ully effective, cost and benet estimates were examined or two time rames: an initial

time rame assuming average effectiveness over the rst our years, and an eventual time rame assuming ull

effectiveness afer our years. Tis rule will prevent 68,790 illnesses initially and 79,170 illnesses when ully

implemented. Compliance costs are estimated to be $103 million a year initially and $95 million when ully

implemented, while monetized benets are projected to be $1.4 billion initially, eventually reaching $1.7 billion,

resulting in a net initial monetary benet o $1.3 billion and an eventual monetary benet o $1.6 billion.

Exempt rom this rule are producers who have ewer than 3,000 layers (egg-producing chickens) and producers

who sell all their eggs directly to consumers. Tis exemption reduces costs by more than hal while only reducingbenets by less than one percent. Although over 90 percent o producers have ewer than 3,000 layers, less

than one percent o the eggs produced in the U.S. are produced on these small arms. Tere ore, exempting

these small arms signicantly reduces costs while maintaining both monetary and health benets. Other small

entities, such as small chick and pullet armers, trucking companies, and holding acilities, will be affected by

this rule. However, the exemption or arms with ewer than 3,000 layers saves cost or these entities as well, since

they will not be required to comply with the rule when dealing with eggs produced on these arms. 36 Tis rule

contains costs while generating signicant net monetary benets and preventing tens o thousands o illnesses.

36 Food and Drug Administration, Prevention o Salmonella Enteritidis in Shell Eggs During Production, Storage, and ransportation. F.R. E9-16119(July 9, 2009). Available athttp://www.regulations.gov/#!documentDetail;D=FDA-2000-N-0190-0018 .
http://www.regulations.gov/#!documentDetail;D=FSIS-2005-0018-0036http://www.regulations.gov/#!documentDetail;D=FSIS-2005-0018-0036


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Prevention o Salmonella Enteritidis in Shell EggsDuring Production, Storage, and Transportation

Annual Monetized Benefts, Compliance Costs, and Estimated Economic Impact (2014$)

Time rame

EstimatedMonetized


EstimatedCompliance

Costs (7%discount)


EstimatedQuantifed

Benefts

EstimatedEconomic Impact

Initially $1.44 billion $102.9 million $1.34 billion 68,790 illnessesaverted

Signifcant impacton more than1,000 small armsand other entitiessuch as smallchick and pulletarms, truckingcompanies, andholding acilities

Eventually $1.66 billion $94.7 million $1.56 billion 79,170 illnessesaverted

Final Rule: National Ambient Air Quality Standards for Particulate Matter

Agency: Environmental Protection Agency (EPA)

Date Finalized: January 14, 2013

Tis rule revises the previous primary health-based standard or particulate matter or PM 2.5 (particles less

than or equal to 2.5 micrometers (m) in diameter) rom 15.0 g/m 3 to 12.0 g/m3 in order to protect public

health and wel are rom the adverse effects o outdoor air pollution. Long- and short-term exposure to high

levels o outdoor air pollution leads to numerous health effects, such as premature mortality, increased hospital

admissions and emergency room visits, and chronic respiratory diseases. Tis revised standard incorporatesnew scientic evidence that includes extended analyses and supporting evidence that the adverse health effects

associated with PM 2.5 exposure to air pollution occur at levels that are lower than the previous standard. Te

revised standard additionally provides increased protection or at-risk populations, such as children, older

adults, and people with pre-existing heart and lung disease. When ully implemented, this revised standard will

prevent up to 1,000 deaths, 480 heart attacks, 250 hospital admissions or respiratory and heart disease, 230

asthma-related emergency room visits, and 40,000 asthma attacks in children each year, among other important

avoided health impacts.

Te costs and benets o this rule were estimated using two methodologies: the xed-cost methodology,

which assumes that controls used in the uture will have a similar cost to those used currently, and the

hybrid methodology, which assumes that uture controls will be available at an increasing cost. Te xed-

cost methodology resulted in the lower estimate and the hybrid methodology resulted in the higher estimate.

With these methods, the compliance costs were estimated to range rom $56 million to $372 million, while

the monetized benets were estimated to be between $4.3 billion to $9.7 billion. Tese estimates result in net
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0492-10110http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0492-10110


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monetary benets o $3.9 billion to $9.6 billion, in addition to tens o thousands o health effects avoided.

Benets that were not able to be quantied, such as improvements in visibility, ecosystem health, public health,

and climate change mitigation, urther contribute to the benets gained rom this rule.

Given the body o scientic literature concluding that air quality regulation has a negligible overall effect on

jobs, this rule is not expected to have a signicant impact on the overall economy. Furthermore, since this rule

is the revision o a national standard, the compliance control measures to be taken to meet this standard are

under the jurisdiction o state and local governments, giving them ultimate responsibility or assessing and

mitigating any negative economic impacts at the state or local levels, depending on the control measures they

choose to implement. 37 Tis revision strengthens protections or public health in a way that reaps very signicant

monetized benets relative to compliance costs, even without the inclusion o substantial, meaning ul benets

that were unable to be quantied.

National Ambient Air Quality Standards or Particulate Matter

Annual Monetized Benefts, Compliance Costs, and Unquantifed Benefts (2014$)

Methodology

EstimatedMonetized


EstimatedCompliance

Costs (7%discount)

Estimated NetBenefts (3%

discount)

Estimated Quantifed Benefts

Health Cases Avoided

UnquantifedBenefts

Fixed-cost $4.25 billion $56.32 million $3.93 billion Adult mortality: 460-1,000 Non- atal heart attacks, age>18:

52-480 Hospital admissions

respiratory, all ages: 110

Hospital admissions cardiovascular, age >18: 140 ER asthma visits, all ages: 230 Acute bronchitis, age 8-12: 870 Lower respiratory symptoms,

age 7-14: 11,000 Upper respiratory symptoms,

asthmatics age 9-11: 16,000 Asthma exacerbation, age 6-18:

40,000 Lost work days, age 18-65:

71,000 Minor restricted-activity days,

age 18-65: 420,000

Improvements in: Visibility Ecosystem

health Public health

Climatechangemitigation

Hybrid $9.67 billion $371.9 million $9.56 billion

37 Environmental Protection Agency, National Ambient Air Quality Standards or Particulate Matter.F.R. 2012-30946 (Jan. 14, 2013) Available athttp://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0492-10110 .


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Final Rule: Mercury and Air Toxics Standards

Also known as: National Emission Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric

Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-

Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units

Agency: Environmental Protection Agency

Date Finalized: February 16, 2012

Tis rule protects public health by establishing emissions standards or hazardous air pollutants that are

produced by coal- and oil-red power plants. Exposure to hazardous pollutants, such as mercury (Hg), hydrogen

chloride, hydrogen uoride, selenium, arsenic, nickel, and others, leads to numerous adverse health effects.

Depending on the degree o exposure, the health effects can include nausea, vomiting, central nervous system

damage, kidney damage, and lung, skin, and mucus membrane damage. Arsenic and hexavalent chromium

are classied as human carcinogens, or cancer-causing agents. wo other pollutants, cadmium and nickel, are

classied as probable human carcinogens. When ully implemented, this rule will prevent between 4,200 and11,000 adult deaths, 20 in ant deaths, 2,800 cases o chronic bronchitis, 4,700 heart attacks, more than 2,600

hospital admissions or lung and heart disease, 3,100 emergency room visits by children with asthma, and

130,000 asthma attacks in children each year, among other health impacts.

Te electric power industry is the largest source o a number o hazardous air pollutants, particularly mercury.

Exposure to mercury in children has been linked to adverse neurodevelopment effects, including impairment o

brain unction assessed using intelligence quotient (IQ) measurements. Te controls that will be implemented to

comply with these mercury emission standards will also reduce the emissions o ne particles (PM 2.5) and sul urdioxide, generating signicant co-benets. While the compliance costs o implementing this rule are estimated

to be $10.6 billion, the monetized benets are expected to be between $41 billion to $99 billion, generating a net

monetary benet o $30 billion to $88 billion. $40 billion to $98 billion o these benets are due to the co-benet

o PM 2.5 reduction. Additional benets that could not be monetized include those related to visibility, reduction

o other neurological effects o mercury, non-neurological health effects o mercury, effects o ozone and direct

exposure to sul ur dioxide and nitrogen dioxide, health effects rom less consumption o mercury-tainted sh,

health risks rom non-mercury air pollutants, and reduced damage to ecosystems.

Tis rule will have a number o potential impacts on jobs, electricity costs, and small businesses. In the short

term, due to the high demand or new pollution control equipment, 46,000 job-years are expected to be created.

In the long term, it is estimated that this rule will result in an increase o 8,000 jobs, the central estimate o a

range between an estimated loss o 15,000 jobs to an estimated gain o 30,000 jobs.


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In 2016, natural gas prices are expected to increase by less than one percent and electricity rates are expected to

increase about three percent. Tis three percent is equal to the average change expected in electricity rates each

year. In the past 50 years, annual changes in electricity rates have uctuated broadly by as much as 23 percent.

Electricity rates in 2015 and 2020 are projected to be lower than in 2010, even with implementation o this rule.

Te increase in utility costs that could result rom this rule is estimated to be small and near the historical yearly

average rate change.

Tough this rule may raise utility costs, the exibility in compliance options outlined in the rule allow or

implementation in a manner that will maximize benets and contain costs or both small and large businesses.

Te signicant amount o monetary, health, and unquantied benets this rule will produce and the potential it

holds or job creation more than justi y the compliance costs. 38

Mercury and Air Toxics Standards

Annual Monetized Benefts, Compliance Costs, and Estimated Economic Impact (2014$)EstimatedMonetized

Benefts


(7% discount)


(3% discount)Unquantifed Benefts Estimated EconomicImpact



Improved visibility Improved ecological health Reduction o other

neurological e ects o Hg Reduction o non-

neurological adverse healthe ects o Hg

Reduction o health e ectsdue to ozone and directexposure to sul ur dioxideand nitrogen dioxide

Reduction o health e ectsrom commercial and non-reshwater fsh consumption

Reduction o health risksrom exposure to non-mercury hazardous airpollutants

-15,000 to +30,000 long-term jobsCentral estimate: +8,000

jobs

+46,000 job-yearscreated in the short term

Average 3.1% increase inelectricity rates in 2016Range: 1.3% to 6.3%

Less than 1% increase innatural gas prices in 2016

Potential signifcantimpact on substantialnumber o small entities

Monetized Benefts Components (3% discount) (2014$)Partial Hg-related benefts $4.42 million to $6.63 million

PM2.5-related co-benefts $39.78 billion to $98.33 billion

Climate-related co-benefts $397.8 million

38 Environmental Protection Agency, National Emission Standards or Hazardous Air Pollutants From Coal- and Oil-Fired Electric UtilitySteam Generating Units and Standards o Per ormance or Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, andSmall Industrial-Commercial-Institutional Steam Generating Units. F.R. 2012-00806 (Feb. 16, 2012). Available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-20147 .
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-20147http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-20147http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-20147http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-20147


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Monetized Benefts

Estimated Reductions in Mercury and PM2.5-Related Health E ects in 2016Health E ect Cases Reduced

Point Estimate Range

Adult premature mortality Pope et al., (2002) (age >30)

Laden et al., (2006) (age >25)

4,200

11,000

1,200 to 7,200

5,000 to 17,000

In ant premature mortality (18) 4,700 1,200 to 8,300

Hospital admissions respiratory (all ages) 830 330 to 1,300

Hospital admissions cardiovascular (age >18) 1,800 1,200 to 2,200

Emergency room visits or asthma (age


30/406

monetized benets. Te projected costs o compliance via changing technology, design, and production total

$1.6 billion, while the monetary benets rom improved health total $7.7 billion to $19.8 billion. Tus, the

net benets o this rule are estimated to be $6.2 billion to $18.8 billion, which do not include the numerous,

signicant benets that were unable to be quantied, such as improvements in air visibility and reductions in

material, ecological, vegetation, and climate damage.

As a result o this rule, the costs o production in vehicle manu acturing and petroleum rening industries

will slightly increase, and this increase may be passed on to consumers. I consumer costs increase, sales may

decline. However, these changes in price and sales are small and negligible in both the short and long term.

Although the jobs impact was unable to be determined, it is expected to be small and insignicant since the

changes in costs and sales are negligible. Because this rule applies to all cars sold in the U.S. regardless o where

they are produced, it does not create an incentive or manu acturers to move their production overseas. 39 While

the economic impacts o this rule will be negligible, the net monetary, quantied, and numerous unquantied

benets generate signicant economic gain and protections or public health.

Control o Air Pollution rom Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards

Annual Monetized Benefts, Compliance Costs, and Estimated Economic Impact (2014$)

EstimatedMonetized

Benefts

EstimatedCompliance

Costs (Nodiscount)


EstimatedQuantifed Benefts

Cases prevented

UnquantifedBenefts



(PM benefts:$6.25 billion to$14.59 billion

Ozone benefts:$1.15 billion to$5.21 billion)


660 1,500PM-relatedprematuredeaths

110 500ozone-relatedprematuredeaths

81,000 workdays lost

210,000 schooldays lost

1.1 million minorrestricted-activitydays

Improved visibility

Reductions indamage o : Materials Ecosystems Vegetation Climate

Negligible increasein production costs,possible consumercosts, and decrease invehicle sales

Negligible increase incost o gas productionand potential consumercosts

Jobs impact expectedto be small sincechanges in cost andsales will be small

39 Environmental Protection Agency, Control o Air Pollution rom Motor Vehicles: ier 3 Motor Vehicle Emission and Fuel Standards, F.R. 2014-06954. (April 28, 2014). Available athttp://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0135-5096 .


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Proposed rule: Hazardous and Solid Waste Management System; Identication and Listing of Special

Wastes; Disposal of Coal Combustion Residuals From Electric Utilities


Date proposed: June 21, 2010

Tis proposed rule seeks to protect public health and the environment by subjecting coal combustion residuals,

commonly called coal ash, generated by electric utility and independent power producers to rst-time

regulations under the Resource Conservation and Recovery Act (RCRA). Coal ash is the byproduct o electricity

production using coal. Large amounts o residual materials are disposed o in sur ace impoundments, which are

areas o land designated or disposal. Coal ash contains a number o toxic materials, such as antimony, arsenic,

barium, beryllium, cadmium, chromium, lead, mercury, nickel, selenium, silver, and thallium. Tese toxins

can contaminate sur ace water afer a release and may also leach into the ground and contaminate groundwater

during storage. In 2008, the ailure o a sur ace impoundment retaining wall at an electric utility plant in

Kingston, ennessee led to a catastrophic release o coal ash into the surrounding environment.40

Te release othese toxins endangers public health and damages properties and ecosystems.

wo alternative regulatory actions are proposed: listing combustion residual materials as a special waste to be

regulated under subtitle C o RCRA, or regulating them as non-hazardous solid waste under subtitle D o RCRA.

Under subtitle C, coal ash would be listed as a special waste and would be subject to regulations spanning rom

generation to disposal. Units where combustion coal residuals are disposed o , treated, or stored would require

permits. Alternatively, under subtitle D, coal ash would be regulated as non-hazardous solid waste and would

only be subject to regulations regarding disposal. National criteria would be established to ensure sa e disposal,but only states or citizens, not the EPA, would be able to en orce these requirements. Both o these alternatives

include provisions regarding dam sa ety in order to improve the structural integrity o disposal areas and prevent

catastrophic releases.

Under subtitle C, the costs o improving the treatment and handling o coal ash would be $1.6 billion, while the

monetized benets would be $6.8 billion to $8 billion, generating a net monetized benet o $5.2 billion to $6.2

billion. Under subtitle D, the compliance costs would be $631 million and the monetized benets would be $2.7

billion to $3.2 billion, creating $2 billion to $2.6 billion in net monetized benets. One possible version o the

subtitle D proposal, called D prime, differs only in its allowance or existing impoundments to operate or their

use ul li e, instead o closing to install liners. Option D prime has estimated compliance costs o $254 million

and estimated monetized benets rom $1.1 billion to $1.4 billion, resulting in an annual net monetized benet

o $822 million to $1.2 billion. Depending on the nal option selected, the rule is estimated to prevent between

148 and 726 bladder and lung cancer cases over a 50-year period.

40 Shaila Dewan, New York imes, At Plant in Coal Ash Spill, oxic Deposits by the on. (December 29, 2008). Available at http://www.nytimes.com/2008/12/30/us/30sludge.html?_r=1&em .
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.nytimes.com/2008/12/30/us/30sludge.html?_r=1&emhttp://www.nytimes.com/2008/12/30/us/30sludge.html?_r=1&emhttp://www.nytimes.com/2008/12/30/us/30sludge.html?_r=1&emhttp://www.nytimes.com/2008/12/30/us/30sludge.html?_r=1&emhttp://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352


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Te monetized benets include the prevention o structural ailure o sur ace impoundments and associated

cleanup costs, the protection o groundwater rom contamination, avoided cases o bladder and lung cancer, and

the potential uture annual increase in benecial uses o coal ash, such as its use as a component in concrete,

drywall, and road beds. Both costs and benets were presented with a seven percent discount rate and, based

on the EPAs past experiences, assumed that the increased cost o disposal will encourage industry to increase

benecial use o coal ash. Additional benets that were unable to be quantied include the prevention o non-

cancer health effects, ecological protection, sur ace water protection, and the prevention o ambient air pollution.

Te regulatory impact analysis prepared or this rule notes that non-quantied ecological benets could add

159 percent and socioeconomic benets could add 24 percent to the benets amount, in addition to the avoided

costs o cleaning up coal ash spills. Additionally, the rule is expected to increase electricity rates by less than one

percent at most, and it will not have an effect on small businesses. 41 Te alternatives outlined in this proposed

rule will protect public health and the environment against the catastrophic release o coal ash in a manner that

generates our to ve times as many benets as the costs required, even without contributions rom signicant

unquantied benets.42

41 Environmental Protection Agency. Regulatory Impact Analysis or EPAs Proposed RCRA Regulation o Coal Combustion Residues(CCR) Generated by the Electric Utility Industry. (April 30, 2010). Available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0003. 42 Environmental Protection Agency, Hazardous and Solid Waste Management System; Identication and Listing o Special Wastes; Disposal o CoalCombustion Residuals rom Electric Utilities. F.R. 2010-12286. (June 21, 2010). Available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352.

Hazardous and Solid Waste Management System; Identifcation and Listing o Special Wastes;Disposal o Coal Combustion Residuals From Electric Utilities

Annual Monetized Benefts, Compliance Costs, Unquantifed Benefts,and Estimated Economic Impact (2014$)

RCRAJurisdiction

EstimatedMonetized

Benefts(7% discount)

EstimatedCompliance

Costs(7% discount)


EstimatedQuantifed

Benefts

UnquantifedBenefts

EstimatedEconomic

Impact

Subtitle C $6.78 billion to$7.96 billion


726 cancercases (over 50years)

Prevention onon-cancerhealth e ects

Ecologicalprotection

Sur ace waterprotection

Prevention oambient airpollution

Less than1% increasein electricityrates

No signifcantimpacton smallbusinesses

Subtitle D $2.69 billion to$3.23 billion

$631.3 million $2.04 billion to$2.58 billion

296 cancercases (over 50years)

Subtitle D

prime

$1.1 billion to

$1.4 billion

$253.8 million $821.6 million

to $1.18 billion

148 cancer cases

(over 50 years)
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0003http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0003http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0352http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0003http://www.regulations.gov/#!documentDetail;D=EPA-HQ-RCRA-2009-0640-0003


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Proposed Rule: Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating

Point Source Category


Date Proposed: June 7, 2013

Tis proposed rule will reduce the amount o pollutants discharged into sur ace water by revising standards

or these types o plants and guidelines or effluent, which is waste that is discharged into sur ace water. Te

electric power industry generates 50 percent to 60 percent o the toxic pollutants discharged into sur ace water

by industries regulated under the Clean Air Act. Tis amount is expected to increase since recent air pollution

controls capture pollutants and trans er them to wastewater discharge. Tese toxic pollutants, which include

mercury, arsenic, selenium, nitrogen, and total dissolved solids, pose risks to human health, aquatic li e, wildli e,

and may contaminate sediment. A number o regulatory options were examined, with our pre erred regulatory

alternatives presented in the proposed rule. Tese alternatives differ in the requirements or discharge associated

with two waste streams rom existing sources.

Depending on the regulatory options, compliance costs are estimated to range rom $175 million to $972

million, while monetized benets may range rom $148 million to $513 million, generating net monetary costs

o $27 million to $459 million. Although the monetary costs are greater than the monetized benets, this rule

will produce substantial benets that are unable to be quantied. Te monetized benets included most o the

benets that were quantied and listed in the table below, plus reductions in IQ loss in children exposed to lead

via sh consumption, in utero mercury exposure via maternal sh consumption, mortality rom air pollutants,

and avoided climate change impacts rom carbon dioxide emissions. Reductions in non-cancer health effects dueto arsenic via sh consumption were quantied but not monetized.

Signicant, substantial benets regarding human health, ecological, and market benets were not able to be

quantied, but they are projected to provide signicant benets. Te overall benets o this rule are urther

underestimated because not all sources o exposure were examined. Reductions in exposure to toxins through

cleaner drinking water, as well as less consumption o contaminated vegetation and contaminated animals other

than sh, would urther increase the health benets o the rule. Additionally, the benets resulting rom the

establishment o best management practices were not included in the benets analysis, but they were included in

the cost estimate.

Te pre erred alternatives outlined in this proposed rule will result in signicant improvements or the

environment, ecosystem, wildli e, and public health in an economically achievable manner. Electric utility

companies are unlikely to ace economic impacts since compliance costs are estimated to be one percent or less

o their revenue. A very small number o companies are projected to incur the highest costs, up to three percent
http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2009-0819-0068http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2009-0819-0068http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2009-0819-0068http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2009-0819-0068


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o revenue. Given the low compliance costs

Documents

The Benefits of Public Protections: Ten Rules That Save Lives and Protect the Environment