Ex ante and ex post cost estimates of the Cluster Rule and MACT II Rule

Morgan Cynthia, Carl Pasurka and Ron Shadbegian
Additional contact information
Morgan Cynthia: US EPA, National Center for Environmental Economics, Washington, DC 20460, USA

Journal of Benefit-Cost Analysis, 2014, vol. 5, issue 2, 195-224

Abstract: This paper compares EPA’s ex ante cost analysis of the Cluster Rule, EPA’s first integrated, multi-media regulation, and MACT II Rule to an ex post cost assessment. The goal of this assessment is to determine if actual costs diverged from ex ante costs and, if so, what factors caused this divergence. We find the EPA ex ante costs overestimated the ex post capital costs for the Cluster Rule by 30 to 100%. Contributing factors appear to be use of cleaner technology, flexible compliance options, site-specific rules, shutdowns and consolidations. Ex ante estimates for the MACT II Rule are found to be overestimated by 25% for capital costs and 200 or more percent for annual costs. The primary reason for the overestimate is the use of the bubble compliance strategy that required fewer paper mills to install pollution abatement equipment than anticipated by EPA.

Keywords: chlorine substitution; Cluster Rule; oxygen delignification; pulp and paper; retrospective analysis (search for similar items in EconPapers)
Date: 2014
References: View references in EconPapers View complete reference list from CitEc
Citations: View citations in EconPapers (6)

Downloads: (external link)
https://doi.org/10.1515/jbca-2014-0026 (text/html)
For access to full text, subscription to the journal or payment for the individual article is required.

Related works:
Journal Article: Ex ante and ex post cost estimates of the Cluster Rule and MACT II Rule (2014)
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:bpj:jbcacn:v:5:y:2014:i:2:p:30:n:4

Ordering information: This journal article can be ordered from
https://www.degruyter.com/journal/key/jbca/html

DOI: 10.1515/jbca-2014-0026

Access Statistics for this article

Journal of Benefit-Cost Analysis is currently edited by Glenn C. Blomquist and William H. Hoy

More articles in Journal of Benefit-Cost Analysis from De Gruyter
Bibliographic data for series maintained by Peter Golla ().