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Title: Making appropriate comparisons of estimated and actual costs of reducing SO{sub 2} emissions under Title IV

A current sentiment within some parts of the environmental policy community is that market-based regulatory approaches such as emissions trading have proven so effective that actual costs will be only a small fraction of what ex ante cost estimation procedures would project. With this line of reasoning, some have dismissed available cost estimates for major proposed new regulations, such as the new PM and ozone NAAQS, as not meaningful for policy decisions. The most commonly used evidence in support of this position is the experience with SO{sub 2} reductions under Title IV of the 1990 Clean Air Act Amendments. In Title IV, a market for emissions allowances has been used to achieve reductions in sulfur dioxides (SO{sub 2}) to ameliorate acid rain. It is commonly asserted today that the cost of achieving the SO{sub 2} emissions reductions has been only one-tenth or less of what Title IV was originally expected to cost. This paper demonstrates that, to the contrary, actual costs for SO{sub 2} reductions remain roughly in line with original estimates associated with Title IV. Erroneous conclusions about Title IV`s costs are due to inappropriate comparisons of a variety of different measures that appear to be comparable only becausemore » they are all stated in dollars per ton. Program cost estimates include the total costs of a fully-implemented regulatory program. The very low costs of Title IV that are commonly cited today are neither directly reflective of a fully implemented Title IV, (which is still many years away) nor reflective of all the costs already incurred. Further, a careful review of history finds that the initial cost estimates that many cite were never associated with Title IV. Technically speaking, people are comparing the estimated control costs for the most-costly power plant associated with earlier acid rain regulatory proposals with prices from a market that do not directly reflect total costs.« less
Authors:
 [1]
  1. DFI/Aeronomics Inc., Washington, DC (United States)
Publication Date:
OSTI Identifier:
679433
Report Number(s):
CONF-980632--
TRN: IM9940%%252
Resource Type:
Conference
Resource Relation:
Conference: 91. annual meeting and exhibition of the Air and Waste Management Association, San Diego, CA (United States), 14-18 Jun 1998; Other Information: PBD: 1998; Related Information: Is Part Of Proceedings of the 91. annual meeting and exhibition. Bridging international boundaries: Clean production for environmental stewardship; PB: [5000] p.
Publisher:
Air and Waste Management Association, Pittsburgh, PA (United States)
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; AIR POLLUTION ABATEMENT; SULFUR DIOXIDE; EMISSION; AIR POLLUTION; COST ESTIMATION; PARTICULATES; OZONE; ENVIRONMENTAL POLICY