Moreover, as the science and economics in this area continue to improve in the coming years, leading environmental agencies such as the federal EPA and the DEC could update their figures, including by using any new damage estimates and discount rates.14 The final version of Part 510 should be drafted in a manner that keep the cost- effectiveness analysis provided for aligned with the most state-of. [...] A definition that omits any mention of quantitatively or qualitatively considering other emissions reductions cannot be called “comprehensive.” To go beyond the bare minimum specified in the statute, and to move in the direction of a more comprehensive framework, the rule should include consideration of other important societal effects: at a minimum, the analysis should, ideally, be required, and. [...] Ozone forms when sunlight reacts with oxides and organic compounds in the air.27 Thus, ozone is less likely to form at night and is also less likely to form in the winter, making time of day and year important for damage from this pollutant.28 Finally, pollution causes damage when individuals are exposed to that pollution, so the size of the exposed population is one of the most important drivers. [...] Although the rule’s purpose under the Act to enable the adoption of cost-effective code changes and to require that cost-effectiveness be calculated in a manner that includes societal impacts, there are instances where the intended arithmetic set forth in the proposed rule lacks clarity. [...] Specifically, the proposed rule introduces confusion by using “life-cycle costs” to denote the net present value of savings, i.e., the metric for the cost-effectiveness analysis, which differs from the terminology used in the DOE Methodology documents.
- Pages
- 8
- Published in
- United States of America
