cover image: RFF Comments on the Proposed Revisions to Circular A-4

20.500.12592/c15p5k

RFF Comments on the Proposed Revisions to Circular A-4

1 Jun 2023

Nonetheless, the figure on the top of page 30 of the Preamble demonstrates that the 30-year trailing average is now less stable with respect to the estimation period than it was when the existing Circular A-4 was written and also throughout the 2000s. [...] The traditional approach of multiplying the average WTP by the size of the population yields the correct total WTP, illustrating that the average WTP is an appropriate metric. [...] On page 3 of the Preamble to Circular A-4, OMB has requested comment on the following question: “Are there any interactions between this section and other sections of the Circular, for example between the sections ‘Scope of Analysis’ and ‘Distributional Effects,’ that should be further accounted for in the revisions to the Circular?” In the “Scope of Analysis” section of the updated A-4, OMB permi. [...] The Value of Risk Reductions, or the Value of a Statistical Life (VSL) Page 66 of the revision states “For example, it is appropriate to use a value for mortality risk reductions (sometimes referred to as the value of a statistical life, or VSL) that does not depend on the income of the sub-population to which the mortality risk reduction benefits accrue, consistent with the guidance provided else. [...] This is consistent with the approach to the VSL taken by the Interagency Working Group on the Social Cost of Carbon, which is the basis for the current interim estimates of the social cost of greenhouse gases, as well as EPA’s 2022 report proposing to update these estimates (EPA 2022).

Authors

Dunlap, Lauren

Pages
13
Published in
United States of America