March 10, 2003

Public Interest Comment on Plywood NESHAP

Key materials
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National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products  

Stated Purpose:

"To protect the public health by reducing emissions of HAP from PCWP facilities."

Summary of RSP Comment:

The proposed plywood emission standards appear likely to cost consumers far more than they would gain from improved health and a cleaner environment. Indeed consumers appear likely to suffer both poorer health and an environment degraded on net by additional ozone despite the reductions in methanol and formaldehyde emissions.

The EPA could develop a more effective approach for regulating plywood hazardous air pollutants (HAP) by developing standards and practices that recognize risk and undertake a cost accounting that--as the OMB directs--takes side-effects into account, even if a full monetization of all benefits and costs remains impractical. For instance, the EPA can require its standards not impose upon consumers a reduction in consumer surplus that would "cause" a number of statistical fatalities that exceeds the statistical fatalities "saved" directly by the reduction in targeted pollution emissions.

And, in estimating the average cost-per-ton of targeted pollutant(s) reduced, the EPA should take into account the associated costs above and beyond those incurred directly by the regulated facilities; e.g., also account for the costs imposed by associated increases in non-targeted pollutants. That fuller cost accounting provides a more accurate view of how large the benefits must average per-ton-of-targeted-pollutant reduced for the proposed regulation to make consumers better--rather than worse--off. In the instance of the proposed plywood NESHAP, unless a ton of HAP reduced can plausibly provide benefits (health and environmental costs prevented) of at least $21,500, the rule should be revised and improved.