We examine the determinants of environmental regulatory activity (inspections and enforcement actions) and levels of air and water pollution for 409 US pulp and paper mills, using data for 1985-1997. We focus on the benefits to the surrounding population from pollution abatement. Plants with larger benefits emit less pollution, as do those with more kids and elders nearby. Plants in poor areas emit more pollution, though (surprisingly) we find less pollution in minority areas. Out-of-state neighbors seem to count less than in-state ones, although this effect diminishes if the bordering state's Congressional delegation is strongly pro-environment. We use 'spatially lagged' instrumental variables to control for the potential endogeneity of which individuals choose to locate near the plant. The results for regulatory activity are noticeably less significant than the emissions results. r

Abstract:EPA has conducted several ex post assessments of regulatory compliance costs, with the ultimate goal of identifying ways to improve ex ante cost estimation. The work to date has culminated in four case studies that examine five regulations using a common conceptual framework. The standardized framework provides a systematic way to investigate key drivers of compliance costs to see if judgments can be made about why and how ex ante and ex post estimates of costs differ. In addition to describing this conceptual framework, we describe the criteria used to select the rules to be analyzed, summarize the main hypotheses for why ex ante and ex post cost estimates may differ and discuss some of the challenges encountered in conducting these ex post analyses.

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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.