Comments on EPA's Notice of Data Availability for §316(b) Stated Preference Survey

Fri Jul 20 16:24:00 EDT 2012
By Dr. David Harrison, Dr. Eugene Ericksen, Dr. Melissa Pittaoulis, and Dr. Bernard Reddy et. al.

A NERA team -- led by Senior Vice President and Environment Group Co-Head Dr. David Harrison -- prepared this study on behalf of the Utility Water Act Group and Edison Electric Institute. On 12 June 2012, the US Environmental Protection Agency (EPA) published a Notice of Data Availability in the Federal Register providing preliminary data and econometric results based upon a stated preference survey related to the potential benefits of regulatory alternatives for cooling water intake structures at power plants and other facilities under §316(b) of the Clean Water Act. The EPA has solicited public comment on all aspects of the stated preference study, including the methodology, the strengths and weaknesses of stated preference methods generally, and the appropriate role, if any, the study should play in the analysis of the final rule. NERA's report focuses on three questions related to the EPA survey: whether the EPA survey provides the basis for respondents to provide meaningful responses; whether EPA's empirical analysis indicates that the survey data and results yield valid willingness-to-pay estimates; and whether EPA's empirical results from the survey provide plausible national and regional willingness-to-pay estimates for §316(b) alternatives. The authors then assess the role the EPA survey should play in EPA's analysis of the final §316(b) rule in light of these evaluations.