On January 20, 2021, President Biden issued E.O. 13990, which re-established an IWG and directed it to develop an update of the SC-CO2 estimates that reflect the best available science and the recommendations of the National Academies. In February 2021, the IWG recommended the interim use of the most recent SC- CO2 estimates developed by the IWG prior to the group being disbanded in 2017, adjusted for inflation (IWG, 2021) (IWG, 2021). As discussed in the February 2021 SC-GHG TSD, the IWG's selection of these interim estimates reflected the immediate need to have SC- CO2 estimates available for agencies to use in regulatory benefit-cost analyses and other applications that were developed using a transparent process, peer reviewed methodologies, and the science available at the time of that process.
As noted above, the EPA participated in the IWG but has also independently evaluated the interim SC-CO2 estimates published in the February 2021 SC-GHG TSD and determined they are appropriate to use to estimate climate benefits for this action. The EPA and other agencies intend to undertake a fuller update of the SC- CO2 estimates that takes into consideration the advice of the National Academies (2017) and other recent scientific literature. The EPA has also evaluated the supporting rationale of the February 2021 SC-GHG TSD, including the studies and methodological issues discussed therein, and concludes that it agrees with the rationale for these estimates presented in the SC-GHG TSD and summarized below.
In particular, the IWG found that the SC-CO2 estimates used under E.O. 13783 fail to reflect the full impact of GHG emissions in multiple ways. First, the IWG concluded that those estimates fail to capture many climate impacts that can affect the welfare of U.S. citizens and residents. Examples of affected interests include direct effects on U.S. citizens and assets located abroad, international trade, and tourism, and spillover pathways such as economic and political destabilization and global migration that can lead to adverse impacts on U.S. national security, public health, and humanitarian concerns. Those impacts are better captured within global measures of the SC-GHGs.
In addition, assessing the benefits of U.S. GHG mitigation activities requires consideration of how those actions may affect mitigation activities by other countries, as those international mitigation actions will provide a benefit to U.S. citizens and residents by mitigating climate impacts that affect U.S. citizens and residents. A wide range of scientific and economic experts have emphasized the issue of reciprocity as support for considering global damages of GHG emissions. Using a global estimate of damages in U.S. analyses of regulatory actions allows the U.S. to continue to actively encourage other nations, including emerging major economies, to take significant steps to reduce emissions. The only way to achieve an efficient allocation of resources for emissions reduction on a global basis -- and so benefit the U.S. and its citizens -- is for all countries to base their policies on global estimates of damages.
As a member of the IWG involved in the development of the February 2021 SC-GHG TSD, the EPA agrees with this assessment and, therefore, in this proposed rule the EPA centers attention on a global measure of SC-CO2. This approach is the same as that taken in EPA regulatory analyses over 2009 through 2016. A robust estimate of climate damages only to U.S. citizens and residents that accounts for the myriad of ways that global climate change reduces the net welfare of U.S. populations does not currently exist in the literature. As explained in the February 2021 SC-GHG TSD, existing estimates are both incomplete and an underestimate of total damages that accrue to the citizens and residents of the U.S. because they do not fully capture the regional interactions and spillovers discussed above, nor do they include all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature, as discussed further below. The EPA, as a member of the IWG, will continue to review developments in the literature, including more robust methodologies for estimating the magnitude of the various damages to U.S. populations from climate impacts and reciprocal international mitigation activities, and explore ways to better inform the public of the full range of carbon impacts.
Second, the IWG concluded that the use of the social rate of return on capital (7 percent under current OMB Circular A-4 guidance) to discount the future benefits of reducing GHG emissions inappropriately underestimates the impacts of climate change for the purposes of estimating the SC-CO2. Consistent with the findings of the National Academies (2017) and the economic literature, the IWG continued to conclude that the consumption rate of interest is the theoretically appropriate discount rate in an intergenerational context (IWG, 2016b) (IWG, 2010, 2013, 2016a) and recommended that discount rate uncertainty and relevant aspects of intergenerational ethical considerations be accounted for in selecting future discount rates. Furthermore, the damage estimates developed for use in the SC-GHG are estimated in consumption-equivalent terms, and so an application of OMB Circular A-4's guidance for regulatory analysis would then use the consumption discount rate to calculate the SC-GHG. The EPA agrees with this assessment and will continue to follow developments in the literature pertaining to this issue. The EPA also notes that while OMB Circular A-4, as published in 2003, recommends using 3 percent and 7 percent discount rates as "default" values, Circular A-4 also reminds agencies that "different regulations may call for different emphases in the analysis, depending on the nature and complexity of the regulatory issues and the sensitivity of the benefit and cost estimates to the key assumptions." On discounting, Circular A-4 recognizes that "special ethical considerations arise when comparing benefits and costs across generations," and Circular A-4 acknowledges that analyses may appropriately "discount future costs and consumption benefits...at a lower rate than for intragenerational analysis." In the 2015 Response to Comments on the Social Cost of Carbon for Regulatory Impact Analysis, OMB, EPA, and the other IWG members recognized that "Circular A-4 is a living document" and "the use of 7 percent is not considered appropriate for intergenerational discounting. There is wide support for this view in the academic literature, and it is recognized in Circular A-4 itself." Thus, the EPA concludes that a 7 percent discount rate is not appropriate to apply to value the SC-GHGs in the analysis presented in this RIA. In this analysis, to calculate the present and annualized values of climate benefits, the EPA uses the same discount rate as the rate used to discount the value of damages from future GHG emissions, for internal consistency. That approach to discounting follows the same approach that the February 2021 SC-GHG TSD recommends "to ensure internal consistency -- i.e., future damages from climate change using the SC-GHG at 2.5 percent should be discounted to the base year of the analysis using the same 2.5 percent rate." EPA has also consulted the National Academies' 2017 recommendations on how SC-GHG estimates can "be combined in RIAs with other cost and benefits estimates that may use different discount rates." The National Academies reviewed "several options," including "presenting all discount rate combinations of other costs and benefits with [SC-GHG] estimates."
While the IWG works to assess how best to incorporate the latest, peer reviewed science to develop an updated set of SC-GHG estimates, it recommended the interim estimates to be the most recent estimates developed by the IWG prior to the group being disbanded in 2017. The estimates rely on the same models and harmonized inputs and are calculated using a range of discount rates. As explained in the February 2021 SC-GHG TSD, the IWG has concluded that it is appropriate for agencies to revert to the same set of four values drawn from the SC-GHG distributions based on three discount rates as were used in regulatory analyses between 2010 and 2016 and subject to public comment. For each discount rate, the IWG combined the distributions across models and socioeconomic emissions scenarios (applying equal weight to each) and then selected a set of four values for use in agency analyses: an average value resulting from the model runs for each of three discount rates (2.5 percent, 3 percent, and 5 percent), plus a fourth value, selected as the 95th percentile of estimates based on a 3 percent discount rate. The fourth value was included to provide information on potentially higher-than-expected economic impacts from climate change, conditional on the 3 percent estimate of the discount rate. As explained in the February 2021 SC-GHG TSD, this update reflects the immediate need to have an operational SC-GHG that was developed using a transparent process, peer-reviewed methodologies, and the science available at the time of that process. Those estimates were subject to public comment in the context of dozens of proposed rulemakings as well as in a dedicated public comment period in 2013.
Table 4-11 summarizes the interim SC-CO2 estimates for the years 2025 to 2040. These estimates are reported in 2019 dollars but are otherwise identical to those presented in the IWG's 2016 SC-GHG TSD (IWG, 2016b). For purposes of capturing uncertainty around the SC-CO2 estimates in analyses, the 2021 SC-GHG TSD emphasizes the importance of considering all four of the SC-CO2 values. The SC-CO2 increases over time within the models  -  i.e., the societal harm from one metric ton emitted in 2030 is higher than the harm caused by one metric ton emitted in 2025  -  because future emissions produce larger incremental damages as physical and economic systems become more stressed in response to greater climatic change, and because GDP is growing over time and many damage categories are modeled as proportional to GDP.
Table 4-11	Interim Social Cost of Carbon Values, 2025-2040 (2019 dollars per Metric Tonne CO2)

                          Discount Rate and Statistic
                                Emissions Year
                                      5%
                                      3%
                                     2.50%
                                      3%

                                    Average
                                    Average
                                    Average
                               95[th] Percentile
                                     2025
                                     $17
                                     $56
                                     $82
                                     $167
                                     2026
                                     $17
                                     $57
                                     $83
                                     $171
                                     2027
                                     $18
                                     $58
                                     $85
                                     $174
                                     2028
                                     $18
                                     $59
                                     $86
                                     $178
                                     2029
                                     $19
                                     $60
                                     $87
                                     $181
                                     2030
                                     $19
                                     $61
                                     $88
                                     $184
                                     2031
                                     $20
                                     $62
                                     $90
                                     $188
                                     2032
                                     $20
                                     $63
                                     $91
                                     $192
                                     2033
                                     $21
                                     $64
                                     $92
                                     $196
                                     2034
                                     $21
                                     $66
                                     $94
                                     $200
                                     2035
                                     $22
                                     $67
                                     $95
                                     $203
                                     2036
                                     $23
                                     $68
                                     $96
                                     $207
                                     2037
                                     $23
                                     $69
                                     $98
                                     $211
                                     2038
                                     $24
                                     $70
                                     $99
                                     $215
                                     2039
                                     $24
                                     $71
                                     $101
                                     $218
                                     2040
                                     $25
                                     $72
                                     $102
                                     $222
Note: These SC-CO2 values are identical to those reported in the 2016 SC-GHG TSD (IWG 2016a) adjusted for inflation to 2019 dollars using the annual GDP Implicit Price Deflator values in the U.S. Bureau of Economic Analysis' (BEA) NIPA Table 1.1.9 (U.S. BEA 2021). The values are stated in $/metric tonne CO2 (1 metric tonne equals 1.102 short tons) and vary depending on the year of CO2 emissions. This table displays the values rounded to the nearest dollar; the annual unrounded values used in the calculations in this RIA are available on OMB's website: https://www.whitehouse.gov/omb/information-regulatory-affairs/regulatory-matters/#scghgs.
Source: Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under E.O. 13990 (IWG 2021)

There are a number of limitations and uncertainties associated with the SC-CO2 estimates presented in Table 4-11. Some uncertainties are captured within the analysis, while other areas of uncertainty have not yet been quantified in a way that can be modeled. Figure 4-2 presents the quantified sources of uncertainty in the form of frequency distributions for the SC-CO2 estimates for emissions in 2030. The distributions of SC-CO2 estimates reflect uncertainty in key model parameters such as the equilibrium climate sensitivity, as well as uncertainty in other parameters set by the original model developers. To highlight the difference between the impact of the discount rate and other quantified sources of uncertainty, the bars below the frequency distributions provide a symmetric representation of quantified variability in the SC-CO2 estimates for each discount rate. As illustrated by the figure, the assumed discount rate plays a critical role in the ultimate estimate of the SC-CO2. This is because CO2 emissions today continue to impact society far out into the future, so with a higher discount rate, costs that accrue to future generations are weighted less, resulting in a lower estimate. As discussed in the 2021 SC-GHG TSD, there are other sources of uncertainty that have not yet been quantified and are thus not reflected in these estimates.
Figure 4-2	Frequency Distribution of SC-CO2 Estimates for 2030

The interim SC-CO2 estimates presented in Table 4-11 have a number of limitations. First, the current scientific and economic understanding of discounting approaches suggests discount rates appropriate for intergenerational analysis in the context of climate change are likely to be less than 3 percent, near 2 percent or lower (IWG, 2021). Second, the IAMs used to produce these interim estimates do not include all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature and the science underlying their "damage functions"  -  i.e., the core parts of the IAMs that map global mean temperature changes and other physical impacts of climate change into economic (both market and nonmarket) damages  -  lags behind the most recent research. For example, limitations include the incomplete treatment of catastrophic and non-catastrophic impacts in the integrated assessment models, their incomplete treatment of adaptation and technological change, the incomplete way in which inter-regional and intersectoral linkages are modeled, uncertainty in the extrapolation of damages to high temperatures, and inadequate representation of the relationship between the discount rate and uncertainty in economic growth over long time horizons. Likewise, the socioeconomic and emissions scenarios used as inputs to the models do not reflect new information from the last decade of scenario generation or the full range of projections.
The modeling limitations do not all work in the same direction in terms of their influence on the SC-CO2 estimates. However, as discussed in the February 2021 SC-GHG TSD, the IWG has recommended that, taken together, the limitations suggest that the SC-CO2 estimates used in this RIA likely underestimate the damages from CO2 emissions. EPA concurs that the values used in this RIA conservatively underestimate the rule's climate benefits. In particular, the Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (IPCC, 2007), which was the most current IPCC assessment available at the time when the IWG decision over the ECS input was made, concluded that SC-CO2 estimates "very likely...underestimate the damage costs" due to omitted impacts. Since then, the peer-reviewed literature has continued to support this conclusion, as noted in the IPCC's Fifth Assessment report and other recent scientific assessments (IPCC, 2014, 2018, 2019a, 2019b; National Academies of Sciences and Medicine, 2016; USGCRP, 2016, 2018)
These assessments confirm and strengthen the science, updating projections of future climate change and documenting and attributing ongoing changes. For example, sea level rise projections from the IPCC's Fourth Assessment report ranged from 18 to 59 centimeters by the 2090s relative to 1980-1999, while excluding any dynamic changes in ice sheets due to the limited understanding of those processes at the time (IPCC 2007). A decade later, the Fourth National Climate Assessment projected a substantially larger sea level rise of 30 to 130 centimeters by the end of the century relative to 2000, while not ruling out even more extreme outcomes (USGCRP, 2018). EPA has reviewed and considered the limitations of the models used to estimate the interim SC-GHG estimates and concurs with the February 2021 SC-GHG TSD's assessment that, taken together, the limitations suggest that the interim SC-GHG estimates likely underestimate the damages from GHG emissions.
The February 2021 SC-GHG TSD briefly previews some of the recent advances in the scientific and economic literature that the IWG is actively following and that could provide guidance on, or methodologies for, addressing some of the limitations with the interim SC-GHG estimates. The IWG is currently working on a comprehensive update of the SC-GHG estimates taking into consideration recommendations from the National Academies of Sciences, Engineering and Medicine, recent scientific literature, public comments received on the February 2021 SC-GHG TSD and other input from experts and diverse stakeholder groups (National Academies 2017). While that process continues, the EPA is continuously reviewing developments in the scientific literature on the SC-GHG, including more robust methodologies for estimating damages from emissions, and looking for opportunities to further improve SC-GHG estimation going forward. Most recently, the EPA presented a draft set of updated SC-GHG estimates within a sensitivity analysis in the regulatory impact analysis of the EPA's November 2022 supplemental proposal for oil and gas standards that that aims to incorporate recent advances in the climate science and economics literature (U.S. EPA, 2022b, 2022e). Specifically, the draft updated methodology incorporates new literature and research consistent with the National Academies near-term recommendations on socioeconomic and emissions inputs, climate modeling components, discounting approaches, and treatment of uncertainty, and an enhanced representation of how physical impacts of climate change translate to economic damages in the modeling framework based on the best and readily adaptable damage functions available in the peer reviewed literature. The EPA solicited public comment on the sensitivity analysis and the accompanying draft technical report, which explains the methodology underlying the new set of estimates, in the docket for the proposed Oil and Gas rule. The EPA is also embarking on an external peer review of this technical report. More information about this process and public comment opportunities is available on EPA's website. EPA's draft technical report will be among the many technical inputs available to the IWG as it continues its work.

Table 4-12 shows the estimated monetized value of the estimated changes in CO2 emissions the proposed option and the more-stringent alternative. EPA estimated the dollar value of the CO2-related effects for each analysis year between 2028 and 2037 by applying the SC-CO2 estimates, shown in Table 4-12, to the estimated changes in CO2 emissions in the corresponding year under the regulatory options.  Note the less stringent regulatory alternative has no quantified emissions reductions associated with the proposed requirements for PM CEMS and the removal of startup definition number two. As a result, there are no quantified benefits associated with this regulatory option.

Table 4-12	Estimated Climate Benefits from Changes in CO2 Emissions for 2028, 2030, and 2035 (millions of 2019 dollars)[a]
                            Regulatory Alternative
                                     Year

                                      5%
                                      3%
                                     2.5%
                                      3%

                                    Average
                                    Average
                                    Average
                                95th Percentile
                                Proposed Option
                                     2028

                                      $4
                                     $13
                                     $19
                                     $40

                                     2030

                                     $16
                                     $50
                                     $72
                                     $150

                                     2035

                                     $102
                                     $308
                                     $439
                                     $939
                          More-Stringent Alternative
                                     2028

                                     $398
                                    $1,292
                                    $1,882
                                    $3,893

                                     2030

                                     $166
                                     $528
                                     $765
                                    $1,597

                                     2035

                                     $64
                                     $193
                                     $275
                                     $588
[a] Climate benefits are based on changes (reductions) in CO2 emissions and are calculated using four different estimates of the SC-CO2 (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate). We emphasize the importance and value of considering the benefits calculated using all four SC-CO2 estimates. As discussed in the Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates under E.O. 13990 (IWG 2021), a consideration of climate benefits calculated using discount rates below 3 percent, including 2 percent and lower, are also warranted when discounting intergenerational impacts.

Table 4-13	Stream of Projected Climate Benefits under Proposed Rule from 2028 through 2037 (millions of 2019 dollars)

                      SC-CO2 Discount Rate and Statistic
                                Emissions Year
                                      5%
                                      3%
                                     2.50%
                                      3%

                                    Average
                                    Average
                                    Average
                               95[th] Percentile
                                     2028*
                                      $4
                                      $13
                                      $19
                                      $40
                                     2029
                                      $15
                                      $49
                                      $71
                                     $150
                                     2030*
                                      $16
                                      $50
                                      $72
                                     $150
                                     2031
                                      $16
                                      $51
                                      $73
                                     $150
                                     2032
                                      $94
                                     $290
                                     $420
                                     $890
                                     2033
                                      $96
                                     $300
                                     $430
                                     $900
                                     2034
                                      $99
                                     $300
                                     $430
                                     $920
                                     2035*
                                     $100
                                     $310
                                     $440
                                     $940
                                     2036
                                     $100
                                     $310
                                     $450
                                     $960
                                     2037
                                     $110
                                     $320
                                     $450
                                     $970
                 3% Discount Rate for PV and EAV Calculations
                                 Present Value
                                     $470
                                    $1,400
                                    $2,100
                                    $4,400
                          Equivalent Annualized Value
                                      $55
                                     $170
                                     $240
                                     $510
* IPM analysis years.

Table 4-14	Stream of Projected Climate Benefits under More Stringent Regulatory Option from 2028 through 2037 (millions of 2019 dollars)

                      SC-CO2 Discount Rate and Statistic
                                Emissions Year
                                      5%
                                      3%
                                     2.50%
                                      3%

                                    Average
                                    Average
                                    Average
                               95[th] Percentile
                                     2028*
                                     $400
                                    $1,300
                                    $1,900
                                    $3,900
                                     2029
                                     $160
                                     $520
                                     $750
                                    $1,600
                                     2030*
                                     $170
                                     $530
                                     $770
                                    $1,600
                                     2031
                                     $170
                                     $540
                                     $780
                                    $1,600
                                     2032
                                      $59
                                     $180
                                     $260
                                     $560
                                     2033
                                      $60
                                     $190
                                     $270
                                     $570
                                     2034
                                      $62
                                     $190
                                     $270
                                     $580
                                     2035*
                                      $64
                                     $190
                                     $280
                                     $590
                                     2036
                                      $65
                                     $200
                                     $280
                                     $600
                                     2037
                                      $67
                                     $200
                                     $280
                                     $610
                 3% Discount Rate for PV and EAV Calculations
                                 Present Value
                                    $1,000
                                    $3,200
                                    $4,700
                                    $9,700
                          Equivalent Annualized Value
                                     $120
                                     $380
                                     $550
                                    $1,100
* IPM analysis years.

Water Quality and Availability Benefits
As described in Section 3, this rule is expected to lead to shifts in electricity production away from fossil-fired steam generation towards renewable and natural gas generation. There are several negative health, ecological, and productivity effects associated with water effluent and intake from coal generation that will be avoided, and the benefits are qualitatively described below. For additional discussion of these effects and their consequent effect on welfare, see the Benefit and Cost Analysis for Revisions to the Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category (U.S. EPA 2020b).
Potential Water Quality Benefits of Reducing Coal-Fired Power Generation
Discharges of wastewater from coal-fired power plants can contain toxic and bioaccumulative pollutants (e.g., selenium, mercury, arsenic, nickel), halogen compounds (containing bromide, chloride, or iodide), nutrients, and total dissolved solids (TDS), which can cause human health and environmental harm through surface water and fish tissue contamination. Pollutants in coal combustion wastewater are of particular concern because they can occur in large quantities (i.e., total pounds) and at high concentrations in discharges and leachate to groundwater and surface waters. These potential beneficial effects follow directly from reductions in pollutant loadings to receiving waters, and indirectly from other changes in plant operations. The potential benefits come in the form of reduced morbidity, mortality, and on environmental quality and economic activities; reduction in water use, which provides benefits in the form of increased availability of surface water and groundwater; and reductions in the use of surface impoundments to manage Coal Combustion Residual wastes, with benefits in the form of avoided cleanup and other costs associated with impoundment releases.
Reducing coal-fired power generation affects human health risk by changing exposure to pollutants in water via two principal exposure pathways: (1) treated water sourced from surface waters affected by coal-fired power plant discharges and (2) fish and shellfish taken from waterways affected by coal-fired power plant discharges. The human health benefits from surface water quality improvements may include drinking water benefits, fish consumption benefits, and other complimentary measures.
In addition, reducing coal-fired power generation can affect the ecological condition and recreation use effects from surface water quality changes. EPA expects the ecological impacts from reducing coal-fired power plant discharges could include habitat changes for fresh- and saltwater plants, invertebrates, fish, and amphibians, as well as terrestrial wildlife and birds that prey on aquatic organisms exposed to pollutants from coal combustion. The change in pollutant loadings has the potential to result in changes in ecosystem productivity in waterways and the health of resident species, including threatened and endangered (T&E) species. Loadings from coal-fired power generation have the potential to impact the general health of fish and invertebrate populations, their propagation to waters, and fisheries for both commercial and recreational purposes. Changes in water quality also have the potential to impact recreational activities such as swimming, boating, fishing, and water skiing.
Potential economic productivity effects may stem from changes in the quality of public drinking water supplies and irrigation water; changes in sediment deposition in reservoirs and navigational waterways; and changes in tourism, commercial fish harvests, and property values.
Drinking Water
Pollutants discharged by coal-fired power plants to surface waters may affect the quality of water used for public drinking supplies. In turn these impacts to public water supplies have the potential to affect the costs of drinking water treatment (e.g., filtration and chemical treatment) by changing eutrophication levels and pollutant concentrations in source waters. Eutrophication is one of the main causes of taste and odor impairment in drinking water, which has a major negative impact on public perceptions of drinking water safety. Additional treatment to address foul tastes and odors to bring the finished water into compliance with EPA's National Secondary Drinking Water Treatment Standards can significantly increase the cost of public water supply. Likewise, public drinking water supplies are subject to National Primary Drinking Water Standards that have set legally enforceable maximum contaminant levels (MCLs), for a number of pollutants, like metals, discharged from coal-fired power plants. Drinking water systems downstream from these power plants may be required to treat source water to remove the contaminants to levels below the MCL in the finished water. This treatment will also increase costs at drinking water treatment plants. Episodic releases from coal fired power plants may be detected only after the completion of a several month round of compliance monitoring at drinking water treatment plants, and there could also be a lag between detection of changes in source water contaminants and the system implementing treatment to address the issue. This lag may result in consumers being exposed to these contaminants through ingestion, inhalation, and skin absorption. The constituents found in the power plant discharge may also interact with drinking water treatment processes and contribute to the formation of disinfection byproducts that can have adverse human health impacts.
Fish Consumption
Recreational and subsistence fishers (and their household members) who consume fish caught in the reaches downstream of coal-fired power plants may value changes in pollutant concentrations in fish tissue. See U.S. EPA (2020b) for a demonstration of the changes in risk to human health from exposure to contaminated fish tissue. This document describes the neurological effects to children ages 0 to 7 from exposure to lead; the neurological effects to infants from in-utero exposure to mercury; the incidence of skin cancer from exposure to arsenic; and the reduced risk of other cancer and non-cancer toxic effects.
Changes in Surface Water Quality
Reducing coal-fired power plant discharges may affect the value of ecosystem services provided by surface waters through changes in the habitats or ecosystems (aquatic and terrestrial). Society values changes in ecosystem services by a number of mechanisms, including increased frequency of use and improved quality of the habitat for recreational activities (e.g., fishing, swimming, and boating). Individuals also value the protection of habitats and species that may reside in waters that receive water discharges from coal-fired power plants, even when those individuals do not use or anticipate future use of such waters for recreational or other purposes, resulting in nonuse values.
Impacts on Threatened and Endangered Species
For T&E species, even minor changes to reproductive rates and mortality levels may represent a substantial portion of annual population variation. Therefore, changing the discharge of coal-fired power plant pollutants to aquatic habitats has the potential to impact the survivability of some T&E species living in these habitats. The economic value for these T&E species primarily comes from the nonuse values people hold for the survivorship of both individual organisms and species survival.
Changes in Sediment Contamination
Water effluent discharges from coal-fired power plants can also contaminate waterbody sediments. For example, sediment adsorption of arsenic, selenium, and other pollutants found in water discharges can result in accumulation of contaminated sediment on stream and lake beds, posing a particular threat to benthic (i.e., bottom-dwelling) organisms. These pollutants can later be re-released into the water column and enter organisms at different trophic levels. Concentrations of selenium and other pollutants in fish tissue of organisms of lower trophic levels can bio-magnify through higher trophic levels, posing a threat to the food chain at large (Ruhl et al., 2012)
 Reservoir Capacity and Sedimentation Changes in Navigational Waterways
Reservoirs serve many functions, including storage of drinking and irrigation water supplies, flood control, hydropower supply, and recreation. Streams can carry sediment into reservoirs, where it can settle and cause buildup of sediment layers over time, reducing reservoir capacity (Graf et al., 2010, 2011) and the useful life of reservoirs unless measures such as dredging are taken to reclaim capacity (Hargrove et al., 2010; Miranda, 2017). Likewise, navigable waterways, including rivers, lakes, bays, shipping channels and harbors, are prone to reduced functionality due to sediment build-up, which can reduce the navigable depth and width of the waterway (Clark et al., 1985; Ribaudo and Johansson, 2006). For many navigable waters, periodic dredging is necessary to remove sediment and keep them passable. Dredging of reservoirs and navigable waterways can be costly. EPA expects that changes in suspended solids effluent discharge from coal-fired power plants could reduce sediment loadings to surface waters decreasing reservoir and navigable waterway maintenance costs by changing the frequency or volume of dredging activity.
Changes in Water Withdrawals
A reduction in water consumption from coal-fired power plants may benefit aquatic and riparian species downstream of the power plant intake through the provision of additional water resources in the face of drying conditions and increased rainfall variability. In a study completed, in 2011, by the U.S. Department of Energy's National Renewable Energy Laboratory (2011), water consumption, which is defined as water removed from the immediate water environment and can include cooling water evaporation, cleaning, and process related water use including flue gas desulfurization, was found to range from 100  -  1,100 gal/MWh at generic coal-fired power plants. This study also found that water withdraws, defined as the amount of water removed from the ground or diverted from a water source for use, ranged from 300  -  50,000 gal/MWh at a generic coal-fired power plant. Reductions in water consumption and withdraws will lower the number of aquatic organisms impinged and entrained by the power plant's water filtration and cooling systems.
Total Benefits
Table 4-15 through Table 4-17 present the total health and climate benefits for the proposed rule and the more stringent alternative.

Table 4-15	Combined PM2.5 and O3-related Health Benefits and Climate Benefits for the Proposed Requirements and More Stringent Alternative for 2028 (millions of 2019 dollars)
                      SC-CO2 Discount Rate and Statistic
                     PM2.5 and O3-related Health Benefits
                             and Climate Benefits
                           Climate Benefits Only[a]

                  (Discount Rate Applied to Health Benefits)

                                      3%
                                      7%

Proposed Rule

                                                                   5% (average)
                                      150
                                      130
                                      4.1
                                                                   3% (average)
                                      160
                                      140
                                      13
                                                                 2.5% (average)
                                      160
                                      150
                                      19
                                                         3% (95[th] percentile)
                                      180
                                      170
                                      40
More Stringent Alternative

                                                                   5% (average)
                                     3,500
                                     3,200
                                      400
                                                                   3% (average)
                                     4,400
                                     4,100
                                     1,300
                                                                 2.5% (average)
                                     5,000
                                     4,700
                                     1,900
                                                         3% (95[th] percentile)
                                     7,000
                                     6,700
                                     3,900
[a] Climate benefits are based on changes (reductions) in CO2 emissions and are calculated using four different estimates of the SC-CO2 (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate).

Table 4-16	Combined PM2.5 and O3-related Health Benefits and Climate Benefits for the Proposed Requirements and More Stringent Alternative for 2030 (millions of 2019 dollars)
                      SC-CO2 Discount Rate and Statistic
                     PM2.5 and O3-related Health Benefits
                             and Climate Benefits
                           Climate Benefits Only[a]

                  (Discount Rate Applied to Health Benefits)

                                      3%
                                      7%

Proposed Rule

                                                                   5% (average)
                                      170
                                      150
                                      16
                                                                   3% (average)
                                      200
                                      190
                                      50
                                                                 2.5% (average)
                                      220
                                      210
                                      72
                                                         3% (95[th] percentile)
                                      300
                                      290
                                      150
More Stringent Alternative

                                                                   5% (average)
                                     1,000
                                      940
                                      170
                                                                   3% (average)
                                     1,400
                                     1,300
                                      530
                                                                 2.5% (average)
                                     1,600
                                     1,500
                                      770
                                                         3% (95[th] percentile)
                                     2,500
                                     2,400
                                     1,600
[a] Climate benefits are based on changes (reductions) in CO2 emissions and are calculated using four different estimates of the SC-CO2 (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate).

Table 4-17	Combined PM2.5 and O3-related Health Benefits and Climate Benefits for the Proposed Requirements and More Stringent Alternative for 2035 (millions of 2019 dollars)
                      SC-CO2 Discount Rate and Statistic
                     PM2.5 and O3-related Health Benefits
                             and Climate Benefits
                           Climate Benefits Only[a]

                  (Discount Rate Applied to Health Benefits)

                                      3%
                                      7%

Proposed Rule

                                                                   5% (average)
                                      430
                                      400
                                      100
                                                                   3% (average)
                                      640
                                      610
                                      310
                                                                 2.5% (average)
                                      770
                                      740
                                      440
                                                         3% (95[th] percentile)
                                     1,300
                                     1,200
                                      940
More Stringent Alternative

                                                                   5% (average)
                                     1,600
                                     1,400
                                      64
                                                                   3% (average)
                                     1,700
                                     1,600
                                      190
                                                                 2.5% (average)
                                     1,800
                                     1,600
                                      280
                                                         3% (95[th] percentile)
                                     2,100
                                     1,900
                                      590
[a] Climate benefits are based on changes (reductions) in CO2 emissions and are calculated using four different estimates of the SC-CO2 (model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate).

Table 4-18	Stream of Combined PM2.5 and O3-related Health Benefits and Climate Benefits for the Proposed Rule from 2028 through 2037 (millions of 2019 dollars)[a]

                   Values Calculated using 3% Discount Rate
                   Values Calculated using 7% Discount Rate
                                     Year
                     PM2.5 and O3-related Health Benefits
                              Climate Benefits[a]
                               Total
 Benefits
                     PM2.5 and O3-related Health Benefits
                      Climate Benefits (discounted at 3%)
                               Total
 Benefits
                                     2028
                                      140
                                      13
                                      160
                                      130
                                      13
                                      140
                                     2029
                                      150
                                      49
                                      200
                                      130
                                      49
                                      180
                                     2030
                                      150
                                      50
                                      200
                                      140
                                      50
                                      190
                                     2031
                                      190
                                      51
                                      240
                                      170
                                      51
                                      220
                                     2032
                                      220
                                      290
                                      520
                                      200
                                      290
                                      490
                                     2033
                                      260
                                      300
                                      560
                                      230
                                      300
                                      530
                                     2034
                                      300
                                      300
                                      600
                                      270
                                      300
                                      570
                                     2035
                                      330
                                      310
                                      640
                                      300
                                      310
                                      610
                                     2036
                                      370
                                      310
                                      680
                                      330
                                      310
                                      650
                                     2037
                                      410
                                      320
                                      720
                                      360
                                      320
                                      680
                                 Present Value
                                     1,900
                                     1,400
                                     3,300
                                     1,100
                                     1,400
                                     2,600
                          Equivalent Annualized Value
                                      220
                                      170
                                      390
                                      160
                                      170
                                      330
[a] Climate benefits are based on reductions in CO2 emissions and are calculated using four different estimates of the social cost of carbon dioxide (SC-CO2): model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate. The 95th percentile estimate is included to provide information on potentially higher-than-expected economic impacts from climate change, conditional on the 3 percent estimate of the discount rate. For the presentational purposes of this table, we show the climate benefits associated with the average SC-CO2 at a 3 percent discount rate, but the Agency does not have a single central SC-CO2 point estimate. Climate benefits in this table are discounted using a 3 percent discount rate to obtain the PV and EAV estimates in the table. We emphasize the importance and value of considering the benefits calculated using all four SC-CO2 estimates. Section 4.4 of the RIA presents estimates of the projected climate benefits of this proposal using all four rates. We note that consideration of climate benefits calculated using discount rates below 3 percent, including 2 percent and lower, is warranted when discounting intergenerational impacts.

Table 4-19	Stream of Combined PM2.5 and O3-related Health Benefits and Climate Benefits for the More Stringent Regulatory Option from 2028 through 2037 (millions of 2019 dollars)[a]
                                     Year
                   Values Calculated using 3% Discount Rate
                   Values Calculated using 7% Discount Rate

                     PM2.5 and O3-related Health Benefits
                               Climate Benefits
                               Total
 Benefits
                     PM2.5 and O3-related Health Benefits
                      Climate Benefits (discounted at 3%)
                               Total
 Benefits
                                     2028
                                     3,100
                                     1,300
                                     4,400
                                     2,800
                                     1,300
                                     4,100
                                     2029
                                     2,000
                                      520
                                     2,500
                                     1,800
                                      520
                                     2,300
                                     2030
                                      860
                                      530
                                     1,400
                                      770
                                      530
                                     1,300
                                     2031
                                      990
                                      540
                                     1,500
                                      890
                                      540
                                     1,400
                                     2032
                                     1,100
                                      180
                                     1,300
                                     1,000
                                      180
                                     1,200
                                     2033
                                     1,300
                                      190
                                     1,400
                                     1,100
                                      190
                                     1,300
                                     2034
                                     1,400
                                      190
                                     1,600
                                     1,200
                                      190
                                     1,400
                                     2035
                                     1,500
                                      190
                                     1,700
                                     1,400
                                      190
                                     1,600
                                     2036
                                     1,600
                                      200
                                     1,800
                                     1,500
                                      200
                                     1,700
                                     2037
                                     1,800
                                      200
                                     2,000
                                     1,600
                                      200
                                     1,800
                                 Present Value
                                    12,000
                                     3,200
                                    15,000
                                     7,700
                                     3,200
                                    11,000
                          Equivalent Annualized Value
                                     1,400
                                      380
                                     1,800
                                     1,100
                                      380
                                     1,500
[a] Climate benefits are based on reductions in CO2 emissions and are calculated using four different estimates of the social cost of carbon dioxide (SC-CO2): model average at 2.5 percent, 3 percent, and 5 percent discount rates; 95th percentile at 3 percent discount rate. The 95th percentile estimate is included to provide information on potentially higher-than-expected economic impacts from climate change, conditional on the 3 percent estimate of the discount rate. For the presentational purposes of this table, we show the climate benefits associated with the average SC-CO2 at a 3 percent discount rate, but the Agency does not have a single central SC-CO2 point estimate. Climate benefits in this table are discounted using a 3 percent discount rate to obtain the PV and EAV estimates in the table. We emphasize the importance and value of considering the benefits calculated using all four SC-CO2 estimates. Section 4.4 of the RIA presents estimates of the projected climate benefits of this proposal using all four rates. We note that consideration of climate benefits calculated using discount rates below 3 percent, including 2 percent and lower, is warranted when discounting intergenerational impacts.

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Economic Impacts
Overview
Economic impact analyses focus on changes in market prices and output levels. If changes in market prices and output levels in the primary markets are significant enough, impacts on other markets may also be examined. Both the magnitude of costs needed to comply with a rule and the distribution of these costs among affected facilities can have a role in determining how the market will change in response to a rule. This section analyzes the potential impacts on small entities and the potential labor impacts associated with this rulemaking. For additional discussion of impacts on fuel use and electricity prices, see Section 33.
Small Entity Analysis
For the proposed rule, EPA performed a small entity screening analysis for impacts on all affected EGUs and non-EGU facilities by comparing compliance costs to historic revenues at the ultimate parent company level. This is known as the cost-to-revenue or cost-to-sales test, or the "sales test." The sales test is an impact methodology EPA employs in analyzing entity impacts as opposed to a "profits test," in which annualized compliance costs are calculated as a share of profits. The sales test is frequently used because revenues or sales data are commonly available for entities impacted by EPA regulations, and profits data normally made available are often not the true profit earned by firms because of accounting and tax considerations. Also, the use of a sales test for estimating small business impacts for a rulemaking is consistent with guidance offered by EPA on compliance with the Regulatory Flexibility Act (RFA) and is consistent with guidance published by the U.S. Small Business Administration's (SBA) Office of Advocacy that suggests that cost as a percentage of total revenues is a metric for evaluating cost increases on small entities in relation to increases on large entities.
Methodology
This section presents the methodology and results for estimating the impact of the rule on small EGU entities in the year of compliance, 2028, based on the following endpoints:
annual economic impacts of the proposal on small entities, and
ratio of small entity impacts to revenues from electricity generation.
In this analysis, we chose to examine the projected impacts of the more stringent regulatory option on small entities in order to present a scenario of "maximum cost impact". As we explain in the Section 5.2.3, we conclude that the projected impacts of the more stringent regulatory alternative do not constitute a Significant Impact on a Substantial Number of Small Entities (SISNOSE). As projected cost impacts of the proposed rule less stringent options are dominated by cost impacts of the more stringent alternative, a no SISNOSE conclusion for the more stringent option can be extended to the proposed rule and less stringent option.
For this analysis, EPA first considered EGUs that are subject to MATS requirements and for which EPA assumed additional controls would be necessary to meet the requirements constituted by the more stringent regulatory option. We then refined this list of MATS-affected EGUs, complementing the list with units for which the projected impact of the more stringent option exceeds either of the two criteria below relative to the baseline:
Fuel use (BTUs) changes by +/- 1 percent or more
Generation (GWh) changes by +/- 1 percent or more
Please see Section 3 for more discussion of the power sector modeling.
Based on these criteria, EPA identified a total of 358 potentially affected EGUs warranting examination in 2028 in this RFA analysis. Next, we determined power plant ownership information, including the name of associated owning entities, ownership shares, and each entity's type of ownership. We primarily used data from Hitachi - Power Grids, The Velocity Suite (c) 2020 ("VS"), supplemented by limited research using publicly available data. Majority owners of power plants with affected EGUs were categorized as one of the seven ownership types. These ownership types are:
 Investor-Owned Utility (IOU): Investor-owned assets (e.g., a marketer, independent power producer, financial entity) and electric companies owned by stockholders, etc.
 Cooperative (Co-Op): Non-profit, customer-owned electric companies that generate and/or distribute electric power.
 Municipal: A municipal utility, responsible for power supply and distribution in a small region, such as a city.
 Sub-division: Political subdivision utility is a county, municipality, school district, hospital district, or any other political subdivision that is not classified as a municipality under state law.
 Private: Similar to an investor-owned utility, however, ownership shares are not openly traded on the stock markets.
 State: Utility owned by the state.
 Federal: Utility owned by the federal government.
Next, EPA used both the D&B Hoovers online database and the VS database to identify the ultimate owners of power plant owners identified in the VS database. This was necessary, as many majority owners of power plants (listed in VS) are themselves owned by other ultimate parent entities (listed in D&B Hoovers). In these cases, the ultimate parent entity was identified via D&B Hoovers, whether domestically or internationally owned.
EPA followed SBA size standards to determine which non-government ultimate parent entities should be considered small entities in this analysis. These SBA size standards are specific to each industry, each having a threshold level of either employees, revenue, or assets below which an entity is considered small. SBA guidelines list all industries, along with their associated North American Industry Classification System (NAICS) code and SBA size standard. Therefore, it was necessary to identify the specific NAICS code associated with each ultimate parent entity in order to understand the appropriate size standard to apply. Data from D&B Hoovers was used to identify the NAICS codes for most of the ultimate parent entities. In many cases, an entity that is a majority owner of a power plant is itself owned by an ultimate parent entity with a primary business other than electric power generation. Therefore, it was necessary to consider SBA entity size guidelines for the range of NAICS codes listed in Table 5-1. This table represents the range of NAICS codes and areas of primary business of ultimate parent entities that are majority owners of potentially affected EGUs in EPA's IPM base case.

Table 5-1	SBA Size Standards by NAICS Code
                                  NAICS Code
                           NAICS U.S. Industry Title
                      Size Standard (millions of dollars)
                      Size Standard (number of employees)
                                    211120
Crude Petroleum Extraction

                                     1,250
                                    212221
Gold Ore Mining

                                     1,500
                                    221111
Hydroelectric Power Generation

                                      500
                                    221112
Fossil Fuel Electric Power Generation

                                      750
                                    221113
Nuclear Electric Power Generation

                                      750
                                    221114
Solar Electric Power Generation

                                      250
                                    221115
Wind Electric Power Generation

                                      250
                                    221116
Geothermal Electric Power Generation

                                      250
                                    221117
Biomass Electric Power Generation

                                      250
                                    221118
Other Electric Power Generation

                                      250
                                    221121
Electric Bulk Power Transmission and Control

                                      500
                                    221122
Electric Power Distribution

                                     1,000
                                    221210
Natural Gas Distribution

                                     1,000
                                    221310
Water Supply and Irrigation Systems
                                    $41.00

                                    221320
Sewage Treatment Facilities
                                    $35.00

                                    221330
Steam and Air Conditioning Supply
                                    $30.00

                                    311221
Wet Corn Milling

                                     1,250
                                    311224
Soybean and Other Oilseed Processing

                                     1,000
                                    322121
Paper (except Newsprint) Mills

                                     1,250
                                    325611
Soap and Other Detergent Manufacturing

                                     1,000
                                    325920
Explosives Manufacturing

                                      750
                                    331110
Iron and Steel Mills and Ferroalloy Manufacturing

                                     1,500
                                    332313
Plate Work Manufacturing

                                      750
                                    332911
Industrial Valve Manufacturing

                                      750
                                    333611
Turbine and Turbine Generator Set Unit Manufacturing

                                     1,500
                                    333613
Mechanical Power Transmission Equipment Manufacturing
                                      750
                                    423520
Coal and Other Mineral and Ore Merchant Wholesalers

                                      200
                                    423990
Other Miscellaneous Durable Goods Merchant Wholesalers
                                      100
                                    424690
Other Chemical and Allied Products Merchant Wholesalers
                                      175
                                    424720
Petroleum and Petroleum Products Merchant Wholesalers
                                      200
                                    522110
Commercial Banking
                                    $750.00

                                    523210
Securities and Commodity Exchanges
                                    $47.00

                                    523910
Miscellaneous Intermediation
                                    $44.25

                                    523930
Investment Advice
                                    $41.50

                                    524126
Direct Property and Casualty Insurance Carriers

                                     1,500
                                    525910
Open-End Investment Funds
                                    $37.50

                                    525990
Other Financial Vehicles
                                    $40.00

                                    541330
Engineering Services
                                    $22.50

                                    541611
Administrative Management and General Management Consulting Services
                                    $21.50

                                    541715
Research and Development in the Physical, Engineering, and Life Sciences (except Nanotechnology and Biotechnology)
                                     1,000
                                    551112
Offices of Other Holding Companies
                                    $45.50

                                    611310
Colleges, Universities and Professional Schools
                                    $30.50

                                    721110
Hotels (except Casino Hotels) and Motels
                                    $35.00

                                    813910
Business Associations
                                    $13.50

Note: Based on size standards effective at the time EPA conducted this analysis (SBA size standards, effective December 19, 2022. Available at the following link: https://www.sba.gov/document/support--table-size-standards). Source: SBA, 2022.

EPA compared the relevant entity size criterion for each ultimate parent entity to the SBA size standard noted in Table 5-1. We used the following data sources and methodology to estimate the relevant size criterion values for each ultimate parent entity:
 Employment, Revenue, and Assets: EPA used the D&B Hoovers database as the primary source for information on ultimate parent entity employee numbers, revenue, and assets. In parallel, EPA also considered estimated revenues from affected EGUs based on analysis of IPM parsed-file estimates for the baseline run for 2028. EPA assumed that the ultimate parent entity revenue was the larger of the two revenue estimates. In limited instances, supplemental research was also conducted to estimate an ultimate parent entity's number of employees, revenue, or assets.

 Population: Municipal entities are defined as small if they serve populations of less than 50,000. EPA primarily relied on data from the Ventyx database and the U.S. Census Bureau to inform this determination.

Ultimate parent entities for which the relevant measure is less than the SBA size standard were identified as small entities and carried forward in this analysis.
In the projected results for 2028, EPA identified 358 potentially affected EGUs, owned by 107 entities. Of these, EPA identified 41 potentially affected EGUs owned by 26 small entities included in the power sector baseline.
The chosen compliance strategy will be primarily a function of the unit's marginal control costs and its position relative to the marginal control costs of other units. To attempt to account for each potential control strategy, EPA estimates compliance costs as follows:
	CCompliance = Δ COperating+Retrofit + Δ CFuel + Δ R
where C represents a component of cost as labeled and Δ R represents the change in revenues, calculated as the difference in value of electricity generation between the baseline case and the rule in in 2028.
Realistically, compliance choices and market conditions can combine such that an entity may actually experience a reduction in any of the individual components of cost. Under the rule, some units will forgo some level of electricity generation (and thus revenues) to comply, and this impact will be lessened on these entities by the projected increase in electricity prices under the rule. On the other hand, those units increasing generation levels will see an increase in electricity revenues and as a result, lower net compliance costs. If entities are able to increase revenue more than an increase in fuel cost and other operating costs, ultimately, they will have negative net compliance costs (or increased profit). Overall, small entities are not projected to install relatively costly emissions control retrofits but may choose to do so in some instances. Because this analysis evaluates the total costs along each of the compliance strategies laid out above for each entity, it inevitably captures gains such as those described. As a result, what we describe as cost is actually a measure of the net economic impact of the rule on small entities.
For this analysis, EPA used IPM-parsed output to estimate costs based on the parameters above, at the unit level. These impacts were then summed for each small entity, adjusting for ownership share. Net impact estimates were based on the following: operating and retrofit costs, sale or purchase of allowances, and the change in fuel costs or electricity generation revenues under the proposed MATS requirements relative to the base case. These individual components of compliance costs were estimated as follows:
 Operating and retrofit costs (Δ COperating+Retrofit): EPA projected which compliance option would be selected by each EGU in 2028 and applied the appropriate cost to this choice (for details, please see Section 3 of this RIA). For 2028, IPM projected retrofit costs were also included in the calculation.
 Fuel costs (Δ CFuel): The change in fuel expenditures under the proposed requirements was estimated by taking the difference in projected fuel expenditures between the IPM estimates under the proposed requirements and the baseline.
 Value of electricity generated (Δ CFuel): To estimate the value of electricity generated, the projected level of electricity generation is multiplied by the regional-adjusted retail electricity price ($/MWh) estimate, for all entities except those categorized as private in Ventyx. See Section 3 for a discussion of the Retail Price Model, which was used to estimate the change in the retail price of electricity. For private entities, EPA used the wholesale electricity price instead of the retail electricity price because most of the private entities are independent power producers (IPP). IPPs sell their electricity to wholesale purchasers and do not own transmission facilities. Thus, their revenue was estimated with wholesale electricity prices.
Results