ABSTRACT
Proponents, opponents, and some who aren't too sure have spilled much ink on the merits of cost–benefit analysis in support of government decisions, including the development of regulations. In this chapter, I present a proponent's view in the specific context of establishing requirements for cooling water intake structures (CWIS) at existing power plants (EPA 2004a). The policy context, regulatory proposal, and environmental and economic evaluation of this regulation are summarized by Harrington in Chapter 8 of this report. Voluminous comments were filed on particular aspects of the estimation procedures, and one more commenter on such details is unlikely to add much value. In its response to public comments, the U.S. Environmental Protection Agency (EPA) used 5,143 pages; of those, about 1,200 focused on benefits related to economics (EPA 2004e). Consequently, the focus of this chapter is on the consistency of the CWIS cost–benefit analysis with quality criteria to which the agency might have been expected to adhere and significantly less on specific details of the existing analysis.
