A Preliminary Analysis of the Benefits and Costs of Current New Source Review Litigation

If all 51 plants charged with NSR violations were cleaned up to BACT levels, avoided asthma and premature deaths alone would total $24-38 billion 1999 dollars. The total cost of the reductions is roughly an order of magnitude less than the benefits–on an annual basis, the cost to clean up these plants would amount to about $3.6 billion 2001 dollars. This means that the benefits outweigh the annual costs of pollution controls by seven to ten times. NSR enforcement holds significant promise for reducing particulate matter, ozone, haze and acid rain where impacts are most severe and emissions reductions will have the most benefit.