EPA's Cost Estimates of the RRP Rule

[ChrWright]

If you've got some extra time on your hands, here's a document you might find interesting:

http://www.epa.gov/oppt/economics/pubs/lrrpnprmea.pdf


Page 4 has a chart of costs for various projects. Looks to me like they didn't include the cost of the lead safe practices (bagging, plastic wrapping, etc.)

1000+ pages...

[Silvertree]

Here's the fee study along with some other stuff.


http://www.epa.gov/fedrgstr/EPA-TOX/2009/March/Day-20/t6167.htm

[SLS-Construction]

Off of Chris's link, I am only on page 44 - quick notes


EPA's Original Proposal which included FLEXIBLE work practices: (Page 10)
All renter-occupied target housing units built before 1960, and owner-occupied target housing units built before 1960 where a child under the age of six resides, plus all target housing units built before 1978 where a child with an increased blood-lead level resides.

What we are currently stuck with was not even proposed or accounted for.

Training & Certification Costs only estimated @ $924 million (page 14)

Annulized costs - over 500 million a year (Page 17)

Cost per business - 1558 to 6000 per year (Page 18)



2005 costs based on Flexible Work Practices
Description Low High
Kitchen Remodel $28 $132
Bathroom Remodel $23 $63
Additions $26 $117
Non-Room-Specific Interior Walla $57 $528
Non-Room-Specific Window/Doorb $58 $528
Interior Paint $42 $285
Whole Exterior Remodel $161 $281
Exterior Remodel in Contained Areac $77 $77
Exterior Paint $161 $281
a Events that involve changes to a wall or walls, where the location is not specified. For
example: re-wiring or repair/replace heating or cooling systems.
b Repair/replacement of windows and/or doors, where the room is not specified.
c Outside repair/remodeling work that involves a specified part of the home, e.g.
installation of a deck.

[Silvertree]

One more thing, in the 1000 page report we find that about 350,000 contractors representing about 1.5 million workers are affected by this rule (trust me the info is there), this represents a vast group of people to collect fees from.
Maybe we can collectively balance the budget and bail out the bankers.

[JasonW]

I'm having a hard time wrapping my head around the idea of putting 20 to 24 square of old siding (average) into plastic bags in under an hour per day...

Oh, and do the rest of this stuff in that time frame as well. Nice of the EPA to blow smoke up the consumers a$$ and make our job of selling the project that much harder!

[SLS-Construction]

This just keeps getting better

Justification for Federal Regulations of Lead Exposure during Renovation
Executive Order 12866 calls for three findings to justify the need for a federal regulation. First, there should be a description of the market failure that can be corrected or other social purpose that can be met through regulation. Second, there should be n explanation of why the regulation should be carried out at the federal level. Finally, there should be a discussion of why current regulatory initiatives are not sufficient to correct the market failure.


The first criteria was met due to:
Incomplete/Incorrect Information (like that issue has been solved) & even with perfect information, the maximum amount that the individual consumer of the renovation would be willing to pay for lead-safe work is likely to be lower than the total amount that that particular consumer plus the other beneficiaries (including children, neighbors, etc.) would be willing-to-pay for the service.

Just wait they fix this by: The proposed regulatory options alter the nature of these three markets by providing information to the consumer and contractor about the risk associated with lead-based paint renovation activities and by requiring lead-safe containment and clean-up practices for professional projects.

PAGE 93: Can we start suing them come May?
However, the analysis does not suggest that the education factor is unimportant. If the regulation is not accompanied by education efforts and enforcement, then EPA could unintentionally drive up demand for non-compliant renovation projects creating additional welfare losses. These losses are the result of the fact that if consumers were aware of the lead paint issues their true marginal valuation for the noncompliant projects is lower than the price of these projects. Thus, if enforcement is not perfect, education is essential. EPA can compensate for the fact that it is raising the costs of lead-free renovation on the supply side by educating consumers on the environmental effects of non-compliant renovations thereby making these cheaper, non-compliant projects less attractive.

[SLS-Construction]

Can one say Garbage In - Garbage Out (that sums this whole thing up)

Tuition for the initial certified renovator training class is estimated to be $186;

Most of the costs used from the R.S. Means database are for an asbestos abatement project, which requires much more elaborate containment and clean up than required under the analyzed options. The R.S. Means labor estimates have been adjusted downwards based on conversations with industry experts to reflect the less stringent requirements of this proposed rule. (Flexible work standard practices...)

Some of the containment and cleaning practice standards specified by EPA under the RRP rule are currently in use by some renovation contractors. The costs of work practices already in use are not incremental costs of the rule and are subtracted out of the cost estimates.

It is estimated that firms will spend a total of three hours to familiarize themselves with the RRP rule’s
requirements and a half an hour to fill out and mail the one-page Application for renovator certification. In addition, firms will spend 5 minutes per-event keeping records that demonstrate compliance with the Renovation, Repair and Painting Rule training and work-practice requirements. At a loaded wage rate of $31.64, the time burden in the first year will be $276 per firm (see Table 4-26).
$165 a year afterwords for the 5 min per-event. (no this does not include the cost of the cert)

Ok I made it to page 156 - to bad the SEC can't investigate these guys record keeping & there version of the Prospectus

[tinner666]

I'm just going to add $550.-$1,500. per planned day into my proposals. That should be a close enough figure so I don't lose my butt. And pretty accurate, I believe.

[Leo G]

I think these guys writing all these rules need to have some renovation done on there houses. Then they can see how much it really affects them when it his there p[ocket book at 7-20% in increased cost of their project.

For the millions of dollars and all the "smart" people writing this, they certainly are clueless.