Regulation of Cooling Water Intake Structures at Existing Facilities

The Stockholm Environment Institute critiques the EPA's cost-benefit analysis for cooling water intake regulations, arguing that monetized benefits are severely underestimated due to the exclusion of non-use values and errors in baseline mortality data. The authors suggest that when benefits are properly calculated and costs are reassessed, the regulations yield positive net benefits with minimal impact on electricity rates and a positive effect on employment and GDP. They strongly advise against site-specific calculations, recommending instead a national standard with a higher threshold for compliance.

• The authors argue that the EPA's monetized benefit estimates for regulating cooling water intake structures are significantly underestimated because they exclude numerous important benefit categories. These omissions include indirect-use marketed-goods benefits (such as ecotourism and property values), direct-use non-market benefits (such as subsistence fishing), and the majority of non-use values for aquatic ecosystems.
• A comparison between EPA's data and a study of the Bay Shore Power Plant (BSPP) in Ohio suggests that EPA's baseline mortality estimates for certain species, such as walleye in the Great Lakes, are erroneously low. The BSPP study found impingement of tens of thousands of walleyes per year at a single plant, whereas EPA's estimates for the entire Great Lakes region were in the hundreds.
• The authors contend that the EPA's calculation of non-use values is flawed because it only applies values from a single Rhode Island study to two of seven regions, effectively setting non-use values to zero for the rest of the country. They argue that non-use benefits should be calculated on a national basis, as people value the protection of ecosystems regardless of their proximity to them.
• The authors present a combined recalculation of benefits and costs (incorporating a cost reassessment by Bill Powers) which indicates that net benefits are positive for every regulatory option at both 3 percent and 7 percent discount rates.
• The document argues that the EPA's projected impacts on electricity rates are minimal. While a simple model suggests increases of up to $17.60 per household under Option 3, a more sophisticated Integrated Planning Model (IPM) shows that for 2028, price increases in five NERC regions range up to only 0.5 percent, while three regions see decreases.
• The authors assert that stricter regulation (Option 3) is the most beneficial for employment and GDP. They argue that EPA's finding of job losses under stricter regulation is an overstatement because it assumes full cost recovery in deregulated states, which they claim is unlikely.
• The authors strongly oppose the use of site-specific calculations for determining the necessity of entrainment controls. They argue that if the EPA lacks the resources to complete benefit calculations at a national level, state and local agencies will be even less capable, leading to under-researched and inconsistent decisions.
• As an alternative to site-specific calculations, the authors suggest adopting a national standard with a higher threshold, such as requiring cooling towers only for facilities above 500 MGD. They estimate this would exempt roughly 80 percent of in-scope facilities while still achieving 80 percent of the benefits of the most stringent option.

APA

Ackerman, F., & Stanton, E. A. (2011). Regulation of Cooling Water Intake Structures at Existing Facilities. Stockholm Environment Institute. https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/Economics_of_climate_policy/SEI-EPA-testimony-cooling-water-Aug2011.pdf

Chicago

Ackerman, Frank, and Elizabeth A. Stanton. Regulation of Cooling Water Intake Structures at Existing Facilities. Stockholm Environment Institute, 2011. https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/Economics_of_climate_policy/SEI-EPA-testimony-cooling-water-Aug2011.pdf.

Wikipedia

{{cite press release |last1=Ackerman |first1=Frank |last2=Stanton |first2=Elizabeth A. |title=Regulation of Cooling Water Intake Structures at Existing Facilities |publisher=Stockholm Environment Institute |date=18 August 2011 |url=https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/Economics_of_climate_policy/SEI-EPA-testimony-cooling-water-Aug2011.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{ackerman2011regulation, author = {Ackerman, Frank and Stanton, Elizabeth A.}, title = {{Regulation of Cooling Water Intake Structures at Existing Facilities}}, publisher = {Stockholm Environment Institute}, year = {2011}, month = aug, url = {https://www.sei.org/mediamanager/documents/Publications/Climate-mitigation-adaptation/Economics_of_climate_policy/SEI-EPA-testimony-cooling-water-Aug2011.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }