Regulation of Cooling Water Intake Structures at Existing Facilities

The authors argue that the EPA's cost-benefit analysis for cooling water intake structures (CWISs) is fundamentally flawed due to the systematic underestimation of environmental benefits and the overestimation of costs. By incorporating a wider range of non-use values, correcting recreational value estimates based on the Bay Shore Power Plant study, and using revised cost estimates from Powers Engineering, the authors demonstrate that the most stringent regulatory options (Options 2 and 3) can yield positive net benefits. They further contend that the economic impact on electricity rates would be minimal and that stricter regulation would actually be more beneficial for national GDP and employment. Finally, they strongly oppose the use of site-specific calculations, suggesting instead a national standard with a higher threshold (e.g., 500 MGD) to protect smaller facilities while maintaining high environmental benefits.

• The EPA's monetized benefit estimates are significantly lower than costs, but this is due to the exclusion of numerous benefit categories and analytical errors. The authors suggest that the monetizable benefits are "much greater than EPA’s estimates would suggest."
• Recreational value estimates by the EPA are likely too low; for example, the EPA valued walleye at $4.10 per fish, while a study of the Bay Shore Power Plant (BSPP) estimated the value at $20.05. Applying the BSPP ratio of benefits to baseline mortality results in recreational and commercial benefits approximately 15 times larger than the EPA's estimates.
• The EPA's treatment of threatened and endangered species is inadequate, focusing only on recreational use for two species. The authors argue that the non-use value of these species is categorically different from market prices and that a benefits transfer method assuming 2% or 4% population losses would significantly increase net benefits.
• When combining revised benefit estimates with cost assessments from Bill Powers—which find compliance costs for power plants to be roughly 63% of EPA's figures—net benefits become positive for every regulatory option at both 3% and 7% discount rates.
• The impact of regulation on electricity rates is projected to be minimal. While a simple model suggests small increases, a more sophisticated Integrated Planning Model (IPM) indicates that for 2028, Option 3 would have no "material ongoing effect on capacity availability and supply reliability" and would result in price changes ranging from a 1.7% drop to a 0.5% increase across NERC regions.
• Contrary to EPA's initial employment projections, the authors argue that stricter regulation (Option 3) is best for employment and output. They claim that if generators in deregulated states only pass through 50% of costs, Option 3 would create a net increase in employment.
• The authors strongly recommend against site-specific calculations, arguing that state and local agencies lack the resources to perform the complex benefit valuations that the EPA struggled to complete at a national level.
• As an alternative to site-specific decisions, the authors propose a national standard with a higher threshold, such as 500 MGD. This would exempt about 80% of facilities while still capturing 80% 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} }