Retrospective Evaluation of the Costs Associated with the 2004 Automobile and Light-Duty Truck Surface Coating NESHAP

The extent to which ex-ante estimates of the costs of regulation differ from ex-post estimates is an empirical question of considerable interest to policymakers, regulated entities, and the public. This paper examines evidence on the actual costs of compliance with the 2004 Automobile and Light-Duty Truck Surface Coating NESHAP and then compares these estimates to the EPA’s ex-ante cost estimates to identify key drivers of any differences. This regulation is particularly interesting from a cost perspective because at the time of promulgation the EPA considered it to be economically significant (and it was therefore accompanied by an extensive cost analysis), under stood who was likely to be regulated under the NESHAP, and had identified several available technologies that could be used to reduce HAP emissions. Data on ex-post costs are gathered from a subset of the industry via survey and follow-up interview. We find that the EPA overestimated the cost of compliance for these plants and that overestimation was driven primarily by use of estimation methods that did not account for regulatory flexibilities such as the ability to utilize any effective HAPs control method. Thus, we find that differences between ex ante and ex post cost estimates for our sample of facilities are primarily driven by differences in the method of compliance rather than differences in the per-unit cost associated with a given compliance approach. In particular, the EPA expected facilities to install pollution abatement control technologies in their paint shops to reduce emissions of hazardous air pollutants, but instead these plants complied by reformulating their coatings.