Ex Ante Costs Versus Ex Post Costs of the Large Municipal Waste Combustor Rule

This article compares the U.S. Environmental Protection Agency’s (EPA) ex ante cost analysis of its 1995 Large Municipal Waste Combustor (MWC): New Source Performance Standards and Emissions Guidelines rule to an ex post assessment of its cost. Unlike many retrospective cost analyses, where ex post assessments are limited due to lack of data on compliance costs, this case study is unique because we located and used plant-level survey data from the U.S. Department of Energy and Governmental Advisory Associates in a comparison of ex ante and ex post costs of individual MWCs. We find the ex post capital expenditures for nitrogen oxide control systems are typically lower than the EPA ex ante estimates, while the ex post capital expenditures for mercury control systems tend to be higher than the EPA ex ante estimates. Finally, while we find a few outliers, the average ratio of ex post to ex ante capital expenditures for particulate matter and sulfur dioxide emissions control is near unity.