Future cost analyses of rule changes would more fully represent areas of possible costs differences if they were more explicit in describing the differences between the rules over time. Administrative, load control, and water quality opportunity costs could be analyzed and reported as a cash flow over time, showing what sectors bear the costs as nutrient load reductions at different levels are pursued. Comparing the rules over time also can provide an opportunity to present a realistic picture of how the timing of water quality improvement actions might unfold with alternative rules, by illustrating the time lags between listing and achievement of water quality standards. Most importantly, reporting on timing would provide useful information for predicting annual budgetary requirements.

Uncertainty is pervasive in estimating the incremental cost of implementing the NNC rule and is inadequately represented in the EPA analysis. In future analyses, reporting the difference in the time paths for implementation of water quality management rules, and associated uncertainties, would provide a more transparent and realistic way to compare costs of the different rules and provide more useful information about where, when, and how costs diverge.

Some Florida stakeholders viewed the EPA cost analysis as being superficial or of limited scope, leading to reduced credibility. The result was to foster disagreement about embedded assumptions rather than using the analysis to isolate and possibly reconcile sources of disagreement. Cost analysis as outlined above can help convey cost estimates in a more transparent way and thus facilitate learning, reduce misunderstandings among stakeholders, and increase public confidence in the results.

Conducting an alternative cost analysis, with increased attention to careful assessment of rule differences, stakeholder engagement, and uncertainty analysis, might not have been possible with the budget and time EPA spent on its cost analysis. Any critique of the existing EPA cost analysis should recognize that some deficiencies may be traced to time and budget limitations.



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