Review of the Air Quality Criteria Document for Particulate Matter

passive use values as opposed to use and non-use, to better identify that in some cases visibilityis actively enjoyed, while in other cases it is passively enjoyed, and realize that it is oftendifficult to separate benefits by these categories (e.g., where does option value fall?). Page 5-23of the staff paper was missing.Criteria Document Chapter 4: Environmental EffectsGeneral Notes Overall, this section is reasonably comprehensive. Two overridingconsiderations are (1) can the presentation be more focused to key questions in the setting ofstandards, rather than a litany of information and appendicies (this seems particularly true for theglobal climate sections), and (2) can economics, if it is to be addressed at all, be addressed moreconsistency in the various subsections.Section 4.2.2: Natural Ecosystems- Lines 7 through 15. I recommend some terminology clean-up here, rather than propogatingterms inconsistent with the broader resource economics literature. All benefits fromecosystems can be described as ecosystem services. I think this could use revision,especially on page 4-20, to state something along the lines of “there are a wide range ofecosystem services, including (1) some with readily recognized market value (e.g., fish,timber, minerals,…) and (2) others services without current or readily identified marketvalues. For the purposes of this discussion only, we refer to the first group as “marketservices” or “goods” and the second as “non-market services”. Table 4.2 illustrates variousmarket and non-market services provided by ecosystems…” Then, I think Table 4-6 is muchmore informative than Table 4-2 and could replace Table 4-2.- Page 4-83 identifies economic literature to demonstrate the significance of ecologicresources and services to mankind (Pimentel and Costanza). These numbers are presented,perhaps, with too much credence. There is significant controversy in the economics literatureabout the reliability of the specific estimates (See the Special Issue of Ecologic Economics,April 1998, and Freeman, 1999), not the least of which is that economics is much bettersuited to evaluate individual services, or better yet changes in service flows for an individualecologic service, than it is to evaluate the total value of all ecologic services. Economicsaside, most all agree that ecologic services are central to human life and obviously ofsubstantial value. Consequently, substantive impact on ecologic services have the potential tohave an important impact on human welfare.Section 4.3.9 Visibility Economics. Generally, there should be more consistency to the StaffPaper write-up. To the degree this is retained along its current lines, I note the following edits.- Page 4-111 line 27. Replace “costs” with “losses” (here and generally throughout thesection).- Page 4-111, line 29, replace “cost/benefits” with “losses from visibility impairment”.- Page 4-111 line 31, and continuing to page 4-113, line 3. The avoided cost method, whileused as a market cost measure of materials damage, and sometimes in other application, isnot used in the visibility literature and should not even be discussed here. Just start withsomething similar to line 4 “There are several methods….”- Page 4-113, line 12, it would be useful to have a citation on visibility property value studies(e.g., Chestnut and Dennis, or the NAPAP work from a few years earlier for summaries,which is cited elsewhere in the CD and staff paper). There is quite a bit of property valueliterature, with the difficulty of sorting out value differences into visibility and healthcomponents. One could also cite some of the new property value applications (Thayer andMurdoch).A - 72