Sample Regulatory & Economic Analysis Projects

Evaluation of Overlapping Emergency Preparedness and Response Planning Requirements: Indtai identified the extent to which Federal emergency preparedness and planning statutes and regulations overlapped and placed unnecessary compliance burdens on industry. Indtai compiled and analyzed statutes and regulations in multiple federal agencies, and identified potential overlaps and mitigation steps. Indtai consultants created a database of over 13,000 EPA-regulated facilities subject to multiple federal emergency planning requirements. After a thorough evaluation, Indtai recommended streamlined requirements and interagency coordination in future rulemakings.

Superfund Outyear Liability Model: Indtai supports EPA's Office of Superfund Remediation Technology Innovation in the review, revision, and enhancement of the Superfund Outyear Liability Model (OLM) that is used to forecast remedial program activities and budget needs. Our consultants analyze key model assumptions regarding event costs, durations, and site characteristics and recommend improvements based on extensive data analyses. Indtai also enhanced the OLM's user interface and output reports, and performed QA/QC.

Benefit-Cost Analysis and High Cost Rules at the FAA: A senior Indtai consultant developed an approach for conducting post-promulgation analyses of the benefits and costs of high-cost regulations. He developed a strategy for agency/industry data-sharing (e.g., cost accounting data regarding compliance) to monitor the impacts of regulation immediately after promulgation so that regulators can assess the net value and unintended effects of regulations. He developed a pilot project for testing the regulatory evaluation methodology and paving new ground in timely agency/industry data sharing. The methodology and associated principles are applicable to all Federal agencies issuing high-cost regulations. For example, the approach would enable EPA to quickly gauge impacts on specific stakeholder groups, thereby improving the ability to meet "Reg Flex" requirements. The innovative methodology also enables regulators to consider alternative regulatory strategies (e.g., exclusions, conditional compliance schedules) based on real-time "hard" data from impacted stakeholders.

Superfund Benefit-Cost Analysis: An Indtai consultant conducted a benefit-cost analysis of various tax and revenue alternatives for financing the Superfund hazardous waste site cleanup program. The analysis supported EPA's Superfund reauthorization efforts by quantifying the tax burden on various industries relative to their share of historical Superfund response costs.

Financial Model for a State Revolving Loan Fund (SRF): Two of Indtai's consultants provided a wide range of support to EPA's Office of Water in the transition from the construction grants program to an SRF program for financing national wastewater treatment needs. One of our analysts developed a cash flow management model that States could use to establish SRFs and manage cash flow for building and operating wastewater treatment plants. The model allowed States to evaluate the financial health of SRFs by conducting sensitivity analysis on levels and timing of program capitalization and plant construction, issuance of municipal bonds, loan terms, and interest rates. Our analyst also developed a user manual for the SRF model that explained relevant financial concepts and defined key financial terms. He presented the model at a national municipal finance conference and trained Regional EPA personnel so that they, in turn, could assist state agency personnel on SRF implementation.

Wastewater Effluent Benefit-Cost Analysis: An Indtai consultant analyzed the economic benefits and costs of a company's non-compliance with wastewater effluent guidelines as part of a legal dispute. He analyzed the type and timing of wastewater treatment technologies employed at a major manufacturing plant. He also captured data and various assumptions in EPA's BEN (Economic Benefit of Noncompliance) Model to evaluate alternative estimates of damages to be paid to EPA.

Assessment of Damages from Sewage Discharge: One of Indtai's advisors served as a program director and expert witness for a regulatory damage assessment under the Clean Water Act. In assessing the impacts of sewage discharge on the New York Harbor, he prepared major support documents on ecological, physical/chemical, and economic estimates of damage associated with the discharge.

Innovative Application of Decision Theory to Environmental Management : Well in advance of ASTM International's adoption of a new industry standard regarding the use of probabilistic cost analysis to estimate environmental liabilities, Indtai consultants were developing models for assessing risks and quantifying costs to comply with environmental regulations and policies. For example, for many Fortune 500 companies, our consultants developed site-specific probabilistic cost models that evaluated the range of costs associated with investigation, remediation, compliance, toxic tort, third-party litigation, alternative cleanup/compliance standards, operations and maintenance, etc. Probabilistic environmental management models also have use in program management, risk management, and program evaluation contexts.

Strategic Environmental Risk Management Initiative: For an electric utility with a portfolio of almost 50 hazardous waste sites, multiple members of our team conducted a strategic environmental management initiative to examine various future response scenarios, taking into account regulatory drivers for site investigation and remediation, potential for toxic tort, natural resource damages and the viability of property sales. We worked with electric utility technical staff to compile site-specific data for all inactive sites and operating facilities. This involved evaluating historical operations and waste handling/disposal practices, ongoing solid waste management units, annual environmental-related compliance costs, groundwater impacts and risks, effluent discharges and permit compliance history, impacted surface waterways, and sensitive human and ecological receptors. Our staff developed probabilistic cost models that accounted for hundreds of variables and scenarios. We conducted sensitivity analyses using the site cost models to test timing and discount rate assumptions, evaluate risks and consider potential alternative regulatory policies, cleanup standards, and remedy decisions. We briefed utility management on risks, range of costs including "expected value" at each site, and possible site response strategies.

Regulatory Reform at DOE: An Indtai staff member consulted to the project team analyzing regulatory reform initiatives at DOE. She analyzed approaches for rulemaking, including no-rule options and techniques for motivating voluntary compliance. She interviewed DOE personnel and reviewed many Department documents. She assessed the effectiveness of benefit-cost analysis for regulation writing and designed and wrote a handbook on rulemaking for DOE staff that presented the rationale and procedures of this complex process in user-friendly language.

Multimedia Regulatory Program Management: Serving as Deputy Assistant Secretary of the Air Force, one of our advisors managed that service's far-reaching environmental, occupational health and safety, and energy conservation programs. He oversaw policy development and compliance/response activities dealing with groundwater contamination, toxic and hazardous materials, health effects of Agent Orange (dioxin), microwave risks, noise, and environmental impact assessments.

Allocation of Cleanup Liability: For many Fortune 500 companies, Indtai consultants analyzed ownership, operational, and other types of data to allocate response costs among responsible parties. We routinely applied multiple allocation theories (e.g., cost-causation) and principles (e.g., "Gore Factors") in the analysis of liability shares. Our analysts have been involved in the development of expert reports and participated in settlement proceedings.

State Sludge Management Regulations: One of our analysts participated in a study to evaluate proposed sludge management regulations and the institutional requirements and burdens placed on states and local communities. She assisted EPA in reviewing, addressing, and responding to comments on proposed sludge rulemakings. She assisted in developing guidance to states on the preparation of state sludge inventories, sludge management program plans, and monitoring activities.

Evaluation of Alternative Energy Sources: One of Indtai's advisors led several Federal and state studies of technical, economic, and social options for conserving energy from fossil fuels. The technologies studied included nuclear power, hydroelectric power, various forms of solar energy, and ocean thermal energy. The technology assessments also covered the economic and social factors important to energy conservation.