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Technical Comments of Avx Corporation on Epa's Proposed Remediation

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Technical Comments of Avx Corporation on Epa's Proposed Remediation Supertund Kecords Cemar SITE: BREAK: RE: ALLEGED INJURY TO PROPERTY VALUES OTHER: . 24500 The books listed below are written by authorities on the topics which the books address and both the books and the authors are generally relied upon by experts. A. George Judge, et al., The Theory and Practice of Econometrics, second edition. (Wiley. 1985). B. Takeshi Amemiya, Advanced Econometrics (Harvard University Press. 1985) C. Charles F. Manski and Daniel McFadden, Structured Analysis of Discrete Data with Econometric Applications, (MIT Press, 1981). D. G. S. Maddala, Limited-dependent and Qualitative Variables in Econometrics, (Cambridge University Press, 1983). E. Hsaio, Cheng. Analysis of Panel Data, (Cambridge University Press, 1986). E. Jon P. Nelson, Economic Analysis of Transportation Noise Abatement, (Ballinger, 1978). 24501 The Maps listed below are official surveyors' maps of the areas they depict. A. 1980 Census Tracts Map, New Bedford, Massachusetts, Standard Metropolitan Statistical Area. B. City of New Bedford, Bristol County, Massachusetts. Index Map showing locations of detailed Assessors Maps C. City of New Bedford, Bristol County, Massachusetts, Zoning Map D. Town of Fairhaven, Massachusetts, Index Map showing locations of detailed Assessors maps. Town of Fairhaven, Massachusetts, Zoning Map, prepared by the Fairhaven Planning Board, revised June 1986. 24502 Professor Mendelsohn prepared five versions of his Repeat Sales Study. 24503 Attachment Q.VIII.d.1 contains a true and accurate copy of Professor Mendelsohn's repeat sales study entitled Assessment of Economic Damages: Analysis of Residential Property Values in the New Bedford Area, Final Report, June 2, 1986. 24504 Attachment Q.VIII.d.2 contains a true and accurate copy of Professor Mendelsohn's repeat sales study entitled Assessment of Economic Damages From PCB Contamination in the New Bedford Area Using Residential Property Values, Final Report, October 1, 1986. 24505 Attachment Q.VIII.d.3 contains a true and accurate copy of Professor Mendelsohn's repeat sales study entitled Assessment of Damages by PCB Contamination to New Bedford Harbor Amenities Using Residential Property Values, Final Report, November 12, 1986. 24506 Attachment Q.VIII.d.4 contains a true and accurate copy of Professor Mendelsohn's repeat sales study entitled Measuring the Aesthetic Damages from Hazardous Wastes, February 20. 1987. 24507 Tables 2. 3, and 4 in Attachment Q.VIII.d.5 contain results of Professor Mendelsohn's Repeat Sales Study that are reported in the Plaintiff's 1990 RFAs. 24508 Attachment Q.VIII.d.5 contains a true and accurate copy of Tables 2, 3, and 4 of the Plaintiffs RFAs. 24509 An hypothesis of the Repeat Sales Study is that the price of housing in the New Bedford Harbor area reflects the use value of the natural resources in the New Bedford Harbor. 24510 An hypothesis of the Repeat Sales Study is that people who live in the New Bedford Harbor area are willing to pay more to live near the harbor than they would be willing to pay for otherwise identical housing farther away from the harbor. 24511 An hypothesis of the Repeat Sales Study is that if the use value of the harbor's resources has declined because of PCB contamination, then homes close to the harbor will experience a greater drop in value than compared to homes farther away from the harbor. 24512 The purpose of Professor Mendelsohn's Repeat Sales Study is to measure the damage to the natural resources of the harbor caused by PCB contamination if such damage occurred. 24513 An assumption of Professor Mendelsohn's Repeat Sales Study is that if PCB contamination causes housing prices to decline, then this reflects damage to the natural resources in New Bedford Harbor; that is, declines in housing prices are used as a proxy for damage to the natural resources in the harbor. 24514 The study is not intended to show that if PCB contamination causes the prices of houses to decline, then this demonstrates injury to those houses. 24515 Professor Mendelsohn's Repeat Sales Study does not demonstrate injury to houses in New Bedford Harbor. 24516 If PCB contamination causes the prices of houses to decline, then this may reflect a financial impact on the owners of the houses. 24517 If PCB contamination causes the prices of houses to decline, then this does not necessarily reflect injury to the house or property. 24518 Attachment Q.VIII.d.6 contains a true and accurate copy of an article by K.E. McConnell, "Hedonic and Travel Cost Models," Land Economics, Vol. 66, No. 2 (May 1990), pp. 121-127. 24519 McConnell concludes that if an hedonic study indicates that PCB contamination affects housing prices, the housing price impacts cannot be added to impacts derived from travel cost analyses of recreation use to determine the total impacts. 24520 McConnell concludes that using the results of hedonic studies along with those of recreation demand studies based on travel costs involves double counting. 24521 Even if an hedonic or repeat sales study purports to indicate that PCB contamination affects housing prices, the housing price impacts cannot be added to impacts derived from travel cost analyses of recreation use to determine the total impacts. 24522 Using the results of hedonic or repeat sales studies along with those of recreation demand studies based on travel costs involves double counting. 24523 An econometric model designed to explain variations in housing prices by variations in exposure to PCB pollution is not valid when it relies on a sample of houses for which the level of exposure to PCB pollution does not vary. 24524 An econometric model designed to explain variations in housing prices by variations in exposure to PCB pollution must be able to hold the influences of other factors constant. 24525 A repeat sales study requires accurate data on market prices of houses and on the dates of the transactions. 24526 If a repeat sales study relies only on information for houses that were equally affected by the presence of PCBs in New Bedford Harbor, the effects of PCBs on real estate prices cannot be distinguished from the effects of other local market forces. 24527 The New Bedford Harbor is polluted with raw sewage and untreated wastewater. 24528 According to the assumptions that underlie Professor Mendelsohn's model, prospective homebuyers would pay more for a house near unpolluted water that is in all other respects exactly the same as a house near polluted water, regardless of what pollutants are present in the polluted water. 24529 If a repeat sales study uses information on houses whose values were not equally affected by the presence of PCBs in New Bedford Harbor, and if the effect of PCBs on property values is influenced by other factors that determine property values, then the effects of these other factors must be included in an analysis of sale prices of houses. 24530 Professor Mendelsohn did not use all of the data that were available to him pertaining to housing characteristics and other factors that affect housing prices. 24531 Professor Mendelsohn intended to estimate a model using only single-family homes in single-family neighborhoods. 24532 Professor Mendelsohn included properties with rental units in his sample. 24533 If preferences shift over time so that houses adjacent to waters that are known to be polluted become less desirable, then property values adjacent to polluted waters will decline over time relative to other property values, all other factors being held constant. 24534 If variations in the level of PCBs and in the levels of other pollutants in New Bedford Harbor are perfectly correlated, then the effects of PCBs on property values cannot be distinguished from the effects of other pollutants, should such effects exist. 24535 If variations in the level of PCBs and in the levels of other pollutants in New Bedford Harbor are highly correlated, then it is very difficult to distinguish the effects of PCBs on property values from the effects of other pollutants, should such effects exist. 24536 If the variations in the level of PCBs and in the levels of other pollutants in New Bedford are not perfectly correlated, then a repeat sales study of the effects of PCBs on property values must control for the effects of other pollutants in New Bedford Harbor. 24537 The time period over which Professor Mendelsohn has observations on the sale prices of houses is 1969 through 1989, 21 years. 24538 It is unlikely that preferences for housing in the New Bedford area have remained constant over such a long period of time. 24539 It is likely that variations in PCB levels and the levels of other pollutants in the New Bedford Harbor are highly correlated. 24540 It would be very difficult to distinguish the effects of PCBs on housing prices from the effects of other pollutants on housing prices should such an effects exist 24541 A repeat sales study of the effects of PCBs on property values must control for the effects of other pollutants in New Bedford Harbor. 24542 The basis for repeat sales analysis is the relationship between the price of a house and the characteristics of the house and other factors that determine the price level. 24543 The basis for repeat sales analysis is hedonic price index analysis. 24544 The basic model equation for a repeat sales study should be specified in terms of the sales price of a house at a given time, rather than the change in price between two sales. 24545 A repeat sales model which purports to estimate the effects of PCBs on housing prices is not valid if it does not include all factors that affect housing prices that vary across time and across time and houses. 24546 Attachment Q.VIII.d.7 is a true and accurate copy of an article by Karl E.
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