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Valuing Visibility in National Parks: Study Plan

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VALUING VISIBILITY IN NATIONAL PARKS: STUDY PLAN DRAFT FINAL Prepared by: Kevin J. Boyle (Virginia Tech University) Richard C. Carson (University of California, San Diego) Christopher G. Leggett (Industrial Economics) Robert Paterson (Industrial Economics) Robert Unsworth (Industrial Economics) With contributions from: Pam Rathbun (PA Consulting) Robert Baumgardner (PA Consulting) John Molenar (Air Resource Specialists) Robert Cameron Mitchell (Clark University) Carlos Silva (Industrial Economics) Prepared for: Susan Johnson Air Resources Division U.S. National Park Service 12795 W. Alameda Parkway P.O. Box 25287 Denver, Colorado 80225 July 2006 Industrial Economics, Incorporated 2067 Massachusetts Avenue Cambridge, Massachusetts 02140 1 INTRODUCTION This document describes a plan for a study designed to estimate the benefits of visibility improvements in national parks and wilderness areas. The study will focus in particular on the visibility improvements expected to result from the implementation of the Regional Haze Rule, but it is anticipated that the results may also be used to evaluate benefits associated with other regulations that impact visibility. The study will involve a nationally representative survey with valuation questions designed to determine the benefits of visibility improvements to U.S. households. Policy Context Specific visibility provisions were included in Sections 169A, 169B, and 110(a)(2)(j) of the Clean Air Act that directed the Environmental Protection Agency (EPA), the states, and federal land managers to prevent any future, and remedy any existing, human-induced visibility impairment at mandatory Federal Class I areas. Mandatory Federal Class I areas (hereafter referred to as "Class I areas") are defined as national parks exceeding 6000 acres, wilderness areas and national memorial parks exceeding 5000 acres, and all international parks that were in existence on August 7, 1977. There are 156 Class I areas throughout the country, including many well-known national parks and wilderness areas, such as the Grand Canyon, Great Smokies, Shenandoah, Yellowstone, Yosemite, the Everglades, and the Boundary Waters (Exhibit 1). In 1980, the EPA promulgated regulations to address visibility impairment reasonably attributable to one or a small group of sources. The EPA defined visibility impairment as “any humanly perceptible change in visibility (visual range, contrast, coloration) from that which would have existed under natural conditions.” The 1980 regulations established procedures to evaluate existing stationary sources and new sources: • States are required to determine which existing stationary facilities should install the Best Available Retrofit Technology (BART) for controlling pollutants that impair visibility in a Class I area. • Permit applicants must assess potential visibility impacts in Class I areas due to new or modified major stationary sources. • States must develop a State Implementation Plan (SIP) detailing a long-term strategy for reversing existing visibility impairments in Class I areas and preventing future impairments. In 1999, the EPA promulgated the Regional Haze Rule (40 CFR Part 51) to address emissions of visibility-impairing fine particles and their precursors from numerous sources over wide geographic areas. This rule calls for states to establish goals and emissions reduction strategies for improving visibility in all 156 Class I national parks and wilderness areas. The Regional Haze Rule encourages states to work together in regional partnerships to develop and 2 implement multi-state strategies to reduce emissions of visibility-impairing pollution. As fine particles are often transported hundreds of miles, all 50 states must participate in the planning and analysis required by the Regional Haze Rule, including states that do not contain Class I areas. Although the Clean Air Act explicitly prohibits the consideration of costs and benefits in setting primary air quality standards, federal and state agencies may consider costs and benefits when analyzing policies that impact visibility: • States may consider costs and benefits when evaluating alternative BART control options for stationary sources. • States and/or regional planning organizations may consider costs and benefits in selecting appropriate visibility-reduction goals under the Regional Haze Rule. • If a regulation is likely to involve annual effects on the economy of $100 million or more, then under Executive Order 12866, a formal regulatory impact analysis (RIA) is required. The RIA must evaluate the costs and benefits of the proposed regulations as well as alternative regulatory approaches. This study will provide benefit estimates for visibility improvements that can be used in these analyses. While the study will focus specifically on the visibility improvements anticipated due to the Regional Haze Rule, we anticipate that the results will also be used to value related visibility improvements through benefits transfer. Valuation Methodology The value of visibility improvements to U.S. households will be determined through a statistical analysis of individuals' responses to carefully constructed survey questions. These survey questions, which are called "conjoint" or "attribute-based" choice questions, will use a combination of photographs and text to provide brief descriptions of policy scenarios, then ask the respondent to choose his or her preferred scenario. The attributes of the policy scenarios vary across questions and respondents, and a statistical analysis of the respondents’ choices allows the researcher to evaluate trade-offs among the attributes and to estimate marginal willingness to pay for improvements in specific attributes. Attribute-based choice questions were initially developed in the transportation and marketing literatures (Louviere, et al., 2000) as a way of estimating implicit prices/marginal willingness to pay for changes in the attributes of goods and determining how subjects trade off various attributes of goods that have yet to be introduced into consumer markets. Recently, the attribute-based choice question methodology has been applied to value a variety of environmental goods, including Atlantic salmon fishing (Teisl et al., 1996), benign timber harvesting practices (Boyle et al., 2001), waterfowl hunting (Gan and Luzar, 1993), green electricity (Roe et al., 2001), farmland preservation (Roe et al., 2004), groundwater protection (Stevens, Barrett, and Willis, 1997), rainforest protection (Holmes, Zinkhan, and Mercer, 1998), ecosystem management (Stevens, 2000), species conservation (Adamowicz et al., 1998), 3 environmentally sensitive areas (Hanley et al., 1998), and nature-based tourism (Naidoo and Adamowicz, 2005). The remainder of the study plan is organized as follows. First, we describe in detail the nature of the commodity that will be valued in the study. Next, we lay out our approach to data collection, including survey design, survey implementation, and sampling procedures. The plan concludes with a schedule for implementing the study and a draft survey instrument. DESCRIPTION OF VISIBILITY IMPROVEMENTS TO BE VALUED This section describes the nature of the good to be valued, which is one of the most important and difficult challenges of a visibility valuation study. Our study focuses on visibility improvements expected to occur in seven geographic regions -- each of which incorporates several national parks and wilderness areas -- due to the implementation of the Regional Haze Rule. Because visibility improvements will need to be presented to the general public within a survey context, our discussion of visibility improvements to be valued necessarily involves two distinct steps. The first step is to characterize the expected visibility improvements associated with the Regional Haze Rule. This step ensures that the visibility improvements valued in the survey are based on actual changes expected to result from the implementation of the Rule. The second step is to distill these improvements into realistic, simplified scenarios that could be presented to survey respondents. After a brief review of the policy context, these two steps are described in detail below. Expected Visibility Improvements Associated with the Regional Haze Rule The Regional Haze Rule requires that each state develop an implementation plan establishing "reasonable progress goals" for visibility in each Class I area within the state and describing emissions reduction strategies designed to achieve these goals. The reasonable progress goals serve as benchmarks along a path designed to lead to natural visibility conditions by 2064. Natural visibility conditions are defined as the distribution of visibility that would exist at Class I areas in the absence of human-induced impairment. The Regional Haze Rule sets 2000 to 2004 as the "baseline" period against which progress towards natural visibility is to be measured. The first state implementation plans will be completed in the 2007-2008 time frame, and they will consider visibility improvements through 2018. In establishing reasonable progress goals for visibility improvements, the Rule requires that states focus on improving visibility on the haziest days of the year (referred to as the "worst 20% days" and defined as all days falling below the 20th percentile of the visibility distribution) while preventing any degradation in visibility on the clearest days of the year (referred to as the "best 20% days" and defined as all days falling above the
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