What are the estimated costs to implement each of the two proposals?
The Regulatory Impact Analysis (RIA) estimates the average annual regulatory cost, for the next 50 years, to be $1,474 million a year under the Subtitle C option and $587 million a year under the Subtitle D option. These estimates include the costs of industry compliance and state and federal government oversight and enforcement costs. On a 50-year present value basis at a 7% discount rate, these average annual costs total to $20.3 billion (Subtitle C) and $8.1 billion (Subtitle D), respectively. The major difference in the cost estimates for the two options is largely the result of compliance rates and the retrofit requirement for Subtitle C. With respect to compliance rates, the analysis assumes a 48% compliance rate under Subtitle D (where we have no enforcement authority) versus a 100% compliance rate under Subtitle C.
