X hits on this document

52 views

0 shares

0 downloads

0 comments

13 / 25

Metrics: (1) the response of a plant’s compliance status to lagged EPA/state enforcement and monitoring activities directed at other facilities in the same state and sector, (2) the response of a plant’s pollution emissions to lagged EPA/state enforcement and monitoring activities directed at other facilities in the same state and sector.8 Metrics should be explored on a sector-by-sector basis.

Peer-Reviewed Foundation: Shimshack and Ward (2005) and Shimshack and Ward (2008).

Potential Data Requirements: (1) compliance status (a discrete 0/1 indicator variable) or specific pollutant emissions (a continuous variable) for plant i in time period t,9 (2) a year indicator for time t, (3) a season indicator for time t if the data are monthly or quarterly, (4) a state indicator for plant i, (5) inspections at other similar plants over the past year, (6) inspections at other similar plants 1-2 years ago, (7) inspections at other similar plants 2-3 years ago, (8) enforcement actions at other similar plants over the past year, (9) enforcement actions at other similar plants 1-2 years ago, and (10) enforcement actions at other similar plants 2-3 years ago.

Potential Statistical Methodologies for the Continuous Emissions Metric: (1) linear regression with plant-specific fixed effects, (2) linear regression with plant- specific random effects, and (3) linear regression with plant-specific conditional random effects. The continuous nature of the emissions metric suggests linear regressions are appropriate. All methods are discussed in Section 2 and the technical appendix of the Task 1 white paper. All are easily implemented (pre- programmed) with modern statistical software. All models include state-specific indicator variables and year-specific indicator variables.

10

Potential Statistical Methodologies for the Compliance Status Metric: (1) logit regression with plant-specific fixed effects, (2) logit regression with plant-

8 Although sector emissions or compliance should be considered on a sector-by-sector basis, it is not strictly necessary to restrict attention to enforcement and monitoring activities directed at other facilities in the same state and sector. However, Gray and Shadbegian [2005] found that plants seem inclined to respond to general deterrence created by the experiences of facilities in the same state, but not neighboring states. In principle, one might examine the response of pulp and paper compliance to enforcement actions levied in the chemical sector, since these actions may also signal the regulator’s reputation for toughness. However, restricting attention to enforcement and monitoring activities directed at other facilities in the same sector seems like the appropriate starting point for analysis.

9 In principle, compliance status may refer to any desired compliance indicator, including Agency determined Significant Non-compliance status or High-Priority Violation status. In the Shimshack and Ward papers that serve as the foundation of the later general deterrence benchmarking analyses, compliance status is determined by examining actual discharges relative to permitted standards. While any exceedance of permitted levels is considered non-compliance, a large number of violations correspond to significant non-compliance (greater than 40 percent above permitted limits for conventional water pollutants).

10 Technically, models with plant-specific fixed effects will not also include state-specific indicators, since these variables are redundant.

12

Document info
Document views52
Page views52
Page last viewedFri Oct 28 22:33:09 UTC 2016
Pages25
Paragraphs327
Words9837

Comments