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Cost-Benefit Assessment in Rulemaking: A Guide for State Agencies
Link: http://www.gorr.state.ny.us/main_gorr_pages/Cost-Benefit_Guide_July2008.pdf
Introduction:
The New York State Administrative Procedure Act (SAPA) requires that when an agency plans to adopt or amend a rule, whether it be a permanent or emergency rule, the agency must issue a Regulatory Impact Statement (RIS) which includes an assessment of the costs and benefits of the proposed action.1 The Governor’s Office of Regulatory Reform (GORR) assists state agencies and the Executive Chamber in the rule making process. GORR has developed this guide to assist agencies in identifying, measuring, and reporting the costs and benefits of regulatory proposals.
Agencies should conduct a cost-benefit assessment not only to evaluate rules that they plan to propose. They should also do cost-benefit assessment to identify existing rules that may need to be rethought.
The nature and complexity of an agency’s cost-benefit assessment will vary depending on the specifics of the rule proposal. ...
In the past, and despite some guidance under SAPA3, agency drafts analyzing costs and benefits have at times been skimpy, anecdotal and variable in quality and clarity. This guide reflects a decision to remedy that situation by providing fuller, ...[more easily understood] direction.
GORR is empowered by Executive Order No. 20 (EO #20), issued by Governor Pataki in November of 1995, to require a formal cost-benefit assessment from agencies subject to EO #20. Governor Spitzer issued Executive Order No. 5 in January 2007 continuing EO #20. Governor Patterson has likewise continued former EO #20. This document replaces the cost-benefit handbook issued by GORR in 1996, entitled Cost-Benefit Handbook: A Guide for New York State’s Regulatory Agencies.
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[This document presents] general information on how to conduct a cost-benefit assessment using ... ten analytical steps. Additional technical information is provided in the appendices to this document. They also note resources for additional information throughout the guide.
Table of Contents
Introduction......................................................................... 3
Step One: Confirm and measure the need for rulemaking ............................... 4
Step Two: Identify several regulatory options and a baseline to compare alternatives..5
Step Three: Select an analytical framework .......................................... 6
Step Four: Identify groups affected by the proposed rule change...................... 8
Step Five: Identify and quantify the costs and benefits of each proposed option.......9
Step Six: Monetize costs and benefits for each regulatory option where appropriate...12
Step Seven: Adjust monetized costs and benefits for inflation where appropriate .... 14
Step Eight: Discount costs and benefits to present value ........................... 15
Step Nine: Calculate net benefits or cost-effectiveness ratio for each alternative...16
Step Ten: Report analysis and findings in required impact statements................ 17
Other Considerations ............................................................... 18
Appendix One: Risk Assessment....................................................... 22
Appendix Two: Alternative Regulatory Approaches .................................... 27
New York State Governor David A. Paterson’s Office of Regulatory Reform www.gorr.state.ny.us
July 2008
New York State Governor Paterson Proposes Cuts To Environmental Protection Fund
Governor Paterson's across-the-board budget cutting proposals will impact New York's Environmental Protection Fund, whose purpose is partly to revitalize natural areas for the state's residents.
On November 11th, 2008 Paterson proposed cutting $50 million from the fund's $255 million budget. The Governor's Office said current funding commitments for environmental conservation would not be impacted, but the proposal limits the fund's expansion.
The governor is also proposing to expand the current five-cent deposit on beer and soda containers to water and other non-carbonated beverages, which now make up about 25 percent of the beverage market. In addition, the governor proposes to capture from the beverage industry all of the five-cent deposits that consumers do not claim. That new state revenue would be paid into the EPF, and thus help offset the cuts to the EPF.
Not included in the governor's budget-cutting proposal is a hike in the gasoline tax, but earlier in the week he told a Syracuse radio station that it "might be considered." ...
Submitted by Dan Hendrick on Thu, 2008-11-13 16:31.
New York League of Conservation Voters www.nylcv.org
November 13, 2008
The New York Times Company's New Headquarters Makes Headlines with 70% Energy Savings using Lutron's Advanced Lighting Controls
Link: http://www.lutron.com/cms/assets/ecosystem/nytimes/nytimes.html
From the Lutron "Case Study":
It takes a lot to impress The New York Times, so when a Times exec analyzed the performance of the company’s state-of-the-art lighting system in their new Manhattan headquarters, and then called the results “groundbreaking,” it was as if the architectural community itself was being told to “Stop the presses!”
The New York Times Building was making headlines within the company with a total light management system that allows it to use 70 percent less energy for lighting than the building’s design called for– and, as we know from the U.S. Energy Information Administration, a typical office building’s lighting system is the largest source of electricity consumption (44 percent).
The 70 percent lighting energy reduction represents a savings of $315,100 per year at New York City electric rates. It also means the prevention of 1,250 metric tons of CO2 emissions each year.
“The energy usage savings is stunning,” said Glenn Hughes, the Director of Construction for The New York Times Company during the design, installation and commissioning of The New York Times Building. “Lutron’s lighting control system has delivered an absolutely over-the-top performance. When I talk with other construction an
lighting consultants, they’re astonished at the results.”
“We designed our building to use 1.28 watts per square foot of lighting power. With Quantum, The New York Times Company is using only 0.38 – that’s 70% less.” according to Hughes.
The company resolved to exercise control at every stage of the project’s design and construction processes, ensuring that the new building accurately represented its corporate culture and values, and reaped real business benefits for the company. “We desired an interior environment that allowed our employees to be as comfortable as possible and that would reinforce our company’s emphasis on open communication, collaboration and transparency,” said David Thurm, Vice President and Chief Information Officer of the Times Company. “In addition, we insisted that the building be as environmentally friendly as possible.”
To accomplish these objectives, the Times Company hired the world-renowned architect Renzo Piano, along with two major architectural firms, FXFOWLE of New York, and Gensler, headquartered in San Francisco. The Times Company also employed the lighting design services of SBLD Studio of New York.
The result is a dazzling 52-story tower with 1.5 million gross square feet jointly owned with Forest City Ratner Companies of New York. The building is a mix of office and retail. Its chief attributes are open spaces and floor-to-ceiling glass walls that provide building occupants wide views of the neighboring skyscrapers and, conversely, allow outsiders to look in. “The whole building structure is designed for maximum light,” said Thurm, whose company owns 28 floors or about 625,000 square feet—the interior space designed by Gensler. “The number one priority was to allow natural light to make our employees feel more comfortable and to produce an energizing work environment.”
... Executives extensively researched the state-of-the-art lighting control options to satisfy their twin desires for daylight harvesting and for the flexibility to reconfigure spaces easily and simply. The word extensively is not used loosely. As Thurm himself described in an article published in the Harvard Business Review, virtually every decision fell under tight scrutiny to drive innovation and to avoid what he called, “well- ntentioned guesses by others as to what you want.”
After the building had been occupied for a year, Glenn Hughes, now president of Glenn D. Hughes Consulting Associates, utilized Quantum’s 30-day energy usage report to see for himself how much energy savings was achieved by the Quantum solution. “We designed our building to use 1.28 watts per square foot of lighting power,” Hughes said. “With Quantum, The New York Times Company is using only 0.38 — that’s 70 percent less.” Hughes said the figure of 1.28 watts per square foot of lighting power was within the local code in effect when the building was constructed. It has since tightened to about 1.1 watts.
He said the Lutron lighting control system has established an excellent baseline for the building is poised to achieve even better energy savings as the system parameters are tweaked.
The research eventually gravitated to the Building Technologies Department at the Lawrence Berkeley National Laboratory at the University of California. With guidance from the Berkeley Lab, the project design team and manufacturers, the Times Company built a replica of the southwest corner of its new building at one of its printing facilities in Queens, New York. For six months, from winter solstice to summer solstice, the mock-up tested an array of different lighting technologies and products from a variety of manufacturers including a new technology just emerging from Lutron Electronics Co. Inc. The testing, plus Lutron’s response to a competitive bid, convinced the Times Company to select Lutron’s Quantum light management solution for its office space.
The energy-saving lighting control strategies employed in the building include the following:
-- light level tuning (setting the appropriate target light level for each space);
-- daylight harvesting (automatically dimming electric lights when enough daylight is present); and
-- occupancy sensing (turning lights off when space is vacant).
Lutron's Quantum prevents wasted lighting energy by maximizing the efficient use of light in a building. The system automatically dims or switches all electric lighting, and controls daylight using automated window shades. Quantum also manages, monitors, and reports on all the lighting usage in a building for optimal energy performance and productivity while minimizing maintenance and operating costs.
For more information about Quantum total light management and The New York Times Building project, visit: www.lutron.com/nyt
Lutron www.lutron.com
Efficiency’s Mark: City Glitters a Little Less
The bright lights of the big city are getting a little bit duller — with just a hint of green.
Motion sensors ensure that unoccupied offices, storerooms and canteens go dark after workers and cleaning crews leave at night. Dimmers soften overhead lights that once could burn only bright or not at all. Timers guarantee that buildings fade to black while the city sleeps.
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The cost of the technology that makes better use of daylight and reduces electricity use at night — motion sensors, software-driven timers and the like — is falling. In some cases, it takes just two years to recoup the investment in this equipment, down from five years not long ago, according to Mark Roush, director of New York marketing for Acuity Brands Lighting, the nation’s largest maker of lighting fixtures.
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Con Edison ... has asked the state for permission to offer businesses a variety of rebates for installing efficient lighting....
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At the new 91,000-square-foot downtown offices of Incisive Media ... architects TPG designed a system that emits less than 0.78 of a watt a square foot. They used fluorescent bulbs that use 28 watts of electricity, compared with 42 to 48 watts for the old lights. Less-frequented areas like hallways have small halogen lights spaced far apart.
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Because of the expense, advanced lighting systems are being installed primarily in new buildings or offices being retrofitted for new tenants.
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More and more, building owners are writing leases that require tenants to pay for their own electricity, leading many tenants to install more efficient lights.
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Con Edison itself has adopted several of these techniques at its 26-story headquarters near Union Square, installing 344 LED fixtures on the clock tower in September. The fixtures, which are meant to last 15 years, use 63 percent less energy than conventional lights, and can be programmed to produce millions of colors without the need for filters ... or other equipment.
By Ken Belson
The New York Times www.NYTimes.com
November 2, 2008
