For states that propose standards more stringent than the federal standard, as in the case of the NCCSA, it is certainly appropriate to consider the benefits and costs of a more stringent standard.
Consider the three sets of standards: 1990 CAAA, 1997 NSPS, and the NCCSA. We consider the annual benefits and costs of moving from the CAAA to NSPS to NCCSA, as well as NSPS to NCCSA.
Table A1 is a comparison of CAAA to NSPS, Table A2 compares NSPS to NCCSA, and Table A3 compares CAAA to NSCS.
In contrast, Figure 1 shows benefits exceed costs for moving from CAAA or NSPS to NCCSA. The net benefits are larger when the firm adapts from CAAA to NCCSA.
If marginal benefit decreased with the more stringent standard, the net benefit to NCCSA would decrease.