Questions From Matt Cahillane, NH Department of Health and Human Services

Here's a list of items that need clarification:

1. As per Table 4-18 on page 4-36 of the EPA Regulatory Impact

Assessment (see link below), there are multiple 'Avoided Health Indices'

that can be projected to provide co-benefit by 2030, these include

reduced mortality and morbidity for PM and ozone. The table also

reports figures for a state option and a regional option. I'd like to

reconcile the figures in this table with the figures reported in the EPA

fact sheet 'By the Numbers' (EPA fact sheet, 2014). Provided below are

the EPA fact sheet figures with questions in blue font:

o 2,700 to 6,600 premature deaths. These figures appear to be only

for PM2.5 mortality and not ozone. The RIA table 4-18 provides figures

for PM and ozone. Why is ozone left out of the summary?

o 140,000 to 150,000 asthma attacks in children. These figures appear

to be only for PM2.5 pediatric asthma, and not ozone. Why didn't the

RIA report data for ozone and pediatric asthma exacerbation?

o 340 to 3,300 heart attacks. The figures in the fact sheet appear to

be a mix of the RIA Table 4-18 state and regional options. Is this an

accurate representation of the range of benefits?

o 2,700 to 2,800 hospital admissions. No question. Figures are the same

in both documents.

o 470,000 to 490,000 missed school and work days. No question. Figures

are the same.

2. A related report from Harvard-Syracuse (Driscoll, 2014) analyzed the

potential impact of carbon reductions on PM and ozone levels for

states across the nation (see Figures, pages 14-23). The EPA RIA

doesn't seem to have similar figures in a table or map format that

show state-by-state reductions in PM and ozone. Where can we find

the air pollutant reductions of the EPA proposal for individual

states?

3. The figures from the EPA fact sheet above are for the entire United

States. The recent analysis by Harvard-Syracuse indicates that the

most benefit from PM and ozone reduction will be realized in the

central and eastern parts of the US, likely due to the higher

concentration of coal-fired power plants. Where can we find the

health benefits of this EPA proposal for individual states?

4. The national EPHT program has a web-based tool (i.e. Mortality

benefit estimates) that models the reduction in mortality from

improvements in PM air quality in the past (2001-2009).

http://ephtracking.cdc.gov/showAirHIA.action# The EPA has now

modeled the health benefits into the future (2020-2030). It seems
that there could be an opportunity here to use the two models in

concert, and allow states to better estimate the health benefits of

PM reductions over time. Are these estimates based on the same

methods and models, or are they not comparable?

(EPA RIA, 2014) Regulatory Impact Analysis for the Proposed Carbon

Pollution Guidelines for Existing Power Plants and Emission Standards

for Modified and Reconstructed Power Plants. U.S. Environmental

Protection Agency, June 2014

http://www.epa.gov/ttn/ecas/regdata/RIAs/111dproposalRIAfinal0602.pdf

(EPA fact sheet, 2014) EPA FACT SHEET: Clean Power Plan. BY THE NUMBERS.

CUTTING CARBON POLLUTION FROM POWER PLANTS. June 2014

http://www2.epa.gov/sites/production/files/2014-06/documents/20140602fs-important-numbersclean-power-plan.pdf

(Driscoll, et al. 2014) Co-benefits of Carbon Standards. Part 1: Air

Pollution Changes under Different 111d Options for Existing Power Plants

May 27, 2014. Driscoll C, Buonocore J, Fakhraei H, Fallon-Lambert K.

http://eng-cs.syr.edu/wp-content/uploads/2014/05/Carbon-cobenefits-study-FINAL-SPE.pdf