# Ozone NAAQS Reconsideration: Supplement to the 2008 Regulatory Impact Analysis (RIA)

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# Briefing for OMB and Interagency

Group November 5, 2009

# Need for Supplement to the 2008 RIA

• Because this is a reconsideration of the 2008 ozone NAAQS, the 2008 RIA is still applicable. • However, the 2008 RIA did not include

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# certain elements new to this proposal. • This briefing will walk through the new analyses contained in the supplement.

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# Basis for Ozone RIA Supplement

• Like the reconsideration of the standard itself, this RIA supplement is based primarily on the analysis done for the 2008 final rule. • Consistent with OMB guidance, we present results of analysis for options within the proposal range (0.060, 0.065, and 0.070 ppm), as well as one lower option

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# (0.055 ppm) and one higher option (0.075 ppm). • These levels are analyzed relative to the old 0.084 ppm standard

– This is the appropriate baseline for comparison because this is a reconsideration of the 2008 standard decision 

# • The underlying air quality modeling and emissions inventory are the same as for the 2008 RIA.

# Updates to the 2008 Ozone RIA Contained in this Supplement This supplemental analysis includes:

• An analysis of the costs and benefits of attaining 0.055 and 0.060 ppm, as these levels were not analyzed in the 2008 RIA (in addition to presenting results for levels of 0.065, 0.070, and 0.075 ppm).

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# • Several key updates to the benefits methodology, which have occurred since the 2008 Ozone RIA. All these assumptions have already been incorporated into the RIAs for cement, NO 2 

# NAAQS and the C3 rules, and are thus included in this RIA as well.*

• An analysis of the proposed secondary ozone standard.

* Note that issues concerning the mortality benefits calculations will be the subject of a separate, more focused, upcoming meeting, and thus are not included in today’ s overview.

# Control Strategies and Cost Analyses

Contained in this Supplement

• No control strategy approach or cost estimation methodological changes have occurred since the 2008 RIA. • For the analysis of the 0.055 and 0.060 ppm levels, we used the same cost methodology as in the 2008 RIA,

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# including the hybrid approach for estimating extrapolated costs. • The analysis of the 0.055 and 0.060 ppm levels are not extended to the year 2030 because of the inherent uncertainty involved at these lower levels. (The 2008 RIA extended to 2030 for severe and serious nonattainment areas in California).

# Benefits Methodology Updates Contained in

this Supplement Ozone: • Removed assumption of no causality with ozone mortality per NAS advice • Included two more NMMAPS studies per NAS advice (Huang and Schwartz). • Revised value of a statistical life (VSL), as done in C3 and NO 2 

# NAAQS RIAs.

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# • Removed one morbidity study because age ranges overlapped PM 2.5 

# : • Removed thresholds from the concentration - response functions as done in Cement, C3 and NO 2 

# NAAQS RIAs. • Revised value of a statistical life (VSL), as done in C3 and NO 2 

# NAAQS RIAs. • Updated benefit- per- ton estimates. 6

# Secondary Ozone Standard Analysis

Contained in this Supplement

• No secondary standard analysis was included in the 2008 RIA, as a separate secondary was not finalized.  This supplement includes:

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#  Counts of additional counties which may not attain a given secondary standard for various levels of a primary standard  Qualitative description of the standard, and  Qualitative description of the benefits of reduced ozone exposure on vegetation.

# Secondary Ozone Standard Analysis Contained in this Supplement (cont.)
 For the reasons outlined below, this supplemental analysis of the secondary proposal options will not include estimates of the benefits and costs of attaining the separate secondary standard.

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# – There is no specific attainment year to measure costs and benefits towards; the secondary standard is “as soon as practicable.”

– A new and/or revised monitoring network is being considered to understand the extent of the nonattainment with a separate secondary standard.

– There is limited experience with air quality modeling of the W126 form of the standard. 8

# Secondary Ozone Standard Analysis Contained in this Supplement (cont.)
Number of Counties Project ed to Exceed V arious W126 Levels While Meeting Va rious Levels of the Primary Standard in the Control Strategy in 2020 a 

### Levels of 12 - hr W126 (ppm - hrs) 8 - Hour Level Met > 21 > 15 > 7

9 0.075 ppm 1 12 130 0.070 ppm 1 8 98 0.065 ppm 0 3 46 0.060 ppm 0 1 12 0.055 ppm 0 0 2

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# Summary of Cost and Benefit Results for this Supplement: Baseline Projected Ozone Air

Quality in 2020

10 Legend 28 counties exceed 0.075 ppm 61 additional counties exceed 0.070 ppm 14 2 additional counties exceed 0.065 ppm 20 5 additional counties exceed 0.060 ppm 14 1 additional counties exceed 0.055 ppm 

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# Summary of Cost and Benefit Results for

this Supplement: Health Benefits S ummary of Total Number of Annual Ozone and PM 2.5 

### - Related Premature Mortalities and Premature Morbidity Avoided: 2020 National Be nefits* Combi ned Estimate

of Mor tality 0.075 ppm 0.070 ppm 0.065 ppm 0.060 p pm 0.055 p pm Bell etal . (2004) 760 to 1,90 0 1,500 to 3,500 2,500 to 5,600 4,000 to 8,700 5,900 to 13,000 Schwartz 800 to 1,900 1,600 to 3,600 2,700 to 5,800 4,500 to 9,200 6,700 to 13,000 NMMAPS Huang 820 to 1,900 1,600 to 3,600 2,800 to 5,900 4,600 to 9,300 6,900 to 14,000

Bell etal . (2005) 930 to 2,000 2,000 to 4,000 3,500 to 6,600 6,000 to 11,000 9,400 to 16,000 Ito et a l. 1,000 to 2,100 2,300 to 4,300 4,000 to 7,100 7,100 to 12,000 11,000 to 18,000 Meta analysis Levy

et al. 1,000 to 2,100 2,300 to 4,300 4,100 to 7,200 7,100 to 12,000 12,000 to 18,000 Combi ned Estimate

of Mor bidity 0.075 ppm 0.070 ppm 0.065 ppm 0.060 p pm 0.055 p pm



### 11 Mor bidity 0.075 ppm 0.070 ppm 0.065 ppm 0.060 p pm 0.055 p pm Acute Myoca rdia l Infarction 1,300 2,200 3,500 5,300 7,500 Upper Resp irato ry Sympto ms 9,900 19,000 31,000 48,000 69,000 Lower Respiratory Sympto ms 13 ,000 25,000 41,000 63,000 91,000 Chronic Bronch itis 470 880 1,400 2,200 3,200 Acute Bron chit is 1,100 2,100 3,400 5,300 7,600 Asthma Exacerbat ion 12,000 23,000 38,000 58,000 83,000 Work Loss Days 88,000 170,000 270,000 420,000 600,000 Sc hool Loss Da ys 190,000 600,000 1,100,000 2,100,00 0 3,700,00 0 Hospital a nd E R Visits 2,600 6,700 11,000 21,000 35,000 Minor RestrictedA ctivity Days 1,000,000 2,600,000 4,500,000 8,100,00 0 13,000,000 *Only includes areas req uired to meet the current standard by 202 0, d oes not include San Joaquin Valley and South Coast air basins in California. 

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# Summary of Cost and Benefit Results for

this Supplement: Costs
Total Monetized Costs with Ozone Benefits and PM 2.5 

### Co - Benefits in 2020 (in Billions of 2006$)* Total B en efits ** Total Costs** * Net Be nefits 3% 7% 7% 3% 7% $6.9 to $1 8 $6.4 to $1 5 $7.6 to $8 .8 $ - 1.9 to$ 10 $ - 2. 4 to$ 7 .40.075ppm $13 to $ 37 $11 to $ 31 $19 to $25 $ - 12 to $1 8 $ - 14 to $ 120.070ppm



### 120.065ppm $22 to $ 61 $19 to $ 53 $32 to $44 $ - 22 to $ 29 $ - 25 to $ 20 $35 to $ 100 $30 to $ 87 $52 to $90 $ - 55 to $ 48 $ - 60 to $ 350.060ppm $53 to $1 6 0 $45 to $ 140 $78 to $130 $ - 77 to $ 8 2 $ - 85 to $ 6 20.055ppm ***Rangereflects lower

a nd uppe r boundcost esti ma tes. Data fo r c alcu lating costs at a 3% discount ratewas not availa bl e fo r a ll secto rs , and t herefore total annua lized costs at 3% a renot pr es entedhe re Note a lso thatCaliforn ia counti es atta inin g by 2030 a renot include d in th e cost esti ma te s .

# Summary of Cost and Benefit Results for this Supplement: Costs and Benefits

$80 $100 $120 $140 $160Billions of 2006$ Comparison of To ta l Monetized Be nefits to Cost s for Al ter native

Sta ndard Levels i n 2020 ( Updated results, 7%dis count rate)



### 13 $0 $20 $40 $60 $80

0. 075

ppm 0. 070 ppm 0. 065 ppm 0. 060 ppm 0. 055 ppmBillions of 2006$

Altern at ive St andar d Leve l *The low benefits estimate is based on Pope/Bell 2004 and the high benefits estimate is based on Laden/Levy. The two cost estimates (unchanged) are based on two different extrapolated cost methodologies. The dotted lines are a visual cue only, and these lines do not imply a uniform range between these endpoints.