## Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

 Table 3

- 1

– EPA has assumed no change in VOC or NOx emissions from Fires (both Wild and Prescribed) and Biogenics in their Base Case modeling between 2011 and 2025. It would seem that fire emissions would increase

– wildfire is likely to be more prevalent if prescribed fire is not allowed or suppressed, and wildfire emissions are much greater than prescribed fire em issions due to the fire and emission characteristics of wild vs. prescribed fire. Also, if improved ozone concentrations result in improved vegetative health and vigor, it would be reasonable to expect that VOC emissions from vegetation will likewise incr ease. Assuming that these two categories will stay the same is just not a good assumption.



### EPA Response: EPA recognizes that climate change may lead to temperature increases, higher stagnation frequency, and increased wildfire activity

, all of which could lead to higher ozone concentrations . Potential future elevated ozone concentrations could, in turn, necessitate more stringent emissions reductions

. However, there are significant uncertainties regarding the precise location and timing of climate change i mpacts on ambient air quality. Generally, climate projections are most robust for periods at least several decades in the future because the forcing mechanisms that drive near

- term natural variability in climate patterns (e.g., El Nino, North American Osci llation) have substantially larger signals over short time spans than the driving forces related to long

- term climate change. It should be noted that international emissions, which may also influence future ozone concentrations, are also held constant in t his analysis based on a similar rationale regarding the significant uncertainty in estimating future levels. We have added the above explanation to the RIA.

In addition, the impacts of ozone levels on biogenic emissions are not currently included in bioge nic emissions models. Therefore it is not possible at this time to project how lower ozone levels might impact biogenic VOC emissions.

 In Appendix 6A, there is additional considerable discussion of crop yield improvements due to improved ozone concentrati ons. However, all of these improvements are based on modeled conditions of theoretical research. For soybeans especially, there appears to be no good correlation between actual yields (using data from the 2012 Census of Agriculture) for nonattainment cou nties in 5 nonattainment areas in the upper mid

- West vs. those attainment counties directly adjacent to the nonattainment counties (in Indiana, Illinois, Missouri, and Ohio, as well as a few additional counties in Kentucky and Wisconsin to complete the non attainment areas and surrounding attainment counties). In fact, the nonattainment counties in those areas in 2012 generally had a higher yield per acre than the attainment counties immediately surrounding them. EPA had intended to address some of this un certainty in the preamble document, but it appears that they are still relying on benefits from crops in the RIA. The commenters would recommend that this discussion in the RIA be quite limited, as it appears that EPA’s modeling isn’t matching reality for
crops. Additionally, EPA states “Crop acreage was projected to decline with the introduction of the ozone standards because additional productivity per acre reduces the demand for crop acreage...” (see p. 6A

- 29, section 6A.2.1.2). Given the increasing wor ldwide population and the worldwide demand for agricultural crops, a small increase in production due to

## Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

improved ozone concentrations (if that is actually correct) will not result in a decrease in agricultural crop acreage anytime in the near future. Tha t decision will be driven more by global crop demand, so EPA’s assumption in their modeling is incorrect. As such, the commenters strongly recommend scaling back the discussion on benefits from crops, as there appear to be incorrect assumptions and incons istencies with reality in EPA’s current modeling assessment.

EPA Response : EPA does not rely on benefits from crops in the RIA; the welfare cobenefits are not added to the human health benefits in any presentation of benefits or net benefits in the RIA.

In the RIA, EPA used a peer

- reviewed model of changes in agricultural and timber markets using concentration

- response functions from the Integrated Science Assessment for Ozone and Related Photochemical Oxidants to assess regional changes in ozone
concent rations. The analytical approach employed by the commenter is not directly comparable to the approach EPA employed. In addition, Appendix 6A is a support document for the FASOMGHG modeling conducted to assess welfare cobenefits associated with crop and t imber production. The scenarios analyzed in the Appendix are illustrative, as described elsewhere in the RIA, and the assumptions used in the FASOMGHG modeling are detailed in the Appendix. Assumptions are made in any type of modeling and were used in th is analysis, for example, to assign crop and timber lands to a particular product because it is not known how crop and timber producers will allocate their lands in the future under actual conditions. Because EPA does not rely on welfare cobenefits in est imating benefits associated with the proposed standards, EPA does not plan to change the current discussion in Chapter 6 or Appendix 6A of this proposal RIA.

 Page 2

- 1, please change wildfires to wildland fires in the sentence (wildfires have never been con sidered as anthropogenic under any EPA rule or policy to date): Thus, emissions from plants, animals, and wildfires wildland fires could be considered either natural or anthropogenic, depending on whether emissions result from agricultural practices, fores t management practices, lightning strikes, or other types of events (US EPA, 2013, sections 3.2 and 3.7.1)

EPA Response: The EPA agrees that this language could be misinterpreted and has removed this sentence and the preceding sentence from the RIA.

 Page2

- 13, please clarify and specify the fire sources to wildfire, prescribed fire and agricultural burning, in the sentence: Fire emissions were based on a multi

- year climatological average as this analysis was mean t to capture seasonal mean background an d typical ranges rather than explicitly quantify background ozone on specific days.

EPA Response: We have edited the sentence to read: “Wildfire emissions were based on a multi

- year climatological average as this analysis was meant to capture seasonal mea n background and typical ranges rather than explicitly quantify background ozone on specific days. ” Prescribed burns and agricultural fires were treated like other anthropogenic sources in that they used 2007 or 2008 year

- specific emissions. Therefore th ese two sources are not

## Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

described separately since the previous sentence describes how all anthropogenic sources were treated.

 Chapter 3 Page 3

- 5, p lease insert in current text (citations are available if needed) : ...and more prevalent wildfires. In the U. S. over the last 15 years this trend is already occurring with the total acres of wildfires increasing and frequency of large wildfires increasing with many states recording their largest fires ever. To the extent that climate change does lead to higher oz one concentrations, there could potentially be a need for more stringent emissions reductions to counteract the higher ozone potential from these phenomena.

EPA Response: We have added the following sentence to this section: “ In the western U.S.

over the last 15 years, increasing wildfires have already been ob served (Dennison et al., 2014).”

Additional Changes to RIA

 Chapter 5 A request was made to include the following clarifying edit (shown below as underlined text) in Section 5.4.4. Benefit

-

per

- ton Estimates for PM 2.5
. Consequently, these estimates may not reflect local variability in factors associated with PM 2.5 - realted health impacts (e.g., population density, baseline health incidence rates) since air quality modeling that could h ave shed light on local conditions was not performed for this NPRM

. EPA Response : EPA made the edit, with one exception noted below (shown in underlined text)

. Consequently, these estimates may not reflect local variability in factors associated with PM2.5

- realted health impacts (e.g., population density, baseline health incidence rates) since air quality modeling that could have shed light on local conditions was not performed for this RIA

. A request was made to include the following clarifying edit s (shown below as underlined text and strikeout text ) in the last paragraph of Section 5. 6

. 3. 4. Unquantified Human Health Effects

. While Graff Zivin and Neidell (2012) report the information needed to quantify ozone

related worker productivity, we are sti ll evaluating the whether and how to most appropriate way to appropriately apply the results of the study in a national benefits
assessment because this is a nascent literature

. Some of the analytic issues to contend with include (1) how to assess the robustness the results including whether results can be replicated and (2) generalizability of the results to the appropriate population . We are considering the feasibility appropriateness of applying the results of this study to estimate the benefits of increased worker productivity as part of the final ozone RIA, and seek public comment on this approach as an important input to our consideration.

EPA Response : EPA made the majority of the suggested edit s , with a few ex ception s noted below ( shown a s under lined text and strikeout text ).

## Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

While Graff Zivin and Neidell (2012) report the information needed to quantify ozone

related worker productivity, we are still evaluating the whether and how to most appropriately apply the limited evidence from this results of the study in a national benefits assessment because this is a nascent literature. Some of the analytic issues to contend with include (1) how to assess the robustness the results including whether results can be replicated and (2) An important issue is the generalizability of the results to the appropriate population. We are considering the appropriateness of applying the results of this study to estimate the benefits of increased worker productivity as part of the final ozone RIA, and seek public co mment on this approach as an important input to our consideration.

 Chapter 7 A request was made to add the following sentence to the last paragraph of Section 7.1.2 Compliance Cost Estimates for Known Controls

. The reason for slight increase in cost relat ive to the increase in stringency is newly affected areas are expected to comply with known technologies rather unknown technologies.

EPA Response : The suggested edit was somewhat out of context, so EPA made the following changes to that paragraph (shown below as underlined text and strikeout text). The reason for these changes is to (i) remove the reference to Tables 7

- 1 through 7

- 3 because those tables are for total costs, not cost per ton , (ii) clarify that the discussion is about cost per ton , and (iii) correct an error in the final sentence in the paragraph.

As shown in Tables 7

- 1 through 7

- 3 below, t The cost trend in terms of dollars per ton of emissions reductio n is increasing for some sectors and decreasing for others. The variation is small for most sectors and depends on the sources that happen to be in the geographic areas of control. In general, the same set of controls is being applied at each level of the alternative standards analyzed. The primary difference in the control strategies for the alternative standards is the greater size of the geographic area of control as the stringency of the alternative standards increases. Overall for all sectors as a whol e, the average cost per ton is actually increasing slightly with increasing stringency of the alternative standard analyzed. The reason for slight increase in cost per ton relative to the increase in stringency is that newly affected areas are estimated to obtain emissions reductions using slightly more expensive known technologies as the alternative standards become more stringent

. A request was made to add the following sentence to the third to last paragraph of sub

- Section 7. 3. 1

. Methods (of Section 7.3 Compliance Cost Esti mates for Known Controls ).

On the other hand, Figure 1 suggests that $15,000 may be an under

- estimate of the average value of the unidentified abatement.

EPA Response : The suggested edit was somewhat out of context, so EPA added the following sentence in the middle of that paragraph (shown below as underlined text).

## Summary of Interagency Working Comments on Draft Language under

EO12866/13563 Interagency Review. Subject to Further Policy Review.

If, for example, the true costs of the unidentified controls are distributed at the upper end of the identified control costs depicted in Figure 7

- 1, $15,000 p er ton may under

- estimate the average value of the unidentified abatement. Alternatively, the assumed value might overestimate the ‘”unobserved” abatement discussed in Section 7.2. The results shown in Table 7

- 4 (per ton cost of NOx reductions for five m ajor NOx

- reducing rules) and Table 7

- 7 (annualized per ton cost of NOs offsets in four regions) may suggest that the $15,000 per ton assumed average cost may be over

- estimating the average value of the unidentified abatement.

 Chapter 10 A request was mad e to delete a sentence above Table 10

- 1 and delete rows in Tables 10

- 1 and 10

- 2, all related to additional labor categories potentially involved in construction and maintenance of control equipment.

EPA Response : The suggested edits to the text and tables were made.