S3‐1

Section 3: Re‐analysis of the Benefits of Attaining Alternative Ozone Standards to

Incorporate Current Methods

Synopsis

This chapter presents a benefits analysis of three alternate ozone standards updated to

reflect key methodological changes that EPA has implemented since having published the 2008

Ozone NAAQS RIA. In this updated analysis we re‐estimate the human health benefits of

reduced exposure to ambient ozone and PM2.5 co‐benefits from simulated attainment with

three alternate daily 8hr maximum standards: 0.075 ppm, 0.070 ppm, and 0.065 ppm.  For an

alternative standard at 0.075 ppm, EPA estimates the monetized benefits to be $6.9 to $18

billion (2006$, 3% discount rate) in 2020.1  For an alternative standard at 0.070 ppm, EPA

estimates the monetized benefits to be $13 to $37 billion (2006$, 3% discount rate) in 2020.  

For an alternative standard at 0.065 ppm, EPA estimates the monetized benefits to be $22 to

$61 billion (2006$, 3% discount rate) in 2020.  Higher or lower estimates of benefits are

possible using other assumptions. The benefits of attaining an alternate standard of 0.060 ppm

and 0.055 ppm may be found in Section 2 of this supplement. These updated estimates reflect

three key methodological changes we have implemented since the publication of the 2008 RIA

that reflect EPA’s most current interpretation of the scientific literature and include: (1) a no‐

threshold model for PM2.5 that calculates incremental benefits down to the lowest modeled air

quality levels; (2) removal of the assumption of no causality for the relationship between ozone

exposure and premature mortality; (3) a different Value of Statistical Life (VSL). These benefits

are incremental to an air quality baseline that reflects attainment with the 1997 ozone and

2006 PM2.5National Ambient Air Quality Standards (NAAQS).  Methodological limitations

prevented EPA from monetizing the benefits from several important benefit categories,

including ecosystem effects.   

S3.1 Background

In response to the recent court vacatur of the 2008 Ozone NAAQS, EPA is reconsidering

this rulemaking.  Consistent with EPA’s decision to, in general, use the “existing record” for this

reconsideration, we present a benefits analysis based on the same air quality modeling inputs

as the 2008 analysis. However, we update this analysis to make the results consistent with an

array of methodological updates that EPA has incorporated since the release of Regulatory

Impact Analysis (RIA) for the 2008 Ozone NAAQS (U.S. EPA, 2008).  Because the rulemaking

period for the reconsideration is condensed, we only provide estimates associated with the

                                                           

1 Results are shown as a range from Bell et al. (2004) with Pope et al. (2002) to Levy (2005) with Laden et al.

(2006).  PM2.5 co‐benefits using a 7% discount rate would be approximately 9% lower.   
S3‐2

promulgated standard level of 0.075 ppm and the two more stringent standard levels

previously analysis (i.e., 0.070 ppm and 0.065 ppm).  A separate analysis of the costs and

benefits of simulated attainment with 0.060 ppm and 0.055 ppm may be found in Section 2 of

this Supplement.  All benefits estimates in this analysis are incremental to the 1997 Ozone

NAAQS standard at 0.08 ppm and the 2006 PM2.5NAAQS standard at 15/35 μg/m3

.   

S3.2 Key updates to the benefits assessment

In this analysis, we update several aspects of our benefits assessment for the human

health benefits of reducing exposure to ozone and PM2.5.

2

  Both ozone benefits and PM2.5 co‐

benefits incorporate the updated population projections in BenMAP.  In addition, both ozone

benefits and PM2.5 co‐benefits reflect EPA’s current interpretation of the economic literature on

mortality valuation to use the value‐of‐a statistical life (VSL) based on meta‐analysis of 26

studies.3

    

For ozone benefits, these updates are a response to recent recommendations from the

National Research Council (NRC, 2008).  In this analysis, we have incorporated three of NRC’s

recommendations:

1) We no longer include estimates of ozone benefits with an assumption of no

causal relationship between ozone exposure and premature mortality.  

2) We include two additional ozone mortality estimates, one based on the National

Morbidity, Mortality and Air Pollution Study (NMMAPS) (Huang, 2005), and one

14‐city study (Schwartz, 2005), placing the greatest emphasis on the multi‐city

studies, such as NMMAPS.   

3) We present additional risk metrics, including the change in the percentage of

baseline mortality attributable, and the number of life years lost due, to ozone‐

related premature mortality.  

In addition to these recommendations, we modify the health functions used to estimate

the number of emergency department visits for asthma avoided by reducing exposure to

ozone.  Specifically, we removed the Jaffe et al. (2003) function because the age range overlaps

partially with Wilson et al. (2005) and Peel et al. (2005) functions. This change results in a

                                                           

2 This analysis does not attempt to describe the overall methodology for estimating the benefits of reducing ozone

and PM2.5.  For more information, please consult Chapter 6 of the 2008 Ozone NAAQS RIA (U.S. EPA, 2008).    3 For more information regarding mortality valuation, please consult section 5.7 of the proposed NO2 RIA (U.S. EPA,

2009b).   
S3‐3

slightly larger estimate of ozone‐related emergency department visits as compared to the 2008

analysis.   

For PM2.5 co‐benefits, this analysis is consistent with proposed Portland Cement NESHAP

RIA (U.S. EPA, 2009a) and proposed NO2 NAAQS RIA (U.S. EPA, 2009b).  In this analysis, we

incorporate four updates:

1) We removed assumed thresholds from the mortality and morbidity

concentration‐response functions for PM2.5.

4

  Removing the assumed 10 μg/m3

threshold is a key difference between the method used in this analysis of PM2.5‐

co benefits and the methods used in RIAs prior to Portland Cement, and we now

calculate incremental benefits down to the lowest modeled PM2.5 air quality

levels. This change results in a larger estimate of PM‐related premature mortality

as compared to the 2008 analysis.

2) We now present the summary of the PM2.5 co‐benefits results using

concentration‐response functions for mortality from two cohort studies (Pope et

al. (2002) and Laden et al. (2006)) instead of range between the minimum and

maximum results from an expert elicitation of the relationship between

exposure to PM2.5 and premature mortality (Roman et al., 2008). This change

produces a slightly narrower range of PM‐related mortality estimates as

compared to the 2008 analysis.  In addition, we provide the full suite of results

based on the expert elicitation in the body of the benefits results chapter.

3) When adjusting the benefits of the modeled PM co‐benefits for alternate

standard levels, we apply PM2.5 benefit per ton estimates calculated using a

broader geographic area, which, when compared to the 2008 analysis, produces

more reliable and generally larger PM‐related benefits estimates.

4) We incorporated an updated methodology for quantifying the health incidences

associated with the benefit‐per‐ton estimates. This change should produce more

reliable estimates of PM‐related health impacts.

In this analysis we estimate ozone‐related premature mortality using risk coefficients

drawn from short‐term mortality studies. Two recent epidemiologic studies assessed the

relationship between long‐term exposure to ozone and premature mortality.  Jerrett et al.

(2009) utilized the ACS cohort with air quality data from 1977 through 2000 (April through

September).  Jarrett et al. reported a positive and statistically significant association between

ambient ozone concentration and respiratory causes of death after controlling for PM2.5 using

                                                           

4 For more information regarding thresholds in the PM2.5mortality relationship, please consult the proposed

Portland Cement NESHAP RIA (U.S. EPA, 2009a).    
S3‐4

co‐pollutant models.  Further examination of the association between ozone exposure and

respiratory‐related mortality revealed the association was increased by higher temperatures

and geographic variation.  In single pollutant models, long‐term ozone exposure was also

associated with cardiopulmonary, cardiovascular, and ischemic heart disease mortality, but the

associations were not present in the co‐pollutant model.  Krewski et al. (2009) also utilized data

from the ACS cohort with air quality data from 1980 (April through September) and observed a

positive association between ozone exposure and all‐cause and cardiopulmonary disease

mortality.  This association was robust to control for ecologic variables, but no association was

observed with ischemic heart disease or lung cancer.  In addition, Krewski et al. observed no

association with year‐round ozone exposure.   

EPA anticipates incorporating risk coefficients from one or both of these two long‐term

cohort studies after consulting with the EPA SAB to resolve key technical questions regarding

the specification of the health impact analysis.  For example, when estimating long‐term PM2.5‐

related mortality we apply an SAB‐recommended 20‐year distributed cessation lag, over which

period we discount monetized benefits. To the extent that there is a lag between the cessation

of ozone exposure and the return of population risk to a new steady state risk level, EPA would

specify this parameter in the health impact analysis. We also plan to elicit guidance from the

SAB regarding the selection of: national versus regional effect coefficients; the use of

estimators derived using single versus co‐pollutant models; and, the health mortality endpoint

to be quantified, among other issues.  EPA anticipates consulting with the SAB in late 2009.  

S3.3 Presentation of results

Tables S3.1 through S3.6 show the results of this updated analysis.  Figures S3.1 and

S3.2 show the breakdown of ozone benefits and PM2.5 co‐benefits by endpoint category using a

single mortality study as an example.  Figures S3.3 and S3.4 show the ozone benefits and PM2.5

co‐benefits by mortality study.  Figures S3.5 and S3.6 show the breakdown of monetized

benefits between ozone, PM, morbidity, mortality, and visibility.  Figure S3.7 shows the results

of this updated analysis graphically.   

   
S3‐5

Table S3.1: Summary of Total Number of  Ozone and PM2.5‐Related Premature Mortalities

and Morbidity Incidences Avoided in 2020 A, D

Combined Estimate of Mortality 0.075 ppm 0.070 ppm 0.065 ppm

Multi‐city Bell et al. (2004) 760 to 1,900 1,500 to 3,500 2,500 to 5,600

Schwartz 800 to 1,900 1,600 to 3,600 2,700 to 5,800

Huang 820 to 1,900 1,600 to 3,600 2,800 to 5,900

Meta‐analysis Bell et al. (2005) 930 to 2,000 2,000 to 4,000 3,500 to 6,600

Ito et al. 1,000 to 2,100 2,300 to 4,300 4,000 to 7,100

Levy et al. 1,000 to 2,100 2,300 to 4,300 4,100 to 7,200

Combined Estimate of Morbidity 0.075 ppm 0.070 ppm 0.065 ppm

Acute Myocardial Infarction B 1,300 2,200 3,500

Upper Respiratory Symptoms B 9,900 19,000 31,000

Lower Respiratory Symptoms B 13,000 25,000 41,000

Chronic Bronchitis B 470 880 1,400

Acute Bronchitis B 1,100 2,100 3,400

Asthma Exacerbation B 12,000 23,000 38,000

Work Loss Days B 88,000 170,000 270,000

School Loss Days C 190,000 600,000 1,100,000

Hospital and ER Visits 2,600 6,700 11,000

Minor Restricted Activity Days 1,000,000 2,600,000 4,500,000

A Does not reflect estimates for the San Joaquin and South Coast Air Basins

B

PM‐related benefits only

C

Ozone‐related benefits only

D All estimates rounded to two significant digits

   
S3‐6

Table S3.2: Summary of Total Monetized Benefits in 2020 (3% discount rate, in millions of

2006$)A, B, C

Combined Estimate of Mortality 0.075 ppm 0.070 ppm 0.065 ppm

NMMAPS Bell et al. (2004) $6,900   to $15,000 $13,000 to $29,000   $22,000   to $47,000

Schwartz $7,200   to $16,000 $15,000 to $30,000   $24,000   to $49,000

Huang $7,300   to $16,000 $15,000 to $30,000   $25,000   to $50,000

Meta‐analysis Bell et al. (2005) $8,300   to $17,000 $18,000 to $34,000   $31,000   to $56,000

Ito et al. $9,100   to $18,000 $21,000 to $37,000   $36,000   to $61,000

   Levy et al. $9,200   to $18,000 $21,000 to $37,000   $36,000   to $61,000

A Does not reflect estimates for the San Joaquin and South Coast Air Basins B All estimates rounded to two significant digits c

Includes Visibility benefits of $160,000

Table S3.3: Summary of Total Monetized Benefits in 2020 (7% discount rate, in millions of

2006$)A, B, C

Combined Estimate of Mortality 0.075 ppm 0.070 ppm 0.065 ppm

NMMAPS Bell et al. (2004) $6,400   to $13,000 $11,000 to $24,000   $19,000   to $39,000

Schwartz $6,700   to $13,000 $12,000 to $25,000   $21,000   to $41,000

Huang $6,800   to $13,000 $13,000 to $26,000   $21,000   to $42,000

Meta‐analysis Bell et al. (2005) $7,800   to $14,000 $16,000 to $29,000   $27,000   to $48,000

Ito et al. $8,600   to $15,000 $18,000 to $31,000   $31,000   to $52,000

   Levy et al. $8,700   to $15,000 $18,000 to $31,000   $32,000   to $52,000

A Does not reflect estimates for the San Joaquin and South Coast Air Basins

B

All estimates rounded to two significant digits

c

Includes Visibility benefits of $160,000
S3‐7

Figure S3‐1: Breakdown of Ozone Health Benefits (using Bell 2004)*

*This pie chart breakdown is illustrative, using the results based on Bell et al. (2004) as an example.  Using the Levy

et al. (2006) function for premature mortality, the percentage of total monetized benefits due to adult mortality

would be 97%.   

Infant Hospital Admissions

1.5%

ER Visits

0.02% School Loss Days

2.3% Acute Resp Symptoms

4.1%

Adult Hospital Admissions

1.8%

Adult Mortality Bell et al.

(2004)

90%
S3‐8

Figure S3‐2: Breakdown of PM2.5Health Benefits (using Pope)*

*This pie chart breakdown is illustrative, using the results based on Pope et al. (2002) as an example.  Using the

Laden et al. (2006) function for premature mortality, the percentage of total monetized benefits due to adult

mortality would be 97%.  This chart shows the breakdown using a 3% discount rate, and the results would be

similar if a 7% discount rate was used.   

Adult Mortality ‐ Pope et

al. 93%

ChronicBronchitis 4%

AMI 2%

Acute Respiratory Symptoms

0.5%

InfantMortality 0.4%

Work Loss Days 0.2%

HospitalAdmissions, Cardio

0.2%

HospitalAdmissions, Resp

0.04%

Asthma Exacerbation 0.01%

Acute Bronchitis 0.01%

UpperResp Symp 0.00%

LowerResp Symp 0.00%

ERVisits, Resp 0.00%

Other1%
S3‐9

Table S3.4: Summary of National Ozone Benefits by Standard Level with 95th percentile confidence intervals (in mi

Endpoint Group Author 0.075 ppm Valuation 0.075 ppm Incidence 0.070 ppm Valuation 0.070 ppm Incidence 0.065 pp

Valuatio

Infant Hospital Admissions, Respiratory $11 550 $17 1,700 $30 

($5.7 ‐‐ $16) (310 ‐‐ 830) ($8.5 ‐‐ $25) (960 ‐‐ 2,600) ($15 ‐‐ $4

Emergency Room Visits, Respiratory

$0.11 290 $0.36 990 $0.66 

(‐$.21 ‐‐ $.35) (‐310 ‐‐ 930) (‐$.71 ‐‐ $1.2) (‐890 ‐‐ 3,200) (‐$1.3 ‐‐ $2

School Loss Days $17 190,000 $53 600,000 $96 

($7.5 ‐‐ $24) (93,000 ‐‐ 280,000) ($23 ‐‐ $76) (300,000 ‐‐ 880,000) ($42 ‐‐ $14

Acute Respiratory Symptoms

$30 510,000 $96 1,600,000 $170 

($12 ‐‐ $56) (280,000 ‐‐ 790,000) ($37 ‐‐ $180) (910,000 ‐‐ 2,500,000) ($68 ‐‐ $32

Hospital Admissions, Respiratory

$13 550 $45 1,900 $81 

($1.7 ‐‐ $22) (130 ‐‐ 980) ($5.6 ‐‐ $77) (550 ‐‐ 3,400) ($11 ‐‐ $14

Mortality Bell et al. 2004

$660 74 $2,200 250 $4,000 

($54 ‐‐ $2,000) (36 ‐‐ 120) ($180 ‐‐ $6,600) (130 ‐‐ 410) ($330 ‐‐ $12,

Mortality Schwartz

$1,000 110 $3,400 380 $6,200 

($82 ‐‐ $3,000) (54 ‐‐ 190) ($270 ‐‐ $10,000) (190 ‐‐ 630) ($500 ‐‐ $19,

Mortality Huang $1,100 130 $3,800 420 $6,800 

($95 ‐‐ $3,300) (66 ‐‐ 200) ($320 ‐‐ $11,000) (230 ‐‐ 670) ($580 ‐‐ $20,

Mortality Bell et al. 2005

$2,000 240 $7,000 800 $10,000 

($190 ‐‐ $6,100) (140 ‐‐ 350) ($630 ‐‐ $21,000) (490 ‐‐ 1,200) ($1,100 ‐‐ $37

Mortality Ito et al.

$2,900 330 $9,900 1,100 $18,000 

($280 ‐‐ $8,200) (230 ‐‐ 450) ($930 ‐‐ $28,000) (790 ‐‐ 1,500) ($1,700 ‐‐ $50

Mortality Levy et al.

$3,000 340 $10,000 1,100 $18,000 

($280 ‐‐ $8,200) (260 ‐‐ 430) ($930 ‐‐ $28,000) (870 ‐‐ 1,500) ($1,700 ‐‐ $50

A Does not reflect estimates for the San Joaquin and South Coast Air BasinsB Confidence intervals are not available for PM co‐benefits because of methodological limitations when using benefit‐per‐ton estimates.C All estimates rounded to two significant digits
S3‐10

Table S3.5: Summary of National Ozone Benefits and PM2.5 Co‐Benefits by Standard Level (in millions of 2006$ at a 3

  

Endpoint Group Author

0.075 ppm

Valuation

0.075 ppm

Incidence

0.070 ppm

Valuation

0.070 ppm

Incidence

0.065 p

Valuat

Ozone

Infant Hospital Admissions, Respiratory $11 550 $17 1,700 $30 Emergency Room Visits, Respiratory $0.11 290 $0.36 990 $0.6

School Loss Days $17 190,000 $53 600,000 $96 Acute Respiratory Symptoms $30 510,000 $96 1,600,000 $170 

Hospital Admissions, Respiratory $13 550 $45 1,900 $81 

Mortality Bell et al. (2004) $660 74 $2,200 250 $4,00

Mortality Schwartz $1,000 110 $3,400 380 $6,20

Mortality Huang $1,100 130 $3,800 420 $6,80

Mortality Bell et al. (2005) $2,100 240 $7,100 800 $13,0

Mortality Ito et al. $2,900 330 $9,900 1,100 $18,0

Mortality Levy et al. $3,000 340 $10,000 1,100 $18,0

PM2.5

Chronic Bronchitis $230 470 $430 880 $700 Acute Myocardial Infarction $140 1,300 $240 2,200 $380 

Hospital Admissions, Respiratory $2.5 180 $4.3 310 $6.8 

Hospital Admissions, Cardiovascular $11 390 $18 670 $29 

Emergency Room Visits, Respiratory $0.22 590 $0.39 1,100 $0.6

Acute Bronchitis $0.08 1,100 $0.15 2,100 $0.2

Work Loss Days $11 88,000 $20 170,000 $34 

Asthma Exacerbation $0.64 12,000 $1.2 23,000 $2.0 

Acute Respiratory Symptoms $31 520,000 $58 980,000 $95 

Lower Respiratory Symptoms $0.24 13,000 $0.45 25,000 $0.7

Upper Respiratory Symptoms $0.29 9,900 $0.54 19,000 $0.8

Infant Mortality $22 3 $44 5 $73 

Mortality Pope et al $5,500 690 $10,000 1,200 $16,0

Mortality Laden et al $14,000 1,800 $26,000 3,200 $41,0

Mortality Expert K $1,900 230 $3,500 430 $5,70

Mortality Expert E $19,000 2,300 $34,000 4,200 $55,0

A Does not reflect estimates for the San Joaquin and South Coast Air BasinsB Does not include confidence intervalsC All estimates rounded to two significant digits
S3‐11

Table S3.6: Summary of National Ozone Benefits and PM2.5 Co‐Benefits by Standard Level (in millions of 2006$ at a 7

  

Endpoint Group Author

0.075 ppm

Valuation

0.075 ppm

Incidence

0.070 ppm

Valuation

0.070 ppm

Incidence

0.065 

Valua

Ozone

Infant Hospital Admissions, Respiratory $11 550 $17 1,700 $3Emergency Room Visits, Respiratory $0.11 290 $0.36 990 $0.

School Loss Days $17 190,000 $53 600,000 $9

Acute Respiratory Symptoms $30 510,000 $96 1,600,000 $17

Hospital Admissions, Respiratory $13 550 $45 1,900 $8

Mortality Bell et al. (2004) $660 74 $2,200 250 $4,0

Mortality Schwartz $1,000 110 $3,400 380 $6,2

Mortality Huang $1,100 130 $3,800 420 $6,8

Mortality Bell et al. (2005) $2,100 240 $7,100 800 $13,

Mortality Ito et al. $2,900 330 $9,900 1,100 $18,

Mortality Levy et al. $3,000 340 $10,000 1,100 $18,

PM2.5

Chronic Bronchitis $230 470 $430 880 $70Acute Myocardial Infarction $140 1,300 $240 2,200 $38

Hospital Admissions, Respiratory $2.5 180 $4.3 310 $6

Hospital Admissions, Cardiovascular $11 390 $18 670 $2

Emergency Room Visits, Respiratory $0.22 590 $0.39 1,100 $0.

Acute Bronchitis $0.08 1,100 $0.15 2,100 $0.

Work Loss Days $11 88,000 $20 170,000 $3

Asthma Exacerbation $0.64 12,000 $1.2 23,000 $2

Acute Respiratory Symptoms $31 520,000 $58 980,000 $9

Lower Respiratory Symptoms $0.24 13,000 $0.45 25,000 $0.

Upper Respiratory Symptoms $0.29 9,900 $0.54 19,000 $0.Infant Mortality $22 3 $44 5 $7

Mortality Pope et al $5,000 690 $9,000 1,200 $14,

Mortality Laden et al $13,000 1,800 $23,000 3,200 $37,

Mortality Expert K $1,700 230 $3,100 430 $5,1

Mortality Expert E $17,000 2,300 $31,000 4,200 $49,

A Does not reflect estimates for the San Joaquin and South Coast Air Basins B Does not include confidence intervalsC All estimates rounded to two significant digits
S3‐12

Figure S3.3: Ozone benefits for Alternate Standard Levels*

*This graph shows the estimated ozone benefits in 2020 using three NMMAPS‐based epidemiology studies and

three meta‐analyses.  The results shown are not the direct results from the studies; rather, the estimates are based

in part on the concentration‐response function provided in those studies.  Because all ozone‐related health effects

are short‐term, the discount rate does not affect the results.   

Figure S3.4: PM2.5 co‐benefits for Alternate Standard Levels*

*This graph shows the estimated PM2.5 co‐benefits in 2020 using the no‐threshold model at discount rates of 3%

using effect coefficients using the Pope et al. study and the Laden et al study, as well as 12 effect coefficients

derived from EPA’s expert elicitation on PM mortality.  The results shown are not the direct results from the

studies or expert elicitation; rather, the estimates are based in part on the concentration‐response function

provided in those studies.  Results using a 7% discount rate would be similar, but approximately 9% lower.

$0

$5

$10

$15

$20

Ito et al. Schwartz Bellet al. 2004 Levy et al. Bellet al. 2005 Huang

Billions of 2006$

NMMAPS Epidemiology study  or  Meta‐Analysis

0.075 ppm 0.070 ppm 0.065 ppm

$0

$10

$20

$30

$40

$50

$60

Pope

et al.

Laden

et al.

Expert

A

Expert

B

Expert

C

Expert

D

Expert

E

Expert

F

Expert

G

Expert

H

Expert

I

Expert

J

Expert

K

Expert

L

Billions of 2006$

Epidemiology study or expert

0.075 ppm 0.070 ppm 0.065 ppm
S3‐13

Figure S3.5: Breakdown of total monetized benefits for Alternate Standard Levels (Low)

$0

$10

$20

$30

$40

$50

$60

0.075 ppm 0.070 ppm 0.065 ppm

Billions of 2006$

Visibility Ozone Morbidity

PM Morbidity Ozone Mortality ‐ Bell 2004

PM Mortality ‐ Pope 2002
S3‐14

Figure S3.6: Breakdown of total monetized benefits for Alternate Standard Levels (High)

$0

$10

$20

$30

$40

$50

$60

0.075 ppm 0.070 ppm 0.065 ppm

Billions of 2006$

PM Mortality ‐ Laden 2006 Ozone Mortality ‐ Levy

PM Morbidity Ozone Morbidity

Visibility
S3‐15

Figure S3.7: Total Monetized Benefits for Alternate Standard Levels*

*This graph shows the estimated total monetized benefits in 2020 using the no‐threshold model at discount rates

of 3% using effect coefficients derived from the 6 ozone mortality studies and PM co‐benefits estimates using the

Pope et al. study and the Laden et al study, as well as 12 effect coefficients derived from EPA’s expert elicitation on

PM mortality.  The highlighted results represent the combined estimates from Bell et al. (2004) with Pope et al.

(2002) and Levy (2005) with Laden et al. (2006).  The results shown are not the direct results from the studies or

expert elicitation; rather, the estimates are based in part on the concentration‐response function provided in those

studies.  PM co‐benefit results using a 7% discount rate would be similar, but approximately 9% lower.

In 2008, the National Research Council (NRC) evaluated the EPA’s approach to

estimating ozone‐related mortality benefits.  Among other recommendation, in its report the

NRC indicated that “EPA should consider placing greater emphasis on reporting decrease in

age‐specific death rates and increases in life expectancy...”  (NRC, 2008).  As a first step in

implementing this recommendation, below for two of the three scenarios, we present changes

in the percentage of total cause‐specific mortality attributable to ozone and the change in the

number of life years.5

  Table 7 summarizes the estimated number of life years gained resulting

from simulated attainment with the 0.065 ppm and 0.070 ppm standard alternatives. To

                                                           

5 Here we omit the results for the 0.075 ppm alternative. We estimated the benefits of attaining this alternative

through an interpolation approach that made subsequent estimation of life years and changes in death rates

technically challenging.  

Pope et al.,

Bell et al. 2004

Laden et al.,

Levy et al.

$‐

$10

$20

$30

$40

$50

$60

$70

Billions of 2006$

Combinations of 6 Ozone benefits estimates with 14 PM2.5 co‐benefits estimates

0.075 ppm

0.070 ppm

0.065 ppm
S3‐16

simplify this presentation we include results based on the estimates of ozone mortality

reported in Levy et al. (2005) and Bell et al. (2004), which provide upper and lower‐bound

estimates, respectively.

Table S3.7: Estimated Reduction in Ozone‐Related Premature Mortality in Terms of Life Years Gained

from Increases in Life Expectancy

Age Range

Bell et al. (2004) mortality estimate Levy et al. (2005) mortality estimate

0.070 ppm 0.065 ppm 0.070 ppm 0.065 ppm

25‐29 75

(32—120)

130

(58—210)

660

(780—830)

1,200

(850—1,500)

30‐34 66

(28—100)

120

(51—180)

580

(420—740)

1,000

(750—1,300)

35‐44 260

(110—410)

460

(200—730)

1,600

(1,200—2,000)

2,800

(2,000—3,500)

45‐54 520

(220—830)

930

(400—1,500)

2,600

(1,900—3,300)

4,500

(3,300—5,700)

55‐64 1,000

(440—1,600)

1,800

(780—2,800)

4,600

(3,400—5,900)

8,100

(5,900—10,000)

65‐74 1,200

(500—1,900)

2,100

(900—3,300)

5,200

(3,800—6,600)

9,100

(6,700—12,000)

75‐84 810

(340—1,300)

1,400

(620—2,200)

3,500

(2,600—4,500)

6,200

(4,600—7,900)

85‐99 400

(170—630)

720

(310—1,100)

1,800

(1,300—2,200)

3,100

(2,300—4,000)

Table S3.8 summarizes the percentage of total mortality attributable to ozone. As

above, we include estimates based on the Bell et al. (2004) and Levy et al. (2005) risk

coefficients.

Table S3.8: Percentage of Total Mortality Attributable to Ozone

Age Range

Bell et al. (2004) mortality estimate Levy et al. (2005) mortality estimate

0.070 ppm 0.065 ppm 0.070 ppm 0.065 ppm

25‐29 0.030% 0.054% 0.126% 0.224%

30‐34 0.029% 0.052% 0.123% 0.217%

35‐44 0.029% 0.051% 0.123% 0.217%

45‐54 0.030% 0.052% 0.127% 0.224%

55‐64 0.028% 0.050% 0.122% 0.212%

65‐74 0.027% 0.047% 0.114% 0.200%

75‐84 0.026% 0.046% 0.112% 0.197%

85‐99 0.027% 0.048% 0.115% 0.206%
S3‐17

S3.4 Comparison of results to previous results in 2008 Ozone NAAQS RIA

The overall effect of incorporating the array of methodological changes was to increase the

estimated benefits of attaining alternate ozone standards estimates presented in the 2008 Ozone

NAAQS RIA.  In general, the key update that had the largest effect on the valuation and the incidence

results is removing the threshold from the PM concentration‐response functions.  Tables 9 and 10 show

the total monetized benefits, costs, and net benefits for the 2008 Ozone RIA analysis and this updated

analysis, respectively.  Figure 6 shows a comparison of the range of net benefits estimates in this

updated analysis compared to the net benefits presented in the 2008 Ozone NAAQS RIA.6

Table S3.9: Total Monetized Costs with Ozone Benefits and PM2.5 Co‐Benefits in 2020

(in Billions of 2006$) * 2008 RIA

Ozone Mortality

Function

Reference Total Benefits ** Total Costs *** Net Benefits

3% 7% 7% 3% 7%

0.075 ppm

NMMAPS and

Multi‐city

Bell et al. 2004 $4.4 to $8.5 $4.1 to $7.7 $7.6 to $8.8 $‐4.4 to $0.9 $‐4.7 to $0.1

Schwartz 2005 N/A N/A N/A N/A N/A

Huang 2005 N/A N/A N/A N/A N/A

Meta‐analysis

Bell et al. 2005 $5.6 to $9.7 $5.3 to $9.0 $7.6 to $8.8 $‐3.2 to $2.1 $‐3.5 to $1.4

Ito et al. 2005 $6.3 to $10 $5.9 to $9.6 $7.6 to $8.8 $‐2.5 to $2.7 $‐2.9 to $2.0

Levy et al. 2005 $6.3 to $10 $6.0 to $9.7 $7.6 to $8.8 $‐2.5 to $2.8 $‐2.8 to $2.1

0.070 ppm

NMMAPS and

multi‐city

Bell et al. 2004 $8.8 to $16 $8.2 to $15 $19 to $25 $‐16 to $‐2.8 $‐17 to $4.1

Schwartz 2005 N/A N/A N/A N/A N/A

Huang 2005 N/A N/A N/A N/A N/A

Meta‐analysis

Bell et al. 2005 $13 to $21 $13 to $19 $19 to $25 $‐12 to $1.5 $‐12 to $0.2

Ito et al. 2005 $15 to $23 $15 to $21 $19 to $25 $‐9.6 to $3.8 $‐10 to $2.5

Levy et al. 2005 $16 to $23 $15 to $22 $19 to $25 $‐9.3 to 4.1 $9.9 to $2.7

0.065 ppm

NMMAPS and

multi‐city

Bell et al. 2004 $15 to $27 $14 to $24 $32 to $44 $‐29 to $‐5.4 $‐30 to $‐7.5

Schwartz 2005 N/A N/A N/A N/A N/A

Huang 2005 N/A N/A N/A N/A N/A

Meta‐analysis

Bell et al. 2005 $22 to $34 $21 to $32 $32 to $44 $‐22 to $2.4 $‐23 to $0.3

Ito et al. 2005 $27 to $39 $26 to $36 $32 to $44 $‐17 to $6.6 $‐18 to $4.4

Levy et al. 2005 $27 to $39 $26 to $37 $32 to $44 $‐17 to $7.0 $‐18 to $4.9

*All estimates rounded to two significant figures. As such, they may not sum across columns. Only includes areas required

to meet the current standard by 2020, does not include San Joaquin and South Coast areas in California.  

**Includes ozone benefits, and PM2.5 co‐benefits. Range was developed by adding the estimate from the ozone premature

mortality function to estimates from the PM2.5 premature mortality functions from Pope et al. and Laden et al. Tables

exclude unquantified and nonmonetized benefits.

***Range reflects lower and upper bound cost estimates. Data for calculating costs at a 3% discount rate was not available

for all sectors, and therefore total annualized costs at 3% are not presented here. Additionally, these estimates assume a

particular trajectory of aggressive technological change. An alternative storyline might hypothesize a much less optimistic

technological trajectory, with increased costs, or with decreased benefits in 2020 due to a later attainment date.

                                                           

6 Net benefits are total monetized benefits minus total monetized costs.  Total monetized benefits include ozone

health benefits, PM2.5 health co‐benefits, visibility benefits, but not other unquantified benefit categories.   
S3‐18

Table S3.10: Total Monetized Costs with Ozone Benefits and PM2.5 Co‐Benefits in 2020  

(in Billions of 2006$) * Updated Analysis

Ozone Mortality

Function

Reference Total Benefits ** Total Costs *** Net Benefits

3% 7% 7% 3% 7%

0.075 ppm

NMMAPS  

and multi‐city

Bell et al. 2004 $6.9 to $15 $6.4 to $13 $7.6 to $8.8 $‐1.9 to $7.4 $‐2.4 to $5.4

Schwartz 2005 $7.2 to $16 $6.8 to $13 $7.6 to $8.8 $‐1.6 to $8.4 $‐2.1 to $5.4

Huang 2005 $7.3 to $16 $6.9 to $13 $7.6 to $8.8 $‐1.5 to $8.4 $‐2.0 to $5.4

Meta‐analysis

Bell et al. 2005 $8.3 to $17 $7.9 to $14 $7.6 to $8.8 $‐0.50 to $9.4 $‐1.0 to $6.4

Ito et al. 2005 $9.1 to $18 $8.7 to $15 $7.6 to $8.8 $0.30 to $10 $‐0.20 to $7.4

Levy et al. 2005 $9.2 to $18 $8.8 to $15 $7.6 to $8.8 $0.40 to $10 $‐0.10 to $7.4

0.070 ppm

NMMAPS  

and multi‐city

Bell et al. 2004 $13 to $29 $11 to $24 $19 to $25 $‐12 to $10 $‐14 to $5.0

Schwartz 2005 $15 to $30 $12 to $25 $19 to $25 $‐10 to $11 $‐13 to $6.0

Huang 2005 $15 to $30 $13 to $26 $19 to $25 $‐10 to $11 $‐12 to $7.0

Meta‐analysis

Bell et al. 2005 $18 to $34 $16 to $29 $19 to $25 $‐7.0 to $15 $‐9.0 to $10

Ito et al. 2005 $21 to $37 $18 to $31 $19 to $25 $‐4.0 to $18 $‐6.0 to $12

Levy et al. 2005 $21 to $37 $18 to $31 $19 to $25 $‐4.0 to $18 $‐6.0 to $12

0.065 ppm

NMMAPS  

and multi‐city

Bell et al. 2004 $22 to $47 $19 to $40 $32 to $44 $‐22 to $15 $‐25 to $7.0

Schwartz 2005 $24 to $49 $21 to $42 $32 to $44 $‐20 to $17 $‐23 to $9.0

Huang 2005 $25 to $50 $22 to $42 $32 to $44 $‐19 to $18 $‐23 to $10

Meta‐analysis

Bell et al. 2005 $31 to $56 $27 to $48 $32 to $44 $‐13 to $24 $‐17 to $16

Ito et al. 2005 $36 to $61 $32 to $53 $32 to $44 $‐8.0 to $29 $‐13 to $20

Levy et al. 2005 $36 to $61 $32 to $53 $32 to $44 $‐7.0 to $29 $‐12 to $20

*All estimates rounded to two significant figures. As such, they may not sum across columns. Only includes areas

required to meet the current standard by 2020, does not include San Joaquin and South Coast areas in California.  

**Includes ozone benefits, and PM2.5 co‐benefits. Range was developed by adding the estimate from the ozone

premature mortality function to estimates from the PM2.5 premature mortality functions from Pope et al. and Laden

et al. Tables exclude unquantified and nonmonetized benefits.

***Range reflects lower and upper bound cost estimates. Data for calculating costs at a 3% discount rate was not

available for all sectors, and therefore total annualized costs at 3% are not presented here. Additionally, these

estimates assume a particular trajectory of aggressive technological change. An alternative storyline might

hypothesize a much less optimistic technological trajectory, with increased costs, or with decreased benefits in 2020

due to a later attainment date.
S3‐19

0.075

ppm

0.070

ppm

0.065

ppm

Figure S3.6: Comparison of Net Benefits in Updated Analysis to 2008 Ozone NAAQS RIA*

2008 RIA         Updated Analysis

  

$(100)

$(80)

$(60)

$(40)

$(20)

$‐

$20

$40

$60

$80

$100

Median

= $0.9b

Benefits are

greater than costs

Costs are greater

than benefits

‐$100

‐$80

‐$60

‐$40

‐$20

$0

$20

$40

$60

$80

$100

Benefits are greater

than costs

Costs are greater than

benefits

Median

= $3.1b

$(100)

$(80)

$(60)

$(40)

$(20)

$‐

$20

$40

$60

$80

$100

Benefits are

greater than costs

Costs are greater than

benefits

Median

= ‐ $4.0b

$(100)

$(80)

$(60)

$(40)

$(20)

$‐

$20

$40

$60

$80

$100

Benefits are greater

than costs

Costs are greater than

benefits

Median

= $1.4b

$(100)

$(80)

$(60)

$(40)

$(20)

$‐

$20

$40

$60

$80

$100

Costs are greater

than benefits

Benefits are greater

than costs

Median

= ‐ $9.0b

$(100)

$(80)

$(60)

$(40)

$(20)

$‐

$20

$40

$60

$80

$100

Benefits are

greater than costs

Costs are greater

than benefits

Median

= $0.7b

These graphs shows all combinations of the 6 different ozone mortality functions and assumptions, the 14 different PM

mortality functions, and the 2 cost methods.  These combinations do not represent a distribution.  
S3‐20

S3.5 References  

Bell, M.L., et al. 2004.  Ozone and short‐term mortality in 95 US urban communities, 1987‐2000.  Journal

of the American Medical Association.  292(19): p. 2372‐8.

Bell, M.L., F. Dominici, and J.M. Samet.  2005. A meta‐analysis of time‐series studies of ozone and

mortality with comparison to the national morbidity, mortality, and air pollution study.  

Epidemiology.  16(4): p. 436‐45.

Huang Y. Dominici F. Bell M. 2005.  Bayesian Hierarchical Distributed Lag Models for Summer Ozone

Exposure and Cardio‐Respiratory Mortality Environmetrics, 16, 547‐562.

Ito, K., S.F. De Leon, and M. Lippmann.  2005. Associations between ozone and daily mortality: analysis

and meta‐analysis.  Epidemiology.  16(4): p. 446‐57.

Jaffe DH, Singer ME, Rimm AA.  2003. Air pollution and emergency department visits for asthma among

Ohio Medicaid recipients, 1991‐1996.  Environ Res 91(1):21‐28.

Jerrett M, Burnett RT, Pope CA, III, et al.  2009.  Long‐Term Ozone Exposure and Mortality.  N Engl J Med

360:1085‐95.

Krewski, D.; Jerrett, M.; Burnett, R.T.; Ma, R.; Hughes, E.; Shi, Y.; Turner, M.C.; Pope, C.A. III; Thurston,

G.; Calle, E.E.; Thun, M.J. 2009. Extended follow‐up and spatial analysis of the American Cancer

Society study linking particulate air pollution and mortality. HEI Research Report, 140, Health Effects

Institute, Boston, MA.

Laden, F., J. Schwartz, F.E. Speizer, and D.W. Dockery.  2006.  Reduction in Fine Particulate Air Pollution

and Mortality.  American Journal of Respiratory and Critical Care Medicine 173:667‐672.

Levy, J.I., S.M. Chemerynski, and J.A. Sarnat.  2005. Ozone exposure and mortality: an empiric bayes

metaregression analysis.  Epidemiology.  16(4): p. 458‐68.

National Research Council (NRC).  2008.  Estimating Mortality Risk Reduction and Economic Benefits

from Controlling Ozone Air Pollution.  National Academies Press.  Washington, DC.   

Peel, J. L., P. E. Tolbert, M. Klein, et al. 2005.  Ambient air pollution and respiratory emergency

department visits.  Epidemiology.  Vol. 16 (2): 164‐74.

Pope, C.A., III, R.T. Burnett, M.J. Thun, E.E. Calle, D. Krewski, K. Ito, and G.D. Thurston.  2002. “Lung

Cancer, Cardiopulmonary Mortality, and Long‐term Exposure to Fine Particulate Air Pollution.”  

Journal of the American Medical Association 287:1132‐1141.
S3‐21

Roman, Henry A., Katherine D. Walker, Tyra L. Walsh, Lisa Conner, Harvey M. Richmond, Bryan J.

Hubbell, and Patrick L. Kinney.  2008. Expert Judgment Assessment of the Mortality Impact of

Changes

Schwartz, J.  2005.  How sensitive is the association between ozone and daily deaths to control for

temperature?  Am J Respir Crit Care Med. Vol. 171 (6): 627‐31.

U.S. Environmental Protection Agency (U.S. EPA).  2008. Regulatory Impact Analysis, 2008 National

Ambient Air Quality Standards for Ground‐level Ozone, Chapter 6.  Office of Air Quality Planning and

Standards, Research Triangle Park, NC.  March.  Available on the Internet at

<http://www.epa.gov/ttn/ecas/regdata/RIAs/6‐ozoneriachapter6.pdf>.  

U.S. Environmental Protection Agency (U.S. EPA).  2009a. Regulatory Impact Analysis: National Emission

Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.  Office of

Air Quality Planning and Standards, Research Triangle Park, NC.  April.  Available on the Internet at

<http://www.epa.gov/ttn/ecas/regdata/RIAs/portlandcementria_4‐20‐09.pdf>.

U.S. Environmental Protection Agency (U.S. EPA).  2009b. Proposed NO2 NAAQS Regulatory Impact

Analysis (RIA).  Office of Air Quality Planning and Standards, Research Triangle Park, NC.  July.  

Available on the Internet at <http://www.epa.gov/ttn/ecas/regdata/RIAs/proposedno2ria.pdf>.  

Wilson, A. M., C. P. Wake, T. Kelly, et al. 2005.  Air pollution, weather, and respiratory emergency room

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312‐21.