# Technical & Policy Issues with 

# EPA’s Proposed Ozone NAAQS June 18, 2010 

# American Petroleum Institute Presentation to: Environmental Protection Agency Washington, D.C.

1

# Recommendation Maintain EPA’s Scheduled 2013 Ozone Review
 complete a thorough review of all new health studies to address unanswered questions on health effects from 

# the last review
 consider new data on ozone background levels / international transport
 Assess utility and applicability of a secondary standard in the W126 form

2

# Discussion Issues

 Human Health Impacts are overstated and more uncertain than presented in the proposed rule
 Policy Relevant Background (PRB) is higher than EPA estimates and therefore the risk assessment overstates 

# the potential benefits of a lower standard
 The evidence does not establish that a secondary NAAQS more stringent and with a different form than the 

# primary standard is warranted

3

# Background

 EPA reconsidering 2008 decision that lowered ozone NAAQS  EPA proposes to again lower the standard to 60 - 70 ppb based on:  

## the scientific record from the last review  

## Provisional Assessment of Recent Studies (PARS) on Health and Ecological Effects of Ozone Exposure of new data 

#  EPA concluded that PARS does not “materially change 

# any of the broad scientific conclusion regarding health effects of ozone made in the 2007 AQCD”  

## A more comprehensive review of new studies suggests an alternate conclusion

4

# Continuing Concerns with EPA’s 2008 Ozone Review

 EPA reanalyzed published studies and reached different conclusions 

## not supported by the author (Adams 2006)  EPA excluded well conducted studies without justification  Schildcrout (2006): reports ozone does not exacerbate asthma  Giradot (2006): reports no effects of ozone in highly exposed hikers  Kamps (2001) finds as unreliable lung function measurement test used in key EPA studies 

##  EPA relied on conflicting hypothesis to explain inconsistent results  Mortimer 2004, Delfino 2002: reached different conclusions on asthmatic symptoms in children  Mortimer 2004, Ross 2002: reached different conclusions on time of day for lung function changes  In both cases, EPA accepts conflicting hypothesis to explain inconsistent results 

##  EPA used individual responses in clinical study designed to assess group effects: Adams 2006 

##  EPA failed to recognize limitations of observational studies  Use of ambient measurements as surrogate for personal exposure; single pollutant models 

##  EPA deviated from established medical criteria in defining adverse effect

5

# New Health Data Challenges 

# EPA 2010 Conclusions 1
 EPA states pulmonary function effects occur at 60 ppb but...  New clinical study ( Schelegle 2009) confirms no effects at 60 ppb transient non - adverse effects at 70 ppb 

#  EPA claimed asthma exacerbation occurs at current levels but...  3 of 4 new studies report no association, including an EPA-sponsored study not cited in the PA (O’Connor 2008) that relies on improved measuring methods 

#  EPA concluded airway inflammation/respiratory morbidity occurs at current levels, but...  All new studies (3) on airway inflammation report no association  Results of new studies on respiratory morbidity continue to be mixed 

#  EPA concluded cardiac hospital admissions occur at current ozone levels, but...  7 of 8 new studies in PA plus one large study (HEI 2009 NMMAPS) not cited by PA report no association 

#  EPA concluded acute mortality occurs at current ozone levels, but...  New studies not in PA (HEI 2009, Smith 2009, Stylianou 2009) do not support case for acute mortality link

6 1 In the proposed rule, EPA makes several key conclusions but indicates new research is needed to reduce uncertainties. In the examples presented, significant new research is already available.

# Concerns with EPA Approach to Determine PRB

 EPA defines Policy Relevant Background (PRB) as concentration that would occur in the US in the absence of anthropogenic emissions in continental North America (US, Canada, and Mexico)


#  EPA assesses risks to human health and environmental effects from O 3 

# levels in excess of PRB
 EPA asserts PRB to be 15 - 35 ppb based on GEOS 

# CHEM modeling
 Modeled PRB is far too low in comparison to monitored values.

7

# Impact of PRB on Acute Mortality Estimates 1
Number of Deaths Attributable to Ozone > GEOS - CHEM PRB Number of Deaths Attributable to Ozone > 40 ppb PRB Percent Reductions If Using 40 ppb rather than GEOS - CHEM for PRB Assumption 

# Atlanta 6.5 0.3 95% 

# Cleveland 37.4 4.3 88% Detroit 37.9 1.8 95% Houston 22.7 1.5 94% Los Angeles 38.5 0.1 99% Sacramento 11.0 0.2 98% St. Louis 4.4 0.3 93%

8 1 Risks estimated using risk specific coefficients from Bell et al. 2004, at exact attainment of the 0.084 ppm NAAQS, average o f 2 002 and 2004 data (CRA, 2007)

# CASTNET Data Indicate Many Rural Areas



# Will Exceed a 60-70 ppb NAAQS 1

9 1VValues are three -Year Average of Fourth Highest Daily Maximum 8 - Hour Average Ozone Concentrations (ppb) in various National Parks for 2006–2008 Yellowstone Rocky Mt.
Acadia
Blackwater Great Smokey Kane National Forest

Monmouth Cave Big Bend Lassen Volcano Yosemite

Petrified Forest

Grand Canyon Sequoia Joshua Tree Konza Prairie

# Transport Issue Must be

Considered 1

 Increasing emissions from Asia are outpacing reductions in the U.S.  Asia NOx emissions increased 44% (55% in China) during 2001 -2006 while ozone precursors from the U.S. decreased by more than a third in 1985 -2008 

##  Recent studies estimate that Asia emissions have contributed up to 17 ppb to tropospheric ozone levels over 1984 -2008  Trend will continue and increase tropospheric ozone 0.7 ppbv per year  Intrusion of tropospheric ozone in spring significantly increases ground level ozone in the west and midwest regions of the U.S. 

##  Key conclusion: ozone transport hindering attainment in U.S.

10 1 Statements, data, conclusions presented are from Cooper et al. (2010).

###  Sole reliance on modeling 

###  Global emission inventory which is out of date  Large grid size of the model  Determined for only 12 US cities  Looked at average of only part of a 

### year verses the statistic of the standard  Does not vary by season or elevation  PRB should be reevaluated before 

### setting a new ozone NAAQS  PRB should be reevaluated using all available data and tools  monitoring, upper air measurements, modeling, and satellite 

###  A new global inventory accounting for increased emissions from Asia  Use a smaller grid size  PRB should be assessed for a broader and more diverse geographic 

### region than 12 cities and for the full year  PRB should use the same form as the NAAQS (4th 

### highest 8 - hr average from a full year’s data) 

###  PRB should vary by:  Season  Elevation  Perhaps geographical location 11 

# Concerns with EPA’s Approach to Determine PRB Recommendations for Improving the PRB Determination

# A Separate Secondary Ozone NAAQS is Not Warranted

 W126 index lacks a strong biological basis, its relevance to biological responses in the real world is speculative.  

## Any protection provided by any W126 indication would not be nationally uniform.  

## Peer- reviewed research concluded W126 greatly overestimated the negative response to ozone and . . . the growing season 4 th 

## highest daily maximum 8 - hour average ozone concentration index had high statistical significance and a much greater association with biological endpoints. (Percy et. al. 2006) 

#  CASAC Feb 19 letter recommends ”EPA collect information and seek additional research that could be used to inform continued refinement of the [W126] 

# standard” ... W126 is not ready

12

# Conclusions for the Proposed Lower Ozone NAAQS

 New and existing health studies do not support EPA’s 

# conclusion that the ozone standard must be lowered  The benefits of a lower ozone NAAQS are questionable  

### the large majority of new and existing studies show no effects at current ozone levels  

### most of EPA’s health impacts in both their Risk and Exposure Assessment and 

### Regulatory Impact Assessment are estimated to occur at levels below the standard and down to EPA’s assumed PRB levels of 15 -35 ppb  

### since EPA has underestimated PRB, the health benefits of alternate standards are vastly over-stated, particularly at lower alternate NAAQS levels 

#  The ozone standard should not be changed until a full 

# review of the new science on health effects, background ozone levels and W126 limitations occurs as scheduled in 2013  Lots of technical and regulatory uncertainty with the 

# implementation leaving a substantial downside for the economy and jobs 13

# Background

14151617 

## EPA Data Show Lowest 10% Ozone Values Have Resisted Changed



## Despite Aggressive Control Program Year 10th Percentile 1980 0.069 1981 0.070 1982 0.069 1983 0.072 1984 0.071 1985 0.069 1986 0.070 1987 0.074 1988 0.077 1989 0.070 1990 0.070 1991 0.068 1992 0.068 1993 0.066 1994 0.069 1995 0.072 1996 0.071 1997 0.066 1998 0.071 1999 0.072 2000 0.067 2001 0.069 2002 0.069 2003 0.069 2004 0.064 2005 0.065 2006 0.064 2007 0,061 2008 0.064 http://www.epa.gov/airtrends/ozone.html 1980 to 2008 : ~10% decrease in 10th Percentile Values18 

## Average Levels of Ozone in the U.S. Continue to Decline

1819 

# Remote Area Nonattainment?

(Hanna et al, 2010)20 

## Model Evaluation Wide spread in individual models, but ensemble represents 

## observations quite well, However... GEOSChem 

## significantly under estimates observations Correlations are generally strongest in East & weaker in West 

## Models have large (+) biases in summer that are largest in the East

Reidmiller, AGU, 2008; in prep for JGR 

## (Fiore, 2009)21



## Effect of Elevation on Ozone Mass Exposure

 The form of the standard in ppm does not change with elevation  Are ozone health effects a function of ozone mass or ozone concentration?  

### In elevated terrain, the mass exposure to ozone is reduced 

##  Ozone health effects should be evaluated as a function of elevation and the form of the standard changed if appropriate 

## .  

### EPA has revised the reference conditions for the PM 10 

### standard (Stoeckenius, 2009)

# Underestimating PRB Results in a Significant Over- Estimation of Health Impacts

• Using a PRB only 5 ppb higher than base case resulted in a decrease in estimated 

### accidental acute mortality of >50% 1



### – e.g. Houston: decreased from 18 to 8 per 100,000 using Bell (2004)

– e.g L.A.: decreased from 24 to 9 per 100,000 using Bell (2004)

• Decrease of mortality of this magnitude (50%) is equal to EPA’s estimate for meeting the most stringent standard (64/4) versus the current standard (84/4) 2



### • Impact of alternate PRB on risk estimates is greater at lower alternate standards 1



### • The reason EPA’s estimates of hospital admissions were higher in their 2008 vs.1997 review was EPA used a PRB of 0.015 - 0.035 vs. 0.04 ppm , resp. 3



### • Conclusion: EPA must reassess PRB and correct their health impact estimates before a decision is made on the NAAQS 1EPA 2007 Policy Assessment Document for Ozone page 5 -82 and table 5C - 18 2EPA 2007 Policy Assessment Document for Ozone page 5 - 96 3EPA 2007 Policy Assessment Document for Ozone page 5 - 92 2223 

## References

23 Adams W. et al. (2006). Comparison of chamber 6.6 - h exposures to 0.04 - 0.08 ppm ozone via square -wave and triangular Profiles on pulmonary responses. Inhal. Toxicol . 8(2):127- 136. Cooper et al. (2010). Increasing springtime ozone mixing ratios in the free troposphere over western North America. Nature 463: 344 - 348. Delfino et al. (2002). Association of asthma symptoms with peak particulate air pollution and effect modification by Anti - inflammatory medication use. Env. Health Persp. 110(10:607- 617. Fiore et al. (2009). Multi - model estimates for intercontinental transport of ozone pollution in the northern hemisphere (and un certainties therein), presentation January 21, 2009, http://www.gfdl.noaa.gov/cms -filesystem - action/user_files/aff/presentation_ppts/fiore_gfdl_jan09. ppt HEI (2009). Air Pollution and Health: a European and North American Approach (APHENA). HEI Report 142. Kamps A. et al. (2001). Peak flow diaries in childhood asthma are unreliable. Thorax 56:180 - 182 Mortimer et al. (2002). The effect of air pollution on inner- city children with asthma. Eur. Resp. J. 19:699 - 705. O’Connor et al. (2008). Acute respiratory health effects of air pollution on children with asthma in U.S. inner cities. J. Allergy Clin. Immunol

. 12: 1133- 9 Schelegle et al. (2009). 6.6 Hour inhalation of ozone concentrations from 60 to 87 ppb in health humans. Am. J. Resp. Crit. Care Med. 164:505 - 517. Smith et al. (1999). Threshold dependence of mortality effects for fine and coarse particles in Phoenix, Arizona. J. Air Wa ste Management Association 50: 1467- 1379. Schildcdrout et al. (2006). Ambient air pollution and asthma in children: an eight city analysis. Am. J. Epi . 164(5): 505 - 17. Smith et al. (2009). Reassessing the relationship between ozone and short -term mortality in U.S. urban communities. Inhalation Toxicology 29:37- 61. Stoeckenius et al. (2010, 2010). Air quality modeling study for the four corners region and addendum. Environ Int. Corp Repo rt. August 2009 and January 2010. http://www.nmenv.state.nm.us/aqb/4c/Modeling.htlm. Stylinaou and Nicolich (2009). Cumulative effects and threshold levels in air pollution mortality: data analysis of nine larg e US cities using the NMMAPS dataset. Environmental Pollution 157:2216 -2223.