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Appendix G: Health Benefit Analysis October 21, 2010 

G-1 Final Staff Report with Appendices For 

Revised Proposed Amendments to Rule 4570 

APPENDIX G 

HEALTH BENEFIT ANALYSIS FOR 

REVISED PROPOSED AMENDMENTS TO 

RULE 4570 (CONFINED ANIMAL FACILITIES) 

(Abbreviated Version) 

October 21, 2010 
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Appendix G: Health Benefit Analysis October 21, 2010 

Health Benefit Analysis 

for the Confined Animal Facilities Rule 

David Lighthall, Ph.D. 

Health Science Advisor 

Contributors: 

SAN JOAQUIN VALLEY AIR POLLUTION CONTROL DISTRICT

October 21, 2010

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Appendix G: Health Benefit Analysis October 21, 2010 

Introduction 

Prior to 2004, state law precluded local air districts in California from permitting 

agricultural sources. With the enactment in 2003 of Senate Bill 700, however, this 

exemption was lifted on January 1, 2004. California air districts are required to adopt 

regulations to reduce ozone precursors from confined animal facilities (CAFs). The 

District adopted its first confined animal facility rule, Rule 4570, at a public hearing held 

on June 15, 2006. Prior to and during the rule adoption hearing, the District considered 

(1) the feasibility of the control measures contained in Rule 4570, (2) the economic 

impacts associated with the rule, (3) reductions in ozone pre-cursors that would result 

from compliance with the rule, and (4) the public health impacts of ozone and ozone 

precursors. As is normally the case under Clean Air Act (CCA) rulemaking, the District 

did not consolidate this information into a specific discussion of the rule’s impact on 

public health in 2006. However, because Rule 4570 was triggered by the enactment in 

2003 of Senate Bill 700 (codified under California Health and Safety Code section 

40724.6(e)), the California Fifth Appellate District ruled that rulemaking under this 

statute must explicitly consider the public health impacts of control measures on CAFs. 

These benefits were to be balanced against the economic impacts of the proposed rule 

and its feasibility. 

In response to this ruling, the District, in conjunction with a temporary suspension and 

readoption of Rule 4570, conducted a health benefit analysis of the 2007 Ozone Plan in 

2009 that included (1) the contribution of the CAF sector to ozone concentrations in the 

San Joaquin Valley, (2) Rule 4570’s contribution to regional ozone reductions in 2012 

and 2020, and (3) a quantification of cumulative health benefits in 2020 resulting from 

the 2007 Ozone Plan.

1

 The 2009 health benefit analysis quantified the distinct 

contribution to VOC reductions made by the original rule (4570 v1) as well as the 

additional reductions accruing from the current proposed amendment (4570 v2). 

This rule project is not subject to SB 700, [Florez, 2003] and an explicit analysis of 

health benefits from the proposed amendment is not required. The purpose of this rule 

project is to meet a control strategy commitment in the District’s 2007 Ozone Plan 

(Control Measure S-AGR-2). However, because of the relevance to the rule project of 

the previous health benefit analysis and the similarity in the VOC reductions estimated 

in the 2009 analysis to the reduction estimate from the proposed amendments of 31.8 

tons per day of VOC, an abbreviated reiteration of the health benefit analysis is helpful. 

Ozone Contribution from the CAF Source Category 

According to the emission inventory used in the 2007 Ozone Plan, confined animal 

facilities in 2005 contributed 57.6 tons per day, and the total VOC inventory for 2005 

was 398.6 tons per day. Thus, in 2005, confined animal facilities accounted for 14% of 

the total VOC emissions for the San Joaquin Valley. 

 

1

 This report contains considerably more background information and is available at: 

(http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2009/June/Agenda%20Item_10_J

une_18_2009.pdf

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Appendix G: Health Benefit Analysis October 21, 2010 

In order to estimate the impact of this sector’s VOC emissions on Valley ozone levels 

and, by extension, public health, the results of CARB’s 2012 and 2020 ozone modeling 

for the 2007 Ozone Plan was employed. Ozone models are based on experimentally 

simulated NOx and VOC reactions in a range of environmental conditions related to 

heat, sunlight energy, and air dispersion. From these modeled reactions, it is possible 

to make reasonable predictions about ozone concentrations under alternative scenarios 

involving different combinations of emission loads and weather conditions. Because 

ozone formation in the Valley takes place over a relatively large area in a given day, a 

key variable in this process involves a geographically accurate specification of NOx and 

VOC emission concentrations from various source categories. 

Table 1 summarizes the contribution that CAF emissions make by 2012 to ozone design 

values at all Valley monitoring sites, with a range of 1.6 to 2.8 ppb. While these 

concentrations appear small in absolute terms, they nonetheless make a considerable 

contribution to ozone design value exceedances beyond the 74 ppb standard. 

Impact of VOC Reductions from Rule 4570 on Ozone Concentrations 

and Public Health 

The health benefit analysis presented below was completed in May 2009 and was 

based on the following assumptions: 

1. According to the 2007 Ozone Plan, Rule 4570 v1 was estimated to achieve 

approximately 9 tons per day of VOC reductions by 2009, 20 tons per day by 

2012, and 24 tons per day by 2020. These values represent a significant portion 

of the District’s overall VOC control strategy. 

2. In addition, a second generation CAF control measure, Rule 4570 v2, was 

scheduled to reduce an additional 6.7 tons per day by 2012 and 21.5 tons per 

day by 2020. 

3. Rule 4570 (v1 and v2) comprised 63% of the VOC reductions that were included 

in the District’s 8-hour ozone attainment strategy (see also Figure 1). 

However, as detailed in Appendix B above, Rule 4570 v2 as currently proposed will 

achieve 27.6 tpd of VOC reductions by 2023. In addition, the proposed rule is 

scheduled to achieve approximately 22 tpd reductions by 2012, well ahead of the 

schedule anticipated in the 2007 Ozone Plan. As a result, the net VOC reductions 

anticipated under the proposed control measures are estimated to be proportionally 

higher, as are the corresponding reductions in ozone concentrations and concomitant 

health effects estimates. It is also important to note, however, that the net difference in 

VOC reductions between the two rule estimates is small in percentage terms, relative to 

(1) the overall VOC inventory, (2) the attenuated impact on ozone concentrations that 

result from Valley VOC reductions, and (3) the relative sensitivity of the ozone and 

BenMAP models employed in the analysis. In light of these potential sources of 

variability in the outcomes of any health benefit estimation using these tools and data 

sources, the outcome of the 2009 analysis is unlikely to significantly differ from one 

based on the 2010 estimate of VOC reductions. 

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Appendix G: Health Benefit Analysis October 21, 2010 

Using the 2012 CARB ozone model results, it is possible to estimate ozone reductions 

attributable to Rule 4570 (v1 and v2) in relation to other 2007 Ozone Plan control 

measures. The ozone reduction benefits from Rule 4570 are depicted in Figure 1 for 

Valley monitoring sites. As seen in Table 2, Rule 4570 (v1 and v2) also makes a 

noticeable contribution to the long-term ozone attainment goals for the region, 

culminating with a planned attainment date of 2023 for the 1997 ozone NAAQS. This 

relative contribution from the rule across Valley monitoring sites in 2012 ranges from 5% 

to 35%. To conclude, these modeling results underscore the relative importance of 

Rule 4570 to the District’s contribution to regional ozone reductions. 

Assessing the Health Benefits from the 2007 Ozone Plan

This section of the report presents the empirical results of the District’s 2009 estimation 

of the health benefits from its 2007 Ozone Plan. As discussed above, the Plan included 

Rule 4570 v1 and v2 as integral to its overall VOC controls. Many different source 

categories make a cumulative contribution to regional ozone concentrations, resulting in 

a comparable number of NOx and VOC control measures. As a result, there are 

inherent scientific limitations to accurately assess an individual rule’s contribution to 

ozone reductions. This is the case for Rule 4570 despite the fact that the rule makes a 

significant contribution to overall VOC reductions. For similar reasons, estimating the 

health benefits of a single ozone control measure would not be an appropriate 

application of the EPA’s BenMAP model for quantifying the health benefits of improved 

air quality. However, the model is well-suited for estimating the overall health benefits 

of the substantial ozone reductions contained in the 2007 Ozone Plan. 

BenMap Overview 

BenMAP is a sophisticated computer software model developed by the U.S. EPA that is 

well-suited for estimating the health benefits from the 2007 Ozone Plan.

2

 Over the 

course of the past decade, ongoing progress in the fields of epidemiology and 

geographic information systems (GIS) have resulted in the development of computer 

models that are capable of estimating the health benefits of improved air quality with 

reasonable accuracy when properly applied. These models estimate the number of 

avoided cases of certain diseases and other health impairment categories, known as 

health endpoints, which result from a specified reduction in exposure to criteria air 

pollutants, e.g. ozone and fine particulates (PM 2.5). This reduction could be the result 

of (1) an individual emission control rule with a substantial reduction in annual 

population exposure, or (2) a body of control rules that comprise the regional 

component of a state implementation plan. 

 

2

 See Abt Associates Inc. (2008) BenMAP Environmental Benefits Mapping and Analysis Program: User’s 

Manual. Prepared for the Office of Air Quality Planning and Standards, U.S. EPA, Research Triangle 

Park, NC (September). SJVAPCD Health Science Advisor, David Lighthall, Ph.D., has received BenMAP 

training from the Community Modeling and Analysis System in Chapel Hill, NC under contract to the U.S. 

EPA. See http://www.epa.gov/air/benmap/ for more information on BenMAP, downloading the program, 

and for technical documents. 

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Appendix G: Health Benefit Analysis October 21, 2010 

If BenMAP was used to estimate the health benefits of Rule 4570 alone, the results 

would be expressed in a relatively wide range around a mean with questionable 

statistical value. Health benefits, particularly at the low end of that estimation range, 

would appear relatively inconsequential. This outcome would not reflect the fact that (1) 

Rule 4570 makes a substantial contribution to overall VOC reductions in the 2007 

Ozone Plan and (2) VOC controls are an integral, essential component of the overall 

ozone control strategy. 

How BenMAP Works 

There are two central objectives in BenMAP analyses. First, the program estimates 

reductions in the incidence rates of health endpoints (i.e. avoided cases of disease, 

premature death, and/or impaired health) based on a specified improvement in ambient 

air quality for a target area and its population. The degree of improvement is based on 

statistical relationships between exposure to a given criteria pollutant and health that 

are derived from previously published epidemiological studies. The second objective 

involves assigning an economic value to those avoided cases of health problems, again 

based on previously published economic analyses of the health endpoints in question. 

A similar benefit estimation model, known as REHEX, was employed in the Hall et al. 

(2008) study that estimated the health and economic benefits of achieving federal 

ozone and PM 2.5 standards in the San Joaquin Valley and South Coast air basins.3

 

Key elements of the BenMAP analysis process include the following: First, BenMAP 

determines the change in ambient air quality as specified by the user. BenMAP does 

not include an air quality model. Instead, this data is either loaded in from external 

modeling sources or generated from a national set of air pollution monitoring data that is 

pre-loaded into BenMAP. The latter was used in this analysis. 

Next, BenMAP calculates the relationship between the reduction in air pollution (e.g. 

ozone or PM 2.5) and health endpoints. This entails the utilization of a concentrationresponse function based on prior epidemiological studies. These functions determine 

the relative health impact of each unit increase in pollution exposure. Users select from 

one or more prior health studies for each health endpoint in order to derive an 

appropriate concentration response function. 

In the final step, BenMAP estimates the incidence reduction for specified health 

endpoints for the target population, depending on the level of pollution reduction 

specified. 

 

3

 Hall, J., V. Brajer, and F. Lurmann. (2008) The Benefits of Meeting Federal Clean Air Standards in the 

South Coast and San Joaquin Valley Air Basins. California State University--Fullerton, Institute for 

Economic and Environmental Studies. See http://business.fullerton.edu/centers/iees/

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Appendix G: Health Benefit Analysis October 21, 2010 

A simplified example of estimating the health effect can be summarized as:4

Health Effect = Health Baseline Incidence X Air Quality Change X Health Effect 

Estimate X Exposed Population 

1. Health Baseline Incidence: The health incidence rate is an estimate of the 

average number of people that die or become ill over a given period of time and 

for a standard population unit that exists prior to any change in air quality, e.g. 

220 cases of asthma per 1,000 individuals per year. 

2. Air Quality Change: The air quality change is the difference between the starting 

air pollution level (i.e. the baseline), and the air pollution level after some change, 

such as a new regulation (i.e. the control). 

3. Health Effect Estimate: The health effect estimate is an estimate of the 

percentage change in adverse health effect due to a one unit change in ambient 

air pollution. Epidemiological studies provide the source for effect estimates in 

BenMAP. 

4. Exposed Population: The exposed population is the number of people affected 

by the air pollution reduction. 

Finally, BenMAP calculates the economic value of avoided health effects due to 

reduced ozone or PM 2.5 air pollution. To summarize: 

Economic Value = Health Effect X Value of Health Effect 

There are several ways to calculate the value of health effect changes. For example, 

the value of an avoided premature mortality is generally calculated using the Value of a 

Statistical Life (VSL). The VSL is an economic estimate of the social value of premature 

death that is used to guide policy makers in making public investments in public health 

or safety. VSL estimates range from $3.8 to $8.9 million per case.5

 VSL estimates are 

based on either contingent valuation surveys or wage risk studies.6 For other health 

endpoints, the medical costs of the illness may be the only valuation available. In other 

cases, prior research has provided survey-based generalizations about participants’ 

willingness to pay (WTP) for avoidance of health symptoms and/or diseases. These 

 

4

 See Abt Associates Inc. (2008) BenMAP Environmental Benefits Mapping and Analysis Program: User’s 

Manual. Prepared for Office of Air Quality Planning and Standards, U.S. EPA, Research Triangle Park, 

NC (September). Summary above taken from pp. 8-9. BenMAP Version 3.0.12 was used in this 

analysis. 

5

 For a further discussion of the VSL, see BenMAP Technical Appendices. Office of Air Quality Planning 

and Standards, U.S. EPA. Prepared by Abt Associates, Inc. September 2008. Available at: 

http://www.epa.gov/air/benmap/docs.html 

6

 Contingent valuation studies are based on surveys that ask how much individuals would be willing to 

pay to avoid a given health problem. Wage risk studies estimate the value of a single life by looking at 

the premium paid to workers in occupations that face an increased risk of occupational mortality. For 

example, a high rise steel worker accepts a 1 in 1,000 (0.001 probability) greater chance of occupational 

mortality in return for an annual wage premium of $5,000. The VSL in this situation is then based on 

multiplying that incremental risk to equal a probability of 1, i.e. 1,000 X $5,000 = $5,000,000. 

G - 8 Final Staff Report with Appendices For 

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Appendix G: Health Benefit Analysis October 21, 2010 

economic valuation functions for key health endpoints are contained within BenMAP 

and can also be imported for custom analyses. 

Results of the BenMAP Analysis 

Reduced Incidence 

The results of the BenMAP incidence analysis are presented in Table 3. As a result of 

the total control measures contained within the 2007 Ozone Plan, these figures 

represent the number of avoided cases of premature death or health trauma that would 

apply to the San Joaquin Valley county populations in the year 2020. 2020 was 

selected as the terminus of health benefits from the Plan because VOC controls from 

Rule 4570 were not anticipated beyond that year.7 As such, the model estimated the 

additional cases of premature death and health trauma that would occur in 2020 if Rule 

4570 and the other District control measures contained within the 2007 Ozone Plan

were not adopted. 

Values in each cell reflect (1) the amount of reduced ozone exposure specified in Table 

3; (2) the demographic characteristics of each county, particularly its population size; 

and (3) the concentration response function (or pooled functions) selected for each 

health endpoint category. These values are means representing the mid-point of a 

range of health endpoint cases. With the exception of Worker Productivity, the standard 

deviation for each county endpoint value is estimated by BenMAP and is presented 

below the mean totals in Table 3.8

 It is important to note the standard deviations. In 

several cases, these values are relatively large by statistical standards, reflecting the 

fact that the studies upon which the incidence reductions are based have a comparable 

level of uncertainty in estimating the health effects of ozone exposure. 

Valuation Results 

Valuation results for all health endpoint categories in each county are presented in 

Table 4. The total annual economic cost savings is $159,636,286 in 2006 dollars. A 

comparable analysis of the economic benefits of ozone attainment conducted by Hall et 

al. (2008) reported an annual value of $88,880,000 in 2007 dollars for the 2007 Valley 

population. In addition to the population increase between 2007 and 2020, one reason 

for the higher figure in this analysis is the higher annual mortality benefits in this study 

(21 cases vs. 9 in the Hall et al. estimate). Other health endpoint estimates are similar 

when scaled for population differences, although the terms used to describe the 

endpoints differ in some cases. 

Conclusion 

The health benefits for the population of the San Joaquin Valley associated with the 

reductions in ambient ozone exposure from the 2007 Ozone Plan are considerable. 

The proposed amendment to Rule 4570 is scheduled to achieve a modest increase in 

 

7

 As stated above, Rule 4570 v2 is now planned to achieve a maximum reduction of 27.6 tyd by 2023. 

8

 BenMAP does not provide a standard deviation for this health endpoint. 

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Appendix G: Health Benefit Analysis October 21, 2010 

G - 10 Final Staff Report with Appendices For 

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overall VOC emission reductions from the CAF sector relative to what was used in the 

2009 health benefit analysis reported above, and it will achieve those reductions at a 

more rapid pace. For these reasons, the health benefits that ultimately result from this 

amendment, if adopted, may be slightly higher than what was estimated in 2009. In 

conclusion, this abbreviated review of the 2009 health benefit analysis demonstrates 

that the reductions in VOC emissions resulting from Rule 4570 v1 and v2 make a critical 

contribution to the District’s overall strategy for meeting the ozone standards in the San 

Joaquin Valley. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix G: Health Benefit Analysis 

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Table 1. 2012 Modeling: Estimated Contribution of CAF Emissions to 2012 Ozone Concentratio

Confined Animal Facilities (CAF) Contribution to 8-hr Ozone 

Benefit of Removing all CAF Emissions

CAF contribution to 8-hr O

Site Modeled Modeled Ozone Design Value Ozone Change 

(ppb) 

Percent De

Chan

Turlock 91 2.2 2.4Merced 95 2.0 2.1Madera 87 1.5 1.8Fresno-Sierra Sky Park 107 2.8 2.7Fresno-First St 99 2.6 2.6Clovis 97 2.6 2.7Parlier 103 2.8 2.8Visalia 91 1.8 1.9Hanford 90 1.8 1.9Shafter 89 1.3 1.5Oildale 96 2.6 2.7Bakersfield-California Ave 96 2.4 2.5Bakersfield-Golden State Ave 93 2.2 2.3Maricopa 94 1.5 1.6Edison 98 2.2 2.2Arvin 109 2.4 2.2This evaluation was performed using modeling completed for the 2007 Ozone Plan based on 2012 emission targets
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix G: Health Benefit Analysis 

G - 12 Final Staff Repo

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Figure 1. Contribution from Rule 4570 (v1 and v2) to Ozone Reductions from the 2007 Ozone P

2012 8-hr Ozone Improvement from the 2007 Ozone Plan

0.00.20.40.60.81.01.21.41.61.82.0

Turlock

Merced

Madera

Fresno

Clovis

Parlier

Visalia

Hanford

Shafter

Oildale

Bakersfield

Maricopa

Ozone Improvement (ppb)

Rule 4570 v1 Rule 4570 v2 Other 2007 Ozone Plan St
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix G: Health Benefit Analysis 

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Table 2. Contribution of Rule 4570 (v1 and v2) in 2012 to Regional Attainment of the 1997 Ozon

Contribution to 8-hr Ozone Attainm

Rule 4570 v1 and v2 2007 Ozone Plan Stra

Site Modeled 

Modeled 

Ozone 

Design 

Value Ozone Change 

(ppb) 

Percent Closer to 

Attainment 

Ozone Change 

(ppb) 

Turlock 91 0.8 14.6% 0.6 

Merced 95 0.8 7.6% 0.7 Madera 87 0.6 34.5% 0.7 

Fresno-Sierra Sky Park 107 1.1 5.0% 0.8 

Fresno-First St 99 1.0 7.1% 0.7 

Clovis 97 1.0 8.2% 0.7 

Parlier 103 1.1 6.2% 0.8 

Visalia 91 0.7 11.6% 0.7 

Hanford 90 0.7 14.0% 0.7 

Shafter 89 0.5 12.0% 0.6 

Oildale 96 1.0 8.9% 0.4 

Bakersfield-California Ave 96 0.9 8.5% 0.6 

Bakersfield-Golden State Ave 93 0.8 10.0% 0.5 

Maricopa 94 0.6 6.8% 0.7 

Edison 98 0.8 6.3% 0.5 

Arvin 109 0.9 3.9% 0.6 

This evaluation was performed using modeling completed for the 2007 Ozone Plan based on 2012 emission targets. Final ozone attainment for the region is estimated to occur in 2023 based on CARB modeling. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix G: Health Benefit Analysis 

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Table 3. Avoided Cases of Premature Death and Health Trauma in 2020 

Mean 

Totals Fresno Kern Kings Madera Merced 

San 

Joaquin 

Mortality 21 6 61 1 1 3 Respiratory Emergency Room Visits 78 20 22

3 2 

3

8

Respiratory Hospital Admissions 286 75 76

8 9 11 32 

School Loss Days 79,532 20,194 22,051 2,301 2,241 3,193 8,661 Acute Respiratory Symptoms 91,402 23,613 25,867 3,109 2,705 3,480 9,651 Worker Productivity 11,828,748 1,887,918 4,818,409 151,810 258,283 586,901 107,985 

Standard 

Deviation 

Mortality 2 20 0 0 1 Respiratory Emergency Room Visits 6 71 1 1 3 Respiratory Hospital Admissions 23 23

3 3 

3 10

School Loss Days 10,599 11,546 1,213 1,182 1,686 4,565 Acute Respiratory Symptoms 6,582 7,202 868 756 972 2,695 Worker Productivity NA NA NA NA NA NA 
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Table 4. 2020 Estimated Economic Value of Avoided Cases of Premature Death and Health Tra

Mean Totals Fresno Kern Kings Madera Merced San Joaquin 

Mortality $132,737,821 $34,347,752 $35,678,672 $3,442,470 $3,442,470 $5,144,200 $16,179,052 Respiratory ER Visits $20,240 $5,215 $5,689 $586 $586 $798 $2,159 Respiratory Hospital Admissions $4,489,142 $1,172,315 $1,199,208 $139,995 $139,995 $172,402 $498,364 School Loss Days $5,960,435 $1,514,521 $1,653,807 $168,065 $168,065 $239,443 $649,562 Acute Respiratory Symptoms $4,599,900 $1,193,650 $1,307,585 $136,725 $136,725 $175,911 $487,836 Worker Productivity $11,828,748 $1,887,918 $4,818,409 $151,810 $258,283 $586,901 $107,985 

$159,636,286 

Standard 

Deviation 

Mortality $26,481,582 $27,506,864 $2,654,342 $2,654,342 $3,966,557 $12,474,714 Respiratory ER Visits $1,622 $1,767 $183 $183 $249 $673 Respiratory Hospital Admissions $360,096 $363,451 $43,27

6 $43,276 $52,548 $152,490 

School Loss Days $794,929 $865,914 $88,654 $88,654 $126,424 $342,401 Acute Respiratory Symptoms $445,659 $487,890 $51,108 $51,108 $65,767 $182,320 Worker Productivity NA NA NA NA NA NA 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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