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- 1 EXECUTIVE SUMMARY
Overview In setting primary national ambient air quality standards (NAAQS), the EPA’s responsibility under the law is to establish standards that protect public health. The Clean Air Act (the Act) requires the EPA, for each criteria pollutant, to set a standard tha t protects public health with “an adequate margin of safety.” As interpreted by the Agency and the courts, the Act requires the EPA to base this decision on health considerations only; economic factors cannot be considered. The prohibition against conside ring cost in the setting of the primary air quality standards does not mean that costs, benefits or other economic considerations are unimportant. The Agency believes that consideration of costs and benefits is an essential decision

- making tool for the eff icient implementation of these standards. The impacts of costs, benefits, and efficiency are considered by the States when they make decisions regarding what timelines, strategies, and policies are appropriate for their circumstances.
The EPA is proposing to revise the level of the ozone NAAQS to within a range of 65 ppb to 70 ppb and is soliciting comment on alternative standard levels below 65 ppb, as low as 60 ppb. T he EPA is also proposing to revise the level of the secondary standard to within the

ran ge proposed for the primary standard of 65 ppb to 70 ppb to provide increased protection against vegetation

- related effects on public welfare. 1 The EPA performed an illustrative analysis of the potential costs, human health benefits, and welfare co

- benefi ts of nationally attaining primary alternative ozone standard levels and did not estimate any incremental costs and benefits associated with attaining a revised secondary standard. Per Executive Order 12866 and the guidelines of OMB Circular A

- 4, this Reg ulatory Impact Analysis (RIA) presents the analyses of the following alternative standard levels

-- 70 ppb, 65 ppb, and 60 ppb. The cost and benefit estimates below are calculated incremental to a 2025 baseline that incorporates air quality improvements a chieved through the projected implementation of existing regulations and full

1 As an initial matter, the EPA is proposing that ambient ozone concentrations in terms of a three

- year average W126 index value within the range from 13 parts per million

- hours (ppm

- hours) to 17 ppm

- hours would provide the requisite protection against know n or anticipated adverse effects to the public welfare, which data analyses indicate would provide air quality in terms of three

- year average W126 index values of a range at or below 13 ppm

- hours to 17 ppm

- hours. Data analyses also indicate that actions t aken to attain a standard in the range of 65 ppb to 70 ppb would also improve air quality as measured by the W126 metric.***E.O. 12866 Review

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- 2 attainment of the existing ozone NAAQS (75 ppb). The 2025 baseline reflects, among other existing regulations, the Mercury and Air Toxics Standard, the Clean Air Interstate Rule , the Tier 3 Motor Vehicle Emission and Fuel Standards, and adjustments for the Clean Power Plan, all of which will help many areas move toward attainment of the existing ozone standard (see Chapter 3, Section 3.1.3 for additional information).

In this R IA w e present the primary costs and benefits estimates for 2025. We assume that potential nonattainment areas everywhere in the U.S., excluding California, will be designated such that they are required to reach attainment by 2025, and we developed our pr ojected baselines for emissions, air quality, and populations for 2025.
The EPA will likely finalize designations for a revised ozone NAAQS in late 2017. Depending on the precise timing of the effective date of those designations, nonattainment areas cl assified as Marginal will likely have to attain in either late 2020 or early 2021. Nonattainment areas classified as Moderate will likely have to attain in either late 2023 or early 2024. If a Moderate nonattainment area qualifies for two 1

- year extensio ns, the area may have as late as 2026 to attain. Lastly, Serious nonattainment areas will likely have to attain in late 2026 or early 2027. We selected 2025 as the primary year of analysis because most areas of the U.S. will likely be required to meet a revised ozone standard by 2025 and because it provided a good representation of the remaining air quality concerns that Moderate nonattainment areas would face; states with areas classified as Moderate and higher are required to develop attainment demonstr ation plans for those nonattainment areas.
In estimating the incremental costs and benefits of potential alternative standards, we recognize that there are several areas that are not required to meet the existing ozone standard by 2025. The Clean Air Act allows areas with more significant air quality problems to take additional time to reach the existing standard. Several areas in California are not required to meet the existing standard by 2025 and may not be required to meet a revised standard until

som etime between 2032 and 2038. 2 We were not able to project emissions and air quality

2 The EPA will likely finalize designations for a revised ozone NAAQS in late 2017. Depending on the precise timing of the effective date of those designations, nonattainment areas classified as Severe 15 will likely have to***E.O. 12866 Review

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- 3 beyond 2025 for California, however, we adjusted baseline air quality to reflect mobile source emissions reductions for California that would occur between 2025 and 2030; these emissions reductions were the result of mobile source regulations expected to be fully implemented by 2030. W hile there is uncertainty about the precise timing of e missions reductions and related costs for California , we assume costs occur through 2 038. In addition, we model benefits for California using projected population demographics for 2038.
Because of the different timing for incurring costs and accruing benefits and f or ease of discussion throughout the analyses , we refer to the different time periods for potential attainment as 2025 and post

- 2025 to reflect that (1) we did not project emissions and air quality for any year other than 2025; (2) for California, emissions controls and associated costs are assumed to occur through 2038; and ( 3) for California benefits are modeled using population demographics in 2038

. I t is not straightforward to discount the post

- 2025 results for C alifornia to compare with or add to the 2025 results for the rest of the U.S. W hile we estimate benefits using 2038 information, we do not have good information on precisely when the costs of control s will be incurred

. Because of these differences in timing related to Ca lifornia attaining a revised standard, the supplemental costs and benefits estimates for post

- 2 025 should not be added to the primary estimates for 2025.

ES.1 Overview of Analytical Approach This RIA consists of multiple analyses including an assessment of the nature and sources of ambient ozone (Chapter 2

– Defining the Air Quality Problem); estimates of current and future emissions of relevant precursors that contribute to the problem; air q uality analyses of baseline and alternative control strategies (Chapter 3

– Air Quality Modeling and Analysis); development of illustrative control strategies to attain the primary alternative standard levels (Chapter 4

– Control Strategies and Emissions R eductions); estimates of the incremental benefits of attaining the primary alternative standard levels ( Chapter 5

– Human Health Benefits ) ; a qualitative discussion of the welfare co

- benefits of attaining the primary alternative standard levels (Chapter 6

– Welfare Co

- Benefits of the Primary Standard); estimates of the incremental
attain sometime between late 2032 and early 2033 and nonattainment areas classified as Extreme will likely have to attain sometime between late 2037 and early 2038

.***E.O. 12866 Review

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- 4 costs of attaining the primary alternative standard levels ( Chapter 7

– Engineering Cost Analysis and Economic Impacts ); a comparison and discussion of the benefits and costs (Cha pter 8

– Comparison of Costs and Benefits); an analysis of the impacts of the relevant statutory and executive orders (Chapter 9

– Statutory and Executive Order Impact Analysis); and a discussion of the theoretical framework used to analyze regulation

- indu ced employment impacts, as well as information on employment related to installation of NOx controls on coal and gas

- fired electric generating units, industrial boilers, and cement kilns (Chapter 10

– Qualitative Discussion of Employment Impacts of Air Qua lity).
Because States are ultimately responsible for implementing strategies to meet revised standards, this RIA provides insights and analysis of a limited number of illustrative control strategies that states might adopt to meet a revised standard. The goal of this RIA is to provide estimates of the costs and benefits of the illustrative attainment strateg ies to the meet each alternative standard level. The flowchart below (Figure ES

- 1) outlines the analytical steps taken to illustrate attainment with th e potential alternative standard levels, and the following d iscussion, by primary flowchart section, describes the steps taken.***E.O. 12866 Review

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- 5 Figure ES
- 1. Analytical Flowchart for Primary Standards Analyses
ES.1.1 Establishing the Baseline The future year base case reflects emissions projected from 2011 to 2025 and incorporates current state and federal programs, including the Tier 3 Motor Vehicle Emission and Fuel Standards (U.S. EPA, 2014a) (see Chapter 3, Section 3.1.3 for a discussion of the rules included in the base case). The base case does not include control programs specifically for the purpose of attaining the existing ozone standard (75 ppb). The baseline builds on the future year base case and reflects the additional emissions reductions needed to reach attainment of the current ozone standard (75 ppb) , as well as adjustments for the Clean Power Plan (U.S. EPA, 2014b).
We p erformed a national scale air quality modeling analysis to estimate ozone concentrations for the future base case year of 2025. To accomplish this, we modeled multiple***E.O. 12866 Review

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- 6 emissions cases for 2025, including the 2025 base case and twelve 2025 emissions sensitivity simulations. The twelve emissions sensitivity simulations were used to develop ozone sensitivity factors (p pb/ton) from the modeled response of ozone to changes in NOx and VOC emissions from various sources and locations. These ozone sensitivity factors were then used to determine the amount of emissions reductions needed to reach the 2025 baseline and evaluate potential alternative standard levels of 70, 65, and 6 0 ppb incremental to the baseline. We used the estimated emissions reductions needed to reach each of these standard levels to analyze the costs and benefits of alternative standard levels.

ES.1.2 C ontrol Strategies and Emissions Reductions The EPA analyzed illustrative control strategies that areas across the U.S. might employ to attain alternative revised primary ozone standard levels of 70, 65, and 60 ppb. The EPA analyzed the impact that addition al emissions control technologies and measures, across numerous sectors, would have on predicted ambient ozone concentrations incremental to the baseline. These control measures, also referred to as known controls, are based on information available at th e time of this analysis and include primarily end

- of

- pipe control technologies. In addition, to attain some of the alternative primary standard levels analyzed, some areas needed additional emissions reductions beyond the known controls, and we refer to t hese as unknown controls (see Chapter 7, Section 7.2 for additional information).
Using average ozone response factors, we estimated the portion of the emissions reductions required to meet the baseline, including any additional emissions reductions beyond known controls. We then estimated the emissions reductions incremental to the ba seline that were needed to meet the alternative standard levels of 7 0, 65, and 6 0 ppb. Costs of controls incremental to (i.e., over and above) the baseline emissions reductions are attributed to the costs of meeting the alternative standard levels. These e missions reductions can come from both specific known controls , as well as unknown controls. The baseline shows that by 2025, while ozone air quality would be significantly better than today under current requirements, depending on the alternative standar d level analyzed, several areas in the Eastern, Central, and Western U.S. would need to develop and adopt additional controls to attain alternative standard levels (see Chapter 4, Section 4.3).***E.O. 12866 Review

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- 7 ES.1.2.1 Emissions Reductions from Known Controls in 2025
Fi gure ES

- 2 shows the counties projected to exceed the alternative standard levels analyzed for 2025 for areas other than California. For the 70 ppb alternative standard level, emissions reductions were required for monitors in the Central and Northeast reg ions. For the 65 and 60 ppb alternative standard levels, emissions reductions were applied in all regions with projected baseline design values (DVs) above these levels. 3 For the 60 ppb alternative standard level, additional VOC emissions reductions were i dentified in Chicago because some sites in that area experienced NO x disbenefits, meaning that the regional NO x emissions reductions resulted in ozone increases from below 60 ppb to above 60 ppb. Table s ES

- 1 through ES

- 3 show the emission s reductions from known controls for th e alternative standard levels analyzed.

Figure ES
- 2. Projected Ozone Design Values in the 2025 Baseline Scenario

3 A design value is a statistic that describes the air quality status of a given area relative to the level of the NAAQS. Design values are typically used to classify nonattainment areas, assess progress toward meeting the NAAQS, and develop control s trategies.***E.O. 12866 Review

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- 8 Table ES
- 1
. Summary of Emission Reductions by Sector for Known Controls for 70 ppb

Proposed Alternative Standard Leve l for 2025, except California (1,000 tons/year) a Geographic Area Emissions Sector NO x VOC

East EGU 25

- Non

- EGU Point 210 0.98 Nonpoint 260 54 Nonroad 5

- Total 490 55

West EGU

- - Non

- EGU Point

- - Nonpoint

- - Nonroad

- - Total
- -

a Estimates are rounded to two significant figures. Table ES
- 2
. Summary of Emission Reductions by Sector for Known Controls for 65 ppb

Proposed Alternative Standard Level for 2025
- except California (1,000 tons/year) a Geographic Area Emissions Sector NO x VOC

East EGU 170

- Non

- EGU Point 410 3.6 Nonpoint 420 95 Nonroad 12

- Total 1,000 99

West EGU 36

- Non

- EGU Point 38 0.47 Nonpoint 37 6.6 Nonroad 1.3

- Total 110 7

a Estimates are rounded to two significant figures. Table ES
- 3
. Summary of Emission Reductions by Sector for Known Controls for 60 ppb

Alternative Standard Level for 2025
- except California (1,000 tons/year) a Geographic Area Emissions Sector NO x VOC

East EGU 170

-

Non

- EGU Point 410 4.2 Nonpoint 420 99 Nonroad 12

- Total 1,000 100

West EGU 62

-

Non

- EGU Point 48 0.47 Nonpoint 39 6.6 Nonroad 1.3

- Total 150 7

a Estimates are rounded to two significant figures.***E.O. 12866 Review

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- 9 ES

. 1 .2 .2 Emissions Reductions beyond Known Controls in 2025
There were several areas where known controls did not achieve enough emissions reductions to attain the proposed alternative standard levels of 70 and 65 as well as the more stringent alternative standard level of 60 ppb. To complete the analysis, the EPA then estimated the additional e missions reductions beyond known controls needed to reach attainment (i.e., unknown controls). Table ES

- 4 shows the emissions reductions needed from unknown controls in 2025 for the U.S., except California, for the alternative standard levels analyzed.

Table ES
- 4
. Summary of Emission s Reductions by Alternative Standard for Unknown

Controls for 2025
- except California (1,000 tons/year) a

Region NO x VOC Proposed Alternative Standard Levels 70 ppb East West 150

- -

- 65 ppb East West 750

- -

- Alternative Standard Level 60 ppb East West 1,900 350 41

-

ES.1.2.3 Emissions Reductions beyond Known Controls for Post

- 2025 Figure ES

- 3 shows the counties projected to exceed the alternative standard levels analyzed for the post

- 2025 analysis for California. For the California post

- 2025 alternative standard level analyses, all known controls were applied in the baseline, so inc remental emissions reductions are from unknown controls. Table ES

- 5 shows the emissions reductions needed from unknown controls for post

- 2025 for California for the alternative standard levels analyzed.***E.O. 12866 Review

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- 10 Figure ES
- 3. Projected Ozone Design Values in the p ost - 2025 Baseline Scenario
Table ES
- 5
. Summary of Emissions Reductions by Alternative Standard Level for

Unknown Controls for post - 2025
- California (1,000 tons/year) a

Region NO x VOC Proposed Alternative Standard Levels 70 ppb CA 53
- 65 ppb CA 110
- Alternative Standard Level 60 ppb CA 140

-

a Estimates are rounded to two significant figures.
ES.1.3 Human Health Benefits To estimate benefits, w e follow a “damage

- function” approach in calculating total benefits of the modeled changes in environmental quality. This approach estimates changes in individual health endpoints (specific effects that can be associated with changes in air quality) and a ssigns values to those changes assuming independence of the values for those individual endpoints. Total benefits are calculated as the sum of the values for all non

- overlapping health endpoints. The “damage

- function” approach is the standard method for as sessing costs and benefits of environmental quality programs and has been used in several recent published analyses (Levy et al., 2009; Fann et al., 2012a; Tagaris et al., 2009).***E.O. 12866 Review

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- 11 To assess economic values in a damage

- function framework, the changes in envi ronmental quality must be translated into effects on people or on the things that people value. In some cases, the changes in environmental quality can be directly valued, as is the case for changes in visibility. In other cases, such as for changes in ozo ne and PM, an impact analysis must first be conducted to convert air quality changes into effects that can be assigned dollar values. For the purposes of this RIA, the health impacts analysis is limited to those health effects that are directly linked to a mbient levels of air pollution and specifically to those linked to ozone and PM 2.5 .
Benefits estimates for ozone were generated using the damage function approach outlined above wherein potential changes in ambient ozone levels (associated with future atta inment of alternative standard levels) were explicitly modeled and then translated into reductions in the incidence of specific health endpoints. In generating ozone benefits estimates for the two attainment timeframes considered in the RIA (2025 and post

- 2025), we used three distinct benefits simulations including one completed for 2025 and two completed for 2038. The way in which these three benefits simulations were used to generate estimates for the two time frames is de tailed in Chapter 5, S ection 5.4.3

. In contrast to ozone, we used a benefit

- per
- ton approach in modeling PM 2.5 co
- benefits. With this approach, we u s e the results of previous benefits analysis simulations focusing on PM 2.5 to derive benefits

- per
- ton estimates for NOx. 4 We then combine the se dollar

- per
- ton estimates with projected reductions in NOx associated with meeting a given alternative standard level to project cobenefits associated with PM 2.5 . We acknowledge increased uncertainty associated with the dollar

- per
- ton approach for PM 2.5, relative to explicitly modeling benefits using gridded PM 2.5 surfaces specific to the baseline and alternative standard levels (see Appendix 5A, Table 5A

- 1 for additional discussion).

In addition to ozone and PM 2.5 benefits, implementing emissions contro ls to reach some of the alternative ozone standard level s would reduce other ambient pollutants. However, because the method s used in this analysis to simulate attainment do not account for changes in ambient

4 In addition to dollar

- per
- ton estimates for NOx, we also used incidence

- per
- ton values (also for NOx) for specific health endpoints to generate incidence reduction estimates associated with the dollar benefits.***E.O. 12866 Review

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- 12 concentrations of other pollutants, we were not able to quantify the co

- benefits of reduced exposure to these pollutants. In addition, due to data and methodology limitations, we were unable to estimate some anticipated health benefits associated with exposure to ozone and PM 2.5 .
ES.1.4 Welfare Co

- Bene

fits of the Primary Standard
Section 109 of t he Clean Air Act defines welfare effects to include any non

- health effects, including direct economic damages in the form of lost productivity of crops and trees, indirect damages through alteration of ecosystem functions, indirect economic damages through the loss in value of recreational experiences or the existence value of important resources, and direct damages to property, either through impacts on material struc tures or by soiling of surfaces ( 42 U.S.C. 74 09 )

. Ozone can affect ecological systems, leading to changes in the ecological

commu nity and influencing the diversity, health, and vigor of individual species (U.S. EPA, 2013). Ozone causes discernible injury to a wide array of vegetation (U.S. EPA, 201 3). In terms of forest productivity and ecosystem diversity, ozone may be the pollutant with the greatest potential for region

- scale forest impacts (U.S. EPA, 2013). Studies have demonstrated repeatedly that ozone concentrations observed in polluted areas can have substantial impacts on plant function (De Steiguer et al,. 1990; Pye, 1988).
In this RIA, we are able to quantify only a small portion of the welfare impacts associated with reductions in ozone concentrations to meet alternative ozone standards. Using a model of commercial agriculture and forest markets, we are able to analyze the effects on consumers and producers of forest and agricultural products of changes in the W126 index resulting from meeting alternative standards within the proposed rang e of 70 to 65 ppb, as well as a lower standard level of 60 ppb. We also assess the effects of those changes in commercial agricultural and forest yields on carbon sequestration and storage. This analysis provides limited quantitative information on the w elfare co
- benefits of meeting these alternative standards, focused only on one subset of ecosystem services. Commercial and non

- commercial forests provide a number of additional services, including medicinal uses, non

- commercial food and fiber production, arts and crafts uses, habitat, recreational uses, and cultural uses for Native American tribes. A more complete discussion of these additional ecosystem services is provided in the final Welfare Risk and Exposure Assessment for Ozone (U.S. EPA, 2014 c ).***E.O. 12866 Review

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- 13 ES.2 Results of Benefit
- Cost Analysis
Below in Table ES

- 6, we present the primary costs and benefits estimates for 2025 for all areas except California

. We anticipate that benefits and costs will likely begin occurring earlier, as states begin implementin g control measures to show progress towards attainment. In these tables, ranges within the total benefits rows reflect variability in the studies upon which the estimates associated with premature mortality were derived. PM 2.5 co
- benefits account for app roximately two

- thirds to three

- quarters of the estimated benefits, depending on the standard analyzed and on the choice of ozone and PM mortality functions used. In addition for 2025, Table ES

- 7 presents the numbers of premature deaths avoided for the alt ernative standard levels analyzed, as well as the other health effects avoided.
Table ES
- 6. Total Annual Costs a and Benefits b for U.S., except California in 2025

(billions of 2011$, 7% Discount Rate) Proposed Alternative Standard Levels Alternative S tandard Level 70 ppb 65 ppb 60 ppb Total Costs (7%) $3.9 $15 $39 Health Benefits (3%) c $6.9 to $14.0 $20 to $41 $37 to $75 Health Benefits (7%) $6.4 to $13.0 $19 to $38 $34 to $70 Net Benefits (3%) $3.0 to $10.1 $5 to $26 ($2) to $36 Net Benefits (7%) $2.5 to $9.1 $4 to $23 ($5) to $31

a Engineering costs reflect 7% discount rate. We do not have a comprehensive data set to be able to calculate engineering costs at a 3% discount rate. b Benefits are nationwide benefits of attainment everywhere except California.

c The benefits range reflects the LOW and UPPER core estimates of short

- term ozone and long

- term PM mortality. Table ES
- 7. Summary of Total Number of Annual Ozone and PM
- Related Premature

Mortalities and Premature Morbidity: 2025 National Benefits a Proposed Alternative Standard Levels Alternative Standard Level 70 ppb 65 ppb 60 ppb Short
- term exposure - related premature deaths avoided (all ages) (Ozone

– 2 studies) 200 to 340 630 to 1,000 1,100 to 1,900 Long
- term exposure - related premature deaths avoided (age 30+) (PM

– 2 studies) O 3 : 680 PM 2.5 : 510 to 1,100 O 3 : 2,100 PM 2.5 : 1,400 to 3,300 O 3 : 3,900 PM 2.5 : 2,600 to 6,000 Other health effects avoided Non

- fatal heart attacks (age 18

- 99) (5 studies) PM 64 to 600 180 to 1,700 330 to 3,100 Respiratory hospital admissions (age 0

- 99) O3, PM 510 1,600 2,900 Cardiovascular hospital admissions (age 18

- 99) PM 180 530 950 Asthma emergency department visits 1,400 4,300 8,000***E.O. 12866 Review

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- 14 Proposed Alternative Standard Levels Alternative Standard Level 70 ppb 65 ppb 60 ppb (age 0

- 18) O3, PM Acute bronchitis (age 8

- 12) PM 790 2,300 4,100 Asthma exacerbation (age 6

- 18) O3, PM 320,000 970,000 1,800,000 Lost work days (age 18

- 65) PM 65,000 180,000 340,000 Minor restricted activity days (age 18

- 65) O3, PM 1,300,000 3,900,000 7,300,000 Upper & lower respiratory symptoms (children) PM 25,000 70,000 130,000 School loss days O3 330,000 1,000,000 1,900,000

a Nationwide benefits of attainment everywhere except California. T o understand possible additional costs and benefits of fully attaining in California in a post

- 2025 timeframe , we provide supplemental results for California in Table ES

- 8. Relative to the primary cost and benefits estimates, the California cost estimates are between 5 and 20 percent and the benefits estimates are between 8 and 15 percent of the national estimates. B ecause of the differences in the timing of achieving needed emissions reductions, incurring costs, and accruing benefits for California, the supplemental costs and benefits estimates for post

- 2025 should not be added to the primary estimates for 2025. For the post

- 2025 timeframe , Table ES

- 9 presents the numbers of premature deaths avoided for the alternative standard levels analyzed, as well a s the other health effects avoided.
The EPA presents separate and supplemental costs and benefits results for California because forcing attainment in an earlier year than would be required under the Clean Air Act would likely lead to an overstatement of costs because California might benefit from some existing federal or state programs that would be implemented between 2025 and the ultimate attainment years; because additional new technologies may become available between 2025 and the attainment years; an d because the cost of existing technologies might fall over time. As such, we use the best available data to estimate costs and benefits for California in a post

- 2025 timeframe, but because of data limitations and additional uncertainty associated with no t projecting emissions and air quality beyond 2025, we recognize that the estimates of costs and benefits for California in a post

- 2025 timeframe are likely to be relatively more uncertain than the national attainment estimates for 2025.***E.O. 12866 Review

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- 15 Table ES
- 8. Tota l Annual Costs a and Benefits b for California, post
- 2025 (billions of

2011$, 7% Discount Rate) Proposed Alternative Standard Levels Alternative Standard Level 70 ppb 65 ppb 60 ppb Total Costs (7%) $0.80 $1.6 $2.2 Health Benefits (3%) c $1.1 to $2 $2.3 to $4.2 $3.4 to $6.2 Health Benefits (7%) $1.1 to $2 $2.2 to $4.1 $3.2 to $5.9 Net Benefits (3%) $0.3 to $1.2 $0.70 to $2.6 $1.2 to $4 Net Benefits (7%) $0.3 to $1.2 $0.60 to $2.5 $1 to $3.7

a Engineering costs reflect 7% discount rate. We do not have a comprehensive data set to be able to calculate engineering costs at a 3% discount rate. b Benefits are nationwide benefits of attainment in California.

c The benefits range reflects the LOW and UPPER core estimates of short

- term ozone and long

- term PM mortality. Table ES
- 9. Summary of Total Number of Annual Ozone and PM
- Related Premature

Mortalities and Premature Morbidity: Post
- 2025 a Proposed Alternat ive Standard Levels Alternative Standard Level 70 ppb 65 ppb 60 ppb Short
- term exposure - related premature deaths avoided (all ages) (Ozone

– 2 studies) 65 to 110 140 to 230 210 to 350 Long
- term exposure - related premature deaths avoided (age 30+) (PM

– 2 studies) O 3 : 260 PM 2.5 : 45 to 100 O 3 : 560 PM 2.5 : 89 to 200 O 3 : 840 PM 2.5 : 120 to 280 Other health effects avoided Non

- fatal heart attacks (age 18

- 99) (5 studies) PM 6 to 54 11 to 110 16 to 140 Respiratory hospital admissions (age 0

- 99) O3, PM 130 280 430 Cardiovascular hospital admissions (age 18

- 99) PM 16 32 45 Asthma emergency department visits (age 0

- 18) O3, PM 340 730 1,100 Acute bronchitis (age 8

- 12) PM 67 130 180 Asthma exacerbation (age 6

- 18) O3, PM 99,000 210,000 320,000 Lost work days (age 18

- 65) PM 5,500 11,000 15,000 Minor restricted activity days (age 18

- 65) O3, PM 320,000 690,000 1,000,000 Upper & lower respiratory symptoms (children) PM 2,100 4,100 5,600 School loss days O3 110,000 230,000 350,000

a Nationwide benefits of attainment in California.
Despite uncertainties inherent in any complex, quantitative analysis, the overall underlying analytical methods used in this RIA have been peer

- reviewed . For a detailed discussion on uncertainty associat ed with developing illustrative control strategies to attain the alternative***E.O. 12866 Review

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- 16 standard levels, see Chapter 4, Section 4.4. For a description of the key assumptions and uncertainties related to the modeling of ozone benefits, see Chapter 5, Section 5.7.3, a nd for an additional qualitative discussion of sources of uncertainty associated with both the modeling of

ozone
- related benefits and PM 2.5 - related co

- benefits, see Appendix 5A. For a discussion of the limitations and uncertainties in the engineering cost analyses, see Chapter 7, Section 7.7. For a discussion about generally framing uncertainty, see Chapter 8, Section 8.3.

ES.4 References De Steiguer, J., Pye, J., Love, C. 1990. Air Pollution Damage to U.S. Forests. Journal of Forestry, 88(8), 17

- 22. Fann N, Lamson A, Wesson K, Risley D, Anenberg SC, Hubbell BJ. 2012a. “Estimating the National Public Health Burden Associated with Exposure to Ambient PM 2.5 and ozone. Risk Analysis,” Risk Analysis 32(1): 81

- 95. Levy JI, Baxter LK, Schwartz J. 2009. “ Uncertainty and variability in health

- related damages from coal

- fired power plants in the United States .” Risk Analysis 29(7) 1000

- 1014. Pye, J.M. 1988. Impact of ozone on the growth and yield of trees: A review. Journal of Environmental Quality, 17, 347

- 360. Tagaris E, Liao KJ, Delucia AJ, et al. 2009. “ Potential impact of climate change on air

- pollution related human health effects. ” Environ mental Sci ence & Technolology 43: 4979

– 4 988. U.S. Environmental Protection Agency (U.S. EPA). 2013. Integrated Science Assessment of Ozone and Related Photochemical Oxidants (Final Report). EPA

- 600/R

- 10/076F. February. Available on the Internet at http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=2 47492

. U.S. Environmental Protection Agency (U.S. EPA). 2014a. Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards. Office of Transportation and Air Quality. Available at http://www.epa.gov/otaq/tier3.htm

. U.S. E nvironmental Protection Agency (U.S. EPA). 2014b. Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for Modified and Reconstructed Power Plants. Available at http://www2.epa.gov/sites/production/files/2014

- 06/documents/2 0140602ria

- clean

- power
- plan.pdf U.S. Environmental Protection Agency. 2014 c . Policy Assessment for the Review of the Ozone NAAQS, Final Report. August. Available on the Internet at http://www.epa.gov/ttn/naaqs/standards/ozone/data/20140829pa.pdf

.