Abstract
In October 2015, the United States Environmental Protection Agency (EPA) lowered the level of the ozone National Ambient Air Quality Standard (NAAQS) from 0.075 ppm to 0.070 ppm (annual 4th highest daily maximum 8-h concentration, averaged over three years). The EPA estimated a 2025 annual national non-California net benefit of $1.5 to $4.5 billion (2011$, 7% discount rate) for a 0.070 ppm standard, and a −$1.0 to $14 billion net benefit for an alternative 0.065 ppm standard. The purpose of this work is to present a combined toxicological and economic assessment of the EPA’s benefit-cost analysis of the 2015 ozone NAAQS. Assessing the quality of the epidemiology studies based on considerations of bias, confounding, chance, integration of evidence, and application of the studies for future population risk estimates, we derived several alternative benefits estimates. We also considered the strengths and weaknesses of the EPA’s cost estimates (e.g., marginal abatement costs), as well as estimates completed by other authors, and provided our own alternative cost estimate. Based on our alternative benefits and cost calculations, we estimated an alternative net benefit of between −$0.3 and $1.8 billion for a 0.070 ppm standard (2011 $, 7% discount rate) and between −$23 and −$17 billion for a 0.065 ppm standard. This work demonstrates that alternative reasonable assumptions can generate very difference cost and benefits estimates that may impact how policy makers view the outcomes of a major rule.
Highlights
The Ozone National Ambient Air Quality Standards (NAAQS) Cost and Benefit Analysis In October 2015, the Environmental Protection Agency (EPA) lowered the level of the current primary and secondary ozone standards from 0.075 parts per million to 0.070 ppm [15]. In their draft regulatory impact analysis (RIA) released with the proposed rule [9], and their final RIA released with the final rule [10], the EPA estimated the 2025 national, non-California net benefits for the 0.070 ppm standard and the
If the EPA is to remain consistent throughout its analysis, they should use the hybrid methodology introduced in the 2008 Ozone NAAQS RIA to estimate the costs of unidentified controls [72]
To estimate the cost from mitigating the remaining 860,000 tons of NOx through unidentified methods, the EPA cited offset prices used in the draft RIA, noted that 97% of the emissions reductions in Control Strategy Tool (CoST) are available at a cost of less than $15,000/ton, and performed several alternative estimation strategies to support the use of an average abatement cost of $15,000/ton of NOx
Summary
The U.S Environmental Protection Agency (EPA) regulates 6 air pollutants (called “criteria pollutants”) through the National Ambient Air Quality Standards (NAAQS) program: ozone, particulate matter (PM), carbon monoxide (CO), lead, nitrogen dioxide (NO2 ), and sulfur dioxide (SO2 ). Res. Public Health 2018, 15, 1586 about the adequacy of the current indicator, level, averaging time, and form of the NAAQS for that pollutant. Based on the scientific data, analysis, and uncertainty, the EPA Administrator must make a policy decision about where to set the level, averaging time, and form of the NAAQS. The EPA Administrator placed the most weight on human controlled exposure studies for the 2015 ozone review, and these studies formed the basis for the EPA’s choice of standard levels [14,15]. A large literature of epidemiology studies exists that investigate the associations between health effects in populations and ambient ozone concentrations [16,17,18,19,20,21,22,23]. The EPA used results from epidemiology studies when estimating the health benefits attributable to decreasing the ozone standard [9,10], and as such these studies form the basis of our discussion of ozone attributable health benefits below
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