Ozone formation is a complex function of local hydrocarbon and nitrogen oxide emissions. Therefore, trading of NOx emissions among geographically distributed facilities can lead to more or less ozone formation than across-the-board reductions. Monte Carlo simulations of trading scenarios involving 51 large NOx point sources in eastern Texas were used in a previous study by the authors to assess the effects of trading on air quality benefits, as measured by changes in ozone concentrations. The results indicated that 12% of trading scenarios would lead to greater than a 25% variation from conventional across-the-board reductions when air quality benefits are based only on changes in ozone concentration. The current study found that when benefits are based on a metric related to population exposure to ozone, two-thirds of the trading scenarios lead to changes in air quality benefits of approximately 25%. Variability in air quality benefits is not as strongly dependent on the temporal distribution of NOx emissions.