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3.4     Nitrogen Deposition Estimates



        Nitrogen deposition estimates are generated using RADM  The RADM was de\ eloped over a ten

\earperiod. 1984 - 1993. under the auspices of the National Acid Precipitation Assessment Program to

address polic> and technical issues associated \\ith acidic deposition  The model is designed to provide a

scientific basis for predicting changes in deposition and air quality resulting from changes in precursor

emissions and to predict the levels of acidic deposition in certain sensitn e receptor regions  To do so requires

that RADM be a multipollutant model that predicts the oxidizing capacity of the atmosphere, including the

prediction of o/one. and chemical transformations mvoh ing oxides of sulfur and nitrogen



        The de\elopment. application, and e\ aluation of the RADM has been documented extensiveh  b>

NAPAP (Chang, et al  1987 & 1990. Dennis et al 1990)  RADM has been used in several recent studies of

acidic deposition, including EPA's 1995 Acid Deposition Standard Feasibility Stud) Report to Congress

(U S EPA. 1995). EPA's 1997 Deposition of Air Pollutants to the Great Waters Report to Congress  (U S

EPA. 1997e). and in \\ork estmatmg  the nitrogen deposition airshed of the Chesapeake Bay watershed

(Dennis. 1997)



        RADM estimates deposition in units of kilograms per hectare (kg/ha)  Wet deposition is estimated

in the form of SO;:\ NO,". NH3. H"  Dr> deposition is estimated in the form of S0:. SO., as aerosol. 0_,.

HNO-,. NO,. H-O^ The deposition estimates  are mapped to specific East Coast and Gulf Coast estuaries and

their \\atersheds  :  Land deposited nitrogen in each \\atershed is multiplied b\  a factor of 10% to obtain the

nitrogen load delnered  Ma export (pass-through) to the corresponding estuan



        Table 3-4 proxidcs a summan  of the nitrogen deposition estimates for each cell in the RADM

domain  The changes range from 0 01 kg/ha to 3 66 kg/ha  The results for the 0 15 option represent an 11%

reduction in the a\eragc annual deposition across the entire domain  The air qualiU technical support

document for this R1A (Abt Associates.  1998) contains maps sho\\mg the nitrogen deposition changes

generated using RADM for each of fi\e regulators altcrnatnes (0 25 Trading. 0 20 Trading. Regionally  1.

0 15 Trading, and 0 12  Trading)  Another technical support document for this RJA (EPA. 1998d) contains

additional information on the reduction in mtroaen loads to 12 stud\ set estuaries

        '• F.PA has de\eloped a methodology to assess nitrogen deposition benefits direct!) for 12 different estuaries

Albemarle,' Pamhco Sounds. Cape Cod Ba\. Chesapeake Ba\. Delaware Bay, Delaware Inland Ba\s. Gardmers Ba\.

Hudson R •' Rantan Ba\. Long Island Sound. Massachusetts Ba}. Narragansett Ba>. Sarasota Ba\. and Tampa Ba\



                                             Page 3-19

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                                                 Table 3-3

                             Summan of S-R Matrix Derived PM Air Qualin

Statistic

Minimum Annual Mean

PM,( (..g'mV'

Maximum Annual Mean

>Mir, (..g'nV) !

A\cragc .Annual Mean

3M,, (. gm''i

Population-\\ eighted

A\ erage Annual Mean

5M (person-, e'mV

Minimum Annual Mean

PM:,(. g'mV

Maximum Annual Mean

PM-, (..g'mV

A\ erage /Vnnual Mean

PM- . f . g m'i

Population- Weighted

A\ erage Annual Mean

PM- , (person-, e'm' i l

2007 Base

Case

539

66 3"

2262

25 96

3 49

2~ 63

10 "4

1262

Change Relath e To 2007 Base Case "

0.25

Trading

-0 56

020

-0 03

-0 03

-052

0 20

-00?

-0 03

0.20

Trading

-056

021

-003

-004

-052

021

-0 03

-0 04

Reg. 1

-053

026

-002

-0 03

-049

025

-0 02

-0 03

0.15

Trading

-057

026

-004

-004

-053

026

-0 04

-004

0.12

Trading

-0 6"

0 16

-0 06

-o u"

-0 6~

0 17

-0 05

-0 06

 The chanec is defined as the eontrol case \alue minus the ba*-e ease \ alue



s The base ^a-.e minimum i maximum) is the \alue tor the counu uith the louest (highest) annual average  The change relatne to ih

the minimum i maximum i from the set of ehange-. in all counties



• Calculated m summmc the product of the protected  2r'0~ counts population and the estimated 2007 counts P\I concentration and

the total populalior in the 3 1 sute^ modeled u^mg the S-R Matrix

; base case picks





then dr. idi:iL r.'-

        Population-weighted air quahtx changes \\ere not estimated using the S-R Matrix results  The

results generated from the RPM modeling sho\vn in Appendix B should be generalh representalne of the

direction and magnitude of changes that would be estimated using the S-R Matrix results



        The air qualm technical support document for this R1A (Abt Associates. 1998) contains maps

showing the base case PM concentrations and PM concentration changes generated using the S-R Matrix for

each of fi\ e regulator) alternatives (0 25 Trading. 0.20 Trading. Regionally 1.015 Trading, and 0 12

Trading)   Similar maps can also be found in Pechan. 1998

                                                 Page 3-18

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1997d)  The standardi/.ation for temperature and pressure was eliminated from this concentration data based

upon proposed rc\ isions to the reference method for PM,,, "



        Because there is little PM,, monitoring data a\ ailable. a general linear model was de\ eloped to

predict PM,« concentrations directh from the 1993 - 1995 PMKJ \alues (U S EPA. 1996b)  A SASrN1

general linear model (i c . GLM) procedure \\as used to predict PM;< values (dependent \anable) as a

function of independent ^ anables for season, region, and measured PMU. value  These dern ed  PM; 5 data

\\ere used to calibrate model predictions of annual average PM:5

3.3.5   Development of Annual Median PM2 ? Concentrations



        The CRDM procedure does not direct!} produce estimates of daih 24-hour a\erage PM

concentrations or annual median PM concentrations  Some health benefits have concentration-response

functions that reh on estimates of either the daih 24-hour average or annual median concentrations  Using

historical data. EPA de\ eloped 24-hour a\erage estimates corresponding to the 99th percentile A alue for PM

and the 98th percentile \ alue for PM, ^  reflecting  forms of PM,,, and PM:, daih standards



        Peak-to-mean ratios (i e . ratio of the 24-hour a\erge value to annual a\erage \alue) are established

from actual PM,, monitor data for 1993 to 1995 from Tier 1 through Tier 3 monitored counties  For PMK,.

the peak \ alue is defined cxacth  the \\a> it is for  the new PMK, NAAQS. i e . the \ alue corresponding to the

99th percentile \aluc of the distribution of actual  daih 24-hour a\eragc PM,,, \alues  For PM:5. the peak

value is also defined exactly the \\ay it  is for the ne\\ PM,, NAAQS. i e . the \ alue corresponding to the 98th

percentile \ alue of the distribution of estimated daih 24-hour a\ erage PM:, \ alues  These historical peak-to-

mean ratios for each monitored count}  are assumed to hold for the 2007 model \ear in this anah sis and arc

applied to the annual a\ erage PM estimates generated b> the S-R Matrix  Peak \ alues in nonmomtored

counties are estimated using the regional a^ erage peak-to-mean ratios in Tier 1 monitored counties



        Starting with the annual mean and peak values de\ eloped from the S-R Matrix, maximum likelihood

is then used to estimate the parameters  of a Gamma distribution that are most consistent \\ith the S-R Matrix

results  The parameters of the Gamma distribution are then used to estimate the annual median concentration

and the concentration corresponding to each decile of the distribution

3.3.6    S-R Matrix PM Air Quality Results



        Table 3-3 pro\ ides a summan of the predicted ambient PM,, and PM: s concentrations used in this

stud\   Similar to the results using the RPM approach, the concentration changes are general!} ven small

For the 0 15 option, annual mean PM,,, changes range from an increase of 0 26 ug/m3 to a decrease of-0 57

tig/m3. with an average annual mean change across the 31 state domain of -0 04 ^g/m?  Therefore, the

absolute changes in PM occur within a slightly wider band than with the RPM. and the average annual mean

change is slightly lo\\er (-0 04 ,^.g/m3 \ersus -0 06 ^,g/m3)

        " See Appendix .1 - Reference Method for PM10, Final Rule for National Ambient Air Quahn Standards for

Paniculate Matter (Federal Register. Vol 62. No 138. p 41. July 18. 1997)



                                             Page 3-17

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        To address this bias, a multiplicatne factor of 0 25 is applied national!) to fugitn e dust emissions as

a reasonable first-order attempt to reconcile differences between modeled predictions of PiYL ^ and actual

ambient data  This is the same adjustment that \\as used in the 1997 PM NAAQS RIA  A 0 25

multiphcatn e  adjustment results in a fugitn e dust contribution to modeled ambient PM;, concentrations of

10% to 17% "  E\en after this adjustment the fugitne dust  fraction of total eastern PM:^ mass is 104%.

which is still greater than the 5% indicated by IMPROVE monitors   Ho\ve-\ er: given that the 0 25

multiphcatn e  factor appears to bring the modeled fugitn e  dust contribution to PM: 5 mass more within the

range of \ alues reported from speciated monitoring data, the fugitive dust  contribution to total PM that is

estimated b> the S-R Matrix is adjusted by this factor  Since this factor still max result in an overprediction

of the fugitne  dust contribution, the S-R Matrix may tend to underpredict the effectneness of strategics that

affect NSA

3.3.4   Normalizing S-R Matrix Results to Measured Data



        In an attempt to further ensure comparability between S-R Matrix results and measured annual

a\ eragc PM \ alues. the S-R results are calibrated using factors de\ eloped for the PM and Ozone NAAQS

RIA (U S EPA. 1997a)  For the NAAQS RIA. a "normalization factor" \\as de\ eloped for each Tier 1 to

Tier 3 monitored count} :'  Nonmomtored counties \\ere calibrated using the appropriate regional

normah/ation factor calculated as the a\erage of Tier 1 normalization factors across a en'en modeling region

The normah/ation factor  was calculated  as the monitored \ alue dn ided b>  the modeled value



        All S-R Matrix predictions \\ere normalized regardless of overprediction or underprediction relatne

to monitored \ alues  This factor \\as applied equalh  across all particle species contributing to the annual

a\erage PM \aluc at a count)-le\ el receptor



        The calibration procedure \\as conducted emplo\mg 1993 - 1995 PMlu ambient monitoring data

from the AIRS database following the air quaht) tier data completeness parameters discussed abo\c  The

PM; data represent the annual a\erage of design value monitors a\eraged o\er three years (U S  EPA.

        "" Sec l: S EPA 199 'b. page 6-5 for a map delineating modeling region  Using 0 25 mulliphcame factoi.

fugime dust as percentage of P.M. = mass for Central US =1" 2%. Eastern U S =  104%. Western U S = 10 6%  B>

comparison, \\ithout using a multiphcame factor, fugitn c dust as a percentage of PM., mass for Central US =44 6%

Eastern U S = .10 9%. Western U S =31 5%



        10 The normalization procedure was conducted for count) -\e\ el modeled PM10 and PM;, estimates falling into

one of four air qualit) data tiers  The tiering scheme reflects increasing relaxation of data completeness criteria and

therefore increasing uncertainty for the annual design \alue (U S EPA. 1997f)  Nationwide. Tier 1 monitored counties

co\er the 504 counties \\ith at least 50% data completeness and therefore have the highest level of certainty associated

with the annual design value  Tier 2 monitored counties cover 100 additional counties \Mth at least one data point (i e .

one 24-hour value) for each of the three \ears during the period 1993 -1995   Tier 3 monitored counties cover 107

additional counties u ith missing monitoring data for one or tw o of the three) ears 1993-1995  In total. Tiers 1. 2  and 3

co\er7H counties currenth  monitored for PM10 in the 48 contiguous states  In 1997 the PM,0 monitoring network

consisted of approximate!;* 1600 individual monitors with a coverage of approximate!)  711 counties in the 48

contiguous states  Tier 4 covers the remaining 2369 nonmomtored counties



                                               Page 3-16

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•       Because ammonium nitrate forms onh under relatively lo\\ temperatures, annual axerage particle

        nitrate concentrations are di\ ided b> four assuming that sufficient!) lo\\ temperatures are present

        onK one-quarter of the > ear



Final!}.  the total particle mass of ammonium sulfate and ammonium nitrate is calculated



        For application to the NO\ SIP call, emissions data for onh those counties located in the 37 OTAG

states plus the District of Columbia are used  Because nationwide emissions are not used, the S-R Matrix

results are incomplete for  air qualih predictions m the counties located in states along the western border of

the OTAG domain  For example, emissions from New Mexico are expected to have a significant downwind

impact on ambient PM concentrations in neighboring counties m Texas  However. New Mexico emissions

are not estimated in this anal} sis  Incomplete air qualit} predictions for the six western border states make

unreliable am anal} sis that imposes a threshold for health effects (see Chapter  11)  As shown in Figure 3-3.

EPA has chosen not to include the air quality results from the six "buffer"' states in the benefits anah scs that

are performed using the S-R Matrix results   Since the 31 remaining states are generally located more than

525 km  (approximate!) 330 miles) from the states for which emissions information is not a\ ailable. the air

qualit} results for the 31 states is belie\ed to be more reliable

3.3.3    Fugitive Dust Adjustment Factor



        As indicated in subsection 34 1. the 1990 CRDM predictions for fugitive dust are not consistent

\\ith measured ambient data  The CRDM-predicted a\ eragc fugitn e dust contribution to total PM;, mass is

3 1% in the East and 32°«in the West (E H  Pechan. 1997b)   Speciated monitoring data from the IMPROVE

net\\ork show that minerals (i e . crustal material) comprise approximate!}  5% of PM;< mass in the East and

approximate!) 15°o of PM- < mass in the West (U S EPA. 1996a)  These disparate results suggest a

s> stematic o\ erbias in the fugitn c dust contribution to total PM  This o\ erestimatc is further complicated b>

the recognition that the 1990 NPI significant!} o\ erestimates fugitn e dust emissions  The most recent

National Emissions Trends imcnton  indicates that the NPI o\ erestimates fugitn e dust PM,,  and PM:,

emissions b} 40% and 73% respectneh" (U S EPA.  1997c)

         To calculate total particle mass of ammonium sulfate and ammonium nitrate, the anion concentrations of

sulfate and nitrate are multiplied b\ 1 375 and 1 290 respectneh



        8 Natural and man-made fugitive dust emissions account for 86% of PM10 emissions and 59% of P.M.,

emissions in the most recent 1990 estimates in the National Emission Trends Inventon



                                             Page 3-14

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because it relates closeh to 1990 emissions and meteorological data used in the CRDM  Since the

IMPROVE network monitors are primanh concerned with e\aluatmg visibility  impairment in predominant!}

rural Class I areas, these comparisons are incomplete due to the lack of coverage in urban areas  With the

exception of the fugitne dust component of PM: * and PM1(1. modeled and measured concentrations of sulfate.

nitrate and organics are comparable (Latimer. 1996)



        The CRDM has also been benchmarked against the RADM-RPM for the Eastern U S using 1990

emissions and meteorology (U S EPA. 1997b)  RADM-RPM incorporates more comprehensn e physics and

chemistry to enable better characterization of secondarih -formed pollutants than Lagrangian-based methods

In general, the CRDM results shew a similar  trend in sulfate and nitrate concentrations \\ithm the same

modeling region  Also, the CRDM-predicted annual a\ erage concentrations of sulfate are within the range of

RADM-RPM base-case predictions Relative to RADM-RPM base case results. CRDM appears to

o\erpredict nitrate concentrations in the Midwest and underpredict nitrate concentrations in the Mid-Atlantic

states

3.3.2    Development of the S-R Matrix



        To de^elop the S-R Matrix, a nationwide total of 5.944 sources (i e . industrial point, utility area.

nonroad. and motor \ chicle) of pnmaiy  and precursor emissions were modeled with CRDM In addition.

secondary organic aerosols formed from anthropogenic and biogemc VOC emissions were modeled  Natural

sources of PM,  and PM:, (i e . \\ind erosion and wild fires) \\ere also included  Emissions of SO:. NOx. and

ammonia were modeled in order to calculate ammonium sulfate and ammonium nitrate concentrations, the

pnmarx particulate forms of sulfate and nitrate  The CRDM produced a matrix of transfer coefficients for

each of these primary and particulate precursor pollutants  These coefficients can be applied to the emissions

of am unit (area source or indnidual point source) to calculate a particular source's contribution to a county

receptor's total annual a\ erage PM,,, or  PM; < concentration  Each indrudual unit in the imentory is

associated \\ith one of the modeled source types (i e . area, point sources with effectne stack height of 0  to

250 m. 250 m to 500 m. and mdnidual  point sources \sith effectne stack height abo\e 500 m) for each

county



        The S-R Matrix transfer coefficients \\ere adjusted to reflect concentrations of secondanh-formed

participates (Latimer. 1996)  First, the  transfer coefficients for SO;. NOx. and ammonia \\ere multiplied b>

the ratios of the molecular \\eights of sulfate/SO-. nitrate/nitrogen dioxide and ammonium/ammonia to obtain

concentrations of sulfate. nitrate and  ammonium 6 The relatne concentrations in the atmosphere of

ammonium sulfate and ammonium nitrate depend on complex chemical  reactions  In the presence of sulfate

and nitric acid (the gas phase oxidation  product of NOx). ammonia reacts preferential!} \\ith sulfate to form

particulate ammonium sulfate rather than react with nitric acid to form particulate ammonium nitrate Under

conditions of excess ammonium and low temperatures, ammonium nitrate forms  For each county receptor.

the sulfate-nitrate-ammonmm equilibrium is estimated based on the following simphfing assumptions



•       All sulfate is neutralized b\ ammonium.

•       Ammonium nitrate forms onh  when there is excess ammonium.

        1 Ratio of molecular \\eights  Sulfate/SCK= 1 50. nitrate/nitrogen dioxide = 1 35. ammonium/ammonia = 1 06



                                             Page 3-13

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                                                Table 3-2

                                Summar} of RPM Derived PM Air Quality



Statistic

Minimum Annual Moan

PMlcu;g'nV)b

Maximum Annual Mean

PM;0 (-g'mV

A\erage Annual Mean

PM : (,. g rn'i

Population-Weighted

A\erage Annual Mean

PM ^ (person-, g'm'i '

Minimum Annual Mean

PM:. (.-g rrf) "

Maximum .Annual Mean

PM:,L.g''mV

A\ erage Annual Mean

PM:< (. g;m"')

Population -\\'eighted

A\ erase Annual Mean

PM,, (person-, g m'> '

2007 Base

Case

1545

3591

26 76



26 46



665

22 63

1 4 96



14 53



Change Relathe to 2007 Base Case2

0.25

Trading

-049

024

-( i 04



-0 03



-(|49

024

.0 04



-003



0.20

Trading

-046

024

-005



-0 05



-0 46

024

-0 05



-0 05





Reg. 1

-045

026

-005



-005



-0 45

026

-0 05



-0 05



0.15

Trading

-049

029

-006



-0 05



-049

029

-006



-005



0.12

Trading

-052

0 18

-0 12



-0 13



-052

0 18

-0 12



-0 1 3



1 The change i1- defined as the Control ca--e \a!ue minus the base case %a!ue  Note that there is no difference between the changes in PM;« and ]

because R U)M RPM onl\ estimates the change in nitrates and sullates \\hich are both in the PM_. fraction



1 1 he hase case minimum (ma\mium > is the \ aluc for the «.ounu \\ ith the lo\\est (highest) annual a\ erage The change relati\e to the base case picks

the minimum (maximum i irom the ->et oi changes m all countie*-



' C alculaled b% summing the product oflhc pro] jclcd 2r>()~ counl\ population and the estimated 2007 counl> PM concentration, and then di\ idinc b\

the total population

3.3.1   Climatological Regional Dispersion Model



        The CRDM uses assumptions similar to the Industrial Source Complex Short Term (ISCST?). an

EPA-recommended short range Gaussian dispersion model  CRDM incorporates terms for wet and dn

deposition and chemical comersion of S0: and N0\. and uses climatological summaries (annual average

mixing heights and joint frequency  distributions of wind speed and direction) from 100 upper air

meteorological sites throughout North America  Meterological data for 1990 coupled with emissions data

from version 2 0 of the 1990 National Paniculate Imenton were used to develop the S-R Matrix



        In order to evaluate the performance of the Phase II CRDM. model-predicted PM concentrations and

measured ambient PM concentrations were compared   Measured annual average  PM concentrations b\

chemical species from the Interagency Monitoring for Protection of Visual Enuronments (IMPROVE)

network \\ere examined for the three-year period March 1988 - February 1991  This period was chosen

                                                Page 3-12

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scenario  A similar procedure is used to estimate PM x alues in the control scenarios  Additional detail on

these procedures can be found in Abt.  1998

3.2.5    RPM PM Air Quality Results



        Table 3-2 proMdes a summan of the predicted ambient PM]fj and PM;^ concentrations used in this

stud>   Since onl\  the NSA fraction of total PM changes, the estimates of changes for PMir and PM; ^ are

identical The concentration changes are general!} xer\ small  For the 0 15 option, annual mean PM changes

range from an increase of 0 29 ug/m3 to a decrease of-0 49 ^g/m\ with an axerage annual mean change

across the RPM domain of -0 06 .'.g/rrf



        Population-weighted changes in RPM predicted annual mean PM- 5 and PM,,, concentrations above

the lex el of each ambient air quahu standard are presented in Appendix B  These changes are estimated for

the total exposed population and for various subpopulations. including minority groups, children, the elderlx.

and the impox enshed  In the SIP call states, the predicted decline in total population exposure abox e the

PM; ^ annual standard le\ el ranges from 5% to  15%  There is no predicted change in total population

exposure abo\ e the PM:  annual standard lex el because there is no predicted baseline exposure abox e the

standard



        The air qualm technical support document for this  RIA (Abt Associates.  1998) contains maps

show ing the base case PM concentrations and PM concentration changes generated using  RPM for each of

fixe regulator*  alternatixes (0 25 Trading. 0 20 Trading. Regionaht}  1.0 15  Trading, and 0  12 Trading)

3.3     PM Air Qualitx Estimates Using the S-R Matrix



        The Source-Receptor Matrix (S-R Matrix) reflects the relationship betx\een annual axerage PM

concentration \ alues at a single receptor in each count} (a hypothetical design value monitor sited at the

countx  population ccntroid) and the contribution bx  PM species to this concentration from each emission

source  (E H  Pcchan. 1996)  The receptors that are modeled include all U S  count} centroids plus receptors

in 10 Canadian pro\ mces and 29 Mexican cities/states The methodolog} used in this RIA for estimating PM

air quaht}  concentrations using the S-R Matrix is similar to the method used in the Julx  1997 PM and 0/one

NAAQS RIA (U S EPA. 1997a)  The S-R Matrix was dexeloped using the Chmatalogical Regional

Dispersion Model (CRDM). and has been calibrated using 1993 -  1995 PM,, and PM:5 monitoring data

These calibration factors, referred to as "normali/ation factors." are applied to all S-R Matrix predictions

                                             Page 3-1

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RPM results, it is neccssan to first use the NSA concentrations to estimate total PM concentrations at each

location under  the baseline and each control scenario for the N0\ SIP call'



        A first step in using information supplied b> RPM is to estimate distributional statistics for total PM.

using ambient  air quaht\ data currenth being developed for the CAAA §812 analysis  The location-specific

inputs axailablc from RPM and the upcoming §812 analysis are as follows



«       mean and peak PM in the §812 data (PMmean 8!:. PM,,9f, 8]:).

•       mean and peak NSA in the §812 data (NSAmcar, 8!:. NSA,,9,, 8::).

•       mean, median, and peak NSA in the N0\ SIP call baseline (NSAmean ba,e,Lr,e. NSAm,d ^ basc:i!,e. NSAr .„

        i^,,).

•       mean, median, and peak NSA in each control scenario of the N'Ox SIP call (NSAmea, ,.,„...,]. NSAniei. ..

        „„..,.. NSA, ,  cor..R.)



        Subtracting the mean NSA from mean total PM. one obtains the "other" component of PM (which

includes such components as soil and elemental carbon)

        It is assumed that the mean of this (location-specific) "other" component is the same in the NO\ SIP

call baseline as it is in the §812 data



                                    Othern,ea. b<^ ,,c = Othernea. , -



        Total PM is estimated in the baseline as

        To obtain an estimate of the 90th percentile le\el of PM in the baseline, it is assumed that the

proportion (p) of NSA,ea. ba<eiirt, to PM^ea. t,,,e;^, e is constant across da\s at the same location



                       P = NSA,,ica: Dfv,_,t / PM,,ed: „,_ = NSA, _ ^ / PM; b_ .



where ; denotes the ;th da\  Gi\en a constant ratio./?, the peak (90th percentile) da\  for baseline PM is the

same da\ as the peak da\ for baseline NSA  This implies

        In the last step, gnen the mean and 90th percentile point of the distribution of daih PM

concentrations (PMmcd;, babe;me and PM09,, baselme). and assuming that the distribution can be fit well by a

Gamma distribution, the anah sis uses a maximum likelihood estimation to estimate the parameters of the

Gamma distribution that are most consistent with the estimated mean and peak values  A distribution of

daih PM values based on NSA components predicted by RPM may then be generated for the baseline

        5 The RPM estimates of NSA are anh\ drous estimates However, ambient measurements of NSA do contain

\\ater. which can increase the total NSA mass tn as much as 10% to 50%  Therefore, the estimates of total NSA mass

changes derived from RPM understate total NSA mass changes



                                             Page 3-10

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3.2.2    Simulation Periods



        To de\elop annual estimates \\ith seasonal controls, an aggregation set of 30 meteorological cases is

separated into a \\arm season set and a cold season set  Because RADM predicts chemistn on a s>noptic: or

daih. time scale (chemical meteorology) an aggregation technique developed during NAPAP is used to

calculate annual estimates of acidic deposition  The de\ elopment and evaluation of the aggregation

simulation set is described by Brooks et al. 1995 Meteorological cases with similar 850-mb wind flo\\

patterns were grouped b\  applying cluster anahsis to classify the wind flo\\ patterns from  1982 to 1985.

resulting in 19 sampling groups, or strata  Meteorological cases were random!} selected from each stratum.

the number selected v»as based on the number of wind flo\\ patterns in that stratum relatne to. the number of

patterns in each of the other strata, to approximate proportionate sampling A total of thirt> cases are used in

the current aggregation approach  Each case is run for 5 days, using a separate initial condition for each

season specific to the scenario being run Outputs from onh the last 3 da\ s are used to a\ oid the influence of

initial conditions  For each emissions scenario modeled, seasonal initial conditions are de\ eloped b\ running

for 10 da\s \\ith those emissions after starting with ambient concentrations representatne of clean continental

conditions  Results for the 30 selected 3-da> cases are \\eighted according to the strata sampling frequencies

to form annual axeragcs  Application of the aggregation technique is described in Dennis et al. 1990 Note.

the aggregation method results in an annual a\erage produced by meteorology  that is representatne of many

\ears of meteorology  a decade or more, rather than for a single, gnen \ear



        While the aggregation method v\as de\ eloped for acidic deposition, it has been extended to daiK

a\eragc paniculate concentrations to calculate the annual mean, median and 90L"' percentiie of the distribution

The applicability of the aggregation method to particulate matter \\as studied by Eder. et al. 1996 using an

extinction coefficient (bev) for mid-da> estimate from human obser\ations of \isible range at airports (Husar

and Wilson. 1993)  The thirt) RADM aggregation cases \\ere found to be \ er> representatn e from an

extinction coefficient (inferred fine particulate matter) pcrspectne and sufficient to derne annual estimates of

fine particulate matter

3.2.3   RPM Model Outputs



        RPM outputs used in this anah sis include ambient concentrations (measured in units of micrograms

per cubic meter. ..g/irf) of particulate SO/. NO-/, and NH/" The outputs produced b\  the simulation period

aggregation method described in section 332 include the annual mean of daiK a\erage ambient

concentrations, and each decile of the distribution of daiK a\erage ambient concentrations  Ho\\e\er. the

health effect concentration-response functions that are used to estimate changes in health  effects for each

polic> scenario require estimates of total PM  Section 334 discusses the procedures used to estimate the

remamine fraction of total PM at each location

3.2.4   Development of Total PM Estimates



        RPM provides the mean, the median, and the peak (90th percentiie value) of daily concentrations, but

onh for the major portion of PM that will change as a result of the NOx SIP call --1 e. the nitrate, sulfate.

and ammonium components (NSA). According to the latest assessment of PM data for the NAAQS review.

NSA comprise 48 2% of total fine particulate in the eastern US  (US. EPA. 1996a)  To proceed with the

                                              Page 3-9

 image: 

















                 l'~ij»ure 3-2

     RADM-RPM Modeling Domain'

P. .«



— - . .) . . . J . . .- ., . - .-•>. - - -

• • •, ' s --•

:::.... •.... . . .3 ** . < . . .

"r-"--(V " " v;c

.-./'. . - . I V •*'

. . .1 . A . V:

                                   V

                                     ?'

          •  -->V

'-i ;--:x."  :  \

                                       \

                                    \

                                                ;;  r

                                             I *. ' '

                                      ff  -  K-K*

                                              X*

                                              W-,.

              pnd s«,,,aa-s ll,at cover ,hc caMc,,, I. S ,,„) s,,,,,hcrn Canada



              f'n^o VS

 image: 

















                                              Table 4-28

                  Monetary Benefits Associated with Visibility Changes in National Parks

                            Outside the Southeast in the NOx SIP Call Region

Regulatory Alternate e

(' 12 Ira Jini:

('15 "Iradms:

Regionaht\ 1

0 2<> Trading

(i 25 'Irading

Monetan Benefits (millions 1990S)

RADM-RPM

Unadjusted

I. cm

S22 8

S134

S~ 1

$83

SI 3

High

S2"7 0

$159

$85

S9 8

SI 6

Adjusted

Lo\\

$18^

$11 U

$5 8

S68

$1 1

High

S22 1

SI 3(i

S"0

S8 (i

SI 3

S-R Matrix

I,o\\

$05

$-54

$-65

$-58

$-52

High

$06

$-64

$-7"

S-69

$-62

4.5

Total Benefits

        The dollar benefits from reducing o/onc and PM le\els resulting from implementing the SIP call

NOx reductions is the sum of dollar benefits from the reductions in incidence of all non-o\erlappmg health

and \\clfare cndpomts associated \\ith PM and o/onc for a an en set of assumptions  If t\\o endpomts are

o\erlapping. then adding the benefits associated \\ith each will result in double counting of some benefits

Although studx-specific point estimates of dollar benefits associated \\ith specific, possibh cnerlapping

endpomts are presented separate!}, estimation of total benefits requires that the benefits from onh non-

ox erlapping cndpomts be included in the total   Four non-en erlappmg broad categories of health and \\elfare

endpomts \\ill be  included in the estimation of total dollar benefits for  the SIP call (1) mortality (2) hospital

admissions. (?) respirator) s\mptoms/illnesscs not requiring hospital admission, and (4) \\clfare cndpomts

When considering onh point estimates, aggregation of the benefits from different endpomts  is relatneh

straightforward  Once a set of non-en erlappmg categories is determined, the point estimate of the total

benefits associated \\ith the health and \\elfare endpomts in the set is just the sum of the endpomt-specific

point estimates If each endpomt-specific point estimate is the mean of a distribution of dollar benefits

associated \\ith that endpomt. then the point estimate of total dollar benefits is ]ust the sum of those means



        There is uncertain!}  about the magnitude of the total moneti/ed benefits associated \\ith am of the

SIP call regulator) alternate es examined in the benefits anal} sis The benefits are uncertain because there is

uncertamt) surrounding each of the factors that affect these benefits the changes in ambient pollutant

concentrations that \\ill result from the SIP call implementation, the relationship bet\\een these changes in

pollutant concentrations and each of the associated health and welfare endpomts. and the value of each

ad\ erse health and welfare effect a\ oided b> the reduction in pollutant concentrations



        Much of the uncertamt} dernes from uncertainty about the true \alues of anal} sis components, such

as the \ alue of the o/one coefficient in a concentration-response function relating ozone to a  particular health

endpomt. or the true dollar value of an a\ oided  hospital admission for congestive heart failure  The analysis

relies on estimates of these parameters, but the true \ alues being estimated are unknown  This type of

                                              Page 4-48

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uncertain!) can often be quantified  For example, the uncertainty  about pollutant coefficients is typicalh

quantified b\ reported standard errors of the estimates of the coefficients in the concentration-response

functions estimated b\ epidemiological studies  Appendix A presents a formal quantitative anal) sis of the

statistical uncertain!) imparted to the benefits estimates b\ the \ anabihu in the underh ing concentration-

response and valuation functions



        Some of the uncertamt)  surrounding the results of a benefits anal) sis. howe\er. imohes basicalh

discrete choices and is less easih quantified  For example, the decision of \\hich air quality model to use to

generate changes in ambient PM concentrations is a choice between t\\o models, embodying discrete sets of

air chemistn and mathematical assumptions  Decisions and assumptions must be made at many points in an

analysis in the absence of complete information  The estimate of total benefits is sensitne to the decisions

and assumptions made Among the most critical of these are the following



        Ozone mortaliu: There is some uncertain!)  surrounding the existence of a relationship betueen

        troposphcric o/one exposure and premature mortaht)   The two possible assumptions are  (1) that

        there is no relationship bctuecn o/one and mortaht). and (2) that there is a potential relationship

        bet\\cen o/one and mortaht). \\hich \\e can quantif) based on the meta-anahsis of current U S

        o/onc mortaht) studies



•       Ozone agriculture effects: The existing set of exposure-response functions relating crop yields to

        changes in o/.one exposure include both o/one-sensitn c and o/one-msensitn e cultn ars  Possible

        assumptions are  (1) plantings of commodity  crop cultn ars are pnmanh composed of sensitne

        \aneties. (2) plantings of commodity crop cultn ars are pnmariK composed of non-sensitne

        \aneties



        PM, 5 concentration threshold: Health effects are  measured onh  down to the assumed ambient

        concentration threshold  Changes in air  quaht) belo\\ the threshold \\ill ha\ e no impact on estimated

        benefits  EPA's Science Adxison Board has recommended examining alternatnc thresholds.

        including background and 15  ...g'm5



•       Sulfate Dominance:  There are u\o  possible interpretations of PM-related health  and \\elfare

        benefits depending on the model used to assess air quaht) changes (1) results generated with

        RADM-RPM are indicatne of a future eastern L" S  atmosphere \\here acid sulfate le\els are still

        high enough to control atmospheric  chemistn. and more  specificalh ammonium nitrate particle

        formation In this circumstance, reductions in NOx emissions ma\ result in non-linear responses in

        total fine particle le\ els. in\ oh ing both decreases and increases, and (2) results generated with the

        Source-Receptor Matrix are indicatne of a future eastern U S. atmosphere where acid sulfate levels

        do not dominate particle formation chemistn.  In this case, reductions  in NOx emissions would be

        expected to result more  direct!) in linear reductions  in PM



•       Recreational visibility: Recreational \isibiht) benefits for residents of the Southeast may overlap

        with "residential" visibilit) benefits  T\\ o alternatn e assumptions may be considered for in-region

        residents (1) recreational ^ isibiht) benefits overlap with residential visibility benefits, and to avoid

        this o\erlap. the recreational Msibiht)  value of $4 per deciview for out-of-region residents is used for

        in-region residents ($2  40 for non-indicator parks, and $1 60 for the indicator park), or (2)

        recreational visibilit)  benefits are in addition to residential visibility benefits, and the m-region \alue

        of S6 50 is used (S3 25  for non-indicator parks,  and $3 25 for the indicator park)

                                              Page 4-49

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        Benefits from \isibiht\ impro\ements ma\  also occur in N0\ SIP call states outside of the

        Southeast The current literature on the \alue of recreational \isibiht> in national parks is limited to

        studies of \alucs in California, the Soutrmest. and the Southeast, and thus excludes the Central and

        Northeast (CNE) portion of the NOx SIP call region  Three altematn e assumptions ma\ be

        considered \\hen \aluing \isibiht>  changes  in the CNE  (1) recreational visibility ^ alues in the CNE

        are much less than that in the Southeast and therefore to insure benefits are not o\ erstated. no \ alue

        should be associated \\ith visibihtx changes in the CNE. (2) recreational \ isibility values in the CNE

        are similar to the \ alues for non-indicator parks in the Southeast, and recreational and residential

        benefits overlap people in and out of the CNE region \ alue CNE recreational visibility at $2 40 per

        decn ie\\. or (?) recreational \ isibihtv \alues in the CNE are similar to the \alues for non-indicator

        parks in the Southeast, and there is no overlap of recreational and residential benefits  the m-region

        CNE \ alue is based on the  Southeast m-region \ alue of S3 25 per decn ie\\. and the out-of-region

        CNE \ alue is based on the  Southeast out-of-region \ alue of S2 40 per decn ie\\



        Tables 4-29 through 4-33 present summaries of the endpomt specific monetan \ alues and the

estimate of total benefits for each of the fi\e regulator) altematn es  Aggregate results are presented for t\\o

assumption sets 1) a "lo\\" assumption set reflecting the assumptions that human health and the emironment

ha\c lo\\ responsn eness to changes in  ambient air quahtv and 2) a "high" assumption set reflecting the

assumptions that human health and the em  ironmcnt arc highh responsn e to changes in ambient air quaht\

The "lo\\" assumption set includes  the  following assumptions 1) there are no PM-related health effects

occurring belo\\ a threshold of 15 jig/m'. 2) changes in PM concentrations are more accurate!}  represented b\

the RADM-RPM  air quaht> model. 3)  there is no relationship betueen o/one and premature mortality. 4)

agricultural commodiK crops are less sensitne to o/one  5) Southeastern recreational \isibilitA \alues are not

transferable to changes in recreational \ isibilit)  in the Northeast and  Central U S . and 6) the lo\\-end

recreational \ isibilm  \ aluation method is correct  The "high" assumption set includes the follo\ung

assumptions  1} P\I-related health effects occur down to the anthropogenic background threshold. 2) changes

in PM concentrations are more accuratch represented b> the S-R Matrix air quaht\ model. 3) the relationship

bet\\een o/one and premature mortalit} is characten/ed b\ the distribution of axoided incidences derned

from the o/one mortality meta-anaKsis. 4) agricultural commodit) crops arc more sensitne to o/one. 5)

Southeastern recreational \isibiht\ \alues arc transferable to the Northeastern and Central U S  . and 6) the

hiuh-end recreational  \isibiht\ method  is correct

                                             Page 4-50

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                                                 Table 4-29

                    Total Quantified Monetan Benefits Associated with the NO\ SIP Call,

                   Incremental to the 2007 Base Case: 0.12 Trading Regulator} Alternative*

Endpoint

Monetary Benefits (million 1990S)

"Lxnv" Assumption Set

"High" Assumption Set

Ozone-related Endpoints

Short-term moriaht\

Hospital admissions

Acute respirator, sMnptoms

N\ orker products ir\

Commodm crops

Commercial forests

$0

$5

SI

S25

S53

$233

$1.496

$5

SI

$25

S415

$233

PM-related Endpoints

Long-term mortality

Hospital admissions

Chronic bronchitis

Acute bronchi;^

Acute respirators s\mptoms

Woik lo>> da\s

MRADs

1 louschold soiliny:

Residential M>ibiht\

Recieationa! Msihihtx

Nitrogen deposition

TOTAL

SI. 468

S3

S589

S<i

SO

S14

S53

S26

SI IS

S52

S248

S2,888

$2.6^2

$4

$245

S(>

$0

$8

$29

Sll

560

S21

$248

S5,473

* Not all pobiiblc benefits are quantified and monetized in this analxsis Potential benefit categories that ha\e not been quantified anc

monetized are listed in Table 4-2

                                                  Page 4-51

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                                                  Table 4-30

                    Total Quantified Monetan Benefits Associated with the NOx SIP Call,

                   Incremental to the 2007 Base Case: 0.15 Trading Regulator} Alternate e"

Endpoint

Monetary Benefits (million 1990S)

"Low" Assumption Set

"High" Assumption Set

O/one-related Endpoints

Short-term mortaliu

1 lospita! admission-!

Acute respirators s\rnptoms

X\ orkei products it\

Commodm crops

I ommereid! forests.

$0

$4

SI

$22

S4~

$21?

$1.326

$4

SI

$22

S?6!

S213

PM-related Endpoints

! one-term mo:ulit\

Hospital admissions

Chrome bronchitis

•\cute honchrus

•\ciite lespiraton s\mpioms

Vk'ork loss ja\ s

MRADs

I loiiscliold >oilnij;

Residential \isibili;\

Recieationa! \i.Mbilit\

Nitrogen deposition

TOTAL

S251

SI

S225

S"

SO

S6

S24

Sid

$2*

S30

S2?8

SI, 100

$1.~6?

$4

$160

$i>

Sfl

S5

Siv

s~

S?8

S9

$238

S-4.170

a Not all possible benefits are quantified and moneti/ed in this anahsis  Potential benefit categories that ha\e not been quantified and

moncti/ed are listed in Table 4-2

                                                  Page 4-52

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                                                 Table 4-31

                    Total Quantified Monetary Benefits Associated with the NOx SIP Call.

                  Incremental to the 2007 Base Case: Regionally  1 Regulator* Alternate ea

Endpoint

Monetan Benefits (million 1990S)

"Low" Assumption Set

"High" Assumption Set

O/one-related Endpoints

Short-term moriaim

Hospital admissions

Acute respiraton s\mptom.s

\\oiker producmm

C ommoditx crops

Commercial loicsts

$0

$4

$1

$20

S43

SI 88

$1.19.

S4

SI

$2<>

S3 IS

S1HS

PM-related Endpoints

,ont>term monaim

Hospital admissions

Chronic bionchitis

Acute bionch'.lis

•\cuic tespiraion s\mptoms

\\ cirk loss da\ s

MRADs

I iouseh(ilJ -^iilinii

Residential MMhilm

Recicational \ isibi;i;\

Nitrogen deposition

TOTAL

S3 IT

SI

S236

Sd

So

S6

S24

Sin

S?4

S3?

$221

SI, 138

$1.326

$4

$122

SO

$0

S4

$15

$t,

$2"

SK)

$221

S3.45''

1 Not all possible benefits arc quantified and monetized in this anal)sis  Potential benefit categories that ha\e not been quantified and

moneti/ed are listed in 1 able 4-2

                                                   Page 4-53

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                                                  Table 4-32

                    Total Quantified Monetary Benefits Associated with the NOx SIP Call,

                   Incremental to the 2007 Base Case: 0.20 Trading Regulatory Alternate e"

Endpoint

Monetary Benefits (million 1990S)

"Low" Assumption Set

"High" Assumption Set

Ozone-related Endpoints

Short-term mortuhn

Hospital admissions

Acute resp;:aton s\mptom>

\\orker product p. in

Commodm crops

Commeicidl lorests

$0

$4

SI

S20

S42

S1S5

$1.108

S4

SI

$2()

S3 12

S185

PM-related Endpoints

I ong-tenr. mor^i'in

1 iospitul admissions

Chionic bionch.Us

•\cutc bronchus

\cuic respnaion v\:r.ptomN

\\ ork loss da\ s

MRADs

I iousehold soilins:

Residential \ iMbilif

Rccreati.'nal \ i^ibn.u

Nitrogen deposition

TOTAL

S3~d

SI

S2 1 6

S'|

S'i

S5

S24

SI"

S?S

S"d

S2 1 0

SI, 156

SI 409

S4

Sl?5

Si '

Sd

S4

sr

$6

S?l

S"

S2 1 0

S3.543

a Not all possible benefits are quantified and moneli/ed in this anaKsis  Potential benefit eategones that have not been quantified and

moneti/ed are listed in 1 able 4-2

                                                  Page 4-54

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                                                 Table 4-33

                   Total Quantified Monetary Benefits Associated with the NO\ SIP Call,

                  Incremental to the 2007 Base Case: 0.25 Trading Regulatory Alternate ea



Endpoint

Monetary Benefits (million 1990S)

"Low" Assumption Set

"High" Assumption Set

O/one-related Endpoints

Short-term mortalm

Hospital admissions

Acute respirator. s\mptoms

Worker productn it\

C ommodm crops

Commercial forests

$0

S3

SI

S14

S?4

SI 43

S824

$3

SI

$14

S242

$143

PM-related Endpoints

Long-term mortaht\

Hospital admissions

Chronic bronchitis

Acute bronchitis

Acute respiraton s\mptonis

Work loss da\s

MRADS

1 lousehold soiling

Residential \isib:h;\

Recreational Msibihu

Nitrogen deposition

TOTAL

S208

SI

S148

Sc

S"

54

S14

S~

S25

S23

SI 52

S777

SI. 400

S4

S12^

S"

Sd

$4

S16

So

S3d

S5

$152

S2,971

' Not all possible benefits are quantified and monetized in thib analysis  Potential benefit categories that ha\e not been quantified and

monetised are listed in Table 4-2

                                                  Page 4-55

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4.6     Limitations of the Anah sis



        Gnen incomplete information, this national benefits anal) sis \iclds approximate results because of

the uncertain!) associated \\ith am estimate  Potential!) important sources of uncertain!) exist and mam of

these arc summan/ed in Table 4-34   In most cases, there is no apparent bias associated \\ith the uncertamt)

For those cases for \\hich the nature  of the uncertainty suggests a direction of possible bias, this direction is

noted in the table

4.6.1    Projected Income Growth



        This anal) sis does not attempt to adjust benefits estimates to reflect expected growth in real income

Economic theon. argues. ho\\e\er. that \VTP for most goods (such as en\ ironmental protection) \\ill increase

if real incomes increase  The degree to \\hich \VTP ma) increase for the specific health and \\elfare benefits

pro\ ided b\  the N0\ SIP call  cannot be estimated due to insufficient income elasticity information Thus, ail

else being equal, the benefit estimates presented in this anal)sis arc hkeh to be understated

4.6.2    I nquantifiable Benefits



        In considering the moneti/ed benefits estimates, the reader should be a\\are that mam  limitations for

conducting these anahses are mentioned throughout this RIA  One significant limitation of both the health

and \\elfare benefits anahscs is the inabiht) to quantif) mam PM and ozone-induced adxerse effects  Table

4-2 lists the categories of benefits that this anal) sis is able to quantif) and those discussed onh  in a

qualitatnc manner  In general, if it \\cre possible to include the unquantified benefits categories in the total

moncu/ed benefits, the benefits estimates presented in this RIA \\ould increase  Specific examples of

unquantified benefits explored in more detail bclo\\ include other human health effects, urban ornamentals.

aesthetic injun to forests, nitrogen in drinking \\ater. and brov,n clouds



        The benefits of reductions in a number of o/one- and PM-mduced health effects ha\e not been

quantified due to the una\ ailabiht) of concentration-response and or economic \ aluation data These effects

include  reduced pulmonan. function, morphological changes, altered host defense mechanisms, cancer, other

chronic respirator) diseases, infant mortality air\\a\ response eness. increased susceptibihu to respiratory

infection, pulmonar)  inflammation, acute inflammation and respirator) cell damage,  and premature aging of

the IUITJS

                                              Page 4-56

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                                                Table 4-3-J

                               Sources of Uncertaint\ in the Benefit Analysis

1. Uncertainties Associated With Concentration-Response Functions

There is uneertamtv surrounding the ozone or PM coefficient in each C-R function

1 here is uncerlamt\ about apphing a single C-R function to pollutant changes and populations in all locations

It is uncertain ho\\ similar future \ear C-R relationships \\ill be to current concentration-response relationships

The correct functional form of each C-R relationship is uncertain  For example, it is uncertain \\hether there are

thresholds and. if so \\hat the\ are

There is uncertamn associated \\ilh extrapolation of C-R relationships beyond the range of ozone or PM

concentrations observed in the stud\

2.  Uncertainties Associated With Daih Ozone and PM Concentrations

1 here is uncertamn surrounding the protected hourh ozone and daih PM concentrations

1 he changes in ozone and PM concentrations resulting from the SIP call pro\isions are uncertain

3.  I ncertainties Associated W ith Possible Lagged Effects

It is uncertain \\hat portion of the PM-related long-term exposure mortality effects associated with changes in annual

PM le\els would occur in a single \ear. and \\hat portion might occur in subsequent \ears

4.  Uncertainties Associated With Baseline Incidence Rates

  me riasehne incidence rates arc not location-specific (e g . those taken from studies) and ma\ therefore not

accurate!} represent the actual location-specific rates

It is uncertain how well current baseline incidence rates approximate what baseline incidence rales will be in the \ear

2' i(>~  gi\en either "as is" o/one and PM concentrations or am altemame SIP call scenario

It is uncertain how well the proiected population and demographics  used to derne incidences, approximate what the

actual population and demographics will be in the \cm 200"

5.  Uncertainties Associated With Economic Valuation

Unit dollai \ alue.s associated \vith health and welfare endpomts are onh estimates of MWTP and therefore ha\e

ancertamu surrounding them  Possible directions of bias are discussed in the technical support document (Abt

l.\en using constant dollars (e g  l'»0 dollars!, it is uncertain whether MWTP for each t\pe of risk i eduction will be

the same in the \ear 20' ~ as the current M\\ 1 P

'I here is uncenainn about the appiopnate discount rate for benefits achie\ ed in the future i200~)

6. U ncertainties Associated W ith Aggregation of Moneti/ed Benefits

Because benefit estimation is limited to those health and welfare endpomts for which concentration-response functions

ha"\e been estimated, there ma\ be components of total benefit omitted  This would lead to a downward bias in the

estimated total monetized benefit

                                                 Page 4-57

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        In addition to the abo\c non-moncti/ed health benefits, there are a number of non-monetized \\elfare

benefits of NO\ emission controls from reduced ad\erse effects on \egetation. forests, and other natural

CCOSN stems  The CAA  and other statutes, through requirements to protect natural and ecological s> stems.

indicate that these are scarce and highh \ alued resources   Lack of comprehcnsn e information, insufficient

\ aluation tools, and significant uncertainties result in understated \\elfare benefits estimates in this R1A

Ho\\e\cr. a number of expert biologists, ecologists.  and economists (Costanza. 1997) argue that the benefits

of protecting natural resources  are enormous and increasing as ecos> stems become more stressed and scarce

in the future  Additional!}.. agricultural, forest and ecological scientists (Heck. 1997) believe that v egetation

appears to be more sensitn e to ozone than humans and consequent!}.  that damage is occurring  to \ egetation

and natural resources at concentrations below the ozone N AAQS  Experts also belie\ e that the  effect of

ozone on plants is both cumulame and long-term The specific non-monetized benefits from  reductions in

ambient ozone concentrations \\ould accrue from decreased foliar injun .  a\erted growth reduction of trees in

natural forests, maintained integrity of forest ecos\ stems (including habitat for name animal species), and

the aesthetics and utilit> of urban ornamentals (e g . grass, flowers, shrubs and trees)  Other welfare

categories for \\hich there is incomplete information to estimate the economic \alue of reduced adverse

effects include existence value of Class 1 areas,  materials damage, reduced sulfate deposition to aquatic and

terrestrial ecos\ stems, and usibihu impairment due to "brown clouds" (i  e . distinct brown lasers of trapped

air pollutants close to the  ground)



        Other Human Health Effects



        Human exposure to PM and ozone is known to cause health effects such as  airwa\ response eness.

increased susceptibility  to respirator,  infection, acute inflammation and respirator, cell damage, premature

aging of the lungs and chronic respirator,  damage  An impro\ement in ambient PM and ozone  air quality is

expected to reduce the number  of incidences \\ithm  each effect categon that the U  S population \\ould

experience  Although these health effects are kno\\n to be PM or ozone-induced, concentration-response data

is not a\ ailablc for quantising the benefits associated \\ith reducing these effects  The mabiht\ to  quantify

these effects leads to an underestimation of the monetized benefits presented in this anaKsis



        I rban Ornamentals



        Urban ornamentals represent an additional \egetation categor. hkeh to experience some degree of

effects associated \\ith exposure to ambient ozone le\els and hkeK to impact large economic sectors  In the

absence of adequate exposure-response functions and economic damage functions for the potential  range of

effects rele\ ant to these r\pcs of •<. egetation. no direct quantitati\e economic benefits anaKsis  has been

conducted  Ornamentals used in the urban and suburban landscape include shrubs, trees, grasses, and

flowers The t\pes of economic losses that could potential!} result from effects that ha\e been associated

with ozone exposure include 1) reduction in aesthetic sen ices o\er the realized lifetime of a plant.  2) the loss

of aesthetic sen ices resulting from the premature death (or earK replacement) of an injured plant. 3) the cost

associated \\ith remo\mg the injured plant and replacing it \\ith a ne\\ plant. 4) increased soil  erosion.  5)

increased energy costs from loss of shade in the urban emironment.  6) reduced seedling sunn ability,  and 7)

am additional costs incurred o\er the lifetime of the injured plant to mitigate the effects of ozone-induced

injun  It is estimated that more than $20 billion (1990 dollars) are spent annually on landscaping using

ornamentals (Abt Associates. 1995). both b\ private property owners/tenants and b> governmental units

responsible for public areas, making this a potential!}, important \\elfare effects categon.  However.

information and valuation methods are not a\ ailable to allow for plausible estimates of the percentage  of

these expenditures that may be related to impacts associated with ozone exposure

                                              Page 4-58

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       Aesthetic Injury to Forests



       O/one is a regional!) dispersed air pollutant that has been sho\\n conclusive!) to cause discernible

      to forest trees (Fox. 1995) One of the \\clfare benefits expected to accrue as a result of reductions in

ambient o/onc concentrations in the United States is the economic \ alue the public receives from reduced

aesthetic m]ur> to forests  There is sufficient scientific information available that ambient ozone le\ els cause

visible miun  to foliage and impair the growth of some sensitn e plant species Ozone inhibits photos\nthesis

and interferes with nutrient uptake, causing a loss in \ igor that affects the abiht> of trees to compete for

resources and makes them more susceptible to a \ anety of stresses (EPA. 1996a. p  5-251)  Extended or

repeated exposures ma\  result in decline and e\ entual  elimination of sensitn e species  Ozone concentrations

of 0 06 ppm or higher arc capable of causing injun to forest ecos\ stems



        The most notable effects of ozone on forest aesthetics and ecosystem function ha\e been documented

in the San Bernardino Mountains in California  Visible ozone-related injun. but not necessanh ecosvstem

effects. ha\ e also been obsen ed in the Sierra Ne\ ada in California, the Appalachian Mountains from

Georma to Maine, the Blue Ridge Mountains in Virginia, the Great Smoky Mountains in North Carolina and

Tennessee, and the Green Mountains in Vermont  (EPA. 1996a. pp 5-250 to 5-251)  These are all locations

\\here there is substantial recreation use and \\here scenic quaht)  of the forests  is an important characteristic

of the resource  Economic \ aluation studies of lost aesthetic value of forests attributed to plant injuries

caused b\  o/onc arc limited to t\\o studies conducted in Southern California (Crocker. 1985. Peterson et al .

1987) Both  included contingent \ aluation sun e> s that asked respondents \\hat the> \\ould be \\ illmg to pa>

for reductions in (or prc\ entions of increases in) •*, isible ozone injuries to plants  Crocker found that

indniduals are \\illmg to pa\ a fe\\ dollars more per da> to gain access to recreation areas \Mth onh slight

o/one miun  instead of areas \vith moderate to se\ere injun  Peterson et al estimated that a one-step change

(on a 5 point  scale) in \ isible ozone injun in the  San Bernardino and Angeles National Forests \\ould be

\alued at an aggregate amount of between S27 million and SI 44 million  for all  residents of Los Angeles.

Orange, and  San Bernardino counties A reassessment of the sune\ design, in light of current standards for

contingent \ aluation research, suggests that it is plausible that concerns for forest ecosx stems and human

health could ha\c been embedded into these reported \ alues The extent of this  possible bias is uncertain



        Present anahtic tools and resources preclude  EPA from quantifying the benefits of impro\ed forest

aesthetics in  the eastern U S  expected to occur from the NOx SIP call This is  due to limitations in our

abiht} to quantifx the relationship between ozone concentrations  and \ isible mjun. and limited quantitatn e

information about the \alue to the public of specific changes in \isible aesthetic quality of forests  Hov\e\er.

there is sufficient supporting e\ idence in the ph\ sical  sciences and economic literature to support the finding

that the proposed NOx SIP call can be expected to reduce mjun to forests, and that reductions in these

miunes \\ill likeK ha\e a significant economic \alue to the public



        Nitrates in Drinking Water



        Nitrates in drinking water are currenth regulated b\ a maximum contaminant level (MCL) of 10

mg/L on the  basis of the risk to infants of methemoglobinemia. a condition which ad^ersel\• affects the

blood's ox>gen cam-mg capacity  In an analysis of pre-1991  data. Raucher. et al  (1993) found that

approximately 2 million people were consuming public drinking water supplies which exceed the MCL

Supplementing these  findings, the National Research  Council concluded that 42 percent of the public

drinking water users in the U S  (approximately  105 million people) are either not exposed to nitrates or are

exposed to concentrations below 1 3 mg/L (National Research Council.  1995)

                                              Page 4-59

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        In a recent cpidemiological stuch b\ the National Cancer Institute, a statistical!) significant

relationship  bet\\ccn nitrates in drinking \\ater and incidence of non-Hodgkin's lymphoma \\ere reported

(\\ ard. et al  . 1996)  Though it is generalh acknowledged that traditional water pollution sources such as

agricultural runoff are mosth responsible for \iolations of the MCL. other more diffuse sources of nitrate to

drinking \\ater supplies, such as that from atmospheric deposition. ma> also become an important health

concern should the cancer link to nitrates be found \ ahd upon further study



        Brown Clouds



        NOx emissions, especially gaseous NCK and NO\ aerosols, can cause a brownish color to appear in

the air (EPA. 1996c)  In higher elexation \\estern cities \\here wintertime temperature imersions frequently

trap air pollutants in atmospheric layers close to the ground, this can result in distinct brown la> ers  In the

eastern L S . a la\ered look is not as common, but the ubiquitous haze sometimes takes on a brownish hue

To date, economic \aluation studies concerning visual air quahtx  ha\e focused primanh on the clant> of the

air. and ha\c not addressed the question of ho\\ the color of the ha/e might be related to aesthetic

degradation  It ma> be reasonable to presume that brown ha/e is hkeh to be perceived as dirt> air and is

more hkeh to be associated \\ith air pollution in people's minds  It has not. ho\\e\er. been established that

the public \\ould hax e a greater \ alue for reducing bro\\n ha/e than for a neutral colored ha/c  Results of

economic \ aluation studies of x isibihh aesthetics conducted in Dem er and in the eastern U S  (McClelland

ct al . 199] i are not directh comparable because changes in \isibiht> conditions are not defined in the same

units of measure  Ho\\e\cr. the \VTP estimates for impro\ements in \isibiht> conditions presented in this

assessment are based on estimates of changes in clanu of the air (measured as deciMC\\) and do not take into

account am  change in color that ma\ occur  It is possible that there ma> be some additional \ alue for

reductions in bro\\msh color that max also occur \\hcn N0\ emissions are reduced



        Other I nquantifiable Benefits Categories



        There are other \\elfarc benefits categories for \\hich there is incomplete information to permit a

quantnatn e  assessment for this anah sis  For some  endpomts. gaps exist in the scientific literature or ke>

anahlical components and thus do not support an estimation of incidence  In other cases, there is insufficient

economic information to allo\\ estimation of the economic x alue of ad\ ersc effects  Potential!} significant.

but unquantified \\clfarc benefits categories include existence and user x alues related to the protection of

Class 1 areas (e g . Shenendoah National Park), damage to tree seedlings of more than 10 sensitne species

(e g . black cherry aspen, ponderosa pinej. non-commercial forests, ecosx stems, materials damage, and

reduced sulfate deposition  to aquatic and terrestrial ecos\ stems   Although scientific and economic data are

not axailablc to allo\\ quantification of the effect of o/one in these categories, the  expectation is that, if

quantified, each of these categories \\ould lead to an increase in the moneti/ed benefits  presented in this RIA

4.6.3   Potential Disbenefits



        In this discussion of unquantified benefits, a discussion of potential disbenefits must also be

mentioned  Se\ eral of these disbenefit categories are related to nitrogen deposition while one category is

related to the issue of ultraMolet light

                                              Page 4-60

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        Passive Fertilization



        Sc\ eral disbencfit categories are related to nitrogen deposition  Nutrients deposited on crops from

atmospheric sources are often referred to as passn e fertilization  Nitrogen is a fundamental nutrient for

pnman production in both managed and unmanaged ecos> stems  Most producm e agricultural s\ stems

require external sources of nitrogen in order to satisfy nutrient requirements  Nitrogen uptake b\ crops

\aries. but t\pical requirements for \\heat and corn are approximate!) 150 kg/ha/yr and 300 kg/ha/yr.

respecm el\ (N APAP. 1990)  These rates compare to estimated rates of passive nitrogen fertilization in the

range of 0 to 5 5 kg/haVr (NAPAP. 1991)  So. for these crops, deposited nitrogen could account for as much

as 2 to 4 percent of nitrogen needs  Holding all other factors constant, farmers" use of purchased fertilizers or

manure ma\ increase as deposited nitrogen is reduced EPA has not estimated the potential A alue of this

possible increase in the use of purchased fertilizers, but a quahtatne assessment of several factors suggests

that the o\ erali \ alue is \ en small relam e to the \ alue of other health and welfare endpomts presented in this

anah sis First, reductions in N'0\ emissions affect onl\  a fraction of total nitrogen deposition

Approximate!) 70 to 80 percent of nitrogen deposition is in the form of nitrates (and thus can be traced to

N0\ emissions) \vhile most of the remainder is due to ammonia emissions (personal communication \\ith

Robin Dennis. NOAA Atmospheric Research Lab. 1997)  Table 3-4 in Chapter 3 indicates the annual

a\erage change in nitrogen deposition attributable to the 0  15 Trading alternatne of the N0\ SIP call is

about 11 percent of baseline le\els. suggesting a relatneh  small potential change in passn e fertilization

Second, some  sources of nitrogen, such as animal manure,  are a\ ailable at no cost or at a much lo\\er cost

than purchased nitrogen  In addition, in certain areas nitrogen is current!) applied at rates \\hich exceed crop

uptake rates, usualh due to an o\ erabundance of a\ ailable  nutrients from animal waste  Small reductions in

passive fertilization in these areas is not hkeh  to ha\e am  consequence to fertilizer application The

combination of these factors suggests that the cost  associated \\ith compensating for reductions in passn e

fertih/ation is  rclatnel) minor



        Information on the effects of changes in passn c nitrogen deposition on forestlands and other

terrestrial ecos\ stems is \er\  limited The multiplicity of factors affecting forests, including other potential

stressors such  as ozone, and limiting factors such as moisture and other nutrients, confound assessments of

marginal changes in am one stressor or nutrient in  forest ecos\ stems  Ho\\e\ er. reductions in deposition of

nitrogen could ha\e ncgatne effects on forest and \egetation growth in ecos> stems \\hcre nitrogen is a

limiting factor (EPA. 1993)



        On the other hand, there is CMdence that forest ecos> stems in some areas of the United States are

nitrogen saturated (EPA.  1993)  Once saturation is reached. ad\erse effects of additional nitrogen begin to

occur such as soil acidification which can lead to leaching of nutrients needed for plant growth and

mobilization of harmful elements such as aluminum  Increased soil acidification is also linked to higher

amounts of acidic runoff to streams and lakes and leaching of harmful elements into aquatic ecos> stems



        Ultraviolet Light



        A reduction of troposphenc ozone is likely to increase the penetration of ultraviolet light, specificalh

UV-b. to ground le\el  UV-b is an issue of concern because depletion of the stratospheric ozone layer (i e ,

ozone in the upper atmosphere)  due to chlorofluorocarbons and other ozone-depleting chemicals is associated

with increased skin cancer and cataract rates Currenth. EPA is not able to adequately quantify these effects

for the purpose of \ alumg benefits for this pohc>

                                              Page 4-61

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        Other EPA programs exist to address the risks posed b\ changes in UV-b associated \\ith changes in

total column o/one  As presented in the Stratospheric Ozone RIA (EPA. 1992). stratospheric ozone le\els

are expected to significant!) improxe o\er the next centun as the major ozone depleting substances are

phased out globalh  This expected impro\ ement in stratospheric ozone  le\ els is estimated to reduce the

number of nonmelanoma skin cancers (NMSC's) b> millions of cases in the U S b> 2075

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Chestnut. L  1997  Draft Memorandum .\fethodoiog\  for Estimating I'alues for Changes in 1'isihihtvat

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Kmne\ et al . 1995  A SensitniU AnaKsis  of Mortality /PM10 Associations in Los Angeles Inhalation

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Krupmck. A J and M L Cropper 1992  The Effect of Information on Health Risk Valuations Journal of

Risk and Uncertainty 5(2) 29-48



Krupmck. A J and R J  Kopp  1988  The Health and Agricultural Benefits of Reductions m Ambient Ozone

in the United States Resources for the Future Discussion Paper QE88-10. Washington. DC August



Krupmck A J . Harrington W.. Ostro B  1990  Ambient Ozone and Acute Health Effects Evidence from

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Loehman. E T . S V Berg. A A Arro>o. R A  Hedmger, J M  Schwartz. M E  Shaw. R W. Fahien. V H De.

RP Fishe. D E  RJO. W F Rossle\. and A E S Green  1979 Distributional AnaKsis of Regional Benefits

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Manuel. EH. RL  Horst. K M  Brcnnan. \V N Lancn. M C Duff and JK Tapiero  1982  Benefits

Anal) sis of Alternative Secondarv National Ambient Air Qua/in Standard* for Sulfur Dioxide and Total

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Mathtech. Inc   1998  Regional Model Farm Benefit Estimation of Alternative Emission Controls for the

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McClelland. G . W Schul/c. D  Waldman. J In\m. D  Schenk. T Stewart. L Deck, and M  Tha>er  1991

Valuing Eastern I'isibilin   A Field Jest of the Contingent Valuation Me/hod  Prepared for Office of

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Moolga\kar et al . 1995  Air Pollution and Daih Mortality in Philadelphia  Epidemiology 6(5) 476-484



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Pollution  a Daih Time Series Anah sis  Am Rev Respir Dis  144 668-674



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                                           Page 4-(V]

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                          Chapter 5. BENEFIT-COST COMPARISONS

        This Regulator. Impact AnaKsis (RIA) provides cost, economic impact, and benefit estimates that

are potentially useful for e\ aluatmg alternative pohc> options for the NOx SIP call  Benefit-cost analysis

provides a systematic framework for assessing and comparing such alternatives  According to economic

theory the efficient alternative maximizes net benefits to society (i e.. social benefits minus social costs)

Hovve1. er. there are practical limitations for the comparison of benefits to costs m this analysis  This chapter

also discusses the ke\ limitations and uncertainties associated with the benefit and cost estimates

Nonetheless, if one is mindful of these limitations, the relative ordering and magnitude of the benefit-cost

comparisons presented here can be useful policy information

5.1      Summary of Cost Estimates



        This section provides a summan of cost results presented in Volume 1 of this RIA  Table 5-1

summarizes the total annual control cost estimates developed in this analysis for the > ear 2007 for a selected

set of regulator, altematnes that closeh approximate the alternate es anahzed in the benefits anahsis

These costs include potential changes in the nationwide costs of electricity generation for the network of

electricity generating sources (EGUs). direct control costs to potentialh affected non-EGU sources, emissions

monitoring costs associated with the administrative costs associated with monitoring  The majority of the

total annual cost is due to control on electnciU generating units (EGUs) for each altematne

                                             Table 5-1

                    Estimated Total Annual Cost of NOx SIP Call Alternate es in 2007

Regulator* Alternate

0 1 2 Trading

60°, o/S5.00d

0 1 5 Trading

60%/S5.000

Regionaht\ 1

60%/S5.000

0 20 Trading

60%/S5.000

0 25 Trading

60%/$5,000

Total Annual Costs

(million 1990S)

$2.128

$1.660

$1.400

S1.230

$925

                                              Page 5-1

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5.2     Summary of Benefits Estimates



        Table 5-2 summarizes the total annual benefits developed m this anaKsis for the year 2007 for the

"plausible range" of assumptions  Not all possible benefits are quantified and monetized in this analysis

Potential benefit categones that ha\e not been quantified and monetized are listed in Table 4-2 in Chapter 4

of Volume 2 of this RJA

                                               Table 5-2

                        "Plausible Range" of Annual Quantified Benefits Estimates

                                  for NOx SIP Call Alternatives in 2007

                                            (million 1990S)'

Regulator) Alternative

0 12 Trading

60%/S5.000

(< 1 5 Irading

60'VS5.00U

Regionally 1

60%, '$5. 000

0 2d Trading

60% S5.00H

(i 25 Trading

60% 55 000

Annual Quantified Benefits—

"Ixw" Assumption Set

$2.888

$1.100

SI. 138

$1.156

S~"~

Annual Quantified Benefits-

"High" Assumption Set

$5.473

$4.17()

$3.457

$3.543

$2.97]

' \ot all possible benefits are quantified and moneti/ed in thi-. anaKsis Potential benefit categories that ha\e not been quantified and monetized are

listed ir, I able 4-2 in Chapter 4 of this Rl \

5.3

Summary of Net Benefits

        Table 5-3 summarizes the total annual quantifiable net benefits for NOx SIP call regulatory

alternatn es for the \ ear 2007  There are se\ eral conclusions that can be drawn from Table 5-3



        For the "High" assumption set. monetized net benefits are positne and substantial for all regulatory

        alternatn es



        As modeled. Regionality 1 is an inferior alternatn e. i.e . even though 0 20 Trading is less stringent it

        achie\ es greater benefits at lower total costs



        Net benefits are greatest at the most stringent regulatory alternative evaluated, i e . 0.12 Trading  For

        the '"High" assumption set. net benefits are approximately 33 percent higher for the 0.12 Trading

        relative to the 0 15 Trading alternative  For the ''Low" assumption set. net benefits are positive only

        for the 0 12 Trading alternative



        While net benefits are negative for the "Lov\" assumption set for all but the 0 12 Trading alternative,

        it is important to remember that while all of the costs are included, mam benefit categories could not

                                               Page 5-2

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        be quantified In addition, the "Lou" assumption set estimate assumes that there are no reductions in

        premature mortality  associated \\ith ozone reductions   Relaxing this one assumption would result in

        positi\ e net benefits for all alternate es at the low end

                                              Table 5-3

                               Estimated Annual Quantified Net Benefits'

                                 for NOx SEP Call Alternatives in 2007

                                            (million 1990S)

Regulator)

Alternative

0 12 Trading

60%''S5.00n

0 1 5 Trading

60%/$5.000

Regionaht} 1

60%/S5 000

0 20 Trading

60%/S5.000

025 Trading

60%.'S5.000

Quantified Net Benefits—

"Low" Assumption Set

$760

($5601

($262)

(S~4;

(SI 48)

Quantified Net Benefits—

"High" Assumption Set

$3345

$2.510

$2.057

$2.313

$2.046

' Calculated as quantified benefits minus costs Not all possible benefits are quantified and moneti/ed in this anaK sis Potential benefit categories that

    not been quantified and monetized are listed in Table 4-2 in Chapter 4 of this \olume of the RI A.

5.4     Limitations to the Benefit-Cost Comparison



        Cost-benefit anaKsis pro\ ides a  \ aluable framework for organizing and e\ aluating information on

the effects of em ironmental programs  When used proper!). cost-benefit anaK sis helps illuminate important

potential effects of alternative policies  However, not all potential costs and benefits can be captured in am

anaK sis. and there always the issue of hou much technological changes will lower future pollution abatement

costs, or change the nature of compliance actions b> the regulated community over time  EPA is general!)

able to estimate reasonably well the costs of pollution controls based on toda\ "s control technology and

assess the important impacts when it has sufficient information for its analysis  EPA is developing an

increasing abiht>  to estimate benefits associated with changes in emissions, but EPA believes that there are

mam important benefits that it can not quantify or monetize that are associated with the NOx  SIP call,

including many health and welfare effects  Potential benefit categories that have not been quantified and

monetized are listed in Table 4-2 in Chapter 4 of this volume of the RIA and should be remembered in

comparing the above quantitative benefits



        Several other important limitations deserve to be mentioned:



        •        The state of atmospheric modeling is  not sufficiently advanced to provide a workable ''one

                atmosphere" model capable of characterizing ground-level pollutant exposure for all

                pollutants of interest (e g.. ozone, paniculate matter, carbon monoxide., nitrogen deposition,

                                               Page 5-3

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 etc)  Therefore. EPA must emplo> several different pollutant models to characterize the

 effects of alternative policies on relevant pollutants  Also, not all atmospheric models have

 been widely validated against actual ambient data  In particular, since a broad-scale

 monitoring network does not yet exist for fine paniculate matter (PM: 5). atmospheric

 models designed to capture the effects of alternative policies on PM-, 5 are not fully validated

 The Agenc\ has chosen the best available models for the application needs of this RJA and

 tried to make the most reasonable assumptions possible in using them for predicting air

 quahu changes Limitations are noted in appropriate areas of the RJA



 There are limitations in some aspects of the data that are available to perform these analyses

 These limitations have been identified along the way in this RJA While they exist. EPA

 behe\ es that it has used all models and assumptions in this analysis in a reasonable way

 based on the a\ ailable e^ idence  Qualitative and more detailed discussions of the above and

 other uncertainties and limitations are included in the analysis  Where information and data

 exists, quantitative characterizations of these uncertainties are included  An illustrative

 example of ho\\ one aspect of uncertaintx can be quantified is pro\ ided in Appendix A of

 Volume  2  However, data limitations pre\ ent an o\ erall quantitatn e estimate of the

 uncertainfA associated \\ith final estimates  Nevertheless, the reader should keep all of these

 uncertainties and limitations in mind \\hen reviewing and interpreting the results



 Another dimension adding to the uncertainty of the results is the potential for pollution

 control inno\ ations that can occur o\ er time  For the NOx SIP call. EPA expects that the

 most significant costs of this regulation (i e . the costs associated with installation  and

 operation of NOx pollution control equipment at coal-fired electricity generating units

 throughout the SIP call region) \\ill occur b> May 2003   The Agenc\ is a\\are of some

 mno\ ations that equipment \ endors are considering now for application at some units before

 200? that are not part of the cost anah ses presented in Volume  1 These mno\ ations

 include the possible use of SCR and SNCR in h\bnd technologies, or improved combustion

 controls  be\ ond what  \ endors ha\ e installed in the past that could be used with and without

 the addition of post-combustion control technolog}  It is impossible to anticipate exacth

 ho\\ much of an impact, if am. these ne\\ technologies ma\ ha\e in lowering the compliance

 costs for the NOx SIP call in the future  Their possible influence can onh be recognized



 There is  also the uncertainty  o\er future costs due to the flexibility afforded b\ an emissions

 cap-and-trade program that EPA is encouraging the States to set up under this rule  The

 anahsis that EPA has completed to date has been fairh consen ati\ e—the anah sis  of the

 electric power mdustn, and large industrial boilers and combustion turbines assumes these

 sources operate under separate trading programs  In realit}. the\ should enter the same

 trading pool and there should be greater efficiency resulting from their ability to trade NOx

 emissions allowances with each other  There is also the possibility of unforeseen innovation.

 which a cap-and-trade program fosters, since it allows the regulated community to  work out

 the best approaches to future compliance  Therefore, the Agency believes that its cost

 anahsis is a reasonably conservative estimate of the future compliance costs that will occur

 if States enter into the trading program that the Agency has described in the Model NOx

 Budget Trading Rule as part of the NOx SIP call rule   If some States do not enter the

program, any inefficiencies that result for the regulated community in those States should not

be viewed as a cost of this rule

                               Page 5-4

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        Despite the abo\ e limitations and uncertainties. EPA behe\ es that the analysis pro\ ided in this report

pro\ ides the Agenc\ with a basis for believing that in the year 2007. benefits resulting from the regulator}

alternatnes that EPA anahzed for N0\ SIP call \\ill be up to t\\o and one-half times costs

5.5     References



US  Em ironmental Protection Agenc\. 1997  Proposed Ozone Transport Rulemalang Regulatory

Analysis  Office of Air and Radiation. Washington. D C September. 1997

                                             Page 5-5

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          APPENDICES



             to the



REGULATORY IMPACT ANALYSIS

FOR THE NOx SIP CALL, FIP, AND

         126 PETITIONS



Volume 2: Health and Welfare Benefits

 image: 

















     Appendix A.  QUANTIFIED UNCERTAINTY IN HEALTH AND WELFARE BENEFITS

A.I     Over\ie«



        Chapter 4 presents point estimates of the monetan benefits associated with each health and welfare

endpomt  For most endpomts. an estimate of the statistical uncertainU range based on measured \ariabihu

in the underh ing health effects and \ aluation components of the anah sis can also be computed  UncertainU

regarding other aspects of the anah sis (such as emissions and resulting air qualm) is not included in the

uncertainU anah sis. resulting in a likeh underestimate of the o\erall uncertainU of the monetized benefits for

each categon



        The t\\o sources of uncertainU that are quantified in the NOx SIP call benefits anahsis are the

uncertainU about  the concentration-response functions (and thus about changes in incidence) and the

uncertainU about  mean \\ilhngness to pa\  for each unit change in incidence (i e . unit dollar values)  The

total dollar benefit associated with a gn en endpoml depends on how much the endpomt will  change  if a gu en

NOx SIP call alternatnc is implemented (e g . ho\\ mam premature deaths will be a\oided) and hov* much

each unit of change is \\orth (e g . ho\\ much a premature death a\ oided is \\orth)  Not all endpomts ha\ c

quantified uncertainU  for both the concentration-response function and \aluation function



        The uncertainU about each component is characterized  b\ a distribution of \ alues that the

component might  ha\e This distribution is essential!} a Ba\esian posterior distribution, based on the

a\ailable information  A distribution of possible incidence changes  and a distribution of possible unit dollar

\ alues for each endpomt is constructed from available information whenex er possible  The uncertainU about

the true  incidence  change (or the true unit dollar \ aluc) for a gn en endpomt is expressed as a 90 percent

credible mten al  This is the inten al from the fifth percentile point to the nmeU -fifth percentile point of the

Ba\ esian posterior distribution of incidence changes (or unit dollar values) for that endpomt  The 90 percent

credible mten al is a "credible range" within which, according to the available information (embodied in the

Ba\esian posterior distribution of possible \alues). the true \alue lies with 90 percent probability



        The uncertainty surrounding estimates of total monetan benefits for each endpomt is similarh

characten/ed b> a distribution of possible  \alues. the fifth and nmeu-fifth percentile points of \\hich

comprise the 90 percent credible intcnal of total monetan benefits for the endpomt  The distribution of total

monetan benefits for an endpomt is generated from the distribution of incidence changes and the distribution

of unit dollar \ alues for that endpomt. using Monte Carlo techniques  In this procedure, on each of mam

iterations, a \ alue is randomh drawn from the incidence distribution and a \ alue is randomh drawn  from the

unit  dollar ^ alue distribution, and the total dollar benefit for that iteration is the product of the t\\o !  If this is

repeated for mam (e g . thousands of) iterations, an estimate of the distribution of total dollar benefits

associated \\ith the endpomt is generated2  The mean of this Monte Carlo-generated  distribution is presented

as the point estimate of total monetan benefits for the endpomt  As the number of Monte Carlo draws gets

larger and larger, the Monte Carlo-generated distribution becomes a better and better approximation to the

        1 This method assumes that the incidence change and the unit dollar value for an endpomt are stochasticalh

independent



        : To improxe computer efficienq. a Latin Hvpercube technique is actual!)  used for the incidence change

distribution \\hen implementing all phases of the Monte Carlo anahsis



                                              Page A-1

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undcrh me Ba> csian distribution of total monetan benefits  In the limit, it is identical to the underh ing

distribution, and its mean, presented as the point estimate, is identical to the mean of the underlying

distribution of total monetan benefits for the endpomt



        The distributions of unit dollar \ alues for those health and welfare endpomts considered in this

uncertaint} anahsis. and the means of those distributions, are gi\en in Table A-l bekrn  In addition, the

means and 90 percent credible mtenals (the fifth and nmet>-fifth percentile points of the distributions of

possible \alues) of axoided incidences and the corresponding means and 90 percent credible intervals of total

monelan benefits associated with these endpomts can be found  in the results technical support document

(Abt Associates. 1998a)

A.2     Underlying Sources of Uncertainty



        For most health endpomts (with the exception of o/.onc-related mortality  and short-term PM-related

mortaht) ). the concentration-response function is obtained from a single epidemiological stud\  For all of

these studies, the uncertain!) about the unknown parameter in the concentration-response function is

characten/ed b\ a normal distribution \\ith mean equal to the estimate of the parameter \ alue reported in the

stud\ and standard de\ lation equal to the standard error of the estimate reported in the stud>  To the extent

that a\ oidcd incidence is a linear function of this concentration-response function parameter, the distribution

of a\oided incidence \\ill also be normalh distributed "



        For o/one-rclated  mortality and short-term PM-related mortaht>.  the distribution of incidence

changes is based on a pooling of the information in se\eral concentration-response functions  In the case of

short-term PM-relatcd mortaht) . the  input components to the concentration-response (C-R) functions

estimated in the studies (e  g . functional forms, pollutant a\eragmg times.  stud\ populations) are all the same

or \er\ similar, so that a pooled, "central tendcncx" C-R function can be dcrned from multiple stud} -specific

C-R functions  For o/onc-relatcd mortalit). ho\\c\er. the pollutant a\eragmg time is not the same across all

studies  Some of the four studies measured daih  1-hour maximum o/one  concentrations while others

measured daih  (or some other) a\erage ozone concentrations It is therefore not possible to pool the C-R

functions to dern e a central tendenc)  "pooled" C-R function for oxone-related mortality  Instead, using the

o/one data appropriate to each stud) (cither one-hour daih maxima or daih a\erages).  national ozone

mortalin  incidence distributions are dern cd corresponding to the C-R function from each stud\. and these

stud\ -specific national incidence distributions are then pooled  That is. the pooling of results is done in

"national incidence space" rather than in "ozone coefficient space " For a more detailed discussion of the

methodology of pooling results  from studies, see the  report titled Selected Health and Welfare Benefits

Mcihoch for the \()x SIP Call RIA (Abt. Associates. September 1998b)



        Construction of distributions of unit dollar \alues. or mean willingness to pa\ (MWTP) for a case

a\ oided. is often not as straightforward to describe  Estimates of MWTP  can be complicated functions of

estimated parameters, for \\hich information about the statistical distributions are not a\ailablc in published

studies  The assumed distributions for MWTP for each endpomt are listed in Table A-1  For a more

complete description of the underlying studies and derivation of the distributions of MWTP. see Chapter 4

and the benefits technical support document (Abt Associates. 1998b).  For some endpomts. while uncertainty-

is recognized and a range of possible \ alues is a\ ailable. there is insufficient information to construct

        •' The concentration-response functions are almost linear functions of the parameter



                                              Page A-2

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                                             Table A-l

                 Point Estimates and Assumed Distributions of MVVTP for Health and

                           Welfare Endpoints in the NOx SIP Call Anahsis

Endpoint

Mortalm

Chronic hi onchitis

URS (as defined b\ Pope el al .

199H

LRS (as defined b> Sehuart/ el al

1994)

"Presence of an\ of 1 l) acute

respiraton s\mptoms"

Acute Bronchitis

Minor Restricted Aeti\ m Da\ s

(MRADsi

V\'ork Loss Da\s

V. orker Pi oducln it\

Yisibihu - Residential

Visibihn - Recreational

Consumer Cleaning Cost Saungs

Point Estimate of MWTP

$4.800.000

$260 000

$19

$12

S18

$45

$38

$8?

SI \\orker 10°-(, change in O,

$14 per unit change in d\

$6 50 per unit change in d\

dn-region)

$4 per unit change in d\

lout-ol'-region)

$2 52 per ug;m' change in

PM.o per household

Derived Distribution of the Estimate of

MWTP (1990S)

A Weibull distribution. Std De\ = $3 24

million

A Monte Carlo-generated distribution.

based on three underh ing distributions, as

described in the technical support

document

Continuous uniform distribution oxer the

mtenal [$7 00. $32.72]

Continuous uniform distribution over the

mtenal |S52?,$1857J

Continuous uniform distribution o\er the

mtenal [SO 00. $36 62]

Continuous uniform distribution o\er the

mtenal [$13 29. $"1674j

triangular distribution centered at $38 3"

on the mtenal [SI 5 "2. $61 02]

N A a

N A

Triangular distribution centered at $ 1 4 on

the mtenal [SS. $21)

Normal distribution \vith std de\ equal to

0 42 (m-region) and 0 10 (out-of-region'i

Beta distribution \\ith. std de\ =$1 00 on

the interval [$ 1 26. $ 1 0 08] The shape

parameters of this distribution are cc=l 2

and P=7 3

"N \ indicates that a distribution is not a\ ailahk

                                               Pase A-3

 image: 

















anything other than a uniform distribution of unit dollar \alues. \\hich assumes that each point in the range is

equalh hkeK



        For agricultural, forestn. and nitrogen deposition benefits, there are no distributions or ranges of unit

\ alues a\ ailable  Variation in the endpomts occurs due to changes in the underlying assumptions in the

models generating the benefit estimates, i e  sensitnity of cultnars to ozone for agricultural benefits  Thus.

for these endpomts. uncertainty ranges are not reported  Sensitn it> to changes in the underly ing assumptions

can be examined through the plausible range approach, \\here assumptions can be grouped to form a range

\\ith lo\\ and hmh estimates

A.3     Quantified Uncertainty for Ozone-related Benefits



        The quantification of the uncertainty about the magnitude of the ozone mortality relationship is a

\er\  important issue in the economic benefits estimation  While the growing bod) of epidemiological studies

suggests that there in a positn e relationship bet\\ een o/onc and premature mortality. it is still unclear \vhether

the apparent o/onc effect on mortality is real  There is a di\ersit>  of published results and substantial

measured uncertain!.) \\ithin each stud)   This high degree of uncertainty has lead to some countenntuitn e

"results "  Based on the meta-anah sis generated distribution of a\ oided o/.one-related cases of premature

mortalit) corresponding to the NOx SIP call estimated future air qualit). there is approximate!) a 13 percent

probability  that there is a negatne relationship betueen o/one exposure and premature mortalit) (i e . that

ele\ ated o/one prevent premature mortalit) )  This "result" should be interpreted \\ith caution. ho\\e\er  It

is biologically implausible that ele\ated o/one lc\els are beneficial to human health  The portion of the

estimated incidence change  distribution in the negatne range is most like!) the result of random error in the

estimation of the o/one coefficients in concentration-response functions and/or the result of modeling

misspccification (the underl)ing models do not pre\ent negatne results apnon. and the estimated

coefficients are  asymptotical!) normal, \\hich results in a negatne lo\\er tail of the distribution)  B\

construction, the meta-anah sis distribution incorporates both bet\\een-location \ anabilit) and \\ithin-

location sampling error  As more studies become a\ ailable. and. in particular, as neuer studies incorporate

information from longer periods of time and therefore ha\e results based on more obsen ations. the sampling

error component of the meta-anahsis distribution \\ill decrease  As this occurs, the mcta-anahsis

distributions \\ill better approximate the underhing distributions of \\hich the)  are estimates, and the

portions of the distributions in the negatne range are likcl) to diminish according!)

A.4     Quantified Lncertainty for PM-related Benefits



        For household soiling damage and visibility, no point estimates or distributions are presented for

a\ oided incidences  This is because PM-related household soiling is direct!)  \ alued on a per household basis.

rather than measuring some unit of incidence (such as hours lost) and multiplying b\ a ^ alue per unit

Visibility is \ alued on a constant percentage decivie\\ change per household,  so there are no avoided

incidences  The correct unit measure is percent change in decivie\\. which is  then input into a \ aluation

function to get \ alue per household, which is then summed over all households in the NOx SIP call region

Thus, uncertamt)  is measured m the \ aluation stage, but not in the generation of changes in visibility

                                              Page A-4

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A.5     Statistical I ncertaint> and Plausible Ranges



        The tables of benefit estimates presented in Chapter 4 represent monetan benefits estimates for fi\c

NOx SIP call regulator* altematncs under the "Lou" and "High" sets of assumptions regarding the PM

threshold lex el. o/one mortality. agricultural benefits, and the PM air quahh model  Benefits estimates

associated \\ith the "High" and "Lo\\" assumption sets  \\a\e corresponding statistical uncertainty ranges as

well. \vith 5d  percentile. mean, and 95!h percentile estimates of benefits  As discussed in Chapter 4. the range

of \alues from the mean of the "Lo\\" assumption set to the mean of the "High" assumption set represents a

"plausible range" across the different assumptions  Ho\ve\er. this range does not prc>-\ ide information on the

likelihood of am set of assumptions being the correct one  Thus, while the plausible range indicates the

sensitivih of benefits to the \ arious assumptions, it does not express the uncertainty associated with am

particular benefits estimate  To understand the uncertaint} associated with a particular estimate, it is

nccessan to kno\\ both the underh ing assumption set and the statistical distribution around the estimate

determined b\ the \ anance of the underK ing concentration-response functions and \ aluation functions

A.6     References



Abt Associates. Inc  1998a  Benefit Analyse Results of Selected Health and Welfare Endpomts for the .\'Ox

SIP Call RIA. Prepared for the U S  Em ironmental Protection Agency. Office of Air Quaht> Planning and

Standards. Research Triangle Park. N C . September



Abt Associates. Inc  1998b  Selected Health and Welfare Benefits Methods for the NOx SIP Call RIA.

Prepared for the U S  Em ironmental Protection Agcnc\. Office of Air Quaht\ Planning and

Standards. Research Triangle Park. N C . September

                                              Page A-5

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       Appendix B.  SUMMARY OF POPULATION-WEIGHTED AIR QUALITY METRICS

        This appendix summan/es the predicted air quahh  changes used in the benefits anahses for this

R1A. \\eightcd b\ population  The population-weighted air quahn changes arc calculated for se\eral

"metrics." or measures of air quality based on results of the air quaht> modeling described in Chapter 3  For

o/one. these metrics include 1 -hour and 8-hour a\ erage concentration predictions above the level of the

respecmc health standards  For PM. the metrics include annual mean PM,, and annual mean PMK,

predictions abo\ e the le\ el of the respective health standards  The metrics are calculated for the total

population and for \arious subpopulations. including minority groups (represented b> the Census Bureau's

"non-\\hitc" category ). the eldcrh (65 years of age and older), children (under 18 \ears old), and the lo\\

income group (1990 annual income under $ 13.359 for a famih of 4) The air quality changes co\ er the entire

area of each modeling domain, data is presented for the entire modeling domain (37  States & D C ) and for

the SIP Call region states  The population-weighted metric for modeled \ isibiht\ degradation is presented in

Chapter 2. Section 2 6. rather than in this appendix  A population-weighted metric is not calculated for

modeled nitrogen deposition changes  Additional detail on all population-weighted metrics can be found  in

the report titled Air Quality Estimation Jor the \()x SI]' Call RIA (Abt. Associates. September 1998)

                                              Table B-l

               2007 Population-Weighted Sum of 1-Hour O/one Predictions Abo>e 124 ppb":

                               Adjusted and Extrapolated LAM-V Results

Population

Percent Change from Base Case

0.25

Trading

0.20

Trading

Regionally

1

0.15

Trading

0.12

Trading

SIP Call States

Ali Population*.

Xon-\\!i;;c

Undei IS

65 and o\ei

I.o\\ Income

-5('9

-4S 9

-50 "

-492

-585

-63 0

-61 6

-62 8

-ol 3

-69 0

-66 6

-64 (i

-66 2

-65 5

-71 4

-69 4

-6~ 8

-69 2

-684

- ' ^ i

-~3 9

-"3 7

-738

-73 1

-780

37 States & D.C.

All Populations

Non- White

Under 1 8

65 and over

Lou Income

-192

-147

-17 3

-25 1

-183

-24 1

-189

-21 7

-31 5

-22 1

-253

-195

-228

-335

-227

-260

-147

-173

-25 1

-183

-27 3

-21 4

-245

-366

-236

 1 he 1 -hour ozone standard allou s an a\ erage of 1 exceedance abo\ e 120 ppb (rounded to the nearest ppb) o\ er a 3 \ ear period This analysis does

not predict three \earj. uorth of air qualify, and is therefore nol direct!) comparable lo the official standard

                                              Page B-1

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                                                       Table B-2

              2007 Population-NX eighted Sum of 8-Hour A^ erage Ozone Predictions Abo\ e 84 ppbj:

                                     Adjusted and Extrapolated L'AM-V Results

Population

Percent Change from Base Case

0.25

Trading

0.20

Trading

Regionally

1

0.15

Trading

0.12

Trading

SIP Call States

All Populations

Non-White

I'ndei IS

65 and o\c;

Lo\\ Income

-31 0

-268

-31 4

-?" S

-38 S

-399

-354

-40 3

-39"

-48 3

-44 0

-395

-443

-43 9

-54 3

-468

-42 3

-4" 2

-46"

-56 "

-51 0

-468

-51 5

-50 9

-604

37 States & D.C.

All Population-

N'on- White

I'nde; IS

65 and o\ e'

I.o\\ Income

-24 I

-20 d

-2? 6

-260

-IS?

-3! 2

-26 4

-304

-33 6

-22 1

-34 3

-29 3

-33 3

-3" 2

-) ~i ~

-36 5

-31 4

-35 5

-39 5

-225

-39 6

-34 6

-38 5

-429

-23 6

 I he 8-hour o/one M.ind.irci ol S(° pph irounded to the nearest ppb i i^ based on each \ear s 4th hiehc^t dail% ma/imum S-hour axcraee o/onc

con^entraiior a\ craved ON ei a 3 war period Ihi-- anaKM*- doe- not predict three \ear- \\orth of air qualiU. and n therefore not direct 1\ comparable to

tht. olTieial ^tan^^rd

                                                       Page B-2

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                                                       Table B-3

             2007 Population-Weighted Sum of Annual Mean PM;5 Predictions Abo've 15.04

                                                      RPM Results

Population

Percent Change from 2007 Base Case

0.25

Trading

0.20

Trading

Regionally

1

0.15

Trading

0.12

Trading

SIP Call States

All Populations

Xon- White

Undei 18

(o and o\cr

I,o\\ Income

-46

-45

-46

-4 5

-5 4

-60

-60

-60

-5 9

-87

-68

-65

-68

-68

-11 4

-6~

-63

-68

-6 5

-62

-14 5

-148

-145

-143

-19 1

37 States & B.C.

All Population-.

Non-White

I'ndcr IS

65 and o'\er

Lo\\ Income

-3 0

-3 8

-3 0

-28

-44

-4 1

-5 1

-4 1

-3 9

~~ ~>

-4 5

-5 5

-4 5

-4 4

-93

-46

-5 4

-46

-4 3

-5 2

-100

-128

-99

-95

-159

8 The PM_. annual mear ^landard o! 1 5  g m' (rounded to ihc neaicst 1  ] Oth i a\ craned o\er a ^ \ ear period  1 his anal\Ms i> nol based on an

evien^ne network ol actual P\i_,  oh^jnation*- and dtt*.^ nol predict ihree \ears \\orlh ol ajr qualiT\. and i^ therefore not directl\ comparable to the

ofllcia! standard

                                                        Page B-3

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                                                        Table B-4

              20(17 Population-Weighted Sum of Annual Mean PM,0 Predictions Abo\e 50.-I //g/m3 a:

                                                     RPM Resultsb

Population

All Populations

Non-While

Under IS

(o and o\c;

1 ou Income

Percent Change from Base Case

0.25

Trading

-00

-fj 0

-00

-00

-00

0.20

Trading

-00

-00

-oo

-(,0

-0 0

Regionally

1

-00

-o o

-00

-0 0

-00

0.15

Trading

-00

-00

-0 0

-0 0

-0 0

0.12

Trading

-00

-00

-00

-0 0

-00

' Tlu P\l.  annual mean Mandard ol 50 . g m' i rounded U> the nearer . g) a\eraged o\er a ^ \ear penod  Ihi-. anaK^i-- doe^ not predia thiee \i.

\\onh o! air quahu  and is therefore no! dueclK wompa^ahle to the official -.tandard

  111 Kvations ha\e predietioiT- helou the PMKi standard hence there are no reduction1- in e\po-;ure<- relatne a 50 ug nr annual mean threshold

                                                       Page B-4

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              Appendix C. EMISSION SUMMARIES FOR BENEFITS-RELATED

                                 AIR QUALITY MODELING

       This appendix presents emissions summaries rele\ ant to the air qualm modeling that is used as an

input to the benefits anah ses co\ ered in Chapter 3 The tables in this appendix contain summary emissions

estimates for the entire modeling domain, not just the area co\ered by the SIP call rule  Table C-l contains a

summaiA  of the ozone season NOx emissions used to drive the regional-scale ozone prediction model. UAM-

V  Tables C-2 through C-5 present summaries of the warm and cold season emissions of NOx and SO. used

to drive the secondan PM prediction model. RADM-RPM Tables C-6 and C-7 contain summaries of NOx

and SO- emissions used to dm e the secondan PM prediction model. S-R Matrix Fmalh. for compansion

purposes. Table C-8 presents the emissions associated with the cost anahses for EGU and non-EGU sources

presented in Volume 1 of the RIA  Each of these tables presents the emissions for each regulators alternate e

for which benefits estimates are de\eloped

                                           PageC-1

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                                   Table C-1

   O/.onc Season Dailv NO\ Kmissions l>v Major Sector and Regulator) Alternative:

                                HAM-V Inputs

Major Sector

IX 11 I Poml Sources

Non-IXrU I'oint Sources

2007 Base Case

2.25S 112

MM. 177

0.25 Trading

1 (idd 001

()()S,7I7

0.20 Trading

1.4V) Sh')

X40694

Reg. 1

1.17<S.OXX

1,101,7X4

0. 15 Trading

1,2-=.! VI')

X40.694

O.I 2 Trading

1.1 'IS XOV

X'l(l(i<).|

                                   Table C-2

Warm Season Annuali/cd IMO\ Emissions l»> Major Sector and Regulatory Alternative:

                              RADM-RPM Inputs

Major Sector

I'XHJ I'oint Sources

Non-l'XHJ I'oint Sources

2007 Base Case

4,')S').()4!

7.9IX.<)4X

0.25 Trading

1.70X,4l>S

6.175.17.1

0.2(t Trading

!.257,42(>

5.424.5X2

Reg. 1

1,075.07')

5.244.24X

0.15 Trading

2,81 1,652

4.XXO.X52

0.12 Trading

2.568,2.15

4,742,169

                                   Table C 3

Warm Season Annuali/,ed SO, Kmissions 1>> Major Sector and Regulators Alternative:

                              RADM-RPM Inputs

Major Sector

I'XHJ Point Sources

Non-IXHJ Point Sources

2007 Base Case

10,4.57 .8-10

14.100,5X2

0.25 Trading

10. 196, 5X7

14,271.520

0.20 Trading

10.400,771

14.041.149

Reg. 1

10.19x291

14,017.691

0.15 Trading

10,115,766

11,958,1X5

0.12 Trading

i 0,071.X 15

11.715,866

                                    Page C-2

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                                  1 able (-4

Cold Season Annuali/,ed NO\ Kmissions by Major Sector and Regulatory Alternative:

                             RADM-RPM Inputs

Major Sector

1'X'rU Pomt Sources

Non-1 i(HJ Point Sources

2007 Base Case

•J.S60.9M

7/l8l.ln9

0.25 Trading J 0.20 Trading j Reg, 1

•1 IS |.| 47

6,(>00.}25

• 1 151 643

6 300 4X9

LI SO 23(,

6.29X.746

0.15 Trading

4.I4X7SI

6 2V7.002

0.1 2 Trailing |

-I I "') "iX"?

d.2XX.2'.>')

                                  Talilt- C-5

Cold Season Annuali/ed SO, Kmissions In Major Sector and Regulatory Alternative:

                             RADM-RPM Inputs

Major Sector

I'XHJ Point Sources

Non-1 'X!U Point Sources

2007 Base Case

1>.()XO,7'H

13.623.675

0.25 Trailing

10.100.2X7

nj.n,oss

0.20 Trading

10,1 16,509

M, 759. 3X5

Reg. I

10.156 XX4

n,775.3S3

O.I 5 Trading | O.I 2 Trading

io.nx.9xx

H. 79 1,381

10, 204, 3 IX

I3,X47,!47

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                           Table C-6

Annual NO\ Emissions h\ Major Sector and Regulators Alternative:

                       S-R Matrix Inputs

Major Sector

1'Xil ) Point Sources

Non-1 •.(HI Point Sources

2(107 Base Case

4 8(v| Xh')

1,141,0X0

0.25 Trading

1 nx1). 7S(.)

2.172.24X

0.20 Trading

i <)02.UH

2.172 24X

Ri'K- I

l.X2(O(,()

2.372.24S

((.ISTradinj-

\715.75I

2.W2.2.IX

O.I 2 Trading

Tf.l 1,(-7I

2."?72.2'I8

                           Table ( -7

Annual SO, Emissions b> Major Sector and Regulators Alternative:

                       S-R Matrix Inputs

Major Sector

1'XiU 1'oint Sources

Non-1 'XilJ Point Sources

2(K>7 Base(ase

10,277.251

\7n.552

0.25 Trading

10.121. 1S^

"?. 711.552

0.20 Trading

10 112,1X4

\711.SS2

Reg. 1

I0.isi.dl5

\7n.552

O.I 5 Trading

I0.10l).')|4

3,711,552

0.12 Trading

10,247.11 1

1,71.1.552

                           Page C-i

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         Appendix D.  NONLINEAR CHEMISTRY AND FINE PARTICLE PRODUCTION

        E\ aluating the effect of major reductions m emissions of nitrogen oxides on particles in made more

difficult because N0\ pla\s an important role in the atmospheric chemistry including formation of nitrate.

organic, and sulfate particles The extent to \\hich Nox reductions reduce fine particle le\els is dependent on

a number of factors that \ an. \vith time and location, including the  concentration of ke> reactne gases and

particles, as well as emissions and meteorology   The following discussion pro\ ides some background on the

nature of these chemical reactions as a basis for understanding the  rele\ ance of non-linear modeling results



D.I     Background



        The h\ dro\\ 1 radical. OH. is a major oxidi/ing specie in the atmosphere  The largest single source of

OH is the breakdown of ozone. O3. b\ ultra\ lolet light in the presence of \\ atcr  Clearh. reduction of NOx

can affect the production ofo/one and OH radical in particular locations Sulfate. a major component of fine

particles, is formed b\ the oxidation of SO- through t\vo main path\\a\s gas-phase oxidation and aqueous-

phase oxidation (in \\ater droplets)  Sulfate is formed in the gas phase b\ oxidation of SO: b> OH  This

process  does not use up OH. b\  and  large, so a change in SO- produces approximate!} an equnalent change

in S0:  Also, an incrcasc'decrease in OH \\ill cause an increase/decrease in gas-phase produced SO4



        Sulfate (SO,) is also formed in the aqueous phase in cloud droplets  This occurs b\ comersion of

SO- b> h\drogen peroxide. H-0-. and O-,  The \ast proportion of the aqueous-phase S0: is produced b\

H-0- for eastern North American conditions  This process does use up oxidants  If SO- is \ cry high, then

there can be oxidant-hmited conditions, i c . the nonhncarit\ that \\as of concern in NAPAP with respect to

the cffectn eness of acid rain controls  Under oxidant-hmited conditions, the production of SO, \\ill be

mosth determined b\ the a\ ailabihn of the oxidant. not b>  the a\ ailabihty of SO-  Modeling anah sis with

RADM  estimates that a majority of the eastern L S  sulfate  comes  from the aqueous-phase oxidation of

sulfur dioxide, the second  path\\a\



        Nitric acid. HNO,. the precursor to aerosol nitrate, in formed b> N0; combining with OH The

formation of HNO, is a termination reaction and uses up both OH  and NO-  This reaction is part of the

photochemical process that accounts for the production of O,



        The radicals that arc produced during am one da> all disappear or terminate during that da> in a

matter of tens of minutes  Production equals termination in the photochemical process  There are t\\o

important path\\a\s of termination that are in constant competition

        a) OH combines \\ith NO-, taking out one radical  If there is a lot of NOx around, this pathwa\ out

        competes and inhibits the a\ailabihh of radicals b\ taking so mam OH's out of the action so

        quickly If NOx is scarce, then this pathwa> cannot compete as well and a second termination

        path\\a> becomes most important

        b) In the second mam termination path\\ay. OH combines \\ith itself, to form H-O;. hydroxy radicals

        combine with perox> radicals to form organic peroxides  Two radicals are taken out



        The relatn e fraction of nitrate that exists in the particle phase (as opposed to vapor phase nitric acid

or ammonium nitrate) depends in turn upon the relatne concentration of acid sulfate species and ammonia

In areas \\ith high acid sulfate concentrations (e g the eastern U S. in the summer), nitrate tends to occur in

the vapor phase and reductions of NOx emissions could not result  in a large reductions in fine particle

nitrates   Where sulfate le\ els are much then nitrate particle le\ els  would be higher



                                             PageD-1

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D.2    \\ hat this means for NOx Emissions and Sulfate



       In urban areas with rclatnch high NOx emissions radical formation and propagation is inhibited  If

NOx emissions are reduced b\ small to moderate amounts. O3 and OH \\ill increase  Note, the response for

a\ erage 0-. can be different than the response for peak O,  If S0: is a^ ailable. then \\here the OH increases.

an increase in the amount of S0; \\ill be oxidized to S0.; in the gas phase  This produces a "nonlinear"

response in S>Q. (increase) to a reduction in NOx



       In rural areas \\ith relatneh models NOx le\els. O3 and OH \vill decrease \\hen NOx is reduced

Percentagewise, the decrease m O, and OH v>ill less than NOx and NO- The ratio of OH  to T\O: \\ill

therefore increase and more of the OH budget \\ill terminate as H:O; This ma\ or ma\ not lead to an

increase in H-O-   In the RADM simulations there \\as an increase in H:O; in certain areas, especially o\er

Ohio and western Pcnns\Kama  If there is excess S0:. then \\here H:O- increases, in increased amount of

S0: \\ill be comerted to SO, in the aqueous phase   This produces a ••nonlinear" response  in SO4  The larger

and more pen asn c source of the nonhneanU in these model results seems to be the change in H-0;

       The  projected relatue abundance of sulfatc \s  nitrate particles m future > ears depends upon

assumptions about the cffectneness of acid rain and as \et undecided strategies to  implement regional haze

and fine particle standards  Under the scenarios examined for this RIA. the sulfate le\ els \\ere high enough to

limit the amount of nitrate aerosol reduction that \\ould accompam a regional NOx reduction If. ho\\e\ er.

future strategies further reduced SOx emissions, the expected reductions in fine particles from NOx

reductions \\ould be  decided!) larger, and more linear  Because of the uncertainties in the atmospheric

chemistn for these future \ears. the RIA relies on modeling tools that estimate both linear  and non-linear

responses for PM reductions

D.3     Reference



Dennis. R L  Memorandum to Scott Mathias and John Bachmann. U S EPA Office of Air Quality Planning

and Standards from Robin Dennis. U S  EPA. Office of Research and De\elopment. September 17. 1998

                                             Page D-2

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                                    TECHNICAL REPORT DATA

                               (Please read Ins{mi.tic»is on reverse before completing)

 1  REPORT NO

   ITA-452/R-98-003ft

                                                                  3 RECIPIENT'S ACCESSION NO

 4 TITLE AND SI BTJTLE

 Regulatory Impact Analysis for the NOx SIP Call. FIP. and

 Section 126 Petitions

     Volume 1: Costs and Economic Impacts

     Volume 2: Health and Welfare Benefits

5 REPORT DATE

Volume 1: September 1998

Volume 2: December 1998

6 PERFORMING ORGANIZATION CODE

OAQPS/AQSSD

 7 AUTHORiS)

 Office of Air Quality Planning and Standards

 Office of Atmospheric Programs	

                                                                  8 PERFORMING ORGANIZATION REPORT NO

   PERFORMING ORGANIZATION NAME AND ADDRESS



   U.S. Environmental Protection Agency

   Office of Air Quality  Planning and Standards &

   Office of Atmospheric Programs

   Research Triangle Park. NC  27711

                                                                  10 PROGRAM ELEMENT NO

11 CONTRACT GRANT NO

 i: SPONSORING AGENCY NAME AND ADDRESS



   Director

   Office of Air Quality Planning and Standards

   Office of Air and Radiation

   U.S. Environmental Protection Agenc\

   Research Triansle Park.  NC  27711

                                                                   13 TYPE OF REPORT AND PERIOD COVERED

M SPONSORING AGENC1 CODE

EPA/200/04

 1?  SUPPLEMENTARY NOTES

 If ABSTRACT

 This report contains EPA's estimates of the annual costs and benefits of the final NOx SIP call and the

 proposed NOx FIP and CAA section 126 petition actions. The report also contains a brief profile of

 potentially affected sources and potential economic impacts.

17 KE^ WORDS AND DOCUMENT ANALYSIS

a DESCRIPTORS

Regulator}7 impact analysis: benefits-cost

comparison

18 DISTRIBUTION STATEMENT

Release Unlimited

b IDENTIFIERS OPEN ENDED TERMS

Air Pollution control

19 SECURITY CLASS (Report)

Unclassified

20 SECURITY CLASS (Page)

Unclassified

c COSATI Field Group



21 NO OF PAGES

22 PRICE

EPA Form 2220-1 (Re\. 4-77)   PREVIOUS EDITION IS OBSOLETE

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