&EPA
Unitsd Sla'cs
Environmental Protection
Combined National and State-level Health
Benefits for the Cross-State Air Pollution Rule
and Mercury and Air Toxics Standards
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EPA-452/R-11-014
December 2011
Combined National and State-level Health Benefits for the Cross-State Air Pollution Rule and
Mercury and Air Toxics Standards
By:
Office of Air and Radiation
U.S. Environmental Protection Agency
Washington, District of Columbia
and
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Health and Environmental Impacts Division
Research Triangle Park, North Carolina
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Introduction and Purpose of Analysis
This year EPA finalized two rulemakings requiring reductions of air pollutants from
electric generators (EGUs)—the Cross-State Air Pollution Rule (CSAPR) and Mercury and Air
Toxics Standards (MATS). Starting in 2012, the CSAPR requires 28 states in the eastern half of
the United States to substantially improve air quality by reducing power plant emissions of sulfur
dioxide (862) and nitrogen oxides (NOx) that cross state lines and contribute to fine particle
pollution (PM2.s) and ground-level ozone (63) in other states. MATS reduces emissions of toxic
air pollutants including mercury (Hg), arsenic, chromium, and nickel as well as acid gases
including hydrogen chloride (HC1) and hydrogen fluoride (HF) from new and existing coal- and
oil-fired power plants across the U.S. starting as early as 2015. As a co-benefit, MATS also
reduces SO2 and direct PM2.5 emissions and thereby reduces ambient PM2.5 concentrations.
While these rules have separate and distinct goals, cover different geographic areas, and
have different implementation timeframes, they are also similar in multiple respects: they affect
overlapping sets of electricity producers; they were finalized within six months of each other;
they will each substantially reduce exposure to air pollution and thereby improve human health
and welfare; and a majority of the quantified benefits of each rule is attributable to reductions in
PM2.5 resulting from SC>2 emission reductions. Given the similarities between these rules, EPA
estimated the national and state-level benefits of these rules combined, which will provide better
understanding of their cumulative human health benefits.
The regulatory assessments of the CSAPR and MATS differed in several respects. For
example, benefits for the CSAPR were estimated directly from air quality modeling of
anticipated emission reductions for the final rule while MATS benefits were estimated using
benefit per-ton (BPT) factors derived from a modeled interim policy scenario. The assessments
also differed in endpoints analyzed. Due to time and resource constraints, the CSAPR
assessment quantified only the health benefits of PM2.s and ground-level ozone reductions as
well as the welfare benefits of recreational visibility improvements and climate benefits of
carbon dioxide (CO2) reductions while the MATS analysis quantified only the health benefits of
PM2.5 reductions and the climate benefits of CO2 reductions. Additionally, the emission
reductions and health benefits were assessed for differing analysis years—2014 and 2016 for the
CSAPR and MATS, respectively. For more detailed information about the human health and
welfare benefits of each rule, as well as the inherent limitations and uncertainties in estimating
1 9
these benefits, please refer to their respective Regulatory Impact Analyses (RIAs). '
1 U.S. Environmental Protection Agency (U.S. EPA). 2011. Regulatory Impact Analysis (RIA) for the
final Transport Rule. Office of Air and Radiation, Washington, DC. lune. Available on the Internet at
.
2 U.S. Environmental Protection Agency (U.S. EPA). 2011. Regulatory Impact Analysis (RIA) for the
final Mercury and Air Toxics Standard (MATS). lune. Available on the Internet at
.
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Methods
In order to sum the benefits of the CSAPR and MATS, EPA needed to update the
CSAPR benefits to reflect the same assessment year as MATS. This required re-running the
benefits model (Benefits Mapping and Analysis Program (BenMAP3)) to assess PM2.5 and ozone
benefits for a 2016 assessment year. EPA did not update the visibility benefits or climate benefits
for the CSAPR.
Updating the benefits modeling affected two key parameters: population year and
projected income growth. These key inputs are important to the health impacts assessment
because the incidence of health impacts reduced, via reduced exposure to air pollutants, depend
on population exposure and because the valuation of health impacts avoided is sensitive to
income. Because EPA applies baseline incidence rates for premature mortality in 5 year
increments (2010, 2015, 2020, etc.), evaluating 2016 rather than 2014 does not change in
baseline incidence rates used to estimate incidences of premature mortality avoided.
While the purpose of this assessment is to evaluate benefits of the CSAPR in 2016, this
analysis is based on existing air quality modeling of emissions under the CSAPR in 2014. We
do not have emissions or air quality modeling to use as the basis for updating the air quality
information in the benefits modeling. However, EPA does not think that this is a significant
source of uncertainty because the state-level emission budgets for the CSAPR do not change
after 2014. While banking of allowances in 2012 and 2013 may impact the trend of emission
reductions over time, creating the potential for reductions in 2016 to be somewhat different than
2014, we expect EGU emission reductions in 2016 will likely be generally similar in aggregate
level and geographic distribution to 2014.
Limitations
This analysis is a screening-level assessment of the combined benefits of the CSAPR and
MATS and is limited in its inputs, methods, and results, which are fully described in the
underlying RIAs. These limitations include:
• This assessment accounts for PM2.5-related human health benefits for the CSAPR and MATS
and ozone-related health benefits for the CSAPR. Time and data limitations precluded the
inclusion of additional benefits that were quantified in the regulatory assessments of these
rules such as visibility improvements and greenhouse gas reductions. For a full list of human
health and welfare effects of pollutants affected by these rules, please refer to Table 5-2 in
the CSAPR RIA1 and Table 5-2 in the MATS RIA.2
• This analysis presents results at the state-level. We are confident, with respect to the
availability of necessary data at the state-level, in the estimation of state-level mortality
benefits. Due to the high proportion of total benefits attributable to the reduction in
premature mortality, we are confident in the total monetized benefits at the state-level.
3 Abt Associates, Inc. 2010. Environmental Benefits and Mapping Program (Version 4.0). Bethesda, MD.
Prepared for U.S. Environmental Protection Agency Office of Air Quality Planning and Standards.
Research Triangle Park, NC. Available on the Internet at .
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However, we are less confident in the estimation of morbidity benefits because the
assessment relies on national average baseline incidence rates. Additionally, we are more
confident in the state-level results for the CSAPR than MATS because, as described in the
MATS RIA, we did not perform air quality modeling for the final MATS scenario.
• As mentioned above, we used the available 2014 emissions and air quality modeling for the
CSAPR to update the benefits of the CSAPR for 2016. While we do not anticipate that this
is a significant source of uncertainty, we note that emission reductions in 2016 may be
different than 2014.
• The PM2.s-related benefits for MATS were derived through a BPT approach, which does not
fully reflect local variability in population density, meteorology, exposure, baseline health
incidence rates, or other local factors that might lead to an over-estimate or under-estimate of
the actual co-benefits of reducing ambient PM2.5.
• State-level results for MATS assume that the state distribution of health co-benefits for the
final policy is equivalent to that of the modeled interim scenario.
• This assessment relies on different methods for estimating the benefits of the CSAPR (air
quality modeling) and MATS (BPT). We used the BPT method to estimate MATS benefits
because EPA did not develop air quality modeling for the final rule. Due to the use of the
benefit per-ton method, there is more uncertainty with the state-level MATS results than for
the CSAPR, and the added uncertainty in MATS contributes to the summed uncertainty.
However, EPA does not anticipate that utilizing different methods will result in significant
uncertainty in the summed benefits.
• We assume that all fine particles, regardless of their chemical composition, are equally potent
in causing premature mortality. This is an important assumption because the health benefits
of these rules are primarily related to reductions of 862, a precursor to ambient PM2.5. PM2.5
improvements produced via reductions in transported precursors (862 and NOx) emitted
from EGUs may differ significantly from direct PM2.5 released from diesel engines and other
industrial sources, but the scientific evidence is not yet sufficient to allow differential effects
estimates by particle type.
• We assume that the health impact function for fine particles is linear within the range of
ambient concentrations under consideration. Thus, the estimates include health co-benefits
from reducing fine particles in areas with varied concentrations of PM2.s, including both
regions that are in attainment with the fine particle standard and those that do not meet the
standard, down to the lowest modeled concentrations.
Results
The results of this assessment show a very small increase in total health benefits
estimated for the CSAPR in 2016 compared to 2014. This increase is due to population growth
between 2014 and 2016 as well as increases in projected income. After re-calculating the
CSAPR PM2.5- and ozone-related benefits to reflect population and income growth for 2016, we
summed these results with the 2016 MATS PM2.s-related benefits to show the combined benefits
of these two rules. Table 1 below depicts the total quantified and monetized human health
benefits of the CSAPR and MATS as well as their combined benefits. Table 2 below presents
the estimated health impacts avoided due to CSAPR and MATS in 2016 at a national level.
Table 3 below displays the estimated health impacts avoided due to the CSAPR and MATS in
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2016 at the state-level (3% discount rate). This table includes incidences of premature mortality
avoided and the total value of all quantified and monetized mortality and morbidity benefits.
The range shows estimated PM2.s-related benefits using Pope et al. (2002)4 and Laden et al.
(2006)5 as well as ozone-related benefits using Bell et al. (2004)6 and Levy et al. (2005).7 The
state-level MATS results are reported in Appendix 5D of the MATS RIA.
Table 1: Total monetized human health-related benefits of CSAPR (2014 and 2016) and
MATS (2007$, billions)
CSAPR CSAPR MATS CSAPR & MATS
2014 2016 2016 2016
Pope et al. (2002) & Bell et al. (2004)
3% discount rate $110 $120 $36 $150
7% discount rate $100 $110 $32 $140
Laden et al. (2006) & Levy et al. (2005)
3% discount rate $270 $290 $89 $380
7% discount rate $250 $260 $80 $340
4 Pope, C.A., III, R.T. Burnett, M.J. Thun, E.E. Calle, D. Krewski, K. Ito, and G.D. Thurston. 2002. Lung
Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution. Journal of
the American Medical Association 287:1132-1141.
5 Laden, F., J. Schwartz, F.E. Speizer, and D.W. Dockery. 2006. Reduction in Fine Particulate Air
Pollution and Mortality. American Journal of Respiratory and Critical Care Medicine 173:667-672.
6 Bell, M.L., et al. 2004. Ozone and short-term mortality in 95 US urban communities, 1987-
2000. Journal of the American Medical Association. 292(19): p. 2372-8.
7 Levy, J.I., S.M. Chemerynski, and J.A. Sarnat. 2005. Ozone exposure and mortality: an
empiric bayes metaregression analysis. Epidemiology. 16(4): p. 458-68
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Table 2: Estimated health impacts avoided due to the CSAPR and MATS—incidences of avoided
health effects1 and value1 (millions of dollars, 2007$) of mortality and morbidity impacts
Health Effect
PM-related endpoints
£ Pope et al. (2002) (age > 30)
|3 3% discount rate
J 7% discount rate
Q Laden at al. (2006) (age > 25)
jk 3% discount rate
S 7% discount rate
18)
3% discount rate
7% discount rate
Hospital admissions — respiratory (all ages)
•g Hospital admissions — cardiovascular (age > 18)
ig Emergency room visits for asthma (age < 18)
*| Acute bronchitis (age 8 - 12)
Lower respiratory symptoms (age 7 - 14)
Upper respiratory symptoms (asthmatics age 9-18)
Asthma Exacerbation (asthmatics age 6-18)
Lost work days (ages 18-65)
Minor restricted-activity days (ages 18-65)
Ozone-related endpoints
. Multi-city and NMMAPS
^ Bell et al. (2004) (all ages)
§ Schwartz et al. (2005) (all ages)
S Huang et al. (2005) (all ages)
§ Meta-analyses
| Ito et al. (2005) (all ages)
§ Bell et al. (2005) (all ages)
^ Levy et al. (2005) (all ages)
Hospital admissions-respiratory causes (ages > 65)
•g Hospital admissions-respiratory causes (ages < 2)
ig Emergency room visits for asthma (all ages)
>§ Minor restricted-activity days (ages 18-65)
School absence days
CSAPR
Incidences
13,000
34,000
59
8,700
15,000
2,700
5,800
9,800
19,000
240,000
180,000
400,000
1,700,000
10,000,000
27
41
37
120
87
120
160
84
86
160,000
51,000
2014
Value
$100
$94
$270
$240
$0.52
$4.2
$1.7
$1.3
$0.039
$0.091
<$0.01
<$0.01
<$0.01
<$0.01
$0.022
$0.21
$0.64
$230
$360
$330
$1,000
$760
$1,100
$4.0
$0.87
$0.033
$10
$4.7
CSAPR
Incidences
2016
Value
14,000
35,000
60
8,900
16,000
2,800
6,000
10,000
19,000
250,000
190,000
410,000
1,700,000
10,000,000
$110
$99
$280
$250
$0.53
$4.3
$1.8
$1.4
$0.041
$0.094
<$0.01
<$0.01
<$0.01
<$0.01
$0.022
$0.21
$0.65
28
42
40
120
90
130
170
85
87
160,000
53,000
$240
$370
$360
$1,100
$800
$1,100
$4.2
$0.88
$0.034
$10
$4.9
MATS
Incidences
2016
Value
4,200
11,000
20
2,800
4,700
830
1,800
3,100
6,300
80,000
60,000
130,000
540,000
3,200,000
$34
$30
$87
$78
$0.20
$1.40
$0.50
$0.40
$0.01
$0.03
<$0.01
<$0.01
<$0.01
<$0.01
<$0.01
$0.10
$0.20
-
-
1 Rounded to two significant digits; no confidence intervals provided.
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Table 3: Estimated state-level health impacts avoided1 due to the CSAPR and MATS2—incidences of premature
mortality3 and value3 (millions of dollars, 2007$) of mortality and morbidity impacts
CSAPR
Participation
CSAPR Benefits
Mortality
Valuation
MATS Benefits
Mortality
Valuation
CSAPR Plus MATS Benefits
Mortality
Valuation
Alabama
Arizona5
Arkansas
California
Colorado5
Connecticut
Delaware
District of Columbia
Florida
Georgia
Idaho5
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana5
Nebraska
Nevada5
New Hampshire
New Jersey
New Mexico5
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon5
Pennsylvania
Tennessee
Texas
Utah5
Vermont
Virginia
Washington5
West Virginia
Wisconsi
Wyoming
PM25,O3
PM25,O3
PM25,O3
PM25
PM25,O3
03
PM25,O3
PM25, O3
PM25
03
PM25, O3
PM2,
130-340
57-150
30-77
630-1,600
610-1,600
610-1,600
540-1,400
95-240
84-220
550-1,400
210-540
24-63
420-1,100
160-100
560-1,400
79-200
230-580
340-870
31-81
PM25,03
PM25, 03
PM25,O3
03
800-2,000
780-2,000
3-8
1,300-3,300
PM25,O3
PM25, O3
PM25,O3
PM25, O3
1,200-3,000
32-83
400-1,000
9-22
680-1,700
700-1,800
18-46
640-1,600
^^^|
280-720
170-150
$3,400-$8,300
$1,800-$4,400
$1,100-$2,800
$500-$ 1,200
$260-$640
$5,400-$13,000
$5,300-$13,000
$5,200-$13,000
$4,700-$ 11,000
$820-$2,000
$730-$ 1,800
$4,700-$ 12,000
$1,800-$4,400
$210-$520
$3,700-$9,000
$1,400-$3,300
$4,800-$ 12,000
$680-$ 1,700
$2,000-$4,800
$2,900-$7,200
$270-$670
$280-$690
$4,000-$9,900
$6,900-$ 17,000
$6,700-$ 16,000
$28-$68
$11,000-$27,000
$1,400-$3,400
_^H
$10,000-$25,000
$280-$680
$3,400-$8,400
$75-$180
$5,800-$ 14,000
$6,100-$15,000
$150-$380
$5,500-$ 14,000
$2,400-$5,900
$1,500-$3,700
140-360
14-35
96-250
6-14
53-140
35-90
13-32
6-15
280-730
190-190
3-7
220-570
110-290
61-160
60-150
83-210
110-290
8-20
84-210
52-130
160-110
57-140
93-240
160-110
3-8
28-72
4-10
10-25
120-320
9-24
170-140
190-180
7-19
220-560
120-300
5-12
210-530
11-29
130-330
11-27
140-370
460-1,200
8-22
4-10
120-300
12-31
38-96
87-220
2-6
$1,200-$3,000
$120-$290
$820-$2,000
$48-$120
$460-$!,100
$300-$750
$110-$270
$51-$120
$2,400-$6,000
$1,700-$4,100
$22-$54
$1,900-$4,700
$960-$2,400
$520-$1,300
$520-$1,300
$710-$1,800
$970-$2,400
$68-$170
$720-$ 1,800
$450-$!,100
$1,400-$3,400
$490-$ 1,200
$800-$2,000
$1,400-$3,400
$25-$62
$240-$600
$33-$82
$84-$210
$1,100-$2,600
$79-$200
$1,500-$3,700
$1,600-$3,900
$63-$150
$1,900-$4,600
$1,000-$2,500
$39-$97
$1,800-$4,400
$96-$240
$1,100-$2,700
$92-$230
$1,200-$3,000
$4,000-$9,700
$74-$180
$34-$83
$1,000-$2,500
$100-$250
$320-$790
$750-$1,800
$20-$49
530-1,400
14-35
300-780
6-14
53-140
170-130
70-180
36-92
910-2,300
800-2,000
3-7
830-2,100
650-1,700
160-100
140-370
630-1,600
320-830
2-83
510-1,300
210-540
720-1,800
140-350
320-820
500-1,300
__ 3~8
59-150
^^ 4-10
42-110
590-1,500
9-24
970-2,500
970-2,500
11-27
1,500-3,900
280-720
5-12
1,400-3,600
44-110
520-1,300
19-50
820-2,100
1,200-3,000
8-22
22-56
760-1,900
12-31
320-820
260-670
2-6
$4,600-$ 11,000
$120-$290
$2,600-$6,400
$48-$120
$460-$!,100
$1,400-$3,500
$600-$ 1,500
$310-$760
$7,800-$19,000
$6,900-$17,000
$22-$54
$7,200-$ 18,000
$5,600-$14,000
$1,300-$3,300
$1,200-$3,100
$5,400-$13,000
$2,800-$6,800
$280-$680
$4,400-$ 11,000
$1,800-$4,400
$6,200-$15,000
$1,200-$2,900
$2,800-$6,800
$4,300-$! 1,000
^^^ $25-$62
$510-$1,300
^^^ $33-$82
$360-$890
$5,100-$13,000
$79-$200
$8,400-$21,000
$8,300-$20,000
$90-$220
$13,000-$32,000
$2,400-$5,900
$39-$97
$12,000-$29,000
$370-$920
$4,500-$! 1,000
$170-$410
$7,000-$17,000
$10,000-$25,000
$74-$180
$190-$460
$6,500-$16,000
$100-$250
$2,700-$6,700
$2,200-$5,500
$20-$49
National Total4
14,000—
35,000
$120,000—
$290,000
4,200—
11,000
$36,000—
$89,000
18,000—
46,000
$150,000—
$380,000
Some states may show benefits even if emissions are not reduced within those states due to pollution transport across state boundaries.
2 State-level MATS benefits estimates assume that the distribution of health-co-benefits for the final policy is equivalent to the modeled interim
scenario. Differences in the scenarios may lead to over- or underestimates of benefits in some states.
3 Range reflects estimates of PM25-related benefits using Pope et al. (2002) and Laden et al. (2006) and ozone-related benefits using Bell et al.
(2004) and Levy et al. (2005); rounded to two significant digits; no confidence intervals provided.
4 State results do not sum to national total due to rounding.
5 States in the Western U.S. are not expected to be significantly impacted by the CSAPR, their benefits are not presented at the state-level.
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United States Office of Air Quality Planning and Standards Publication No. EPA-452/R-11-014
Environmental Protection Health and Environmental Impacts Division December, 2011
Agency Research Triangle Park, NC
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