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1 Introduction
Pages 17-33

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From page 17...
... The process of estimating health improvements for various regulatory options is known as health benefits analysis. These analyses, often controversial, attempt to quantify changes in the expected number of mortality and morbidity cases likely to result from the proposed regulation.
From page 18...
... Consider issues important in estimating the health-risk-reduction benefits of airpollution regulations, including the scientific data, risk assessment approaches, populations affected, baseline used, assumptions, analysis of uncertainty, andidentif~cationofkeyincticators of exposure andpopulation health status.
From page 19...
... , the "Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements" (EPA 1999a) , and the "Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements" (EPA 2000a)
From page 20...
... In 1981, President Reagan formally established CBA as an integral part of the evaluation of proposed regulations with the issuance of Executive Order 12291. This executive order required agencies to assess the costs and benefits of proposed "major" regulations and established OMB as the review agency for these analyses.
From page 21...
... In addition to the overarching requirements mandated in executive orders, Congress has imposed statutory and administrative requirements to conduct CBAs under various acts. The Clean Air Act Amendments of 1990 require EPA to assess periodically the costs and benefits ofthe Clean Air Act.
From page 22...
... ~ Estimating changes in ambient air pollutant concentrations.3 To allow calculation of the health benefits, the changes in pollutant emissions must be translated into changes in ambient air concentrations and should take account of factors that might affect exposure, when possible. · Estimating changes in human health outcomes.
From page 23...
... Documents that contain some guidance on aspects of these analyses typically focus on broacler regulatory analyses, such as RIAs or economic analyses. Relevant documents issued by EPA, OMB, the World Health Organization (WHO)
From page 24...
... ~ Anticipating nonregulatory factors. Although nonregulatory factors are important (for example, changes in industrial behavior that affect pollutant emissions but are unrelated to regulatory actions)
From page 25...
... Although five methods to analyze uncertainty are listed (scenario analysis, Delphi methods, sensitivity analysis, meta-analysis, and Monte Carlo andprobabilistic models) , OAQPS states that "for analyses in which benefits unambiguously exceed costs, a sensitivity analysis should be adequate." The committee notes that determining the likelihood of benefits unambiguously exceecIing costs requires an uncertainty analysis and not simply sensitivity analyses.
From page 26...
... These guidelines were based on an OMB document released in 1996 that described "best practices" for conducting economic analyses required under Executive Order 12866 (OMB 19964. Similar to the EPA guidelines, the OMB guidelines provide general information on conducting an economic analysis.
From page 27...
... Any analysis that indicates a change in the preferred option or a substantial change in the net benefits should be critically evaluated. Other considerations noted in the OMB guidelines include avoiding clouble-counting when estimating benefits, analyzing effects on different groups, identifying any negative effects of regulatory options, and evaluating the sensitivity of estimates to assumptions.
From page 28...
... The WHO report stated that the impact of air pollution on all-cause mortality should be assessed, as well as that on cause-specif~c mortality for the following conditions: cardiovascular disease, chronic nonmalignant respiratory disease, lung cancer, and age-specific deaths, particularly for younger and older populations. The group noted that the effects of air pollution on mortality in sensitive subpopulations should be better estimated and stressed that care must be taken when transferring mortality rates from the study population (the population evaluated in the scientific literature)
From page 29...
... Factors that should be considered include the mixture of pollutants to which each population is exposed and eachpopulation's baseline health status. Assumptions should be clearly articulated and assessed and justifications provided for transferability of the results from the study population to the target population.
From page 30...
... Factors that should be considered in the analysis include differences between study and target locations with respect to pollutant sources, pollutant mix, variation in time and space ofthe pollutant mix, locations ofthe monitors, and assumptions used to determine population average exposure, such as amount of time spent indoors, work habits, and use of air conditioners. The group noted that the effects attributed to a specific pollutant in epidemiological studies should be viewed as the effects resulting from exposure to pollutant mixtures emitted by particular sources.
From page 31...
... The conference focused primarily on the legal, political, philosophical, and ethical issues associated with CBA, particularly the valuation techniques, and not on the methodological issues on how to conduct benefits analysis. However, the recommendations made by the steering committee are relevant here.
From page 32...
... l 999a. Regulatory Impact Analysis - Control of Air Pollution from New Motor Vehicles: Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements.
From page 33...
... INTRODUCTION 33 The White House. January 11 , 1 996.


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