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3 Framing the Analysis
Pages 57-74

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From page 57...
... This chapter discusses how EPA has dealt with each of these sets of decisions and uses examples from the four EPA benefits analyses reviewed by the committee and summarized in Chapter 2 of this report. REGULATORY OPTIONS EVALUATED In three of the analyses examined by the committee, EPA focused on evaluating a single set of regulatory options: (1)
From page 58...
... and ozone National Ambient Air Quality Standards (NAAQS)
From page 59...
... A related issue concerns assumptions made about compliance with air pollution regulations. As indicated in Chapter 1, current EPA Of flee of Air Quality, Planning and Standards guidance calls for analysts to assume full compliance with regulatory requirements when estimating the costs and benefits of regulations.
From page 60...
... For the prospective analysis, EPA did not assume perfect compliance with proposed regulations but assumed stationary sources would achieve only 80% oftarget reductions for nitrogen oxides (NOx) and volatile organic compounds (VOCs)
From page 61...
... The committee recognizes that time and resource constraints may require trade-offs between the number of scenarios considered and the level of detail for each. As an aside, the committee notes that the examples provided are unintended negative impacts and that there may be unintended positive impacts of air pollution control regulations outside the boundaries of the analysis.
From page 62...
... The analyses for the Tier 2 emissions standards and the HD engine and diesel-fuel rule evaluated benefits only in 2030. The analysis for the PM and ozone NAAQS evaluated health benefits in 2010.
From page 63...
... as a reason for aggregating Titles I-V in estimating the benefits of the 1990 CAAA: The estimates in Table 8-3 reflect the difficulty we encountered in reliably disaggregating benefits by CAAA Title or even by pollutant.... These difficulties in separating the effects of individual emissions reductions on the benefits estimates also highlights the need for an integrated air quality modeling system that can more readily analyze multiple scenarios within reasonable time and resource constraints.
From page 64...
... This change is necessary if EPA is to evaluate multiple regulatory alternatives and if it is to evaluate each alternative at reasonable time intervals such as every 5 years. The ability to evaluate the ambient air quality associated with more emissions scenarios is also essential if the uncertainty inherent in emissions estimates is to be carried through to estimating avoided cases of mortality end morbidity.
From page 65...
... Emissions Predictions In all four analyses reviewed by the committee, EPA predicts emissions for all major source categories of the criteria pollutants: industrial point sources, utilities, nonroad engines and vehicles, motor vehicles, and area sources for one or more future years, such as 2010 or 2030. These predictions are made without the regulation analyzed in the study (designated the regulatory baseline)
From page 66...
... The calculation of emissions predictions, the ways in which the information should be presented, and the relevance of uncertainty to the analysis are discussed in the following sections, using as examples emissions predictions for electric utilities and emissions predictions for motor vehicles. Emissions Predictions for Electric Utilities In the prospective analysis, EPA predicts SO2 emissions for electric utilities in 2010 with and without regulatory action.
From page 67...
... Although this information may be available in technical support documents, additional information about the components of total SO2 emissions could be presented for the two scenarios in the main text as a table listing the national aggregate fuel consumption by category of power plant and the national average pollution intensity by category of powerplant. This breakdown of the components of predicted emissions could also be supplemented with historical information on aggregate fuel consumption and average pollution intensify by class of powerplant.
From page 68...
... The figures should be accompanieci in the main text by some explanation of the assumptions that drive the results. For example, if analysts predict a rapid increase in the percent of light-duty trucks powered by diesel, this assumption requires an explanation, especially if it accounts for a large percent of the PM~o emissions in the regulatory baseline and, thus, a large percent of the particulate reductions attributed to the Tier 2 emissions standards.2 2In the Tier 2 emissions standards RIA, Table IIIA-13 shows light-duty diesel trucks increasing from 0.
From page 69...
... See Chapter 5 for a description ofthe procedures for formalizing the uncertainty associated with emissions estimates and other components ofthe health benefits analysis. Predictions Regarding Population and Health 6 The goal of a health benefits analysis associated with a proposed air pollution regulation is to estimate the avoidable risk associated with that regulationócases of morbidity end mortality that are likely to be avoided if the regulation is implemented.
From page 70...
... For example, rates of heart disease, one of the maj or disease categories affected by ambient air pollution, have been remarkably reduced in the past 30 years. Although it is probably not feasible to project baseline rates for all health outcomes considered in health benefits analyses, EPA should incorporate estimates of future trends in mortality and morbidity formajorhealth outcomes, such as those that make up two-thirds of total deaths or lost life-years, that are being considered.
From page 71...
... ∑ A critical step in the preliminary stages of an RIA is the development of a range of regulatory options to evaluate. Fewer regulatory alternatives than would be needed to follow OMB guidelines are presented or appear to be evaluated in recent EPA analyses.
From page 72...
... ~ EPA should modify the air-quality models used in translating preclicted emissions into predicted levels of ambient air quality to reduce resources required for air-quality modeling. This change is necessary if EPA is to evaluate multiple regulatory alternatives and to evaluate each alternative at reasonable time intervals, such as every 5 years.
From page 73...
... 1999a. Regulatory Impact Analysis Control of Air Pollution from New Motor Vehicles: Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements.
From page 74...
... 2000. Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality, A Special Report of the Institute's Particle Epidemiology Reanalysis Project.


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