In_Reply_To: $RFSaveInfo: 6276E46F23BCE88885257323003F42AE $Links: ldf_createddate: null ldf_from: null ldf_archive: null ldf_temp: null $AltNameLanguageTags: InheritedReplyTo: InheritedFrom: CN=Al McGartland/OU=DC/O=USEPA/C=US InheritedAltFrom: CN=Al McGartland/OU=DC/O=USEPA/C=US InheritedFromDomain: Logo: StdNotesLtr21 tmpImp2: DefaultMailSaveOptions: 1 Query_String: Principal: CN=Bryan Hubbell/OU=RTP/O=USEPA/C=US SentToDocu: False Subject: Re: Where are we on UVB? ldf_locale: en-US ReturnReceipt: 0 delTmpEncrypt: delTmpImportance: delTmpReturnReceipt: delTmpSign: SendTo: CN=Al McGartland/OU=DC/O=USEPA/C=US@EPA CopyTo: conner.lisa@epa.gov,evans.ron@epa.gov,hubbell.bryan@epa.gov,CN=Lydia Wegman/OU=RTP/O=USEPA/C=US@EPA,mcgartland.al@epa.gov,CN=Pat Dolwick/OU=RTP/O=USEPA/C=US@EPA,CN=Karen Martin/OU=RTP/O=USEPA/C=US@EPA,CN=Harvey Richmond/OU=RTP/O=USEPA/C=US@EPA InetSendTo: Mcgartland.Al@epamail.epa.gov InetCopyTo: .,.,.,Wegman.Lydia@epamail.epa.gov,.,Dolwick.Pat@epamail.epa.gov,Martin.Karen@epamail.epa.gov,Richmond.Harvey@epamail.epa.gov $StorageTo: 1 $StorageCc: .,.,.,1,.,1,1,1 $Mailer: Lotus Notes Release 6.5.2 June 01, 2004 $MessageID: From: CN=Bryan Hubbell/OU=RTP/O=USEPA/C=US INetFrom: Hubbell.Bryan@epamail.epa.gov PostedDate: 07/25/2007 03:00:40 PM $Signature: Encrypt: $UpdatedBy: ,CN=RTAIRMAIL1/OU=RTP/O=USEPA/C=US $Orig: D259EAB949A087908525732300446815 Categories: $Revisions: RouteServers: CN=RTAIRMAIL1/OU=RTP/O=USEPA/C=US RouteTimes: 07/25/2007 03:00:41 PM-07/25/2007 03:00:41 PM $MsgTrackFlags: 0 DeliveredDate: 07/25/2007 03:00:41 PM I have attempted to answer your questions below. The overarching comment I have is that any scoping level estimate would not pass the tests that other endpoints have gone through and failed. I will go through below the specific reasons why such a scoping analysis will be fatally flawed. I will point out the incredible difficulty we have had providing ozone mortality estimates in our RIA's even given the huge amount of literature, the well specified C-R functions, the good modeling and monitoring data available, etc. We finally have made some progress, but it took over 10 years!! to get there. There definitely seems to be a double standard when it is an effect that OMB would like to see added. Other examples where benefits have been excluded because of "too much uncertainty" include the impacts of acidification on recreational fishing, the impacts of nitrogen deposition, impacts of ozone on forest yields, impacts of ozone on forest recreation values, impacts of ozone on urban ornamentals, impacts of PM and ozone on birth outcomes, value of visibility changes in non-class I areas, and value of visibility changes in class I areas outside of the 3 Chestnut and Rowe study areas. I would certainly like to see us find a way to evenly evaluate the state of science and economics in each of these areas, but I do not think it fair or approrpriate to decide on an ad hoc basis that we will commit to doing a scoping excercise for one specific "disbenefit" that a group of non-experts has decided rises to the level of significance. We have expert panels that have determined that this is likely to be a non-issue, and we should listen to them. In addition, we have a rulemaking which states that quantification is inappropriate, and we have language in the proposed ozone standards that says it is not appropriate to quantify the effect ( "Thus, the Criteria Document concludes that any assessment that attempts to quantify the consequences of increased UV-B exposure on humans due to reduced ground-level O3 must include consideration of both negative and positive effects. However, as with other impacts of UV-B on human health, this beneficial effect of UV-B radiation has not been studied in sufficient detail to allow for a credible health benefits or risk assessment. In conclusion, the effect of changes in surface-level O3 concentrations on UV-induced health outcomes cannot yet be critically assessed within reasonable uncertainty (Criteria Document, p. 10-36)".) Not that it has any real relevance to quantification, but it should also be noted that if quantification were to be attempted, as noted in the CD, the beneficial effects of UV-b on vitamin D production. (" Beyond these well recognized adverse health effects associated with various wavelengths of UV radiation, the Criteria Document (section 10.2.3.6) also discusses protective effects of UV-B radiation. Recent reports indicate the necessity of UV-B in producing vitamin D, and that vitamin D deficiency can cause metabolic bone disease among children and adults, and may also increase the risk of many common chronic diseases (e.g., type I diabetes and rheumatoid arthritis) as well as the risk of various types of cancers.) Please see below for my direct responses. Dr. Bryan J. Hubbell Senior Advisor for Science and Policy Analysis Health and Environmental Impacts Division U.S. EPA/OAQPS (C504-02) RTP, NC 27711 (919) 541-0621 Al McGartland/DC/USEPA/US 07/25/2007 07:50 AM To Lydia Wegman/RTP/USEPA/US@EPA cc conner.lisa@epa.gov, evans.ron@epa.gov, hubbell.bryan@epa.gov, mcgartland.al@epa.gov Subject Re: Where are we on UVB? I didn't have time to write up a more detailed explanation of how we might "scope out" the UVB benefits (disbenefit). But here is what I was thinking. After you read this, if someone could respond why this isn't possible, then I think we might have enough to begin a discussion. I think we would all agree that quantifying all the benefits, disbenefits, and costs should be the goal of any analysis. Bryan has argued, somewhat effectively in my mind, that we can't have double standards for disbenefits and benefits. I agree with him. I think we can't add effects if the science is such that we have no confidence in the number, even is we qualify it. But I would be happy to discuss other benefit categories that have fallen out of the RIA because someone thought it wasn't "good" enough. In this case, it seems to me we understand the science quite well -- that is, the effect, the mode of action, the exposure, the UV filtering etc. are all well understood conceptually. It must be the case that the issue is quantifying the exposure changes (UVB changes) from the new Ozone NAAQS. I don't think we can do this perfectly, but it seems to me that it might be possible to perform some exercises to show that how big this disbenefit is likely to be. First, the Strat Ozone RIA contains both estimates of skin cancers and UV exposure. I recall, but its been a while, that the dose-response curve is based on collecting skin cancer data by city and UV exposure. Hence we have a relationship between UV and skin cancer. Next, we understand the relationship between the ozone column and UV filtering. I recall a conversation with Bryan where he indicated that we also know how much of the ozone column is from ground level ozone. He cited a number, to support an argument that this total disbenefit is likely to be small. Tropospheric ozone on average represents around 10 percent of total column ozone. However, according to our atmospheric modelers, this percentage varies over the continental U.S. In addition, the Final Response for the Ozone Remand indicates that during the summer, tropospheric ozone in the Eastern U.S. contributes only 1 percent to total column ozone. It may be possible to get gridded estimates of total column ozone from CMAQ which could be used to calculate the tropospheric contribution to total column ozone by location. He sounded convincing to me, which is why it might be important to quantify this disbenefit, even if crudely, so we can show that the number isn't a dramatic offset to the benefits already quantified. (We could, after we do this, discuss how to present these numbers in the RIA. They could, for example, be placed in an appendix and clearly labeled speculative bounding exercise.) If we know how much of the UV filtering is from ground level ozone, why not calculate for a given metropolitan area that mean percent reduction in ground level ozone by season (based on the air quality modeling already done). This could be done, with some additional effort, because we are typically focused on other shorter term metrics for the health benefits analysis. However, this does not address the need for additional modeling to indicate how the change in EXPOSURE to UV-B would change. UV-B exposure does not depend on average ozone shielding, but rather on the time-weighted exposure pattern which would need to reflect how much of the total exposure to UV-B occurs in areas with different levels of baseline ozone and different levels of reduction in ozone. We do not have the ability to estimate these actual exposures. As such we are missing the essential dose piece of the equation. We can proxy the change in dose using the average change in ozone shielding across an urban area, but this introduces a definite bias of unknown magnitude or sign. Generally when this has been the case (see urban visibility), we have been given guidance to avoid quantifying the effect, even when we know that the effect estimate is non-zero. Reduce UV filtering accordingly, and calculate the number of increased cancers that are expected to result from such a change. The actual reduction in UV filtering is also not easily determined by looking at the temporally averaged ozone concentrations, because the time of day matters when determining UV exposure -- "atmospheric absorption is more complete in winter months and both early and late in the day, as compared to the absorption around mid-day near the summertime solar zenith" Source: Final Response to Ozone Remand I know this would be very crude -- ground level ozone is not constant across time, the changes are not constant, etc. People's activities change etc. Some of this might already be captured in the epi study if they used cancer estimates and UV exposure, activity patterns are already implicitly captured, for example.) These are not small issues. The effect of a NAAQS on tropospheric ozone is very complex and heterogeneous. Peak values may be affected more than daily or seasonal means, and ozone concentrations are altered in vary heterogenous ways across different locations. To accurately estimate the effect of changes in tropospheric ozone on UV-b impacts requires matching the spatial and temporal distributions of the ozone concentration changes to the spatial and temporal distribution of UV-B exposure. Note that "the biologically effective dose of radiation that actually reaches target molecules generally depends on the duration of exposure at particular locations, time of day, time of year, behavior (i.e., ‘‘sun avoidance’’and ‘‘sun seeking’’ behavior), and, for the skin, characteristics that include pigmentation and temporal variations (e.g., changes in the pigmentation due to tanning)" Source: Final Repsonse for the Ozone Remand. There is a much more detailed discussion in the Final Response to the Remand about these exposure issues. But such a calculation could, I think, show whether this number is likely to be small or large, and it seems to me that this is the most important question surrounding this disbenefit. Note that the $ disbenefits would be even smaller relative to other factors because of the potentially long latency period between exposure and incidence of cancer. As such, the $ benefits would need to be discounted over that latency period. There are also several other issues with comparing disbenefits with benefits, because the disbenefits are based on a lifetime cumulative exposure calculation, and the pattern of exposures over a lifetime can greatly influence the resulting impacts. In addition, we would need to convert this somehow to an annualized impact for comparison with the annual impacts we show for other health effects. This would require a great deal of work to understand the strat ozone modeling results and determine how to approrpiately convert that analysis into something that could be used with the current data we have for tropospheric ozone. I apologize but I just don't know enough about this to understand why this can't be done. It is not that it can't be done, it is a question of whether it can be done credibly, and if not, should it be done at all. Previous policy has been to not do it if it could not be done credibly. If someone could respond, I could then engage Brian and others to make some headway. Also, if you could send the response to the courts, that might be helpful too. (Or tell me how to get my hands on it.) Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 OriginalModTime: 07/25/2007 07:50:16 AM In_Reply_To: ldf_createddate: null ldf_from: null ldf_archive: null ldf_temp: null $AltNameLanguageTags: InheritedReplyTo: InheritedFrom: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US InheritedAltFrom: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US InheritedFromDomain: Logo: StdNotesLtr28 useApplet: True tmpImp2: DefaultMailSaveOptions: 1 Query_String: Principal: CN=Al McGartland/OU=DC/O=USEPA/C=US SentToDocu: False Subject: Re: Where are we on UVB? ldf_locale: en-US Sign: 0 ReturnReceipt: 0 delTmpEncrypt: delTmpImportance: delTmpReturnReceipt: delTmpSign: SendTo: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US@EPA CopyTo: conner.lisa@epa.gov,evans.ron@epa.gov,hubbell.bryan@epa.gov,mcgartland.al@epa.gov InetSendTo: Wegman.Lydia@epamail.epa.gov InetCopyTo: .,.,.,. $StorageTo: 1 $StorageCc: .,.,.,. $Mailer: Lotus Notes Release 6.5.5 November 30, 2005 $MessageID: From: CN=Al McGartland/OU=DC/O=USEPA/C=US INetFrom: McGartland.Al@epamail.epa.gov PostedDate: 07/25/2007 07:50:23 AM Encrypt: RouteServers: CN=DCCCWMAIL14/OU=DC/O=USEPA/C=US,CN=RTAIRMAIL1/OU=RTP/O=USEPA/C=US RouteTimes: 07/25/2007 07:50:23 AM-07/25/2007 07:50:30 AM,07/25/2007 07:50:31 AM-07/25/2007 07:50:31 AM $Orig: 6276E46F23BCE88885257323003F42AE Categories: $Revisions: 07/25/2007 07:50:31 AM $MsgTrackFlags: 0 DeliveredDate: 07/25/2007 07:50:31 AM $UpdatedBy: ,CN=DCCCWMAIL14/OU=DC/O=USEPA/C=US,CN=EPAHUB15/O=USEPA/C=US $RespondedTo: 2 I didn't have time to write up a more detailed explanation of how we might "scope out" the UVB benefits (disbenefit). But here is what I was thinking. After you read this, if someone could respond why this isn't possible, then I think we might have enough to begin a discussion. I think we would all agree that quantifying all the benefits, disbenefits, and costs should be the goal of any analysis. Bryan has argued, somewhat effectively in my mind, that we can't have double standards for disbenefits and benefits. I agree with him. I think we can't add effects if the science is such that we have no confidence in the number, even is we qualify it. But I would be happy to discuss other benefit categories that have fallen out of the RIA because someone thought it wasn't "good" enough. In this case, it seems to me we understand the science quite well -- that is, the effect, the mode of action, the exposure, the UV filtering etc. are all well understood conceptually. It must be the case that the issue is quantifying the exposure changes (UVB changes) from the new Ozone NAAQS. I don't think we can do this perfectly, but it seems to me that it might be possible to perform some exercises to show that how big this disbenefit is likely to be. First, the Strat Ozone RIA contains both estimates of skin cancers and UV exposure. I recall, but its been a while, that the dose-response curve is based on collecting skin cancer data by city and UV exposure. Hence we have a relationship between UV and skin cancer. Next, we understand the relationship between the ozone column and UV filtering. I recall a conversation with Bryan where he indicated that we also know how much of the ozone column is from ground level ozone. He cited a number, to support an argument that this total disbenefit is likely to be small. He sounded convincing to me, which is why it might be important to quantify this disbenefit, even if crudely, so we can show that the number isn't a dramatic offset to the benefits already quantified. (We could, after we do this, discuss how to present these numbers in the RIA. They could, for example, be placed in an appendix and clearly labeled speculative bounding exercise.) If we know how much of the UV filtering is from ground level ozone, why not calculate for a given metropolitan area that mean percent reduction in ground level ozone by season (based on the air quality modeling already done). Reduce UV filtering accordingly, and calculate the number of increased cancers that are expected to result from such a change. I know this would be very crude -- ground level ozone is not constant across time, the changes are not constant, etc. People's activities change etc. Some of this might already be captured in the epi study if they used cancer estimates and UV exposure, activity patterns are already implicitly captured, for example.) But such a calculation could, I think, show whether this number is likely to be small or large, and it seems to me that this is the most important question surrounding this disbenefit. I apologize but I just don't know enough about this to understand why this can't be done. If someone could respond, I could then engage Brian and others to make some headway. Also, if you could send the response to the courts, that might be helpful too. (Or tell me how to get my hands on it.) Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 OriginalModTime: 07/24/2007 06:15:30 PM In_Reply_To: ldf_createddate: null ldf_from: null ldf_archive: null ldf_temp: null $AltNameLanguageTags: InheritedReplyTo: InheritedFrom: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US InheritedAltFrom: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US InheritedFromDomain: Logo: StdNotesLtr28 tmpImp2: DefaultMailSaveOptions: 1 Query_String: Principal: CN=Al McGartland/OU=DC/O=USEPA/C=US SentToDocu: False Subject: Re: Where are we on UVB? ldf_locale: en-US Sign: 0 ReturnReceipt: 0 delTmpEncrypt: delTmpImportance: delTmpReturnReceipt: delTmpSign: SendTo: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US@EPA CopyTo: conner.lisa@epa.gov,evans.ron@epa.gov,hubbell.bryan@epa.gov,CN=Al McGartland/OU=DC/O=USEPA/C=US@EPA InetSendTo: Wegman.Lydia@epamail.epa.gov InetCopyTo: .,.,.,. $StorageTo: 1 $StorageCc: .,.,.,. $Mailer: Lotus Notes Release 6.5.5 November 30, 2005 $MessageID: From: CN=Al McGartland/OU=DC/O=USEPA/C=US INetFrom: McGartland.Al@epamail.epa.gov PostedDate: 07/24/2007 06:15:34 PM Encrypt: $UpdatedBy: ,CN=DCCCWMAIL14/OU=DC/O=USEPA/C=US RouteServers: CN=DCCCWMAIL14/OU=DC/O=USEPA/C=US,CN=RTAIRMAIL1/OU=RTP/O=USEPA/C=US RouteTimes: 07/24/2007 06:15:34 PM-07/24/2007 06:15:39 PM,07/24/2007 06:15:39 PM-07/24/2007 06:15:40 PM $Orig: E3A791EE7F076AC0852573220079DE13 Categories: $Revisions: $MsgTrackFlags: 0 DeliveredDate: 07/24/2007 06:15:40 PM I would like ot see the FR notice if possible. I was asked to write up how we might do a "scoping" assessment of this benefit and then ask you why we can't do this. Such an analysis may tell us if this is a small deal or a potential big deal. I will write it up tonight and ask for your reaction. I think OPEI is looking for language that will say that EPA will explore this issue and assess whether a quantitative analysis is feasible. I know you don't want to do that, but since Brian doesn't have time to study the issue enough between now and when you want it released, this is the fall back position for OPEI. He may talk to Bob and George Gray to see if they can support such a statement. I will know more tomorrow when I see him. We missed each other today. Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 Lydia Wegman/RTP/USEPA/US 07/24/2007 06:08 PM To mcgartland.al@epa.gov cc hubbell.bryan@epa.gov, evans.ron@epa.gov, conner.lisa@epa.gov Subject Where are we on UVB? Al, I think we last left this with me responding to you about the fact that we have nothing in writing other than the CD. Karen Martin reminded me today that we also have the response we wrote to the court's remand on this issue explaining why we could not do quantitative assessments of UVB at that time. I think this was done around 2000. Nothing has changed from our perspective since there is no new research that has been conducted that would enable us to do a credible assessment. Let me know if you want to see that FR notice. But, meanwhile, we need to get the proposed RIA out this week, so can we move forward and continue our discussions, on the understanding that we remain of the view that it is not possible to do a quantitative analysis and that we will meet with Brian to explain why in further detail than he's heard from me so far? Thanks. Subject: Re: CEA ozone analyses, advice to Bob From: CN=Al McGartland/OU=DC/O=USEPA/C=US ComposedDate: 07/19/2007 05:25:41 PM PostedDate: 07/19/2007 05:24:58 PM SendTo: CN=Lydia Wegman/OU=RTP/O=USEPA/C=US@EPA,CN=Bryan Hubbell/OU=RTP/O=USEPA/C=US@EPA,"Dr. Al McGartland" CopyTo: CN=Ron Evans/OU=RTP/O=USEPA/C=US@EPA Importance: 2 SenderTag: Logo: StdNotesLtr28 $Links: $Orig: 19F7BC628919BA4A8525731D0075A4C4 $UpdatedBy: CN=EPAHUB16/O=USEPA/C=US $MessageID: RouteServers: CN=EPAHUB16/O=USEPA/C=US,CN=RTAIRMAIL1/OU=RTP/O=USEPA/C=US RouteTimes: 07/19/2007 05:24:58 PM-07/19/2007 05:24:59 PM,07/19/2007 05:25:48 PM-07/19/2007 05:25:49 PM Categories: $Revisions: $MsgTrackFlags: 0 DeliveredDate: 07/19/2007 05:25:54 PM I can't opine on the uv-b issue because I don't know enough. I need to learn more. There are several technical issues that will, I think determine how feasible any quantification of benefits will be. If you are committing to exploring how we can do this I think we are OK. Would you all be adverse to me asking a consultant if this is feasible? An independent second opinion might help. Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 ----- Original Message ----- From: Lydia Wegman Sent: 07/19/2007 01:19 PM To: Bryan Hubbell; mcgartland.al@epa.gov Cc: Ron Evans Subject: Re: CEA ozone analyses, advice to Bob Thanks to both of you for wending our way through the CEA issue and reaching a solution. The language Art gave me on that issue is: "We are investigating options for conducting a CEA and expect to provide estimates based on that analysis in the final RIA." On UV-B we need to have a full discussion of the issue. As Bryan says, we in OAQPS all continue to believe that we do not have the information available to do a quantitative assessment of UV-B effects. We all feel quite strongly about it. I think the next step needs to be a meeting with Brian, our shop and ORD to discuss this issue. We would need to invite Bob Meyers as well. I have told Art that we are not willing to put language about further analyses related to UV-B in the proposed RIA. If Brian is insistent on that, we need to schedule the discussion on this subject immediately. If not, we can wait until the proposed RIA is completed and then meet in August or September. Let me know Al if you think we can wait until after the proposed RIA is done. Thanks. Bryan Hubbell/RTP/USEPA/US 07/19/2007 12:56 PM To Al McGartland/DC/USEPA/US@EPA cc Ron Evans/RTP/USEPA/US@EPA, Lydia Wegman/RTP/USEPA/US@EPA Subject Re: CEA ozone analyses, advice to Bob Thanks Al. Clearly we need to continue our discussions on all of these issues. At this point, we will need a specific sentence characterizing the CEA agreement. I believe thaqt Lydia got that sentence from Art last night, so hopefully she can provide it. We still need a final decision on UV-b. My very firm belief is that it is both scientifically and practically inappropriate to conduct a quantitatove impact assessment for the uv-b screening impacts of reducing tropospheric ozone to meet alternative ozone standards. On the issue of costs, we also want to make progress, and I believe that Ron is planning to initiate discussions on this issue in early september. ----- Original Message ----- From: Al McGartland Sent: 07/19/2007 12:30 PM To: Bryan Hubbell Cc: Ron Evans; Lydia Wegman Subject: Re: CEA ozone analyses, advice to Bob I talked with Brian Mannix. We can agree to this approach for the RIA. Thanks for being flexible. Just fyi. Brian asked about some of the other issues -- this may give you some hints about what is important to him. He is very interested in making progress on how we model the cost of reductions when the we can no longer identfy control options. Specifically, assuming a perfectly elastic supply curve for emission reductions is difficult for him to accept. Hopefully, our offices will make some headway on this. He (and I) are very interested in the ethanol issue and how this may affect future ozone levels Finally, perhaps not surprisingly, Brian discussed UV filtering issue. I told him we agreed on some qualitative text for the proposal. He thinks you need to do an analysis of this as well for the final. He mentioned that Lydia had talked to him about this some time ago. Lydia, you probably recall the conversation. Brian said he didn't agree with your arguments. Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 Bryan Hubbell/RTP/USEPA/US 07/19/2007 10:10 AM To Al McGartland/DC/USEPA/US@EPA, Ron Evans/RTP/USEPA/US@EPA cc "bryan hubbell" , Lydia Wegman/RTP/USEPA/US@EPA, Marjorie Jones/RTP/USEPA/US@EPA, "page steve" Subject Re: CEA ozone analyses, advice to Bob My understanding is that Art has agreed to limit the language in the proposal to a commitment to evaluate the available data and methods and state that we "expect" to provide a CEA analysis for the final. I am okay with this language as long as we understand that the exact form and extent of such an analysis will be dependent on our review. In addition there needs to be an understanding that OAQPS currently does not have the staff available to develop an extensive new method, and as such, funding and staff will need to be committed by OPEI. If we can agree on this, then we can move forward. Al, if you can call me as soon as you are available, perhaps we can close on this. Margo Schwab has indicated she is comfortable with this understanding. ----- Original Message ----- From: Al McGartland Sent: 07/18/2007 06:25 PM To: Ron Evans Cc: Hubbell.bryan@epa.gov; Lydia Wegman; Marjorie Jones; page.steve@epa.gov Subject: Re: CEA ozone analyses, advice to Bob Several points: (1) It is required by Circular A-4. Hence we should do it unless there is some overwhelming problem in doing so. I don't think there is. And, in the case of PM and ozone, it is a very useful analysis to have along side the Benefit-Cost analysis (BCA). (2) I don't understand why the lack of SAB advice should stop us. There are lots of issues where Economics has methods etc., for which the SAB has not opined. We still go forward and use these methods. Cost-effectiveness analysis is a widely used tool, most often involving life-years. It is well accepted -- SAB advice should not be necessary to move foward. (3) Bryan, you, Nathalie and I participated in a meeting in your building where we discussed how we might do CEA for ozone. We then deployed an RA to gather the necessary data. We would, of course, have the analysis peer reviewed, but I think its doable. We would have to make assumptions about the extent of preexisting conditions on folks who would die as a result of ozone exposure. We would, of course, convene the Bryan, Pamela, Margo, Al group to work out the specifics of this methodology. (4) There are lots of risk assessments that go forward before the NAS or the SAB weigh in. Why can't we do one here? (5) I'm not sure what you mean by using the same assumptions as that for PM. The epi studies for PM allowed us to calculate teh remaining life years if a straightforward manner. As you point out, ozone won't. (6) In some people's minds, the CEA is at least as important as the BCA, yet EPA doesn't give it an equal effort. I responded to Doug's email. I haven't heard back from him on the post 2020 issue. Al McGartland, PhD. Director, National Center for Environmental Economics US EPA 1201 Pennsylvania Ave., N.W. Washington, D.C. 20460 202.566.2244 Ron Evans/RTP/USEPA/US 07/18/2007 05:28 PM To Al McGartland cc Lydia Wegman, Bryan Hubbell, Marjorie Jones/RTP/USEPA/US, page.steve@epa.gov Subject CEA ozone analyses, advice to Bob Al, I talked to Lydia after our OMB call and indicated that you said that Brian and Bob needed to talk before any deal with OMB was complete. Lydia asked me to share the information we have provided to Bob on why we think that committing to a specific CEA analysis for ozone in the final ozone RIA is not a good idea. Can you give us an idea on why Brian differs on this issue and what points he would like to raise to Bob? Hopefully we can come to a common understanding and agreement amongst ourselves and eliminate the need for a specific discussion between them. Cost Effectiveness Analysis (CEA): There is no advice from SAB on doing CEA for ozone mortality specifically. The question of how to appropriately address CEA analysis is currently raised in two separate advisory panels. We are awaiting feedback from the NAS panel on ozone mortality, doing this kind of analysis was one of the items raised for their consideration. In addition, a number of specific charge questions were submitted to the Science Advisory Board Environmental Economics Advisory Committee (EEAC) pertaining to estimating the value of premature mortality reductions. Currently there is insufficient data on ozone and its effects to calculate life years. This NAS advice specifically focused on ozone mortality is due in December 2007 but would come too late to be incorporated into the RIA as their advice would not come in the form of a methodology; the EEAC advice is expected sooner and may provide information used in developing a methodology but may not have specific guidance on ozone. OPEI has offered to have a contractor develop a methodology but we need the caveat that there may not be sufficient data to do an analysis (or NAS may indicate that we should not do this analysis until further data is developed). It is for this reason that we have been unwilling to commit to the analysis in the RIA. We have offered to commit to the analysis IF we used the identical assumptions as used for PM in the PM RIA with appropriate caveats. Ron Evans Leader, Air Benefit & Cost Group HEID/OAQPS/OAR/EPA Mail Drop C-439-02 919-541-5488 919-541-0839 fax