Ron Evans/RTP/USEPA/US 

05/18/2007 05:01 PM

	

To

Eileen Pritchard/DC/USEPA/US@EPA

cc

Bruce Schillo/DC/USEPA/US@EPA, Marjorie Jones/RTP/USEPA/US, Mary
Henigin, simon.nathalie@epa.gov, rosalina rodriguez, Lydia Wegman,
Lesley Schaaff/DC/USEPA/US@EPA, Thomas Gillis/DC/USEPA/US@EPA, Joseph-J
Dougherty/DC/USEPA/US@EPA

Subject

draft chapter of ozone NAAQS RIA to forward to Rob Johnasson of OMB









Mary Henigin is out of the office today and indicated it would be OK for
me to forward this to you directly.  Please forward to Rob Johnasson at
OMB.

Rob,

We have the first chapter (benefits chapter with some appendices) of the
RIA ready for your review.  There few things I want to lay out before
you dig in.

First, it is important to note and recall that with some trepidation on
the part of others, I have directed an aggressive redesign of the RIA. 
The focus of the redesign is to present what has changed in the
methodology since the PM NAAQS RIA analysis or other appropriate
reference (so in the case of the benefits chapter, the calculation of
ozone mortality benefits) and then reference the rest.  Thus, where in
the past we provided the derivation of the value of a statistical life
in the body the RIA, now we state the VSL in the year 2020 and refer the
reader to the PM NAAQS RIA for the background and derivation.  This will
allow you to review a much shorter document focusing on what has changed
in methodology and what the results are.  All chapters of the RIA are
designed in this fashion.  For example, those who have reviewed the
benefits chapter in the past are probably expecting to review roughly
150 pages not including the appendices.  The benefits chapter you have
to review is roughly 45 pages including tables.  The 2 appendices will
be familiar to those who reviewed the PM NAAQS RIA; the language is
virtually unchanged while the new results have been included.

Second, we have tried to be aggressive in providing you with the
methodologies and results in our briefings (including at least some time
for questions), so you should not be surprised by any of the
presentation in the chapter itself.  Certainly we welcome any comments
you have but I hope that our discussions have been clear enough that
there are no significant conceptual issues at this stage. As a result of
the detailed briefings, I am comfortable in supplying you with this
chapter even though much of the discussion in this chapter relies upon
references to other chapters in this RIA. Because these chapters have
yet to be finalized, you will not have available all the necessary
context to review the chapter but I think it is clear enough to proceed.
 

Third, I think it will be useful for you and the rest of the interagency
committee to start with the document entitled “overview of the
approach”.   In 2 pages it outlines our philosophical approach to the
design of the RIA.   I hope it will provide you some additional guidance
on how this chapter fits into the broader RIA structure.

Fourth, there is a special caveat to the language on ozone mortality. 
We, in partnership with other offices in EPA, have negotiated the
presentation and language on the ozone mortality piece with OMB and have
reached agreement on these.  We believe that the presentation and
language in the chapter enclosed is faithful to that agreement.   Please
review this portion with that spirit in mind and let us know where there
errors or we have not been completely faithful to the agreement.

Fifth, there is a detail in the California results that our internal
review pointed out that we needed to address in this cover note.  We
estimated the 2020 benefits for California fully attaining a revised
alternate standard of 0.070 ppm incremental to the current standard of
0.084 ppm in two ways. In method A we assumed that two areas in
California projected to be in severe nonattainment for the current
standard would need only to meet the so-called "glide path" design value
targets in 2020 which are above the current standard of 0.084 ppm and
would be above an alternate standard of 0.070 ppm. In California, San
Joaquin and LA qualify for these glide path targets. In method B we
"forced" 2020 full attainment of 0.070 ppm incremental to 0.084 ppm in
all parts of California. 

It is important to keep in mind that the glide path targets are
sensitive both to the analytical year and the severity of the projected
air quality problem. As such, we believe that the glide path targets are
a useful analytical construct that provide context to the total estimate
of national benefits. However, if the principal goal of this RIA is to
provide a best estimate of the costs and benefits of fully attaining an
alternative ozone standard incremental to the current standard, the full
attainment benefit estimate for California holds the most analytical
value for the attainment year of 2020.  This is clearly still an open
policy question and thus the presentation of the full attainment benefit
results may change pending the resolution of this question.

Finally, the ozone and PM incidence and valuation estimates use
difference confidence intervals. The next iteration of the benefits
chapter will use consistent confidence intervals across incidence and
valuation estimates.

I will be flowing chapters to you as soon as I feel they are ready.  I
expect that you will get several next week, hopefully a complete set by
the 25th or immediately following the holiday weekend.  For short term
planning purposes, I would ask you and the rest of the interagency
committee get comments back to us on this chapter and appendices by the
25th.

Please let me know if you have any questions or concerns about the
above.   

Ron Evans

Leader, Air Benefit & Cost Group

HEID/OAQPS/OAR/EPA

Mail Drop C-439-02

919-541-5488

919-541-0839 fax

