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From:  CN=Bryan Hubbell/OU=RTP/O=USEPA/C=US
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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




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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




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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" <mcgartland.al@epa.gov>
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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" <hubbell.bryan@epa.gov>, Lydia Wegman/RTP/USEPA/US@EPA, 
Marjorie Jones/RTP/USEPA/US@EPA, "page steve" <page.steve@epa.gov>
	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















