Estimating the Public Health Benefits of Proposed Air Pollution Regulations

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EPA estimates that thousands of premature deaths and cases of illnesses may be avoided by reducing air pollution. At the request of Congress, this report reviews the scientific basis of EPA's methods used in estimating the public health benefits from its air pollution regulations.
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Product Details

  • ISBN-13: 9780309086097
  • Publisher: National Academies Press
  • Publication date: 10/31/2002
  • Pages: 192
  • Product dimensions: 5.92 (w) x 8.94 (h) x 0.47 (d)

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations

Copyright © 2002 National Academy of Sciences
All right reserved.

ISBN: 978-0-309-08609-7

Chapter One


The U.S. Environmental Protection Agency (EPA)has estimated that thousands of premature deaths and numerous cases of illness, such as chronic bronchitis and asthma attacks, could be prevented by reducing exposure to air pollution. These estimates come from regulatory health benefits analyses, which attempt to quantify changes in the expected cases of mortality and illness that are likely to result from proposed air pollution regulations. The estimates are often controversial, and the methods used to prepare them have been questioned.

In 2000, Congress recognized concerns about the methods used by EPA and emphasized the need for "the most scientifically defensible methodology in estimating health benefits." It directed EPA to ask the National Academy of Sciences "to conduct a study of this issue and recommend to the agency a common methodology to be followed in all future analyses."


In response to EPA's request, the National Research Council (NRC) convened the Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations, which prepared this report. Members were chosen for theirexpertise in risk assessment, exposure assessment, toxicology, epidemiology, biostatistics, health economics, and air pollution regulations. The committee was asked to accomplish the following tasks:

1. Consider issues important in estimating the health-risk-reduction benefits of air pollution regulations, including the scientific data, risk-assessment approaches, populations affected, baselines used, assumptions, analysis of uncertainty, and identification of key indicators of exposure and population health status.

2. Critically review methods used for recent estimates of regulatory health benefits.

3. Identify methods used by federal regulatory agencies and others, recommend standard good-practice guidelines and principles for estimating health benefits, and delineate the data-gathering required to better assess health benefits in the future.

4. Identify approaches to estimating regulatory health benefits when relevant information is limited.

5. Where applicable, recommend areas for further research and monitoring.

The committee was not asked to evaluate methods used to estimate other types of benefits, such as improvements in visibility, resulting from air pollution control. The committee also was not asked to review the methods used for economic valuation of health benefits or for regulatory cost analyses.


To accomplish its charge, the committee heard, in public session, presentations from representatives of EPA, the U.S. Senate, the Office of Management and Budget (OMB), and other interested parties; reviewed materials submitted by EPA and others; and reviewed current literature relevant to health benefits estimation. The committee selected for detailed review the health benefits analyses contained in the regulatory impact assessments (RIAs) prepared by EPA for the following rule-makings: (1) "Particulate Matter and Ozone National Ambient Air Quality Standards" (1997), (2) "Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements" (1999), and (3) "Heavy Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements" (2000). The committee also reviewed the health benefits analysis completed for EPA's analysis of the benefits and costs of the 1990 Clean Air Act Amendments (CAAA) (1999). All of these analyses are described in Chapter 2 of this report (see Tables 2-1 and 2-5).

Ozone and airborne particulate matter (PM)were the primary focus of the EPA analyses selected by the committee for review. Therefore, the committee spent a considerable amount of time discussing these pollutants, especially PM, and did not address issues associated with the analysis of the hazardous air pollutants (HAPs). However, many of the findings and recommendations of the committee have broad applicability and are not limited to analyses conducted for PM.


Despite many inherent uncertainties, the committee concludes that regulatory benefits analysis can be a useful tool for generating information valuable to policy-makers and the public. Properly conducted analyses can help identify the type, magnitude, and relative importance of health benefits, highlight the sensitivity of the benefits estimates to assumptions made in the analysis, and indicate the areas of greatest scientific uncertainty. Information from the analyses can help focus future research efforts to reduce key uncertainties. The committee emphasizes, however, that estimates of health benefits and their economic valuation are only one part of the deliberative and political processes necessary for the development of sound policy.

Estimating the health benefits of a potential reduction in ambient air pollution involves a series of steps. First, the regulatory options to be evaluated must be clearly defined with regard to scope, timing, and implementation. Then, the boundaries of the analysis, such as the time period for which benefits are evaluated, must be established. In addition, the regulatory baseline (the description of conditions without the proposed regulation) must be defined. Once the analysis has been structured, future changes in pollutant emissions and resulting changes in ambient pollutant concentrations and population exposures can be predicted. Changes in health outcomes can then be estimated by applying concentration- or exposure-response functions (derived from the health literature) to estimated changes in population exposures.

The committee finds that these basic steps provide a reasonable framework for conducting health benefits analysis and that EPA has generally used this basic approach when estimating the expected health benefits of proposed air pollution control regulations. However, on the basis of the analyses reviewed by the committee, EPA's implementation of these steps could be improved. Recommendations for improvements in the process are described in the following pages.

The committee notes that analysis of health benefits for any regulation will require flexible, innovative, and multidisciplinary participation and guidance of scientific experts. Therefore, the committee did not attempt to write a detailed manual for conducting benefits analysis but instead addressed the key methodological issues and their importance in the EPA benefits analyses reviewed by the committee.

Regulatory Options, Boundaries, and Baselines

The health benefits that are estimated to result from reducing air pollution depend on the decisions made at the beginning of the analysis regarding the regulatory options to consider, the health outcomes to evaluate, the time frame over which benefits are estimated, and the assumptions made about conditions with and without implementation of the regulation. In three of the four EPA analyses reviewed by the committee, EPA focused on evaluating a single regulatory option. This approach conflicts with current OMB guidance on benefits analysis, which suggests consideration of a range of regulatory options and a variety of technical and economic interventions.

The committee acknowledges that EPA cannot evaluate every possible regulatory option, given time and resource constraints; however, a realistic range of options guided by expert opinion and technical feasibility should be represented in EPA's benefits analyses. At the beginning of each analysis, EPA should describe this range of options and any preliminary analyses that were conducted to exclude certain options from the formal benefits analysis. This approach would strengthen analyses that might otherwise appear to serve the purpose of justifying EPA's chosen regulatory option.

Once the regulatory options are selected, EPA must determine how broadly to define the scope of the analysis, including the degree to which secondary or unintended effects of the regulation should be examined. For example, air pollution regulations can change not only ambient air pollution levels but also how fuels are made or how combustion devices are operated. These changes might affect human health through other pathways, such as through water pollution or occupational exposures. An analysis of health benefits that ignores those effects might result in a substantial misrepresentation of the potential impacts of pollution-control measures on society. Although the committee recognizes that assessment of secondary effects may be difficult, the benefits analysis should discuss whether such impacts appear to be important and, if so, should incorporate a plan for assessing them.

Although EPA usually evaluates the costs of regulatory options for the time period between introduction and full implementation of the regulation, the benefits of the regulation have often been examined for only a single year-typically the year in which the regulation will have been fully implemented. Evaluation of benefits for only a single year has two limitations. First, when the costs of the regulatory action decrease over time and the benefits increase, the comparison of benefits and costs in the distant future could be misleading. Second, choosing an evaluation point in the distant future, such as 2030, is likely to increase the uncertainty associated with estimating both benefits and costs. These limitations can make the analysis misleading. Therefore, benefits should be estimated at reasonable intervals, such as every 5 years, over the regulatory time frame, including both the period of implementation and the expected period of expression of all significant health effects.

To estimate the benefits of a proposed air pollution regulation, EPA makes predictions about conditions expected to occur both with the regulation (control scenario) and without the regulation (baseline scenario). Predictions concerning air emissions and the U.S. population are especially relevant to calculating the health benefits. Two issues regarding emissions predictions particularly concern the committee. First, many important components of an emissions analysis, such as number of vehicles in a class, average miles traveled per vehicle, and emissions per mile, are seldom summarized for the benefits analysis. This lack of information makes it difficult to judge the plausibility of the emissions estimates. Second, current emissions models fail to provide an assessment of uncertainty associated with the emissions predictions for the baseline and control scenarios, which can be substantial. Comparison of emissions predictions to historical trends could help elucidate discrepancies that should be explained or formally incorporated into an uncertainty analysis and taken into account when estimating health benefits.

Predictions about future populations, such as numbers, age distributions, and baseline health status, are important aspects of EPA's benefits analyses. However, it is difficult to make confident predictions about the characteristics of populations 30 years in the future. EPA should evaluate the uncertainty involved in these predictions and the impacts of these uncertainties on the benefits estimates. Some sense of the uncertainty in these predictions maybe obtained by comparing the characteristics, such as age, sex, ethnic mix, disease, and mortality, of the projected future population with those of the populations studied in the epidemiological studies on which the benefits estimates are based.

Exposure Assessment

A critical step in estimating the benefits of proposed air pollution regulations is determining the effect of emissions changes on ambient air quality. This has traditionally been accomplished using air-quality models of varying complexity. EPA's approaches to exposure assessment evolved considerably over the period of the analyses reviewed by the committee as a result of continued improvement in the models and marked increase in available monitoring data for key pollutants. Overall, the methods used in the most recent EPA analysis reviewed by the committee (heavy-duty engine and diesel-fuel analysis) represent an appropriate and reasonably thorough application of the available data and models for exposure assessment.

Several issues, however, deserve to be mentioned regarding the models and the assumptions used in the exposure assessments. First, models are simplifications of reality. Estimating how well a model simulates pollutant concentrations in the ambient air resulting from emissions changes estimated at some future time is difficult and requires a systematic process of model testing and evaluation. Without such a process, it is difficult to know how much confidence to place in the predictions. The methods used to test the models also need to be clearly described in the benefits analysis. Second, many of the models used by EPA are time and resource intensive, thus limiting the modeling that can be conducted. The limitation is problematic because it restricts the number of regulatory options that can be considered and the number of years for which benefits can be estimated.

A tacit or explicit assumption in exposure assessment is that pollutant concentrations in ambient air adequately represent human population exposures. Although ambient concentrations in many cases appear to be reasonable indicators of human exposure, EPA should more rigorously assess the relative contributions of different emissions sources to human exposures. For example, EPA should evaluate whether PM emissions from diesel-fuel vehicles have a greater impact on human exposure than those from stationary sources, because diesel exhaust is emitted closer to people.

Another assumption specific to the analyses reviewed by the committee concerns PM. PM is a heterogeneous mixture that varies in size, composition, and source of origin; therefore, the health effects of PM exposures in one area might be different from those in another area and might vary over time. For example, the health effects of agricultural PM, which are derived primarily from crustal, animal, and plant sources, may differ from the health effects of urban PM, which are derived primarily from combustion sources, such as power plants and automobile and truck traffic. Because scientific information on PM toxicity is incomplete, EPA has typically made the assumption of equivalent potency across particle types. The committee believes that benefits analyses would be strengthened by evaluating a range of alternative assumptions regarding relative particle toxicity in sensitivity or uncertainty analyses.

Health Outcomes

The appropriate selection and definition of adverse health outcomes is integral to any assessment of health benefits. A wide range of health effects, primarily related to the respiratory and cardiovascular systems, is linked to exposure to air pollutants. In the analyses reviewed by the committee, EPA appears to have carefully considered the majority of these effects. However, many health outcomes are not quantified because there are insufficient data or because inclusion of certain health effects in the primary analysis could lead to double-counting.

The committee identified several issues regarding the selection and definition of mortality and morbidity (disease and other adverse health effects) outcomes. Clinically diagnosed illnesses, such as chronic bronchitis and asthma attacks, are typically evaluated in benefits analyses. A problem with these diagnoses is that they cover a wide range of severity levels and time courses. For example, chronic bronchitis can range from a chronic cough to a severe chronic airway obstruction that requires long-term care. The lack of clear categorization of outcome severity in benefits analyses has implications for quantification and valuation of the outcomes. Although EPA has made some attempt to deal with this issue, it needs to investigate and improve the methods used to reconcile differences between the severity of disease described in air pollution epidemiology and that commonly used to develop estimates of background disease prevalence and incidence.


Excerpted from Estimating the Public Health Benefits of Proposed Air Pollution Regulations Copyright © 2002 by National Academy of Sciences. Excerpted by permission.
All rights reserved. No part of this excerpt may be reproduced or reprinted without permission in writing from the publisher.
Excerpts are provided by Dial-A-Book Inc. solely for the personal use of visitors to this web site.

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Table of Contents


1 Introduction....................17
The Charge to the Committee....................18
The Committee's Approach....................18
Regulatory Context....................19
Critical Steps of a Health Benefits Analysis....................21
Organization of Report....................31
2 Health Benefits Analyses: EPA Case Studies....................34
Particulate Matter and Ozone National Ambient Air Quality Standards....................34
Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements....................42
Heavy Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements....................45
Prospective Analysis of the 1990 Clean Air Act Amendments....................49
3 Framing the Analysis....................57
Regulatory Options Evaluated....................57
Selection of Effects to Evaluate....................60
Time Frame for the Analysis....................62
Description of Conditions with and without the Regulation....................64
4 Exposure and Response....................75
Exposure Assessment....................75
Health Outcomes....................84
Concentration-Response Functions....................93
5 Uncertainty....................126
EPA's Approach toUncertainty Analysis....................127
Critique of EPA's Current Uncertainty Assessments....................133
Examples of Uncertainty Assessments....................138
Recommended Approach to Uncertainty Assessment....................141
6 Using, Presenting, and Reviewing Health Benefits Analyses....................153
Compatibility of Health Benefits Analyses with Cost-Benefit Analyses....................154
Compatibility of Health Benefits Analyses with Cost-Effectiveness Analyses....................156
Compatibility of Health Benefits Analyses with Cost Analyses....................157
Communication of Methods and Results of Analysis....................158
Quality Assurance and Quality Control....................163
Appendix Biographical Information on the Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations....................166

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