Estimating The Public Health Benefits Of Proposed Air Pollution Regulations

Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations

Board on Environmental Studies and Toxicology

NATIONAL RESEARCH COUNCIL
OF THE NATIONAL ACADEMIES

THE NATIONAL ACADEMIES PRESS
Washington, D.C.
www.nap.edu



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Estimating the Public Health Benefits of Proposed Air Pollution Regulations Estimating The Public Health Benefits Of Proposed Air Pollution Regulations Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations Board on Environmental Studies and Toxicology NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES THE NATIONAL ACADEMIES PRESS Washington, D.C. www.nap.edu

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations THE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, D.C. 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This project was supported by Cooperative Agreement No. X-82885301 between the National Academy of Sciences and U.S. Environmental Protection Agency. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the organizations or agencies that provided support for this project. Library of Congress Control Number 2002113941 International Standard Book Number 0-309-08609-4 Additional copies of this report are available from: The National Academies Press 500 Fifth Street, NW Box 285 Washington, DC 20055 800-624-6242 202-334-3313 (in the Washington metropolitan area) http://www.nap.edu Copyright 2002 by the National Academy of Sciences. All rights reserved. Printed in the United States of America.

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce M. Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm. A. Wulf is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce M. Alberts and Dr. Wm. A. Wulf are chair and vice chair, respectively, of the National Research Council www.national-academies.org

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations COMMITTEE ON ESTIMATING THE HEALTH-RISK-REDUCTION BENEFITS OF PROPOSED AIR POLLUTION REGULATIONS Members JOHN C. BAILAR, III (Chair), (emeritus) University of Chicago, Chicago, Illinois HUGH ROSS ANDERSON, University of London, London, England MAUREEN L. CROPPER, University of Maryland, College Park JOHN S. EVANS, Harvard University, Boston, Massachusetts DALE B. HATTIS, Clark University, Worcester, Massachusetts ROGENE F. HENDERSON, Lovelace Respiratory Research Institute, Albuquerque, New Mexico PATRICK L. KINNEY, Columbia University, New York, New York NINO KÜNZLI, University of Basel, Basel, Switzerland; as of September 2002, University of Southern California, Los Angeles BART D. OSTRO, California Environmental Protection Agency, Oakland CHARLES POOLE, University of North Carolina, Chapel Hill KIRK R. SMITH, University of California, Berkeley PETER A. VALBERG, Gradient Corporation, Cambridge, Massachusetts SCOTT L. ZEGER, Johns Hopkins University, Baltimore, Maryland Staff ELLEN K. MANTUS, Project Director ROBERTA M. WEDGE, Senior Program Officer RUTH E. CROSSGROVE, Editor MIRSADA KARALIC-LONCAREVIC, Research Assistant JENNIFER E. SAUNDERS, Research Assistant LUCY V. FUSCO, Senior Project Assistant Sponsor U.S. ENVIRONMENTAL PROTECTION AGENCY

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY1 Members GORDON ORIANS (Chair), University of Washington, Seattle JOHN DOULL (Vice Chair), University of Kansas Medical Center, Kansas City DAVID ALLEN, University of Texas, Austin THOMAS BURKE, Johns Hopkins University, Baltimore, Maryland JUDITH C. CHOW, Desert Research Institute, Reno, Nevada CHRISTOPHER B. FIELD, Carnegie Institute of Washington, Stanford, California WILLIAM H. GLAZE, University of North Carolina, Chapel Hill SHERRI W. GOODMAN, Center for Naval Analyses, Alexandria, Virginia DANIEL S. GREENBAUM, Health Effects Institute, Cambridge, Massachusetts ROGENE HENDERSON, Lovelace Respiratory Research Institute, Albuquerque, New Mexico CAROL HENRY, American Chemistry Council, Arlington, Virginia ROBERT HUGGETT, Michigan State University, East Lansing BARRY L. JOHNSON Emory University, Atlanta, Georgia JAMES H. JOHNSON, Howard University, Washington, D.C. JAMES A. MACMAHON, Utah State University, Logan PATRICK V. O’BRIEN, Chevron Research and Technology, Richmond, California DOROTHY E. PATTON, International Life Sciences Institute, Washington, D.C. ANN POWERS, Pace University School of Law, White Plains, New York LOUISE M. RYAN, Harvard University, Boston, Massachusetts JONATHAN M. SAMET, Johns Hopkins University, Baltimore, Maryland KIRK SMITH, University of California, Berkeley LISA SPEER, Natural Resources Defense Council, New York, New York G. DAVID TILMAN, University of Minnesota, St. Paul LAUREN A. ZEISE, California Environmental Protection Agency, Oakland Senior Staff JAMES J. REISA, Director DAVID J. POLICANSKY, Associate Director and Senior Program Director for Applied Ecology RAYMOND A. WASSEL, Senior Program Director for Environmental Sciences and Engineering KULBIR BAKSHI, Program Director for the Committee on Toxicology ROBERTA M. WEDGE, Program Director for Risk Analysis K. JOHN HOLMES, Senior Staff Officer SUSAN N.J. MARTEL, Senior Staff Officer SUZANNE VAN DRUNICK, Senior Staff Officer RUTH E. CROSSGROVE, Managing Editor 1   This study was planned, overseen, and supported by the Board on Environmental Studies and Toxicology.

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations OTHER REPORTS OF THE BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY The Airliner Cabin Environment and Health of Passengers and Crew (2002) Arsenic in Drinking Water: 2001 Update (2001) Evaluating Vehicle Emissions Inspection and Maintenance Programs (2001) Compensating for Wetland Losses Under the Clean Water Act (2001) A Risk-Management Strategy for PCB-Contaminated Sediments (2001) Toxicological Effects of Methylmercury (2000) Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices (2000) Scientific Frontiers in Developmental Toxicology and Risk Assessment (2000) Copper in Drinking Water (2000) Ecological Indicators for the Nation (2000) Waste Incineration and Public Health (1999) Hormonally Active Agents in the Environment (1999) Research Priorities for Airborne Particulate Matter (3 reports, 1998-2001) Ozone-Forming Potential of Reformulated Gasoline (1999) Arsenic in Drinking Water (1999) Brucellosis in the Greater Yellowstone Area (1998) The National Research Council’s Committee on Toxicology: The First 50 Years (1997) Carcinogens and Anticarcinogens in the Human Diet (1996) Upstream: Salmon and Society in the Pacific Northwest (1996) Science and the Endangered Species Act (1995) Wetlands: Characteristics and Boundaries (1995) Biologic Markers (5 reports, 1989-1995) Review of EPA's Environmental Monitoring and Assessment Program (3 reports, 1994-1995) Science and Judgment in Risk Assessment (1994) Pesticides in the Diets of Infants and Children (1993) Protecting Visibility in National Parks and Wilderness Areas (1993) Dolphins and the Tuna Industry (1992) Science and the National Parks (1992) Assessment of the U.S. Outer Continental Shelf Environmental Studies Program, Volumes I-IV (1991-1993) Human Exposure Assessment for Airborne Pollutants (1991) Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991) Decline of the Sea Turtles (1990) Copies of these reports may be ordered from The National Academies Press (800) 624-6242 or (202) 334-3313 www.nap.edu

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations Preface The U.S. Environmental Protection Agency (EPA) estimates 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 are derived from health benefits analyses, which attempt to quantify changes in the expected cases of mortality and illness that are likely to result from proposed regulations. These estimates are often controversial and the methods used to produce them are often questioned. Because of the importance of these estimates in decision-making, the U.S. Senate directed EPA to request that the National Research Council (NRC) evaluate methods used to derive the health benefits estimates and make recommendations on best practices for these types of analyses. In this report, the NRC’s Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations reviews recent EPA analyses and provides recommendations for improvement of the methods used. Specifically, the committee addressed issues concerned with the structure of the analysis, such as the regulatory options to evaluate, the time frame to use, and the assumptions to make about conditions with and without the regulation. The committee also considered issues regarding the exposure assessment, the selection of health outcomes and the concentration-response function, the analysis of uncertainty, and the presentation of the methods and results.

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise according to the procedures approved by the NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Aaron J. Cohen, Health Effects Institute, Boston, Massachusetts; Douglas J. Crawford-Brown, University of North Carolina, Chapel Hill, North Carolina; Edmund A.C. Crouch, Cambridge Environmental Inc., Cambridge, Massachusetts; Daniel Krewski, University of Ottawa, Ottawa, Ontario; Alan J. Krupnick, Resources for the Future, Washington, DC; Michal Krzyzanowski, European Centre for Environment and Health, Bonn, Germany; Jonathan I. Levy, Harvard School of Public Health, Boston, Massachusetts; Thomas A. Louis, Johns Hopkins Bloomberg School of Public Health, Baltimore, Maryland; Robert L. Maynard, U.K. Department of Health, London; Roger O. McClellan (emeritus), Chemical Industry Institute of Toxicology, Albuquerque, New Mexico; Michael H. Scheible, Air Resources Board, Sacramento, California; George D. Thurston, New York University School of Medicine, Tuxedo, New York. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Donald R. Mattison, National Institute of Child Health and Human Development, Bethesda, Maryland; and Maureen M. Henderson, (emeritus) University of Washington, Seattle, Washington. Appointed by the NRC, they were responsible for making certain that an independent examination of this report was conducted according to institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution. The committee gratefully acknowledges the following individuals for making presentations to the committee: Robert Brenner and Bryan Hubbell, EPA; Andrew Wheeler, U.S. Senate Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety; Robert O’Keefe, Health

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations Effects Institute; John Graham, Office of Management and Budget; and Alan Krupnick, Resources for the Future. In addition, the committee especially thanks Armistead Russell, Georgia Institute of Technology, who provided background information and further analysis on air-quality modeling to the committee. The committee is also grateful for the assistance of the NRC staff in preparing this report. Staff members who contributed to this effort are Ellen Mantus, project director; Roberta Wedge, program director for risk analysis; Eileen Abt, program officer; Ruth E. Crossgrove, editor, Mirsada Karalic-Loncarevic, research assistant; Jennifer Saunders, research assistant; and Lucy Fusco, senior project assistant. I would especially like to thank all the members of the committee for their efforts throughout the development of this report. John C. Bailar, III, Chair Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations Contents     Summary   1 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     Guidance,   23     Organization of Report,   31     References,   32 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     References,   54

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations 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     Conclusions,   71     Recommendations,   72     References,   73 4   Exposure and Response   75     Exposure Assessment,   75     Health Outcomes,   84     Concentration-Response Functions,   93     Conclusions,   115     Recommendations,   116     References,   118 5   Uncertainty   126     EPA’s Approach to Uncertainty Analysis,   127     Critique of EPA’s Current Uncertainty Assessments,   133     Examples of Uncertainty Assessments,   138     Recommended Approach to Uncertainty Assessment,   141     Conclusions,   146     Recommendations,   146     References,   148 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

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Estimating the Public Health Benefits of Proposed Air Pollution Regulations     Conclusions,   164     Recommendations,   164     References,   165     Appendix Biographical Information on the Committee on Estimating the Health-Risk-Reduction Benefits of Proposed Air Pollution Regulations   166

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