FUTURE REGULATORY-IMPACT ANALYSES INVOLVING OZONE MORTALITY
Because short-term exposure to ambient ozone is likely to contribute to premature deaths, future regulatory-impact analyses (RIAs) concerning ozone- control measures should include the benefits of reduced mortality risk. As in EPA’s RIA for the recently finalized ozone NAAQS, emphasis should be on using estimates from new systematic multicity analyses that used national databases of air pollution and mortality, such as in the National Morbidity, Mortality, and Air Pollution Study, without excluding consideration of meta-analysis of previously published studies. Future RIAs should give little or no weight to the assumption that there is no causal association between estimated reductions in premature mortality and reduced ozone exposure. Health-benefits estimates should be accompanied by a broad array of analyses of uncertainty.
Distributed-lag models over several days appear better than single-day models at capturing the acute and subacute mortality effects of ozone exposure and should be part of future benefits assessments to the extent that they are supported in the literature.
Future RIAs should incorporate research results on the mortality effects of chronic ozone exposure and research that addresses key uncertainties related to potential confounding factors, exposure measures, and susceptibility as appropriate.
Despite many concerns about the accuracy of any specific WTP value and a corresponding VSL that does not vary with population or risk characteristics, the committee recommends a single VSL as the most scientifically supportable approach at present for monetary valuation of ozone-related mortality. Before making a substantial change in its approach for valuation of mortality-risk reductions, EPA should have fairly conclusive empirical evidence to support the change. It is the committee’s judgment that the available evidence is not now sufficient to support such a change, but sensitivity analyses should explore alternative approaches and further research should be conducted to answer the questions raised about the validity of EPA’s current approach. Benefits-assessment methods may need to be revised as new information emerges on characteristics of populations susceptible to an ozone-mortality risk and on variations in WTP for mortality-risk reductions (or increases in life expectancy) based on different population characteristics.
EPA should consider placing greater emphasis on reporting changes in age-specific death rates and changes in life expectancy in the relevant populations than on reporting estimates of lives saved or premature deaths avoided.
In this report, the committee has identified major gaps in knowledge about methods for assessing benefits of ozone-related mortality risk reduction and has recommended research strategies to close those gaps. The committee recognizes that many of the recommended research activities are complex and will be difficult to undertake, and that sufficient resources may not be available to undertake them all in the near term. Therefore, EPA and other agencies that might carry out the recommended research will need to set priorities and develop a strategy for addressing the various information needs.