ILLINOIS

POLLUI

)N

‘ON2ROL BOARD

March

,

1978

IN THE

MATTER

OF:

AMENDMLNTS 9~O

THE

ILLINOIS

AIR POLLUTION

EPISODE

REGULATIONS

SUPPLEMENTAL OPINION

OF THE

BOARD

On

April

9,

1976 the

Illino

P llution Control Board

(Board)

adopted

an Interim

Opinion

11

this proceeding~

21 PCB

169~

In

that

Opinion the

Board stat~2Its reasons

in

support

of the

Regulation

as adopted,

includirg Its reasons for providing

that the Regulation take

effect wit

it

deIay~ Pursuant to

§27(b)

of the

Illinois

Environmenta

~rotection

Act

(Act),

Ch.

111~1/2

Ill

Rev~Stat. §1027(b)

(1°5

the Board conducted

hearings

on the

economic impac

~t the rew Regulation

while the

new Regulation continued in

effect

~2~esehearings were held

August

2,

1977 in Chicago and

Auqi st

2

,

1977 in Springfield~

Most of the testimony

given

ctt

he August

2

and August

24

hearings dealt with the economic

irrp~ctstudy published

by the

Illinois Institute for Environrcental

Qhallty,

IIEQ Document

No.~ 77/04, “Cost/Effectiveness

o

t

e

Illinois Ozone Episode

Regu1ation~” This study was p

cp~

d

pursuant to §6(b),

(d)

of

the Act, Ch~ ll1~-1/2

I1LRev~Stat

~,

006(b),

(d)

(1975),

and

attempted to quantify the

social

cst~and ozone precursor

reductions attributable to

the inst ant Regulation

(**R~6;Ex~ 64,

pal).

The author of the

study

Dr~Alan Cohen, claimed order-

of-magnitude accuracy (R~36;

Ex~ 64

p

11).

Benefits of the

tradit~oni r~crtwere not estimated~

For

example,

a common

benefit estina br

technique entails using

some

sort of damage fu~ctron

ctes changes

in the

ambient

concentration of a giier po11u~ant~o a given indicators

The indicator

may

be such a

th~~as hospital-days, mortality

rates,

or, most commonly,

dollars

This type of

analysis

is not

possible

with

ozone~

Ozone,

i~rlike

ither pollutants,

is formed

in the airs

Meteorology great

v

influences the distribution of

ozone, an~the fraction of lo

~irrent ozone obtained

from

local emissions

will

in part iet~riire the effectiveness of a

*

The Board acknowledges

the accistance of Ken F~Kirkpatrick,

Administrative

Assistant

to the Board,

in the preparation

and drafting of

this

Suppleniertcl

pinion.

**

In this Opinion

“R” refers

to the economic impact hearings;

“T” iefers

to

all other

heasi

~

29

—

470

---

control action reducing local precursor eriissions.

Ozone trans-

port is

not completely understood and thus the effect on

ambient

ozone

levels

in one Air Quality Control Regior

caused

by initi-

ation of control

acti-~nnin another RegloL

‘see Rule 402(f))

would be difficult or impo~sib1e to accura ely predict,

The

above illustrate tI~eurcortain nature of th?. rulationship between

precursor reductions and ozone levels,

The basic appron~ used in the econo~iicimpact study was

to

divide the Regulatio~ 1

22 separate ‘~ortrolactions and perform

an analysis of each actr

n.

It was cmp~asizelthat the

22

actions

are not independeiit ard that to e~tixate~os

s and precursor

reductions of each i~iaodestage rsquired further analysis

(R.6,

Ex.

‘~4, p 2o~j

Several key as:urptions used

r

the

SLULJ

should be noted.

It was assumed that produ~tiona ~d cons inptio

t tals would

not

change

(R,ll)

ard that the adjustmcnt.~made

t

keep these totals

despite episodes are the primary costs a~tribitable to the

Regu—

lation

(R 11).

tll e~tploymentwas

~issumed R,lOl

and

delayed

production was assuired to use overtirie labo

(R.24

Dx.

64,

pp.123,

248,

272,

289,

~96,

314)

.

Episodes gererally were assumed to

occur

on weekdays and assumed to begin at the ~tart

of a workday

(Ex.

64, p.11)

uercain emission reduction estimates assume

otherwise,

either ixplicitly

(Ex.

64, p 124

or explicitly

(Ex.

64, p.298).

The Chicago Standard Metropolitan Statistical Area

(SMSA)

was used

n.~the study area

(Ex

64, p

~i,

and

it

was assumed

that

results

for Illinois

could

be calculatad b~sca~ingup

Chicago

SMSA results

by a

factor of 1.48,

(Dx.

64

p

5

footnote

d;

p

301).

Voluntary

reductions

in consumption ~cr~ vieqed a~social costs.

(Ex.

64, pp.2,

18

286

292,

29a

315

I~cBoard a~sonotes the

statement of the author of the study

~I

end to ove~estimate

costs

and underestimate benefits”

(R.lI’

As mentioned abore

an est station

f

the csts and emission

reductions of eact epi~do stage required ricre

than a simple

summing of the applicable .~ontroi act ens

ouch ar estimation

was

made for variou~ep ~ de lengtI~s Dx

64

up

283~298)

.

An

ozone

Advisory

is en mated

to have a soc a

cost comprised solely

of

diverted br adc~sttimc used ~or publ:c rotification.

Precur-

sor reductions were assumed

to

be

insmgr tm~nt

*

The social

costs

of a Yellow Alert were estirrated

lx

64, up 284~286)

Notification costs and th~costs assocma~d ~12h

a soluntary re~~

duction

in electricitl

~nsurup~ioii~rs~i12st

ov~r90

of the

total cost

of a Yel1o~ Alert

(Ex.

64, p 283

Table 25.2)

~his

estimation emphasizes

that tnis study does not estimate

benefits

in the traditional sense

No12ficatmon at the advisory

level obviously

benefits susceptible mdi

iduals despite the

fact that there

may be

no reduction

in precursor emissions.

29~471

---

—3—

When the ozone concentration reaches 0.3 ppm, the next epi-

sode stage,

a Red Alert,

is reached.

This

is the level at which

the health of the entire population is adversely affected and

the level at which emission reductions will affect ozone formation.

Both costs and emission reductions are significantly higher than

they are for the Yellow Alert

(Ex.

64, p.288,

Table

25.6).

The

most significant single cost by far is overtime adjustment, com-

prising over 70

of the total costs of a one day Red Alert

(Ex.

64, p.288,

Table

25,6),

The overtime adjustment cost is the sum

of the costs

to the manufacturing, waste collection,

and trans-

portation and utilities industries of making up for lost production

(Ex.

64,

p.291)

.

Large manufacturing firms are assumed to need an

additional day

after

an episode to start up operations

(Ex.

64,

p.289).

The Emergency level of 0.5 ppm will activate all control

actions, resulting in the greatest social cost and largest pre-

cursor emission reductions.

Again the overtime adjustment compo-

nent is the most significant

cost,

being over

75

of the total

cost of an Emergency episode

(Ex.

64, p.296,

Table 25.15).

An estimation of the annual costs and emission reductions of

the Regulation was made

(Ex.

64, pp.298-300).

This was done by

multiplying the costs and emission reductions of the various

episode

stages by their expected yearly frequencies

(Ex.

64,

p.298, Equation 25.8).

These frequencies appear to be somewhat

higher than past experience would indicate

(T.l28l; R.ll9-120;

R.19)

for this and other reasons the annual cost estimates were

termed “..,somewhat tenuous...”

(R.l9)

by the study’s author,

Dr. Cohen, who suggested that the annual estimates “...should

not probably be given that much weight in terms of evaluating the

Regulations”

(R.l9).

The efficiency of the Regulation,

defined as cost per unit

of emission reduction, was examined in a number of contexts

(Ex.

64, pp.

302—303;

308—311;

316—320)

.

Due to the interrelated

nature of the various control actions, some analyses are severely

limited

(Ex.

64, p.302).

However,

it can be seen that “...for

small reductions in emissions the cost per ton reduced is

relatively small.

As the

total quantity of emission reductions

increases,

the cost

per ton

reduced increases”

(Ex.

64, p.316).

Those control actions with high emission reduction potential,

but at a relatively high

cost,

are called into play at those

higher levels where the health of the entire population is ad-

versely affected.

For example,

Dr. Cohen~sorder—of—magnitude

estimates of hydrocarbon and NO~emission reductions

in the

Chicago SMSA for a one day Yellow Alert are 42.3 tons and 69.3

tons at a total social cost of $108,000;

for a one day Red Alert

are 925 tons and 492 tons at a total social cost of $9,320,000;

and for a one day Emergency are 1490 tons and 953 tons at a total

social cost of $36,600,000.

The cost/effectiveness ratios,

in

terms of dollars per ton of precursor emission reduction,

grow

29—472

---

from

$968/ton

(Yellow

Alert

t

(Emergency)

(Ex.

64, p 312

tat

The

Illinois

ManufacLure

only

comment

on

the

Ste

j.

Study

presented

,,a

gr

.s

ur

these

regulations

to

th

i12

z

s

The

original

p~ep

~a

mental

Register

#1

0

among the

Yellow

Alert

coa.

r

the

International

Courci

~

action

to be

relat

e

COS

y

ratios,

when

conpared

to

the

(T.905—957).

This

testrmor

Study,

given

the

a.~ut

cj

Ii

It should

be

notel

tfct~

c

lot

restrictions

trait

12e

el

actions.

In conclusi

r

he

Boar

Yellow

Alert

lev~

to

o

for

an

Advisory

was

2

of

d

pp.283—4).

Notif

~tm

1

~O

ar

reductions

in e

ectric

Ly

o

over

90

of the

total

c

st

25.2).

At these 12o

“~

el

12

adverse

economic

imp~

or

t

c

The

control

actiors

a

trw

t

are

more

severe

as

ar~

th

he

t

these

higher

levels

gerera

I

potential

as

well

an

e

g

ea

as

cost

per

ton

of

o

l~’~’

or

1c

more

severe

controL

-c~

~

adverse

economic

mirpact

vi

people

of

the

State

o~

t

m

t

adverse

economic

mn~a

e

B

a

economically

reasorab

c

i

m

of

what

one expert

h

cd

tants”

(T.l06)

The Board

cone

uced

extremely

dangerois

po2

(that

is, above

u

3’~

~Oi

are less

pronounced

extensive

testimony

tejaro

r

testimony

indicated

that

)~

af

lung

tissue;

causes

chro

a

r~-

t

d t e

t

to $15,000/ton

I

ur

ttcd

the

‘as tnat the

~ont

f

C

3

1)

•ab

o

5

20),

C

arkmrg

e trol

)t~~

and

ated

ii

tary

itute

L

Dable

~-a~ no

c

evcls

a

mc

s at

ction

s

as

well

These

~some

I

a

the

~e

this

C

C

edes

oli~

r

~

us

-~

-

I

~.LoinS

12

ed on

n

ama

a

r

ar’~’

r riton—

r

ctmons

Ia

I

ritrol

x

4

I

---

—5-.

causes

red

blood

cell

fragility and enzyme modifications; decreases

lung capacity; increases cough and chest discomfort rates; acts

synergistically

with

sulfur

dioxide; inactivates

an enzyme called

benzopyrene hydroxylase, which destroys a known carcinogen; affects

the release of oxygen from hemoglobin;

and may cause premature

aging similar

to continued exposure

to ionizing radiation.

21 PCB

169,

170-172.

The ozone episode regulation is intended to reduce

the frequency and

severity

of these and other medical effects.

Such reductions

are the

true benefits of this regulation and these

benefits are

as necessary today as they were when the Regulation

Mr. Werner dissents.

I,

Christan

L.

Moffett,

Clerk of the Illinois Pollution Control

Board,

hereby

certify

the pbove Supplemental

Opinion was adopted on

thea~~day

~

1978 by

a vote of

I/~i

Illinois Polluti