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By law, the EPA cannot consider costs when setting a health-based National Ambient Air Quality Standard (NAAQS). Nonetheless, to inform stakeholders, the Agency typically calculates the costs of meeting the NAAQS as well as the monetary benefits.
Note: The current health-based ozone standard is 75 ppb.
The EPA estimates costs at $3.9 billion in 2025 for a standard of 70 ppb and $15 billion for a standard of 65 ppb nationwide, excluding California. (The Agency has analyzed costs and benefits for California separately because a number of California counties would have longer to meet the proposed standard, based on their ozone levels.) Health benefits in 2025 are estimated at $6.4 billion to $13 billion annually at 70 ppb, and $19 billion to $38 billion annually at 65 ppb, again, except for California.
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Table 1 shows what the EPA says are the costs and net benefits for 3 alternative ozone standards for the country, excluding California. Table 2 shows the costs and net benefits for the 3 alternatives of California.
Table 1: Costs and benefits in billions (2011 dollars) nationwide (except California) in 2025
| 70 ppb | 65 ppb | 60 ppb | |
| Cost | $3.9 billion (b) | $15b | $39b |
| Benefits | $6.4b to $13b | $19b to $38b | $34b to $70b |
| Net Benefits | $2.5b to $9.1b | $4b to $23b | $5b to $31b |
Table 2: Costs and benefits in billions (2011 dollars) for California post-2025
| 70 ppb | 65 ppb | 60 ppb | |
| Cost | $0.80b | $1.6b | $2.2b |
| Benefits | $1.1b to $2b | $2.2b to $4.1b | $3.2b to $5.9b |
| Net Benefits | $0.3b to $1.2b | $0.60b to $2.5b | $1b to $3.7b |
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Other Proposed Changes
In addition to changing the primary ozone NAAQS, the EPA has proposed other substantial changes related to ozone standards. These include:
- Secondary standard. The secondary standard for an NAAQS is established to protect “public welfare,” a term that generally refers to ecosystems and vegetation. The EPA is proposing to also amend the secondary standard to within the range of 65 ppb to 70 ppb measured over 8 hours; the proposed form is the same as the existing form. Also, in setting the secondary standard, the EPA is using the W126 index, a seasonal index that scientists often use to assess the impact of ozone on plants and trees. The Agency is proposing that air quality meeting a W126 index value between 13 and 17 parts per million-hours (ppm-hours), averaged over 3 years, would provide the “requisite protection” that the law requires.
- Monitoring. Under existing regulations, the current ozone monitoring season requires monitoring seasons from 4 to 12 months, depending on the state. But, according to the Agency, year-round monitoring data for 2010 to 2013 show that ozone can be elevated earlier in the spring and last longer into the fall, periods for which monitoring is not currently required in some states. Therefore, the EPA is proposing to lengthen the monitoring seasons for 33 states. Under the proposal, the monitoring season would be extended by 1 month for 24 of the 33 states, with longer extensions in 9 others.
- State implementation plans (SIPs). In September 2013, the EPA issued general guidance to states on submitting infrastructure SIPs. In the proposal, the Agency notes that this guidance did not address the critical issue of ozone transport, and that will be one major addition to an updated guidance document the Agency says it will issue within 1 year after the final revised ozone NAAQS.