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<strong class="journal-contentHeaderColor">Abstract.</strong> Chemical mechanisms are critical to chemical transport models for air quality research and policy analysis. Several mechanisms are available and intercomparison, especially using metrics which reduce sensitivity to modeling scenario, is important for interpreting results and assessing uncertainties. Here, we investigate Ozone Production Efficiency (OPE) as a comparison metric under conditions where nitrogen oxides (NO<sub>X</sub>) are limited. OPE is the net number of ozone molecules produced per NO<sub>X</sub> molecule lost and can be computed in simulations using chemical process analysis (CPA). We compute OPE (OPE-CPA) for four chemical mechanisms (CB6r5, CB7r1, SAPRC07, RACM2) and find a similar response to varying anthropogenic emissions of volatile organic compounds (VOC) and NO<sub>X</sub>. RACM2 consistently produces the largest OPE-CPA and differences between mechanisms are greatest at high VOC/NO<sub>X</sub> ratios. The high RACM2 OPE-CPA is partially due to a slower OH + NO<sub>2</sub> rate and potentially to its treatment of NO<sub>X</sub> recycling. OPE-CPA is generally consistent with aircraft OPE measurements downwind of Houston but direct comparison is difficult due to uncertainties in deposition and VOC speciation. More recent OPE measurements are required to determine whether trends over time are consistent. OPE-CPA responds nonlinearly to NO<sub>X</sub> and increases at low NO<sub>X</sub> even as ozone production decreases. Using OPE to predict ozone response to NO<sub>X</sub> emissions reductions is therefore an oversimplification that will tend to overstate ozone reductions. OPE-CPA is a viable metric to compare mechanisms, however, additional work would be helpful to define standardized conditions for comparisons.