On their way out the door the Trump Administration’s EPA is making it harder to consider health benefits by adding new cost-benefit analyses in conjunction with the Clean Air Act.
For the Biden Administration it will require a formal process to undo it, so this is some seriously bad medicine.
Some argue this rule is not needed as there are already mechanisms to include cost-effectiveness.
Just some of the concerns:
—Unbalanced treatment of benefits and costs by setting more stringent standards for benefit estimation than cost estimation
—Uses a “willingness-to-pay” metric that is not good at measuring non-market goods, such as air quality and associated health risk
—Benefits richer communities and continues to put poorer communities at greater risk
—Disregard forco-benefits (such as particulate matter also be considered with presence of mercury)
— Burdensome provisions would embolden corporate polluters
Proponents praise that it brings more consistency and transparency. If only that were the true intention!
From a multi-state letter from Attorneys General written earlier this year:
“The Proposal would arbitrarily weaken benefit-cost analyses by, for example, narrowing consideration of benefits, neglecting co-benefits, and minimizing greenhouse gas-related benefit-cost analyses, in violation of EPA’ s core mission to protect human health and the environment.”
Here’s the 113-page rule document if you are so inclined:
Read what American Lung Association has to say:
Letter from Attorneys General: