Dec 9 2020: EPA puts costs before health in New Cost-Benefit Rule

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:

(https://www.epa.gov/sites/production/files/2020-12/documents/final_rule_increasing_consistency_and_transparency_in_considering_benefits_and_costs_in_the_clean_air_act_rulemaking_process_-_prepublication_version.pdf)

Read what American Lung Association has to say:

https://www.lung.org/getmedia/3b300666-ff1a-49f4-9e02-6a5a53ebe9ef/epa-cost-benefit-analysis-in-clean-air-rulemakings-factsheet.pdf

Letter from Attorneys General:

https://oag.ca.gov/system/files/attachments/press-docs/Multi-State%20Comment%20Letter%20on%20EPA%27s%20Proposed%20Clean%20Air%20Act%20Cost-Benefit%20Rule.pdf