Last week, ATS member Edward Petsonk, MD, testified in Charleston, West Virginia at an EPA hearing to collect public input on the EPA’s recent proposal to repeal the Clean Power Plan to reduce greenhouse gas emissions from U.S. power plants. 

In his comments, Dr. Petsonk noted that the EPA used faulty assumptions to estimate the cost benefits of repealing the Clean Power Plan.  In 2015, when the EPA first announced its Clean Power Plan to reduce greenhouse gas emissions, the agency estimated that, by 2030, the plan would cost $8.4 billion to implement, but would result in $34-$54 billion in health benefits.  Two years later, the EPA is proposing to repeal that same rule, re-estimating that compliance costs would exceed $33 billion, while yielding only $20-$24 billion in benefits.      

Under the new “cooked book” cost estimating, the EPA willfully ignores the health benefits associated in co-pollutant reductions that would also have been achieved under the Clean Power Plan.  These health benefits were fully recognized in the 2015 cost estimate – as was common practice for federal agencies in both Republican and Democratic Administrations.

Further, EPA also now assumes a “threshold effect” that ignores the significant health benefits for reducing pollution emissions below EPA established standards.

The “threshold effect” assumes there is a pollution exposure level limit at which any further reductions do not yield additional health benefits.  Multiple research studies have shown that reduction in air pollution exposure levels – at levels below EPA standards – results in measurable and significant improvements in health.  The EPA’s decision to apply a “threshold effect” to the cost-estimate dramatically under values the health benefits that would be achieved by reductions in air pollution emissions.

The comments deadline for the EPA’s proposal to repeal the Clean Power Plan closes January 16, 2018.