HomeWashington Letter2020 ▶ EPA Issues Proposed Rule to Change Clean Air Cost/Benefit Calculations
EPA Issues Proposed Rule to Change Clean Air Cost/Benefit Calculations

Last week, the EPA issued a proposed rule seeking to significantly change how the agency calculates the costs and benefits of future Clean Air Act standards. If implemented, the proposed rule would make changes to the cost/benefit estimation process that emphasize industry compliance costs and under-value the public health benefit of Clean Air Act protections.

“The announcement by EPA to revise their approach to cost benefit analysis, including their proposal to not consider reductions in co-pollutants in calculating benefits of agency actions, remind us how far the agency has strayed from its original mission and organizing principles when it was established 50 years ago,” says Kevin Cromar, PhD, co-chair of the ATS environmental Health Policy Committee.  

Recognizing that a piecemeal approach to complex environmental challenges defies effective action, President Nixon called for the creation of the EPA to not only bring together the diverse disciplines necessary for effective pollution control, but also to perceive the environment as a single, interrelated system.  The EPA's proposal not only divorces their evaluation of the societal benefits of environmental protection from established economic principles, it also attempts to fragment the management of an interconnected environment into discrete pollutants as if they were emitted separately from one another.

It is particularly concerning that the Agency intends to rely on the results of their flawed Integrated Scientific Assessment to no longer consider the economic benefits of reducing mortality risks from exposure to elevated levels of ozone.  The scientific community provided overwhelming evidence, to no avail, in opposition to the Agency's decision in 2019 to downgrade the impacts of ozone on mortality from "likely to be causal" to "suggestive of a causal relationship." The proposed rule intends to rely on this existing agency document to selectively remove mortality impacts from ozone from future inclusion in benefit calculations.

The deadline for submitting comments on the EPA proposed rule is July 27. Due to the complexity and significant impact of the proposed rule, the ATS seeks an extension in the public comment period. 

Last Reviewed: June 2020