If you were to do a cost-benefit analysis of your lunch, it would be pretty difficult to do the calculation without the sandwich. But it appears that the US Environmental Protection Agency (EPA) is moving in this same direction—removing the benefit—when it comes to air pollution regulations.
According to a New York Times report based on internal emails and documents—and demonstrated by a recently produced analysis on the EPA website—the EPA is changing its cost-benefit analysis process for common air pollutants. Instead of comparing the economic cost of a certain pollution limit to an estimate of the economic value of the resulting improvements in human health, the EPA will just qualitatively describe health benefits while carefully quantifying economic costs.
Cost-benefit analysis has been a key component of EPA regulations. Any decision to raise or lower air quality standards or pollution limits includes evaluations of the cost that change, like the addition of new pollution control equipment at power plants, would incur, for example.
That cost gets compared to the economic benefits of reduced pollution, which is obviously a bit harder to calculate. At the more tractable end of the spectrum, they can calculate things like health care costs and lost economic productivity for people whose health worsens. Even this requires an estimate of how much of a health impact to expect for a given change in pollution.
But what’s the intrinsic dollar value of someone’s health? Attempts to tackle that thorny question in some practical way result in estimates known as “value of a statistical life.” The EPA has described this as “how much people are willing to pay for small reductions in their risks of dying from adverse health conditions that may be caused by environmental pollution.” Having this number gives us something to hold up next to the cost of that pollution control equipment.
The move to exclude the estimated benefits relates specifically to fine particulate matter smaller than 2.5 micrometers (known as PM2.5) and ozone. This particulate matter, commonly produced by combustion, is small enough to make it through your respiratory system and into your bloodstream. For this reason, it is associated with a host of health impacts even beyond respiratory conditions. That has made research on those impacts the target of anti-regulation advocates who claim scientists exaggerate the harm.
Ozone is also a familiar enough pollutant in smoggy areas to be mentioned in weather forecasts as a warning for people with conditions like asthma. Ozone pollution in the lower atmosphere results from reactions between nitrogen oxides and volatile organic compounds emitted by various anthropogenic sources.
The new EPA language claims that past analyses have failed to adequately represent the scientific uncertainty of the economic value of reducing these pollutants. The new economic impact analysis for stationary combustion turbines, for example, says this “leads the public to believe the Agency has a better understanding of the monetized impacts of exposure to PM2.5 and ozone than in reality.” It continues, “Therefore, to rectify this error, the EPA is no longer monetizing benefits from PM2.5 and ozone but will continue to quantify the emissions until the Agency is confident enough in the modeling to properly monetize those impacts.”
A 2024 regulatory impact analysis for stationary combustion turbines had estimated those benefits at $27–$92 million per year for a tightening of emissions limits.
This is not the first time that these numbers have become political targets. Between 2004 and 2008, the Bush administration reduced the EPA’s value of a statistical life by around 11 percent. But instead of moving numbers to the lower end of scientific estimates, the Trump administration is more aggressively weaponizing scientific uncertainty. Functionally, the logic is that since estimates of benefits vary from large to extremely large, the EPA will default to a value of zero. Only the costs will be calculated, and those numbers are sure to be highlighted as justification for loosening pollution limits.
Currently, documentation for how the EPA previously calculated pollution regulation benefits based on research—including transparent assessments of scientific uncertainties—is still available on the EPA website.
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