How a Minor Change to EPA Rules Could Slash Environmental Protection
By Joseph Aldy
Since the Reagan administration, federal agencies have been required to produce cost-benefit analyses of their major regulations. These assessments are designed to ensure that regulators are pursuing actions that make society better off.
In my experience working on the White House economic team in the Clinton and Obama administrations, I found cost-benefit analysis provides a solid foundation for understanding the impacts of regulatory proposals. It also generates thoughtful discussion of ways to design rules to maximize net benefits to the public.
On June 7, U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt proposed changing the agency's approach to this process in ways that sound sensible, but in fact are a radical departure from how government agencies have operated for decades.
As the agency frames it, the goal is to provide "clarity and real-world accuracy with respect to the impact of the Agency's decisions on the economy and the regulated community." But I see Pruitt's proposals as an opaque effort to undermine cost-benefit analysis of environmental rules, and thus to justify rolling back regulations.
The Importance of Co-Benefits
Have you ever done something for more than one reason? An action that you justified because it "kills two birds with one stone"? When a regulation leads to improvements that it was not designed to produce, government agencies call the unexpected payoffs "co-benefits."
For example, the Clean Air Act's Acid Rain Program was designed to reduce sulfur dioxide pollution from electric power plants, a key ingredient in acid rain. Some utilities complied by installing devices called scrubbers to capture sulfur dioxide emissions from plant exhaust.
The scrubbers also reduced fine particulate matter, which is linked with a wide range of health effects that can cause premature deaths and illnesses. This represented a huge co-benefit—one that economists have estimated to be worth $50 billion to $100 billion yearly.
Historically, federal agencies have given co-benefits full weight in regulatory impact analysis because they help to show how Americans would be better off under the policy for multiple reasons. Pruitt wants to change this policy.
Eliminating Co-Benefits From Rule-Making
Pruitt's proposal solicits public comment on how to weigh co-benefits from pollution reductions. While this request may appear neutral, it reflects an interest in trying to minimize or eliminate consideration of co-benefits.
According to an EPA analysis, amendments to the Clean Air Act in 1990 that tightened emissions standards will produce benefits through 2020 that exceed their costs by a factor of more than 30 to one.USEPA
Why would EPA's administrator seek to reduce estimated benefits of regulations? As I see it, the agency faces a regulatory conundrum. President Trump issued an executive order in 2017, focused on the costs of regulations that required agencies to eliminate two rules for every new rule they issue. Since regulations have benefits as well as costs, if an existing rule delivers more benefits than costs, then striking it would impose net harm on the public.
For example, Pruitt is seeking to roll back three Obama administration air pollution initiatives: the Clean Power Plan, which limits greenhouse gas emissions from power plants, and combined carbon emission and fuel economy standards for light-duty vehicles and heavy-duty vehicles. Halting these rules would save money for some electric utilities and vehicle manufacturers, but would also greatly increase air pollution.
Specifically, one recent analysis estimates that eliminating these rules would increase premature deaths from inhaling fine particulate matter by more than 80,000 over a decade. In today's dollars, and using the current value EPA employs to monetize mortality risk reduction, public health costs from reversing these three rules amount to nearly $75 billion per year—far more than any potential benefits to industry.
Even for an administration with a strong deregulatory tilt, such a step would raise political red flags. It also would run afoul of another executive order that has governed regulatory review in Democratic and Republican administrations since 1993, and requires agencies to issue rules if their benefits justify the costs. The Obama administration concluded that each of these air pollution regulations passed that test.
But what if the EPA can find a way to ignore major categories of benefits, such as zeroing out estimated co-benefits from reducing premature deaths? Then regulatory rollback could appear to pass a cost-benefit test on paper, even if it makes the American people worse off in the real world.
Pruitt has already taken other steps in this direction. Notably, the EPA has reduced its estimate of the damages from climate change from $42 per ton of carbon pollution at the end of the Obama administration to as low as $1 per ton now. This makes the social benefit of actions that reduce greenhouse gas emissions, such as the Clean Power Plan, look much smaller than they actually are.
EPA Administrator William Reilly, left, watches as President George H.W. Bush signs the Clean Air Act Amendments, November 15, 1990.USEPA archive / Carol T. Powers
Gaming the Numbers
The late Nobel laureate Gary Becker, who often called for limited government intervention in the economy, once wrote that "cost-benefit analysis may also be useful for undermining misleading claims of self-interested political pressure groups." By this he meant that rigorous, transparent assessment of a regulation's social benefits and costs makes it politically hard for special interests such as the coal industry to hijack the rule-making process.
Some conservative critics argue that under the Obama administration, the EPA gamed cost-benefit analysis to justify overregulation by introducing what they describe as speculative "social costs" and "social benefits." But this approach is not new or imprecise. When regulators do cost-benefit analysis, they are calculating the net change in "social welfare" that a regulation is expected to produce. This term comes from the White House guidance to agencies for conducting such analysis. Economists define social welfare as social benefits minus social costs.
The EPA used this process during the Reagan administration to show that the public would benefit from reducing lead in gasoline. Under President George H.W. Bush, the EPA's cost-benefit analysis supported phasing out chlorofluorocarbons that were destroying the ozone layer. Cost-benefit analysis has also supported hundreds of other EPA regulations over more than 30 years.
Indeed, transparent analysis of the social benefits and costs of regulations helps to hold regulators accountable. But if agencies put their thumbs on the scale by excluding major public health benefits, they will weaken the legitimacy of regulatory policy and make the American people worse off.
Pruitt Prepares Block on Scientific Studies That Protect Public Health https://t.co/iNkjBphJpB @ScienceNewsOrg @TheScienceGuy— EcoWatch (@EcoWatch)1524690033.0
Joseph Aldy is associate professor of public policy at Harvard University.
Disclosure statement: Joseph Aldy receives funding from the Alfred P. Sloan Foundation and the Administrative Conference of the United States. He is affiliated with Resources for the Future, the National Bureau of Economic Research and the Center for Strategic and International Studies.
Reposted with permission from our media associate The Conversation.
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Jean-Marc Neveu and Olivier Civil never expected to find themselves battling against disposable mask pollution.
When they founded their recycling start-up Plaxtil in 2017, it was textile waste they set their sights on. The project developed a process that turned fabrics into a new recyclable material they describe as "ecological plastic."
Mounting Piles of Waste<p>It is not only the streets of Chatellerault where pandemic pollution is piling-up, but also the world's beaches and oceans. Once there, they can take up to 450 years to degrade and disappear.</p><p>Esther Röling, co-organizer of the annual Adventure Clean Up Challenge held on Hong Kong Island, has seen this waste firsthand. In October the sports challenge pitted teams against one another in a competition to remove trash from 13 hard-to-reach coastal areas around the city.</p><p>They find tons of both disposable and reusable masks, said Röling. "You wonder how it ended up there. Was it just thrown on the ground? Or was it in a garbage bag that broke open?"</p><p>Almost 10,000 kilometers away in Antibes on the sunny French Riviera, it's a similar picture. For the past few months, divers and clean-up volunteers working with an ocean clean-up non-profit called Operation Mer Propre have been collecting an increasing number of masks found on land and in the sea.</p><p>"Since the beginning of the lockdown when we started to count, we've reached 800, 900, [and now in total] 1000 masks," said co-founder Joko Peltier. </p><p>According to <a href="https://unctad.org/news/growing-plastic-pollution-wake-covid-19-how-trade-policy-can-help" target="_blank">UN estimates</a>, up to 75% of all coronavirus-related plastic could end up as waste in oceans and landfills.</p>
The Limits of Recycling<p>Yet not all are convinced the recycling of this waste is possible on a global scale. </p><p>"What those citizen groups are doing is really beneficial but once they collect it, it should just go to a landfill or an incinerator. They shouldn't necessarily expect it to get recycled," said Jonathan Krones, an industrial ecologist and visiting assistant professor of environmental studies at Boston College.</p><p>That's because mask recycling programs like Plaxtil are few and far between and most don't have the benefit of a readily adaptable production process. </p><p>Even in countries with solid recycling infrastructure, he says, the system is designed to separate out specific types of waste like bottles or cardboard.</p><p>"I imagine that it would be technically feasible to develop a separation process to filter out masks, but there simply aren't enough of them to make that economical," he said.</p><p>Collection is a big hurdle, he adds. Since each mask only weighs a fraction of a gram and they're scattered on roads or mixed with other trash, it is difficult and costly. </p><p>"You need a lot of raw material of the right quality to make investing in the recycling technology and the recycling system worthwhile," he said.<span></span><br></p>
Hemp, Sugar Cane and Sustainable Alternatives<p>Some projects are instead addressing the material used to make masks.</p><p>French company Geochanvre have created a mask made primarily from hemp, while in Australia, researchers at the Queensland University of Technology are experimenting with a disposable product made from agricultural waste. </p><p>Biodegradable options are exciting alternatives to reduce the fossil fuels needed for the creation of plastic-based masks, said Krones, but they don't absolve the wearer from the responsibility of what happens afterwards. </p><p>Bio-based masks often need their own composing solutions, he explains, because in landfill they can produce high amounts of the greenhouse gas methane when anaerobic bacteria feeds on the organic material. Methane is known to be significantly more potent than carbon dioxide.</p><p>"I think as long as we have in our mind that we want to have disposability, we're going to have to wrestle with a variety of different sorts of environmental tradeoffs," he said, adding that reusable, fabric masks are the best option available to most people.</p><p>Precimask is developing a clear face covering with an optional visor made from hard plastic, designed to be long-lasting.<br></p><p>Air enters either side of the cheeks through a technology normally found in pool filters and car exhaust systems, said company spokeswoman Juliette Chambet.</p><p>"We wanted to make ceramic-based filters that would be washable and cleanable, which would allow them to be reused as many times as desired without having to buy a new consumable or produce waste," she said. </p><p>Ultimately, encouraging mask wearers to think about the entire lifecycle of a mask is key, explains Neveu. </p><p>"We want people who put on the masks to realize that they are also responsible for the waste, he said. "It's not inevitable that this [pandemic] will become an environmental catastrophe.</p><p><em>Reposted with permission from </em><em><a href="https://www.dw.com/en/covid-19-recycling-pollution-trash-pandemic/a-55707817" target="_blank">Deutsche Welle</a>.</em><a href="https://www.ecowatch.com/r/entryeditor/2649032193#/" target="_self"></a></p>
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