Environmental Regulation, Jobs, and Human Health: Industry Estimates on Boiler Rule Flunk Economics 101

by Catherine O'Neill | November 03, 2010

Economics professors at two major universities just issued their reviews of industry-funded assessments of the costs of EPA’s proposed boiler rule (via NRDC). The professors’ conclusions: “the methodology is fundamentally flawed;” “the resulting estimates of job losses are completely invalid;” “the results reported are useless;” “if I were grading this, I would give it an F.” These strongly-worded indictments should make us sit up and take note. 

Professors Charles Kolstad and Jason Shogren were asked to review industry-funded estimates of the costs of EPA’s proposed boiler MACT rule. These estimates have been cited in support of recent industry claims that it would be too costly and result in a large loss of jobs. The professors’ reviews usefully reveal the serious flaws in the “evidence” around which industry has been spinning its anti-regulatory story. In an earlier post, I examined another aspect of the industry story, showing how it neglected to mention that the estimated benefits of regulating particulates, heavy metals, and dioxins would dwarf the estimated costs (and that's without even counting benefits for mercury reductions). With the assistance of Kolstad and Shogren, we can see how, in addition to belittling the benefits, the industry story has attempted to exaggerate the costs.

Here is some background reading for this assignment:

How does environmental regulation affect jobs?

As Kolstad explains, environmental regulation can be expected to have three impacts within the regulated industrial sector:

“[C]hanges in employment from regulatory action are ...

DC Event -- Regulating from Nowhere: Environmental Law and the Search for Objectivity

by Ben Somberg | November 03, 2010
Tomorrow, Thursday, the American Constitution Society will host a midday panel discussion about the issues and ideas presented in Regulating from Nowhere: Environmental Law and the Search for Objectivity, by CPR Member Scholar Douglas A. Kysar. The panel includes CPR Board Member Amy Sinden. Drawing insight from a diverse array of sources, including moral philosophy, political theory, cognitive psychology, ecology, and science and technology studies, Kysar offers a new theoretical basis for understanding environmental law and policy. He exposes a ...

Cap-and-Trade is Still Alive (In California)

by Alice Kaswan | November 02, 2010
As “Cap-and-Trade Is Dead” continues to echo through the empty halls of Congress, California rolled out its proposed greenhouse gas (GHG) cap-and-trade program on Friday. The proposed regulations send a powerful message that, notwithstanding political paralysis at the federal level, the states are proceeding with meaningful climate action. The proposed cap-and-trade program, to be voted on by the California Air Resources Board (CARB) at its December 2010 meeting, is scheduled to take effect in January 2012. At the outset, it will apply ...

In Williamson v. Mazda, SCOTUS Has Chance to Right Preemption Wrongs

by Bill Funk | November 01, 2010
Cross-posted from ACSblog. The Supreme Court will hear arguments on November 3 in a potentially important preemption case, Williamson v. Mazda Motor of America. In Williamson, a child was fatally injured in a collision when she was sitting in the center rear seat of a Mazda van, secured by a lap belt. The two other passengers in the vehicle, both wearing lap-shoulder belts, survived with minor injuries. The young Williamson, however, suffered severe abdominal injuries and internal bleeding because her ...

The Economics of California's Climate Law

by Ben Somberg | October 29, 2010
Over at Grist, CPR Member Scholar Frank Ackerman explains why the economic calculations used by the Yes on 23 campaign in California are rather fishy. ...

Moving Along: Preserving the Great Wildlife Migrations

by Yee Huang | October 28, 2010
On November 7, the National Geographic Channel is premiering Great Migrations, a seven-episode series that chronicles the movements of animals on every continent, from the magnificent monarch butterfly migration from Mexico to northern Canada to the impressive wildebeest migration across the plains of the Serengeti. A report by the United Nations concluded that climate change will impact population sizes, species distribution, the timing of reproduction and migration events, and the increased vulnerability to disease and predation. Compounding these effects are ...

Meet the New BOEMRE, Same as the Old MMS

by Holly Doremus | October 27, 2010
Cross-posted from Legal Planet. The Minerals Management Service within the Department of Interior was responsible for overseeing offshore oil development in federal waters from its creation in 1982 until its demise earlier this year. MMS was always a troubled agency, to put it mildly, dogged by scandals and a revolving door with the industry it regulates. After the Deepwater Horizon incident made its failings obvious, Interior Secretary Ken Salazar reorganized MMS out of existence, promising that the new management structure ...

Update: EPA Releases Full FY 2010 Stats on CWA Convictions

by William Andreen | October 26, 2010
Since my post last week ("Convictions for Violations of the Clean Water Act Continue to Ebb"), a number of significant things have occurred. On October 20, the EPA’s Assistant Administrator for Enforcement and Compliance Assurance, Cynthia Giles, announced that the Director of the Office of Criminal Enforcement, Forensics and Training was retiring and that the Director of the Criminal Investigation Division had decided to pursue new challenges within the agency. In addition to this personnel shake-up, Assistant Administrator Giles has pledged to ...

The Feds Take On Climate Adaptation

by Daniel Farber | October 20, 2010
On October 14, the White House’s Climate Change Adaptation Task Force released its recommendations to President Obama for how agencies can better prepare the United States to respond to the impacts of climate change.  Once again we are reminded of how important it is to have an Administration that takes climate science seriously. According to the scientists, even if we curb emissions, global temperatures will continue to rise for decades, bringing along with them rising seas, more heat waves, more ...

A New Round in the OSHA-OSHRC Fight Over Noise Exposure

by Matt Shudtz | October 19, 2010
Today, OSHA released a “proposed interpretation” of its 39-year old noise exposure standards. Talk about making up for lost time. All joking aside, this move truly is a positive step for American workers, and may demonstrate a path of action that could help OSHA address hazards in addition to excessive noise.  Over the years, the federal courts and the Occupational Safety and Health Review Commission (OSHRC) have muddied the waters of many OSHA regulations, enforcement policies, and rulemaking procedures. Their sometimes contradictory, sometimes ...

Convictions for Violations of the Clean Water Act Continue to Ebb

by William Andreen | October 19, 2010
According to the latest data published by TRAC Reports, the number of federal convictions obtained for violations of the Clean Water Act during fiscal year 2010 has continued to follow a recent downward trajectory. Since reaching a high of nearly 70 in FY 1998, the number of convictions has continued to decline toward what may be its lowest level since the early 1990s. During the first ten months of FY 2010, the Department of Justice reported 23 convictions, a pace that would ...

MSHA Takes Bold Step to End Black Lung Disease, Proposes Tough New Regulation

by Celeste Monforton | October 14, 2010
Cross-posted from The Pump Handle. Labor Secretary Hilda Solis and MSHA asst. secretary Joe Main are proposing new rules to protect U.S. coal mine workers from developing illnesses related to exposure to respirable coal mine dust. The most commonly known adverse health effect is black lung disease, but exposure is also associated with excess risk of chronic obstructive pulmonary disease, progressive massive fibrosis, chronic bronchitis, and emphysema. The proposal, scheduled to be published in the Federal Register on Oct 19,* ...

A Frank Assessment: EPA Finds Illinois' CAFO Program Inadequate

by Yee Huang | October 14, 2010
The EPA Region 5 recently published a refreshingly blunt report on the state of concentrated animal feeding operation (CAFO) permitting in Illinois, and the assessment is disturbing. EPA concluded that the Illinois Environmental Protection Agency’s National Pollution Discharge Elimination System (NPDES) permitting program for CAFOs “does not meet minimum thresholds for an adequate program.” Ouch. As in many other states around the country, agriculture in Illinois is one of the state’s leading economic drivers and one of the leading sources ...

The Oil Spill Commission, the White House, and the Next Election

by Rena Steinzor | October 13, 2010
Whatever happens at the polls this November, President Obama will get a chance to turn the electoral tide in 2012, perhaps without the loadstone of recession around his political neck.  And, while the economy and many other issues will continue to occupy the President for the best and most obvious of reasons, it’s fair for everyone in the country to expect him to multi-task. For progressives who care about the environment, I’d suggest one critical criterion for judging the Administration: Can the ...

Boiler MACT Rule Would Have Enormous Health Benefits from Air Pollutant Reductions -- And That's Not Even Accounting for the Reduced Mercury Emissions

by Catherine O'Neill | October 12, 2010
EPA’s proposal to curb emissions from the second largest source of mercury in the United States – industrial boilers and process heaters – has come under fire in recent weeks.  Those industries that would be subject to the “boiler rule” have objected to its costs, and some senators have embraced their claims (see also Lisa Jackson's response). The industry story, however, leaves out important facts. The industry story does not mention that, on balance, the estimated costs of the rule are ...

CRE's Proposed Interactive Public Dockets—Tilting the Regulatory Process Further in Industry's Favor

by James Goodwin | October 08, 2010
Back in the 1970s, when many of the great environmental, health, and safety statutes were adopted, public interest groups shared an overwhelming optimism that greater public participation held the key to maintaining—and even expanding upon—their successes. All they needed was a seat at the  table where decisions are made, and their ideas would ultimately prevail. At first, they were right—public interest groups were able to advance their cause through participation in the regulatory process. But before long, regulated industry discovered that they could ...

Farber LAT Op-Ed on California Climate Law

by Ben Somberg | October 04, 2010
CPR Member Scholar Daniel Farber and Richard Frank, both of BerkeleyLaw, have an op-ed in the LA Times today on Proposition 23, the ballot initiative that would suspsend California's climate law, AB 32. They argue: For California to retreat on the climate issue now would send a defeatist message nationally and worldwide. It's true that other climate measures would remain on the books, but suspending AB 32 would be like benching a football team's quarterback while leaving the other players ...

US OSHA Reviews State Plans

by Ben Somberg | October 01, 2010
Over at The Pump Handle, Celeste Monforton looks at federal OSHA's review, issued this week, of the state worker safety programs. ...

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