Trump Is Making It a Lot Easier for Polluters to Pollute

This post was originally published by Home of the Brave. Reprinted with permission.

To the extent that people think about the U.S. Environmental Protection Agency (EPA) at all, they likely think of an institution that works to safeguard our health and well-being, and that of our environment. So, The New York Times made quite a splash recently when it reported that the agency had adopted a new policy under which it would stop considering the health benefits of two of the most harmful and pervasive air pollutants: fine particulate matter and ozone.

Protecting the environment is the congressionally established mission of the EPA. The point of this policy shift is to make it easier for the Trump administration to undermine that mission by rolling back existing environmental regulations that are delivering real safeguards for real people. To understand how, it’s useful to dig into some background.

This policy relates to something called a “regulatory impact analysis,” or a “cost-benefit analysis,” as it is more commonly known. When agencies perform these analyses, they are attempting to predict all the rule’s likely future effects—both good (benefits) and bad (costs). In the grand scheme of things, tallying a rule’s costs is relatively easy. For a rule that requires a factory to install a certain kind of pollution control technology, the agency would need to account for the costs of installing and running that technology.

Accounting for environmental rules’ benefits is a lot trickier, though. For an air pollution rule, the EPA would have to translate the resulting emissions reductions that result from the required control technology into actual public health impacts, such as the prevention of premature deaths or asthma attacks—processes generally referred to as “risk assessment” and “risk management.”

Then, the agency must convert those impacts into dollars-and-cents terms: How much money is preventing a premature death or an asthma attack worth? This “monetization” step is highly controversial as a practical and ethical matter, but is defended as necessary for allowing a direct comparison of the rule’s costs and benefits with a common metric.

Indeed, accounting for benefits in monetary terms is so hard that the EPA ends up not doing it for the vast majority of its rules, and this can present a big political hurdle for implementing strong environmental regulations. Rules that lack significant net benefits on paper face strong pushback from conservative lawmakers and the affected business community.

Notably, however, fine particulate matter and ozone are the rare exceptions. Thanks to some groundbreaking epidemiological studies, we have a pretty good handle on how changes in the atmospheric concentrations of those pollutants can impact public health. In addition, the economics profession has made more progress on monetizing these public health impacts than most.

What’s more, both these pollutants are inevitable byproducts of fossil fuel combustion. As a result, any rule that results in the reduction of fossil fuel combustion, even if just incidentally, will generate substantial reductions in fine particulate matter and ozone as a “co-benefit.”

The upshot is that many of the EPA’s existing regulations are supported by cost-benefit analyses with significant net benefits—and it’s all on the strength of the reductions in fine particulate matter and ozone they generate. This is true of regulations aimed at directly reducing fine particulate matter and ozone. It also shows up in the cost-benefit analyses for rules that indirectly generate these reductions, such as those limiting water pollutants from fossil-fueled power plants or clamping down on greenhouse gas emissions from automobiles.

By definition, then, any future regulations that would seek to rescind or substantially weaken existing ones would have cost-benefit analyses with significant net costs. That’s because the cost-benefit analysis ledger would simply be flipped: The “benefits” of those deregulatory rules would be the relatively small foregone compliance costs, while the “costs” would be the significantly large foregone benefits that would have come from the reductions of fine particulate matter and ozone.

The problem for the current Trump administration is that much of its environmental agenda involves rescinding or weakening those regulations. And that would require pushing through several regulatory actions tainted by the political Scarlet Letter of bad cost-benefit analyses. Faced with this conundrum, its response—unsurprisingly—is to cook the books so that the benefits of reducing fine particulate matter and ozone emissions magically disappear. If those benefits are now worth $0 to the agency, then the administration’s deregulatory actions will have net benefits instead of net costs—at least on paper.

Put differently, the long-recognized benefits of reducing fine particulate matter and ozone pollution are like a dam holding back much of the Trump administration’s anti-environmental agenda. Pretending that those benefits are too uncertain to measure, as the Trump administration now claims, is just a lazy way of removing that dam so that its deregulatory tsunami can be unleashed.

Of course, what happens in reality is different from what the Trump EPA lies about on paper. If these deregulatory actions are permitted to stand, they will have catastrophic impacts on the health and well-being of millions of Americans, regardless of what the cost-benefit analysis says.