Since 1980, ground-level ozone pollution has dropped by one-third, to a nationwide average level of 68 parts per billion (ppb) in 2014. But for the Environmental Protection Agency’s bureaucrats, that reduction isn’t enough. Thus, the agency announced its newest standard, which reduces the allowable level of ground-level ozone from the current 75 parts per billion (ppb) to 70 ppb.
According to the EPA, by 2025, the new ozone standard will provide annual benefits of between $2.9 billion and $5.9 billion, at an annual cost of only $1.4 billion. One can almost hear one of those late-night announcers shouting: “You get all this — fewer premature deaths, fewer missed school days, fewer asthma attacks, all for the low, low price of just $1.4 billion. But wait, there’s more!”
So how did the EPA, which recently spent $92 million on new office furniture for its employees, determine that the benefits of the proposed ozone rule would greatly exceed the costs? Simple: The EPA adds in the “co-benefits” associated with reducing particulate emissions that the agency assumes also will occur when ozone levels are reduced.
EDITORIAL: Emissions Overreach
There’s nothing wrong with including so-called co-benefits in a cost-benefit analysis. They’re like the remora that is attached to a shark, or the first Clinton presidency: With the one, you get the other. Change the oil in your car, and not only will your engine last longer, your car will get better gas mileage. Both are benefits.
Problem is, the EPA keeps including the exact same co-benefits over and over to justify its different emissions rules. With the proposed ozone rule, the EPA has now counted the same benefits from reduced particulate emissions four separate times.
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Now, I would love to count each push-up four times and be paid four times for the same work. But that’s not how the real world works. The EPA has simply corrupted cost-benefit analysis to justify environmental regulations that cannot stand on their own.
The EPA first estimated the benefits of reducing particulate emissions back in 2008, when it adopted a new standard for particulate emissions. In 2012, the agency issued a revised cost-benefit analysis, which determined that, in 2020, full attainment of the standard would cost between $53 million and $350 million per year, while providing annual benefits of $4 billion to $9 billion.
#share#Next came the EPA’s mercury rule in 2011, which the U.S. Supreme Court upended, but did not strike down, earlier this year. The EPA projected benefits for that rule of between $37 billion and $90 billion per year, at an annual cost of just under $10 billion per year. But the actual benefits from reduced mercury emissions are trivial, only between $4 million and $6 million per year. Instead, 99 percent of the benefits of the mercury rule are attributed to reduced particulate emissions, plus $360 million of benefits from reduced emissions of carbon dioxide. Had the EPA not counted the same particulate-emissions reductions benefits from the 2008 particulate standard, the mercury rule would offer a $10 billion annual bill with almost negligible benefits.
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Then there is the Clean Power Plan, which the agency released in August of this year. Yet again, the co-benefits from reduced particulate emissions account for the majority of benefits in the EPA’s cost-benefit analysis. According to the EPA, reducing carbon dioxide emissions from electric generating plants will provide $34 billion to $54 billion in benefits per year by 2030, at the low, low cost of just under $9 billion per year. The EPA estimates $20 billion per year in benefits from reduced carbon dioxide emissions, even though the Clean Power Plan will have no measurable impact on climate, less than 0.02 degrees by the year 2100. The remaining $14 billion to $34 billion per year is supposed to come from . . . reduced particulate emissions.
And now, the ozone rule, for which, once again, the EPA’s cost-benefit justification hinges on including the very same health benefits from reducing particulate emissions.
#related#Cost-benefit analysis can be a great policy tool, but not if the same benefits are counted over and over to justify ever more stringent regulations. That’s what the EPA has done.
Moreover, this quadruple-counting of the same benefits doesn’t even address the actual methods the EPA uses to calculate benefits in the first place, such as estimating the direct benefits of reduced mercury exposure by assuming lots of pregnant women eat nothing but fish and finding $20 billion in benefits from reduced carbon dioxide emissions when the reduction would have zero impact on climate. But those are subjects for another article.
The EPA calls all of this science. I can think of a few other names.