but it should
BY A N T H O N Y J. A H E R N
I DON’T AGREE with those who say we don’t need the Environ-
mental Protection Agency (EPA). We do need the EPA, but we
need it to respect science.
President Obama stated in his inaugural address, “We will restore sci-
ence to its rightful place...”. Unfortunately, the EPA is misusing science
in a sort of bait-and-switch game to justify new regulations. Scientists
and economists have scratched their heads over the size of health sav-
ings claimed by the agency from recent air quality rules. Slowly com-
ing to light as the result of their probing is the ploy being used.
For example, when EPA issues a new or stricter air quality regulation,
it typically touts that the rule will generate health beneﬁts that exceed
its costs. However, for the recent air toxics rules, the majority of the
health beneﬁts come not from reductions in the targeted pollutants.
Rather, the bulk of the beneﬁts are derived from coincidental reduc-
tions in already-low concentrations of ﬁne particles in the atmosphere.
This creates the impression of a beneﬁt-cost justiﬁcation for regula-
tions that are not intended to address ﬁne particles.
EPA has widely claimed that the air toxics rule will save up to
17,000 lives per year, prevent 11,000 heart attacks, and cut down
on numerous other respiratory and cardiovascular ailments. But all
of those purported health beneﬁts are due to EPA’s prediction of
coincidental reductions of ﬁne particles, not the air toxics. Of all
the air toxics targeted by this rulemaking, EPA has estimated bene-
ﬁts only for mercury — and EPA’s highest estimate of those mer-
cury beneﬁts is only $6 million per year. This is compared to EPA’s
estimate of $10.9 billion in costs per year.
Over 99.99 percent of the beneﬁts that EPA has attributed to the
air toxics rule actually are due to reducing ﬁne particles, rather
than the pollutants it seeks to limit. This bait-and-switch game has
them taking credit for reducing ﬁne particle concentrations far
below the level EPA itself has otherwise deemed safe. To put it sim-
ply, EPA is using one rule to lower the emissions threshold for a
separate class that has its own legal limits. EPA uses these greatly
inﬂated risk estimates to justify a wide range of regulations other
than ﬁne particle concentrations, although the agency is not pre-
pared to argue that those risks are credible enough to justify action
in the form of even-tighter ﬁne particle standards.
If such large health beneﬁts occur by reducing ﬁne particle levels,
the appropriate policy action would be to tighten the ﬁne particle
standards, not to regulate something else altogether in order to ob-
tain those beneﬁts through “coincidence.” This is not consistent
with restoring science to its rightful place.
2 COUNTRY LIVING
• MAY 2012
olume 54, No. 8
www.ohioruralelectric.coop Anthony Ahern
President & CEO
Dir. of Comm.
Editor Art & Prod. Manager
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