Georgetown Professor Coauthors New Study That Finds EPA Mercury Analysis Is “Seriously Flawed”
Department of Economics professor Arik Levinson, in a new study with experts across prominent academic institutions, found that the Environmental Protection Agency’s (EPA) benefit-cost analysis of its Mercury and Air Toxics Standards is “seriously flawed.” The authors assert that the analysis disregards public health benefits, recent scientific findings and transformative change in the electric sector over the past decade.
The analysis in question was used to justify a proposed rollback that would leave mercury regulations vulnerable to legal challenges.
About the Study
The study, which was published in Science magazine, finds deep flaws in the U.S. EPA’s benefit-cost analysis. The results of the organization’s current analysis are incomplete, but indicate support for a proposal to roll back the legal underpinnings of its Mercury and Air Toxics Standards (MATS), which power plants have been complying with since 2016. This rollback could cause the current standards to become vulnerable to legal changes.
Levinson was among the researchers from Georgetown, Harvard, Yale, Claremont McKenna College, UC Berkeley and Resources for the Future (RFF) that claim that the EPA “ignores scientific evidence, economic best practice and its own guidance” in the new analysis. The authors assert that EPA “can and should do better.”
“The main objective of the EPA’s new analysis is to discontinue the longstanding practice of considering all the benefits and costs of a regulation, and to only consider benefits directly related to the regulated pollutant—mercury in this case, but those other considerations are important,” says Levinson.
The economist referred to the implementation of the old 55-mph speed limit in the U.S. that was set in 1974 as an example. This new traffic law was initially put in place to reduce fuel consumption, but it had the additional side effect of causing a decline in traffic accidents. In their current cost-benefit analysis, the EPA is ignoring the greater effects of mercury pollution.
“For example, air pollution regulations have been shown to result in more water pollution,” says Levinson. “Ignoring those indirect consequences would be bad economics and lead to bad policy.”
What This Means for the Future
The authors found that EPA’s analysis was guilty of disregarding economically significant but indirect public health benefits, or “co-benefits,” and also failed to account for recent science that identified important sources of direct health benefits from reducing mercury emissions, such as fewer heart attacks. It also ignored the transformative changes in the structure and operations of the electricity sector over the last decade.
The danger of discounting the aggregate effects of regulated mercury pollution is that removing these measures may lead to an increase in the future of negative side effects that had been decreasing due to the regulation. As policies limiting mercury emissions are rolled back, heart attacks may increase.
“If finalized, the new rule will undermine continued implementation of MATS and set a concerning precedent for use of similarly inappropriate analyses in the evaluation of other regulations,” the authors state.
Levinson collaborated on this study with his colleagues Joseph Aldy (Harvard University and RFF), Matthew Kotchen (Yale University), Mary Evans (Claremont McKenna College), Meredith Fowlie (University of California, Berkeley) and Karen Palmer (RFF) on this article.