Earlier this week, the
New York Times reported that the Trump administration plans to stop assigning dollar values to the human health benefits resulting from the imposition of national ambient air quality standards. According to the Times,
Carolyn Holran, an E.P.A. spokeswoman, said in an email that the agency was still weighing the health effects of PM2.5 and ozone, but wouldn’t be assigning them a dollar value in cost-benefit analyses. “E.P.A., like the agency always has, is still considering the impacts that PM2.5 and ozone emissions have on human health,” Ms. Holran said. ‘Not monetizing does not equal not considering or not valuing the human health impact.’
Time will tell whether EPA truly takes the health benefits of stringent PM2.5 and ozone standards into account. What’s not in question to those who still care about what used to be known as “science”, is that the evidence for the health benefits of stringent ambient air quality standards, particularly for PM 2.5,
keeps getting more compelling.
What’s astounding to me is the extent to which support for rigorous cost-benefit analysis seems to depend on whose ox is going to be gored. This is not a new phenomenon, but it has gotten worse in recent years. As I have noted previously, it used to be that environmentalists were skeptical of cost-benefit analysis, “treating environmental questions as moral issues that should not be subject to something as crass as cost-benefit analysis.” Republicans recently began to share environmentalists’ contempt for cost-benefit analysis. The only difference is that, while too many environmentalists want only “benefit” analysis, too many Republicans now want only “cost” analysis.
As the New York Times notes, even Justic Scalia, in Michigan v. EPA, noted that:
Consideration of cost reflects the understanding that reasonable regulation ordinarily requires paying attention to the advantages and the disadvantages of agency decisions.
In short, there’s no such thing in the literature as “cost” analysis or “benefit” analysis. There’s only rigorous cost-benefit analysis. And that requires putting a value on the human health benefits of regulations. If we decide to regulate, or not to regulate, we are implicitly saying that it is, or is not, “worth it” to regulate. We owe it to ourselves to be explicit.
