Panel Paper:
Systemic Understatement of Benefits of Regulations Aimed at Reducing Low-Income Communities Exposure to Energy Related Pollution
*Names in bold indicate Presenter
This paper examines analytical changes made in regulatory impact assessments published in support of recent proposed and realized regulatory rollbacks. Air pollution regulations, aimed at protecting public health, serve to delineate the “fence-line” that determine the costs borne by the unit producing or extracting energy versus the costs borne by communities, typically low-income, that live in close proximity to these operations. This paper delves into analyses offered by federal agencies for the rollback of three regulations, i.e., first, the proposed the Affordable Clean Energy Rule to replace the Clean Power Plan Rule; second, the proposed revision to the Supplementary Findings to the Mercury Rule; and third, the provision revisions of the Methane rule. The original rules offer public health protection from air pollution related to energy extraction and generation. The Clean Power Plan aims to incentivize the shift from reliance on coal-fired power plants to renewable energy generation; the Mercury Rule aims to cut mercury pollution from coal-fired power plants; and the Methane Rule aims to reduce methane and volatile organic compounds from oil and gas operations.
This paper demonstrates how these analytical changes systematically understate benefits from public health protections, and as a result, tilt the benefits-costs analyses towards supporting the weakening of regulations. The paper details the numerous ways in which public health benefits from regulations have been understated. First, these analyses do not fully account for co-benefits from air pollution regulations i.e., the reduction of other pollutants when a regulation targets a pollutant. Second, these analyses understate health benefits by employing a threshold model on the relationship between pollutants and health outcomes. Third, several analyses employ high discount rates that understate benefits that accrue to future generations. Additional ways by which the analyses understate health benefits from regulations are detailed in the paper. A number of these analyses depart from analyses used by both past Republican and past Democratic administrations.
Beyond analytical changes, federal agencies have ended at least one key study investigating links between energy extraction activities and public health and safety. Specifically. the National Academy of Science study investigating the link between mountain top coal mining in Appalachia and the health of surrounding communities has met an abrupt end. This study had been requested by the West Virginia’s Department of Environmental Protection.
Regulatory rollback, based on questionable analyses, would the shift the fence-line far towards to greater externalization of costs from polluters to communities in close proximity or downwind from coal-fired powered powerplants and oil and gas extraction operations.
