“The announcement by EPA to revise their approach to cost benefit analysis, including their proposal to not consider reductions in co-pollutants in calculating benefits of agency actions, remind us how far the agency has strayed from its original mission and organizing principles when it was established 50 years ago,” said Kevin Cromar, PhD, vice chair of the ATS environmental Health Policy Committee.
Recognizing that a piecemeal approach to complex environmental challenges defies effective action, President Nixon called for the creation of the EPA to not only bring together the diverse disciplines necessary for effective pollution control, but also to perceive the environment as a single, interrelated system. The EPA’s proposal not only divorces their evaluation of the societal benefits of environmental protection from established economic principles, it also attempts to fragment the management of an interconnected environment into discrete pollutants as if they were emitted separately from one another.
It is particularly concerning that the Agency intends to rely on the results of their flawed Integrated Scientific Assessment to no longer consider the economic benefits of reducing mortality risks from exposure to elevated levels of ozone. The scientific community provided overwhelming evidence, to no avail, in opposition to the Agency’s decision in 2019 to downgrade the impacts of ozone on mortality from “likely to be causal” to “suggestive of a causal relationship.” The proposed rule intends to rely on this existing agency document to selectively remove mortality impacts from ozone from future inclusion in benefit calculations.
“It is apparent from the EPA’s announcement, and the accompanying regulatory impact analyses over the last several years, that the current leadership at EPA view economic analysis as little more than an inconvenience in the pursuit of their preferred policy goals,” said Dr. Cromar.
“The proposed changes are just the latest effort to codify their ongoing efforts to intentionally dismiss the health benefits that accrue for pollution reductions below arbitrary thresholds, to change economic assessments to fit predetermined outcomes rather than using economic analysis to inform decision-making, and to ignore the economic benefits of any pollutant besides a narrowly defined target pollutant.”
He added: “Along with their parallel efforts to systematically ignore scientific research demonstrating the adverse health risks from environmental pollutants, these proposed changes make it clear that the current leadership at EPA works in direct opposition to the Agency’s mission to protect human health and the environment.“
About the American Thoracic Society
Founded in 1905, the American Thoracic Society is the world’s leading medical association dedicated to advancing pulmonary, critical care and sleep medicine. The Society’s 15,000 members prevent and fight respiratory disease around the globe through research, education, patient care and advocacy. The ATS publishes four journals, the American Journal of Respiratory and Critical Care Medicine, the American Journal of Respiratory Cell and Molecular Biology, the Annals of the American Thoracic Society, and ATS Scholar
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