The problems with the EPA's mercury analysis

A recent revision of the US Environmental Protection Agency's (EPA) cost-benefit analysis in support of a proposed rule about the regulation of hazardous air pollution from coal-burning power plants proved concerning, according to a collaboration of researchers from various prestigious institutions. The researchers published their concerns in the journal Science, stating EPA "can and should do better."

The cost-benefit analysis is part of a proposal to roll back the legal groundwork of the Mercury and Air Toxics Standards (MATS). Power plants have been obliged to comply with MATS since 2016; the proposed rollback would make it easier for coal-burning power plants to sidestep MATS.

"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 study authors write.

The researchers summarized their concerns about the cost-benefit analysis in several key points. Eureka Alert reports them in the following way:

• “It disregards economically significant but indirect public health benefits, or "co-benefits," in a manner inconsistent with economic fundamentals. The expected benefits of reducing particulate matter pollution of $33-90 billion per year easily exceed the expected costs of $9.6 billion under EPA's original 2011 analysis of the MATS rule.”
• “It fails to account for recent science that identifies important sources of direct health benefits from reducing mercury emissions, such as fewer heart attacks.”
• “It ignores transformative changes in the structure and operations of the electricity sector over the last decade. Shifts from coal to natural gas and renewable sources, including wind and solar power, for electricity generation have decreased the number of power plants that must install pollution control equipment. The investment in pollution control has been about half of what was projected in 2011.”

The team, made up of esteemed scientists from Harvard, Yale, Claremont McKenna College, UC Berkeley, Georgetown, and Resources for the Future (RFF), asserts that the analysis from the EPA "ignores scientific evidence, economic best practice, and its own guidance."  

"The EPA's new analysis of the cost and benefits of the MATS rule is clearly insufficient. It fails to account for advances in our understanding of the negative health impacts of mercury and changes in electricity generation since 2011, which have led to much lower compliance costs than were originally projected," says coauthor Karen Palmer, who is an RFF Senior Fellow. "And, it dismisses an entire category of benefits."

Sources: Science, Eureka Alert