3 ms·
Apples and oranges. The EPA primary standard (which is they propose to change) is based only on health and not economics. From the Regulatory Impact Analysis[1
by schiffern 4y ago
Apples and oranges. The EPA primary standard (which is they propose to change) is based only on health and not economics.
From the Regulatory Impact Analysis[1]:
(yes it's long, but the quote preempts a lot of the predictable replies here)
>The Clean Air Act (CAA) requires the EPA, for each criteria pollutant, to set standards that protect public health with “an adequate margin of safety” and public welfare from “any known or anticipated adverse effects.” As interpreted by the Agency and the courts, the CAA requires the EPA to base the decisions for primary standards on health considerations only; economic factors cannot be considered. The prohibition against considering cost in the setting of the primary air quality standards does not mean that costs, benefits, or other economic consequences are unimportant. The Agency believes that consideration of costs and benefits is an essential decision-making tool for the efficient implementation of these standards. The impacts of costs, benefits, and efficiency are considered by the States when they make decisions regarding what timelines, strategies, and policies are appropriate for their circumstances.
TL;DR: Primary standards are meant to determine healthy levels, including for vulnerable people like children and the elderly. They are not intended to determine what levels are economically efficient. That's handled during implementation, not when setting the primary standards.
[1] https://www.epa.gov/system/files/documents/2023-01/naaqs-pm_ria_proposed_2022-12.pdf#page24 https://www.epa.gov/system/files/documents/2023-01/naaqs-pm_...
- onecommentman 4y agoDo wonder whether they are using a threshold model instead of simple linear model for dose-response for particulates nowadays. Makes a huge difference when determining health effects at low doses, and back in the day it wasn’t clear which model was the clear winner. Assume a threshold model and most of your health effects disappear. Probably buried in this light-hearted report (2000 pages). https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=347534 https://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=347534