Pruitt Holdover Cost-Benefit Plan Is Regulatory Land Mine

Washington, DC, Aug. 13, 2018 — Scott Pruitt may be gone but some of his most troublesome proposals are still raising dust, including one to rewrite how cost-benefit analyses are conducted on all major U.S. Environmental Protection Agency regulations.  Pruitt’s plan to standardize all cost benefit-analyses, regardless of topic or available data, is a thinly veiled effort to mask the benefits of safeguards, according to public comments filed today by Public Employees for Environmental Responsibility (PEER).

EPA is requited to do a cost-benefit analysis for all proposed major regulations. There are already rules for how cost-benefit analyses are performed but Pruitt proposed EPA adopt its own regulations specifying the methodology for its cost-benefit analyses. The PEER comments point out that Pruitt’s approach is neither neutral nor inclusive, as it would enable EPA to, among other things –

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  • Zero out or minimize benefits of environmental protection, as Pruitt did when he reversed a 2015 cost-benefit analysis’ conclusion by declaring that protecting streams and wetlands confer no benefits because they are too speculative to quantify;
  • Exclude consideration of benefits from reductions in pollutants not directly regulated by the action (i.e., “ancillary benefits”), even though these reductions have direct quantifiable benefits in increasing life expectancy, cutting health-related costs and lost wages; and
  • Force a single methodology regardless of the available data, differing pollutants, and unique impacts to human health and the environment, likely resulting in inaccurate and/or incomplete analyses.

“Pruitt’s plan is about as benign as a wolf in sheep’s clothing,” stated PEER Science Policy Director Kyla Bennett, a scientist and attorney formerly with EPA.  “His not-so-hidden agenda is to rig cost-benefits analyses for human health and environmental safeguards so that one size fits none.”

In addition, Pruitt would eschew the precautionary principle such that significant threats of harm to the environment or health could not be considered at all until they are scientifically unquestionable.

At the same time, the latest White House review of major regulations for the decade between 2006 and 2016 concedes that the net benefits have been hugely positive. Similarly, even today, EPA brags that its post-1990 Clean Air Act Amendment regulations have resulted in major pollution reductions, tremendous health benefits, with little apparent adverse effect on economic growth.

“Pruitt’s fix is a non-solution in search of a problem,” added Bennett, noting today is the deadline for public comments. “We urge Acting Administrator Andrew Wheeler to shelve this pointless and time-consuming exercise and concentrate limited EPA resources on real problems to further rather than detract from the agency’s mission.”

Read the PEER comments

See Pruitt’s attempt to zero out benefits from protecting streams and wetlands

View the Pruitt plan