For those of you looking for a good analysis of the book-cooking by the EPA, check out science blogger Chris Mooney's article in the American Prospect.
Mooney describes the two alternative approaches -- using the"best available technology" to reduce mercury pollution, the approach traditionally used to control toxic substances, and the "more lax, market based 'cap and trade'" model.
Mooney describes how this administration, which talks big about "cost-benefit" analysis and sound science, has somehow forgotten to factor the benefits into its analysis:
maybe most stunningly, the GAO added that the EPA had failed to "quantify the human health benefits of decreased exposure to mercury, such as reduced incidence of developmental delays, learning disabilities, and neurological disorders." In short, perhaps the most obvious source of benefit from regulatory action -- and an area where the tougher technology-based approach clearly bests cap and trade -- got short shrift. And despite this, the technology-based approach still had a net economic benefit of $ 13 billion annually!And not only did the EPA falsify the economic analysis, but the regulatory watchdog of this administration, the White House Office of Management and Budget, somehow overlooked the fact that the benefits of the technology approach were missing:
But wait, there's more. In a February report, the EPA inspector general highlighted some of the same problems as the GAO, but also noted that the EPA had failed to select the best technology-based approach to begin with. In effect, the EPA cherry-picked a technology-based standard that
would result in mercury reductions comparable to the administration's Clear Skies plan, rather than a standard that would actually achieve the maximum possible pollution reductions (as the Clean Air Act requires). To do so, the agency had to attempt multiple model runs just to find a technology-based scenario that was bad enough that it would match the cap-and-trade approach. In short, once again the EPA rigged its analyses to make the Bush administration's politically favored approach seem like it could match the competition.
Moreover, the White House branch typically charged with scrutinizing agency proposals to make sure they're based on rigorous economic analyses -- John Graham's office within the OMB --- was curiously "asleep at the cost-benefit switch," as legal scholars Lisa Heinzerling and Rena Steinzor of the Center for Progressive Regulation explain in a lengthy article on the corruption of economic analysis in the mercury-regulatory process.It's so disappointing how they live up to our lowest expectations.
Remember the big picture here: Conservatives are the ones who have long yelped about the need to impose an economic check on federal-agency regulations. But along came a proposed agency action with massive benefits, and the hardheaded economists at the OMB simply shrugged while a politicized EPA rigged its analyses. Whatever regulatory option the administration ultimately chooses for mercury next week, we now know that it will have emerged from a truly dubious process.
- Well, This is a Surprise! EPA Distorted Mercury Analysis, GAO Says, March 8, 2005
- EPA: Too Much Mercury? Too Bad, December 16, 2000