# EPA’s many rollbacks of pollution protections ignore the value of lives saved 

*Published:* 2026-05-26
*Author:* Sharyn Stein

The Trump EPA is dismantling a series of clean air protections that reduce dangerous pollution from cars and trucks, power plants, oil and gas facilities, and other sources. And thanks to a policy quietly adopted earlier this year, the agency isn’t even bothering to estimate the overwhelmingly harmful health impacts of these actions.

For instance, just last week EPA proposed delaying life-saving protections against [soot and smog pollution from vehicles](https://nam11.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.edf.org%2Fmedia%2Ftrump-epa-proposes-delay-vital-health-protections-would-reduce-car-and-truck-pollution&data=05%7C02%7Csstein%40edf.org%7C15196a5bdee64ebafb4008deb1feb8d9%7Cfe4574edbcfd4bf0bde843713c3f434f%7C0%7C0%7C639143904803569702%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=VLN9lopwA%2F4JSELTJVqxjIb2oEnQoVRPXcUvKe2KHEY%3D&reserved=0) without an assessment of health impacts. EPA has also finalized weakened standards for smog from new gas-fired power plants and for greenhouse gas emissions from vehicles without those assessments.

For decades, across both Democratic and Republican administrations, EPA has carefully evaluated the health impacts of its clean air rules when it considers the benefits and costs of regulations. That means considering the lives saved, avoided hospital and emergency room visits, and asthma attacks, along with the economic value of those benefits. And both EPA’s analyses and independent studies have consistently found that clean air programs yield enormous benefits, with a monetary value that vastly exceeds compliance costs to industry.

Here’s one example: a Congressionally-mandated, [peer-reviewed study](https://www.epa.gov/sites/default/files/2015-07/documents/fullreport_rev_a.pdf) of the benefits and costs of the Clean Air Act published in 2011 found that EPA’s clean air programs **saved 160,000 lives in one year** alone, with total **benefits of approximately $2 trillion** – about 30 dollars in economic benefits for every dollar spent on compliance.

EPA has performed these analyses using rigorous and transparent approaches that have gone through scientific peer review, multiple rounds of independent assessment by outside experts, and numerous opportunities for public comment. Yet the Trump administration recently decided to abandon this analysis entirely, citing “uncertainty” about the health benefits of clean air rules. At the same time, the Trump administration has continued to quantify compliance costs to industry. This arbitrary approach introduces a bias against clean air regulation that flies in the face of EPA’s Congressional mandate to protect human health and welfare.

**The Trump EPA’s decision to devalue public health**

EPA’s decision to abandon its decades-long practice of evaluating health impacts appeared for the first time in January of this year, in a brief discussion buried in an economic impact analysis for a final rule amending emissions standards for smog-forming pollution from new gas-fired combustion turbines.

In that final rule, the Trump EPA weakened a subset of the standards based on cost concerns, and touted [industry savings of $87 million](https://www.epa.gov/system/files/documents/2026-01/correct_fact-sheet-nsps-stationary-combustion-turbines.pdf) relative to the previous 2006 standard. But the agency refused to assess the health impacts associated with the rule or estimate the economic value of those impacts, [citing uncertainties](https://www.epa.gov/system/files/documents/2026-01/combustion_turbines_eia_final_2026-01.pdf) in EPA’s analytical methods for ground-level ozone (“smog”) and particulate matter pollution.

EPA did not cite any expert reports or data to support its abrupt decision to stop estimating health impacts. Nor did it explain why the agency’s well-established approaches to estimating those impacts – and addressing uncertainties – were no longer adequate. And despite acknowledging that the “costs presented in this RIA may be overestimates,” EPA did not treat its calculation of costs with the same skepticism as health benefits.

The Trump EPA is now consistently refusing to quantify health impacts as it proceeds to dismantle other vital Clean Air Act protections. EPA failed to calculate the massive health consequences of its repeals of the 2009 [Endangerment Finding and](https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-rescission-greenhouse-gas-endangerment) greenhouse gas standards for motor vehicles, the [Mercury and Air Toxics Standards](https://www.epa.gov/stationary-sources-air-pollution/mercury-and-air-toxics-standards) for coal plants, the previously mentioned delay of [criteria air pollutant standards for motor vehicles](https://www.epa.gov/regulations-emissions-vehicles-and-engines/revision-tier-4-criteria-pollutant-standards-part-1), and hazardous air pollutant standards for [marine tank vessels](https://www.epa.gov/stationary-sources-air-pollution/marine-vessel-loading-operations-national-emission-standards). As a result, EPA is ignoring the massive health benefits of those rules – and is also keeping the public in the dark about the true costs of its attacks.

The table below shows that just a subset of the protections EPA is rolling back adds up to hundreds of billions in benefits annually.

[![](https://blogs.edf.org/climate411/wp-content/blogs.dir/7/files//Chart-1-3.png)](https://blogs.edf.org/climate411/wp-content/blogs.dir/7/files//Chart-1-3.png)Sources: Institute for Policy Integrity, [*Tracking the Damages of Regulatory Rollbacks*](https://policyintegrity.org/tracking-regulatory-rollbacks); EPA, [*Final Regulatory Impact Analysis for the Reconsideration of the National Ambient Air Quality Standards for Particulate Matter*](https://www.epa.gov/system/files/documents/2024-02/naaqs_pm_reconsideration_ria_final.pdf)*;* EPA, [*Regulatory Impact Analysis for the Final Federal Good Neighbor Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard*](https://www.epa.gov/system/files/documents/2023-03/SAN%208670%20Federal%20Good%20Neighbor%20Plan%2020230315%20RIA_Final.pdf). Health impacts listed for Particulate Matter Standards for year 2032. U.S. EPA, [*Final Regulatory Impact Analysis for the Reconsideration of the National Ambient Air Quality Standards for Particulate Matter*](https://www.epa.gov/pm-pollution/final-reconsideration-national-ambient-air-quality-standards-particulate-matter-pm) *(2024)***The strength of the science**

The Trump EPA claims that it intends to pursue new methods for calculating health impacts at some indefinite point in the future but ignores the vast body of science underlying its prior methodologies. Notably, EPA’s methodologies *already* account for uncertainty – in fact, there isn’t a single EPA benefits methodology that fails to do so.

As [recently detailed by experts](https://media.rff.org/documents/Report_26-04.pdf), EPA’s methodologies for quantifying health impacts and associated uncertainties have undergone multiple forms of peer review and independent expert review, including by the EPA Science Advisory Board, the EPA Clean Air Scientific Advisory Committee, the EPA Environmental Economics Advisory Committee, the EPA Science Advisory Board Council on Clean Air Act Compliance Analysis, and the National Academies of Science, Engineering, and Medicine. Through these multiple rounds of review, EPA has honed its approaches to account for uncertainties and conducted numerous sensitivity analyses.

The most recent of these reviews came in 2024, when a panel of EPA’s Scientific Advisory Board issued a report reviewing the agency’s Environmental Benefits and Mapping ([BenMAP](https://www.epa.gov/benmap)) software tool and the [*Technical Support Document for Estimating PM2.5- and Ozone-Attributable Health Benefits*](https://www.epa.gov/system/files/documents/2024-06/estimating-pm2.5-and-ozone-attributable-health-benefits-tsd-2024.pdf) *(TSD)*. This tool and support document set forth the agency’s framework for estimating health impacts of ground-level ozone across the United States. Notably, the Scientific Advisory Board’s [review](https://review%20of%20benmap%20and%20benefits%20methods/) found that EPA’s analyses are “scientifically robust and appropriate for regulatory analyses.” And although the report provides specific recommendations to EPA on how to refine its framework to further address uncertainties, the data and evidence largely reflect that EPA’s methodologies may be *understating* health harms. (see [report](https://review%20of%20benmap%20and%20benefits%20methods/) at pages 48 to 51)

**EPA’s consideration of health impacts follows executive orders, Congressional directives and court opinions**

EPA’s long-standing consideration of health impacts is consistent with federal policies and judicial rulings requiring agencies to fully and even-handedly consider both the benefits and costs of their actions.

In 1981, President Ronald Reagan issued an executive order mandating that agencies prepare analyses of the costs and benefits of significant regulations and proceed with regulation only when benefits outweighed costs. In response to that directive, the EPA began developing economic models to estimate the health impacts of its air regulations with input from air and water quality modelers, health scientists, economists, and other experts.

In 1993, President Clinton replaced the Reagan-era executive order with a revised framework that maintained the required cost-benefit analyses but also required that regulations justify the costs rather than strictly outweigh them. Subsequent Democratic and Republican administrations retained this cost-benefit framework for decades and have used it to review the rigor of EPA’s assessments of health impacts.

In 2000, Congress passed the [Regulatory Right-to-Know Act](https://www.foreffectivegov.org/files/regs/library/rrtka.pdf), which requires that the Office of Management and Budget submit an annual report estimating benefits and costs of significant rules. Based on these executive orders and the Regulatory Right to Know Act, the Office of Management and Budget drafted guidance (known as [Circular A-4](https://bidenwhitehouse.archives.gov/wp-content/uploads/2023/11/CircularA-4.pdf)) to guide federal agencies on best practices for cost-benefit analysis.

Circular A-4 supports full consideration of costs and benefits, including quantification and monetization of those benefits where possible. In addition, it provides best practices for meaningfully analyzing uncertainty when quantifying impacts. When reviewing EPA rules, Office of Management and Budget examiners have historically [carefully reviewed EPA’s health benefits assessments](https://www.reginfo.gov/public/jsp/Utilities/circular-a-4_regulatory-impact-analysis-a-primer.pdf) to make sure they conform to the guidance provided in Circular A-4 on cost-benefit assessment.

[Congress further mandated](https://www.epa.gov/clean-air-act-overview/benefits-and-costs-clean-air-act#sect812studies) that EPA calculate the impacts of clean air regulations on public health, the economy, and the environment as part of the 1990 amendments to the Clean Air Act. In that provision, Congress explicitly directed that EPA “consider all of the economic, public health, and environmental benefits” of Clean Air Act rules. Further, Congress specifically instructed EPA not to overlook such benefits by assigning them a zero value as a “default.” The statute states, “where numerical values are assigned to such benefits, a default assumption of zero value shall not be assigned to such benefits unless supported by specific data.“ *(42 U.S.C. 7412 (b)* This statutory directive shows that Congress appreciated the importance of quantifying and valuing health impacts and other benefits of regulations, and wanted EPA to put forward its best estimates of those benefits rather than use uncertainty as a basis for overlooking their value.

Courts have likewise found that it is arbitrary and unlawful for agencies to assign no value to pollution reduction benefits from regulations simply because those benefits are subject to uncertainty. Further, courts have held that agencies cannot focus on the costs of regulations to the exclusion of benefits – they must fairly account for both. (See *Center for Biological Diversity v. Nat’l Highway Traffic Safety Admin*., 538F.3d 1172, 1189 (9th Cir. 2008); *Public Citizen v. Fed. Motor Carrier Safety Admin*., 374 F.3d 1209, 1219 (D.C. Cir. 2004); *American Trucking Associations v. EPA*, 175 F.3d 1027, 1051–53 (D.C. Cir. 1999)).

As a result of the Congressional directive described above, EPA prepared comprehensive assessments of the health benefits of the Clean Air Act from 1970 to 2020. Those assessments show that the benefits of clean air regulation decisively outweigh costs. EPA’s latest such report, [issued in 2011](https://www.epa.gov/sites/default/files/2015-07/documents/fullreport_rev_a.pdf), estimated that clean air rules spanning 1990 to 2020 would result in approximately $1.4 trillion to $35 trillion in health benefits – an amount vastly exceeding the overall compliance costs of $380 billion. The table below shows estimates health benefits in 2010 and 2020 alone. The data is from EPA’s [*Progress Cleaning the Air and Improving People’s Health*](https://www.epa.gov/clean-air-act-overview/progress-cleaning-air-and-improving-peoples-health)*.*

[![](https://blogs.edf.org/climate411/wp-content/blogs.dir/7/files//Chart-2.png)](https://blogs.edf.org/climate411/wp-content/blogs.dir/7/files//Chart-2.png)**Compliance costs are uncertain and frequently overestimated**

The Trump EPA cites alleged uncertainties as a reason to stop evaluating the health impacts of its attacks on clean air protections. Yet it continues to tout the cost savings to industry from rolling back key protections, even though compliance costs are themselves subject to uncertainty and are frequently overestimated. Since the inception of environmental regulation in the United States, industry has argued that clean air protections will result in economy-crushing burdens. To the contrary, clean air regulation has resulted in enormous economic benefits, in addition to saving lives – and frequently at a much lower cost than originally projected.

For example, the EPA initially estimated the 1990 Acid Rain Program – a highly successful l Clean Air Act program that dramatically reduced harmful sulfur dioxide pollution from power plants – would cost $6.1 billion annually. Experts later estimated the program cost *less than half* of the initial estimate, [with studies](https://cepr.org/voxeu/columns/us-sulphur-dioxide-cap-and-trade-programme-and-lessons-climate-policy#:~:text=Although%20compliance%20costs%20of%20the,Rain%20Program%20at%20$6.1%20billion) [ranging from](https://hero.epa.gov/reference/89305/) $1.1 billion to $3 billion.

EPA also overestimated the annual costs of the 2012 Mercury and Air Toxics Rule for power plants – which successfully reduced mercury from power plants by XX% - by [more than $7.2 billion](https://www.andovertechnology.com/wp-content/uploads/2025/10/C_25_EDF_080725.pdf). Instead of $9.6 billion per year estimated by EPA prior to the rule, the cost of the rule ended up being no more than $2.4 billion per year.

The health benefits of EPA’s clean air standards are significant and measurable. By focusing solely on costs to industry and assigning a zero-value to human health, the Trump administration is arbitrarily attempting to justify deregulation at the expense of human lives.

This harmful about-face flouts EPA’s mission to protect human health and the environment and ignores decades of science-backed methodologies and longstanding agency and White House guidance.