Market Forces

Thank You, EPA

Given that EPA is in the midst of finalizing some of the most critical regulation protecting American human health from poisonous air pollution, one might think that a simple “thank you” might be in order.

Instead, EPA is facing unfounded attacks from several angles – one of the most egregious from Steve Milloy in a recent Washington Times op-ed in which he asked the agency to “show him the bodies” of victims of air pollution.

The evidence linking air pollution to adverse human health impacts including mortality is substantial.  Recently, Michael Livermore, executive director of the Institute for Policy Integrity at New York University School of Law, released an excellent response that easily rips Milloy’s arguments to shreds:

“Questioning these health concerns means countering a substantial body of empirical health studies, conducted both by federal agencies and by independent researchers. These studies, which have been subjected to the scrutiny of the peer review process, have come to a set of well-supported conclusions about the relationship between particulate matter and mortality …”

Livermore points to specific research, including that of the National Research Council (reviewed by a range of independent bodies) and other peer-reviewed studies that back up the EPA’s analysis.

Lynn Goldman, Dean and Professor at the George Washington University School of Public Health and Health Services and a member of EDF’s Board of Trustees, also responded to Milloy’s baseless assertions in a recent Letter to the Editor in the Washington Times:

“As a research scientist, I know that volumes of medical science document the harm air pollution does to the human body, and that the scientific community has concluded air pollution causes disease and death …”

She refers to the family members who can actually point to the bodies of loved ones who “dropped dead from a heart attack after breathing too much air on a Code Red day” and to the children she has treated as a pediatrician suffering from asthma attacks. And the problem of air pollution is widespread — according to the American Lung Association, about half of all Americans live in areas with unhealthy levels of ozone or particulate matter.

Similar to Milloy, Texas Republican Rep. Joe Barton has also questioned the science behind EPA’s analyses, but additionally questioned their economic assessment of the value of the benefits resulting from EPA’s regulation.  Referring to the monetized value of avoiding premature death from air pollution, Barton said that he doesn’t trust EPA’s assumptions and wants someone to check them.

In fact, EPA’s assumption about the value of avoiding premature death (known as the Value of a Statistical Life, or VSL) represents the most credible, scientifically sound, and peer-reviewed figure available.  The VSL measures how much people are willing to pay for small reductions in the risk of mortality, and is often estimated by looking at how much you have to pay someone to take a more dangerous job.  The EPA uses an average value across 26 studies estimating the VSL published between 1974 and 1991 – a value of $6.3 million (in 2000 dollars) that has been vetted and endorsed by the Science Advisory Board (SAB).

Although the idea of placing a value on human life can be controversial, the main thing to remember is that regulations reducing harmful air pollution will save lives, and it is crucial that these benefits are captured when undertaking economic analyses – EPA’s methodology for doing so is based on years of careful, peer-reviewed study, and its credibility is widely acknowledged.

As New York University researcher, Scott Holladay, pointed out in a recent blog post, “what the EPA is able to value, it does in the most rigorous, academically defensible manner.”

The conclusion is that cleaner air will save lives, improve the health of Americans across the country, and is a great investment for our economy – thank you, EPA.

For more on how cleaner air can save lives, improve health, and help our economy, see the Moms Clean Air Force website and a previous EDF blog post on the overwhelming benefits of the Clean Air Act Amendments.

Posted in Clean Air Act, Politics / Leave a comment

The Clean Air Act Amendments: Good for Our Health AND Our Economy

The Clean Air Act and its amendments prevent millions of premature deaths, significantly reduce illnesses, and save trillions of dollars for American families. But those in Congress who are working to stall EPA actions still claim that Clean Air Act regulations are too costly. Fortunately there’s some new and conclusive evidence to show that they’re wrong.

The EPA’s just-released cost-benefit analysis of the 1990 Clean Air Act Amendments leaves no room for argument:  we simply cannot afford a world without regulations on the harmful pollution that the Clean Air Act is designed to fight.

This comes as no surprise. The Clean Air Act has been saving lives, improving the health of American children, and saving us trillions of dollars for years now. But this report is a new and definitive confirmation of just how critical this law is to the health of the American people — and to our economy.

EPA sets the gold standard in economic modeling with this report. It provides an excellent, no-nonsense analysis of both the costs of complying with the Clean Air Act Amendments and the benefits. Benefits are the clear winner. From 1990 to 2020, they manifest in the form of avoided premature deaths, reduction in illnesses and associated health care costs, and improved ecological and welfare impacts (like increased agricultural yields and better visibility conditions).

The report finds that, at the central estimate, and after taking costs into account, the net benefits of the Clean Air Act Amendments are $12 trillion in present value. Yes, that’s TRILLION.

The report also finds that the benefits of the Clean Air Act outweigh the costs by a factor of more than 30 to one. Let me say that again: 30 to one. And that’s a more modest estimate; the report’s high benefits estimate exceeds costs by 90 times.

These estimates don’t even account for some benefits that are more difficult to monetize, such as health effects from air toxics, and chronic respiratory diseases other than chronic bronchitis. They also don’t include the pain and suffering associated with illnesses, so the benefits estimate should be seen as conservative.

Let’s look at one of the most important results: health impacts. Last year alone, the Clean Air Act Amendments saved more than 160,000 lives, prevented more than 85,000 emergency room visits, prevented millions of cases of respiratory problems (including bronchitis and asthma), enhanced productivity by preventing 13 million lost workdays, and prevented 3.2 million lost school days (just to name a few of the benefits).

In the year 2020, the Clean Air Act Amendments are projected to prevent more than 230,000 early deaths and provide benefits reaching approximately $2 trillion. All of which makes it mind-boggling that opponents in Congress continue to push back against this successful law.

The enormous benefits of the Clean Air Act are nothing new. EPA’s earlier cost-benefit analysis of the law, from the years 1970 to 1990, showed that the net benefits in present value over the period were nearly $22 trillion, and that the benefits outweighed the costs by 40 to one.

Here’s more good news:  protecting children from neurotoxins now will give us workers with higher IQs later — and that’s something that also turns out to come with real economic benefits. The latest study by Harvard’s Dale Jorgenson and his co-authors shows that the Clean Air Act has boosted productivity and growth: Gross Domestic Product in 2010 is up to 1.5% higher than it would have been without the Clean Air Act.

The bottom line is that the Clean Air Act and its Amendments have left Americans enormously better off – in terms of health, productivity, and economic growth. Why stop now?

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First steps for the California carbon trading market

Whoever said cap and trade is dead hasn’t been paying attention to the news in California.

Recently, the first trade of a greenhouse gas emissions permit in the Golden State took place, signaling the beginning of what experts project to be a robust carbon market—and the largest in the U.S. given the absence of a nation-wide policy (note that the Regional Greenhouse Gas Initiative (RGGI), the first mandatory market-based effort in the U.S. with 10 participating Northeastern states, applies to utilities, while California’s program will also apply to industry and in later years, transportation).  The trade takes place hot on the heels of the defeat of Proposition 23 in the November elections.

Although the compliance market won’t launch until 2012, Barclays Bank and NRG Energy completed the first allowance trade:  a forward contract which guarantees the delivery of allowances valid for use in the California market at the start of the program at a locked-in price (around $11-$11.50 according to Point Carbon).  By helping provide certainty about the future, these types of trades allow firms to make smart business planning decisions, such as which energy technologies to invest in.  Experts at Barclays as well as at San Francisco-based CantorCO2 expect that other early trades are soon to follow, as firms look for ways to reduce risk and start transitioning to a clean energy economy.

Ensuring the integrity of the carbon market…

State regulators have been able to provide sufficient certainty about how the market will be structured and the timeline for regulatory action to allow for this early launch of the California market.  However, it will be important to nail down sooner rather than later the nitty-gritty specifics of how the market will be regulated in order to ensure that trading occurs in an efficient and transparent way (note that the California Air Resources Board (CARB) is currently accepting comments on a detailed rule proposal).

The financial crisis we just lived through should provide ample incentive for us to make sure to get the rules right and for ensuring tough enforcement and strong oversight — for example, by requiring all carbon trading to be done on registered exchanges, rather than over the counter.  On that point, it’s worth noting that the recently passed Dodd-Frank Financial Reform legislation requires the Commodities Futures Trading Commission (CFTC) to lead an interagency study on how best to regulate the carbon market.  (Carl Royal’s 2009 testimony from the House Energy & Commerce Committee hearing on the American Clean Energy and Security Act and our own fact sheet provide some more arguments).

The path forward for CA

California’s cap-and-trade program will cover the power and industrial sectors starting in 2012 and the transportation sector (including cars and fuels) beginning in 2015.  Time and time again, California and other regional initiatives, like RGGI, continue to lead the nation on sensible energy and climate policy (and stay tuned for developments in the Western Climate Initiative (WCI) as well as New Mexico).  Time for Washington to catch up.

Posted in California, Cap and Trade Watch, Markets 101 / Leave a comment