Document Type

Article

Publication Date

2022

Abstract

This report reviews the Economic Analysis (EA) that supported the 2020 Revisions of the Effluent Limitation Guidelines (ELGs) and Standards for the Steam Electric Power Generating Point Source Category (“2020 Rule” or “Rule”). We review the economic framework, literature, and analyses performed to support these revisions. Our report builds on Davis Noll and Rothschild (2021). In that report, Davis Noll and Rothschild detailed numerous impacts of the 2020 Rule that EPA neglected to examine in the EA, such as the health impacts from bromide, lead, and mercury emissions, harms to threatened and endangered species, and forgone climate benefits related to use of the Trump administration’s social cost of carbon (SCC) value. For example, the agency left millions of dollars in benefits unquantified by not monetizing the health benefits of fewer incidences of bladder cancer from reductions in bromide levels. Similarly, the Trump-era SCC value dramatically understated the expected harms from climate change to the U.S. by excluding foreign spillover effects on U.S. financial, property, and national security interests, among other methodological flaws. The 2021 report concluded that EPA should reexamine the benefits estimates for any related ELG rulemaking or update to the 2020 Rule.

Comments

Copyright © 2022 by the Institute for Policy Integrity. All rights reserved. Reproduced with permission.

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