EPA’s Plan to Ignore Co-Benefits Will Cost American Lives

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By Derrick Z. Jackson, Union of Concerned Scientists

People who can afford to live in their most-desired neighborhood often select it for the primary reasons of convenience, cleanliness, and quiet. Those features come with what environmental scientists call social, economic, and environmental “co-benefits.”

For instance, streets lined with trees are associated with less crime, more neighborly socialization and child play, lower air conditioning bills in summer heat and less runoff problems in heavy rain. Other major co-benefits involve pollution. Besides trees, which also absorb carbon dioxide and release oxygen, such neighborhoods have drinkable water and playable soil. They do not abut roaring interstates, refineries, chemical factories, fracking operations or facilities with dust clouds swirling off mountains of scrap metal, ores or ash to aggravate the lungs of children with chronic asthma or rob young brains of IQ with neurotoxins.

The concept of co-benefits has moved center stage over the last two decades as scientists realize that nearly all the pollutants from burning fossil fuels can severely damage human health. Those pollutants include black carbon, methane, ozone, sulfur, carbon monoxide and non-methane hydrocarbons. The Intergovernmental Panel on Climate Change said in its 2014 report that the inhalation of the pollutants related to climate change is responsible for 7 percent of the global burden of disease and nearly 8 percent of potential life years lost.

Since then, the World Health Organization has estimated that 4.2 million people a year die from ambient outdoor pollution through heart disease, stroke, lung cancer, chronic obstructive pulmonary disease and acute respiratory infection. Outdoor and indoor pollution from poorly ventilated fuel burning in developing countries kills roughly 7 million people a year.

These dramatic figures appear to be of no concern to the Trump administration. In one of its most cynical schemes yet, the Environmental Protection Agency is currently on a mission to eliminate the co-benefits the Obama administration used to calculate the level of “appropriate and necessary” protections for air and water. Erasing the benefits that come from a clean environment allows industry to claim its toxic plumes, discharges and waste piles are nowhere as harmful as scientists have found, and thus, they need not be forced to spend money to contain them.

With the nation’s air quality deteriorating, according to the 2019 “State of the Air” report by the American Lung Association, this is no time to forget the co-benefits of controlling pollution for both the climate and human health. The science is as clear as ever that the many of the emissions contributing to a perilous future for the world’s climate are also a matter of life and death right now.

The fight over mercury

At the center of the Trump administration’s attack are rules implemented during the Obama administration called the Mercury Air Toxics Standard, or MATS. Mercury, a pollutant from coal-fired power plants, is a neurotoxin that can move in the atmosphere for hundreds of miles before falling back to earth. It can travel up the food chain in forests, rivers, and lakes until it poisons fish-eating birds such as loons and people who consume contaminated fish. Mercury exposure can cause cognitive loss and behavioral changes, damaging humans’ nervous systems and endangering wildlife as well.

The Obama administration created the new mercury standards in 2011 as part of its efforts to address the multiple related dangers of coal burning. Power plants spew far more than mercury into the environment, including particulates, arsenic, chromium, nickel and acid gases.

Back then, the EPA estimated that it would cost industry up to $9.6 billion to comply with the standards. But, importantly, the agency concluded that its rules to cover the broad range of emissions were “appropriate and necessary,” because the estimated annual health benefits would range from $37 billion to $90 billion. It calculated that the standards could prevent up to 11,000 premature deaths, 4,700 heart attacks and 130,000 asthma attacks every year, resulting in up to 5,700 less emergency room visits a year and 540,000 less sick days at work annually.

Then there is the co-benefit of less-harmed brains. In the Europe Union for instance, researchers found in 2013 that 1.8 million children were born every year with excess mercury exposure. They calculated that, removing that exposure would reduce brain damage and increase aggregate IQ scores by more than 600,000 points, translating into an economic benefit of nearly $12 billion a year.

Some of the same researchers did a similar estimate for the United States, finding that stricter mercury regulations could increase aggregate IQ scores by some 264,000 points a year, with a corresponding annual economic benefit of $5 billion.

Common economic sense and basic humanity on health would seem to demand that we take such immense benefits and co-benefits into account. As law professor Cary Coglianese, director of the University of Pennsylvania’s Program on Regulation put it, “There is a risk any time regulators overlook all the effects of their actions, whether on the benefits side or the costs side of the equation.”

And make no mistake. Industry does its best to conjure up “co-costs” when it fights regulations. For instance, one reason that asbestos is still used today in car brakes and building construction is because the industry successfully argued in 1991 that the EPA did not fairly factor in the costs to industry and the safety of substitute materials either in brakes or for workers. But the actual cost to Americans for industry’s sleight of hand on asbestos has proven enormous. A 2018 study found that some 39,275 asbestos-related deaths in the United States in 2016—more than double previous estimates, and more than the number of Americans killed by gun violence.

Sadly, industry does not have to worry about the current EPA undercounting its co-costs with Administrator Andrew Wheeler, a former coal lobbyist, running the show. The Trump EPA takes no issue with the Obama administration’s estimate of $9.6 billion in annual costs to industry. But Wheeler wants to throw the MATS co-benefits into the incinerator. Under his direction, the EPA is pushing to revise the standards so the agency is obligated only to consider the most direct effects of mercury contamination, such as the effect on children who eat recreationally caught freshwater fish, which they calculate as costing only somewhere between $4 million and $6 million.

Wheeler’s EPA is silent, meanwhile, on the fact that more than 90 percent of mercury intake by Americans actually comes via consumption of fish from the ocean. While marine fish indeed can come from all over the world, a 2017 review by university researchers from Harvard, Syracuse, Michigan, Connecticut, Washington and the Biodiversity Research Institute in Maine (BRI) has done extensive research to map the toxic trail of mercury, finding “marked decreases in mercury in Atlantic coastal fisheries in response to decreases in mercury emissions.”

Despite the international body of work quantifying the economic impact of brains damaged by mercury and a 2017 review in the International Journal of Environmental Research and Public Health that concluded, “recent studies suggest that chronic exposure, even to low-concentration levels of mercury, can cause cardiovascular, reproductive, and developmental toxicity, neurotoxicity, nephrotoxicity, immunotoxicity, and carcinogenicity,” a December memorandum from Wheeler’s office claimed “it was not possible to quantify the estimated value” of those harms. And, as for the research by BRI to map the toxic trail of mercury in marine fish, the EPA now contends that, “more research is required to link these ecological effects to ecosystem services.”

In a crowning shame, the EPA memo utterly dismisses the other by-products of coal plants and thus the possible co-benefits of controlling them, such as particulates, ozone-related effects, arsenic, benzene, cadmium, chlorine, formaldehyde, lead, manganese, nickel and selenium, citing “data gaps, model capabilities and scientific uncertainty.” This is despite the well-established neurological and carcinogenic dangers of several of these heavy metals, and the plethora of environmental justice campaigns all over the United States to get rid of them.

Ignoring the science

It is hard to overstate the damage the Trump administration’s proposal on co-benefits could ultimately cause if it is widely implemented. For instance, Sir Andy Haines, an expert on the connection between climate change and pollution at the London School of Hygiene and Tropical Medicine, wrote in a 2017 commentary in the Lancet that clean energy policies to hold planetary temperature rise to 2 degrees Celsius could save a total of 175,000 American lives from pollution by 2030 and 22,000 lives per year thereafter.

Haines cited a 2012 study published in the Journal Science involving scientists from the EPA, NASA and the Scripps Institute of Oceanography which found that climate policies designed to reduce short-lived fine particulate, especially black carbon from incomplete combustion, could also prevent up to 4.7 million premature deaths from air pollution. As Haines put it: “In an era when powerful interests seek to cast doubt on climate change science, major ancillary near-term benefits (co-benefits) of climate action provide added justification for policies to cut greenhouse gas emissions.”

These emerging projections clearly have the fossil fuel industry in a frenetic race against the facts. Of the $2 billion spent on climate change lobbying from 2000 to 2016, fossil fuel companies and industries dependent on oil and gas outspent the renewable energy lobby and environmental groups 10 to 1.

Beyond mercury: The threat to federal  water protections

Notably, as enormous as the implications are from ignoring co-benefits related to global warming emissions and air pollution,  the Trump administration is also trying to turn cost-benefit on its head for water pollution as well. The most obvious example is the attempted rollback of the Waters of the US Rule. In this arena, the Trump administration is trying to make the nation’s wetlands seem relatively worthless (thereby effectively allowing more industrial and agricultural pollution) by not considering the benefits and co-benefits these waterways offer.

The reality, of course, is that wetlands offer enormous benefits and co-benefits. They store water in drought, they absorb fertilizer and erosion runoff and provide nurseries for wildlife. Obama’s EPA said compliance costs of up to $476 million a year were outweighed by benefits up to $572 million a year. New York University School of Law’s Institute for Policy Integrity now estimates the benefits of wetlands to range between $612 million to $1 billion.

But, while under Wheeler’s direction, the Trump EPA conveniently left the Obama EPA’s compliance costs intact, it cut out consideration of wetlands to claim the nation would get back only up $73 million in annual benefits.

Trump wants to roll back water protections despite the fact that, in the United States, nearly a half of rivers and streams, a third of wetlands and a fifth of lakes are in “poor biological condition.” Last year, researchers from the University California Irvine and Columbia University found that in 2015, 21 million people drank water from sources that violated health-based water standards. In no surprise, given the iconic tragedy of lead contamination in Flint, Michigan, the study found gaps in compliance for water systems serving the rural poor and low-income communities of color.

The study said that generally, Americans can count on clean water, but enough water systems still fall out of compliance to give Americans more than 16 million cases of acute gastroenteritis every year, leading the researchers to write,  “Currently, state enforcement agencies lack a systematic procedure to select systems for additional inspection and monitoring.”

A deadly calculation

All the talk of aggregate deaths and dollar amounts doesn’t adequately bring the issue home. On behalf of UCS and The American Prospect magazine, I’ve reported on a neighborhood in southeast Chicago that, with the help of dedicated scientists in the regional EPA,  successfully protested against local mountains of petcoke from oil refining that blackened homes and smothered lungs with dust. Although the petcoke mountains were removed, dangerous levels of manganese and lead were respectively discovered blowing in the air and in the yards of residents.

Simply put, any industry that spews multiple sources of toxic emissions should be held accountable for all of them. And yet, the Trump administration is moving in the opposite direction, leaving many scientists and close watchers alarmed that mercury is a Trojan Horse for a concerted effort to ignore the benefits of pollution control across all industries.

For instance, the Trump administration admitted last year that its attempt to kill the Obama-era Clean Power Plan would cost American lives. The EPA under President Obama estimated that the plan to curtail carbon pollution, including particulates, would save up to 3,600 lives a year and prevent 1,700 heart attacks and 90,000 asthma attacks. For $8.4 billion of annual compliance costs, the nation would experience the nation would experience health benefits worth up to $54 billion by 2030.

Even the Trump administration’s own figures admitted its plan to relax regulations would release so much more particulate matter into the air that up to 1,400 more Americans would die prematurely and there would be 15,000 more cases of respiratory diseases. The administration also seeks to rollback Obama-era clean air standards for vehicles and block states such as California from setting their own pollution standards. In Obama-era estimates that are still available on the EPA web site, stricter standards for cars, trucks, construction and agricultural equipment and rail and marine engines could save nearly 40,000 lives a year in 2030. For $15 billion of compliance costs, the nation would receive nearly $300 billion (20 times more) in monetized benefits according to this analysis of the co-benefits.

In an era when state pollution protections are notoriously spotty,  the federal Environmental Protection Agency ought to fulfill its role as the chief environmental inspector and protector the nation can count on. Instead, at every turn, the Trump administration’s EPA is now seeking to deny the scientifically established benefits and co-benefits of cleaner air and water. This is no theoretical exercise. Even by the Trump administration’s own accounting in the case of the Clean Power Plan, these changes will cost American lives.

In environmental justice circles, neighborhoods that abut toxic industries are sometimes dubbed “sacrifice zones.” In its effort to erase the concept of co-benefits from the American conscience, the Trump administration is making the entire nation a sacrifice zone.

Originally posted here.

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