CEI’s Latest Comment On Cost Benefit Analysis Reveals their Moral and Intellectual Bankruptcy

  • Published on August 12th, 2020
The Trump administration has been going after the cost-benefit analysis process for a while now, and a set of changes meant to devalue human lives for industry’s profit that were once on the backburner are getting some renewed (albeit last-minute) attention. A particular target for the lobbyists presently running our regulatory bodies has been co-benefits, the concurrent perks of reducing one type of pollution as the result of a policy aimed at a different type of pollution.

By Climate Denier Roundup

To get specific, since coal plants emit a lot of tiny soot particles known as PM2.5, the Obama-era regulation on mercury would also reduce a lot of PM2.5. The health benefits of that much less soot in the air appear enormous, and the benefits of that PM2.5 reduction helped justify the mercury rule. Therefore, coal supporters, including those in the Trump administration, have been undermining the premise that co-benefits, like the PM2.5 reduction, should count when doing the cost-benefit analysis.

How sound is their argument for this relatively major change to established regulatory law and process?

Well, the Competitive Enterprise Institute was nice enough to summarize their comment submission after the period closed earlier this month, and offered up some suggestions for “reining in PM2.5 co-benefits abuse.”

The first of these is essentially a reverse legal loophole, the second and third are that the EPA should “develop the case” that PM2.5 reducations actually increase costs (despite preventing thousands of heart attacks and saving billions of dollars in health expenses) and that reductions below a certain threshold just shouldn’t be counted.

And finally, the concluding remarks, the note on which they chose to end their summary, is to throw to Steve Milloy, who combined his current job defending fossil fuels with his past job defending tobacco by comparing it to smoking. Apparently, someone who never smokes inhales about 2 ounces of PM2.5 over a lifetime, while a steady half-pack-a-day smoker will inhale 4.5lbs of PM2.5 over 15 years.

But — and this is where it gets super clever — if a smoker quits at 35, their life expectancy is the same as the never-smoker. Therefore, says super smart Steve Milloy, “if one can inhale either a little or a lot of PM2.5 over the course of a lifetime and expect to live the same length of time, then PM2.5 does not kill on a long-term basis.”

Now why, we wondered, would Milloy compare the nonsmoker to the person who quit smoking, and not someone who continued to smoke? After all, his argument is that PM2.5 isn’t a problem, right? So shouldn’t it also not be a problem if the person didn’t quit inhaling it? What’s the average life expectancy of a regular smoker, Mr. Milloy?

Turns out, it’s not as long. Smoking causes about one in five deaths in the US every year, and according to the CDC, “life expectancy for smokers is at least 10 years shorter than for nonsmokers.”

The reason that those who quit early don’t always face the same long-term consequences is because lungs can recover and heal from the damage, and stopping smoking stops the constant bombardment of the lungs. So what Milloy’s argument for CEI implies is that we should not reduce PM2.5 pollution now, because if we were to eliminate it in the future (like the person who eventually stops smoking) then we could then begin to heal from the damage that it’s done.

But… why not just stop smoking/PM2.5 now, and prevent a bunch of that damage in the first place? (Because Milloy has smoke to sell, that’s why.)

Of course the more salient and literal point is that it only takes a single particle to kick off a deadly chain reaction, something known as the “linear dose response” that we’ve discussed before in the context of Steve Milloy pushing radiation exposure as a good thing.

So while the EPA’s standard for PM2.5 is set at 12mg/m3, reducing that level to 10, or five, or zero, as a result of closing polluting coal plants, will continue to pay off in terms of reduced health impacts.

Which is exactly why Milloy, CEI, and the Trump administration’s fossil fuel staff are trying to undermine it by saying those benefits don’t count.

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