It may be an apocryphal story, but my understanding as to why so many small municipal landfills in New Hampshire ended up on the NPL is that some bright light in the Granite State thought that Superfund was a public works program and that the fund would pay for the landfill closures. The result? Small towns became PRPs, responsible for Superfund response costs which, in some cases, approximated their annual municipal budget.
I recall going to a public meeting concerning EPA’s preferred alternative at one site. At most sites, the public pleads for EPA to require more cleanup – because someone else will be paying, of course. Here, the public was begging for less cleanup, because they thought that they had better ways to spend the money. Even if the money had to be devoted to public health and safety, they were confident that spending money on traffic lights and police and fire departments would yield a greater return.
I was reminded of this episode by EPA’s announcement last week of the release of guidance recommending the removal of PCB-containing light ballasts from schools. According to a report in the Wall Street Journal, New York City estimates that the cost to remove the ballasts will be $1 billion. Anyone think that NYC might have a better use for $1 billion in school spending?
There are really two points to this story. The first is that legislation in response to panics is not a good idea. The notion that there are special legislative provisions for PCBs, unlike the myriad of other toxic chemicals which are handled under provisions of general application is, to use a technical term, nuts. It has led to a separate PCB program within EPA which, in the bureaucratic nature of things, has to justify its existence, leading to costly recommendations such as those made last week.
Second, what if it really would be better to spend money on fire trucks, or traffic lights, or anti-drug programs in schools? To be fair to EPA, this is not a question the agency is tasked with answering. However, shouldn’t somebody be asking and answering such questions before regulations with such potential consequences are promulgated?
This is not about cost-benefit analysis, which simply asks whether the benefit of the requirement is worth its costs. It’s not even cost-effectiveness analysis, at least as EPA normally thinks about it. Such analysis would normally only try to determine the most cost-effective way to eliminate PCBs. I’m after something deeper. Even after we’ve determined the most cost-effective way to eliminate PCBs from light ballasts, I want to know how much that would cost, how much risk reduction it would achieve, and whether more risk reduction could be obtained by spending the money elsewhere.
I can dream, can’t I?