Last week, EPA formally revised the cost-benefit analysis for its rule limiting the emissions of hazardous air pollutants from coal-fired power plants. The rule jettisons consideration of so-called “co-benefits,” in this case, the benefits from the reduction in emissions of PM2.5 that result from limits on mercury emissions. The very idea of excluding consideration of co-benefits is just plain incoherent.
I’ve spent my career defending cost-benefit analysis to many of my environmentalist friends. I have to concede that this rule is Exhibit A for their case. People who die as a result of emissions don’t care whether it’s the mercury or the PM2.5 that kills them. If the implementation of cost-benefit analysis can be gamed to eliminate consideration of benefits because they are the wrong kind of benefits, then one has to wonder about the entire exercise.
Here’s the simple version. EPA has an obligation to assess limits on emissions of HAPs from coal-fired power plants. It should consider all benefits of a particular rule and all costs. Seems correct to me. Why is that so difficult?
And, by the way, the existence of these co-benefits suggests that the current PM2.5 NAAQS may not be sufficiently protective – but I’ve covered that one elsewhere.