An Analysis of the EPA's Proposed Lead Hazard Standards For Homes

Exposure to lead in homes poses such large risks to children's health that reducing it is a major public health priority. To limit these risks, the Environmental Protection Agency (EPA) recently proposed national standards to identify hazardous levels of lead dust and lead in soil, as well as hazardous conditions for lead-based paint. Meeting those standards would require controls that would cost an average of thousands of dollars per home in 21 million homes where lead-based paint is present, according to the EPA. Although the EPA believes its proposed standards reflect an appropriate balancing of benefits and costs, a proper assessment of its proposal suggests otherwise. Each of the EPA's proposed standards for paint, soil and dust would result in measures to control lead that have costs in excess of benefits. Together those costs, less the associated benefits, are likely to exceed $20 billion. Estimates of net costs would be still greater if based on an analysis that corrects remaining deficiencies in the EPA's work. The EPA's proposal would likely increase unnecessarily the premature abandonment of housing in instances where control costs are large relative to the market value of homes. Such abandonment is especially undesirable because it will occur mostly in low-income neighborhoods of older homes. Standards with lower costs would result in less abandonment. The EPA's media-specific, national standards would have other undesirable consequences. Perversely, about half of all the homes that do not meet the standards have risks of elevated blood-lead less than at other homes in full compliance with the standards. In addition, all homes built before 1978 would be subject to the same national standards, although exposure, risk and the cost of controls vary substantially among different households. As a consequence, the EPA's standards would result in controls in homes of more than one million middle-income families whose children face risks lower than the risks for children of poor families living in homes that meet the standards. Controls to reduce low risks are not likely to be cost-effective and are unfair to families facing lower risks who would bear the brunt of the control costs. The EPA can set standards that would offer greater net benefits and avoid controls in lower-risk homes. To provide greater net benefits, the EPA should set less stringent standards based on a more careful reappraisal of the benefits and costs of controlling residential lead hazards. To avoid control measures in lower-risk homes, the EPA should set standards based on lead levels in all media and establish a range of lead levels where recommendations to control lead depend on risk factors specific to individual homes.

Is EPA's Ozone Standard Feasible?

The Environmental Protection Agency's estimate of the cost of meeting the new health-based ozone standard is likely to underestimate substantially the actual cost. EPA's cost estimates unrealistically assume that pollution control costs are capped at $10,000 per ton. Yet the required emission reductions in some cities exceed total motor vehicle emissions. By dropping EPA's assumption that control costs are constant, I show that meeting the standard in 2010 would cost nearly$5 trillion in one city, and $70 billion in seven other cities. These cost estimates exceed EPA's estimates of$10 billion per year by orders of magnitude. I also find that the incremental costs of control are likely to far exceed any estimates of incremental benefits. The high cost of meeting the ozone standard strongly suggests that it is likely to be infeasible in several cities. To avoid having EPA set such infeasible standards, Congress should amend the Clean Air Act to require the agency to balance the benefits and costs of regulation.

Rationalizing Air Pollution Regulation

On Valentine's Day, President Bush proposed new air pollution standards that would cut sulfur dioxide emissions from their the current level of 11 million tons per year to three million, nitrogen oxide emissions from five million tons to 1.7 million, and mercury emissions from 48 tons to 15 tons, all by the year 2018. At the same time, the Bush administration continues to advocate suspending the New Source Review (NSR) program, which critics have chastised for encouraging energy companies to continue operating "grandfathered" refineries and generation plants that are outmoded and minimally maintained, instead of refurbishing them or replacing them with new facilities. Clearly, environmentalist lawmakers and the White House have an opportunity to forge a sensible compromise that would enable the passage of new sulfur dioxide, nitrogen oxide, and mercury caps while dumping NSR. But that process will not yield legislation that can be implemented in an economically sound manner unless Congress and the administration pay attention to a few basic economic issues.Environment, Technology and Industry, Regulatory Reform

An Analysis of the U.S. Department of Agriculture's Proposal to Allow Irradiation of Meat

Foodborne pathogens in the United States kill thousands and sicken millions each year, despite major efforts by federal agencies and industry to combat the problem. Food irradiation could safely prevent a substantial part of those deaths and illnesses and has been endorsed by all major public health organizations. Yet federal regulations prohibit the use of irradiation to kill pathogens on meat, eggs, and seafood and restrict its use on poultry, and so contribute to avoidable deaths and illnesses. The U.S. Department of Agriculture should expedite its rulemaking to allow irradiation of meat, and it should not require that food labels mention irradiation more prominently than they identify food additives. Most importantly, to boost food irradiation in the marketplace, the Food and Drug Administration should promptly determine that irradiation of any food, including precooked meats, eggs, and seafood, is generally recognized as safe.

An Analysis of the Use of EPA's Clean Air Benefit Estimates in OMB's Draft Report on the Costs and Benefits of Regulation

Many advocates of regulatory reform recommend more and better benefit-cost analyses. Perhaps the single most ambitious and sophisticated such analysis ever conducted is the retrospective report on the benefits and costs of clean air recently completed by the Environmental Protection Agency. But EPA's estimates of trillions of dollars in benefits from the Clean Air Act depend on a few arbitrary assumptions about the nature and value of health improvements. Although a panel of well-respected scientists and economists reviewed the EPA's report, the Office of Management and Budget should not include it in its own report to Congress without more extensive discussion of key limitations. In particular, OMB should include a quantitative illustration of how alternative assumptions as plausible as those in the EPA report could shrink the expected value of benefits to a fraction of those reported.

Clean Air For Less: Exploiting Tradeoffs Between Different Air Pollutants

The Administration's Clear Skies initiative and all competing legislative proposals take a pollutant-by-pollutant approach to address air pollution problems caused by emissions of both nitrogen oxides (NOx) and sulfur dioxide (SO2). Randall Lutter and Dallas Burtraw argue that as a result they miss an important opportunity to cut compliance costs without reducing expected environmental protection. For a scenario where firms could use permits to emit three tons of NOx instead of one ton of SO2, we estimate that compliance costs would fall by more than $1 billion per year relative to emissions caps like those in Clear Skies. Yet expected environmental damages would not increase because the projected damages from three tons of NOx are roughly the same as from one ton of SO2. To ensure that new air pollution legislation is cost-effective, Congress should allow firms to exchange NOx and SO2 permits at a rate that reflects relative environmental damages.

Assessing Benefits of Ground-Level Ozone: What Role for Science in Setting National Air Quality Standards?

A key determinant of the fate of the Environmental Protection Agency's (EPA) 1997 ozone standard is how the Agency responds to a Court of Appeals' decision that it must consider not only harmful respiratory effects, but also ozone's beneficial ability to reduce exposure to harmful ultraviolet radiation (UV-B). In January 2001, EPA Administrator Browner signed a proposed response to the Court of Appeals' decision, but it has several problems. EPA's Scientific Advisory Committee did not review the scientific basis for Browner's proposed response, although such review is required by statute and EPA's internal procedures. The proposed response also ignores earlier EPA analysis suggesting that the health benefits of ozone are not negligible. Finally, it has significant conceptual flaws that the Advisory Committee could have corrected. The existence of a tradeoff between respiratory effects and UV-B related risks means that careful science is essential to ensure that air quality standards improve public health. Before publishing a proposed response to the Court's decision, EPA should submit its assessments of UV-B related risks to its Scientific Advisory Committee. It should also seek the Committee's advice about how to set standards.

Does Mercury in Fish Come from the Air?

Concerns with public health risks associated with mercury-contaminated fish have prompted a variety of proposals to cut or eliminate mercury emissions. As a step toward assessing how such reductions could affect fish contamination, we develop a cross-sectional epidemiological model of mercury levels in fish. Using data on stream characteristics, land use, the presence of point sources and both measured and modeled atmospheric deposition of mercury, we explain two-thirds of the variation in mercury levels in fish. We find that greater mercury deposition is not generally associated with higher mercury levels in fish. These results suggest that reductions in deposition (and emissions) may affect mercury levels in fish only slightly or with a significant delay.

Do Regulations Requiring Light Trucks To Be More Fuel Efficient Make Economic Sense? An Evaluation of NHTSA's Proposed Standards

The National Highway Transportation Safety Administration (NHTSA) recently proposed increasing the fuel economy of new light trucks by 1.5 miles per gallon for vehicles produced in model year 2007. NHTSA's analysis of its proposal implausibly concludes that the benefits to consumers are more than twice the costs to manufacturers, ignoring effects on the environment or dependence on foreign oil. NHTSA's proposal has several serious flaws. It wrongly presumes that manufacturers cannot produce items that consumers are willing to buy, even though they could make money by doing so. Its analysis uses overly optimistic measures of net benefits. In addition, NHTSA neglects the adverse effects from the increased driving induced by the proposal. By lowering the cost of driving, NHTSA's proposal increases vehicle miles traveled, thereby boosting traffic accidents and congestion. The increase in the costs of accidents and congestion fully offsets and probably outweighs the social benefits resulting from greater fuel economy. If NHTSA is interested in a cost-effective way of reducing gasoline use, it should consider giving consumers better information about fuel economy of new vehicles, or suggest a modest gasoline tax. A penny per gallon levy would conserve more fuel in 2007 than NHTSA's proposal, while lowering, rather than increasing, traffic congestion and accidents.

Unacknowledged Health Benefits Of Genetically Modified Food - Salmon And Heart Disease Deaths

Randall Lutter and Katherine Tuckerargue that the marketing of GM salmon will lower salmon prices and increase consumption of salmon, an exceptionally good source of omega-3 fatty acids linked to lower risk of heart disease.The authors estimateestimate that the resulting increase in omega-3 intake will prevent between 600 and 2600 deaths per year in the U.S.Environment, Health and Safety