美国环境保护局如何错误地将空气污染法规的收益货币化（英）

About the Authors Bryan Hubbellis a senior fellow at Resources for the Future (RFF). Hubbell is anexpert on the health and environmental impacts of air pollution. He served as thenational program director for the Air, Climate, and Energy Research Program in the USEnvironmental Protection Agency’s Office of Research and Development. He notablyled the EPA team that developed the Environmental Benefits Mapping and AnalysisProgram (BenMAP), a tool now used worldwide to evaluate the benefits of clean air. Healso led the Risk and Benefits Group, where he was responsible for assessing exposure Alan Krupnickis an RFF senior fellow and director of the Industry and Fuels Program.Krupnick is an expert on the oil and gas sector, reducing greenhouse gas emissionsfrom this and the industrial sectors, and cost-benefit analysis. In particular, Krupnick’srecent research focuses on green public procurement, decarbonized hydrogen andtax credits, and developing markets for green natural gas. His portfolio also includes About RFF Resources for the Future (RFF) is an independent, nonprofit research institution inWashington, DC. Its mission is to improve environmental, energy, and natural resourcedecisions through impartial economic research and policy engagement. RFF is The views expressed here are those of the individual authors and may differ from thoseof other RFF experts, its officers, or its directors. Sharing Our Work Our work is available for sharing and adaptation under an Attribution-NonCommercial-NoDerivatives 4.0 International (CC BY-NC-ND 4.0) license. Youcan copy and redistribute our material in any medium or format; you must giveappropriate credit, provide a link to the license, and indicate if changes were made,and you may not apply additional restrictions. You may do so in any reasonablemanner, but not in any way that suggests the licensor endorses you or your use.You may not use the material for commercial purposes. If you remix, transform, or Abstract The Trump administration’s US Environmental Protect Agency (EPA) has decidedto stop quantifying and monetizing human health benefits when analyzing theimpacts of federal regulations, overturning decades of established and peer-reviewedconventions. Instead, only the costs incurred by companies for complying with aregulation will be quantified when implementing regulatory decisions, leading to anunbalanced assessment of impacts. The EPA’s arguments for not quantifying andmonetizing benefits are unsupported and out of step with the best available science Contents 1. Introduction12. Uncertainty Has Always Been a Part of Regulatory Analyses33. Benefits Gained by Reducing Particulate Matter Concentrations BelowNational Standards64. The Value of a Statistical Life Is the Best Method for Monetizing MortalityBenefits75. No Co-benefits—Only Benefits86. Conclusion9References10 1. Introduction A critical part of the US Environmental Protect Agency (EPA) rulemaking process isthe preparation of regulatory impact analyses (RIAs) that assess the costs, benefits,and economic and equity impacts of proposed and final regulations. By providinginformation about both the costs and benefits of proposed regulations, RIAs However, the Trump administration in its recent economic impact analysis1of newsource performance standards for combustion turbines has proposed to not quantifyor monetize human health benefits, focusing solely on the costs to the regulatedindustry (EPA 2026). Such an approach would ignore human health benefits, whichEPA has previously estimated to be large, thereby tilting the analysis in favor of lessstringent regulation. Excluding the health benefits of regulation would go against In this report, which builds upon a recent If/Then blog, we assess each of EPA’sarguments for making such a drastic change to its proposed analytical process(Hubbell and Krupnick 2026). We find that its arguments don’t hold up to even the Both EPA (EPA 2011a) and outside analysts (Palmer, Burtraw, and Shih 2007; Chestnutand Mills 2005) have estimated large human health benefits of EPA’s air pollutionregulations. Mortality benefits from reduced ozone and particulate matter less than 2.5micrometers in diameter (PM2.5) have provided the majority of all benefits of federalregulations in the last several decades (OMB 2024). Excluding air quality health benefits is inconsistent with EPA’s Guidelines for EconomicAnalysis, Circular A-4 from the Office of Management and Budget (OMB), and withcore economic principles (EPA 2024a;OMB 2003). If EPA fails to quantify the humanhealth benefits of air quality regulations (or the foregone benefits of deregulation), While in many cases costs and benefits estimated in RIAs cannot form the legal basisfor regulatory decisions, they are critical parts of the agency’s public justificationfor the regulations. For example, when EPA issued the revised National Ambient AirQuality Standard (NAAQS) for PM2.5in 2024, the first paragraph of the agency’s p