EPA Proposal on Mercury Pollution Is Based on Faulty Analysis

Environmental economists from Columbia Mailman School of Public Health, Harvard, Yale, and other leading research institutions say an Environmental Protection Agency (EPA) proposal that would eventually allow more mercury pollution from power plants relies on a cost-benefit analysis that is fatally flawed. In a new report, the economists detail how the EPA’s calculations inappropriately fail to consider how reducing mercury pollution provides tens of billions of dollars in health benefits to the American people.

“The EPA is ignoring important public health benefits that should be part of the cost-benefit analysis,” said Matthew Neidell, Columbia Mailman School professor of health policy and management. Neidell and the other report authors are members of the External Environmental Economics Advisory Committee (E-EEAC), an independent organization providing the best available economic advice to the EPA. The E-EEAC was established after the EPA dissolved its own EEAC in 2018. Neidell once served on that EPA advisory committee, which had contributed to policy analysis for 25 years as part of the EPA’s science advisory board system.

A central issue in the report is that of “co-benefits”—benefits the American people gain that are not the main focus of a given rule. In the case of EPA’s rule limiting mercury pollution from power plants—called the Mercury and Air Toxics Standards (MATS) — tens of billions of dollars in public health benefits were estimated to come from the associated reduction in particulate matter – tiny pieces of matter less than 2.5 micrometers in size that are a hazard to human health.

Office of Management and Budget (OMB) policies and EPA guidance say co-benefits should always be considered when analyzing the effects of proposed policies. But EPA’s proposed mercury rule omits any consideration of co-benefits, including reducing particulate pollution.