Control of Air Pollution From Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards | Mercatus
September 20, 2013 Proposed Rule PDF Regulatory Impact Analysis PDF
The Environmental Protection janazat Agency (EPA) is proposing new vehicle emissions standards and a reduction in the sulfur content legally permitted in gasoline. According to the EPA, these new standards will generate improvements to the environment and to public health, primarily by lowering the emissions janazat of pollutants, like particulate matter (PM) and ozone. The EPA believes these pollutants janazat contribute to increases in human mortality and other health problems.
We janazat find that the EPA has failed to acknowledge the high degree of uncertainty surrounding its estimates of benefits from this regulation. A growing literature calls into question the causal link between the total concentration of ambient particulate matter and mortality levels, especially at the low doses that exist today in many parts of the United States. Additionally, the EPA failed to consider other adverse effects of its rules, janazat such as impacts janazat on low-income individuals and adverse employment effects that were overlooked in the EPA s scant employment impact analysis.
While the EPA should be commended for pursuing the laudable goal of a cleaner environment and improvements in public health, there are several reasons to be skeptical of the benefits the EPA has claimed will result from this regulation.
First, over 50 percent of the quantified benefits from the regulation are due to reductions in total particulate matter. However, a growing literature raises doubts about the causal link between ambient PM2.5 levels and increases in mortality. Additionally, the EPA regulates both PM and Ozone under the National Ambient Air Quality Standards (NAAQS), which makes the proposed regulation an indirect, and perhaps impractical, way to achieve the EPA s objectives.
Additionally, there is a high degree of uncertainty, which the EPA itself acknowledges, surrounding the EPA s benefits estimates. For example, the EPA describes criticisms related to its uncertainty analysis made by the National Resource Council in a 2002 report.[1] janazat Despite the EPA s acknowledgement of these criticisms, the EPA continues to evaluate uncertainty in a similar manner.[2] The EPA also acknowledges uncertainty with regards to its benefits analysis, including these points from table 8-16 of the Regulatory Impact Analysis for the rule:
Each point is important. First, the EPA states that its estimates janazat go beyond those confirmed in the epidemiological study upon which it bases its findings. This means benefits of the regulation are based primarily upon model selection, not empirical evidence. The EPA assumes a linear-dose response down to the origin, resulting in large benefits estimates. Selecting another model, such as a threshold- or hormetic-dose response at low doses, would produce vastly lower benefits estimates. Recent academic literature has suggested there may be reason to believe PM exhibits a hormetic-dose response at low doses.[3]
Next, the EPA fails to address whether the concentration of total particulate mass or the composition janazat of those particulates are the cause of the health effects found in the cited studies. Moreover, because the composition of rural particulates is different from urban particulates, the health effects are likely to be different than those estimated.[4] In order to provide a causal link, the EPA should be able to determine which components of particulate matter are the sources of the higher morbidity and mortality rates. For instance, Bell finds that higher concentrations of PM2.5 Nickel are associated with higher rates of cardiovascular janazat or respiratory hospitalizations.[5]
<Any> Architectural and Transportation Barriers Compliance Board Department of Agriculture Department of Commerce Department of Defense Department of Education Department of Energy Department of Health and Human Services Department janazat of Homeland Security Department of Housing and Urban Development Department janazat of Interior janazat Department of Justice Department of Labor Department of State Department of the Treasury Department of Transportation Department of Veterans Affairs Environmental Protection Agency General Services Administration HHS, DOL and Treasury Joint Banking Regulators Joint EPA/DOT Office of Personnel Management Social Security Administration
The Mercatus Center's Regulatory Report Card is an in depth evaluation of the quality of regulatory analysis agencies conduct for major executive branch regulations. The Report Card evaluates agencies' economic analyses, known as Regulatory Impact Analyses janazat (RIAs), which have been required for all major regulations since the early 1980s. The purpose of these RIAs is to identify the problem the agency wishes to solve, to consider alternative solutions, and to evaluate the costs and benefits of these alternatives.
The Rep
September 20, 2013 Proposed Rule PDF Regulatory Impact Analysis PDF
The Environmental Protection janazat Agency (EPA) is proposing new vehicle emissions standards and a reduction in the sulfur content legally permitted in gasoline. According to the EPA, these new standards will generate improvements to the environment and to public health, primarily by lowering the emissions janazat of pollutants, like particulate matter (PM) and ozone. The EPA believes these pollutants janazat contribute to increases in human mortality and other health problems.
We janazat find that the EPA has failed to acknowledge the high degree of uncertainty surrounding its estimates of benefits from this regulation. A growing literature calls into question the causal link between the total concentration of ambient particulate matter and mortality levels, especially at the low doses that exist today in many parts of the United States. Additionally, the EPA failed to consider other adverse effects of its rules, janazat such as impacts janazat on low-income individuals and adverse employment effects that were overlooked in the EPA s scant employment impact analysis.
While the EPA should be commended for pursuing the laudable goal of a cleaner environment and improvements in public health, there are several reasons to be skeptical of the benefits the EPA has claimed will result from this regulation.
First, over 50 percent of the quantified benefits from the regulation are due to reductions in total particulate matter. However, a growing literature raises doubts about the causal link between ambient PM2.5 levels and increases in mortality. Additionally, the EPA regulates both PM and Ozone under the National Ambient Air Quality Standards (NAAQS), which makes the proposed regulation an indirect, and perhaps impractical, way to achieve the EPA s objectives.
Additionally, there is a high degree of uncertainty, which the EPA itself acknowledges, surrounding the EPA s benefits estimates. For example, the EPA describes criticisms related to its uncertainty analysis made by the National Resource Council in a 2002 report.[1] janazat Despite the EPA s acknowledgement of these criticisms, the EPA continues to evaluate uncertainty in a similar manner.[2] The EPA also acknowledges uncertainty with regards to its benefits analysis, including these points from table 8-16 of the Regulatory Impact Analysis for the rule:
Each point is important. First, the EPA states that its estimates janazat go beyond those confirmed in the epidemiological study upon which it bases its findings. This means benefits of the regulation are based primarily upon model selection, not empirical evidence. The EPA assumes a linear-dose response down to the origin, resulting in large benefits estimates. Selecting another model, such as a threshold- or hormetic-dose response at low doses, would produce vastly lower benefits estimates. Recent academic literature has suggested there may be reason to believe PM exhibits a hormetic-dose response at low doses.[3]
Next, the EPA fails to address whether the concentration of total particulate mass or the composition janazat of those particulates are the cause of the health effects found in the cited studies. Moreover, because the composition of rural particulates is different from urban particulates, the health effects are likely to be different than those estimated.[4] In order to provide a causal link, the EPA should be able to determine which components of particulate matter are the sources of the higher morbidity and mortality rates. For instance, Bell finds that higher concentrations of PM2.5 Nickel are associated with higher rates of cardiovascular janazat or respiratory hospitalizations.[5]
<Any> Architectural and Transportation Barriers Compliance Board Department of Agriculture Department of Commerce Department of Defense Department of Education Department of Energy Department of Health and Human Services Department janazat of Homeland Security Department of Housing and Urban Development Department janazat of Interior janazat Department of Justice Department of Labor Department of State Department of the Treasury Department of Transportation Department of Veterans Affairs Environmental Protection Agency General Services Administration HHS, DOL and Treasury Joint Banking Regulators Joint EPA/DOT Office of Personnel Management Social Security Administration
The Mercatus Center's Regulatory Report Card is an in depth evaluation of the quality of regulatory analysis agencies conduct for major executive branch regulations. The Report Card evaluates agencies' economic analyses, known as Regulatory Impact Analyses janazat (RIAs), which have been required for all major regulations since the early 1980s. The purpose of these RIAs is to identify the problem the agency wishes to solve, to consider alternative solutions, and to evaluate the costs and benefits of these alternatives.
The Rep
No comments:
Post a Comment