The EPA has said it will not meet its September 30th deadline for issuing greenhouse gas regulations. Good news, yes, but the train wreck is still moving forward.
Despite the costs of the EPA’s regulations, there remains a large amount of uncertainty in the agency’s estimates of benefits. The problems?
- The EPA states that the Transport Rule is important because it will save up to 34,000 lives, but their own analysis actually says that premature mortality avoided will be 13,000 to 34,000.
- Estimates include a great amount of uncertainty and may significantly overestimate the benefits of the rule.
- EPA models assume a high degree of precision
- EPA does not provide any assessment of the quality and certainty of the estimates in their cost-benefit analysis.
- In a 2002 study the National Research Council made a strong recommendation that the EPA do more quantitative assessment of uncertainty.
- EPA’s approach masks the uncertainty in benefits, making hard to compare their models to the real world.
- This doesn’t give policymakers enough information to make important decisions.
- Depending on their choice of model, the benefits could be overstated by an order of magnitude.
- The EPA should do a quantitative uncertainty analysis to get a more robust estimate of the costs and benefits of their regulations
All this uncertainty makes it clear that we need something like the TRAIN Act, which would require a comprehensive review of the EPA’s regulations.