EPA Develops New Regulation Assessment Strategy
The EPA plans to implement smog reduction requirements that will cost $90 billion dollars to implement. These cost will be born by the private sector(who else?). S. William Becker, Executive Director of the National Association of Clean Air Agencies claims that the new EPA regulations “will produce benefits that will trump the cost many times over”.
I called Bill’s office and asked for the trump card information to which he referred.
To their credit he sent me the EPA Fact Sheet –Supplement To The Regulatory Impact Analysis for Ozone, upon which he based his rosy prediction of cost benefits.
It is amazing that such a change in regulations with a $90 billion cost estimate is being touted as cost beneficial based on such bogus information. The so called FACT SHEET has NO facts. There are 9 benefit categories in the FACT SHEET which contain estimates of the benefit expectations over a ten year period.
The first category is one that claims that between 4,000 and 12,000 premature deaths will be avoided if the regulations proposed will be enacted. The range of the estimate is a clear indication that whatever science is being used to determine results is faulty at best and perhaps not science at all.
The entire fact sheet has the scent of WAGS being used to gain support for a Regulation adjustment that EPA has decided to do, no matter what the financial consequences are, that fall on the private sector.
I would challenge anyone to tell me how a factual determination that a benefit of 8.1 million days of restricted activity will be eliminated from American life if a 0.060 ppm of fine particle concentration is achieved.
The presumptive analysis methodology to reach the FACT SHEET conclusions of benefits is without a doubt structured to produce estimates that clearly are solely designed to indicate results that support EPA assumptions.
I looked at the EPA Supplement for several days trying to figure out why it had a feeling of familiarity. I realized that it looked like worksheets that I had seen many times at meetings with my staff when we were contemplating a project that had many unknowns. When we didn’t have hard facts or comparable projects to base our assumptions, we often started the project analysis with some WAGS.
The WAGS were simply to get our thinking organized and proceed with hard work improving the WAGS to come to conclusions which would enable us to make the investment needed.
The EPA seems to have followed the WAG system and decided that enough work had been done. A FACT SHEET, with no facts, was all that was needed to meet the requirements for the private sector to spend $90 billion.
Lisa Jackson and Janet Napolitano probably did their public policy studies at the same school which had a Degree in Illusion Creation. Lisa evidently studied harder since her work is hidden behind a curtain called a FACT SHEET.
Note: If you are not familiar with a WAG- It means Wild Ass Guess, which is something for which the private sector couldn’t get financing. Lisa Jackson and the EPA doesn’t have that problem. They will just take it out of our pockets using a factless FACT SHEET
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