The federal government's reported figures for jobs "created or saved" by the "stimulus" bill (formally the American Recovery and Reinvestment Act of 2009, or "ARRA") are now known to be wrong. The Recovery Accountability and Transparency Board, which oversees these figures, apparently has decided not to correct them.
A scandal has erupted over the federal government's reporting of the number of jobs created or saved by the "stimulus" bill (formally the American Recovery and Reinvestment Act of 2009).
This scandal would have been avoided if the government had complied with the Information Quality Act.
A careful look at parts of EPA's proposed endangerment finding show the causal chain that the Agency believes is scientifically sufficient. This causal chain has interesting implications for air pollution policy more generally.
EPA's proposed endangerment finding asserts that greenhouse gas emissions from US mobile sources cause or contribute to public health harm. However, the Clean Air Act distinguishes between "public health" and "welfare." EPA proposes to count some welfare-related effects as public health effects.
In July 2008, the Environmental Protection Agency published an advance notice of proposed rulemaking that raised numerous issues concerning the regulation of greenhouse gas emissions through the Clean Air Act. Regulations.gov reports over 17,000 entries labeled as public comments.
Today, the Environmental Protection Agency proposed to use authority in Section 202(a) of the Clean Air Act to regulate US emissions of six greenhouse gases.
In recent years there has been a notable increase in the use of expert elicitation in human health risk assessment. The method usually involves empaneling a group of experts and, through a carefully crafted and complex set of procedures, asking each panel member to provide a subjective probability that some phenomenon that cannot be directly observed is true or false. The Environmental Protection Agency has an informative external review draft white paper on the subject.
In environmental health, expert elicitation has been used to quantify the risk of cancer from drinking water disinfection byproducts, the likelihood that routine exposure to particulate matter in air causes premature mortality, and the magnitude of uncertainties related to climate change. Each is a tough scientific question. For example, the risk involved may be quantitatively small, and hence hard to discern, or the scientific uncertainties may be very large. Judgment is required, and the judgments of scientists inevitably reflect a mixture of scientific expertise and nonscientific opinion.
The need for discerning science from policy in expert judgment has been recognized for decades, at least since the 1983 National Research Council Red Book. No consensus yet exists concerning how to do this in practice. As a result, practitioners of expert elicitation typically acknowledge the problem but not much else. The EPA external review draft white paper mentioned above, for example, says that Agency technical support documents relying on expert elicitation should address "[p]ossible correlations with non-elicited components of the overall analysis or policy question" -- a phrase that, when translated into plain English, means the inflitration of experts' policy views into their characterization of science.
Today's Wall Street Journal has an example drawn from a very different arena -- macroeconomic forecasting -- that offers a wealth of insight about the problems with expert elicitation.
On July 15, 2008, we published a post concerning the Environmental Protection Agency's advance notice of proposed rulemaking (ANPRM) concerning whether greenhouse gas emissions warranted regulation under the Clean Air Act. At the time, it was widely thought that this single regulatory action could be the largest in U.S. history, with annual effects on the economy of roughly $100 billion per year. We had planned to run a series of posts on the issues presented in this ANPRM.
We were overtaken by events. Not only do the ANPRM and its supporting documents run to thousands of pages, but the number of items in the public docket now exceeds 2,500, not including public comment mass mailings. However desirable it might be as a public service to sift through this information, it is beyond our current funding capabilities to complete.
Meanwhile, a truly unexpected event happened shortly after the ANPRM was published. The world financial panic that erupted in September is so much greater in scope and scale that this ANPRM suddenly looks small.
Neutral Source is revising its priorities for 2009 given these extraordinary events. Please be patient.
On July 11, 2008, EPA published for public comment an advanced notice of proposed rulemaking on the question whether, and if so, how, EPA should regulate carbon dioxide as a criteria air pollutant under the Clean Air Act. EPA simultaneously published a letter from Susan Dudley, Administrator of OMB's Office of Information and Regulatory Affairs, publicly distancing the Bush administration from EPA's proposal. Comments sent to EPA by other federal agencies also were made public.
This set of events may be unprecedented in the annals of federal regulatory poliicy. Today we begin a series providing a policy-neutral examination of the documents and the issues presented.
The Washington Post's environment reporter says EPA has weakened the national ambient air quality quality standard for ozone. Given that the standard is going down, what does she mean? More...
Following up on yesterday's post, we now look at compact fluorescent (CFL) light bulbs. June Fletcher of the Wall Street Journal reported that the payback period for CFLs is "about four months." She provided no source for this figure. More...
Wall Street Journal reporter June Fletcher says (link temporarily available to nonsubscribers) it's not easy being green at home because a lot of heavily-promoted household renovations and products cost more that they deliver in environmental benefits, including energy savings. "Most homeowners like the idea of going green," she writes, " -- until they get the bill.
With home sales slumping and consumers rethinking their remodeling budgets, building contractors and suppliers are dangling green upgrades. They hope that energy-efficient systems and products made from sustainably harvested materials will hook consumers concerned about global warming, pollution and natural resources.
Yet with a few exceptions, green materials and construction cost extra, making them a hard sell. Enermodal Engineering, a Canada-based consulting firm, estimates the premium at 5% to 10%, depending on how extensively a builder uses recycled materials and water- and energy-efficient products. When Specpan, an Indianapolis research firm, surveyed builders recently for Building Products magazine, the greatest number estimated a 10% to 19% cost increase when going green.
Some consumers are willing to pay for green goods and services even if they are not cost-effective. Making significant headway into the market, however, requires that they demonstrate cost-effectiveness. Fletcher says there are two examples of green products that pass this test: home appliances and comfact fluorescent (CFL) light bulbs. Citing estimates from US EPA's Energy Star web site, Fletcher says Energy Star clothes washers and refrigerators have a "relatively short payback" of 3.5 years and 3.1 years, respectively, and that CFLs "pay back their extra cost in about four months."
Today we look at the claims for Energy Star appliances. More...
Regulation is widely understood as a tax on the activity or person being regulated. Where these activities repair genuine market failures, benefits from regulation may result. If there are benefits from, say, automobile safety regulation, one would expect the beneficiaries to be persons who otherwise would have been killed or injured at the pre-regulatory safety level.
But what about the costs of regulation? Who bears them? More...
Experts in risk analysis often distinguish between risk assessment and risk management. But sometimes they don't, and that can leave the public confused about the difference.
Today's example is trichloroethylene, commonly called TCE. More...
