Key Takeaways

• EPA policy shift may undercount benefits: By dropping monetary estimates of health benefits from air pollution rules and focusing mainly on industry compliance costs, the EPA risks presenting a misleading picture of the true economic impacts of regulation.
• Health impacts are substantial and uneven: Decades of research show that reducing PM2.5 and ozone delivers major health and economic gains that often far outweigh costs, and weakening standards could disproportionately harm children, low-income communities and communities of color.
• Regulatory and climate consequences loom: Ignoring benefits in cost analyses could undermine legally required standards, make it harder for states to meet air quality goals and lead to higher pollution levels that worsen public health and climate change.

A North Carolina State University professor is warning that a recent policy change implemented by the Environmental Protection Agency could understate the true benefits of air pollution regulations, potentially affecting public support for stronger standards.

The EPA is changing how it evaluates the economic impact of air pollution regulations by no longer assigning a monetary value to the health benefits of reducing fine particulate matter (PM2.5) and ozone. Instead, the agency will focus primarily on the compliance costs for industry.

“If the EPA only counts compliance costs, it would provide a grossly inaccurate picture of the economic outcomes of regulation,” said Jennifer Richmond-Bryant, an associate professor in the Department of Forestry and Environmental Resources, whose research specializes in human exposure to air pollution with a focus on marginalized communities.

Richmond-Bryant noted that past EPA analyses found that air quality standards save Americans roughly thirty times more than they cost. For every dollar spent on compliance, society avoids about $30 in medical expenses, lost productivity and other harms.

Historically, the EPA analyzed both the benefits of reducing pollution, such as improved health outcomes, avoided healthcare costs and fewer missed workdays and the compliance costs for industry, including pollution-control equipment and cleaner fuels.

In its economic impact analysis for the new policy, the EPA now states that current estimates of health benefits carry too much uncertainty, asserting that assigning dollar values to lives saved or health improvements from reduced air pollution can create a “false sense of precision.” 

Richmond-Bryant noted that despite estimation errors and uncertainties in data, the scientific evidence linking air pollution to serious health risks is strong. She added that measurement errors often lead to underestimating harm, meaning the effects could be even worse than models indicate.

Some experts worry that downplaying economic benefits could influence perceptions of stricter air quality standards, potentially making regulations seem less advantageous and weakening public and political support for stronger protections.

Richmond-Bryant emphasized that the methodological change technically should not result in higher pollution levels, since cost analysis is not supposed to influence decisions on the National Ambient Air Quality Standards (NAAQS), which states are still required to comply with. However, loosening restrictions on the New Source Performance Standards for individual sources will undermine compliance with the NAAQS. 

Even though the NAAQS themselves aren’t supposed to be influenced by cost considerations, meeting those standards depends on how much pollution individual facilities are allowed to emit. New Source Performance Standards help keep emissions from new and upgraded plants in check. If those limits are relaxed, more pollution can enter the air overall, which makes it harder for states to meet and maintain national air quality standards, even if the standards on paper haven’t changed.

Under the Clean Air Act Section 111(a), when the EPA sets New Source Performance Standards, it is required by law to look beyond just how much pollution can be reduced. The agency must also consider how expensive it is to reduce that pollution, whether the controls produce health or environmental impacts including benefits, and whether they affect energy use or reliability.

“Section 111 is clear that regulators must consider both costs and benefits of the New Source Performance Standards. It is arbitrary to use uncertainty as a pretext for completely ignoring the benefits of control technologies, while costs also have uncertainties but are not being ignored by the EPA,” Richmond-Bryant said.

She warned that if the EPA were to ignore this legal requirement and cite costs to justify relaxing regulations, it could shape how states implement the NAAQS and influence permitting decisions for industrial facilities.

The consequences could be severe. Strong evidence links PM2.5 and ozone to serious health problems. Based on thousands of peer-reviewed studies, the EPA has concluded that short- and long-term exposure to PM2.5 causes heart disease and premature death, while short-term ozone exposure triggers respiratory illness.

Certain groups are especially vulnerable. Research shows that children, Black communities and low-income populations face higher health risks from PM2.5 exposure. According to Richmond-Bryant, weakening regulations could exacerbate these disparities, particularly when combined with limited access to health care and other social disadvantages.

“Disparities in exposures and health effects have started to decline, but those might expand again as states permit greater emissions for facilities located in close proximity to communities of color or low-income communities,” Richmond-Bryant said.

Because PM2.5 largely comes from burning fossil fuels, allowing more emissions could also worsen climate change. Decades of research show that coal, oil and gas combustion releases heat-trapping gases that drive global warming. 

“It stands to reason that permitting more pollution will accelerate warming and exacerbate the impacts of climate change,” Richmond-Bryant said.