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NERA Testimony on 'Quality Science for Quality Air'

4 October 2011
By Dr. Anne E. Smith

On 4 October 2011, NERA Senior Vice President Dr. Anne E. Smith delivered testimony at a hearing on "Quality Science for Quality Air" before the US House of Representatives Committee on Science, Space, and Technology's Subcommittee on Energy and the Environment. Dr. Smith was asked to share her perspective on the economic underpinnings of the Environmental Protection Agency's (EPA) policy analyses for setting air quality standards. Dr. Smith's testimony focused primarily on her analyses and research on the costs and benefits in EPA's Regulatory Impact Analyses (RIAs). Dr. Smith argued that, in order to create the appearance of large health benefits from air regulations for pollutants other than fine particulate matter (PM2.5), EPA is relying to an extreme degree on calculations of "co-benefits" from small reductions in PM2.5 concentrations that are already at levels EPA deems safe -- reductions that EPA predicts will occur as a coincidental result of having to comply with the regulations on non-PM pollutants. Dr. Smith also argued that EPA's unwillingness to set a PM2.5 air quality standard low enough to directly mitigate those purported risks suggests EPA recognized that its estimates of "co-benefits" are not reflective of true public health risks. This practice in EPA's RIAs is dubious scientifically, but also leads to overly costly and complex ways of providing for national air quality needs.