EPA: Friend to Seniors?

Publicly, the Environmental Protection Agency (EPA) has expressed great interest in protecting the elderly, recently launching an “Aging Initiative” to examine their particular vulnerability to environmental health hazards. Yet behind the scenes, the agency is employing analytical methods that systematically devalue the lives of seniors in setting environmental standards, making strong protections much less likely.

EPA announced its Aging Initiative in October of 2002, and has since launched a web site [1], as well as a series of public listening sessions [2] geared toward seniors. Unfortunately, the agency’s approach to cost-benefit analysis -- which has emerged as the heart of the administration’s regulatory decision-making -- presents a huge barrier to turning this listening into action (as discussed in greater detail previously by OMB Watch [3] and here by the Natural Resources Defense Council [4]).

Specifically:

• In monetizing human life [5] (a requirement of cost-benefit analysis), EPA is assigning less value to the lives of those over age 70, scoring them at 63 percent of those under age 70. This happened in a recent analysis for EPA’s much-touted Clear Skies Initiative [6], as well as in a major rule on snowmobile emissions finalized this past September, which not surprisingly, was much weaker than current technology would have allowed [7].

• At the urging of the White House Office of Management and Budget (OMB), EPA is estimating benefits in terms of life years saved (in addition to number of lives, the more common method of measurement over the years). This approach, which is advised by OMB in new proposed guidelines [8] for cost-benefit analysis, naturally skews decision-making against protections for the elderly, who have fewer life years remaining.

• OMB is also insisting that EPA “discount” the value of lives saved in the future, which has the effect of discouraging action against cancer or other diseases of old age, which have long latency periods. The further in the future a “statistical life” is saved as a result of regulatory action today, the more it will be discounted from its “present value,” and the less likely the action will pass a cost-benefit test -- this can be understood as a form of “interest in reverse.” The practice of discounting human life is not new, but there has been a significant change in emphasis. The current administration sees monetized cost-benefit analysis as the best way to determine proper regulation. It is no longer just one tool, among many, to inform decision-making. It is the tool, which makes discounting much more consequential.

EPA’s public listening sessions, which will take place in six cities over the course of this month, are being held to gather public input for the development of a “national agenda” that will “examine and prioritize environmental health threats to older persons,” who represent an increasing proportion of the population. “By 2030, the number of older persons aged 65 and older is expected to double to 70 million, one out of every five Americans,” according to EPA [9].

EPA will be accepting public comments [10] on these issues through May 16. More information, including registration details, on the public listening sessions being held in Florida, Texas, Iowa, Pennsylvania, California and Maryland, is available on EPA’s website [2].