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What Trump's Latest EPA Rollbacks Can Teach Us About the Importance of Co-Benefits

Lost among the recent ubiquity of pandemic-related headlines was a critical chapter in President Trump’s sustained assault on key environmental regulations. This time, the issue was mercury, and the move will undoubtedly have knock-on effects for our respiratory health.

While cursory glances at the headlines may simply suggest yet another Trumpian rollback of U.S. Environmental Protection Agency (EPA) measures, a closer look at this recent ruling reveals much more about the nature of environmental protection and the need for a comprehensive understanding of how we regulate pollutants.

First, the science.

Mercury is a common by-product of power-plant activities and industrial mining processes. When ingested by humans (most commonly through the fish we eat) mercury poisoning (or Minamata disease, named after the Japanese town in which it was first documented) can lead to a host of medical conditions that include hair loss, muscle weakness/paralysis, organ damage, loss of senses, depression, and even death. 

(In fact, scientists at IISD Experimental Lakes Area, in a highly controlled experiment, intentionally added small amounts of traceable mercury to a lake to discover how it moved through the ecosystem and food web, and how it reached and accumulated in the fish that billions of people around the world consume daily.)

When it comes to mercury, the direct human health benefits of reductions were quantified at a maximum of USD 6.2 million. However, when you include the corollary benefits, the impact on human health in dollar figures shoots up to between USD 37 billion and USD 90 billion.

Back in 2011, the Obama administration finally recognized the evident need for the regulation of mercury emissions from coal- and oil-fired power plants. They decided to deem it "appropriate and necessary" for the U.S. EPA to introduce a series of thresholds and rules.

The administration determined, however, that when calculating the benefits of new mercury-emission regulations, "co-benefits" should also be counted. Co-benefits, put simply, are the ancillary effects of a set of regulations or practices that are also beneficial to the original intention. In this case, that intention was protecting public health.

When it comes to mercury, the direct human health benefits of reductions were quantified at a maximum of USD 6.2 million. However, when you include the corollary of particulate matter (including sulphur dioxide and nitrogen oxides) that is reduced due to the installation of the required mercury-control technology, the impact on human health in dollar figures shoots up to between USD 37 billion and USD 90 billion.

That calculation offers a clear justification for the USD 9.6 billion price tag industry spent in implementing the changes. But without that "co-benefits" line in the calculations, the benefits tumble back down to $6 million, making a less convincing financial case to industry.

And the originally intended health benefits? Had co-benefits been disregarded in the original U.S. EPA mercury calculations, it is estimated the United States would have suffered 11,000 more premature deaths, 4,700 more heart attacks, and 130,000 more asthma attacks every year.

Including co-benefits was a necessary step and should provide an aspirational blueprint for environmental policy.

But the Trump administration has now managed to axe the justification of the inclusion of co-benefits—when it comes to mercury, at least. The Mercury and Air Toxic Standards still stand but are now vulnerable to lawsuits and further rollbacks, due to their now supposed diminished value.

This is a highly disquieting move whose impacts could be experienced by hundreds of thousands of people in the United States and abroad, given that mercury emissions literally blow in the wind and pay no regard to international borders.

But what should worry us more is the precedent that is being set. Now that the devaluation of critical co-benefits has been officially sanctioned in the context of mercury, and with a head of the EPA that just happens to be a former coal lobbyist, the scene is now set for a docket of pollutants emitted from the burning of fossil fuels to have their regulations loosened.

Fish lies on a wooden table with a stick inside it held by someone wearing blue gloves
Scientists at IISD Experimental Lakes Area intentionally added small amounts of traceable mercury to a lake to see how it reached and accumulated in the fish that billions of people around the world consume daily.

Including co-benefits was a necessary step and should provide an aspirational blueprint for environmental policy. And in the context of this current pandemic, protecting air quality and its impact on our citizens’ health is at the forefront of our minds.

As the months pass, we cannot forget the critical role that the valuation of co-benefits plays in safeguarding public health and must ensure that this recent ruling proves to be a blip and not the signal of a new normal.

Want to learn more about what IISD Experimental Lakes Area has discovered about the impact of mercury on fresh water and fish? Click here.

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