Air Pollution

Since 1971, the Environmental Protection Agency (EPA) has been required to do benefit-cost analyses, or regulatory impact analyses, to support its regulatory actions. GAO concludes that improvements in the presentation and clarity of information in EPA's analyses would enhance their value to both agency officials and Congress in assessing the benefits and costs of proposed regulations. Many of the analyses GAO reviewed did not clearly identify key economic assumptions, the rationale for using these assumptions, the degrees of uncertainty associated with both the data and the assumptions used, or the alternatives considered. Not clearly displaying this information makes it hard for decisionmakers and Congress to appreciate the range and the significance of the benefit and cost estimates presented in these documents.

GAO noted that: (1) while certain key economic assumptions, such as the discount rate and the value of human life, can have a significant impact on the results of benefit-cost analyses and are important to the regulations being proposed, eight of the RIAs did not identify one or more of these assumptions; (2) furthermore, in the RIAs that identified key economic assumptions, the rationale for the values used was not always explained; (3) for example, one RIA assumed a value of life that ranged from $1.6 million to $8.5 million and another, prepared in the same year, assumed a value of life that ranged from $3 million to $12 million; (4) in neither instance did the RIAs provide a clear explanation of the rationale for the values that were selected; (5) even though EPA's guidance suggests that RIAs account for any uncertainties in the values of key assumptions by conducting sensitivity analyses, which show how benefit and cost estimates vary depending on what values are assumed, 13 RIAs used only a single discount rate; (6) all 23 RIAs assigned dollar values to the estimated costs of proposed regulations, however, 11 of the RIAs assigned dollar values to the estimated benefits; (7) according to EPA officials, assigning dollar values to potential benefits is difficult because of the uncertainty of scientific data and the lack of market data on some of these effects; (8) all of the RIAs contained some quantitative or qualitative information on the expected benefits, such as a reduced incidence of mortality and illness; (9) while the number and the types of alternatives considered in the 23 RIAs were not always clear, GAO's examination indicated that six of the RIAs compared a single alternative, which was the regulatory action being proposed, to the baseline, which was the situation likely to occur in the absence of regulation, the status quo; (10) the remainder compared two or more alternatives to the baseline; (11) resource constraints and the specific requirements of authorizing legislation, which sometimes limits EPA's options, were factors influencing the extent to which alternatives were considered; (12) ten of the RIAs GAO examined did not include executive summaries, even though these summaries can be a significant benefit to decisionmakers; and (13) EPA officials acknowledged that some of the RIAs did not include executive summaries and agreed that executive summaries, by providing easily accessible information, can be useful to decisionmakers.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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