A TRAIN that Shouldn't Leave the Station

Opponents of clean air and water standards are putting their money into a new set of wheels. It's called the TRAIN Act (TRAIN stands for Transparency in Regulatory Analysis of Impacts on the Nation - read the bill here).

Put briefly, this proposal is an attempt to open a new line of attack on  the Environmental Protection Agency and rules that protect and promote clean air and water, veiled in the language of "cost-benefit analyses." And when the proponents of this proposal say "cost-benefit" analysis, what they really mean is "cost-cost" analysis - that is, an evaluation that takes into account only the costs and not the benefits of clean air and water for businesses, local economies, and communities.

The fact is, we already have review processes set up to look carefully at the full picture of costs and benefits when it comes to updating the standards that protect our air and water. We have plenty of cost-benefit analyses, both from government agencies and from independent third parties. And when you look at the full picture, it's clear that the benefits of our air and water standards far outweigh the costs for small businesses and for our economy overall.

A new briefing paper from the Economic Policy Institute reaffirms these conclusions. The paper, which looked at both final and proposed EPA rules, found that for nine final rules and four proposed rules studied:

  • The combined annual benefits from the nine final rules exceed the costs by $32 billion to $142 billion a year (with benefit/cost ratio ranges from 4-to-1 to 22-to-1).
  • The combined annual benefits from the four proposed rules exceed the costs by $160 billion to $440 billion a year (with benefit/cost ratio ranges from 12-to-1 to 32-to-1).

Looking at these benefit-to-cost ratios, we're talking about an impressive return on investment.

Clean air and clean water are Main Street values and always have been. A true cost-benefit analysis shows that they make economic sense for small businesses and for the economy as a whole.

Here's hoping for small businesses that the ill-conceived TRAIN Act never leaves the station.

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