When the Trump administration last week finalized a rule that could make it more difficult to enact public health protections by changing the way the EPA calculates costs and benefits of new limits on air pollution, the rule makers didn't take into account Chattanooga's example of how such costs and benefits play out.
Or, seeing as it is the Trump administration, they just didn't care.
The new cost-benefit requirements, which apply to all future Clean Air Act rules, instruct the Environmental Protection Agency to weigh all the economic costs of curbing an air pollutant, but disregard many of the incidental benefits that arise. "Incidental" benefits such as avoided illnesses and deaths.
In short, if reducing emissions from power plants or foundries also saves tens of thousands of lives each year by cutting soot, those "co-benefits" should be not be counted.
"This is all about transparency and conducting our work in a transparent fashion," EPA Administrator Andrew Wheeler said Wednesday as he announced the finalized rule during a webinar at the Heritage Foundation, a conservative think tank. "Our goal with this rule is to help the public better understand the why of a rulemaking, in addition to the what." The agency's past approach "has meant inconsistent rules and a disoriented private sector," he added.
What it really is all about is the push by conservatives and some industry lobbyists to steer Donald Trump's bulldozing of more than 125 environmental policies. These are folks who view pollution control merely as a cost to try to avoid.
But look around our city and ask yourselves how that "cost and benefit" would be playing out here today had the nation's dirtiest city of the 1960s and 1970s not cleaned up its act by forming a local air pollution bureau and leaning on foundries like Combustion and U.S. Pipe to put scrubbers on their smokestacks.
We might still have have some of those foundries — though likely not, since U.S. Pipe was swallowed by the plastic pipe industry and Combustion fell victim to a nuclear industry hollowed out by Three Mile Island and other nuclear woes.
But waiting for clean air merely by market chance would have shrouded us much longer with smog so terrible drivers had to turn on their headlights downtown on a sunny day. That fact alone would have meant we wouldn't now be a thriving and growing tourism center.
No one would travel here for Ironman Triathlon competitions if they couldn't see the Tennessee River or the mountains. No one would want to move here if we were still struggling to breathe each time we went outside. Volkswagen would not have put its North American plant here a decade ago and employ 3,800 people. And without VW, Chattanooga wouldn't have 11 new auto supplier companies employing another 1,100 workers to assemble everything from seats to axles to dashboards.
But thanks to this and other new Trump administration rules, the future contemplation for manufacturing will in reality be anything but "transparent."
Left alone, these kinds of rollbacks could again engender the kind of one-sided equations that allowed foundries of old to belch whatever nastiness came out. Or the kind of one-sided calculation that allowed the now-defunct Chattanooga Coke and Chemical company to ditch waste coal tar to Chattanooga Creek and the Tennessee River. Or the kind of industry-takes-all thinking that allowed a Southside saddlery to drop the skinned carcasses of livestock into the river for cost-free, float-away disposal.
But Trump's lame-duck EPA is on a mission to beat the clock ticking toward Joe Biden's Jan. 20 inauguration, and environmental experts fear there are 50 more last-minute rollbacks in the offing.
Also last week, EPA rejected calls to tighten national standards for fine particle pollution, known as PM2.5 — a scientific term for the particulate matter most of us know as soot. It is the nation's most widespread deadly air pollution.
The current allowable measure of fine particle pollution was set in 2012. But EPA scientists in a draft report last year recommended lowering the standard further to save between 9,050 and 34,600 lives a year.
Trump's EPA said the Obama-era level is "adequately protective of human health."
Cost vs. benefit. What's a few thousand lives (incidental benefits if they are saved) worth compared to the cost of installing a new air scrubber or developing a cleaner process or — wowsa — developing a cleaner energy source?
Environmental advocates suggest the new cost-benefits rule will not withstand legal challenges. And certainly Biden's incoming administration is likely to begin work to overturn it and other rollbacks. But this will take time, and time is money. There are legal procedures that must be followed to eliminate existing regulation.
Trump and his EPA minions have shown no respect for the law or the environment or the health of Americans in four years, so we know not to expect it now. These midnight rollbacks are just more sulfurous acts of sabotage, designed to obstruct Biden and future administrations.
The trouble is, this senseless and vengeful waste of time, resources and good will hurts all of America, too.