Deep Flaws in a Mercury Regulatory Analysis

A study from experts across prominent academic institutions finds that an EPA benefit-cost analysis of its Mercury and Air Toxics Standards is “seriously flawed.”

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April 9, 2020


Joseph E. Aldy, Matthew Kotchen, Mary Evans, Meredith Fowlie, Arik Levinson, and Karen Palmer


Journal Article in Science

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1 minute


Researchers from Harvard, Yale, Claremont McKenna College, UC Berkeley, Georgetown, and Resources for the Future (RFF) find deep flaws in the US Environmental Protection Agency (EPA)’s benefit-cost analysis in support of a proposed rule related to the regulation of hazardous air pollution from coal-burning power plants. The analysis forms part of the foundation for a regulatory proposal to roll back the legal underpinnings of its Mercury and Air Toxics Standards (MATS), which power plants have been complying with since 2016, leaving the standards vulnerable to legal challenges.

The authors highlight the following as flaws in EPA’s analysis:

  • It disregards economically significant but indirect public health benefits, or “co-benefits,” in a manner inconsistent with economic fundamentals. The expected benefits of reducing particulate matter pollution of $33-90 billion per year easily exceed the expected costs of $9.6 billion under EPA’s original 2011 analysis of the MATS rule.
  • It fails to account for recent science that identifies important sources of direct health benefits from reducing mercury emissions, such as fewer heart attacks.
  • It ignores transformative changes in the structure and operations of the electricity sector over the last decade. Shifts from coal to natural gas and renewable sources, including wind and solar power, for electricity generation have decreased the number of power plants that must install pollution control equipment. The investment in pollution control has been about half of what was projected in 2011.


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