The Environmental Protection Agency (EPA) will cease quantifying the health effects of air pollution and ozone in dollar terms, citing too much uncertainty, according to a new regulatory impact analysis issued by the agency.

Historically, the EPA applied a dollar value to the health benefits of reducing air pollution in the United States, including the number of illnesses and premature deaths avoided. In the new document, presented as a final rule entitled “New Source Performance Standards Review for Stationary Combustion Turbines and Stationary Gas Turbines,” the agency wrote that the uncertainty surrounding the estimates of fine particulate matter and ozone now precludes assigning dollar values to health effects such as illnesses and deaths prevented. 

According to the document, “The EPA’s analytical practices often provided the public with a false sense of precision and more confidence regarding the monetized impacts of fine particulate matter (PM_2.5) and ozone than the underlying science could fully support, especially as overall emissions have significantly decreased, and impacts have become more uncertain.”

The report added that the current use of benefit-per-ton monetized values for dollar amounts “reduced complex spatial and atmospheric relationships into an average value per ton, which magnifies uncertainty in the resulting monetized estimates.” 

The report further stated that “ to rectify this error, the EPA is no longer monetizing benefits from PM_2.5 and ozone but will continue to quantify the emissions until the agency is confident enough in the modeling to properly monetize those impacts.” 

Disservice to Public Health

“While uncertainty is real, removing health benefits from the analysis does not resolve it,” wrote MeiLan Han, MD, chief of the Division of Pulmonary and Critical Care at the University of Michigan in Ann Arbor, Michigan, in a Substack post responding to the EPA’s changes. “Cost-benefit analysis shapes outcomes. When health effects disappear from the benefits side of the ledger, regulations become harder to defend,” Han said. “Industry costs remain visible and exact. Public health becomes something that can be acknowledged in narrative form, but not weighed,” she added.

Han wrote that she and her pulmonologist colleagues see their patients’ health get worse in the presence of high pollution levels, and they see lung damage caused by chronic exposure to air pollution. The EPA has repeatedly concluded that reductions in premature death have been the greatest benefits of air pollution regulations, Han noted.

Costs Difficult to Quantify

Estimating monetary savings in terms of medical costs, economic costs (productivity), and illness and deaths avoided allows for documentation of greater benefits in public health that outweigh significant industry costs, as shown in previous EPA reports.

Han added that removing the costs of lives saved from air pollution policy analysis will weaken air quality protection. “This decision belongs to a broader dismantling of public health infrastructure, where protections are weakened not by overt repeal, but by removing the tools that once made them defensible,” she said in her post.

Examples of uncertainties include but are not limited to: epidemiological uncertainty (eg, concentration-response functions, mortality valuation); economic factors (eg, discount rates, income growth); and methodological assumptions (eg, health thresholds, linear relationships, spatial relationships). 

Han disclosed no financial conflicts of interest.