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E-M:/ George Bush and Devaluation of Life to Lighten Regulatory Burdens

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>

Here is a briefing paper from NRDC on the matter
of White House beancounters attempting to
devalue the lives of some of our citizens in order
to allow industry to escape environmental control regulations....

April 2003
NRDC Backgrounder
Cheapening the Value Of Life: The Bush Administration's Death Discount
Contact: John Walke, 202-289-2406, or Elliott Negin, 202-289-2405

The Bush administration recently added a new tool to its anti-environmental 
kit that could significantly change the way the government assesses and 
regulates environmental threats. The tool is a biased form of cost-benefit 
analysis that makes regulations appear less worthwhile by lowering the 
hypothetical monetary value of human life. Senior citizens are particularly 
at risk under this new approach, since many of the techniques can be used 
specifically to discount the life of the elderly when regulating some of 
the greatest threats to their health, such as air pollution.

Recently the administration has used this analysis in new air pollution 
control rules and proposed legislation that cater to industrial polluters 
at the expense of public health. Last fall, the Environmental Protection 
Agency featured this "alternative" analysis in its support documentation 
for the administration's air pollution legislation for power plants (see 
<http://www.nrdc.org/air/pollution/fclearsk.asp>), and in its final rule 
for off-road engines like the ones used in snowmobiles. Both of these 
proposals would not adequately protect the public from soot, smog and other 
dangerous pollutants.

This novel approach was so tilted that the level of benefits calculated 
under this method was more than 90 percent less than under the usual EPA 
method, falling from the previously accepted standard value of $6.1 million 
per life saved to less than half a million dollars for many fatalities. 
What is more unsettling is that most of the reduction in benefits was due 
to lowering the estimate of the value of saving a human life, not to a 
change in the estimate of the number of lives that would be saved.

To lower the estimate for the value of lives saved under these proposals, 
the White House Office of Management and Budget (OMB) had EPA reduce its 
established value through a series of steps. One of the most startling 
steps was to count the value of saving the lives of Americans over 70-years 
old as worth only 63 percent of the standard value assigned to people under 
70 - a percentage based on a flawed concept and an unsuitable study.

The main administration proponent for this kind of slanted analysis is John 
Graham, head of the OMB office that reviews regulations 
(<http://www.nrdc.org/onearth/03spr/graham1.asp>). In October 2001, Graham 
recommended that the National Academy of Sciences consider using a related 
calculus, called Quality Adjusted Life Years (QALY), when evaluating air 
pollution policies. The theory behind QALY is that the value of saving 
someone's life should be adjusted downward the older and more infirm he or 
she gets. But the theory behind QALY conflicts with more valid empirical 
studies that show that as people get older they do not value their lives 
any less than they did when they were younger. In any case, it is 
objectionable on its face if one believes in equal protection for all 
members of society.

More recently, Graham and OMB have proposed fundamental changes to the 
guidelines that agencies follow when conducting their reviews of the costs 
and benefits of regulations. One of the more notable recommended changes 
would have agencies shift from the standard statistical measure for the 
value of a life to a different concept, the Value of a Statistical 
Life-Year (VSLY). Like QALY, the concept of VSLY is biased against the 
elderly because it lowers the value of saving a life based largely on the 
numbers of years a person has left to live.

Seniors are not the only people whose lives would be cheapened by the Bush 
administration's new approach. Other administration techniques could apply 
to everyone. They include selectively excluding studies that heighten the 
estimate of people's willingness to pay for protection (in this case 
wage-risk studies) and discounting the value of saving people from cancer 
and other kinds of illnesses that are not immediately fatal. The 
administration also is only considering alternative techniques that would 
lower the value of life instead of approaches that might raise the standard 
estimate, such as shifting from assessments based on a current "willingness 
to pay" for safeguards to approaches based on a "willingness-to-accept" 
harms or risks.

The blatant onesidedness of the administration's approach reveals its 
intention to only use methods that ratchet down the value of life to reduce 
the perceived benefits of regulation, and thereby minimize the steps 
industry must take to clean up polution. Although the EPA claims that it 
ultimately did not use this biased approach in setting its standard for 
off-road engines, nothing prevents it from doing so in the future. Indeed 
the presence of this alternative analysis, however distorted, becomes a 
convenient hook for legal and legislative action hostile to environment 

The implications of discounting lives are quite significant. If, for 
example, the government decided the value of life is now worth less than a 
tenth of what is used to be, policymakers could decide to allow 10 times as 
many deaths from environmental pollution - claiming the "benefits" were 
unchanged - to keep costs down for industry. Such a review procedure could 
block federal agencies from adopting meaningful standards for a range of 
pollutants, and even set the stage for agencies to weaken effective 
environmental protections that are already in place.

The Natural Resources Defense Council is a national, non-profit 
organization of scientists, lawyers and environmental specialists dedicated 
to protecting public health and the environment. Founded in 1970, NRDC has 
more than 550,000 members nationwide, served from offices in New York, 
Washington, Los Angeles and San Francisco. More information is available 
through NRDC's Web site at www.nrdc.org <http://www.nrdc.org>.

John D. Walke
Director, Clean Air Program
Natural Resources Defense Council
1200 New York Avenue, NW, Suite 400
Washington, D.C. 20005-3928
(202) 289-2406 (Ph)
(202) 289-1060 (Fax)

Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Evidence Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
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