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



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Enviro-Mich message from "Savoie, Kathryn" <KSavoie@accesscommunity.org>
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This is truly objectionable, and highlights an inherent danger in assigning
a monetary value to human life. . . 

I hope that the environmental community -- not to mention AARP --  challenge
this attack on equal protection of all people. 

Kathryn Savoie, Ph.D.
Environmental Program Director
ACCESS

NEW ADDRESS & PHONE:
6450 Maple Street
Dearborn MI  48126
(313) 216-2225
ksavoie@accesscommunity.org <mailto:ksavoie@accesscommunity.org> 

	-----Original Message-----
	From:	Alex J. Sagady & Associates [SMTP:ajs@sagady.com]
	Sent:	Friday, April 04, 2003 1:08 PM
	To:	enviro-mich@great-lakes.net
	Subject:	E-M:/ George Bush and Devaluation of Life to Lighten
Regulatory Burdens

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


	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)
	jwalke@nrdc.org



	
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