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Center for Regulatory Effectiveness

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The Anti-Stimulus Plan
The Obama Administration says the air needs to be further cleaned up. Winston says, first consider the consequences.

EPA estimates the cost of tightening the ground-level ozone standard at between $19-$90 billion, depending on where the permissible level is set. Benefits are estimated by the agency to be somewhere in the range of $13-$100 billion.

Before any rule is finalized, there needs to be a thorough understanding of its costs, including job losses and impacts on state and municipal budgets. EPA should identify, on a state-by-state basis, how many jobs of what types are likely to be lost. For example, EPA should estimate how many manufacturing jobs the rule would cost in Ohio.

The estimated costs and potential benefits of the rule, and the validity of the underlying studies, need to be subjected to strict scrutiny under the Data Quality Act. Key studies relied on by the agency will have to meet the DQA's reproducibility requirement for "influential" information and the agency must adhere to the OMB's Peer Review Bulletin and Updated Principles for Risk Assessment.

Studies relied on by EPA, and the agency's interpretations and conclusions, are subject to challenge and correction under the DQA.

NGOs such as the Environmental Defense Fund, Clean Air Watch and NRDC are pleased with EPA's proposal. Even environmental watchdogs, however, are hinting at some of the consequences of a final regulation. An NRDC official said that "counties that would be in violation would have to impose pollution curbs on businesses" while an EDF scientist described compliance as "not impossible."

With unemployment at 10% and many families and states in economic crisis, the Administration needs to decide how many billions they want spent to kill American jobs.

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