Occasionally during his presidency, Donald Trump has suggested that he cares deeply about clean air and water, even as he expresses deep skepticism about climate change. But the specifics of Trump’s deregulatory approach tell a different story. The Trump administration has undertaken a series of regulatory moves to weaken the analytical foundation for clean air and water regulations. These moves seek to eliminate or undercut precisely those regulations that bring the biggest health benefits. The clean air regulations under the Clean Air Act, which account for the overwhelming majority of all quantified and monetized benefits of all federal regulation, are under significant threat.
Four specific analytical moves are particularly troubling: first, shifting focus to costs and ignoring benefits of regulation; second, erasing public health science; third, reviving discredited scientific models; and fourth, eliminating indirect benefits from regulatory impact analysis. Individually, each of these four strategies, if fully implemented, would significantly harm the health and welfare of Americans. Together, they threaten a fundamental reshaping of environmental and public health protection in the United States. These four moves—manifested in rules currently proposed or already promulgated by the U.S. Environmental Protection Agency and other agencies—represent a concerted attack on rational economic analysis of regulation that has received little comprehensive academic discussion. When put together, these disparate deregulatory measures paint a picture of a truly monumental assault on rational policymaking.
