Who wants more coal company pollution in water streams?

by on February 4, 2017 at 10:28 am in Current Affairs, Economics, Law, Uncategorized | Permalink

That is one of the news stories of the end of this week, namely that the Trump administration eliminated a previous Obama administration ruling on this, see Brad Plumer for details.  That sounds horrible, doesn’t it?

I took a look at the cost-benefit study (pointed out on Twitter by Claudia Sahm, or try this link, and please note it was prepared by consultants, not by the government itself).  I spent some time with these hundreds of pages, and they are not always easy to parse (my apologies to the authors for any misunderstandings).  Anyway, I quickly came upon this and related passages (p.45, passim):

In summary, the Final Rule is expected to reduce employment by 124 jobs on average each year due to decreased coal mined while an additional 280 jobs will be created from increased compliance activity on average each year.

Of course those “newly created jobs” are a cost, not a benefit, and should be switched to the other side of the ledger.  That is not what this study did.  And if I understand p.4-31 correctly, this study is using a multiplier of about 2.  This approach is completely wrong, and if it were right Appalachia would love a lot of this coal regulation for its job-creating proclivities, but of course the region doesn’t.

The claimed annual benefit from the changes, from the side of coal demand (not the only effects), is $78 million, fairly small potatoes.  Note the study doesn’t consider what are commonly the most significant costs of regulation, namely distracting the attention of managers and turning companies into legal and regulatory cultures rather than entrepreneurial cultures.  The study does mention uncertainty costs from regulation, although I could not find any quantification of them.

Furthermore, I am not able to scrutinize the introductory section “SUMMARY OF BENEFITS AND COSTS OF THE STREAM PROTECTION RULE” and figure out the final assessment of net benefits for the rule and where that assessment might come from.  I find that worrisome, and paging through the study did not put my mind at ease in this regard.

Now, I know how this works.  Many of you probably are thinking that we need to do whatever is possible to attack or shrink the coal industry, because of climate change.  Maybe so!  Maybe we want to stultify the coal companies, for reason of a greater global benefit.  But a) there is still a role for evaluating individual policy changes by partial equilibrium methods and reporting on those results accurately, and b) “putting down the coal companies,” as you might a budgie, is not what the law says is the proper goal of policy.

Imagine holding an attitude that places the Trump administration as the actual defenders of the rule of law!  Besides, don’t get too worked up (p.174):

Our analysis indicates that there will be no increase in stranded reserves under any of the Alternatives.

There is, however, a very small decline in annual coal production (pp.5-20, 5-21) from the rule that had been chosen.  Water quality is improved in 262 miles of streams (7-26), in case you are wondering, that’s something but hardly a major impact and that almost entirely in underpopulated parts of the country.  All the media coverage I’ve seen implies or openly states a badly exaggerated sense of total water impact, relative to this actual estimate (are you surprised?).  Returning to the study, there is also no region-specific estimate of how large (or small) those water benefits might be, at least not that I could find (again, maybe I missed it, but I did find some language suggesting that no such estimate would be provided).

Chapter seven calculates the benefits of the resulting carbon emissions, but after reading that section my best estimate for those marginal benefits is zero, not the postulated $110 million.  The “social cost of carbon” is actually an average magnitude, and it does not measure benefits from very small changes.  Again, you might think there is an imperative to consider “this policy is conjunction with numerous other anti-coal changes,” but that is not what the law stipulates as I understand it and furthermore it hardly seems that many other anti-coal regulatory changes are on the way.

If it were up to me, I would not have overturned the coal/stream regulations, and my personal inclination is indeed to fight a war on coal.  But if you look at the grounds for evaluation specified by law, and examine the cost-benefit study with even a slightly critical mindset, we don’t know what is the right answer on this individual policy decision.  The study outlines nine different regulatory alternatives and it is not able to conclude which is best, nor is the quantitative thrust of the study aimed toward that end.

Mood affiliation aside, to strike this regulation down, as the Trump administration has done, is in fact not an indefensible action.

On a more practical political level, Trump wishes to send a signal to Appalachian voters that he is looking out for coal and looking out for them.  This is actually a very weak action, and it was chosen because for procedural reasons it was quite easy to do.  The more you complain about it, the stronger it looks, and that’s probably a more important fact than any of the particular details of this study.  Whether you like it or not, the coal debate is not really one that favors the Democrats.

Addendum: Here is the CRS paper, which seems to be derivative of other work, most of all this study.

1 TMC February 4, 2017 at 10:47 am

Thanks for the treatment of this. I couldn’t find good information about it.

“Imagine holding an attitude that places the Trump administration as the actual defenders of the rule of law! ” That’s how he got elected.

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2 anon February 4, 2017 at 11:09 am
3 TMC February 4, 2017 at 11:31 am

So Tribe has a problem with enforcing the law. Thanks, confirmation on how Trump got elected.

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4 anon February 4, 2017 at 11:48 am

That is dangerously uninformed, or dishonest, or both.

Have you kept up on Whitehouse email handling?

http://www.politicususa.com/2017/01/25/hypocrisy-alert-trump-white-house-private-rnc-email-system-again.html

Trump always was a hypocrite, but the sad thing is that he has now hung all the people who honestly (gullably) believe that he cared about law out to dry.

That is sad for you. All it would have taken by him was minimum compliance, to keep you covered.

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5 TMC February 4, 2017 at 12:00 pm

You who never actually reads the links he posts:

“Newsweek reports that some Obama staffers had DNC email addresses, but they say they were told by White House counsel that all work related emails had to be forwarded to the government email system.”

For political activities, the administration is REQUIRED BY LAW to use private server. Trump, Obama and Bush did so as required. Hillary got in trouble for conducting government business and transmitting classified information on a private server – FORBIDDEN BY LAW.

6 anon February 4, 2017 at 12:20 pm

He is using the same system that “lost” 22 million Bush era emails.

If that is not in your face hypocrisy I don’t know what is.

7 Jan February 4, 2017 at 12:27 pm

If you don’t understand how much of a hypocrite Trump is there is really no point arguing about. Either you eat his big shit sandwich or you don’t. But my personal favorite is him practically merging the federal government with Goldman Sachs immediately after spending nearly a year howling about Clinton and Cruz’s relationships with GS bankers.

8 msgkings February 4, 2017 at 12:48 pm

Yeah, Trump may have some defensible qualities, but lacking hypocrisy isn’t even close to one of them.

9 TMC February 4, 2017 at 1:17 pm

@msgkings Maybe so, but providing a non example isn’t a way to prove anything. I assume that’s the worse example you have, so it’s pretty much nothing.

Trump has been a hypocrite, but yelling “Trump is a hypocrite for not following the law”, and using examples of him following the law is not helpful.

10 anon February 4, 2017 at 3:46 pm

It is apparent that Trump does not understand the Constitution.

https://twitter.com/realDonaldTrump/status/827981079042805761

Pick your side on that.

11 anon February 4, 2017 at 3:49 pm

He also doesn’t understand the 2 year vetting cycle already in place, but that is mere incompetence, not unconstitutional belligerence.

12 TMC February 4, 2017 at 6:17 pm

Yes, he’s wrong on that last tweet. Obama completely ignored the constitution and you’ve never mentioned that though. What’s that called again? H something.

13 msgkings February 4, 2017 at 8:16 pm

“Obama completely ignored the constitution”

Hilarious starts with ‘H’, as does hogwash.

14 anon February 4, 2017 at 9:17 pm
15 Heorogar February 5, 2017 at 9:15 am

Save us, O Lord, from the wrath of the liberals!

16 Dick the Butcher February 5, 2017 at 9:24 am

Point of Information regarding the so-called judge and his bogus stay: exactly what chapter and verse of what US law or which Article/Amendment in the US Constitution gives 6+ billion foreigners the unlimited rights to come to the US and live off us taxpayers until they decide to kill us?

17 JCS February 4, 2017 at 10:49 am

Tyler, the link to the paper is a link to your downloads folder. Can you update the link to the online version?

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18 Tyler Cowen February 4, 2017 at 10:57 am
19 CS February 4, 2017 at 10:58 am
20 anon February 4, 2017 at 11:08 am

For future reference, the CRS report is “The Office of Surface Mining’s Stream Protection Rule: An Overview” CRS Report R44150.

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21 anon February 4, 2017 at 10:52 am

262 miles seems a lot to this occasional fly fisherman. Checking, the Brook Trout is the state fish of West Virginia and “While there are 500 miles of native trout streams in West Virginia, the streams are small and represent only two percent of the total miles of stream in the state.”

http://www.wvdnr.gov/Wildlife/BTrout.shtm

So I guess the question might be why only 500 can support trout? Are so lucky that the 262 would remove none?

That is, for some of us it might actually be about the streams.

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22 Politics of Cruelty February 4, 2017 at 11:02 am

Streams? No, costs and benefits have to only be about jobs. Killing fish, and making human sick, from polluted water, is considered entirely acceptable by our new Tweeter in Chief and his minions.

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23 anon February 4, 2017 at 11:05 am

I kind of worry that one interpretation of Hotelling’s rule is that you destroy all the streams, and then fish in Maryland.

As long as Maryland has fish. Repeat.

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24 Yancey Ward February 4, 2017 at 1:45 pm

You might try finding out how many miles of streams (as defined by BLM for the study itself) are in areas affected. Having grown up there, I know the actual number is magnitudes larger than 262 miles, so, no it isn’t significant on that scale. A single mountain top mine probably impacts hundreds of miles of streams off that mountain and the surrounding ones. Most of the streams per the study are intermittant or ephemeral (you get them when it rains heavily).

In other words, we are not discussing “trout streams” here and not even “fishable ones” per your link- most don’t have enough water to support fish larger than your finger if that. I would guess the BLM is counting streams that number in West Virginia and Eastern Kentucky alone at a minimum of 20,000 miles, and likely much, much larger.

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25 Michael P February 16, 2017 at 9:10 am

I think you’re right. Out of curiosity, I looked up how many miles of streams are in my home county of Fairfax, VA; the county seems to think the answer (as of 2004) is about 856 miles: http://www.fairfaxcounty.gov/dpwes/publications/stormwater/01_ps_qc_full_ada_v2.pdf

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26 The Anti-Gnostic February 4, 2017 at 10:58 am

my personal inclination is indeed to fight a war on coal.

Yeah I wish I lived in Hobbiton too. Or in Unicorn Fairy Land.

End globalism. I promise you carbon emissions will decrease.

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27 ConfirmationBiasIsAFemaleDog February 4, 2017 at 11:47 am

“End globalism.” What a plausible and possible policy stance. It’s just as simple as snapping your fingers!

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28 The Anti-Gnostic February 4, 2017 at 11:57 am

I can get more specific: halt immigration and end foreign aid.

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29 Jan February 4, 2017 at 12:28 pm

Did you know foreign aid is >25% of the US gov budget?

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30 AlanW February 5, 2017 at 6:59 am

0.9-1.2 percent, depending how you count. It will be interesting to see if that changes.

31 msgkings February 4, 2017 at 12:49 pm

You are right about carbon emissions. Will anything else happen?

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32 konshtok February 4, 2017 at 10:59 am

I loved the part where 124 jobs (presumably mostly blue collar ) are eliminated but 280 bureaucratic jobs are created

that alone justifies taring and feathering the people who wrote this rule

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33 anon February 4, 2017 at 11:01 am

You have never seen an environmental stream crew, have you.

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34 derek February 4, 2017 at 11:27 am

Actually no. And I get out alot.

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35 anon February 4, 2017 at 12:38 pm
36 TMC February 4, 2017 at 1:30 pm

The report says :”while an additional 280 jobs will be created from increased compliance activity on average each year”

I may be wrong, but compliance activity does not imply stream crews, which would be helpful. Sounds like DC living folks.

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37 Ryan February 4, 2017 at 3:57 pm

Compliance activity does often mean restoration work on streams. There’s some management/bureaucratic work too, sure.

Mitigation banking might be a reasonable comparison (though I haven’t read through the CRS study).

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38 buddyglass February 4, 2017 at 11:31 am

Depends on the context of the cost/benefit analysis. If the bureaucratic jobs are funded by federal taxes and/or paid for by coal companies (who then pass the cost on to their customers) then they may represent a net gain for those who live where they’re created.

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39 Erv February 4, 2017 at 12:17 pm

The difference is that the 280 jobs do a good thing (cleaning/protecting the environment) while the 124 jobs are doing a bad thing (extracting a polluting substance that messes up rivers and causes respiratory health problems).

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40 chip February 4, 2017 at 12:39 pm

Actually they both do the same thing – depend on cheap and plentiful energy that has enabled modern civilization, and which is suddenly a bad thing based on models that have no predictive value.

This paper studies just one small part of a movement that is costing nations many billions of dollars. Ontario, which is already saddles with over $300 billion of debt and spends more than $10 billion a year on interest alone, is spending well over $100 billion on green energy with absolutely zero idea of how much this will impact temperature, or even if this impact is actually a net benefit to life on this planet.

Prof Judith Curry wasn’t kidding when she cited the “craziness” of the climate change movement when she recently resigned from Georgia Tech. It’s a religious mania among a significant part of the population who are primarily motivated by fear and paranoia.

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41 Edgar February 4, 2017 at 2:23 pm

Thanks for mentioning Judith Curry who I admire. There ought to be an award for the academic who, at personal risk, makes the most valuable contribution to public discourse. It should be named “The Judith Curry Prize for Academic Integrity” in honor of her. And Tyler should get nominated for it for speaking these unpleasant truths about the low quality of federal regulations and CRS reports.

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42 Mark Bahner February 5, 2017 at 5:28 pm

“Actually they both do the same thing – depend on cheap and plentiful energy that has enabled modern civilization, and which is suddenly a bad thing based on models that have no predictive value.”

I haven’t read the analysis of the rule, but I’d expect that the effect on the price of electricity from coal-fired power plants would be incredibly small (i.e. a difference of pennies a month for a typical residential customer).

“This paper studies just one small part of a movement that is costing nations many billions of dollars. Ontario, which is already saddles with over $300 billion of debt and spends more than $10 billion a year on interest alone, is spending well over $100 billion on green energy with absolutely zero idea of how much this will impact temperature, or even if this impact is actually a net benefit to life on this planet.”

There are a *lot* of differences between Ontario and the U.S. 🙂 No offense intended, I’m just sayin’. In the U.S., photovoltaics in the Southwest (or even parts of the South, as photovoltaics prices come down) are become very cost-competitive with other forms of electricity. And photovoltaics supply is well-matched to demand in the Southwest, where air conditioners a huge part of peak load.

“Prof Judith Curry wasn’t kidding when she cited the “craziness” of the climate change movement when she recently resigned from Georgia Tech. It’s a religious mania among a significant part of the population who are primarily motivated by fear and paranoia.”

I would go even further and say there is significant fraud involved. Specifically, the climate change movement has promoted Representative Concentration Pathway (RCP) 8.5 as being a Business As Usual (BAU) scenario in the absence of agreements about climate change. (Formerly, this was the IPCC A1FI scenario.) It has always been clear to anyone who is informed about the matter there is no chance that CO2 emissions will be as high as in the RCP 8.5 pathway. It is *already* clear that the amount of coal burned in the 21st century will be nowhere near what’s in the IPCC RCP 8.5 scenario.

Here’s a good assessment of the matter by Dave Rutledge at Cal Tech, on Judith Curry’s blog: https://judithcurry.com/2014/04/22/coal-and-the-ipcc/

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43 Yulventis February 4, 2017 at 12:42 pm

Because producing usable and convenient energy has no net value?

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44 Borjigid February 4, 2017 at 3:46 pm

There are multiple ways to produce usable and convenient energy. For instance, natural gas.

The nice thing about natural gas compared to coal is that it is less harmful to air quality, water quality, the landscape, and the people who extract it. Why use coal and all its attendant costs when natural gas is available?

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45 msgkings February 4, 2017 at 4:43 pm

+1. Coal is doomed not due to Obama or Al Gore, but because of natural gas/fracking. In addition to the advantages you listed, it’s cheaper.

46 Alistair February 5, 2017 at 6:16 am

Actually, it justifies nailing the consultants who wrote this “cost-benefit” analysis to a wall, and then suing their company out of existence for gross professional malpractice.

It worked for Arthur Anderson. White collar idiots and frauds need to be called on their professional misdeeds.

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47 buddyglass February 4, 2017 at 11:19 am

I’m more upset about dumping pollution in streams than about emitting CO2. For that matter, I’m more upset about coal burning emitting non-CO2 pollutants and other particulate matter than I am the CO2. One doesn’t need to be overly concerned about global warming to oppose the dumping of pollutants into streams.

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48 TMC February 4, 2017 at 12:06 pm

I agree with you entirely, and presume there were not actual polluting activities considered or found. I’m sure they’d be added to the report if they were. Non-CO2 pollutants and other particulate matter is a good reason to cut down or eliminate coal use, but fake legislation is not the way to go about it. I’d rather see the industry continue clean up the process or then go out of business. I’m OK with taxing the externalities of coal, but scrubbers have done a lot of good in cleaning these up.

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49 Jan February 4, 2017 at 12:35 pm

I thought weird his assumption that defenders of the regulation would be solely focused on fighting coal in order to slow climate change, rather than on the main purpose of the rule, which is to prevent dumping pollution into clean water sources.

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50 TMC February 4, 2017 at 1:20 pm

I’m not sure he made that assumption. It may be the only benefit of the legislation.

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51 Turkey Vulture February 4, 2017 at 2:58 pm

I very much agree. I think the often single-minded focus on carbon emissions is a big mistake, and results in more popular opposition than would result from a focus on pollutants that cause a much more obvious and immediate harm.

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52 megamie February 4, 2017 at 11:33 am

The building I live in was built in 1912 and it has/had a coal chute; why did they close off that coal chute..why cant myself and the hundreds and hundreds of buildings around me no longer heat with coal??

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53 Jan February 4, 2017 at 12:36 pm

Burning coal is a very dirty business baby!

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54 spencer February 4, 2017 at 3:47 pm

Because oil, gas and electricity were cheaper and better.

Any questions?

Over about 30 to 40 years almost the entire country switch away from coal heat.

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55 Free the TrumpRolled! February 6, 2017 at 9:47 am

only yuppies can afford milk deliveries.

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56 Joan February 5, 2017 at 1:56 am

Because burning coal reduces the life expectancy of your neighbors.

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57 Harun February 4, 2017 at 11:41 am

Tyler sure flies a lot for someone concerned with carbon emissions. We should regulate his flying

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58 Free the TrumpRolled! February 6, 2017 at 9:58 am

the Golfing Burn burns all presidents.

we now also have the Inflated Trump Properties burn.

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59 Jon February 4, 2017 at 11:52 am

Interesting piece, but it’s getting a bit old to see you throw out the term “mood affiliation” to preemptively delegitimize the opposing view.

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60 Turkey Vulture February 4, 2017 at 3:01 pm

I wouldn’t mind it quite so much if Tyler would occasionally apply it to himself.

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61 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:19 pm

He just means partisanship, apparently. He made up a new name for it.

Of course one would only apply bad labels to the Out Group, not to oneself. Because each and every one of us knows that Ours Is the Only Virtuous Political Tribe. It’s just a given.

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62 Free the TrumpRolled! February 6, 2017 at 10:01 am

In 2019, Foxnews, Breitbart et al will replace “Alt Right” with “The Only Virtuous Political Baggers”.

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63 Bill February 4, 2017 at 11:54 am

If you read the Congressional Research Service summary you will see that Tyler committed the Environmental Human Health Benefits from his cost benefit analysis.

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64 Bill February 4, 2017 at 11:55 am

omitted rather than committed. damn that spell checker or is it spellchecker.

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65 TMC February 4, 2017 at 12:14 pm

Not Tyler, but the report omitted them :”However, because of data limitations, OSM was unable to quantify most categories of benefits or to reliably monetize any of benefits. Qualitatively, the agency projected that the proposed rule would have several types of benefits.”

Recreational, CO2 and drinking water benefits were listed, but unquantified because they probably don’t exist.

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66 Bill February 4, 2017 at 5:21 pm

No excuse in either case.

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67 Bill February 4, 2017 at 5:27 pm

By the way, TMC, your statement implies that CO2, drinking water were the only environmental and human health effects.

Not so.

From the report: “OSM was able to quantify benefits in terms of biophysical changes. For example, the agency projected that the proposed rule would improve water quality because fewer stream miles will be adversely affected (i.e., 4 stream miles will not be filled annually, 29 stream miles will be restored annually; 1 downstream stream mile that does not experience adverse water quality impacts will be preserved annually; and 292 downstream stream miles will be improved annually). Similarly, stream restoration and reforestation provisions of the proposal were estimated to result in 2,811 acres of forest improved annually and 20 acres of forest preserved annually.
However, because of data limitations, OSM was unable to quantify most categories of benefits or to reliably monetize any of benefits. Qualitatively, the agency projected that the proposed rule would have several types of benefits. OSM was able to quantify benefits in terms of biophysical changes. For example, the agency projected that the proposed rule would improve water quality because fewer stream miles will be adversely affected (i.e., 4 stream miles will not be filled annually, 29 stream miles will be restored annually; 1 downstream stream mile that does not experience adverse water quality impacts will be preserved annually; and 292 downstream stream miles will be improved annually). Similarly, stream restoration and reforestation provisions of the proposal were estimated to result in 2,811 acres of forest improved annually and 20 acres of forest preserved annually.
However, because of data limitations, OSM was unable to quantify most categories of benefits or to reliably monetize any of benefits. Qualitatively, the agency projected that the proposed rule would have several types of benefits. OSM was able to quantify benefits in terms of biophysical changes. For example, the agency projected that the proposed rule would improve water quality because fewer stream miles will be adversely affected (i.e., 4 stream miles will not be filled annually, 29 stream miles will be restored annually; 1 downstream stream mile that does not experience adverse water quality impacts will be preserved annually; and 292 downstream stream miles will be improved annually). Similarly, stream restoration and reforestation provisions of the proposal were estimated to result in 2,811 acres of forest improved annually and 20 acres of forest preserved annually.
However, because of data limitations, OSM was unable to quantify most categories of benefits or to reliably monetize any of benefits. Qualitatively, the agency projected that the proposed rule would have several types of benefits. Improved aesthetics may improve property values and the quality of recreational opportunities.
 Reforestation requirements and fill design changes will increase carbon storage and reduce emissions, thus reducing human health risks and climate-change related risks.
 Stream restoration and reforestation requirements will reduce human exposure to contaminants in drinking water and probability of adverse health effects.
 Improvements to water quality and forest and biological resources will result in potential for increased recreational opportunities.”

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68 Marcus February 4, 2017 at 11:55 am

Tyler, why do you find it reasonable to consider income guarantee but not reasonable to create jobs by regulating dirty industries? Talk about more affiliation, I can see high and most your regulars sputtering into your favorite signaling soup dish right now.

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69 Scott February 4, 2017 at 12:37 pm

I don’t think there is any inconsistency there. In doing the cost-benefit analysis for the regulation, the clean streams go in the benefits column and the regulatory jobs in the costs column. For the income guarantee, the good that people get from the income goes in the benefit column and the money we spend goes in the costs column (or the value of whatever was going to be done with the money).

(I think this also implies that the jobs lost from the regulation go in the benefits column, with some multiplier less than one, since some of the people will go on to do other beneficial jobs. I need to think more about that though.)

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70 Dzhaughn February 4, 2017 at 12:45 pm

Do try to keep up. (1) Income guarantees are interesting to the extent they are superior to other redistribution, anti-poverty, and “safety net” programs. (2) Jobs are a cost, not a benefit. Are four people looking at the same spreadsheet in the same way really twice as valuable as two people?

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71 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:24 pm

Jobs are a benefit, but you need to find something useful for the people to do, not just make work.

That’s the big problem with UBI– that people who don’t have work, on average, don’t feel good about life or themselves. Until/unless that changes, then a job will be better than an income for people who are capable of working.

That’s one reason Trump got elected. He promised people jobs, though he can not deliver on that. Hillary promised a better social safety net. A mistake. One should always promise voters an unrealistic and pleasant fantasy, if one wants their votes.

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72 Stormy Dragon February 4, 2017 at 11:56 am

I’m sure it would save nearby businesses a lot of money if, instead of paying for disposal, they could just dump their garbage on Tyler’s front lawn. Of course, they’re not allowed to do so because, as a property owner Tyler rightfully expects to have his property rights protected.

But thanks to the political clout of mining interests, property owners downstream from coal mines have no such expectation.

This is considered a win for “small government”.

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73 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:24 pm

Yes, that is what Libertarianism is all about, isn’t it?

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74 Rich Berger February 4, 2017 at 12:06 pm

Precision such as

” in summary, the Final Rule is expected to reduce employment by 124 jobs on average each year due to decreased coal mined while an additional 280 jobs will be created from increased compliance activity on average each year.”

is a delusion.

I recall that Ted Cruz asked some regulator (I think he was from the EPA) if he could give an example of a rule that was rejected on a cost/benefit basis, and he could not recall any. My impression is they give lip service to CBA (using made up numbers like the ones TC cited).

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75 chrisare February 4, 2017 at 12:08 pm

This and the immigration ban are just weak symbolic actions that satiate Trump’s base (at least temporarily) and drive the media and the left into a frenzy. Then he can go about doing things antithetical to why his base elected him like trying to overturn Dodd Frank.

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76 msgkings February 4, 2017 at 12:52 pm

Bingo

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77 TMC February 4, 2017 at 1:24 pm

These are kinda just showboating, but why is the repeal of Dodd-Frank antithetical? His stance on deregulation was widely known and supported.

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78 prior_test2 February 4, 2017 at 2:10 pm

Particularly by a number of Trump’s friends, as noted by the president – ‘We expect to be cutting a lot out of Dodd-Frank because, frankly, I have so many people, friends of mine, who have nice businesses who can’t borrow money. They just can’t get any money because the banks just won’t let them borrow, because of the rules and regulations in Dodd-Frank.’ http://thehill.com/policy/finance/317756-trump-says-business-friends-cant-get-loans-because-of-dodd-frank

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79 chrisare February 4, 2017 at 3:10 pm

Because this is the sort of deregulation that stands to help the elites at risk to Joe Sixpack.

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80 poorlando February 4, 2017 at 4:50 pm

If Dodd-Frank goes away, banks will lend again, businesses will be able to borrow, invest and make more products that they can sell, and the increased economic activity will lead to more jobs, thus *helping* Joe Sixpack.

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81 msgkings February 4, 2017 at 5:16 pm

Yeah Dodd-Frank was not a great piece of legislation. After the financial crisis they had to “do something” and that’s what resulted, a lot of regulation of things that mostly didn’t factor into the crisis. The best improvement to banks since the crisis has been the increase in capital requirements (less leverage) and the repeal of the mark to market rule in early 2009.

82 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:28 pm

Trump’s base elected him because he was a crude macho apparent billionaire apparent successful business man celebrity reality TV star. And he will still be that, no matter what fool things he does. He did act like he was the Savior to the working class and middle class. But people who voted for him are naive, and easily believe whatever Fox, Breitbart, and Drudge tell them. So they will likely believe whatever excuse he gives for not helping them in various ways. Maybe he will claim their continued problems are all Obama’s fault.

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83 Alain February 4, 2017 at 12:13 pm

Please post this on Bloomberg.

You can omit the fig leaf of your personal inclination.

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84 Ray Lopez February 4, 2017 at 12:14 pm

The post by TC was poorly written, you had to read this sentence half way through to understand TC was pro-coal and against the EPA rule: “Now, I know how this works.  Many of you probably are thinking that we need to do whatever is possible to attack or shrink the coal industry…”

As for the ‘cost-benefits’ analysis being wrong, I wonder if this is standard operating procedure, in that a ‘benefit’ is the jobs created by pollution reduction? Firstly, I don’t see why this benefit is wrong, perhaps TC can explain in a follow-up post? Certainly less water pollution in terms of less cancer is a benefit, but why are not jobs reducing pollution also a benefit? Why is that not unlike a doctor saving lives? Doesn’t a doctor’s efforts get included as a benefit rather than a cost in the GDP? More followup is needed. Maybe a guest post by Cass Sunstein! I rate TC’s post as a C+, with red ink saying “needs clarification”.

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85 Jonathan February 4, 2017 at 1:42 pm

You don’t understand that jobs are costs, not benefits? Suppose we didn’t call them “jobs” but called them “checks sent out.” Then do they seem like costs? Or let’s try it another way: we want to get rid of a pile of manure. We can build a big manure-processing facility staffed by robots that costs, say, $10,000. Or, we can pay 50,000 people with shovels $1,000 each to take the pile away. Between these two proposals, one has costs of $10,000 and the other has the benefit of 50,000 jobs. Both have the benefit of the lower manure pile. So go with the one with the better benefits? Especially since it has no costs!

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86 Tununak February 4, 2017 at 2:24 pm

What’s the value of a job to a coal miner? Is it all monetary, or are there intrinsic benefits, like having pride in yourself and a reason to get up in the morning? Not getting on meth because there is no other point to your life? If you count all of the people who have dropped out of the workforce, and all the ways that that is a cost to society, the simple statement that “jobs are costs, not benefits” starts to sound ridiculous. This is another thing that got Trump elected: he understands that jobs have intrinsic value. Coal has a place in the economy, otherwise no one would be buying it. Shutting it down entirely for virtue signalling is unwise from many perspectives but easy to do if you live in DC.

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87 Mondfledermaus February 4, 2017 at 3:05 pm

One man’s job is another man’s inefficiency. That’s why I find that “Job Creators” title so ridiculous. You hire someone when you can no longer avoid it, the better paid the job, the more reluctant the businessman will be fill it and automation or contracting will be considered first.

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88 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:31 pm

Of course labor is a cost to the employer. But to the citizenry, jobs are a benefit that they vote for, when it’s offered. And they voted for Trump to bring coal mining jobs back, thought he likely can’t deliver much there.

89 Free the TrumpRolled! February 6, 2017 at 9:04 am

Employees are “Profit Creators”

Customers are “Business Creators”

Conservatives are Slavery Creators

90 Ray Lopez February 4, 2017 at 8:44 pm

@Jonathan – As implied by Danno755, the secret is to read on Bastiat’s glazier’s fallacy, see: https://en.wikipedia.org/wiki/Parable_of_the_broken_window

My point is that the costs and benefits of pollution ablation have to be thought out a bit more, and I was not clear about how costs are calculated (apparently they do not, unlike what you suggest Jonathan, count jobs as costs, as you define them, but as benefits).

So here is my calculation:

1) costs: money spent to control the pollution

2) benefits: putting some old coal miners to work as pollution control experts (some fudge factor for this can be deduced, or the taxes on their salaries can be counted), reducing pollution, decreasing cancer and increasing life expectancy, and some arbitrary fudge factor for other positive externalities.

If benefits – costs > 0 then proceed with the program. If not, either don’t proceed or do some manipulation such as moving costs into benefits until Big Coal gets its comeuppance and the anti-coal law is passed.

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91 Danno755 February 4, 2017 at 2:23 pm
92 rayward February 4, 2017 at 12:18 pm

Of course, it’s not just coal that is fouling our streams and the fish and other wildlife that depend on them. No, another culprit, a more widespread culprit, is sewage, sewage that migrates from septic tanks to our streams and aquifer, sewage dumped into streams and rivers in the rainy season when the alternative is sewage backing up in peoples’ homes because of inadequate treatment facilities. Cowen’s cost-benefit analysis is what’s expected from an economist, an economist who likely hasn’t set foot in a stream, wet a line in a stream, in his life. But that’s beside the point. Coal is dirty business and everyone knows it. Sewage, on the other hand, is even dirtier, the difference being that it’s the silent killer, that everyone produces and insists on flushing down the drain and into the streams, oblivious to the damage being done to our streams and the wildlife that depend on them.

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93 chip February 4, 2017 at 12:56 pm

Victoria, BC, dumps over 100 million liters of untreated sewage into the sea, much to the ire of its American neighbors.

In the last federal election, 75% of Victoria residents voted for the socialist and green parties, both of which place climate change at the top of their agendas.

Environmentalists understand cost benefit analysis as well as anyone. They’re just inherently selfish in demanding those costs are applied to others.

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94 Alain February 4, 2017 at 2:15 pm

“Environmentalists understand cost benefit analysis as well as anyone. They’re just inherently selfish in demanding those costs are applied to others.”

+100

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95 Edward Burke February 4, 2017 at 2:34 pm

Naomi Klein, call your airline booking agent for your next bookstore barnstorming tour.

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96 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:32 pm

Yeah, they are demanding that companies that make a mess should clean it up. How presumptuous of them, huh?

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97 Free the TrumpRolled! February 6, 2017 at 9:14 am

A carbon tax assigns commerce system costs to the carbon source.

Conservatives apply costs in a manner that creates victims, also distorting commerce.

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98 Meets February 4, 2017 at 12:43 pm

The left tends to underrate the harmful effects of bad regulations.

Why would you need 280 bureaucratic jobs to regulate coal when coal is banned?

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99 Dzhaughn February 4, 2017 at 12:48 pm

To regulate the police that quell the riot?

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100 Free the TrumpRolled! February 6, 2017 at 9:23 am

Dead and disabled coal country residents don’t “riot”.

Dead victims don’t vote.

Dead victims don’t give testimony.

From conservative perspective, eliminating resistance is the “silver lining” of the “silver cloud” of conservative policies.

Arbeit Macht Frei.”

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101 reed E Hundt February 4, 2017 at 12:52 pm

What have you accomplished with all this parsing? You’ve ended up defending pollution. Good use of time?

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102 prior_test2 February 4, 2017 at 1:10 pm

Well that pollution occurs ‘almost entirely in underpopulated parts of the country,’ so really, who should care? Certainly not Prof. Cowen.

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103 Alain February 4, 2017 at 6:03 pm

We’re all really happy to have you around to tell us what to do. Please, continue.

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104 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:33 pm

Aren’t Libertarians all very much in favor of pollution? I thought that was what Libertarianism was about– defense of the “rights” of the .01% to pollute the environment and to make people sick or kill them.

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105 James Crimmins February 4, 2017 at 1:12 pm

What about the water? Living is the real issue. Not jobs. Not economics. Not politics. Dumping stuff in the water is what has caused many of the nation’s health problems. Think life not bottom lines.

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106 Li Zhi February 4, 2017 at 1:19 pm

280 people for 262 miles of stream? That’s gotta be a typo – or am I just misunderstanding? Cue giant sucking sound…

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107 Rob February 4, 2017 at 2:06 pm

Ok, so we now know the cost of the legislation is hard to determine.

But anything on the economic impact from the pollution itself? Health care/ higher costs to source fresh water for residents etc

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108 Turkey Vulture February 4, 2017 at 2:52 pm

When you don’t allow countervailing tarriffs to make it as-if foreign production was subject to US environmental regulation, you move the political incentives towards eliminating US environmental regulations in order for US production to be more competitive.

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109 Pipsterate February 4, 2017 at 3:03 pm

I mostly care about the water quality in this situation, not the jobs created/destroyed or the impact on the atmosphere.

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110 jbsay February 4, 2017 at 7:04 pm

If we improve water quality by a factor of 50 and decrease standard of living and therefore life expectance and myriads of other quality of life issues by a factor of 2 (or .2) would you be satisfied ?

All improvements in things like water quality are apid from from our standard of living.
They are net gains when WE chose them – as people did on their own when they shifted from coal to oil and gas at additional cost a century ago.
They are by definition net losses when we do not chose them and government choses them for us – because if they really were of value – we would have voluntarily chosen them.

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111 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:38 pm

Yeah, everybody always carefully decides how to spend their every penny, on the basis of complex analyses of the pollution caused by the types of fuel they might use. No one ever experiences pollution or sickness or any other problems, because they always choose the things that are of value and do not choose the things that are unpleasant. And the choices are always the individual’s to make, since we all have complete control over, and knowledge about, our environments.

Is this world part of the Libertarian ideology? What planet is this world on?

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112 Dallas Weaver Ph.D. February 4, 2017 at 3:20 pm

Getting into the details of these regulatory issues is where the devil lives. Little falsehoods like calling regulatory employment increase a benefit and not a cost start to add up.

This type of report to justify regulations using an outside contractor and publishing the results in the gray literature (not like a scientific journal with outside reviewers) is standard. Having been a consultant doing this type of report (decades ago), I made the mistake of not giving the EPA the answer they wanted (the problem was only relevant for net precipitation areas of the country — a non-issue in the SW deserts) and showed that their concept of the problem missed the big environmental risk of killing everything from the site to the mouth of the Mississippi River upon failure. I also proved that their 3 million dollar study could be reproduced based upon sampling methods independent of the properties of the actual samples (ie pure nonsense). The outcome was that EPA in DC wouldn’t publish the report and the contracting officer for EPA had to spend years getting it published by another agency. The other outcome was that I was never a PI on an EPA contract again: I didn’t give the right answers.

Not being an economist, but knowing a lot about the environment, I went to the sections of the report that I know something about. Of course, that led to Selenium pollution along with suspended solids and other water pollution issues. These are areas I have spent a career working on and actually cleaning up.

When looking at selenium (one of those elements where if you don’t have enough, you die and if you have too much it is toxic: used in critical enzymes), the impact depends on magnification up the food chain. Some plants appear to use selenium to poison those that want to eat them with very high magnifications so its behavior in the environment is complex, to say the least. The EPA drinking water standard uses 50 µg/l, but the environmental standard is apparently 5 µg/l for mine discharges. On this issue, I went to their references (another government study/report) where they did some decent ecological modeling work. However, going deeper using scholar.google.com combined with getting past some pay walls (do a lot of reviewing for journals which provide pay wall permissions) I found that their primary source variable was Suspended Solids (SS) that is really composed of inorganic materials (mud, clay, silt, etc. and elemental Se) and organic materials (decaying leaves, detritus, etc.) that concentrate Se from the water by a factor in 2000 range. When one of their other issues was SS from the mine waste which is inorganic, not organic. Couldn’t find data on the uptake by the food chain of the Se nanoparticles produced under anaerobic conditions by bacteria. However, when going over the details of the mathematics in the models, spearating SS into components wouldn’t make any real difference. With SS being so dominant, the water concentration becomes somewhat irrelevant.

Selenium is one of the trace elements often requiring an addition to fish feeds (especially vegetarian diets), but we do have good data showing that very high levels are highly toxic and you can get high levels from coal ash. This is a very site-specific issue and a general rule won’t work. The rock being dumped may or may not have selenium that may or may not become mobilized that may or may not move up the food chain or became trapped in the sediments. Some of the scientific literature prefers Hydrolic Units (local drainage basins) as individual identies.

From looking at the details, this one appears sightly more scientifically solid, if incomplete in the Models, with the main fault in applying a general solution to a specific problem requiring a specific solution. How including an insignificant case in the projects killed by this regulation is factored in is for the economists.

I have really seen a lot worse “junk science” in regulations.

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113 Houtx February 4, 2017 at 3:36 pm

I would point out that the stream miles figure is per year. That may account for why you sense media reports are exaggerating. I think it’s fair to take a multi year view when looking at that statistic. 2k miles per decade. That is both real (according to the study) and meaningful.

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114 jbsay February 4, 2017 at 6:56 pm

If true that is just another problem with such a report.

There is no way such a value would be linear over time.
If it was 200miles the first year – it probably is not 500 miles the first decade and probably not more than 500 miles forever.

It is fari to take a multi-year approach – but the real problem is that the entirety of this is not far from made up.

If we took every aspect of these studies and tracked realistic values for error through them, the results woul all be orders of magnitude below the error bars.

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115 Houtx February 5, 2017 at 8:40 am

I’ll grant that there may be false precision but there are two facts that need to be balanced (the targeted activities change streams and make coal mining more expensive). Just because you may not know the precise answer doesn’t mean you should avoid trying to figure it out I am reassured that, with all its flaws, this type analysis guides our rule making vs just going by our collective gut or opinion.
I think reasonable people will agree with you: we should do reviews of regulations to see if our a priori analyses held up and if stuff needs to be tweaked or adjusted. It’s also dangerous to assume that regulations are good or bad.
I would love to hear an expert’s critique of this document’s science and analysis. So far I have only seen reasonable and unreasonable comments from non experts such as myself and TC. I’m inclined to trust experts because they know more than I. I know others will fundamentally distrust experts and assume they are wrong. One of those two tendencies is more dangerous than the others, and I think is a more interesting way to define the electorate than left right.

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116 Anonymous February 4, 2017 at 3:56 pm

It helps to have some experience in reading RIAs.

1) Not every regulation must pass a strict cost-benefit test. The reason for this is that we don’t have monetization of a large number of benefits. Many rules have sufficient monetized benefits to directly pass a cost-benefit test, but for many others, the information is simply unavailable. (And that’s not even getting into the question of whether or not you use willingness to pay, etc, to quantify benefits….) In those cases, a judgment call must be made. That said, read section 7 for a description of the health benefits.

2) Yes, everyone knows that jobs are a “cost” from an economics point of view. Try telling that to congress. In fact, there are often mandates to do employment analyses as part of an RIA. These are not included in the quantified cost-benefit analysis (at least in the rules I’m aware of) because it’s just too difficult to make sense of. For example, in the most naive economic models, the net employment impact will always be zero. There are plenty of IO-type analyses of direct and indirect jobs, but the flaws in those analyses are also well-known.

3) The Social Cost of Carbon is a marginal quantity. Please look it up. See, for example, https://www.epa.gov/climatechange/social-cost-carbon before it disappears.

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117 jbsay February 4, 2017 at 6:49 pm

And how many of these have been thoroughly studied AFTER the fact to assess how accurate they were.

I am sorry – with all respect to the people involved in these.
I do not beleive that regulators and economists have the knowledge and skill necescary to do this.

With respect to 1).

Bunk. If the benefits of a regulation are so substiantially net positive – there would never be any need for the regulation.
Even if the actions cost the producer more – the product would be far more appealing to consumers.

Regulation exists for arguably one of two reasons.

1) because the costs exceed the benefits, but the benefit politically appeals to some group or interest.

2). because the costs are very direct and the benefits so difuse that this will never happen on its own.

Further I am not so sure that 2 is even real. Diffuse indirect benefits are guesses, ideology, wishful thinking or statistical gamesmanship. Regardless, there is no reason to trust anyone’s predictions.

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118 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:42 pm

The costs of the coal companies cleaning up their own mess, so that they do not make people sick with pollution, are indeed greater than the benefits to those companies. But you have to be a rich coal company to get away with this. If you disagree, try canceling your garbage service and just dumping your garbage in the middle of the street from now on.

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119 Anonymous February 4, 2017 at 11:07 pm

This is an environmental regulation. Please look up the concept of an externality.

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120 jbsay February 4, 2017 at 6:52 pm

2). Jobs are not a cost “from an economics point of view” they are just a cost.
Standard of living is increased when the value produced increased and the human resources to produce it decrease.

That politicians have inverted this does not alter the fact that it is stupid.

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121 jbsay February 4, 2017 at 6:33 pm

The observation at the end seems to fit Trump so far nearly perfectly.

He is mostly doing what are really relatively small things that appear to keep campaign promises.
And the left is playing into his hands perfectly by jumping up and down and shouting “end of the world” which makes them look far bigger then they are.

And even the few on his side that grasp this – still smile, because he has the left absolutely appoplectic.
And frankly I think he loves that.
This could be a very unusual presidency. Trump seems to thrive on being attacked by the left and the media.
And they are doing their best to give him exactly what he wants.

I personally disagree with many things he has done. But none are consequential – if they are not signals of much much larger efforts at the same.

So he is building a wall. It is practically criminal that I am saying this – but what is $8B in a 4T budget – small change.

I am sorry for the couple of hundred people screwed up by his imigration order.
Personally I support near perfectly open borders – even if that means more terrorism.
I am trying to figure out as a libertarian whether that is a choice I can impose on others, and I am not so sure.

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122 Mine Is the Only Virtuous Political Tribe February 4, 2017 at 7:44 pm

The things he is doing are not minor. He’ll have some sections of the country breathing air they can see, like in big Chinese cities. And the hospitals filled with kids with respiratory disorders.

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123 Yancey Ward February 5, 2017 at 2:23 am

No he won’t. The internment camps for the anti-Trump city dwellers will be out in the country where the air is clean. Watch and learn.

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124 jbsay February 4, 2017 at 6:41 pm

Why is it that we beleive these types of studies ?

I am sure they are done by decent and honest people – though I truly doubt they were able to keep their own biases out.

Regardless, this is not all easy to do. Frankly I do not think it is possible to do.
I kind of want anyone who thinks otherwise to read through “I, Pencil”
a couple more times.
Though I beleive Paul Romer had an interesting paper that essentially said – enough simulataneous equations and coeficients and you can always make a model that tracks reality for the moment and predicts anything you want.
Worse still you can easily do so without consciously trying.

And that argument goes to the core of the entire regulatory state.

I do not think these types of reports are meaningful.
To much complexity.

We handle these problems in markets – not because markets get things right first time.
Not because people in markets are smarter. but because whatever is done nearly automatically triggers reactions throughout the marketplace – and if those reactions are not what we expect – the market will quickly act differently.
Regaulations do not work that way/ There is no feedback loop

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125 The Free Market Is Not God February 4, 2017 at 7:45 pm

LOL, markets get things right the first time. That’s why no one ever gets sick from pollution, no matter how unregulated it is.

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126 Dallas Weaver Ph.D. February 6, 2017 at 11:22 am

I agree with the modeling mathematics. Given enough arbitrary parameters, you can model anything and get any result you desire.

The bias problem is even more significant when the “consultant” doing the report or study for the agency depends upon future contracts for similar studies to survive as an institution.

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127 jorod February 4, 2017 at 6:55 pm

Some day technology will end the need for fossil fuels. Until then, we are stuck with current technology. BEW, Obama and Dick Durbin cut a deal with BP to go on polluting Lake Michigan.

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128 The Free Market Is Not God February 4, 2017 at 7:45 pm

No matter who does a thing like that, it’s wrong.

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129 Hopaulius February 4, 2017 at 9:22 pm

One wonders whether the color of coal has anything to do with the imperative that it be suppressed. Or is it the color of the miners that is determinative?

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130 Mark February 5, 2017 at 4:33 am

“Whether you like it or not, the coal debate is not really one that favors the Democrats.”

I’m sorry, what?

The Republican argument is we should have more coal (which is more expensive than natural gas and more polluting than everything). That’s more health care costs for everyone. More carbon mitigation for everyone. More pollution mitigation for everyone. Higher prices for everyone.

And we should explore “clean coal” to make the coal even more expensive.

And by the way, in the free market this industry is dying already.

But by all means, this isn’t a winner for the Democrats.

LOL.

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131 The Other Jim February 5, 2017 at 9:13 am

Right. These measures for so important for clean water that Former President Obama waited til the last 15 minutes of his administration to implement them.

No.

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132 kb February 6, 2017 at 2:08 am

Oh Jeezus. You’ve never operated under a deadline?

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133 TMC February 6, 2017 at 11:02 am

Got 8 years to do something, and wait for the last day. Obama wasn’t exactly a busy guy those last 8 years. If it wasn’t something completely stupid and he didn’t want to take the heat for it, he’d have done it way before this.

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134 Boonton February 5, 2017 at 10:36 am

Pulled out these numbers a while ago, they are directionally accurate:

1979 about 200K coal mining jobs
1990 about 100K coal mining jobs
2015 or so about 97K coal mining jobs

observations:
1. Reagan was the era of economic genocide of coal miners, about 1 in 2 didn’t have a job in coal mining by the end of the era.
2. Since then coal mining has been pretty steady.
3. Coal mining is not a serious source of jobs. In comparison there’s maybe 100K dog groomers in the US. You won’t see many business reports about the plight of dog groomers. You won’t see NPR profiling dog groomer culture or wondering if dog groomers are ‘understood’ by Democrats or Republicans.

The 114 versus 280 jobs is essentially statistical noise. Reality is we’d have cleaner streams with almost no cost. When you’re dealing with a base of 97K or 100K trying to measure 100 or 200 jobs up or down is like asking how much the sea level will rise in Miami if everyone in France pisses into the ocean on their holiday.

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135 kb February 6, 2017 at 2:06 am

I work on studies like this. It would be wonderful if the funders (agencies, industry, whoever) knew enough to allocate sufficient funds for an appropriate level of peer review or even an adversarial critique/synthesis, but in 16 years, I have yet to see that happen. You could oppose that on the grounds that you’re spending too much on analysis, but in regulatory processes like this, there’s money to go around, but it’s usually directed by big engineering firms that view the economics as a throwaway piece.

My approach, which sounds like it is not shared by the authors of the report under discussion here, is to presume the benefits are lower than you think (round down, if you have multiple valuations emphasize the lower value, etc.) and to find as much as you can about as-built costs. I don’t even bother with multipliers and jobs because they can be used to support any position under the sun. For those parts, if I can I usually drop in Econ 101 boilerplate and let the reader come to their own conclusion, which they are likely to do anyway.

To some extent you can formalize your assumptions, but in a sense it’s like a property appraisal. I would almost be embarrassed to admit all this, but reading contemporary econ literature, I see plenty of PhD-level work that fails to survive contact with the real world.

One issue I have with Tyler’s comment is with the impacts on streams in “underpopulated” areas. Stream ecology is a fascinating subject. Little streams turn into larger streams. Biological activity in headwater reaches has profound effects on river systems. Even an ephemeral stream has effects on the ones we “officially” care about. Modest reductions in biomass inputs to first-order streams can cause huge impairment of biological activity, with detrimental effects hundreds of miles downstream. Mining activities can affect this activity as well, and with cumulative effects from multiple waterways, climate variability, and the eventual human influence in populated areas, you can run into serious problems.

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136 Free the TrumpRolled! February 6, 2017 at 2:14 am

You won’t see many business reports about the plight
You don’t see genuine business attention to the plight/interests of any employees. When you see concern trolling, it is boilerplate chamber of commerce sly victim-blaming.

of dog groomers
Dog groomers don’t live in “mono industry” locales

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137 Boonton February 6, 2017 at 5:51 am

Why is that a plus about coal miners? That many live in ‘mono industry’ locals often with a single employer, no opportunity to ever own the business yourself…these are all things that make a job bad rather than good.

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138 Free the TrumpRolled! February 7, 2017 at 5:47 pm

many live in ‘mono industry’ locals often with a single employer.. make a job bad [worse] rather than good.
yes, my point

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139 Chris February 6, 2017 at 10:35 am

So we have to ruin two miles of stream for every job saved? That seems reasonable? And why does it matter that it’s unpopulated? Can’t I derive some utility in knowing that a few wild places survive in the east?

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140 Annoyed in Illinois February 7, 2017 at 12:58 pm

Well, this seems to be an all-time low for you. Maybe you can answer a few things:

-What coal company pollution will end up in streams from repeal of this?

-How many active mountain top removal coal mines are in production right now?

-Why was Bob Murray so upset about this agency rule tweak while Peabody, Arch, Alliance, CNX, Warren Buffett and every other owner of longwall mining operations were quiet?

Ultimately, if you look closely at the Office of Surface Mines revision to the Surface Mine Reclamation Act of 1977, the wording on the mine depths was so refined that the only mines in the country it would have any bearing on are Bob Murray’s underground mines.

Yes, Bob Murray is a total nut job and poked the bear by repeatedly suing Obama and the EPA. Leftists wanted retribution and tweaked a rule to attack Bob Murray and put him out of business. The issue is this obscure agency is the Office of Surface Mines. Bob Murray doesn’t even operate a surface mine.
And yes, Bob Murray was an early supporter of Trump and is always a donor to Republicans – rightfully so, since Congress is protecting him from retaliatory agencies.

If OSM truly wanted to cut our nation’s coal supply, they would put the screws down on self-bonding – because that has no reason to exist. Of course, the goal isn’t to further put our electricity fuel supply at risk, but rater political payback to put Bob Murray out of business.

More disturbing is how casually you mention your inclination is to fight a war on coal in the same fashion you would ask for recommendations for southwestern Nepalese restaurants in Dubuque.

Go on the websites for MISO, PJM Interconnent, SWPP, or any of the “fly over” ISO’s. Coal is the dominant fuel supply for us moon-faced mouth-breathers and slack-jawed yokels in the middle.

Pay attention to where you are on a cold day. Natural gas is almost totally consumed by furnaces for heating. What keeps your lights on in the southeast?

Aside from electricity generation, how many blast furnaces on the planet operate without coal? How much cement is made without coal in the kilns? How much metal is separated from ore without coal?

I’m sure you aware of how much value and wealth coal has created for man throughout history, but are you aware how much it is in everything you touch on a daily basis?

My guess is that your war on coal advocacy is more akin to a “let them eat cake” statement rather than the group of eugensists that want to turn back the clock on the industrial revolution.

Either way, I have been trying to understand the anger at the supposed elites that brought a Donald Trump to the presidency, and I certainly feel it now.

Boiling something down to “economic benefit” is kind of hard when you don’t have lights on or shelter over your head. Maybe you can assume a new totally new fuel? Maybe you can assume renewable energy storage? Maybe the tooth fairy will make your assumptions real?

The 100K or so jobs of coal miners bring far more value to our society than nearly everybody else but farmer and the good people at the water utilities. The rest of us are just consumers.

Finally, Europe’s industrial revolution population boom was a result of coal. With your last name Cowen, I’d wager you owe your very existence on this planet to that coal fueled population growth.

We are much more likely to capture and use CO2 emissions from coal stacks (just like fly ash and sulfur) than we are to do without the fuel.

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