For years, the Environmental Protection Agency has assigned a dollar value to the lives saved and the health problems avoided through many of its environmental regulations.
Now, that has changed. The EPA will no longer consider the economic cost of harm to human health from fine particles and ozone, two air pollutants that are known to affect human health. The change was written into a new rule recently published by the agency. It weakened air pollution rules on power plant turbines that burn fossil fuels, which are sources of air pollution of many types, including from fine particles, sometimes called soot.
The EPA writes in its regulatory impact analysis for the new rule that, for now, the agency will not consider the dollar value of health benefits from its regulations on fine particles and ozone because there is too much uncertainty in estimates of those economic impacts.
EPA press secretary Brigit Hirsch clarified that the agency is still considering health benefits. But it will not assign a dollar amount to those benefits until further notice, as it reconsiders the way it assesses those numbers.
Health experts worry that the move could lead to rollbacks of air pollution rules, which could result in rising pollution levels, leading to more health risks for millions of Americans.
"I'm worried about what this could mean for health," says Mary Rice, a pulmonologist and air pollution expert at Harvard University and the director of Harvard's Center for Climate Health and the Global Environment. "Especially for people with chronic respiratory illnesses like asthma and COPD, for kids whose lungs are still developing, and for older people, who are especially susceptible to the harmful effects of air pollution on the heart, lungs and the brain."
Fine particles, known as PM2.5, come from a variety of sources, including power plants that burn fossil fuels like coal and gas. Long-term exposure to fine particle pollution is known to cause significant health risks, from higher rates of asthma to more heart attacks to dementia, and even premature death. Cleaning up pollution from fine particles has, by the agency's previous estimates, saved more than 230,000 lives and billions of dollars per year in recent years.
The policy shift could facilitate further rollback of air pollution regulations, says NYU environmental law expert Richard Revesz. The economic costs to industry of implementing air regulations are still quantified, at least in the new rule. But if the benefits aren't assigned a similarly concrete dollar amount, he says, it is easier to ignore them. "It looks good only because you ignore the main consequence of the rollback, which is the additional negative impact on public health," he says. "By just saying we are assuming no harm doesn't mean there is no harm."
The health costs of air pollution
Decades of research have shown that exposure to pollution, such as fine particles, damages people's health. The landmark Harvard University Six Cities study, which ran from the 1970s until the 1990s, showed unambiguously that living in more polluted areas shortened people's lives. Since then, hundreds of research analyses — including many produced by EPA scientists — have linked risks to people's lungs, hearts, and brains with fine particle pollution. And reducing that pollution can have near-instantaneous health benefits: After the closure of a polluting coke plant in Pennsylvania, for example, cardiovascular and respiratory problems dropped dramatically in the surrounding population.
A 1981 executive order from President Ronald Reagan required agencies like the EPA to consider the costs and benefits of major regulations such as the Clean Air Act. So alongside evolving evidence about the health risks of exposure to air pollution, the EPA began to figure out how to assess both.
The cost estimates were relatively straightforward: What would it cost industry to upgrade their equipment and processes to comply with a rule? The benefits were slightly trickier. The agency developed sophisticated ways to estimate how many lives would be saved and health problems avoided from lower pollution, driven by tighter regulations. The EPA also developed economic models that could estimate how much money such changes would save the American people.
Most estimates routinely came up with high economic benefit-to-cost ratios, says Rice, the Harvard pulmonologist. "The Clean Air Act is often cited as having benefit-cost ratios of upward of 30 to 1," she says. "The economic return is so great that even small reductions in pollution, across millions of people, translate into very large savings."
A 2014 U.S. Supreme Court case clarified that agencies like the EPA had to take both benefits and costs into account in their regulatory processes. But the courts have "not waded into the question of how exactly [EPA] should do that," says Jeffrey Holmstead, an EPA expert and lawyer at Bracewell, LLC and former leader of the EPA's Office of Air and Radiation during the George W. Bush administration. "So, yes, they do have to consider both, but there is no legally enforceable requirement for them to do it in any particular way," he says. That leaves it up to the agency's discretion, Holmstead says, whether to forgo an economic benefits calculation, as long as the EPA still assesses the health benefits in some way.
Other EPA regulations, he says, assess the health benefits without assigning a specific dollar value, like some of the rules concerning hazardous air pollutants, which are associated with significant but more uncertain health risks.
However, "you can't do a sophisticated cost-benefit analysis without trying to monetize both the costs and the benefits," Holmstead says. "This will be the first time in a long time that EPA hasn't tried to provide a monetary benefit to reducing at least PM 2.5 and ozone."
The move to not consider economic benefits marks a major policy change, says NYU legal expert Revesz. "It's extraordinarily unusual," he says.
Not just air pollution
Revesz points out that under the Trump administration, the EPA has made moves to reconsider the economic benefits of regulations in other areas, as well.
In its proposal to roll back vehicle emissions standards, for example, the EPA did not assess the potential economic benefits to consumers who switched to electric vehicles instead of choosing gas-powered cars. It also explicitly declined to calculate societal economic benefits of reducing greenhouse gas emissions, and significantly lowered the estimates of the health savings from tighter rules. The EPA did the same in its efforts to roll back the endangerment finding, which has been in place since 2009. That finding concludes that the buildup of greenhouse gases in the atmosphere poses serious risks to public health and well-being.
Revesz says that makes three ways the EPA used to consider economic benefits to Americans from regulations. And now the "EPA has said that it's going to ignore all three of them," he says.
EPA administrator Lee Zeldin wrote in a 2025 statement that his priorities at the agency were to "lower the cost of buying a car, heating a home and running a business."
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