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Thursday April 2, 2009

 

Supreme Court Ruling Allows EPA to Base Decisions on Cost-Benefit Analysis

By Larry West

 

On April 1, 2009, the U.S. Supreme Court ruled that the Environmental Protection Agency can weigh the benefits of protecting billions of fish against the cost of requiring aging power plants to upgrade their cooling systems to use recycled water instead of drawing water directly from rivers and streams.

 

In a 6-3 decision, the Supreme Court ruled that the Clean Water Act gives the EPA authority to use cost-benefit analyses as the basis for such decisions, but the Court stopped short of saying the EPA was required to base its decisions on a cost-benefit analysis.

 

What’s at Stake?

 

The EPA was planning to require more than 500 older power plants to upgrade their systems that use water to cool machinery before the lawsuits began. The water intake systems used by older power plants kill an estimated 3.4 billion fish and shellfish every year. Such power plants draw 214 billion gallons of water from U.S. waterways every day. Billions of fish and other aquatic creatures are sucked into the cooling systems or crushed against intake screens and killed.

 

The closed-cycle cooling systems used by newer plants reduce the death rate by 98 percent, but installing closed-cycle systems in older power plants would cost $3.5 billion annually. Alternative technology could reduce the number of fish killed by 80 percent to 95 percent, according to the EPA, and would cost roughly one-tenth as much to install.

 

Installing closed-cycle cooling systems at older power plants might also force electricity costs to rise by 2.4 percent to 5.3 percent, the EPA said. Closed-cycle systems would reduce the amount of electricity the power plants generate, and would require utilities to build 20 new 400-megawatt power plants to replace the lost electricity. Installation and construction of the new cooling systems could also force some plants to close down for a few months, resulting in even more costs.

 

What’s the Background?

 

The Supreme Court decision overruled an earlier decision by the 2nd U.S. Circuit Court of Appeals in New York, which ruled that the Clean Water Act does not allow cost to be used when deciding what technology would best minimize environmental impacts. The Clean Water Act requires remedies that "reflect the best technology available for minimizing adverse environmental impact."

 

The three dissenting Supreme Court justices—John Paul Stevens, Ruth Bader Ginsburg, and David Souter—argued that, in passing the Clean Water Act, Congress never intended for agencies to base their decisions on cost-benefit analyses because its members understood that it is nearly impossible to put a dollar value on the loss of wildlife.

 

What’s the Problem?

 

And that’s the primary problem most environmentalists have with the notion of using cost-benefit analyses to make conservation decisions—it’s difficult to find a valuation method that everyone can agree on, or that even makes sense.

 

In the current case, the EPA analysis placed a value of $83 million per year on the fish that would be saved by installing close-cycle cooling systems at older power plants. But that number only takes into account the value of fish that are caught by either sport or commercial fishermen—less than 2 percent of all the fish currently killed by water-intake systems. The EPA assigned no value at all to more than 98 percent of the fish, shellfish and other aquatic life killed by power plants each year.

 

My Take on the Issue

 

Don’t get me wrong. Balancing the needs of business and consumers with what it takes to protect and preserve the natural environment is essential. We are, after all, part of the environment we are trying to manage. Yet, in failing to address the value of a living resource, and the benefit of conserving it, both the EPA and the Supreme Court have clearly demonstrated the shortcomings of the agency’s current cost-benefit method and its application to important environmental decisions.

 

By clearing the way for the EPA to base critical decisions on a flawed method, with no mandate for the agency to first improve its cost-benefit calculations, the Supreme Court may have inadvertently laid the groundwork for a series of short-sighted environmental decisions with no long-term benefits for anyone.