Surprise! Scott Pruitt’s EPA Uses Bad Economics on the Clean Water Rule


In the Aftertime, when our descendants are fighting over the last scraps of arable land, this fucking Okie hump is going to be one of history’s primary villains.

Scott Pruitt is not an honest man. He has one core belief–that extraction industries (and really any industry) should be able to do whatever they want to maximize profits. His ancillary beliefs–that there should be no regulations, that labor or environmental protections are evil, that climate change is a hoax, that we the poor and undeserving should choke on the ashes of capitalism–all flow from that.

All of his dishonesty and petty idiocy come from this. He’s an industry shill who literally copy-and-pasted comments extraction flacks wrote for him about EPA regulations he was fighting (before he was put in charge of the damn thing). He forces his department to self-censor the truth or lose their jobs (many choose the later). He replaces scientists with industry goons. He’s says it is “insensitive” to talk about climate change being a cause of more powerful and destructive because he knows it is inarguable, and so hides behind a veneer of compassion for environmental victims his whole career proves a lie.

He’s one of the primary disasters of the Trump regime, coming in close behind or ahead of Sessions, depending on where you stand on things. I’ll consider them tied. It flows from the top, of course. Just like in Pruitt’s EPA, dishonesty has begun to affect the noble institution with every one of his idiotic appointments.

We can see that inherent dishonesty in a recent review of the Clean Water Rule of 2015 (this is also known as Waters of the United States Act, or just WOTUS). The administration has been trying to overturn these regulations, which changed what water could be regulated by the federal government. The definition was expanded to include many irrigation channels and small streams.

To many, this was big government intrusion at its worst. And to be fair, I find that argument sympathetic. Irrigation channels often run on private land. The problem, of course, is that they don’t end there. Water seeps into aquifers or it runs rivulets of phosphate into lakes, creating murderous algae blooms, or it is just wasted. But, more regulations could be onerous to farmers, who already eke out a meager existence.

Who was on their side? Well, nearly everyone.

President Donald Trump made repeated campaign promises to repeal WOTUS, which is opposed by a variety of industrial sectors, including agriculture, iron and steel manufacturing, home builders, and mining groups. Industry associations representing those sectors argue it would trigger requirements to obtain costly federal permits to dredge wetlands and streams that they say fall under state and local laws already.

Now, some argue, maybe we should protect wetlands more. It’s a compelling argument these days. So who knows what to do? But no fear! That’s why the EPA commissioned a study. And they found that the economic burden would be super expensive. There’s just, well, one problem. From the Commies at Bloomberg.

The Trump administration was sloppy in how it estimated the economic impact of a proposal to repeal an Obama-era water pollution regulation, relying on data and assumptions that industry previously criticized, according to economists and regulatory analysts interviewed by Bloomberg BNA.

Chief among their complaints was that the Environmental Protection Agency and the U.S. Army Corps of Engineers used recession-era economic data and failed to account for some of the benefits of leaving the 2015 Clean Water Rule in place. Their economic analysis even drew criticism from David Sunding, a University of California-Berkeley agricultural economist who was hired by industry groups to counter theanalysis the Obama administration used to back its regulation.

“I am not normally this dismissive, but this is the worst regulatory analysis I have ever seen,” Sunding told Bloomberg BNA in telephone interview.

It’s worth repeating that Sunding had been hired by industry groups, in large part because he criticized the conclusions of the Obama administration, saying they had used faulty data to overstate the benefits. But then the Trump admin under Pruitt used the same numbers to come up with even worse results.

When the program was first proposed, it was under one set of economic conditions (coming out of the recession). That skewed the benefits, because it started from an artificially low baseline. But Pruitt’s EPA used that same baseline, and ignored any benefits. Bloomberg can explain.

The Trump administration used the 2013 estimates as a starting point, assuming that the costs of that regulation would be avoided by a repeal and the benefits of the regulation would be foregone. The proposed repeal was estimated to result in $162 million to $476 million in avoided costs, while the estimated foregone benefits range from $34 million to $73 million per year.

In the 2013 analysis, the EPA estimated the annual costs of implementing the water jurisdiction rule to range from $133.7 million to $277 million, but those costs were outweighed by annual projected benefits of between $300.7 million and $397.6 million.

The EPA’s 2017 approach drew the ire of economists because no recent permitting data was used to estimate the economic impact of the proposed repeal. Instead, the analysis used data from fiscal years 2009 and 2010, a time when U.S. economic activity was at its lowest since World War II, particularly in the manufacturing, residential, and commercial development sectors.

Basically, the Obama estimates might have been wrong, but the Trump ones were almost deliberately misleading. Or, knowing them, not almost.

I err on the side of WOTUS, clearly. But it is worth looking into. We do need to know the impact of everything we do. Scott Pruitt sort of agrees. He thinks we should know the negative impact of any regulation. He doesn’t really care to know any of the benefits, or care about the long-and-short term destruction of our environment. That sort of impact doesn’t matter.

The only impact that matters is if business is happy. For some reason they don’t, or won’t, see the ground crumbling beneath their feet. They don’t see the flames licking up the sides of the house. They feel the lash of the storm, but assume it is passing, or pretend their boat can get out of the way. Theya re depserate and greedy murderers, and Scott Pruitt is their chief enabler.

If we’re lucky enough to have history in 100 years, his name will be cursed.


A Couple of Rainy Day Thoughts on How We’ve Altered the Landscape

Image result for chicago rain

It’s been a gloomy rainy sort of day here in Chicago. The White Sox opener has been postponed, which is fine. I don’t mind delaying this 95-loss season another day. It’s not spring yet, anyway.  It’s the sort of April rain that feels like the lingering of March, the whole month of which felt gray and wet, a Smarchian sort of slog.

You look out the windows and see the dull and lumpy sky wrinkle itself in a thousand plinging puddles, and watch the puddles grow and slink off toward the sewer, and its hard to remember that it’s only been a few hundred years that rain has been allowed to land that way. It used to fall on the ground, and slowly make its way across whatever basin it found itself in, if it weren’t used up or simply evaporated, reimagining its particles into invisibility so it could fall again.

But that’s not the way it is, anymore. It’s a profound change, and the short-term effects have been, in some ways, disastrous. To build our cities, we’ve altered to way water has distributed itself around the world. We’ve paved over floodplains and changed rivers. We’ve manipulated drainage.

Look at a very minor example, the North Branch of the Chicago River. Patti Welti of DNA Info has the story.

A total of 1.67 inches fell, a record for March 30.

It wasn’t enough to push the North Branch of the Chicago River to flood, but the water did rise more than two feet during the morning and early afternoon.

How does less than two inches translate into more than two feet?

Before the Chicago area was extensively settled, the river meandered across a marsh-like geography, dispersing water over a greater space. Precipitation was absorbed by vegetation and stored in the ground, wetlands and flood plains, according to the report.

As the area became more urban, green space was paved over, wetlands were drained and the river was straightened to better collect runoff that would have previously seeped into the ground. The result is a watershed with very little stormwater capacity, the report explains.

So much of urban history has been about how to drain marshes and swamps. There were enormous struggles in England in draining The Fens, which led to political upheaval, revolutions, and other intrigues. These were enormous marshes, the “sink of thirteen counties”, as Daniel Defoe described them. But the English managed to straighten the rivers and turn the Fens into farmland.


Or one could look at the Great Black Swamp that used to cover much of Northeast Ohio, a terrible oozy wasteland that slowed down water flowing into Lake Erie. This was a swamp that was nearly impassable by anyone who didn’t know exactly how to transverse its deep sludgy waters, and was frequently a refuge for natives, who could get through it faster than European-Americans could get around it. Draining it was an enormous accomplishment that led to the creation of cities like Toldeo, not to mention millions of acres of farmland.

Funny thing, though. It turns out the swamp helped keep Lake Erie clean, serving as a natural filter for whatever came through the basin’s rivers. The enormous runoff that resulted, combined with chemicals from the regions farms (which the swamp would have filtered) is one of the main reasons why Lake Erie has died several times. The swamp helped keep away the algae blooms that have decimated the lake.

So we don’t know. We don’t know how these experiments will end. The Chicago River was slow and windy, often more marsh than river. It wasn’t meant to be a straight channel. Maybe straightening it was the price of the city. Maybe paving over its wetlands is how we were built. And maybe it will be fine.

But a rapidly rising and fast moving Chicago River, devoid of any drainage, is, in a very literal sense, unnatural. The short-term effects of how completely we’ve altered our landscape are only beginning to show. The long-term effects are unknown. But, with the rushing clarity of a springtime flood, we know one thing: water always wins.