Richard Pearshouse
5 min
This paper examines the systematic dismantling of air quality regulations during the second term of the Trump administration. The author argues that the Environmental Protection Agency (EPA) has shifted from a health-centric regulatory model to one that prioritizes industrial costs, often by manipulating the economic metrics used to justify environmental standards. By excluding the monetary value of avoided deaths and illnesses from cost-benefit analyses, the administration has effectively "zeroed out" the human benefits of clean air policies, leading to a regression in public health protections.
The paper highlights a significant methodological shift in how the EPA evaluates environmental rules. While the Clean Air Act historically required standards to be set based on health protection, recent actions—such as requesting to vacate revised particulate matter (PM2.5) standards and rescinding mercury emission limits—demonstrate a move toward prioritizing industry compliance costs. By failing to quantify the health benefits of these regulations, the agency creates a skewed economic justification for weakening environmental safeguards, which disproportionately impacts vulnerable populations, including children, the elderly, and low-income communities.
The author situates these domestic policy shifts within the context of international human rights law. As global jurisprudence—such as rulings from the Inter-American Court of Human Rights and the European Court of Human Rights—increasingly recognizes that exposure to toxic pollution violates the right to life and a healthy environment, the US government’s deregulatory path appears increasingly isolated. The paper concludes that the right to health provides a necessary framework to challenge these technical regulatory changes, urging a return to environmental governance that centers on the protection of human life rather than industrial convenience.
viewpoint Trump's War on Clean Air richard pearshouseAir pollution rarely appears on death certificates.With a notable exception from a London coroner's report following the death of a nine-year-old girl in 2013, individual deaths are not typically attributed to air pollution. 1Yet in the United States, an estimated 100,000 to 200,000 people die prematurely each year because of polluted air. 2 These deaths receive less attention than they merit in large part because air pollution's effects are insidious, cumulative, and difficult to attribute to a single cause.Air pollution harms lungs-causing lung cancer and exacerbating pneumonia and asthma-but it more frequently kills through cardiovascular pathways, including strokes and heart attacks.It also affects the brain, contributing to cognitive decline, dementia, and even depression.As scientific understanding evolves, the evidence of harm continues to expand.Even at levels below current regulatory thresholds, air pollution has measurable adverse health effects.The burden of these harms is unevenly distributed.Children, older people, those with preexisting health conditions, and communities that are low income or racial and ethnic minorities are disproportionately exposed and more vulnerable to the effects of polluted air.This unequal distribution contributes to the systemic masking of air pollution as a public health crisis.If understanding the health impacts of air pollution is inherently challenging, it has become significantly more so during President Trump's second term.The administration has systematically dismantled elements of the regulatory framework designed to protect air quality, weakening multiple pollution standards and reducing the institutional capacity of the federal agency tasked with implementing the Clean Air Act. 3 These moves represent a form of regulatory regression that is increasingly incompatible with the right to the enjoyment of the highest attainable standard of physical and mental health under international human rights law.As early as 2000, the Committee on Economic, Social and Cultural Rights noted in its General Comment 14 that the right to health includes "the prevention and reduction of the population's exposure to harmful substances … and harmful chemicals or other detrimental environmental conditions that directly
Sam: It means they stop putting a dollar value on the good things that happen when pollution is reduced. If a new rule prevents thousands of early deaths and hundreds of thousands of asthma attacks, those are substantial gains for society. By refusing to calculate the economic value of those lives saved, the agency makes it appear that the regulation provides zero benefit—even when the health data shows the opposite. The costs to industry are counted in full. The benefits to people are recorded as nothing.
Alex: And that asymmetry has real consequences. How does this change things for actual people?
Sam: If the EPA decides a rule is too expensive because they've left out the health savings, they may allow higher levels of pollution. For a child in a heavily polluted area, that means more days missing school due to asthma attacks. For an older adult, it might mean a cardiac event triggered by winter air that traps pollution near the ground. The math doesn't stay on a spreadsheet—it shows up in people's health.
Alex: It sounds like they're separating public health from environmental governance entirely. Is there an international standard they should be measured against?
Sam: There is a growing global framework built around what's called the "right to health." This framework holds that governments have an obligation to prevent exposure to harmful substances, and to avoid what's called "regulatory retrogression"—which simply means weakening protections that are already helping people stay healthy.
Alex: And how does the U.S. compare to that standard?
Sam: The paper suggests the U.S. is currently moving in the opposite direction. The World Health Organization recommends much stricter limits on PM2.5 than the U.S. currently enforces. When the EPA moves to weaken its own thresholds, it is effectively setting aside the best available science and moving away from those international health obligations.
Alex: I want to make sure I understand the scope here. What does this paper actually cover, and where does it stop?
Sam: The paper focuses on the legal and human rights frameworks, and on the administrative changes in how the EPA calculates costs and benefits. It does not attempt to model how pollution physically moves through specific neighborhoods. It's examining the policy logic, not the local atmospheric science.
Alex: So if this methodology persists, what does the long-term picture look like for the EPA?
Sam: The paper raises the concern that the EPA risks becoming an economic accounting office rather than a public health agency. By consistently prioritizing a lopsided ledger over the protection of human life, the agency effectively erases the health crisis from the official record. When the government stops counting the value of a human life in its regulatory calculations, it doesn't just change policy—it removes the foundational reason the agency exists in the first place.
Alex: That's a sobering place to land. Thanks for walking us through it, Sam, and thanks to everyone listening to ResearchPod.