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Laurie Johnson’s Blog

Industry Reports Attacking Clean Air Rules Earn Poor Grades from Professors

Laurie Johnson

Posted October 28, 2010

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In response to two sets of forthcoming EPA clean air standards, industry lobbyists have launched a furious lobbying campaign on Capitol Hill to block or weaken the proposed public health protections. To create economic alarmism, the lobbyists commissioned three economic reports which reach fantastically false predictions of economic ruin due to these clean air safeguards.

We knew the industry conclusions to be junk, and I blogged about each of them: the Manufacturer’s Alliance’s attack on stronger smog standards; the Council of Industrial Boiler Owner’s attack on standards to reduce toxic air pollution; and the American Forest and Paper Association’s attack also on the toxic air pollution standards.

Based upon my own cursory review of the studies, I had a strong feeling that not only were they junk, they wouldn’t even pass muster in a typical college economics class. With methodology so lacking in basis, they would probably earn very low marks.

So NRDC asked three respected academic economics professors to evaluate these industry reports as if the reports had been submitted to the professors as assignments in their undergraduate courses (Disclosure: we gave an honorarium to the professors for their time).

Today, NRDC is releasing the embarrassing grades that the reports received. No matter how you slice it, it is hard to make the case that reports which would earn grades of “Incomplete”, “F” and “D/F”, if they were handed in to a college professor, deserve to be taken seriously or even considered reasons for blocking or delaying clean air protections that together could save as many as 17,000 lives each year. The grades for all the reports can be downloaded here.

One of the reports, commissioned by the Manufacturer’s Alliance (MAPI), attacked soon-to-be issued national smog standards by EPA that could save as many as 12,000 lives each year and prevent tens of thousands of cases of respiratory illness. It earned an “Incomplete” from economist Richard Howarth, the Pat and John Rosenwald Professor of the Environmental Studies Program at Dartmouth College. As Dr. Howarth said in his evaluation:

“The MAPI report is fundamentally flawed, resting on an analytical framework that is scientifically unsound and inappropriate for use in policy evaluation. The report fails to apply standard statistical techniques that are taught to students specializing in the fields of statistics and econometrics. The report would warrant a grade of “incomplete” if it were submitted as an undergraduate honors thesis or master’s thesis in an academic program focusing on environmental policy analysis.”


The two other industry reports attacked forthcoming EPA standards, which will reduce toxic air pollution from industry plants that are projected to save nearly 5,000 lives per year and prevent thousands of cases of respiratory and heart disease.

One of them, commissioned by the American Forest and Paper Association, received an “F” from Dr. Charles Kolstad, Chair of the Department of Economics at the University of California at Santa Barbara. Dr. Kolstad noted:

“If I were grading this, I would give it an F. The economics is all wrong (lack of an incidence analysis or acknowledgement of its importance; failure to draw on the relevant literature), which of course would be my main concern.

But the paper has some redeeming features ‐‐ the English grammar is decent and typically better than I see on a poor paper. Furthermore, I would want to encourage the student to work harder on the next assignment.”


The other report attacking the toxic air pollution standards, commissioned by the Council of Industrial Boiler Owners (CIBO), received a two-part grade of D (for application) and F (for transparency) from Jason Shogren at the University of Wyoming’s Department of Economics and Finance. Regarding the report’s transparency, Dr. Shogren wrote:

“Weak discussion on the basic economic role of responsiveness and substitution possibilities, multiplier justification is unclear, abatement cost assumptions incomplete, unclear, and inadequately justified.”


As industry lobbyists attempt to persuade Congress to get in the way of the vital public health protections that combined would save as many as 17,000 lives per year, it is worth noting that the supposed ‘basis’ of industry arguments are reports whose grades any college student would be ashamed to show to his or her parents.

The Manufacturer’s Alliance, the Council of Industrial Boiler Owners and the American Forest and Paper Association should be embarrassed by the reports they commissioned. What’s more – the companies that are members of these associations should be embarrassed to be associated with the reports and these the efforts to block important public health protections.

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Jim DiPesoOct 28 2010 02:21 PM

For some reason, the poor performance of these papers reminded me of the Animal House scene in which the dean confronts the Delta House gang about their poor grades.

"Mr. Blutarsky - Zero. Point. Zero!"

P. OdeOct 29 2010 11:46 AM

Yo, my fraternity brother at Alcoa Exxon Pfizer told me if I bought these reports from him then I would score at least a B- in my Econ 101 class. These grades are B.S. I really got played by that loser.

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