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Beneath the Surface

The Concealed Costs of the Clean Water Rule Rollback

By Bethany Davis Noll, Peter Howard, Ph.D., Max Sarinsky, Jason Schwartz, and Jeffrey Shrader, Ph.D.
April 27, 2020

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Filed under Environmental Health, Reports, Jobs and Regulation, Safety and Consumer Protection, Transparency

In restricting the scope of the Clean Water Act through two regulatory rollbacks, the Environmental Protection Agency and Army Corps of Engineers claim that the estimated compliance-cost savings exceed the environmental harms (in the form of forgone benefits). Yet these analyses suffer from severe methodological flaws. And correcting the analyses would very likely show that the rollbacks are net costly to society, depriving the public of potentially billions of dollars in annual forgone benefits. As detailed in this report, the agencies’ failure to meaningfully assess the substantial harms that will result from their rollbacks violates both regulatory precedent and the agencies’ legal obligations.