This is unfortunately part of a pattern of book-cooking the administration has performed in order to get its cost-benefit analyses to show that deregulation is helping, rather than hurting, the economy. A few other examples... /1
No longer including "co-benefits" of a regulation (a break from long-standing government practice and official government policy). I.e., “favorable impact of [a] rule that is typically unrelated or secondary to the statutory purpose of the rulemaking.” brookings.edu/research/exami… /2
Throwing out certain studies on the grounds that they are too old (yet still citing even older studies within the same cost-benefit analysis), in order the disregard research findings that happen to be inconvenient: environment.yale.edu/news/article/Y… /3
Coming up with a new (lower) estimate for the social cost of carbon, by changing the discount rate and newly excluding costs felt outside U.S. borders: nytimes.com/2018/08/23/cli… /4
Changing the internal computer-generated climate models so that they project the impact of climate change through 2040, rather than through the end of the century, as had been done previously: nytimes.com/2019/05/27/us/… /5
Counting costs already "sunk" as if they are instead future costs (coal plants purchased expensive new tech in response to a 2012 mercury emissions rule; Trump admin treats those purchases as if they haven't already happened to justify repealing rule): news.bloombergenvironment.com/environment-an… /6
