—The manufacturing group's nationwide study assumed that some plants would close rather than install expensive pollution-control equipment. The 11-state study assumed plants would stay open and install the equipment. The EPA makes the same assumption and says that industry innovations usually bring down the cost of control equipment.
—The alliance did not factor in efforts to lower ozone levels by reducing auto emissions; the petroleum group's study did. It costs far less to test vehicle emission systems — motorists usually pay for inspections — than for industry to install expensive control equipment.
—The alliance did not factor in areas of the country that could devise ways to meet air-quality standards without major job losses. In setting ground ozone standards, the EPA gives states leeway in devising ways to meet the air-quality requirements. The 11-state study only researched areas that may need expensive additional measures to comply with a new air-quality rule.
Those opposed to government regulations rarely mention the potential benefits to society. The EPA, for example, estimated that its proposed smog standards could prevent up to 12,000 premature deaths and 58,000 cases of aggravated asthma, and save as much as $100 billion in health costs.
Some industry models don't take into account job gains. Someone has to manufacture and install new anti-pollution equipment. If meat sales drop, purchases of fish or other foods may increase, ensuring that a supermarket would not lay workers off.
"It's not up to me to make the other guy's case. It's up to them to make their case," said Dunham, who did the meat industry study.
Researcher Stuart Sessions studied potential costs of an Occupational Safety and Health Administration noise-reduction plan that has now been withdrawn. Hired by the Coalition for Workplace Safety, composed of employers and trade associations, Sessions said he did take into account jobs that would be created if new noise-reduction equipment would be required.
His model produced a wide range of possible scenarios: job losses from a low of 8,300 to a high of 200,000.
Sessions acknowledged the limits of his research.
"I'm waffling, but that's a responsible thing for an analyst to do," he said. "It's important to try your best to come up with estimates of costs and benefits. It's important . to be fair and honest about the uncertainties and let policymakers decide, 'Is it worth the cost?'"
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