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The latest EPA analysis argues that it was inappropriate to factor in such co-benefits.
The EPA analysis is "a radical departure from established science and economics," charged attorney David Doniger of the Natural Resources Defense Council.
As for the economy, most analyses - including a recent EPA analysis of the Lieberman-Warner climate bill - find that the US could drastically reduce emissions with fairly little impact on economic growth.
Riverkeeper claims that current EPA analysis methods fail to give adequate weight to the ecological cost of fish killed by outdated cooling systems.
"The bottom line is that this new Pruitt EPA analysis assumes that dirty air is safer to breathe than the Obama team did," said Frank O'Donnell, who heads the advocacy group Clean Air Watch, in an email.
Preliminary EPA analysis shows that in 2010, Clean Air Act fine particle (soot) and ozone (smog) programs implemented since the 1990 Amendments will have prevented more than 160,000 premature deaths.
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The U.S. EPA's analysis, approaches, and conclusions are consistent with multiple sets of peer-reviewer recommendations (U.S. EPA 2012a).
The U.S. EPA's analysis found that a wide range of possible contributions of TCA to PCE carcinogenicity, from as little as 12% to as much as 100%, is consistent with the available data (U.S. EPA 2012b).
The U.S. EPA's analysis identified the central nervous system, kidney, liver, immune and hematologic systems, and development and reproduction, as target organs of PCE toxicity (U.S. EPA 2012c).
The input parameters into the C-R functions for these outcomes are the same as those used in the U.S. EPA cost benefit analysis of the Clean Air Act (U.S. EPA 1999).
Lethal concentrations of cypermethrin at which 50% mortality of the fish occurred (LC50) and its 95% confidence limits were estimated for 96 h from the mortality data using EPA-Probit analysis version 1.5 statistical software based on the probit analysis method of Finney (1971).
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