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Bush weighs life's worth, cost of rules

03/17/03

JIM BARNETT

WASHINGTON -- The Bush White House is pushing federal agencies to slash
the dollar value they place on human life, a move that has ignited an
ethical debate with administration critics and allies alike.

To calculate benefits of rule changes, such as cutting power plant
emissions, agencies typically assign a uniform value to each life saved.
The Environmental Protection Agency uses $6.1 million, a value set under
President George H.W. Bush and indexed for inflation.

But the method is unfair and economically unsound, according to
officials in the current Bush administration, because it fails to
recognize differences in quality of life: An elderly person with chronic
illness is equal in value to a healthy child with decades to live.

Under the White House approach, agencies would account for the health
and age of people who benefit from new rules. It's the same principle
used a decade ago to justify the Oregon Health Plan, which sparked
national controversy by proposing to ration medical care for the poor.

Leading the charge is John D. Graham, administrator of the White House
Office of Information and Regulatory Affairs. Graham wants agencies to
identify what types of people would benefit from regulation and by how
much.

His goal: Get more bang for the buck.

"The method will focus agencies on developing rules that have the most
public health promise, measured by both the number of life years saved
and improvements in quality of life," he said. "The method is
pro-health."

But the approach has produced some unsettling results. In Bush's
signature Clear Skies plan, for example, EPA values the lives of some
people who benefit from cleaner air as low as $96,000 less than 2
percent of its standard measure.

Business and industry stand to gain from the White House initiative.
Regulators must weigh benefits against costs of regulation, so lower
life values can limit government's reach in cutting emissions and
requiring companies to invest in new equipment.

Indeed, opponents fear that consequences could ripple across the
bureaucracy as agencies apply the method to an array of laws intended to
protect human health -- from toxic-waste cleanup to workplace safety and
food labeling.

"It can prevent EPA and other agencies from taking action they otherwise
would have taken," said Wesley Warren, an assistant budget chief under
President Clinton.

Potentially more troubling for President Bush is a growing unease among
religious conservatives -- some of his most stalwart supporters -- who
believe that differentiating lives by age and health would give
bureaucrats a God-like power to pick favorites.

"In general, if you're valuing one life over another, we've got lots of
problems here," said Walt Grazer, who tracks environmental issues for
the National Conference of Catholic Bishops in Washington.

Clear Skies proposal

EPA has served as the boiler room for the White House's new approach,
with the first public signs contained in an "alternative analysis" that
was included in the fine print of Clear Skies and other recent
proposals.

Bush unveiled Clear Skies in February 2002 as a market-based answer to
more rigid regulation. To build support, EPA chief Christie Whitman and
other officials touted Clear Skies' big payoff -- health benefits valued
at $93 billion by 2020.

EPA arrived at its estimate in part by assuming that 12,000 lives could
be extended by cleaner air and that each life should be valued at its
standard rate of $6.1 million, according to documents on the agency's
Web site.

But in comparison, EPA's alternative analysis appeared to undercut the
proposal by pegging benefits at a dramatically lower figure -- just
$14.1 billion, an amount far closer to the $6.5 billion cost of the
plan.

Although benefits still outweigh costs, opponents said, the lower
estimate serves as a barrier against more stringent emissions limits.
And in the long run, it could discourage agencies from developing new
rules that might protect health at higher cost, they said.

"It's not rocket science to see that the purpose is to smother some of
these proposals in the cradle," said Warren, now a fellow at the Natural
Resources Defense Council. "The public will never know they are being
denied these protections."

A major factor in the alternative estimate: EPA officials challenged the
agency's longstanding method for assigning a dollar value to lives
improved by cleaner air.

First, the agency rejected most of the 26 academic studies that served
as the basis of its $6.1 million-per-life standard. The agency kept only
five studies that were based on public opinion surveys. That cut the
estimate to $3.7 million a life.

EPA then cited a single study -- published in 1989 and later challenged
by its author -- concluding that elderly people would pay only 63 cents
for every $1 that younger people would pay to reduce their risk of
death. The result: Elderly lives valued at $2.3 million.

Next, EPA assumed each beneficiary suffered from heart disease and
therefore could expect to live just five more years. On that basis, it
capped elderly lives at $1.4 million. And it assumed some people would
live only six extra months -- a benefit worth $96,000.

Measuring effectiveness Cost-benefit analyses, like those applied to
Clear Skies, are required of all regulations expected to have economic
impact greater than $100 million. Results rarely dictate a decision, but
policy-makers generally regard the exercise as helpful in building
consensus.

The White House's effort to refine the analysis is the latest chapter in
a long-running conflict over how to balance demands for cleaner air,
cleaner water and safer workplaces against the cost to industry and
consumers.

Graham, who founded the Harvard Center for Risk Analysis before joining
the budget office, is prodding agency leaders to measure the relative
effectiveness of proposed rules in addition to simply tallying benefits
based on a series of subjective assumptions.

By applying quality-of-life considerations, EPA's alternative analysis
allows for comparisons with rules proposed by other agencies, he said.
That way, policy makers can determine which course of action achieves
the greatest benefit at the least cost.

"OMB's role is to strive for some consistency across agencies in how
they address analytic issues," Graham said in an interview in his office
overlooking the West Wing. "It is not desirable to have the same
disease, for example Alzheimer's disease, evaluated differently by the
various federal agencies."

Federal agencies have been dabbling with quality-of-life analysis at
least since the Clinton administration, Graham noted. And some leading
social researchers favor the approach because they think it serves both
common sense and economic efficiency.

"I'd rather save my life when I'm healthy than when I'm sick," said
Richard Zeckhauser, a professor at Harvard's Kennedy School of
Government. "It's giving people what they say they want."

But the approach opens the door to difficult ethical questions: Who's to
say that a heart patient doesn't value his life as much as a perfectly
healthy person? And what about the terminally ill, whose life quality
and expectancy could pencil out to zero?

"Any effort to try to gauge the relative value of a human life in the
context of a public safety issue like this is inherently suspect," said
Andy Imparato, president of the American Association of People with
Disabilities.

Similar questions have haunted relatives of those who died in the
terrorist attacks of Sept. 11, 2001. Many have received compensation
based on a hodgepodge of factors -- age of the deceased, income,
insurance, number of dependents and more -- and some have decried the
formula as unfair.

Experimenting in Oregon In the early 1990s, Oregon political leaders
also tried an experiment in valuing lives to make government more
effective. But instead of encouragement from the White House, they
received threats.

The goal was to extend coverage to more low-income people under the
Oregon Health Plan. Money was limited, so state officials commissioned a
public-opinion survey to rank more than 700 procedures in order
improvement in quality of life.

"I always said it was rational care, not rationed care," recalled former
Gov. Barbara Roberts, a Democrat.

But groups representing the disabled and the elderly attacked the plan,
saying it was based on prejudices of able-bodied people. Religious
groups joined in, hoping to head off what they regarded as government
intrusion on "the sanctity and dignity of life," recalled Robert J.
Castagna of the Oregon Catholic Conference.

They found a powerful ally in the first President Bush. The White House
regarded the Oregon plan as a dangerous precedent, and Bush's advisers
launched an administration effort to block it.

In a letter dated Aug. 3, 1992, Health and Human Services Secretary
Louis Sullivan told Roberts that the plan would violate the Americans
with Disabilities Act. And on Bush's last full day in office, Jan. 19,
1993, a top Justice Department lawyer outlined the legal case against
assigning relative values to people's lives.

"(A)ny methodology that would intentionally ration health care resources
by associating quality-of-life considerations with disabilities does not
comport with the mandate of the ADA," wrote Timothy J. Flanigan, who
later served as deputy White House counsel in the current Bush
administration.

Putting value on lives Ultimately, state health officials abandoned the
telephone survey results, said Darren Coffman, director of the Oregon
Health Services Commission. They substituted opinions of health-care
professionals and were allowed to proceed by the Clinton administration.


Since then, the debate has been confined largely to circles of
academics, mostly economists, who are trained to focus on questions of
efficiency. Ethical and moral considerations have taken a back seat.

EPA has yet to grapple with those issues, but it is considering how to
solicit ethical advice, said Jeffrey Holmstead, an assistant
administrator. In the meantime, the agency will continue looking for
ways to improve its quality-of-life analysis.

"I don't disagree that it certainly raises some difficult issues to be
valuing one life different from another," Holmstead said. "But it's the
only way we feel like we at least have a tool that can help inform these
sorts of policy decisions."

Likewise, there has been little debate in Congress about the method used
in EPA's alternative analysis. But leaders of several advocacy groups
said they hoped to raise public awareness as members take up Bush's
Clear Skies initiative.

"This looks on the surface like a really technical, geeky, wonky thing,
so it's hard to pull out moral arguments," said Daniel Swartz, executive
director of the Children's Environmental Health Network. "But as people
figure out what's going on certainly as they see things like 63 cents on
the dollar for the elderly -- there's starting to be some outrage."

  *** NOTICE: In accordance with Title 17 U.S.C. Section 107, this
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