President Donald Trump’s administration’s proposed cuts to environmental protections for waterways rely on questionable analysis, according to new Yale-led research.

In June 2017, Trump directed the Environmental Protection Agency to abandon an Obama-era rule that had increased the purview of the Clean Water Act, even though an analysis conducted under former President Barack Obama’s administration found financial advantages to protecting wetlands.

“Wouldn’t you think to yourself, wait a minute, if the Obama administration found positive benefits in enforcing a new rule, and Trump administration is simply reversing that rule, wouldn’t Trump’s people find that it is just not worthwhile?” said Kerry Smith, a co-author of the paper.

The paper, published in Science on Oct. 6, took a critical look at two competing analyses, conducted under the Obama and Trump administrations, respectively. The researchers found that intentional oversights in the Trump administration’s analysis led the administration to undervalue the benefits of protected waterways.

Analysis conducted under the Obama administration concluded that the Waters of the United States rule — which increased the number of water bodies protected — could produce between $300 and $500 million in “wetland benefits,” Smith said. To remove the rule, Trump’s administration carried out an analysis that discounted 90 percent of those benefits, arguing that since there was no easy way to quantify them, they may as well not be counted at all, said Kevin Boyle, co-author of the paper. The Obama-era rule has never been enforced, as the U.S. Court of Appeals placed a stay on it.

The Clean Water Act aimed to regulate the discharge of pollutants into U.S. waters, though it left ambiguous to which waterways it would apply, Boyle said.

Wetland benefits are notoriously hard to quantify, though their existence is clear. For example, Smith said, wetlands are habitats to fish, which benefits fisheries. On the recreational side, people simply enjoy wetlands and would like to see them protected, he added.

It is easy to look at quantifiable data and ignore non-numerical data, Smith said.

“In the Trump administration’s analysis, the wetland benefits are simply marked as unquantifiable.” he said. “That is, in many circumstances, an implicit zero.”

Lax guidelines on environmental cost evaluations explain the discrepancy between Obama and Trump’s competing analyses. The wiggle-room in how costs and benefits are determined allows for political motives to undermine the value of such analyses. In removing the vast majority of wetland benefits from their analysis, the Trump administration made questionable assumptions that are inconsistent with standard practice for valuing environmental benefits, said Matthew Kotchen, professor of economics at the Yale School of Forestry & Environmental Studies and co-author of the paper.

While some standards for cost analyses exist, they are not strong enough to prevent political “mischief,” Smith said.

“We have standards, but are those standards as good as the ones the Bureau of Labor Statistics uses to construct the consumer price index? No, they’re not,” Smith said. He added that while the government invests over $200 million annually to support the Bureau of Labor Statistics’ efforts to understand price indexes, only a million dollars are invested in environmental protection programs’ evaluations.

The analysis conducted by the Obama administration, while more extensive, was also imperfect. The data used was old, and not all of it was collected through best practice, Smith said. Overall, the researchers agreed that there is a need for greater oversight of environmental analyses to prevent political motives from undermining supposedly objective processes.

The Clean Water Act became law in 1972 when the U.S. Senate and House of Representative overrode President Richard Nixon’s veto.

Maya Chandra | maya.chandra@yale.edu

MAYA CHANDRA