But exactly how much companies like Shell and ExxonMobil receive is something of a mystery. Tucked into tomes of tax code, subsidies for fossil-fuel industries are often obscured. The IRS does not make public the amounts that companies save, and estimates range widely. One analysis found that about $72 billion went to oil, gas, and coal producers from 2002 to 2008. But we really don’t have a clear or complete picture of the actual total; it could easily be much higher.

Certainly the record profits posted by companies like Exxon suggest that their tax subsidies could be allocated more efficiently elsewhere. The first step in deciding on the appropriate level of tax breaks for these types of industries would be finding out what they’re getting right now. After nations agreed to lower their fossil-fuel subsidies at the Toronto G8 summit, the Organization for Economic Co-operation and Development (OECD) set to work cataloging these subsidies around the world. Their results can also help to fine-tune estimates on what our government is giving to oil and coal producers. But we still don’t have a complete picture.

In an effort to better account for what various energy sectors get from U.S. taxpayers, we at the Institute for Policy Integrity have launched a wiki. It will use crowdsourcing to catalog tax-code sections that provide tax relief to energy-producing companies, tapping the expertise of lawyers, economists, tax professionals, and concerned citizens.

Nowadays we may be inured to the sound of big-dollar figures: $400 billion in budget cuts, $700 billion stimulus, $14 trillion deficit. But make no mistake: tens of billions in taxpayer dollars each year going to a handful of industries that have been well established in this country for a century — that’s a lot of money. If we cut even a fraction of that, we could restore funding for important services or launch new job-creating infrastructure projects.

Before we delve into the federal budget looking for ways to save, shouldn’t we at least know how much we are sending to industries that don’t need our help?

See also:

• Should we get rid of all energy subsidies?
• Is it politically realistic to eliminate energy subsidies?
• Direct subsidies to fossil fuels are the tip of the (melting) iceberg

In Tuesday’s State of the Union address, President Obama is likely to focus heavily on economic growth and job creation. But he should also make clear that economic progress need not come at the expense of the environment; to the contrary, the public-health efforts he’s made over the past year will generate billions of dollars in value for the American public.

In a preview of the speech, Obama suggested there will be some focus on energy — hardly surprising since the Keystone XL pipeline and congressional inquiry into Solyndra were such high-profile issues in the past year. The administration’s decisions on environmental regulation this past year made news too — the delays and punts that angered environmentalists, like the ozone standard and coal ash rule, and the public-health protections that have angered industry, like the mercury rule.

Energy even boiled over into the presidential campaign recently: The Obama-Biden 2012 campaign’s first TV ad of the season was something of a rebuttal to the president’s critics in the energy industry.

With energy and environmental topics in the news, and many Americans confused about their impact on jobs, it makes sense that the president would want to give more airtime than usual to these issues in his speech.

In doing so, he would do well to combat the argument that has become conventional wisdom about the effect of environmental efforts on jobs: that somehow new rules can “kill” or “create” jobs. The downturned economy has allowed this questionable idea to dominate the debate over public-health efforts.

Neither cutting nor strengthening environmental regulations will do anything to address the jobs crisis. It is macroeconomic factors like availability of credit and consumer demand that affect unemployment. Nothing the Obama administration has done to clean the air or protect public health will have significant impacts on the unemployment rate.

Correcting the erroneous notion that environmental regulation is an important driver of unemployment is in Obama’s interest. The longer this false assumption lingers out there, the more damage it can do to the president’s political outlook, not to mention public health and the environment.

Overall, the Obama administration has shown support for rules that protect clean air and water, balanced by concern about their costs. Though he has not taken as hard a line as green groups would like, the president has made important strides. Recent rules from EPA will help cut interstate pollution from power plants and improve fuel efficiency for cars. Along with other rules in the pipeline, these advances demonstrate a commitment to strong public health and environmental protections.

But beyond appealing to those who specifically care about green issues, these efforts are a boon to the American public. They generate billions in economic benefits — doctors’ bills never sent, sick days never taken, untimely deaths avoided. In his State of the Union speech, Obama should take credit for these money-saving measures. They provide huge value for the nation’s families and that’s something to be proud of.

The president’s energy and environmental agenda has been used as a weapon by his opponents for most of his term. But they may find that they have picked up a double-edged blade. The efforts of EPA and other agencies under Obama have been greatly beneficial to the American public. Making that case Tuesday night could take what his opponents hope will be a liability in the campaign and turn it against them.

New mercury pollution standards: something everyone should celebrate.

But economists can also feel good about this holiday-season gift of clean air: Two decades of agency analysis have found the EPA’s new mercury standards for power plants to be overwhelmingly cost-benefit justified. With annual compliance costs around $11 billion, and health benefits estimated to be up to $140 billion per year, even the most hard-nosed bean counter should be feeling festive.

But that’s only part of the story. This number doesn’t even fully capture the benefits of the rule, because EPA’s economic analysis does not include many of the risks of mercury pollution. 

The EPA’s analysis of mercury reduction benefits is limited to quantifying lost future earnings due to lower IQ. The idea here is that mercury, a neurotoxin, can cause development problems for in utero fetuses. To account for the cost of this risk, EPA places a price on wages lost because of lost IQ points.

But any parent whose child has been exposed to mercury will care about more than the loss of potential earnings — over a lifetime, contact with the pollutant can mean more than smaller paychecks. There are also risks of cognitive and social defects, negative autoimmune effects, genetic effects, and heart attacks that are not quantified. 

Even the narrow IQ-related effects EPA looks at are estimated only for a small group of people — children born to families that catch freshwater fish for their own consumption. Excluded are any of the potential risks that come from eating commercially bought fish, which is the vast majority of total consumption. 

Some seem to like to pretend that these unquantified risks don’t exist at all. The Wall Street Journal editorial page, in a broadside against the rule, quoted EPA’s finding that “the benefits to society from the mercury reductions in the utility rule max out at $6.1 million, total.” The paper failed to mention all of the benefits that EPA recognized, but was unable to put a dollar figure on.

Getting a handle on these risks is challenging. Once mercury enters the ocean and contaminates fish (that will eventually be eaten), it’s very difficult to trace back to the offending plants. Using current analytical techniques, it is nearly impossible to tell which mercury came from U.S. coal plants, versus Chinese coal plants, versus other nations’ coal plants. Essentially, mercury becomes everybody’s fault and nobody’s fault at the same time. But that difficulty doesn’t excuse U.S. coal plants from their share of contributing to the problem.

Even without putting an exact figure on the mercury benefits, we know the rule is richly cost-benefit justified because of all of the positive side effects that we get from reduction in other pollutants, like particulate matter (a particularly deadly air pollutant).

When the economics, public health benefits, and environmental benefits align this nicely, it takes a real Grinch to refuse to celebrate. 

EPA and its minions in the press and the professional environmental lobbies have assumed an absolute monopoly right to flood the American economy with regulations, litigation, and compliance costs that are out of proportion to any environmental problem — real and imagined — that has reached the congressional calendar.

It’s time to get off this super bureaucracy kick unless you really believe that the present drastic deterioration of our economy, productivity, international competitiveness, and living standards will soon miraculously fade away.  It won’t happen so long as we keep writing blank checks that authorize hotshot junior lawyers and zealots ensconced in the EPA to bleed American industry of scarce funds needed for investment, modernization, and job creation.

Given the strong rhetoric, it would fit right into today’s environmental debate. But it was actually written by David Stockman, when he was leaving Congress in the early 1980s to become Ronald Reagan’s Office of Management and Budget director.

Of course, in hindsight, we know that the sky did not fall. The “drastic deterioration” did fade away (“miraculously” or not), even after early attempts by the Reagan administration to gut environmental protection were halted by popular backlash. Businesses have not been bled to death by environmental compliance costs, but instead have hummed along for three decades, generating wealth for the American people while improving their environmental performance. In the three decades since 1981, when Reagan took office, the U.S. economy has grown by an average rate of 3.3 percent, with per capita GDP more than tripling during that time.

Of course, since the EPA was created in 1970, the U.S. has seen recessions, bubbles, flush times, and dire straits. But not one of these macro episodes was caused by anything the EPA has done. Instead, they were caused by financial crises, like the 2007 mortgage crisis and the savings and loan crisis in the late 1980s, or external shocks, like the 1970s oil embargo (made all the worse by the country’s addiction to gasoline).

But whenever the economy declines, the same anti-environmental rhetoric is trotted out, with those on the right calling the EPA a bunch of “hot shot junior lawyers and zealots” (Stockman, 1980s), or even worse, “the Gestapo of government” (Tom DeLay, 1990s), and accusing the agency of wanting to “put the American economy in a straightjacket” (Joe Barton, 2010s).

How many times must these dire predictions about economic doom from environmental protection be proven untrue before we collectively stop listening?

At the same time that it’s become crystal clear that economic growth and environmental protection can go hand-in-hand, the science showing the antagonistic relationship between pollution, public health, and environmental quality has grown considerably stronger. From particulate matter deaths to the climate change crisis, we know a lot more about our effect on the environment, and the environment’s effect on us. And the more we learn, the stronger the case for action has become.

Putting this all together, the EPA recently conducted a retrospective analysis of the costs and benefits of cutting pollution under the 1990 amendments to the Clean Air Act. The agency found that these protections added over a trillion in net benefits to the U.S. economy per year in 2010. This report, which was based in the best available scientific and economic information, touches only a portion of the essential environmental protection done by federal and state governments.

Rather than being a drag on the economy, the “super bureaucracy” warned of by Stockman is a supercharged boon for the American people.

There are some that may benefit from unrestricted pollution: owners of fossil fuel companies and the dirtiest industrial firms. Even they are harmed by dirty air and water, but cleaning up their act is costly for their bottom lines.

But when pollution goes unaddressed, it is the general public that pays through doctors’ bills, sick days, lowered property values, and untimely deaths. These costs add up to billions of dollars — far more than the investments needed to bring pollution down. 

That side of the ledger is rarely acknowledged by those who decry the EPA’s work. These voices do their best to downplay the downsides of emissions — going so far as to question basic public health science. Instead of genuine costs and benefits, we are given the false choice of a clean environment or a strong economy.

After 30 years, it is time to start ignoring all of the hyperventilating about the imaginary economic horrors of environmental protection. In reality, there is overwhelming evidence that a healthy environment is part of a strong economy; indeed, allowing pollution to continue unabated is the economically foolish thing to do.

You want bodies? We got ‘em.

It is tempting to go line by line through the piece debunking each point. But Milloy makes a specific request to see “bodies,” and sadly, that is easy enough to show him. 

The science showing the harmful effects of particulate matter, or soot, is very strong. The microscopic bits spewed out of smokestacks around the nation are small enough that they can travel deep into human lungs and can even slip directly into the bloodstream. 

The result: higher incidences of asthma, bronchitis, impaired lung development in children, and heart disease.

Questioning these health concerns means countering a substantial body of empirical health studies, conducted both by federal agencies and by independent researchers. These studies, which have been subjected to the scrutiny of the peer review process, have come to a set of well-supported conclusions about the relationship between particulate matter and mortality — the focus of Milloy’s post. 

This research, which has included efforts by the National Research Council and has been reviewed by a range of independent bodies, has led the American Lung Association to make reduction of particulate matter pollution a core priority.

If Milloy is actually interested in looking for the “bodies,” he should simply examine the peer-reviewed studies [PDF] that back up the EPA’s analysis. It is true that particulate matter is a silent killer — risks are spread over large populations, masking the true threat. But when standard scientific tools are used, the reality becomes very clear: This is a deadly pollutant that takes a substantial toll.

Milloy also asks the EPA “demonstrate that its ever-tightening air quality and emissions standards are producing actual benefits.” Luckily, the agency recently released a deep study of the costs and benefits of amendments to the Clean Air Act between 1990 and 2020. The report uses the most rigorous, academically defensible economic tools to evaluate the worth of healthy air. 

Avoided are costs like doctors’ visits, increased property values, and, yes, pollution-related deaths. These and other benefits add up to $1.3 trillion, compared to costs of only $53 billion in 2010. Milloy may believe that industry is the true victim, subject to the whim of government regulators. But these figures show who actually pays the price when pollution goes unchecked: the American public.

Once we start down the road of challenging basic scientific findings, there is no clear stopping point. What started out as criticism of climate models has expanded to questions about the basic science supporting public health protections. While understanding these studies may take a basic scientific education, any responsible commentator should take the time to do a review of the literature before making broad based assertions about agency bad faith. EPA shouldn’t have to drag anyone to the morgue to make its point: The facts about particulate pollution have been established over the course of several decades of publicly available research, at the fingertips of anyone actually interested in learning the truth.

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Photo: Horia VarlanIn January, President Obama issued a call for all federal agencies to review their existing regulations, looking for rules that had grown outdated, ineffective, or insufficient over time. Back then, there was much discussion over whether the move was a gift to business or a robust defense of strong protections even in a downturned economy. 

Now, the EPA and other agencies have released their proposed plans for retrospective review, and the proof is in the regulatory pudding. In its current form, there is too little in the EPA’s proposal that suggests review efforts will strive to enhance cumulative net regulatory benefits. Ideally, these plans would be neutral, and would seek to maximize net benefits regardless of whether rules needed to be rolled back, updated, or expanded. 

Largely, it seems, the EPA has focused narrowly on paperwork reductions and appealed to specific business interests — a far cry from modernizing the regulatory state. There has been far too little emphasis on updating and expanding rules.

The very first rule selected for review by the EPA provides a telling example. The EPA proposes revisiting its rule that protects children and adults from lead-based paint dust and chips. This rule was developed only three years ago, has been in effect for just over a year, and was most recently amended in May 2010. Yet without identifying any changed circumstances, new technological developments, new scientific understandings, or new data on the costs and benefits of complying with the rule, the EPA now suggests this rule has grown outdated or ineffective, and warrants another review.

In fact, the only reason EPA gives for targeting this rule is that it had received complaints about the regulation. While both the public and regulated businesses may be excellent sources of information on when changed circumstances or new data on regulatory benefits or burdens provide a legitimate reason for retrospective review, changing a rule simply because the regulated party does not care for it and complains loudly about it is a bad basis for policy.

A large number of other rules identified for review in both the EPA’s plans and other agencies’ agendas concentrate on opportunities to reduce paperwork burdens by simplifying reporting requirements and allowing electronic data collection. While these are certainly worthwhile efforts, President Obama’s call was about more than letting businesses submit their permit applications online. 

It was supposed to be a request for agencies to look broadly for the chance to improve the effectiveness and efficiency of rules. It would have been better to also look for cases where new technology has reduced compliance costs and a stronger rule could deliver more net social benefits, or where economic circumstances have changed and point to the need for a more flexible approach to regulation. 

By concentrating too much on the admittedly low-hanging fruit of paperwork reductions, agencies risk missing opportunities to pick reviews that might deliver even greater gains to net benefits.

There are some bright spots. For example, the EPA has long been notoriously slow in reviewing certain air quality standards as required by statute; the agency’s proposal now refocuses on prioritizing the most important of these reviews and completing them. The EPA also occasionally seems open to the possibility of expanding a rule based on a retrospective analysis; it noted that it’s considering expanding current protections on pesticide exposure. 

The EPA’s plan is also commendable for encouraging the use of the latest scientific methodologies and newer regulatory techniques, like disclosure, to increase the effectiveness of its regulatory programs. In line with the president’s executive order, the EPA does aim to improve transparency and promote innovation. Yet overall, the federal agencies’ initial proposals on retrospective review read more like a series of small gifts to business than a truly balanced approach for reassessing its existing regulations.  

The EPA and the other agencies still have a lot of work to do to develop a more balanced, meaningful, and long-lasting plan for retrospective review.

In his vision of an America transitioning away from fossil fuels, Jon Wellinghoff, the chairman of the Federal Energy Regulatory Commission, sees information technology as the basis for tremendous financial and employment opportunities. And with the right policies and incentives, this could happen soon. But in our current political reality, it feels like light years away.

Speaking on the future of American energy in the United States at Princeton recently, Wellinghoff got into the details of the technologies, many sitting on the shelf today, that could change individuals’ use of electricity and fuel — and would change some of how America does business for the better.

Wellinghoff talked about car batteries charged in garages that could help balance the electricity grid. The grid could temporarily draw electricity from these batteries to meet shortfalls in supply, saving money and pollution at the same time. Cars would be fully charged when owners need to hit the road, and there would be some extra cash from the juice they sold.

The technology exists to put this into action in the short-term, but the lack of government policy and financial incentives serves to scare off major investors.

There are real economic and job creation opportunities from the marriage of information technology and the need to update our energy system. Smart metering could help homeowners and businesses manage electricity consumption; new information intensive transmission systems could tap into the vast wind potential in the central United States; distributed generation could help cut down on transmission waste. But without the right political leadership to put enabling infrastructure in place, the potential of these projects remains locked up.

Getting investments in these kinds of game-changing technologies doesn’t necessarily require comprehensive climate legislation (though, of course, that would help). As has recently been discussed, cutting subsidies for fossil fuel and using the money to support efficiency or cleaner energy would be a good early step. So would stronger air quality regulations or a national renewable energy standard.

But sometimes it seems we are nowhere near where we need to be politically even for a smart but watered-down energy plan. The green agenda has been kicked back 30 years, with groups forced in to a defensive position to protect the Clean Air Act (and undergoing a big internal reassessment on strategy). Instead of incentivizing new ways to jump start some economic activity, the political discourse can’t even make room for established scientific findings on climate change or (absurdly) the direct health effects of air pollution.

Wellinghoff is not suggesting that the transition away from fossil fuels will be completely painless — those who deal in dirty power will feel the pinch. But in his view, a cleaner and smarter energy infrastructure is foundational to long-term economic growth and, in the medium-term, the massive project of updating our aging system will create a world of private sector opportunities.

So why are we focusing on the few likely losers of a move toward cleaner energy — the coal mines and dirty power plants that will have to shut down — and not the rest of us who will benefit? That’s a question we must now pose to our elected officials. Otherwise visions of the future like Wellinghoff’s will fall away from our grasp and become just an echo to remind us of how far we are from change.

In a recent House Energy and Commerce Committee climate hearing, Rep. Ed Markey (D-Mass.) jokingly asked if some of his fellow colleagues were going to overturn the law of gravity, “sending us floating about the room.”

It seems funny until you realize that it’s in response to a disturbing trend in Congress of misusing, manipulating, or ignoring scientific facts and academic research. As Lisa Jackson, the head of the EPA, put it, if they keep it up, “[p]oliticians overruling scientists on a scientific question would become part of this committee’s legacy.”

Just one example: in another Energy and Commerce Committee hearing last week, Rep. Michael Burgess (R-Texas) disparaged the link between greenhouse gases and increased asthma rates due to higher temperatures, saying this about what causes his own flare ups: “It’s horses, it’s dogs, it’s cats … but it’s not carbon dioxide. It never has been; it never will be. I exhale carbon dioxide every time I take a breath.” 

Burgess’s comments about asthma and greenhouse gas obscure the issue. Scientists do not claim that inhalation of greenhouse gases causes respiratory issues. Instead, higher temperatures mean more ground level ozone, longer pollen seasons, and more mold allergies. That is how CO2 is linked to respiratory problems. Burgess, who is a medical doctor, should be able to figure this out.

The committee subsequently voted three separate times to overturn a scientific finding on the dangers of global warming.

These anti-science bromides are often accompanied by claims about standing up for the best interests of blue-collar workers and middle class Americans. In the same hearing, Rep. Joe Barton (R-Texas), accused scientists of having “a conclusion and try to make the facts fit,” and worried that the U.S. economy shouldn’t be put in a “straitjacket because of a theory that hasn’t been proven.”

But it is often big business that stands the most to gain when science is ignored. Environmental regulations often generate massive benefits for the public (a recent analysis shows a 20 to 1 ratio for air quality rules), with firms in polluting industries paying a fraction of that amount to clean up their act. Because cleaner air, or a stable climate, has less effect on their bottom lines, polluters disregard the outsize public benefits and complain mightily about their compliance costs, giving backup to politicians who question the link between environmental protections and the health of the public.

Skewing public opinion on scientific realities is a cheap way to fight public health protection.

Often, the details are technical, findings are presented in the midst of in-depth statistical analysis, and the scientific conclusions are necessarily tentative. Confusing the public by scrambling or misrepresenting the facts is easier than trying to fight a rule that everyone acknowledges would protect public health.

Climate change is certainly a complicated issue with many unclear facets. Even scientists and economists who are experts in the field find interpreting the data to be a challenge. But to ignore the worldwide scientific consensus that there is a problem is dangerous. And talking down to the public by misrepresenting research is a cynical and shortsighted way of running our government.

The regulations will require the installation of scrubbers at plants like this one.Photo: Duke Energy

In this version, revised in the face of significant political backlash, the rules were made less stringent to lower compliance costs. Compared to an earlier draft of the rule, emissions limits for many pollutants are more forgiving, and some sources are exempt from specific limits and only need to perform a “tune-up.” 

As a result, EPA estimates the annual implementation costs will drop by nearly $2 billion dollars. It will be interesting to see if this move has any effect in preempting criticism from industry and members of Congress opposed to environmental and public health protections.

That is unfortunate because, in this case, lower compliance costs for industry raises the price that the American public pays in exposure to harmful pollution. As David Roberts noted last week, they will have to pay for more doctors’ visits, the costs of more missed work days, and in some cases, more untimely deaths.

For almost every hazardous pollutant covered by the regulations, the revised rule permits more emissions than the original proposal (though certainly still a reduction from the business-as-usual status quo). For example, instead of cutting 16,500 pounds of mercury per year, the new rules cut just shy of 3,000. These are significant changes that may give those companies a discount, but the bill is ultimately paid by the public.

As we noted in our comments to EPA, in order to maximize net benefits and get the most bang for taxpayers’ buck, standards from last year’s proposal would have to be more stringent, not less. Some options to increase stringency would have even saved businesses money in the long run. For example, we advised EPA to expand a requirement for energy efficiency audits, so more sources would gain timely information about cost-effective cuts they could implement; EPA declined to strengthen this provision.

EPA is advertising that the new rules cut down on costs with no negative effect on benefits. But this isn’t due to the rule change; it’s due to a more precise economic analysis — if this were applied to the older rule it would likely display even more economic upshot from stronger protections.

After nearly a decade of study on this issue, EPA is right to move forward with these rules. They are cost-benefit justified and will go a long way in cleaning the air, keeping American’s healthy, and generating net economic benefits. 

But it should be noted that the discrepancy between the cost savings from the new version of the rule isn’t free money for companies: The difference is paid by the public who will have to deal with doctors, hospitals, and in the worst cases, funeral expenses. There are true costs of allowing pollution to go unchecked. 

Speak up!Photo: theparadigmshifter

But to augment that advocacy, it is equally important for greens to engage in the regulatory process, which offers a refuge from the dysfunction of political discourse. Because of the legal structure that undergirds it, it is one of the few bastions in American government where truth can trump rhetoric.

Whenever a federal agency proposes a rule it must, by law, allow time for the public to give feedback. This is an opportunity to raise serious concerns, insert new ideas, or provide substantive support.

The legal weight behind this public comment process makes its use particularly important. Agencies must consider reasonable comments they’ve received, or risk being found arbitrary and capricious during litigation. As a result, agencies devote significant portions of final rules to discussion of issues raised by commenters.

Industry and other groups that oppose regulation often submit comments that focus on the costs of regulation. It is equally important for greens to argue that adequate attention musts be paid to the economic benefits of protecting the environment and public health. If that point of view is not put forward, it is less likely to be part of the conversation.

When rules are proposed, environmental advocates can help fill in the blanks and provide a fuller picture of its impact. This is not always an easy task — it requires significant legal, economic, and scientific expertise to counter the sophisticated arguments industry groups make. It is also a time-consuming endeavor as regulations can take years to play out.

But devoting resources in this forum pays dividends because the requisite for fact-based decisionmaking is so entrenched and because the potential gain is so great.

For example, the EPA and the National Highway Traffic Safety Administration (NHTSA) have been working together to improve fuel efficiency and reduce greenhouse gas emissions from cars. In May of last year, the agencies issued an early draft that tightens standards for vehicles that come out between 2012 and 2016 model year vehicles, but then really clamps down on emissions from model years 2017 to 2025. The rule will make a major dent in U.S. greenhouse gas emissions, improve public health, and keep a big chunk of cash in consumers’ pockets.

But when the agencies start releasing the first drafts of the rules for public comment (probably this summer) the auto industry may be quick to argue that people might not like smaller vehicles, or less horsepower. Green groups should be prepared to weigh in with their side of this story: that the environmental and economic benefits of the steeper emissions cuts outweigh any lost consumer welfare.

If all of the most powerful arguments are presented by automakers, it weakens the ability of the agency to move forward with tighter rules. It is up to environmental advocates to provide a counterweight of equally hefty information.

This rule started off strong — but sometimes proposed rules are too weak and need to be strengthened. Other times they are irredeemable and should be scrapped. But in every scenario, there is a role for environmentalists to play.

Grassroots campaigning and engaging in the daily back-and-forth of the political process are essential, but participating in the long and often tortured journey as regulations are adopted is also crucial. And while advocates must often pry their way into closed-door political negotiations, the public comments process creates an entry point for engaging in rulemaking at the most substantive level, when the best policy (not just the best connected interest group) stands a chance of coming out ahead.