Document ID: RIA-93307-2026-001 Date of Preparation: February 24, 2026 Preparer: Parent/Guardian of Subject A Subject: Female, DOB June 2022, Age 4 Residence: Zip Code 93307, Bakersfield, Kern County, California
1. Purpose and Scope
This analysis applies the methodology of OMB Circular A-4 to project health outcomes for one individual (Subject A) resulting from EPA's final rescission of the 2009 Greenhouse Gas Endangerment Finding, published February 18, 2026. The analysis period covers Subject A's projected lifetime from 2026 (age 4) through 2082 (age 60). All monetary values in 2024 dollars unless noted.
2. Baseline Conditions
Subject A resides in zip code 93307, Bakersfield, California. Bakersfield ranks first among 216 U.S. metro areas for year-round particle pollution (American Lung Association, 2024). The San Joaquin Valley has been out of federal compliance on air quality for 25 consecutive years. Pediatric asthma ED visit rates in the San Joaquin Valley run up to 2.6× the statewide average (Fresno County, 2016). California children ages 0–4 experience asthma hospitalization rates 3× higher than children ages 5–17 (17.3 vs. 5.9 per 10,000, 2022).
Subject A was diagnosed with moderate persistent asthma at age 3. She uses a daily inhaled corticosteroid and a rescue inhaler as needed. Current rescue inhaler use: 3–4 times per week.
3. Policy Scenario and Cost-Benefit Framework
The rescission eliminates the regulatory basis for greenhouse gas emission standards for on-highway vehicles. Per analysis by the Environmental Defense Fund and as cited in Inside Climate News, the rescission will produce up to 18 billion additional metric tons of pollution, up to 58,000 additional premature deaths, up to 37 million additional asthma attacks, and 26,000–92,000 additional ER visits nationally by 2055.
| Category | National "Benefit" (EPA RIA) | Cost to Subject A (2026–2055) |
|---|---|---|
| Vehicle technology savings | $1.1 trillion | — |
| Avoided EV infrastructure costs | $200 billion | — |
| Additional asthma exacerbations | Not quantified | 8–14 additional ER visits |
| Missed school days | Not quantified | 42–78 additional days |
| Reduced FEV1 lung capacity by age 30 | Not quantified | 4–9% permanent deficit |
| Monetized value of Subject A's health | $0 | $0 |
4. Discount Rate Analysis
OMB Circular A-4 prescribes discount rates of 3% and 7% for regulatory analysis. OMB has acknowledged that 7% "is not considered appropriate for intergenerational discounting." The rescission RIA applies both rates to a 2027–2055 analysis window. Applied to Subject A's projected health benefits:
| Subject A's Age | Year | Value of $1 Health Benefit (3%) | Value of $1 Health Benefit (7%) |
|---|---|---|---|
| 4 (current) | 2026 | $1.00 | $1.00 |
| 14 | 2036 | $0.74 | $0.51 |
| 30 | 2052 | $0.48 | $0.17 |
| 50 | 2072 | $0.26 | $0.05 |
| 60 | 2082 | $0.19 | $0.03 |
HHS values a statistical life at $13.6 million (2024). OMB's revised Circular A-4 specifies that children's values should be at least as high as those for adults. EPA's base figure, unchanged since 1997, is $7.4 million (2006 dollars). The rescission RIA monetizes neither. Health impact valuation: $0.
5. Sensitivity Analysis
Scenarios correspond to low, central, and high estimates of regulatory rollback pace and resulting pollution increases, per the American Lung Association range (9–37 million asthma attacks nationally; 26,000–92,000 ER and hospital visits nationally).
| Scenario | Rollback Implementation | Additional ER Visits (2026–2055) | Additional Missed School Days | FEV1 Deficit by Age 30 |
|---|---|---|---|---|
| Low | Partial | 8 | 42 | 4% |
| Central | Full, phased | 11 | 58 | 6% |
| High | Full, accelerated | 14 | 78 | 9% |
All scenarios assume Subject A maintains current medication access and insurance coverage. Scenarios do not model coverage interruptions, household energy cost increases, or compounding heat-ozone interactions beyond 2055. EPA's own analysis projects fuel price increases of 25¢/gallon by 2035, with total consumer fuel costs of $1.4–$1.7 trillion, exceeding the projected $1.3 trillion in deregulatory savings.
6. Limitations
This analysis was prepared by a private individual using publicly available data and EPA's published methodology. The preparer has a calculator, a child, and the ability to read government documents.
Population-level analytical frameworks introduce uncertainty when applied to individual cases not captured in standard confidence intervals. Individual-level projections for Subject A are illustrative of methodology and should not be interpreted as clinical predictions. Zip-code-level environmental burden data are derived from EPA's EJScreen tool and may not reflect block-group variation within 93307. FEV1 projections are extrapolated from published cohort studies of San Joaquin Valley children and have not been validated for individual prognostic use.
Preparer: Parent/Guardian of Subject A 93307
- The lawsuits are filed: Multiple public health and environmental organizations challenged the rescission immediately after publication, joining suits already filed in 2025, with Harvard's Salata Institute tracking the legal reasoning EPA used to sidestep its own scientific record.
- Former EPA staff dissent: The Environmental Protection Network, representing career EPA officials, submitted oral comments calling the RIA's 60 pages "not a serious assessment" and noting the prior vehicle standards alone produced over $96 billion in net benefits annually.
- The secret panel ruling: A federal judge found that the Department of Energy violated the law by handpicking five researchers who rejected scientific consensus to produce the report EPA cited in its initial proposal.
- The $13 billion baseline: California already spends an estimated $13 billion annually on asthma-related costs including medical expenses, lost school and work days, and premature death, with San Joaquin Valley children bearing disproportionate hospitalization rates that the rescission's additional pollution burden will compound.