Three years ago I wrote a draft post about the cost of PCB removal in schools, but then never finished it. What reminded me about it was a recent article by Robert Herrick et al in which he developed an estimate of the number of schools in the US that may contain PCBs in caulk. His estimate is presented as a range: 12,960 to 25,920 schools.
Herrick speculates that this range is likely to be low, and I agree. My own estimate from 3 years ago was closer to 43,000. Given the statistical limitations of our methods, trying to extrapolate from small possibly non-representative sample sets to the entire population of US schools, our numbers are actually pretty close.
However, what particularly interests me is the next step in the analysis, estimating the potential costs of remediating all those schools. This is a step that Herrick, perhaps quite wisely, did not take. With that introduction, what comes next is a lightly edited version of my 2013 unpublished post in which I do try to estimate possible costs of removing PCBs from schools nationwide.
Did EPA consider compliance costs for municipalities in its development of the PCB regulations?
When the USEPA proposes new regulations, two of the questions Congress and the public usually ask are: “How much will it cost to implement these new requirements? And is it worth it?” To answer these questions, EPA will typically conduct a “cost-benefit analysis.” This analysis is supposed to demonstrate the advantages of EPA’s proposed actions and explain how the benefits are worth the cost.
These analyses aren’t always 100% accurate because it can be hard to know all the exact costs associated with changes just as it can be difficult to anticipate all the benefits. None-the-less, the cost-benefit analysis is a good-faith effort to consider the positives and the negatives associated with a proposed regulation. Developing these analyses is one reason EPA employs economists.
Surprisingly though, EPA’s 1998 PCB Mega Rule contained no cost-benefit analysis; there was not a single sentence that spoke to the issue of the costs of these regulations even though they have imposed huge financial burdens on the public and private sectors. To give EPA some benefit of the doubt, much of that burden is only now becoming evident as the full extent of PCBs in schools and other buildings is being discovered.
Isn’t it worth any cost to protect schools and children from any risk?
There is no answer to this question that will satisfy everyone, but as a society we can take steps to limit the negative impacts or real demonstrable risks in our schools. By real risks I mean threats that have been shown to actually harm schools and children under real world conditions. Examples from the top of my list of demonstrated risks would include cars and guns, but PCBs in building materials wouldn’t be on my list at all. Why aren’t PCBs on my list of threats? The answer is simple, there are no credible scientific studies showing harm to the health of schools, students or staff despite the presence of PCBs in buildings for over 60 years.
But in this post I want to focus on the financial burden the PCB regulations are putting on schools and public education. As a former board of education member in a small New England town, I can tell you first-hand about the battles to secure funding for public school systems. Every year costs go up and every year vocal groups want to pay less tax and accuse administrators of mismanaging funds.
Anyone who thinks that a typical municipality can come up with extra millions of dollars to pay for PCB removal in a school ought to spend some time on their local board of education. There isn’t extra money to do PCB remediation in a town’s budget; that money is going to come right out of the education budget. The harm done to a typical school system by redirecting funds from educational programs to PCB removal is much greater than any harm done by the PCBs.
So, did anyone at EPA think about PCB remediation costs? No? Let me help.
So back to the threshold question, did EPA think about the financial burden it was placing on municipalities when it retroactively banned PCBs in building materials including those already in schools? If they did, I can’t find any evidence of it. To be helpful, I am providing below a very rough estimate of the possible national cost of removing PCBs from US K-12 schools.
The approach I use is a method I picked up in college called “the back of the envelope” approach. I’ll leave developing a more rigorously researched approach to the economists at EPA; it’s been my experience that the back of the envelope approach often gets you remarkably close to the right answer.
The Back of the Envelope Accounting Office
From a quick Google search I discovered that there are approximately 132,000 private and public K-12 schools in the US. As a somewhat educated guess, let’s assume that 33% (one in three) of these schools have PCBs in at least one building. Further, let’s assume that the average cost of testing and removing PCBs from an average school is $2 million. Some schools will cost less to remediate, but many will cost much more. Some quick multiplication takes us to a cost of $87 billion to remove PCBs from all public and private K-12 schools. I recently heard Speaker of the House Paul Ryan say that $80 billion is a lot of money even in Washington.
There is obviously a lot of uncertainty in this estimate. My guess is that I underestimated the actual number of affected school buildings and that I also underestimated the average cost per building to remove PCBs. None-the-less it is a starting point and I am going to use it below for a few simple comparisons.
What do we spend per year on Public K-12 Education?
How much is an $87 billion PCB removal cost in terms of the nation’s K-12 education budget? According to the National Center for Education Statistics, public school districts had a total budget of $610 billion for the 2008-2009 school year. This amount historically increases by only 1-2% per year so I am just going to use the 2008-2009 budget numbers because the uncertainty in the other values I am using in this analysis likely swamp out the small change I would make to adjust the school budget number. Of the total K-12 spending budget, $519 billion went to current education, $65.9 billion went to capital construction projects, $16.7 billion went to cover interest payments and $8.5 billion went to other costs.
Cost of Getting PCBs out of Public Schools
The $87 billion for PCB removal is for public and private schools, and about 75% of all K-12 schools are public. So assuming the costs for PCB removal are the same for either public or private schools, the cost for removing PCBs from just public schools will be about $67 billion. This means the PCB removal cost would be about 11% of one year’s total national education budget or about 13% of the annual operating budget. However it would be about 100% of the capital construction projects for a year.
This analysis is obviously too simplistic, because some school systems will not have any PCBs, and some will likely have a lot. There is no apparent way for school systems across the country to even out these costs nationally among themselves, although there may be some ability for states to even out the costs within a state.
Still it highlights what a large issue PCBs in schools can be for a municipality and it clearly answers why most school administrators want to stay as far away from testing their schools for PCBs as they possibly can.
Two final thoughts for this post:
First and foremost – If there were credible scientific evidence that PCBs in schools were actually causing harm to the health of students or staff I would be fully supportive of decisions to get them out regardless of the cost. But this evidence does not exist and not for lack of trying on the part of research scientists. The fact is that most students and staff receive significantly more PCBs daily in their diet than they do from being in school buildings. The 60+ years of history of PCBs in building materials has simply not turned up evidence of harm to the health of building users.
Second – The estimated $2 million per school PCB removal cost is potentially well short the actual average cost per school because in many cases schools simply cannot be made PCB free. Instead school buildings have been closed down with the children and staff reassigned to other schools.
In affluent communities the solution to this problem might be demolishing the old building and constructing a new one, but in more typical American communities it means a long-term loss of educational resources and a significant lessening of educational capacity as the old school building is shuttered and becomes a long-term reminder of what has been lost.
 “Review of PCBs in US schools: a brief history, an estimate of the number of impacted schools, and an approach for evaluating indoor air samples”; Herrick, R.F., Stewart, J.H., and Allen, J.G.; Environ Sci Pollut Res (2016) 23: 1975-1985.