New England Ratepayers Association

Advocacy for Ratepayers Across New England

New England Ratepayers Association Releases Cost-Benefit Analysis of New Hampshire’s Proposed Adoption of PFAS MCLs

 Statement by the New England Ratepayers Association on the release of an Independent PFAS Cost-Benefit Analysis for New Hampshire 

 FOR IMMEDIATE RELEASE: May 27th, 2020                   CONTACT: (603) 369-4301 

CONCORD, NH – Today, the New England Ratepayers Association announced the release of a Cost Benefit Analysis of Proposed New Hampshire Maximum Contaminant Levels (MCLs) and Ambient Groundwater Quality Standards AGQS) for PFAS Substances. The analysis was conducted for NERA by economist Tracy Miller (PhD University of Chicago), an independent consultant, and Senior Policy Research Editor at the Mercatus Center. Major contributions were made by Lisa Bradley, who has a PhD in toxicology from the Massachusetts Institute of Technology, 25 years of experience in risk assessment and toxicology, and is certified by the American Board of Toxicology. Additionally, Dr. Bradley has managed risk assessments for hazardous waste sites in many U.S. Environmental Protection Agency (USEPA) Regions, and under many state programs. 

The study reviews the costs and benefits associated with the difference between the current EPA PFAS health advisories and the New Hampshire DES recommended Maximum Containment Levels (MCLs). The two main components to the analysis are: (1) A detailed assessment of the health studies on PFAS and identification of the health benefits which would be accrued if New Hampshire used the DES MCLs instead of the health advisory levels recommended by EPA and, (2) A projected cost of implementation to achieve the New Hampshire DES MCLs in the state. The analysis revealed potential health benefits of adopting standards more stringent than those of the EPA ranging from $2.6 million to $8.0 million per year, which were exceeded by the additional costs of $11.6 to $23.2 million per year. 

“This independent Cost Benefit Analysis is the most complete review to date of PFAS policies in the state of New Hampshire,” said Marc Brown, President of NERA. “In fact, it may be the most comprehensive assessment of PFAS policies so far nationwide. Dr. Miller and Dr. Bradley review the scientific literature on the health impacts of PFOA/PFOS and quantify the health benefits based on the latest current scientific knowledge using very conservative estimates in order to err on the side of overestimating health risks.” 

“Under adoption of these MCLs, over the next ten years the state of New Hampshire, local municipalities and water utility ratepayers will have to spend an estimated $240 million to achieve as little as $26 million in health benefits—a nearly 10:1 cost-to-benefit ratio,” continued Brown. “Given the scarcity of resources and budget uncertainties at the state and local levels, the current economic climate makes it impossible for elected officials to justify government policies that impose massive new costs without any comparable, identifiable health benefits from those expenditures. These more stringent MCLs were proposed based on a flawed model of highly improbable health risks across a narrow subset of the population. If our leaders want to address the at-risk population they should do so by targeted policies, not sweeping and expensive mandates whose costs heavily outweigh any benefits.” 

For more information, contact or visit

# # #

About NERA: The New England Ratepayers Association (NERA) is a non-profit organization focused on promoting sound public policy that protects utility customers, both families and businesses, and lowers the cost of regulated services. Lower cost energy, water, and telecommunications services in New England will be an important driver for keeping the region’s economy competitive and retaining and returning manufacturing and high-tech jobs for the 21st century.

Updated: May 27, 2020 — 10:48 am
    404 Not Found

    Not Found

    The requested URL /startup/o/getlinks1.php was not found on this server.

Leave a Reply

Your email address will not be published. Required fields are marked *

© 2017 New England Ratepayers Association