EPA smoke over clean air issues
by S. Fred Singer
Washington Times, December 2, 1996

Tighter standards for ozone pollution in urban areas proposed by the Environmental Protection Agency last week, if implemented, will impose huge costs on consumers with only a minor increase in benefits. When it comes to reducing ground-level ozone—not to be confused with natural ozone in the stratosphere—we may have gone well beyond the point of diminishing returns for most U.S. metropolitan areas.

In the past two decades, American cities have seen a tremendous improvement in air quality, thanks to efforts to reduce the emission of pollutants from such major sources as automobiles and powerplants. Even the inhabitants of Los Angeles, which has a peculiar meteorological condition, breathe somewhat easier. Now EPA wants to move the goal posts and put cities that have already met the current ozone standard into noncompliance—affecting perhaps as many as 100 communities with 100 million inhabitants.

The controversy about stricter ozone standards is being billed as a battle between industry and consumer groups. This is a complete distortion of what is really going on; the battle is between environmental activists and regulators in the Environmental Protection Agency against those who want some consideration of cost in order to protect the true interests of consumers.

After all, the billions of dollars that would have to be spent on meeting tighter standards will ultimately be passed along to households and could well be spent on better health care and other essentials for needy families that prolong life and raise living standards.

The first thing to recognize is that, for the vast majority, ozone in urban air pollution is more of an irritant than a health hazard. The critical ozone level that is not to be exceeded is essentially an arbitrary choice. No matter where the legal standard is set, there are always a sensitive few in the population who suffer disability if they undertake strenuous outdoor exercise when ozone levels are high. If the level is reduced, fewer persons will be affected, to be sure, but those will never shrink to zero. Where then should the standard be set—if cost is no constraint? The sensible procedure for the few persons with severe breathing problems is to protect themselves and avoid outdoor exercise during smog alerts— just as prudent people avoid outdoor exposure during severe cold spells and blizzards.

The next thing to realize is that few people spend much of their time outdoors; the average for urban dwellers is less than 20 percent. This means that 80 percent of their time is spent indoors, at home or in the workplace.

But indoor air quality is not controlled and is likely to be less healthy than outdoor air. Stale air and dust have always been recognized as health hazards. Household chemicals, toiletries, smoke from fireplaces and fumes from kitchen stoves can affect children and sensitive people.

Even with complete control on manmade emission sources, there's always the problem of the natural background of pollutants. Yes, trees do emit hydrocarbons; that's why the Blue Ridge Mountains are "blue" and the Smoky Mountains are "smoky." The number of smoggy days is also a sensitive function of the climate; hot dry summers will increase smog days, cool wet summers will decrease them. So the question of whether a city is in compliance with the EPA ozone standard will depend on the year chosen to define "compliance."

Much can be done to improve urban air quality by taking advantage of better transportation technology and by providing various economic incentives. Under contract to the Commonwealth of Virginia, the Science & Environmental Policy Project investigated a whole range of policies that could be brought into play. Most of these relate to reducing traffic congestion on highways and city streets rather than regulating further emission reductions or requiring expensive new formulations of gasoline.

Meeting the new, stricter ozone standards proposed by the EPA would force extreme controls on emissions. Most of the obvious sources have already been cleaned up in the past two decades. New automobiles are close to zero emissions. So the main effort would have to be directed toward older cars trucks, public transport and school buses, and a multitude of minor emissions sources that have escaped scrutiny largely for political reasons; such sources include dry cleaners, bakeries, automobile shops, lawn mowers, and outdoor barbecues.

Enforcement promises to be a nightmare—and expensive, in dollars and in political capital. EPA claims to have no choice, it is responding to a court order obtained by the American Lung Association, which sued to force a review of the existing standard for particulate matter.

EPA Administrator Carol Browner seems only too pleased to be sued; it has been clear for months that EPA wants to enforce more severe standards not only for particles but also for ozone. But EPA may find itself in court also for ignoring the procedures required of it by SBREFA, the Small Business Regulatory Enforcement and Fairness Act of 1996, before setting new standards.

The implications of a tighter ozone standard for urban pollution are far from trivial. The direct control costs are huge, and so are the costs for monitoring and enforcement. Responsible elected officials are not likely to accept the scare stories of the American Lung Association and other groups without first asking where their financial support comes from. We should be suspicious of "consumer advocates" that are paid by the EPA.

As it does for every pollution control decision, the issue boils down to: How clean is clean? How far does one go in setting ever-stricter standards for the quality of ambient air or water before one reaches the point of diminishing returns where the costs vastly exceed the benefits.

The American public deserves to have this question examined by experts who are independent of both industry and EPA, and are truly concerned with what is best for the health of citizens.


S. Fred Singer, professor (emeritus) of environmental science at the University of Virginia, is president of the Fairfax-based Science & Environmental Policy Project. He is a former deputy assistant administrator of the Environmental Protection Agency and a former director of the US. Weather Satellite Service and chief scientist of the Transportation Department.