Recent actions in Washington, D.C., make it clear that the era of big government is not over yet. Ignoring much of the advice of its own Scientific Advisory Committee, the Environmental Protection Agency (EPA) released a proposal last November calling for two significant changes in federal air quality standards. These changesone involving stricter standards on ozone and the other on particulate matterwill hurt U.S. competitiveness and cost workers jobs and income while producing questionable benefit for either health or the environment.
The proposed standards would more than triple the number of counties, mostly in eastern states like Michigan, that are designated as having unhealthy air. By EPAs own estimates, half the U.S. population lives in areas that would then be subject to new regulations on automobile use, power generation, lawn mowers, wood burning stoves, fireplaces and even barbecue grills. At least two dozen of Michigans 83 counties could be included.
A recent Grand Rapids Press editorial put it bluntly: "The standards themselves are breathtaking. One reduces the allowable ozone content of air . . . close to the level at which it occurs naturally." The EPAs own advisory panelthe Clean Air Scientific Advisory Committee (CASAC)claims that what the EPA wants done is just not possible to achieve.
In other words, in the view of competent professional scientists who advise the EPA, the tighter and very costly ozone standards proposed by the agency will produce negligible health benefits. So what is the agencys response? Put the evidence aside, and impose the standards anyway.
The other proposed standard would impose stricter limits on particles of airborne soot, dust, and liquids that are smaller than 1/28th the width of a human hair. Like most other states, Michigan has no monitoring system in place that would permit such minute measurements at this time. Russell J. Harding, director of Michigans Department of Environmental Quality, told researchers at Midlands Mackinac Center for Public Policy recently that "there is no agreed upon methodology for the monitoring of particles that small."
Perhaps a monitoring system that would do the job can someday be devised and implemented, but Harding says "the real weakness of the EPAs proposal is that the agency just has not made the scientific case. We have little reason to believe that after we spend all this money, well have anything to show for it."
Statistical studies attempting to correlate mortality with levels of small particles have led the EPA to conclude there is a correlation, but the lack of consensus by independent scientists reflects the uncertainty of these conclusions. Much more work needs to be done to prove a direct connection between minute particles in the air and the heart or respiratory problems of individuals.
The EPA projects billions of dollars in costs but billions more in health benefits from the new standards, derived from "cleaner air for everyone, particularly safer air for children, the elderly, asthmatics and persons with heart and other respiratory problems." However, many independent, professional, non-EPA scientists argue that the agency is overstating the benefits and undercalculating the costs. The problem is that the scientific evidence that might allow for reasonable estimates of costs and benefits just doesnt exist.
According to Michigan scientist Dr. George T. Wolff, CASACs chairman, the panel found that there was "no bright line which distinguishes any of the proposed [ozone] standards . . . as being significantly more protective of public health" than the current standards. While the panel agreed on the need for different measurement of ozone levels, it refuted the notion that the scientific evidence favors the imposition of tighter standards. Only four of the twenty-one panel members supported a level as low as that proposed by EPA for small particles.
EPAs proposals come at a time when much progress in reducing pollution has already occurred. Since the 1960s there have been significant reductions in U.S. air emissions, despite population and industrial growth. In the last ten years ozone is down 12 percent, sulfur dioxide down 25 percent, particulate matter down 20 percent and lead down 86 percent. More progress will come as many regulations already called for by the 1990 Clean Air Act Amendments are implemented in forthcoming years. This suggests that now is not a good time to impose new rules that promise great cost and dubious additional benefit.
EPAs failure to use proven scientific methodology is unnecessary and inexcusable. The agency should back away from its proposals and gather the required data that make a solid case for change. Meantime, Congress should reconsider the directives under which the EPA operates. For the sake of both the environment and the economy, it is time to make sure regulations have a basis in sound science.