Last Thursday, the United States Environmental Protection Agency announced plans to lower its standard for urban ozone, popularly known as smog, to a level between 60 and 70 parts per billion. This would be the fourth such reduction since the implementation of the Clean Air Act in the 1970s.
The original standard was 120 parts per billion, a goal that was reduced under the Clinton administration to 80 parts per billion in 1997 and further reduced under the Bush administration to 75 parts per billion in 2008. The Clinton-era reduction in the smog standard was widely-hailed among environmental groups, while the further reduction during the Bush administration was roundly criticized by those same groups.
“Using the best science to strengthen these standards is a long overdue action that will help millions of Americans breathe easier and live healthier,” USEPA Administrator Lisa Jackson said in a press release. The “best science” refers to the advice of the EPA’s Clean Air Scientific Advisory Committee (CASAC) a purportedly independent board of scientists who participate in the process of setting increasingly more stringent definitions of clean air.
However, USEPA is not supposed to base its decisions solely on CASAC’s recommendations. According to the EPA, the “scientific community, industry, public interest groups, the general public and the Clean Air Scientific Advisory Committee (CASAC)” all get to play a role whenever the Agency sets new standards. That formula, which every president from Nixon through Bush has employed, has been effectively tossed out the window by the Obama administration, which has chosen to defer to CASAC.
The fact that CASAC picked the lowest proposed standard as the best proposed standard should come as no surprise. Of the seven CASAC members four are engineers, modelers and one eco-systems analyst, all of whom are wholly unqualified to opine on issues regarding public health. The remaining three have a vested interest in seeing lower smog standards promulgated, since all are academics whose research funding depends on air pollution alarmism. CASAC chair Dr. Jonathan Samet, for example, has spent a great deal of his professional career decrying secondhand smoke and is also an advisor to the American Lung Association (ALA), an organization that spends a great deal of time and money lobbying for more restrictive smog standards. Another CASAC member, Dr. Helen Suh MacIntosh, was once the answer lady at treehugger.com.
EPA estimates the costs of implementing new smog standards at $19 to $90 billion, but the Agency hastens to add that the benefits will total $13 to $100 billion. The benefits consider only avoided costs, in terms of reduced medical care, worker productivity (due to a reduction in sick days) and the like. Factors like increased unemployment, due to reduced profit margins in the manufacturing sector, and the increased cost of goods and services associated with a tighter standard are not part of the analysis. Further, when estimating the cost of compliance, the EPA acknowledges that it factors is the unknown cost of installing controls that haven’t yet been invented yet.
One of the biggest reasons that EPA and organizations like ALA say that this new, drastically more stringent, standard is necessary is to prevent childhood and other forms of asthma. In the last thirty years, data compiled by the National Center for Health Statistics indicate that childhood asthma as increased by over 150%. However, in that same period, according to USEPA monitoring data, smog concentrations have decreased by 25% nationwide.
If adopted, the new smog standards will significantly increase the cost of living for millions of Americans. They will be forced to purchase low-vapor pressure, and therefore more expensive, special formulations of gasoline. Vehicle inspection programs, ubiquitous to large metropolitan areas, will spread to mid-sized metropolises. Remotely-located power generation facilities, heretofore untouched by smog rules, will have to install and maintain expensive new control systems and will pass that cost along to consumers. Perhaps most distressing of all, the beleaguered American manufacturing sector, which has so far managed to escape the most painfully expensive parts of clean air regulation, will face new mandates that will make it even more difficult to compete against plants overseas that are not similarly constrained.
But, for the Obama administration, there is nothing to lose. At the absolute earliest, the new smog standard will require industry compliance in 2014. Given the inevitable legal challenges and regulatory inertia that accompany any rule making of this type, the full effects won’t likely be felt until 2016 or beyond. Thus, the president has once again written another I.O.U., one that he won’t have to cash, but will be rather deferred to another generation that will be faced with the Hobson’s choice of paying the bill or of rejecting the “consensus” that Obama has embraced.