Saturday, April 22, 2000

EPA defends air rules

Report: Costs well worth benefit

BY Ben L. Kaufman
The Cincinnati Enquirer

        A little-noted report by the Environmental Protection Agency (EPA) rebuts industry assertions that tough new limits on air pollution don't pay.

        EPA predicts a $110 billion annual benefit to national health, the environment and agriculture in the year 2010 with a $27 billion compliance cost.

In the year 2010, aggressive reductions in air pollution would prevent:
• 23,000 premature deaths from lung problems.
• 1.7 million asthma attacks or aggravations of chronic asthma.
• 67,000 incidents of chronic or acute bronchitis.
• 91,000 attacks of shortness of breath.
• 4.1 million lost work days.
• 31 million activity days in which Americans didn't have to hide from pollution.
• 22,000 hospital admissions for respiratory-related illnesses.
• 42,000 hospital admissions for pollution-related heart/blood problems.
• 4,800 emergency room visits for asthma.
• Damage to crops, buildings and the clarity of air in such places as national parks where views draw visitors' dollars.
Source: U.S. Environmental Protection Agency <
        That's a 4-to-1 ratio in favor of cleanup.

        EPA attributes most of that saving to 23,000 fewer premature deaths from inhaling soot and other tiny particles formed from gases emitted by vehicles, power plants and other industries.

        Similar, albeit smaller annual benefits and costs will accrue along the way, EPA added.

        All of this was in the report, The Benefits and Costs of the Clean Air Act Amendments of 1990, submitted to Congress on Nov. 15.

        The prediction was cheering, but “it may be an underestimate” of what tougher standards might achieve, Dr. George D. Leikauf, a professor of environmental health at the University of Cincinnati, said Wednesday. He said an estimated 70,000 Americans die each year from lung disease attributed to inhaled particulates.

        Sierra Club and Rivers Unlimited activist Marilyn Wall agreed. “It was always cheaper for industry to look at the costs to them and not the costs to the environment, the people downwind, the people downstream.”

        The new numbers, Ms. Wall, of Glendale, said, show that industry and developers “need to protect the environment because protecting the environment is good for the economy.”

        EPA officials said they expect the report to draw more attention when legislators debate reauthorization of the 1970 Clean Air Act.

        Compared with the first two decades of Clean Air Act enforcement, when each dollar spent removed gobs of pollution, the public policy debate has focused on whether further reductions are worth the expense.

        Few people in pollution-creating industries — especially those operating coal-fired power plants — were familiar with the report.

        Jayne Mardock, national director of the Clean Air Network in Washington, D.C., said EPA's calculations would draw more attention this year and after the November election, when Congress debates the reauthorization of the Clean Air Act and its 1990 amendments.

        However, one critic, Anne E. Smith, of Charles River Associates in Washington, D.C., reviewed the report for General Motors and she didn't like what she found.

        She faulted EPA for reducing all costs and all benefits to a summary figure in 2010.

        A member of EPA's outside Advisory Council on Clean Air Act Compliance Analysis, Ms. Smith analyzed costs and benefits of each pollutant and suggested that summary figure could lead to overzealous controls on the wrong sources.

        Instead, she suggested a different regulatory approach for each contaminant.

        Two inches thick, EPA's report was the agency's first attempt to predict the economic impact of the amendments.

        An earlier agency report concluded that the pioneering Clean Air Act produced $20 in benefits for every $1 spent on pollution control between 1970 and 1990 when the air was dirtier.

        In the 1990-2010 study, EPA focused on volatile organic com pounds; nitrogen oxides; sulfur dioxide; carbon monoxide; coarse particulate matter; and fine particulate matter (PM2.5).

        Although nitrogen oxides are most commonly associated with smog and sulfur dioxide is the key ingredient in acid rain, both also contribute to creating troubling particulate in the atmosphere.

        Much of the report involves EPA explanations of how it chose the numbers it used.

        • Emission estimates anticipated growth in population, transportation, electric power generation and other economic activity.

        • Estimates of direct costs included research and development, equipment costs, and operation and maintenance expenses.

        • EPA excluded such potentially substantial secondary costs as lost jobs among miners if compliance meant switching from coal to natural gas.

        • Also excluded from benefits were anticipated reductions in some hard-to-quantify but pollution-related illnesses.

        Even so, EPA said those costs were sufficient for a “good initial measure of the effect” of the 1990 amendments on the economy.

        The summary figure — a a 4-to-1 benefit over cost — EPA reported showed wildly differing benefit/cost ratios, depending on varying assumptions included in its calculations.

        At the low end, costs equaled or slightly exceeded benefits. At the high end, benefits exceeded costs by nine or 10 times.

        EPA adopted the 4-to-1 ratio as most likely.

        EPA based its analysis on contrasting assumptions:

        • No controls beyond those in place in 1990.

        • Controls that appeared likely after adoption of the 1990 amendments.

        The agency estimated an after-cost total benefit of $510 billion from 1990 to 2010, based largely on fewer premature deaths, reduced respiratory problems and lost workdays. The range, howev er, was from costs exceeding benefits by $20 billion to benefits exceeding costs by $1.4 trillion.

        Again, EPA settled on the “central” estimate.

        The shocker — neither included nor expected — was a subsequent federal court decision spiking tough new standards for ozone and fine particulate on grounds that EPA overreached its authority.

        Those were the kinds of stringent limits assumed by EPA for its benefits/cost calculations.

        EPA also estimated another $530 billion benefit — after costs — from 6.3 million fewer skin cancer deaths if pollution controls preserve and restore ozone in the stratosphere. However, EPA said, those benefits are very iffy because they are spread over 175 years.

        EPA conceded that its best efforts remained estimates, but the report reflects what the agency called “the best currently available science and the most up-to-date tools and data we had at our disposal — and the most reasonable assumptions we could adopt — as each step of the analysis was implemented.”

        When better analytical tools and data become available, EPA said, the assumptions, calculations and conclusions should be redone.

        One particularly important assumption involved “correlations between increased air pollution exposures and adverse health outcomes found by epidemiological studies.”

        These, EPA said, “indicate causal relationships between pollutant exposures and adverse health effects.

        “Future research may lead to revisions in this assumption as well as other key assumptions, data, and models we use to estimate the benefits and costs of the Clean Air Act.

        “Such revisions may in turn imply significant changes in the estimates of Clean Air Act costs and benefits presented here and in past and future assessments.”


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