Self-appointed protectors of the environment have a long history of advancing their agendas by postulating sinister threats to our children, distorting the views of mainstream science, and dismissing their critics as profit-hungry plunderers of public health. Advocates of more stringent "air quality" standards are keeping up the tradition. If they succeed, we will soon be harnessed with extraordinarily costly new regulations that could harm public health more than improve it.
When air is heavily polluted, human health suffers. Specific episodes throughout this century confirm that pollution can increase respiratory distress and, in some cases, even cause premature death. No argument there.
But we already have extensive air quality legislation in effectnamely, the Clean Air Act of 1970which has substantially reduced "particulate" and ozone pollution levels. The Environmental Protection Agency's (EPA) own data say so.
So the question at hand is not, as environmentalists like to pose it, "are we in favor of clean air or dirty air," but "will making the air standards even more stringent lead to improved public health?"
The EPA justifies its proposal to tighten clean-air standards by arguing that the new regulations would provide "additional protection for children and asthmatics." Yet, the only "evidence" EPA has that current ozone and particulate air standards are unsafe are statistical associations between (a) death rates and hospital emergency room admissions for respiratory diseases, and (b) local air readings. There are no data available demonstrating evidence that the current air standards are inadequate and making people sick.
In addition, the proposed new standards are based on absurd premises. For example, they assume we spend 24 hours a day exposed to the pollution concentrations measured at outdoor EPA monitoring stations primarily located on rooftops in urban areas. In reality, most Americansespecially in urban areasspend more than 85 percent of their time, on average, indoors. And there are significant differences between indoor and outdoor air pollutant concentrations.
At best it can be argued that the benefits of the new restrictions are unknown. But the costs of the draconian proposal are quite clear. EPA estimates, for example, range between $6.5 billion and $8.5 billion each year. Others place the figure much higher. The president's Council of Economic Advisers estimates that full attainment costs of the proposed new ozone standard would range from $12 billion to $60 billion. Another study concluded that the new standard would cost the city of Chicago alone from $2.5 billion to $7 billion annually.
These extraordinary costs would be absorbed initially by business and industrybut like all regulatory costs would eventually be passed along to consumers in higher prices for cars, gasoline, electricity and most other consumer products.
What would be the benefits for such an expenditure?
In a recent television appearance, a representative of the American Lung Association (who surely should know better) accused those who argued that benefits were purely hypothetical because scientific evidence of harm was so scant of emulating the tobacco industry's tactics in rejecting a link between smoking and lung cancer. This is analogous to comparing two bodies of evidence: one the size of an elephant, the other the size of ant. Eager to evade a focus on the paucity of science behind the proposal, this advocate declared victory by characterizing the debate as one of "corporate greed vs. children's health."
Asthma and other respiratory diseases are serious problems in the United States. But the proposed standards will not only fail to address these problems, but will divert time and resources away from public health solutions that will work.
Further, the new standards will cost so much that they could actually worsen public health by lowering living standards and reducing access to health care. Among the known risk factors for asthma are several factors associated with poverty: exposure to cockroaches and other indoor allergens, limited access to health care, and prematurity.
Just the other day, I received a letter from the public health commis- sioner of a small Ohio town asking if I could encourage scientists to speak out on the specious benefits and onerous costs of the EPA plan. He wrote: "Why is the health commissioner concerned about the local economy? Because, the EPA standards will very likely cause us to lose even more good-paying jobs . . . this translates, I fear, into a lower standard of living, more poverty, more people without health insurance coverage, and less access to health care for our low-income residents. We already suffer greatly from these problems without . . . the questionable new air standards. In effect I see the bottom line to be a worsening of our community health statuscommunities with higher unemployment suffer not only from worsening physical health but also more mental health problems, including rates of depression and suicide."
Has the EPA, while touting the purely speculative benefits of tighter air standards, considered the downside risk? This question demands an answer.
Dr. Elizabeth Whelan is president of the American Council on Science and Health, a New York based research and public health advocacy group.
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Open Letter Rejecting New Proposed EPA Air Standards
June 10, 1997
If It's Not Broken, Don't Fix It
Scientists Reject New Proposed EPA Air Standards
We, the undersigned members of the scientific community, urge the Environmental Protection Agency to withdraw its proposal to further tighten air quality standards.
Our nation already has extensive air quality legislation in effect namely, the Clean Air Act of l970, which has substantially reduced particulate and ozone pollution levels. We know of no data indicating that the current air standards are inadequate and are making people sick.
The costs associated with the proposed new EPA standards would be substantial. These costs would initially be absorbed by business and industry, and would eventually be passed along to consumers in higher prices for cars, gasoline, electricity and other consumer products. We feel that the EPA should refrain from advocating new, tighter standards and the associated costs until the agency has sound scientific evidence that such a regulation would improve public health. Moving ahead with regulations without scientific basis may cause unanticipated adverse societal and economic effects, including increases in unemployment and poverty, and therefore a loss of access to health care, which could actually jeopardize the state of public health.
If you would endorse this position, please send your name and affiliation to:
