A Clear Mistake

The Clear Skies Initiative, President Bush's big environmental bill targeting power plant emissions, appears to be stalled in Congress.  In an effort to get around this impasse, the administration now plans to implement similar provisions via EPA regulations rather than legislation.  Either way, this Republican attempt to go green will prove to be both bad policy and bad politics.<?xml:namespace prefix = u1 /> <?xml:namespace prefix = o ns = “urn:schemas-microsoft-com:office:office” />


The plan focuses on coal-fired utility emissions of nitrogen oxides (NOx), sulfur oxides (SOx), and mercury.  It would expand upon the so-called cap and trade provisions for SOx under the existing Clean Air Act, creating new targets and timetables for reducing emissions of these three pollutants.


Proponents consider this approach an improvement over the costly and inflexible command and control schemes that comprise most of the rest of the Clean Air Act.  Cap and trade allows the regulated entities to trade amongst themselves for the rights to emit the pollutants.  Under such “markets,” utilities that cannot reduce emissions cheaply can buy the rights to emit from those that can, with a tight overall emissions budget ensuring reductions over time.


Cap and trade is very much in favor in <?xml:namespace prefix = st1 ns = “urn:schemas-microsoft-com:office:smarttags” />Washington as being more efficient than command and control in reducing emissions.  However, critics point out that efficiency means nothing if the end goals are not worthwhile in the first place.  This is why Clear Skies is a bad idea.


Regardless of how it is done, these new provisions will likely yield negligible public health returns.  Both NOx and SOx emissions from power plants and other sources have already been successfully regulated under the Clean Air Act.  Ambient concentrations of these two pollutants have declined significantly, and virtually the entire nation is in compliance with federal air quality standards for them.  In addition, new measures on the books and scheduled to take effect in the coming years ensure further declines, with or without Clear Skies.


Beyond the direct effects of NOx and SOx, EPA's primary argument is that these gaseous pollutants are transformed in the atmosphere into fine particles measuring 2.5 microns or less (PM2.5), and that these particles pose a serious health threat.  The agency estimates that it can save up to 14,000 lives annually by reducing PM2.5 concentrations through the Clean Skies bill or its regulatory alternative.


These claims, based on epidemiologic studies correlating higher PM2.5 concentrations with increased mortality, are questionable.  The statistical associations are too weak and inconsistent to conclude that current PM2.5 levels are as dangerous as claimed.  Further, EPA assumes there is no threshold below which PM2.5 does not cause harm, an assumption that has little or no empirical support but grossly inflates the claimed benefits.  Nor has EPA explained the lack of any evidence of benefits over the past two decades, despite significant PM2.5 declines over that span.


In addition, the Clear Skies approach is problematic in that it targets a particular industry—coal-fired electricity generation—and not PM2.5-forming compounds regardless of source.  As it turns out, the nation's highest PM2.5 levels are mostly in California, where no coal is used and PM2.5 comes from sources unaffected by Clear Skies.


There are also reasons to doubt the benefits of the mercury emissions reductions mandated under Clear Skies.  Though coal combustion by American utilities does release trace amounts of mercury, all but a few percent comes from other sources—natural emissions, other man-made sources, and non-US power plants.  Thus, notwithstanding questions about how much of a public health problem current mercury levels pose, the Clear Skies approach goes after only a relatively small contributor to that problem.  In addition, as with NOx and SOx, mercury emissions in the U.S. are already on the decline, due to other provisions such as those dealing with waste incineration.


Of course, the administration is pushing Clear Skies for political reasons as well, but it is unlikely to do them any good.  The environmental establishment and most environmental journalists are far too partisan to ever be won over by Republicans, and attempts to woo them typically backfire.  In fact, rather than accept the Bush administration's boast that 14,000 lives will be saved annually under Clear Skies, green activists have cleverly turned the tables, arguing that Bush is actually killing thousands more by refusing to impose even tougher standards.  Many reporters have picked up on this spin.


President Bush could learn much from his father's experience.  The 1990 amendments to the Clean Air Act was a massive gift to environmental activists—more so than anything President Clinton ever gave them.  Yet Bush I received virtually no environmentalist support in the 1992 elections.  The less ambitious Clear Skies Initiative will fare no better.