Clearing the Air on EPA’s New Emissions Proposal
Care to spend $2 billion or more a year on a health measure with no detectable health benefits? The Environmental Protection Agency (EPA) is preparing to do precisely that in the auto emission rules that President Clinton announced May 1st. The EPA proposal is intended to reduce nitrogen oxide (NOx) and hydrocarbon emissions and the sulfur content of gasoline. The proposed rules would also require that sport utility vehicles (SUVs) and pickups meet the same emissions standards as passenger cars; as a result, some larger SUV models may be forced off the market entirely.
While the new regulations will increase auto and gasoline prices, their effect on levels of NOx and hydrocarbons, which are the precursors of smog, will be far less certain; in fact, they may produce no reductions in smog. According to a study by the American Automobile Association, 75 to 85 percent of smog precursors in major cities are from non-automobile sources. Moreover, while NOx from automobiles and small trucks fell 33 percent between 1970 and 1996, NOx from non-auto sources increased by 16 percent during the same period.2
In fact, EPA’s proposal could actually retard the air quality improvements that have resulted from the continuing replacement of older, more-polluting vehicles with newer, cleaner ones. Because the EPA rules will drive up new-car prices and may actually eliminate certain vehicle models, they will cause some consumers to hang on to their old vehicles for far longer than they otherwise would have.3
Even if the new rules do manage to reduce levels of NOx and other smog precursors, they will still have no discernible effects on health. NOx reacts in sunlight to produce ozone, and ozone can cause such respiratory problems as nasal congestion, throat irritation, coughing and tearing in people exposed to levels that occasionally occur in outdoor air. These effects, however, are transient. In 1995, EPA’s own Clean Air Science Advisory Committee (CASAC) reviewed the evidence on ozone and health and concluded that "there is no ‘bright line’ which distinguishes any of the proposed standards … as being significantly more protective of human health."4
CASAC did not recommend any changes in the ozone standard. Nonetheless, EPA Administrator Carol Browner pushed ahead with new standards in 1997, claiming that they would prevent asthma, especially among children.5
While environmental organizations have supported EPA’s ozone-asthma connection, medical groups have not. The American Thoracic Society concluded, "Poverty may be the number one risk factor for asthma."6 A study in the New England Journal of Medicine reported that "exposure to cockroach allergen has an important role in … asthma among inner-city children."7
The government’s own data reveal the tenuousness of the connection between ozone and asthma. According to EPA’s National Air Quality and Emissions Trends Report, 1996, ozone concentrations fell 15 percent between 1987 and 1996. If EPA were correct, then decreases in asthma would have accompanied these falling ozone levels. But in fact, according to the Centers for Disease Control, the number of asthma cases and asthma death rates across the country increased during this time period,8 indicating that other agents are responsible for the disease.
The National Institute of Environmental Health Sciences’ statements on asthma similarly demonstrate the weakness of EPA’s link. The Institute’s website lists 10 "common triggers" for asthma: Neither ozone nor air pollution appears on that list.9
Poverty and its accompaniments, such as cockroaches, are more closely tied to asthma in children than is air pollution. The health of children will not be improved by raising the cost of cars and gasoline. If anything, it will deteriorate.
Regulations make goods and services more expensive, and as costs go up, disposable income falls. Ralph L. Keeney, who has examined the health impacts of regulatory costs, writes, "Since individuals on average use additional income to make their lives safer and healthier, the regulatory costs lead to higher mortality risks and fatalities." He calculates that every $5 million to $11 million in regulatory costs "induces a fatality."10 Left to their own good sense, consumers do a better job than regulators of spending their money to benefit their health.
It’s time for both Congress and the public to take a hard look at what EPA proposes. Doing so would save us not only money but, very likely, lives as well.
1Michael Gough(firstname.lastname@example.org) is a senior scientist at the Competitive Enterprise Institute.2AAA Press Release, "Cars Not Main Cause of Smog", Aug. 12, 1997.3R.W. Crandall et al., Regulating the Automobile 102, Brookings Institution, 1986.4Letter from CASAC Chairman George T. Wolff to EPA Administrator Carol Browner ("CASAC Closure on the Primary Standard Portion of the Staff Paper for Ozone," Nov. 30, 1995).5A. Antonelli "Can No One Stop the EPA?" (Heritage Foundation Backgrounder No. 1129, July, 8, 1997), a description of the 19997 standards and controversies about them. www.heritage.org/categories/enviro/by1129.html. See also Michael Fumento, Polluted Science. American Enterprise Institute, 1997.6D. Rosenstreich, New England Journal of Medicine 336:1356-1384, May 8, 1997.7Quoted in Heritage Backgrounder, p. 6.8David M. Mannino, et al., "Surveillance for Asthma – United States", 1960-1995. Mortality and Morbidity Weekly Report. 47:1-28, April 24, 1998, figure 2.9National Institute of Environmental Health Sciences, "NIEHS Asthma Prevention: Asthma Alert," Feb. 12, 1999, www.niehs.nih.gov/airborne/prevent/alert.html. The 10 "common triggers" are cigarette smoke, cockroaches, dust mites, mold, pets and animals, pollen, cold air, exercise, stress and respiratory infections.10Ralph L. Keeney, "Estimating Fatalities Induced by the Economic Costs of Regulations," Journal of Risk and Uncertainty 14:5-23, 1997.