The Full Story Behind Industry Attacks on EPA
|Clearing the Air May 1997 one in a series of fact sheets on the clean air health standards debate|
In another attempt to discredit EPA's proposed ozone and particulate standards, industry opposition continues to dwell on issues raised during the inter-agency review of the standards. What they have failed to do is put these matters in their proper context. First, most of the memos that have been cited were circulated before EPA published the proposed rule. Second, many of the issues deal primarily with implementation concerns, rather than on the rule itself. Finally, concerns are not based on existing evidence and past trends.
Did EPA miscalculate compliance costs?
In December 1996, the Council of Economic Advisors estimated that full compliance with the revised ozone standard would be close to $60 billion. That is double what it costs today to implement the original 1970 Clean Air Act, and the 1977 and 1990 amendments, combined (to date), about $30 billion annually. This includes programs like lead phase-out, CFC phase-out, acid rain, the Title V permit program, and air toxics. EPA has asked CEA to explain their calculations; to date, they have been unwilling to do so.
It is worth noting that EPA and industry have historically overstated the costs of air pollution control programs. Costs are generally calculated based on conventional control technologies; and industry often finds cheaper, more innovative ways of controlling air emissions. During initial debates about the acid rain program in 1990, industry projected the emission allowance would be $1,500 per ton; EPA projected costs to be closer to $450-$600. Today, emission allowances are selling for about $100/ton.
Is EPA ignoring small business impacts?
Since January 1997, EPA has held a series of meetings to solicit comments on the proposed rules from small businesses. In February, EPA appointed additional small business representatives to the Federal Advisory Committee focusing on implementation of the new standards. EPA is not arguing that the proposed rules could not have an impact on small businesses. But such impacts will vary from state to state, as states develop implementation plans and identify which sources to control. EPA has pledged to work with states to come up with cost-effective, workable plans.
In the past, the Agency has either exempted small sources entirely from new clean air rules, or changed existing rules to minimize their burden on small businesses. For example, most of the air toxics standards promulgated since 1990 apply only to major sources, exempting tens of thousands of small businesses from these rules. Also, EPA's ongoing Common Sense Initiative has allowed small businesses to participate directly in the development of new regulations.
Nevertheless, false rumors are spreading that every baker and drive-through business and auto body shop will have to run out and apply for a state air permit if these rules go into effect, a scenario as unlikely as seeing controls placed on our backyard barbecues. Instead, control programs will likely focus on the greatest sources of particulate and ozone pollution: power plants, cars, trucks and buses, and cleaner fuels.
Are the proposed rules an economic hardship for small farms?
Farming and farm equipment contribute extremely small amounts of fine particle and ozone air pollution. Farm equipment is responsible for approximately one percent of nitrogen oxide emissions (a fine particulate precursor) and less than one percent of VOC emissions (an ozone precursor) nationally. These amounts are so small and insignificant when compared to emissions from other sources; and controls will likely be placed on the largest sources of regulated pollutants.
Some farm organizations, using outdated estimates, have claimed that farmers will be regulated under the new PM 2.5 standards because of their dust emissions. However, measurements done in one farming region, San Joaquin Valley, California, showed that only a small percentage of PM 2.5 is attributed to dust (7.1%), of which 5% came from agricultural-related wind erosion, tilling, and livestock.
EPA is considering regulations to clean up emissions from new heavy duty engines used in farming equipment. However, the estimated cost of new equipment would be insignificant (less than one percent). After the 1990 Clean Air Act amendments, automobile manufacturers estimated that new pollution controls would cost $1,500 per car_actually, the result has been an increase in $60 to $100 per car.
The claim that the new standards will significantly increase the cost for farming equipment may be yet another example of industry inflating costs to generate opposition.
Will the new standards threaten states' transportation programs?
Again, there is little historical data to support this concern. In fact, under the Clean Air Act areas are not being sanctioned for failing to meet the standards but for failing to try. EPA issues sanctions only if the state is uncooperative and behind in meeting the planning and implementation deadlines imposed by the Clean Air Act. Since the 1990 amendments, no area has lost highway money for failing to meet their deadlines. The Administration is committed to helping cities and counties meet the new standards. In its ISTEA reauthorization bill, the Administration increased the CMAQ program to help fund transportation-related projects in non-attainment areas. The bill also gives the Secretary of Transportation access to additional money to meet the increased demand for CMAQ money if the new standards become final.
This is one in a series of fact sheets on the revisions to the Clean Air Act's health-based standards. For more information, contact the Clean Air Network, an alliance of over 900 citizen environmental, public health, religious, and other community groups working to protect the air we breathe, 202/289-2429.
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