Interdisciplinary Minor in Global Sustainability
Senior Seminar
University of California, Irvine June 1997 


Conflict over Air Quality Standards

by Akiko Allison Gotoh

ID#32860304

February 5, 1997

ESS190B

Issue Paper I

Proposed by: The United States Environmental Protection Agency (EPA)

The American Lung Association (ALA)

The Natural Resources Defense Council (NRDC)

The Sierra Club

Consumer and Other Environmental Organizations

Opposed by : The Air Quality Standards Coalition (It consists of approximately 600 industrial companies and interest groups)

Automobile manufacturers

The American Trucking Association,

The National Association of Manufacturers

The Chemical Manufacturers Association (CMA)

According to the annual survey of air quality done by the United States Environmental Protection Agency (EPA) in 1995, air pollution has decreased 30% nationwide over the past twenty five years yet "80 million people in the U.S. still breathe air that fails to meet these standards."2 General air quality of an area is determined by EPA by monitoring the concentrations of six criteria pollutants, which are carbon monoxide, lead, ozone, particulate matter (PM) and sulfur dioxide, in the air. Emissions of these six pollutants are regulated by the National Ambient Air Quality Standards program (NAAQS). Under the Clean Air Act, EPA is required to review NAAQS every five years to see if changes are necessary.

Out of these six pollutants, ozone and PM are more difficult to control than other four pollutants. Ozone is a chemical which is produced naturally in the stratosphere to provide a protective layer above the surface of the earth; but at ground level, it is produced by the photochemical reaction of nitrogen oxides and volatile organic compounds in sunlight to contribute to the formation of smog. PM, on the other hand, is soot or "a mixture of solid particles and liquid droplets found in the air."7 Particles larger then 2.5 microns are often produced from windblown dust and grinding operations, while particles less than 2.5 microns are usually produced by fuel combustion, agricultural burning and woodstoves. Now, EPA faces a big conflict on the control of these two pollutants.

The beginning of this conflict goes all way back to 1991, when the American Lung Association (ALA) among with consumer and environmental organizations sued EPA stating that the agency had not revised the ozone or PM standards as required by law even though there was sufficient evidence that the standards needed to be tightened. In fact, EPA has reviewed the standards only twice, in 1979 and 1987, since the initial standards were set during the early 1970s. But EPA has made no change to the standard then. As a consequence, a court ordered EPA to publish a proposed standard for public comment by the end of November 1996. On November 26, 1996, EPA announced its proposal for new air quality standards. In this proposal, EPA recommends that the standard of the ozone emission to be lowered from 0.12 ppm measured over one hour to 0.08 ppm measured over eight hours. As for the PM, the current standard requires the concentration of PM smaller than 10 micron to be lower than 50 micrograms per cubic meter annually and 150 micrograms per cubic meter daily; but the new proposal recommends the concentration of PM smaller than 2.5 micron to be lower than 15 micrograms per cubic meter annually and 50 micrograms per cubic meter daily, and the current standard is maintained for the concentration of PM larger than 2.5 micron.4

The reason for these tight restrictions are the various effects of ground-level ozone and PM on human health and natural environment. EPA states that ozone, even at very low levels, can cause acute respiratory problems and inflammation of lung tissue, aggravate asthma, decrease in lung capacity temporary, and impair the body's immune system defenses.6 Environmentally, ground-level ozone can cause poor growth and reproduction of plants, weaken sensitive vegetation, reduce agricultural yields of many economically important crops and alter the composition of aquatic environment resulting fish kills and algae blooms.6 Similarly, PM causes a series of significant health problems such as premature death, aggravated asthma, acute respiratory symptoms, chronic bronchitis, and decreased lung function.7 Damages done by PM to natural environment include visibility impairment, and soiling. In fact, it is known that the visual range has been cut by over 70% in many parts of the United States.7

EPA Administrator Carol M. Browner estimates that the new air standards will save 20,000 lives per year by preventing premature deaths, will avert 250,000 sick days of aggravated asthma per year, and will prevent 60,000 cases of bronchitis per year, 1.5 million cases of decreased lung function per year and 9,000 hospital admissions per year.3 Under the new standards, it is projected that the number of county whose air quality does not meet the standard would rise from 106 counties today to 355 counties for ozone and from 41 counties today to 167 counties for PM. EPA believes those counties can meet the strict standards by doing things such as adoption of regional utility and other control strategies, the 49-state national low emission vehicle (LEV), the full implementation of the sulfur dioxide reductions from power plants under the acid rain program, cost-effective utility and combustion controls, the installation of low Nox burners, and the economic incentive programs to reduce traffic congestion.8 To implement the proposed air quality standards for both ozone and PM, EPA is estimating its cost to be about $6.5 billion to $8.5 billion per year with benefits of $120 billion which include "fewer lost work and school days as well as fewer hospital admissions."3

To the proposal of more strict air quality standards, much of the American industries strongly oppose because it would take a high cost to meet the new standards. Over 600 industrial companies and interest groups including automobile manufacturers, the American Trucking Association, the Chemical Manufacturers Associations (CMA), and the National Association for Manufacturers have come together and they formed the Air Quality Standards Coalition in opposition to the more strict standards.1 The coalition claims that "the health benefits of the opposed standards are not clearly supported by science, and their adoption could deal a crushing economic blow to U.S. business."3 Joe J. Mayhew, assistant vice president from environment and policy analysis for CMA, believes the actual cost of implementing the new particulate matter standard alone may cost $16 billion annually, including the cost of industry displacement from nonattainment areas and lost jobs.3

Opposition is heard from politicians also. Senator Christopher Bond (R-Mo.) and Dale Bumpers (D-Ark.) have warned Browner and EPA stating that it is not in full compliance with certain aspects of the Small Business Regulatory Enforcement Fairness Act of 1996.3 This new act was passed last year to give Congress an ability to review any new regulation having an economic impact of $100 million before an agency could implement it. Because the act was just passed last year, it has not yet been used to enact any regulation. Many political spectators are thinking that EPA's new air quality standards will just provide a perfect opportunity for Congress to demonstrate an enactment of regulation using such an Act.

Currently, the final standards is scheduled to be published by June 1997. EPA is expecting to publish a proposal that will out line the specific control requirements by June 1998 and take final action on that proposal in Jun1999. Plans to meet any finalized standards would be due in 2002 for PM and in 2000 for ozone control strategies. After that, counties will be given a period of 10 years and an extension of 2 years to achieve new air standards.

It seems as though EPA's proposal for more strict air quality standards has started a battle of human lives versus money. Which is more precious? This question will be answered in near future when the new standards are finalized. Hopefully, people will make the right choice to start the new century with fresh clean air.

Sources Cited :

  1. Hanson, David. "Conflict Over Air Quality Rules." Chemical & Engineering News. v 74, n 51, 1996 (Dec. 16), p. 27-8.
  2. Hanson, David. "EPA Reports Continues Air Quality Improvement." Chemical & Engineering News. v 75, n 1, 1997 (Jan. 6), p. 22-3.
  3. Raber, Linda R. "Clean Air: Dollars Versus Lives." Chemical & Engineering News. v 75, n 5, 1996 (Feb 3), p. 28-30.
  4. USEPA Office of Air and Radiation. "EPA Announces Proposed Standards." Jan. 13, 1997. http://ttnwww.rtpnc.epa.gov/naaqspro/index.htm.
  5. Ryan, Dave. "EPA Proposes Air Standards for Particulate Maater and Ozone." Nov. 27, 1996. http://134.67.104.12/naaqspro/press.htm.
  6. USEPA Office of Air and Radiation and Office of Air Quality Planning & Standards. "Health and Environmental Effects of Ground-Level Ozone." Nov. 29, 1996. http://134.67.104.12/naaqspro/o3hlth.htm.
  7. USEPA Office of Air and Radiation and Office of Air Quality Planning & Standards. "Health and Environmental Effects of Particulate Matter." Nov. 29, 1996. http://134.67.104.12/naaqspro/pmhlth.htm.
  8. USEPA Office of Air and Radiation and Office of Air Quality Planning & Standards. "How the New Proposed Standards Will Affect My City or County." Nov. 26, 1996. http://134.67.104.12/naaqspro/mycity.htm.

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