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Cleaning up the air: Risk elimination or risk management?

Editor: The "Tough acid rain provisions of new Clean Air Act" (Bill Kemp, January, pp. 21-23) ignore the accomplishments to date and are a perfect example of the law of diminishing returns, of how politicians exploit "feel good" issues and of why the only thing we really need to fear is fear itself.

In the hype that surrounds the clean air frenzy, we forget that we are already spending $33 billion a year on clean air, far more than any other country, in terms of dollars or percentage of gross national product. And we have more than gotten our money's worth.

There has been a 55 percent increase in the number of ears on the road since the Clean Air Act was passed in 1970 and large increases in utility and industrial output as well. Yet, during this period, lead concentrations in the air we breathe are down 98 percent and carbon monoxide has been cut by a third. The release of sulfur dioxide into the air, reduced by 8 million tons a year, has also been cut by a third. Particulate matter is down 21 percent. Even ozone-causing emissions have been cut by 17 percent.

Over the past 15 years the historical sources of air pollution the auto industry and utilities have committed billions to clean-air technologies. These tremendous costs already have been passed along to and willingly paid by the public. Now the environmentalists, led by the politicians, say we will have to spend billions more. Why?

Most Americans are shocked to discover, for example, that ozone risk levels in all but a handful of the 70-odd "noncompliance" cities are exceeded on average less than 1 to 2 percent of the year, or fewer than seven days, for only an hour or so each day and then only in the worst danger zones of each city. Yet we are supposed to spend tens of billions of dollars to reduce 2 percent to zero.

Consider how the feds measure compliance. A city is said to be in "noncompliance" if the ozone levels exceed federal standards for just three separate days over a three-year period. The city only has to exceed those standards for just one hour during each of those days. Also, despite the fact that recent studies show that high temperatures increase ozone concentrations, the U.S. Environmental Protection Agency (USEPA) doesn't take unusually hot weather into account when measuring compliance.

These federal standards are not based on a rational appraisal of normal average human exposure. Instead, the "maximum exposed individual" is assumed to be living directly at the point of highest pollutant exposure, outdoors, 24 hours a day, 365 days a year, throughout a 70-year lifetime.

A study by the USEPA in 1984 revealed, interestingly enough, that over a 20-year period the share of cancer deaths even attributed to environmental causes had plunged from 70 percent to 2 percent. As the Washington, D.C., Circuit Court of Appeals rebuked the Natural Resources Defense Council in 1987: " 'Safe' does not mean 'risk free.' Instead, something is 'unsafe' only when it threatens humans with ' a significant risk of harm.' " The case has not been made that we are signficantly at risk.

It is to be hoped that the USEPA will listen to its own Science Advisory Board and move away from absolute risk elimination to risk management, from environmental utopianism to the realism with which human beings cope with their mortality every day. But don't hold your breath.

Daniel J. Sobieski
Chicago

April 1990/Illinois Issues/7


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