I'm about to give you an unprecedented look inside the workings of my economic brain. I am going to read an article and provide commentary in real time--or as fast as I can type. My comments will be in italics, because I think in italics. Here's the full article.
Pollution experts have "serious scientific concerns" that newly unveiled U.S. air quality standards may pose risks to human health and welfare, according to a letter made public Tuesday.
What's the difference between health and welfare?
The experts, all charter members of a key advisory panel to the U.S. Environmental Protection Agency, questioned the agency's decision to keep annual standards for fine soot particles at the same level they have been since 1997.
The panel's scientists, along with a broad range of environmental and health groups, had sought to lower the amount of soot permissible, citing research that showed health risks from even small amounts over the course of a year.
OK, so there might be some benefit, but what is the cost?
"There is clear and convincing evidence that significant adverse human-health effects occur in response to short-term and chronic particulate matter exposures at or below 15 micrograms per cubic meter (of air), the level of the current annual ... standard," the experts wrote in a Sept. 29 letter to EPA Administrator Stephen Johnson.
Clear and convincing evidence? I'm skeptical already. Scientists have confused me enough lately. There used to be a brontosaurus: Now it's an Apatosaurus. Neil Armstrong used to say "That's one small step for man..." but now a missing microscopic 'a' has been found on the original recording: "That's one small step for a man..." It used to be pronounced NeanderTHal, now it's NeanderTal. Pluto used to be a planet, now it's a planet-like substance. What's next? The moon's not made of cheese?
Johnson announced the decision to leave this standard unchanged on Sept. 21, saying it offered "cleaner air to all Americans," and would reduce premature deaths, heart attacks and hospital stays for people with heart and lung disease and bring health benefits valued at between $20 billion and $160 billion a year.
Wow, that's a lot of benefit. BUT WHAT'S THE COST? This seems to be a popular strategy for getting what you want. Quote a big benefit number found in some economic study and then claim that the action must be undertaken. There are two sides to every decision. Benfits and COSTS. Also, notice the range on that number. That's a margin of error of 700%. That's like me telling a student 'your grade will be somewhere between a 10 and an 80.'
INDUSTRY'S VIEWPOINT
Uh oh, here we go...time to villify industry.
While Johnson agreed with the advisory panel to strengthen daily air quality standards by nearly 50 percent, he did not follow their recommendation to reduce the annual standard to 13 or 14 micrograms per cubic meter of air.
So we're reducing daily standards by 50 percent and that has no effect on annual levels? I'm confused.
Rogene Henderson of the Lovelace Respiratory Research Institute, who chairs EPA's Clean Air Scientific Advisory Committee and who signed the letter along with six other panel members, said the key concern was for health and welfare.
"The main thing is to protect the public health," Henderson said in a telephone interview from Albuquerque, New Mexico. The unchanged annual standards do not provide a margin of safety, as stipulated by the U.S. Clean Air Act.
EPA spokeswoman Jennifer Wood, in an e-mail response to questions about the scientists' letter, said, "Where the science was clear, EPA took clear action."
Which explains why EPA rarely takes action. Sorry, too easy.
"Administrator Johnson fully considered the science, (the panel's) advice about the science and more than 120,000 public comments in making his policy decisions about the appropriate levels of the particle pollution standards," Wood said.
The public? (I ask incredulously). How dare the EPA consider public opinion when designing public policy? The science is clear...sort of...isn't that enough? I wonder if any of those comments were "How much will this cost?" I sure hope so.
However, Henderson and others have noted that 20 of the 22 members of the full advisory committee advised more stringent annual standards. The two who advised against tightening the standards were a former longtime employee of General Motors and the former president of the Chemical Industry Institute of Toxicology, funded by chemical companies.
And what is the decision rule the scientists used for deciding when tighter restrictions are a good idea? What is the threshold? As cynical as I am towards scientific communication, science is a good thing. The problem as I see it, is that once the health effects are measured, scientists often step outside the realm of their training and make prescriptive policy recommendations using no clear decision rule. Soot levels are X, therefore they are too high, therefore you should take action Y. The first part of the statement is objective science. The last two are subjective assessments of the objective science. So I ask again "How much will this cost?"
"I think they did present the industry viewpoint," Henderson said of these two members. "They would say they based it on science."
I would guess they based it on economics.
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