The current system for abating air pollution in the United States desperately needs attention. We challenge the prevalent view that the Clean Air Act Amendments, the flagship legislation of the environmental decade of the 1970s, have worked well and that reauthorization need only smooth a few rough edges.
The myth of success comes from the earlier dramatic gains of the 1950s and 1960s, sustained during the past decade primarily through the "good luck" of a limping economy and continuing substitution of oil and natural gas for coal. According to reports from the Environmental Protection Agency, for most pollutants neither average ambient concentrations nor estimated national emissions declined significantly during the 1970s. If the economy expands and the use of coal and wood increases, enormous strains will be placed on the current system of pollution control. Changes are needed in the setting of air quality standards, in the emissions-control strategies for industry and vehicles, and in the coordination of environmental, energy, and economic policies.
Ambient air quality standards were created to deal with widespread pollutants that are threats to health and welfare. In three of the seven cases, the wrong pollutant is being regulated. Fine respirable particles and acid sulfates should replace total suspended particulate matter and sulfur dioxide, and the hydrocarbons standard should be scrapped altogether.
The congressional requirement for an adequate margin of safety in the standards assumes a threshold below which few, if any, people would suffer adverse effects. However, such thresholds are not demonstrable. Thus, the threshold/margin-of-safety approach should be replaced by analysis of remaining risks at alternative levels of a standard.
Assessment of compliance with the national ambient air quality standards depends entirely upon a monitoring system that is in shambles. Methods are unreliable, siting is arbitrary, quality control is lax, and localities can manipulate monitoring to serve their ends. At least 40 areas have used a loophole to become "unclassified" and avoid stringent requirements. Congress should address this real problem and order EPA to assume control of the monitoring system, directing the location of measuring stations and controlling the reporting of data.
Congress should clarify the roles of federal and state regulation. The federal government should have primary responsibility for policies and regulations affecting public health, regional policy, long-distance transport, national park and wilderness areas, and monitoring. States should have full responsibility for the state implementation plans, subject only to EPA disapproval within a specified time period. States should have the lead in setting secondary ambient air quality standards and in dealing with visibility in attainment regions other than national parks and wilderness areas.
Emissions-control strategies are aimed at stationary sources, mostly industries and utilities, and mobile sources, predominantly automobiles. EPA issues technology-based standards for stationary sources. Congress itself issued and revised national emissions standards for automobiles. This legalistic regulatory approach has been almost totally preoccupied with the design of new sources, neglecting the much greater emissions from existing sources and ignoring the worsening performance as control systems deteriorate with use.
The history of regulation of the automobile must be especially frustrating to Congress. Congress should not continue to set detailed regulations such as standards and deadlines for motor vehicle emissions. Instead, all standard-setting should be delegated, while Congress emphasizes its oversight role. The emissions standards set in the Clean Air Amendments of 1970 were to be achieved by 1975. Instead, the deadlines for attaining the standards were postponed, and the standards were relaxed. Even now, new car models are certified that on the road do not come close to meeting the statutory standards for hydrocarbons, carbon monoxide, or nitrogen dioxide emissions. For example, EPA's tests show 18.8 grams of carbon monoxide per vehicle mile for models whose prototypes met the 3.4 gram standard (after 50,000 miles of driving). Meanwhile, the rhetoric in Congress remains fixed on present and proposed standards of 3.4 and 7.0. Realistic emissions standards must be enforced by economic incentives over the entire life of vehicles in use. Congress and EPA should abandon pass-fail tests on prototype vehicles.
This year can mark an important transition in the pursuit of environmental goals. Economic and energy policies will severely strain the fragile, ill-prepared pollution control system.
Opinion polls indicate that Americans strongly support protection of the environment, yet they also show considerable anxiety about inflation, productivity, energy, defense, and tax burdens. In the reauthorization of the Clean Air Act, Congress must recognize that environmental goals can no longer be pursued in isolation from other national goals.
It is not necessary to relinquish the nation's air quality goals, but it is necessary to focus the effort, to be clear about which pollutants are the significant threats to health or to the environment, and to revise emission control strategies to achieve the goals at lower costs. All of that agenda is feasible.