Within a few weeks, Douglas Costle, administrator of the Environmental Protection Agency, will decide on a revised air-quality standard for smog. It will probably be the most expensive regulation promulgated by a federal gaency in 1979. Even a relatively modest relaxation of the standard could save consumers as much as $7 billion per year. To ensure that costs as well as benefits are considered in the regulatory process, President Carter has selected Costle to chair the Regulatory Council, created to review proposed regulations for inflationary impact. Therefore, the smog standard will be viewed as an important test of how the Regulatory Council will grapple with the trade off between health and inflationary costs.
Standing in the way of relaxation of the smog standard is the public's genuine and deep concern for the environment in general and urban air quality in particular. In a flood of sentiment against the automobile, Congress required emissions to be abated 95 percent per vehicle-mile, even though there wasn't information to make an informed decision. EPA followed the lead of Congress in setting an extremely stringent ambient air quality standard. Subsequent information shows both the Congress and EPA to have acted in haste; the Congress softened the emissions standard, and EPA has announced its tentative decision to relax the ambient air quality standard. Reactions to EPA's proposal almost uniformly favor relaxation. All states agree, and all but three believe the standard should be relaxed more than is proposed.
According to the 1970 amendments to the Clean Air Act, EPA must set national ambient air standards that will protect people's health, particularly that of sensitive individuals, with an adequate margin of safety. Those with chronic respiratory disease have been assumed to be the most sensitive group; a 22-year-old study found that asthma attacks occurred more often when smog levels were high. However, subsequent studies have failed to confirm that result, and a re-examination of the study found that smog levels were mismeasured. The original standard of 0.08 parts per million (ppm) derived from that study should have been set at 0.16 to 0.20 ppm.
Other studies, performed in the last two decades, fail to show a consistent association between smog and health. The positive studies suggest that athletic performance and the ability to do heavy work are slightly impaired and that breathing is somewhat more difficult. EPA relies upon a study in which six subjects exercised on a treadmill while breathing polluted air; at an ozone level of 0.30 ppm, two of the subjects displayed diminished breathing capacity, an effect termed significant, but no significant effect was found at lower concentrations. No permanent damage is suggested by these studies, but merely reduced breathing capacity and temporary discomfort. One animal experiment suggested that resistance to disease may be lowered by ozone, but it is difficult to extrapolate this result to humans.
Thus, the evidence implies that smog causes temporary discomfort in some people and tends to reduce the ability to perform heavy work. But there is no suggestion of potentially disastrous consequences. In marked contrast is the evidence regarding the health effects of suspended particulates and sulfur oxides. While the magnitude of these effects is still controversial, it appears that the health benefits for controlling these two pollutants exceed the social costs of abatement.
Further complicating EPA's decision is the definition of smog. Automobile emissions (unburned hydrocarbons and nitrogen oxides) are cooked by sunlight into smog. A vast number of compounds are involved, any of which might have health effects. Faced with the impossibility of defining standards for each of the compounds, EPA has decided to view one component of smog, ozone, as an indicator of all. While simplification is necessary, it is unwise to focus strictly on ozone and forget the other, possibly more harmful compounds.
EPA has proposed to relax the ozone standard to 0.10 ppm. This picayune relaxation reflects EPA's concern for protecting the most sensitive people from any adverse effects. But subsequent work has shown the impossibility of achieving this goal. EPA quotes the National Academy of Sciences: "No clear threshold can be identified for health effects due to ozone... selecting a standard from this continuum is a judgment of prudent health practice, and does not imply some discrete or fixed margin of safety that is appended to a known "threshold.'" Thus, EPA must abandon the search for a threshold, and the discredited standard. Instead, it should attempt to define 'prudent public health practice' by estimating the number and magnitude of estimated health effects and the costs of achieving alternative levels of ambient air quality. This is especially true since Costle's decision as EPA administrator will be reviewed by Costle as Regulatory Council chairman to ensure that the social benefits exceed the social costs.
The current standard of 0.08 ppm puts 90 large metropolitan areas out of compliance. To achieve 0.08 or the proposed 0.10 would require tightening current controls on automobiles and industrial sources such as power plants, gasoline stations and drycleaning plants. Indeed, automobile owners in these cities would be required to have annual inspections of their vehicles and to repair emissioncontrol systems. The cost of the inspection and repair program has been estimated by the administration to be about $2 billion per year, but this estimate doesn't include the cost and inconvenience of getting the vehicles inspected and repaired.
The total cost of achieving 0.10 ppm is estimated to be $14 billion to $19 billion per year. A relaxation of the standard to 0.16 ppm would save $4 billion to $7 billion per year, without a marked increase in health effects. Relaxation to 0.20 ppm would save $5 billion to $9 billion per year. To put these standards in perspective, even a pessimistic reading of the health evidence implies that just over one person per thousand would experience a few additional hours of discomfort per yuear as a result of ozone concentrations of 0.16 ppm. Society would be paying more than $2,000 to save each hour of discomfort for each sensitive individual if the standard were left at 0.08 ppm.
Or consider the fact that in 1976 Washington exceeded 0.08 ppm on 83 days, with the highest daily reading being 0.22. Was Washington's air quality unacceptably bad for 83 days during 1976? If the standard had been 0.16 ppm, 10 days would have been unacceptably bad. At a standard of 0.16 ppm, other cities, such as Atlanta, would be in compliance and would not be required to adopt the more stringent measures for inspecting vehicles and contolling industrial sources.
We urge Costle to consider a standard of 0.16 to 0.20 ppm. Setting the ozone standard at 0.16 ppm would permit doubling or tripling the current medical research budget, further reducing particulate and sulfater pollution or simply lowering the inflation rate by as much as half a percentage point.