- The Washington Times - Tuesday, March 8, 2011


The Environmental Protection Agency last week released the second prospective analysis of the costs and benefits of the 1990 Amendments to the Clean Air Act (“1990 CAAA”), ordered by Congress as part of those amendments. The benefits are nothing short of extraordinary, and deserve serious attention at a time of equally serious questions about existing EPA authority with respect to both carbon dioxide, or CO2, and health-related, traditional pollution.

The headline numbers are $2 trillion in benefits (against $65 billion in costs) as of 2020 and 230,000 lives saved annually as of that date, with the majority of the benefits already realized. The benefits are largely the result of reductions in fine-particle pollution (which EPA knows how to calculate) and do not include many reductions of unquantified benefits.

Nor does this study include the 1990 CAAA Title VI, which regulated stratospheric ozone-depleting substances (like CFCs) and which was assessed in the first prospective study. That study found that the benefits “vastly” exceeded the costs and should also not be ignored, especially because the greenhouse-gas reductions achieved were 5 to 10 times the greenhouse-gas reductions of the much better known Kyoto treaty.

One of the key messages of this report is that stunning pollution-control benefits can be achieved without imposing costs that either come close to offsetting the benefits or materially impair economic performance. Many critics of the 1990 CAAA effort predicted dire adverse economic consequences. But the legislation was implemented during one of the greatest economic booms of U.S. history, and obviously did not retard growth, even if it also did not trigger it.

But there is another, equally important message contained in the report that should provide caution against trying for a double or triple in the next two decades simply by tightening the same controls that gave us the first round of numbers.

The caution derives from the fact that the benefit numbers result almost exclusively from the reduction of just one of the several pollutants EPA is responsible for (fine particles), and, within that limited universe, relate to efforts directed primarily at just one of the two major precursor emissions. The caution is that in the future, EPA will have to focus on the other set of precursor emissions if it is to maintain its high benefits-to-cost ratio and its benign impact on jobs and economic growth.

The polluter of primary focus has been coal, the combustion of which mixes in the air to contribute the single largest portion of fine- particle pollution (by virtue mostly of sulfur dioxide, or SO2, emissions, and to a lesser extent, emissions of nitrogen oxides, or NOx, and numerous acid gases).

As a result of the 1990 CAAA, SO2 emissions are on the way to declining from 18 million tons in 1990 to just 4 to 5 million tons in just a few years from now. The other, less contributing coal pollutants are on the same trajectory.

The cautionary lesson is that there is obviously not that much more SO2 to attack, and, furthermore, the cost of controlling the remainder will begin to skyrocket, potentially causing serious economic hardship. The good news, though, is that EPA’s previous inattention (relatively speaking) to the other source of fine particles that almost matches SO2 provides ample opportunity to continue to provide outsized benefits — if it will pivot to focus now on the other primary particulate-matter source.

That other source is elemental carbon and organic carbon, fine-particle precursors, which emit primarily from the mobile (or motor transport) sector and which can be reduced either by cleaning the fuel (i.e., gasoline and diesel) or demanding more of the catalytic controls on cars. Here, the attention has been primarily on car controls, except for the removal of sulfur from gasoline and diesel during the George W. Bush administration and a relatively modest removal of toxic components of gasoline under President George H.W. Bush.

There is a great deal more that can be done on the mobile-source side of the ledger to continue to clean up the air and save lives at a relatively modest cost. One of the major “side” benefits would be a potentially dramatic increase in energy security resulting from increased use of much cleaner, homegrown alternative fuels, such as natural gas (used as compressed natural gas in transport vehicles), biomass, coal to liquids and electric cars (using electricity that is generated exclusively from domestic inputs). And there would be major CO2 reduction co-benefits as well (with carbon capture and storage for coal), achieved as a byproduct of energy security and cleaner air.

C. Boyden Gray has served as White House counsel and as ambassador to the EU.

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