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]]]]] BUSH CLEAN AIR PROGRAM IS FULL OF RISKS TO ECONOMY [[[[[[
(9/18/1989)
By Warren T. Brookes
[From Human Events, 16 September 1989, pp. 11-12]
[Kindly uploaded by Freeman 10602PANC]
On July 21, President George Bush sent his Clean Air Program
(CAP) to Capitol Hill and along with it, his economic future,
which is already being shaken by the serious strategic investment
uncertainty which CAP has raised, and for good reason.
Office of Management and Budget (OMB) careerists have been
shocked at the massive level of intervention in the economy
proposed in the early drafts. ``It's far worse than anything
Jimmy Carter ever proposed,'' said one. A top Bush official
admitted to us, ``We got rolled by the environmentalists.''
Sadly, the risk to the U.S. economy is infinitely greater than
the slight health risks which the CAP might address. In an
interview, we asked President Bush's chief counsel, C. Boyden
Gray, ``How many additional lives will this program save?''
His answer was instructive: ``We don't have a figure. We
don't know whether the Environmental Protection Agency does or
not.'' It doesn't. We are about to spend $15 billion to $20
billion a year without knowing how much health or safety we are
really buying.
Gray said, ``That's not entirely true. We do have a range of
premature deaths on air toxics of 1,500 to 3,000.'' But on
surface ozone non-attainment and acid rain, there are no known
death risks.
Even the 1,500 to 3,000 air-toxics number is based on
hypothetical damages to the ``most exposed individual'' (MEI) at
the point of highest exposure, 24 hours a day, 365 days a year
for 70 years.
Any realistic assessment of risks would drop that ``1,500 to
3,000 range'' to 300 to 500, and none of those would be saved for
at least 20 years, or $400 billion more spending.
Small wonder EPA Administrator William Reilly has ordered his
own agency to develop a prioritization of risks (but what about
the risk of $400 billion in lost employment?). This will be
ready presumably sometime late next year when the acid rain study
will be completed. So why is Bush so eager to spend now in haste
and then study in leisure?
Or as Lawrence Livermore Laboratory's distinguished scientist
Hugh Ellsaesser wonders, ``If our present draconian clean air
program has not reduced airborne pollution to Congress' standards
.. why should we expect a miraculous improvement from... another
10 to 20 years of tightening the screws?... Must we wait until
then to bring reason into the program?''
``You don't understand,'' said Boyden Gray. ``It's not the
EPA, it is the courts that are now telling EPA the law requires
addressing the ultimate risk to the most exposed individual.
``For example, Bill Ruckelshaus [EPA head, 1983 to 1985] was
nearly cited for contempt trying to develop a more realistic risk
on radon,'' even though seminal work by Dr. Bernard Cohen at the
university of Pittsburgh had shown there is no health risk from
residential radon.
However, as Dr. Cohen told me, ``You understand, radon is the
most serious risk with which the EPA is now dealing.''
``But, Dr. Cohen,'' I said, ``you just got through telling me
that residential radon poses no public health risk!''
``That's right,'' he said.
In other words, if the EPA's claim that residential
radon ``causes 20,000 cancer deaths a year'' is fatuous
(and it is), what is to be said about EPA's much lower
estimates for air toxics?
In fact, the greatest challenge to EPA over the past decade
has come from its own Science Advisory Board (SAB), which said in
a 1988 report, ``The general field of risk assessment is rapidly
moving away from the practice of giving worst-case estimates to
that of providing best estimates along with a statement of the
uncertainty of that best estimate.''
``Unfortunately,'' said Boyden Gray, ``the courts don't agree.
In the vinyl chloride case, Judge Robert Bork ruled that the
language of the statute requires the most extreme risk reduction.
``The court situation is growing intolerable every week.
Phoenix is pretty close now to being run by a federal judge.
Chicago is facing a court-imposed environmental plan like L.A.''
Gray argues that the President's bill contains two major
reforms to correct this: getting out of the clean air statute
precise health risk language and using market incentives to allow
greater flexibility in to meet standards.
``What is going on in our bill is not just an initiative to
crack down on polluters -- that's important -- but there's a lot
of reform. For the first time, Section 112, which deals with
risk, does not spell out a standard, but allows risk
management,'' says Gray.
It also increases the number of hazardous pollutants from
seven to 280, and even as Gray said that, his benign proposal was
getting trashed in leaks to the Washington Post. That's what he
hopes. And bills now before Congress would set one premature
death in a million as a hard standard, which under MEI theory
actually means one every 12 million years!
So far, Gray and his President have lulled the conservative
community with the carrot of ``market-based'' pollution control,
which Gray says ``takes the decisions out of the political
process and puts them on a sounder ethical and economic basis.''
Maybe so, but those market proposals are small cosmetics
compared with the cosmic intervention which a regenerated EPA and
its liberal allies in Congress now have firmly in mind.
*
By far the most expensive EPA-supported element in the Bush
Clean Air Program is the estimated $11 billion to $15 billion for
equipping cars to burn ``alternative fuels,'' ethanol and
methanol.
The EPA, in effect, wants George Bush to be Jimmy Carter,
mandating and forcing technology from Washington. Some in the
White House are still trying to keep Bush out of that trap by
insisting on at least an attempt at a market-based solution.
But bet your money on a ``Jimmy Bush'' style ``sin-fuels''
program and on its architect, EPA Deputy Administrator William
Rosenberg, George Bush's most disastrous appointment. When he was
Michigan's Public Service Commission chairman, Rosenberg made
even interventionist-minded Democrats nervous with his massively
intrusive regulation.
Now Rosenberg has really big power. He wants to force at
least nine to as many as 20 to 30 cities to mandate alcohol
fuels as the chosen way to reach the present 0.12 parts per
million (ppm) ozone standard, making Detroit equip one
million cars a year to burn those fuels.
The President's own chief counsel, C. Boyden Gray, a committed
alcohol fuels enthusiast, at least wants to give industry the
chance to meet those standards in the most efficient way:
``The bill we have sent up has a performance standard based
wholly on things like fuel oxygen content in some cities (to deal
with carbon monoxide) and ozone-producing emissions in others.
But it says nothing about how to meet those standards.''
But that's not completely true. The bill mandates methanol in
nine cities by 1995. It even mandates details on how gas stations
will comply. In the interim, it does allow a period of 18 months
of ``rule-making'' in which industry can offer alternatives. But
will EPA let that process kill its power-hungry, costly
``sin-fuels'' approach?
Even the Office of Technology Assessment (OTA) in Congress
says there are far less expensive ways of attaining the same
ozone reduction. OTA's data suggest the only way either methanol
or ethanol could ever be cost effective in reducing pollution is
if they were less expensive than gasoline (which they are not).
This is because, outside Los Angeles, the emissions gains from
using those fuels are small, especially on post-1981 cars. While
methanol might lessen the need for more consumer-painful
inspection and maintenance (I/M) regimens, it costs from 30 to 50
cents more per energy equivalent gallon than gasoline because it
has less than 60 per cent of the energy-mileage value per gallon.
It also generates four to eight times as much formaldehyde, which
is much more ozone-producing than hydrocarbons, with no solution
yet in sight.
Furthermore, batteries of tests (which the White House
disputes) suggest methanol's relative emission-reduction costs
range from $20,000 per ton to as much as $280,000 per ton, with
OTA pegging it at an average of $39,000 per ton, or 10 times
EPA's $2,000-per-ton target level.
If consumers had to choose between I/M and actually paying for
alternative fuels, the choice is obvious. That's why OTA looked
to methanol for only 1 per cent of volatile organic compound
(VOC) reduction. That compares with 6 per cent each for
reasonably available control technologies (RACT) on the half of
emissions from stationary sources ($3,500 per ton); 6 per cent
from tighter controls on gasoline vapor at the pump and in the
car ($1,200 per ton); and 3 per cent from enhanced inspection and
maintenance at $3,500 a ton. (See Table.)
There are no comparable costs for ethanol, because its very
high price allows only 10 per cent to 15 per cent usage in blends
with gasoline. And while ``gasohol'' does reduce carbon monoxide
and other air toxics, it produces higher volatile organic
compounds (VOCs) than gasoline.
This means ethanol is primarily useful as an oxygenate to
fight carbon monoxide, but it costs almost $1.40 per gallon to
produce for only 70 per cent of the energy. Without its 60- to
90-cents-per-gallon subsidies from taxpayers (which President
Bush says he would like to phase out), ethanol would disappear
from the market.
That is especially true because some two-thirds of the
oxygenation ethanol provides is now being provided by an
unsubsidized methanol-based product called MTBE (methyl tertiary
butyl ether), which cuts carbon monoxide emissions for $300 a ton
compared with $650 to $1,620 per ton for ethanol.
``Look,'' said Gray, ``we are as much in favor of MTBE as we
are ethanol. In fact, many cities, like Denver, Albuquerque,
Salt Lake City, Reno, are already mandating the use of MTBE as a
replacement for toxic aromatics now used to hype octane. But
MTBE is half methanol, and ETBE, an even better oxygenate, is
half ethanol.
``So what we are already seeing is an ethanol/methanol program
through the back door, with as much as 15 per cent to 25 per cent
alcohol fuels not only to fight carbon monoxide but to reduce
ozone generation. In fact, I see a lot of cities opting in for
MTBE without any mandate, and that's fine with us.''
Precisely. So why not let that happen naturally without costly
mandates? And why not use I/M to charge consumers for the
pollution level of their own car -- and let consumers decide on
the best way to reduce those charges?
Because they would never choose EPA's ``sin-fuels.''
[The following table appeared on page 11:]
-----------------------------------------------------------------
VOC* (Ozone) Reduction Methods and Costs
-----------------------------------------------------------------
1993 Reduction
Method Potential Cost Per Ton
Per Cent Dollars
RACT** (on stationary sources) 6 $ 3,500
Gasoline volatility limits 6 600
Enhanced I/M*** 3 3,500
Federal controls on small stationary
VOC sources 3 1,800
Gasoline vapor recovery -- pumps 3 1,000
Gasoline vapor recovery -- in cars 3 1,200
Methanol fuels 1 $39,000
-----------------------------------------------------------------
Source: Office of Technology Assessment, U.S. Congress.
* Volatile organic compounds.
** Reasonably available control technologies on stationary
sources.
*** Inspection and maintenance for automobile pollution control
devices.
[The following is not part of the original article.]
Cohen, B.L., 1980, ``Health effects of radon from insulation of
buildings,'' Health Phys. 39:937.
Cohen, B.L., 1982, ``Health effects of radon emissions from
uranium mill tailings,'' Health Phys. 42:695.
Cohen, B.L., 1987, ``Tests of the linear-no threshold
dose-response relationship for high-LET radiation,'' Health
Phys. 52:629.
* * *
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