Putting the Clean Air Act on Ice
Guest post by David Middleton
This article rekindled an idea I had several years ago…
Lead pollution in Greenland ice shows rise and fall of ancient European civilizations
Ice-core study finds evidence of plagues, wars and imperial expansion
- May 14, 2018
- Desert Research Institute
- Scientists, historians and economists have used ice samples from the North Greenland Ice Core Project to measure, date and analyze European lead emissions that were captured in Greenland ice between 1100 BC and AD 800. Their results provide new insight for historians about how European civilizations and their economies fared over time.
Thousands of years ago, during the height of the ancient Greek and Roman empires, lead emissions from sources such as the mining and smelting of lead-silver ores in Europe drifted with the winds over the ocean to Greenland — a distance of more than 2800 miles (4600 km) — and settled onto the ice. Year after year, as fallen snow added layers to the ice sheet, lead emissions were captured along with dust and other airborne particles, and became part of the ice-core record that scientists use today to learn about conditions of the past.
In a new study published in PNAS, a team of scientists, archaeologists and economists from the Desert Research Institute (DRI), the University of Oxford, NILU — Norwegian Institute for Air Research and the University of Copenhagen used ice samples from the North Greenland Ice Core Project (NGRIP) to measure, date and analyze European lead emissions that were captured in Greenland ice between 1100 BC and AD 800. Their results provide new insight for historians about how European civilizations and their economies fared over time.
“Our record of sub-annually resolved, accurately dated measurements in the ice core starts in 1100 BC during the late Iron Age and extends through antiquity and late antiquity to the early Middle Ages in Europe — a period that included the rise and fall of the Greek and Roman civilizations,” said the study’s lead author Joe McConnell, Ph.D., Research Professor of Hydrology at DRI. “We found that lead pollution in Greenland very closely tracked known plagues, wars, social unrest and imperial expansions during European antiquity.”
A previous study from the mid-1990s examined lead levels in Greenland ice using only 18 measurements between 1100 BC and AD 800; the new study provides a much more complete record that included more than 21,000 precise lead and other chemical measurements to develop an accurately dated, continuous record for the same 1900-year period.
I had previously played around with trying to tie EPA data for lead pollution into data from the ACT2 Ice Core, Greenland ice core…
So, I downloaded the latest EPA data for lead (Pb), sulfur dioxide (SO2), nitrogen dioxide (NO2) and particulate matter (PM10 & PM2.5) and tied those data into ice core records of comparable “pollutants.”
For each pollutant, I determined a “geological background” (the Earth puts a lot of schist in the air without any human assistance) by calculating the 1772-1850 average ± two standard deviations. The ice core lead (ng/g) correlated very well with the overlapping EPA lead (ppb) data:
Atmospheric lead in the US is clearly at or near an irreducible level. For SO2 and NO2 I used data from Geng et al. 2014. I found a good correlation between the EPA SO2 and Geng’s SO42-.
I didn’t find a good correlation with the EPA’s US NO2 data. Neither HNO3 nor NO3– fit very well.
The most we can say about NO2 is that it’s dropping rapidly and probably near the geological background range.
For particulate matter, I referred to Zielinski & Mershon, 1997. Unfortunately there was only one overlapping point with the EPA’s PM10 data. So, I multiplied the PM10 and PM2.5 data by 246 to put it roughly at the same scale as the ice core data.
Reducing particulate matter has become the EPA’s primary focus in their never-ending quest to statistically save statistical lives. Oddly enough, most of the serious particulate matter pollution is outside the EPA’s jurisdiction and a lot of it appears to be related to deserts and other arid climatic zones.
What have we learned here? We’ve learned the the Clean Air Act has been wildly successful. The EPA deserves a pat on the back for reducing key air pollutants down to nearly irreducible levels. So, why has the EPA been continuously pushing to further reduce these pollutants further below the current National Ambient Air Quality Standards (NAAQS) and often pushing to lower the NAAQS levels?
I guess the EPA figures that so long as there are statistical lives to be saved, they have a duty to statistically save them. But… Is that any way to measure the cost to benefits ratios for new regulations? Unfortunately, that’s exactly how the EPA performs cost-benefit analyses.
Real Costs vs Fake Benefits
[M]any in Congress have expressed concern that Clean Air Act and other environmental regulations harm the nation’s economy. One issue raised by critics is whether EPA underestimates the cost and other negative impacts of CAA rules—in part, by considering them individually, and not considering cumulative impacts. Another criticism is that the agency relies for most of its benefit assessments on the effects of reducing a single category of pollutants, particulate matter (PM). Research has tied PM to tens of thousands of premature deaths, and EPA often finds that reductions in PM emissions justify regulation, even where PM reductions are a “co-benefit” of reducing another targeted pollutant. A third issue critics raise is whether the methodology used to place monetary value on the avoidance of premature death—a technique referred to as calculating the “value of a statistical life”—inflates the estimated benefits of regulation.
According to EPA, the estimated benefits of CAA regulation will exceed the estimated costs by more than 30 to 1 in the period 1990-2020. CAA regulations prevent 230,000 premature deaths annually, according to the agency.
The estimated benefits of CAA regulations rely heavily on the effects of reducing particulate emissions, and on the value placed on the avoidance of premature death as a result of such controls.
Many rules have benefits or costs that cannot be quantified or monetized in light of existing information.
President Trump has issued two executive orders that address the cost of EPA regulations: Executive Order (E.O.) 13771, signed January 30, 2017, and E.O. 13783, signed March 28, 2017. The former directs OMB to set regulatory “budgets” for executive branch departments and agencies and, in general, to rescind two regulations for every new one issued. The latter requires EPA to review—and, if appropriate, suspend, revise, or rescind—several CAA regulations affecting energy production, with an eye to avoiding regulatory burdens. At present, the effect of the two orders on future CAA regulations is unclear. The report discusses some of the possible implications.
A frequent criticism of EPA’s Clean Air Act regulations is that the agency underestimates the cost and other negative impacts of rules by considering them individually, and thus potentially ignoring cumulative impacts. Other critics assert that, by considering rules individually, EPA cost-benefit analyses may double count the benefits of simultaneous regulations. EPA’s RIAs do focus on individual rules, because both the statute—in the many places that it requires consideration of cost or economic factors—and E.O. 12866 require the agency to weigh costs and economic factors and consider options for individual rules.
A second criticism of EPA cost-benefit analyses is that the estimated benefits often rely on the effects of reducing a single category of pollutants, particulate matter (PM). Research has tied PM to tens of thousands of premature deaths, and EPA often finds that reductions in PM emissions justify regulation, even where the target of the regulations is a different pollutant.
EPA Studies of Cumulative Costs and Benefits
Although most cost-benefit analyses have focused on individual rules, EPA has conducted three analyses of the cumulative impact of Clean Air Act regulations, as required by Section 812 of the Clean Air Act Amendments of 1990.20Each of the three analyses found that the benefits of Clean Air Act regulations far exceed the cost.
- The first of the studies, a retrospective study entitled, The Benefits and Costs of the Clean Air Act, 1970 to 1990, was completed in 1997. It estimated that the cumulative cost of Clean Air Act regulations between 1970 and 1990 was $523 billion (in 1990 dollars). The benefits of those regulations outweighed the costs by more than an order of magnitude, according to the agency. The estimated economic value of benefits ranged from $5.6 to $49.4 trillion over the 20-year period, depending upon the assumptions employed, with a mean value of $22.2 trillion. Human health effects accounted for the vast majority of this economic value: the agency concluded that the regulations reduced premature mortality by 205,000 persons annually.21
The agency noted a number of limitations and uncertainties in the data. On the cost side, the agency noted that the estimate ” … does not include several potentially important indirect costs which could not be readily quantified, such as the possible adverse effects of Clean Air Act implementation on capital formation and technological innovation.”22 On the benefit side, the agency noted, “… it is important to recognize the substantial controversies and uncertainties which pervade attempts to characterize adverse human health and ecological effects of pollution in dollar terms.”23 In addition, the estimates ” … do not include a number of other potentially important benefits which could not be readily quantified, such as ecosystem changes and air toxics-related human health effects.”24 Nevertheless, the agency concluded, “Given the magnitude of difference between the estimated benefits and costs, … it is extremely unlikely that eliminating these uncertainties would invalidate the fundamental conclusion that the Clean Air Act’s benefits to society have greatly exceeded its costs.”25
- The second study, a prospective study entitled The Benefits and Costs of the Clean Air Act, 1990 to 2010, was released in November 1999. The study estimated the cost of compliance for regulations under the 1990 amendments to Titles I through V of the Clean Air Act at $19 billion annually in the year 2000 (in 1990$), rising to $27 billion annually in 2010. The estimated economic value of benefits ranged from $16 billion to $160 billion annually in 2000, and $26 billion to $270 billion in 2010. Although costs slightly exceeded benefits at the low end of the benefit estimate, EPA concluded that benefits exceeded cost by more than 4 to 1 for the central estimate.26The study estimated costs and benefits separately for Title VI, which deals with protection of the stratospheric ozone layer. The benefits and costs for this title were estimated for a 175-year period, reflecting the slow nature of repairing the ozone layer. The agency estimated benefits of $530 billion over that time, with costs of $27 billion.27
- The third study, another prospective study, is entitled The Benefits and Costs of the Clean Air Act, 1990 to 2020. This study was released in March 2011. The study estimated the annual cost of compliance for regulations under the 1990 amendments to the Clean Air Act at approximately $65 billion in 2020, with a central estimate of benefits of $2 trillion. Using the central estimates, benefits exceed costs by 31 to 1. As with the earlier studies, “Most of these benefits (about 85%) are attributable to reductions in premature mortality associated with reductions in ambient particulate matter…. ” The agency estimated that “cleaner air will … prevent 230,000 cases of premature mortality” in 2020, at a cost of $280,000 per premature mortality avoided.28
I’ve read dozens of CRS reports over the past decade and this is the first I’ve come across in which the authors names were redacted… Odd. I wonder if this is some sort of protest against President Trump ordering them to actually examine the cost of CAA regulations.
So… The EPA cost-benefit calculation weighs fake benefits against grossly underestimated real costs. In other words, “It’s a joke.” I say “fake benefits” because there is no way to prove or verify that any cases of premature mortality have been avoided. The EPA also likes to use asthma attacks averted – a bigger joke.
It seems to me that a better way to measure the cost-benefit ratio would be in terms of dollars spent vs. incremental reductions of the pollutants. The reduction in the atmospheric concentrations are easy to determine. The EPA rightfully brags about this and makes the data easily available. Straight cost estimates, on the other hand, are not so easy to obtain.
In order to estimate the direct compliance costs of the CAA, I relied on three byzantine EPA reports:
- Benefits and Costs of the Clean Air Act, 1970 to 1990: Retrospective study – On October 15, 1997, EPA issued the first in this series of reports, entitled “The Benefits and Costs of the Clean Air Act, 1970 to 1990,” following completion of a six-year process of study development and outside expert review. The report shows that the public health protection and environmental benefits of the Clean Air Act exceeded the costs of its programs by a large margin.
- Benefits and Costs of the Clean Air Act, 1990 to 2010: First prospective study – On November 15, 1999, EPA issued the second in this series of reports, “The Benefits and Costs of the Clean Air Act, 1990 to 2010” This second study, the first of an ongoing series of prospective analyses, was also issued after a six-year process of study development and outside expert review. This first prospective study also finds that the benefits of the programs and standards required by the 1990 Clean Air Act Amendments significantly exceed costs.
- Benefits and Costs of the Clean Air Act, 1990 to 2020: Second prospective study – On March 1, 2011, EPA issued the third in this series of reports, “The Benefits and Costs of the Clean Air Act, 1990 to 2020.” This third study updates and expands the First Prospective Study by using new and better data and modeling tools. The new study also looks further out into the future by evaluating the costs and benefits of 1990 Clean Air Act Amendment programs through the year 2020. The second prospective study also finds that the benefits of the programs and standards required by the 1990 Clean Air Act Amendments significantly exceed costs.
Using data from the 1997 and 2011 “studies” and an inflation calculator, I cobbled together the following…
From 1980-2000, the inflation-adjusted compliance costs were actually declining, However, if I applied a realistic discount rate, they would have steadily risen and be approaching infinity as I type this.
To estimate the benefits of the compliance costs of the CAA, I divided the annual cost by the annual incremental reduction each of the five pollutants analysed against ice core data. The purpose here is not to determine an actual unit cost of pollution abatement (impossible to do with the data available). The purpose is to determine if the unit cost is rising or falling. I excluded years in which the criteria air pollutants rose, because it yielded negative compliance costs.
Next sulfur dioxide…
Next up, nitrogen dioxide…
On to PM10…
On to the most evilest of all pollutants, PM2.5… Well second most evilest if you count carbon dioxide…
It’s clearly time to put the Clean Air Act on ice. It needs to be repealed or amended to require the EPA to use real cost-benefit analyses for pollution abatement.
Geng, L., B. Alexander, J. Cole-Dai, E.J. Steig, J. Savarino, E.D. Sofen and A.J. Schauer, “Nitrogen isotopes in ice core nitrate linked to anthropogenic atmospheric acidity change.” Proc. Nat. Acad. Sci., 111 (16), 5808-5812, doi:10.1073/pnas.1319441111 (2014).
McConnell, J.R. and R. Edwards. 2008. “Coal burning leaves toxic heavy metal legacy in the Arctic.” Proceedings of the National Academy of Sciences. August 18, 2008. doi:10.1073/pnas.0803564105.
McConnell, Joseph R., Andrew I. Wilson, Andreas Stohl, Monica M. Arienzo, Nathan J. Chellman, Sabine Eckhardt, Elisabeth M. Thompson, A. Mark Pollard, Jørgen Peder Steffensen. “Lead pollution recorded in Greenland ice indicates European emissions tracked plagues, wars, and imperial expansion during antiquity.” Proceedings of the National Academy of Sciences May 2018, 201721818; DOI: 10.1073/pnas.1721818115
Zielinski, G.A., and G.R. Mershon. 1997. “Paleoenvironmental implications of the insoluble microparticle record in the GISP2 (Greenland) ice core during the rapidly changing climate of the Pleistocene-Holocene transition.” Geological Society of America Bulletin 109:547-559.
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