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AIR QUALITY PROTECTION Essay
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Nov 19th, 2019

AIR QUALITY PROTECTION Essay

Thither or Yonder? In pondering an essay on the scope and objectives of a national air quality program, I was filled with some considerable trepidation. What is the role of government & legislation in air quality? What are the required elements of successful regulation? How much is enough? How much is too much? These are profound subjects where science and technology alone cannot generally provide clearcut answers. Political (money) issues, and just plain personal opinion, weigh heavily in the resolution of these issues.

I reached the point where I broke out the Jack Daniels to assist in my contemplation. After all, who am I to be recommending anything? I have no academic or scholarly credentials. I have not served with any industry or government agency charged with air quality regulation or control. I have very little information normally attributed to those in the know. Then I considered the expertise of our leading legislative figures and appointed department heads—those very high on the political food chain.

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Amazingly, I fit right in! I am a perfect example of a growing trend in government circles. That is, the less you know about a given subject, the higher you may expect to rise in government, regulatory, or media circles. Given this, I might reasonably expect to someday head a major environmental protection agency, research institute, industrial concern, or news organization. This is a very exciting prospect! My trepidation evaporated with the realization that I was in concert with the prevailing trend. Confidence restored, I began to tackle the task at hand and now present an enlightened vision for national air quality. Unsullied by expertise or experience. Role of (Federal) Government in Air Quality Regulation The real (i.e. political) essence of this question seeks to define the role, scope, and intrusiveness of the federal government in air quality affairs. A pitched political battle, which continues to this day. Why shouldn’t state and local governments bear the primary responsible for air quality laws and regulations? What should the overall scope of legislation be? The United States initially developed as a mercantile economy, followed by transition to an industrial economy. The laws, regulations, and governance that developed in parallel with the new nation reflected a highly utilitarian view of natural resources and overall environmental quality. And also a strong resistance to federal intervention in the mercantile or industrial market place. Why shouldn’t the market place determine the scope and effect air quality control? What is dirty air? What is clean air? What are air pollutants? How do we know that these are bad? What should be the criteria for identifying air pollutants? How, where, and when are these measured? An inclusive discussion of the debates on these questions is much beyond the ability of this humble essay to approach. But I am reminded of a story from World War II, which I’ll summarize here. A young man in New York was questioning why his school conducted regular air raid drills. Did the Germans have aircraft that could reach Long Island? After some research, his father told him that the Germans probably did not have airplanes which could reach us, but they did have very good submarines and we’d better watch out for them. Meanwhile, the air raid drills were a good idea just in case they had something that we didn’t know about. Which brings me to the first tenet of government action and air quality regulation: There are certain things we should do—-just in case. This is a healthy logic, and applies well to the notion of national government involvement in air quality issues. Even a brief perusal of literature from such sources as the EPA or the National Center for Atmospheric Research shows a very real uncertainty about the health or economic effects of dirty air. Or even a defined composition of dirty air. Or the distribution of clean or dirty air. Many statistical studies have shown an apparent correlation between deaths/illness to dirty air. But the complexities of individual health make it almost impossible to link a particular pollutant concentration to group mortality or morbidity. Even the notion of what constitutes a pollutant is up for grabs. Global warming is an intensely debated topic and formerly-innocuous gasses such as carbon dioxide and water vapor are now accused of causing global climate changes. How much of this is so much political hogwash? Debate and inaction can proceed ad infinitum. But here lies the rationale for a level of national involvement in air quality regulation. The first requirement for air quality control is to define the most apparent components, concentrations, and sources for air pollutants in a uniform and applicable manner. A catalog of these elements is a very good first step. National government has responded with reasonable effectiveness to this entry-level requirement. Indeed, it has provided these definitions with a fair degree of uniformity and applicability. Science, however, has not yet provided a definitive understanding of air pollution interaction with health, climate, and economic activity. But the entry-level definitions provided by the national government (read EPA) allow a rational starting point for government and industry to begin to address these issues—just in case. Regulatory Strategies This brings me to the second tenet of government legislation and air quality regulation. Objectives. Before an effective regulation of air quality may begin, a clearly defined national policy and a set of goals/objectives must somewhere be defined. The national government, through the EPA, has done appropriate work in providing entry-level definitions for the components, concentrations, sources, and measurement of air pollution. Much research and refinement of these definitions is proceeding. A reasonable roadmap for implementation and enforcement of air quality, however, has been something of a mixed bag—and a mixed blessing. Certainly the EPA advertises many apparent successes in using its’ myriad of definitions and criteria to yield improvements in air quality throughout the U.S. Criteria pollutants such as SO , NO , CO, and Pb are all down substantially. Or at least, our measurements say so. In the hands of activists, however, the National Environmental Policy Act (1969) has become a strict procedural statute rather than a guideline. Citizen action groups have acquired the ability to block any development on even the most superficial procedural grounds. The classic case for this vignette is Scenic Hudson Preservation Council vs Federal Power Commission (1966). This contradictory state of affairs has been reached by a failure to articulate clear, unambiguous objectives for air quality and to develop a public consensus for reaching these objectives. What is our overall national air quality goal? A zero-discharge economy? Sustainable development? Managed biodiversity? Status quo or sustained reduction in pollutants? Again, these are fundamental questions which have not been unambiguously answered. Absent an agreed goal, even at local level, every interest in the on-going air quality debate has developed its own interpretation of objectives for regulation. The federal government, it seems, is vested with a responsibility to do something—-just don’t do us out of money, power, jobs, or conveniences. Facing the contradictory wrath of their public, and the whims of the media, politicians and bureaucrats have generally tried to straddle the issue or to avoid it like the plague. On this subject, I’m again reminded of a story—this one from my personal files. Some years ago, I took up an interest in service rifle competition. At the time, I elected to compete with a Springfield Model 1903 rifle. The service rifle we fought World War I with, and just like Gary Cooper used in Sergeant York. My first outing to the range was an enlightenment, however. I took a good solid grip on the wooden stock, a good solid cheek-weld, good stance, lined up the sights, and touched it off. On recoil, the butt of my right hand slapped me just below the eye. My shooting coach, an old pro at this, snickered. By the end of the range session, I had an embarrassing, and unexplainable, knot on my right cheek, just below the eye. My coach explained. The Springfield stock was designed by a committee. None of them were accomplished riflemen. Each had a vested interest in a portion of the weapon, but not in the overall product. The committee’s objective was to design a stock that would fit everyone. The result was that it fitted no one. And so it is today with much air quality regulation. As a second tenet of government legislation and air quality regulation, then: You need clearly understood goals & objectives. If you don’t know where you’re going, any road may get you there. Or no road at all.Regulatory Economics The third tenet of air quality control is simple to state, but most difficult to attain in practice. Common Sense. Common sense rejects the deep green argument for a fundamental reallocation of global production and consumption. Common sense also rejects the status quo. How much economic resource is to be spent on air quality? How much is too much? How should this be determined and allocated? I’m saving the answer to these enigmas for my term as a high ranking industry mogul or talk show host. From a pure economic standpoint, however, government is probably a poor choice as the primary instrument for controlling the resources used in air quality control. Government can be surprisingly effective in defining problems, but is much less effective in providing solutions. An excellent analogy was pointed out by Milton and Rose Friedman in their classic 1980 economic text Free to Choose. The Friedman’s describe 4 ways in which money is spent:- You spend your money on yourself. You’re motivated to get the things you – want at the best price. So middle-age men haggle with Porsche dealers- You spend your money on other people. You still want a bargain, but you’re less interested in pleasing the recipient.- You spend other people’s money on yourself. You get what you want, but price no longer matters. The second wives who ride with middle age men in Porsches do this kind of spending at Nieman Marcus- You spend other people’s money on other people. And in this case, who cares?I would posit that most government spending follows Rule 4 above. This leads to my third tenet of air quality economics: A degree of air degradation is a cost of being alive, a cost of being employed, and a cost of services enjoyed. If we want to manage air quality with common sense, then that management should provide economic benefits. I would also posit that government’s role, and challenge, in regulatory economics is to provide standards, definitions, to encourage sound basic research, and to provide incentives for meeting air quality goals and standards. And speaking of controlling air pollution, in my utopian world of economics, frivolous lawsuits would be one of the first forms of pollution to be controlled. Scenic Hudson, spotted owls, and the snail darter again spring to mind. So where does this leave us? These ideas are remarkably free of details. Consider, however, that Sir Walter Raleigh was not mired in the details of sail construction or rudder design when he stated (paraphrased); He who rules the seas rules commerce, and he who rules commerce rules the world. I’ll save the rest for my next television appearance.

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