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Particle Omissions



Dear Editor:

Harold Henderson (April 18) attempts to split hairs with an axe when he says, "While environmentalists exaggerate, the business and antiregulation lobbyists lie," citing as an example the use of a quotation from a letter sent by EPA's Clean Air Scientific Advisory Committee (CASAC) saying that the EPA had failed to "provide a scientifically adequate basis" for setting a fine-particulate standard, which he asserts was only a comment on rough drafts and does not represent the committee's final conclusion on the EPA's final proposal. After saying they lie, he notes: "The quotation is accurate." So how is it a lie? Misleading, perhaps. An exaggeration, perhaps. But how can an accurate quote be a lie?

Let's lie some more. Let's accurately quote George Wolff, the atmospheric scientist who headed the CASAC panel: "I don't think the standards that have been chosen accurately reflect the advice that CASAC has given the administrator." Mr. Wolff notes that it is almost unprecedented for the EPA to ignore the committee's suggestions. But, when you have your mind made up, why should EPA administrator Carol Browner let the facts stand in her way?

The CASAC panel wrote to Browner: "The Panel felt that the weight of the health effects evidence indicates that there is no threshold concentration for the onset of biological responses due to exposure to ozone above background concentrations....This means that the paradigm of selecting a standard at the lowest-observable-effects-level and then providing 'an adequate margin of safety' is no longer obtainable."

Perhaps this is why most members of CASAC advised against lowering the ozone standard, concluding that it would not be "significantly more protective of public health," why only four out of twenty-one members supported the proposed new standard for particulate matter, and why CASAC concluded that "...there are no significant public health benefits observed by going from the present standards to any of the standards proposed by the EPA."

It is mind-boggling that in an op-ed piece in Insight magazine (April 28) Carol Browner could admit that since 1970 "emissions of the six major air pollutants have dropped by 29 percent, while the population has grown by 28 percent and the gross domestic product has doubled" and yet insist on the need for new ozone and particulate matter standards so draconian that, as Senator John Chaffee notes, you could shut down every factory and barbecue grill in Rhode Island and the state would still not be in compliance. The city of Baltimore has calculated that motorboats and lawn mowers alone currently contribute more ozone to its air than all of its industry put together, indicating both how clean our air has become and how stringent the new standards are.

One can argue that the EPA has indeed failed to "provide a scientifically adequate basis" for its proposed new standards. And one can argue that what is going on here is that the EPA fears it may be a budgetary victim of its own success and is yelling fire in a fireproof theater to ensure an ever-flowing stream of money and bureaucratic power. Why else would it insist on standards that would place national parks in danger of noncompliance?

The EPA proposes to cut smog levels by one-third to 80 parts per billion. Yet the EPA's own data shows nine national parks and forests that had average smog levels from 36 to 72 parts per billion--that last reading recorded at the Theodore Roosevelt National Park in highly industrialized and urbanized North Dakota. As S. Fred Singer, professor emeritus of environmental science at the University of Virginia, notes, trees produce hydrocarbons and that's why the Blue Ridge Mountains are "blue" and the Smoky Mountains are "smoky." If national parks are in danger of smog violations, how can urban industrial centers ever hope to avoid them?

Particulates in the air are primarily either windblown dust or minute aerosols formed by the oxidation of sulfur, nitrogen, and organic gases and vapors in the atmosphere. The sources of these particulates are ubiquitous, being of natural, foreign, and domestic origins. Jet stream winds can bring industrial emissions across the Pacific Ocean from the Far East within 48 hours. Agricultural activities can produce dust laced with nitrates and ammonia. Sulfur gases are produced from the decay of vegetation, volcanoes, and even algae in the ocean. Forests contribute significant quantities of organic vapors.

According to a Centers for Disease Control study: "No evidence exists that supports the role of outdoor pollution levels as the primary factor in asthma morbidity." Out of an average of some 28,000 asthma-related hospital admissions in New York annually, the EPA itself projects that under the new rules there would be just 265 fewer admissions, a reduction of an outstanding .009 percent. Anyone care to run a cost-benefit analysis?

In a recent issue of Science, Julian M. Hopkin concludes that increased asthma rates are not linked to increased air pollution or other environmental toxins. And the National Institute of Environmental Health Sciences, a research arm of the Clinton Administration's Department of Health and Human Services, states that "the distribution of asthma in other countries also fails to implicate pollution as an aggravating factor."

Studies on rodents bolster the notion that current standards are more than adequate. A two-year study conducted by the National Institute of Environmental Health Sciences found "no evidence of 'carcinogenic activity' from ozone in rats continually exposed for two years at levels up to one part per million--about 8.3 times the federal standard and far higher than levels in urban smog."

For the vast majority of people the present condition of the air poses no health risk at all, even on the hottest summer day. Only severe asthmatics, the elderly, and those with advanced cardiovascular-respiratory disease have trouble breathing. And that's more a function of their deteriorated capacity than of the quality of the air. It is ridiculous to wager billions of dollars on the speculative possibility that we may be able to extend the lives of a few terminally ill patients on the average of, at most, a few hours.

The EPA is ignoring the law of diminishing returns and forcing communities to spend limited resources chasing after phantom health risks associated with smog rather than on such things as teen drug use, crime, AIDS prevention and treatment, poor educational performance, or a host of other problems they may consider more serious than occasional shortness of breath or wheezing.

Daniel John Sobieski

S. Monitor

Harold Henderson replies:

EPA and its independent science advisory committee (CASAC) had a monthslong conversation about the fine particle standard. In the middle of that conversation (January 1996), CASAC said there wasn't any scientific basis for such a standard. At the end of the conversation (June 1996), CASAC said there was. Three business and antiregulation lobbyists that I know of quoted CASAC's statement from the middle of the conversation as if it were the conclusion. If that's not a lie, very few are ever told.

True, CASAC did not even come close to agreeing on what the standard should be. EPA was left to decide that on a policy basis. Wolff is entitled to his personal opinion (he recommended a more lenient standard). EPA might perhaps have been mistaken or hasty in proposing a new standard. But that case will have to be made on the merits. I saw no evidence in the record of their conversation that EPA's action "ignored" or contradicted CASAC's advice. If there were any, Mr. Sobieski's letter could have been quite brief.

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