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
   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
*** Inspection  and maintenance for  automobile pollution control

     [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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