If Jean-Paul Sartre were still alive he might be induced to update his play “No Exit” to be about Americans locked in a room discussing how EPA air regulation destroyed their standard of living.
In a commentary in the New England Journal of Medicine (July 6), Jonathan Samet asserts that,
For ozone and particulate-matter pollution, because no thresholds have been identified below which there is no risk at all, the EPA is using scenarios of risk and exposure to gauge the effects of setting the standards at various concentrations and giving consideration to the burden of avoidable disease.[Emphasis added]
Samet is not just some random person spouting junk science; he happens to be chairman of the EPA’s Clean Air Scientific Advisory Committee (CASAC), a group that purports to pass on the scientific merits of EPA air standards.
What Samet is saying is that there is no scientific basis for EPA not continually reducing manmade air emissions until there aren’t any. As Samet points out, under the Clean Air Act, the EPA could literally regulate us out of any sort of industry without regard to the consequences:
The CAA also requires the EPA administrator to set National Ambient Air Quality Standards (NAAQS) for pollutants for which air-quality criteria are listed. The language of the law on this point provides a strong public health mandate that has evolved through application and litigation. By intent, the NAAQS must protect susceptible groups within the U.S. population, although protection for the most susceptible may be unattainable. The achievement of what the CAA calls an “adequate margin of safety” does not imply that risk-free levels have been set, but that an acceptable level of risk has been reached, given uncertainties in the evidence. The costs of implementation and compliance are not to be considered in setting the NAAQS, although the law does call for costs to be considered in the setting of individual emission standards (e.g., for vehicles and electric utilities) that are intended to help meet the NAAQS. [Emphasis added]
Contrary to Samet’s view, however, the scientific reality of today’s air quality is that no one is America is being harmed by it. American air is clean and safe.
As such, further EPA efforts to tighten air quality standards are unnecessary; they will cost millions of jobs and trillions of dollars in economic growth, while producing exactly zero in terms of public health. This is not what Congress intended when the Clean Air Act was passed in 1963 and amended in 1970, 1977 and 1990.
The Clean Air Act, as implemented by the Obama EPA, is nothing short of a political attack on America using air quality as an excuse.
For those of us who have been in the business of having to comply with EPA whimsy, the phrase “more and more regulations over less and less” was used 20 years ago. Unlike environmental groups, corporate America is not in business to take EPA to court over idiotic regs, especially with a judiciary that is on the side of the greenies.