Kyle Isakower
Mgr., Environment Policy, American Petroleum Institute

The key term to remember when discussing the PM2.5 science is uncertainty. Supporters of tighter standards primarily use epidemiological studies to justify their positions. However, these studies are highly uncertain due to many factors too numerous to discuss here. Suffice it to say that many variables can influence epidemiological study results, and it is difficult for researchers to single out any one variable with a high degree of certainty.

The studies in question show an extremely small association between ambient PM levels and health impacts–so small, in fact, that they are dwarfed by the analyses' inherent uncertainties. It is analogous to an early election-night poll that shows one candidate with a 50.0% to 49.8% lead and a margin of error of +/- 3.0%. It would be nonsensical in such a situation to predict the outcome. Similarly, the current epidemiological studies cannot reliably detect miniscule risks given their inherent uncertainty.

The stakes are high. The suggested revisions would dramatically increase the number of nonattainment areas across the country. Those nonattainment areas would face severe restrictions on future economic development.

EPA has promulgated stationary and mobile source rules in response to the last revision to the PM standard in 1997. Local controls will also be required in many areas. Collectively, these emissions controls represent tens of billions of dollars in new investments. Yet we have not seen whether these investments will provide their expected health benefits. With so much at stake, and the science so uncertain, doesn't common sense dictate that we evaluate the health benefits of the current standard before we significantly change it?

Dr. George D. Thurston
Associate Professor,
NYU School of Medicine

Cleaning up the air we breathe is not only sound science, but it is also sound economics–especially when you consider what air pollution costs us every day in needless sickness, lost work days, missed school days, added hospital admissions, and even premature deaths.

So what's the "payback"? It is said: "An ounce of prevention is worth a pound of cure." Actually, the most recent cost-benefit study done by the Environmental Protection Agency (EPA) found that the monetary value of clean air health benefits is even more than 16 to 1–it is some 30 times the cleanup cost.

Clean air has been a good investment. Air emissions have been cut by half since 1970, while the U.S. GDP has increased about 176%. EPA estimates that lower pollution was responsible for averting 200,000 deaths, 210,000 hospital admissions, 22,000 cases of coronary heart disease, 850,000 asthma attacks, and 22 million lost work days in 1990 alone. For 1970 to 1990, EPA values the health benefits at $22 trillion, versus only $0.5 trillion for cleanup. Cleaner air has paid great dividends.

But if history is any guide, there will be those who spread "sour grapes" saying that the new clean air goals will be too costly. This has always been the argument, and it has always been proven wrong. Some have claimed that it would cost $1,500 per ton of sulfur dioxide to reduce acid rain, but emissions allowances are presently trading as low as one-fifth of that figure. The fact is, American industry invented and sold new technology to clean the air once it was required to do so by law. American business should again be turning those "sour grapes" into the "fine wine" of cleaner air and higher profits.