CFACT briefing paper on clean air

CFACT Briefing Paper #103

For much of this century clean air has been a public concern. 
Many are troubled by the health impacts smog, soot and other
airborne particles are alleged to cause.  Most Americans, to be
sure, are happy to see regulatory limits placed on machines,
factories, and autos that are responsible for such pollution.

Experts say the problem of dirty air is directly related to a
situation called “the tragedy of the commons.”  In essence, the
argument goes, because air is free to be used by all, no one has
to take responsibility to ensure it remains clean.  Therefore
government intervention becomes necessary.

Unfortunately, the government’s involvement in cleaning up our
air has come at a price.  While it certainly is true that laws
like the Clean Air Act have helped scrub pollutants such as lead
and carbon monoxide out of the sky, making our air much more
clean, the EPA bureaucracy that was established to regulate the
problem has had to justify its existence now that the dangers
from air pollution have been largely abated.  Today, in an era of
government downsizing and budget deficits, this has become
increasingly the case, and the laws regulating clean air have
kept getting tighter and tighter. 

For the American public this bureaucratic and top-down
approach to cleaning up our air has been, and is becoming
increasingly costly.  The number of jobs in jeopardy, the impact
on economic productivity, and the rising costs for such items as
gasoline and electricity are all combining to potentially wreak
havoc on the US standard of living.

This report will seek to examine the current clean air debate in
more detail. It will look into such questions as: (1) How clean
is America’s air today — have we been making great strides, (2)
are there still serious health problems associated with clean air
standards in America, and (3) what are the possible consequences
with going too far in trying to make our air cleaner than clean?

A Clearer View Back

Air pollution is as old as the hills.  Queen Eleanor recorded the
first complaint against dirty air in England when she visited
Nottingham in 1257.1  Londoners spoke of air pollution in the 14th
century, and Italians were allegedly killed by airborne mercury
poisoning in the 18th century.2 

According to one historian, mining operations in medieval England
caused so much pollution that King Edward I, in 1307, issued a
royal proclamation making the burning of coal a capital offense
while Parliament was in session —  an offense for which a man
was actually beheaded.  And by the 17th century pollution had
become so bad in London that John Evelyn wrote a book lamenting
“this Glorious and Ancient city … should so wrap her stately
head in Clowds of Smoake and Sulphur, so full of Stink and
Darknesse [sic].” 3

More recently in this century, air pollution is alleged to have
caused respectively sixty, twenty and 4,000 so-called “excess
deaths” in three classic air pollution episodes: Meuse Valley,
Belgium in 1930, Donora, Pennsylvania in 1948, and London,
England in 1952.  Although more contemporary research done by
scientists like Dr. Hugh Elsaesser of the Lawrence Livermore
National Laboratory casts doubt over the validity of air
pollution as the culprit in these tragedies, citing outbreaks of
influenza as being a more likely villain, they nevertheless
remain fixed in the public mind as clear case examples of the
deadly consequences of too much air pollution.4

What are the Trends?

Even before the Clean Air Act amendments were passed in 1970, air
quality was improving significantly.

The following information was gathered from Continuous Air
Monitoring Project Stations set up in 1962 to monitor six major
cities — including Chicago, Cincinnati, Denver, St. Louis,
Philadelphia, and Washington.  They found that:

* Concentrations of settleable dust fell between 1925 and 1965.

* Levels of sulfur dioxide fell between 1962 and 1968.

* Total oxidants (ozone) fell between 1964 and 1968.

* Carbon monoxide levels fell in four cities and rose in two
between 1964 and 1968.5

In addition, data taken from the National Air Sampling Network
revealed that:

*Between 1957 and 1966, concentrations of airborne particulates
fell in 58 urban areas and were almost unchanged in 20 nonurban
areas.

* Between 1962 and 1968, sulphur dioxide levels fell at 22
urban sites.6

Total emission levels for many pollutants, to be sure, did rise
between 1900 and 1970.  However, on a per capita basis, as a
cursory review of EPA data taken from their publication National
Air Pollution Trends 1900-1993 reveals, there were definite
downward trends for a number of serious pollutants over the
century.  Whereas in 1920, for example, the per capita emissions
of sulphur dioxide was around 200 million tons per 1000 persons,
and in 1930 VOC’s (volatile organic compounds) were around 150
million tons per 1000 people, both levels had dipped to 125 and
130 million tons respectively by 1960, and to under 100 million
tons today.7  Total particulate matter [PM-10] emissions actually
fell from about 16 million short tons in 1940 to around 12
million short tons in 1970.8

Again, this is not to say total emissions from all pollutants
have dipped since the turn of the century, but clearly there were
encouraging trends even before the powerful Clean Air Act of 1970
was signed into law.

The reasons for these encouraging trends were manifold.  As
explained by Dr. Hugh Ellsaesser, “the trend toward cleaner air
[was] driven by technological change, state and local pollution
controls, increasing electrification, and a shift of economic
activity from manufacturing to service industries.”9  In other
words, our own progress was beginning to clean the air even
before legislators got in on the act.

1970-Present: Air Pollution Takes a Dive

Since the passage of the 1970 Clean Air Act (CAA), major
pollutants have witnessed even sharper declines in emissions. 
Among those that have dropped dramatically since 1970 are:

* Carbon Monoxide by 23 percent

* Volatile Organic Compounds by 24 percent

* Particulate Matter [PM-10] by 78 percent

* Sulphur Dioxide by 32 percent

* Lead (Pb) by 98 percent

Indeed, air pollutants as a whole have decreased some 24 percent
since 1970.  This despite a 27 percent increase in US population,
a 111 percent increase in domestic vehicle miles traveled, and a
90 percent increase in our GNP.10 

And for those worried about the aftermath of the Reagan-Bush
years, well they can sleep easy.  More recent data taken over the
past ten years shows that things are still on the up and up. 
According to the EPA, air quality continues to improve
dramatically, with sharp drops in all six NAAQS pollutants
monitored between 1986-1995.11

The Clean Air Act
The Clean Air Act, as we know it today, was originally enacted in
1970, amended in 1977, and again in 1990.*  At the cornerstone of
this legislative effort was the establishment of National Ambient
Air Quality Standards (NAAQS).  These standards set the minimum
acceptable air quality concentrations of certain pollutants
deemed to be a potential hazard to public health.

There are six major pollutants for which the EPA has set
standards, these include: Carbon monoxide (CO), nitrogen dioxide
(NO2), lead (Pb), ozone (O3), particulate matter (PM10), and
sulphur dioxide (SO2).

For each of these pollutants, primary and secondary standards
have been set that are defined as follow:

Primary: Levels sufficient to protect public health including
sensitive populations such as asthmatics, children and the
elderly from measurable adverse effects with an adequate margin
of safety; and

Secondary: Levels which protect public welfare from adverse
effects on economic value (e.g. crop damage, wildlife, visibility
and building damage) and personal comfort (e.g. weather,
climate).12

These standards are allegedly based on “scientific” analysis
without any regard being given to cost or technical feasibility.
 
Further, the Act requires a periodic review of the criteria set
for the various pollutants and, if appropriate, a revision of the
requirements.  The Act mandates the establishment of an
independent scientific review committee to examine the criteria
and recommend to the EPA Administrator any changes that might
need to be made.  The name of this committee is the Clean Air
Scientific Advisory Committee (or CASAC for short).

*The Clean Air Act actually first passed in 1963, however, in its initial form bore little resemblence to what what it looks like today.  Therefore, it is commonly said to have first been passed in 1970.

The present standards are as follows:

Pollutant     Primary  Secondary

Carbon Monoxide 
8 hr concentration  9 ppm
1 hr concentration  35 ppm

Lead
Qtrly arithmetice mean 1.5 Fg/m3  1.5F3

Nitrogen Dioxide
Annual arithmetic mean 0.053 ppm  0.053 ppm

Ozone
1 hr concentration  0.12 ppm  0.12 ppm

Particulate [PM10]
Annual arithmetic mean 50Fg/m3  50Fg/m3
24 hr concentration  150 Fg/m3  150Fg/m3

Sulphur Dioxide
Annual arithmetic mean 0.03 ppm
24 hr concentration  0.14 ppm
3 hr concentration     0.50 ppm

Fg/m3 = micograms/cubic meter, ppm = parts per million, mg/m3 = milligrams/cubic meter of air 
_________________________________________________________________

At present, there are some 4469 monitoring stations located
throughout the US.  These are referred to as the EPA’s Aerometric
Information Retrieval Service.  These monitors are not often
placed where the overall public is actually exposed, but where
pollution is thought to be the highest. In addition, the monitor
which has the worst reading is used as the basis for determining
whether a given municipal area is in “attainment” or
“nonattainment.”  In other words, if even one monitor in a given
city is out of compliance for just one hour under the present
ozone standard, the whole city is gigged for the entire day.

Further, if any of the monitors exceed compliance levels just
four times in three consecutive years, the entire city is
labelled as being in “nonattainment.” It will retain this label
for at least three years — even if it comes back into compliance
immediately.

Once designated as being in nonattainment, the EPA then pegs the
region as being in one of five categories (depending, of course,
on how far the city exceeds its compliance level): These are
“moderate,” “marginal,” “serious,” “severe,” and “extreme.” 
Depending on how out of whack a given region is, certain measures
are to be undertaken in “state implementation plans” to get the
city back into compliance.  Many of these measures, like mandated
carpooling, tailpipe inspections at centralized facilities, and
the selling of reformulated gasoline, have been explosive issues
that have received a great deal of publicity.

At present, there are 32 remaining carbon monoxide nonattainment
areas, 31 moderate, 1 serious.  There are 71 nonattainment areas
for ozone, 82 nonattainment areas for particulates, 43 
nonattainment areas for sulphur dioxide, 10 remaining
nonattainment areas for lead, and only one for nitrogen
dioxide.13

The Fundamental Problem with the Clean Air Act

While the Clean Air Act has certainly done much to lower emission
levels of pollutants over the past twenty years, there is one
large problem associated with it;  namely, its goal.  To put it
bluntly, the goal of the Clean Air Act is simply unattainable.

The language of the CAA calls for air quality standards to be
“based on such criteria and allowing an adequate margin of
safety, [as] a requisite to protect the public health.”  While
this may sound rather nebulous to most people, this language has
come to mean, for the EPA anyway, that there is to be a “zero
risk” paradigm against any possible adverse health effect to any
individual.  This goal, naturally, is to be pursued by the agency
without reference to costs and benefits and without distinction
between major and minor health impacts. Even two time EPA
administrator William Ruckelshaus has referred to the prime
directive of the CAA as an “impossible standard of perfection.”14

The goal is made even more unachievable by the fact that some
pollutants, like ozone, provoke biological responses in certain
people down to the lowest levels — even those commonly found in
nature.  The CASAC recently sent a letter to Carol Browner,
Administrator of the EPA, saying: “Based on information now
available, it appears ozone may elicit a continuum of biological
responses down to background concentrations … {thus} the
paradigm of selecting a standard at the lowest-observable-
effects-level and then providing an `adequate margin of safety’
is no longer possible.”15

Health Impacts: Smoggy at Best

On November 27, 1996, the EPA announced the most significant
tightening of its air quality standards in over a decade — a
move that sent industry howling in protest.  Specifically, the
EPA was promoting new standards for particulate matter (i.e.
“soot”) and ground level ozone (i.e. “smog”).  The particulate
standard would be expanded to include particles down to a size of
2.5 microns or smaller while the ozone standard would be dropped
from a level of .12 ppm to .08 ppm (while the hours of exceedence
increased from one to eight).  The move is being justified, of
course, to protect public health.  As Carol Browner noted at the
press conference announcing the proposal, “The current standards
do not adequately protect human health.”16

But is she correct?  Most scientist say, “No.”

Regarding particulate matter, there is simply not a lot of
credible evidence to suggest any widespread health panic.  This
was made clear by the CASAC in a letter to Carol Browner dated
June 13, 1996 which stated:

“The diversity of opinion [among EPA scientists] also reflects
the many unanswered questions and uncertainties associated with
establishing causality of the association between PM2.5 and
mortality.  [A number of] panel members were influenced, to
varying degrees by the many unanswered questions and
uncertainties regarding the issue of causality.  The concerns
include:  exposure misclassification, measurement error…the
lack of understand of toxicological mechanisms, and the existence
of possible alternative explanations [to explain mortalities].”17

Indeed, the primary evidence suggesting a problem are two
questionable studies.  The first is by researchers (Pope et al.)
who used data from the American Cancer Society and the second was
a Harvard report called the “Six Cities Study.”  The conclusions
drawn from these two reports was later extrapolated by the
Natural Resources Defense Council and used to trumpet the claim
that “64,000 people may die prematurely from heart and lung each
year due to particulate air pollution.”18  These studies, along
with the NRDC report, received widespread coverage in the major
media and no doubt contributed greatly to the EPA’s decision to
move forward with tighter particulate matter regulation.

However, there are a number of glaring problems with the ACS and
Six Cities Studies — problems which obviously compromise the
validity of the NRDC report as well.  According to Dr. Kenneth
Brown, a consultant who reviewed the reports, these problems
include:

1. Unverifiable levels of personal exposure to particulate matter
— The studies made an assumption that all people in a given city
receive equal levels of PM emissions. Most certainly, some people
receive “high” levels of PM exposure while others do not.  This
is certainly the case with the various EPA monitors in a given
metropolitan area. Even more importantly, though, “one cannot
determine if individuals with higher personal exposure to PM2.5
tended to have higher mortality rates than those with lower
personal exposure.”19  In short, there is a large potential for
error when city wide data is used to replace individual levels of
personal exposure.

2. Very short timeperiod of exposure examine — The ACS study, in
particular, used fine particle data for 1979-83.  The persons
they examined covered the period 1982-89.  This is a very short
timeperiod between the exposure of PM and observing its
consequences.  A more long-term analysis would be far more
accurate in determining a correlation.  As the author states,
“Air pollution levels for the preceding decade or two may be more
relevant if cause-and-effect is to be postulated.”20  The study
is made even more shaky since air pollution levels have continued
to drop over the past several decades. 

3.  A statistical cross-section of America was not used —  The
population that was relied upon for the ACS study was not
representative of the makeup of our nation.  Only 4 percent were
black, less than 1 percent hispanic, almost none were single, and
only 25 percent of the men smoked while nearly 50 percent of the
women in the survey did.  The reason for the unusual mix was
because volunteers were relied upon to generate the data.  Those
enrolled consequently were largely the friends, relatives, and
neighbors of the volunteers.  A more accurate study would take a
more realistic cross-section of our nation and its cities.

As a sidenote, PM10 levels have declined steadily over the past
ten years.  According to data collected from the 585 stations
that gather data on PM10, concentrations have dropped from around
34 Fg/m3 in 1988 to around 27 Fg/m3 in 1995.21  What’s more, the
precursors to fine particulate matter (namely SO2 and VOC’s) have
also dropped in recent years, indicating much of the drop of PM10
was largely due to declines in PM2.5.22  What this simply means is
that health concerns regarding particulate matter should be
diminishing, not a cause for alarm, hardly necessitating a need
by the EPA to bolster standards.

Regarding the health effects surrounding ozone, the second
concern of the EPA’s latest regulatory squeeze, epidemiological
studies fail to demonstrate serious health consequences even at
levels far in excess of the present standard.  As noted by Dr.
Harry M. Walker of the Society for Environmental Truth:

“Some of the regimens used in human ozone exposure experiments
called for exercise at a level approximately equal to that
required to run a marathon race generally for 50 minutes per
exposure hour.  Few people go in for heavy exercise at the peak
of the day [when ozone levels are highest] …You just can’t
produce adverse [health] effects at .12 ppm without unreasonable
levels of exercise.  Again, the effects that can be created by
such artificial means always quickly disappear — sometimes in an
hour or so, essentially always overnight.  The environmentalists
have worked hard to try to prove the existence of long-term ozone
effects but they haven’t found them at possible real world
levels.” 23

Based upon the EPA’s estimate, as noted by the Center for the
Study of American Business, typical subjects usually experience
less than a 10 percent drop in lung function even at ozone levels
twice the current standard of .12 ppm — and in many cases even
four times the current CAA standard!24  Such a decline in lung
function is undetectable to most people.

Studies on rodents even further bolster the notion that exposure
to high levels of ozone isn’t necessarily a significant health
hazard. According to an article in the Wall Street Journal, a two
year study conducted by the Health Effects Institute and the
National Institute of Environmental Health Sciences (a federal
agency) 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.”25

Thus, although the EPA has made claims in the past that some 23.5
percent of the US population lives in ozone nonattainment areas,
this is hardly anything to panic about — especially from a
public health perspective.  Usually exceedences in the ozone
standard are very brief in duration at a time when people are
mostly indoors, i.e. the “heat of the day.”

Finally, one of the most authoritative studies ever done on the
issue of what causes cancer was conducted by Sir Richard Doll and
Dr. Richard Peto in 1981 and found that air pollution, at best,
only accounts for just 1 percent of all US cancer each year.  The
famous epidemiologists acknowledged, surprisingly, that even this
1 percent estimate was a very crude guess since they found
absolutely no concrete evidence suggest any link whatsoever
between cancer and air pollution.  It is safe to say, then, that
whatever link might have existed back then is even less likely
today since air pollution levels are far lower than the early
1980’s.26

Gasping at the Costs

The CAA amendments of 1990 stipulate that the EPA must conduct
periodic studies to weigh the costs and benefits of its clean air
efforts.  The first report covering the years between 1970-90 was
released in May 1996.  The Agency estimated that the benefits
derived from the CAA was between $2.7 and $14.6 trillion while
the costs were only around a cool $436 billion for compliance.  A
good deal to be sure, but there are clearly three glaring
deficiencies in this analysis:
1. Almost all of the benefits noted by the EPA were for cutting
down on just two pollutants: lead and particulate matter.  Many
other programs most assuredly did not pass the cost-benefit
muster, a point that was even tacitly acknowledged by the EPA in
its draft report which stated, “it is likely that some specific
historical programs or standards may not have yielded monetorized
benefits in excess of costs.”27  Thus to say all the costs
associated with the CAA were worth it is clearly overstating the
point.

2. Opportunity costs are also not taken into account in the EPA’s
cost-benefit analysis.  There is no way to know for certain if
society would have been better served placing much of the money
spent on cleaning up our air into other areas which are more
productive.  A Harvard University study notes that 60,000 lives
are lost unnecessarily each year because of the current
regulatory regime which chooses certain costly actions to save
few lives over less expensive ones to save more lives. In
environmental regulation, where oftentimes billions are spent to
only save a hypothetical life, this is well known to be
especially the case.  Thus, by implication the costs regarding
clean air may indeed be higher when one considers how the monies
might have otherwise been spent.28

3. Finally, as pointed out by the Center for the Study of
American Business, historical cost-benefit analysis portray
little resemblance to future comparisons.  Because pollution
levels were so high in the past, achieving a favorable cost-
benefit ratio was rather easy, per se.  Today, however, with
pollution levels down to those nearly found in background levels,
attaining a favorable cost-benefit ratio is nearly impossible.

If in fact the new standards are tightened, there will be a
number of costs imposed on the public.  For starters, a whole
host of regions will automatically be out of compliance, not
because they are unsafe, but because they have been moved there
by shuffling statistics.  Under the proposal, hundreds of
communities where at least 100 million people live would, with a
stroke of the pen, be placed in nonattainment regions.   Indeed,
virtually every major metropolitan city would be in violation of
the EPA’s ozone standard alone.29

According to Eric Peters of the Washington Times, the EPA’s
tightened standards would make the nonattainment areas for ozone
jump from just over 70 to approximately 326 — a fourfold
increase, and as many as 75 percent of the nation’s counties
could run afoul of the proposed standards.30

What this would mean, of course, for those living in these areas
would be a host of inconveniences, like mandated carpooling,
purchase of reformulated gasoline, expensive emissions testing at
centralized facilities, and maybe even some other unimagined
bureaucratic contrivances that have yet to be dreamed up.

In a cost study by Sierra Research, Inc., it was determined that
just tightening the standard for ozone, as the EPA is proposing
to do, would cost the City of Chicago alone $2.5 to $7 billion! 
As for benefits to Chicagonians, another study conducted by
Prasad Rao and Thomas Lareau of the American Petroleum Institute
found an incremental benefit of just $33 million for meeting the
.08 ppm standard (as opposed to the .12 ppm standard now in
force).31  Hardly a good deal when you consider there are
essentially no public health benefits.  Again, as noted by CASAC
in a letter to EPA Administrator Carol Browner:  “…there are no
significant public health benefits observed by going from the
present standards to any of the standards proposed by the EPA.”32

Indeed, just trying to get cities into compliance with the
present regulatory guidelines is expensive enough.  The Office of
Technology Assessment ran a study on costs and benefits
associated with bringing today’s nonattainment areas into
compliance with current standards (i.e. .12 ppm).  They found
that for an across-the-board reduction of VOC’s (which is
necessary to drop ozone levels) of 35 percent, a level thought to
bring only a third of the said cities up to snuff, the costs
would range around $7.8 to 11.9 billion and benefits would only
range from somewhere between $365 million and $2.4 billion.  The
benefits, incidentally, assume that every person who exercises
receives a full benefit from the lowered standard.33

What’s more, it may be impossible in some regions to attain
compliance with the EPA regulations because nature produces
levels of ozone approaching the set standards.  The National
Research Council, for example, suggests that “in many cities even
if manmade VOC emissions are totally eliminated, a background of
[natural] VOCs will remain.”  And on hot days, this means natural
background levels “should be able to generate ozone
concentrations that exceed the NAAQS standard of 0.12 ppm.”
Indeed, certain national forests, like the Theodore Roosevelt
Nation Park in North Dakota, often had their natural ozone levels
ranging from .05 to .072 ppms between 1988-94 — just a hair
under the superstrict EPA standard!34

Many states and communities are alarmed about the potential costs
associated with a tightened standard, hence no fewer than 17
governors and scores of congressmen, senators, mayors, and state
legislators have written the Clinton Administration questioning
what the EPA is up to.35  Many feel the new standards constitute
an “unfunded mandate” and therefore will be looking to Washington
to help them ante up.

Breathing Fresh Air into New Clean Air Regs
So what should be done to balance the need to keep America’s
cities clean while not imposing unreasonable costs on society?  A
few things might be considered:

1. First and foremost, the standard ought not be tightened any
further.  Already many communities are struggling to maintain
compliance with the 1990 standards.  Moving the PM and ozone
standard to a level that would cost the nation billions while
providing no public health benefit seems, to say the least, ill-
advised.

2.  As suggested by the CATO Institute,36 requiring the EPA to
use the most up to date data, instead of relying upon information
obtained in hot years like 1988, would also improve a
metropolitan area’s ability to meet EPA standards.  Ideally, the
agency should consider how weather conditions impact pollution
trends and try to differentiate between what man does to what is
the likely influence of Mother Nature.

3. State and local governments ought to be given more flexibility
in how to meet CAA requirements.  Too often the EPA has tried to
impose costly and burdensome requirements for states to meet
their attainment goals.  Since many of these costs are going to
be borne by the municipality struggling with the pollution
problem, the least the federal government could do is give them
maximum flexibility in how to fix it.

4. Adopt a clean air objective that truly protects public health
and is attainable.  Reject the current impossible “standard of
perfection.”  Replace it with a goal of safeguarding the public
against unreasonable risk, something along the lines of a 1 in
10,000 chance of getting cancer.

5. Clean air regulation’s impact on economic prosperity should
also be weighed more seriously in cost-benefit analysis conducted
by the EPA.  It is widely known that regulations that hurt a
nation’s economic well-being ultimately hurt public health. 
Requiring the EPA to assess the economic impacts of its proposed
regulations in a more meaningful manner might ward off
unreasonable rulemaking.

 ENDNOTES

1 The True State of the Planet, Ron Bailey, The Free Press,
New York, 1995, pg.345.

2 Handbook on Population (fifth edition), Robert L. Sassone,
American Life League, Inc., Stafford (VA), 1994, pg.76.

3 Ibid.

4 Misuse of Science in Environmental Management, Heartland
Policy Study [No. 70, 12/08/95], pg. 9.

5 “Air Quality Without the EPA,”  Executive Alert
(March/April 1996), National Center for Policy Analysis, pg. 8.

6 Ibid.

7 National Air Pollutant Emission Trends, 1900-1993,
Environmental Protection Agency, Document #R-94-027, pg. ES-10.

8 Ibid., pg. ES-07.

9 “Misuse of Science …,” pg. 4. 

10 The Myth of the Dirty Power Plant: How Clean Air Act
Programs Achieve their Air Quality Goals, The Center for Energy
and Economic Development, Alexandria (VA), November 1996, pp.1-2.

11 National Air Quality and Emissions Trends Report, 1995,
Environmental Protection Agency, Document #454/R-96-005, pg 1.

12 The Myth of the Dirty …, pg. 5.

13 Ibid., technical appendix 4 {chart}.

14 Has the Battle Against Urban Smog become “Mission
Impossible?”, Kenneth W. Chilton and Stephen Huebner, Center for
the Study of American Business [Policy Study No. 136], November
1996, St. Louis, pg. 3.

15 “National Ambient Air Quality Standards for Ozone and
Particulate Matter,” Federal Register, Vol. 61, No. 114, June 12,
1996, pg. 29721.

16 “Capital Hill Prepares for Battle Over EPA’s new Air
Quality Standards,” EPA Watch, Vol. 5, No. 20, December 10, 1996,
pg. 2.

17 Letter to Carol Browner from Dr. George t. Wolff, Chair of
the Clean Air Scientific Advisory Committee, June 13, 1996, pg.
3.

18 Breathtaking: Premature Mortality Due to Particulate Air
Pollution in 239 American Cities, NRDC report, May 1996, pg. 1.

19 Kenneth G. Brown, Ph.D., A Critical Review of NRDC’s
Report,  Kenneth G. Brown, Inc., Chapel Hill (NC), pg. 6.

20 Ibid.

21 Analysis of PM10 Trends in the U.S. from 1988 Through 1995,
Darlington and Kahlbaum, Air Improvement Resource, Inc., June 5,
1996, pg. 10 [chart].

22 Comments by the American Automobile Manufacturers
Association to Drs. McKee, Caldwell and Gerth at the EPA
regarding 61 Federal Register at 29719, August 30, 1996, pg 8.

23 Petrochemical Ozone: Let’s Face the Facts,” Dr. Harry M.
Walker, The Torch, October 1995, pg. 6.

24Has the Battle Against Urban Smog …, pg. 6.

25 David Stiff, “Two Ozone Studies Find Little Evidence of
Lung Damage or Cancer in Rodents,” Wall Street Journal, 2/3/95.

26 Eco-Sanity: A Common Sense Guide to Environmentalism,
Bast, Hill & Rue, Madison Books, Lanham (MD), 1994, pg. 14.

27 The Benefits and Costs of the Clean Air Act 1970-1990
Draft Report, Environmental Protection Agency, May 3, 1996, pg.
28.

28 How to Talk About the Environment [white paper No. 16],
John Shanahan, The Heritage Foundation, Washington, D.C.,
September 6, 1996, pg. 4.  

29 Capital Hill Prepares for Battle …,” pg. 2.

30 Eric Peters, “Energy Ambush by EPA Fiat,” The Washington
Times, November 22, 1996, pg. A19.

31 Has the Battle Against Urban Smog …, Pg. 18.

32 Eric Peters, “Energy Ambush ….”

33 Has the Battle Against Urban Smog …, pg. 13.

34 Ibid., pg. 21.

35 William Frick, “Peering through the fog over clean air,”
The Washington Times, December 8, 1996, pg. B3.

36 Time to Reopen the Clean Air Act: Clearing away the
Regulatory Smog, K.H. Jones and Jonathan Adler, Cato Institute
Policy Analysis, No. 233, July 11, 1995, pg. 38.

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About the Author: CFACT

CFACT defends the environment and human welfare through facts, news, and analysis.