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Cash 4 Clunkers: Now, for the Unintended Consequences

sam.staley@reason.org (Samuel Staley) — Wed, 23 Sep 2009 14:12:00 EDT

Funny how the Cash for Clunkers (C4C) program snuck up on me this summer. I must not have been watching the inside the beltway politics closely enough to see how this $2.8 billion program gained momentum. Now, the chickens are coming home to roost.

William Jeanes, the auto editor at AOL.com, has an excellent summary of the "morning after" regrets from this program, including buyer's remorse (about 17 percent), the addition to consumer debt (which was already dampening consumer spending), and the ethics of an effective wealth transfer from general taxpayers to the 700,000 new car buyers.

Jeanes also notes that, while average gas mileage per vehicle increased 16.3 to 23.8, most people are likely to put more miles (about 4,000 on average) on the new, more fuel efficient car. Jeanes suggests this will wipe out the benefits of weaning us off gasoline. (I'm a bit more skeptical since we need to look at household driving, not miles put on one car in a two-car household. For example, our household shifted more miles to our Prius from the minivan when we bought the car in 2003, but our household VMT did not increase.)

Nevertheless, research from the University of Michigan suggests the impact on actual fuel economy will be modest. According to the abstract from a September 2009 report by Michael Sivak,

"This study evaluated the effects of the U.S vehicle-scrappage program (“Cash for
Clunkers”) on the average fuel economy of new vehicles purchased in July and August
2009. The predicted, baseline fuel economy, without the existence of the program, was
derived using a model obtained from a regression analysis performed on the data from
October 2007 through June 2009. The regression used the unemployment rate and the
price of gasoline as the predictors of the fuel economy. The results indicate that the
program improved the average fuel economy of all vehicles purchased by 0.6 mpg in July
2009 and 0.7 mpg in August 2009."

Not very impressive.

This is not to say that the C4C program had no benefits. On the contrary, the original idea behind this program was to take older, more polluting cars off the road. The goal was improving environmental air quality, not stimulating the economy, saving the automobile industry, reducing our dependence on foreign oil, or, for that matter, reducing carbon emissions.

As environmental policy consultant Joel Schwartz has repeatedly emphasized, improvements in vehicle technology and fleet turnover--the "greening" of the vehicle fleet--has been and will continue to be the most important contributor to improving air quality. (See also Joel's highly readable essay here.)

The C4C program was a success when measured by this metric, although it's not clear it was cost effective.

President Obama's Fuel Economy Standard Follies

rbailey@reason.com (Ronald Bailey) — Tue, 27 Jan 2009 00:00:00 EST

Reason.com

"We must ensure that the fuel-efficient cars of tomorrow are built right here in the United States of America," President Barack Obama declared yesterday. He also signed an order directing the Environmental Protection Agency (EPA) to review the denial of California's request to set its automobile mileage standards higher than those adopted by the federal government.

In 2007, Congress passed and President George Bush signed legislation aimed at increasing Corporate Average Fuel Economy (CAFE) standards to at least 35 miles per gallon (mpg) by 2020, up from 27.5 today. Federal CAFE standards were originally set in 1975 during the first "energy crisis." If an automaker's average mileage fails to meet the CAFE standards, it must pay a fine which currently stands at $5.50 per 0.1 mpg, multiplied by the manufacturer's total domestic production. Some companies choose to simply pay the penalty. For example, BMW handed over $230 million in fines last year while Daimler, the maker of Mercedes-Benz automobiles, paid $55 million, and Volvo paid $56 million.

Now, California and 13 other states, representing about 50 percent of the U.S. automobile market, want to force carmakers to meet the 35.7 mpg standard by 2016, rising to 42.5 mpg in 2020. Proponents argue that the higher mileage standard is needed to both cut the emissions of greenhouse gases that are contributing to man-made global warming and to reduce our dependence on foreign oil.

Do CAFE standards work? The CAFE standards established in 1975 during the first "oil crisis" explicitly aimed to reduce America's dependence on imported oil. In 1975, the U.S. imported about one-third of the petroleum it consumed. By 2008, imports accounted for about two-thirds of consumption. On the other hand, a National Academy of Sciences (NAS) report in 2002 estimated that CAFE standards had reduced U.S. oil consumption by 14 percent below what it would otherwise have been.

In 2007, the Pew Campaign For Fuel Efficiency released a poll in which 89 percent of respondents said that it was important for Congress to pass higher automobile fuel efficiency standards. Whatever Americans might tell pollsters, they voted quite differently with their pocketbooks. For example, CAFE standards on passenger vehicles had a big unintended consequence—the rise of sport utility vehicles (SUVs). Mileage standards for light trucks were set lower at 20.7 mpg and SUVs and minivans qualified as light trucks. In 1975, only 20 percent of vehicles sold were light trucks, but by 2002, that had risen to more than 50 percent of vehicles. In 2002, the San Francisco Chronicle reported that the EPA's 10 most fuel efficient models constituted less than 2 percent of auto sales. As recently as 2007, none of the top 10 vehicles chosen by consumers voting at the popular website CarGurus.com had an average gas mileage that met current federal CAFE standards

In his announcement yesterday, Obama estimated that the new federal mileage standard would save 2 million barrels of oil per day. Although estimates vary considerably, boosting fuel efficiency is not cost-free. California Air Resources Board Chair Mary Nichols endorses a rosy scenario, claiming that the state's new standards will only add about $400 per car. On the other hand, General Motors Vice Chairman Bob Lutz apocalyptically predicts that even the less stringent new federal CAFE standards will boost car prices by $4,000 to $10,000 per vehicle, averaging around $6,000. The Energy Information Administration's middle of the road calculation is that the new California regulations would add about $1,900 in costs to each vehicle. Essentially, CAFE standards function as a kind of inefficient stealth tax on driving. It's inefficient because drivers pay more, car companies make less money, and state and federal governments don't get any extra revenues.

But CAFE proponents argue that there is a bright side—the higher costs for the gas-sipping cars will be offset by lower gas bills. For example, a car driven 12,500 miles per year at 27.5 mpg would use 454 gallons of gas annually. Raising the mileage to 35 mpg reduces that figure to 357 gallons per year. So the new California standards would save drivers an average of 100 gallons per year. At $1.50 per gallon that comes to $150 per year; at $4 per gallon it comes to $400.

Politicians claim that manufacturing the new CAFE-compliant cars will increase jobs in the auto industry. But will it? All other things being equal, increasing the price of a product is not usually considered a sure fire recipe for attracting more customers. Higher prices mean lower demand, something that normally results in fewer jobs in the auto industry. On top of that is the fact that it takes fewer workers to manufacture the generally smaller cars that meet CAFE standards. It's hard to see how higher CAFE standards will produce more jobs.

If California's state legislators—and the other politicians who favor the new higher mileage standards—really want their citizens to drive more fuel efficient (and generally smaller) cars, there is a simpler and more honest policy: Hike gasoline taxes substantially. In 2002, the NAS's report correctly observed, "There is a marked inconsistency between pressing automotive manufacturers for improved fuel economy from new vehicles on the one hand and insisting on low real gasoline prices on the other. Higher real prices for gasoline—through increased gasoline taxes—would create both the demand for fuel efficient new vehicles and an incentive for owners of existing vehicles to drive them less." In other words, taxing gasoline would achieve the politicians' stated goals of reducing imports of foreign oil and cutting greenhouse gas emissions much more efficiently than convoluted CAFE standards—since taxes would apply to all vehicles, not just new ones.

The NAS further noted that more models of high mileage cars were produced abroad largely because gasoline in other countries costs $4 to $5 per gallon. Last year, we learned definitively that Americans respond with alacrity to higher fuel pump prices. As gasoline prices soared to over $4 per gallon, consumer demand for smaller cars rose by 37 percent over the previous year. At nearly 64 cents per gallon, California already imposes the highest gasoline tax in the country, yet Californians continue to insist on buying and driving cars of which their legislators disapprove. Ultimately, setting CAFE standards is just a way for cowardly politicians to avoid telling their fellow citizens that they should pay more for the privilege of driving.

Ronald Bailey is Reason magazine's science correspondent. His book Liberation Biology: The Scientific and Moral Case for the Biotech Revolution is now available from Prometheus Books.

This column first appeared at Reason.com.

USDA Tries Pricing and Trading Environmental Benefits

skaidra@reason.org (Skaidra Smith-Heisters) — Mon, 26 Jan 2009 00:00:00 EST

The announcement that the United States Department of Agriculture (USDA) is creating a new Office of Ecosystem Services and Markets was largely overlooked in December amidst the recession and presidential transition.

The importance of the announcement was not lost, however, on editors at The Katoomba Group, whose Ecosystem Marketplace website is the largest clearinghouse of information on markets and payment schemes for ecosystem services. There, the creation of the Office of Ecosystem Services and Markets was welcomed as "part of a massive realignment of the management of natural resources."

USDA is already far too big and has not served taxpayers well. The agency specializes in doling out entitlements, administering corporate welfare, increasing the cost of food for consumers, and generally ensuring that the nation's agricultural sector operates in a bubble untouched by the realities of the market. However, the new ecosystem and markets program offers a little bit of hope for an agency that is otherwise hostile to free markets.

Refining the concept of ecosystem services has been the topic of serious academic deliberation only in the last few years. The definition of ecosystem services depends on the context. The most widely known assessment of ecosystem services is the Millennium Ecosystem Assessment published by the United Nations in 2005. That report described declining stocks of natural assets as an impediment to reaching international development goals relating to basic human welfare in impoverished communities.

Among the ecosystem services identified in the report as diminished worldwide were fisheries, wild foods, genetic resources, and processes that naturally moderate or regulate air quality, local and regional climate, erosion, water purification, pests and natural hazards like flooding. Other ecosystem services were reported on an upward trend, including production of crops and livestock, and a net increase in climate-stabilizing carbon sequestration worldwide.

Agricultural lands are managed ecosystems that produce market commodities, like food and fiber, but also ecosystem services such as the mitigation of flood waters, recharge of groundwater aquifers, nutrient cycling, carbon sequestration, and, at a stretch, even the warm fuzzy feelings brought to mind for some at the idea of happy cows and family farmers. In economic parlance, these services are positive externalities of agricultural production. If the idea of positive environmental externalities is a more foreign concept than that of negative environmental externalities, there's good reason for that. There's little incentive to provide positive environmental externalities, so such goods and services are produced more or less accidentally, altruistically-or just not at all.

From subsidized irrigation water to price supports to special property tax credits, our agricultural policies reveal a general sentiment that farms and ranches provide social value beyond the sum of the commodities they produce. The 2008 Farm Bill, which directed USDA to undertake research into markets for ecosystem services, also provided hundreds of billions of dollars in farm subsidies that have an effect exactly opposite from markets for ecosystem services. The subsidies promote production of commodities out of proportion to actual market demand, frequently at the expense of environmental values. Ideally, the Office of Ecosystem Services and Markets will review these farm subsidies that have, at best, only a sloppy relationship to any social values, and scrap them in favor of programs that more accurately represent market demands.

The new ecosystem and markets program is far from being USDA's first trial in incentive payments to farmers for conservation. Conservation payments have been a popular method of subsidizing farms and improving on-farm environmental performance dating back to the 1930s. USDA will administer more than $4 billion in conservation funds this year, including $1.8 billion in rental payments through the Conservation Reserve Program.

The presumed role of the new office differs from these older conservation programs in that it will try to find private buyers for environmental services from agricultural lands, as opposed to using public funds as carrots to reduce environmental harms associated with farm operations. In comments to the press last week, outgoing Secretary of Agriculture Ed Schafer said, "…as important as publicly funded conservation efforts are, we also need to supplement them with strong private markets where environmental benefits can be priced and traded."

The first ecosystem service to be examined at the new office will be carbon sequestration. There is a relatively small domestic market for carbon sequestration in the form of retail carbon offsets-the international voluntary carbon offset market was worth an estimated $258 million in 2007. However, rural landowners don't need the help of the Office of Ecosystem Services and Markets to engage in that market. (In a recent report on the U.S. voluntary carbon offset market the Government Accountability Office concluded that increasing the role of the federal government in that market might "reduce flexibility, increase administrative costs, and stifle innovation.")

The bigger game is anticipated in carbon offsets to comply with government caps on greenhouse gas emissions, a niche for ecosystem service providers that is market-like only in the sense that offsets are volunteered for sale. Similarly, there are many active domestic compliance schemes trading pollutant permits driven by government water quality standards in regulated water bodies.

As yet, there has been somewhat less action in implementation of truly private markets for such ecosystem services domestically, though there are numerous examples in Costa Rica, Mexico, and elsewhere. A private market could help to clean up one of the nation's most concerning areas of environmental devastation, the dead zone that can stretch for more than 8,000 square miles from the mouth of the Mississippi River out into the Gulf of Mexico each summer. Surveys show that nitrogen and phosphorus runoff from corn and soybean production is primarily responsible for the problem. It's no coincidence that the two crops are among the most heavily-subsidized nationwide. The first-best solution would be to cut subsidies that encourage over-intensive production of these crops.

Another needed approach is to implement market schemes to facilitate payments by downstream water users-including other farmers, municipalities, and potentially the shrimping and fishing industries-to improve the way fertilizers and runoff are managed on agricultural lands upstream. In this case, ecosystem services markets will allow the biggest beneficiaries of cleaner water and healthier fisheries in the Mississippi River system to make the smart investments that are so badly needed.

A "massive realignment in the management of natural resources" to bring more ecosystem services out of the political realm and into the market would be welcome news. It is hard to imagine such change coming from within USDA, but that would certainly be a good place to start.

No Biofuels Bailout

rbailey@reason.com (Ronald Bailey) — Tue, 13 Jan 2009 00:00:00 EST

Reason.com

Clean Renewable Energy Bonds ("CREBs") Everyone wants a bailout. Last week, a coalition of mostly farm energy lobbyists sent a letter to the Congressional Democratic leadership begging for billions in subsidies and tax credits. Farm energy is an umbrella term that encompasses everything from the growing of crops for biofuel production to the infrastructure that turns those crops into fuels, and additional energy sources such as farmer-owned windmills. In their letter, the lobbyists claim that a farm energy bailout would "help resuscitate our nation's economy and create hundreds of thousands of well-paying jobs." First, the renewable energy lobbyists ask for $1.2 billion per year to build and operate "clean energy" facilities. Their letter specifically mentions additional funding for the Rural Energy for America Program, Bioenergy Crop Assistance Program, and the Biorefinery Assistance Program. This would be on top of $1.1 billion in farm energy subsidies authorized by Congress last year.

In addition, biofuel lobbyists want Congress to "extend the federal Production Tax Credits (PTC) for renewable energy, cellulosic biofuels, and biomass for five years," and make them "fully refundable." Generally, tax credits reduce the amount of tax a company or an individual owes. In this case, however, "fully refundable" means that if a company doesn't turn a profit, the Treasury will send them a check to offset the amount they've invested in their power plants and biorefineries. Roughly, if a company invests $1 million in a bioethanol refinery, makes no profits, and thus owes no taxes, the feds will still send it a check for $1 million as a production tax credit. In the past, money-losing renewable fuels companies could sell their tax credits to financial institutions like JP Morgan which used them to reduce their tax liabilities. Since the financial crisis, fewer firms are willing to buy up such credits, so now the lobbyists want the money to be "refunded" directly to their clients.

Finally, the coalition of lobbyists calls for the expansion of the clean renewable energy bond (CREB) program. This allows biofuels and other renewable energy companies to issue what are, in effect, interest free bonds. CREB issuers do not make interest payments; instead, the federal government provides a tax credit to the issuer. Purchasers of CREBs take the amount of the tax credit as a credit against their regular income tax liabilities. In all cases, taxpayers would be on the hook for the subsidies, credits, and loans.

The proposed bailout would apply not to just to bioenergy companies, moreover, but to bioenergy and farming groups that make up the majority of the 33 lobbying groups that signed the letter to Congressional Democrats. It's easy to see why: Numerous biofuels companies are shutting down and going bankrupt. The biofuels crash is occurring despite the federal mandate that requires gasoline refineries to blend billions of gallons of ethanol into their fuels and the federal tax credit worth 51 cents per gallon (lowered in December to 45 cents) handed out to ethanol refiners. Besides shoring up the faltering bottom lines of their industries (and incidentally contributing to job creation and energy independence), renewable fuels lobbyists argue that the biggest benefit of biofuels subsidies is that they will replace dirty fossil fuels and thus reduce the carbon dioxide emissions that are causing man-made global warming. But is this true?

To answer that question, Mark Jacobson, a professor of Civil and Environmental Engineering and Director of the Atmosphere/Energy Program at Stanford University, recently published a review of the environmental and health effects of twelve possible ways to power vehicles using renewable and low-carbon energy sources. Jacobson looked at combinations in which battery electric vehicles (BEVs) would be fueled using electric power generated by wind, solar, hydro, tidal, or nuclear plants, and where vehicles would use corn or cellulosic ethanol. Interestingly, Congress passed a cellulosic biofuels production tax credit for up to $1.01 per gallon. Cellulosic biofuels are produced using agricultural waste, wood chips, and perennial energy crops like switch grass.

Jacobson ranked each of the twelve proposed sources of renewable/low carbon energy for vehicles on the basis of their environmental and health effects. Corn and cellulosic ethanol came in dead last. Why? Among other things, Jacobson points out that biofuels use a lot of land and water, reduce wildlife habitat, contribute to air pollution, and boost the price of food. In addition to all those negative impacts, biofuels may not even reduce greenhouse gas emissions. As evidence for this, Jacobson cites a 2008 study in Science that found that producing corn ethanol nearly doubles greenhouse emissions over 30 years and that cellulosic biofuels derived from switch grass could increase such emissions by 50 percent.

Worse yet, even if such "tax subsidies" do result in marginal decreases in greenhouse gas emissions, they do so at a vast expense. In a 2007 study, Tufts University economist Gilbert Metcalf found, "The tax credit for ethanol is an example of a cost ineffective subsidy. The cost of reducing CO2 emissions through this subsidy exceeded $1,000 per ton of CO2 avoided in 2006." Keep in mind that proposed carbon dioxide taxes generally start at around $20 per ton.

Ultimately, Jacobson finds that "the biofuel options provide no certain benefit and result in significant negative impacts." He concludes that "the diversion of attention to the less efficient or non-efficient options represents an opportunity cost that delays solutions to climate and air pollution health problems." Biofuels represent one such "non-efficient option," and a bailout of that faltering industry would divert attention from more effective solutions. In a new study for the Manhattan Institute, a free market think tank, Metcalf calculates that around 50 percent of energy subsidies currently go to fossil fuels and 50 percent go to various renewable fuels. If Congress decides that greenhouse gases are a big problem, it should stop trying to pick energy technology "winners" by subsidizing favored sectors, and instead end all subsidies and put all energy technologies on a level playing field. Congress should then set a price on carbon dioxide, and let the most affordable and most efficient energy technology win—be it wind, solar, clean coal, nuclear, or whatever.

Ronald Bailey is Reason magazine's science correspondent. His book Liberation Biology: The Scientific and Moral Case for the Biotech Revolution is now available from Prometheus Books.

This column first appeared at Reason.com.

California Air Resources Board Passes Costly Plan During Economic Crisis

skaidra@reason.org (Skaidra Smith-Heisters) — Mon, 22 Dec 2008 00:00:00 EST

In one room in Sacramento last week, state lawmakers were staring into a $40 billion budget hole stretching sometime into 2010. There's talk of the cash-strapped state government handing out IOUs when bills come due in February. Not far away, in another room in Sacramento, the California Air Resources Board was unanimously adopting what The New York Times described as the "country's first comprehensive plan for curbing emissions of heat-trapping gases." What about the economic implications of the emissions plan during this huge budget crisis and national recession? The nonpartisan Legislative Analyst's Office said the plan was not "directly influenced by cost-effectiveness considerations or macroeconomic analysis."

The disconnect is startling. Gov. Arnold Schwarzenegger's words of warning about California's impending "financial Armageddon" were still hanging over the Capitol, but environmentalists didn't seem to notice.

Mainstream environmental groups have been slow to acknowledge that, realistically, progress on climate change will need to take backseat to stabilizing the economy right now. In September, while new bank failures were in the headlines on a daily basis, the Sierra Club was asking its members to "turn up the heat" on American Funds, Vanguard, Fidelity, Ameriprise, Morgan Stanley and other mutual funds that the organization believes don't take climate change seriously enough. It was not the most opportune moment to discuss the global distribution of permafrost, to say the least.

On the other hand, reducing greenhouse gas emissions need not wait for climate change policy to be enacted-the economic downturn is also an emissions downturn. For example, the most recent state figures showed gasoline consumption this August was down 8 percent and diesel consumption declined 14 percent compared to the same month last year. The decrease in gasoline and diesel transportation emissions in August alone was 40 percent larger than a year's worth of greenhouse gas savings associated with building the high-speed rail system, as estimated in California's adopted climate change plan for 2020. That's right, a large emissions reduction achieved without any mandate passed down from Washington or Sacramento.

U.S. Transportation Secretary Mary E. Peters' recent announcement that Americans drove 3.5 percent less in October 2008 than last October (the sharpest decline since 1971), and November's 37 percent drop in national auto sales are two signs indicating that the sour economy will continue to keep fuel consumption low, even though gas prices are no longer near this summer's historic highs. So this is a perfect time to implement the radically moderate principle at the heart of both fiscal conservatism and environmental conservation: living within our means.

There are several ways to help taxpayers save money and reduce emissions simultaneously. Pay-as-you-drive car insurance will be available to California drivers next year, giving people an incentive to drive less. Groups like the Brookings Institution, Environmental Defense Fund and others, suggest if 30 percent of California drivers switch to the new usage-based insurance coverage, most will pay less in premiums, while reducing their time on the road enough to save 5.5 billion gallons of gasoline by 2020 (on an annual basis, this is more than four times the savings of the proposed high-speed rail project which is being pushed in California as a way to reduce emissions).

Similarly, pay-as-you-save programs for everything from major appliances to building retrofits can help individuals overcome the initial price hurdle of energy-efficiency upgrades in homes and businesses. These types of programs allow people to pay off the initial cost of such upgrades in installments, with the money they save on their utility bills. (And amidst the fiscal backdrop, the small loans entailed in such programs are as secure as they come.) Combined with the smarter metering and pricing currently being implemented by utility companies, consumers will soon have the means and the incentives to make more efficient energy decisions. Based on the results of pilot programs using smart meters, being able to see electricity prices at the time of use could prompt consumers to cut peak energy demand by 5 percent. Much more significant reductions are observed when these metering and pricing systems are used in conjunction with smarter thermostats and appliances.

The California Energy Commission has modeled scenarios that reduce greenhouse gas emissions from electricity use to 1990 levels by the year 2020 using these types of efficiency measures alone. These measures would save more than $100 per metric ton of avoided greenhouse gases. The adopted climate change plan would implement roughly equivalent measures, but it also calls for increased renewable energy generation that, by air board estimates, would cost about $84 per metric ton.

Innovative pay-as-you-go approaches can work to cut unnecessary waste and increase efficiency at the same time that they help balance the environmental accounts, making sure we keep a safe margin of natural resources in the bank. Lawmakers working to curb greenhouse gas emissions and those looking to cushion the blow of the recession should focus on measures that cut costs first.

A previous round of major make-work projects in the Western states, the massive New Deal water projects-like California's Central Valley Project and the damming of the Colorado River-were carried out with virtually no regard for expense or environmental disruption. Today, those projects still represent some of the greatest examples of corporate welfare in history, with a costly and complex legacy that has yet to be paid off. Right now, more than ever, California can't afford bad policies.

Cars Disproportionately Blamed for Greenhouse Gas Emissions

skaidra@reason.org (Skaidra Smith-Heisters) — Tue, 12 Aug 2008 00:00:00 EDT

General Motor's Hummer brand, popular back when gasoline cost a little over a dollar a gallon, is well on its way to becoming a historic anecdote now that gas prices top $4 a gallon in many places. Yet, the myth persists that American drivers-and U.S. automakers-will never change. If the U.S. is going to be successful in its climate change policy, that kind of anti-economic thinking needs to follow the Hummer into the dustbin.

In the near future, the United States will likely commit-just as some individual states already have-to a long-term goal of reducing greenhouse gas emissions by 60 to 80 percent. Many assessments of this significant challenge begin with the observation that transportation currently accounts for 33 percent of total CO2 from fossil fuel combustion, the "largest share from any end-use economic sector," and end with the conclusion that meeting greenhouse gas emission reduction targets means eliminating the personal automobile as a mode of transport. But before jumping to that conclusion, it is worth examining more closely how much transportation contributes to greenhouse gas emissions and what forces are already at work reducing transportation emissions.

Personal transportation is unduly targeted for emission reductions at the onset as an accident of how we account for greenhouse gas emissions. We're frequently told that the transportation sector is the largest contributor of greenhouse gas emissions in the United States, but this is a misleadingly statement. The U.S. Environmental Protection Agency (EPA) inventories emissions in six main categories-electricity generation, transportation, industry, agriculture, commercial and residential. When inventoried in those categories, electricity generation is the largest source of greenhouse gas emissions (34 percent in 2006), followed by transportation (28 percent), industry, agriculture, commercial, through to the smallest sector, residential (5 percent). Electrical power is an industrial product "consumed" by the other economic sectors, however, so the next step EPA reports is a calculation of emissions with electricity generation allocated among the five smaller sectors. After these emissions are distributed, "industry" accounts for the largest share of greenhouse gas emissions (29 percent in 2006), followed by transportation (28 percent), commercial, residential and agriculture (8 percent).

This simple example shows how the categories in which emissions are reported in has a large influence over how each economic sector is perceived. Distributing emissions from the electrical power industry dramatically changes the respective contribution of the other sectors, with the exception of transportation, where a nearly insignificant amount of rail transportation contributes a small amount of electricity to the mix. Transportation is "consumed" by the other sectors, just as electricity is, but the accounting method just lumps together passenger cars, light-duty trucks, sport utility vehicles, commercial trucks, domestic aviation, military aircraft, commercial and recreational boats and emissions from all other modes of motorized transport.

Even with commercial, personal and other kinds of transportation included in one sector, it still doesn't add up to the "largest share" of total U.S. greenhouse gas emissions. Rather, it is the largest share of carbon dioxide (CO2)-the dominant greenhouse gas-from fossil fuel combustion-the main source of anthropogenic CO2. Weighted for global warming potential over a 100-year time horizon, EPA reports that CO2 from fossil fuel combustion accounted for approximately 80 percent of U.S. greenhouse gas emissions in 2006. The other 20 percent, including CO2 from industrial processes, methane from livestock and landfills, nitrous oxide from agriculture, and some chemical solvents and propellants, should not be overlooked in greenhouse gas reduction strategies-in fact, these categories provide some of the quickest and least expensive opportunities for emission reductions. Household vehicle use currently is responsible for a much smaller portion of U.S. greenhouse gas emissions, 16-18 percent, than is commonly believed.

What is vastly more important than the relative amount of greenhouse gas emissions from this sector, however, is the utility provided by passenger cars and light-duty trucks and the opportunities that lie ahead for reducing the greenhouse gas intensity of personal motorized transport while maximizing utility. Recent data show that is exactly what has occurred in recent years, even without greenhouse gas emission reduction schemes in place. Since 1990, fossil fuel consumption in the U.S. has grown at an average rate of 1 percent per year, lower than the average annual population growth rate (1.1 percent), electricity consumption (1.9 percent) and GDP (3.0 percent).

CO2 emissions from personal automobiles are widely viewed as a function of three factors: carbon content of fuels, fuel economy (often expressed in miles per gallon, but passenger miles per gallon is another important measure), and vehicle use (typically expressed as vehicle miles traveled or VMT). Since 1990, the average fuel economy has increased slightly while the power and capacity of vehicles has increased to a large degree. Fuel carbon content has remained relatively unchanged.

Changes in vehicle characteristics (e.g. hybrid fuel-electric engines) and the types of fuels used (e.g. ethanol and biodiesel) increasingly require full life-cycle analyses-including emissions from production and disposal processes (in the case of batteries)-to make meaningful comparisons to fossil fuel carbon contents possible. A related affect of the growing market share of these alternative vehicle types is that the transportation sector may become more similar to the industrial sector, in which energy-intensive production processes are increasingly "off-shored" under the pressure of domestic environmental regulations.

Life-cycle analysis of mass transportation, particularly rail transit, is likewise revealing. When greenhouse gas emissions associated with the underlying infrastructure required for rail transit are included in the lifetime operating emissions, new rail systems are unlikely to compare favorably to the average passenger car.

Of the three factors contributing to vehicle greenhouse gas emissions, vehicle miles traveled (VMT) is the most complicated and controversial in many respects. Strictly speaking, VMT for the U.S. vehicle fleet-unlike the volume of gasoline sold or the number of car registrations-isn't measured, but estimated from traffic counts, sample odometer readings, household surveys and other references. Of these three factors, VMT has arguably the closest relationship to the actual utility (mobility) derived from vehicle use and the most distant relationship to greenhouse gas emissions. VMT estimates derived from travel demand models are a very poor basis for estimating greenhouse gas emissions, though they are frequently used for this purpose by regional planning agencies. Greenhouse gas emission estimates derived this way fail to capture excess fuel consumed as a result of congestion, among many other factors.

A final perception that makes personal automobiles disproportionately maligned as a source of greenhouse gas emissions is the idea that demand for this mode of transportation is somehow out of control, and that consumers are indifferent to price signals, including the price of gasoline. In one recent analysis, for example, analysts noted that "a $10/ton CO2 permit price would have a large impact on coal prices, creating a relatively strong incentive for coal-dependent electric utilities to consider shifts in their generation portfolio. In the transport sector, by contrast, the same carbon price would translate into a 10-cent per gallon increase in gasoline prices." In the short-run, automobile drivers would be expected to absorb the carbon-adjusted cost of gasoline without significantly changing their behavior.

Consumer behavior is not completely unaccountable, however, as the considerable response to fuel prices and other economic signals in the past couple of years has proven. The popularity of light-duty trucks and sport utility vehicles has waned, and average new vehicle fuel economy improved in 2005 and 2006 as a result. Growth in VMT among passenger vehicles, at 2.7 percent per year for the period from 1990 to 2004, dropped to an average annual growth rate of 0.8 percent from 2004 to 2006. As gas prices spiked this year, the U.S. Department of Transportation reports that Americans traveled 40.5 billion fewer miles from November 2007 through May 2008 than they drove during the same period a year ago. Additionally, nationwide, hybrid vehicle registrations increased 38 percent in 2007.

Policymakers should not despair if, as expected, reducing CO2 emissions from the transportation sector is more expensive in the short-term than reducing greenhouse gas emissions in other sectors of the economy. Personal transportation is responsible for a relatively small share of U.S. greenhouse gas emissions and provides a value which consumers rightly place in high priority - mobility. In the long-term, consumer preferences will undoubtedly change as efficient and cost-effective new vehicle technologies become widely available.

Are Hydrogen Cars Good for America?

info@reason.org (William J. Korchinski) — Thu, 01 Nov 2007 18:00:00 EDT

Hydrogen cars have captured the imagination of politicians and the public alike. Governor Arnold Schwarzenegger, Senator John Kerry, and Energy Secretary Samuel Bodman have all hailed hydrogen as an important component of the nationwide effort to develop cleaner, greener, and more sustainable sources of energy. In addition to hydrogen’s perceived efficiency and environmental friendliness, policymakers also have welcomed hydrogen as a source of energy that could wean the coun...

Study: Hydrogen Cars Don't Reduce Greenhouse Gas Emissions

Thu, 01 Nov 2007 15:22:00 EDT

Los Angeles (November 1, 2007) – Switching from gasoline-powered cars to hydrogen cars would not reduce greenhouse gas emissions nor would it eliminate America's dependence on the Middle East's energy supplies, according to a new Reason Foundation study.

The Reason Foundation report shows that if the U.S. replaced 20 percent of today's vehicles with hydrogen cars, CO2 emissions would either drop a tiny amount from 1.67 billion tons per year to 1.63 billion tons, or actually rise to 2.13 billion tons a year, depending upon what method is used to produce the hydrogen.

"Hydrogen isn't the quick-fix we've been led to believe it could be," said Adrian Moore, vice president of research at Reason Foundation and the study's project director. "Producing and transporting hydrogen for use in fuel-cell cars requires significant amounts of conventional energy and therefore won't reduce greenhouse gas emissions. When you look at the facts you see hydrogen isn't a solution to global warming and it isn't going to decrease our dependence on foreign energy."

While hydrogen cars would reduce American reliance on crude oil, they would also significantly increase the need for foreign-produced natural gas. The countries with the largest natural gas reserves are Russia, Iran, Qatar, Saudi Arabia and the United Arab Emirates.

"In order to become energy independent, we will need new sources of energy, such as solar polar, wind power and safe nuclear power," said William J. Korchinski, the study's author. "We are better off investing in new sources of energy, than we are in infrastructure and an economy built around the production and distribution of hydrogen, which requires more energy than we use now."

Full Report Online

Are Hydrogen Cars Good for America? is available online at reason.org/ps363.pdf.

About Reason

Reason Foundation is a nonprofit think tank dedicated to advancing free minds and free markets. Reason Foundation produces respected public policy research on a variety of issues and publishes the critically acclaimed monthly magazine, Reason, and its website www.reason.com. Reason Foundation also hosts Reason.tv, an online community showcasing the best free market ideas and videos on the Internet. For more information about Reason Foundation, please visit www.reason.org.

Media Contacts

Adrian Moore, Vice President of Research, Reason Foundation, (661) 477-3107
Chris Mitchell, Director of Communications, Reason Foundation, (310) 367-6109

How Environmentalists and Scientists Mislead Americans about Air Pollution and Climate Change

adrian.moore@reason.org (Adrian Moore) — Fri, 14 Sep 2007 19:36:36 EDT

As usual, Joel Schwartz cuts through the smog.

Technology, Not Transit, Is Key to Improving Mobility

sam.staley@reason.org (Samuel Staley) — Wed, 29 Aug 2007 00:00:00 EDT

Washington Examiner

Some particularly hardcore environmentalists and a few city planners hope cars will go the way of dinosaurs. They believe we'll run out of oil and be forced to find a new means of travel, preferably by foot, bike and train.

That would mean a return to the "good life" they say, where we live in apartments, or high-rise condos and walk or hop a train to work in downtown high-rise office buildings not far from home. In short, we'd revert to a 19th century life of low mobility.

The history of my Toyota Prius, which just hit 100,000 miles, suggests otherwise. Technology and innovation, like hybrids, show we can keep the benefits of enhanced mobility that come with our cars — more contact with friends and family; access to more career options and work locations; more entertainment and shopping choices — while improving the auto in ways that reduce impacts on the environment.

In 2003, when I bought my used Prius, gas was cheap, hovering slightly above $1 a gallon in Ohio where I live. But technology alone wasn't enough to make the purchase a no-brainer. A couple hundred dollars in gas savings would not compensate for the potential headaches of a new technology, lack of access to cheap repair shops and limited cargo space for kids and sports equipment.

Now, of course, my decision looks brilliant. Gas prices hit $2 in 2004. By the summer of 2005, drivers were choking at the sight of $3 a gallon. Refinery bottlenecks, reformulated gas mandates, uncertainty around pesky South American socialists, and a protracted military presence in the Middle East conspired to keep prices relatively high.

With its consistent 48 miles per gallon performance, the Prius has generated a small financial windfall and more than paid back in savings the difference in price between a conventional car and the hybrid.

I'm not alone. Hybrid sales have jumped along with gas prices. Dealers are on track to sell 345,000 in 2007. But this is just the tip of the iceberg. Hybrids are a small, but growing segment of the car market. JD Power speculates that 65 hybrid models will swarm the market by 2010. The next generation will offer fuel efficiency approaching 70 miles per gallon (or more).

All this bodes well for mobility in America. We can live where we want. Work we want. And commute how we want.

Yet groups yearning for cars to go extinct believe we should ditch cars, and the mobility they provide, for transit. But transit commuters in Washington spend an average of 47 minutes commuting, while solo drivers spend just 29 minutes, according to the U.S. Bureau of the Census.

In most of our biggest cities — New York, Chicago, Seattle, Los Angeles, San Francisco, Boston and Philadelphia — commute times are actually much longer for transit riders than solo drivers. Yes, despite all that gridlock on the roads.

Most Americans don't want to double our commute times by shifting to buses and trains. Most don't want to cram our kids into smaller houses and apartments to live closer to downtown or work.

And ingenuity from the creative minds that created my Prius will make sure we don't have to. Our cars will run cleanly, boosting air quality and reducing the health risks of living in cities. We will be able to reach the most diverse and interesting places in our cities on our schedule, not someone else's.

Instead of hoping for the demise of the car because of a ‘reliance on evil foreign oil,' we should celebrate the mobility it provides.

Can Carbon Taxes Work in India?

shikha.dalmia@reason.org (Shikha Dalmia) — Mon, 30 Apr 2007 15:31:00 EDT

The Mint

India should be prepared for an earful of eco-haranguing by the West now that the Intergovernmental Panel on Climate Change has declared that global warming will have the worst consequences for poor, agro-based tropical economies least able to defend themselves. The haranguing will go: "India should act now to contain its carbon dioxide emissions – if not to save the planet then to save itself."

Yet even if one accepts this call for action, the question is, is there any proposed cure for global warming that in fact won't hurt the Indian economy more than the disease?

The West's latest hot idea for cooling the earth is a global carbon tax. No less than Fareed Zakaria, Newsweek's Indian international editor, has written glowingly about it. This panacea has become especially popular as Europe's one-year-old experiment with "cap-and-trade" is fizzling out. Under this experiment, every European signatory to the Kyoto treaty got a fixed quota for carbon dioxide emissions that it then divvied up among its utilities, manufacturing plants and other greenhouse-gas-spewing industries. Companies that exceeded their allotment had to buy off-setting credits from those with a surplus. The hope was that this type of trading would allow carbon cuts to happen where they are the cheapest.

But the scheme has not substantially cut carbon dioxide emissions because countries, loath to burden their industries with excessive mitigation costs, obtained rather generous allotments in the first round of horse trading. Even if they subsequently accept tighter limits, the technology to capture carbon emissions is exceedingly expensive, something that will inevitably invite their industries to cheat.

A carbon tax would be more enforceable. But that's not the only reason for its growing appeal. The environmentally-minded like it because it will make conventional fossil fuel sources – petrol, diesel and coal – more expensive and create an incentive for research into cleaner-burning alternative fuels. But even many free-market advocates for whom any talk of taxes is usually anathema are warming up to a carbon tax – especially if it means replacing a portion of income taxes. Far better to tax "bads" like pollutants and internalize their costs to the polluters than "goods" like income, they reckon.

So is a carbon tax the way for India to go? Actually, the reverse in the case: India already has a carbon tax of sorts that it needs to slash – both for the sake of its economy and environment.

Taxes constitute 52 percent of the price of petrol and 32 percent of the price of diesel in India. By contrast, they constitute 18 percent of the price of both petrol and diesel in the United States; and 45 and 33 percent respectively in Japan. Even consumers in greener-than-thou Europe pay much less than Indians in such fuel taxes.

Notwithstanding fuel subsidies to the poor, the net effect of these taxes has been to raise fuel prices and depress energy consumption in India. Indeed, per capita energy consumption in India is not just low by the standards of developed countries but also developing countries: It is 17 times less than United States, eight times less than Denmark and England, nine times less than Japan and about two-and-a-half times less than China and Brazil. Indian households pay the highest rate for energy in the world in purchasing power parity terms. Furthermore, because petrol and diesel are so exorbitant, this energy consumption is heavily skewed toward even dirtier fuels like coal and wood that power more than half of India's economy.

If calls for a global carbon tax escalate, India will face immense pressure to extend its petrol and diesel taxes to coal as well. But putting one of the few affordable sources of energy off-limits would be tantamount to administering hemlock to the Indian economy.

The far better option would be for India to cut taxes on petrol and diesel. Counter intuitive though this might sound to Western ears, this will be good for the global environment because it will diminish India's need for coal-fired plants and automatically cut down on its green-house gas emissions. Furthermore, to the extent that increased oil consumption by a growing economy like India will raise its prices for the rest of the world, it will help the very search for alternative fuels that a carbon tax is supposed to trigger. A ready supply of diverse energy sources will also allow India to maintain its stellar economic growth, something that will put it in a far better position to deal with the ill effects of global climate change that the IPCC is so concerned about.

In short, India can't help the environment without first helping its economy. And for that it needs an energy policy that puts cheap – not more expensive -- fuel at the disposal of every Indian. Ironically, the only Indian politician who has consistently made slashing India's stratospheric fuel taxes a top-order priority is Communist Party of India General Secretary Prakash Karat. India would do well to block out Western sages like Zakaria and listen to him on this one.

Todayís ìtelecommuting is on the riseî tidbit brought to you by Ö

ted.balaker@reason.org (Ted Balaker) — Thu, 08 Feb 2007 09:38:47 EST

WorldatWork:

A growing number of American workers are reporting that their employers allows them to work remotely at least one day per month, according to a recent survey by WorldatWork. The survey found that 12.4 million workers reported that their employer allowed them to work remotely at least one day per month in 2006, up from 9.9 million in 2005 and 7.6 million in 2004. WorldatWork estimates that about 8 percent of American workers have an employer that allows them to telecommute at least one day per month. The organization says the increase is likely the result of a combination of factors, including the proliferation of high speed/broadband and other wireless access (which has made it both less expensive and more productive to work remotely) and the willingness of more employers to embrace flexibility. More here. Related: Telecommuting no big deal anymore Related: Wait'll all those MySpacers become managers

Burying Evidence--Contruction Equpment and Air Quality

adrian.moore@reason.org (Adrian Moore) — Sat, 20 Jan 2007 04:43:23 EST

In Digging Up Trouble: The Health Risks of Construction Pollution in California, the Union of Concerned Scientists (UCS) claims air pollution from construction vehicles is killing more than 1,100 Californians each year, sending similar numbers to the hospital, and sickening hundreds of thousands more. UCS estimates the economic toll at more than $9 billion per year. Fortunately, these claims have little to do with reality. UCS exaggerates harm from air pollution by excluding contrary evidence and ignoring weaknesses in studies that support its predetermined conclusions. Read Reason's analysis of the report, by Joel Schwartz, here. Laer, at Cheat Seeking Missles, weighs in here.

Burying Evidence

info@reason.org (Joel Schwartz) — Tue, 16 Jan 2007 00:00:00 EST

Introduction

In Digging Up Trouble: The Health Risks of Construction Pollution in California, the Union of Concerned Scientists (UCS) claims air pollution from construction vehicles is killing more than 1,100 Californians each year, sending similar numbers to the hospital, and sickening hundreds of thousands more.[1] UCS estimates the economic toll at more than $9 billion per year. Fortunately, these claims have little to do with reality. UCS exaggerates harm from air pollution by excluding contrary evidence and ignoring weaknesses in studies that support its predetermined conclusions.

According to UCS, the harm from construction emissions results mainly from two air pollutants: particulate matter (PM) and ozone. PM can be directly emitted (e.g., diesel smoke) or formed in the atmosphere from gaseous emissions (e.g., nitrogen oxides (NOx) can be converted to particulate nitrate). The California Air Resources Board (CARB) estimates that construction equipment contributes 3 percent of statewide direct fine particulate matter (PM_2.5) emissions and 28 percent of PM_2.5 emissions from diesel vehicles specifically.[2] Ozone is not directly emitted, but is formed in the atmosphere through reactions of NOx and volatile organic compounds (VOC) in the presence of sunlight. CARB estimates that construction equipment contributed 11 percent of statewide NOx emissions and 5 percent of VOC in 2005.[3]

Construction equipment is thus a significant contributor to total air pollutant emissions. Nevertheless, the actual harm from these emissions is far lower than UCS claims:

Laboratory studies indicate that current, historically low levels of air pollution are at worst a minor factor in people�s health.[4] Health researchers have been unable to kill laboratory animals even with particulate matter at concentrations many times greater than the most polluted California air. Laboratory studies with human volunteers, including asthmatics, have not found harm from PM_2.5 even at concentrations a few times greater than the highest real-world levels. This is true even for components of PM, such as diesel soot, that would be expected to have the highest toxicity. UCS does not mention or include any of this evidence in its report.
Instead, UCS bases its health claims on the results from a much weaker type of study design called an "observational" epidemiology study. Observational studies work with non-randomly selected subjects and non-randomly assigned pollution exposures and then use statistical techniques to try to remove the biases inherent in non-random data. Unfortunately, a range of evidence shows that observational studies are unreliable and tend to create an appearance of risk where no risk in fact exists. UCS does not mention the weaknesses in its chosen form of evidence. Furthermore, even with their inherent biases, many observational studies have not found any harm associated with air pollution, yet UCS omits this contrary evidence from its analysis as well.
UCS assumes that NOx emissions from construction equipment increase ozone, but in fact NOx emissions reduce ozone. A range of air pollution research has shown that when the ratio of VOC to NOx in air is relatively low�a condition typical in California�s metropolitan areas�reducing NOx increases ozone, and vice versa. The key evidence is that total NOx levels decline substantially on weekends, mainly due to reductions in the use of diesel trucks and construction equipment, but ozone levels rise.
UCS exaggerates Californians� exposure to air pollution. For example, UCS claims "more than 90 percent of Californians live in areas that do not comply with the federal ozone standard." The real percentage is only one-third of what UCS claims. UCS generated its exaggerated value by counting "clean" areas as "dirty." For example, even though 99 percent of people in San Diego County live in areas that comply with the federal 8-hour ozone standard, UCS counts all 3 million San Diegans as living in an area that violates the standard. Thus, in addition to exaggerating the harm from any given level of air pollution, UCS also exaggerates the air pollution levels themselves.

At high enough concentrations diesel exhaust can be an unpleasant and aggravating nuisance. But this is a far cry from UCS�s accusation that more than a thousand people are killed each year or that hundreds of thousands suffer serious harm from construction-related emissions.

UCS has vilified the Bush administration, sometimes with good reason, for manipulating scientific research for political purposes, and has even created a whole campaign and Web site to expose and condemn the politicization of science. Yet, in Digging Up Trouble UCS itself puts on a clinic in the selective use of scientific evidence to reach predetermined conclusions and support extra-scientific political goals.[5] The remainder of this commentary provides a more detailed critique of UCS�s misleading account of the health effects of current, historically low air pollution levels.[6]

Evaluating the Real Risks

UCS attributes 98 percent of the harm from construction emissions to premature deaths supposedly caused by PM_2.5 and ozone.[7] But these deaths are statistical figments rather than real harm from air pollution.

UCS implicitly attributes about 40 percent of the air pollution-related deaths from construction equipment to nitrate PM caused by NOx emissions.[8] However, laboratory research on animals and human volunteers indicates that nitrates are not toxic, even at levels many times greater than ever occur in the most polluted California air.[9] UCS assumes all particulate matter has the same health effects, regardless of composition, and does not mention any of the evidence showing that nitrate PM is not harmful. Right off the bat these data reduce UCS�s death claim by 40 percent.

UCS attributes another 10 percent of deaths to ozone caused by NOx and VOC emissions.[10] But emissions from construction equipment actually cause a net decrease in ozone. The reason is that when there is a low ratio of VOC to NOx in air, NOx becomes a net ozone destroyer. Under this circumstance, reducing NOx actually increases ozone.[11] This is the situation in much of California and has been for at least a decade. For example, in the Los Angeles region, NOx levels are about 25 percent to 40 percent lower on Sundays than on weekdays, but ozone levels are 20 percent to 50 percent higher.[12] Even though weekends account for only 29 percent of all days of the year, nearly 50 percent of 8-hour ozone exceedance days in the Los Angeles metro area occur on weekends. San Diego and the San Francisco Bay Area similarly have lower NOx and higher ozone on weekends.

NOx levels drop so much on weekends because diesel vehicles�such as construction equipment�are a large source of NOx and these vehicles are much less active on weekends.[13] The evidence suggests that NOx reductions are the cause of the increase in weekend ozone levels.[14] Thus, regardless of the health effects of ozone, construction emissions reduce ozone. Knock off another 10 percent of the deaths and health costs UCS claims for construction emissions. Despite its claim to be a group of scientists that bases its claims on scientific research, UCS does not mention any of the substantial scientific literature on the role of NOx emissions in reducing ozone levels in California.

Diesel smoke is more noxious than nitrate PM, as anyone who has ever stood near the exhaust pipe of an old school or transit bus can attest. Yet, even diesel smoke and PM_2.5 in general show little evidence for harm at the relatively low exposure levels that occur in the real world today. For example, two separate Health Effects Institute (HEI) studies exposed both healthy and asthmatic human volunteers to 100 µg/m³ of diesel particulate matter (DPM) and 200 µg/m³ of Los Angeles-area PM_2.5 for 2 hours while they exercised.[15]

Both of these are high exposures when compared with PM_2.5 levels people out in the real world experience. Recent measurements next to one of the busiest freeways in Los Angeles found that black carbon, a major component of diesel smoke, never exceeded 10 µg/m³ and averaged 5.4 µg/m³.[16] In terms of total PM_2.5, even Riverside, California, which has the highest PM_2.5 levels in the United States, never reaches 200 µg/m³ of total PM_2.5 and only rarely exceeds even 100 µg/m³. Despite the relatively high particulate exposure levels in the HEI study, the researchers did not find changes in symptoms or lung function in either the healthy or asthmatic subjects.

Animal studies can use much higher PM levels than studies with human volunteers. Yet diesel soot and ambient PM_2.5 do not cause premature death in animals until concentrations reach levels tens to hundreds of times greater than would ever be experienced in ambient air.[17] As a recent review concluded:

It remains the case that no form of ambient PM�other than viruses, bacteria, and biochemical antigens�has been shown, experimentally or clinically, to cause disease or death at concentrations remotely close to US ambient levels.

[18]

Thus, the weight of the evidence from controlled studies with animals and human volunteers suggests that PM is unlikely to cause premature death or other serious health effects at levels found in real-world air. UCS does not mention any of these research results or even imply that there is any evidence at all against the claims it makes in Digging Up Trouble.

The studies discussed above randomly assigned subjects to "treatment" and "control" groups. Random assignment ensures that the treatment and control groups differ only in whether they are exposed to air pollution. Thus, any observed health effects can be more confidently attributed to air pollution and not to other unrelated factors. This type of study is the "gold standard" for sorting out whether a given factor�for example, a new drug, a change of diet, an air pollutant, etc.�really affects health.

Like UCS, other environmental activists, as well as government regulators, have ignored the evidence from controlled studies. Instead, they cite results from a much weaker type of study design called an "observational" study. Observational studies work with non-randomly selected subjects and non-randomly assigned pollution exposures and then use statistical methods to try to remove the biases inherent in non-random data. Most epidemiological studies you read about in the newspaper�studies that assess the effects of diet or health habits on risk of cancer or heart disease, for example�are of this non-randomized, observational sort.

The output of an observational epidemiology study is a correlation between some factor, say air pollution levels or dietary fat, and a health outcome, such as death, atherosclerosis, or an asthma attack. But unlike controlled laboratory studies, which produce direct evidence for cause-effect relationships, the evidence from observational studies is indirect. The implicit assumption in an observational study is that after researchers have controlled for all known sources of bias, any residual correlation between, say, air pollution and risk of death represents a genuine causal connection. However, several lines of evidence indicate that this assumption is false, and that observational studies instead tend to turn up false indications of risk.

Publication Bias and Data Mining

First, it is nearly impossible to control for all of the biases inherent in non-random data, because most of these biases are either unmeasured or unknown. Second, phenomena known as "publication bias" and "data mining" exaggerate the apparent size of any given health effect reported in the epidemiologic literature and encourage researchers to "find" what they are looking for.

Publication bias refers to the tendency of researchers to seek publication of, and for scientific journals to accept for publication, mainly those studies that find a statistically significant effect, while not publishing studies that do not find an effect. As a result, the real effect of any particular air pollutant, diet, medical intervention, etc., is smaller than the studies in the scientific literature would na�vely lead one to believe.

Data mining refers to the risk that observational studies can become statistical fishing expeditions that turn up chance correlations, rather than real causal relationships. Think of the statistical models that researchers use to control for bias in observational studies as having lots of "dials" or "knobs" that the researchers can turn in order to "tune" the statistical model until it fits the observations. Within the presumed uncertainties in the data and methods, researchers tend to turn these knobs and dials in ways that maximize the effects they "expect" or "hope" to find, and are more likely to seek publication of studies that find the expected effect.

Researchers have been aware of these problems for a long time.[19] Here is a recent caution on publication bias from a group of air pollution epidemiologists:

Publication bias arises because there are more rewards for publishing positive or at least statistically significant findings. It is a common if not universal problem in our research culture�In the field of air pollution epidemiology, the question of publication bias has only recently begun to be formally addressed.

[20]

Air pollution epidemiologists have also noted that it is common for researchers to selectively report results for statistical models that maximize the apparent risks of air pollution, rather than the full ensemble of results of their statistical modeling:

Estimation of very weak associations in the presence of measurement error and strong confounding is inherently challenging. In this situation, prudent epidemiologists should recognize that residual bias can dominate their results. Because the possible mechanisms of action and their latencies are uncertain, the biologically correct models are unknown. This model selection problem is exacerbated by the common practice of screening multiple analyses and then selectively reporting only a few important results.[21] (emphasis added)

each study can generate a large number of results for various outcomes, pollutants and lags and there is quite possibly bias in the process of choosing amongst them for inclusion in a paper.

[22]

Publication bias and data mining are not merely speculative concerns. They are serious problems in air pollution epidemiology and health research in general. In just the last few years much conventional medical wisdom that was based on observational epidemiology studies has been tested and overturned by randomized controlled trials that eliminate the biases inherent in observational studies.[23] Spurious results from observational studies have become such a pervasive problem in the medical literature that health researchers have been creating new journals specifically designed to combat publication bias and data mining.[24] A number of epidemiologists believe that observational epidemiology methods are not even capable of providing reliable evaluations of health risks, especially when the putative risks are relatively small, as they are for air pollution.[25]

Epidemiologists have also provided direct evidence that observational studies of air pollution and health are generating false indications of risk.[26] Furthermore, the key observational studies that regulators and activists use to justify their air pollution health claims suffer from spurious and biologically implausible results.

For example, UCS cites two research reports from the American Cancer Society (ACS) study of particulate matter and mortality as the evidence for premature death from long-term exposure to PM_2.5.[27] But these same two reports concluded that PM_2.5 appeared to kill men but not women, those who said they were moderately active but not those who said they were either very active or sedentary, and those with no more than a high school degree but not those with at least some college-level education. These biologically implausible outcomes suggest that the ACS results reflect uncontrolled statistical biases rather than real harm from pollution.

The Health Effects Institute (HEI) performed sensitivity analyses on the ACS data that provided additional evidence that its results were merely statistical artifacts. For example, when migration rates into and out of various cities over time were added to the ACS statistical model relating PM_2.5 and risk of death, the apparent effect of PM_2.5 disappeared.[28] Cities that lost population during the 1980s�Midwest "rust belt" cities�also had higher PM_2.5 levels. People left these cities, which were in economic decline, in search of work in more economically dynamic parts of the country. But people who work and have the wherewithal to migrate also tend to be healthier than the average person. Hence, what appeared to be an effect of PM_2.5 was actually the result of relatively healthier people leaving cities with higher-than-average pollution levels. Migration was just one of several confounding factors that diminished or erased the apparent harm from PM_2.5 but were not accounted for by the ACS researchers. Incidentally, UCS ignores two other major studies that did not find any harm from long-term PM_2.5 exposure.[29]

Another HEI effort, the National Morbidity, Mortality and Air Pollution Study (NMMAPS), reported that in about one-third of the 90 cities evaluated, higher levels of particulate matter and ozone were associated with lower risks of premature death.[30] How could air pollution kill people in some cities but save them in others? More likely both effects are the spurious result of uncontrolled statistical biases.

Not the Whole Truth

Digging Up Trouble includes many more examples of UCS exaggerating or cherry-picking the evidence. For example, UCS claims "as much as 10 to 20 percent of all summertime hospital visits and admissions for respiratory illness are associated with ozone�"[31] But not even CARB or EPA claim anywhere near this large a health burden from ozone and UCS claims to base its health effects estimates on the same studies that CARB and EPA use.[32] When CARB adopted a tougher ozone standard for California, agency staff estimated that eliminating virtually all human-caused ozone in the state would reduce asthma-related emergency-room visits by 1.75 percent and respiratory hospital admissions by 1.2 percent.[33] EPA scientists estimated similarly small health benefits from reducing ozone.[34] Compared to the regulators' estimates, UCS overstates the harm from ozone by at least a factor of six.

But even the small impact of ozone claimed by CARB and EPA is still an exaggeration of the real harm, because both agencies ignored contrary evidence. For example, when assessing the potential benefits of a tougher ozone standard, CARB�s staff omitted a study in California�s Central Valley that found that higher ozone was associated with a lower rate of hospital visits.[35] CARB was certainly aware of the existence of this study, because CARB funded and published it.

According to Digging Up Trouble PM_2.5 also contributes to respiratory hospital visits and asthma symptoms.[36] But UCS ignores a study of several hundred asthmatic children in Connecticut that did not find any association between PM_2.5 and asthma symptoms.[37]

The two studies just cited, the Central Valley study and the Connecticut study, are signal examples of how the overall evidence in the research literature is far more equivocal than advocates make it appear. The Central Valley study reported harm from PM, but not ozone. The Connecticut study reported harm from ozone, but not PM. Regulators and activists mention only the PM results from the Central Valley study and only the ozone results from the Connecticut study, creating an appearance of consistency and robustness in the research base that does not in fact exist.

Data from California and elsewhere in the United States also show that hospital visits for asthma attacks are lowest in July and August�the months when ozone concentrations are at their highest.[38] UCS ignores this evidence as well.

UCS claims that ozone from construction emissions causes more than 300,000 school absence days each year.[39] As shown above, construction emissions actually reduce ozone. Regardless, UCS was selective in choosing its evidence on whether higher ozone is associated with an increase in school absences. UCS cites a CARB health effects report as the source its claims of school absences due to ozone.[40] CARB in turn cites Gilliland et al. (2001), which used data from CARB�s Children�s Health Study (CHS), a long-term study of thousands of California children living in communities with a wide range of pollution levels.[41]

CARB and UCS ignored the biological implausibility of the results in Gilliland et al. For example, an absence from school on a given day appeared to be due mainly to ozone levels from one or two weeks ago, rather than ozone levels during the previous few days. Spending more time outdoors, which would have increased ozone exposures, was paradoxically associated with fewer school absences. Particulate matter was associated with a large increase in non-illness-related absences, but not with absences due to illness. Taken as a whole, the study�s results are not credible and are an additional example of the problems with observational studies.

UCS and CARB also fail to mention that two other studies have been published using the exact same CHS dataset, but did not find an association between ozone and school absences.[42] This is another example not only of UCS�s selective use of evidence to support its pre-determined conclusions, but also of the unreliability of observational studies for assessing health risks, since three different studies using the same data came up with three different results.[43]

Overexposure

In addition to exaggerating the health effects of any given level of air pollution, UCS creates a false appearance that elevated air pollution is more widespread than it really is. According to UCS "more than 90 percent of Californians live in areas that do not comply with the federal ozone standard." This is one of those claims that contains a technical grain of truth, but that leads readers to draw conclusions that are false.

EPA and CARB classify entire regions as "non-attainment" areas under the Clean Air Act even if only a single pollution monitor in the region violates a federal pollution standard. This makes sense from a regulatory perspective, because emissions in one part of a region can affect pollution levels in other parts. But UCS�s implication here is that more than 90 percent of Californians actually breathe air that does not comply with the federal ozone standard. This claim is high by about a factor of three.

For example, San Diego County violates the federal 8-hour ozone standard, but only at a single rural monitoring site in the town of Alpine. The other 99 percent of San Diego County�s 3 million residents breathe air that meets the 8-hour standard, but UCS still counts all of them as breathing air that violates the standard. Even about 65 percent of Los Angeles County�s 10 million residents breathe air that complies with the 8-hour standard, as does everyone in the San Francisco Bay Area. Overall, about 30 percent of Californians live in areas that violate the federal 8-hour ozone standard�just one-third of what UCS claims.

Conclusion

In summarizing its case for harm from air pollution UCS states:

Numerous epidemiological studies tracking thousands of individuals have linked PM exposure to premature death as well as cardiovascular and respiratory illnesses. Similar studies have been carried out for exposure to ozone pollution�The health effects quantified in this report are based on peer-reviewed epidemiological studies used by both the EPA and CARB to evaluate the benefits of reducing air pollution. These studies establish a statistically significant relationship between exposure to PM and ozone and increased incidences of specific health endpoints�The uncertainty in these estimates is quantified by presenting results as both a mean estimate of the number of incidences and a range of estimates representing the 95 percent confidence interval.

[44]

This statement has the appearance of a weight-of-the-evidence scientific review, but it is misleading and disingenuous. First, UCS fails to mention the existence of a large body of evidence that contradicts its claims. Second, UCS implies that peer review provides quality assurance. But despite being peer reviewed, a large fraction of published epidemiology studies have little to do with reality.[45]

Third, UCS creates the false impression that the statistical certainty measure used�the 95 percent confidence interval�represents the real uncertainty in the estimates of air pollution�s health effects derived in Digging Up Trouble. But the 95 percent confidence interval is a measure of real uncertainty only if the study subjects have been randomly selected and randomly assigned to pollution exposures, neither of which are the case in the studies UCS uses for its health effects claims. The 95 percent confidence interval isn�t meaningful unless the biases created by non-random data, data mining, and publication bias have been removed.

At high enough concentrations, diesel exhaust can be an unpleasant and aggravating nuisance. But this is a far cry from UCS�s accusation that more than a thousand people are killed each year or that hundreds of thousands suffer serious harm from construction-related air emissions. The weight of the evidence suggests that air pollution at current, historically low levels is a minor factor in people�s health.[46]

According to its Web site, UCS "stands out among nonprofit organizations as the reliable source for independent scientific analysis."[47] UCS also leads a "scientific integrity" campaign devoted to opposing the manipulation of scientific research results for political ends. However, in Digging Up Trouble UCS selects and structures information to create the appearance of scientific support for its apparently predetermined conclusions about the health risks of air pollution from construction vehicles. The report fails to live up to UCS's own standards.

Joel Schwartz is a Visiting Fellow with the American Enterprise Institute.

Endnotes

[1] Union of Concerned Scientists, Digging Up Trouble: The Health Risks of Construction Pollution in California (Berkeley, CA: December 2006), http://www.ucsusa.org/assets/documents/clean_vehicles/Digging-up-Trouble.pdf.

[2] These percentages include only exhaust emissions. CARB also estimates that dust kicked up by "construction and demolition" accounted for about 5 percent of direct PM_2.5 emissions. Presumably some of these emissions are due to the movement of construction equipment on unpaved surfaces. It doesn�t appear that UCS included these emissions in its estimates. 2005 is the year for which UCS estimated the health impacts of air pollution from construction equipment. California Air Resources Board, "Forecasted Emissions by Summary Category," last updated February 2, 2006, http://www.arb.ca.gov/app/emsinv/ccos/fcemssumcat_cc214.php; California Air Resources Board, "California Off-Road Diesel Fueled Equipment Inventory," October 2006, http://www.arb.ca.gov/msprog/ordiesel/documents/tier_distribution_table.pdf.

[3] Ibid.

[4] Air pollution has been dropping for as long as we�ve been measuring it�which means since the early or mid 1900s in some cases. California and national air pollution emissions and ambient concentrations are at historic lows and continue to decline. For summary national trends in air pollution levels from 1980-2005, see www.epa.gov/airtrends and click on any of the pollutants for a trend graph. For California ozone and PM₁₀ trend data, see http://www.arb.ca.gov/adam/cgi-bin/db2www/polltrendsb.d2w/start. For California air toxics (i.e., benzene, 1,3-butadiene) trend data, see http://www.arb.ca.gov/adam/toxics/toxics.html. Some areas, including Los Angeles and Pittsburgh, have data going back to the early- or mid-20th Century. See, for example, C. I. Davidson, "Air Pollution in Pittsburgh: A Historical Perspective," Journal of the Air Pollution Control Association 29 (1979): pp. 1035-41; J. H. Ludwig, G. B. Morgan and T. B. McMullen, "Trends in Urban Air Quality," EOS 51 (1970): pp. 468-75; H. W. Ellsaesser, "Trends in Air Pollution in the United States," in The State of Humanity, ed. J. L. Simon (Malden, MA: Blackwell, 1995), pp. 491-502.

[5] For more detailed discussions of popular portrayals of evidence on air pollution levels and health effects, see, for example, J. Schwartz, Air Quality: Much Worse on Paper Than in Reality (Washington, DC: American Enterprise Institute, May 2005), http://www.aei.org/docLib/20050602_EPOMay_Junenewg%282%29.pdf; J. Schwartz, Air Pollution and Health: Do Popular Portrayals Reflect the Scientific Evidence? (Washington, DC: American Enterprise Institute, May 2006), http://www.joelschwartz.com/pdfs/AirPoll_Health_EPO_0506.pdf; J. Schwartz, "Air Pollution: Why Is Public Perception So Different from Reality?" Environmental Progress 25 (2006): pp. 291-97.

[6] See note 4 for summary information on air pollution trends.

[7] UCS claims construction-related air pollution causes $9.14 billion per year in harm, of which $8.94 billion represents premature death.

[8] UCS doesn�t make this explicit. However, Digging Up Trouble cites CARB�s health-effects report on goods movement in California as the source for its air pollution death claims. CARB attributes 40 percent of premature deaths to nitrate PM specifically. The percentage breakdown for construction equipment might be a few percentage points higher or lower than for goods movement. There�s no easy way to know for sure, because Digging Up Trouble provides only cursory information on the methodology used to derive its estimates, and does not provide any quantitative breakdowns of its results beyond the summary estimates of total health effects from all construction-related air pollution. In the absence of these details, I use CARB�s goods-movement results as a reasonable ballpark breakdown of the fraction of all health effects contributed by the various components of construction-related air pollution. See California Air Resources Board, Quantification of the Health Impacts and Economic Valuation of Air Pollution from Ports and Goods Movement in California (Sacramento, CA: March 21, 2006), http://www.arb.ca.gov/planning/gmerp/march21plan/appendix_a.pdf, p. A-75.

[9] L. C. Green and S. R. Armstrong, "Particulate Matter in Ambient Air and Mortality: Toxicologic Perspectives," Regulatory Toxicology and Pharmacology 38 (2003): pp. 326-35; M. T. Kleinman, W. S. Linn, R. M. Bailey et al., "Effect of Ammonium Nitrate Aerosol on Human Respiratory Function and Symptoms," Environmental Research 21 (1980): pp. 317-26; R. B. Schlesinger and F. Cassee, "Atmospheric Secondary Inorganic Particulate Matter: The Toxicological Perspective as a Basis for Health Effects Risk Assessment," Inhalation Toxicology 15 (2003): pp. 197-235; M. J. Utell, A. J. Swinburne, R. W. Hyde et al., "Airway Reactivity to Nitrates in Normal and Mild Asthmatic Subjects," Journal of Applied Physiology 46 (1979): pp. 189-96.

[10] See note 8 for how this estimate was derived.

[11] J. H. Seinfeld, "Urban Air Pollution: State of the Science," Science 243 (1989): pp. 745-52.

[12] Based on hourly ozone and NOx monitoring data for 1997�2001 downloaded from the California Air Resources Board�s Web site, http://www.arb.ca.gov/aqd/aqdcd/aqdcddld.htm.

[13] C. L. Blanchard and S. J. Tannenbaum, "Differences between Weekday and Weekend Air Pollutant Levels in Southern California," Journal of the Air & Waste Management Association 53 (2003): pp. 816-28; E. M. Fujita, D. E. Campbell, B. Zielinska et al., "Diurnal and Weekday Variations in the Source Contributions of Ozone Precursors in California�s South Coast Air Basin," Journal of the Air & Waste Management Association 53 (2003): pp. 844-63; R. A. Harley, L. C. Marr, J. K. Lehner et al., "Changes in Motor Vehicle Emissions on Diurnal to Decadal Time Scales and Effects on Atmospheric Composition," Environmental Science and Technology 39 (2005): pp. 5356-62.

[14] Blanchard and Tannenbaum, "Differences between Weekday and Weekend Air Pollutant Levels in Southern California"; C. L. Blanchard and S. J. Tannenbaum, "Weekday/Weekend Differences in Ambient Air Pollutant Concentrations in Atlanta and the Southeastern United States," Journal of the Air & Waste Management Association 56 (2006): pp. 271-84; E. M. Fujita, W. R. Stockwell, D. E. Campbell et al., "Evolution of the Magnitude and Spatial Extent of the Weekend Ozone Effect in California�s South Coast Air Basin 1981-2000," Journal of the Air & Waste Management Association 53 (2003): pp. 864-75; Harley, Marr, Lehner et al., "Changes in Motor Vehicle Emissions on Diurnal to Decadal Time Scales and Effects on Atmospheric Composition"; D. R. Lawson, "The Weekend Effect�the Weekly Ambient Emissions Control Experiment," Environmental Manager (July 2003): pp. 17-25; L. C. Marr and R. A. Harley, "Modeling the Effect of Weekday-Weekend Differences in Motor Vehicle Emissions on Photochemical Air Pollution in Central California," Environmental Science & Technology 36 (2002): pp. 4099-106; L. C. Marr and R. A. Harley, "Spectral Analysis of Weekday-Weekend Differences in Ambient Ozone, Nitrogen Oxide, and Non-Methane Hydrocarbon Time Series in California," Atmospheric Environment 36 (2002): pp. 2327-35; B. K. Pun and C. Seigneur, "Day-of-Week Behavior of Atmospheric Ozone in Three U.S. Cities," Journal of the Air & Waste Management Association 53 (2003): pp. 789-801; R. Torres-Jardon and T. C. Keener, "Evaluation of Ozone-Nitrogen Oxides-Volatile Organic Compound Sensitivity of Cincinnati, Ohio," Journal of the Air & Waste Management Association 56 (2006): pp. 322-33.

[15] H. Gong, Jr., C. Sioutas and W. S. Linn, "Controlled Exposures of Healthy and Asthmatic Volunteers to Concentrated Ambient Particles in Metropolitan Los Angeles" (Boston: Health Effects Institute, 2003); S. T. Holgate, T. Sandstrom, A. J. Frew et al., Health Effects of Acute Exposure to Air Pollution. Part I: Healthy and Asthmatic Subjects Exposed to Diesel Exhaust (Boston: Health Effects Institute, 2003).

[16] Y. Zhu, W. C. Hinds, S. Kim et al., "Concentration and Size Distribution of Ultrafine Particles near a Major Highway," Journal of the Air and Waste Management Association 52 (2002): pp. 1032-42.

[17] Green and Armstrong, "Particulate Matter in Ambient Air and Mortality: Toxicologic Perspectives"; S. H. Moolgavkar, "A Review and Critique of the EPA�s Rationale for a Fine Particle Standard," Regulatory Toxicology and Pharmacology 42 (2005): pp. 123-44.

[18] Green and Armstrong, Ibid.

[19] Publication bias is a well-documented problem in a range of disciplines. See, for example, Victor M. Montori, Marek Smieja and Gordon H. Guyatt, "Publication Bias: A Brief Review for Clinicians," Mayo Clinic Proceedings 75 (2000): pp. 1284-88; Alison Thornton and Peter Lee, "Publication Bias in Meta-Analysis: Its Causes and Consequences," Journal of Clinical Epidemiology 53 (2000): pp. 207-16.

[20] H. Anderson, R. Atkinson, J. Peacock et al., Meta-Analysis of Time-Series Studies and Panel Studies of Particulate Matter (PM) and Ozone (World Health Organization, 2004), www.euro.who.int/document/e82792.pdf.

[21] T. Lumley and L. Sheppard, "Time Series Analyses of Air Pollution and Health: Straining at Gnats and Swallowing Camels?" Epidemiology 14 (2003): pp. 13-14.

[22] Anderson et al., Meta-Analysis of Time-Series Studies and Panel Studies of Particulate Matter (PM) and Ozone.

[23] For example, hormone replacement therapy and Vitamin A turned out not to reduce risk of cardiovascular disease, following a low-fat diet turned out not to reduce risk of heart disease or colorectal and breast cancer, and calcium supplements didn�t reduce the risk of osteoporosis. S. A. Beresford, K. C. Johnson, C. Ritenbaugh et al., "Low-Fat Dietary Pattern and Risk of Colorectal Cancer: The Women�s Health Initiative Randomized Controlled Dietary Modification Trial," Journal of the American Medical Association 295 (2006): pp. 643-54; B. V. Howard, L. Van Horn, J. Hsia et al., "Low-Fat Dietary Pattern and Risk of Cardiovascular Disease: The Women�s Health Initiative Randomized Controlled Dietary Modification Trial," Journal of the American Medical Association 295 (2006): pp. 655-66; G. Kolata, "Big Study Finds No Clear Benefit of Calcium Pills," New York Times, Feburary 16, 2006; Moolgavkar, "A Review and Critique of the EPA�s Rationale for a Fine Particle Standard"; R. L. Prentice, B. Caan, R. T. Chlebowski et al., "Low-Fat Dietary Pattern and Risk of Invasive Breast Cancer: The Women�s Health Initiative Randomized Controlled Dietary Modification Trial," Journal of the American Medical Association 295 (2006): pp. 629-42; G. D. Smith, "Reflections on the Limitations to Epidemiology," Journal of Clinical Epidemiology 54 (2001): pp. 325-31; G. Taubes, "Epidemiology Faces Its Limits," Science 269 (1995): pp. 164-69.

[24] Sharon Begley, "New Journals Bet 'Negative Results' Save Time, Money," The Wall Street Journal, September 15, 2006, p. B1, http://online.wsj.com/article/SB115827169620563571-email.html.

[25] J. P. Ioannidis, "Why Most Published Research Findings Are False," PLoS Med 2 (2005): e124, http://medicine.plosjournals.org/archive/1549-1676/2/8/pdf/10.1371_journal.pmed.0020124-L.pdf; Smith, "Reflections on the Limitations to Epidemiology"; Taubes, "Epidemiology Faces Its Limits."

[26] Anderson, Atkinson, Peacock et al., Meta-Analysis of Time-Series Studies and Panel Studies of Particulate Matter (PM) and Ozone (; M. L. Bell, F. Dominici and J. M. Samet, "A Meta-Analysis of Time-Series Studies of Ozone and Mortality with Comparison to the National Morbidity, Mortality, and Air Pollution Study," Epidemiology 16 (2005): pp. 436-45; K. Ito, "Associations of Particulate Matter Components with Daily Mortality and Morbidity in Detroit," in Revised Analyses of Time-Series Studies of Air Pollution and Health (Boston: Health Effects Institute, 2003); W. R. Keatinge and G. C. Donaldson, "Heat Acclimatization and Sunshine Cause False Indications of Mortality Due to Ozone," Environmental Research 100 (2006): pp. 387-93; G. Koop and L. Tole, "Measuring the Health Effects of Air Pollution: To What Extent Can We Really Say That People Are Dying from Bad Air?" Journal of Environmental Economics and Management 47 (2004): pp. 30-54.

[27] D. Krewski, R. T. Burnett, M. S. Goldberg et al., Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality (Boston: Health Effects Institute, July 2000); C. A. Pope, 3rd, R. T. Burnett, M. J. Thun et al., "Lung Cancer, Cardiopulmonary Mortality, and Long-Term Exposure to Fine Particulate Air Pollution," Journal of the American Medical Association 287 (2002): pp. 1132-41.

[28] Krewski, Burnett, Goldberg et al., Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study.

[29] J. E. Enstrom, "Fine Particulate Air Pollution and Total Mortality among Elderly Californians, 1973-2002," Inhalation Toxicology 17 (2005): pp. 803-16; F. W. Lipfert, H. M. Perry, J. P. Miller et al., "The Washington University-EPRI Veterans� Cohort Mortality Study," Inhalation Toxicology 12 (suppl. 4) (2000): pp. 41-73.

[30] M. L. Bell, A. McDermott, S. L. Zeger et al., "Ozone and Short-Term Mortality in 95 US Urban Communities, pp. 1987-2000," Journal of the American Medical Association 292 (2004): pp. 2372-8; F. Dominici, A. McDermott, M. Daniels et al., Revised Analyses of the National Morbidity, Mortality, and Air Pollution Study (Boston: Health Effects Institute, May 2003).

[31] UCS, p. 7.

[32] See UCS, p. 25. UCS says its health effects estimates are derived from health studies cited in the following reports from CARB and EPA: California Air Resources Board, Appendix A. Quantification of the Health Impacts and Economic Valuation of Air Pollution from Ports and Goods Movement in California (Sacramento: March 21, 2006), http://www.arb.ca.gov/planning/gmerp/march21plan/appendix_a.pdf; Environmental Protection Agency, Final Regulatory Analysis: Control of Emissions from Nonroad Diesel Engines (Washington, DC: May 2004), http://www.epa.gov/nonroad-diesel/2004fr/420r04007a.pdf.

[33] CARB�s report does not provide these percentages explicitly. Instead, in one part of its staff report CARB estimates the number of incidences of various health effects avoided by reducing ozone. Another part of the report provides estimates of the total number of incidences of each health effects. Dividing the former by the latter gives the fraction of health effects avoided by reducing ozone. I demonstrate this in J. Schwartz, Rethinking the California Air Resources Board�s Ozone Standards (Washington, DC: American Enterprise Institute, September 2005), http://www.aei.org/doclib/20050912_Schwartzwhitepaper.pdf. For CARB�s estimates, see California Air Resources Board, Review of the California Ambient Air Quality Standard for Ozone (Sacramento: March 2005), http://www.arb.ca.gov/research/aaqs/ozone-rs/ozone-final/ozone-final.htm.

[34] Once again, EPA does not provide explicit percentage changes, but the percentage changes can be calculated from data provided in a journal article by EPA�s scientists. See B. J. Hubbell, A. Hallberg, D. R. McCubbin et al., "Health-Related Benefits of Attaining the 8-Hr Ozone Standard," Environmental Health Perspectives 113 (2005): pp. 73-82; Schwartz, Rethinking the California Air Resources Board�s Ozone Standards.

[35] S. F. van den Eeden, C. P. Quesenberry, J. Shan et al., Particulate Air Pollution and Morbidity in the California Central Valley: A High Particulate Pollution Region (Sacramento: California Air Resources Board, July 2002).

[36] UCS, p. 9.

[37] J. F. Gent, E. W. Triche, T. R. Holford et al., "Association of Low-Level Ozone and Fine Particles with Respiratory Symptoms in Children with Asthma," Journal of the American Medical Association 290 (2003): pp. 1859-67.

[38] For data on asthma emergency room visits and hospitalizations by month, see, for example, Spokane Regional Health District, Asthma in Spokane County (Spokane, WA: April 2002), http://www.srhd.org/information/pubs/pdf/factsheets/AsthmaInSpokaneCounty.pdf; J. K. Stockman, N. Shaikh, J. von Behren et al., California County Asthma Hospitalization Chart Book, Data from 1998-2000 (Sacramento: California Department of Health Services, September 2003), http://www.ehib.org/cma/papers/Hosp_Cht_Book_2003.pdf; Texas Department of Health, Asthma Prevalence, Hospitalizations and Mortality � Texas, 1999-2001 (Austin: November 21, 2003), http://www.tdh.state.tx.us/cphpr/asthma/asthma.pdf; K. Tippy and N. Sonnenfeld, Asthma Status Report, Maine 2002 (Augusta, ME: Maine Bureau of Health, November 25, 2002); K. R. Wilcox and J. Hogan, An Analysis of Childhood Asthma Hospitalizations and Deaths in Michigan, 1989-1993 (Lansing, MI: Michigan Department of Community Health, undated), http://www.michigan.gov/documents/Childhood_Asthma_6549_7.pdf.

[39] UCS, p. 9.

[40] California Air Resources Board, Appendix A. Quantification of the Health Impacts and Economic Valuation of Air Pollution from Ports and Goods Movement in California.

[41] F. D. Gilliland, K. Berhane, E. B. Rappaport et al., "The Effects of Ambient Air Pollution on School Absenteeism Due to Respiratory Illnesses," Epidemiology 12 (2001): pp. 43-54.

[42] K. Berhane and D. C. Thomas, "A Two-Stage Model for Multiple Time Series Data of Counts," Biostatistics 3 (2002): pp. 21-32; V. Rondeau, K. Berhane and D. C. Thomas, "A Three-Level Model for Binary Time-Series Data: The Effects of Air Pollution on School Absences in the Southern California Children�s Health Study," Statistics in Medicine 24 (2005): pp. 1103-15.

[43] There are other reasons to conclude that the claim of a connection between ozone and school absences is not credible. For details, see pp. 28-30 in Schwartz, Rethinking the California Air Resources Board�s Ozone Standards.

[44] UCS, p. 25.

[45] Ioannidis, "Why Most Published Research Findings Are False"; Smith, "Reflections on the Limitations to Epidemiology"; Taubes, "Epidemiology Faces Its Limits"; Begley, "New Journals Bet �Negative Results� Save Time, Money."

[46] See note 4 for summary information on air pollution trends.

[47] UCS, "About UCS," http://www.ucsusa.org/ucs/about/.

Hollywood pollutes the most in LA?

sam.staley@reason.org (Samuel Staley) — Mon, 13 Nov 2006 06:45:25 EST

It turns out, the industry that pollutes more than any other in Southern California than perhaps petroleum refineries is--Hollywood! According to a recent UCLA report from the Institute of the Environment:

The industry tops hotels, aerospace, and apparel and semiconductor manufacturing in traditional air pollutant emissions in Southern California, according to the study, initially prepared for the Integrated Waste Management Board, and is probably second only to petroleum refineries, for which comparable data were not available. The entertainment industry ranks third in greenhouse gas emissions.

The complete article is here. The full report from UCLA can be found here.

Not being productive? Maybe a nap is what you need

ted.balaker@reason.org (Ted Balaker) — Wed, 01 Nov 2006 12:52:28 EST

I see stuff like this as more evidence that managers should rethink their in-the-desk-from-9-to-5 mentality:

subjects that took a 10 minute nap significantly improve performance in multiple post-nap tests.

Study here; via Tasty Research. I think one of the reasons telecommuters often work longer and more productively than office workers is because they're better able to fit in recuperative activities. Even just creating a more comfortable environment–working outdoors from a reclining chair as I recall one design engineer doing, going tie-less (or even less)–helps workers' brains stay fresh. Related: Telecommuters Prove More Productive (with comments from yours truly)

Working from AnywhereóInternational Space Station Edition

ted.balaker@reason.org (Ted Balaker) — Sun, 24 Sep 2006 12:56:13 EDT

Anousheh Ansari is the first female Muslim in space, the first Iranian to reach Earth orbit, and perhaps the first civilian telecommuter in the ISS:

she has been trying to keep on top of her office work while she has been aboard, and has been receiving status reports from her staff at Prodea Systems, the telecommunications company she co-founded. Article here. Related: Directing a film from a hospital bed; attending college from home

Not so keen on telecommuting, after all?

ted.balaker@reason.org (Ted Balaker) — Wed, 12 Jul 2006 15:45:11 EDT

many people would rather work at the office even if their job allowed telecommuting

Sure, not everyone, perhaps not even most would telecommute if given the option, but that doesn't mean we should assume workers aren't interested in it and leave it at that. In most of the top 50 metro areas telecommuting already tops transit commuting and, apart from driving alone, it was the only commute mode to gain market share from 1980 to 2000. The evidence is pretty clear that the practice has continued to grow since 2000. According to one recent survey, 80 percent of San Diego area folks who don't telecommute say they would if given the chance. Do I think 80 percent of those surveyed really would telecommute? No way, but it still shows there's pretty strong interest. And even if only, say, 20 percent really did end up working from home that would still make a big difference. According to the National Technology Readiness Survey, of those who telecommute, most only do so one, two, or three days a week. But people should only do it as often as they want to, and the more people learn about part week (or even part day) telecommuting, the better. My hunch is that many managers and employees quickly dismiss the idea because they assume telecommuting is an all-or-nothing choice. Few people will be able to ditch the office entirely, but as more people realize that telecommuting frequency can vary tremendously more will give telecommuting another look and figure out the best way to personalize the process of work. Article here; thanks to Bobby B. for the tip.

Cut telecommuting, then cut office space?

ted.balaker@reason.org (Ted Balaker) — Wed, 05 Jul 2006 14:22:58 EDT

Hewlett-Packard plans to consolidate its sprawling real estate holdings into more densely packed locations as part of its ongoing cost-reduction plan, the company announced Thursday. The four-year review of HP's real estate kicked off a little less than a year after CEO Mark Hurd announced plans to aggressively cut costs within the company. Under the new program, HP wants to reduce the number of offices it maintains and to have a smaller number of "core sites," it said in a press release. Article here; Thanks to Brad Hutchings for the tip. Getting by with less office space is easier when you allow employees to telecommute, yet HP recently pulled most of its IT staff back to the office.

Getting Real on Air Pollution and Health

adrian.moore@reason.org (Adrian Moore) — Fri, 23 Jun 2006 19:59:06 EDT

Once again Joel Schwartz nails it on air pollution issues, this time in the venerable Washington Post. The EPA attributes well over 90 percent of the benefits of its clean air programs to improvements in human health. Thus, a key policy question is whether EPA's health-benefit claims are credible. . . . The most serious claim about air pollution is that it prematurely kills tens of thousands of Americans each year. This claim is based on small statistical correlations between pollution levels and risk of death. But correlation doesn't necessarily mean causation, as demonstrated recently by a number of embarrassing reversals of conventional medical wisdom. The air pollution--mortality claim deserves even greater skepticism. First, it is based on the same unreliable correlation methods that have led medical authorities astray in other areas. Second, even though pollution is weakly correlated with higher premature mortality on average, it seems to protect against death in about one-third of cities. How could pollution kill people in some cities and save them in others? More likely, both results are chance correlations rather than real effects. Third, in laboratory experiments, researchers have been unable to kill animals by exposing them to air pollution at levels many times greater than ever occur in the United States.

Whatís really going on with HP?

ted.balaker@reason.org (Ted Balaker) — Thu, 08 Jun 2006 11:24:54 EDT

Responding to this post of mine in which I examine Hewlett Packard's recent decision to bring nearly all of its IT staff back to the office, Brett from Oregon writes:

One assumption in this blog post is that HP wants to retain talent. I currently live in an HP town, and HP has been laying off workers left and right. There has not been a single job posting in years. It is widely believed that HP is trying to eliminate facilities and reduce payroll. The layoffs are so severe in Oregon that HP has brokered a deal whereby their layoff numbers are kept secret. Odds are, this rule change away from telecommuting and flexible work schedules is an attempt to get rid of workers who require these flexible schedules. This would reduce unemployment costs from eventual layoffs as well as operational costs. Interesting point. Bernie Goldbach seems to agree:

WANT TO SQUEEZE your workforce before they cash in on pensions? Then change work practises on them. ... HP has a bulge at the 15/50 point--I reckon around 600 people. That's a trainload full of employees who have been with the company for nearly 15 years or that's a cohort of seasoned experience approaching 50 years of age. They have to squeeze that cohort because it's expensive labour with attitude. It's much easier to impose a lower cost-per-employee on a work force that's younger and more flexible about work practises and company policies. H-P people with the experience have roots in communities, often hundreds of miles away form their assigned office cubicles. They probably will resign their positions rather than pay the extra petrol charges or move house. And that cuts wage costs at H-P. It also sheds a lot of expertise in places like enterprise services and if imposed with a clock-in system at the main doorway, it could place the efficiency of the printer division at risk.

Can Bill Ford Defeat His Green Goblins?

shikha.dalmia@reason.org (Shikha Dalmia) — Thu, 01 Jun 2006 00:00:00 EDT

Reason.com

If those of us in the Wolverine State had to pick one candidate for divine intervention—Ford Motor Company or General Motors—we would be well advised to pick Ford. The company is not more worthy of heavenly help, but under its greener-than-thou chief executive officer Bill Ford, who has dragged America's number two automobile manufacturer into an acute existential crisis, it needs even more help. Absent a miracle, Ford might well go down the tubes—and take Michigan with it.

It is no secret that the Big Two automakers are in Big Trouble. Delphi Corp., GM's biggest supplier, recently declared bankruptcy in order to void its extravagant union contracts. Meanwhile, the United Auto Workers union—never shy about killing the golden goose—recently authorized a strike against Delphi. Should the strike actually go forward, it may ring the death knell of GM, which, after six consecutive quarters of losses, has neither the cash reserves nor the inventories to weather such an event.

But if GM's losses are more serious, Ford's are more intractable. Ford cut thousands of white collar jobs last year and plans to eliminate 30,000 more by 2008. It will shutter 14 factories over the next few years. Its debt has been trading at junk level for about a year. And it posted its worst quarterly loss earlier this year (even bigger than GM's), partly as a result of the expensive buy-out packages that it was forced to pay to reduce its bloated workforce.

Radical cost-cutting measures might stanch the company's losses, they won't restore its profitability. What the company needs, sorely, to regain its health are exciting cars that people will buy at full price without bribes of zero interest loans and Dell computers. But these products have eluded Ford for years now.

Nor is this a surprise. Under Bill Ford, the company, the majority of which is still owned by the Ford family, can't make up its mind whether the automobile—his great-grandpa's invention—is a boon to humanity or a blot on the face of Mother Earth. Where Henry, the founder of the company, was a proud promoter of the automobile, his great-grandson worries whether or not the automobile is compatible with "sustainable development."

Henry Ford had an ideology too—a noxious mix of anti-Semitism and anti-unionism, as a matter of fact. But he kept his business separate from his politics and raised the wages of his workers well over industry norms to fuel demand for his cars. But Bill Ford, a former member of the Sierra Club, is more interested in setting the "pace in the industry on important environmental and social priorities, such as reducing water consumption, conserving energy, recycling and reusing non-renewable materials, eliminating toxic materials, establishing codes of working conditions and safety in our plants and supply chain, and addressing public health issues from HIV/AIDS to cancer to juvenile diabetes." Everything but making cars.

The company's inner conflict between saving itself and saving the planet is particularly acute when it comes to pick-up trucks and SUVs—until recently its most successful products.

Last month, Ford partnered with TerraPass, a group that invests in alternative energy sources, to launch a website that would allow owners of these gas-guzzlers to calculate the greenhouse gases they emit in a year. It would then direct them to invest in companies that produce clean technologies to offset these emissions.

But investors need no invitation from Ford to put their money elsewhere. Ford stocks were trading at a 15-year low a few weeks ago and are worth a modest $7 or so today, compared to $25 in 2001.

This is not Ford's first foray into environmental correctness since Bill Ford took over the company in 1999. Ford was the first automaker to withdraw from the Global Climate Coalition—a coalition of manufacturers lobbying against the Kyoto Treaty's mandates against greenhouse gas emissions.

Last year, after Toyota overtook Ford as the world's second biggest automaker (behind General Motors), one might have thought Ford would devote every dollar it could muster to improving its products and recapturing its lost market share.

Instead, Ford launched a multi-million-dollar advertising campaign—complete with full-page ads in The New York Times and 60-second radio commercials—to publicize that Toyota was not the only one holding the bragging rights to making hybrids. Ford was making these money losers too.

Worst of all, Bill Ford has repeatedly called on the government to impose a gas tax to discourage sales of SUVs. "We can't be in the business of dictating what the customer wants to buy," he says—implying, of course, "but the government can."

Nor is this simply feel-good PR designed to earn brownie points with the enviros. The company's environmental mission has become inextricably entwined with its business strategy. Ford has convinced itself that the public's growing environmental conscience combined with stricter government regulation against greenhouse gas and other emissions means that the future will belong to greener car makers.

To this end, the company has decided to bump up its annual hybrid production from 25,000 now to 250,000 by 2010. But it typically costs $6,000 more to manufacture a hybrid than a gas-powered car, according to Ford insiders. The best estimates suggest that the company loses $2,000 to $3,000 on every hybrid it sells.

It is stunning that Ford would increase by ten-fold production on such colossal cash-suckers when it is inches away from bankruptcy. But it justifies its decision on grounds that Toyota is jacking up its hybrid production to 1 million by 2010.

The big difference is that for Toyota hybrid production is about PR, not about reviving its flagging fortunes. And Toyota can well afford to splurge on such gambits given that its market capitalization—the total value of its outstanding stock—is $200 billion, about 15 times more than Ford's. Hybrids might one day yield a profit. But the question is whether Ford will still be in business when that happens.

The repercussions of Ford's failure to come up with a winning business strategy won't be limited to its glass-and-steel headquarters in Dearborn; they will be felt all over the state. Home foreclosure rates in neighboring Oakland County, the fourth richest county in the nation, have doubled in the last two years, The Wall Street Journal reported recently. Area restaurants and other businesses have drastically slashed prices. People are severely cutting back discretionary spending on all kinds of services from landscaping to spa treatments, adding to a sense of general gloom in the area.

People could leave the state for greener pastures—as opposed to greener corporations—elsewhere, except that it's not so easy for those of us who have homes here. Property values have slumped in the past two years and many homes are staying on the market for months even after deep cuts in the original asking price.

Our fates therefore depend a great deal on Bill Ford exorcising the environmental gods and devoting himself angst-free to the task of making cars that people will buy, just as great-grandpa did.

Look whoís saving the world now

ted.balaker@reason.org (Ted Balaker) — Thu, 18 May 2006 10:35:47 EDT

I just saw a license plate border that read: "saving the planet one hybrid at a time." It was attached to a hybrid Ford Escape AKA an SUV! Perhaps the reputation of SUV owners (at least hybrid SUV owners) has come full circle. From a 2003 article of mine:

There was a time when SUV owners were depicted as robust outdoor enthusiasts and sporty soccer moms. Then as SUVs bulked up and became less fuel-efficient, public opinion started to turn against them and their owners. Buying an SUV stopped being simply a reflection of the owner as a consumer, and more about the owner as a moral agent. In some circles, buying an SUV was no longer a choice, it was a sin. SUV foes demanded to know why someone would suck up natural resources, and trash the planet just to intimidate other drivers with his street-legal monster truck? As the moralizing mounted, the social standing of SUV owners continued to erode. Today, SUV owners can only claim moral superiority over the likes of smokers and spammers. But I wonder how drivers of super-efficient hybrids feel about Escape owners who brag about their eco-friendliness. And as I pointed out here, many owners of regular non-hybrid cars have plenty to boast about too. BTW, the most self-righteous message on the back of a hybrid is still: "How many lives per gallon do you get?" Watch the South Part "Smug Alert!" episode here.

What politicians drive

ted.balaker@reason.org (Ted Balaker) — Wed, 26 Apr 2006 14:30:43 EDT

Or perhaps it's more accurate to say "what the drivers of politicians drive":

"Since George Bush and Dick Cheney took over as president and vice president, gas prices have doubled!" charged Sen. Barbara Boxer (D-Calif.), standing at an Exxon station on Capitol Hill where regular unleaded hit $3.10. "They are too cozy with the oil industry." She then hopped in a waiting Chrysler LHS (18 mpg) -- even though her Senate office was only a block away. ... At about the same time, House Republicans were meeting in the Capitol for their weekly caucus (Topic A: gas). The House driveway was jammed with cars, many idling, including eight Chevrolet Suburbans (14 mpg). ... After lunchtime votes, senators emerged from the Capitol for the drive across the street to their offices. Sen. John Sununu (R-N.H.) hopped in a GMC Yukon (14 mpg). Sen. Jim DeMint (R-S.C.) climbed aboard a Nissan Pathfinder (15). Sen. Ben Nelson (D-Neb.) stepped into an eight-cylinder Ford Explorer (14). Sen. Dianne Feinstein (D-Calif.) disappeared into a Lincoln Town Car (17). Sen. Edward Kennedy (D-Mass.) met up with an idling Chrysler minivan (18). Next came Sen. Bob Menendez (D-N.J.), greeted by a Ford Explorer XLT. On the Senate floor Tuesday, Menendez had complained that Bush "remains opposed to higher fuel-efficiency standards." Also waiting: three Suburbans, a Nissan Armada V8, two Cadillacs and a Lexus. The greenest senator was Richard Lugar (R-Ind.), who was picked up by his hybrid Toyota Prius (60 mpg), at quadruple the fuel efficiency of his Indiana counterpart Evan Bayh (D), who was met by a Dodge Durango V8 (14). More here. Related: Public Officials Tout Transit More than They Use It

The tangled web of particulate pollution policy

adrian.moore@reason.org (Adrian Moore) — Mon, 17 Apr 2006 10:52:45 EDT

I just finished submitting comments to the EPA on their proposed standards for particulate pollution. Rather than focusing on how to address the real health threats from air quality and get the most out of the rules we have in place to address them, the EPA is pursuing particulate standards that are not supported by epidemiological standards of evidence. You can read Reason's brief comments on the proposed rules here. In a similar vein, my colleague Joel Schwartz finds similar problems with the science in the EPA's new toxics report. In his column (here) he says

Based on EPA's own estimates, air pollution even in the "most toxic" areas of the country poses a miniscule cancer risk. More importantly, EPA's cancer risk estimates are grossly inflated, because they depend on the false assumption that chemicals pose the same per-unit cancer risks at real-world trace exposures as they do at massive laboratory exposures.

And Joel also dissects (here) the latest research in the Journal of the American Medical Association showing that particulates kill mice:

However, researchers have been unable to kill animals with air pollution at levels anywhere near as low as the levels found in ambient air. As a recent review of particulate matter toxicology concluded: "It remains the case that no form of ambient PM -- other than viruses, bacteria, and biochemical antigens -- has been shown, experimentally or clinically, to cause disease or death at concentrations remotely close to US ambient levels."

All three items are related because in each case activists, some researchers, and sometime the EPA, point to dramatic health impacts only by making extreme unrealistic assumptions or dropping standards of epidemiological research. It's all about changing our thinking. Air pollution is dramatically different from what we thought 10 years ago--we are beating it, but too many are still stuck in the rut of "we're all gonna die!" and can't shift from finding the next crisis to working on getting results from the efforts we already have going.