Pull the Plug on Electric Vehicle Charging Stations

Posted on March 19, 2013, 9:59pm | Baruch Feigenbaum

The Atlanta Journal-Constitution published my op-ed against subsidizing electric vehicle charging stations.

In summary, the city of Atlanta is using federal subsidies to install electric vehicle car-charging stations. This may sound like a good way to invest in the future. Unfortunately, there are several significant problems with this taxpayer supported subsidy.  

First, electric vehicles in GA are not cleaner than traditional gas-powered vehicles. Most electricity in Georgia is generated by coal power, which produces far more carabon dioxide than gas engines. And the lithium batteries, which power most electric vehicles, requires mining lithium. The negative environmental consequences of mining lithium far outwiegh any positive benefits from operating electric vehicles. 

Electric vehicles are used mostly by the wealthy. For example, the average income of a Chevrolet Volt owner is $170,000. The only automaker whose customers have a higher income is Mercedes-Benz. Why are taxpayers subsidizing new cars for the rich who can already afford them?

And even with the subsidy auto sales are not exactly taking off. Ford sells more F-Series pickups in a year than Chevrolet sells Volts and Nissan sells Leafs combined in a year. The combined federal and Georgia subsidy of up to $15,000 cannot make customers but a product they do not want. 

The complete op-ed is available here.

The Facts Behind EPA's Greenhouse Gas Regulations

Posted on April 3, 2012, 5:35pm | Adam Peshek

After the defeat of his carbon dioxide cap-and-trade legislation in 2009, President Obama told a room of reporters that there was “more than one way to skin a cat.” And in the new political era of regulation without legislation, the President’s EPA has released standards on carbon dioxide that do just that.

In perhaps its most sweeping regulatory approach to date, the EPA under Lisa Jackson recently released New Source Performance Standards (NSPS) for carbon dioxide, which aim to cut greenhouse gases emitted by the U.S.

In today’s post, I will look at the logic behind the rule and its fundamental flaws. In later posts I will look at what’s next for carbon dioxide regulations and an examination of the very idea of regulating carbon.

How EPA Skins a Cat

The NSPS requires all newly constructed power plants to meet an emissions standard of 1,000 pounds of CO2 per megawatt-hour (MWh) regardless of the type of fuel. The average coal-fired power plant puts out 2,000 pounds of CO2 per MWh and newer, more efficient models emit about 1,800 pounds per MWh. Simple math shows that the future of coal-fired electricity in the U.S. looks bleak, even for the industry’s best facilities.

Advocates for the new rules (who apparently must portray themselves as pro-coal) say that the new rules will not hurt the coal industry. That is because the rule only calls for 1,000 pounds of CO2 per MWh over a 30 year average. So in theory, a coal plant could emit 1,800lbs of CO2 for the first 10 years of operation, so long as it implemented yet-to-exist technologies to cut its emissions to 600 pounds per MWh by year 11.

If only it were that simple.

EPA’s rationale for the feasibility of the regulation is two-fold: (1) technologies will be available in the next decade that allow the capture and storage of CO2 emissions from coal and (2) the abundance of cheap natural gas that has flooded the market in the past few years.

The (Un)available Best Technology

The section of the Clean Air Act (CAA) that details the NSPS directives requires EPA to create regulations based on the “best system of emission reduction” that “has been adequately demonstrated,” taking into account costs, environmental impacts, and energy requirements.

The technology EPA points to with this regulation is called "carbon capture and sequestration" (CCS). CCS involves the capture of carbon dioxide from power plants before it is emitted and then the storage of the captured gas underground. The problem with using CCS as a “best available technology” is that it is not in use anywhere in the U.S., and is only in use in experimental, highly expensive sites in a handful of sites in Europe. It is nowhere near the point of viability technologically or financially.

EPA’s own, typically bullish analysts themselves admit that CCS viability is at least a decade away. To make this pass muster, EPA applied the 30-year average requirement. In doing so, EPA is saying “yes, the technology is not available today, therefore, apply the best technology available and in a decade apply CCS when it is viable.” Government agencies are prone to the conceit that they can predict the future, but this is a stretch even by EPA standards.

Aside from the technological and financial problems involved with CCS, there is also the problem with citing plants in places that can eventually store CO2 underground. This leads to even larger permitting headaches. How can you predict permitting requirements for a technology that is not yet in use and thus has not been subject to federal, state, or local permitting requirements? It is not merely a matter of building a new, modern plant and hoping you chose a site that is adequate for CCS.

Gas, Naturally!

The second, seemingly more logical, rationale for the rule’s approach is the abundance of cheap natural gas that is making coal less economically appealing.

It is true that in the near term, low natural gas prices are already making coal uneconomical, with utilities rushing to refurbish or build new natural gas plants to take advantage of its record low prices. As I mentioned in a post two weeks ago:

A gold rush of shale gas plus the ability to get eight-times the amount of energy from one well has caused gas supplies to skyrocket, driving down prices. With low prices, companies are fleeing the historically inexpensive and dirty coal-fired plants and maximizing natural gas plants, which emit roughly half the greenhouse gases. According to the study, the U.S. emitted nearly 9% less CO2 (the chief greenhouse gas) in 2009 than it did in 2008, mostly because gas prices dropped from $12 per million British thermal units in June 2008 to less than $4 per MMBtu in September 2009. During that time, the cost of generating electricity from natural gas plants fell an average of about 4 cents per kilowatt. With average natural gas prices at $2.30 MMBtu today, it is safe to say this trend will continue. Utilities are shutting down coal-fired plants at record pace and replacing them with new or expanded gas-fired plants.

On average, coal supplies roughly 40 percent of U.S. electricity. But according to the Energy Information Agency (EIA), coal-fired electricity dropped below the 40 percent mark last December for the first time in over 30 years. Coal consumption will likely drop another 5 percent this year according to the EIA. The agency expects natural gas to pick up the slack, with a 9 percent increase this year, or a record high of 22.7 billion cubic feet a day.

However, it’s important to note that these have all been the economics of a struggling economy with a drop in electricity demand. But, as we know, energy needs fluctuate. During last summer’s heat wave, every single unit scheduled for retirement was running to meet increased demand, including coal. Had these facilities been taken off-line there would have been sweeping brown outs across the warmest areas of the U.S.

So, according to EPA’s own analysis, natural gas’s affordability makes NSPS rule unnecessary. Economic factors – not environmental concerns – are already giving utilities more than enough incentive to switch from coal to gas. As noted in my earlier post, this leads to cheaper energy and a cleaner environment. But the Agency is following its usual path of imagining what the future will look like today. With natural gas prices and energy demands locked at 2011 levels, an emissions standard of 1,000 pounds per MWh makes sense. But they refuse to note that maybe, just maybe, market conditions will change. If natural gas prices and electricity demand rise simultaneously, this rule will be enormously costly and may have an effect on keeping the lights on in certain regions.

A New Type of Regulation

From a regulatory standpoint, this is a first for EPA.

As noted above, NSPS requirements in the Clean Air Act require the Agency to create regulations based on the “best system of emission reduction” that “has been adequately demonstrated,” taking into account costs, environmental impacts, and energy requirements. The statute does not allow EPA to prescribe specific technologies, only an emissions level for the source to meet.

For 40 years, the EPA has regulated NSPS based on specific fuel types (oil, gas, coal, etc.), as laid out in statute. For this regulation, however, EPA has chosen not to distinguish between fuel types. Instead, it requires coal to meet the emissions level of natural gas, which can easily meet the requirement. In other words, it implicitly asks coal to meet the emissions levels of gas with a technology that has not been demonstrated as technically or financially viable. If you asked natural gas to reach the emission levels of nuclear, you would also effectively ban natural gas plants. This is not a game EPA has played before, and it is a dangerous precident to set without legislation to point to.

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Unlike most EPA regulations, NSPS are binding once it is printed in the federal register. This is problematic for two reasons. First, it has effectively put a ban on the construction of new coal plants. Second, any legislative action to deal with this issue is hamstrung by the fact that the rules are not officially “final,” and thus could get around being subject to legislative review. It could easily be more than a year until EPA addresses all the comments and proposes a final rule.

Luckily for the coal industry, there is still a global market for coal. Metallurgic coal is in high demand in China where is used for steel making. Energy-dense bituminous coal is highly valued in places like India where it is burnt for power and heat. In fact, if you look at the countries across the globe who have growing economies, just about all of them are building new, state-of-the-art coal plants.

Electricity demand is flat thanks to a struggling economy, so the results may not be immediate. The question is its effects long term once the economy rebounds.

A big part of this will be whether or not EPA releases regulations on current coal facilities, as they have said they would do. Most observers believe that Obama will issue such regulations if he earns a second term in office.

My next post will look at the implications of a similar regulation on existing sources.

EPA's Fuzzy Math

Posted on February 17, 2012, 12:42pm | Adam Peshek

In my opinion piece yesterday I argued that the Environmental Protection Agency (EPA) is using fuzzy math to justify massive regulations:

MATS claims to target one pollutant but draws all of its benefits from another pollutant that is already below EPA-approved safe levels. The air is cleaner than it's ever been, but at $10 billion a year, MATS will be the most expensive EPA air regulation ever. Last week, the closure of nine power plants in four states was announced directly because of the regulation, and more are looming. Affordable energy is key to a recovering economy and when the costs and benefits are weighed, it's clear that this regulation's costs are enormous and the benefits to society are minimal at best.

MATS is supposed to target reductions of mercury and other toxic emissions. But by EPA's own calculations, benefits from reductions in mercury will result in between $500,000 and $6 million in benefts. As I noted, EPA is able to justify a regulation costing $10 billion a year by inflating the benefits that come from reductions in a pollutant that is already below levels that the EPA considers safe.

The Economist has more commentary on this today:

The minutiae of how regulators calculate benefits may seem arcane, but matters a lot. When businesses complain that Mr Obama has burdened them with costly new rules, his advisers respond that those costs are more than justified by even higher benefits. His Office of Information and Regulatory Affairs (OIRA), which vets the red tape spewing out of the federal apparatus, reckons the “net benefit” of the rules passed in 2009-10 is greater than in the first two years of the administrations of either George Bush junior or Bill Clinton.

But those calculations have been criticised for resting on assumptions that yield higher benefits and lower costs. One of these assumptions is the generous use of ancillary benefits, or “co-benefits”, such as reductions in fine particles as a result of a rule targeting mercury.

For more information on EPA's latest $10 billion regulation, see my commentary here.

EPA's Utility MACT - More Policy-Driven Science

Posted on December 21, 2011, 10:51am | Adam Peshek

Today at 2pm, EPA Administrator Lisa Jackson will visit a children’s hospital in Washington, D.C. and unveil the Agency’s new Utility MACT rules. She will stand at a podium, most likely surrounded by doctors and sick children, and proudly announce that starting today, children and pregnant women will no longer have to worry about the main menace being targeted with these rules – mercury. Unfortunately, these rules will have negligible impact on mercury and, as President Obama promised while campaigning, the regulation is really targeted at putting an end to the coal industry in the U.S.

...

Mercury is a neurotoxin that can harm fetal development and reduce I.Q. in children. It can find its way into bodies of water and accumulate in fish, which has lead health officials, in the name of “better safe than sorry”, to caution women about eating types of seafood when pregnant.

EPA estimates that it will cut mercury emissions by nearly 90% by pressing forward with these rules, which impose $11 billion in annual compliance costs for utilities. It is widely accepted that, at the very least, these compliance costs will pose difficult problems in ensuring that the lights stay on for many Americans.

But EPA says it’s worth it. They proclaim that the rules will eliminate 11,000 heart attacks, 17,000 premature deaths, 120,000 cases of asthma, and an overall reduction of 850,000 sick days per year. Risk analysts nation-wide will cheer at such impressively accurate estimates.

Further, EPA’s cost-benefit analysis, or Regulatory Impact Analysis (RIA), estimates between $53 and $140 billion in annual health benefits thanks to this rule going forward. The only problem is that these benefits have absolutely nothing to do with reductions in air toxics emissions – the entire purpose of the rule. In fact, EPA’s own estimates show benefits of only $500,000 to $6 million per year – less than .01% of the estimated benefits. This is due to the reduction of just one of the toxic air pollutants, mercury. 

So where are the benefits coming from? Entirely from particulate matter (PM). PM is targeted by other regulations, but for the past couple of years, EPA has been using it as a way to push through industry-specific regulations that it could never pass on a basic cost-benefit analysis. It’s able to do this by calculating coincidental “co-benefits” of PM for rules that are not targeting PM.

EPA currently considers PM emissions above an average of 15 micrograms per cubic meter (μg/m3) to be harmful to human health. However, EPA has been calculating PM risks as low as 4 and 5μg/m3 – three times below what EPA defines as safe. A key and very dubious assumption being made with this method is that risks to PM are linear to zero. In other words, EPA is assuming that changes in air quality at safe and nearly unobservable levels have the same effect as changes at high levels where legitimate health associations have been determined. David Kreutzer at the Heritage Foundation describes it well:

Suppose a study examined accidents in which four people each fell a distance of 50 feet. If two of the four died, the prediction of what is called a linear-dose response is that for every 200 feet that a population falls, two people will die. This would be averaged out among the population and the distance of falling. For instance, this linear-dose response would predict that for every 400 people who step off a six-inch curb, two will die from the impact. A cost-benefit calculation using this assumption would show that even a small city would save thousands of lives per day by cutting down all curbs. Though stepping out into street may be dangerous for other reasons, dropping down six inches is not the cause of any fatalities. Nor would eliminating curbs reduce any of the other dangers of stepping into the street.

Likewise, the EPA’s analysis of the Utility MACT rule using a linear-dose response is way off base, because existing mercury and particulate levels are more analogous to stepping off a six-inch curb than a 50-foot cliff.

EPA says it will reduce mercury by 90% with these rules. But clearly, based on EPA’s own analysis, this will be 90% from an already negligible amount.

This is just another example in EPA’s long and dubious use of cost-benefit analyses to drive industry specific regulations to eliminate coal. Don’t believe me? Here is then candidate Obama discussing his policies regarding coal:

EPA Ignores Improved Air Quality to Advance Regulation

Posted on November 16, 2011, 8:33pm | Adam Peshek

A new report finds that many of the air quality goals of the Cross State Air Pollution Rule (CSAPR) have already been achieved. Thus, these controversial and costly rules are largely unneeded.

CSAPR is often referred to as the “good neighbor rule.” Its intent is to curb emissions from states that “contribute significantly” with the maintenance of healthy air quality in neighboring states.  Specifically, the rule addresses emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx), which are the main precursors to fine particulate matter (PM2.5) and ozone. Compliance costs for this rule, according to EPA, are $2.4 billion annually. Several states – including those not affected by the rule – have filed a lawsuit suing the EPA to delay implementation of CSAPR, which becomes effective January 1, 2012.

But according to a recent report conducted by Alpine Geophysics for the Midwest Ozone Group, these contentious rules are largely unnecessary with improvements already occurring in the affected areas.

To support this rule, EPA took emission data from 2003-2007 to determine which states were significantly contributing to poor downwind air quality. The Agency then applied computer modeling to predict which states would likely be “bad neighbors” in 2012 and 2014 – essentially contributing more than 1% of the level of nonattainment of ozone and PM2.5.

However, EPA has released more recent data from 2007-2010 that shows things have significantly improved, accomplishing regulatory outcomes in areas that will be forced to comply – without spending billions of dollars in questionable permitting schemes. For example, EPA data from 2003-2007 shows that 16 areas don’t meet air quality standards for ozone and an additional 16 areas don’t meet standards for PM2.5. According to the newer data, these numbers have been reduced to 6 and 2 areas respectively. This data was available to EPA during the crafting of the rule and its omission is puzzling.

Over the past few decades, ozone and particulate matter emissions have declined nearly 30 percent and they continue to decline. Precursor emissions of SO2 and nitrogen oxide NOx have fallen nearly twice as fast. It’s not clear – environmentally or financially – what is to be gained from this rule. States have proven that they are more than equipped to curb emissions without Washington’s expensive, burdensome, and rushed regulatory agenda.

Read the full report here. Read my past blog on faults with EPA’s implementation of CSAPR here.

House Votes to Delay "Boiler MACT"

Posted on October 14, 2011, 11:16am | Adam Peshek

The House voted late Thursday night to delay implementation of the "Boiler MACT" rule, national emission standards currently being rolled out by the Environmental Protection Agency (EPA) in an effort to curb emissions from industrial boilers and process heaters.

This regulation imposes stringent emission limits for eleven categories of boilers used in manufacturing, processing, mining, refining, and other industries, as well as commercial boilers used in malls, apartments, restaurants, and hotels.  Boilers burn fuels, such as natural gas, coal, biomass, and fossil fuels to produce steam, which is then used to produce electricity or heat.

The EPA Regulatory Relief Act of 2011 (H.R. 2250) was approved by a vote of 275-142, with 41 Democrats giving their support.  The bill would postpone implementation of a new, less stringent standard for at least 15 months and would give manufacturers and others five years to comply instead of three year compliance in the current rule.

EPA’s methods of promulgating boiler rules are costly, widely unachievable, and highly contentious. Under the rule, the majority of coal-fired boilers will need to be retrofitted with new and costly emissions curbing technologies. With EPA's cost estimates of $9.5 billion up front and annual compliance costs of $3.2 billion, Boiler MACT is one of the most expensive EPA regulations in the Agency's queue.

There are many problems with the rules, but here are just a few:

1. the use of pollutant-by-pollutant standard setting instead of source-by-source;
2. the decision to not apply health-based emission limits for certain pollutants;
3. and the reclassification of many materials which will place them under stricter incinerator standards.

Without EPA’s willingness to readdress these issues, Congress is justified in intervening to create a better rule that protects the public and the environment, without being overly burdensome and unachievable by industry.

Two Examples of EPA Overreach

Posted on October 11, 2011, 1:52pm | Adam Peshek

The idea of out-of-control bureaucrats has become a major topic of discussion in politics, with debates over the role of the Environmental Protection Agency (EPA) rising to the level of nationalized health care and government bailouts.  Those on the right characterize the Agency as an Orwellian Ministry, with those on the left portraying it as the last hope against oil CEOs buying votes in dimly lit, smoke filled Capitol offices.

Once you dig through the partisan conjecture you get to the real problem:  EPA is acting like President Obama is going to be a one-term president – meaning they need to act fast.  With this in mind, the Agency is pushing through the most expensive set of regulations in American history.                                                                                        

Measures taken to protect the environment are necessary and welcomed.  But concerns for air quality should always be measured against the larger context of the economy and real-world achievability.

Here are two current examples of EPA’s neglect for this principle.

EPA’s Frankenstein

“Boiler MACT” is the name given to EPA’s new standards aimed at cutting emissions from boilers used in industries like manufacturing and processing and in commercial use by the likes of malls and hospitals.  These boilers burn fuels to produce steam, which is then used to produce electricity or heat.

Under the regulations, the majority of boilers will need to be retrofitted with new and costly emissions curbing technologies, with an upfront price tag of $10 billion and annual compliance costs of around $3 billion.

Boiler MACT is an example of EPA regulating outside of reality.

The Clean Air Act gives EPA authority to regulate boilers based on the best performing similar facilities.  One could easily interpret this as monitoring facilities with the best pollution controls and then directing the industry to move towards similar technologies.  Instead, the Agency looked at individual pollutants at facilities, cherry picked the best results, spiced them together, and set the bar there.  Even if a facility is the worst polluter of a particular pollutant, it could still be considered a best performing facility if its emissions of another pollutant are low.

This approach has been dubbed the “Frankenboiler” by industry – a facility created in a lab which does not exist in the real world.  In testimony before a House committee, Paul Gilman, EPA official turned industry representative, compared this approach to “asking that the decathlon champion at the Olympics be able to win not only the overall decathlon, but all of the 10 individual events as well.”

Picking on Texas

In July, EPA finalized their Cross-State Air Pollution Rule, an updated Bush-era program which regulates emissions from power plants in states that the EPA finds “contribute significantly” with the maintenance of healthy air quality in neighboring states. 

The final rules came after a standard process in which the Agency proposes standards, allows stakeholders and the public an opportunity to comment on the proposal, and crafts a regulation, hopefully taking into account valid comments in their final product.

When the proposal was released a in 2010, EPA data that showed Texas’ contribution to out-of-state emissions were not high enough for inclusion.

But when the final rule was released in July, Texas found itself included in the program.

The last minute inclusion is based on a hypothetical linkage between Texas emissions and a pollution monitor hundreds of miles away in Granite City, Illinois.  The monitor is located half-a-mile from a steel mill, and was placed there specifically to monitor it.  In fact, the area meets air quality standards today after the Illinois Environmental Protection Agency and the mill agreed on the installation of pollution controls.

Texas was never given the opportunity to publicly comment on this information because it was not part of the proposed rule, which is when the public has the opportunity to share concerns.

Curiously, when six other states were added to the program after the proposal, EPA gave them additional notice and time to comment on the Agency’s findings.  So why was Texas snubbed?

Compliance costs for this rule are estimated at $2.4 billion annually.  Texas’ will be required to cut emissions by nearly 50 percent under the regulations, which go into effect in January 2012 – less than six months after the rules were released and Texas learned of its inclusion.  Not surprisingly, a Texas utility company recently announced it would shut down plants and fire nearly 500 employees as a direct result of the regulation.

In January, President Obama ordered agencies to regulate using the "least burdensome tools" that take "into account benefits and cost" and "[promote] economic growth ... and job creation."  The EPA, with 20,000 employees and a budget of $8.5 billion dollars, has simply ignored this. The President intervened in early September when he ordered the Agency to withdraw a burdensome regulation on ozone that would have cost $100 billion a year and shut down economic growth in hundreds of communities across the nation.

These are just two examples of EPA’s lack of discretion when crafting major rules that affect jobs, energy costs, and billions of dollars in diverted capital. 

The EPA is acting like they’ll be out of a job in 2013, and with this tunnel-visioned lack of restraint they have become the biggest contributor to that cause.

Some Health Benefits of Ground-Level Ozone

Posted on September 23, 2011, 1:26pm | Adam Peshek

For decades, environmentalists have been calling for drastic limits on ozone to protect public health. But the benefits of ground-level ozone are often ignored.

In a recent paper, a team from the National Center for Atmospheric Research finds that efforts to reduce ozone emissions lead to exposing more of the population to elements known to induce sunburn and skin cancer:

Improving air quality by reducing ambient ozone (O₃) will likely lower O₃ concentrations throughout the troposphere and increase the transmission of solar ultraviolet (UV) radiation to the surface … These relative increments in exposure are non-negligible given the already high incidence of UV-related health effects...

Ozone in the upper atmosphere protects us from ultraviolet radiation, but at ground level it can cause temporary respiratory problems and is the main constituent of urban smog.  Environmentalists and their counterparts often use junk science and small studies to make the case for squeezing billions of dollars out of industry for very marginal benefits.

But with rent-seeking groups like the American Lung Association lambasting generally safe levels of ozone, maybe groups like the American Academy of Dermatologists should be adding some more context to the debate on ozone’s health effects.

Early Success for Pay-As-You-Drive (PAYD) Vehicle Insurance in California

Posted on September 10, 2011, 1:09pm | Harris Kenny

Nearly three years ago today California Insurance Commissioner Steve Poizner proposed a voluntary pay-as-you-drive (PAYD) insurance option for California drivers. At the time, state regulation prevented insurance companies from offering PAYD Vehicle Insurance, or any equivalent option, to consumers.

For those unfamiliar, the Victoria Transport Policy Institute’s TDM Encyclopedia defines PAYD vehicle insurance in the following manner:

PAYD Vehicle Insurance (also called Distance-Based, Usage-based, Mileage-Based, Per-Mile Premiums and Insurance Variabilization) means that a vehicle’s insurance premiums are based directly on how much it is driven during the policy term. The more you drive the more you pay and the less you drive the more you save. This can be done by changing the unit of exposure (i.e., how premiums are calculated) from the vehicle-year to the vehicle-mile, vehicle-kilometer or vehicle-minute. Existing rating factors are incorporated so higher-risk motorists pay more per unit than lower-risk drivers.

Poizner’s proposal received support across a broad coalition of stakeholder groups from environmentalists and insurance companies to civil libertarians and consumer advocacy groups. The Los Angeles Times reported Poizner saying:

I am thrilled to pave the way for California drivers to obtain insurance that is more environmentally friendly and more accurately reflects driving habits. As a strong advocate of healthy market competition and a healthy environment, I am especially pleased to encourage this kind of innovation and additional options for consumers.

Earlier this week Daniel C. Vock, a staff writer for Stateline, highlighted the early success of California’s new PAYD insurance option. Vock writes:

The state’s Department of Insurance gave companies the green light last year to charge customers based on the number of miles driven, with the goal of cutting back traffic and saving drivers money. Insurance carriers like the change, because it lets them get more information on driving habits and charge appropriately.

Already, more than 80 percent of policyholders with the Auto Club of Southern California are using the new plans, which were first offered in February, says spokesman Jeffrey Spring. The auto club expects that number to climb to more than 90 percent.

State Farm, the nation’s largest auto insurer, would not reveal how many of its California customers have opted for the mileage-based plans. But last year, it predicted a quarter of them would choose the new option, saving the drivers $31 million. Bob Devereux, a spokesman for State Farm in California, says the new pricing scheme received a “very positive response.”

“It puts the customer in the driver’s seat,” he says. “(Customers) like the fact that they have more control over their future premiums.”

California’s early success is praiseworthy for one reason in particular: it’s voluntary. Further, California lawmakers resisted the urge to implement by fiat and instead enabled the marketplace to determine and meet consumer needs. Private insurance companies like the Auto Club of Southern California and State Farm then devised effective incentive plans to encourage consumers to make the switch. Lawmakers basically decided to legalize insurance companies providing insurance – and it’s working.

California policymakers were able to satisfy privacy concerns by adopting a unique approach. In California, drivers can voluntary adopt PAYD vehicle insurance and can comply by reporting their mileage driven through verified odometer checks. Insurance companies in other states (such as Illinois, Ohio, Colorado and Texas) offer a range of alternatives using different technologies.

Reason Foundation policy analyst Skaidra Smith-Heisters advocated for this approach in a December 2008 reason.org commentary available here. For more, see the Victoria Transport Policy Institute’s TDM Encyclopedia entry on PAYD Vehicle Insurance here.

Obama Scraps Ozone Regulation

Posted on September 2, 2011, 12:12pm | Adam Peshek

President Obama today announced that he will put a stop to the EPA’s effort to ratchet down national air quality standard for smog-creating ozone. 

This is a much welcomed announcement.

The proposed standards would have lowered emissions levels from 75 parts per billion (ppb) to between 60ppb and 70ppb – 3 years before the EPA is even required to review the current standards.

This revision would add – based on the EPA’s own analysis – an additional $90 billion in compliance costs for industry, making it one of the most expensive regulations in U.S. history.

It seems that President Obama could no longer ignore pleads from businesses and communities who would be decimated by the proposed rule.  In his statement the President cited concerns over the struggling economy as the main reason for the rule scrapping, adding, "Ultimately, I did not support asking state and local governments to begin implementing a new standard that will soon be reconsidered.”

The standards are up for review in 2013 – when Obama will be starting his second term or a Republican challenger begins their first. 

For more information on the ozone rule, see my op-ed in the Washington Times and my Out of Control blog highlighting the questionable science behind the proposed ozone levels.

Ozone Standards Not Scientific Either

Posted on August 19, 2011, 12:05pm | Adam Peshek

In my commentary in today’s Washington Times, I argue that the EPA is using unnecessary, premature regulations that are costing industry billions of dollars:

 

EPA is under no obligation to develop new regulations at this time. The Clean Air Act - the legal basis for most federal air quality regulations - requires the EPA to review national air quality standards every five years. If they find that current thresholds are detrimental to health, the EPA can go through the process of setting a new, scientifically-backed standard. The last time these standards were reviewed was three years ago. Legally, EPA is not obliged to initiate a review for another two years.

So, why is it doing so now? Is smog on the rise? Nope. According to the EPA, ozone levels have been falling year after year. Since 1980, ozone emissions have fallen by nearly 50 percent. And yes, new standards played a significant role in this. But it takes time for companies to develop and implement technologies that will enable them to comply in cost effective ways. Small companies in particular find this difficult because they have fewer resources to use in complying with regulations.

 

But does the science even suggest that these standards are warranted?

The basis for the EPA's regulatory ratcheting down rests on two very small studies, which the authors themselves say is not a basis for stricter standards.  Clean Air Science Advisory Committee (CASAC) member, and author of one of the studies stated:

 

[EPA’s] approach amounts to attempting to find effects in a very few individuals when the statistical tests are not significant, which is a dangerous precedent – especially in this case where we are looking at small effects in 3 of 30 vs. 1 of 30, a pitiful number on which to attempt to base policy...

 

Senator James Inhofe (R – OK), Ranking Member on the Environment and Public Works committee echoed concerns recently:

 

Today I am calling on the Obama-EPA to halt its plan to move forward with the reconsideration of the ozone standard.  EPA Administrator Lisa Jackson has repeatedly said that she is basing her decision on the recommendations of CASAC. Yet an investigation by my staff has uncovered an apparent lack of impartiality and financial conflicts of interest among the members of EPA's science advisory panels.  EPA is clearly politicizing the science, all in the name of an environmental activism that will destroy jobs.  This further undermines the scientific integrity of the Obama Administration, and in particular, the EPA.

 

Clearly, there is not scientific agreement that new standards would have any health benefits.  With billions of dollars and millions of jobs potentially at stake, the administration would be wise to take a closer look.

Deregulation of Nuclear Power Saves Money and Reduces Pollution

Posted on August 3, 2011, 2:23pm | Adam Peshek

“Deregulation, Consolidation, and Efficiency: Evidence from U.S. Nuclear Power,” a working paper out of Berkeley’s Energy Institute at Haas, finds that the deregulation of the nuclear industry in the ‘90s created a 10% increase in efficiency, which led to approximately $2.5 billion in savings annually and a decrease of 40 million tons of carbon emissions in the atmosphere each year.

The efficiencies that resulted from deregulation are impressive. It’s even more impressive when you consider that this was entirely from gains in efficiencies, not increases in the number of plants or transmission lines.

Our results imply a substantial increase in electricity production. In 2009 U.S. nuclear reactors produced 800 billion kilowatt hours of electricity, about 20% of total U.S. electricity generation. We estimate that the increase in electricity production due to deregulation and consolidation exceeds 40 billion kilowatt hours annually. At current average wholesale prices, the value of the increased electricity production is approximately $2.5 billion annually.

Granted, economic improvements associated with deregulation may not impress those who are in favor of regulation. Well how about environmental improvements?

In addition, because the increased electricity production displaces mostly coal‐ and natural‐gas‐ fired power, these gains in efficiency also have substantial implications for the environment, implying an annual decrease of 38 million metric tons of carbon dioxide emissions. Using a conservative estimate for the social cost of carbon dioxide ($20 per ton) this is an additional $760 million in benefits annually. To put this into perspective, this is more carbon abatement than was achieved by all the U.S. wind and solar generation combined during the same period. Whereas there are explicit programs directed at promoting low‐carbon energy in the case of wind and solar, this decrease in carbon emissions is noteworthy because deregulation is not usually envisioned as a means for achieving environmental goals.

The study of the nuclear power industry is especially useful for discussions of energy deregulation because, unlike other industries, nuclear power is always used as a “baseload” generation. In other words, they are constantly running and do not respond to fluctuations in demand.

Another reason to study nuclear deregulation is that there is a very clear sample – of the 103 reactors in the U.S., 48 of them were sold by states to independent companies at a very rapid pace during the ‘90s.

Deregulation is certainly not one of the methods environmentalists and enviro-bureaucracies look to when trying to limit greenhouse gases in the U.S.  But, by opening up the industry to competition, states across the country provided incentives for firms to do what companies are created to do: increase efficiency and cut costs to create value for the consumer and increase their own profits.

That is what is seen.

What are often missed by those who favor of regulation are the unseen benefits of the competitive market.  In this case: profit-inspired efficiencies that reduced emissions more than the entire “green” energy industry in the country without a single government subsidy, political battle, or increased cost to the consumer. That’s a policy environmentalist, industries, and politicians should all get behind.

Solving Car Pollution Problems Through Technology Fixes

Posted on May 11, 2010, 7:47am | Samuel Staley

Recent years have seen a resurgence of interest in using public policy to shift travel behavior, most notably in the U.S. Department of Transportation's strategic plan that emphasizes "livability" and "environmental sustainability." US DOT has combined with the U.S. Department of Housing and Urban Development and U.S. Environmental Protectin Agency to encourage policies that direct people into higher density, transit-oriented "urban villages" or cities to reduce the human footprint on the environment.

That's why a recent academic study published in the Berkeley Electronic Presses Journal of Economic Analysis and Policy is of interest. The authors find that a tax on gasoline, vehicle size, and engine size--"second best" alternatives to a more efficient, direct "pigouvian tax" on pollutants--could achieve 71 percent of the gains in reduced air pollutino. Nearly two-thirds of this improvement is achieved through a tax on gas.

The lesson in my opion: The most of effective policies are those that directly address the identified problem. Attempts to change behavior to achieve goals like environmental improvement are indirect at best, often several times removed from the impact we want to mitigate, and as a result indirect and ineffective.

Here's the abstract to the academic study and cite:

 

Tax and Subsidy Combinations for the Control of Car Pollution

Don Fullerton, University of Illinois at Urbana-Champaign
Sarah E. West, Macalester College

 

EPA's Proposed Ozone Standards Would Exacerbate State, Local Fiscal Woes

Posted on January 8, 2010, 1:21pm | Leonard Gilroy

At a time of historic fiscal woes for state and local governments, the last thing they need are more mandates from D.C. that worsen the problem. Yet, our tone-deaf U.S. Environmental Protection Agency could obviously care less, because it is proposing exactly that.

At issue is the EPA proposal to tighten ozone standards that cities and metros have to meet. And with the threat of holding back federal highway dollars for non-compliance, local governments that fail to meet the new standards would be severely punished economically, forcing their backs to the wall. The only realistic alternative is to comply with the ozone standards and take your medicine—generally involving lots of new expenditures on public transit, building retrofits, new planning and studies, and other so-called "green" strategies aimed at reducing ozone levels. Not to mention a whole plethora of regulations (i.e., building code tweaks and the like) aimed at forcing the medicine down everyone's throats, including the job-creating business sector.

So it's a fiscal double whammy. You get new government spending to meet what is essentially a politically determined ozone standard (despite claims that it is "science-based") at a time when budgets are thrashed and "extra" money is nowhere to be found. And then you get the second effect of the dampening economic effect as regulations force businesses to spend more and become less productive, eventually manifesting itself in reduced tax revenues to government.

Poor Houston offers a taste of how this ozone whimsy may play out:

The federal government proposed a tougher limit on ozone pollution Thursday that will force Houston to make deeper emissions cuts just as the former smog capital met the previous standard for the first time. [...]

The tougher stance will likely have a profound effect on Texas, where more than 25 counties could be out of compliance and in jeopardy of losing federal highway funds.

Those areas will have up to 20 years to meet the new standard.

Houston, for one, must make further pollution cuts from vehicles and industry just as the eight-county area complies for the first time with the previous standard.

While environmentalists and public health advocates applauded the stricter limit, industry groups and some Texas officials said it will harm the state's economy without yielding meaningful health benefits.

"The EPA's only consistent target has been the target on the backs of Texas workers and taxpayers," said Gov. Rick Perry, who added that the state has invested more than $1 billion to comply with the 1997 standard.

Translation: The state of Texas and Houston spent a ton of money and worked for years just to finally meet the current ozone standard. Now that they finally achieved it, they face the prospect of spending a lot more because economically-ignorant environmental regulators in D.C. see a window of political opportunity and want to set up a moving target. Imagine Charlie Brown upended trying to kick the football Lucy's just pulled away.

For an administration supposedly so focused on job creation and economic recovery, you'd think that the folly of imposing new, costly ozone standards on state and local governments and private businesses—potentially on top of cap-n-trade or some other new carbon regulation regime—would be obvious.

But the economy isn't EPA's concern—in fact, they get the luxury of ignoring the costs it imposes on the economy:

Federal law prohibits the EPA from considering cost when setting air standards. It has estimated the price tag of the new program at $19 billion to $90 billion per year by 2020, depending on the standard it sets, but also said the expense could be offset by reduced health care costs.

So EPA gets to set standards in a vacuum while forcing all of the accompanying economic trade-offs on others.

How nonsensical is this ozone proposal? The failed first stimulus was largely a union-backed, temporary bailout of state and local governments, and now policymakers are angling for a second stimulus in light of continuing state fiscal woes. At the same time the administration apparently sees no problem with imposing tremendous new costs on states and locals via more stringent environmental regulation. Unfortunately, this is typical D.C. practice—what one hand giveth the other taketh away.

UPDATE: I used "moving target" above metaphorically, but The New York Times notes that the administration is considering imposing an actual moving target on ozone:

The Obama administration is also proposing a secondary smog standard that would vary with the seasons to protect plants and trees from repeated exposure.

More sound "logic" from D.C. environmental bureaucrats—it's been hard enough for cities to meet one target, so let's throw more several at them.

UPDATE 2: Of course, you'll hear that the reason for this nonsense is "to protect lives and human health." But looking at this WaPo graphic, it looks to me like the estimated additional "benefit" of the proposed changes—likely on the rosy high end, as this was estimated by the EPA itself—would be felt by less than 200,000 people nationally (mostly those with respiratory problems, much less so for those with acute bronchitis or aggravated asthma).

To put that into perspective, a policy proposal that would cost untold billions if past experience is any judge will bring a purported benefit to around 0.7% of the U.S. population. I leave it to the readers to judge whether that's a trade-off worth making.

Season's Scrooging from Maricopa County

Posted on December 31, 2009, 4:05pm | Leonard Gilroy

I must confess to having had a major laugh today to my seven-year old's reaction to the Maricopa County (Arizona) Air Quality Department's issuance of it's fifth no-burn day since Christmas Eve. Her reaction to our local government Scrooge: "that's not just stupid, it's idiotic!"

As a very practical matter, I have to agree, federal threats over the County's violation of particulate matter standards notwithstanding. At a time when people are generally frustrated with big government at all levels, how out-of-touch is it to start rolling out a sequence of burn-bans on Christmas Eve, the moment that families typically come together to do enjoy things like eggnog and presents around a fireplace? Or New Years Eve celebrations, for that matter.

Better dial up the fireplace DVD in Maricopa County though, or else you're looking at a $50 to $250 fine if some bureaucrat in a truck spots the smoke from your chimney. The good news is that despite government's urging, citizens don't seem willing to turn in their neighbors for ignoring this nanny-state overreach—per the Arizona Republic (emphasis mine):

Last week's Christmas Eve no-burn advisory upset hundreds of people, who vented their anger on azcentral.com and in phone calls and e-mails to the county Air Quality Department. [...]

Even with warnings about the health risks of polluting the air, many people went ahead and burned Christmas Eve fires anyway. The 24-hour average for fine-particle pollution was 39.6 micrograms per cubic meter on Christmas Eve. The next day, the average spiked to 87.6 micrograms per cubic meter. [...]

Even with the smoke clearly visible in the air, the county did not receive one complaint from residents, who are encouraged to report violators.

Nanny Scrooge's response is typically tone-deaf:

"People would say, 'How dare you tell me not to burn on Christmas?' " said Holly Ward, a spokeswoman for the county agency.

"We don't do this based on what day of the week it is. It's based on meteorology and air-quality data. The air was really bad on Christmas Eve and Christmas Day, so we put restrictions in place to keep people from adding to pollution."

I hope it's not lost on Maricopa taxpayers that the whole reason for these spoilsport moves is that the Feds have threatened to withhold highway money from the County if it doesn't meet a D.C.-set standard of so many micrograms per cubic meter of some tiny particles between 7 to 28 times smaller than a human hair (PM10 and PM2.5, respectively). Given all of the other naturally-occuring airborne dusts out there that we have no hope of controlling, I, for one, feel much safer that our wise leaders in D.C. are on top of these two.

Cash 4 Clunkers: Now, for the Unintended Consequences

Posted on September 23, 2009, 2:12pm | Samuel Staley

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.

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

Posted on September 14, 2007, 7:36pm | Adrian Moore

As usual, Joel Schwartz cuts through the smog.

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

Posted on February 8, 2007, 9:38am | Ted Balaker

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

Posted on January 20, 2007, 4:43am | Adrian Moore

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.

Hollywood pollutes the most in LA?

Posted on November 13, 2006, 6:45am | Samuel Staley

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

Posted on November 1, 2006, 12:52pm | Ted Balaker

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

Psychology researchers performed a study with 16 subjects, each restricted to 5 hours of sleep at night. The subjects were split into 4 groups – no nap, 30-s nap, 90-s nap, and 10-min nap. Subjects that took naps for 90 seconds or less were not found to perform any better on alertness and cognitive tasks. However, subjects that took a 10 minute nap significantly improve performance in multiple post-nap tests. This seems to suggest that only stage 2 sleep helps you recuperate from lack of nocturnal sleep.

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

Posted on September 24, 2006, 12:56pm | Ted Balaker

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?

Posted on July 12, 2006, 3:45pm | Ted Balaker

One-quarter of the U.S. work force could be doing their jobs from home if all those able to telecommute chose to do so, according to a study on Wednesday which said many still elect to work at the office.

All those people working from home could translate into annual gasoline savings of $3.9 billion, according to the National Technology Readiness Survey.

The study found that 2 percent of U.S. workers telecommute full-time and another 9 percent do so part-time.
But another 14 percent of workers have the option of telecommuting, or have jobs conducive to the practice but choose not to, the study found.

The numbers suggest that many people would rather work at the office even if their job allowed telecommuting, said Professor P.K. Kannan, of the Robert H. Smith School of Business at the University of Maryland, which sponsored the study with Rockbridge Associates Inc., a Great Falls, Virginia research firm.

"That seems to suggest that even if employers were to say tomorrow that everybody had the option of telecommuting and you would save a lot of gas, that's not going to happen," Kannan said.

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?

Posted on July 5, 2006, 2:22pm | Ted Balaker

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

Posted on June 23, 2006, 7:59pm | Adrian Moore

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.