State of the Scare, Once Again

American Lung Association report distorts

The American Lung Association may be the only institution in the country that still gives out failing grades, but you have to hand it to them — they do it with gusto. “State of the Air 2004” continues ALA’s five-year tradition of inflating air pollution levels and health risks in a so-far successful effort to maintain an unwarranted climate of public fear. ALA and other activist groups’ tried-and-true strategy stands on three pillars: (1) exaggerate the frequency and extent of high air pollution, (2) take modest, rare, or nonexistent health risks and turn them into serious and pervasive ones, and (3) ignore positive trends and invent negative ones.

ALA’s web page asks, “are you one of the 159 million Americans breathing unhealthy air?” That’s a big number — more than half the population. There’s just one problem: in many counties, only a small area actually violates the standard. For example, in Los Angeles County, 60% of residents breathe air that passes the 8-hour ozone standard; 95% in Cook County (Chicago); and 99% in San Diego County. Nevertheless, both San Diego and Cook counties earned failing grades from ALA. Indeed, when you base the estimate on actual pollution levels, you find that 97 million people live in areas that violate EPA’s 8-hour ozone and/or fine particulate matter (PM2.5) standards. Still a big number (more on that below), but far less than ALA claims.

If you type in your Zip Code, ALA’s helpful web site will even tell you the amount of pollution in your area. But for anyone who lives in a county with more than one pollution monitor, the numbers the ALA gives you are virtually always false. We typed in our Zip Codes and checked ALA’s claim against the actual EPA data for where we live (Sacramento, CA and McLean, VA, respectively). Downtown Sacramento averaged two days per year exceeding the 8-hour ozone standard during 2000-2002, the years ALA used for its report (and one day during 2003). But ALA claimed 27.2 exceedances per year for downtown Sacramento. Likewise, McLean averaged 5.7 8-hour exceedances per year, but ALA claimed 17.7.

Is ALA just making the numbers up? Not quite, but they might as well be. Here’s how ALA pads the results: Most populous counties have more than one ozone monitor, because ozone varies from place to place. For example, in Sacramento County, if ozone exceeds the 8-hour standard one day in Folsom, and the next in Sloughouse, about 15 miles away, ALA counts two days for the entire county, even though nobody experienced more than one. Sacramento County has six ozone monitors, ranging from one to nineteen 8-hour ozone exceedances per year. But it doesn’t matter what Sacramento County Zip Code you type in — you’ll always get the same answer, and it will always be greater than the actual ozone levels. “State of the Air, 2004” also includes particulate matter for the first time and uses similar methods to inflate daily PM2.5 levels — so much so that although only 0.6% of monitoring locations violate EPA’s 24-hour PM2.5 standard, ALA somehow managed to squeeze 81 million Americans into that handful of locations.

So even if ALA inflates pollution levels and exaggerates the number of people living in non-attainment areas, 97 million is still a big number, right? It sure would be if that many people were being harmed by air pollution. But they’re not, because ALA inflates pollution’s health effects too. For example, while ALA claims exceeding 8-hour ozone standard puts most of the population in danger, EPA in 1997 concluded that going from full national attainment of the 1-hour ozone standard to full national attainment of the 8-hour standard would reduce hospital admissions for asthma attacks by 0.6%. Yet the 8-hour standard is much more stringent, with 4.5 times as many sites violating the 8-hour standard as the 1-hour.

And even a report sponsored by a coalition of environmental groups concluded that reducing all U.S. power plant emissions by 75% would reduce respiratory and cardiovascular emergencies by 0.2% to 0.6%.[1] Big pollution reductions, tiny health benefits.[2] And while activists blame air pollution for the doubling of asthma during the last two decades, Figure 1, below, should test the intestinal fortitude of even the most diehard pollution apparatchik. The figure presents national-average trends in air pollution from EPA monitoring data, and the trend in asthma prevalence from the Centers for Disease Control.[3]

Figure 1. Declining Air Pollution, Rising Asthma

Ozone: exceedance days per year
PM: micrograms per cubic meter
CO, NO2, SO2: parts per million
Asthma: rate per thousand population

But isn’t any improvement in health, even a fraction of a percent, worth it? It would be if air pollution were the only risk we faced and the pollution reductions were free. In the real world we face many risks and have many aspirations, but have limited resources. In the real world, consumers ultimately pay regulatory costs through higher prices for useful goods and services. More money for pollution control means less money for everything else — health care, housing, food, leisure, education, as well as other bigger health and safety risks. A regulation will do net good only if it confers benefits greater than the harm from its income-reducing costs.

The public’s interest is in an accurate portrayal of risk. This is the only way to make informed choices on air pollution reductions versus other public and private priorities. With the health benefits exaggerated and the costs safely hidden from view, the result has been unnecessarily stringent standards and overinvestment in pollution control. Even the EPA, under President Clinton no less, implicitly reached this conclusion for ozone at least, when it concluded that the social costs of attaining the 8-hour ozone standard would be twice as great as the health benefits achieved (and outside economists believe EPA underestimated the costs of attaining the standard by at least an order of magnitude).

As if the ALA’s bleak picture wasn’t bad enough already, “State of the Air’s” closing section begins “the Clean Air Act is seriously at risk.” ALA’s focus here is on New Source Review (NSR), which requires new and modified industrial facilities to install technology to meet the “lowest achievable emission rate.” Activists, as well as several states’ attorneys general and newspaper columnists, continue to claim that the Bush Administration’s relaxation of some key NSR provisions amounts to “gutting” the Clean Air Act and will cause millions of tons more pollution emissions each year.

It’s not clear how this could happen, because several other pollution reduction requirements remain in force and will eliminate most remaining industrial and vehicle pollution in coming years. Table 1 lists some of the major ones. While “State of the Air” claims power plant pollution will increase, in the real world, EPA’s NOx “SIP Call” regulation — unmentioned by ALA — will reduce NOx from coal-fired power plants and industrial boilers by 60% just days from now.

Table 1. According to ALA “the Clean Air Act is seriously at risk.” You be the judge. Here are EPA’s actual regulatory requirements. None of the industry requirements is affected by any changes to New Source Review.[4]

Regulation Requirement Effective Date
Clean Air Act Title IV SO2 program Phase 1 already reduced SO2 emissions from coal-fired power plants by 30% between 1995 and 2000. Phase 2 requires an additional 20% reduction between 2000 and 2010. Phase 1, 1995
Phase 2, 2000
Clean Air Act Title IV NOx program 26% reduction in NOx emissions from coal-fired power plants between 1997 and 2002. 1997
NOx “SIP Call” 60% reduction in NOx emissions from coal-fired power plants and industrial boilers during May-September “ozone season.” May 2004
Clean Air Act Title III Standards for Hazardous Air Pollutants “HAPs” More than 70 industry- or process-specific rules already promulgated. All rules require “maximum achievable control technology” (MACT). Reductions are typically 60%-99% for a wide range of substances, including heavy metals, organic chemicals, and particulates. Various dates from 1994 through the next few years
“Tier 2” automobile emission standards Decreases allowable NOx and VOC emissions by 70%-80% below “Tier 1” requirement. Extends emissions warranty requirement from 100,000 to 120,000 miles. Requires same low emissions from SUVs and pickups as for cars. 2004 model year and beyond
Heavy-duty diesel truck NOx and smoke standards 90% reduction in NOx and soot below already-implemented 2003 truck standards. 97% reduction in sulfur content of on-road diesel fuel. 2007 model year and beyond
“Tier 4” off-road diesel NOx and smoke standards (proposed rule) 90% reduction in NOx and soot below already-promulgated “Tier 1” through “Tier 3” standards. 97% reduction in sulfur content of off-road diesel fuel. 2010 model year and beyond

Perhaps the greatest failing in the sorry history of “State of the Air” and similar nonsense is not that activist organizations like ALA tell fibs about air pollution, but that journalists don’t call them on it. Of course, the two go hand in hand. If the press stopped giving activists a free ride, they might clean up their act, lest they lose public credibility.

But it’s even worse than that. With few exceptions, the press routinely aids and abets activists’ efforts to make it seem that we’ve made little progress on air pollution and that the situation is only getting worse. Figure 2 compares typical activist and press quotes on air pollution with actual pollution monitoring data. Although this is the 5th installment of “State of the Air,” the Washington Post apparently still hasn’t passed the report along to its fact-checking department.

Figure 2. National trend in average number of days per year exceeding the 1-hour ozone standard for all sites that happened to be operating in a given year, and for all sites with continuous data from 1983 to 2003

Fortunately, air pollution affects far fewer people, far less often, and with far less severity than activists or regulators would have us believe. Now that’s a story worth telling.

Joel Schwartz is an adjunct fellow at Reason Foundation and visiting scholar at American Enterprise Institute.

Steven Hayward is resident fellow at American Enterprise Institute.


[1] Abt Associates, The Particulate-Related Health Benefits of Reducing Power Plant Emissions, Prepared for the Clean Air Task Force, Bethesda, Maryland, 2000.

[2] The most serious health claim is that particulate matter at current levels kills tens of thousands of Americans each year. For an in-depth analysis showing why this is implausible see J. Schwartz, Particulate Air Pollution: Weighing the Risks (Competitive Enterprise Institute, April 2003).

[3] CDC changed its survey methods after 1996, so more recent data are not comparable.

[4] For references on these pollution reductions, please refer to “New Source of Confusion.”