The Implementation of the New National Ambient Air Quality Standards (NAAQS) for Ozone and Fine Particles (Panel 2)

Apr 24, 1997 | Alan J. Krupnick
Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety, Committee on Environment and Public Works, U.S. Senate


EPA's tighter national ambient air quality standards (NAAQS) will be "incredibly expensive" to implement, Senior Fellow Alan Krupnick told Congress in April 1997. The expense will be high, he added, even though EPA Administrator Carol Browner has "clearly endorsed cost-effectiveness as a major criterion" for developing an implementation strategy to further reduce ozone and fine particles in the air. Krupnick has spent years studying issues associated with the Clean Air Act and the design of environmental policies. Currently, he co-chairs the committee that he said. Browner hopes will develop ideas for reducing the costs of meeting the new standards. That committee -- the Federal Advisory Committee Act (FACA) Subcommittee for Ozone, Particulate Matter, and Regional Haze Implementation Programs -- will continue to meet through 1997. Its goal is to provide EPA with input and, if possible, consensus recommendations on developing a pollution control strategy scheduled for proposal next June. Specifically, the FACA subcommittee is assessing ways to achieve cost-effective emissions reductions that allow NAAQS attainment and reductions in regional haze.But the group, whose members include industry and environmental advocates, "cannot work miracles," Krupnick warned. The former want cost reductions, the latter greater certainty of standard attainment. Meanwhile, the states want greater autonomy from EPA. Even if consensus is reached, there is no guarantee that the recommendations will be as cost-effective as they might be, Krupnick added. The negotiation process will demand some trading off of cost savings for certainty. And EPA may choose to ignore what the FACA subcommittee recommends; it is only an advisory body."EPA may come up with what it considers better ideas, or it may find that some suggestions run afoul of the Clean Air Act," such as implementing a regional system of caps on the amount of nitrogen dioxide industry is allowed to emit and of trade among firms of their allowances. Indeed EPA is "severely limited by the Clean Air Act in its ability to implement new ideas," Krupnick said.Urging Congress to ease the act's constriction, Krupnick outlined measures that he believes offer some promise of reducing implementation costs below what they otherwise would be. He cautioned, however, that his recommendations were no indicator of what the FACA subcommittee might recommend.Based on ideas that his group has been discussing to help cut implementation costs, Krupnick suggested a regional cap and trade program for nitrogen oxide emissions, and regional air management partnerships to address the long-range transport of both ozone and fine particulate matter. He also suggested that emissions reduction progress should be tied to the location, type, and concentration of pollutants, rather than assume that all tons of emissions are equally detrimental, and that states should receive credit now for programs that will reduce emissions in the future. New sources of emissions that participate in a cap and trade system and wish to locate in areas not in attainment with air quality standards should be permitted to trade emission allowances in exchange for meeting abatement technology requirements.To allay fears of prohibitive costs, a ceiling could be placed on what a firm has to pay per ton of emissions. A "Clean Air Fund" could be established to cover the costs of reducing pollution outside of the state implementation plan process. In lieu of abatement, polluters might have the option of paying into the fund the ceiling price per ton of emissions. Greater emphasis should be placed on real-time monitoring of mobile (vehicular) emissions through new technologies, such as remote and on-board sensing. As for area sources, focus should be placed on controlling "episodic" noncompliance with air quality standards.Krupnick offered his opinions on implementing the revisions to the NAAQS before the U.S. Senate's Committee on Environment and Public Works, Subcommittee on Clean Air, Wetlands, Private Property, and Nuclear Safety. In a separate panel before the same subcommittee, he testified on the merits of the revisions themselves.