Testimony and Public Comments

Performance of the Clean Air Act and its Amendments

May 1, 2002 | Alan J. Krupnick
Subcommittee on Energy and Air Quality, Committee on Energy and Commerce, U.S. House of Representatives


Whether viewed through the lens of cost-benefit analysis or through comparing emissions and air quality trends to trends in economic activity, the Clean Air Act and its Amendments appears to have successfully delivered net benefits to the American people, although there are significant uncertainties surrounding the cost and benefit estimates in the U.S. Environmental Protection Agency's retrospective and prospective studies of the Clean Air Act and its Amendments. In addition, because these studies did not disaggregate the benefits by pollutant, sector, or subsection of the Act, it is difficult to tell which parts are performing well and which are not.<BR><BR>From other analyses, it appears that federal measures for mobile source controls and the sulfur dioxide (SO2) allowance trading program for electric utilities are particular bright spots, albeit ones that can be made brighter. Viewed pollutant by pollutant, reductions in particulate emissions and SO2 as a fine particulate precursor appear to be particularly beneficial on net.<BR><BR>Less effective segments of the act and its amendments include: the SIP process, which is not well suited to address issues of long-range pollution transport; inspection and maintenance programs, which poorly target the older and dirtiest vehicles; and New Source Review, which has led to much litigation and is redundant to a cap-and-trade system. In light of the apparent lack of a concentration threshold for the criteria pollutants, the criteria by which the National Ambient Air Quality Standards are to be set remains too vague, in spite of the recent Supreme Court ruling against use of cost-benefit analysis.