Facts Not Fear on Air Pollution

Studies | Environment

No. 294
Monday, December 11, 2006
by Joel Schwartz


Notes

  1. Here are the sources for all trend data discussed in this section: Trends for CO, NO2, SO2, PM10 and lead were downloaded from EPA at http://www.epa.gov/airtrends/ on October 8, 2006.  The trend for PM2.5 is based on a comparison of PM2.5 measurements collected in 87 metropolitan areas from 1979 to 1984 by the Inhalable Particulate Monitoring Network (IPMN), an EPA special-study network, with data in the same locations collected from 2000 to 2005.  Recent national PM2.5 data were downloaded from EPA at http://www.epa.gov/air/data/index.html. IPMN data were retrieved from David Hinton et al., "Inhalable Particulate Network Report: Operation and Data Summary (Mass Concentrations Only), Vol. I, April 1979-December 1982," Environmental Protection Agency, 1984; David Hinton et al., "Inhalable Particulate Network Report: Data Summary (Mass Concentrations only), Vol. III, January 1983-December 1984," Environmental Protection Agency, 1986. 
  2. Based on monitoring data from all continuously operated monitoring sites in the Clean Air Status and Trends Network (CASTNET) downloaded from EPA at http://www.epa.gov/castnet.  Also see "Acid Rain Program: 2005 Progress Report," Environmental Protection Agency, October 2006; available at http://www.epa.gov/airmarkets/cmprpt/arp05/2005report.pdf. 
  3. Compliance with federal air pollution standards is on site-by-site national monitoring data downloaded from EPA's AIRData database, EPA at http://www.epa.gov/air/data/index.html. For detailed charts showing ambient air pollution trends through 2003, see Joel Schwartz and Steven Hayward, "Air Quality in America: A Dose of Reality on Air Pollution Levels, Trends and Health Risks," American Enterprise Institute, April 28, 2004; available at http://www.aei.org/docLib/200404301_schwartzhayward.pdf. 
  4. The 8-hour standard did not exist back in 1980. But since we have national ozone monitoring data for 1980 we can go back retrospectively and calculate what the violation rate would have been had the current 8-hour standard existed back then.
  5. This is based on the annual standard of 15 millionths of a gram per cubic meter (µg/m3) and the 24-hour standard of 65 µg/m3.  EPA recently lowered the 24-hour standard to 35 µg/m3, which will increase the fraction of monitoring sites violating the standard to about 27 percent. It is likely that nearly the entire nation would have violated this standard back in the early 1980s. 
  6. Alan Gertler et al., "Measurements of Mobile Source Particulate Emissions in a Highway Tunnel," International Journal of Vehicle Design, Vol. 27, No. 1-4, 2002, pages 86-93; Thomas Kirchstetter et al., "Characterization of Particle and Gas Phase Pollutant Emissions from Heavy- and Light-Duty Vehicles in a California Roadway Tunnel," American Geophysical Union Fall Meeting, San Francisco, Calif., December 13-17, 2004. 
  7. Thomas Kirchstetter et al., "Characterization of Particle and Gas Phase Pollutant Emissions from Heavy- and Light-Duty Vehicles in a California Roadway Tunnel," American Geophysical Union Fall Meeting, San Francisco, Calif., December 13-17, 2004. 
  8. A. J. Kean, R. F. Sawyer, R. A. Harley et al., Trends in Exhaust Emissions from In-Use California Light-Duty Vehicles, 1994-2001 (Warrendale, Penn.: Society of Automotive Engineers, 2002); S. S. Pokharel, G. A. Bishop, D. H. Stedman et al., "Emissions Reductions as a Result of Automobile Improvement," Environmental Science and Technology, Vol. 37, No. 22,  2003, pages 5,097-101; Joel Schwartz, No Way Back: Why Air Pollution Will Continue to Decline (Washington, D.C.: American Enterprise Institute, July 2003), available at http://www.aei.org/docLib/20030804_4.pdf.
  9. D. Bearden, Air Quality and Vehicle Emission Standards: An Overview of the National Low Emission Vehicle Program and Related Issues (Washington, D.C.: Congressional Research Service, January 4, 1999), available at http://www.ncseonline.org/nle/crsreports/air/air-23a.cfm; J. G. Calvert, J. B. Heywood, R. F. Sawyer et al., "Achieving Acceptable Air Quality:  Some Reflections on Controlling Vehicle Emissions," Science, Vol.  261, No. 5117, July 2, 1993: pages 37-45; S. C. Davis and S. W. Siegel, Transportation Energy Data Book: Edition 22 (Oak Ridge, Tenn.: Oak Ridge National Laboratory, September 2002), available at http://www-cta.ornl.gov/cta/data/Download22.html; Environmental Protection Agency, Federal and California Exhaust and Evaporative Emission Standards for Light-Duty Vehicles and Light-Duty Trucks (Washington, DC: February 2000), available at http://www.epa.gov/otaq/cert/veh-cert/b00001.pdf.
  10. Joel Schwartz, No Way Back.
  11. "Health Assessment Document for Diesel Engine Exhaust," Environmental Protection Agency, May 2002; "Final Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines," Environmental Protection Agency, May 2004; available at http://www.epa.gov/nonroad-diesel/2004fr/420r04007.pdf.
  12. "Regulatory Announcement: Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements," Environmental Protection Agency, December 2000; available at http://www.epa.gov/otaq/highway-diesel/regs/f00057.pdf.
  13. "Final Regulatory Impact Analysis: Control of Emissions from Nonroad Diesel Engines," Environmental Protection Agency, May 2004. 
  14. The "ozone season" means May through September.  Ozone formation requires sunlight, and ozone levels are highest during the summer and very low during the winter.  Thus, NOx reductions to reduce ozone are focused on the warmer months.  See "Charts and Tables for Final Clean Air Interstate Rule," Environmental Protection Agency, March 2005; available at http://www.epa.gov/cair/charts.html.
  15. Ibid.
  16. For the industrial emission reduction requirements, see EPA's Air Toxics Web site at http://www.epa.gov/ttn/atw/mactfnlalph.html.
  17. "Survey of Air Pollution Perceptions: Final Report," Foundation for Clear Air Progress, January 2002; available at http://www.cleanairprogress.org/news/quorum_res_01_14_02.asp; "Clean Air National Survey Results," Foundation for Clean Air Progress, August 2004; available at http://www.cleanairprogress.org/news/quorum_res_01_14_02.asp; Jonathan Rauch, "America Celebrates Earth Day 1970 - for the 31st Time," National Journal, Vol. 32, No. 4, April 2000; "The Nation's Worries," Washington Post Poll, November 1999. 
  18. "Clearing the Air with Transit Spending," Sierra Club, November 2001. 
  19. "Darkening Skies: Trends toward Increasing Power Plant Emissions," Public Interest Research Group, April 2002.
  20. D'Vera Cohn, "Particles as Well as Ozone Foul Region's Air; Lung Association Report Ranks Areas among Worst in U.S.," Washington Post, April 29, 2004.
  21. Traci Watson, "Smoggy Skies Persist Despite Decade of Work," USA Today, October 16, 2003.
  22. The standard was adopted in September 2006.  The proposed 24-hour PM2.5 standard had been reduced from 65 /m3 to 35 /m3.  "Stronger Standards for Particles Proposed," Environmental Protection Agency, Press Release, December 21, 2005; available at http://yosemite.epa.gov/opa/admpress.nsf/4d84d5d9a719de8c85257018005467c2/1e5d3c6f081ac7ea852570de0050ae2b!OpenDocument.  
  23. "EPA Proposes ‘Status Quo' Revisions to PM NAAQS," American Lung Association, December 21, 2005. Available at http://www.cleanairstandards.org/article/2005/12/406.
  24. "President Bush Gives Early Christmas Present to Smokestack Industries," Clean Air Watch, December 20, 2005; available at http://cleanairwatchpressroom.blogspot.com/2005/12/president-bush-gives-early-christmas.html. 
  25. Jeff Nesmith, "EPA Barely Budges on Soot; Health Advice Disregarded," Atlanta Journal-Constitution, December 21, 2005. 
  26. Frank O'Donnell, "Smog Problems Nearly Double in 2005," Clean Air Watch, November 10, 2005.  Available at http://cleanairwatchpressroom.blogspot.com/2005/11/smog-problems-nearly-double-in-2005.html.
  27. "Number of Ozone Action Days Up from Last Year," Pennsylvania Department of Environmental Protection, September 28, 2005; available at http://www.ahs.dep.state.pa.us/newsreleases/default.asp?ID=3643&varQueryType=Detail.
  28. "New England Experienced More Smog Days during Recent Summer," Environmental Protection Agency, September 26, 2006; available at http://www.epa.gov/region1/pr/2005/sep/dd050917.html.
  29. Jeff Holtz, "A Hot Summer Meant More Smog," New York Times, October 2, 2005.
  30. For a detailed account, see Joel Schwartz, "Air Quality: Much Worse on Paper Than in Reality," American Enterprise Institute, Environmental Policy Outlook, May-June 2005; available at http://www.aei.org/docLib/20050602_EPOMay_Junenewg%282%29.pdf.
  31. Ibid.
  32. "Poor Air Quality in the State Threatens Health of a Third of Residents," Associated Press, May 1, 2001; "Report: Poor Air Quality Threatens Health of One in Three States," Associated Press, May 1, 2001; "Report: New Jersey's Air among the Dirtiest in the Nation," Associated Press, May 1, 2001; "Eleven Southern Cities among Nation's Most Polluted," Associated Press, May 1, 2001; and "News in Brief from the San Joaquin Valley," Associated Press, May 1, 2001.
  33. Comparison of IPMN data collected from 1979 to 1983 with data collected since 1999. California Air Resources Board, iADAM Air Quality Data Statistics, http://www.arb.ca.gov/adam/welcome.html;   California Air Resources Board, Air Pollution Data CD, http://www.arb.ca.gov/aqd/aqdcd/aqdcd.htm; David Hinton et al., "Inhalable Particulate Network Report: Operation and Data Summary (Mass Concentrations Only) Volume I, April 1979-December 1982," Environmental Protection Agency, November 1984; David Hinton et al., "Inhalable Particulate Network Report: Data Summary (Mass Concentrations Only), Volume III, January 1983-December 1984," Environmental Protection Agency, April 1986.
  34. Asthma prevalence trends are estimated from the Centers for Disease Control's (CDC) annual National Health Interview Survey (NHIS).  The CDC changed its asthma survey questions in 1997, preventing comparison with data collected up to 1996.  Between 1997 and 2000, the CDC stopped asking people whether they currently had asthma.  However, in 1997 CDC began asking people who had ever been diagnosed with asthma whether they had had an attack in the past 12 months.  In 2001, CDC began once again to ask people whether they currently had asthma, but with a slightly different question than pre-1997 surveys.  Based on these data, the prevalence of asthma attacks leveled off from 1997-2003, while the prevalence of asthma declined from 2001 to 2003.  "Trends in Asthma Morbidity and Mortality," American Lung Association, May 2005; available at http://www.lungusa.org/atf/cf/%7B7A8D42C2-FCCA-4604-8ADE-7F5D5E762256%7D/ASTHMA1.PDF; David Mannino et al., "Surveillance for Asthma - United States, 1980-1999," Morbidity and Mortality Weekly Report, Vol. 51, Surveillance Summary No. 1, March 2002, pages 1-13. 
  35. See, for example, Waltraud Eder, Markus J. Ege and Erika von Mutius, "Current Concepts: The Asthma Epidemic," New England Journal of Medicine, Vol. 355, No. 21, November 23, 2006, pages 2,226-35. 
  36. For data on asthma emergency room visits and hospitalizations by month, see, for example, "Asthma in Spokane County," Spokane Regional Health District, April 2002; available at www.srhd.org/downloads/info_pubs/factsheets/Asthma2006FactSheet.pdf; Jamila Stockman et al., "California County Asthma Hospitalization Chart Book, Data from 1998-2000," California Department of Health Services, September 2003; available at http://www.ehib.org/cma/papers/Hosp_Cht_Book_2003.pdf; "Asthma Prevalence, Hospitalizations and Mortality - Texas, 1999-2001," Texas Department of Health, November 21, 2003; available at http://www.tdh.state.tx.us/cphpr/asthma/asthma.pdf; Kathy Tippy and Nancy Sonnenfeld, "Asthma Status Report: Maine 2002," Maine Bureau of Health, November 25, 2002; Kenneth Wilcox and Joanne Hogan, "An Analysis of Childhood Asthma Hospitalizations and Deaths in Michigan, 1989-1993," Michigan Department of Community Health, undated; available at http://www.michigan.gov/documents/Childhood_Asthma_6549_7.pdf.
  37. "Worldwide Variation in Prevalence of Symptoms of Asthma, Allergic Rhinoconjunctivitis, and Atopic Eczema: The International Study of Asthma and Allergies in Childhood (ISAAC)," Lancet, Vol. 351, No. 9111, April 25, 1998, pages 1,225-32. 
  38. Joachim Heinrich et al., "Trends in Prevalence of Atopic Diseases and Allergic Sensitization in Children in Eastern Germany," European Respiratory Journal, Vol. 19, 2002, pages 1,040-46; Joachim Heinrich et al., "Is the Prevalence of Atopic Diseases in East and West Germany Already Converging?" European Journal of Epidemiology, Vol. 14, No. 3, April 1998, pages 239-45. 
  39. James Gauderman et al., "The Effect of Air Pollution on Lung Development from 10 to 18 Years of Age," New England Journal of Medicine, Vol. 351, No. 11, 2004, pages 1,057-67.
  40. This is despite the fact that the 12 communities in the study ranged from zero to more than 120 8-hour ozone exceedance days per year, and zero to more than 70 1-hour ozone exceedance days per year during the study period.  The CHS study set up special-purpose monitors to measure pollution levels in the communities where the study was performed. CARB staff provided the data from these monitors. 
  41. Unfortunately, this has not stopped environmental groups from claiming otherwise. For example, in "Impacts of Ozone on Our Health," the Carolinas Clean Air Coalition claims, "Children have a 10 percent decrease in lung function growth when they grow up in more polluted air." See "Impacts of Ozone on Our Health," Carolinas Clean Air Coalition, undated; available at http://003af56.netsolhost.com/Air%20Basics/ozone_impact.htm. 
  42. As measured by the volume of air a person can blow out in the first second of an exhalation after a full breath when blowing as hard as he or she can, and based on the total volume of air a person can blow out during an entire exhalation when blowing as hard as he or she can. These are standard measures in lung-function tests.
  43. Alicia Di Rado, "Smog May Cause Lifelong Lung Deficits," USC Today, September 8, 2004; available at http://www.usc.edu/uscnews/stories/10495.html.
  44. This analysis assumes that there are no health benefits from additional ozone reductions once the standard is achieved. If benefits continue to accrue as pollution drops below the level of the standard, then total benefits would be as much as five times greater than the values in the text. Bryan Hubbell et al., "Health-Related Benefits of Attaining the 8-Hr Ozone Standard," Environmental Health Perspectives, Vol. 113, 2005, pages 73-82; Joel Schwartz, "Rethinking the California Air Resources Board's Ozone Standards," American Enterprise Institute, Working Paper No. 116, September 12, 2005; available at http://www.aei.org/doclib/20050912_Schwartzwhitepaper.pdf. 
  45. "Review of the California Ambient Air Quality Standard for Ozone," California Air Resources Board, March 2005; available at http://www.arb.ca.gov/research/aaqs/ozone-rs/ozone-final/ozone-final.htm. 
  46. Once again, the benefits would be as much as five times greater if they continue to accrue as pollution continues to drop below the level of the standard. Joel Schwartz, "Rethinking the California Air Resources Board's Ozone Standards," American Enterprise Institute, Working Paper No. 116, September 12, 2005.
  47. Abt Associates Inc., "The Particulate-Related Health Benefits of Reducing Power Plant Emissions," Clean Air Task Force, October 2000; available at http://cta.policy.net/fact/mortality/mortalityabt.pdf. 
  48. "Latest Findings on National Air Quality, 2002 Status and Trends," Environmental Protection Agency, EPA Publication No. 454/K-03-001, September 2003; available at http://www.epa.gov/air/airtrends/aqtrnd02/2002_airtrends_final.pdf.
  49. "Review of the California Ambient Air Quality Standard for Ozone," California Air Resources Board, March 2005; Bryan Hubbell et al., "Health-Related Benefits of Attaining the 8-Hr Ozone Standard," Environmental Health Perspectives, Vol. 113, 2005, pages 73-82; Joel Schwartz, "Rethinking the California Air Resources Board's Ozone Standards," American Enterprise Institute, Working Paper No. 116, September 12, 2005. 
  50. "Breath-Taking: Premature Mortality Due to Particulate Air Pollution in 239 American Cities," National Resources Defense Council, May 1996; available at http://www.nrdc.org/air/pollution/bt/btinx.asp; Richard Wilson and John Spengler, Particles in Our Air: Concentrations and Health Effects (Cambridge, Mass.: Harvard University Press, 1996); Michelle Bell, Francesca Dominici and John Samet, "A Meta-Analysis of Time-Series Studies of Ozone and Mortality with Comparison to the National Morbidity, Mortality, and Air Pollution Study," Epidemiology, Vol. 16, No. 4, 2005, pages 436-45. 
  51. The Roman statesman Seneca bemoaned "the stink, soot, and heavy air" of Rome in A.D. 61. London suffered from air pollution at least as far back as the Middle Ages, when coal became a common fuel in smithies and lime burners.  The problem was bad enough that King Edward I in 1285 created a commission to improve the city's air quality. See, for example, George Miller, Living in the Environment (Pacific Grove, Calif.: Brooks/Cole, 2000); and cited in Bjorn Lomborg, The Skeptical Environmentalist (New York: Cambridge University Press, 2001). 
  52. Laura Green and Sarah Armstrong, "Particulate Matter in Ambient Air and Mortality: Toxicologic Perspectives," Regulatory Toxicology and Pharmacology, Vol. 38, No. 3, December 2003, pages 326-35. 
  53. Henry Gong, Jr., Constantinos Sioutas and William S. Linn, "Controlled Exposures of Healthy and Asthmatic Volunteers to Concentrated Ambient Particles in Metropolitan Los Angeles," Health Effects Institute, Research Report No. 118, 2003, pages 1-36; discussion 37-47. 
  54. The study exposed people to a PM2.5 level of 200 µg/m3. Even in the most polluted areas of the United States, it would be rare for PM2.5 to exceed even half this level. 
  55. The diesel soot concentration was 100 µg/m3; again, this is much higher than would occur in the real-world. Stephen Holgate et al., "Health Effects of Acute Exposure to Air Pollution, Part I: Healthy and Asthmatic Subjects Exposed to Diesel Exhaust," Health Effects Institute, Research Report No. 112, 2003.  
  56. Stephen K. Van Den Eeden et al., "Particulate Air Pollution and Morbidity in the California Central Valley: A High Particulate Pollution Region," California Air Resources Board, July 12, 2002; available at http://www.arb.ca.gov/research/apr/past/97-303.pdf.
  57. "Hospitalizations and Emergency Room Visits Increase Following High Particulate Matter Episodes, Study Finds," California Air Resources Board, February 24, 2003; available at http://www.arb.ca.gov/newsrel/nr022403.htm.
  58. "Air Quality Criteria for Ozone and Related Photochemical Oxidants (Second External Review Draft) Volumes I-III," Environmental Protection Agency, August 2005; available at http://www.epa.gov/ttn/naaqs/standards/ozone/s_o3_cr_cd.html.
  59. "Stronger Relationship between Particulate Matter (PM) and Premature Death," California Air Resources Board, March 23, 2006; available at ftp://ftp.arb.ca.gov/carbis/board/books/2006/032306/06-3-1pres.pdf. This presentation was based on the results of Michael Jerrett et al., "Spatial Analysis of Air Pollution and Mortality in Los Angeles," Epidemiology, Vol. 16, No. 6, 2005, pages 727-36. 
  60. James Enstrom, "Fine Particulate Air Pollution and Total Mortality among Elderly Californians, 1973-2002," Inhalation Toxicology, Vol. 17, No. 14, December 2005, pages 803-16. 
  61. Frank Gilliland et al., "The Effects of Ambient Air Pollution on School Absenteeism Due to Respiratory Illnesses," Epidemiology, Vol. 12, No. 1, 2001, pages 43-54. 
  62. Kiros Berhane and Duncan Thomas, "A Two-Stage Model for Multiple Time Series Data of Counts," Biostatistics, Vol. 3, No. 1, 2002, pages 21-32; Virginie Rondeau, Kiros Berhane and Duncan 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, Vol. 24, 2005, pages 1,103-15. 
  63. "Review of the California Ambient Air Quality Standard for Ozone," California Air Resources Board, May 17, 2006; Joel Schwartz, "Rethinking the California Air Resources Board's Ozone Standards," American Enterprise Institute, Working Paper No. 116, September 12, 2005. 
  64. American Lung Association, Medical Journal Watch, available at http://www.cleanairstandards.org/category/medical-journal-watch/. 
  65. For example, the site does not include any studies by Fred Lipfert, Suresh Moolgavkar, Richard Smith, Gary Koop, William Keatinge, Laura Green or James Enstrom - all of whom have provided evidence against a connection between low-level air pollution and risk of premature death.  Based on a search of the Medical Journal Watch Web site on April 6, 2006. 
  66. Francesca Dominici et al., "Revised Analyses of the National Morbidity, Mortality, and Air Pollution Study, Part II," Health Effects Institute, Special Report, 2003. 
  67. William Keatinge and Gavin Donaldson, "Heat Acclimatization and Sunshine Cause False Indications of Mortality Due to Ozone," Environmental Research, Vol. 100, 2006, pages 387-93. 
  68. 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, Vol. 75, No. 12, December 2000, pages 1284-88; Alison Thornton and Peter Lee, "Publication Bias in Meta-Analysis: Its Causes and Consequences," Journal of Clinical Epidemiology, Vol. 53, No. 2, 2000, pages 207-16. 
  69. Sharon Begley, "New Journals Bet ‘Negative Results' Save Time, Money," Wall Street Journal, September 15, 2006, page B1. 
  70. John P. A. Ioannidis, "Why Most Published Research Findings Are False," PLoS Medicine, Vol. 2, No. 8, August 2005, page e124; William Keatinge and Gavin Donaldson, "Heat Acclimatization and Sunshine Cause False Indications of Mortality Due to Ozone," Environmental Research, Vol. 100, 2006, pages 387-93; Gary Koop and Lisa 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, Vol. 47, No. 1, January 2004, pages 30-54; Thomas Lumley and Lianne Sheppard, "Time Series Analyses of Air Pollution and Health: Straining at Gnats and Swallowing Camels?" Epidemiology, Vol. 14, No. 1, January 2003, pages 13-14; Suresh Moolgavkar, "A Review and Critique of the EPA's Rationale for a Fine Particle Standard" Regulatory Toxicology and Pharmacology, Vol. 42, 2005, pages 123-44; George Smith, "Reflections on the Limitations to Epidemiology," Journal of Clinical Epidemiology, Vol. 54, No. 4, pages 325-31; Gary Taubes, "Epidemiology Faces Its Limits," Science, Vol. 269, No. 5221, July 1995, pages 164-69. 
  71. Daniel Krewski et al., "Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality," Health Effects Institute, Special Report, July 2000; Arden Pope et al., "Lung Cancer, Cardiopulmonary Mortality, and Long-Term Exposure to Fine Particulate Air Pollution," Journal of the American Medical Association, Vol. 287, No. 9, March 6, 2002. 
  72. Daniel Krewski et al., "Reanalysis of the Harvard Six Cities Study and the American Cancer Society Study of Particulate Air Pollution and Mortality," Health Effects Institute, Special Report, July 2000. 
  73. Cliff Davidson, "Air Pollution in Pittsburgh: A Historical Perspective," Journal of the Air Pollution Control Association, Vol.  29, 1979, pages 1,035-41. 
  74. John Ludwig et al., "Trends in Urban Air Quality," Eos, Transactions American Geophysical Union, Vol. 51, No. 5, 1970, pages 468-75. 
  75. Ibid. 
  76. Hugh Ellsaesser, "Trends in Air Pollution in the United States," in The State of Humanity, Julian Simon, ed. (Malden, Mass.: Blackwell, 1995), pages 491-502. 
  77. "Statistical Abstract of the United States," Bureau of the Census, 1981; "Environmental Quality," Council on Environmental Quality, 1971; "National Air Quality and Emission Trends Report, 1976," Environmental Protection Agency, 1977; H. Schimmel and T. J. Murawski, "SO2 - Harmful Air Pollutant or Air Quality Indicator?" Journal of the Air Pollution Control Association, Vol.  25, 1975, pages 739-40. 
  78. See, for example, Jonathan H. Adler, "Fables of the Cuyahoga: Reconstructing a History of Environmental Protection," Fordham Environmental Law Journal, Vol. 14, 2002, pages 89-146. 
  79. Susan E. Dudley, "National Ambient Air Quality Standard for Ozone," Mercatus Center at George Mason University, March 12, 1997; available at http://www.mercatus.org/repository/docLib/20060830_MR_RSP_PIC_EPA_NAAQS_Dudley_March_12_1997.pdf; Stephen Huebner and Kenneth Chilton, "EPA's Case for New Ozone and Particulate Standards: Would Americans Get Their Money's Worth?" Center for the Study of American Business, Washington University, Policy Study No. 139, June 1997; available at http://csab.wustl.edu/csab/CSAB%20pubs-pdf%20files/Policy%20Studies/PS139%20Huebner-Chilton.pdf; Randall Lutter, "Is EPA's Ozone Standard Feasible?" AEI-Brookings Joint Center for Regulatory Studies, Regulatory Analysis No. 99-6, December 1999; available at http://www.aei-brookings.org/admin/authorpdfs/page.php?id=93. 
  80. Ann P. Bartel and Lacy G. Thomas, "Predation through Regulation: The Wage and Profit Effects of the Occupational Safety and Health Administration and the Environmental Protection Agency," Journal of Law and Economics, Vol. 30, No. 2, 1987, pages 239-64; David Schoenbrod, "Protecting the Environment in the Spirit of the Common Law," in The Common Law and the Environment: Rethinking the Statutory Basis for Modern Environmental Law, Roger E. Meiners and Andrew P. Morriss, eds. (Lanham, Md.: Rowman & Littlefield, 2000); Aaron Wildavsky, Searching for Safety (New Brunswick, N.J.: Transaction Publishers, 1988). The costs of environmental regulations are also regressive, falling more heavily on the poorest. See Frank B. Cross, "When Environmental Regulations Kill: The Role of Health/Health Analysis," Ecology Law Quarterly, Vol. 22, No. 4, 1995, pages 729-84; H. David Robinson, "Who Pays for Industrial Pollution Abatement?" Review of Economics and Statistics, Vol. 67, No. 4, November 1985, pages 702-06. 
  81. Randall Lutter, John F. Morrall, III, and W. Kip Viscusi, "The Cost-Per-Life-Saved Cutoff for Safety-Enhancing Regulations," Economic Inquiry, Vol. 37, No. 4, 1999, pages 599-608; W. Kip Viscusi, "The Value of Risks to Life and Health," Journal of Economic Literature, Vol. 31, No. 4, December 1993, pages 1,912-46; Aaron Wildavsky, Searching for Safety (New Brunswick, N.J.: Transaction Publishers, 1988). 
  82. Randall Lutter, John F. Morrall, III, and W. Kip Viscusi, "The Cost-Per-Life-Saved Cutoff for Safety-Enhancing Regulations," Economic Inquiry, Vol. 37, No. 4, October 1999, pages 599-608. The value is adjusted from 1997 to 2004 dollars based on the Consumer Price Index
  83. Randall Lutter, "Is EPA's Ozone Standard Feasible," AEI-Brookings Joint Center for Regulatory Studies,  Regulatory Analysis No. 99-6, December 1999; Darrell A. Winner and Glen R. Cass, "Effect of Emissions Control on the Long-Term Frequency Distribution of Regional Ozone Concentrations," Environmental Science & Technology, Vol. 34, No. 12, 2000, pages 2,612-17. 
  84. Tammy O. Tengs et al., "Five-Hundred Life-Saving Interventions and Their Cost-Effectiveness," Risk Analysis, Vol. 15, No. 3, June 1995, pages 369-90.  The researchers estimated the cost at $42,000 in 1993 dollars. 
  85. This is necessarily so, because these few pollution sources account for the vast majority of all air pollution 
  86. National Research Council, Air Quality Management in the United States (Washington, D.C.: National Academy Press, 2004); available at http://www.nap.edu/openbook/0309089328/html/index.html. 
  87. National Research Council, Modeling Mobile-Source Emissions (Washington, D.C.: National Academy Press, 2000); Armistead Russell and Robin Dennis, "NARSTO Critical Review of Photochemical Models and Modeling," Atmospheric Environment, Vol. 34, Nos. 12-14, 2000, pages 2283-2324; Robert F. Sawyer et al., "Mobile Sources Critical Review: 1998 NARSTO Assessment," Atmospheric Environment, Vol. 34, Nos. 12-14, 2000, pages 2,161-81. 
  88. Alison K. Pollack et al., "Final Report: Evaluation of the U.S. EPA Mobile6 Highway Vehicle Emission Factor Model," Coordinating Research Council, March 2004; available at http://www.crcao.com/reports/recentstudies2004/CRC_E-64_Final_032004.pdf. 
  89. Peter McClintock, "MOBILE6 vs. On-Road Exhaust Emissions and MOBILE6 Evaporative Credits vs. I/M Gas Cap Failures," 19th Annual Mobile Sources Clean Air Conference, National Center for Vehicle Emissions Control and Safety, Steamboat Springs, Colo., September 2003; Peter McClintock, "Comparing Remote Sensing Emissions Measurements in St. Louis to Emissions Estimates from the MOBILE6 Arterial Roadway Type," 16th Annual CRC On-Road Emissions Workshop, San Diego, Calif., Coordinating Research Council, March 2006. 
  90. Howard K. Gruenspecht and Robert N. Stavins, "New Source Review under the Clean Air Act: Ripe for Reform," Resources, Issue 147, Spring 2002, pages 19-23; available at http://www.rff.org/rff/Documents/RFF-Resources-147-newsource.pdf; Byron Swift, "How Environmental Laws Work: An Analysis of the Utility Sector's Response to Regulation of Nitrogen Oxides and Sulfur Dioxide under the Clean Air Act," Tulane Environmental Law Journal, Vol. 14, No. 2, Summer 2001, pages 309-425. 
  91. Data in this discussion are all drawn from Byron Swift, "Grandfathering, New Source Review, and NOx - Making Sense of a Flawed System," Environment Reporter, Vol. 31, 2000, pages 1,588-96. 
  92. "Lowest Achievable Emission Rate" is a Clean Air Act term, defined case-by-case by EPA. 
  93. Todd J. Zywicki, "Industry and Environmental Lobbyists: Enemies or Allies?" in The Common Law and the Environment: Rethinking the Statutory Basis for Modern Environmental Law, eds. Roger E. Meiners and Andrew P. Morriss (Lanham, Md.: Rowman & Littlefield, 2000). 
  94. Douglas R. Lawson et al., "Analysis of U.S. Roadside Vehicle Emissions and Tampering Survey Data and Evaluation of Inspection and Maintenance Programs: Final Report," Coordinating Research Council, March 21, 1996; National Research Council, Evaluating Vehicle Emissions Inspection and Maintenance Programs (Washington, D.C.: National Academy Press, 2001); Joel Schwartz, "An Analysis of the USEPA's 50-Percent Discount for Decentralized Vehicle I/M Programs," California Inspection and Maintenance Review Committee, March 1995; Joel Schwartz, "Improving Evaluation of Mobile Source Policies: Comments to the National Research Council on Its Review of EPA's Mobile Source Emissions Factor Model,"  California Inspection and Maintenance Review Committee, March 1999; Donald H. Stedman et al., "On-Road Evaluation of an Automobile Emission Test Program," Environmental Science & Technology, Vol. 31, No. 3, 1997, pages 927-31; Donald H. Stedman, Gary A. Bishop and Robert S. Slott, "Repair Avoidance and Evaluating Inspection and Maintenance Programs," Environmental Science & Technology, Vol. 32, No. 10, 1998, pages 1,544-45. 
  95. Schwartz, No Way Back; D. H. Stedman, G. A. Bishop, S. P. Beaton et al., On-Road Remote Sensing of CO and HC Emissions in California - Final Report (Sacramento: California Air Resources Board, February 1994).
  96. "The Clean Air Act and Amendments Regulations: The 1990 Clean Air Act Amendments," Environmental Health and Safety Online; available at http://ehso.com/caa_regs.htm.  The amount of ethanol required to be used in gasoline was more than doubled in the Energy Policy Act of 2005, available at http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109. 
  97. Donald Stedman and Richard Barrett, "High Temperature and Fuel Impact on HC Emissions," 14th Coordinating Research Council On-Road Emissions Workshop, San Diego, Calif., March 2004. 
  98. Marlo Lewis, "Corn Is King," Energy, Vol. 30, No. 3, Summer 2005, pages 36-38. 
  99. See, for example, "EPA Funds New Research on Air Pollution, Children's Health and Watershed Protection," Environmental Protection Agency, Press Release, July 29, 2003; available at http://yosemite.epa.gov/opa/admpress.nsf/4a4be1d8ed4c0b198525702100564fe3/0c118e5e18c3d34a85256d720051db49!OpenDocument; "Renewed EPA Funding for Harvard School of Public Health Research Focuses on Major Component of Air Pollution," Environmental Protection Agency, Press Release, December 15, 2005; available at http://yosemite.epa.gov/opa/admpress.nsf/d9bf8d9315e942578525701c005e573c/96125238fcf089b2852570dc0051746c!OpenDocument; "EPA Awards $8 Million to University of Rochester for Study of Air Pollution Health Effects," Environmental Protection Agency, Press Release, December 12, 2005; "UC Davis Wins $8 Million EPA Grant to Study Health Effects of Air Pollution," University of California at Davis, Press Release, November 15, 2005; available at http://www.news.ucdavis.edu/search/news_detail.lasso?id=7541.  Also see EPA's list of EPA-funded air pollution health research centers at http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/outlinks.centers.  The California Air Resources Board is also a major funder of air pollution health research. Details on CARB's research funding programs can be found athttp://www.arb.ca.gov/research/health/healthres.htm.   
  100. "Smart Growth Funding Resource Guide," Environmental Protection Agency and Smart Growth Network, June 2001; available at http://www.smartgrowth.org/pdf/funding_resources.pdf; "Technical Assistance Programs Offered by the Smart Growth Network," Smart Growth Network, July 2006 (revised edition); available at http://www.smartgrowth.org/pdf/SGN_TA_JulyRevision2006.pdf; Randall O'Toole, "EPA Funds Anti-Sprawl Critics with Tax Dollars," Cato Institute, Daily Commentary, February 25, 2000, available at http://www.cato.org/dailys/02-25-00.html. 
  101. See, for example, Bruce Hill and Martha Keating, "Children at Risk," Clean Air Task Force, 2002; Daniel Lashof et al., "Heat Advisory," National Resources Defense Council, 2004; "American Lung Association Calls on EPA to Strengthen Particle Pollution Protections for All Americans," American Lung Association, March 8, 2006; "100+ Scientists Endorse Stringent New PM Standards," American Lung Association, December 19, 2005; available at http://www.cleanairstandards.org/article/2005/12/404. 
  102. For general examples, see Steve Inskeep, "Commuting IV: All Things Considered," National Public Radio, May 30, 1997; available at http://www.npr.org/templates/story/story.php?storyId=1039432; and Randal O'Toole, The Vanishing Automobile (Bandon, Ore.: Thoreau Institute, 2000), pages 260-61. Additional examples of environmental and smart growth activists promoting increased road congestion include the following: Dom Nozzi, "Traffic Congestion: Friend or Foe?" Walkable Streets, undated, at http://www.walkablestreets.com ["It is a serious strategic blunder for sprawl-busters and other community and environmental advocates to oppose traffic congestion"]; "Fewer Marylanders Using Mass Transit," Montgomery Journal, June 4, 2002 ["My hope is that it will get so congested that people will want to invest in public transit," Marie Howland, Professor of Urban Studies, University of Maryland]; "The Automobile and the Environment: MIT Conference Addresses the Costs of Congestion and Looks for Solutions," MIT Center for Environmental Initiatives Newsletter, June 1999, page 7; available at http://lfee.mit.edu/public/CEI_Newsletter_V1N4.pdf ["Mr. Michael Replogle of the Environmental Defense Fund argued that from an environmental point of view, reducing traffic congestion can be counterproductive"]; Michael A. Replogle, "Minority Statement of Michael A. Replogle," in Expanding Metropolitan Highways: Implications for Air Quality and Energy Use - Special Report 245,  (Washington, D.C.: National Academies Press, 1995), Appendix E, page 358; available at http://www.nap.edu/books/0309061075/html ["Limiting further highway capacity expansion, reducing highway capacity, and calming traffic (especially in central areas) can be effective strategies for reducing energy use, air pollution, and other environmental problems"]. 
  103. "Smart-Growth Funding Resources Guide," Environmental Protection Agency and Smart Growth Network, June 2001; available at http://www.smartgrowth.org/pdf/funding_resources.pdf; "Technical Assistance Programs Offered by the Smart Growth Network," Smart Growth Network, July 2006 (revised edition); available at http://www.smartgrowth.org/pdf/SGN_TA_JulyRevision2006.pdf; Randal O'Toole, "EPA Funds Anti-Sprawl Critics with Tax Dollars," Cato Institute, Daily Commentary, February 25, 2000; available at http://www.cato.org/dailys/02-25-00.html. 
  104. Americans are not unique in favoring automobiles and suburbs.  Europeans use automobiles for 78 percent of all travel. Most Europeans also live in suburbs and nearly all new development in the West is suburban-style development.  "National Transportation Statistics 2004," U.S. Department of Transportation, Bureau of Transportation Statistics, January 2005; available at http://www.bts.gov/publications/national_transportation_statistics/2004/index.html; "Panorama of Transport: Statistical Overview of Transport in the European Union, Part 2," European Commission, 2003; available at http://epp.eurostat.cec.eu.int/cache/ITY_OFFPUB/KS-DA-04-001-2/EN/KS-DA-04-001-2-EN.PDF. For population living in suburbs and central cities, see Wendell Cox Consulting, "High-Income World Metropolitan Areas: Core City and Suburban Population Trends," Demographia, June 29, 2004;  available at http://www.demographia.com/db-highmetro.htm

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