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Speeches By EPA Administrator

 

Harvard University -- Kennedy School of Government Forum

02/24/1997
Carol M. Browner
Administrator, U.S. Environmental Protection Agency


Harvard University -- Kennedy School of Government Forum
Cambridge, Massachusetts
February 24, 1997



Thank you and good evening.   It is a very special privilege to be invited back to the Forum.

The last time I was here, a little more than two years ago, I spoke in broad terms about the nation’s 25-year commitment to protect the air we breathe, the water we drink and the land on which we live.  I spoke about the progress we have made as a nation, and the challenges that lie ahead.  I also spoke about the process of environmental regulation -- how EPA sets standards to protect the public health -- and what we have been doing to make that process work better.

This evening offers a good opportunity to continue that discussion -- and to examine the rationale for EPA’s standard-setting process.  At the core of EPA’s mission, at the core of the standard-setting process, is protecting the public health.

Over the last two years, that process has come under almost constant attack -- some in the Congressional leadership essentially suggesting that if monetized benefits did not outweigh the costs of pollution reduction -- that is, if the dollar amounts assigned to improved public health were not greater than the dollar amounts assigned to pollution reduction technology -- then standards could not be set or health protections strengthened.

More recently, the process has come under fire over the EPA’s much-debated proposal to revise the national ambient air quality standards for particulate matter (or PM) and ground-level ozone -- better known as soot and smog.

In keeping with the law -- the Clean Air Act -- EPA has proposed to strengthen the standards and expand the public health protections -- and thereby reduce the levels of those pollutants in the nation’s air.

If adopted as proposed, the new ozone standard would protect nearly 50 million more Americans from the adverse health effects of smog -- 13 million of whom are children.  And the new standard for particulate matter would result in 20,000 fewer premature deaths, a quarter-million fewer cases of aggravated asthma, another quarter-million fewer cases of acute respiratory problems in children and 60,000 fewer cases of bronchitis -- each year.

Taken together, these proposed standards would extend protections -- cleaner air -- to a total of 133 million Americans, including 40 million children.

Now, as you might have heard, not everyone is happy with these proposed standards.  In fact, I can safely say that this has been the toughest and most controversial national issue I have had to face in my more than four years at EPA.

I suppose you might say that we are under an “air assault.”  Some representing industry have argued that the implementation costs to businesses would be excessive, while others have accused us of “moving the goal posts” in the middle of the game.

Still others have warned about impending lifestyle changes -- that these standards would lead to the banning of barbecue grills and Fourth of July fireworks.

Let me tell you they are nothing more than scare tactics.  They are false.  They are wrong.  They are manipulative.  And, sadly, they detract from what could be and should be a rational, informed debate on an issue of great importance to millions of Americans.

Perhaps I cannot change the fact that there is opposition among some in industry to EPA’s proposed standards.  But I can hope to bring a measure of reason to the debate.

I believe the debate is properly shaped by a simple question:  Have we reached the point in this country where we would abandon the nation’s longstanding commitment to a health-based standard for air pollution?  Or, put another way, are we prepared to accept, as the science shows us, large numbers of Americans experiencing real health effects, even death, because some in industry project “high costs” to reduce their pollution of the public’s air?

I believe the answer is no.  Americans want clean air.  They want the public health to come first.  They want their children protected.  And they want EPA to do its job -- which is ensuring that the air they breathe is safe and healthy.

That’s why we have the Clean Air Act.  This is why, this year, we celebrate its 27th anniversary.


It was a spirit of bipartisanship that launched the Clean Air Act in 1970 and that made the uncompromising promise of public health protection.  Richard Nixon proclaimed it to be, in his words, “a historic piece of legislation that puts us far down the road toward...(the) goal of clean air.”

It was that same bipartisan spirit that led to the strengthening of the Act in 1990, with President Bush saying, again in his own words, that “every American expects and deserves to breathe clean air.”

And, in fact, due to the success of the Act, many millions of Americans today are breathing healthier air.  Millions more of our children are protected from the harmful effects of breathing polluted air.

Make no mistake, the Clean Air Act has worked for America.  It has helped protect the public health.  And it has done so without holding our economy back.  In fact, since 1970, emissions of the six major air pollutants have dropped by 29 percent while the population has grown by 28 percent and the gross domestic product has nearly doubled.

Economic growth and cleaner air.  Now that’s a level of progress we can all be proud of.  Time and time again, American industry and the American people have risen to the challenge of cleaner air.

But does that mean the job is done?  That the goal of clean air is achieved?  That we rest on our laurels?  That we stand pat?  That because we are making such great progress, there is no need to revisit our standards, no need to reassess them in light of any new scientific findings, no need to ensure that they are adequate to protect the public health?

Unfortunately, that is what some are suggesting.

But Congress -- in its infinite, bipartisan wisdom -- ensured that we would never be allowed to make that choice.

From the beginning, the Clean Air Act has contemplated the march of technology and science.  It has recognized that science will always come up with better ways to understand the health effects of the air we breathe -- and that the standards of the 1970s may not be right for the 21st Century.  And, therefore, the Congress set forth a process to ensure that the standards would be set and, if necessary, revised in a manner that puts the public health first and ensures that Americans are protected with an adequate margin of safety.


First, it directs EPA to review the public health standards for the six major air pollutants at least every five years, in order to ensure that they reflect the best current science.  It also lays out a specific procedure to obtain that science and, if needed, revise the standards.  This is to ensure that we never get to the point where the government tells Americans that their air is healthy to breathe, when the scientific community knows that, in fact, it is not.  This is to safeguard the public’s right to know the quality of the air they breathe.

Next, the process requires that EPA’s standard-setting work and the underlying health studies -- some 250 of them in this case -- be independently reviewed by a panel of scientists and technical experts from academia, research institutes, public health organizations and industry.  In this case -- ozone and particulate matter -- the panel -- over a four-year period -- conducted 11 meetings, all open to the public -- a total of 124 hours of public discussion of the scientific data, research and the studies of the health effects of smog and soot.

EPA has held further public meetings, at which hundreds of representatives from industry, state and local governments, organizations -- as well as members of the public -- have offered their views.  The public comment period remains open until March 12.

I can safely say that this has been the most extensive scientific review and public outreach process ever conducted by EPA for public health standards.

After a thorough review of all the scientific evidence -- all of the published, peer-reviewed and fully debated health studies -- literally peer review of peer review of peer review -- the conclusion of the independent panel is that the current air standards are not adequately protecting public health and that they should be revised.  Serious health effects are occurring in children, the elderly and other sensitive populations at particulate matter and ozone concentrations at and below existing standards.

So that is why we have proposed to strengthen them.

Some opponents have questioned the science.  They say that unless you can show exactly how a pollutant causes asthma attacks in children -- unless you can show exactly how a pollutant causes sickness or death -- unless you can produce cold, hard biological evidence -- then EPA has no business setting a standard to protect those children -- even though the best available science demands action.

I tell you, they are treading on very dangerous ground.  When EPA ordered the phase-out of lead from gasoline back in the 1970s, we didn’t know exactly how the lead was ending up in children’s blood.  We didn’t know exactly how that lead caused our children to lose IQ points.  We couldn’t explain with absolute scientific certainty the path lead pursued in the child’s body from inhalation to illness.

But we did know, from the best available science, that with the advent of leaded gasoline, our children’s blood changed -- and they became sick.  We had a cause -- leaded gasoline -- and an effect -- lead poisoning.  So we took action.  As a result, lead levels in the blood of our children fell dramatically.  Driven by the scientific evidence of cause and effect, we acted -- and an entire generation of children was protected.

Should we have waited ten years or more before acting on leaded gasoline?  Should we have waited to see how lead-poisoned children of the 1970s fared in the 1980s?  Should we have waited for people to die so we could dissect their lungs and their brains in order to figure out exactly how lead devastates human health?

Of course not.  We knew in the 1970s that lead was bad and that it was poisoning our children.  By acting when we did, we prevented developmental problems in hundreds of thousands of children.  We prevented many thousands more cases of heart disease, stroke and hypertension in adults.  We did the right thing.

The same goes for cigarettes.  We didn’t know exactly how they caused lung cancer.  But science could tell us that people who smoked greatly increased their chances of getting the disease.  So the government acted to make sure people were aware of the risks.

Today, some opponents have asked why we don’t base the level of public health protection we provide on the dollar costs it will impose on industry and our society.  The answer is simple -- the law doesn’t allow us to.  The Clean Air Act clearly requires levels of smog and soot to be based solely on health, risk, exposure and damage to the environment -- and not projected costs for reducing pollution.

This is no accident.  In the 1970 Clean Air Act debate, Congress deliberated the issue of cost -- as well as the technical feasibility of meeting clean air standards.  At the time, there was a great deal of frustration that such considerations were preventing any real progress toward cleaner air.

Thus, the decision was made -- the public health must come first.  The current best science must prevail in determining the level of protection the public will be guaranteed.  Nothing else can take precedence.

This issue has been revisited each time the Clean Air Act has been amended -- in 1977 and again in 1990.  And, each time, Congress and the President have come down firmly on the side of the public health over cost considerations.

Not only does the law forbid us from considering the costs of these standards, but history and real experience tell us we’d be foolish to try.


Each and every time we have begun the process to set or revise air standards, the costs of doing so have been grossly overstated -- by both industry and EPA.  For example, during the 1990 debate on the Clean Air Act’s acid rain program, industry initially projected the cost of an emission allowance to be $1,500 per ton of sulfur dioxide, while the EPA projected it to be as much as $600.  Today, those allowances are selling for less than $100.

Likewise, the auto industry said a few years ago that the cost of meeting California’s emission standards would amount to $1,500 per car.  Again, the actual cost is less than $100.

The point is that industry always rises to the challenge -- again and again -- finding cheaper, more innovative ways of meeting standards -- and lowering their pollution.

That doesn’t mean that there is no role for the practicalities of attaining these protections.  There is such a role when it comes to implementing the standards.  In that case, it certainly is appropriate to consider costs.  If these new standards are adopted, EPA will work with all who are affected  -- state governments, local governments, community leaders, businesses large and small -- to find cost-effective and common sense strategies for reducing pollution and providing the public health protections.  That is part of the process, too.

So, when you listen to what is being said about the proposed clean air standards, remember that EPA did not just pluck them out of thin air -- if you’ll pardon the expression.

There is a law.  It is a good law.  There is a process.  It is a good process.

It provides for the clean air standards to be periodically reviewed and updated.  It ensures that we will always have the best available science, subject to independent review.  It enables everyone -- businesses, state and local governments, community groups and the public -- to participate in the process and have their say.  It honors the public’s right to know.  And it sets out a reasonable and rational procedure for implementing revised standards and assuring that it is done in the most common sense, cost-effective way.

Most importantly it guarantees that our first priority will always be to protect the public health.  

Does it challenge us?  Yes.

But this nation -- its industries, its communities, its people -- are fully capable of rising to that challenge.  Working together, we can have cleaner air and not sacrifice our economic vitality.  We’ve done it before.  We can do it again.


So this is not about backyard barbeques.  It is not about banning fireworks on the Fourth of July.  It is about whether our children will be able to go outside on the Fourth of July and enjoy those fireworks and those barbeques.  It is about following the science  It is about finding ways in which we can all work together to ensure that the air we breathe is healthy, and that our standards protect the greatest possible number of Americans.

I ask the question again: Have we reached the point where we should abandon our commitment to a public health standard for air pollution?


I think not.  I don’t think we ever will.

Over the history of the Clean Air Act, the goal is -- always has been and always will be -- clean air.  Nothing in that has ever changed.  No goal post has been moved.

What has changed is science -- which is forever bringing advancements and innovations to improve the quality of our lives.  Science now tell us that our air pollution standards are not adequate to protect the public’s health -- that the currrent standards leave too many at risk.

Let us listen to the science.  Let us respond as we have before.  Let us work together toward common ground, to continue to improve the quality of our air and to protect the health of our citizens.

Let us do it for our children.

Thank you.