Regulatory Action and Technology Forcing

I spoke with Dr. John Vandenberg, associate director for health, and Dr. Ila Cote, senior science adviser, at the EPA's National Center for Environmental

Assessment about historical trends in regulations and environmental improvements. We talked about the role that the EPA as well as state agencies such as CARB have had in technology forcing. This term refers to the process by which a gradual but timely phase-in of new pollution-emission standards allows (or forces, depending on one's point of view) the relevant industry to develop the necessary technology needed to reach the new standard. Usually this can cost a great deal of money, although Dr. Vandenberg pointed out that in many cases actual costs are often not as high as originally estimated. He mentioned the example of power plants struggling to meet the lower SO2 standards required by the Clean Air Act. The use of low-sulfur coal as opposed to the higher-sulfur coal found in the eastern half of the country was crucial to reach the lower SO2 levels mandated by the regulations. He pointed out that railroad deregulation, which was passed at around the same time, made it much cheaper for eastern and Midwestern coal-burning power plants to ship low-sulfur coal from the west. This allowed power plants to meet the standard at a significantly lower cost than anticipated.

The issue of costs versus benefits for environmental regulations and standards is a complex one. Many people do not realize that the EPA and other agencies do in fact perform cost-benefit analyses connected to all new environmental regulations (with the exception of those related to the six priority air pollutants defined in the Clean Air Act). For other air pollutants and for all water-pollution regulations, cost-benefit determinations must be taken into account. As pointed out by Drs. Cote and Vandenberg, it is often easier to calculate the cost of a cleanup program or preventive regulation than to figure out the financial equivalents of many of the benefits. Economists can use measures such as work days and income lost due to illness, hospitalization costs, etc., but it isn't easy to put a price on a blue sky or a clear, clean stream.

Drs. Vandenberg and Cote echoed the sentiments of many on the industry side, acknowledging that litigation over regulation is a waste of time and money for both the government (and the taxpayers) and industry, and it is much better to come to a consensus agreement whenever possible. Previous EPA administrators Lee Thomas and Bill Reilly, who held the job in the late 1980s and early 1990s, tried to follow this approach. Their efforts helped pave the way for the chemical industry's Responsible Care program. Drs. Vandenberg and Cote also pointed out that often positive changes can be produced not only by legally binding regulations, but also by the pressure of publicity and the availability of transparent information. For example, the Toxic Release Inventory, an EPA program, makes data on the release of emissions of toxic agents (see chapter 4) available to the public, which includes local environmental groups and media. The data is submitted by the companies themselves. Many companies voluntarily go to the trouble and expense of limiting or eliminating emissions of toxic substances in order to avoid being confronted by local activists or the media. "Right-to-Know" laws, both at the federal and state levels, can perform the same function. In one case, the possibly carcinogenic solvent trichloroethylene was voluntarily removed from Bic's Wite Out, Sanford's Liquid Paper, and similar products due to public disclosure of its presence. I should note that this mechanism of environmental improvement presumes a culture that expects and demands clean and healthy products and environments.

My discussion with Drs. Vandenberg and Cote reinforced my general view, stemming from years of interaction with EPA scientists and officials, that the people working for EPA and other regulatory agencies are creative and thoughtful individuals who are intensely committed to the health and safety of the American public. New ways of finding solutions to the many environmental problems of such a large and diverse country is a daunting task. To quote Dr. Vandenberg, "Creative solutions for the future are not necessarily the same as those that worked in the past.'' Even a cursory glance at the EPA website will inform the reader that the EPA is continuously searching for new and creative solutions, and as I hope you are beginning to understand, is more and more successful in dealing with our environmental problems.


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