Statement of Paul Hansen
Izaak Walton League of America
April 29, 1997

Mr. Chairman and Members of the Subcommittee: I am Paul Hansen, Executive Director of the Izaak Walton League of America, which is celebrating its 75th year of working to conserve, maintain, protect and restore the soil, forest, water and other natural resources of the United States. I appreciate having the opportunity to talk with you today about the Environmental Protection Agency's proposal for new national air quality standards for ozone and fine particulate matter, commonly referred to as PM-2.5.

Protection of our nation's air quality is a part of the Izaak Walton League's mission and an issue of vital importance to League members, many of whom live in the nation's agricultural communities. We have worked on clean air issues since the first Federal Air Pollution Act, which was passed during the Eisenhower Administration. With the adoption of new air quality standards just months away, the League is concerned that the health, environmental and economic benefits that new standards would provide be understood, recognized and considered as you review this critical decision.

Today, I want to touch on a few of the benefits this new standard would realize for the health of our people and our natural environment, but 1 especially want to implore you to consider the findings of the U.S. Department of Agriculture's National Crop Loss Assessment Network, which was released during the Reagan Administration. We were involved in the NCLAN study, and cosponsored a symposium in 1982, with the Boyce Thompson Institute at Cornell University, at which many of the findings were released and discussed. 1 personally conducted a literature review of the effects of air pollution on crops in 1990, a summary of which is available here today for your consideration.

You know that the new air quality standards would protect public health by preventing approximately 15,000 premature deaths and 250,000 to 400,000 illnesses each year. The proposed ozone standard of .08 ppm would provide much needed health protection to anyone who spends time outdoors working, exercising or relaxing. This includes, of course, farm owners, operators and employees. The particulate matter standard for PM-2.5 would protect, among others, anyone with heart or lung disease. Most importantly, both standards would improve protections for our children's health.

You also know that new limits on ozone and fine particulate matter pollution would further reduce emissions of air pollutants that deposit on our rivers, lakes and streams and degrade water quality necessary for wildlife, fisheries, and water-based recreation. As you know, ozone and particulate matter pollution are secondary, not primary pollutants. This means that they are not emitted directly but instead are created from a mixture of primary pollutants including nitrogen oxides and sulfur dioxides. By reducing emissions of these primary pollutants, the new standards would help to prevent the acidification of our rivers, lakes, streams, and other special aquatic ecosystems such as the Chesapeake Bay.

Most critical to the responsibilities of this Committee, the new ozone standard would provide millions of dollars in agricultural benefits each year. At air pollution levels well below those that exist in our air today, ozone can reduce the productivity of commodity crops such as corn and soybeans by 10 percent. This means that dirty air costs our country approximately one billion bushels of corn and more than two hundred million bushels of soybeans each year -- at today's prices almost three billion dollars in revenues.

It is well-established in the literature that the effects of ozone on crops is very insidious, and, in most cases, invisible. With soybeans, for example, there are no fewer beans, but lighter beans. A 10 percent reduction, which can be common at ozone levels found throughout much of the soybean growing region, while highly significant in terms of yield, would be effectively invisible -- even to the trained eye.

In the last two years, three groups of experts on ozone's vegetative impacts have reconfirmed the seriousness of ozone's impacts on commodity crops, forests, and other vegetation, which were first measured by the National Crop Loss Assessment Network in 1982. A workshop sponsored by the Southern Oxidants Study in 1995 convened agricultural, forest, and ecological scientists with extensive experience studying the effects of ozone on ecosystems to discuss the need for a new ozone standard. The Workshop recommended that EPA adopt a seasonal secondary standard that would provide vegetation with additional protection during the growing season.

More recently, the Department of the Interior recommended that EPA adopt a more protective secondary standard because the proposed primary standard of .08 ppm was not adequate to protect natural and cultural resources.

Finally, the Clean Air Scientific Advisory Committee (CASAC) that reviewed the research behind the proposed standards advised EPA that a secondary standard, more stringent than the primary, was needed to protect vegetation from ozone.

I know that concern has been expressed regarding the cost of implementing a new PM-2.5 standard, particularly in agricultural areas, and 1 would like to close by addressing that issue.

First, it is essential that our air quality standards be set at levels that are protective of human health, not at levels that regulated industries and others consider cost-effective.

Second, the new particulate matter standard applies to PM-2.5, not PM-10. EPA has not recommended any tightening of levels of PM-10 pollution. The distinction is important because almost all PM-2.5 is a product of combustion and almost all PM-10 is created by earth moving activities such as construction, mining, and agricultural practices like tilling.

Third, on most farms, the primary source of combustion is diesel fueled farm equipment. This equipment is responsible for a very small amount of the primary pollutants that create PM-2.5. The amounts of these primary pollutants created by farm equipment are so small they are insignificant when compared to emissions from other PM-2.5 sources. Farm equipment creates about one percent of national nitrogen oxide emissions and almost no sulfur dioxide emissions.

Finally, the history of pollution controls strongly suggests that even if controls on diesel fueled vehicles become necessary, these controls will cost far less than predicted. Reductions in sulfur dioxide emissions, for example, which cost less than $ 100 per ton today were predicted to cost as much as $1,500 per ton. Reduced crop yields are much more likely than tighter pollution controls to negatively impact a farmer's bottom line.

In closing I would like to again thank you for the opportunity to address the proposed new standards' agricultural impacts and to shed light on one of the hidden victims of our nation's polluted air, the American farmer.

NEW STANDARDS WILL IMPOSE FEW BURDENS ON THE FARMER

The Izaak Walton League believes the impact that these standards will have on our nation's agriculture industry have been mis-characterized by some. Industry opponents to the new PM-2.5 standard, for example, claim the new standard will create a horrible regulatory burden for farmers. These opponents are assuming that EPA will target the same farming activities for PM-2.5 as it did in developing strategies for controlling PM-10. However, this assumption is mistaken.

EPA's principle interest in implementing the new air quality standards is to bring areas of non-attainment into attainment. Most projected non-attainment areas are urban areas where fine particulate matter pollution is a product of combustion. Therefore, the major targets of regulatory focus are very likely to be sources of combustion in urban areas: electric utilities, buses, and large commercial boilers, for example.

The changes EPA is proposing to the PM-1O program -- which do not include a tightening of PM-10 pollution limits -- actually result in fewer regulatory burdens on agricultural activities. For example, by proposing a switch to a "98th percentile" form for measuring compliance with the PM-10 standard, EPA is proposing to allow more than six exceedances every year to be "excused" instead of just one. In comments critical of this element of EPA's proposal, the California Air Resources Board calculated that in the Great Basin Valley peak PM-10 levels 68 percent above the standard would be legal under the new proposal.

Finally, there has been testimony in the U.S. House of Representatives that the new PM-2.5 standard will also affect farmers who use nitrogen-based fertilizers and, because of the volatilizations of ammonia, dairies with manure lagoons. In reality, combustion sources such as factory boilers and electric utilities emit many times the level of PM-2.5 particles than do manure lagoons. They are not likely to be regulated under the State Implementation Plans developed to implement these standards.