Mr. Wehrum, thank you for coming to testify to the Committee to provide us with your views on the current national ambient air quality standards review of particulate matter and your proposal to tighten the current daily standard. I would make the point that I do not believe the science justifies ratcheting down the regulations at this time, given that the estimated risk today is less than what was estimated in 1997 under Carol Browner when the current standard was set.
I am also troubled that EPA has been selective in what studies it has chosen to give weight to in this review, thus skewing the results by downplaying studies which show the current standard is sufficiently strict to protect human health with an adequate margin of safety.
But we will examine the science issues in detail during the hearing next Wednesday. Today, we are focused on better understanding the process by which EPA makes these determinations, the history of past decisions, and impacts caused by possible tightened standards. I believe the economic impacts will be severe.
I am troubled that EPA has not provided to the public or this oversight Committee a comprehensive regulatory impact analysis. While a NAAQS [pronounced naax] review is based on health considerations by statute, Congress wrote the law and is responsible not only for overseeing its execution, but for evaluating whether the way it is crafted is appropriate in light of its unintended consequences.
Moreover, any assessments of health benefits can only be made with an understanding of the economic consequences because there is a clear link between economic vitality and human health. In short, wealth is health. Poorer communities often suffer from inadequate infrastructure and that in turn will be exacerbated if these areas are designated nonattainment unnecessarily. As we have heard in the past, when electricity prices rise, the poor and elderly in inner cities such as Chicago, turn off their air condition and scores die each summer because they can’t afford their A/C. As local officials know all too well, additional burdens placed on new manufacturing facilities discourage them from locating in these regions.
It is my belief that we should be judicious in selecting what standards we impose on our cities and states, taking into account what would be required to fully attain these standards by the deadline set by the Clean Air Act, and then enforce these standards to ensure public health. It makes no sense to set unnecessarily and unrealistically stringent requirements, but then to excuse areas which will not comply because it is expensive while others that take their commitment seriously suffer job losses and slower growth. I am thinking in particular of California, which has consistently failed to meet previous standards and has continued to receive exemptions.
As a former mayor, I know that air regulations – and the increased control burdens that accompany them for many areas – can be an important factor in decisions by companies as to where to locate their facilities.
Many counties, through the implementation of current regulations such as the diesel rule, clean air interstate rule, and others, will come into compliance with current health standards. Yet these areas will be designated nonattainment with the new standards, and thus forced to impose additional controls and to remain unattractive for new business investments. By moving the goal posts, we upset the ability of these communities to pursue their compliance strategies and keep them in an endless loop that depresses their economies.
I know some of my colleagues don’t think we should be holding today’s hearing, but it would be irresponsible if this Committee did not conduct thoughtful oversight of not only the science-health issues, as we will less than a week from today, but also the potential economic impacts from these regulations. We have to look at both sides and I applaud Chairman Voinovich for holding today’s hearing.