Depending on pollutant mobility, air pollution may be local (factory
odors, smoke), regional (acid rain) or even global (greenhouse
gas build-up, ozone depletion by CFC's). Obviously localized
problems are easier to deal with than larger-scale problems.
Under the Clean Air Act Amendments of 1970, the EPA assumed
principal authority from the states for controlling air pollution,
and adopted the usual "command-and-control" (CAC) regulatory
approach. The EPA distinguished conventional from hazardous
pollutants. It defined uniform ambient air quality standards
for each conventional pollutant (short- and long-term averages).
All conventional air pollutants have primary standards
designed to protect human health; some also have secondary
standards to protect aesthetics, vegetation, etc. The stricter
standard applies. These standards were defined by the EPA without
regard to cost of compliance. Enforcing these standards
was left to the state governments. Not surprisingly, many states
missed the federal deadlines for achieving primary standards.
Areas out of compliance with these standards were designated
as non-attainment areas.
States are required to file State Implementation Plans (SIP's)
with the EPA. The EPA is authorized to deny federal sewage and
transportation funds for states that don't file SIP's. (New Castle
County is still a non-attainment area, and Delaware has been so
delinquent in filing its revised SIP that its federal highway
funds are currently being withheld.) All major new or modified
pollution sources in non-attainment areas must achieve lowest
achievable emissions rates (LAER) regardless of cost or control
practices at other sources.
The EPA's prevention of significant deterioration (PSD)
policies are intended to keep regions with high air quality from
letting their air quality deteriorate toward the primary standards.
PSD regions are designated as Class I, II or III depending on
allowable deterioration.
The EPA's air quality standards are clearly inefficient. Most
are based on poorly-documented health thresholds and target zero
adverse health effects. They confuse ambient concentrations with
actual human exposures. Costs of compliance are explicitly excluded
from consideration. Uniform standards ignore critical locational
differences and time factors. Even if the chosen standards were
efficient, the CAC approach is still not cost-effective. The
divergence between CAC and least-cost compliance is particularly
high for standards of intermediate toughness.
Emissions trading policies can provide substantial efficiency
gains. A system of emission reduction credits allows firms
achieving more than the required level of control to either bank
or sell credits for emissions reductions. Offset policies
require new sources to offset their emissions by acquiring emission
reduction credits from existing sources. Bubble policies
define standards for multi-firm areas which can be satisfied by
actual emission reductions and/or acquisition of emission credits.
Netting policies treat individual firms as bubbles, so
that emissions increases from one process can be offset by emissions
reductions in other processes within the same firm.
Emissions trades are becoming increasingly common although they
generally involve high transactions costs because they must be
approved by regulators. Recent revisions to the Clean Air Act
include formalization of a sulfur emissions market for coal-burning
electric utilities. The Chicago Board of Trade is even developing
a futures market in emissions permits to help firms hedge against
future permit price risks. Are such markets vulnerable or price
manipulation? A diverse initial allocation of permits can reduce
the likelihood of cartelization.
Emissions charges may be levied to (a) make polluters pay
the social costs of their pollution, or (b) achieve a given standard
at minimum cost. Emissions charges may be used to subsidize the
development and adoption of emission control technologies. However,
a system of charges is inherently less flexible than a marketable
permit system: charges need to be adjusted in accordance with
changing price levels, technologies and environmental standards.
Hazardous pollutants are controlled separately under the
Clean Air Act. EPA is supposed to to list hazardous pollutants,
quickly define ambient standards, and enforce them. Standards
for hazardous pollutants are supposed to protect human health
"with an adequate margin of safety." Caught between
environmentalists' demands for zero-emissions standards and industrial
necessity, the EPA has actually listed very few hazardous pollutants,
and has tried to incorporate risk assessments and benefit-cost
analyses into their regulatory policies.
Tietenberg summarizes Haigh, Harrison and Nichols's benefit-cost analyses of controlling benzene, coke oven emissions and acrylonitrile emissions. Valuing each human life saved at $1 million, they showed that strict BAT's and relaxed uniform emissions standards both yielded lower (more negative) net benefits than differential standards reflecting human exposures caused by each emittor. Nichols (Example 15.3) shows that standards reflect neither differential control costs nor differential exposures; emissions charges overlook reflect differential exposures; exposure charges do account for both control costs and exposure levels.