EPA’s Tier 3 tyranny
High cost, no benefit, does nothing to forestall agency’s quest for ecological utopia
Paul Driessen
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The
latest example involves a third layer (or tier) of rules that the
agency says will clean the nation’s air and save lives, by forcing
refineries to remove more sulfur and other impurities from gasoline. EPA
and refiners call the proposal Tier 3 rule making.
Tier 3 tyranny is more accurate – as the rules would cost billions of
dollars but bring infinitesimal benefits, and will likely be imposed
regardless.
Since 1970, America’s cars have eliminated some 99% of pollutants that once came out of tailpipes. “Today's
cars are essentially zero-emission vehicles, compared to 1970 models,”
says air pollution expert Joel Schwartz, co-author of Air Quality in America.
In addition, he notes, more
recent models start out cleaner and stay cleaner throughout their
lives. “As a result, fleet turnover has been reducing on-road emissions
by an average of about 8 to10 percent per year.” Over time, that has
brought tremendously improved air quality, and continues to do so.
Moreover, since 2004, under Tier 1 and 2 rules, refiners have reduced sulfur in gasoline from an average of 300 ppm to 30 ppm
– a 90% drop, on top of previous reductions. Those benefits are
likewise ongoing. Using EPA’s own computer models and standards, a
recent ENVIRON International
study concluded that “large benefits in ground-level ozone
concentrations will have accrued by 2022 as a direct result” of Tier 1
and Tier 2 emission standards and lower gasoline sulfur levels” that are
already required by regulation.
By
2022, those existing emission reduction requirements will slash volatile
organic pollutants by a further 62%, carbon monoxide by another 51% and
nitrous oxides 80% more – beyond reductions achieved between 1970 and
2004.
But even this is not enough for EPA, which now wants sulfur levels slashed to 10 ppm – even though the agency’s models demonstrate that Tier 3 rules, on top of these earlier and ongoing reductions, would bring essentially zero air quality or health benefits.
Viewed another way, further Tier 3 improvements would amount to reduced monthly ozone levels of only 1.2 parts per billion
(peak levels) to 0.5 ppb (average levels). These minuscule improvements
(equivalent to 5-12 cents out of $100 million) could not even have been
measured by equipment existing a couple decades ago. Their contribution to improved human health would be essentially zero.
To achieve those zero benefits, the new Tier 3 standards would cost $10 billion in upfront 
capital
expenditures and an additional $2.4 billion in annual compliance
expenses, the American Petroleum Institute says. The sulfur rules will
raise the price of gasoline by 6-9 cents a gallon, on top of new fuel
tax hikes and gasoline prices that have rocketed from $1.79 to $3.68 per
gallon of regular unleaded over the past four years. These and other
hikes will ripple throughout the economy, affecting commuting and
shipping, the cost of goods and services, the price of travel and
vacations. (White House and EPA officials claim the Tier 3 rules would add only a penny per gallon to gasoline costs, but that is highly
dubious.)
capital
expenditures and an additional $2.4 billion in annual compliance
expenses, the American Petroleum Institute says. The sulfur rules will
raise the price of gasoline by 6-9 cents a gallon, on top of new fuel
tax hikes and gasoline prices that have rocketed from $1.79 to $3.68 per
gallon of regular unleaded over the past four years. These and other
hikes will ripple throughout the economy, affecting commuting and
shipping, the cost of goods and services, the price of travel and
vacations. (White House and EPA officials claim the Tier 3 rules would add only a penny per gallon to gasoline costs, but that is highly
dubious.)
EPA believes the
additional sulfur reductions are technologically possible. Its attitude
seems to be, if it can be done, we will require it, no matter how high
the cost, or how minimal the benefits.
Citizens
need to tell EPA: “The huge improvements to date are enough for now. We
have other crucial health, environmental, employment and economic
problems to solve – which also
affect human health and welfare. We don’t have the financial, human or
technological resources to do it all – especially to waste billions on
something where the quantifiable health benefits payback is minimal, or
even zero.”
Moreover, there are
better ways to reduce traffic-related urban air pollution. Improve
traffic light sequencing, to speed traffic flow, save fuel, and reduce
idling, emissions, driver stress and accidents, for example. That’s
where our efforts should be concentrated.
Another
basic problem is that EPA always assumes there is no safe threshold
level for pollutants – and pollution must always and constantly be
ratcheted downward, eventually to zero, regardless of cost.
This
flies in the face of what any competent epidemiologist knows: the dose
makes the poison. There is a point below which a chemical is not
harmful. There are even chemicals which at low or trace quantities are
essential to proper operation of our muscular, brain and other bodily
functions – but at higher doses can be poisonous. There are also
low-level chemical, radiation and pathogen exposures that actually
safeguard our bodies from cancer, illness and other damage, in a process
known as hormesis.
Even worse, this Tier 3 tyranny is on top of other highly suspect EPA actions. The agency has conducted illegal experiments
on humans, used secret email accounts to hide collaborations with
radical environmentalist groups, and implemented 54.5 mpg vehicle
mileage standards that will maim and kill thousands more people every
year, by forcing them into smaller, lighter, less safe cars.
EPA also expanded the ethanol mandate to promote corn-based E15 fuels
(15% ethanol in gasoline). That means we must turn even more food into
fuel, to replace hydrocarbons that we again have in abundance (thanks to
fracking and other new technologies)
but our government won’t allow us to develop, and to substitute for
cellulosic ethanol that doesn’t exist (but EPA tells refiners they must
use anyway). So corn farmers get rich, while consumers pay more for
gasoline, meat, fish, eggs, poultry and other products.
The agency is also waging war on coal, automobiles and the Keystone XL pipeline – based on assertions that carbon dioxide emissions are causing “dangerous man made global warming.”
Even the UN’s Intergovernmental Panel on Climate Change, NASA, British
Meteorological Office, and many once alarmist scientists now acknowledge
that average planetary temperatures have not budged in 16 years, and
hurricanes, tornadoes, floods, droughts
and sea level rise have shown no statistically significant variation
from century-long averages – even as CO2 levels have “soared” to 395 ppm (0.0395% of Earth’s atmosphere). True scientists
increasingly recognize solar and other complex, interconnected natural
forces as the primary drivers of Earth’s ever changing and unpredictable
weather and climate.
These
inconvenient truths have apparently had no effect on Administration
thinking. Perhaps rising indoor CO2 emissions from larger EPA and White
House staffs have “weirded” their thinking. The EPA’s yellow brick road to Eco-Utopia
is not one our nation should travel. It will not take us to an economic
recovery, more jobs, a cleaner environment, or improved human safety,
health and welfare.
Nothing in the
Clean Air Act says EPA needs to promulgate these rules. But nothing says
it can’t do so. It’s largely discretionary, and this Administration is
determined to “interpret” the science and use its executive authority to
restrict and penalize hydrocarbon use – and “fundamentally transform”
America.
EPA administrator nominee
Gina McCarthy says EPA will “consider” industry and other suggestions
that it revise greenhouse gas and other proposed rules. However, neither
she nor the President has said they will modify or moderate any
policies or proposals, or retreat from their climate change agenda.
We
are desperately in need of science-based legislative standards,
commonsense regulatory actions, and adult supervision by Congress and
the courts. Unfortunately, that is not likely to be forthcoming anytime
soon, and neither Republican Senators nor the House of Representatives
seem to have the power, attention span or spine to do what is necessary.
Where this all will end is therefore anyone’s guess.
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Paul Driessen is senior policy advisor for the Committee For A Constructive Tomorrow (www.CFACT.org), and author of Eco-Imperialism: Green power - Black death.
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