CRI Focus Areas

How an A Becomes and F


In 2014, for the first time, Delaware met all Air Quality Standards for every measured pollutant. That is an “A” in my book! Yet the American Lung Association (ALA) just released a report giving Delaware an “F” grade for air quality. How could that be?   Start by following the money. The ALA received $20 million in grants from the U.S. Environmental Protection Agency (EPA) over the last decade, and generally advocates for tougher regulations. The EPA has a self interest in maintaining the impression air quality is in crisis. No crisis means less funding and fewer jobs at the EPA which writes and enforces the standards.   Second, follow the bias. The ALA has a legitimate concern about the health impacts of certain air pollutants, especially ozone. They appear willing to exaggerate the situation to build public pressure for tighter air quality standards. The ALA Annual Air Quality Report Card is designed to support the EPA’s self serving position and should not be trusted.   The ALA report card is toughest on ground level ozone giving all three counties an “F”. Ozone is not emitted directly but forms from chemical reactions between nitrous oxide and volatile organic compounds, which occur both as manmade and naturally occurring chemicals. Those reactions are accelerated by sunlight and heat so tend to peak on hot summer days when temperatures exceed 95° F. Summers with a lot of heat waves have more days with high ozone levels. Great Smokey Mountain National Park in Tennessee gets its name from the summer haze formed from volatile compounds emitted by pine trees in the park. The park would have gotten an “F” from the ALA for ozone even before man occupied the continent! It is also possible Delaware is just measuring background levels of ozone at this point and no regulatory strategy will improve air quality further.   The ALA methodology basically adopts the standard metrics they want rather than the metrics approved in a rigorous regulatory process. They also put their emphasis on just two pollutants individually rather than using a weighted average of all six pollutants with air quality standards, some of which are at levels 90% below the maximum allowed. For example, fine particulate pollution in Delaware averages 25% below the allowed maximum.   The standard excludes up to six individual days a year when the average may be over the standard. One of four Air Quality Monitoring Stations in New Castle County has averaged two days over the peak standard over the last three years. ALA uses those high days, regardless of whether they are over by 1% or by 100%, to determine the grade. This leads to the ridiculous result of a “C” grade for New Castle County and an “A” grade for Kent and Sussex Counties when there is only a 3% difference in the three year average peak levels of fine particles, and all three counties meet the EPA standard. Similar methodology is used for ozone.   If you work for the EPA, the worst possible outcome is to actually have clean air. If there is no harmful pollution, there is no reason for regulation. To keep the EPA in business a standard needs to be set low enough so it can never be met.   The EPA has proposed a tighter standard for ozone that will likely be lower than naturally occurring levels in most locations resulting in job security and in the EPA maintaining the power to control our lives, and the national economy. We suggest opposing the new ozone standards.   Dave Stevenson Policy Director    


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