INTERVIEW
Professor Stern on air When the existing legislative mandate expires (June 1975) what assurances have we that it will be continued? i don't have the slightest doubt that we will continue to have a federal air pollution act. Neither the Congress nor the public will tolerate a complete cessation of air pollution control activities in the U.S. at the federal level. Further, I do not anticipate that we will completely scrap the present Clean Air Act, and replace it with an entirely new act. There are eight parts of the present Act that have withstood the test of time; there would be no need to repeal them and substitute new amendments for them (see box material). At a conference on the Clean Air Act held in late 1973, you discussed deficiencies of the Act. Have your views changed? There are two approaches to what we do about the Clean Air Act. One is to look at the broad bases for air pollution control that went into the Act to see if they are the ones that we really want to live with for the next several years. The other approach is to do nitpicking of individual requirements of the Act, and to amend a requirement by changing several words or dates. I think that it is more important to address the general concepts that went into the Act. Certainly. if the general concepts are not revised, we are going to have to amend the Act by nitpicking. From 1966-1969 the administration, represented by the Dept. of Health, Education, and Welfare and the Public Health Service, proposed a system of air pollution control in the U.S. based on national emissions standards. At that time, the Senate Public Works Committee rejected that notion, and opted for an approach that has now come to be known as air quality management. This put the U.S. upon a course considerably different from the rest of the world, which has followed what is generally known as the best practicable means control approach-essentially what was proposed by the administration.
In my opinion, what Congress needs to do is to reevaluate that basic decision, and decide whether it wants to continue to develop the minutiae of a system that follows the air quality management approach. That is, the development of air quality standards, the use of mathematical models to go from air quality standards to emissions siandards, the requirement of state implementation plan filing, the use of both primary and secondary standards, the development of a completely different system for control of existing sources and new sources. i think that a more viable system of control in the U.S. would follow by going back to first principles, national emissions standards, which were abandoned by the Congress in 1967 and 1970. I would like to see this occur, but It is not my prognosis that it will. What do you feet have been the most effective provisions of the Act in its several metamorphoses? Those provi-
sions of the Act that set up financial grants to states and localities for planning, development, establishment, improvement, and maintenance of state and local air pollution programs. This financial assistance program has developed a strong system of state air pollution control programs across the U.S. and, in turn, has helped strengthen municipal air pollution control programs. With strengthened programs, the states have enacted, in most cases without the necessity of having had a federal impetus in terms of the state implementation plans, control practices and procedures for the sources within their states. These strong and quite healthy air pollution control endeavors stem from the wisdom of Congress in the early 1960's in setting up financial support for state and local activities. The main benefit of the 1970 Act, with regard to the requirement of state implementation plans, has been to require the states to put a control policy on paper.
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The Water Managers
S U B S I D I A R Y OF MERCK & CO., I " Z
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POLLUTANT MANAGEMENT Do you foresee a need for legislation that would regulate the "life cycle" of a pollutant such as SO2 emissions forming sulfates which may fall as acid rain to pollute water, landhegetation? The problems of dealing with each of the media are so complex that to expect a level of intermedia control that would follow a pollutant through its entire cycle is something for the much more distant future. As far as the acid rain problem as it affects the pH of aquatic environments and forests is concerned, there is serious question as to whether the sulfur sources for the types of acid rain that have been experienced in Scandinavia are in fact transported long distances as was originally hypothesized. It seems more likely that a much larger percentage than was anticipated is of law-level local origin. So the problem is the necessity to control the massive sulfur coming from a large number of low-level sources, as well as what we previously thought was the principal problem of long distance transport from tall stacks.
Is our knowledge of regional climatic and meteorological conditions sufficient to be able to predict the dispersion pattern of a pollutant? There are many unanswered questions, particularly those having to do with the transformations that occur. Most of our efforts to date have been on the atmospheric photochemistry of the hydrocarbons, and we haven't. done an equivalent amount of work on the atmospheric photochemistry of the sulfur oxides. One of the thing!; that will be discussed at the Gordon Research Conference: Environmental Slsiences-Air, in August will be the statue of our knowledge of the transformation processes as they convert materials from the gaseous phase to liquid end solid phase particles. But, I don't think that the kind of information that we do have contraindicates the use of 1:all stacks as a means for pollutant dispersal. Since C 0 2 can affect earth's climate dramatically, are you concerned that our regulations niay have overlooked the very thing that may kill us? If there is to be any beneficial effect whatsoever from the recent energy crisis, it is the awakening to the fact that there is a limit to the amount of fossil fuels that we have available to us, and there is a need to get enerciy from sources other than the burning of fossil fuels. This beneficial effect may be a curtailment of the rate of intrcrducing Con to the atmosphere. We most likely will see that in the future, way beyond my lifetime, the trend will change from increasing
CO2 to a leveling off or decreasing as we generate more of our energy from noncombustion sources. I don't think that this time interval is sufficient to make the difference between our existing or not existing as a people.
Do you foresee legislation that might regulate total emissions regardless of how clean the emissions are? I don't think that we have a body of evidence on which to base any restriction on total fuel combustion. We don't have the means to equate the burning of a certain amount of fuel with a change of so many degrees in the temperature of the earth, and we have other factors at work such as the increase in particulate matter in the atmosphere.
TECHNOLOGY
Is stack gas scrubber technology reliable enough to justify EPA's insistence on its use by utilities? I actually don't believe that this should be the criterion. Even if it were to be conceded that scrubbers were completely reliable, I don't think that this is the sole argument for not utilizing the dispersive properties of the atmosphere when they can be so used. In my opinion we should rely upon dispersion through high stacks to the extent that the atmosphere can assist us and, of course, not go beyond the point where there will be an adverse buildup of levels of pollutants. With tall stacks, you're really not getting rid of the pollutants you're just dispersing them aren't you? We have ongoing chemical reactions in the atmosphere, many of them we don't understand. But we know that the net result of these reactions is to cleanse the atmosphere. So I don't think that we can take an a priori position that anything that is objectionable at the time it is put into the air will remain objectionable for time immemorial. The objectionable materials, by and large, are converted into relatively innocuous materials in the atmosphere, and we have been genetically bred to live with these materials. If we find that the materials are not innocuous then we have to take special precautions. Since fine particulate matter ( < 3 p ) may present a health hazard, are present measurement methods and control devices adequate? The size range of the mix of the particles in the atmosphere is dynamic. We add small particles to the atmosphere, they grow and eventually leave the atmosphere by various sedimentation and scavenging processes. So that the size range of particles that people breathe, and that
Stern speaks out. After 20 years, assessment of the Clean Air Act shows that the U.S. did more things Right . . . 0
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expanded the definition of concern to include public health and welfare extended to those administering the Act the choice of methods to accomplish their responsibiitbs channeled the federal effort into buiWing up state and focal ak po#utkm control capability separated federal financial assistance to state and bcal agencief, into specific types of program grants opened air potlotion eKHlrc%sto inspection and monitoring nationally mandated federal jurisdiction over air pollution from the automobb and airplane permitted citizen suits against actions taken or not taken under the Act established a national system of new sour- performance standards for stationary sources
Than Wrong. . . adopted the air quality management approach instead of best practicable means of control approach specified the extent of and dates for the reduction of auto emissions, as well as dates for abatement of pollution from all sources set up a system of primary and secondary air quality standards instead of a single standard specified the steps the EPA administrator must foUow from the issuance of a criteria document to the promulgationof a standard made land use planning subsidiary to air pollution control regulations ignored, then overreacted, to the energy implications of the control requirements
plants are exposed to and that damage materials has a tremendous uniformity to it regardless of how we inject the particles into the atmosphere. All that one can show is that there is only a certain size range of particles that is fully respirable into the lungs. This size range is going to bear the same relationship to the size range of particles in a dynamic atmosphere that it always has in the past and that it will for long times in the future. So again, I don't think that we are going to greatly change that by devising better means of preventing the emission of fine particles to the atmosphere. I don't know that there will be any demonstrable improvement in the effects of atmospheres on people, plants and things by having a better fine particulate matter removal technology than the best that we have today. Thus there need not be that great a drive to push the improvement of technology for very fine particle removal. Volume 9, Number 6, June 1975
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"I believe that the American public has been forced into expenditures of literally billions of dollars to provide more control than is necessary on the automobile. " Arthur C. Stern
ECONOMICS
MODELS, HEALTH
Under present economic conditions and with our near-term reliance on imported oil, can the U.S. afford to comply with deadlines 01 the Clean Air Act? I don't think t k present economic situation should be used as the reason to relax standards. Part of my issue with the present Clean Air Act is the inclusion of specific deadline dates and, for the case of the automobile, specific numerical percentage reductions. I believe that these should be lefl to the discretion of the administrator rather than be embedded in the Act. I don't favor air pollution iegislation that has numbers in it for emission limits, percentage reductions, or dates. I believe that these are more properly left to the discretion of the administrative agency.
D O you feel that the objective of the
Do you agree with Lee lacocca, the president 01 Ford Motor Co., that the American car buying public will have l o expend several billions of dollars to implement 1978 standards that are unjustiliable since there is a lack of scientific agreement on the health effects? I was the chairman of the panel on standards of the Committee on Motor Vehicle Emissions of the National Academy of Sciences and we issued two reports, one a critique on carbon monoxide and hydrocarbon automotive emission standards, and the other on the oxides of nitrogen standards. In both instances, the panel felt that the automotive emissions standards were too severe by a factor of about three to accomplish their intended purpose. I believe that the American public has been forced into expenditures of literally billions of dollars to provide more control ' than is necessarv on the auton "
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Environmental Science 8 Tt
St. Louis Regional Air Pollution Study (RAPS) l o develop improved air quality simulation models will be met? I'm in strong support of the Regional Air PoIIutlon Study (RAPS) in St. Louis because we need to validate the models that we're using if we are going to continue to use such models in pursuing air pollution control in the US. And even if we move to another strategy, we still will need to have good models in order that specific situations may be computed. I have every reason to believe that the St. Louis study will produce validation of the models we are using, or else changes in the models as the data show that they cannot be validated. IS lead in gasoline a public hazard? The National Air Quality Criteria Advisory Committee, of which I am a member, has on two different occasions requested the administrator of EPA to develop and publish an ambient air qualiy standard for lead. The Committee is of the belief that until there is such a standard, there is no rational basis for the administrator to regulate the amount of lead in gasoline. This a i m has been the position taken by the courts. The administrator's first proposal to regulate lead in stationary sources was to regulate the total particulate emissions from stationary sources without any mention of lead whatsoever. It is my personal feeling that he did that because he didn't have an air quality standard for lead, and he did have one for total particulates. And, therefore, faced with a real need to put limits on lead emission from stationary lead sources, he went around the barn and through the back door to try to do it. So that, i been my position that before
the administrator can rationally set limits on lead emissions from sources he should have an air quality standard for lead. But, this air quality standard does not necessarily have to be an ambient standard, it can be a deposited matter standard.
ENVIRONMENTAL EDUCATION How does a developing country balance industrialization with concern about maintaining a good quality environment? I am involved with an AID1 UN-funded program here at the University of North Carolina, the "International Program in Environmental Aspects of Industrial Development," to train policymakers of foreign nations on the environmental effects of industrialization. One of the first things that we tell students is that they have to establish priorities within their own cultural framework, and their own local situation. If feeding the population, housing them and other things have a higher priority than protecting the atmosphere and species, then they take precedence. We then try to tell them that within this priority scale, problems will arise-effects on the air, on water, on soil, effects of noise and transportation, impaction of schools, and all the other things that may occur-when you industrialize an area. Again, when discussing control technology, we tell them to adapt technology to their own scale of activities. You don't try to bring equipment and instruments into a system where there is not the ability to service, maintain and keep them in operation. Two years ago we had a group of 30 foreign students in this program, and we have another group of 30 here right now.
