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The City Club of Cleveland

Carol M. Browner
Administrator, U.S. Environmental Protection Agency

Remarks Prepared for Delivery
The City Club of Cleveland

Cleveland, Ohio
March 25, 1997

Thank you, Art Brooks, for that introduction.  It is a special privilege to be back here in Cleveland at the City Club.

Over the past quarter century, America has made great progress in protecting the public health and the air, the water and the land that we all share.  And over the past four years, President Clinton and his administration have accelerated this progress.

We have made these strides because together, as a nation, we have insisted that the public health be protected -- and because businesses, communities and public agencies have worked to meet the health standards we have set.

As just one example, the air in the Cleveland metro area is cleaner than it once was.  It now meets federal public health standards.  And this community -- its industries, its leaders, its people -- deserves nothing but the highest praise for getting the job done.

Which brings me to the question I would like to address today:  “Where do we go from here?”

Do we rest on our laurels?  Do we stand pat?  Do we say that, because we are making progress, there is no need to revisit our clean air public health standards, no need to reassess them in light of any new scientific findings, no need to ensure that they are adequate to protect the public health?

As it happens, the law does not allow us to do that.  Rather, it requires us to review all adopted air quality standards to ensure that they are supported by the best available science and that they provide an ample margin of safety for the public’s health.

Many of you know that EPA is proposing to strengthen the national ambient air quality standards for particulate matter and ground-level ozone -- better known as soot and smog.  We know from the best, current science that strengthening the ozone standard as we have proposed would protect nearly 50 million more Americans from the adverse health effects of smog -- 13 million of whom are children.  And the new standard we proposed for particulate matter would result in 20,000 fewer premature deaths, a quarter-million fewer cases of aggravated asthma, another quarter-million fewer cases of acute respiratory problems in children and 60,000 fewer cases of bronchitis -- each year.

This is what the science has shown us.  That’s why we have proposed to strengthen the standard.  And that is what we have been receiving comments on.

Some in industry and some in public office have vigorously objected to our proposal.  A lot of money is being spent by some in industry on campaigns to convince members of Congress and the American public that these standards are not necessary, that they would impose unreasonably high costs on business, and that they are based on unfounded science.

I assure you that we welcome honest debate on these proposed standards.  We welcome legitimate expressions of concern by those who believe they will be affected by the proposed revisions in the air quality standards.  Everyone should have their say.  In fact, just recently, we closed the most extensive scientific review and public outreach process ever conducted by EPA for developing a public health standard.  All submitted comments will be considered, and our final decision will obviously reflect what we received during the comment process.

But some, I’m afraid, have gone beyond the pale -- branding EPA as “extremist” and using scare tactics about intolerable lifestyle changes that these proposed standards would force on the American people.

What they haven’t talked about is the public health and how to protect it.

And that brings up some interesting questions:  Where matters of public health are concerned, how much weight should be given to vested interests?  How much say should industry have in the setting of air quality standards?

Fortunately, the Clean Air Act provides some answers.

Born under President Nixon, amended and strengthened under Presidents Carter and Bush, the Clean Air Act is the embodiment of an ongoing, bipartisan desire to protect all Americans from the harmful effects of breathing polluted air.

From the beginning, the Act has contemplated the march of technology and science.  It has recognized that science will always come up with better ways to understand the health effects of the air we breathe -- and that the standards of the 1970s may not be right for the 21st Century.  And it anticipated that some in industry -- some with vested interests in the status quo, some that may not want to reduce their pollution of the public’s air -- might not agree with the conclusions of the scientific and public health communities.

Therefore, Congress set forth a process to ensure that the standards would be set and, if necessary, revised in a manner that puts the public health first and ensures that Americans are protected with an adequate margin of safety.

First, the Clean Air Act directs EPA to review the public health standards for the six major air pollutants at least every five years, in order to ensure that they reflect the best current science.  It also lays out a specific procedure to obtain that science and, if needed, revise the standards.  This is to ensure that we never get to the point where the government tells Americans that their air is healthy to breathe, when, in fact, it is not.

Next, the process requires that EPA’s standard-setting work and the underlying health studies -- some 250 of them in this case -- be independently reviewed by a panel of scientists and technical experts from academia, research institutes, public health organizations and industry.  The ozone and particulate matter scientific panels, over a four-year period, conducted 11 meetings, all open to the public -- a total of 124 hours of public discussion of the scientific data, research and the studies of the health effects of smog and soot.

EPA has held further public meetings, at which hundreds of representatives from industry, state and local governments, organizations -- as well as members of the public -- have offered their views.  The public comment period ended two weeks ago.

We are now in the process of analyzing and considering the submitted comments and, after doing so, we will set final public health standards.  Congress then has its say and may vote up-or-down on EPA’s health standards.

As many of you know, members of Congress have been watching this process very closely.  And Congress does have a review process for these kinds of regulations.  It is a good process -- as long as it is carried out responsibly, looks at all the facts, and judges them in the best interests of all Americans.  When looking at these air standards, I hope Congress will review all of the scientific analysis.  I hope they will study the entire body of evidence.

EPA did look at the evidence -- all of it published, peer-reviewed and fully debated health studies -- literally peer review of peer review of peer review.  The independent scientific panel looked at it, too.  And the conclusion is that the current air standards are not adequately protecting public health and that they should be revised.  Serious health effects are occurring in children, the elderly and other sensitive populations at particulate matter and ozone concentrations at and below existing standards.  So that is why we have recommended strengthening those standards.

Some have said that we are “changing the rules” and “moving the goal posts” in the middle of the game, after so much progress has been made.  But nothing could be further from the truth.  Over the history of the Clean Air Act, the goal is -- always has been and always will be -- clean air.  Nothing in that has ever changed.

What has changed is the science -- which is forever bringing advancements and innovations to improve the quality of our lives.  Science now tells us that our air pollution standards are not adequate to protect the public’s health -- that the current standards leave too many at risk -- and that EPA has proposed to tighten those standards in order to ensure that we are being truthful with the American people about the quality of the air they are breathing and what it is doing to them.

Take the case of Lake County, here in the Cleveland area.  Two summers ago, there wasn’t one day that Lake County did not meet the current federal standard for smog.  But there were 21 days on which the citizens of Lake County were exposed to smog levels that the best available science now tells us were damaging to human health.  And if we don’t revise the standards to reflect the best, available science, the very same thing could happen this coming summer -- Lake County air could be damaging to human health and we won’t be telling anyone the facts -- we won’t be telling anyone the science as we know it.

How damaging?  Let me give you some compelling examples of what recent studies have shown.

Simply put, smog aggravates asthma and other respiratory ailments, and causes temporary decreased lung function of up to 20 percent in healthy people.

One recent study showed large increases in hospital admissions when smog levels were up.  Even on days when smog levels were at or below the current U.S. standard, nearly one in three hospital admissions for respiratory problems were linked to smog.  On high pollution days, smog was associated with about half of all respiratory admissions.

Another study found that non-smoking men and women living in areas with relatively high levels of smog had more than half the lung damage of a pack-a-day smoker.

Still another study indicates that healthy young adults engaging in routine construction work outdoors will experience significant breathing problems at ozone levels equal to the current standard.

And a study of active children at an outdoor summer camp found consistent loss of lung function at a below the current ozone standard.

For particulate matter -- soot -- studies have consistently found a correlation between this pollutant and early death.

One extensive study, by the American Cancer Society, tracked a quarter-million Americans and found that the risk of early death is 15 to 17 percent higher in areas where levels of fine particulates are highest.

Another study, published in 1993 in the New England Journal of Medicine, showed that exposure to fine particulates in the air increases the risk of early death by 26 percent and, in the most polluted cities, shortens individual lives by an average of one to two years.

And a study in Birmingham, Alabama, showed that air with higher soot levels was directly associated with higher numbers of elderly people going to the hospital for respiratory and cardiovascular illnesses.

Let me give you some other facts:

Lung disease is the third leading cause of death in this country -- killing an estimated 335,000 Americans each year.

Asthma is the most common chronic illness in children.  Nearly five million kids have it, along with nearly 10 million adults.  Asthma is now the leading cause of hospital admissions for children.  And deaths from asthma attacks among children and young people more than doubled between 1980 and 1993.

In 1993 alone, asthma killed 342 Americans under age 25 and sent nearly 200,000 for a stay in the hospital.

No less than the American Academy of Pediatrics has recommended that pediatricians make parents aware of the daily variations in ozone and -- when ozone levels are high -- keep their kids indoors.

Is this the kind of future we are willing to accept?  Knowing what science is telling us about the quality of our air, do we just throw up our hands and say that we’ve done enough?

Do we accept what one industry lobbyist recently was quoted as saying by a national magazine -- that people can protect themselves from smog by avoiding jogging and keeping asthmatic kids from going outdoors and riding their bicycles?

Do we simply give up on our quest for cleaner, more healthy air and just keep prescribing steroids to children with asthma?  That’s a common treatment, you know.

As a mother, and as the administrator of the agency charged with protecting public health and the environment, I cannot accept such a future.  I don’t think anyone should.

These are the facts as we now understand them, and Congress needs to take them into account when it reviews EPA’s standards.  On this vital public health issue, the nation deserves that Congress listen to medical doctors, not spin-doctors.

As for the costs of these standards, let me say that we do consider costs.  We take our responsibility to do that very seriously.  But the law does not, and should not, allow us to consider costs at this critical public health stage of the process.  The Clean Air Act clearly requires levels of smog and soot to be based solely on health, risk, exposure and damage to the environment, as determined by the best available science -- and not projected costs for reducing pollution.

This is no accident.  In the 1970 Clean Air Act debate, Congress deliberated the issue of cost -- as well as the technical feasibility of meeting clean air standards.  At the time, there was a great deal of frustration that putting cost considerations first was preventing any real progress toward cleaner air.

Thus, the decision was made -- the public health must come first.  The current best science must prevail in determining the level of protection the public will be guaranteed.  Nothing else can take precedence.

This issue has been revisited each time the Clean Air Act has been amended -- in 1977 and again in 1990.  And, each time, Congress and the President have come down firmly on the side of the public health first and foremost.  That has been the history for the past quarter-century.

Not only does the law forbid us from considering the costs in setting these standards, but history and real experience tell us we’d be foolish to try.

Almost every time we have begun the process to set or revise air standards, the costs of doing so have been grossly overstated -- by both industry and EPA.  Dire predictions of economic chaos -- always a part of the clean air debate -- have never come to pass.

Why?  Because industry always ultimately rises to the challenge -- again and again -- finding cheaper, more innovative ways of meeting standards -- and lowering their pollution.

Can it be done again?  Of course it can.

Like administrations before us, we believe that environmental protection should build upon the ideals that have long made this country great -- our creativity, innovation, ingenuity.  The system must do more than just seek the minimum -- it must demand the best.  It must reward those willing to do more than just an adequate job, to go further, to push the envelope, to provide the strongest possible protections, to prevent pollution.

That doesn’t mean that there is no role for the practicalities of attaining these protections.  There is such a role when it comes to implementing the standards.  In that case, it certainly is appropriate to weigh the costs, industry by industry, of reducing pollution -- allowing us to find the most-effective solution.  If these new standards are adopted, EPA will work with all who are affected  -- state governments, local governments, community leaders, businesses large and small  -- to find cost-effective and common sense strategies for reducing pollution and providing the public health protections.  That is part of the process, too.

Working together, we can have cleaner air and not sacrifice our economic vitality.  We’ve done it before.  Since 1970, emissions of the six major air pollutants have dropped by 29 percent while the population has grown by 28 percent and the gross domestic product has nearly doubled.

Economic growth and cleaner air.  Now that’s a level of progress we can all be proud of.  You can thank good old American ingenuity for that.  Time and time again, American industry and the American people have risen to the challenge of cleaner air.

So as the debate over air standards rages on, I would ask that you ask yourselves the following question: “Have we reached the point where we should abandon our commitment to a public health standard for air pollution?”

I believe the answer is no.  Americans want clean air.  They want the public health to come first.  They want their children protected.  They want EPA to do its job -- which is ensuring that the air they breathe is safe and healthy.  They want government to be honest about when the air is unhealthy.  And they have every right to expect that industry will rise to the occasion, meet the challenges, and once again reduce their pollution of the public’s air.

Clearly, this is a vital issue of tremendous importance to millions of American families.  And I think that, in this debate, we all have a responsibility to stick to the facts.  No more scare tactics.  The public health is too important to be decided on trumped up, exaggerated charges put forth by some in industry who might be required to take steps to reduce air pollution.

Let us listen to science.  Let us respond as we have before.  Let us work together toward common ground -- not only on this particular issue, but on all environmental and public health issues -- to improve the quality of the air we breathe, the water we drink and the land on which we all live.

Let us do it for our children.

Thank you, and I am happy to answer your questions.