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OCR for page 3
Automotive Emissions
Research
DONALD KENNEDY
Stanford University
THOMAS P. CRUMBLY
Health Effects Institute
We must notforget the policy objective behind
auto emission regulations to protect the public
health. Short-term tactical battles over standards
cloud much more fundamental issues- namely,
will reduction of auto pollution actually improve
ambient air quality significantly, and will better
air actually improve public health? These ques-
tions have not yet been answered satisfactorily.
Rep. David Stockman
Harvard University
October 19, 1978
Emissions Control: The
History of Conflict
The United States has had laws to control
air pollution for the past 30 years. Since the
passage of amendments to the Clean Air
Act in 1970, our society has made an heroic
effort to reduce automotive emissions, as
one cornerstone of an overall air pollution
control policy. And as a result of these
laws, we have, in fact, seen major reduc-
tions in several pollutants. Some of the
Air Pollution, the Automobile, and Public Health. ~ 1988
by the Health Effects Institute. National Academy
Press, Washington, D.C.
3
benefits of control are obvious: in parts of
the country, the air is noticeably cleaner;
and with recent improvements in many
. . .
inspection anc maintenance programs,
fewer cars will present gross problems that
lead to emissions beyond current standards.
The costs of this control have also been
great and not only in terms of dollars
expended by taxpayers, stockholders, and
car owners. Throughout the 1970s, our
efforts to make meaningful emission reduc-
tions and to ensure that these reductions
were carried out provided difficult tests for
some in our society. For a time, perceived
attempts by some car companies to resist
regulation brought the industry into disre-
pute with much of the public. In addition,
the Clean Air Act amendments raised ex-
pectations that have not yet wholly been
achieved.
With the advantage of nearly two dec-
ades of hindsight, it seems indisputable that
the 1970 law was an important exercise in
symbolic politics. The car companies had
permitted themselves, one could argue, to
be cast as forces of evil. The Congress,
responding to the burgeoning environmen-
tal movement so well symbolized in the
Earth Day of that year, seized the high
moral and political ground as a way to
transform a policy situation that had be
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4
The Social Context of Automotive Emissions Research
come increasingly unsatisfactory. The
Congress overwhelmingly enacted stan-
dards and mandated pollutant reductions
that would protect the public and provide,
in the words of the statute, an "adequate
margin of safety," for all people-includ-
ing particularly sensitive populations. The
Congress further empowered the presi-
dent, now acting through the new Envi-
ronmental Protection Agency, to take
strong enforcement action against compa-
nies and states that did not comply with
tough timetables for action. The struggle to
meet these new standards in a timely way
led, at various times during the 1970s, to
threats by major corporations to shut
down, and to governmental plans for state
compliance that seemed to many as exer-
cises in futility. In the eyes of many citi-
zens, the reputations of government as well
as industry suffered during this period.
Benefits of Regulation
Have the dollars, antagonisms, and lost
credibility been worth the benefits our so-
ciety has derived from mobile source reg-
ulation? Should we continue to control a
major sector of the economy in the same
way? Should we continue to explore alter-
native methods of regulation, such as emis-
sion fees, that have always proven politi-
cally unacceptable in the past? The answers
will only be found by assessing the benefits
we have already achieved, and in looking at
what might be achieved in the years ahead.
We need to see whether we are achieving
the fundamental purposes of the Clean Air
Act. Are we adequately protecting the pub-
lic health? In particular, are we meeting the
special needs of the old, the young, and
those already compromised by disease pro-
cesses or by other biological processes
that we are only just beginning to under-
stand?
In the early days of program implemen-
tation, the answers to these questions
seemed easy. Anyone familiar with the
famous London fog of 1952 that ultimately
killed 4,000 people, or with the "incident"
at Donora, Pennsylvania, in which another
48 people died, knew that air pollution at
high levels causes disastrous health prob-
lems. We also knew that automobiles were
significant contributors to the air pollution
problem because of seminal work done in
the Los Angeles basin. On any hot day in
Washington in the late 1960s, the Senate
Environment and Public Works Commit-
tee knew without asking that automotive
emissions just could not be good.
The initial results of control were visible.
Air pollution alerts decreased (independent
of any changes in how these alerts were
defined), and auto emissions came down.
Hydrocarbons, carbon monoxide, and ox-
ides of nitrogen have all been significantly
reduced. After much struggle, we have also
made considerable progress in reducing
lead emissions from autos. In noteworthy
contrast, we have not sought to control
heavy-duty truck and bus emissions until
more recently because of energy concerns.
Accordingly, many of us still complain
bitterly about these emissions, especially if
we are behind a vehicle that is not well
malntalnec ,.
Current Problems for
Motor Vehicles
The air is cleaner. Not surprisingly, as
progress was made, public pressure about
motor vehicle emissions declined. Because
of the determined efforts of many scientists
and environmentalists, the leaded gasoline
issue has retained a high profile, and the
government took strong action during
1985. Ozone control is still a vexing prob-
lem, from both a health and an environ-
mental perspective, and no strategy for
control is without substantial practical
problems for industry or state and local
governments. Inspection and maintenance,
and associated tampering, also appear on
the public agenda from time to time, and
we have not yet fully explored the health
ramifications of the diesel engine.
For the most part, however, other air
pollution and environmental issues have
displaced mobile sources at the top of our
environmental policy agenda. Problems of
hazardous waste, radon, acid rain, and pes-
ticides now seem more pressing. This is no
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Kennedy and Grumbly
5
sign of failure, but of success, despite the
presence of a revisionist movement that
castigates the efforts at emissions control as
a case of regulatory overkill.
But, to paraphrase the famous question
from another context, "What do we know,
and when did we know it?" A variety of
commentators concerned about control
policy, regardless of their political persua-
sion, quickly dispose of the science of the
health effects of auto emissions, citing the
inherent problems of dealing with uncer-
tainty in assessing benefits. Science in this,
as in some other policy arenas, often seems
like the poor cousin- one to be quickly
introduced and just as quickly sent away,
lest the rest of the family be embarrassed.
This treatment is often meted out by law-
yers, economists, and various other profes-
sionals who somehow assume that the rest
of the risk assessment/risk management
. . .
equation IS more certain.
The hard fact still is, of course, that we
don't know how successful our air pol-
lution and motor vehicle emission con-
trol policies are from a public health per-
spective. Stockman's question at the open-
ing of this preface is still the relevant one.
We have reduced acute health problems
through our regulation, but we cannot be
sure how much. We know that the policies
have had effect, but we cannot assume that
biological damage reduction is proportion-
ate to pollution reduction, particularly as we
learn more about biological systems. And all
of our modes of analysis, whether they in-
volve experimentation with people or ani-
mals, epidemiology, or in vitro laboratory
work, are still imperfect. Given the compar-
ative expenditures in control technology and
relevant environmental health research, how-
ever, it is surprising that we know so much
about the health benefits of air pollution
control. There is obviously nothing we can
do about past policy, but a great deal that we
can do about policy for the future.
Importance of Continuing
Health Research
The question inevitably arises about the
value of additional expenditures to find out
whether auto emissions and other air pol-
lutants are, in fact, risks worth worrying
about. Even if we take it for granted that
current emission control regulations have
reduced the most serious acute health ef-
fects problems, why is research still impor-
tant? The answers flow directly from the
social context as we just described it.
Regulations: Form or Substance?
If it is true that the structure and some of
the imperatives of the current Clean Air
Act sprang significantly from an exercise in
"symbolic politics," that is, a political sit-
uation in which positive societal action
required the construction of a stage on
which good and evil played clearly defined
roles, then it is now important to see
whether rational inquiry conducted in a
less-heated time supports the symbols.
This is important not only as an exercise in
political science and evaluation, but as a
step in rebuilding a base of public trust. We
Americans are just now emerging from
two decades of internal conflict. Perhaps
we now have the luxury of reexamining the
choices we made in more turbulent times.
And, as a matter of the continuing credi-
bility of the government, the need for
intellectual integrity alone justifies a con-
tinuing examination of the reasons we have
undertaken a cleanup costing billions of
dollars. We need to see if our past choices
were right or just expedient.
7
Safety Margins and Susceptible Groups
The Clean Air Act is quite specific in
setting out the need for adequate margins
of safety in establishing standards. The
debate in the Congress, and subsequent
reports from the relevant congressional
committees, also makes it clear that these
safety margins need to take into account
so-called susceptible populations. Neither
in the statute nor in the legislative history is
the concept of susceptible populations ade-
quately described. The courts and policy
makers are left to their own devices in
interpreting the term. From a standard-
setting process, then, identifying and deal-
ing with groups of people who may be
either more susceptible to disease from any
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6
The Social Context of Automotive Emissions Research
given dose of pollutant, or who begin to
exhibit "health effects" at levels below
those seen in the general population, are
critical. Indeed, it can be said to drive the
regulatory system with respect to criteria
pollutants, and it can only be dealt with
through continuing research.
Complicating the problem, of course, is
that the current "revolution in biology"
was not envisioned by the framers of the
amendment. Accordingly, we are develop-
ing a range of techniques that can show,
even at the subcellular level, the effect of a
particular dose of toxic pollutant. We do
not, however, yet know how to translate
much of this knowledge into terms that can
help us quantify risk. But to leave the
science at its current stage of development,
or simply to leave to chance its capacity to
generate information that can help regula-
tion, would be to hinder the regulator in an
already difficult task. Accordingly, this
commandment to seek out and deal with
susceptible populations forms a fundamen-
tal scientific driving force in the implemen-
tation of the Clean Air Act.
Costs and Benefits
From a practical perspective, it is important
to understand whether additional invest-
ments by taxpayers and consumers are nec-
essary to further reduce emissions of the
so-called criteria pollutants. Many econo-
mists (including those with biases toward
environmental regulation) now believe that
we are in a condition of declining marginal
benefits for each dollar invested, and that
we have been in this condition for some
time. If that is right, then our society
should be thinking hard about reallocating
motor vehicle emission control dollars to
other problems in risk reduction where the
return will be greater. The only practical
way to approach this issue is through re-
search investments designed explicitly to
quantify the risks to human health from
pollutants at levels that approximate cur-
rent use, or that are likely to exist without
additional control in the next decade. That
this research investment has not already
been made is undoubtedly a function of
several things. These include the absence of
the scientific tools with which to make
major progress, and to put the matter
plainly the reluctance of government and
industry to move the issue away from
symbolism and into reality. Fortunately,
the tools are being developed, and as we
describe below, the attitudes of many for-
mer combatants seem to be changing for
the better.
We would not argue, of course, that
uncertainty about risk can ever be elimi-
nated through science. To say this, how-
ever, is different from saying that we can-
not reduce uncertainty into the range in
which rational policy makers could have
more confidence in their control and re
. . .
source Recisions.
Emergence of a New Regulatory
Structure in Mobile Source
Emission Regulation
The 1970 Clean Air Act amendments di-
rected special attention to a particular
group of pollutants, the so-called "criteria
pollutants." Given the technology of 1970,
this was arguably appropriate. Atmo-
spheric chemists and biologists have
known for some time, however, that our
approach to understanding and controlling
air pollutants, including motor vehicle
emissions, is too simple. Not only are
many more products actually emitted than
are currently controlled, but atmospheric
and biological reactions multiply signifi-
cantly the numbers and the complexity of
the ultimate pollutants that hit the "target"
organ. We say this not to downplay the
need to control "criteria" pollutants, but to
emphasize the importance of using those
parts of the law that focus on noncriteria or
"unregulated" pollutants. We live in a
world of complex chemical mixtures, and
new technology or fuels further complicate
that mixture.
For the Environmental Protection Agen-
cy, these new facts may mean that we are
about to enter an era in which the EPA
begins to look more like its older regula-
tory cousin, the Food and Drug Adminis-
tration. Because of what seemed at the time
in 1977 to be rather minor amendments to
the Clean Air Act, the EPA and the man
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Kennedy and Grumbly
7
ufacturers now have the responsibility to
determine whether new emissions or the
technologies that produce them will result
in an "unreasonable risk" to the public
health. The EPA will find itself more and
more in the classic regulatory mode of
premarket approval in an era in which
quantitative risk assessment provides the
standard of evidence. The EPA will only be
able to quantify the risk of new mixtures or
new technology in the presence of consid-
erable health research information. It will
be able to sustain its decisions only if such
research is credible within the wider scien-
tific and public policy community.
Research and Comprehensive
Risk Management
The assessment of risk through the appli-
cation of science will never be, nor should
it be, the sole criterion for decision making.
However, it seems clear that future corpo-
rate leaders and regulatory managers will
increasingly look at issues of comparative
risk in deciding how to deploy limited
resources. Just as important, it seems likely
that we are also entering an era in which we
are beginning to look at the risk of a
substance from each of its sources before
making control decisions, so that we max-
imize control in a cost-effective way and do
not transfer risks from one media to an-
other. In the motor vehicle arena, this
means looking closely at all the sources of
nitrogen oxides, carbon monoxide, partic-
ulates, formaldehyde, benzene, and other
chemicals before implementing additional
controls. The techniques to do these anal-
yses are still lacking, and research is re-
quired particularly in the critical risk assess-
ment arena.
Regulatory Credibility and the
Maturation of Toxicology
In the past several years, we have witnessed
a determined attack on what some have
called the "new social regulation," includ-
ing many areas of environmental protec-
tion. Indeed. it can be argued that a presi-
dent of the United States was elected in part
because of the success of these arguments.
, ~
This attack goes well beyond arguments
concerning the costs and benefits of any
particular regulation, and to the core of
whether much of the government's regula-
tory behavior was inherently just. Science
per se cannot deal with this latter question,
but science can narrow the argument. Over
time and with effort, science can substan-
tially reduce the uncertainties in extrapolat-
ing from animal and laboratory data to
human experience. Ironically, then, science
can change the debate from a technocratic
one to one in which we really do grapple
with the fundamental question of"how
much control and regulation do we want as
a society?"
Our ability to understand and manipu-
late basic genetic material offers the possi-
bility of radically improving toxicology. It
does this by providing ways in which we
can compare the results of traditional ex-
periments with results by some of the new
methods. That does not mean that tradi-
tional toxicology will be less important.
Indeed, we will need more chronic testing
in order to maximize the utility of some of
the newer methods such as "computer
modeling." To take advantage of new op-
portunities will require, however, the long-
term effort to bridge historic gaps between
the basic and the applied biological sci-
ences. It requires ways to bring together
scientists of a variety of disciplines under
mission-oriented banners. In short, it will
require money as well as the right institu-
tional structures.
The Health Effects Institute
and the Social Context
This preface has briefly concentrated on
some of the antagonisms, concerns, and
possibilities that surround the science and
regulation of auto emissions. The concern
about credibility and the search for an
institutional structure that could marry the
basic and applied sciences formed the fun-
damental bases for establishing the Health
Effects Institute, the institutional frame-
work from which this book has developed.
In 1979, it had become apparent that
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The Social Context of Automotive Emissions Research
health research related to mobile source
emissions needed to be organized in a dif-
ferent fashion. There was simply too
strong an adversarial tone; government-
sponsored research, especially if it was
done within the regulatory agency, was
mistrusted on the grounds that it was
aimed at regulatory outcomes, whereas in-
dustry-sponsored research was seen as di-
rected toward the exoneration of its own
products. Fortunately, realization arrived
almost simultaneously at the Environmen-
tal Protection Agency and at the automo-
tive industry. A group of motor vehicle
and engine manufacturers and Douglas
Costle, then Administrator of the EPA,
asked Archibald Cox, Donald Kennedy,
and William Baker to be the founding
Directors of a new organization called the
Health Effects Institute (HEI). It came into
being in 1981 under the Executive Direc-
torship of Charles Powers, and its research
program was launched during 1983.
The basic idea behind the HEI was sim-
ple enough. It was to solve two problems:
first, public mistrust of the sponsorship of
research on the health effects of mobile
source emissions; and second, the lack of
involvement of the best academic scientists
in that kind of research. Clearly the two
problems are related. Most scientists want
to work on interesting questions, but- all
other things being equal would prefer
that the answers yield useful outcomes.
But, where controversy and suspicion sur-
round the sponsorship and evaluation of
research, the best scientists will exercise
their option to busy themselves elsewhere.
The HEI sought to change this situation by
clearing the sponsorship of suspicion and
finding ways to reengage the interest of
first-rate people in the hope that others
would follow.
The basic concept, then, was that the
HEI would draw research resources in
equal measure from the regulatory agency
and from regulated industry. It would then
assemble groups of scientific leaders who
would elicit proposals from good research
organizations and make the awards. In that
way, public confidence in the objectivity of
the work could be established and main-
tained. At the same time, the continuing
availability of resources and credible spon-
sorship would build interest and confidence
within the research community, so that
first-rate scientific groups would be pre-
pared to make long-term commitments to
work in the area. That would further rein-
force public belief that the science could be
trusted; and so on.
The history of the HEI has, so far, borne
out these expectations. The first step was to
recruit a group of outstanding scientists for
the two committees that would do the
main work of the Institute: the Research
Committee, responsible for the develop-
ment of research objectives and the evalu-
ation of proposals; and the Review Com-
mittee, responsible for scientific peer
review of the work done. Under the re-
spective chairmanships of Walter Rosen-
blith of the Massachusetts Institute of
Technology and Robert Levy of Columbia
University, these committees have been
able to develop rosters of outstanding sci-
entists, retain them, and above all en-
gage their attention in a sustained way.
Everyone who has served on policy com-
mittees knows how difficult this last task is.
The committee flies in to the meeting site,
having (in many cases) done its homework
on the airplane; over 36 hours many prob-
lems are discussed and tentative conclu-
sions reached; and then everyone goes
home before a permanent memory trace
has been established. This mode of scien-
tific committee work, once termed BOG-
SAT (the acronym for Bunch of Guys
Sitting Around a Table), is fraught with
hazards. But the HEI committees have
largely been free of these, in large part
because of the Institute's insistence on pur-
chasing a greater commitment of time and
energy from the committee members.
In its equilibrium state, then, HEI seems
to be working. It has an annual budget of
approximately $6-7 million and over 40
research projects under contract. Only six-
teen have been completed, but that is
enough to give us confidence in the pro-
cesses of review and evaluation. The Insti-
tute is constantly being asked to do more,
or different, things; and as is usual for any
research field, priorities are constantly
shifting. It is better not to let the setting of
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Kennedy and Crumbly
priorities fall entirely to external demand,
because often the urgent preempts the im-
portant and long range, and potentially
comprehensive solutions may be missed.
By 1985 then, the Institute had recognized
that its own intellectual capital needed replen-
ishment. Accordingly, we brought together
a group of people from government, indus-
try, and academia to write and critique pa-
pers that would not only review the relevant
fields, but that would also identify ap-
proaches and a strategy that would most
likely lead to improving our risk assessment
capability. Only by improving this capability
will we ultimately be able to answer Stock-
man's opening question: What are the health
effects of emissions?
9
The noted political scientist Aaron Wil-
davsky has written, "There is no point in
having good ideas, if they cannot be carried
out." We believe that this book, far from
being some "academic" exercise in research
planning, represents another step in the
social policy context of trying to get a good
idea, that is, preventing health problems
from air pollution, to work. This book is
an important link in helping us determine
whether further control is necessary,
whether symbolic politics can be made real
in our society, and whether the public
should believe, as we do, that government
intervention, so visibly represented by
emissions regulation, can ultimately be jus-
tified by the facts.
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Representative terms from entire chapter:
air act
