The New York Times today ran its second editorial scolding the Obama Administration for its decision to delay a tightening of ozone standards in response to a lengthy article by John Broder who exhaustively detailed the big players in this decision and their thought processes. Though there are critiques of the science behind the evidence of harm from ozone concentrations of ~75 parts per billion, I’d like to focus on an outcome of the ozone tightening that the NYT implies is nothing but an industry talking point:

This page was not impressed by those arguments then and is no less skeptical of them now in light of John M. Broder’s exhaustive account in The Times on Thursday of the steps that led up to the decision. The article paints a picture of an aggressive campaign by industry lobbyists and heavyweight trade groups like the American Petroleum Institute that began soon after it became clear that Ms. Jackson was determined to tighten the rules governing allowable ozone levels across the country.

The standards governing ozone — the main component of harmful smog — are supposed to be set every five years. But because the standards proposed by the Bush administration in 2008 were seen as inadequate by the scientific community and had been challenged in court, Ms. Jackson decided to set her own standards, tough but achievable. Their health benefits would approximate their costs, and they would not begin to bite for several years, giving industry time to prepare.

Until the very last moment, she believed that Mr. Obama would go along. But as The Times’s article made clear, she had very few friends in the White House and many opponents — not least William Daley, the president’s chief of staff, who had been incessantly lobbied by business and by state governors fearful that the rules would cost jobs.

In one telling moment during internal negotiations, E.P.A. experts laid out the numbers on the lives that would be saved and the illnesses avoided by the proposed rules. At which point, Mr. Daley asked: “What are the health impacts of unemployment?” — a question the article describes as “straight out of the industry playbook.”

The editorial may leave the casual reader with the impression that this is yet another industry talking point pulled right out of thin air. As it turns out, sometimes the industry playbook contains a grain of truth, or in this case several grains. There is significant evidence that losing your job can lead to short and medium term impacts on your health, indeed some that the NYT has reported on in the past:

Though it’s long been known that poor health and unemployment often go together, questions have lingered about whether unemployment triggers illness, or whether people in ill health are more likely to leave a job, be fired or laid off.

In an attempt to sort out this chicken-or-egg problem, the new study looked specifically at people who lost their jobs through no fault of their own — for example, because of a plant or business closure.

“I was looking at situations in which people lost their job for reasons that…shouldn’t have had anything to do with their health,” said author Kate W. Strully, an assistant professor of sociology at State University of New York in Albany, who did the research as a Robert Wood Johnson Foundation scholar at the Harvard School of Public Health. “What happens isn’t reflecting a prior condition.”

Only 6 percent of people with steady jobs developed a new health condition during each survey period of about a year and a half, compared with 10 percent of those who had lost a job during the same period. It didn’t matter whether the laid off workers had found new employment; they still had a one in 10 chance of developing a new health condition, Dr. Strully found.

David Williams, a professor at the Harvard School of Public Health who was not involved in the research, said the study is a reminder that job loss and other life stressors have a tremendous impact on both mental and physical health and contribute to the development of chronic conditions.

Common sense, while not always the best heuristic, would seem to support the idea that unexpected job losses can cause negative health outcomes. Industry has estimated that the ozone rule would have caused a significant number of job losses. Even if you assume their estimate is wildly pessimistic, I think it is clear to all that shutting down power plants while unemployment is very high can lead to unemployment and those individuals won’t be able to immediately find new jobs.

The Environmental Protection Agency sprang two surprises last week. First, EPA asked a federal judge to allow them to delay issuing the boiler MACT (Maximum Available Control Technology) rule until April 2012, which would give EPA time to reconsider and rewrite the proposed regulation.  The rule is designed to cut air pollution from approximately 200,000 industrial boilers, process heaters, solid waste incinerators, etc.  Industrial users of boilers have made a good case that the proposed standards were going to be impossible to meet in many cases.

Next, EPA announced that the ozone or smog rule would be delayed until July 2011, while it reconsidered the scientific and health studies on smog’s effects.  The announcement suggests that EPA has bowed to intense opposition from Congress, state and local governments, and industry and is now going to re-write the smog rule so that it is less economically catastrophic.  EPA nonetheless is going ahead with regulating greenhouse gas emissions from major stationary sources on January 1, 2011.  There is little reason to think that those regulations are any less damaging than the smog rule.

The EPA also announced last week that it was holding its second National Bed Bug Summit meeting in early February. You may laugh, but at least with bed bugs EPA is addressing a real environmental health problem.

A recent study by the Manufacturer’s Alliance/MAPI finds that EPA’s proposed revision of the “primary” (health-based) national ambient air quality standard (NAAQS) for ozone would have devastating economic impacts, such as:

• Impose $1 trillion in annual compliance burdens on the economy between 2020 and 2030.
• Reduce GDP by $687 billion in 2020 (3.5% below the baseline projection).
• Reduce employment by 7.3 million jobs in 2020 (a figure equal to 4.3% of the projected labor force in 2020).

In a companion report, the Senate Republican Policy Committee estimates the job losses and  ”energy tax” burden (compliance cost + GDP reduction) each State will incur if EPA picks the most stringent ozone standard it is considering.

The costs of tightening ozone standards are likely to overwhelm the benefits, if any, as Joel Schwartz and Steven Hayward explain in chapter 7 of their book, Air Quality in America: A Dose of Reality on Air Pollution Levels, Trends, and Health Risks. 

So let’s see — we have emission regulations that function as de-facto energy taxes, and the costs far outweigh the putative benefits. Sound familiar? The resemblance to Waxman-Markey is more than superficial, because if stringent enough, air pollution regulations can restrict fossil energy use no less than carbon taxes or greenhouse cap-and-trade schemes.

For more information on EPA’s proposed ozone NAAQS and the MAPI study, see my post today on CEI’s Open Market.Org.