On “average,” there is no air pollution

What do Chinese Communist Party air pollution officials share in common with Bush administration air pollution officials?

Resort to the rhetoric of “averages” when it comes to obscuring and excusing air pollution.

A front page story in today’s Washington Post examines the terrible air pollution in Beijing as China prepares to host the summer Olympics in 2008. This article should be read just for the sobering insights it offers into the dismal state of air pollution, its regulation, monitoring and reporting in China. But what caught my eye was this passage: Beijing officials “have refused to publicly release figures on the amount of pollutants at any given location, such as the Olympic Village or Tiananmen Square, preferring to stick with a citywide average.”

These citywide “averages,” of course, are likely to present a false understanding of the actual air quality in locations where the Olympic athletes will be competing. The article makes clear that Chinese officials are seeking to avoid the embarrassment that would accompany reports of unhealthy air quality in these locations. The article suggests that officials are starting to hint they will not honor previous pledges to shut down belching factories during the Olympic games, preferring economic growth over air quality, the health of the athletes and public, and the approval of the international community.

This should all be familiar territory for observers of the Bush administration’s air pollution agenda over the past seven years, especially as that agenda concerns coal-fired power plants. The Bush administration has offered an even more farflung version of the geographic “averaging” argument employed by Beijing officials to obscure air pollution levels across that city. Bush administration officials have argued that nationwide reductions in air pollution, on average, justify the gutting of a Clean Air Act program called “new source review” that controls facility-specific pollution levels from power plants and other industrial polluters.

The administration has issued a proposed rulemaking to effectively eliminate the new source review requirements covering coal-fired power plants. In this measure, EPA’s air program has argued that nationwide reductions in power plant emissions under a separate rulemaking embodying a pollution trading scheme, render unnecessary an independent Clean Air Act mandate to control pollution locally and regionally from individual power plants. Yet EPA itself admits that its rule would allow individual power plants to increase emissions by thousands of tons; allow hundreds of power plant units never to install pollution controls; and allow counties in dozens of states to experience overall (net) pollution increases totalling thousands of tons. EPA pooh-poohs objections that its rule will allow and invite local air quality to worsen, by observing wanly that it believes such concerns are “diminished” or “mitigated” in a system where total annual pollution is “capped nationally.”

The Bush administration resorted to a similar rhetorical deception involving temporal averaging – averaging pollution levels across time – when it was selling its ill-fated Clear Skies legislation governing power plants. The administration insisted that its legislation would reduce power plant air pollution 70% by 2018, with President Bush going so far as to make this claim in his 2003 State of the Union speech. Not true. Instead, the legislation’s cap-and-trade approaches established pollution “caps” in 2018 corresponding to 70% reductions, but EPA’s own analysis revealed that actual pollution reductions of 70% from power plants would not be achieved until some time after 2025; this was due primarily to the legislation’s emissions credit “banking” features, which allowed credits to be banked, then withdrawn and spent well beyond the 2018 cap date. EPA was misrepresenting the legislation’s rigor and timeliness by failing to highlight the temporal averaging and credit banking inherent in its chosen cap-and-trade scheme.

Now EPA just needs to pull off the trick of convincing people to breathe nationally, on average, or across time, on average, rather than in the locales where they actually live, in real time. Maybe an administration committed above all to pollution trading schemes – except when it comes to global warming pollution since, whoops, that would require capping and reducing actual pollution – could explore a credit trading regime for breathers. If someone in an area with clean air held their breath for 5 minutes, they could sell the right to breathe that healthy air in the form of a breathing credit to a resident of Los Angeles or Houston or Pittsburgh suffering from unhealthy air quality. Breathing credits could be bought and sold for the same calendar year or future years, with the time value of money and inflation affecting pricing. The market would identify the optimal price for breathing, and rational actors would stay indoors or move to different states or stop breathing based upon price signals. Credit pricing might even be affected by halitosis or minty fresh breath.

So if the political pollution spinmeisters at EPA are looking for new work as the Bush administration winds down, there's still time to land a job in Beijing before August 2008.