Should Cost Be Included in Air Quality Standards?

On first look, the fact that the Environmental Protection Agency (EPA) cannot consider costs in the establishment of National Ambient Air Quality Standards (NAAQS) under the Clean Air Act (CAA) seems a bit absurd. However, on deeper inspection, the explicit requirement of the EPA to focus solely on health considerations instead of economic or technical feasibility is an important facet of the Clean Air Act (Salzman and Thompson 2019, 121). Consistent and inflexible federal standards that are supported by flexible and specific state implementation, like the Clean Air Act provides, have created reductions in air pollutants across the country even as economic activity and populations have increased (Salzman and Thompson 2019, 115).

Inflexible and easy to administer standards at the federal level provide several benefits. Firstly, national standards avoid the issue of local standards being more susceptible to local political pressures and business intervention (Salzman and Thompson 2019, 121). This also minimizes issues with interstate competition for industry that can lead to race-to-the-bottom scenarios, but also provides businesses a consistent standard to follow instead of multiple sets of different state requirements (Salzman and Thompson 2019, 121-140).

Secondly, a key strategy in addressing issues regarding scientific uncertainty is the precautionary principle (Salzman and Thompson 2019, 20). As science in healthcare has advanced over the years, we have learned more about how detrimental pollution can be on health even more so than before (Salzman and Thompson 2019, 121). Setting limits that are focused solely on health considerations utilizes the precautionary principle and ensures the human health goals are not usurped by short-term corporate profit motivations.

There are also several arguments against the CAA’s sole focus on health considerations. However, many of these are directly mitigated by the implementation flexibility that is part of the policy. While federal policy can be inflexible and inefficient on their own, states have a wide variety of methods in which they can work to enforce the NAAQS under the CAA. For example, state implementation plans (SIPs) just need to satisfy the NAAQS but can utilize cost considerations. This allows local conditions to be accounted for in the planning, ensuring a more flexible approach that can be more site-specific (Salzman and Thompson 2019, 122).

States can also implement aspects that consider benefit-cost, cost-effectiveness, or risk-risk analysis (Salzman and Thompson 2019, 64-65). This allows the NAAQS to be easily administered at a high level but allowing local customization at the state level (Salzman and Thompson 2019, 121). Since the overall goal of the NAAQS is health considerations, then the standards should be developed with that as the sole focus. The flexibility in state implementation reduces the inefficiencies and over-protection issues that can arise from federal standards and allows states to develop more custom methods to achieving those standards. While technology, politics, business, and culture changes, it is critical for federal policies to set standards based on health considerations in a way that allows flexible implementation that can take into account cost and other concerns like the Clean Air Act does.

Author: Logan Callen


Salzman, James, and Barton H. Jr. Thompson. 2019. Environmental Law and Policy. 5th ed. St. Paul, MN: Foundation Press.

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