Clearing the Air

Rating:
Summary: Critique By Data Analysis
Review: From Environmental History, Vol. 6, No. 2, (April 2001), at 316.

It has become common practice among environmental advocates to use history to justify their policy positions. In keeping with its title, Clearing the Air is an attempt to set the record straight about the war against air pollution. Goklany argues that it is wrong to give the federal Clean Air Act credit for recent improvement in air quality, since historical data show that per capita emissions of SO2, VOC, NOx, CO and PM, as well as urban smoke concentrations, had peaked and were in decline long before Congress passed the modern form of the Act in 1970. To Goklany this indicates that federal legislation was unnecessary, since natural forces would have reduced emissions anyway.

If the federal program was not responsible for cleaner air, then what was? Goklany attributes the improvement to a societal mechanism he calls "the environmental transition." Over the long term, emissions of a pollutant will increase to the point at which its harmfulness becomes recognized, then the problem is addressed and the pollutant starts to decline. Goklany explains this phenomenon to be a function principally of wealth and technology: as affluence and technological sophistication increase, the human desire to improve living standards causes pollution problems to be addressed.

While policy advocates use history to score points, historians should judge such accounts not by their utility but by the quality of their scholarship. While the book presents a strong historical narrative in its first chapter, summarizing the history of air pollution and its control, thereafter the book addresses historical issues almost entirely through data analysis. This is an original contribution, but it has certain shortcomings.

First, in the absence of a fuller historical treatment the data by itself only suggests a range of interpretations. Since the effects (i.e., the development of modern environmental institutions) could have resulted from a number of causes, a statistical approach does not provide a way to reason back from an observed effect to any specific antecedent as its cause. To find the drivers of the environmental transition, one needs to know specifically what decision-makers actually considered. This is the problem: much of the argument is made by inference rather than by evidence. One welcomes a better statistical account of the history, but the account is incomplete without the details.

A second general concern is that Clearing the Air fails to make a clear distinction between traditional smoke and modern air pollution problems. The inquisitive reader would stop there and ask, "If emissions had peaked, why would Congress establish a new federal program to control emissions that were already being adequately controlled?" Two alternative explanations come to mind. (1) One might conclude, as Goklany has, that Congress was simply mistaken. But isn't it also plausible that Congress was motivated in 1970 not by a desire to fix pollution problems that were already being solved but to address problems that were not? And there were in fact unsolved problems regarding modern air pollution that the Act addressed, such as lead and other auto emissions. Thus, while the Act gained jurisdiction over the pollutants that were already subject to state regulation in order to create a comprehensive national program, the regulatory approach applied throughout reflects Congress' concern for the distinctly modern pollution problems that were believed to be out of control. This explanation is compatible with the finding that some of the traditional pollutants had already leveled off or declined. (2) It may be that ambient concentrations had not peaked yet, since we can never know the counterfactual scenario. Were it not for the federal Act, the modern air pollution problems might have gotten much worse than they already were. It is logically circular to argue that the Act was useless because pollution did not get worse, since the Act had a role in making sure it did not get worse. Because the book's argument relies on a comparison to the counterfactual scenario, that argument can be neither proved nor disproved.

Third, while Clearing the Air claims that because of the environmental transition the pre-existing forces would have reduced emissions without federal regulation, it never makes clear whether the reduced emissions prior to 1970 resulted from market forces or from regulation. The book points to advancement of technology as the principal remedy in the environmental transition, but not by what means that technology appeared.

While Clearing the Air makes a solid contribution to the literature, a more modest title would have been preferable. With its argument based almost entirely on interpretation of data that represent more traditional than modern air pollution problems, this book's findings, for all their technical merit, cannot be considered established as generally applicable principles.

Reviewed by Alan P. Loeb, formerly a senior attorney at the Environmental Protection Agency. Mr. Loeb now practices law in Washington, D.C., and is a visiting professor in the Department of History at the University of Maryland.

Rating:
Summary: Critique By Data Analysis
Review: From Environmental History, Vol. 6, No. 2, (April 2001), at 316.

It has become common practice among environmental advocates to use history to justify their policy positions. In keeping with its title, Clearing the Air is an attempt to set the record straight about the war against air pollution. Goklany argues that it is wrong to give the federal Clean Air Act credit for recent improvement in air quality, since historical data show that per capita emissions of SO2, VOC, NOx, CO and PM, as well as urban smoke concentrations, had peaked and were in decline long before Congress passed the modern form of the Act in 1970. To Goklany this indicates that federal legislation was unnecessary, since natural forces would have reduced emissions anyway.

If the federal program was not responsible for cleaner air, then what was? Goklany attributes the improvement to a societal mechanism he calls "the environmental transition." Over the long term, emissions of a pollutant will increase to the point at which its harmfulness becomes recognized, then the problem is addressed and the pollutant starts to decline. Goklany explains this phenomenon to be a function principally of wealth and technology: as affluence and technological sophistication increase, the human desire to improve living standards causes pollution problems to be addressed.

While policy advocates use history to score points, historians should judge such accounts not by their utility but by the quality of their scholarship. While the book presents a strong historical narrative in its first chapter, summarizing the history of air pollution and its control, thereafter the book addresses historical issues almost entirely through data analysis. This is an original contribution, but it has certain shortcomings.

First, in the absence of a fuller historical treatment the data by itself only suggests a range of interpretations. Since the effects (i.e., the development of modern environmental institutions) could have resulted from a number of causes, a statistical approach does not provide a way to reason back from an observed effect to any specific antecedent as its cause. To find the drivers of the environmental transition, one needs to know specifically what decision-makers actually considered. This is the problem: much of the argument is made by inference rather than by evidence. One welcomes a better statistical account of the history, but the account is incomplete without the details.

A second general concern is that Clearing the Air fails to make a clear distinction between traditional smoke and modern air pollution problems. The inquisitive reader would stop there and ask, "If emissions had peaked, why would Congress establish a new federal program to control emissions that were already being adequately controlled?" Two alternative explanations come to mind. (1) One might conclude, as Goklany has, that Congress was simply mistaken. But isn't it also plausible that Congress was motivated in 1970 not by a desire to fix pollution problems that were already being solved but to address problems that were not? And there were in fact unsolved problems regarding modern air pollution that the Act addressed, such as lead and other auto emissions. Thus, while the Act gained jurisdiction over the pollutants that were already subject to state regulation in order to create a comprehensive national program, the regulatory approach applied throughout reflects Congress' concern for the distinctly modern pollution problems that were believed to be out of control. This explanation is compatible with the finding that some of the traditional pollutants had already leveled off or declined. (2) It may be that ambient concentrations had not peaked yet, since we can never know the counterfactual scenario. Were it not for the federal Act, the modern air pollution problems might have gotten much worse than they already were. It is logically circular to argue that the Act was useless because pollution did not get worse, since the Act had a role in making sure it did not get worse. Because the book's argument relies on a comparison to the counterfactual scenario, that argument can be neither proved nor disproved.

Third, while Clearing the Air claims that because of the environmental transition the pre-existing forces would have reduced emissions without federal regulation, it never makes clear whether the reduced emissions prior to 1970 resulted from market forces or from regulation. The book points to advancement of technology as the principal remedy in the environmental transition, but not by what means that technology appeared.

While Clearing the Air makes a solid contribution to the literature, a more modest title would have been preferable. With its argument based almost entirely on interpretation of data that represent more traditional than modern air pollution problems, this book's findings, for all their technical merit, cannot be considered established as generally applicable principles.

Reviewed by Alan P. Loeb, formerly a senior attorney at the Environmental Protection Agency. Mr. Loeb now practices law in Washington, D.C., and is a visiting professor in the Department of History at the University of Maryland.

Rating:
Summary: An outstanding environmental issue history.
Review: In Clearing The Air, Indur Goklany (formerly chief of the technical assessment division of the National Commission on Air Quality and a consultant in the Office of Policy, Planning, and Evaluation at the Environmental Protection Agency) explains how it came to pass that America's air quality is better today than ever before in modern history -- and continues to steadily improve. Goklany draws upon a painstaking compilation of long-term empirical data to challenge the conventional wisdom that credits federal regulation with this history improvement of air quality. Clearing The Air shows that the air had been getting cleaner prior to federalization because states and localities had taken steps to clean it up. Goklany's data authoritatively refutes the argument that state and local inaction compelled the federal government to get involved. He also argues persuasively that improved technology and the shift from a manufacturing-based to a service-based economy have contributed to improved air quality. Clearing The Air is an invaluable, documented, highly recommended contribution toward a proper understanding of the political, technological, and environmental issues involved with today's improved air quality across the country.