If you drive a car and live in the greater Chicagoland metropolitan area, you are periodically required to have your tailpipe emissions checked to ensure that your vehicle meets emissions standards. When this happens, the state checks for levels of two very specific air pollutants, carbon monoxide and nitrogen oxides, and one general class of air pollutants, total hydrocarbons.
These are not all of the air pollutants your car emits. It emits hundreds of other chemicals, albeit in very low amounts. The reason the Environmental Protection Agency (EPA) only checks for three is because they know that they are indicators of proper engine and pollution control performance. There is no reason to sock the taxpayer with the cost and burden of measuring hundreds of air pollutants when a simple test for three tells the agency all it needs to know to ensure environmental protection.
The same principles apply to regulation of industrial emissions, even though EPA data clearly shows that industrial emissions comprise an increasingly smaller fraction of the total mass of all air pollution emissions as recent decades have rolled on. Indeed, with the exception of sulfur dioxide, EPA figures show that industrial sources of air pollution are now minor contributors to emissions of criteria pollutants, with transportation sources, consumer products and activities, and natural events like wildfires generating the vast majority of emissions.
It is for all of the above reasons that we should be troubled when someone attempts to demonize a particular source of emissions or a particular EPA decision without making a reasonable attempt to contextualize the source or the decision. The Daily Herald ran a piece penned by the Better Government Association’s Brett Chase in its November 24 edition under the provocative headline “Rollback of EPA oversight in the Midwest favors polluters.” That heavily-slanted article should concern anyone who understands the difference between choosing a position based on the facts and choosing facts based on a position.
One cannot help but wonder why Chase’s musings were published in a way that suggested they were factual reporting of hard news, when his piece in fact largely expressed the opinions of someone whom—in this environmental professional’s view—has only a minimal understanding of the way environmental regulation works and the relative importance of sources that impact the environment.
This starts with Chase’s implication that the Obama-era EPA was justified in ordering the stacks from a Veolia North America waste incinerator located in Sauget, Illinois should be “…continuously monitored for arsenic, lead, mercury and other harmful metals…” and that the Trump-era EPA was irresponsible in reversing that decision. Chase goes on to tug at the reader’s heartstrings, citing a 78-year-old grandmother’s assertion that emissions from the incinerator are responsible for health problems of her three great-grandchildren.
The first claim is just plain silly. EPA has published hundreds of regulations and approved tens of thousands of permits that deal with emissions of “harmful metals.” EPA knows, industry knows, and Brett Chase ought to know that with few exceptions metal emissions into the environment take the form of particulate (solid) matter. Accordingly, EPA commonly requires potential sources of metal emissions to monitor total particulate emissions. The idea being that if a source is effectively controlling particulate emissions it is also effectively controlling emissions of the metals that are a subset of total particulate matter. This is exactly analogous to the way EPA doesn’t test your car for every potentially toxic compound under the sun, but rather uses three indicator compounds to ensure your car’s combustion and pollution control systems are working as designed.
As to our 78-year-old grandmother, let’s be fair to her. I stand in the shadow of no one in my admiration of 78-year-old grandmothers, but I do not believe there are many such grandmothers who are air quality experts, who understand the nuances of atmospheric dispersion, who understand how small a source Veolia’s incinerator is in the scheme of things, or who are aware of the thousands of sources that impact our air quality, and the millions of variables that influence our health, and that of our progeny.
Citing a 78-year-old grandmother living in a heavily industrialized, urbanized area as one’s source of air quality information is insulting to readers. Worse, doing so takes repugnant advantage of a senior citizen who clearly does not know, nor should be expected to know, the many facets central to the cause she is being used to advance.
Richard J. Trzupek is a chemist who has been employed as an environmental consultant to industry for more than 25 years.
