Air-pollution policy: stretching beyond science.

Wallace Kaufman's FOCUS feature on acid-rain/forest-health research ends with a plea for Americans to listen to, and use, scientific information. As one trained in science and working a career as a natural-resource conservationist, I'm strongly in agreement. But I'm also painfully aware of the limits of science and the scientific method in settling some of the major political questions of our day. The air-pollution issue offers a good illustration.

The relevant questions are three: 1) Should the nation move at this time to reduce air pollution? 2) Why? and 3) How? A careful reading of Kaufman's article (which, incidentally, fairly and accurately portrays the current state of acid-rain research insofar as I am able to determine) leads to the conclusion that several years of intensive research has produced no firm conclusion on the first question, mixed evidence on the second, and few if any clues on the third.

So the challenge is to take the scientific evidence that we have been able to amass and use it as one factor, but far from the only factor, in making a political decision. Starting in 1986, the Board of Directors and staff of the American Forestry Association started that process. Upon its conclusion, we came to a decision-one that elicited considerable criticism from many quarters for being scientifically insupportable. So we reviewed the decision, and reaffirmed our position. We now have another year's evidence, and debate. My personal judgment (the Board of Directors has not restudied the issue in 1989) is that our position is still valid and has, in fact, been strengthened by events and findings. Some of our critics will disagree, so it is worthwhile to restate our conclusions and set forth the case as we see it.

The answer to question No. 1 is: The United States should move swiftly and aggressively to reduce air pollution from both fixed and mobile sources. The risks and costs of further delay outweigh the risks and costs of making some mistakes and taking some wrong turns as we seek the most effective ways of getting air-pollution levels down. The reasons are several-fold:

1) Forest Impacts: Air pollutants have changed environmental conditions within forest ecosystems, and those changes are stressful to those ecosystems. It is not clear that they are stressful in all places and at all concentrations. But they are part of an ongoing syndrome, and add to it.

For the last decade, many of the nation's forest regions have been subjected to a higher-than-average drought incidence, which also stresses forests (see AMERICAN FORESTS, March/April 1989). Pollution-stressed forests are more susceptible to drought damage-and drought-stressed forests are more susceptible to pollution impacts. And in the process, the compound effects of these stresses may be overshadowed by the fact that it is an insect or disease outbreak that visibly kills the trees or alters the vegetative mix.

Does the fact that a bug administered the coup de grace obviate the fact that the forest was stressed and weakened by both drought and pollution? Obviously not. Has the forest survived drought cycles of this magnitude before? Almost certainly. Has the insect been a normal part of this forest ecosystem for centuries? Yes, except for introduced pests. What, then, is the new stress that provided the straw that broke the camel's back?" Air pollution gets a strong vote, even when it cannot be proven by laboratory or field studies that it was the singular or even primary cause. - We must also point out that forest impacts go far beyond treegrowth and mortality rates. Air pollution affects soil chemistry, water chemistry, air chemistry, visibility, sunlight transmission, heat reflectance, and average temperatures. The fact that none of these can be said to be affected to the degree that they exhibit toxic effects to higher plants is misleading. The relevant fact is that one portion of an ecosystem cannot be degraded without creating ripple effects that will eventually be felt throughout the system. It may be that foresters should not wait for trees to die. Maybe it is a lichen, or some other sensitive plant, that is the miner's canary' in this issue. That possibility, not certain at this stage, encourages additional caution and research.

2) Lakes and Streams: The "acid rain- components of air pollution have increased acidity in some lakes and streams. This is particularly true in regions where soils lack the buffering capacity to readily absorb and neutralize additional acid-forming compounds. Aquatic life and, ultimately, entire ecosystems can be altered with such changes.

3) Crops: Ozone damages sensitive crop plants. That case has been strongly made. Other air pollutants are implicated in crop reductions as well, but the cause-and-effect data are perhaps not as clear as those for ozone. It is estimated that rural ozone levels have doubled in the past century.

4) Human Health: Again, ozone is implicated, as it has been shown to damage lung cells almost instantly upon inhalation. Other air pollutants, including the other components of smog, do not get off unscathed either. For people susceptible to respiratory ailments, air pollution is bad news. Harvard University researchers estimate that air pollution could be implicated in up to 70,000 premature deaths a year in the United States alone ! Without trying to stretch the technical case in the last three categories, we feel that these situations add support to the conclusion that less air pollution is better than more air pollution, and that the risks associated with sustaining continued damages are greater than the costs associated with beginning a sensible control strategy.

That conclusion leads to the last question: How should the nation spend its money and energy wisely in this effort?

Federal law should be explicit on goals, objectives, and timetables, but less specific on technical methods. We should set new pollution-reduction goals, establish a phase-in period with target dates for each step of the reduction in air-pollution emissions, and then let scientific research and market economic forces determine the most cost-effective way for various industries and regions to meet the target dates. The goal is not stack-scrubbers or catalytic converters. ft is clean air. Beyond creating a reasonably level "playing field" so that industries do not face a bewildering array of different regulations in different states, Congress should seek to encourage technical innovation and Economic efficiency, not stifle them.

The real question, of course, is; "What happens if the goals are not reached?- That has happened before, and will no doubt happen again. The answer is that we re-gear our expectations, set new goals, and continue to strive. We didn't get "fishable, swimmable" waters everywhere as a result of the Clean Water Act, but we made significant progress virtually everywhere, and the nation's environment is immeasurably better as a result. Is the job done? Of course not. It won't ever be.

Air pollution is in a similar situation. We've made many gains in recent years, and air quality is better as a result. But we can't rest where we are, in the face of continued economic growth and the evidence that pollution is causing adverse environmental impacts,

This Association does not in any sense speak for the forest industry. But we hear its voice as an important part of the citizens' group that we monitor. Industry has already spent millions of dollars to meet air-quality regulations. it does not want new regulations to create any new competitive disadvantages between industries here and abroad, or between industries in different states. It doesn't want to spend money that won't result in an improved environment. And it is particularly concerned about forest lands, because that is its bread and butter.

Our position that new pollution controls are needed now has offended some in industry who read it as a "do something no matter what the price" call to action. We hope it is not that, but rather a call to rational action, We encourage all parties to come together, in this Congress, and find ways to enact the most rational approach possible, given what we know today. On the basis of what we have seen, we think this is preferable to a continued -no action" approach, even if we don't have all the answers.

Finding ways to live in harmony with each other and the other living creatures of earth, within a natural environment that harbors the cycles of all life, is not a trivial matter. It is the essence of the human condition.

In that effort, we should use the best information that scientific insight can contribute. But we should not be stalemated when science cannot deliver all the answers we need, as fast as we need them. At that point, the decision-making moves out of the calculated formulae and onto the political agenda. We think air pollution and its control have clearly achieved that status, and it is time for aggressive action, partly for scientific reasons, partly for economic reasons, partly for social reasons. It's time to stop talking about whether we should move to reduce pollution, and focus on devising the most effective and promising public and private strategies for getting the job done,