Developing a Framework for Effective Air Quality Management

3.3 Setting Air Quality Goals for a Region

3.3.2 The Process for Setting Air Quality Standards
Air quality management processes are expensive and difficult, it thus requires considerable political buy in from policy makers to make significant progress. This means that the policy makers must be able to trust the air quality standards that are used as the basis for the air quality management process. It follows then that the standards used for air quality management must be traceable to a documented science based process. Many developing countries have chosen to adopt standards from the United States or Europe or they have used the standards recommended by the United Nations. This is a logical choice since it is generally believed that health impacts are relatively universal, and the ‘safe’ level of pollutant in one area would be the same level in another region. Another reason developing countries have chosen to adopt standards from other areas is that it is very costly to conduct health effects research that is needed to determine the appropriate standards.

The United States uses an elongated process to set its air quality standards. A national advisory committee has been established to support the development of air quality standards, which is called the Clean Air Scientific Advisory Committee (CASAC). CASAC is made up of seven technical experts representing a cross-section of the scientific community. The USEPA technical staff develops a document called a “criteria document” which reviews relevant research concerning the health and welfare impacts of an air pollutant. The CASAC committee reviews the criteria document as it is developed. When the criteria document is ready for public review, the USEPA develops a related “staff paper” which is designed to be easier to read by non-technical persons and includes recommendations on standard modifications. Both the criteria document and the staff paper are made available to the public for several months of review. After the public review and comment and additional comments by the CASAC, the Administrator of the USEPA who is appointed by the President of the United States decides based on the public reviews and of the criteria document and staff paper if new standards are appropriate and makes a proposal. This proposal is subject to some review as well. After further review, the Administrator of the USEPA can promulgate the standards, which become official for the United States.

Economic considerations often overwhelm the process of setting air quality goals and attainment timelines and can often significantly delay the air quality management process. This is because it is difficult to measure the cost of health impacts of pollution and the opportunity cost of green technology that results from the mandated clean up. The most successful plans have set air quality goals and attainment timelines even with limited knowledge of the economic impacts. This allows for the process to get underway and produces investments from regulators, inventors and the industry to find solutions to the pollution problem. Most plans allow a ‘postponement’ or extension if a good faith effort has been made and the technological and economically feasible solution has not been found.