CLEAN AIR WORKING GROUP
ACID RAIN BRIEFING
for
THE 92 GROUP
April 22, 1987
We appreciate this opportunity to discuss acid rain.
strong in the acid rain debate.
Clearly, feelings run
Many sincerely believe that the problem has been
neglected too long, that the delay is costly and that we know enough to mandate
legislation to protect resources of concern.
Others believe there is no acid rain
problem and any control program beyond the provisions of the Clean Air Act would be
a waste of national resources.
The Clean Air Working Group (CAWG) has taken a
middle ground that there may be a problem, but based on a growing body of evidence,
it is not an ecological crisis.
policy.
That we have time for science to guide public
That there is substantial justification to avoid a rush to judgement.
That
we will never have all the answers, but in 18 to 24 months we will have additional
and key information to determine the size and scope of an acid rain program.
It is our view that acid rain is one of several atmospheric phenomena that
should be studied to insure that sound science guides public policy.
These studies
have been underway for many years and the results are just now becoming available.
Prudence dictates that we pause and consider this important information.
Further,
we believe there is no acid rain crisis and no justification for a rush to judgement
by the 100th Congress.
; _,
The National Acid Precipitation Assessment Program (NAPAP) mandated by Congress
in 1980, is supplying information and answers to important questions.
The NAPAP
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L985 annual report to Congress was released in March, 1987.
The NAPAP interim
report, summarizing their findings to date, is due in June, 1987.
NAPAP
participated in the Joint Report to Bilateral Advisory and Consultative Group (BACG)
February, 1987, status report of Canadian-U.S.research in acid deposition.
The
results of this carefully conceived, comprehensive, Congressionally mandated 10-year
investigation will continue to flow to the public for several years.
By design, the
most important and comprehensive information was not expected to be available from
the NAPAP effort until the last two years of their study.
Meanwhile, the Clean Air Act is working
*
health-based ambient air quality
standards for sulfur dioxide and nitrogen oxides (SO- and NO ) have been attained in
virtually all of the country and sources of SO- and NO
emissions are controlled.
We can all agree that there is a perception of a problem.
the public is concerned about acid rain.
Polls confirm that
And we recognize that this concern
translates into political pressure for Congress to act.
The pressure will not be
relieved until Congress acts or until the facts reassure the public.
We believe the facts are reassuring.
It is our hope that the evolving science
*
of acid rain, as reflected in NAPAP and other studies, will guide the Congressional
debate so that legislation, if needed, will invest national resources in a costeffective manner that effectively protects resources of concern.
The precursors of acid rain are SO- and NO .
The major source of SO- emissions
are coal and oil-fired electric utility plants, industrial activities and space
heating.
Total S0_ emissions reached a peak of 28.7 million tons per year in 1973.
By 1985, they had been reduced over 26 percent to less than 21 million tons.
The
trend in S0_ emissions is down and may continue to decline or stay flat for several
years.
Please note that the S0 9 annual emission rate between 1973 and 1985
. 4 *•
decreased by about 8 million tons
in several acid rain control bills.
a reduction similar in scale to that called for
3
The major source of NO X emissions are electric utility plants,
transportation
*
and industrial activities.
NO
x
emissions have also declined from a peak of 2L.i
million tons per year in 1978 to 20 million tons in L985.
of NO
Transportation emissions
have consistently declined over the last 10 years and will continue to
decline
these reductions have more than offset other NO
x emission increases.
NO
x
emissions may remain flat for the next few years.
The point is that acid rain precursors, SO^ and N0v , are controlled under the
Clean Air Act.
Their emissions have been significantly reduced and national
emission trends are down for SO. and flat for NO .
^
X
. Yet, despite significant S0 ? and NO
£m
emission reductions, there has been no
4\
measurable change in the acidity of rainfall over the same period.
documented reduction in acid deposition over the same period.
There is no
There seems to be no
corresponding change in the alleged effects of acid rain.
While we generally understand how acid rain is formed, we do not have an
adequate understanding of the relationship between sources of emissions and acid
deposition at a receptor.
NO
There is no certainty that a given reduction of S0 9 and
emissions will result in an equivalent reduction in acid deposition at a
receptor or that alleged effects will be alleviated.
We simply do not know if
future emission reductions will improve the acidity of rain or decrease acid
deposition.
More importantly, will future emission reductions alleviate the alleged
effects of acid rain and provide any protection to resources of concern?
To answer these questions, we must be able to model the acid rain phenomenon.
We can measure what is happening and compare it with historic data without fully
understanding acid rain.
However, to predict what will happen requires a fuller
understanding of the phenomenon and sophisticated computer models that have not yet
been developed.
100 percent.
Currently, field measurements and models differ by as much as
We simply do not have the tools to predict with confidence the impact
-4-
au a receptor from source emission reductions.
If past reduction and impact
measurements are any guide, there may be no impact, no improvement, no measurable
environmental change from future SO- and NO
^
emission reductions.
X
The extent of actual effects from acid rain is very uncertain.
In many cases,
the alleged effects of acid rain have been exaggerated, misunderstood or not demonstrated.
Since these effects are the basis for public concern and possible
Congressional action, they need to be fully understood.
Resources, such as lakes and forests, are thought to be at risk from acid
rain.
If they are, they should be protected.
But before mandating protection we
need to understand the risk to ensure we provide meaningful protection.
Surface water acidification is the major acid rain concern.
The claim that
thousands of lakes are now quite acidic and many more will become so is not
supported by the facts.
A 1986 National Academy of Sciences report states that in
the Northeast, some lakes have become more acidic, some less, others unaffected and
the role of acid deposition is not known.
acidic lake in the West
in Florida.
The 1986 EPA Lakes Survey identified one
from natural causes, and perhaps 600 in the East
many
The EPA survey does identify lakes that may be vulnerable to
acidification.
We have reason to assume there is a problem with the acidification of lakes.
But the size of the problem was exaggerated.
protect our lakes
We need to know the cause and how to
perhaps on a case by case basis
before we act.
Is the cause
acid deposition, agricultural runoff, natural soil conditions or local rather than
the long-range transport of acid deposition?
We also have reason to doubt that a significant emission reduction program will
protect a lake.
Past reductions have had no documented impact.
- j
For lakes then, the
size of the problem has been exaggerated and there is no single, simple solution.
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Much less is known about the effects of acid rain on forests than on aquatic
systems.
Reports of forest declines in Europe and the U.S. are of concern.
In
Germany, the most recent explanation is not acid rain but a combination of factors,
including nature, climate and local sources of pollution.
In the U.S., the Northeast red spruce decline is often blamed on acid rain.
However, a L986 National Academy of Sciences report states there is no indication
now that acid rain is an important factor.
The report does list other possible
causes.
The U.S. Forest Products Industry has conducted extensive evaluations of forest
decline reports in Germany and the U.S.
They concluded that there is no evidence of
a widespread regional forest decline caused by air pollutants in North America.
For forests then, acid rain probably is not the culprit.
rain's role are either wrong or not fully understood.
Concerns for acid
Local sources of pollutants
may be one cause and ozone appears to be a factor.
It is difficult to identify damage to materials caused by specific pollutants
or combinations of pollutants.
Materials naturally deteriorate with time and it is
difficult to distinguish the effects of acid rain from normal weathering.
The role,
if any, played by acid rain in the degradation of materials has simply not been
demonstrated.
The likely culprit is weather and local sources of pollutants.
Until recently, human health has not been an acid rain issue.
And, it should
not be.
The National Ambient Air Quality Standards for S0 n and NO were set to
2
x
protect human health. Virtually all of the country is an attainment area for both
pollutants.
Therefore, human health is protected from both acid rain precursors.
If there is any question of protecting human health, it should be addressed through
the Clean Air Act.
. .
In recent Congressional testimony, health effects were discussed for SCNO
but, at concentrations above the ambient air quality standards.
and
The testimony
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also covered adverse health effects from ozone but, again, ac or above the
health-based ozone standards.
Acid rain is not a public health problem.
The only health issue that may be
associated with acid rain is the release of heavy metals when exposed to low pH, and
this is the subject of current research.
Our understanding of the acid rain phenomenon is not complete and results of
current research presents substantial justification for pausing to reflect on the
nature and scope of the problem.
many facets of acid rain.
There remains a great deal of uncertainty about
Yet with all of the uncertainty surrounding acid rain,
the one certain consequence is a staggering cost
over 20 years.
perhaps exceeding $100 billion
This represents a significant investment of our national resources.
It would have an adverse impact on jobs, regional dislocations, international
competitiveness, electric utility rates and national energy security.
In light of the evolving science, uncertainties and staggering costs, can we
justify acid rain controls now?
We think not.
science can help answer these questions
And perhaps not in the future.
if we give it a chance.
We have time to
consider the flow of information from Congressionally-mandated research.
time for science to guide public policy in the acid rain debate.
rain crisis!
But
We have
There is_no acid
There is no need to rush to judgement on acid rain legislation.
Thank you for listening to our views on acid rain.
perspective and then discuss our differences.
We would like to hear your