Date: Sat, 10 Sep 1994 01:07:18 -0700 (PDT) From: Alexander Volokh Subject: CEI LIST - HOW BAD SCIENCE LEADS TO ENVIRONMENTAL EXCESS AND HIGHER PRICES To: Recipients of the CEI List HOW BAD SCIENCE LEADS TO ENVIRONMENTAL EXCESS AND HIGHER PRICES by Ben Lieberman, CEI environmental research associate appeared in *The Washington Times*, 9/5/94 In what may turn out to be the most expensive measure ever taken to protect the environment, the federal government has imposed a strict phaseout on the production of chlorofluorocarbons (CFCs). These compounds have literally hundreds of uses, most importantly as the refrigerants in over 200 million air-conditioning and refrigeration systems. The rapid elimination of these compounds from our lives will be costly. But is it necessary? In theory, CFCs leak into the atmosphere, and eventually rise to the stratosphere, where they release chlorine atoms which deplete the ozone layer. And since the ozone layer shields the earth from an excess of harmful ultraviolet B radiation (UVB), its depletion may cause an increase in a number of human health and environmental consequences linked to UVB exposure. Evidence does indicate that small amounts of CFCs reach the stratosphere, and that the chlorine atoms released from these molecules can, to some extent, reduce ozone, although natural events, such as the eruption of the Mt. Pinatubo volcano, are now believed to have a much larger effect. However, little if any direct evidence shows higher UVB levels. The theory's proponents have simply assumed a UVB increase, although actual measurements have failed to provide confirmation. The most comprehensive set of UVB measurements, covering eight U.S. stations from 1974-1985, indicated no increase. After 1985, the funding for these stations was cut, and has not yet been restored. In the absence of sufficient American measurements, scientists have had to place undue reliance on a handful of measurements at a few scattered sites throughout the globe. Most recently, a study of UVB over Toronto purported to show a four year upward trend. Although highly publicized by the mass media and environmentalists as the smoking gun, the implication that the study proves a CFC-induced UVB increase has not been accepted by the scientific community, many of whom do not believe the data established a significant trend. The "trend" was largely caused by a few high measurements in 1993, the final year of the study, that are attributable to natural factors such as the Mt. Pinatubo eruption and an unusually severe storm, and not CFC-induced ozone depletion. James Kerr, the lead scientist in the study, acknowledges that "you shouldn't expect the UV increase to continue into the future." In addition, there are no other reliable measurements that show UVB on the rise. "There is no solid evidence of a long-term increasing trend in biologically-relevant ultraviolet radiation over North America," says John Frederick, an atmospheric scientist with the University of Chicago. Undaunted, some researchers have bypassed the question of actual UVB levels, assumed a worldwide increase, and have claimed to quantify the resulting damage. The EPA has publicized studies predicting a rise in the incidence of several forms of skin cancer, as well as increases in cataracts and immune system suppression as a consequence of an expected UVB increase. Essentially, these studies estimate the percentage increase in disease incidence rates expected for each percentage rise in UVB, and then multiply that number by their estimated UVB increase. While the possibility of a future human health impact can always be speculated, there is no evidence that anything has happened thus far. "There is no proven impact of ozone depletion on human health to date," says Dr. Martin Weinstock, a dermatologist and epidemiologist with the Veterans Affairs Medical Center and the Roger Williams Medical Center. Similarly, some biologists have claimed to have discovered environmental damage caused by increased UVB. For example, a team of researchers recently linked the reduction in certain frog populations in the Pacific Northwest to a hypothetical UVB increase. Although these claims have been widely accepted by television news reporters, Greenpeace activists, and EPA bureaucrats, most biologists are unconvinced by the study's conclusions. "The hypothesis that UVB has affected frog populations warrants further testing, but remains far from proven," says Joseph Pechmann of the Duke University Department of Zoology and the Savannah River Ecology Laboratory. The lack of evidence can no longer be attributed to the newness of the issue. In fact, the CFCs reputed to cause the problem have been in use for more than half a century, and the ozone depletion theory, with its predictions of imminent catastrophe, is itself over twenty years old. Yet, after all this time (and $1.3 billion in research), there still is no scientific consensus that tangible effects on human health or the environment have occurred. All that exists are a few speculative and heavily disputed claims of harm, and, of course, predictions of terrible consequences to begin occurring at some future date. Not surprisingly, several supporters of the current policy, perhaps recognizing that there is little solid evidence of the perils of CFC use, have begun to make the transition from predicting impending disaster to proclaiming that disaster is going to be narrowly averted because of the phaseout. Needless to say, such logic makes it impossible to prove that their original predictions were wrong. While the evidence of biological harm from CFC use is still uncertain, the costs of eliminating these compounds are not. As the law now stands, 1994 and 1995 production of CFCs is severely limited, with all production coming to an end on January 1, 1996, just a year and a half away. As a result, millions of Americans have already paid considerably more money to have their air-conditioners repaired, and numerous businesses have had to make expensive investments in new or modified equipment. These costs will rise considerably in the years to come, reaching as much as $100 billion in the U.S. alone. Of course, these economic sacrifices, however high, would be acceptable if truly necessary to avert catastrophic consequences. But with little reason to believe that CFC use has caused any real damage thus far, it appears that the phaseout, in its current form, is an expensive overreaction to an exaggerated problem. _______ __________ ___________ / | / | | | |__________ | | | | \ | | \ _______ |__________ ___________ COMPETITIVE ENTERPRISE INSTITUTE 1001 Connecticut Ave. NW #1250 Washington, DC 20036 202-331-1010, fax 202-331-0640 cei@digex.com Permission to copy granted as long as these lines are left intact. To subscribe to the cei list, send a message to volokh@netcom.com. "The Virtual Hand: CEI's free-market guide to the information superhighway" is available for $5. CEI's monthly newsletter, "CEI UpDate," is free to contributors of $25.