There is a lot of hyperbole regarding President-Elect Trump’s potential environmental agenda. During the campaign there was also a lot made about issues of employment and opportunity in the "Rust Belt" (a term I personally do no like). Here are two suggestions of how the incoming Trump Administration could bring greater opportunity to the Rust Belt without controversial roll backs of environmental standards.
- Bring Logic to Air Quality Standards and Regulations
- Moonshot on Brownfield Redevelopment
Bring Logic to Air Quality Standards and Regulations
Midwestern states with large populations and a heavy manufacturing base are hit particularly hard by tightening air quality standards for ozone and small particulate matter (p.m. 2.5). On October 1, 2015, EPA strengthened the National Ambient Air Quality Standards (NAAQS) for ground-level ozone to 70 parts per billion (ppb). EPA will designate areas in late 2017 based on monitoring data as to whether they meet the ozone standard ("Attainment Areas") or do not meet the standard ("Non-Attainment Areas"). States will have until at least 2020 to achieve compliance with the revised standards.
As the adjacent map demonstrates, Wisconsin, Michigan, Ohio and Pennsylvania (all key states to Trump’s victory) will have significant portions of the state designated as non-attainment areas. The designations will result in more regulation and restrictions on economic growth.
The good news is that U.S. EPA projects that most areas will be able to reach attainment of the new standards as a result of already promulgated federal regulations for gasoline, autos, power plants, and other sources of emissions. U.S. EPA projects that these already promulgated regulations will bring all but 14 of the 241 counties that currently don’t meet the 70 ppb ozone standard into attainment. However, the bad news is that these reductions will not be achieved until 2025, five years past the ozone deadline. Furthermore, some Members of Congress are trying to block the federal regulations.
As discussed in a recent Congressional Research Service report on the new ozone standard, some while Members in Congress have objected to the federal standards for motor vehicles, fuels, power plants, and other sources. However, the net effect of repealing them would be to shift the burden of attaining the ozone NAAQS more squarely in the direction of state and local governments. As detailed in prior posts (here and here), the states have very little ability to improve air quality through state specific regulations under required emission reduction plans (State Implementation Plans- SIPs) to meet the NAAQS. The federal regulations are far more cost effective.
It’s not just new regulations that will hamper economic growth in non-attainment areas, it is also mandated restrictions on economic growth. Under the Clear Air Act, businesses looking to expand or relocate must pay for more costly emission controls in non-attainment areas. Also, in non-attainment areas any increase in air emissions associated with a business expansion must be offset by reductions from existing businesses before a permit can be issued that allows the expansion to go forward (i.e. "Offsets"). These requirements push businesses to avoid non-attainment areas reducing opportunities for economic expansion.
A Trump Administration could bring more logic to this regulatory mish mash by resisting calls to roll back the more cost effective federal regulations and by adjusting attainment deadlines to give states more time to take full advantage of federal regulations already on the books. Such actions would also avoid promulgation of costly new local air regulations that will largely do very little to improve air quality.
Moonshot on Brownfield Redevelopment
A major focus during the campaign was how to improve our urban centers- finding ways to attract development and jobs to our neglected cities. A highly effective means of giving a boost to our inner cities would be to energize U.S. EPA’s brownfield program as well as other brownfield incentives.
As detailed in a four part series on this blog, brownfields lead to significant decay, social injustice and loss of opportunity (i.e. jobs). The cost for businesses to expand in our urban centers is often complicated by the cost to cleanup pre-existing contamination. Those costs are avoided by moving out of the City and developing on greenfields instead.
While brownfield programs have been successful, they have been wholly inadequate to make a significant difference. If part of the Trump Administration’s massive infrastructure program was directed toward brownfield redevelopment, this could be a major shot in the arm promoting capital investment, cleaning up sites that pose public health issues and creating more jobs for those living in the inner city.