M. Sc.

II Semester

Air Pollution Control Philosophies and Regulations

PCT 102.3_’09
by B. R. Manandhar

Regulation of air pollution control is a challenging job for any society/country. It

is so because of the fact that pollution of ambient air is the end result of emissions
from numerous point and fugitive sources around. Such sources could be
stationary or mobile. As the adverse impacts of polluted air are now better known
to us, control of air pollution has become a very important and even more urgent
task for regulatory agencies of a society or country. Moreover, it is also a fact that
unlike other forms of pollution, no one can escape the effects of air pollution.

Ideally, we all would like to enjoy completely unpolluted air at no cost to anyone.
But in reality this is not possible. Thus a logical goal for us would be to enjoy an
appropriately clean environment at an appropriate cost appropriately distributed
among industry, car owners, homeowners and other pollution sources.

With regard to air pollution control regulation, there are quite a few regulation
approaches/philosophies which are currently in common use world-wide and some
which are under limited use or are still under research.

Whatever the extent of the use of these philosophies, a perfect air pollution
approach/philosophy should have the following qualities inherent with them:

 Cost-effective: maximum possible benefits for the resources spent on

pollution control
 Simple: understandable to all involved and requires little in terms of legal
interpretations
 Enforceable: clear responsibilities of all parties involved and compatible
with the court procedures
 Flexible: can deal with special situations such as equipment breakdown or
delays in equipment delivery
 Evolutionary: capable of utilizing new information on the effects of
pollution and new developments/inventions in CT without
major changes in legal structure or major revisions of
existing industrial plant

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There are four major philosophies available for regulating air pollution control.
They are: (i) Emission Standard Philosophy (cleanest possible air philosophy), (ii)
Air Quality Standard Philosophy, (iii) Emission Tax Philosophy and (iv) Cost-
Benefit Philosophy. Each of them is described as follows:

Emission Standard Philosophy

This approach/philosophy recognizes the fact that there exists a maximum possible
or practical degree of emission control and this degree varies between various
classes (categories) of emitters such as industries, motor vehicles, households etc.
Presumably the degree of control can be determined for each class based on the
employment of the best technology currently available and also on requirement of
good maintenance of the equipment. The following are some examples:
 Prohibition against open burning of garbage/agricultural wastes
 Regulations of visible emission from stacks/vents
 Regulation of Sulfur content in fuel and olefin content in gasoline
 Numerical standards e.g. 0.03 lb of particulates/106 Btu of fuel burned; 0.25
g of HC's/mile drive of an automobile

Air Quality Standard (AQS) Philosophy

This philosophy is also known as “Zero Damage" philosophy. According to this
approach, a certain level of contamination of ambient air, known as threshold
values, can be permitted below which no air pollution damage would occur. It is
important to understand that damage to health depends both on concentration level
of a pollutant and period of exposure to it. This combination can better be
explained by the concept of dosage. Dosage of a particular pollutant is given by
the integration of the pollutant concentration in air breathed over the exposure
period (∫pollutant concentration in air breathed×dt).

The threshold limit value (TLV) for a pollutant does not represent true no-effect
concentration. It rather indicates pollutant concentration level in ambient air at
which the individual health effects (if they exist at all) are less than the variation in
the health of the general populace when they are subjected to repeated exposure to
this concentration on a long-term basis. There exist TLVs generally for many
pollutant species.

In this context, it is important to understand the difference between chronic effects

and acute effects. Current interest in air pollution and human health is mostly
directed at long-term, low-concentration exposures leading to chronic effects.
Short-term, high-concentration exposures, which lead to acute effects, occur only
in industrial accidents or air pollution emergency episodes.

National Ambient Air Quality Standard (NAAQS) is set with adequate margin
over the TLV to ensure protection of human health.

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Pollutant dispersion models, such as Gaussian model, help to determine emission
reduction requirements based on the AAQS and needed emission reductions lead
to a set of emission standards that are based not necessarily on best available
technology but may turn out to be technology-forcing emission standards.

Emission Tax Philosophy (Economic Tools)

This philosophy/approach is not in use to a significant extent world-wide. It is
currently more of academic/research use and rather offers prospects of future
alternatives for air pollution regulation mechanism.

Under this approach, emitters are taxed according to the rate of emission of a
particular pollutant (e.g. Rs. X per gm of pollutant Y for all emitters). This means
that once tax is paid on account of pollutant emission/discharge, the emitter is free
to continue polluting environment. Thus, this philosophy is also considered as a
license to pollute. This approach can work better in combination with AQS
philosophy by providing added incentives to reduce emissions to lower levels than
those required by AAQS.

Tax rebates, low-interest loans & direct public subsidies are others forms of
economic incentives offered under this approach which assumes that environment
is naturally capable of removing/diffusing pollutants (CFCs could be an
exception).

This approach/philosophy brings two desired results: (i) each industry/firm can
choose the degree of control such that it will help to minimize the sum of control
costs and taxes for the firm; (ii) misallocation of pollution control resources is
minimized

Cost-benefit Philosophy
This philosophy is still much of academic exercise and research. This philosophy
assumes that either no threshold or very low threshold exists such that it's not
affordable to have air that clean. Thus, choice/decision has to be made for the level
of acceptable damage and corresponding cost to reduce damage to this level. This
philosophy also raises the question of social justice and equity as damages and
cost of emission control are distributed among the entire population no matter who
is the polluter and who is not.

The cost of damage goes high while cost of pollution control goes low with the
higher level of concentration of a pollutant permitted in ambient air. Conversely,
cost of damage goes low while that of control goes high with the lower level of
concentration of a pollutant permitted in ambient air. As both the damage cost and
the control cost are burden to a society, this clearly implies that there also exists an

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optimum level of concentration of a pollutant for which the total cost (sum of
damage cost and control cost) is the minimum for the society.

As a conclusion, the following shows a quick comparison among all the four
philosophies in terms of the desired qualities described above.

Comparison among the four philosophies

Desirable Emission AAQ Emission Cost-benefit
quality Standard Standard Tax Philosophy
Philosophy Philosophy Philosophy
Cost- Very bad Good Fair Excellent
effectiveness
Simplicity Excellent Poor Excellent Terrible
Enforceability Excellent Fair Excellent Unknown
Flexibility Poor Fair Unnecessary Unknown
Evolutionary Fair Fair Good Good
ability

The following schematic diagram shows the air quality management process
undertaken for ensuring a desired and legally required ambient air quality in a
country or a city.

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 Start

Measure AA Quality

yes Predict future AQ,

Is it acceptable or Does
accounting for growth
it meet AAQS?

No
yes
Is it acceptable? stop
Compute needed
emission reductions
No

Compute and enforce

needed emission
Enforce needed controls
emission reductions