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National environmental organizations have been in full war cry over the Bush administration's "assault on the environment." Many of the same criticisms were made twenty years ago about the Reagan administration, yet the data from the 1980s show environmental improvement in most major areas. The environmental record for this decade is also certain to show improvement as well. The hyperbole of environmental lobbies should be understood for its political rather than substantive content.

No matter who is appointed to succeed Christine Todd Whitman as administrator of the Environmental Protection Agency, he or she is certain to face brutal confirmation hearings in the Senate. "Show trial" might be a more accurate description than "confirmation hearing," for there are few Bush administration policies that excite more fury than those dealing with the environment, and confirmation hearings will be an ideal setting to vent this fury in a way calculated to generate media coverage.

Fred Krupp, president of Environmental Defense, laid down an unsubtle marker with a press release issued the day Whitman resigned: "During confirmation hearings Congress should make sure that any new administrator will serve as a strong advocate, willing to take on lobbyists and other agencies in order to protect America's public health and the environment."[1] The Natural Resources Defense Council offered an echo: "Americans will now have a chance to demand that [Whitman's] successor be more committed to protecting the public interest rather than letting the White House ram through its pro-industry agenda."[2] The Sierra Club's Carl Pope said: "Given the Administration's track record on the environment, we have little hope that President Bush's next EPA Administrator will be allowed to do a better job of cutting pollution and keeping families safe."[3] Is there a central office somewhere cranking out talking points?

The more politicized environmental groups have nearly exhausted the critical vocabulary in attacking the Bush administration. Newsweek satirist Andy Borowitz captured the mood with an article entitled "Bush to Eliminate the Environment." The "story" reads in part: "One week after Christine Todd Whitman departed her post at the Environmental Protection Agency, President George W. Bush announced ambitious new plans to phase out the environment altogether by 2004. 'In addition to cutting taxes, it is the goal of this administration to cut our wasteful, bloated environment,' Bush said in a speech before the Association of Indiscriminate Applauders in Washington."[4] (Who says satire is dead?)

Borowitz's whimsy is not very far from what many environmentalists seem to believe literally. Consider, for example, this jeremiad from a consortium of leading environmental groups:

"The President . . . has broken faith with the American people on environmental protection. During his first 14 months in office, he and his appointed officials have simply refused to do the job that the laws require and that Americans expect of their government--to protect the public from pollution and to use publicly owned resources and lands for the public good. Instead, the Administration officials are handing over to private use the clean air and water, forests, grasslands, coal and oil that belong to all of us."

The environmental organizations that put out this statement can at least be credited with practicing what they preach about recycling, because this statement was made in 1982 about the Reagan administration. It comes from a report entitled Ronald Reagan and the Environment, which is described as "an indictment prepared by Friends of the Earth, Natural Resources Defense Council, The Wilderness Society, Sierra Club, National Audubon Society, Environmental Defense Fund, Environmental Policy Center, Environmental Action, Defenders of Wildlife, and Solar Lobby." (This report will be henceforth referred to the 1982 FOE report.) This is just one of many hyperbolic alarms about the environmental ruin that Reaganites were allegedly imposing on the nation. "We think the Administration's environmental policies have harmed the Nation, and that the harm grows steadily worse."

There is nothing being said about the Bush administration that was not said with nearly identical terms about the Reagan administration twenty years ago. This suggests a parlor game, similar to spotting the parallels between Al Gore's Earth in the Balance and the Unabomber's manifesto "Industrial Civilization and Its Discontents," of trying to tell the difference between what was said about the Reagan administration then with what is said about the Bush administration now, but with the added twist of tracking the record of environmental progress made during the Reagan years. Virtually none of the dire predictions of environmental deterioration under Reagan came to pass; to the contrary, most categories of pollution declined during his tenure (and have continued to decline), and millions of acres of public land were set aside for conservation purposes. And it is a near certainty that our environmental measures will show continued improvement at the end of President Bush's first term in office, as well as his second term if he has one. (The author offers an open invitation to any environmentalists who doubt this to enter a $1,000 wager, similar to the famous bet on resource scarcity that Julian Simon and Paul Ehrlich made in 1980. For those who do not know or remember the outcome, Ehrlich, who predicted resource scarcity, lost the bet.)

In the sections that follow, environmental complaints about Reagan will be paired with complaints about Bush, along with measures, where data exists, of the progress during and since the Reagan presidency. Wherever the name of the administration was mentioned, it will be omitted in the quotations here; the attributions that follow will indicate which administration was being criticized in each case.

Public Lands

(A) "The Administration has tilted management away from conservation toward rapid development and control by private interests."

(B) "The Administration has been busy fulfilling industry's desire to exploit resources in our public lands."

(C) "Once again, the Administration is trying to sell off millions of acres of pristine public forests to the logging, mining, and drilling industries."

(D) "The Administration's policy is to open the [wilderness] system to oil, gas, and mineral development, and close off major additions of new land."

Statement (A) is from the 1982 FOE report; statement (B) is from the Natural Resources Defense Council in January 20035; statement (C) is from Greenpeace in May 20036, statement (D) is from the 1982 FOE report.

The debate between conservation (i.e., managed use) versus preservation (i.e., no use) of public land has been going on for over a century, but today's environmental rhetoric implicitly decides the question in favor of preservation. Pop quiz: When was the last time a national environmental organization endorsed a resource development project on public land? If any have done so in recent decades, they must have done it on a public access cable channel in the middle of the night. Notwithstanding federal law mandating that public lands be used for multiple purposes, including resource development, the default position of many national environmental groups (though not local environmental groups) is: No.

There is little doubt that the public supports preserving more land, and the record shows the amount of land placed in some category of preserved status expanded substantially during the supposedly anti-environmental reign of the Reagan administration. As table 1 shows, the Reagan administration added 38 million acres to various federal land preservation categories. The Reagan administration also added 3,619 miles to the National Wild and Scenic Rivers program, and over 1,300 square miles to the National Estuarine Reserves.

Table 1: Millions of Acres of Protected Land Added during Reagan Administration

Protected Land Category	Acres Added (Millions)
National parks	3.1
National wildlife refuges	19.2
National forests	4.02
National Wilderness Preservation System	11.75
Total	38.07

^{Source: Council on Environmental Quality, 1993 annual report, data tables 66-69.}

It is a mistake, however, to judge land preservation by the single metric of federal preservation. The amount of land privately preserved (i.e., through land trusts, conservation easements, and so forth), or preserved by the states, has been growing rapidly. According to one federal report, the total amount of public and private land dedicated to parks and wildlife increased from 98 million acres to 225 million acres between 1978 and 1987.[7]

Meanwhile, what is the total amount of public land proposed for resource development by the Bush administration? What percentage of public land does it amount to? One percent? Five percent? Environmental critics offer no statistics on this question, in part because no aggregate measures are easily available. The amount is surely very small (probably less than 1 percent), as the example of the much-contested proposal to explore for oil and gas in the Alaska National Wildlife Refuge (ANWR) demonstrates. ANWR, at 19 million acres, is about the size of South Carolina; the area proposed for exploration covers fewer than 2,000 acres, or 0.01 percent of the total land area.

Air Quality

(A) "The Administration has proposed or supported amendments that would emasculate the Clean Air Act, has dragged its feet on issuing regulations the law requires, and has abolished or watered down existing regulations. Specifically, the Administration has called for amendments to the law that would do away with requirements that, in polluted areas, new sources of pollution (such as power plants, refineries, chemical plants) use the most effective pollution controls available. . . . It has changed clean air rules to allow many coal-burning plants to dump more sulfur dioxide into the air. . . . Pollution will increase because the rules designed to control it and the agencies that enforce the rules are being systematically weakened. The Administration's attention has focused upon easing the burdens for polluters instead of protecting the public."

(B) "The Administration finalized a set of changes to create more loopholes in . . . the part of the Clean Air Act that requires factories to install modern pollution control devices whenever they make a change that increases pollution."

Statement (A) is from the 1982 FOE report; statement (B) is from the Sierra Club, July 29, 2002.

Reality check: Air pollution fell sharply during the Reagan years. Between 1981 and 1989, emissions and ambient levels of the six criteria air pollutants regulated under the Clean Air Act that fell significantly. (In some cases, the ambient level fell by a larger amount than emissions.) Table 2 displays the declines in air pollution during the Reagan years.

Table 2: Air Quality Trends during the Reagan Administration, 1981-1989

Pollutant	Emissions	Ambient Level
Sulfur dioxide	-12.0%	-16.7%
Ozone*	-17.6%	-8.8%
Nitrogen oxides	-6.3%	0.0%
Carbon monoxide	-13.4%	-24.4%
Lead	N/A	-85.2%
Particulates*	N/A	-52.0%

^{Source: EPA Data Tables (www.epa.gov/ttn/chief/trends/trends01/ trends2001.pdf)
*Ozone emissions figures are for VOCs (volatile organic compounds); data unavailable for lead emissions; particulate emissions and ambient data are for TSP (total suspended particulates) and PM10; EPA measurements and methodology were changed in 1988.}

The long-term trend of declining air pollution has continued under the first year of the Bush administration, according to preliminary EPA data, and is certain to continue for the rest of this decade and beyond.[8] This does not stop environmentalists from ignoring the data and crying wolf. As can be seen from comparing statements (A) and (B), the environmental claims made about the Bush administration's proposed changes to the Clean Air Act's New Source Review program are identical to the incorrect claims made about the Reagan administration's stewardship of the Clean Air Act twenty years ago. For example, American Lung Association president John J. Kirkwood says, "The U.S. Environmental Protection Agency's announced changes to the Clean Air Act rules, known as New Source Review, are accounting gimmicks that will increase pollution and threaten public health."[9] Friends of the Earth president Brent Blackwelder says the Bush administration is already making our air dirtier: "The Bush EPA has made our water more polluted, our air dirtier, and our communities more at risk from toxic dumps."[10] Of course, Blackwelder offers no data to back up these claims, because none of the data do so.

The reasons for the long-term trend of falling air pollution have to do with changing technology, increasing wealth, and broad-gauge regulatory standards (such as vehicle emission targets) whose gains will continue to accumulate for years to come. Sometimes environmentalists recognize the deeper trend at work. The Sierra Club's Carl Pope recently remarked, "We've had the big national debate about whether we want clean air. There really isn't a big constituency out there for letting the air get dirty, or for mercury in fish, or for less parkland. We've had the dialog and we've pretty much settled it in terms of the American people's wishes."[11] Why then the sky-is-falling rhetoric? Any shift in policy away from litigation and centralized rule-making toward markets and local decision-making and control will diminish the political clout of national environmental lobbies, as can be seen in the next section.

Regulatory Reform

(A) "Under the Administration, 'Regulatory Reform' is a euphemism. In practice, it has come to mean reduced opportunities for public participation in policy making [and] increased opportunities for industry participation in government decisions. . . . The Administration has proposed to curtail the rights of citizens to propose lands as unsuitable for mining, to participate in permit reviews, and to play a role in other aspects of the regulatory program."

(B) "In recent proposals, the Administration has sought to scale back long-standing requirements for environmental reviews and public participation applying to highway construction, offshore oil development, and logging in our national forests."

Statement (A) is from the 1982 FOE report; statement (B) is from the Natural Resources Defense Council in January 2003.

The deeper reason for the environmental fury against the Bush administration, like the fury against the Reagan administration twenty years ago, is revealed in these two comments about "public participation" in the regulatory process. For more than twenty-five years lawsuits by environmental organizations have driven major aspects of regulatory policy.[12] The landmark environmental statutes of the 1970s provided explicitly for citizen participation and enforcement through litigation. In practice, of course, very few real citizens engage in this process; these statutory clauses have become the cornerstone for the empowerment of organized environmental lobbies as de facto official participants in the formulation of regulatory policy. (In fact, the EPA seldom formulates new rules without extensive consultation with environmental lobbies, because regulators know that if environmental lobbies do not like a rule, they will sue to have it changed to their liking.) In other words, this constitutionally dubious state of regulatory law places environmental lobbies in a privileged position in Washington.

Policy changes such as the Bush administration's "Clear Skies" proposal to lower air pollution through a market-based tradable emissions permit system, or reforms of the environmental review process requiring petitioners to identify tangible rather than speculative harms, threaten to diminish the privileged position environmental lobbies now enjoy. Special interest groups are understandably loath to surrender sources of political clout without a fight. In this respect the heated rhetoric of national environmental organizations represents politics-as-usual. The news media, which usually discounts the political calculations of interest groups, tends to pass along environmental scare stories at face value. This does a disservice to serious environmental policy, as the next designee as EPA administrator is certain to find out.

Notes

[1] www.environmentaldefense.org/pressrelease.cfm?ContentID=2808 (accessed May 29, 2003).

[2] www.nrdc.org/bushrecord/other_more.asp#1342 (accessed May 30, 2003).

[3] http://newyork.sierraclub.org/rochester/ statement_on_epa_leader_quits.htm (accessed May 31, 2003).

[4] www.msmnc.com/news/916618.asp?0cv=KB20 (accessed May 29, 2003).

[5] Robert Perks and Gregory Wetstone, Rewriting the Rules, Year-End Report 2002: The Bush Administration's Assault on the Environment (Washington, DC: National Resources Defense Council, January 2003), p. 29.

[6] www.greenpeaceusa.org/ "Call Forest Service Chief Demanding He Protect Our National Forests" (accessed May 29, 2003). [I added this to fill out the citation a little, since the URLs on this website don't show the viewer much.]

[7] A. B. Daugherty, Major Uses of Land in the United States, 1987 (Washington, DC: U.S. Department of Agriculture, 1991).

[8] See Joel Schwartz's forthcoming study for the American Enterprise Institute, "No Way Back: Why Air Pollution Will Continue to Decline." A preliminary copy of this study can be downloaded at http://www.aei.org/events/eventID.280,filter./ event_detail.asp.

[9] www.lungusa.org/press/envir/air_061402.html (accessed May 29, 2003).

[10] www.foe.org/new/releases/0503whitman.html (accessed May 29, 2003).

[11] http://www.sierraclub.org/planet/200304/carl_pope.asp (accessed May 29, 2003).

[12] The classic analysis of the role of litigation in the making of air-pollution policy is R. Shep Melnick, Regulation and the Courts: The Case of the Clean Air Act (Washington, DC: Brookings Institution, 1983).

Steven F. Hayward is the F. K. Weyerhaeuser Fellow at AEI and the author of the Index of Environmental Indicators, published jointly by the Pacific Research Institute and AEI. (To order the 2003 edition call 800.276.7600 or 415.989.0833 or go to www.pacificresearch.org/environment03.)

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