| WASHINGTON - October 24 - The non-profit Clean Air Trust today named John Graham, the
White House Office of Management and Budget's regulatory czar,
the clean air "villain of the month" for October.
Czar Graham earned this dubious distinction by launching a
bizarre attack on a proposed EPA rule designed to require
less-polluting recreational vehicles, including snowmobiles. It
was the first significant air pollution control proposal issued by
the Bush Administration -- and it isn't particularly tough -- but
the Czar apparently felt he had to attack it on general
anti-regulatory principles. And he showed that even the most
fervent anti-government spokesman can spout nonsensical bureaucratic
gobbledygook.
First, a little background on the Czar: As has been widely
reported, in his prior job he ran the industry-funded Harvard
Center for Risk Analysis, an outfit that was paid to lend an ivy
patina to corporate efforts to undermine various health and safety
standards -- he was sort of a tweedy version of that poor fellow
who runs that tiresome "junk science" Web site.
Health and environmental groups opposed the Czar's nomination as
director of OMB's Office of Information and Regulatory Affairs, but
the business lobbyists called in their chits and got the Senate to
confirm him. Czar Graham is wasting no time putting his unique
stamp on the job of reviewing all federal rules.
Consider, for example, his treatment of EPA's "snowmobile"
proposal, which is the subject of an EPA hearing today. EPA
proposed a modest reduction in pollution from new recreational
vehicles because of concerns that: 1) most recreational boats spew
huge volumes of unburned fuel into lakes and rivers; 2)
snowmobiles, dirt bikes and off-highway motorcycles tend to stink
up national parks as well as create shroud-like haze; 3) these
vehicles are a significant percentage of overall pollution.
Environmentalists have assailed the EPA proposal as far too weak.
State air pollution regulators are also raising concerns.
Enter the Czar. In a recent letter to EPA, he charged that EPA
did not evaluate the effect of its proposal on the "attributes" of
engines used in recreational vehicles. "We believe it is important
to develop an estimate of the value of these attributes," wrote
Czar Graham.
Think about that for a second. Are all attributes of equal
value? Are there "sound" attributes and "junk" attributes? Does
a one-size-attribute fit all? (Those interested in delving deeper
into philosophical questions of this sort should dust off Plato's
dialogue, Meno, and review Meno's discussion with Socrates on the
attributes of excellence (see note a). Plato, of course, favored
government by philosopher-kings and the Czar may well see himself
as one of these.)
Czar Graham also demanded that EPA include "the loss in consumer
surplus" associated with the proposal. "The consumer surplus loss
could be large," he warns.
The trouble is, we can't figure out what the heck he means by
the term "consumer surplus." Is it something like a tax refund for
overpayment? Is it the difference between the total we owe -- and
the monthly minimum payment -- on our Visa card? Or could it be
what a grandmother thinks ought to be spent on the grandkids versus
what granddad thinks they can afford? Do less affluent consumers
have the same surplus as rich ones for the purpose of this analysis
-- or are we talking the consumer surplus of the "average man?"
The bottom line here is it appears that the Czar plans to make
it difficult for an agency like EPA to issue even a mediocre rule
-- and he'll make up a lot of jibberish if he doesn't have a real
complaint about the rule.
------
(a) Consider this sample:
Meno: Let us take first the attribute of excellence in a man: he
should know how to administer the state, and in the process to
benefit his friends and harm his enemies. He must also be careful
not to suffer harm himself. A woman's excellence may also be easily
described: her duty is to order her house, and keep what is
indoors, and obey her husband. Every age, every condition of life,
young or old, male or female, slave or free, has a different
attribute of excellence. There are numberless types of this
attribute, and no lack of definitions of them. For the attribute of
excellence is relative to the actions and ages of each of us in all
that we do.
Socrates: How fortunate I am, Meno! When I ask you for one
attribute of excellence, you present me with a swarm of them.
Suppose that I carry on the figure of the swarm, and ask of you,
What is the attribute of the bee? And you answer that there are
many kinds of bees, and I reply: But do bees differ as bees,
because there are many and different kinds of them; or are they not
rather to be distinguished by some other quality, as for example
beauty, size, or shape? How would you answer me?
Meno: I guess bees do share the common attribute of being
bees...
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