A few weeks ago, there was a good deal of Internet debate about a proposal affecting coal- and wood-fired pizza ovens under consideration by the city of New York. Opponents of the measure described it as a ban. Supporters said it was nothing of the kind. Both were, either by intention or by error, misrepresenting the issue.
The pizza oven ban wasn’t an actual ban in that it never says thou shalt not operate wood-fired pizza ovens. The pizza oven ban is rather a textbook example of what government does when it wants to force a certain outcome but still appear to be fair. The proposal created a set of obstacles that would drive some coal- and wood-fired pizza oven operators out of business and/or significantly cut into their profits.
Americans pay an enormous amount of tax dollars funding the U.S. Environmental Protection Agency (EPA) and a host of state and local agencies that operate beneath the EPA’s umbrella. Together they’re charged by Congress with protecting human health and the environment on a macroscopic scale. They regularly evaluate sources of pollution to determine which are most important in terms of the absolute mass of pollutants emitted, and, as important, which are the most significant in terms of local exposure to pollutants that present a more significant risk.
When a municipality, even one as large as New York City, steps in to put one particular source of pollution under the microscope when neither the federal nor state authorities charged with managing everything has chosen to do so, we should ask ourselves why they’re doing so. What makes this particular environmental risk so important? Does this source type really present a unique and current danger to the community that neither the federal nor state authorities have considered? If old wood-fired pizza ovens presented a significant threat to the health and welfare of citizens of New York City, why didn’t the EPA or the New York Department of Environmental Conservation identify that threat and act upon it?
There are two ways that air pollution emissions can be considered a significant threat to human health and the environment. The first is that emissions from a particular type of source account for a significant percentage of those emissions across the nation, within the state, or in a municipality.
The pollutants of concern most often cited in support of the proposed wood-fired pizza oven ban is particulate matter less than 2.5 microns in aerodynamic diameter (PM 2.5). Are older wood-fired pizza ovens a significant source of these emissions? They aren’t.
According to the EPA’s latest national emissions inventory, about 15,000 tons of PM 2.5 are generated in New York City annually. Uncontrolled wood-fired pizza ovens account for about seven of those tons. If you’re keeping score at home, that’s less than 0.05 percent of all PM 2.5 emissions in New York City. Emissions from wood-fired pizza ovens are about as innocuous as emissions can get in the grand scheme of things.
But how about that local effect? Are neighbors of wood-fired pizza ovens exposed to a disproportionate risk because of the proximity of the pizza oven exhaust to their homes? If we are to consider that issue fairly, let’s consider all of the sources of PM 2.5 emissions that can occur in close proximity to a resident of New York City. These sources include, but are not limited to, the following: fireplaces, two- and four-stroke engines used for gardening and snow-blowing, charcoal grills, natural erosion, internal combustion engines associated with mobile sources, and a host of other processes that can generate PM 2.5.
Small two- and four-stroke engines of the sort used in lawnmowers and snow blowers accounted for almost 300 tons of PM 2.5. Residential fireplaces? Sixteen tons. Charcoal used for smoking food products? Just short of 1,000 tons.
The bottom line here is that old wood-fired pizza ovens are a very, very small source of fine particulate emissions relative to all the industrial, commercial, residential, and natural sources of the pollutant—so small that it’s difficult to imagine why New York would go after them, unless it’s simply to score points with the green crowd.
