I concur in the portions of the majority opinion concluding that the State Air Resources Board may not reject department recommendations as to the health effects of air pollution and that the board may incorporate a “margin of safety.”
However, I must dissent from the majority’s determination that the board need not consider the economic effects of proposed standards of ambient air quality. In my view, the board must consider the economic consequences of proposed standards, including the potential loss of industry and jobs and the costs of compliance. I am compelled to this view by the language of the governing statute, Health and Safety Code section 39605,1 consideration of the board’s function as a quasi-legislative agency in the light of fundamental *530principles of governmental responsibility, the history of statutory regulation of air pollution, and other provisions of the Mulford-Carrell Air Resources Act (§ 39000 et seq.).
We should not construe the statute inconsistently, as the majority do, by interpreting section 39606 broadly to permit consideration of a “margin of safety” but interpreting the section narrowly to exclude consideration of the economic consequences of proposed action. We should not construe a statute establishing a government agency with broad quasi-legislative power to permit it ostrich-like to bury its head and refuse to consider the consequences of its own actions, such as the potential loss of thousands of jobs resulting from its standards. In the absence of the clearest language that the Legislature intended the agency to act irresponsibly, we may not conclude that it intended such a result.
Recognizing that the economic consequences of air pollution regulation are potentially great and should not be ignored entirely, the majority take the position that local and regional authorities may take them into account and have “broad discretion to grant reasonable variances” {ante, p. 523) not only from local regulations but also from the board’s standards. I do not believe that the Legislature intended that, when the board establishes a standard of 25 micrograms of sulfates per cubic meter of air for a basin, local and regional authorities remained free to reject that standard by granting variances and to adopt a standard of 30 or 50 micrograms. Under the statutes, the board’s standards are binding on local and regional authorities, not merely guidelines or goals. Local and regional authorities are not in a proper position to adjust the standards adopted by the board, and to permit them to do so runs the risk of defeating the clean air goals of the legislation.
Obviously, effective implementation of the act will require sacrifices by many people. When the government establishes a program which necessitates sacrifices, there is all the more reason for it to show that the interests of those called upon to sacrifice for the common good were fully considered and not ignored by the bureaucracy. Health considerations are paramount, but in connection with such matters as safety factors and economic effects of air pollution, there is room for the consideration of economic impact of the standards to be adopted, and such consideration is required of the board by the statute and fundamental principles of responsible government.
Language of the Statute
The trial court concluded that the board violated section 39606 by failing to consider the effects on the economy of standards to be adopted. The court construed the statute to require the board to consider the economic costs of *531compliance with the standards adopted. It relied upon the language of the section, which is not limited to health and safety but also includes welfare, and the history of air quality regulation in California as showing legislative intent that the costs of compliance were to be considered. The court reasoned that local districts could not consider the economic impact of the standard but only the most economical method of meeting the standard, and that unless the state board considered the economic impact of its regulations no agency would. In this connection the court stated: “If the Legislature did not want [the board] to consider effects on the economy in carrying out the Legislature’s directive, it could simply authorize [the board] to adopt standards prohibiting the presence of all deleterious pollutants in the atmosphere. Such Draconian measures would certainly give complete protection to the health of all human beings but at the same time it would be disastrous to our economy.”
The board does not claim that it considered the costs to the economy of complying with the standards it adopted. Its position is that it need not consider such costs. It urges that the “effects on the economy” it is required to consider by section 39606 are the effects of air pollution on the economy, not the effect of the board’s standards.
In construing a statute to determine the intent of the Legislature we turn first to the words themselves for the answer. (Tracy v. Municipal Court (1978) 22 Cal.3d 760, 764 [150 Cal.Rptr. 785, 587 P.2d 227].)
The relevant portion of section 39606 provides that the board shall adopt “standards of ambient air quality for each air basin in consideration of the public health, safety, and welfare, including, but not limited, to health, illness, irritation to the senses, aesthetic value, interference with visibility, and effects on the economy.” (Italics added.) The reference to “public health, safety, and welfare” is ordinarily a reference to the police power of the state, reflecting the breadth of matters to be considered by the board, and the public welfare has long been held to embrace regulations designed to promote the economic welfare, public convenience, and general prosperity of the community. (E.g., Graham v. Kingwell (1933) 218 Cal. 658, 659 [24 P.2d 488].) The use of such terminology can only be read as meaning that the Legislature intended the matters were to be considered in a broad rather than restrictive light. Indeed, in the discussion of safety margins, the majority recognize: “The language of section 39606, directing the Board to adopt standards in consideration of the public health, safety, and welfare, reflects the breadth of matters to be considered by the Board.” {Ante, p. 516.) The view also finds support in the fact that the following clause is “including but not limited to,” again reflecting the breadth of the matters to be considered. Furthermore, the term “effects on the economy” gram*532matically relates to standards to be adopted rather than air pollution, a term not appearing in the section.
The majority initially argue that because standards cannot cause illness, irritate the senses, interfere with visibility or be aesthetically displeasing, the Legislature intended to focus the board’s attention on the effects of pollution. The majority then reason that the following term in the statute, “effects on the economy,” like its antecedents must be read to refer to the consequences of air pollution, rather than to the potential economic effects of air quality standards.
There are a number of defects in this line of reasoning. First, it omits mention of the first of the specified terms, health. No one claims that air pollution causes health; the thought is absurd and the majority’s categorization of the terms fails. This defect is alone obviously fatal to the majority’s argument but there are other equally clear objections to the argument.
Second, the majority’s reasoning is an attempt to limit the plain language of the statute, and it should be entitled to little, if any, weight when we are construing a statute which grants broad quasi-legislative power to an agency to consider “public health, safety, and welfare.” Obviously, the term “welfare” in this context is intended to be expansive rather than limiting, and a limiting rule of construction or reasoning designed to limit should not be applied.
Third, employment of the majority’s rule of construction appears inappropriate when we are considering a statute which grants broad quasi-legislative power to adopt standards and speaks of the matters to be considered. Because quasi-legislative power is granted, it is to be anticipated that the agency will balance several factors in adopting regulations. But the limiting rule of construction tells us, as the majority illustrate today, that all factors must be read to point in the same direction. If so, there is nothing to balance. Under the majority’s construction, it would seem to follow that the board which may employ safety factors and has nothing to weigh against the evils of air pollution should prohibit all air pollution, and it seems impossible to justify the standards adopted insofar as they permit any air pollution.
Fourth, the majority overwork their rule of construction by using it to limit not only the term “effects on the economy” in the statute but also the word “welfare.” Even assuming that the term “effects on the economy” reasonably might be limited to economic effects of air pollution, this is not helpful to the majority. Limiting the term “effects on the economy” on the basis of its associates may not serve to also limit the term “public . . . *533welfare” because the Legislature in no uncertain terms has told us that it may not. The wording of section 39606 is to adopt standards “in consideration of the public health, safety, and welfare, including, but not limited to, .. . effects on the economy.” (Italics added.) Thus, even if we agree with the majority that “effects on the economy” must be limited to effects on the economy caused by air pollution, we may not use the restricted definition of “effects on the economy” to limit the meaning of the term “public . . . welfare,” because the Legislature has expressly told us that “effects on the economy” does not limit the preceding words by stating, “including, but not limited to.” We are left then with the term “public . . . welfare” unrestricted, and no citation of authority is required for the proposition that public welfare, absent limiting provision, encompases economic concerns generally.
Fifth, the board is not merely an investigating agency but is a regulatory agency. Thus, it is not merely concerned with the effect of air pollution on such matters as health and the economy but ultimately must determine the effects, if any, of proposed standards so that it may choose the appropriate one.
Finally, it appears to me that the majority position is internally inconsistent in its interpretation of section 39606. First, the majority tell of the breadth of matters to be considered by the board in concluding that the board may adop( safety margins. (Ante, pp. 515-516.) There is no discussion of reasoning limiting the board to consideration of the effects of air pollution. The reasoning is only invoked as to economic effects. Obviously, safety margins are no more a cause of air pollution than are standards. Safety factors are no more associates of illness, irritation of the senses, interference with visibility or aesthetically displeasing than are the economic consequences of potential standards. The majority only appear to apply their reasoning when they find it convenient.
I find it difficult to conceive of broader language that the Legislature might have used to describe matters that a state agency may consider than “public health, safety, and welfare.” Further, “effects on the economy” points directly to economic impact of the agency’s work. Even if the latter words did not do so, they are prefaced by the familiar term “including, but not limited to” making it abundantly clear that the Legislature did not want the word “welfare” limited to succeeding terms. The language of the statute thus requires the board to consider the economic impact of proposed standards before adopting them.
Governmental Responsibility
The board is granted quasi-legislative powers the exercise of which may have a profound effect on our society, including health, social and economic *534matters. Common sense dictates that in the absence of the clearest showing of legislative intent to the contrary, the matters to be considered by the board in exercising its powers should be commensurate with its responsibilities. The board is charged not merely with determining the need for regulation but must determine the best methods of regulation and the extent of regulation. To do its job responsibly it must consider the consequences to health and the economy of the proposed regulations. By ignoring the consequences of its own regulations, an agency runs the risk that it may cause more mischief than it cures.
Obviously, ambient air quality standards adopted by the board may have major effects on our economy, possibly substantially limiting industry and employment. In a closely related code section, the Legislature has recognized that clean air regulations may have important economic effects and made clear its intent to require the board to consider the economic impact of its regulations. Providing that the board shall adopt emission standards for new motor vehicles, the Legislature stated: “Prior to adopting such standards, the state board shall consider the impact of such standards on the economy of the state, including, but not limited to, their effect on motor vehicle fuel efficiency.” (§43101.)
The language of the section, “impact ... on the economy,” is not substantially different from “effects on the economy” in section 39606, and the additional words “of such standards” in section 43101 do not warrant a distinction because section 39606 is concerned with matters to be considered in adopting standards. Motor vehicle fuel efficiency is an economic matter, and section 43101 tells us that it is “included” in “impact ... on the economy.” Effects on the economy likewise should be read to include relevant economic concerns.
Automobile emissions are a major cause of air pollution. The legislative determination that impacts on the economy are to be considered in adopting emission standards reflects not only legislative concern that the standards adopted might have undesirable effects on the economy but also legislative belief that the agency can effectively consider those effects with the health hazards of air pollution.2
The trial court recognized that unless economic impact of proposed standards was considered by the board, there was a danger that the standards adopted would be disastrous to our economy. Because the board refused to *535consider evidence as to economic effects, we do not know whether the standards adopted will have the effect of crippling some industries, causing widespread layoffs, and preventing the normal growth of industry.
Statutory History and Administrative Construction
The historical background confirms that the board must consider the impact of proposed standards on the economy. Prior to 1967, the health department adopted standards for the quality of the air. The original provision made no reference to the public welfare or economic impact. (Former § 426.1, Stats. 1959, ch. 835, p. 2885.) Local districts were authorized to regulate air pollution (former § 24260) but there was no provision making the department’s standards mandatory for the districts. Thus, the standards were goals rather than regulations.
In 1967 the Legislature authorized the board to adopt ambient air quality standards providing for the first time for consideration of the public welfare including effects on the economy. It also provided that local districts shall comply with the standards of the board, and nothing in the law excused them because they may have believed that the board adopted a standard which was uneconomic. (Stats. 1967, ch. 1545; former §§ 39051, 39313.) In addition, the statutory scheme empowers the board to oversee the effectiveness of local programs and regulations (§ 41500, subd. (b)), and the board has adopted stricter regulations for a district when it found the district’s emission regulations too lenient. (Stauffer Chemical Co. v. Air Resources Board (1982) 128 Cal.App.3d 789, 793 [180 Cal.Rptr. 550].) As the trial court concluded, before 1967 local districts could be expected to consider local economic concerns in adopting pollution regulations to accomplish the health department goals but when the Legislature provided for mandatory standards to be adopted by the board it provided for the board’s consideration of economic effects of these standards.
The majority’s argument on the basis of long-standing administrative interpretation (e.g., Rivera v. City of Fresno (1971) 6 Cal.3d 132, 140 [98 Cal.Rptr. 281, 490 P.2d 793]), and the reenactment rule (e.g., Division of Industrial Safety v. Municipal Court (1976) 61 Cal.App.3d 696, 701 [132 Cal.Rptr. 573]), is predicated on title 17 of the California Administrative Code, section 70101. The section is a general statement of policy. One provision of the section states: “The objective of ambient air quality standards is to provide a basis for preventing or abating the effects of air pollution, including effects on health, esthetics and economy.” The question before us is not whether the board shall consider the effects of air pollution on the economy; under any interpretation of section 39606 the board may consider the effects of air pollution on the economy. The question is whether *536the board must consider the impact of its standards on the economy. The regulation is silent as to that issue. Moreover, the authority cited for the regulation is not section 39606 but two other code sections. In these circumstances, there is no long-standing administrative interpretation limiting the broad language of section 39606 and therefore no reenactment following administrative interpretation.
The majority also rely upon Lead Industries Ass’n v. Environmental Protection (D.C. Cir. 1980) 647 F.2d 1130, 1148, where it was held that in establishing ambient air quality standards under the Clean Air Act (42 U.S.C. § 7401 et seq.) the administrator need not consider economic or technical feasibility. The court pointed to statutory history for the view that if industries could not meet the standards, they should be shut down or come to Congress for relief. (647 F.2d at pp. 1148-1154.) There is no comparable legislative history for the state statutes.3 The federal court also states that there is no language in the federal act that economic feasibility was to be considered. In contrast, section 39606 requires the board to consider economic effects.
The relationship between the two statutes provides further reason to require consideration of economic effects when the board goes beyond implementation of the federal act. The federal act provides for state implementation of the federal standards. There are primary federal standards which the state must seek to implement within five years, and secondary standards to be implemented within a reasonable time which may be more strict than the primary standards. (Lead Industries Ass’n v. Environmental Protection, supra, 647 F.2d at pp. 1137, 1180.) In addition to its duty to adopt ambient air standards under section 39606, the board is directed to implement the Clean Air Act. (§ 39602.) However, the Legislature subsequently limited the implementation power, providing: “Notwithstanding any other provision of this division, the state implementation plan shall only include those provisions necessary to meet the requirements of the Clean Air Act.” {Ibid.) The effect then of sections 39602 and 39606 is that the board must implement the Clean Air Act, but when it goes beyond the federal clean air standards, it must consider broad factors such as the public welfare and economic effects of its standards, including not only the potential costs of devices to limit air pollution, but also potential limitations on economic growth and resulting loss of jobs.
Local and Regional Authorities
The majority, in apparent recognition that the economic consequences of application of the board’s standards are potentially great and should not be *537ignored entirely, take the position that the power to grant variances given to the local and regional agencies permits them to grant variances from the state standards. In my view the local and regional agencies may grant variances from their rules and regulations but may not grant variances from the standards established by the board. To permit local districts to depart from the standards adopted by the board is contrary to the statutory pattern and specific provisions of the statutes, creates an administrative quagmire, and jeopardizes the entire clean air program.
As pointed out in Stauffer Chemical Co. v. Air Resources Board, supra, 128 Cal.App.3d 789, 792-793, “[ujnder the air pollution control provisions of the Air Resources Act, as amended (Health & Saf. Code, § 39000 et seq.), the Board is under a duty to ‘[ajdopt standards of ambient air quality for each air basin [in the state] ’ (§ 39606, subd. (b)). Once adopted, it becomes the duty of local and regional air quality districts, including respondent district, to promulgate and implement rules and regulations reasonably assuring achievement and maintenance of the state standards. (See §§ 40000-40002.) The statutory scheme empowers the Board to oversee the effectiveness of local programs and regulations (see § 41500, subd. (b)) with ultimate authority to establish a program or ‘rules and regulations . . . necessary to enable the district to achieve and maintain such ambient air quality standards.’ (§ 41504, subd. (a).)3” (Fn. 2 omitted.)
In Stauffer Chemical Co., the board adopted regulations superseding regulations adopted by the Bay Area Air Quality Management District governing sulfur dioxide emissions from industrial facilities in the Bay Area. The board’s regulation reduced the amount of allowable sulfur dioxide emissions from specific sources. The court upheld the board’s regulations. Section 41504, subdivision (a) and the case show that the board is to ultimately determine the air quality standard and that to assure conformance to its standard it may supersede local regulations. To permit local authorities to grant variances from the board’s standard of 0.05 parts per million sulfur dioxide and establish a standard of 0.06 parts per million appears inconsistent with the board’s power to insist that local rules and regulations achieve its standards.
Other statutes similarly make clear that it is for the board rather than local authorities to determine whether local conditions warrant a special standard of ambient air quality. The basic statute with which we are concerned, *538section 39606, provides that the board shall divide the state into air basins and adopt “standards of ambient air quality for each air basin in consideration of the public health, safety, and welfare . . . .” (Italics added.) Thus, the basic statute authorizing the board to adopt standards contemplates that those standards may vary on the basis of local concerns.
The local district’s power to adopt rules and regulations is expressly made subject “to the powers and duties of the state board” (§ 40001), and thereby emphasizing that local authorities must conform to the board powers, and there is nothing to indicate that they may claim some exemption based on economic hardship or otherwise.
Most importantly, the provision granting districts power to grant variances provides only for variances from the provisions of section 41701 (a provision prohibiting emissions greater than a defined opacity) and from district rules and regulations. The section reads: “Any person may apply to the hearing board for a variance from Section 41701 or from the rules and regulations of the district. ...”(§ 42350.) The absence of any reference to state board standards should be conclusive in the circumstances before us.
Practical considerations also point to the conclusion that the districts should be bound by the standards adopted by the state agency and are not free to depart from them by granting variances. If the district on the basis of local economic hardship is to be permitted to grant variances from the sulfur dioxide standard of 0.05, the local district should before doing so weigh health and other hazards against the economic hardship. But to do this the districts would have to consider all the health and other evidence considered by the board. Such a great undertaking does not seem contemplated by the variance procedure.
Rather, the districts adopt rules and regulations attempting to meet the board’s standards, and the variance procedure contemplates that variances to the districts’ rules and regulations when coupled with the rules and regulations will not violate the board’s standards. If local authorities are of the view that the board’s standards are unduly restrictive and will result in great and unjustified economic hardship, their remedy is to request the board to reconsider the standards for the basin.
The variance procedure does not contemplate that variances will be a means to avoid compliance with the board’s standards and should not serve to jeopardize the clean air program. As we have seen, the 1967 statute was adopted when the former law which made the state standards mere goals or guidelines proved ineffective, and the 1967 law required the districts to *539comply with the state standards. (Stats. 1967, ch. 1545; former §§ 39051, 39313.) The variance power should not be applied to reduce the state standards to goals or guidelines.
I am satisfied that the board must consider the economic impact of contemplated standards. This does not mean that the board must enter into a formal cost-benefit analysis attempting to put monetary valuations on the benefits of reduced air pollution.4 Rather, the board must consider the impact on the economy of its standards along with the other factors enumerated in section 39606.5
The board’s refusal to consider evidence as to the economic effect of standards to be adopted requires affirmance of the judgment. Had the board considered economic effects, it might have adopted a combined standard for sulfates or used a different safety factor in establishing the standard for sulfur dioxide. (Cf. Southern Cal. Gas Co. v. Public Utilities Com. (1979) 23 Cal.3d 470, 477 [153 Cal.Rptr. 10, 591 P.2d 34]; City and County of San Francisco v. Public Utilities Com. (1971) 6 Cal.3d 119, 129 [98 Cal.Rptr. 286, 490 P.2d 798].)
I would affirm the judgment.
Unless otherwise indicated, all statutory references are to the Health and Safety Code.
Because the Legislature has provided for weighing health and economic concerns with respect to automobile emissions, arguments of amici that it is impossible or impractical to do so appear questionable. Moreover, the Legislature as well as individuals constantly weigh economic concerns with health, social and personal concerns.
The state statutes were first adopted prior to the federal act, and there is no basis to conclude that our statutes were adopted in the light of the Clean Air Act legislative history.
Subdivision (a) provides: ‘If, after a public hearing, the state board finds that the program or the rules and regulations of a district will not likely achieve and maintain the state’s ambient air quality standards, the state board may establish a program, or portion thereof, or rules and regulations it deems necessary to enable the district to achieve and maintain such ambient air quality standards.’ ”
In American Textile Mfrs. Inst. v. Donovan (1981) 452 U.S. 490 [69 L.Ed.2d 185, 101 S.Ct. 2478], the United States Supreme Court rejected a cost-benefit analysis for OSHA as to standards for toxic materials and harmful physical agents. (452 U.S. at p. 512 [69 L.Ed.2d at p. 203].) However, the court also held that the administrator must determine economic feasibility of his regulations. (452 U.S. at pp. 522-536 [69 L.Ed.2d at pp. 209-218].)
I concur in the portion of the majority opinion dealing with procedural issues. However, I must point out that the Japanese telegram was contrary to the report of the health department in that the latter stated that no report had indicated health effects at concentrations of sulfur dioxide less than . 10 parts per million averaged over 24 hours whereas the Japanese telegram indicated health effects at lower levels. As the majority hold, the board must follow health department recommendations for standards relating to health effects. (Ante, pp. 511-512.) When the board is confronted with evidence presented which contradicts the health department report, it should call the evidence to the attention of the department and solicit its views. It did not do so. However, the parties did not request additional health department comment, and in this proceeding the parties did not claim that the board erred in failing to seek health department comment. In these circumstances, we may not set aside the sulfur dioxide standard on the basis of failure to consult the health department.