Federal air quality rules must be based on science – not used to stifle energy and industry
It’s called the Clean Air Act, but it was never intended to ensure pure, pristine air. Congress wanted America to have safe, healthy air, and regulations based on solid scientific and medical studies.
The law says costs cannot be considered where human health and safety are actually at stake. But legislators also understood that efforts to bring emissions to zero are unnecessary, technologically impossible, extremely expensive, harmful to electricity generation, factory output, job creation and retention, and living standards – and thus likely to reduce human health, wellbeing and longevity.
The Obama Environmental Protection Agency ignored these facts and employed highly dubious analyses to justify stringent new emission standards that impose enormous costs for no health benefits. The new Congress and Trump Administration must now restore integrity, rigor and balance to the process.
A good place to begin is with EPA’s rules for fine particulates: PM2.5, soot particles smaller than 2.5 microns (a fraction of the size of pollen and mold spores). EPA claims reducing PM2.5 emissions from power plants, factories, refineries, petrochemical plants, cars, light trucks, and diesel-powered vehicles and heavy equipment will save countless lives. In fact, it says, nearly all the (supposed) benefits from its Clean Power Plan and other recent rules are actually “ancillary benefits” from reducing PM2.5 levels.
Premature mortality is “associated with” fine particle pollution “at the lowest levels measured,” Obama EPA Administrator Gina McCarthy has said. “There is no level at which premature death does not occur.” If we could further reduce particulate pollution, previous Obama EPA chief Lisa Jackson told Congress, it would be like “finding a cure for cancer” – hundreds of thousands of lives saved.
These assertions have no basis in reality. Even EPA’s own studies show they are predicated on two things: epidemiological analyses that count deaths within normal variations in death rates and attribute them to soot emissions; and experiments that unethically exposed humans to PM2.5 concentrations at levels which EPA says cause cardiovascular and respiratory disease, cancer and people “dying sooner than they should.”
The agency’s air pollution epidemiological studies are compromised by uncontrollable “confounding factors.” No data exist on actual individual exposure levels, so researchers cannot reliably attribute specific deaths to particulates, emergency room physician John Dunn explains. Moreover, PM2.5 particles emitted by vehicles, power plants and factories cannot be separated from particles from volcanoes, forest fires, construction projects, dust storms, agricultural activities, and even cigarettes that send hundreds of times more tiny particles into lungs than what EPA says is lethal if they come from sources it regulates.
Nor does a death certificate determine whether a death was caused by airborne particles – or by viruses, bacteria, dietary and exercise habits, obesity, smoking, diabetes, cold weather or countless other factors.
If particulates are a short-term cause of death, there should be a clear association between bad air and deaths within clusters of similar areas, and effects should be consistent across clusters, notes statistician Stan Young in discussing causation versus association. However, a recent re-analysis of 1969-1974 data from 533 US counties confirmed the previous conclusion: improved air quality did not reduce mortality.
Similarly, in 2002, Canadian forest fires sent massive amounts of smoke (composed largely of PM2.5 particles) into Boston and New York City. EPA doctrine says deaths should have shot up, but they did not. 2008 forest fires in California engulfed Los Angeles in smoke and PM2.5 soot, but again deaths did not increase. In fact, they were below normal as soot levels soared during the fires.
EPA has not proposed a plausible medical explanation to support its claim that super-tiny particles cause multiple diseases and kill people by getting into their lungs or bloodstreams. It just counts deaths during arbitrarily chosen intervals of days, and says differences in the number dying in relation to air pollution levels represents “premature” deaths – rather than the fact that more people die on some days than others.
People certainly did die during some atmospheric inversions that trapped large quantities of airborne chemicals in urban areas like London in 1952. However those pollutants have been dramatically reduced in America’s air. For example, since 1970 US cars have reduced tailpipe pollutants by 99% and coal-fired power plants have eliminated over 90% of their particulate, sulfur dioxide and nitrogen oxide emissions.
EPA thus sponsored 20 years of lab experiments that exposed human test subjects to high air pollution levels. That raises legal, ethical and scientific problems. US laws, the Nuremberg Code, the Helsinki Accords and EPA Rule 1000.17 make it unethical or illegal to conduct toxicity experiments on humans.
In addition, researchers failed to advise volunteers that EPA claims the pollution they were going to breathe is toxic, carcinogenic and deadly. Moreover, many of the human guinea pigs were elderly, asthmatics, diabetics, people with heart disease and even children – the very people EPA claims are at greatest risk and most susceptible to getting sick or dying from the pollutants volunteers would breathe.
Finally, test subjects were exposed to eight, thirty or even sixty times more particulates per volume of inhaled air – for varying periods of time: up to two hours – than they would breathe outdoors during routine physical activities. And yet, they did not get seriously ill or die. That raises important questions:
* If PM2.5 particulates are dangerous or lethal when emitted by factories or vehicles, and there is no safe threshold – how can those same pollutants be harmless to people who were intentionally administered pollution many times higher, and for longer periods, than they would encounter in their daily lives? Why didn’t those test subjects have seizures, develop lung, cardiac or cancer problems, or die?
* If they did not, how can EPA say there is no safe level, all PM2.5 particulates are toxic, its regulations are saving countless lives, and regulatory benefits vastly outweigh their multi-billion-dollar annual costs?
Simply put, there is no basis for these claims – or for the Obama EPA’s war on fossil fuels and factories.
America’s air is healthy and safe. EPA’s PM2.5 emission standards and regulations are clearly based on bald assertions, rank conjecture, epidemiological studies that provide no scientific support for the agency, and human testing that actually proves small particulates pose no toxic or lethal risk to risk to human health, even at levels dozens of time higher than what EPA claims are dangerous or lethal in outdoor air.
Any computer models based on these assertions and studies are thus garbage in-garbage out game playing that provide no valid basis for claims about lives saved or regulatory benefits exceeding costs.
(A thorough analysis of this untenable situation can be found in JunkScience.com director Steve Milloy’s new book, Scare Pollution: Why and how to fix the EPA, which documents the ways EPA uses deceptive tactics to frighten people into believing the air they breathe is likely to sicken or kill them.)
The incoming Trump EPA needs to conduct its own internal review of existing agency PM2.5 claims, documents, emission levels and regulations – and fund an independent review by respected medical experts – to determine whether they are based on honest, replicable science. If they are not, everything based on the fraudulent PM2.5 pollution narrative should be subjected to a total do-over.
While all that is being done, EPA should suspend implementation of all policies, guidelines and rules based on the scheme. It must also inform legislators, journalists and citizens about the facts – and clearly and vigorously address inevitable environmentalist objections and denunciations.
The new EPA and Congress should also require that all past, current and future researchers make their raw data and methodologies available for outside peer review. They should stop funding activist groups that have engaged in collusive lawsuits or rubberstamped EPA actions, including the American Lung Association. Last, they should fully reform the agency’s supervisory panels, board of scientific counselors and Clean Air Act Scientific Advisory Committee (CASAC) – and repopulate them with experts who do not have government grant or other conflicts, and will bring integrity and rigor to the scientific process.
These steps will help make EPA credible and accountable, and its actions based on solid science.
Paul Driessen is senior policy analyst for the Committee For A Constructive Tomorrow (www.CFACT.org) and author of Eco-Imperialism: Green power - Black death and other books on the environment.