By the Texas Public Policy Foundation
The U.S. Environmental Protection Agency relied on four highly questionable assumptions in 2009 to drastically inflate the health benefits from far-reaching new rules, according to a new report published by the Texas Public Policy Foundation.
“For the last three years, the EPA has justified a series of strict and incredibly expensive new air quality regulations on the assumption that even trace levels of particulate matter can accelerate death,” said the report’s author, Kathleen Hartnett White. “But the science behind the EPA’s new approach to assessing health risks is deeply flawed and misleads the public.”
Since 2009, the EPA has attributed risk of “early death” or shortened lifespan from fine particulate matter (PM 2.5) concentrations far below the health protective national standards and even below natural levels that would occur absent human activity. The EPA is justifying the many unprecedented new regulations commonly known as the EPA train wreck on the basis of the health benefits gained from reducing these new risks from already low levels of particulate matter – a substantial portion of which is airborne dust.
The new regulations, however, target other pollutants and not PM 2.5. In the recently finalized rule to reduce mercury emission from power plants, EPA estimated 99.9 percent of the health benefits derive from coincidental reduction of particulate matter at levels far below the already conservative federal standard. Without this methodology, the cost of reducing mercury would be far higher than the benefits of further reduction of mercury.
In the report, White challenged four key assumptions at the root of the EPA’s new risk-assessment methodology:
- PM 2.5 causes early death.
- There is no level of PM 2.5 below which risks of premature death cease.
- The EPA’s new rules are necessary to prevent hundreds of thousands of deaths.
- Coincidental reduction of PM 2.5 is sufficient justification for new regulations designed to control other pollutants.
“The EPA’s manipulation of cost-benefit analyses to project massive benefits at comparatively modest cost denies policymakers and the public the information needed to weigh the many trade-offs involved in complex societal decisions about unacceptable risks,” White said. “Economic impact does matter, and it matters to human health. Life span and health are strongly correlated with the opportunity to work and make a good income.”
The report recommends amendment of the Clean Air Act to establish minimal criteria for rigorous scientific risk assessment of health effects.
The report, “EPA’s Pretense of Science: Regulating Phantom Risks,” is available for download from the Foundation’s website, www.TexasPolicy.com.
Kathleen Hartnett White is director of the Armstrong Center for Energy and Environment at the Texas Public Policy Foundation. She was commissioner and chairman of the Texas Commission on Environmental Quality from 2001 to 2007.