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 report recommends amendment of the Clean Air Act to establish minimal criteria for rigorous scientific risk assessment of health effects.