EPA's Pretense of Science: Regulating Phantom Risks -- Texas Public Policy Foundation

EPA's Pretense of Science: Regulating Phantom Risks -- In this report (May 2012) theTexas Public Policy Foundation found that [from the press release] "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...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.