"EPA's regulatory agenda is a perilous pipe-dream precluded by the laws of math and physics."
This conclusion by the former Chairman and Commissioner of the Texas Commission on Environmental Quality Kathleen White is a must read for any person interested in the environment and truthfulness from EPA. She had a staff of 3,000 and was in charge of the second largest environmental regulatory agency in the world after the U.S. Environmental Protection Agency.
Equally important is the fact that White is a co-owner of a ranching operation in two counties in Texas.
In May, 2012, the Texas Public Policy Foundation published a report by White entitled "EPA's Pretense of Science: Regulating Phantom Risks". The paper written by White is a devastating critique of EPA's misuse of data and science to reach a preconceived policy goal.
The paper demonstrates that science in the hands of political operatives is easily compromised in determining a policy outcome. And, the objective is clear: That EPA policy is to supplant fossil fuels.
EPA regulates Particulate Matter (PM). PM 2.5 is microscopic particles released from combustion. EPA believes that urban PM is enriched with pollutants with a chemical content which is more hazardous than natural dust. EPA has concluded PM 2.5 particles pose a serious health risk by irritating and damaging little air sacs in a person's lungs. The present 24-hour PM 2.5 standard is 35 ug/m3 and the annual standard is 15 ug/m3.
In layperson's terms, this is 35 micrograms in a cubic meter.
Lisa Jackson, the incumbent EPA Administrator, has made juvenile assertions to Congress regarding PM 2.5. White quotes Jackson as saying "We are actually at the point in many areas of the country…the best advice is, don't go outside. Don't breathe the air. It might kill you."
Jackson further claims, "If we could reduce particulate matter to levels that are healthy, it would have identical impacts to finding a cure for cancer." To put this into perspective, cancer causes approximately 600,000 deaths per year.
There is absolutely no evidence the Jackson statement contains a grain of truth that would be accepted in a court of law. (In fact, as a trial lawyer, I suggest that such a claim in a complaint might be considered fraud and misrepresentation.)
EPA appears to be obsessed with reducing the PM 2.5 standard to rid the nation of fossil fuels. In fact, EPA disregards studies, according to White, which show in 27 U.S. communities, a decrease in mortality rates when there are increased levels of PM 2.5.
EPA claims "The best scientific evidence…is that there is no threshold level of fine particle pollution below which health risks reductions are not achieved by reduced exposure." How EPA reaches this conclusion will probably surprise you.
EPA relies on epidemiological studies which even EPA says are incapable of establishing a "causal" link between death and ambient concentrations of PM 2.5. EPA relies on two studies. "These chronic exposure studies exclude accidental death and somewhat adjust for other factors such as smoking or obesity but otherwise attribute all nonaccidental deaths to PM 2.5!
EPA claims these two studies show that there is no evidence of a safe threshold to exposure of PM 2.5; however, there are many studies which are ignored by EPA which do show a threshold. So EPA is telling the American public that there is no risk which is too low and therefore EPA must further regulate sources of PM 2.5 such as coal fired facilities and diesel engines.
Conflicts of interest
EPA seldom points out, according to White, the substantial evidence of financial conflicts of interest that members of EPA's technical review panels have in recommending more stringent PM 2.5 regulations. For example, she points out, "Six of the seven members of EPA's Clean Air Science Advisory Committee ("CASAC") have received EPA grants to conduct research for the agency." One of the principal advocates for more stringent PM standards is CASAC chairman, Jonathan Samet, who has received over $9.5 million in grants from EPA.
Administrator Jackson is frequently quoted as saying "…the Clean Air Act has saved literally hundreds of thousands of lives…" The problem is, as White declares, "these saved lives are nothing more than statistical constructs; they do not refer to real people." EPA is basing its saved life on a person who may gain additional life expectancy at 80 years of age!!!
At that age, life expectancy is estimated in terms of months, not years, but EPA is assigning the value of $8.9 million per statistical life gained.
White's paper demonstrates why many reputable scientific bodies such as the National Academy of Science and the National Research Council have said "EPA science is on the rocks…"
I would say this paper sinks EPA's scientific credibility like a rock!