The EPAs Hot Air
By Michael Fumento
The Weekly Standard, July 7, 1997
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Copyright 1997 The Weekly Standard
Okay, lets be fair. Punctilious honesty has not been the Clinton
administrations strong suit. But every bell curve has its extremes — its
outliers, as it were. The word "outlier" brings to mind Environmental Protection
Agency administrator Carol Browner and her new air pollution standards.
These proposals, to be enforced under the Clean Air Act, would increase
burdens on automobiles, factories, and utilities that could range from
installing filters to using different fuels to ceasing operations altogether.
One type of pollution targeted by the new standards is particles in the air.
Particulate matter (PM) can be solid or liquid, emitted directly or formed in
the atmosphere when gaseous pollutants (called "precursors") interact. One
common way of categorizing particulate matter is by size. "PM10" includes
particles up to 10 microns wide — about a hundredth the width of a human hair.
Currently, EPA regulates only PM10, while the new standards would also
regulate "fine particles," 2.5 microns wide or less. Most PM2.5 comes from
sulfur dioxide (produced by power plants and manufacturing plants) and nitrogen
oxide (from power plants, manufacturing plants, and vehicles), combined with
The second type of pollution EPA seeks to further regulate is ground-level
ozone, or "photochemical smog." This is formed when two precursor gases,
volatile organic compounds (mostly from vehicles, but also from freshly applied
paints and solvents, backyard barbecues, and industrial processes such as baking
bread and dry cleaning) and nitrogen oxide, mix and are "cooked" by sunlight.
Those are the facts upon which all can agree. Then the truth gets wrapped up
in a demagogic fog. For every fib Browner tells, there is at least one fact that
FIB: Browner is not only on the side of the angels, she says; she is also on
the side of solid science. As she said at a November 27, 1996, press conference,
on air pollution, "the scientific findings are clear."
FACT: One scientist recently summed up the situation as to particulates this
way: "Current data do not support clear associations of [premature mortality]
effects with either fine particles (PM2.5), inhalable particles PM10 or PM15."
She is Rosina Bierbaum, assistant director for the environment at the White
House Office of Science and Technology Policy.
FIB: Browner has said over and over, including in testimony before Congress
in February, that the EPAs Clean Air Scientific Advisory Committee reviewed "
86 studies . . . indicating that our current air standards are not adequately
protecting the publics health."
FACT: Regarding ozone, the Clean Air Scientific Advisory Committee said there
was no scientific basis for choosing a new standard; they called it a "policy
judgment." As to particulates, only six of the 21 committee members agreed with
EPAs proposed 24-hour and annual standards for PM2.5. Only four members said
the allowable level of PM2.5 should be set as low as EPA wanted.
In a June 1996
letter to Browner, the committee said EPAs "deadlines did not allow adequate
time to analyze, integrate, interpret, and debate the available data." But,
added George Wolff, the chairman of the committee: " There does not appear to be
any compelling reason to set a restrictive PM2.5 [standard] at this time."
FIB: Browner speaks of the "consistency and coherence" of the studies on
FACT: Three men, who receive lots of EPA funding, do consistently find that
particulates are unhealthy. One formerly worked for the agency, and he and
another member of this "Particle-Hunter Triumvirate" were advisers to a 1996
report by the Natural Resources Defense Council (the folks who brought us the
Alar scare) claiming that an amazing 64,000 Americans are killed each year by
air pollution. Other researchers seem consistently unable to find these same
effects — notably in their research on Salt Lake County, Birmingham,
Philadelphia, Detroit, Minneapolis-St. Paul, and Steubenville.
For all of Browners talk of 86 studies, "The database for actual levels of
PM2.5 is also very poor, and only a handful of studies have actually studied
PM2.5 effects, per se," notes Bierbaum. Even with the help of one of the
Particle-Hunter Triumvirate members, Harvard researcher Douglas Dockery, I was
able to locate only 13 studies of PM2.5 specifically. Four looked for
associations with premature deaths. Of these, two found statistically
significant associations with particle increases and two did not.
This isnt the only kind of lawn mower the EPA wants to regulate.
Nine studies looked for associations between fine particles and non-fatal
illness. Of these, four showed no association with any of the symptoms. Five
showed a statistically significant association with some of the symptoms
measured, but these symptoms showed up in some studies and not others.
FIB: In her February 12 testimony before the Senate Environment and Public
Works Committee, Browner presented a poster entitled "Soot/Particulate Matter:
The Science Calls for Action." It summarized five of the 13 PM2.5 studies.
FACT: Even of these five, only one clearly supports the "adverse health
effect" Browners poster claimed. Another comprised results from six cities,
only three of which had statistically significant associations between PM2.5 and
harm. The three with harmful associations were on the chart, while the three
that showed no injury from fine particles were left off.
FIB: Far from costing us money, the particulate-matter regulations will
generate health-cost savings that amount to a tremendous windfall.
FACT: To achieve the alleged savings, the EPA refrains from performing a full
cost-benefit analysis. But the act of removing pollution from the air increases
in cost as the air gets cleaner: Each ton of pollutant is more expensive to
remove or prevent than the previous ton, and each ton removed or prevented has
less effect on health. It might cost $10 million to save the first ten lives
from some danger — and $100 million to save ten more lives. Thus, by using
only a partial analysis, the EPA disguises the real costs.
It also assigns a value of $4.8 million to each premature death prevented,
even though the potential victims are people in poor health with a life
expectancy of one to two years. By contrast, the Department of Transportation
assigns a value of $2.7 million to deaths, although these are accidental deaths
of healthy people with a life expectancy of 38 more years.
FIB: When it comes to ozone, the benefits from tighter standards wont save
us much in health costs, but they wont cost much either.
Accessory to murder?
FACT: To reach its estimate that the cost of implementing the new regulations
will be between $600 million and $2.5 billion, EPA assumes that compliance
will not be complete. The presidents Council of Economic Advisers, however, did
a "full attainment" estimate and placed the costs as high as $60 billion. The
Reason Public Policy Institute reached a similar figure, while George Masons
Center for the Study of Public Choice put it somewhere between $54 billion and
On the benefit side, EPA makes assumptions that defy credulity.
While the Council of Economic Advisers values the benefits at practically
nothing, the EPA values the prevention of a single case of non-fatal bronchitis
at a stunning $587,500.
FIB: Browner claims the new standards will save 15,000 lives and prevent
500,000 respiratory problems annually.
FACT: Economists have long accepted that "wealth equals health." Wealthier
people can afford better health care, better hygiene, and safer occupations. By
diverting wealth, regulation suppresses health. W. Kip Viscusi of Harvard
calculates that "every $ 50 million spent on regulation induces one statistical
death." Depending on whose estimate of the cost of EPAs new regulations is
used, they could actually cause tens of thousands of such deaths every year.
FIB: The clean-air standards are "not about outdoor barbecues and lawn mowers," says Browner, dodging charges that Americans could be forced to change their lifestyles. When industry spokesmen bring up these issues, Browner smears
their claims as "junk science" and "scare tactics" that are " fake," "wrong,"
and "manipulative." The environmentalists back her up. Talk about barbecues and
lawn mowers is "crazed propaganda," says Frank ODonnell, executive director of
the Clean Air Trust.
FACT: In 1994, EPA already had plans to regulate lawn mowers. "The small
gasoline engines that Americans use in yard and garden work are a significant
source of air pollution," Browner said that year. In 1996, EPA promulgated
emissions standards for lawn mowers. A Pentagon document noted that to comply
with "the current ozone standards, EPA proposed [restricting the use of] even
lawn mowers and other small engines."
One state, California, already regulates barbecue grills, leaf blowers, and
paint. Denver severely restricts the use of wood-burning fireplaces and has
outlawed them in new homes. Regulators in San Francisco have urged residents to
refrain from using aerosol deodorants and alcohol-based perfumes to reduce
FIB: Asked at the June 26 press conference, "Do you have estimates for how
many counties will fall out of compliance?" Browner pleaded ignorance on this
sensitive issue. "We dont at this time. We are still looking at that," she
FACT: The EPA staff paper on particulates states that counties not complying
with the fine-particle regulation will quadruple from 41 to 167. The staff paper
on ozone says that the non-complying counties will more than triple in number.
(Outside evaluators say the EPA numbers are too low.) You can even go to EPAs
web site and see whether your county is a potential offender.
FIB: Taking her cue from her boss, who plays the "child card" at every
opportunity, Browner invokes children as major beneficiaries of the new
proposals. "When it comes to protecting our kids," she intoned at a recent press
conference, "I will not be swayed."
FACT: According to EPAs own staff papers, to the extent there are premature
deaths from air pollution they will be among "vulnerable individuals, primarily
the elderly and individuals with preexisting respiratory disease." Even the
National Resources Defense Council admitted in its 1996 report, "The elderly and
those with heart and lung disease are at greatest risk of premature mortality
due to particulate air pollution."
FIB: Rising rates of asthma are caused by air pollution. Top White House
environmental official Kathleen McGinty told reporters at the June 26 press
conference that smog "seriously [exacerbates] asthma conditions and other lung
ailments, and that particularly [affects] children. Asthma is on the rise
throughout the United States."
FACT: Asthma is indeed rising sharply among children — even as pollution is
dropping. All six of the major air pollutants EPA monitors have declined over
the last decade, including ozone and PM10. Two researchers recently wrote in
Science magazine that these "suggest that asthma prevalence has increased
because of something lacking in the urban environment, rather than through the
positive actions of some toxic factor." Then in May, researchers reported that
the major cause of asthma in inner cities (where rates are by far the highest)
is neither cars nor corporations but cockroaches.
"Its a cruel hoax to lead parents to believe their children will be
protected from having asthma if only the EPA clamps down on outdoor air
pollution," says Robert Phalen, a biomedical scientist who for 22 years has
directed the Air Pollution Health Effects Laboratory at the University of
California in Irvine.
Indeed, Phalen believes EPAs whole new regulatory scheme is a cruel hoax.
And if its the child card you want to play, consider: The new regulations wont
kick in until the next century, with costs then steadily rising. Long after
Carol Browner and Bill Clinton have settled into retirement, who do you think is
going to pay the price for their prevarications?
Read Michael Fumentos additional work on pollution and on the EPA.