The Texas Public Policy Foundation has just released a comprehensive analysis of the “science” that EPA uses to assign potential health benefits to much of its “regulatory train-wreck” of new rules. EPA focuses on the benefits of reducing exposure to “fine particulate matter” (such as the smallest dust or ash particles).
Written by Kathleen Hartnett White, former chairman of the Texas Commission on Environmental Quality, the study is a devastating look at how EPA uses assumptions and statistical manipulation to invent health benefits out of thin air.
The EPA science is riddled with unwarranted assumptions. As Kathleen writes, no specific medical conditions or causes of death are attributed to its studies of the hazards of fine-particulate matter. For instance: “The EPA’s typical approach is to assume any non-accidental death from cardiopulmonary conditions is caused by air quality.” EPA applies an absolute form of the precautionary principle to its assumptions, treating small probabilities as virtual certainties. One scientist has described its approach this way: “Assuming I am right, it is extremely unlikely that any reasonable combination of alternative assumptions would show that I am wrong.”
EPA makes heavy use of first-order statistical correlations without any inquiry into causal links. As a result, it often reaches conclusions in the following form: because people swim more in the summer and have more heart attacks in the summer, swimming should be assumed to cause heart attacks.
Sounds crazy? Well, it gets worse: Assistant EPA administrator Gina McCarthy recently told Congress that “there is no threshold level of fine-particulate matter below which health-risk reductions are not achieved by reduced exposure.” In other words, the less exposure you have to fresh air, the better. Therefore, EPA can regulate you to reduce your exposure to fresh air. How’s that for science fiction?
Kathleen’s paper is a must-read.
— Mario Loyola is director of the Center for Tenth Amendment Studies at the Texas Public Policy Foundation.