Statistical Constructs and Scare Tactics: The EPA’s Scientific Sleight of Hand

We all care about the quality of the air we breathe, but can we trust the government to correctly assess the science our health depends upon? At the moment, the answer is no, but reform is underway.

Last week, in a rare occurrence, the EPA’s Clean Air Advisory Committee (CASAC) voted 4 to 2 against tightening the standards for fine particulate matter, known as PM2.5. EPA almost always tightens the federal standards during its regular reviews, rather than leave them unchanged.

Particulate matter is ubiquitous on this planet, whether it occurs as natural dust or the product of industrial combustion (commonly called soot). It is listed as one of the six criteria pollutants in the Clean Air Act under the premise that it aggravates certain heart and lung conditions, thereby leading to premature death. The nature and extent of these adverse health effects and their bearing on the current air quality standard for PM2.5 is what was being debated at the CASAC meeting.

Only 18 out of 3,007 counties in the U.S. fail to attain the already-strict standard for PM2.5. Nevertheless, the EPA under the Obama administration shamelessly and literally used a variety of terms—premature deaths, lives saved, premature mortality—to scare the American public into thinking PM2.5 is directly killing thousands of Americans every year. As former Administrator Lisa Jackson put it: “We are actually at that point in many parts of this country … the best advice is don’t go outside. Don’t breathe the air. It might kill you.”

More stringent, exorbitant regulation of industry was pitched as necessary to save lives. Ironically, air quality in the U.S. was dramatically improving at the same time EPA leadership was declaring our air unfit to breathe.

However, the “premature deaths” that the EPA has proffered are nothing more than statistical constructs; they do not refer to real people. When not speaking for public consumption, the EPA calls them “statistical lives.”

The EPA constructs a statistical life by estimating the increase in life expectancy or life-years gained assumed to result from reduction in ambient PM2.5. The small risk reductions from individuals are aggregated until they reach a total of one statistical life. Quite obviously, “statistical lives saved” bear no direct relationship to actual, individual human lives.

For the thousands of lives that the EPA claims PM2.5 will end, not a single individual death from direct exposure to PM2.5 has been identified. As Dr. Jim Engstrom noted in his CASAC testimony, “Despite over 25 years of claims about the adverse health effects of PM2.5, there is still NO established etiologic/biologic mechanism for PM2.5 to cause premature death.” With the exception of smoking and obesity, the EPA’s typical approach is to assume that any non-accidental death from cardiopulmonary conditions is caused by air quality.

Many EPA staff may still insist that outdoor particulate matter can kill people, but the real-world evidence supporting that conclusion is lacking. As Steve Milloy testified at the CASAC meeting, “The epidemiology relied on by EPA staff, even gullibly accepted at face value, is insufficient on its own to draw any conclusions about PM.”

Due to the consistent confusion created by the previous EPA and many environmental groups, these false claims about increases in premature deaths due to insignificant increases in PM2.5 also riddle the media reporting on this issue. Similar mistakes blot a recently released study by researchers at Carnegie Mellon University, which was widely cited in mainstream news articles reporting on the CASAC meeting.

It’s shameful for the federal government to mislead the public about something which is so important to their well-being, and the American public and their elected officials should not be expected to take a class on statistics in order to understand these claims of grave health risks.

Fortunately, current EPA Administrator Andrew Wheeler recently issued a memo citing a need to make transparency and consistency in cost-benefit analyses a first priority. Administrator Wheeler and the current EPA Office of Air and Radiation should be commended for their efforts to heighten public understanding of air quality such that our elected officials are not duped by scientific slights of hand.

Thanks to our prosperity in the U.S., a sophisticated and complex body of science supports an effective system of public health. But this scientific enterprise has been co-opted by a political movement that seeks to drive pollution levels to zero and eliminate entire industries—regardless of the lack of scientific evidence supporting their claims.

The current EPA should be applauded for fighting back against the effort to silence the necessary scientific debate on these important issues and reestablish the proper role of science in the environmental policy arena.