The current leadership of the Environmental Protection Agency repeatedly trumpets the dire need for new air quality regulations in order to save hundreds of thousands of lives. A headline on the summary for a 2011 EPA report on the benefits of the Clean Air Act is typical: “In 2020, the CAA Amendments will prevent over 230,000 early deaths.”

Such declarations scare the public and intimidate the skeptic. In a congressional hearing, EPA Administrator Lisa Jackson even claimed that reducing fine particle pollution would be as valuable as finding a cure for cancer.

If the EPA’s claims about saving lives were true, the case for its aggressive regulatory agenda would be compelling. But after peeling back the layers of assumptions on which the EPA’s claims of preventing deaths depend, EPA’s grim avowals are grossly misleading at best and deceptive at worst.

For starters, the saved lives and early deaths are not actual people but mathematical constructs. When not speaking for public consumption, the EPA refers to these logical abstractions as “statistical lives.”

For the thousands of lives that the EPA claims air pollution has ended or that CAA regulation will save, there is not one identified individual. Nor are specific medical conditions or causes of death attributed to fine particulate matter exposures.

The EPA’s default assumption is that air quality causes any non-accidental death from cardiopulmonary conditions. Lives saved, deaths prevented or avoided, and premature mortality: the EPA’s terms are misleadingly imprecise.

Since clean air does not confer immortality, “avoided deaths” do not occur.

Extended life-expectancy or life-years gained more accurately describe the health benefit at issue. Living longer to most non-statistical persons is a benefit, but what EPA means as a life-year gained is also a statistical construct. A “statistical life” has traditionally referred to the aggregation of small risk reductions to many individuals until that aggregate reflects a total of one statistical life. Quite obviously, “statistical lives saved” bear no relationship to actual individual human lives.

The EPA study mentioned above finds that the monetized value of “preventing 230,000 deaths” amounts to $1.8 trillion. EPA arrives at this whopping figure by assigning a dubious monetary value of $8.9 million to each statistical life.

The EPA’s favored studies find that the median age of people to whom additional life expectancy accrues is 80 years. And the increased life expectancy is estimated in several months, not years.

But when aggregated into one statistical life, the EPA sets a value of $8.9 million per statistical life-year gained. That figure is more commonly used as a monetized value for a healthy 25-year old adult.

The monetized value of additional life expectancy for an 80-year old is more typically estimated at about one-sixth the value of an individual 25 years old.

If the more commonly used value for the octogenarian is used, the benefits from the 230,000 “prevented deaths” are slashed by $1.5 trillion.

The ambient levels of the pollutant to which EPA now ties its claims of “preventing deaths” – fine particulate matter – has fallen by more than 55 percent. Most of the country now achieves the national air quality ambient standard for particulate matter, set by law at a concentration adequate to protect human health with a margin of safety and regardless of cost.

Also consider that the concentrations of fine particles indoors are far higher than outdoors. Cooking, cleaning a closet, roaming through a mall – any takers that these activities present risks of early death?

Most toxicological data shows that current ambient levels of particulate matter are too low to cause serious disease or death.

The EPA Administrator, however, said when she last year appeared on Real Time with Bill Maher, “Don’t breathe the air. It might kill you.”

In the last century, our life spans have increased by 70 percent. Reifying statistical constructs into a warm-blooded risk of imminent death is pathetic propaganda for the EPA’s overreaching agenda.

Kathleen Hartnett White is director of the Armstrong Center for Energy and Environment at the Texas Public Policy Foundation. She was commissioner and chairman of the Texas Commission on Environmental Quality from 2001 to 2007.

 

 

“