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At a Capitol Hill news conference today, Citizens for a Sound Economy Foundation released a study by Kay Jones, a top environmental advisor to President Jimmy Carter, contradicting Environmental Protection Agency claims that 15,000 Americans die prematurely every year from exposure to fine particulate matter. Particulate matter is very fine material emitted into the atmosphere. The size of particulate matter discussed by the EPA -- 2.5 microns -- is roughly 28 times smaller than the width of a single human hair.
According to the CSE Foundation study, EPA vastly overstated the health risk from particulate matter (PM2.5). After making a 25 percent error in its estimate of mortality from fine particulate matter, the EPA said it is still "refining" its calculations. The most recent "refinement," due to the statistical error, led the agency to lower its estimate of PM 2.5 mortality from 20,000 to 15,000. EPA had claimed the figure to be as high as 40,000 as recently as November.
Jones, who discovered the original error, has looked into this problem and has found several mistakes in the agency's analysis of a key study by the American Cancer Society (ACS). His analysis shows that once the EPA's mistakes are corrected, the annual mortality from PM 2.5 falls to less than 1,000 deaths per year -- despite other numerous flaws in the EPA's methodology.
"The release of the CSE Foundation study -- coinciding with the start of National Clean Air Week -- comes at a significant time," said Matt Kibbe, CSE Foundation Vice President. The EPA will announce in July its decision on whether or not to implement new air quality standards. "If the new standards go into effect, the economic impact would be considerable, ranging from tighter vehicle emission standards, higher energy costs, sweeping agricultural restrictions and possibly even bans on outdoor barbecues," he said.
Jones found two substantial problems with the EPA's mortality estimates. First, EPA used mislabeled data points in the ACS study to set the level of the standard, which resulted in setting the PM 2.5 standard far too low. Second, Dr. Jones found that the agency was calculating benefits at levels below the PM 2.5 standard -- a level it had already proclaimed provided an adequate margin of safety.
The controversial methods used by the agency to calculate annual mortality, combined with the statistical error of the ACS study resulted in the exaggeration of the health risk from PM 2.5, according to Jones.
The two major errors found by Jones raise serious concerns about the proposed standards, but these problems only add to the existing data gaps and uncertainties surrounding the EPA's PM 2.5 rule, according to Kibbe. "Some of the more fundamental problems include: the EPA is relying on a statistical association between PM exposure and mortality that is so weak that many consider it insignificant; the EPA has not identified a biological mechanism to show why PM 2.5 is harmful; and the EPA has not yet collected sufficient data on PM 2.5," he said. "The errors identified by Dr. Jones simply show that even on the EPA's terms -- the PM standards have not been scientifically justified. More research is necessary to determine if there is any health risk from PM 2.5."
The EPA's rush to regulate has produced flawed scientific research, which, contrary to the EPA's claims, does not show a significant health risk from PM 2.5, according to Jones. "At this point, the agency must declare a five-year moratorium so scientists can go back and review the current data on PM 2.5 to find answers to all questions that remain. Only after this review may scientists have collected enough research to decide whether PM 2.5 is dangerous to public health. Only a careful and patient analysis of the science will allow the EPA, Congress, and most importantly, the public, to come to an informed and responsible decision on PM 2.5 regulation," concluded Jones.
Dr. Jones served as senior advisor on air quality at the President's Council on Environmental Quality (1975-79) and also as a senior technical advisor and research manager for the Environmental Protection Agency. He has written the air quality status and trend chapters for eight of the last fourteen Presidential CEQ Environmental Annual Reports to Congress. He is the head of a Seattle-based environmental consulting firm and is an adjunct scholar at Citizens for a Sound Economy Foundation.
CSE Foundation is a 250,000-member national research and education organization that searches for free market solutions to public policy problems.