EPA’s Questionable Behavior

In two Policy Briefs earlier this year and in several Briefs in the past few years, we have questioned the EPA and the American Lung Association for their methodology in claiming that the Pittsburgh region has some of the worst air quality in the country. But beyond their silly argument that above EPA guideline readings at one pollution monitor in the area is sufficient to label the entire region as out of compliance, there are concerns about the claims over the relationship of air quality to health and mortality rates.

As we noted in May, the air quality in Los Angeles has for many years been ranked as among the worst if not the worst in the country while the air quality in Laramie, Wyoming is ranked as being some of the least polluted in the nation. If air quality is the exceptionally important determinant of health and mortality the Lung Association and the EPA constantly insist it is, then age specific death rates in Los Angeles ought to be worse than the national rates and much higher than the Laramie rates. But for virtually every age group, especially the older ages which should be showing the effects of years of prolonged exposure to high pollution, Los Angeles mortality rates are much lower than the national rates and measurably lower than Laramie rates.

The Lung Association has proffered no answer to this obvious challenge to their claims but does not even indicate it is interested in producing an explanation. Ditto the EPA.

And it gets worse. The EPA has a guideline for mortality from pollution known as the Maximum Individual Carcinogenic Risk, defined as the estimated risk of contracting cancer for person exposed to a pollutant 24 hours per day, 7 days a week, and 52 weeks a year for 70 years. Clearly, as we noted in August Brief, there hasn’t been and never will be a study to evaluate such conditions. It is simply not feasible. So, the estimate has to be produced by epidemiological statistical studies that inevitably require a lot of assumptions and interpolations that cannot get at possible causalities and mechanisms of the harmful effects of pollutants.

Obviously, it would be a violation of all known protocol prohibitions to subject human beings to high level of air pollutants in a controlled environment where they might suffer harm-especially in light of the EPA claims that the pollutants are known to cause harm and death.

But that has not prevented the EPA from doing just that. Tests have been happening since 2004. These experiments are now the subject of a lawsuit by an asthmatic individual who was negatively affected by the experiment. A study documenting the violations of human experimentation prohibitions and the less than straightforward recruitment of volunteers is available on the web. http://epahumantesting.com/summary.

The logical inconsistency of the EPA’s testing is stunning. They claim the tested pollutants are extremely hazardous and yet they are in need of proof so badly they are willing to subject elderly and unhealthy subjects to tests involving as much as twenty times normal concentrations of pollutants. Their argument is that it is for the greater good to learn the mechanisms of possible deleterious health effects. But what is more stunning is that testing in 2010 and 2011 involving 41 subjects only two showed negative effects, one serious. A person with known pre-existing heart problems had to be hospitalized. No mention in the report that the bulk of the test subjects showed no clinical effects. What hypocrisy.

What Will Air Quality Zealots Complain About Now?

Headline: The air quality monitor in Liberty Boro is now in compliance with EPA guidelines based on the three year average reading from 2009-2011. Particulate matter of 2.5 microns or less is measured at 15 micrograms per liter, the current standard. Thus, the Liberty monitors, which have been the only ones in Allegheny County registering levels above the three year standard and have brought down the wrath of the American Lung Association and the Heinz Endowments on the County and region as not being in compliance with EPA guidelines will have to be replaced by some other air quality villain.

The County and the Southwest Pennsylvania region have been wrongfully and scurrilously labeled as a poor air quality region because of a couple of monitors that detected particulate matter concentrations above the EPA standard. No matter that the rest of the region was in compliance and that several counties with no monitors were caught in that smear despite the absence of any evidence of their air quality being out of compliance.

One call which will certainly arise is that the guidelines need to be lowered. The current 15 microgram per liter standard will not be low enough to ensure respiratory health. Ironically, even if the guideline were cut to 12 micrograms, only Liberty would be out of compliance. And, as a result, the region would once again be labeled as having poor air quality despite the obvious massive improvements in air cleanliness. Some will not be happy until we have pre-colonial levels of particulates in the air even though we cannot be sure what they might have been. One can liken this to the cries for more forest land although forested acreage has been stable over a century.

Editorial Writers Schizophrenic about Jobs

On Tuesday the PG’s editorial page writers were adamant in arguing that Congress and the President take dramatic actions to accelerate growth job. Decrying the awful state of the job market and lack of employment gains, the editorial said the time for political bickering must be set aside. Unfortunately, the calls for action do not ask Obama to offer up any rollbacks of the regulatory nightmare that has been created since he became President. How the writer expects the business world to shake off the impacts of the reduced return on investment and the higher levels of risk produced by the piling on of new regulations is not made clear.

Amazingly, one day later, the same editorial page offers up a sharp criticism of Obama’s decision to delay for a couple of year a job destroying EPA plan to lower the ozone level standard for a couple of years. The editorial argued that opponents’ claims the tighter ozone standard would create billions in additional business costs was an old rerun of the argument that a cleaner environment is the enemy of economic prosperity.

The problem with the editorial position is that ozone levels have fallen significantly over the last two decades, locally and across the country (California remains the poster child for serious ozone problems). Moreover, if the EPA’s desired reduction in the standard of 75 parts per billion to a range of 60 to 70 parts per billion were imposed at say 65 parts per billion, virtually every county in the country with suburban levels of population density would fail to meet the new standard-based on the latest EPA data. Locations in the northern tier of Western and Midwestern states will not be slapped with a non-attainment ruling. Hawaii will also escape the impact.

In short, with the new lower level standard in hand, the EPA would be in a position to go after any company contributing to ozone levels. The negative impact on new investment as well as current and future jobs would be substantial at a time when job creation is at a standstill.

The irony is that the cleanest air in any of the lower 48 states in terms of ozone concentration is in the 50 parts per billion range. So the EPA and the editorial writer are willing to do untold damage to the economy in an effort to get every monitoring station to within 15 to 20 parts per billion of the lowest readings currently being taken. The efforts to get everyone under the current ozone cap are costing enough already. Check with California where environmentalism reigns supreme and many ozone monitor readings are routinely100 per parts billion or higher. The EPA’s effort is designed simply to continue expanding its power.

For the people supporting the EPA, the costs imposed by what they do are irrelevant. Their objective is zero pollution beyond what nature itself creates. Although, if they could sue Mother Nature they would take a serious look at doing so after a volcano or earthquake throws out pollutants.

More Silly Economic Thinking in the ‘Burgh

According to the Post- Gazette followers of Paul Krugman’s school of incoherent economics, the cause of our country’s slow economic growth is inadequate government spending and the unwillingness to levy higher taxes. Their silliness is encapsulated in the assertion that cutting spending will cost some Federal government workers their jobs, thereby worsening the nation’s jobs picture. Apparently, the geniuses who came up with that gem have never noticed that the bigger the Federal civilian payroll the weaker the nation’s private sector ability to create activity and new jobs.

Here is the sad truth. The U.S. has been under the whip hand of massive deficit spending for three years as well as the most "stimulative" monetary policy imaginable. And still the economy languishes with subpar growth and ongoing large layoff announcements. Granted, the housing collapse and the attendant financial crisis of 2008 meant recovery would take longer and be more difficult than a typical recession.

However, the President and the Democrat controlled House and Senate opted to begin piling huge new regulations on the economy through constitutionally questionable Obamacare, the EPA and the NLRB that, taken together, have acted as a massive anchor on the economy. The administration’s fealty to organized labor was demonstrated through the terms of the auto company bailouts, support for Card Check, refusal to denounce the goonish tactics of labor unions in Madison Wisconsin, and more recently the insanely destructive NLRB ruling on the Boeing Company’s plans to open a manufacturing facility in South Carolina. Regardless of how the courts eventually rule, this NLRB-and by definition Obama supported-action has cast a pall over the nation’s free enterprise system. Nothing can be more chilling to business investment than the prospect of government agencies telling companies they cannot locate legally in a state of their choosing.

The unwillingness of proponents of ever more spending and taxes to realize the damage already being done by that approach and their inability to link the heavy handedness of government regulators and burdensome regulations to the increasing caution of business people to invest or hire new workers or retain existing workers speaks to an ideological blindness of monumental proportions. Sadly, decades of programs that have made a large fraction of Americans dependent on government or the beneficiaries of government regulations, along with the fact that 50 percent of citizens pay no income tax, have created a huge voting bloc who are completely vested in keeping government growing in size and scope.

As noted in a blog last week, handout and entitlement programs can be sustained only by having a growing private sector economy capable of producing adequate tax revenues at low tax rates that do not threaten after tax rates of return on investment. Failure to recognize the need to strengthen and encourage the free enterprise system through a better set of tax and regulatory policies will inevitably be the nation’s undoing as a republic of free people.