NCPA - National Center for Policy Analysis

EPA's Pretense of Science: Regulating Phantom Risk

June 5, 2012

The U.S. Environmental Protection Agency (EPA) would have Americans believe that hundreds of thousands will die unless its new and unparalleled regulatory agenda is enacted.  Targeting emissions of fine particulate matter (PM), regulators argue that they seek to reduce premature deaths across the United States and improve health outcomes overall, says Kathleen Hartnett White, director of the Armstrong Center for Energy & the Environment at the Texas Public Policy Foundation.

However, as is so often the case with the EPA's regulatory agenda, the justifications for its policy recommendations are misleading and hyperbolic. The following represents the EPA's depiction of its PM-limiting regulations and subsequent projected benefits:

  • EPA studies estimate the Clean Air Act (which regulates fine PM along with several other emissions) will save 230,000 lives in 2020.
  • The EPA mon­etizes the value of those saved lives at nearly $2 trillion but estimates the direct compliance costs at a comparatively pal­try $65 billion.
  • Thus, the EPA implies that the public pays only $1 dollar for every $30 dollars in health benefits as a result of additional reduction of PM.
  • Over 90 percent of the $2 trillion derives from alleged prevention of "premature mortality."

However, the studies informing these conclusions and justifying the regulation are inconclusive, fail to consider scientific objections and overgeneralize.

  • PM causes premature deaths: No direct evidence of this causation has been found, as EPA studies merely assumed causation from a discovered correlation, and even these studies failed to control for crucial confounding variables.
  • There is no PM emissions threshold below which the air is healthy: Because PM also results from natural processes (i.e. volcanoes, erosion, brush fires), attempting to reduce emissions below natural levels will be ineffective and unlikely to save lives.
  • "Lives saved" have extraordinary value: EPA studies value a "saved life" at $8.9 million, yet because the regulations specifically extend the lives of the elderly, standard public health protocol suggests that the true valuation should be closer to one-sixth of this figure.

EPA cost-benefit analysis assigned a 100 percent probability to the truth of each of its assumptions.  Properly discounted for a generous 50 percent probability (and including the proper valuation of a "life saved"), regulatory health benefits fall to $19 billion, compared with $65 billion in regulatory costs.

Source: Kathleen Hartnett White, "EPA's Pretense of Science: Regulating Phantom Risk," Texas Public Policy Foundation, May 2012.


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