Contributors to this article include : Amir Mehrban (a) Jane Orient (b), Warren Kindzierski (c), Daren Bakst (d), Robert Obenchain (e), Barbara Nowell (f) Ronald Stein (g) Tom Golab (h)
Let’s first explain for our readers that PM2.5 stands for Particulate Matter of 2 and a half microns. A micron is a millionth of a meter in size. EPA currently restricts emissions of such size particles to 12 micrograms per cubic meter.
Tightening the PM2.5 standard in the National Ambient Air Quality Standards will raise energy prices significantly without offering any benefit whatever to the health of the nation. Multiple studies prove this emphatically.
Less than a year ago, EPA Administrator Michael Regan dismissed all the advisors from two legally required panels, the Science Advisory Board and the Clean Air Scientific Advisory Committee (CASAC). This move made before EPA’s decision to review the current PM2.5 standard gives the impression that the administrator wants to hear only from those who will support President Biden’s agenda which is clearly anti-industry and surely anti-capitalism.
John Graham who had led the EPA’s disbanded Science Advisory Board stated after the aforementioned purge said “Now, for the first time, in the agency’s 50 year history, we have an administrator interested in scientific advice only from those scientists he has personally appointed.” Researchers funded with EPA grants. This action alone undermines anything coming from the newly formed Clean Air Scientific Advisory Board (CASAC). This is the reality of why such a purge should never have taken place.
The crux of the Office of Science and Technology Policy (OSTP) purpose is stated precisely as follows:
“The scientific process benefits from a culture of rigorous scientific debate that guards against inadequate methods and analysis, that welcomes open discussion across potentially disparate perspectives. However, clear and transparent processes are required for addressing scientific disagreements and for ensuring that debates are based on differences of scientific opinion and not a desire to achieve predetermined outcomes. Agencies need to provide clear and transparent processes for addressing disagreements and seeking paths toward resolution.”
The new Clean Air Advisory Board (CASAC) is composed almost completely of academics and likeminded individuals most of whose institutions are recipients of EPA research grants. In other words, those who will not dissent from current political policy. This appears contradictory to the objectives described above from the OSTP guidance.
The current effort of the Biden Administration to tighten the PM2.5 NAAQS actually violates the Federal Advisory Committee Act, which requires that the advisors be “fairly balanced in terms of the points of view represented”. Additionally, the activist PM2.5 panel is failing to advise the EPA Administrator of any adverse public health, welfare, social, economic or energy effects which may result from various strategies for attainment and maintenance of such NAAQS. These serious adverse impacts will disproportionately affect disadvantaged groups.
PROOF of EPA’s disinterest in dissenting opinions is that on February 25 EPA held a zoom meeting for the members of the Clean Air Advisory Council (CASAC) to hear testimony from the public on proposed changes to the PM2.5 regulation. Approximately 20 individuals gave 3 minute oral testimony after which members of CASAC were allowed to ask questions following each 3 minute oral presentation. Not a single question was asked by members of CASAC of anyone giving testimony. This is true though only two giving testimony agreed that the regulation should be strengthened while all others objected very strongly.
The standard method for showing cause and effect is through an experiment. One factor is changed and the result is examined. If another variable changes with the factor under study, after any confounding factors are eliminated, there is evidence of causality. Fairly recently an increase in PM2.5 was observed due to major forest fires. This natural unintended experiment did not lead to an increase in mortality.
Cox, Popkin and Ricci studied 100 U.S. cities where fine particulate matter varied significantly. They found no concurrent effects on mortality. This study was published in 2013 in the journal Regulatory Toxicology and Pharmacology. This was also the focus of a highly regarded paper by Dr. James Enstrom published in the Journal of American Physicians and Surgeons, Spring 2018 titled “Scientific Distortions in Fine Particulate Matter Epidemiology.”
Correlation (association) is not causation. Logically, it only takes one valid negative association study to negate any number of positive association studies. The EPA refuses to discuss seemingly valid negative association studies.
Conversely the most recent of EPAs supposed evidence for changing the PM2.5 regulation stems from Medicare records of 69 million recipients who tend to be older with co-morbidities. Using such records for science violates basic ethical and epidemiological principles. The individuals never gave consent. The data is not public so it really is not science as it cannot be verified.
Where, in the process, are the unintended consequences of more stringent restrictions considered. When is the cost/benefit analysis performed for the cost/impact to communities and industries of tighter constraints versus the possible human health benefit? This is particularly concerning when the science behind a revised regulation is questionable, and all data is not available to the public. Is secret science even science?
Industry has spent billions of dollars to comply with a current regulation for which there has not been any causal relationship proven. Fine particulate matter does not affect human health and mortality from the small quantities in the air from emissions of activities throughout our nation. But regardless the nation has complied with the current standard. Now EPA desires to move the goal posts at great expense despite no evidence to support such a move.
Many taxpayer-funded researchers claim, diseases caused by PM2.5 are on the rise, yet the EPA’s measurements show there to be a drop in ozone and PM2.5. Clearly, these diseases can’t be caused by ozone and PM2.5. The data show there to be an inverse relationship, exposure is going down, yet the claimed effects are going up, which is a contradiction. We should let the existing regulations continue in place as it makes no sense to waste taxpayer funds on studies attempting to link certain diseases to ozone and PM2.5 until these noted problems are resolved.
NOTE: a-College student in Psychology, b-President of Doctors for Disaster Preparedness, c- Retired college professor, d- Heritage Foundation,e- Consultant, f- Concerned citizen, g-Pulitzer Prize Nominee in Contamination from Renewable Energy, (h) President American Council on Science and Health
More: (https://www.youtube.com/watch?v=ZkMsBXwyenw) and (https://casac.epa.gov/ords/sab/f?p=113:19:22380851460992:::RP,19:P19_ID:966). These links will allow the devoted reader to watch all 20 public commenters (including you and me) and to read all the related EPA documents. Also, you should submit Part 1 and Part 2, including their CFACT links, to [email protected] as your written comments on the PM2.5 NAAQS. Several public commenters, including me, have already posted their comments. My comment can also be found here: http://www.scientificintegrityinstitute.org/pmpanel022522.pdf .