EPA’s flawed zero tolerance policy?
For the last three years, the Environmental Protection Agency has justified new air quality regulations — unprecedented in stringency and cost — on the assumption that even trace levels of particulate matter can cause early death.
A recent EPA report states that by 2020, the EPA’s rules “will prevent 230,000 early deaths.” EPA Administrator Lisa Jackson has gone so far as to testify before Congress that the new regulations would provide health benefits as valuable as a cure for cancer. If true, this is compelling. Unfortunately, such rhetoric is built on implausible assumptions, biased models, statistical manipulations and two cherry-picked studies.
Unwinding this tangled web is tedious but necessary to prevent the EPA from becoming a national economic planning agency that transforms our economy and undermines our form of democratic government, in which elected representatives — not federal technocrats — have the authority to make the country’s major policy decisions.Extrapolating from assumptions, the EPA in 2009 decided that no risk is too low, improbable or uncertain that it is not worth responding to with regulation. With a straight face, the EPA’s leadership now maintains that there is no safe level of ambient fine particulate matter — however near to zero — at which risk of “early” death ceases. Statisticians call this analytic approach a “no threshold linear regression to zero.”
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