By John Walke, Natural Resources Defense Council
The Trump Environmental Protection Agency has announced plans to try to repeal the Clean Power Plan, and deny Americans annual health benefits that include avoiding 3,600 premature deaths; 90,000 asthma attacks in children; 1,700 hospital admissions; and 300,000 missed days of school and work.
The EPA’s Clean Power Plan set the nation’s first-ever limits on carbon pollution from power plants, which would also drive reductions in fine particle pollution (PM2.5), smog (ground-level ozone), sulfur dioxide, nitrogen oxides and hazardous air pollutants that together cause asthma attacks, heart attacks and strokes, cardiovascular and respiratory diseases and even early death.
In 2015, EPA valued the Clean Power Plan’s climate benefits at $20 billion and its health benefits at $14 to $34 billion, once fully implemented in 2030. Most these health benefits come from reducing deadly fine particle pollution. After subtracting out compliance costs, the rule’s annual net benefits to Americans are an astonishing $26-45 billion in 2030.
Now, the Trump EPA says matter-of-factly, unapologetically, that by proposing to repeal the Clean Power Plan, EPA knows it “would no longer reduce emissions of certain precursor pollutants (e.g., SO2, NOx, and directly emitted particles), which in turn would no longer lower ambient concentrations of PM2.5 and ozone.” (EPA also says wanly that it didn’t even bother analyzing the forgone “health effects from reductions in directly emitted PM2.5, direct exposure to NOx, SO2, and hazardous air pollutants; ecosystem effects; or visibility impairment.”)
So there, America.
In seeking to repeal the Clean Power Plan, the Trump EPA feels the political need to downplay and deny the tremendous health benefits from reducing all of these harmful air pollutants. EPA feels equally compelled to manipulate and exaggerate industry’s compliance costs. My colleagues, Kevin Steinberger and Starla Yeh, examine EPA Administrator Scott Pruitt’s cost abuses here, and the benefit abuses here. My post will focus on one central abuse underlying EPA’s indefensible denial of health benefits from cutting deadly fine particle pollution.
So how does the Trump EPA deny the hazards it would allow by repealing a rule projected to deliver so many health and economic benefits to Americans?
Through scientific fraud.
As detailed below, fine particle pollution, PM2.5, is harmful to human health, even deadly, at very low concentrations. The scientific consensus, long held by EPA during Republican and Democratic administrations, is there is “no threshold” level of fine particle pollution below which health risk reductions are not achieved by reducing exposure.
Contrary to this well-established scientific reality and agreement, the Trump EPA simply assumes for the first time that deadly fine particle pollution is safe at levels that the scientific consensus recognizes to be harmful.
By shifting abruptly to a scientifically indefensible assumption, the Trump EPA just denies that Americans are suffering asthma attacks, strokes and heart attacks, and premature deaths due to air pollution that causes these results in the real word.
The Trump EPA’s retreat is so extreme it contradicts scientific and economic practices endorsed during the Bush administration by the president’s current nominee to head EPA’s air office, William Wehrum, and his nominee for EPA deputy administrator, Andrew Wheeler.
EPA’s long-standing position on the harmfulness of fine particle is captured well here, in this 2012 letter to Congress:
Studies demonstrate an association between premature mortality and fine particle pollution at the lowest levels measured in the relevant studies, levels that are significantly below the [National Ambient Air Quality Standards, or NAAQS] for fine particles. These studies have not observed a level at which premature mortality effects do not occur. The best scientific evidence, confirmed by independent, Congressionally-mandated expert panels, is that there is no threshold level of fine particle pollution below which health risk reductions are not achieved by reduced exposure. Thus, based on specific advice from scientific peer-review, we project benefits from reducing fine particle pollution below the level of the NAAQS and below the lowest levels measured in the studies.
In a radical departure from this science, the Trump EPA calculated the forgone PM2.5 health benefits from repealing the Clean Power Plan by just assuming health benefits “fall to zero in areas whose model-predicted air quality is at or below the annual average PM2.5 NAAQS of 12 µg/m3.”
The scientific consensus that PM2.5 is a “no-threshold” pollutant—with a risk of PM2.5-related harm and death below the NAAQS level—has been independently reviewed and confirmed by EPA’s official Clean Air Science Advisory Committee, the Advisory Council on Clean Air Compliance Analysis (and separately, the Health Effects Subcommittee of this Council), EPA’s Science Advisory Board and the National Academy of Sciences.
The World Health Organization similarly has concluded that “[s]mall particle pollution has health impacts even at very low concentrations—indeed no threshold has been identified below which no damage to health is observed.”
In 2010, EPA issued a “Summary of Expert Opinions” on this precise issue. This review reaffirmed the “no-threshold” conclusion for health impacts related to fine particle pollution. The experts included doctors, scientists and researchers from the American Heart Association, the Health Effects Subcommittee from The National Academies, the National Research Council, EPA’s Clean Air Science Advisory Committee, the Harvard School of Public Health, the Harvard Medical School, Yale University, Columbia University, the George Washington University Medical Center, the Duke University Medical Center, the University of North Carolina, North Carolina State University, Brigham Young University, the Institute of Occupational Medicine in the United Kingdom, New York University, the University of Southern California, and many, many others.
Noted particulate matter researcher, Dr. George Thurston, ScD, with the New York University School of Medicine and the American Thoracic Society, commented this week on the Trump EPA’s planned repeal of the Clean Power Plan:
“One key thing to understand with respect to the expected (EPA alternative) proposal is that there is no convincing evidence that an air pollution exposure threshold exists below which particulate matter exposure does no harm to human health,” he said.
The Bush administration EPA also understood and accepted that fine particle pollution causes premature death and other health hazards below the NAAQS level. The Bush EPA agreed that reducing fine particle pollution exposure below these levels continues to deliver health benefits that should be counted and whose economic benefits should be monetized:
- In conducting economic analysis for its so-called Clear Skies legislation, in 2003, the Bush administration wrote that “[l]inear concentration-response relationships between PM and all health effects are assumed, indicating that reductions in PM have the same impact on health outcomes regardless of the absolute level of PM in a given location.” Accordingly, the Bush EPA heralded $110 billion in annual human health benefits, from avoiding 14,100 premature deaths, 180,000 asthma attacks, and 23,000 non-fatal heart attacks. Many of these health benefits were achieved in areas already meeting the NAAQS for PM2.5, reflecting the fact that fine particle-related health benefits still accrued at levels below the NAAQS.
- In the economic analysis for its 2004 “Tier IV” rule to control emissions from nonroad diesel engines, the Bush EPA found no basis for any threshold of health hazards stopping at low concentrations of fine particle pollution, including at levels below the PM2.5 NAAQS. The Bush EPA credited the conclusion of its “Science Advisory Board’s Advisory Council for Clean Air Compliance” that “there is currently no scientific basis for assuming any specific threshold for the PM-related health effects considered in typical benefits analyses.”
- In the economic analysis for its 2005 Clean Air Interstate Rule, the Bush EPA agreed there are no thresholds for fine particle pollution-related health effects, including premature mortality. (4-43 to 4-44).
Why is this history so relevant—and so damning—today to the Trump EPA’s exercise in scientific fraud? A key EPA official involved in these Bush administration clean air rules, William Wehrum, is now President Trump’s nominee to be Assistant Administrator for EPA’s Office of Air & Radiation, the office tasked by Trump and Administrator Scott Pruitt with repealing the Clean Power Plan.
Should Mr. Wehrum be confirmed—despite NRDC’s view that he is unfit for the job—he will inherit Pruitt’s scientific fraud, which contradicts not just the overwhelming science on PM2.5 health hazards, but positions consistently taken by Mr. Wehrum himself at EPA.
At his recent Senate confirmation hearing, Mr. Wehrum told Senator James Inhofe (R-Okla.) that the Tier IV nonroad diesel rule was the project of which he was most proud during his tenure with the Bush EPA.
Mr. Wehrum and EPA relied on the fact that there is no threshold for PM-related health effects, even at levels below the PM2.5 NAAQS, to project that by 2030 the rule would prevent 12,000 premature deaths and 15,000 nonfatal heart attacks.
Indeed, Mr. Wehrum and EPA rejected comments at the time by the American Petroleum Institute—Wehrum’s subsequent client after he left EPA—that EPA “overstate[s] the certainty that PM alone is causing mortality and morbidity,” and that EPA “overestimated the benefits of reducing ambient levels of PM.” The Bush EPA disagreed, stating:
PM, alone or in combination with other pollutants, is associated with adverse effects below those allowed by the then-current standards. EPA has reviewed the substantial literature on this topic and believes that health and welfare effects do result from levels of PM2.5 observed in ambient air.
The Bush EPA went on to reaffirm, in response to other comments, that its Science Advisory Board and the National Research Council agreed “that there is currently no scientific basis for assuming any specific threshold for the PM-related health effects.”
As noted, the Bush EPA relied on this same scientific agreement when analyzing the health and economic benefits of its 2003 Clear Skies legislation. The legislation’s co-sponsor, Senator Inhofe, relied on this same analysis to boast in a press release that, by 2020, Clear Skies would avoid 12,000 premature deaths and 370,000 asthma attacks, among other health benefits. Some of those health benefits would have occurred in areas below the PM2.5 NAAQS.
And who was Senator Inhofe’s chief staff person working on the Clear Skies bill, at the time? The individual who oversaw promotion of the bill, including the aforementioned press release? Andrew Wheeler, President Trump’s nominee to serve as EPA Deputy Administrator under Administrator Pruitt.
In his push to repeal the Clean Power Plan, Pruitt contradicts not only the most esteemed scientific bodies, doctors and researchers in the U.S., but the men nominated to be his #2 and air office head.
So, what new, peer-reviewed studies does Pruitt reference to retreat from the accepted science that fine particle pollution harms health even at very low concentrations, and that no threshold has been identified below which no damage to health is observed?
Does Pruitt rely upon old peer-reviewed studies, or even non-peer-reviewed studies?
Administrator Pruitt’s push to repeal the Clean Power Plan stems from result-oriented politics and ideology. Scientific fraud is just the means to an end.
But this particular scientific fraud is so indefensible, so contradicted by mountains of scientific evidence, so unsupported by even a modicum of counter-evidence, that Pruitt is painting a big red target on his attempted repeal of the Clean Power Plan. He is giving critics—certain to challenge his retreat in court—further powerful grounds for a court to declare his actions arbitrary, capricious and unlawful.
In his zeal to repeal the Clean Power Plan, Pruitt tries to hide the dirtier air and health hazards that will result by denying any harm from increasing deadly fine particle pollution. There appears to be no threshold below which Pruitt will not stoop to let industry pollute more and hurt Americans.