Friday, February 3rd 2012, 4:41 PM EST
Despite growing concern about the high costs and minimal benefits of the Environmental Protection Agency’s mercury, particulate, MACT, cross-state and other air pollution rules, the EPA has pushed forward with numerous rulemakings.
Dr. Willie Soon and I have followed this situation closely and written a number of articles about it. Indeed, Willie is one of the few people who have carefully analyzed EPA’s rulemakings; examined its analyses, assumptions, assertions and conclusions; and scrutinized the agency’s attempted medical and scientific justifications for the rules. Simply put, we vigorously disagree with EPA.
Our latest analysis strongly contests EPA’s methodologies, its latest rulemaking – and its most recent claims that the agency’s expensive “National Emission Standards for Hazardous Air Pollutants” will somehow protect Americans’ health.
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Agenda-driven “science” at EPA
Newly proposed air pollution rules impose exorbitant costs for illusory health benefits
Willie Soon and Paul Driessen
In December 2011, the Environmental Protection Agency released new Clean Air Act “National Emission Standards for Hazardous Air Pollutants.” Once again, EPA Administrator Lisa Jackson touted the supposedly huge benefits of controlling emissions of mercury (Hg) and other air toxics from U.S. coal- and oil-fired power plants (or electric generating units, EGUs).
The people of Idaho may welcome this new rule, since EPA’s miraculous modeling machine has promised to prevent “six premature deaths” and create “up to $54 million” in health benefits by 2016 – even though not one coal-fired EGU in Idaho fits the EPA’s final rules. Even the District of Columbia, which has only one oil-fired unit, will somehow, magically realize “up to $120 million” in health benefits, presumably from new restrictions on coal-fired units in Maryland or Virginia.
The average U.S. citizen, however, can be excused for no longer being willing to be penalized by EPA – the Extreme Punishment Authority – for such minimal, imaginary and manufactured benefits.
In fact, the final rule may be the most expensive one ever devised by EPA. And yet, even EPA admits, the alleged “hazards to public health” from mercury and non-mercury emissions from American EGUs are “anticipated to remain after imposition” of the new regulations.
As to benefits, EPA computer models claim Hg emission cuts will reduce average per person “avoided IQ loss” by an undetectable “0.00209 IQ points,” with estimated “total nationwide benefits” of $500,000 to $6.1 million by 2016. For the electric utility sector, says EPA, net job creation from the rules will be “not statistically different from zero” and could be between minus 15,000 and plus 30,000 jobs.
In fact, the new regulations will likely eliminate tens of thousands of jobs annually, especially in energy-intensive industries that rely on low-cost electricity to survive and face growing competition from foreign companies that pay far less for energy, labor and raw materials. Small businesses will also get hammered.
“EPA cannot certify that there will be no SISNOSE from this rule,” the agency admits. “SISNOSE” is EPA-speak for “significant impacts on a substantial number of small entities.” In other words, the rules are likely to inflict significant economic harm on small businesses, and thus on the health and welfare of numerous (former) small business owners, employees and families. The agency failed to explain why it has once again ignored the adverse impacts on human health and welfare caused by its rules.
EPA also confessed that U.S. power plants actually contribute a mere 3% of the total mercury deposited in computer-modeled American watersheds, and thus in fish tissue. Citizens will justifiably wonder where the other 97% comes from, and why we should spend so much money for so little benefit. (The “missing” mercury comes from foreign sources and from volcanoes, subsea vents and other natural sources.)
To see how extreme EPA’s scenarios are, consider five more egregious errors in the final regulations. First, EPA admitted it could “calculate risk” for only 3,100 (4%) of the continental USA’s 88,000 watersheds.
Second, for over 60% of the 3,100 watersheds it did model, EPA took only one or two fish mercury measurements – making it virtually impossible to adopt even valid 75th-percentile fish mercury values. There is a breaking point where extremely poor statistical sampling renders EPA’s pretentious number crunching, conclusions and rules invalid. That breaking point has clearly been reached.
Third, the agency’s estimates for mercury exposure risks are solely for “hypothetical female subsistence consumers” who daily eat almost a pound of fish that they themselves catch in U.S. streams, rivers, and lakes over a 70-year lifetime. That’s less than 1% of U.S. women. For the rest of American women (who eat mostly ocean fish, purchased at a grocery, on a far less regular basis), EPA’s rules are irrelevant.
Fourth, EPA admits that only 22 to 29% of its computer-modeled watersheds are “at risk” from EGU mercury, even when it erroneously assumed that at least 5% of total Hg deposition into the watersheds came from U.S. power plants. If the modeling criteria were tweaked only slightly – to reflect average freshwater fish consumption rates for American women, and require that at least 15% of total mercury deposition be attributable to EGUs – not one U.S. watershed would be at risk.
Finally, EPA ignores the presence of selenium in nearly all fish. Its strong attraction to mercury molecules protects fish and people against buildups of methylmercury (MeHg), mercury’s biologically active and more toxic form.
Combining any series of small probability scenarios results in a near-zero likelihood that the events will actually happen. If each of five scenarios has only a 20% chance of happening, the likelihood that all five will happen is 0.032 percent.
As the preceding analysis suggests, the probability that all the EPA’s improbable scenarios will actually happen is virtually zero; the likelihood that its new regulations will benefit human health is also zero.
However, EPA still stubbornly “disagrees that [mercury] exposure levels in the U.S. are lower than those in the Faroe Islands.” Exposure to MeHg in the U.S. is “the same” as in the Faroe Islands, EPA insists.
The agency is simply wrong.
Extensive medical and scientific studies demonstrate that average Americans are exposed to at least 5 to 10 times less MeHg than average Faroe Islanders. The islanders consume large quantities of pilot whale meat and blubber – which is high in methylmercury, high in PCBs and low in selenium. As a result, their blood mercury concentrations can be up to 350 times higher than the mean blood mercury levels measured by the Centers for Disease Control for average American women.
The Faroe Islands study is irrelevant to mercury exposure risk for average Americans. EPA’s use of that study is deceptive. American women and children are safe from any likely threats from mercury.
To top it off, EPA itself proclaims: “The emissions limits in today’s rule are technology-based … and do not need to be justified based on their ability to protect public health.”
In other words, if the technology exists to eliminate these pollutants, the agency will impose the new regulations – regardless of their cost, their effect on electricity prices and reliability, their impact on factory and other jobs, and whether the rules actually do little or nothing to improve human health.
It has become increasingly obvious that EPA’s real goal is to assert its authority over ever-increasing segments of our economy; reinterpret medical and scientific studies to fit its regulatory agenda; and replace as many coal-fired power plants as possible with costly, unreliable renewable energy systems.
American voters, elected officials and courts need to challenge these radical, unelected, unaccountable bureaucrats, demand an end to EPA’s distortion of science and reality – and reverse these flawed rules.
Willie Soon is a natural scientist with strong interest in mercury and public health issues. Paul Driessen is senior policy advisor for the Committee For A Constructive Tomorrow and Congress of Racial Equality.