A Little Pollution Saves Lives

March 7th, 2012 by Roy W. Spencer, Ph. D.

I’ve been studying up to help out on a future John Stossel segment which will likely address the EPA’s overreach in trying to reduce pollution to vanishingly small levels.

Of course, if we could do such a thing at reasonable cost, and there were clear benefits to human health and welfare, then such a goal might make sense. But what was once a noble and achievable goal to clean up most of our air and water pollution has become an end in itself: to keep making things cleaner and cleaner, no matter the cost.

I remember driving through the Gary, Indiana industrial complex in the 1960s. The air pollution was simply unbelievable. You could not escape the stench and smoke; rolling up the car windows did not help.

I also remember the Cuyahoga River fire of 1969. There is no question that the EPA has greatly helped…but we must remember that the EPA was the result of the public’s realization that is was time to start cleaning up some of our messes.

The fundamental problem, though, is that the EPA was given what amounts to limitless power. They do not have to show that their regulations will not do more harm than good to human health and welfare. Now, I will admit they do provide periodic reports on their estimates of costs versus benefits of regulations, but the benefits are often based upon questionable statistical studies which have poor correlations, very little statistical signal, and little cause-and-effect evidence that certain pollutants are actually dangerous to humans.

And the costs of those regulations to the private sector are only the direct costs, because indirect costs to the economy as a whole are so difficult to assess.

Even if some (or even all) pollutants present some risk to human health and welfare, it makes no sense to spend more and more money to reduce that risk to arbitrarily low levels at the expense of more worthy goals.

Economists will tell you that society has unlimited wants but only limited resources, and so we must choose carefully to achieve maximum benefits with minimum cost. It is easy to come up with ideas that will “save lives”; it is not so easy to figure out how many lives your idea will cost. The same is true of government jobs programs, which only create special interest jobs at the expense of more useful (to the consumer) private sector jobs.

The indirect costs to the economy can be the greatest costs, and since we know very well that poverty kills, when we reduce economic prosperity, people — especially poor people — die.

Income is directly proportional to longevity; you cannot keep siphoning off money to chase the impossible dream of pure air and pure water, because those are simply not achievable goals. It makes absolutely no sense to give a government agency unlimited authority to regulate pollution to arbitrarily low levels with no concern over the indirect cost to society.

But that’s what we have with today’s EPA. Several years ago I gave an invited talk at a meeting of CAPCA, the Carolinas Air Pollution Control Association. There was also an EPA representative who spoke, and to everyone’s amazement stated something to the effect that “we can’t stop pushing for cleaner and cleaner air”. Eyebrows were raised because in the real world, such a stated goal ignores physical and economic realities. There is no way to totally avoid pollution, only reduce it.

How far we reduce it is the question, and so far the EPA really does not care how many people they might kill in the process. Or, they are too dumb to understand such basic economic principles.

Let’s take the example of fine particulate matter in the air (the so-called PM2.5, particles less than 2.5 microns in size), which the EPA recently decided is unsafe at any level (“no threshold” at which it is safe). Let’s take a look at a satellite estimate of the global distribution of this “pollution”:

You will note that the most “polluted” air occurs where almost no one is around to pollute: in the deserts. This is because wind blowing over bare soil causes dust particles. If you really are worried about fine particulate air pollution, do not go outside on a windy day.

Also note in the above map the blue to cyan areas, which have concentrations below 10 micrograms per cubic meter. Those are levels the World Health Organization has previously deemed safe. The western United States is largely below that level. If one examines the monitoring station data west of Denver, there is no correlation between changes in fine particulate matter pollution and deaths, but the oft-quoted Pope et al analysis of those data lumps all of the U.S. data together and finds a weak statistical relationship between deaths and changes in fine particulate pollution.

The EPA then concludes that NO level of such pollution is safe, even though the data from the western U.S. suggests there is a safe level.

As a scientist who deals in statistics and large datasets on almost a daily basis, I can tell you it is easy to fool yourself with statistical correlations. The risk levels that epidemiologists talk about these days for air pollution are around 5% or 10% increased risk compared to background. This is in the noise level compared to the increased health risk from cigarette smoking, which is more like 1,500%. When statistical signals are that small, one needs to look far and wide for confounding factors, that is, other more important variables you may not have accounted for to the accuracy needed to make any significant conclusion.

Actually establishing a mechanism of disease causation is not required for the EPA to regulate; just weak correlations and a board of “independent” scientific advisers who are themselves supported by the EPA.

Of course, when Congress makes any attempt to rein in the EPA, there are screams that decades of air pollution control progress is being “rolled back”. Bulls&!t. The new pollution regulations now being considered have reached the point of diminishing returns and greatly increased cost.

This week I was with about 250 representatives of various companies involved in different aspects of growing America’s (and a good part of the world’s) food supply. The most common complaint is the overreach of government regulation, which is increasing costs for everyone. The extra costs have been somewhat shielded from the consumer by industry, but they told me that sharply increasing food prices are now inevitable, in fact they are already showing up in grocery stores.

And I haven’t even mentioned carbon dioxide regulations. Even if we could substantially reduce U.S. CO2 emissions in the next 20 years, which barring some new technology is virtually impossible, the resulting (theoretically-computed) impact on U.S or global temperatures would be unmeasurable….hundredths of a degree C at best.

The cost in terms of human suffering, however, will be immense.

It is time for the public to demand that Congress limit the EPA’s authority. The EPA operates outside of real world constraints, and is itself an increasing threat to human health and welfare — the very things that the EPA was created to protect.

47 Responses to “A Little Pollution Saves Lives”

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  1. Olavi says:

    At the same time while USA, Europe and Australia reducing emissions, China, India and others building more emmissions without any hesitation. China and India developing their economy fast, so in ten years they’ll say how this world goes forward. Europe’s economy is going to fall like plane to crashlanding with this Cap and trade policy. This leads to trade war sooner or later. From USA, Europe, Kanada and Australia millions industrial jobs has allready gone to Asian countries do theese politicians believe that economies can survive if we wash each others clothes?

  2. Greg in Houston says:

    Actually, the US government has already put a defacto “worth” on a human’s life in at least one area: automotive travel safety. Back in 1974, the 55 mph speed limit was put into place to save energy. When saving energy was no longer a political concern, the speed limit remained because increasing the limit would cause more deaths/injuries. Because of the resultant outcry due to the lost efficiency of travel, there is now no national limit, and one can find legal speeds as high as 80 mph. This comes at a cost in human lives, almost assuredly. The number of increased deaths and devastating injuries can be estimated, I suppose, and you could compare that to the value of increased efficiency.

    My point is that the government has already decided to allow increased mortality in exchange for reduced cost. If the National Highway Traffic Safety Administration were combined with the EPA, we would not be allowed to drive.

    • Snorbert Zangox says:

      I have seen a couple of studies, which I cannot cite, that claim to have shown that differential speed is the most dangerous aspect of speed. When the difference between the fastest and the slowest cars exceeds 20 mph, accident rates rise rapidly. Most States, perhaps in recognition of this, have laws that prohibit a person to drive more than 10 mph below the speed limit.

      • Bulkhead50 says:

        There has already been a NHTSA study of the German Autobahn vs. US highways. Per million miles driven, the US averages .84 deaths. The Germans average .72 deaths. So, your theory that more deaths from higher speed doesn’t hold water.

  3. David Thomas says:

    “Of course, when Congress makes any attempt to reign in the EPA,”

    I think you meant rein in.

  4. Greg in Houston says:

    Snorbert, I am sure you are right. The faster you are going when you hit something that is not moving, the more it is going to hurt! (That both objects may be moving can only increase the severity of the collision).

    • Snorbert Zangox says:

      Absolutely, the amount of damage done is proportional to the square of differential speed.

  5. CO2 is a false god, a gaseous idol. It is supposed to be vengeful and demand sacrifices.
    Embracing this new religion might be the end.
    Burning ethanol is burning food and destroying forests.
    Petroleum and gas are the resources that nature put at our disposal, but the new insanity say otherwise.
    Thanks Dr. Spencer, for all you have done to preserve human kind.

    • Rafael Molina Navas, Madrid says:

      You say:
      “Petroleum and gas are the resources that nature put at our disposal …”
      You are right, and it took nature TENS OF MILLION YEARS to produce them, taking carbon from the atmosphere and putting it into fossil fuels…
      And we are throwing it back to the air -CO2- during just A COUPLE OF CENTURIES …
      Would climate system be too fragile – as Dr. Spencer says – if, due to our deplorable action global mean temperatures rised a few degrees?

  6. Adam Gallon says:

    Eventually, a beaurocracy’s main aim, is to perpetuate its own existance. As such, it must find more reasons to justify its existance.
    Very much like politicians, infact, who feel they must keep making new laws and finding new “problems” to legislate upon.
    Vested interests also add to the mix, via pressure groups, “useful idiots” and lobbying.
    You can bet your bottom dollar, that companies selling air monitoring & treating equipment, will be hard at work on this, especially if there’s a US manufacturer.

  7. Joel Upchurch says:

    In a similar vein there is a new crusade against ‘third hand smoking’. First they went on a crusade against ‘second hand smoking’, even when the smoking was happening outdoors. Now smokers will be forbidden to come to work if anyone can smell tobacco on their clothing. The assertion is made that there is no safe level of exposure to tobacco smoke. I did some checking and it turned out there is no actual scientific research supporting this and a lot of research saying that below a certain level, there is no statistically measurable damage.

    The trouble is once an organization is created to alleviate some harm, they will never come out and say that their job is done and they will disband and find useful employment. First they attacked smoking and then 2nd hand smoke and then 3rd hand smoking and even when tobacco is banned, they will never go away.

    I don’t smoke and have never smoked, but I know bs when I hear it.

  8. Pat Moffitt says:

    I’ve always wondered- does EPA have the authority to set air standards more restrictive than the “natural condition” ? Might be time to start asking.

    I’ll bet air quality for many areas of the country with respect to reactive nitrogen and particulates is better now than it was prior to modern fire suppression. (Probably for ozone precursors as well) Those hazy days of summer were caused by smoke and natural epoxides. For much of southern NJ the total nitrogen deposition now is probably about what what it was when the Pinelands burned at the pre-fire suppression levels.

    One only needs to look at the CT air quality violations following this October’s snow related power outages to see the impact of cranking up those fireplaces. People complained in Chicago last summer about the air violations due to 100,000 acre Minn wild fire. Imagine the complaints when this same area of MN burned nearly 100,000 acres every year plus you add in another 100 million acres of prairie fire!

  9. Massimo PORZIO says:

    PM2.5? Uhmmm…
    Here in West Ticino river cities we “fought” against PM10 last Sunday.
    Embracing a EU directive we had to stop all our cars from 8AM to 6PM to reduce the PM10 pollution in our cities.
    The absurd was that you can use your car if you had at least 2 passenger on board.
    You must know that in EU diesel cars have been recommended in the past, now more than 50% of the cars on our roads have diesel engine. EU government recommended diesel cars also because they said that they produce less CO2 per km than gasoline ones. True, but they missed to tell the people that diesel cars produce about 10 times PM10 than gasoline ones, so now we have exceeded the “safe limits” (they say) and despite I own a gasoline car I had to stay at home last Sunday because the public administration didn’t matter of that.
    They didn’t matter if driving my car alone I pollute about one third the amount of the “one driver and two passengers occupied diesel car”. I had to stay at home or I could get a fine.
    That’s crazy and next Sunday my city administration will do it again. Someone is comforted by knowing that at least we can use the cars during the working days. That’s because about two weeks ago the major of a city near here did worse. He closed the city streets to all the even number plated cars on odd days and on the even days he closed the city streets to the odd number plated cars (sound crazy, yeah? It had absolutely happen here in Italy, and that wasn’t the first time).
    If you lived in that city and you wanted to go to work that days you should had two cars having one odd number plate and one even number plate or you had to go at work before 8AM and return home after 8PM.

    Looking to that “PM2.5 pollutant map” I can imagine someone Italian public administrator could suggest stop the camels to run in the Sahara one day 🙂

  10. cynthia says:

    Glutathione is the mechanism that the body uses to detoxify itself. If you have good glutathione levels you can easily tolerate 10 times the pollution as a person with low glutathione levels. It is not a cost effective strategy to spend billions trying to reduce the pollution level to zero, and spend nothing on boosting our glutathione levels. You need to have good gluathione levels for good health anyway, because man made pollution is not the only insult to our bodies.

  11. Greg F says:

    EPA’s overreach extends beyond what most people know. If you have any doubt the agency should not be dissolved read this.


  12. KevinK says:

    Dr. Spencer, very well stated.

    As some might know, the human body only develops an antibody response to those germs that it is exposed to. So, if you only expose your body to a sterile environment you will not develop any antibody response at all and will likely suffer greatly from the first germ you happen to encounter.

    So you are indeed correct, there is a point of diminishing returns; if you spend all of your time washing your hands to rid them of germs, you cannot accomplish many other tasks. Sure, you should wash your hands when appropriate, but you cannot keep them germ free.

    Perhaps we should start carefully vacuuming up all the stray dust in those deserts to keep the particulate levels below what somebody claims is “SAFE”, ha ha ha.

    Nice post, a good expose on the balance between reality and what a bureaucrat “could possibly” accomplish with unlimited authority and budget.

    Cheers, Kevin.

  13. Sam Barnett says:

    I have worked for the Division of Air Pollution Control in the state of TN for 11 years and this article hits home. Not only do I agree, but this is stuff that I (and others here on the front lines) have been screaming. With all due respect, I don’t think even you realize the insane amount of regulations that is promulgated that I have to enforce. Go take a look at the secondary aluminum MACT regulations and let me know when you are done. You’ll have to take off work a few weeks. Then we have the ozone standard being lowered down to possibly .065 ppm over 8 hours I am hearing? Has their been any quantifiable study done on what “normal” terrestrial background ozone should be so we know when to stop? When I first arrived, I saw ozone concentrations much higher than this by the one hour standard and now it’s considerably less. There is a time to stop. This is not only killing this country, but it’s discouraging economic growth Roy. And all my superiors are all about making the EPA as happy as possible. But in the end, I have to as well because that’s how I put food on the table. But I don’t have to like it.

  14. I guess what I don’t understand about this post is why it is focusing on PM2.5. The two new regs EPA has implemented concern the Boiler MACT rule (the ‘Mercury Rule’) and the Cross-state pollution rule (CSAPR). Even the CO2 (GHG) rule has been delayed beyond the court-ordered schedule, and we’re still waiting for it. The ozone rule was shelved. Treating fly ash as a hazardous waste under RCRA has not happened. EPA has begun exercising CWA authority to deal with the dumping of fill from mountaintop removal, but that’s based on some 100+ studies of downstream pollution and seems to be justified.

    If you want to make the scientific case that a particular NAAQS is not justified, that’s cool. That is what the scientific community is talking about (and it’s a discussion I am not qualified to weigh in on … I trust the Dr.’s as far as safe levels for my kids to inhale). But to suggest that this EPA is overreaching is wrong in a legal sense.

    Take the Boiler MACT for instance. It was required by the 1990 CAA Amendmnets. When EPA dragged its feet, EPA was sued, and courts ordered it to enact a rule for mercury (and other nasty stuff like nickel and arsenic). The Bush EPA passed a version of such a rule, but it was struck down by the courts (it tried to implement a cap-and-trade type system for these pollutants, but that was not permitted under the hazardous pollutant portion of the CAA). Obama’s EPA was required to enact some rule controlling the emission of these pollutants, and it is required by law to set the standard consistent with Maximum Achievable Control Technology.

    Similar history with respect to the CSAPR. SOx and NOx are criteria pollutants that have been regulated by NAAQS since the 1970s. Emissions in some states were causing non-attainment in other states, so the courts required EPA to address these cross state polltants. The Bush EPA tried with the CAIR, and it too was stricken by the D.C. Ct of Apps. The Obama EPA was required to enact a new cross state rule addressing these emissions. It did.

    Both of these rules set standards that can be easily met by currently available and feasible tachnology; in fact, most facilities are already in compliance. Those that aren’t are the really old and decrepid plants that were grandfathered in under the 1977 CAA amendments (i.e., they weren’t subject to existing NAAQS unless they were substantially modified). Many companies, especially Constellation Energy, have been taking steps for years in anticipation of the regs. In fact, Constellation has been trying to expedite the rules so they can reep the competitive advantage of their foresightful investment.

    The rules also allow for waivers for facilities that cannot come into compliance within the two year window required by the rules.

    The GHG rules for existing facilities, not yet issued despite a court ordered settlement that they would be finalized last year, were known to be coming ever since the Mass v EPA decision in Spring 2007.

    These rules do require electric generating entities to make a business decision to shut down old plants now rather than sink invesntments for emission technology into 50-year-old plants. Those plants would have to be closed in the relatively near future anyway, though the pending regs may have hastened the business decision by a few years. Expediting the business decision is, I would say, a good thing. The grandfather provision of the CAA has been abused for too long to keep big belching monstrosities in service far longer than they should be in light of modern technology.

    Oh, and the cost of compliance is actually a factor to be considered under the BACT analysis EPA undertakes, contrary to the assertion in this article. For hazardous pollutants (like mercury; contrasted with criteria pollutants like SOx), maximum achievable control technology (MACT) is the standard, and cost isn’t considered. Same is true for criteria pollutants in non-attainment areas. But for the criteria pollutants in attainment areas, cost and feasibility is a consideration in the BACT analysis.

    • Kevin says:


      One thing you left out is that the Supreme Court decision in Mass. v. EPA did not mandate that greenhouse gas emissions be regulated. Rather, it indicated that EPA had the authority to determine whether greenhouse gas emissions were a danger to human health and welfare. The EPA “Endangerment Finding” was the trigger for regulating greenhouse gases. In my opinion, that finding was more political than scientific, as I am sure Dr. Spencer woluld agree.

  15. Terry says:

    Hi Roy

    I agree that Pm2.5 is the correct pollutant to focus on from a scientific point of view, although in a few years we may find that this moves down to smaller particles that are submicron. The most useful study to date has been the recent AMA (Amercian Medical Association) study that showed for the first time the mechanisms of damage to human health caused by particulate. What they also found was that it was the ultrafine combustion derived particles that are of most concern. PM2.5 is a reasonably good surrogate for these, and is way better than PM10.

    The Pope et al study and Dockery et al should have been dismissed years ago, but the WHO have steadfastly held them up as being the definitive works. But what is even more egregious by WHO and the EPA is their refusal to allow sea salt to be accounted for in the PM10 and PM2.5 budgets. Their excuse is that it is too hard. In many urban environments, sea salt accounts for up to HALF the recorded PM10 and PM2.5 and non compliance with the standards is common. All caused by sea salt. Now if the human race is being killed off by exposure to sea salt aerosol, then I am closer to the monkey race than I had thought.

  16. Colin says:

    I’m a little curious as to why there doesn’t appear to be any records for central Australia.

  17. CoRev says:

    Dr Spencer would you please list the components of your calculation for: “…the resulting (theoretically-computed) impact on U.S or global temperatures would be unmeasurable…. hundredths of a degree C at best.”

    I especially agree with this calculation of temperature impact if we implemented the ACO2 goals. My own calculations makes it even less than you do.

    So few actually do the simplest of math to define this possible impact. It’s all about the emotions don’cha know. We’re saving the planet, whales, polar bears, chilruns….

    We would be more successful in discussions if we just cited these easy to calculate impacts.

  18. Pat Moffitt says:

    Sam Bartlett – “Has their been any quantifiable study done on what “normal” terrestrial background ozone should be so we know when to stop?”

    My point made earlier asking- does EPA have the authority to promulgate regulations stricter than the “natural condition”?

  19. KR says:

    Dr. Spencer: “You will note that the most “polluted” air occurs where almost no one is around to pollute: in the deserts.”

    Funny – I never thought of China, India, or Bangladesh as ‘deserts’ – there may be a billion or two people who would disagree with you about that.

    “substantially reduce U.S. CO2 emissions in the next 20 years… The cost in terms of human suffering, however, will be immense.”

    _Every_ cost/benefit analysis I have ever seen shows the health and health cost benefits of reducing pollution, _especially_ small particulate matter. But I suppose the various industry folks you spoke to weren’t too concerned about external societal costs that they don’t get directly billed for…

  20. So it looks like, from the map, that whatever standards EPA has implemented for PM2.5 have had their intended effect. And, at least as far as I know, there are no pending or contemplated rules or new standards contemplated for PM2.5 (by my understanding, they were last updated in 2006). EPA has done it’s job in reducing particulate matter emissions. Good work EPA!

    So what is the point of this post again?

  21. Kevin (@ 1:20 p.m.) — You are correct that Mass v EPA did not compel regulation. It did, in essence, compel the endangerment analysis. And, given the state of the science, EPA could not have possibly concluded that GHG emissions could not reasonably endanger public health and welfare (‘public welfare’ being defined to include effects on weather and climate). The Bush EPA reached the exact same endangerment conclusion as the Obama EPA, so I think it is inaccurate to say that it was a political finding. Go read the 900+ page endangerment analysis, and read Samuel Johnson’s similar analysis under Bush, before you make such ideologically-motivated and inaccurate assertions.

  22. Doug Cotton says:

    O H Dahlsveen says on WUWT:
    March 8, 2012 at 1:14 pm

    I do not believe the theory of the Atmospheric Greenhouse Effect (AGHE) to be a “misnomer”. I think it is just plain wrong

    Basically you are correct. There can be no transfer of thermal energy from the cooler atmosphere to the warmer surface by any physical process, radiation or otherwise. However, we have to acknowledge that radiation from the atmosphere does slow the rate of radiative energy transfer from the surface to the atmosphere. This is why it can be warmer on moist nights. However, on balance, other processes, mostly evaporation and diffusion (conduction) will make up for any reduction in radiative flux, because of the stabilising effect of the massive store of thermal energy beneath the outer crust, which is not due to the very slow rate of terrestrial energy flow.

    There is also a cooling effect due to water vapour and CO2 etc as these absorb downwelling IR radiation from the Sun and send upward backradiation to space.

    The temperature gradient in the atmosphere is determined by the mass of the atmosphere and the acceleration due to gravity, both close enough to being constants. All the claims about 255K are based on the false assumption that the surface is anything like a blackbody. It’s not because it’s not insulated from losses by diffusion and evapoation. Less than half the energy exits by radiation. So, not only is that 33 degree figure based on a totally incorrect 255K figure, but it also ignores the fact that there is an adiabatic lapse rate that has nothing to do with backradiation.

    This is a very brief summary of my peer-reviewed paper being published next week.

  23. MRW says:

    This is factually wrong: “The same is true of government jobs programs, which only create special interest jobs at the expense of more useful (to the consumer) private sector jobs.”

    Read THE 7 DEADLY INNOCENT FRAUDS OF ECONOMIC POLICY (free online but not on Amazon):

    [Please read this, Roy. The real economic history of the US is unknown to 99% of Americans because it was never taught. It’s a couple of web screens. It may cause you to be more discerning about economic policy. We were a prosperous nation when we were on paper. It was the British bankers who imposed the gold standard, then restricted the amoutn of gold and silver to back it via The Currency Act of 1764, which led to the American Revolution. What is taught in schools is Hollywood drivel written, originally, by Eastern European directors:
    http://www.jimbernard.org/gpage16.html )

  24. Doug Cotton says:

    Willis wrote on WUWT: .. the guesstimated range of climate sensitivity hasn’t narrowed in any significant fashion. It’s still right around 3 ± 1.5°C per double of CO2, just like it was in 1979.

    Indeed, and they still don’t recognise, even though it’s been pointed out numerous times, that the sensitivity calculation is based on completely fabricated “physics” which assumes, firstly that the Earth’s surface only loses thermal energy by radiation – hence their 255K figure – and then they say that 33 degrees is due to water vapour and trace gases, when in fact it’s not 33 degrees at all (because the 255K is wrong) , and whatever it should be is due to the acceleration due to gravity, which determines the adiabatic lapse rate. Then, to cap it off, they put back evaporation and diffusion (wrongly named convection or thermals) into their energy diagrams, thus admitting their mistake in assuming that the surface only radiates like a perfectly insulated blackbody does.

    They also neglect the cooling effect due to absorption of solar radiation in the SW IR range, followed by upwelling “backradiation” to space. This SW IR has more energy per photon than does the LW IR from the surface. And backradiation to space does prevent warming, just like reflection, whereas backradiation downwards cannot transfer thermal energy to the surface – it can only slow the radiative component of surface cooling, not the evaporative of diffusion processes.

    Hence there is absolutely no basis whatsoever for any warming sensitivity when, in fact, carbon dioxide almost certainly has a very slight net cooling effect.

  25. KR says:

    Doug Cotton – What journal are you publishing in?

  26. Chuck L says:

    Dr. Roy, please let us
    when Stoessel’s piece will air.


  27. Kevin says:


    I am afraid we will have to disagree on whether EPA could have reached a different conclusion in its Endangerment analysis. I am not a climate scientist, but I am an environmental attorney and have studied the Massachussets case, the Endangerment Finding, the successive IPCC Reports and read numerous books on both sides of the Global Warming debate. I have concluded that there is not an objective assessment of the causes of climate change or the potential effects of GHG emissions within the US Government agencies. Rather, I believe there has been a bandwagon effect, with agency regulators and bureaucrats climbing aboard without independently evaluating the science. EPA did not attempt to independently evaluate the science, depending almost entirely on the IPCC conclusions.

  28. Kevin,

    I come at it from a similar perspective (as a recovering environmental attorney who now teaches Sustainable Energy Law and who reads everything I can lay my hands on on either side of the issue). With respect to the endangerment analysis, remember that the language of the statute requires EPA to regulate a pollutant “if it may reasonably be anticipated to endanger public health and welfare.” And ‘public welfare’ is defined broadly to include effects of weather and climate. The CAA does not require a finding that a particular pollutant “will harm humans.”

    Given the state of the scientific literature, it would be uncredible to conclude that there is no reasonable chance that GHG emissions could threaten climate patterns. I’ve read Dr. Spencer’s books and many of Dr. Lindzen’s articles, I don’t think that even they would argue that GHG emissions won’t have any effect on climate (and potentially on health).

    The conclusions in EPA’s endangerment analysis went beyond what is required for regulation under the CAA.

    That said, you are correct that EPA relied heavily on the IPCC in reaching its conclusions. That is an argument that has been made in various lawsuits … basically that EPA abrogated its evaluative responsibility to the IPCC (and relatedly that, by relying so much on the IPCC, EPA failed to have an open decision-making process and create an adequate record). Those arguments have gone nowhere so far.

    By the way, I think both the National Acadamies and the US Climate Change Research Group have independently evaluated the science in issuing their reports over the past couple years. In fact, they differ from the IPCC in some regards, though the basic conclusion — human-caused climate change of a significant enough degree to warrant action — is comparable.

  29. StGeorge says:

    All this regulation by EPA is all well and good until we reach the point that it costs us all dearly. Once electricity rates “necessarily skyrocket” as Obama said they would under his plan, once fuel costs for vehicles and other means of transport go significantly higher, once we can no longer produce enough energy on the electrical grid due to regulations and incur rolling blackouts, I think some people might change their view of how great EPA is right now. Indeed, wait and see how the carbon tax plays out in Australia when analyses there are showing it could eat up 30% or more of people’s incomes from the tax increases than energy costs do now.

  30. AlaskaHound says:

    The EPA should be showing the before & after effects and rejoice that the U.S. came from a poluted night to a brighter day by presenting Lake Erie and the industrial complexes of the 50’s-70’s as compared to today. Instead they’ve attained a bizarre attitude and apparently think we older folks have to go so the youngsters can be trained properly without input from the elders of society.
    This whole scene where the world gets gobbled up by liberal ideals has no chance in the long run. The really unfortunate part is when the backlash becomes larger than the encompassing tyrannical situation.
    It all ends quite badly, as it always has over man’s short journey on this planet.
    Teach your children well!

  31. EPA is NOT proposing new standards for particulate matter!!! (The last time they made the PM2.5 standards more stringent was under Bush).

  32. bob paglee says:

    I Remember the river that caught fire and the canal turned into a waste dump. Fixing those and similar unhealthy things was essential and beneficial back then, and I applauded. But we now seem to be in overkill mode, and sooner or later the pendulum will swing back. The greater the foolish overkill is now the greater the future correction will be. More’s the pity.

  33. Thanks Dr. Spencer. Good post!

    In my pages I have posted an article based on the paper Surface Temperature Records: Policy Driven Deception by Joseph D’Aleo and Anthony Watts. Updated, August 27, 2010.

  34. James Mattinson says:

    Excellent article and commentaries.
    A truly ‘adult’ discussion for once.
    EPA,DOE,DOJ etc. under the current Administration are dogma driven.Pragmatism has no place in the issues with which they deal.
    Humankind is a polluter par excellence.
    The only way to make any real impact on the incidence of pollution is to reduce the rate of human population growth.
    I has just passed 7 billion,is increasing at a rate of more than 70 million per year and is on course to exceed 9 billion before we reach mid Century.

  35. w.w.wygart says:

    The mind of the environmentalist [even notice the word ‘mental’ in environmentalism?] contains a self-sealing re-rationalization of responsibility.

    The costs and unanticipated consequences of their programs are systematically reattributed to the original polluters. If people in Bangladesh or Egypt starve because of a food price shock due to some environmental policy that they had enacted, the consequences [dead people] are automatically reattributed to the original [in their minds] offender rather than their own policy – not my responsibility.

    And of course the environment ‘must’ always be ‘restored’ to some arbitrary [name your favorite epoch] level of purity.

    Whatever else it may be, environmentalism can be examined psychologically as an out of control purity neurosis [much like the National Socialists in Germany] ‘everything’ ‘must’ be made ‘pure’ again.


  36. Utahn says:

    “If you really are worried about fine particulate air pollution, do not go outside on a windy day.”

    About particulates/wind etc…I live in Salt Lake (the little red spot out in the intermountain west in the map!) where we oftentimes have auto/industry pollution trapped in our mountain valley.

    The wind comes from the West/SouthWest (where it is desert-think Salt Flats). Rarely we get a big sandstorm that raises particulates (more often PM 10 than PM 2.5). More often we pray for wind to clear out the valley of our manmade particulates…

    As for the Eastern US, those “red zones” sure ain’t coming from desert dust storms, but from all the coal plants out there (note there is a scale difference in what is red from World Map in OP, from same paper).

  37. Utahn says:

    “If you really are worried about fine particulate air pollution, do not go outside on a windy day.”

    What a silly, casually dangerous thing to say. If you live in the desert, don’t go outside in a dust storm. If you live in an urban area, wind is usually your friend in clearing out manmade particulates so you DO want to go out when it’s windy!

  38. patent says:

    Sassan says: March 25, 2012 at 12:55 pm

  39. finance says:

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