EPA is taking live public comment today and tomorrow on the Trump EPA proposal to leave the current PM2.5 standards where they are. Here is my oral testimony.
Good morning. I am Steve Milloy. I publish JunkScience.com.
I commend EPA for leaving the PM2.5 NAAQS where they are — although they really should be rolled back entirely.
The PM standards were conceived and executed by EPA staff and EPA-funded researchers who committed large-scale, far-reaching scientific fraud.
EPA’s CASAC has acknowledged as much in its letter reviewing the EPA staff’s draft PM assessment:
CASAC stated that the EPA staff’s PM assessment “… does not provide a sufficiently comprehensive, systematic assessment of the available science… due largely to lack of a comprehensive, systematic review of relevant scientific literature.”
CASAC said there was “inadequate evidence and rationale for altered causal determinations… and a need for clearer discussion of causality and causal biological mechanisms and pathways.”
That was a polite way of saying the standards are entirely fraudulent.
First, the PM epidemiology is not science — it’s just statistics.
And statistical associations by themselves are not science.
EPA has admitted in federal litigation with me that epidemiology alone is inadequate for determining causality.
This is no surprise.
It’s basic epidemiology.
Additionally, the data used in the PM epidemiology are garbage.
The exposure data are poorly guesstimated and often overwhelmed by other PM exposures, especially smoking.
It’s no wonder that EPA staff allow agency grantees to hide their data from public scrutiny.
And let’s not forget that EPA staff ignored all the PM epidemiology studies that report no association between PM and death.
Let’s look at PM toxicology.
There is no lab animal experiment that has produced deaths in animals – despite intense PM exposures.
There is no human clinical experiment that has produced health effects let alone deaths despite exposing elderly and sick people to intense PM levels.
None of this is surprising since there are no real-world examples where PM has killed anyone ever.
Studies show that smokers who quit by age 40 will have inhaled thousands of times more PM than nonsmokers yet have the same life expectancy.
PM levels in Chinese and Indian cities can be 100 times greater than US outdoor air – but there are no reports of actual deaths from inhaling Chinese or Indian air.
Historic incidents of deadly air pollution were caused by acidic gases concentrated in the air by weather phenomena.
They were not caused by PM.
Coal miners and diesel workers have large exposures to PM – but they have greater life expectancy than workers not occupationally exposed to PM.
And guess what, when PM levels are reduced, deaths don’t go down.
Yet, EPA staff ignores this real-world data, doubles down on the fraudulent and secret science and raves that PM is more dangerous than ever.
Harvard fraudsters have now even attempted to link COVID-19 deaths with PM2.5.
It’s a shameless con.
And the fraud is not just about deaths. PM in the air doesn’t cause or exacerbate asthma or have any health effects whatsoever.
All the foregoing is indisputable.
So how did all this fraud take hold in the first place?
Since 1996 the last time CASAC told EPA that there is no evidence PM kills EPA staff has funneled at least $600 million to university researchers willing to commit scientific fraud in order to invent and maintain the lie that PM kills.
After the 1996 CASAC review, EPA staff saw to it that future CASAC review boards were staffed and controlled by the same researchers funded to commit the PM science fraud.
The current CASAC board is the first one in more than 20 years not to be run by the fraudsters.
And I would be remiss if I omitted mention of the Health Effects Institute.
HEI is funded by EPA and car, truck and engine manufacturers.
The industry guys want more stringent PM standards so they can sell ever more pointlessly expensive vehicles and engines.
HEI is hardly an objective forum.
Others and myself have asked HEI to sponsor a debate on PM.
But HEI has repeatedly dodged these requests, apparently since the last thing it wants is to have the PM fraud exposed.
So where does all this leave us?
For now CASAC has advised EPA to call a halt to PM fraud. That’s great.
But the future will undoubtedly see more desperate PM science fraud come out of places like the Harvard TC Chan School of Public Health, which in case you didn’t know is funded by Communist China.
None of the PM fraudsters can reputationally afford to walk back their junk science.
Nor would their Chinese overlords want them to.
China is more than happy to fund research calling for insanely stringent PM rules to sabotage the American economy.
In short, the PM fraudsters gonna lie ‘til they die.
Finally, if you don’t believe what I’ve said, you just ask HEI’s Dan Greenbaum to sponsor a public forum where these issues are openly and honestly debated.
Just don’t hold your breath waiting for him to do it.
Thanks for listening.