The Biden EPA plans to return to the good old pre-Trump days of regulating based on fake benefit-cost analysis. You can file your written comments with EPA here. The deadline is June 14,2021. The Federal Register announcement is here. Please support JunkScience.com in our fight against the bad guys!
Good morning. My name is Steve Milloy. I publish JunkScience.com.
The Biden EPA wants to roll back the Trump EPA’s rules for improving benefit cost-analysis.
It’s a transparent attempt to return to the days of prior EPAs… when the agency fraudulently invented fake benefits to justify the very real costs of job killing overregulation.
I will limit my comments to the Biden EPA’s insistence on inventing fake benefits.
The Biden EPA objects to the existing requirement that claimed benefits be based upon scientific evidence indicating a causal relationship between pollutant exposure and effect.
So let’s consider the case of airborne fine particulate matter called PM2.5, which will refer to as PM.
The Obama EPA justified its most significant rules on the basis that PM in outdoor air kills hundreds of thousands of Americans every year.
Here’s how this scam worked.
The Obama EPA would claim that a rule… like the Cross State Air Pollution Rule or the Mercury Air Toxics Standards or the Clean Power Plan… would save tens of thousands of lives per year by reducing emissions of PM from coal plants.
EPA then valued each imaginary life saved at $9 million.
By multiplying tens of thousands of imaginary lives saved by $9 million dollars per life, EPA would literally invent fake benefits purportedly worth tens of billions of dollars and more.
In the case of the Mercury Air Toxics Standard, for example, EPA claimed reducing coal plant PM emissions would produce as much as $380 billion annually in economic benefits.
It was as if EPA was some sort of golden goose laying regulatory golden eggs.
The problem, however, is that there is no scientific evidence that PM causes any deaths.
Neither the epidemiology, nor the animal toxicology, nor EPA’s own human experiments show that PM kills.
There is no real-life air pollution episode that shows PM kills.
But there are myriad real-life exposures to PM – especially the smoking data — that show PM does not kill at any real-world exposure level.
The smoking data is so persuasive on this point that EPA-funded researcher Arden Pope was tasked to explain how breathing blue sky outdoor air was deadlier than smoking.
That there is no scientific evidence showing that PM kills has now been recognized twice by the EPA’s own Clean Air Scientific Advisory Committee.
So naturally, the Biden EPA wants to get rid of the requirement that PM be scientifically shown to cause death. Because it cannot be done.
Now I realize that EPA’s mind is made up and this public comment exercise is just check-the box, pro forma government regulatory theater.
But I would warn the EPA that the Supreme Court did roll back the egregious Mercury Air Transport Standard with this warning from Justice Scalia:
It is not rational, never mind ‘appropriate’ to impose billions of dollars in economic costs in return for a few dollars in health or environmental benefits.
Future litigation over the Biden EPA’s PM rules will reveal to courts the massive and demonstrable PM science fraud that
EPA has committed and encouraged.
And those revelations will doom the coming Biden PM regulations.
See you in court, EPA.