New Climate Regulations Will Save Lots of Imaginary People

Now I can finally relax, take a deep breath, and breathe easier.  The Environmental Protection Agency, an aggressive arm of the nanny government, has just issued new air quality standards that mandate that the new "safe" level of ozone in the air we breathe shall be lowered from the current 75 parts per billion to 70 ppb.  I feel better already, perhaps.

I also feel better for all the theoretical lives that will be saved, according to EPA sponsored studies such as this one.  However, my joy is tempered by the realization that  those are not real lives saved – rather, they are "estimated deaths saved," as in "We applied health impact assessment methodology to estimate numbers of deaths and other adverse health outcomes that would have been avoided during 2005, 2006, and 2007 if the current (or lower) NAAQS ozone standards had been met. Estimated reductions in ozone concentrations were interpolated according to geographic area and year, and concentration–response functions were obtained or derived from the epidemiological literature."

Thus, the fewer ozone deaths will be taking place in a computer-generated fantasy world, where epidemiological data-torturing takes place by bits and bytes, not in the hospital admission records for real-life patients.  The referenced paper concludes: "We estimated that annual numbers of avoided ozone-related premature deaths would have ranged from 1, 410 to 2, 480 at 75 ppb to 2, 450 to 4, 130 at 70 ppb, and 5, 210 to 7, 990 at 60 ppb. Acute respiratory symptoms would have been reduced by 3 million cases and school-loss days by 1 million cases annually if the current 75-ppb standard had been attained. Substantially greater health benefits would have resulted if the CASAC-recommended range of standards (70–60 ppb) had been met."

Such papers are used to justify the EPA's claims that "[s]tudies indicate that exposure to ozone at levels below 75 ppb -- the level of the current standard – can pose serious threats to public health, harm the respiratory system, cause or aggravate asthma and other lung diseases, and is linked to premature death from respiratory and cardiovascular causes."  Lowering of atmospheric ozone concentration is presented as a win for health and associated increased energy costs: "EPA estimates that the benefits of meeting the proposed standards will significantly outweigh the costs. If the standards are finalized, every dollar we invest to meet them will return up to three dollars in health benefits. These large health benefits will be gained from avoiding asthma attacks, heart attacks, missed school days and premature deaths, among other health effects valued at $6.4 to $13 billion annually in 2025 for a standard of 70 ppb, and $19 to $38 billion annually in 2025 for a standard of 65 ppb. Annual costs are estimated at $3.9 billion in 2025 for a standard of 70 ppb, and $15 billion for a standard at 65 ppb." 

As a physician, I am intrigued, if not put off, by the EPA concept of "premature deaths."  How am I to know that that unfortunate patient, who has just died, died prematurely?  If asked, he would undoubtedly claim that he had died before his time, no matter the actual cause.  All deaths are "premature" when viewed subjectively.  The answer lies within the all-knowing, EPA-sponsored computers, as in "health assessment methodology" that claim the ability to define who died before their time.

When independent epidemiological researchers examine real-world patients, real-world hospital admissions, and real-world medical records, the EPA health claims are not validated.  In smoggy central California, such a study reported:  "Average ground-level ozone (O3) and fine particulate matter (PM2.5) measurements were not correlated with 19,327 patient admissions for asthma at the University of California-Davis Medical Center (UCDMC) during 2010-2012."  Another study concluded: "Overwhelming epidemiologic evidence now indicates that there is no relationship in California between PM and total mortality [also known as 'premature deaths.']"  Yet another study: "[T]he empirical evidence is that current levels of air quality, ozone and PM2.5, are not causally related to acute deaths for California. An empirical and logical case can be made air quality is not causally related to acute deaths for the rest of the United States."

Surely smoggy air must be unhealthy.  It must be, because it looks so bad.  The poster child for such smoggy air is Shanghai, China, where newspaper pictures depict a yellow haze obscuring the visibility of buildings.  However, the average lifespan there is 82.5 years, bettering the reported lifespan in any major U.S. city.

Surely pristine nature would be the place to avoid smoggy air.  Millions visit the Great Smoky Mountains National Park, in spite of the off-putting name.  When it is nature, it is smoky; when man-made, it is smog.  Yet the basic chemical process is the same.  Native conifers emit organic compounds known as terpenes, which interact with sunlight to produce…smog.  Few park visitors are reported being victims of "premature death" secondary to breathing polluted air.

One final reason not to expect the EPA's claims of ozone reduction and resultant saving of premature deaths of asthma victims to materialize is that the root cause of asthma is not completely known.  It may be hereditary, and it may be secondary to environmental factors, or some combination thereof.  A variety of factors can trigger an asthma attack in a susceptible individual.  It maybe exercise, cold air, or indoor antigens.  The Wall Street Journal October 1, 2015 article "Asthma Linked to Missing Bacteria" reported an association with the type of intestinal bacterial flora.  A puzzling observation is that even as the EPA air quality standards have achieved a 63-percent reduction in major air pollutants between 1980 and 2014, asthma rates have continued to rise in the U.S.  Between 1980 and 2010, asthma incidence in the population is reported to have gone from 3.1 percent to 8.4 percent.

The EPA computers have spoken, and theoretical "premature deaths" will be averted.  In the real world, energy prices will likely increase and impact the least advantaged the hardest as they struggle to pay for the air-conditioning and heating by which modern technology protects us from the reality of nature's health impacts.

Charles G. Battig, M.S., M.D., Piedmont Chapter president, VA-Scientists and Engineers for Energy and Environment (VA-SEEE).  His website is

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