'[EPA] regulations in the study are less likely to have economic benefits in excess of their costs.'

Photo: Martin Koser of Denmark
Photo: Martin Koser of Denmark

From Indiana University:

Researchers say anti-pollution rules have uncertain effects

BLOOMINGTON, Ind. — Air pollution regulations issued by the U.S. Environmental Protection Agency are estimated to save thousands of lives annually. A new study by researchers at Indiana University says these estimates are more uncertain than commonly believed.

Researchers Kerry Krutilla, David H. Good and John D. Graham of the IU School of Public and Environmental Affairs analyzed the costs and expected lifesavings of nine regulations issued between 2011 and 2013. The bulk of these regulations require national emissions standards for hazardous air pollutants. The analysis includes the Mercury and Air Toxic Standards and the Cross State Air Pollution Rule.

The researchers estimate that the lives saved from this group of regulations could plausibly range from none to more than 80,000 per year. The range reflects uncertainty about the health effects of fine particles, and the possibility that airborne exposures to fine particles do not increase mortality risks.

The higher bound for lives saved is comparable to estimates by the EPA, but the possibility that no lives are saved is not reflected in standard EPA analyses of these regulations. If exposures to fine particles do not increase the risk of premature deaths, then most of the regulations in the study are less likely to have economic benefits in excess of their costs.

The IU research is based on a re-evaluation of an EPA-sponsored “expert elicitation” study conducted in 2006. The study surveyed the opinion of experts about the health effects of fine particle exposures. The elicitation format allows experts to synthesize and adjust the empirical findings for limitations in the research area.

Since 2006, the U.S. Environmental Protection Agency has used other methods to assess expert opinion. However, Krutilla, Good and Graham recommend updating the 2006 elicitation study to reflect additional experience with the method and new scientific knowledge. The authors conclude that better information is needed on the economic effects of air regulations, given the wide range for the lives they are estimated to save and the potential impact of the regulations on the U.S. economy.

The study, “Uncertainty in the Cost Effectiveness of Nine Air Quality Regulations,” has been published in the Journal of Benefit-Cost Analysis (Spring 2015). Krutilla and Good are associate professors at the School of Public and Environmental Affairs at IU Bloomington; Graham is the school’s dean. A team of graduate students assisted the study.


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Bruce Cobb
May 26, 2015 10:40 am

Oh, I dunno. It makes people feel good.

John Bell
May 26, 2015 10:51 am

Anthony, mods, can we run this as a WUWT blog entry? I wrote this story. It concerns the EPA.
In March of 2004 I took a job as a hydraulic pump design engineer at a private company in Auburn Hills, Michigan. The company had a contract with the EPA (NVFEL) in Ann Arbor to design and build prototype hydraulic pumps to be used in hydraulic hybrid UPS delivery trucks. The project was the brain child of Charles Gray, who had been with the EPA since its inception, and who retired in 2012. I was happy to further my career and to be involved in this interesting project, to help design a drive train that uses hydraulic pumps and accumulators to capture braking energy and then reuse that energy to accelerate the vehicle again. I believed in the project for the first six months, and then I saw the light. Turns out it was just another wasteful government boondoggle.
What happened? Things were not making sense. Firstly, I thought the approach was barking up the wrong tree because it was a series drive, instead of parallel, also known as a launch assist, (http://en.wikipedia.org/wiki/Hydraulic_Launch_Assist) which propels the vehicle from a stop and as stored hydraulic pressure is exhausted the vehicle is then propelled by the normal transmission gears. The hydraulics are only in use during braking and starting from a stop. Conversely, a series hydraulic system (hydrostatic drive) is active any time the vehicle is moving.
So with a series drive the truck will be propelled by the engine-driven pumps as it cruises down the road at constant speed, not a good idea because gears are more efficient. Energy saved in the start/stop cycle will be used during constant speed driving, due to the inefficiencies of the pumps plus energy needed to flow the oil through the many hoses and fittings. At least the EPA drive uses highly efficient variable displacement bent axis pumps. Hydraulic systems are generally heavy, noisy, expensive, and not very efficient, but are highly controllable and can pack lots of power in a small space. Electric hybrids (Prius) have high energy density, while hydraulic hybrids have high power density.
It would make more sense to use a launch assist in addition to the existing drive train, but there was no room for that on the vehicle, in fact the stock transmission had to be removed to make room for this new drive. Hydraulic hybrids are best suited for big, heavy trucks in frequent start/stop service, like trash trucks (Parker RunWise system). Even with fuel at $4/gallon, payback time is ten years or more, and by then the pumps may be worn out. With fuel at under $5 per gallon there is simply no business case for hydraulic hybrids unless they are heavily subsidized, like wind turbines.
Other things bothered me, but I played along, it was a good job to have. None of the people at the EPA had ever worked in industry, they are all career bureaucrats. The few times I went to EPA for meetings, the parking lot was full of SUVs, nary a Prius to be seen. I am glad I only attended a few of the weekly meetings, I found Charles Gray annoying. Pompous and intoxicated by his position, he considered himself some kind of mechanical engineering genius, yet he only held a chemical engineering degree. He was always meddling in the minutiae of the pump, hoping to discover some breakthrough that others were too blind to see. Far from it, he went down many dead ends that I knew were a waste of time, but we were happy to take his money and give him whatever he wanted, to extend the program and give our suppliers more business.
Charles apparently had old connections in Washington DC and he was able to get funding for his pet project, to play with hydraulics until he retired. Government has a poor track record in developing new technology for industry, and I sensed that this would be another shining example. He also wanted to claim patents (at taxpayer expense) from which he would receive royalties. I looked up some of his patents, they are for things like solar hot dog warmers. We had about 10 people on the program, EPA had about 6 people on it, and our suppliers had several people working full time on it. Charles revised the specifications a few times, I worked on three generations of pumps in five years. Prototype pumps like these are very expensive, over $200,000 each, whereas production pumps are under $5,000.
We designers had a love/hate relationship with Gray and he was the butt of many jokes. We loved him for being the source of our jobs, but hated him for wasting tax money on silly ideas. I never asked my bosses what they thought of the program, I knew they were just playing the game too, they had good salaries. The whole program must have run north of $50 million total. It was a high pressure job and there was always a hurry up urgency about everything, as if hydraulic hybrids will save the world.
In March of 2009 the recession caught up with us and a quarter of the company was laid off, including me, and a year later the hydraulic hybrid program was ended. I was glad to be out of there, I knew that such a vehicle had no commercial value.
Let’s crunch a few numbers: the average UPS (or FedEx) package truck gets about 10 mpg and drives about 12,000 miles per year. UPS reports that the hydraulic hybrid system improves mileage 25% to about 12.5 mpg, which results in a savings of about 240 gallons per year. With gasoline at $3.00 per gallon that is a savings of $720 per year, or $7200 per 10 years. Let’s say that a hydraulic hybrid costs a mere $15,000 more than a regular UPS truck, so it would take over 20 years before the savings even begin!
To take a bad idea one step further, the EPA partnered with Chrysler in 2011 to build a hydraulic hybrid mini van, again with a series drive train. As I mentioned before, only large vehicles making lots of stops might benefit from a hydraulic hybrid drive, and the family car is way too small. I would love to drive that mini van, I can only imagine that it is louder, heavier, more expensive, and gets worse mileage that the stock vehicle. I love hydraulics but this is not a good application.
I do not understand how people can think that such a drive would be commercially viable; it seems attractive on the surface, until you examine the numbers. Payback times of 10 years do not make good business sense. Furthermore, such schemes should not be subsidized by government, they should be able to stand on their own merit. There are a few other companies developing or selling hydraulic hybrid drives in the US, one in Michigan and another in Colorado. I suspect that such companies are grant farms, or their products must be subsidized heavily to entice buyers. The company that inherited the EPA design, American Hydraulic Power, (http://americanhydraulicpower.com/) closed their Troy, Michigan office in 2012 and is up for sale, but I doubt that it will sell.
Don’t get me wrong, I am all for saving energy and protecting habitat and wildlife, I am a tree-hugging, nature-loving outdoorsman and camper, and efficiency appeals to me as an engineer. I understand what many climate alarmists feel; 7 billion people is a bit scary to contemplate. I also worry about the environment and the future. We all thought that gasoline prices would only go up and up, just as we thought that real estate would do the same, until the bubble burst.
Our tax dollars at work.

Reply to  John Bell
May 26, 2015 12:27 pm

Seven billion people is a bit scary to comtemplate, until you realize that you could pack seven billion people into a land area the size of the state of Connecticut, and every person would have a shade more than two square meters to occupy.
All of a sudden, it’s a bit scary to think of how big the Earth is.

Reply to  LeeHarvey
May 26, 2015 11:51 pm

But each needs about 2000 times that area for food.
Imagine 2000 Connecticuts of farm land.

Reply to  LeeHarvey
May 27, 2015 5:52 am

@scot –
I have to question that each person needs 4000 square meters of farm land to support them. Yeah, we might use that much, but the majority of that land is going to grazing,
A little cursory digging indicates that, even including permanent pasture land in the total area of what’s considered ‘agricultural land’, the world total is only about 48,000,000 square kilometers. If First Worlders were more inclined to get their protein from things like goats and sheep instead of cattle, I’m thinking that number could be cut in half. Until there’s real economic pressure to move that way, though, there’s no reason to pass up a steak when one wants it.

Reply to  LeeHarvey
May 27, 2015 6:27 am

2000 Connecticuts would be less than the area of the US. Beyond that, there are significant improvements yet to be made in farm productivity.

Reply to  LeeHarvey
May 27, 2015 7:00 am

@MarkW –
The total United States is about 684 Connecticuts and change. 2000 would be slightly more than all of North America.
Still, I agree wholeheartedly with your point that improvements in agricultural efficency have yet to be made.

Reply to  LeeHarvey
May 27, 2015 10:26 am

So 48 million km^2 farm land is 48 trillion m^2, or enough, even @ 4000m/capita, for 12 billion people. Considering that even the UN projects a maxing out of population at slightly over 9 billion, let’s not panic yet. Just keep pumping out plant-feeding CO2.

Reply to  John Bell
May 26, 2015 12:32 pm

john you could write that same story about wind and solar farming. Of course the details would be different but the point the same. In the case of both those it is even more crazy when you look at the energy consumed to produce them and in that situation you need everything to go just right for 25 years to recover even that!

Reply to  fossilsage
May 26, 2015 2:22 pm

You could also write the same story about ethanol from corn.
Takes more energy to produce 1 gallon of ethanol from corn than that 1 gallon produces.
Then figure in all the petrochemical fertilizer runoff that hits the streams,creeks,rivers,great lakes and oceans.
Then there’s the fact that corn is a food crop.
No one would make ethanol from corn,and no farmers would grow corn for ethanol production without government subsidies.
Wind and solar power are not commercially viable without government supports,neither is ethanol,neither is the hydraulic hybrid nonsense-as John said-it’s only a plus for big heavy trucks that make frequent stops,and even then,it’s not economical due to the length of time to recoup initial costs. I did go to school for mechanical engineering,and I don’t see how any hydraulic system like the one described could be manufactured and sold for a profit in the real world.

Reply to  fossilsage
May 26, 2015 3:54 pm

Fossilsage, John
You could also write the same story about biofuels as well as every energy the government touches. One example is the Navy is required by the administration to buy fuel at $ 26 per gallon while most agree it is a total misuse of defense funds since the military is significantly underfunded by many.
Here is an old, partial list of green energy failures wasting taxpayer dollars which include at least one for which I provided engineering consulting, and I doubted at the time that it would succeed:
The 19 asterisked companies have already filed for bankruptcy. The others are near bankruptcy or the project was dropped because it was a failure:
1.Evergreen Solar ($25 million)*
2.SpectraWatt ($500,000)*
3.Solyndra ($535 million)*
4.Beacon Power ($43 million)*
5.Nevada Geothermal ($98.5 million)
6.SunPower ($1.2 billion)
7.First Solar ($1.46 billion)
8.Babcock and Brown ($178 million)
9.EnerDel’s subsidiary Ener1 ($118.5 million)*
10.Amonix ($5.9 million)
11.Fisker Automotive ($529 million)
12.Abound Solar ($400 million)*
13.A123 Systems ($279 million)*
14.Willard and Kelsey Solar Group ($700,981)*
15.Johnson Controls ($299 million)
16.Brightsource ($1.6 billion)
17.ECOtality ($126.2 million)
18.Raser Technologies ($33 million)*
19.Energy Conversion Devices ($13.3 million)*
20.Mountain Plaza, Inc. ($2 million)*
21.Olsen’s Crop Service and Olsen’s Mills Acquisition Company ($10 million)*
22.Range Fuels ($80 million)*

Reply to  John Bell
May 26, 2015 1:13 pm

Numbers don’t matter to liberals. In fact, giving themselves permission to ignore facts, reality and numbers is the way a person becomes a liberal. Reality becomes so plastic and malleable that in truth, a liberal lies to himself all day long and that results in the sad truth that he lies to his family. his friends, indeed words are voiced far more for how their perception will drive the agenda of the moment than for what exactly they mean. This is how BHO can say something honestly in the morning and contradict himself honestly in the afternoon.
We no longer have the luxury of listening to liberals, let alone giving in to anything they demand. They are children when this dangerous world has far too few honest adults.

Reply to  buckwheaton
May 26, 2015 7:40 pm

Buck– Leftists (don’t call them liberals–they’re anti-liberty) have the right to free speech..
Censorship is what Leftists have done throughout history for the reasons you mentioned.
Free speech allows hate speech, erroneous speech, insane speech, lies (not slander), half-truths, etc….
Never fall into the trap of only allowing “TRUE” speech, because the State arbitrarily and ultimately gets to decide the legal definition of what the “Truth” is…

Reply to  John Bell
May 26, 2015 1:48 pm

Very interesting story, thanks for the informative posting.
It is true that the bureaucratic expense in government is a travesty, made worse by pompous asses who believe they are servants of humanity deserving of extravagant pensions and other benefits.
I would add though that I have seen close to the same level of waste in large corporations. The bureaucracies in large corporations can be mind numbing and very lucrative for consultants whom they never tire of hiring to ironically explain to career bureaucrats how to run their business. The failed financial companies from the meltdown of a few years ago failed not only due to avarice but from grossly incompetent and uninformed management.
Not that hiring consultants is all bad, they can provide very useful expertise. But I guess the lesson is that low knowledge management with highly paid but low knowledge workers can help you make some good money. It did for me.

Reply to  John Bell
May 26, 2015 2:29 pm

Seven billion people could comfortably tread water in Lake Superior, I think we all calculated right here on this same website, back in about 2007. I think the alarmists have never driven Highway 50 across the Western US. They elbow to elbow sit in Starbucks and peek at Google Earth once in a while.

Reply to  John Bell
May 26, 2015 9:14 pm

John, with the EPA involved, it was not intended to save money. The pump would be heavily subsidized by taxes because of the 20 percent supposed reduction in CO2 gases. EPA does not care one wit about saving money. If you are worried about the environment, then a highly prosperous country and people are the best solution. In addition, the birth rates in prosperous countries rapidly drops.

Reply to  John Bell
May 27, 2015 12:38 pm

I once calculated that the entire world population would fit, 4 to the standard suburban home, in Texas, and using intensive square foot garden methods could be fed from the area normally used for yards. Now it wold likely need Oklahoma too…
And that is without resorting to hydroponics with even higher food density…
All electricity easy via ocean derived uranium at lower prices than paid in California today. Or via roof solar at higher prices (but plenty of capacity).
Water from the Mississippy River is plenty.
The rest of the world being empty of people.
We do things the present way because we want to, not because we must.

May 26, 2015 10:55 am

Since everybody knows we all die, there is no such thing as lives saved.
I would think the measurement standard should be how a regulation increases the population’s life expectancy and somehow measure the overall quality of that longer life.

Reply to  mikerestin
May 26, 2015 11:37 am

mikeerestin: I totally agree with you. You cannot save a life and I get sick and tired of people claiming doctors or whomever saved a life. The best anyone can do is postpone a death.

Reply to  PeterK
May 26, 2015 11:49 am

That’s why I would ask, “How will this law affected overall human life expectancy.”
We have quantifiable evidence that clean drinking water, working sanitation systems, and chemicals like DDT can extend a region’s human life expectancy.
We should try to get maximum benefit for expenditures

Mike Maguire
Reply to  PeterK
May 26, 2015 2:16 pm

How many lives have been lost from breathing ambient levels of atmospheric CO2 since it increased from 280 ppm to 400 ppm? Zero
How many deaths have been premature from breathing ambient levels of atmospheric CO2 in the last 10,00 years? Zero
If atmospheric CO2 doubles to 800 ppm(which will never happen) how many lives will be shortened from breathing ambient levels of atmospheric CO2? Zero
How many animals, including humans will have repository issues from the increase in CO2? Zero
How many plants will benefit?
Just about all of them
Sun +H2O +CO2 + Minerals = O2 + Sugars(food)
But some humans think that they know what the perfect level of CO2 in the atmosphere should be……………and set that at the level our planet was at decades ago. In order to supposedly keep CO2 from increasing, the EPA has ruled that CO2=pollution which gives them the power to regulate it as a pollutant under the Clean Air Act.
The law of photosynthesis has been redefined by the EPA:
Sun + H2O +Pollution + Minerals = O2 + Sugars(food)

Reply to  mikerestin
May 26, 2015 12:24 pm

“Lives saved” is much more catchy than clearer skies and better smelling, less irritating air. The presumption is obviously that the latter leads to the former, but the proof of that is problematic. On the other hand, not dreading driving into the city from a rural home to shop because the air is so irritating you’ll regret it for a day or two after, leads to improved commerce in the city.

Reply to  Duster
May 26, 2015 9:19 pm

Duster, the regulations in effect in the 1990s were quite sufficient for air quality. On those days that the air quality may have been poor in some cities back then, the pollution levels exceeded the THEN current regulations. The new regulations drastically drive up the cost of energy and increase poverty and suffering for millions of Americans for what is arguably no detectable improvement in air quality what so ever. The new regulations are massive pain for zero gain imho.

Reply to  mikerestin
May 26, 2015 4:29 pm

That reminds me of a story:
Fred goes to the doctors for a check up and the doctor says you will live ten years longer if you give up smoking. Fred liked the sound of this and said to the doctor I will give up.
Fred thinks about this driving home. Can I have the ten years next month when I am thirty one and be thirty two in ten years time. No it will be when I am seventy five living in a nursing home, going senile. So he carried on smoking.
Quality of life is important.
I would rather have cheaper electric and a slightly warmer climate than dear electric and not have such good weather.
My land is off grid being wind and solar and my flat is mains electric. So both worlds. I am looking at getting bottled co2 for my aquarium.
Is co2 a bad thing?
Is mankind’s small continuation to the warming world a bad thing as life on the planet dose better then?
Should we build our lives around MODELS or TEMPERATURE trend. I drive my car as to present knowledge on the road (temperature trend) not worst case scenario (models) if I did I would not drive.
Just my own thoughts!

Reply to  mikerestin
May 31, 2015 1:29 pm

“Delayed Deaths” also add significantly to health care costs. Older people require more and more expensive health care.
This should be included, maybe as a “social cost,” on the cost side of the cost-benefit analysis.

May 26, 2015 11:00 am

No new dams
Let the fish come first
No new power plants
Let chaos rule
No input from “you people”
Lie based Climate Change.
Mix it up for 30 years you get California out of water and out of power and out of luck.

Reply to  fobdangerclose
May 26, 2015 1:44 pm

fob. old soul,
And the worry here is that with Historian Amber Rudd running – well, presiding over – Energy, and the husky-hugging Cameron I/C, we in the UK may be going down the same toilet.
Hmmmm. PDQ.
Auto – with more than a scintilla of concern about lights staying on in five years if we do get a nuanced global cooling.

May 26, 2015 11:06 am

Can’t help but love Bloomington Indiana!

May 26, 2015 11:08 am

@John Bell… you already blogged this at Bishop Hill http://www.bishop-hill.net/blog/2015/5/25/waste-pumps.html
That being said, great story.

May 26, 2015 11:17 am

U.S. companies pay roughly $2 TRILLION/yr in government rules, regulation and mandate compliance costs, with perhaps 75% of these costs serving absolutely no purpose whatsoever.
To put that amount of waste into perspective: the entire GDP of India (population: 1 billion) is around $2 trillion/yr, $2 trillion is equal to 40 million jobs @ $50K/yr… or equal to $20K/yr per U.S. household..
It’s a completely insane amount of money wasted every year…. Had this amount of money been kept in the private sector and invested wisely, we’d probably have LFTRs providing all our energy, a cure for cancer, some rich would be living to 1,000, and we’d have warp-drive engines by now…
Under a free-market economy, insurance companies would act as regulators imposing cost/benefit rationalized standards on their insured companies to minimize product liability risk exposure…
We’d probably have a few parts per billion more air pollution, but what the heck, we’d have frigging warp drive!!
Instead, we have an $18+ trillion national debt, $100 trillion in unfunded liabilities, The Patriot Act, and the DMV….
Oh, goody… What a bargain…

Reply to  SAMURAI
May 26, 2015 11:40 am

…perhaps 75% of these costs serving absolutely no purpose whatsoever.
What? No purpose? That’s just silly. That 75% goes towards salaries, benefits and overhead so that more rules, regulation and mandate compliance costs can be implemented, updated and made more stringent.

Reply to  PiperPaul
May 26, 2015 12:13 pm

PioerPaul– Oh, yeah… Sorry, I forgot about the magical mystery multiplier effect of wasted money; the more money wasted, the more money is created… Silly me… Sarc/off
I wish more people would read Bastiat’s Broken Window Fallacy and apply its lessons…

Reply to  PiperPaul
May 26, 2015 2:22 pm

“I wish more people would read Bastiat’s Broken Window Fallacy”
That issue and much more is well covered in “Economics in One Lesson: The Shortest and Surest Way to Understand Basic Economics” by the famous Henry Hazlitt.

Mark from the Midwest
May 26, 2015 11:22 am

It’s a start, along with Dr. Pielke, Dr. Curry, Dr. Watts and others, who are pushing back against the nonsense. In this case it’s significant that there’s a Dean of the School involved, and that it’s a legit Tier 1, (very high research), University.

May 26, 2015 11:25 am

Always known by toxicologists. There are tolerances to most substances. For example wood or plant smoke can kill in a variety of ways depending on the concentration. But it has no effect on mammals in mild doses. Yet using CDC and EPA methodology, they would take a 100% kill rate of an element of the smoke and merely reduce it as a percentage of the population so a portion of thst population would always die statistically.

Mark from the Midwest
Reply to  Pat Ch
May 26, 2015 12:00 pm

I prefer statistical death to the real thing

Crispin in Waterloo
Reply to  Pat Ch
May 26, 2015 3:00 pm

Pat Ch
The EPA idea of linear response at all doses is that if one million people smoke a cigarette each, one of them drops dead. The next day 999,999 people smoke a cigarette and one person drops dead. They do not have the older model where exposure to some level of particulate matter (which of course varies in position) has zero effect as far as anyone can tell – the ‘sub-clinical dose’ has replaced ‘no effect’. all doses cause disease, is the thinking.
Note that all particulate matter is lumped into one description: PM4.0 or ‘respirable’ meaning it gets deep into the lungs. Often PM2.5 is reported as in Beijing. It means ‘smaller than 2.5 microns’.
Two things: what the particles are made of matters, and, the dose-response matters. The latter is not linear. The EPA would these days have it otherwise: there is no concentration below which there is no risk, none. They have taken exposure to Plutonium and projected its effects onto all particles. Success in passing legislation depends on keeping the assenters ignorant of the salient facts. Elected representatives have a duty to become informed on these topics. Help educate them.

Alex Avery
May 26, 2015 11:46 am

Pat, you are talking about the linear, no-threshold toxicology model that has almost no basis in empirical evidence and even ignoring the well-supported theory of Hormesis. Look up the Chinese apartment building accidentally made with steel contaminated by Cobalt-60. By the time they found the contamination and radiation, residents had lived in the building 10-15 years and the Cobalt-60 had spent most of its radioactivity. So what were the cancer rates among long-term residents? Only 3% of the expected!!! (i.e. they got a 97% cancer incidence reduction)
Regulators will NEVER give up their coveted linear, no-threshold paradigm.
Alex Avery

Mark from the Midwest
Reply to  Alex Avery
May 26, 2015 12:10 pm

Back in the 80’s there was an advisory from the CDC on fetal alcohol syndrome that could occur from as little as “a single drink.” But the data came from the study of approximately 60 birth mothers who ranged from intermittent binge drinkers to chronic alcoholics. That’s when I starting becoming suspicious of anyone, outside the armed services, who gets their paycheck directly from taxpayer offerings.

Owen in GA
Reply to  Mark from the Midwest
May 27, 2015 5:41 am

Having served 24 years in the Air Force, I’d say your exception is too broad. There are plenty of pencil pushing bureaucrats running around in uniform that are every bit as bad as the rest of the federal government (though I will give you that the concentration of them is far lower.)

Reply to  Alex Avery
May 26, 2015 12:22 pm

“Regulators will NEVER give up their coveted linear, no-threshold paradigm.”
How true indeed. If they were forced to use a threshold model, such as used by the FDA and pharma., that would kick the foundations out from under every major regulatory initiative they have undertaken since the mid ’80’s. And they know it.

Reply to  Alex Avery
May 26, 2015 12:32 pm

I’ll save people the trouble of looking:

May 26, 2015 1:31 pm

Personally, I’d rather the EPA take a cautious approach with known toxins that have proven negative impacts on public health morbidity and mortality (Such toxins do not include CO2, at least not at PPM levels). In fact the original guidelines for particulates, one of the items mentioned in the study, are now known to have been too lax. It’s well established that hospitalizations and deaths correlate with increasing particulate levels. Furthermore, the original restrictions on PM10 levels did not account for the increased toxicity of smaller PM2.5 matter. Certainly the implementation of tighter PM2.5 standards in the late nineties and early 2000’s have lead to significant public health benefits.
As the study indicates, there is uncertainty in the epidemiological data. However, that doesn’t mean we should throw out the baby with the bathwater. Do the latest regulations go too far, imposing extra costs for very few or no improvements in life expectancy? Perhaps, but that really means we need to additional studies, not that we should drop such regulations all together.
Air quality in the U.S. is significantly better today than in the 1960’s and is much better than in China or other places without such stringent regulations.

Reply to  SemiChemE
May 26, 2015 2:28 pm

“Air quality in the U.S. is significantly better today than in the 1960’s”
OK, true enough. But the EPA did not even get started until the mid ’70’s. Let’s pick a date, say 1990. Now, point to one critical environmental polution problem which was causing real *and* demonstrable public health problems, and had not yet been addressed.
Go ahead, take your time, we’ll wait.
Nonetheless, it has been full-bore Regulation Nation from the EPA ever since. The result has been hugely costly and intrusive regulation with absolutely *no* measurable benefit. Now let’s face it, if you can not demonstrate a real, measurable benefit, you have no grounds for imposing the regulation. Remember, when you are throwing your weight around with the full police force and coercive power of the state, “models”, and “studies suggests” simply is not good enough.
“tighter PM2.5 standards in the late nineties and early 2000’s have lead to significant public health benefits”
Could we find anyone outside of the EPA to support that with anything like real measurement data?
From where I stand, it looks for all the world like PM2.5 and associated health effects were fabricated to support a new regulatory agenda which was in the works at the time.
In my opinion it is a huge mistake to accept any EPA claims of cost, benefit or justification at face value.
Sorry, SemiChemE, I just can not let some of that go unchallenged.

Reply to  TonyL
May 27, 2015 7:52 am

Sorry for the slow response, I had to work. Demonstrable public health problems? The Wasatch Front in Utah is a prime example. There’s a pretty nice summary here:
In particular:
* A group of Utah physicians said the unhealthy air is a crisis that kills as many as 2,000 people along the Wasatch Front each year, and shaves two years off of a person’s life.
Now admittedly, Utah’s problems are a combination of geography, weather, population growth and pollution, but the facts are plain. Ultimately, it’s up to the politicians and the people to decide on the right trade-off between industry/transportation costs and life-expectancy, but to say the trade-offs don’t exist is just plain foolish. Especially, if your child is one of the 65,000 asthma sufferers in the state likely to visit the hospital when the pollution gets bad.

Reply to  SemiChemE
May 26, 2015 2:30 pm

Two rejoinders. 1. The linear no threshold concept has near to no basis in observational reality. I do not know of a single valid example. LD50, oncogenesis, radiation exposure, … all say that model is wrong. The EPA uses it to justify their continued existance, rather than declaring the pollution war mostly won and going home.
2. Diminishing marginal returns guarantee that costs eventually exceed benefits. At which point, one should stop. EPA’s answer is to understate costs, overstate benefits, and keep on going. Recent examples include second hand smoke, PM2.5 (at US, not Chinese levels), and ‘cost of carbon’.
The Mass. v. EPA SCOTUS ruling on CO2 pollution revolved around the appellate court’s constitutional inability to challenge official fact findings unless the finding procedures themselves are statutorily flawed. The lesson is, NEVER give bureaucrats the procedural means to perpetuate their own existence. CCA did give that means to the EPA. See my CE guest post on clean coal, republished in Blowing Smoke. That is why Congress needs to amend CCA. Your vote in the next election will count toward this objective at multiple levels.

Reply to  ristvan
May 26, 2015 2:49 pm

All true, ristvan.
I would just like to amplify one point. The Mass. v. EPA SCOTUS suit was what is known on the inside as a “guided lawsuit”. The EPA worked extensively with the Mass State Attorney General’s office so as to file just exactly the suit the EPA needed to win the case in just exactly the way they needed. The state government in general and the AG’s office in particular were very sympathetic to what the EPA was attempting to do, and so became a willing partner in the suit. In effect, EPA got to control both sides of the suit.
The rest of us consider the process to have been rigged from the outset.

Reply to  ristvan
May 26, 2015 3:56 pm

The EPA worked extensively with the Mass State Attorney General’s office so as to file just exactly the suit the EPA needed to win the case in just exactly the way they needed.
No, the EPA wanted to lose the case. The EPA thought the CCA federal law did not give the EPA to regulate CO2. The EPA wanted Massachusetts to bring a case and the EPA would roll over and play dead — getting exactly what it wanted.

Reply to  SemiChemE
May 26, 2015 4:35 pm

All regulations have costs. Those costs result in people being poorer and in delays of new technology.
Being poorer and delaying new technology has costs, usually measured in lives lost.
Unless someone can actually demonstrate that a particular concentration of a chemical is causing harm there is no need to regulate the concentrations below that level.

Reply to  SemiChemE
May 26, 2015 9:28 pm

Semi… but I thought Obama and EPA was telling everyone that respiratory illness rates and asthma were increasing because of AGW?? Im confused, you claim there is extensive evidence that air quality regulations have made large reductions in respiratory illness and asthma but at the same time they are increasing? Sounds like Progressive logic to me.

Reply to  alcheson
May 27, 2015 9:08 am

Make no mistake, I am not defending Obama’s ridiculous crusade against CO2 emissions (or AGW), but that’s not what the main article was about. The article was about EPA regulations on particulates, mercury, and other pollutants that are known to be toxic and harmful to public health. These pollutants are the reason the EPA was formed and arguably should be it’s primary focus.
One need only look at China and in particular, Beijing, to see where we would be without the clean air act and EPA regulations. Air pollution kills and there are many strong studies confirming the links between particulates (even at fairly low levels), hospitalizations, and deaths. Public health in Beijing is a disaster because of the high levels of pollution, that is an undisputed fact. Estimates are that as many as 1.2 million premature deaths in China can be linked to Air Pollution (http://www.npr.org/sections/health-shots/2013/04/02/176017887/chinas-air-pollution-linked-to-millions-of-early-deaths)
The EPA has done a lot to improve air quality in the U.S., but is it good enough? In many places the answer is yes, but there are also many problem areas Of course you cannot completely eliminate particulates since a significant number come from natural sources (pollen, dust, etc…), but where is the right balance between regulation and cost? Those are exactly the questions the EPA should be studying and investigating. These are questions with direct implications for our economy and quality of life.
The EPA should stay focused on REAL air pollution hazards, rather than the boondoggle of AGW, where economically devastating regulations would be required to make any significant impact on world-wide CO2 emissions and the predicted impact of those reductions are dubious at best.

Gary Pearse
May 26, 2015 3:09 pm

Am I imagining it, or are their more and more studies coming out resisting government policies?. Retirement of the old compromised guard could be a self correcting aspect of the CAGW/environmental hysteria and subversion of science. Another effect could be that the younger set realizes that when Obama is gone, they could find themselves on the wrong side of the issues with the new government if they cling to the old guard.

May 26, 2015 3:49 pm

In the video attached to Dr. Roy Spencer’s Keynote Speech at #ICCC9 (WUWT July 14, 2014), there is a 20 min talk by Dr. Jay Lehr, a groundwater hydrologist who was in at the beginning of the EPA. He argues the effectiveness of the EPA was strong and good from 1968 to 1980, but since 1980 the EPA has produced nothing “that has had any value.”
I wrote up some time-stamped notes of his talk to the video I was going to put up just a sample of the notes, but the video link is currently unresponsive. So here are my full notes of his talk.

27:20 – Write the reasons humans are not responsible for Earth’s temperature on back of business card. Talk to 3 people a day while traveling.
Climate science is Junk science cherry picking.
32:40 – The primary force we battle is the US EPA. I Don’t think we can reduce the power of EPA, We have to Replace the US EPA. I have a plan.
34:40 – The plan in detail is 4 pages at Heartland.org [See: https://www.heartland.org/policy-documents/replacing-environmental-protection-agency – Dr. Jay Lehr, July 15, 2014]
35:15 – There is no one with a greater right to propose a plan to replace EPA in Washington than I. For I played the greatest role in America to establish it. 1968 I helped the Bureau of Water Hygiene into something stronger. No regrets for what I started, but I’ve been doing penance for 40 years.
36:30 – William Ruckelshaus first and biggest mistake: banning DDT. Responsible for deaths of over 100 million people.
37:10 – Safety net of regulations. Clean Water, Clean Air, Mining, … seven laws. “We did nothing in the 70s that was NOT effective.” “I would argue since 1980 there has not been a single” law, reg, “that has had any value.” Superfund was first of these disasters. Endangered Species Act, too.
38:30 – My Plan: Replace Washington EPA with Committee of the Whole of the 50 States — In Topeka, Kansas – the geographic center of the USA. “Government is best when it is local.”
39:50 – Phase out US EPA (Wash DC) over 5 years. 50 state agencies. Each State sends 3 delegates. They will elect a Chairman for 3 years, no more.
41:00 – “No one in this room could name for me the 14 offices of US EPA.” Phase out as follows:
“Over the next 5 years, you will all lose your jobs. Some of you will go back to your states.” The states will get $20 million/year/state. Budget for EPA is $8.2 billion. New plan: $1 Billion goes to states, $1 goes to Topeka HQ and research. $6.2 billion is saved.
42:30 – First two offices to go: Office of Indian Affairs. And Office of Indian Environment. Move them to Bureau of Indian Affairs, with 1/2 of budget.
43;10 – Year 2: Move offices of policy, admin, enforcement.
Year 3: Move Air and Radiation, Solid Waste
Year 4: Move Water, Chemical Contamination
Year 5: Move Chief Council, CFO, Env. Information Officer, Administrator.
A very smooth transitions to shut down Washington and Regional Offices. The States should be thrilled. They will have a say in everything and more money.
44:45 – Over these 5 years, the Committee of the Whole will review every regulation the states are forced to operate by US EPA. They will have the right to revise, eliminate, delegate to States, or advise Congress for changes. Global Warming is about to become the biggest thing EPA has ever done. The States will embrace the phase in. I think Congress will embrace it.
46;30 I am a recruiter. Ex-Navy. Take the plan. Talk to people. Journey of 1000 miles begins with a step. Take that step. Send it around.
Nobody LIKES EPA. They think we NEED it. The Plan does not eliminate environmental protection. We will lose nothing but 15,000 people and $6 billion in budget.

Reply to  Stephen Rasey
May 26, 2015 4:47 pm

Thanks for the document.

Alan Robertson
May 26, 2015 3:56 pm

What difference, at this point, does it make?

Reply to  Alan Robertson
May 26, 2015 4:37 pm

But it does, it makes a difference.

Alan Robertson
Reply to  Andres Valencia
May 27, 2015 3:25 am

Hello Andres,
My statement is actually a direct quote from Hillary Clinton, as she testified before a Congressional inquiry into the sordid Benghazi assassination. While it definitely was not her intent, the words highlight the entire lack of accountability, credibility and unfathomed control of the US government.
Do you really think that at this point, “it” makes a difference? Consider the recent edicts by the unelected bureaucrats in the EPA. Consider last weeks commencement address by POTUS to the US Coast Guard Academy graduating class…

May 26, 2015 4:35 pm

“The higher bound for lives saved is comparable to estimates by the EPA, but the possibility that no lives are saved is not reflected in standard EPA analyses of these regulations. If exposures to fine particles do not increase the risk of premature deaths, then most of the regulations in the study are less likely to have economic benefits in excess of their costs.”
As they are.
It seems like the EPA has nothing of value to do, declaring CO2 a pollutant was suicidal.

George Devries Klein, PhD, PG, FGSA
May 26, 2015 5:03 pm

During a three year period (1993-1996) I served as a marine consortium president and state sea grant director in New Jersey. The New Jersey equivalent agency was called “Department of Environment and Energy..”
When visiting a local business, I was told “DEPE’ stands for “Don;t Expect Progress Ever.” That’s the motto at the US-EPA too.

May 26, 2015 5:48 pm

The Administration has lost numerous cases in court including the EPA with overreach.
Here is a recent case that has halted a pre-emptive veto at an Alaska mine
“The Environmental Protection Agency’s plan to veto the Pebble Mine in Alaska’s Bristol Bay was put on hold by a federal judge on Monday, hailing a small victory for the mine’s supporters in their legal battle to keep the project going.
“The court victory, however, was only a “procedural victory” that “does not resolve our claims that EPA pursued a biased and predetermined” process against the Pebble Mine, Pebble Limited Partnership (PLP) CEO Tom Collier said in a statement.”
“The small legal victory, combined with a federal investigation, could present huge problems for the EPA, which is preventing Pebble from getting a key federal permit needed to operate. PLP can now obtain documents through discovery and depose individuals in their pursuit to show that the EPA’s veto of the Pebble Mine was biased.”
More details at the website

Reply to  Catcracking
May 26, 2015 6:36 pm

…. Until there is a US Attorney General that will convict and jail bureaucrats that willfully deprive people of life, liberty, and property, the people in the EPA will continue to do as they please. Until then, the worst that can happen is they get their way for a few years while simultaneously inflicting enormous expense on their targets. That’s a Win-Win situation from EPA’s point of view.
Congress can’t do a thing about it except make a very temporary, very much ignored, fuss.

Owen in GA
Reply to  Stephen Rasey
May 27, 2015 6:00 am

The current congress cannot do a thing. There needs to be enough people that understand the problem and don’t sympathize with big government in congress to avoid a filibuster, and either enough to overcome a veto, or a president who actually believes in freedom to sign the bill. None of those are in evidence at the moment. There are maybe 30% of the House and 20% of the Senate that would restructure the Clean Air and Clean Water acts to rein in the EPA. Of the rest, 50% of the House and 40% of the Senate are afraid to touch the problem for fear of the political backlash and because they really don’t see what the problem is. 20% of the House and 40% of the Senate see the EPA as one more way to assure the federal government’s supremacy over all aspects of human life and would only change it if the change would further enhance federal dominance over the individual.

Reply to  Stephen Rasey
May 28, 2015 4:38 pm

There’s a much better chance of a judge finally snapping and tossing some bureaucrats in jail for contempt of court. Seems like judges are finally tiring of them ignoring court orders and claiming innocent error when caught. One can hope, anyway.

Reply to  Stephen Rasey
May 30, 2015 3:02 pm

There’s a much better chance of a judge finally snapping and tossing some bureaucrats in jail for contempt of court.
That may be true, but since that chance has a probability = nil + epsilon, I am not optimistic.
I am convinced there is no remedy short of a Constitutional Amendment restructuring the US Department of Justice and removing the provision that the US Attorney General serves at the pleasure of the President. The conflict of interests are enormous as it is currently structured with the AG reporting to an increasingly powerful Executive.
What would I change? At the very least, reconfirmation of the AG by Congress on a yearly basis. When you think about it, even a year is a long time between meaningful performance reviews. A company’s Board of Directors can, if they are fed up enough, can haul an executive officer in front of them on a Saturday afternoon and fire them. Congress should have no less power. As it is, the barriers against removal of corrupt political appointees are too high.

May 26, 2015 6:26 pm

“EPA regulations in the study are less likely to have economic benefits in excess of their costs”
They’re not meant to. EPA is on a mission from enbalma to throw a monkey wrench into the economy and to help in his war against Capitalism.

old engineer
May 26, 2015 7:55 pm

How right you are Alex. I found out about their linear, no-threshold model back in the early ’80’s when I was working for an EPA contractor on mobile source air toxics. I haven’t believed an EPA cost-benefit analysis since. I don’t think they will give it up because they too have kids to put through college and need the job. With the linear, no threshold model there will always be lives saved.

May 26, 2015 8:00 pm

Have any of you subscribed to the Journal of Benefit-Cost Analysis, and if so, do you think it’s a good value?

May 28, 2015 5:56 pm

That’s because it is a big steaming pile of horse poo!

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