New Ozone Regulations Will Save Lots of Imaginary People

Shaghai-air-pollution
The skyline of Shanghai, China showing air pollution

Guest essay by Charles Battig

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 www.climateis.com.

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October 6, 2015 8:42 am

The real motivation has nothing to do with health. If you check the data, many major metro areas were on the verge of reaching the 75 ppb standard (not to mention the previous 85 ppb standard). When a metro area reaches attainment, the power that the EPA has over that area is severely diminished. And, of course, any diminution of EPA power is to be avoided at all costs.

October 6, 2015 9:51 am

Mortality, in epidemiological studies, is the rate of deaths in a population. Deaths / ( time * population ) If you have actuarial tables, you can figure out when people are likely to die. This isn’t voodoo, it’s basic biostatistics.
Smog is composed of more than ozone – hell, ozone itself is invisible. The haze over pine forests is based on organic vapors, but it is missing large amounts of nitrogen oxides, particularly nitrogen dioxide. NO2 is brown in color and highly irritating to the lungs. It’s one of the key elements to something being smog. Ozone and NOx react with the organic vapors, and that gives reactive irritating compounds.
Asthma is still a complicated disease that remains poorly understood. I’ve heard all kinds of theories, including in the comments here. Given the effects of ozone on tissue, I wouldn’t be surprised if it played a role, but the EPA is going off half-cocked.
The problem with Ozone is that the evidence for the current NAAQS standard is fairly weak compared to other chemicals such as carbon monoxide or even particulates. (I’ve personally had a problem with the PM standards since they don’t take into account the chemical makeup of the particles) Low level ozone exposure effects are still uncertain. (Ozone is very toxic as the concentration rises, but I’ll be damned if they pull another LNT hypothesis here)

johann wundersamer
October 6, 2015 5:49 pm

H.R. on October 5, 2015 at
5:58 am
If ozone pollution affects human lungs, wouldn’t it also affect all mammals’ lungs?
Then the EPA needs to explain to me why deer and raccoon populations are out of control in my neck of the woods and the black bear population is growing?
____
Hint:
‘Other Mammals’ don’t get hyperventilated by reading News Papers, watching BBC or reacting to EPA alarms.
Sounds a bell; All Other Mammals don’t need EPA, saying ‘Live goes on without You’.
Hans

October 6, 2015 7:49 pm

I posted on Science Magazine… http://news.sciencemag.org/environment/2015/10/new-u-s-ozone-standard-won-t-please-greens-or-industry?utm_campaign=email-news-weekly “A major argument for lowering the ozone bar is to reduce the risk of asthma especially in children. This has been the subject of many of the research studies EPA director Gina McCarthy references. Child asthma rates are up 131% since 1980; this is despite falling ozone levels across the country. The percentage of the U.S. population with asthma increased from 3.1 percent in 1980 to 8.4 percent in 2010 according to the U.S. Centers for Disease Control and Prevention (CDC), an enormous increase. Meanwhile, average ozone concentrations nationwide dropped by 33 percent from 1980 to 2014, with levels in every region dropping significantly. This raises questions that ratcheting down industrial and transportation sources of ozone may not be effective and we need to understand the causative linkages better. Since the pattern of changes in asthma incidence and ozone levels have moved counter to what one might expect, another question is how much of the increase in asthma in the population is attributable to ozone (or does the data say that reducing ozone will cause higher incidence of asthma). Facing these uncertainties, (the U.S.) should be focusing on addressing problems where the problems are worst, e.g., in California. And understanding the problem better.
So childhood asthma is up 131% while national ozone levels are down by 33% since 1980, one might be tempted to conclude that each 1% decrease in average ozone levels will increase childhood asthma rates by around 4%, and the EPA’s 5 percent drop will increase childhood asthma rates by 20%. Of course this is not true. But correlations of asthma incidence with attribution errors that are conceptually similar to using highball climate sensitivities in climate models. Something is missing.
In a PUBMED search on the keywords childhood AND asthma, hundreds of studies discuss lifestyle, diet and excessive use of antibiotics as being related to the rising incidence of childhood asthma. “A new paper issued last week in Science Translational Medicine (Thursday, Oct 1, 2015) , “Early infancy microbial and metabolic alterations affect risk of childhood asthma.” which already has been reviewed in various news media. The authors of the study found that loss of certain (good) gut microbes – especially early in life – has a demonstrated link to development of asthma in children …“good germs, the ones we get from mom, are just disappearing.” “Using DNA sequencing, four bacterial species were found (there could be more) whose low or undetectable levels predicted with “100-percent accuracy” whether the babies would suffer early signs of asthma, such as wheezing and skin allergies, by one year old. None of the infants with high levels of these bacteria in their stool at 3 months old developed such symptoms. The study emphasizes that in that first 100 days the structure of the gut microbiome seems to be very important in influencing the immune responses that protect us from asthma. This discovery is not just giving us a diagnostic tool but a lead into understanding the root causes of asthma in children.”
So we need to focus on this root cause linked to changing lifestyle, diet and greater use of antibiotics affecting mothers and how these immunities are passed to their unborn children. Two causative pathways are involved in the increase in the incidence of asthma, the passage of mother’s immunities and ozone levels, and we simply don’t understand the extent of tangible improvement that will result from implementing the 5 ppb drop in ozone limits.