The Misuse of Asthma as a Justifaction for EPA Rules

Guest post by David Middleton

EPA Administrator Scott Pruitt was one of the featured guests on Fox News Sunday yesterday.  Chris Wallace grilled him about President Trump’s decision to scrap Obama’s Clean Power Plan (CPP).  The interview mostly consisted of Wallace reading Obama Maladministration talking points about the CPP and demanding that Pruitt explain how they were going to “prevent those terrible things” without the CPP.

One of Chris Wallace’s mindbogglingly ignorant “gotcha” questions of struck a raw nerve:

WALLACE: A look at Nationals Park, where Washington’s finest have opening day tomorrow for the baseball season. But, there will be no presidential first pitch as the White House declined an invitation.

Mr. Trump, who once called global warming a hoax, signed a sweeping executive order this week calling for regulators to rewrite President Obama’s climate change policies.

Joining me now from Oklahoma is Scott Pruitt, Mr. Trump’s new administrator for the Environmental Protection Agency.

Mr. Pruitt, welcome to “Fox News Sunday.”

SCOTT PRUITT, EPA ADMINISTRATOR: Good morning, Chris. How are you?

WALLACE: Good.

When the Obama EPA announced its Clean Power Plan, it said that the reduction in carbon pollution would have the following health benefits. I want to put them up on the screen.

By 2030, it said there would be 90,000 fewer asthma attacks a year, 300,000 fewer missed work and school days, and 3,600 fewer premature deaths a year.

Without the Clean Power Plan, how are you going to prevent those terrible things?

PRUITT: Well, Chris, I think what’s important this past week is to recognize that the president is keeping his promise to the American people to rollback regulatory overreaches that have been occurring the last couple of years. And as you know, the Clean Power Plan is subject to a U.S. Supreme Court state. The steps have been taken by the EPA historically, they’ve equally been challenged several times with respective CO2 regulation. And each of those times the Supreme Court and courts have said that the power that has been used has been an overreach.

And so, the president is keeping his promise to deal with that overreach, Chris. It doesn’t mean that clean air and clean water is not going to be the focus in the future. We’re just going to do it right within the consistency of the framework that Congress has passed. Now, I think that’s very important to recognize.

WALLACE: But, sir, you’re giving me a regulatory answer, a political answer. You’re not giving me a health answer. I talked about 90,000 fewer asthma attacks, 300,000 fewer missed days in school and work.

The Obama Clean Power Plan called — said that carbon pollution from the power sector would be reduced by 30 percent. It would be one-third lower than it was in 2005.

Here’s what the American Lung Association says, “Half of all Americans now live in counties with unhealthy air.” You talk about all the regulatory overreach, but the question is, there are 166 million people living in unclean air and you are going to remove some of the pollution restrictions, which will make the air even worse.

PRUITT: Well, Chris, a couple things, we are actually pre-1994 levels with respect to our CO2 footprint. So, this country is doing far better than most across the globe. As you know, also since 1980, we’ve got a 65 percent reduction in those key air pollutants, SOx and NOx and particulate matter and ozone, while at the same time growing our economy.

I think what’s happened the last several years is that we’ve adapted to and adopted this previous administration’s views that if your pro-jobs and pro-growth, you can’t be pro-environment. If you’re pro-environment, you can’t be pro-growth and pro-jobs. And that simply is not the way we’ve done business as a country.

WALLACE: But, sir —

[…]

Fox News

How is it that the EPA can continue to get away with claiming that its latest rule du jour will prevent any asthma attacks?  It’s impossible to prove that something won’t happen in the future.  Furthermore, there is no evidence that any of the rules imposed under the authority of the Clean Air Act (CAA) have even “bent the curve” as it pertains to asthma.

When the CAA was first passed by Congress, air pollution was a serious issue and air pollution was reduced by about 40% by 1990.

pollutionreduction_0
Figure 1. Air pollution abatement is following a diminishing returns function.  The more regulations and greater the cost of compliance, the less return in emissions averted.  Source EPA (https://www.epa.gov/clean-air-act-overview)

If air pollution was a major driving factor in asthma, why did this happen?

EPA_Asthma
Figure 2: Figure 2.  During the period of rapid emissions reduction (1970-1990) the asthma rate continued to climb.  CDC (https://www.cdc.gov/mmwr/preview/mmwrhtml/00052262.htm)

The Institute for Energy Research (IER) demolished the EPA’s asthma claims here: Five Charts That Blow Apart EPA’s Asthma Claims

All five of the EPA’s “criteria pollutants” have been drastically reduced since 1980, yet asthma continues to rise:

figure-3
Figure 3. Ozone vs Asthma.  A four of the other criteria pollutants exhibit a similar relationship to asthma prevalence,  (IER)

If the drastic reduction in real air pollution hasn’t reversed the trend in asthma, how can the regulation of a non-pollutant, CO2 have any effect on asthma?   Unless the goal is to lower atmospheric CO2 to about 150 ppm and wipe out ragweed and other allergen-producing plants, the EPA’s Clean Power Plan, like all previous rules, will have no demonstrable effect on asthma.  Anyone who clicked the “ragweed” link is probably asking the same question I did, “Why do the alarmists claim that CO2 and AGW will kill all the good plants and enable ragweed to thrive”?

On a personal note: I have suffered from asthma since I was 4 years old and was hospitalized for about a week in 1963.  Since my onset of asthmatic symptoms occurred prior to Al Gore’s invention of climate change in 1988, I am confident that my asthma was not related to Gorebal Warming.  While, I would love to see asthma eradicated, I wouldn’t agree to pay 1¢ more per kWh of electricity or gallon of gasoline to fund this Quixotic war on climate change… Because I know it won’t have any effect on either the prevalence of asthma or the weather and I know it will cost trillions of dollars.

Why does the EPA continue to justify new rules and regulations on the basis of unverifiable claims of x cases of y malady averted?  Probably because they can’t offset the compliance costs with tangible benefits, particularly when they are forced to apply a realistic discount rate.

At What Cost is the Air Clean Enough?

Dr. Roy Spencer has a great example of the relationship between a clean environment and the cost of pollution reduction in his book, Climate Confusion: How Global Warming Hysteria Leads to Bad Science, Pandering Politicians and Misguided Policies That Hurt the Poor:

spencer_eci_zps16948f96
Figure 4.  “It’s Economics, Stupid.”

The CAA is a textbook example of a law which served its intended purpose… Unfortunately, it lacked any sort of sunset provision. Most pollutants are already at or near irreducible levels and almost all are well below the national standard; yet the EPA continues to ratchet down the standards, exponentially increasing compliance costs.

NO2
Figure 5: NO2

 

SO2
Figure 6: SO2

 

PM_25
Figure 7: PM2.5 (fine particulate matter)

 

PM_10
Figure 8. PM10 (coarse particulate matter).
CO
Figure 9. Carbon monoxide.

The U.S. EPA says, “the annual standard for PM2.5 is met whenever the 3 year average of the annual mean PM2.5 concentrations for designated monitoring sites in an area is less than or equal to 15.0 µg/m3.” The particulate matter pollution problem is not in the United States…

483910main1_global-pm2-5-map-670
Figure 10. PM 2.5 (NASA).

Ozone (O3) pollution has also been declining for 30 years:

O3
Figure 11. Ozone.

Note that the National Standard for surface level ozone (O3) is ~0.07 parts per million. Ozone isn’t a problem until it gets above 0.2 ppm…

0.200 ppm

Prolonged exposure of humans under occupational and experimental conditions produced no apparent ill effects. The threshold level at which nasal and throat irritation will result appears to be about 0.300 ppm.

0.300 ppm

The ozone level at which some sensitive species of plant life began to show signs of ozone effects.

0.500 ppm

The ozone level at which Los Angeles, California, declares its Smog Alert No. 1. Can cause nausea in some individuals. Extended exposure could cause lung edema (an abnormal accumulation of serous fluid in connective tissue or serous cavity). Enhances the susceptibility to respiratory infections.

http://www.understandingozone.com/limits.asp

Lead (Pb) is generally considered to be one of the most toxic pollutants. Lead pollution dates back at least to Roman times. It appears that lead pollution peaked in the mid-20th century and have been dropping like a lead weight since the 1960’s, totally ignoring the population “explosion” and the EPA (which did not commence its mischief until 1970). Lead levels are currently about where they were before the industrial revolution.

Figure 12: Atmospheric Pb 1770-2010

 

Figure 13. Atmospheric Pb and environmental regulatory “milestones.”

 

Figure 14.  At what cost is the air clean enough?  Annual compliance costs are in millions of 2006 US dollars.  These compliance costs are according to the EPA.  The odds are that the actual compliance costs are much higher and the benefits are almost totally unverifiable.

Pollution abatement follows a production (AKA diminishing returns) function. Each dollar spent removes less pollution than the previous dollar.  At what cost will the air be clean enough?

 

As usual, any and all sarcasm was probably intentional.

References

McConnell, J.R. and R. Edwards. 2008. Coal burning leaves toxic heavy metal legacy in the Arctic.  Proceedings of the National Academy of Sciences, doi:10.1073/pnas.0803564105 (published online in PNAS Early Edition, August 18, 2008).

The Benefits and Costs of the Clean Air Act from 1990 to 2020.  Final Report – Rev. A.

U.S. Environmental Protection Agency Office of Air and Radiation April 2011.

Featured image source.

 

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powers2be
April 3, 2017 4:02 pm

What is it about this alarmist mumbo jumbo that turns otherwise intelligent and inquisitive newspeople like Chris Wallace into a quivering bowl of “OMG we are all going to die” lemmings. He has to be in on the hoax.

myNym
Reply to  powers2be
April 6, 2017 3:17 am

The press is built on OMG. Boring doesn’t sell.

Robert Kral
April 3, 2017 4:50 pm

An exhaled breath is roughly 4% CO2, in other words normal physiological concentration of CO2 in the fine structures of the lung is 40,000 ppm (half the time, anyway). The notion that an increase in atmospheric CO2 from 350 to 400 ppm could trigger asthma is patently ridiculous. Asthma has all kinds of triggers, mostly biologic in origin. Diesel exhaust particulates in a certain size range have been reported to be problematic in terms of triggering asthma attacks. Yet the regulations in question were justified on the basis of reducing CO2 emissions, as though the health benefits would flow from that. If you want to target particulates, then make the case on that basis. The projected health benefits from the regs are based on nothing more than hand-waving, and Pruitt should have said so.

Roger Knights
Reply to  Robert Kral
April 3, 2017 8:30 pm

the regulations in question were justified on the basis of reducing CO2 emissions, as though the health benefits would flow from that.

IIRC, the EPA’s claim of health benefits from the CPP was not based on its reducing CO2 emissions, but on reducing the unhealthy by-products of coal combustion. (And liquid fuel combustion, to a minor extent.)

Reply to  Robert Kral
April 4, 2017 1:43 pm

Remember that the incoming blood is going to be at a lower pH and contain more than 4% carbon dioxide, Most of it is carboxyhemoglobin, which the lower pH facilitates exchange at the alveolus. The now outgoing oxygenated blood has far less carbon dioxide in it (dissolved and protein bound) and far more oxygen, where the higher pH facilitates the exchange and has far more oxygen in it (dissolved and protein bound, primarily oxyhemoglobin).

JohnWho
April 3, 2017 5:21 pm

If it hasn’t, this thread should be sent to Wallace.

“The real issue is how much we contribute to it and measuring that with precision.”

Exactly. If that precision shows that our contribution is negligible and our CO2 emissions are an insignificant amount of that, what’s the problem?

April 3, 2017 5:30 pm

Typo in the headline, I think you mean “Justification.”

However, I first read it as “Justifiction” – which makes perfect sense.

April 3, 2017 5:57 pm

American Lung Association Never Mentions CO2 as Harmful to Human Health
https://co2islife.wordpress.com/2017/04/02/american-lung-association-never-mentions-co2-as-harmful/

Chuck Dolci
April 3, 2017 6:10 pm

Pruitt’s mistake was in not asking Wallace ‘Have you actually read these reports and surveys you are referring to or are you just regurgitating talking points that were handed to you? Did you check their sources and references? How do you know they are valid? Ohhh, so you haven’t read them yourself and you have not checked their references. Well, in that case I will have to look at those studies and reports, analyze them and then get back to you and your viewers, with an intelligent, reasoned response.” I would then issue a demand to any news outlet that wants to interview me. “If you are going to play ‘Gotcha’ by asking me about some report or study, etc. you must advise me or my staff in advance, and give us a copy of the report or study so that I can research the matter and give an informed opinion.” And let the public know that those are the conditions.

Pamela Gray
April 3, 2017 6:22 pm

Actually, asthma attacks are improved by breathing in moist humid air with a greater concentration of CO2 than in surrounding ambient air. Oxygen rich dry air can bring on an asthma attack at worst, and make it more difficult to recover from an attack at best. CO2 helps asthma, not worsens it.

April 3, 2017 6:29 pm

David Middleton, your EPA link and quote are out of date: “the annual standard for PM2.5 is met whenever the 3 year average of the annual mean PM2.5 concentrations for designated monitoring sites in an area is less than or equal to 15.0 µg/m3.” The PM2.5 annual standard was lowered to 12.0 µg/m3 several years ago.

In 2015 I retired from a long career in air pollution analysis, forecasting, air monitoring data validation, and air monitoring quality assurance and I agree completely with your assessment. We are well past the point of diminishing returns and have reached the point of greatly diminishing returns when it comes to air pollution control. From what I recall reading, serious asthma is more correlated with respiratory illness in winter than anything else.

Retired Kit P
Reply to  oz4caster
April 4, 2017 8:44 am

@oz4

I love contributions from experts. While I have training in ‘air pollution analysis’ I do not have much experience being in nuclear power.

“… have reached the point of greatly diminishing returns …”

I would say we have reached the point of no returns. During the Bush Admin standards were lowered to the level where dose response curves were flat. This was not costly because most (all?) of the US was in attainment or on the way because of advancement in pollution control technology.

POTUS Obsma lowered them some more, not based on science, but to show he was tough on the environment. For places not in attainment, very expensive.

One of the things I noticed about the debate many years ago about the health affects of coal power, is that coal plants were blamed even in places like California.

Can an ‘air pollution analysis’ explain what physical property causes pollutants to migrate from areas of ‘good air quality’ like around coal plants to places with ‘good air quality’ but lots of cars and increase pollution?

It is simple. Chris Wallace has a car. If I wanted to improve his air quality, I would take away his car. This solution also works for AGW.

I would also like to take away electricity from those who want to close coal and also nuke plants. This would be a futile since many are not smart enough to know where energy comes from other than pixie dust.

Reply to  Retired Kit P
April 4, 2017 1:33 pm

Retired Kit P, long-range air pollution transport is dominant for ozone and PM2.5 in the US. For a given metropolitan area, incoming background levels often account for as much as 80-90 percent of the peak design values for ozone. Likewise, for PM2.5 on an annual average basis, incoming background levels typically account for about 80-95 percent of the annual average. That doesn’t leave much room for lowering concentrations by adding local control measures.

Reply to  Retired Kit P
April 4, 2017 1:48 pm

Yes, though many do not realize that green plants, particularly when stressed, release significant amounts of VOCs, enough to make ground level ozone detectable by my nose. We are so far into the land of diminishing returns, with respect to ‘pollution’, that the natural background pollution will overwhelm our control technologies in most urban areas. Places like LA and the Great Smoky Mountains will remain pretty much as hazy as ever. We could revert all of these rules back to 1990/92 levels and not be able to detect it, again, for most of the USA.

Johann Wundersamer
April 3, 2017 6:53 pm

It’s already forgotten that Obama gave the political advice to EPA to watch ‘most possible damage’.

So the EPA’s regulations were drawn out of thin air without any base at all.

myNym
Reply to  David Middleton
April 6, 2017 3:57 am

Sorry. Lost you at “Obama thought”.

The youtube clip [https://www.youtube.com/watch?v=cxxxGUeZtno] is funny however. Shows his “thinking” process when the teleprompter fails.

Johann Wundersamer
April 3, 2017 6:58 pm
Roger Knights
April 3, 2017 8:35 pm

I suspect that Pruitt had been instructed not to dispute matters relating to the Social Cost of Carbon, for some politics reason—presumably because Trump hasn’t decided whether to confront warmism head-on or not, or not yet. He may feel he’s taking enough flack already.

littlepeaks
April 3, 2017 9:20 pm

My wife suffers from asthma. I think one of the main factors driving her asthma, is that she is allergic to just about everything, except CO2. She is finally getting effective treatments — she has already gone through two series of allergen injections providing temporary relief, but with her allergies coming back worse than ever. She is receiving Xolair shots — effective, but very expensive.

Pamela Gray
Reply to  littlepeaks
April 4, 2017 6:03 am

Try therapies geared towards CO2 enhanced breathing treatments. It works. My family suffers from reactive airway disease that brings on asthma including unceasing coughing. I have gained relief just breathing in and out with a plastic bag. My own exhaled breath is moist and has CO2 in it.

JP
Reply to  Pamela Gray
April 4, 2017 8:08 am

My wife and two of my children suffer from asthma. It’s too bad the US and UN banned the old inhalers (CFC based inhalers). The old CFC inhalers forced the medicine right into the lungs and the improvements were immediate. The new inhalers are much more expensive and do not do the job during an actual attack. We’ve had to use nebulizers or go to the emergency room to treat something, that 15 years ago, was easily treatable.

Reply to  Pamela Gray
April 4, 2017 1:54 pm

Indeed. I saw this with my mother, who after years of ‘mini-strokes’ got to the point where aspiration would trigger bronchitis. The inhaler she was given wouldn’t work well most of the time. In the office/hospital, where the meds were given via pre-moistened pressurized oxygen blown through the liquid containing the bronchial dilators worked virtually all of the time.

April 3, 2017 10:26 pm

Hunter nailed it: ‘The clear and correct answer is “CO2 has nothing to do with asthma, Chris.” ‘.

However the paper above is flawed. Firstly it attempts to show a negative correlation with asthma PREVALENCE rather than the number of ATTACKS. Secondly it falls into the trap of confusing CORRELATION with CAUSATION.

Phoenix44
April 4, 2017 4:08 am

Judging from two recent papers in Europe, asthma isn’t increasing – the misdiagnosis is though.

http://www.telegraph.co.uk/science/2016/03/15/half-a-million-children-with-asthma-may-not-actually-have-condit/

https://www.theguardian.com/society/2015/jan/28/1m-people-uk-wrongly-diagnosed-asthma

Both papers looked at children and adults who had been diagnosed and tested for the clinical symptoms rather than the classic wheezing. between 30 and 50% did not have actual asthma. GPs had simply heard wheezing and said “asthma”.

So now we have fictitious increases leading to unnecessary regulation whilst spending huge sums to alleviate the symptoms of diseases people don’t have.

Marvelous.

April 4, 2017 5:12 am

The “Harvard Six Cities” research was and is the basis for EPA’s “findings” about PMA 2.5. Asthma is related to ALLERGENS, not particulates.

“So it was a shock to Nolen —today the Lung Association’s assistant vice president of national policy and advocacy—when Harvard School of Public Health researchers highlighted still deadly air pollution in the small city of Harriman, Tennessee that was taking years from people’s lives.
   “It was not one of those places you’d think of as having a pollution problem,” Nolen said. Nolen, who joined the Lung Association the year after the study was published and who authors its annual State of the Air report, has followed the far-reaching effects of the Harvard Six Cities Study, including a new suite of U.S. air pollution regulations that has seen the nation’s air grow cleaner, political controversy over those regulations that continues today, and a new generation of studies investigating avenues opened by Six Cities’ findings.
   “It’s a landmark, no question about it,” Nolen said of the Harvard study. “[It has] just absolutely been fundamental to the work we’ve been doing over the last 20 years to reduce particle pollution across the country…Because of this work showing an association, it was easier to convince people that this wasn’t just an arbitrary health effect, it was lives lost.”
   The Six Cities Study documented the health effects of air pollution over nearly two decades in Harriman; St. Louis, Missouri; Watertown, Massachusetts; Steubenville, Ohio; Portage, Wisconsin; and Topeka, Kansas. It broke new ground by highlighting for the first time the danger from the smallest particles, no bigger than 2.5 microns in diameter—one fourth the size in the air pollution standards at the time. It linked pollution from those particles not only to ill health, as other studies had before, but directly to deaths, which were 26 percent higher in the most polluted city—Steubenville—than in the least.”

I have been to Steubenville, lived through it, saw nothing untoward…

MarkW
Reply to  Michael Moon
April 4, 2017 7:01 am

According to the “science”, these people should be dropping like flies. Yet they aren’t.
Obviously they are science deniers.

Retired Kit P
Reply to  Michael Moon
April 4, 2017 8:53 am

Another case of flawed modelling and bad theories.

By those who make a living out of fear mongering not fixing things.

Paul Penrose
April 4, 2017 6:25 am

If CO2 causes asthma, are asthmatics causing their own illness every time they breath out? When you put it that way, doesn’t it sound preposterous?

What Pruitt should have said was, “Chris, the CPP is about reducing CO2, but there is no evidence that CO2 causes asthma or makes it worse. There is simply no valid scientific basis for their 90,000 number. We would be much better off finding the real causes to asthma rather than chasing non-existent problems.”

Steve T
Reply to  Paul Penrose
April 5, 2017 6:15 am

Paul Penrose
April 4, 2017 at 6:25 am

If CO2 causes asthma, are asthmatics causing their own illness every time they breath out? When you put it that way, doesn’t it sound preposterous?

As with many things, something preposterous may contain an element of truth. It is the way one breathes out that matters. If you lose too much CO2 (deep breathing and through the mouth) one can “blow off” a lot of CO2 which is a loss to the blood chemistry, this can lead to asthmatic problems.

SteveT

DHR
April 4, 2017 6:53 am

So why was Pruitt so ill prepared? The answers to Wallace’s question is clearly there but he was, like Pruitt, too lazy to find them. But then, he is a reporter so we expect ignorance from him.

So many times in the climate business, answers to questions are in the data, but the data are seldom used. Can’t these networks and government administrators find some Middleton’s out there to advise them?

DHR
Reply to  David Middleton
April 4, 2017 9:11 am

Who was it saying a lie travels around the world before the truth gets its socks on? It seems sound bytes sell soap and since our reporters are no longer interested in truth, but soap selling, we are in trouble.

dmacleo
April 4, 2017 7:24 am

haven’ t looked but wonder if the increase coincides with the push to over insulate buildings.

Steve T
Reply to  dmacleo
April 5, 2017 6:24 am

dmacleo
April 4, 2017 at 7:24 am

haven’ t looked but wonder if the increase coincides with the push to over insulate buildings.

It is far more complicated than that, for instance per capita where are the highest asthma levels?

Certainly among the highest are New Zealand and Australia – go figure.

SteveT

JP
April 4, 2017 8:03 am

So, a minuscule increase of a trace gas causes changes in asthma symptoms? CO2, is there anything it cannot do?

Retired Kit P
April 4, 2017 10:28 am

Are asthma rates increasing?

A few years before retiring I was diagnosed with asthma and given an inhaler by my doctor. I have never needed it.

This was based on an interview. When I was young I lived in a cold climate and ran to get from place to place. Sometimes after running hard when it was 30 below, my chest would tighten and it would hurt a little to breath.

For many years as an adult, I had an annual physical and a breathing test as part of the job requirement to wear emergency breathing equipment under arduous conditions.

Now I am a statistic as a asthma victim.

Snarling Dolphin
April 4, 2017 3:37 pm

Ranks right up there with the misuse of fish-eating pregnant women and mercury-related IQ impacts to justify regulatory programs. And then they have the gall to wonder why we question their methods? Disgraceful.