Steve Milloy
Contributor
The Trump Environmental Protection Agency just decided to no longer inflate the monetized benefits of EPA air quality regulations with imaginary deaths prevented. This has put the greens into orbit.
The New York Times headline blared “EPA to Stop Considering Lives Saved When Setting Rules on Air Pollution.” The article continues: “In a reversal, the agency plans to calculate only the cost to industry when setting pollution limits, and not the monetary value of saving human lives, documents show.”
EPA chief Lee Zeldin responded on X: “Yet another dishonest, fake news claim courtesy of the New York Times. Not only is the EXACT OPPOSITE of this headline the actual truth, but the Times is already VERY WELL AWARE that EPA will still be considering lives saved when setting pollution limits. The Times’ unyielding commitment to destroying journalism is second to none.” (RELATED: How One White House Council Is Fighting To End ‘Regulatory Reign Of Terror’)
What is going on?
The evaluation of a proposed rule’s costs and benefits has been a commonsense administrative requirement before setting new regulations since the Reagan administration. Until the Clinton administration, so-called cost-benefit analysis was an effective tool in stopping costly overregulation, particularly at the EPA. But the Clinton EPA figured out how to game the cost-benefit analysis process in order to issue its most expensive regulations – air quality rules that were eventually used by the Obama EPA to destroy half of the U.S. coal industry.
After failing in its first effort to implement an anti-fossil fuel agenda through a “BTU tax,” the Clinton EPA moved to issue more stringent air quality standards for ozone. The problem is that the monetized benefits of the tighter ozone standard (possibly fewer asthma attacks triggered by outdoor air) paled in comparison to the economy-wide compliance costs of the regulation (tens of billions of dollars).
The Clinton EPA’s solution was to pair the ozone proposal with another proposal to regulate, for the first time, a newly invented air pollutant called “fine particulate matter” or “PM2.5,” which is microscopic dust, soot or pollen in outdoor air. As described in great detail in my 2016 book “Scare Pollution,” the Clinton administration developed the false and junk science-based notion that normal levels of PM2.5 in outdoor air could cause people to die prematurely.
How did this help the ozone proposal? The EPA claimed that regulating PM2.5 would prevent 20,000 premature deaths per year. Each prevented death, the EPA claimed, provided economic benefits of $5 million. When you multiply 20,000 premature deaths prevented by $5 million dollars, you get $100 billion in economic benefits, which the EPA claimed would be much greater than any possible compliance costs. So the EPA’s proposed air quality rules passed the required cost-benefit test since the benefits outweighed the costs.
By the time of the Obama administration, the EPA was claiming that PM2.5 was responsible for 570,000 (i.e., about one in five) deaths per year in the U.S. and the value of preventing a premature death had risen to $9 million. Given that EPA determined there was no safe level of inhaling PM2.5, the cost-benefit analyses for its rules could beat back over $5 trillion in claimed compliance costs futilely spent trying to eliminate PM2.5 from the air.
The problem, though, is that the EPA’s claims were all chicanery. Both the alleged deaths caused by PM2.5 and the monetized value of a premature death were each invented out of thin air.
I have been in federal court with the EPA about its scientific claims on PM2.5, where it admitted that its primary line of evidence – i.e., epidemiology data – does not in fact show that PM2.5 outdoors has killed anyone. The EPA has also experimented on real people, including the sick and elderly, with high exposures to PM2.5. Those didn’t harm anyone either.
The monetization of premature deaths is truly bizarre. The $5 million value of a premature death avoided was derived through a type of economic research called “willingness to pay,” in which people are polled for how much they would pay for something of value. In the case of PM2.5, EPA nonsensically asked people how much they would be willing to pay to reduce their risk of premature death by 1-in-100,000.
Let’s say, for example, that your risk of dying prematurely is 50%. Per the results of the EPA’s survey, people would pay $50 to reduce that risk to 49.99999%. That sum multiplied by 100,000 is where the $5 million came from. EPA has arbitrarily raised the willingness-to-pay figure to $9 million per life saved.
Now let’s say you are a 99-year-old who, because of PM2.5, dies “prematurely” today instead of tomorrow, as EPA assumes otherwise would have happened. Because you died “prematurely,” according to the EPA, PM2.5 caused an economic loss of $5 million. Contrast that EPA fantasy with the realistic situation of a 21-year-old young soldier being killed on the battlefield. The U.S. government’s standard valuation of that soldier’s life, paid out in real dollars, is $100,000.
The Trump EPA has now merely decided that it will no longer consider the monetization of imaginary PM2.5 deaths in the cost-benefit analyses of EPA air regulations. This will ensure that air pollution regulations make sense and are not pointlessly burdensome – a welcome change after 30 years of EPA just making things up.
Steve Milloy is a biostatistician and a lawyer. He posts on X @JunkScience.
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Getting back to common sense with the Trump administration.
I can see why the Left is upset about this: Common sense is not part of the Left’s agenda.
Love Lee Zeldin’s reply to the New York Times!
The trump administration:
Trump shares altered map of U.S. flag covering Canada, Greenland and Venezuela
Trump is trying to assure the reelection of Carney in the almost inevitable 2026 Canadian election. After all having a total stodge in power here is to his advantage.
And you fell for it.
Try to stay on topic.
The EPA’s lives saved 2.5pm studies make the covid mask studies look like the gold standard for scientific studies.
How do the studies show a reduction in deaths greater than the actual number of deaths from 2.5pm? The vast majority of respiratory deaths are for causes unrelated to 2.5pm such as cigarette smoking and the flu.
I wonder how many out of the 20,000 early-diers willing to pay $5m are able to pay $5m. And how would any one of them know they were an early-dier before hand? What BS.
PM2.5 is classic POOMA statistics.
It was mostly the claim against PM2.5 that killed the woody biomass industry in most of New England, resulting in degraded forests having less chance of improvement. The argument I often heard here was against subsidies- which is fair. I say end all subsidies of any sort for any type of energy and see how that plays out. If the long term benefit of improved forests is counted, along with very real ecosystem benefits, woody biomass would do well in some regions.
Indeed, ending direct subsidies would reduce the market distortion. Normal tax exemption, profit/loss exclusions should remain for productive enterprises, of course.
I have advocated all energy be removed from the futures markets on the stock exchanges.
After ending subsidies can we also end taxes so as to provide energy to the end user at a normalised rate.
Woody biomass does just great in my fireplace!
The obesity epidemic will cause more premature deaths. The airborne things that will also cause premature death are called viruses and bacteria, not particles as defined under PM2.5 rules.
The abortion epidemic has already caused 70,000,000 premature deaths in this country alone, adding another million every year. At $5m per death the cost side of the equation is $350,000,000,000,000.00 (read three hundred fifty trillion dollars). There is no benefit side.
hmmm… right— good point… but… but… the libs must have fought ferociously to stop that, right? /s
When I was in college in the late ’60s, a friend called me and said, “my girlfriend is pregnant- can you help us find an abortionist?”. He presumed everyone in college here in Wokeachusetts must know an abortionist. I told him, “well, Mike- I’ll support your decision on what to do about it- but I won’t help in any way- it’s your karma”. Apparently they changed their mind or couldn’t find an abortionist.
When he passed some years ago, his daughter talked with me at the funeral. Little did she know that if I had helped Mike find an abortionist – she wouldn’t be alive. That got me thinking that I can only wonder what other secrets there are that we have no clue about.
5 million? Simple back of the envelopment math is 5 million divided by 45 years equals 111,111.11 per year of income. Now I’m an older gen X and for the majority of my working career I did not make 6 figures, matter of fact all 6 years of my military service combined did not hit 6 figures. I then spent quite a bit of time between 30k and 50k per year. While I now make 6 figures I’m not far enough up that chain to come anywhere near making up the deficit of 5 million earned over my working career.
Come to think of it when I was in my early 20’s we were told that if the average person made 1 million over their working careers they would be doing good.
I has a question that’s been bugging me for a long time. I have zero trust in government; but anarchy turns into gangs which turn into government, so here we are. So don’t get me wrong and think that I am backing the EPA here. This is a real question, and want to know what trickery is going on here, almost certainly from the EPA and Greens.
Whether or not the ozone was defined in hindsight at a level which coincidentally coincided with DuPont’s Freon patent expiring, the mere existence of the ozone hole seems rather curious. The Wikipedia article on the ozone hole tries to bat down two claims (https://en.wikipedia.org/wiki/Ozone_depletion#Misconceptions).
I know Wikipedia is only reliable for simple things, like atomic weights in the periodic table. They were never going to be trustworthy for something as political as the ozone hole.
Are there better discussions of the ozone hole? Debunkers can be just as blind and partisan, but would at least be some counter to Wikipedia. But I’d rather find some more neutral discussion.
Just to clarify, ground-level ozone (transient increases due to certain air pollutants during conducive near-surface atmospheric conditions) and stratospheric ozone (anomalously low ozone levels allegedly but not proven to be tied to fluorocarbon refrigerants in the upper atmosphere) are separate phenomena. The mention of ozone in the present context refers to the former.
And Wikipedia claims “the forces of wind can fully mix the gases in the atmosphere.” Thus my ask for any neutral and useful discussion of the whole question, not just one tiny corner.
390 W/m^2 IR upwelling, theoretical 15 C BB
324 W/m^2 IR downwelling “back” from low to high w/o work
66 W/m^2 IR “net” duplication
is another example of thin air fraud.
“Back radiation” is something you clearly don’t understand, and as you are a BSME, I can only say you must have missed some relevant classes, where the assignment was calculating the temperature of electronic components in a chassis, or parts in an engine, or supports in a boiler.
Let me have a shot at it for your and hopefully other reader’s benefit.
The electromagnetic emissions of a black body is dependent on T^4 as per the following graph. The total energy emitted by a body with a temperature of T, is the area under the temperature curve in question.
This graph is the energy emission from the surface at temperature “T” to outer space (actually to 0 Kelvin). Look at say the 5777K line. Now let’s say there is a body at 300K between the 5777K body and outer space.
That 300K body is emitting electromagnetic radiation back towards the 5777K body and both bodies have the same characteristics below the 300K line.
So the net radiation loss of the 5777K is reduced by the area below the 300K line.
That area under the 300 curve is referred to as the “back radiation”. And the net electromagnetic radiation is what Carnot would have described as “heat” and the difference is somewhat obscured by common usage and abused by textbooks.
Yeah, probably somewhat misleading terminology…maybe “blocked radiation” would have been better. None-the-less it is the reduction in net heat that a warm surface can emit…due to the radiation received from its surroundings…in atmospheric context, the mosaic view of the temperature of the sky as viewed from the warmer surface….
‘“Back radiation” is something you clearly don’t understand, and as you are a BSME, I can only say you must have missed some relevant classes, where the assignment was calculating the temperature of electronic components in a chassis, or parts in an engine, or supports in a boiler.’
‘Electronic components in a chassis, or parts in an engine, or supports in a boiler’ are all objects, i.e., they are composed of condensed matter, which emits thermal radiation at temperatures above absolute zero. I won’t take up space here to list the key properties of thermal radiation, but suffice it to say these don’t apply to atmospheric gases, at least on this planet.
If, and when, you deign to stop disparaging others, perhaps you can explain how the phenomenological physics of radiant transfer theory, as opposed to convection, accounts for the transfer of energy from the Earth’s surface to the top of the troposphere. A big clue here is that your beloved ‘back radiation’, as opposed to ‘radiance’ has never been measured.
https://issuu.com/johna.shanahan/docs/241128_thermaliztion_of_sunlight
Hmmm…apparently you missed the same classes as Nicholas did. The “watts/Sq.M of “back radiation” (I don’t like the terminology either…is not used in my old engineering textbooks but comes up in climate physics textbooks, which implies maybe they don’t quite “get it”)….anyway….it is measured all the time and is inherent in the calculations for IR thermometers, but for accuracy one should use a pyrgeometer, (measures radiance over an area to cover your note) and those normally exist at university grade weather station labs. In fact, it’s measurement is one of the best confirmations of Stephan Boltzmann’s equation.
Yes, I am a little disparaging to old engineers who should know better…”I was one”…BSME myself, and restudied what I thought I knew about the 2nd law of thermo and the mysterious “back radiation” a long time ago when I first read some WUWT confusion. Had some advantage though having taken graduate level heat transfer courses later for career purposes, plus being the guy called to check heat transfer calcs that “didn’t make sense” for big industrial heaters…
Thanks for the link although I disagree with the never-been-measured interpretation. You might as well say “thermometers have never measured temperature, only the expansion of mercury.”
Hmmm, that was quick. You should look into how IR thermometers work, since all the ones I’m aware of measure in the so-called atmospheric window, hence, it’s doubtful they measure ‘back radiation’ from GHGs.
As for pyrgeometers, assuming they’re sensitive to IR frequencies outside of the atmospheric window, they only measure the non-directional radiance of the emissions in their immediate vicinity, meaning they tell us nothing about energy transport. In other words, they are expensive thermometers.
I have no doubt that you are well educated, but again you should note that there is a big difference between measuring the thermal radiation emitted by objects like ‘big industrial heaters’ and modeling energy flow in the troposphere based on the phenomenological physics of radiative transfer theory..
Let me know when you’ve finished the Shula article – I’d be happy to be informed of any errors in his ideas. Otherwise, I’ll just have to go on believing that there is something fundamentally wrong with climate modeling given that there is absolutely no evidence in the geological record that CO2 affects temperatures.
IR thermometers are calibrated to report a referenced temperature assuming the target is BB. Power flux is inferred from that temp assuming an emissivity. Assuming 1.0 for surface is incorrect.
If target is not BB then black tape or paint is advised or known emissivity.
TFK_bams09 63/396=0.16 emissivity for instrument correction and the 396 up/333 back/63 duplicate loop vanishes.
People who measure 396 & 333 (USCRN & SURFRAD) do not know what they are doing.
‘IR thermometers are calibrated to report a referenced temperature assuming the target is BB. Power flux is inferred from that temp assuming an emissivity.’
Or more directly, the so-called ‘target’, being one or more atmospheric gases, has neither a ‘body’ nor a ‘surface’, and therefore does not exhibit any of the thermal radiative properties characteristic of a black body.
So-called ‘back radiation’ is the result of phenomenological physics that erroneously conflates radiance with energy flow:
‘Whether spelled out explicitly or not, the key premise of phenomenological photometry as well as of the phenomenological RTT is that matter interacts with the energy of the electromagnetic field rather than with the electromagnetic field itself. This profoundly false assumption explains the deceitful simplicity of the phenomenological concepts as well as their ultimate failure. Indeed, the very outset of both phenomenological disciplines is the postulation of the existence of the radiance as the primordial physical quantity describing the “instantaneous directional distribution of the radiant energy flow” at a point in space. This is followed by a “derivation” of the scalar RTE on the basis of “simple energy conservation considerations” and the postulation that it is the electromagnetic energy rather than the electromagnetic field that gets scattered by particles and surfaces.’
https://ntrs.nasa.gov/api/citations/20140012672/downloads/20140012672.pdf
An experiment.
By “tweaking” the emissivity setting I can spoof this IR thermometer into displaying temperature and power flux that clearly do not exist.
MSM today sets the narrative and attacks any dissent. That’s why it’s dying.
The entire 390/324/66 loop is imaginary as is your esoteric handwavium.
Temperature is a function of the kinetic processes.
Radiation is function of temperature & just comes along for the ride.
Mostly agree, but it is missing a nit.
EM has a latency of c, speed of light.
Thermal has a latency of ~ 1/2 speed of sound.
That is why W/m^2 is used, so that nasty little detain does not have to be accounted for.
“Temperature is a function of the kinetic processes.
Radiation is function of temperature & just comes along for the ride.”
Thank you for saying that. !!
Steve,
There is another health factor with a huge multiplier. In a 2018 paper in Lancet Public Health, Bruce Lanphear estimated that 400,000 US people could be going dead each year from poisoning by the element Lead, Pb. Newspapers ran with it. He wrote that many people have fatal heart problems, Lead can cause blood pressure heart problems, so Lead is a toxin killing many people. (In contrast, about 20 US people a year have Lead poisoning on death certificates as a cause of death).
This technique can of course be copied for Mercury or any other substance that affects the heart like Lead does, even many foods and drinks, so the total effect could reach some millions of US deaths a year. Trouble is, we now have a competition for which substance affecting the heart does a more serious job than Lead. Taken to extremes, everyone can expect to die from substance poisoning before natural causes apply, which some readers might ridicule, especially when dollar costs are put on deaths. Geoff S
Eat food, drink water, and die. 🙂
100% mortality guaranteed!
In its economic justification for the latest mercury limits, EPA justified lowering the limits based on and increase of IQ at less that 1 IQ point. When multiplied by the entire US population, this resulted in a large IQ “improvement.”
Studies have indicated that repeated IQ tests yield results of 5 to 20 points less, on a norm of 100. So, at best, the IQ test has a -5% reproducibility, which means a <1 IQ difference is just noise. What a great fact to base $billions of costs on.
Of course, the NYT is the BBC’s first port of call for what is going on the USA (Plus the WaPo and the LAT).
“This has put the greens into orbit”…and hopefully their trajectory leads straight into the sun, never to come back.
The Trump Environmental Protection Agency just decided to no longer inflate the monetized benefits of EPA air quality regulations with imaginary deaths prevented. This has put the greens into orbit.
****************
“Hell hath no fury like arrogant environmentalists and climate activists scorned.”
I love the smell of truth and napalming of overreach in the morning.
Air quality better than victorian london is too good for the average citizen anyways.
Modern coal fired power has basically ZERO effect on air quality.
Lithium battery fires on the other hand are EXTREMELY TOXIC.
Lee is the best. Only NY could lose a leader like him and then criticize his wonderful accomplishments afterwards.
No doubt this same fiction about PM2.5 and related claims is embedded in the NY “Energy” “Plan” which was recently updated and adopted by the “Planning” “Board” in support of the state’s implementation of the CLCPA (Climate Leadership and Community Protection Act.)
How so? By computing absurdly high “Health” “benefits” with no stream of hard money receipts to justify the painful expenditures for non-emitting electricity sources, EV’s, building electrification, transmission upgrades, etc. This even exceeds the imaginary “Avoided GHG benefits” – the other unsound justification manufactured from thin air – in the net zero scenarios.
This is Figure 56 from the section 16 “Pathways Analysis” part of the Energy Plan.
https://drive.google.com/file/d/1_gt5EYltq5B2Y2tSAA7zf6GbNkbg3Xso/view?usp=sharing
Thanks, Steve, for your energetic battle against junk science.
“Making things up” epitomizes left wing reasoning. The easily manipulated fall for obvious false narratives every time. The zombie apocalypse still has a significant number of brain dead adherents goose stepping to legacy media and clinging to hate.
Why should anyone believe what the government says?
Or the MSM.
The Linear No-Threshold risk model and the Precautionary Principle both do a lot of heavy lifting at the EPA. Eliminate them next after the CO2 endangerment finding.
Do the model designated dead get both benefit checks and retroactive reparations payments? Check with your Minnesota benefits office to find out.
Yes, they also get to vote!
Two thing going on here: Cloward–Piven strategy and Brawndo.
Some really want to destroy the USA while other have little use for intelligence and critical thinking.