The EPA Terminator

EPA Administrator, Gina McCarthy, in a recent speech said, “we’re coming after you” in discussing criticism of EPA science from some members of Congress and so called conservative groups.  Her remarks were in response of efforts to obtain studies on which the agency has based some of its regulatory actions.

If it wasn’t for the recent experience of the IRS targeting or the Justice Department’s unprecedented seizure of telephone communication of AP reporters, her remarks might be dismissed as just carelessness.  Maybe she had just watched the Godfather or similar gangster movie.

In her remarks, she said, “Science is real and verifiable,” she said. “With the health of our families and our futures at stake, the American people expect us to act on the facts, not spend precious time and taxpayer money refuting manufactured uncertainties.”  She claims that the reports in question have been peer reviewed as if that makes them beyond criticism.  The studies supporting cold fusion a few decades ago and the infamous “hockey Stick” also had been peer reviewed.

Instead of issuing threats, Ms. Terminator McCarthy could simply release the reports for review.  If they are that good surely they would withstand close scrutiny.  The problem is that many of these studies while carefully done are based on assumptions for which there is no scientific foundation.  Two of those assumptions are linear dose response and the one hit

Model. The first is that there is a linear relationship between the dose of a toxin or carcinogen and its harmful effects.  There is very little credible data on the adverse health effects of very low doses while there is data showing that low doses of poisons like arsenic which is found in nature have no harmful effects.  The second assumption is the one-hit model that holds that one molecule of a carcinogen can cause cancer.  Again, it is an assumption, and a very conservative one at that.

EPA science is driven by environmental extremes and the scientists that the agency supports tend to agree with its political philosophy.  For decades, EPA has held that air pollution is the primary cause of asthma.  While no one disputes that air pollution can aggravate asthma, the agency’s underlying assumption has not been validated and is contradicted by the fact that asthma rates have increased as air quality has improved.  Would Ms. McCarthy support dirtier air to reduce asthma rates?

Many of the regulations that EPA issues draw their scientific support from epidemiological studies that study populations to understand the causes of illnesses.  These can be very valuable in developing hypotheses but are scientifically crude because of the difficulty of controlling for the large number of variables in the populations being examined.  For that reason, epidemiologist set standards for mortality or morbidity ratios to minimize false conclusions.  These studies generally find associations or correlations but every scientist knows those differ from causation.

Independent reviews of EPA regulatory actions generally conclude that they are overly conservative and excessive imposing costs that far exceed demonstrable benefits.  Instead of issuing threats that “we’re coming after you”, the Administrator would serve the nation’s interest better by actions that make sure the agency’s research can pass the Caesar’s Wife test—to be above suspicion.

This article appeared on the FuelFix weblog at http://fuelfix.com/blog/2014/04/30/the-epa-terminator/

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