California Construction Trucking Association (CCTA)

Three able and well respected scientists and statisticians spent a couple of hours this month in San Diego making the case that the Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) are pursuing a political agenda rather than paying attention to their primary mission—public health.

The three, Dr. James Enstrom, Dr. Robert Phalen, and Dr. Stanley Young, presented papers to a group of nearly 100 attendees at the annual American Statistical Association meeting, held at the San Diego Convention Center, August 2.

Dr. Enstrom’s presentation homed in on the facts regarding PM 2.5, a criteria pollutant at the core of the CARB diesel regulations and the subject of new rule-making right now by the EPA.

Enstrom made clear that there is virtually no health effects from PM 2.5 (actually a measurement of mass, not a substance) in the western half of the nation.  He did this by citing the very studies used by the public agencies to promulgate their regulations, which demonstrate there are no proofs of causation from epidemiological studies of PM 2.5 exposure, only low-level “associations” which can be attributed to a variety of causes.  Enstrom, who has conducted two studies of these effects, said the agencies steadfastly refuse to acknowledge the science that does not confirm their preconceived regulatory agenda.

He introduced Brian Bloom, a San Diego business owner, who talked about the costs to his business (a local moving company) that the CARB rules are imposing—with no scientific proof of the need to take actions that will ultimately mean replacement of his entire fleet.  Bloom pointed out the state of California spends as much on CARB staff as it does the entire California Highway Patrol, some $800 million a year. Bloom described the CARB/EPA approach to public health as “scientific Sharia law,” an approach based more on political faith than the actual data.

Dr. Young, Assistant Director for Bioinformatics for the National Institute of Statistical Sciences, decried the government agency approach of refusing to make the underlying data in the studies they use for rule making available for other scientists to check.  He said the EPA’s one-size fits all approach to regulation makes no sense based on the science which shows no health effects in the West.  He also demonstrated the number one threat to public health in America is poverty, stating: “If there is any effect of PM 2.5 it is dramatically less than the effect of income.”

The most damning testimony came from Dr. Phalen, a professor School of Medicine, director of the Air Pollution Health Effects Laboratory at the University of California, Irvine, and a member of the EPA’s Clean Air Scientific Advisory Committee (CASAC) and that group’s subcommittee on particulate matter.  Dr. Phalen called the current EPA approach to regulation “too narrow.”

“Isolating individual pollutants, not considering PM composition, ignoring health trade-offs and imposing national standards are problematic,” Phalen said.  “The process is linear, without opportunities to discuss compliance feasibility, economic hardships or unintended health effects that vary regionally.  Such limited advice can mislead the EPA Administrator and the public with respect to the adequacy of the scientific advice provided by CASAC.”