Ozone, Asthma, and EPA Junk Science

On June 22, 2017, the Arizona Daily Star ran a story with the alarmist headline: “Tucson-area air quality the worst in five years.” The “worst in five years” thing is that on just five days during the past three months ground-level ozone measurements exceeded the EPA standard of 70ppb by a few parts per billion. “Ozone levels at Saguaro National Park-East that topped the 70 parts per billion federal standard: June 15 — 77 ppb, June 14 — 73 ppb, May 12 — 71 ppb, April 21 — 73 ppb, April 20 — 74 ppb.” The EPA claims that ozone causes asthma and other respiratory ailments, hence the strict standards. But, the EPA’s own data debunks the claim.

For many years, the EPA has been conducting experiments on the effects of ozone exposure. They placed volunteers in a closed room and subjected them to 300ppb and 400ppb ozone for two hours while they performed mild exercise. The 6,000 volunteers included children, the elderly, and even asthmatics. The EPA reports that “not a single adverse event.. [was] observed.” (Source)

There is also independent data showing that EPA ozone standards are bunk. For instance, there was “No association between air quality (PM2.5, ozone) and hospital admissions for asthma in University of California-Davis Health System during 2010-2012 (19,000+ cases). (Source)

According to the Institute for Energy Research, “average ozone concentrations nationwide dropped by 33 percent from 1980 to 2014. Since the incorporation of the 2008 standards, average ozone levels have declined by more than 9 percent, nationally.”

IER also reports: “According to an August 2015 report by NERA Economic Consulting, which analyzed the impacts of a 65 ppb standard (EPA ultimately went with a slightly higher 70 ppb standard), the total compliance costs could total $1.13 trillion from 2017 to 2040. The rule could also lead to annualized GDP declines of $140 billion as well as $840 in consumption losses for households.” (Source)

The EPA’s rules were endorsed by a panel of scientists required by law to review them, called the Clean Air Scientific Advisory Committee (CASAC). Both the Clean Air Act and the Federal Advisory Committee Act required that CASAC panels be independent and unbiased. So was the panel independent and/or unbiased? A report shows that members of the board received a total of $192 million worth of EPA grants. (Source)

Some background:

“Ground-level ozone is formed through a chemical reaction when nitrogen oxides (NOx) and volatile organic compounds (VOCs) interact with sunlight. Emissions from power plants, industrial facilities, automobiles, gasoline vapors and solvents are all sources of NOx and VOCs. Natural sources, such as plant life and fires, also contribute to the formation of ozone; today, given how much ozone levels in the United States have already been reduced, a significant portion of a given area’s ozone concentration is made up of natural background ozone and ozone that has traveled from other states and, increasingly, from overseas.” (Source, study by National Association of Manufacturers)

A measurement problem:

“While the EPA has long known that ozone measurements are significantly biased upward by mercury vapor, the agency has required States to use ultraviolet ozone monitors subject to mercury interference. These ozone monitors blow air between an ultraviolet (UV) lamp and a UV detector. Ozone strongly absorbs UV, so reductions in UV arriving at the detector are proportional to the ozone in the air. But mercury vapor and other contaminants in air also absorb UV, thus, artificially inflating the amount of ‘ozone’ that is measured. The bias can range from a few parts per billion to many more.” (Source)

Mercury occurs in soil in and around Tucson. It is possible that readings recorded by local instruments may be “biased upward” by the mercury contained in blowing dust. A study in Avra Valley, west of Tucson, found soil mercury values up to 750ppb. (Arizona Geological Survey, Open-File Report 81-5, 1981).

The AZ Star article expresses much concern over the County exceeding EPA standards. These standards are the current law, so they may have economic consequences for non-attainment. There is, however, no proof that exceeding these standards have any effect on health.

See also: EPA experiments on humans debunk their ozone and particulate matter health claims

EPA’s Clean Power Plan would disproportionally hurt the poor

According to a study commissioned by the National Black Chamber of Commerce, the EPA’s “Clean Power Plan” would have “serious economic, employment, and energy market impacts at the national level and for all states, and that the impacts on low income groups, Blacks, and Hispanics would be especially severe.”

The report is entitled “Potential Impact of Proposed EPA Regulations On Low Income Groups and Minorities.” You can read the full report here (127 pages).

The report abstract reads as follows:

“EPA is proposing new regulations, including guidelines to reduce CO2 emissions from existing fossil-fueled power plants. These regulations would have serious economic, employment, and energy impacts at the national level and for all states, and the impacts on low-income groups, Blacks, and Hispanics would be especially severe. The EPA rules would: 1) Significantly reduce U.S. GDP every year over the next two decades – over $2.3 trillion; 2) Destroy millions of jobs; 3) More than double the cost of power and natural gas to over $1 trillion; 4) Require the average family to pay over $1,225 more for power and gas in 2030 than in 2012.”

“The EPA regulations will increase Hispanic poverty by more than 26% and Black poverty by more than 23%. The energy burdens for Blacks and Hispanics will increase and large numbers of both groups will be forced into energy poverty and Black and Hispanic household incomes will decline by increasing amounts each year. There would be increasing job losses: By 2035, cumulative job losses for Blacks will total about 7 million and for Hispanics will total 12 million. Most job losses would occur in the states in which Blacks and Hispanics are most heavily concentrated.”

The report provides analysis of impact nationally and by state.

In concluding remarks (page 103) the report warns:

“The EPA regulations will significantly increase the energy burdens for Blacks and Hispanics and increase the numbers of Blacks and Hispanics suffering from “energy poverty.” The regulations will greatly increase energy prices and set off repercussions throughout the economy, but nowhere do high prices bring consequences as swiftly and harshly as in low-income and minority households. For the tens of millions of low income households, the higher energy prices will intensify the difficulty of meeting the costs of basic human needs, while increasing energy burdens that are already excessive. At the same time, the EPA regulations will threaten low-income access to vital energy and utility services, thereby endangering health and safety while creating additional barriers to meaningful low-income participation in the economy. While home energy costs average about four percent per year in middle class households, they can reach a staggering 70 percent of monthly income for low-income families.”

The government’s campaign to reduce carbon dioxide emissions has no basis in science or economics; it is essentially a method for obtaining power and making citizens more dependent on government. As Dr. Indur Goklany writes, “…it is a strange moral calculus that endorses policies that would reduce existing gains in human well-being, increase the cost of humanity’s basic necessities, increase poverty, and reduce the terrestrial biosphere’s future productivity and ability to support biomass, all in order to solve future problems that may not even exist or, if they do, are probably more easily solved by future generations who should be richer both economically and technologically. Moreover, because food, fibre, fuel and energy – basic necessities – consume a disproportionately large share of the income of the poorest, they would also pay the highest price for these policies.” Goklany is the author of a paper “The Pontifical Academies’ Broken Moral Compass.” Read full paper here.

See also:

EPA versus Arizona on regional haze issue

EPA war on coal threatens Tucson water supply

EPA fuel standards costly and ineffective

EPA targets wrong cause of haze in Grand Canyon

Electricity supply endangered by EPA regulations

Impact of new EPA ozone rule

EPA experiments on humans debunk their ozone and particulate matter health claims

EPA conducted illegal and potentially lethal experiments on children

The EPA is destroying America

Replace EPA

EPA emission standards for trucks: heavy cost, no benefit

At a cost of only $30 billion, new EPA regulations may save us from 0.0026°C of global warming by the year 2100.

According to an EPA report (971 pages) [link]: “The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA), on behalf of the Department of Transportation, are each proposing changes to our comprehensive Heavy-Duty National Program that would further reduce greenhouse gas emissions (GHG) and increase fuel efficiency for on-road heavy-duty vehicles,…”

The National Center for Policy Analysis estimates that “The Environmental Protection Agency’s second round of heavy-duty truck efficiency standards could cost more than $30 billion.” – costs that will be passed on to consumers.

“Auto manufacturers and the freight and long-haul transportation industry already understand the importance of fuel efficiency. Nearly 3 million heavy-duty Class 8 trucks carry approximately 70 percent of America’s freight, consuming more than 50 billion gallons in fuel and spending more than $140 billion in diesel costs. The industry operates on razor-thin margins and plans its driving routes down to the tenth of a mile to save on fuel costs.” – Nicolas Loris, The Daily Signal

The Obama administration says these new regulations are necessary to meet Obama’s carbon dioxide reduction goals.

The EPA claims “The proposed standards are expected to lower CO2 emissions by approximately 1 billion metric tons…”

So, what benefit will we get for $30 billion? EPA’s own figures show no benefit to the environment and no effect on global climate.

According to the EPA report linked above, the new regulations will accomplish the following (page 6-45): “As a result of the proposal’s emissions reductions from the proposed

alternative relative to the baseline case, by 2100 the concentration of atmospheric CO2 is

projected to be reduced by approximately 1.1 to 1.2 parts per million by volume (ppmv), the

global mean temperature is projected to be reduced by approximately 0.0026 to 0.0065°C, and

global mean sea level rise is projected to be reduced by approximately 0.023 to 0.057 cm.” Wow!

Among the first things the next President should do is to issue an executive order forbidding federal agencies from regulating carbon dioxide emissions and rescind all regulations that do so.

The U.S. Supreme Court recently ruled against the EPA on certain power plant emissions (see here). It remains to be seen whether the principles cited in that case will be extended to motor vehicles.

See more articles on EPA stupidity:

EPA versus Arizona on regional haze issue

EPA war on coal threatens Tucson water supply

EPA fuel standards costly and ineffective

EPA targets wrong cause of haze in Grand Canyon

Impact of new EPA ozone rule

EPA experiments on humans debunk their ozone and particulate matter health claims

EPA conducted illegal and potentially lethal experiments on children

The EPA is destroying America

EPA Clean Power Plan is Junk Science

Replace EPA

But the EPA did get one right: EPA says fracking does not harm drinking water supply


Revealed – EPA conducted illegal and potentially lethal experiments on children

Back in December I reported on EPA experiments that exposed senior citizens to potentially lethal doses of ozone and particulate matter from diesel exhaust, see EPA’s own human experiments debunk health claims.

JunkScience.com has been investigating these EPA experiments and found in late December, from documents obtained through the Freedom of Information Act, that the EPA was also experimenting on children 10 to 15 years old. These children were exposed to up to 300 micrograms of diesel exhaust particulate matter (PM2.5) which is 60 times the amount EPA claims is dangerous.

JunkScience says “the U.S. Environmental Protection Agency paid the University of Southern California (USC) and the University of California, Los Angeles (UCLA) to conduct experiments testing whether exposure to diesel exhaust harms children. These experiments are illegal under the Nuremberg Code, California state law and federal regulations concerning the protection of human subjects in medical research.” The tests were conducted without adequate informed consent.

Read the full JunkScience report here.

Some excerpts:

“EPA’s characterization of the PM2.5 [particulate matter] component renders diesel exhaust essentially one of the most deadly substances known to man in that any exposure can kill within hours. While JunkScience.com disagrees with this characterization, EPA and CARB [California Air Resources Board] nonetheless regulate diesel exhaust and PM2.5 on this basis.”

“Given this context, the conduct of the EPA, USC, UCLA and researchers in intentionally exposing children as young as 10 years old without informed consent to a deadly substance is quite clearly illegal, not to mention heinous and barbaric.”

“That the EPA and USC apparently attempted to conceal these facts from the public once they were discovered underscores the criminality of the conduct.”

“The only defense the EPA has to these charges would be admissions that its and the CARB’s pronouncements on the lethality and toxicity of diesel exhaust and PM2.5 are not true.”

Do you think anybody will be prosecuted?

From Thomas Sowell: “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong.”

UPDATE: Documents contradict EPA claim that it stopped diesel fume tests on kids

See also:

Replace the Environmental Protection Agency

EPA targets wrong cause of haze in Grand Canyon

Economic consequences of EPA power plant regulations

Impact of new EPA ozone rule

EPA experiments on humans debunk their ozone and particulate matter health claims

The rogue EPA is proposing to lower the ground-level ozone standards from the current 75 parts per billion (ppb) to 60 ppb. This comes on the heels of a report that in 2007, the EPA conducted experiments on the effect of ozone on human subjects and found no adverse effects even at 400 ppb.

In a previous article (Impact of new EPA ozone rule) I documented the potential economic impact of this rule, it would:

Reduce U.S. GDP by $270 billion per year and $3.4 trillion from 2017 to 2040;

Result in 2.9 million fewer job equivalents per year on average through 2040;

Cost the average U.S. household $1,570 per year in the form of lost consumption.

The EPA claims that the lower standard would reduce deaths from asthma. Few people know, however, that back in 2007, the EPA conducted human experiments on the effect of ozone.

They recruited 6,000 elderly individuals with a history of asthma and exposed them to 400 ppb of ozone for two hours while the people performed mild exercise. The EPA reports that “not a single adverse event.. [was] observed.” (Source)

The EPA has been conducting experiments on humans for years. Back in 2011, then EPA Administrator Lisa P. Jackson testified before Congress: “Particulate matter causes premature death. It doesn’t make you sick. It is directly causal to you dying sooner than you should.”

As reported by Steve Milloy in the Washington Times, the EPA has been “exposing unwary and genetically susceptible senior citizens to air pollutants the agency says can cause a variety of serious cardiac and respiratory problems, including sudden death.”


During that time at those university laboratories, EPA-employed or -funded researchers have intentionally exposed a variety of people to concentrated levels of different air pollutants, including particulate matter (soot and dust), diesel exhaust, ozone and chlorine gas — the latter substance more recognized as a World War I-era chemical weapon than as an outdoor air pollutant.

Over the same period that the experiments in question have been conducted, the EPA has become more and more alarmist in communications to Congress and the public about danger the air pollutants pose to individuals even at commonplace, non-concentrated levels. The EPA has determined, for example, that any exposure to fine particulate matter can cause death within hours or days of inhalation. EPA Administrator Lisa P. Jackson, moreover, has testified in Congress that particulate matter causes about 1 of every 4 deaths in America.

Not only is diesel exhaust largely made up of “deadly” particulate matter, but its components include polycyclic aromatic hydrocarbons (PAHs), which the EPA considers to be cancer-causing. The agency generally says that any exposure to a carcinogen increases the risk of cancer. Diesel exhaust also includes lead. The EPA has determined that lead can be readily absorbed from inhalation into the blood and that there is no safe level of lead in blood.

The university laboratories referred to in the quote above include the Chapel Hill campus of the University of North Carolina School of Medicine, Rutgers University, the University of Michigan, University of Rochester, University of Southern California and University of Washington.

The EPA has conducted at least four separate experiments where people were subjected to 10 to 20 times the particulate matter concentration the EPA says is safe. (See details on Wryheat).

Investor’s Business Daily reports that the tests were also done on children. Here is how the tests were conducted according to IBD:

“EPA parked a truck’s exhaust pipe directly beneath an intake pipe on the side of a building. The exhaust was sucked into the pipe, mixed with some additional air and then piped directly into the lungs of the human subjects. EPA actually has pictures of this gas chamber, a clear plastic pipe stuck into the mouth of a subject, his lips sealing it to his face, diesel fumes inhaled straight into his lungs.”

Remember, these tests by the EPA were conducted while the EPA claimed “that any exposure to fine particulate matter can cause death within hours or days of inhalation.”

There is now a website devoted to exposing this EPA testing: http://epahumantesting.com/ See the “guided tour” on the left sidebar of the site. That website likens the EPA testing to NAZI experimentation of prisoners during World War II.

See also:


The EPA is destroying America

EPA Clean Power Plan is Junk Science

This post is reblogged from Globalwarming.org article by Marlo Lewis. Its full title is “How Can EPA’s ‘Clean Power Plan’ Deliver $Billions in Climate Benefits If It Has No Detectable Impact on Global Temperatures, Sea-Level Rise, or Other Climate Indicators?”

EPA’s carbon “pollution” rule for existing power plants, dubbed the Clean Power Plan, requires states, on average, to reduce power-sector carbon dioxide (CO2) emissions 30% below 2005 levels by 2030.

EPA’s Regulatory Impact Analysis projects significant incremental annual compliance costs — $7.3 billion to $8.8 billion in 2030 (RIA ES-7) — but also much larger air quality and climate benefits. EPA’s Clean Power Plan “By the Numbers” Fact Sheet estimates the public health and climate benefits at $55 billion to $93 billion. The RIA projects net benefits of $46 billion to $84 billion in 2030 (RIA ES-23).

Reductions in premature fatalities attributed to coincidental reductions in ozone and fine particulate (MP2.5) pollution account for more than 90% of the estimated $23 billion to $59 billion in health benefits in 2030 (RIA ES-22). Those gigantic air quality “co-benefits” should be taken with several handfuls of salt.

Claims that PM2.5 pollution currently kills thousands of Americans annually are based on cherry-picked studies and extrapolation of health effects below the lowest PM2.5 concentrations associated with mortality in epidemiological studies. Such claims also conflict with toxicological studies, which indicate that current PM2.5 concentrations in U.S. cities are too low to cause significant disease or death.

As for ozone pollution, the rule’s purported health benefits are even less plausible, since asthma prevalence – especially childhood asthma rates — increased since 1980 while ozone concentrations declined by 25%.* The Clean Power Rule will reduce ozone precursor emissions chiefly by forcing states to shift base load generation from coal to natural gas. But the state with the worst ozone pollution is California, which obtains only 0.4% of its electricity from coal.

Those are my preliminary reactions to the rule’s co-benefit claims. I turn now to the main topic of this post — whether the rule’s alleged climate benefits justify the estimated costs.
Go to source for remainder of the article.

Another Obama scandal may be brewing at the EPA

Obama scandals dominating the news about how the administration failed our Libyan delegation at Benghazi, about how the IRS targeted conservative groups, and about administration spying on the Associated Press, now have another contender.

It seems that the Environmental Protection Agency has been giving preferred treatment to environmental groups while denying similar treatment to watchdog groups.

More on the story may be read at the Washington Examiner here and at the Competitive Enterprise Institute (CEI) here.

CEI: “Public records produced by EPA in response to a lawsuit filed by CEI under the Freedom of Information Act illustrate a pattern of making it far more difficult for limited-government groups – in particular those who argue for more freedom and less EPA – to access public records.”

Examiner: “For 92 percent of requests from green groups, the EPA cooperated by waiving fees for the information. Those requests came from the Natural Resources Defense Council, EarthJustice, Public Employees for Environmental Responsibility, The Waterkeeper Alliance, Greenpeace, Southern Environmental Law Center and the Center for Biological Diversity. CEI, on the other hand, had its requests denied 93 percent of the time.”

CEI: “This demonstrates a clear pattern of favoritism for allied groups and a concerted campaign to make life more difficult for those deemed unfriendly. The left hand of big government reaches out to its far-left hand at every turn. Argue against more of the same, however, and prepare to be treated as if you have fewer rights.”

See also:

How NEPA crushes productivity

The EPA is destroying America

EPA sued in federal court over illegal human testing

EPA targets wrong cause of haze in Grand Canyon

As a followup to a previous post: “The EPA is destroying America,” I will focus today on the issue of haze in the Grand Canyon.

The EPA is targeting the coal-fired Navajo Generating Station (NGS) in regard to its emissions of nitrogen oxides. The EPA is insisting that NGS install “selective catalytic reduction” to control nitrogen oxides, at an added cost of $48 million per year, even though, just two years ago, the plant installed devices to control nitrogen oxides. This EPA action is of particular concern to Southern Arizona because NGS supplies the electricity to run pumps that provide water via the Central Arizona Project Canal (See more here.)

The story below demonstrates the perfidy of the EPA in its war on coal, its possible collusion with environmental groups, and there is even a connection to President Obama’s nominee for Secretary of the Interior. First, let’s look at the composition of haze in the Grand Canyon.

In the chart below, compiled from data produced by the Western Regional Air Partnership (part of the Western Governor’s Association), we see that nitrogen oxide emissions from electrical generating stations represent only about 1 percent of the constituents of haze in the Grand Canyon. Most haze is a combination of soot, dust and sulfates.

Grand canyon haze causes

In the pie chart above, we see that nitrates constitute about 8% of haze. The bar chart, if it is to proportional scale, indicates that nitrates from power plants (see asterisk) comprise about 13% of total nitrates, therefore nitrate contribution to total haze is about 1% (8% of 13% = 1%). See here for a clearer view of the chart. The EPA is, therefore, imposing a very expensive requirement to target less than one percent of the problem. As I’ve point out in another article, the EPA’s solution will have no effect on Grand Canyon haze (see: “EPA versus Arizona on regional haze issue“). It appears that the EPA attack on the Navajo Generating Station is part of the administration’s war on coal. See more on the Navajo Generating Station here and specifics on emissions control equipment here.

There have been many wild fires and controlled burn fires near the Grand Canyon, all of which contribute to the haze. In fact, the National Park Service (NPS) has a Facebook page on the subject on which they show several photos. Ironically, NPS celebrates smoke in the Canyon as “a photographer’s paradise::

“Fire has always played a role in the ecology of the high altitude forests of the Grand Canyon’s rims. The mixed conifer forests of the North Rim are dependent on fire. Natural fires burn low to ground, clearing out the down and dead wood on the forest floor. Fire creates a mosaic of burned and unburned vegetation, these openings and gaps on the landscape provide habitat for forest animals enriching the diversity of life a healthy forest needs. Prescribed fire is one tool park managers use to maintain a healthy forest ecosystem. Prescribed fires can smolder for days or even weeks creating smoke that lifts in high plumes during the day and sinks into the canyon at night. Smoke in the canyon may seem like a bummer, but in fact creates dynamic, beautiful vistas. Grand Canyon, regardless of conditions, is a photographer’s paradise.”

There is another curious connection. An environmental group, the National Parks Conservation Association (NPCA), has a hit piece on the Navajo Generating Station. Within that article is a video which shows a hazy Grand Canyon and the article strongly implies that the haze is due to emissions from the station. However, that video was filmed during the past summer when there were fires in the area contributing to the haze. The people featured in the video also belong to Diné Care, a Navajo environmental group that is fighting the generating station although the Navajo people as a whole value the station for jobs and income. Navajo President Ben Shelly, recently said in a public statement and in testimony before Congress, “I still think that the federal government has placed too much of an emphasis on visibility in contrast to the costs of compliance and the potential economic ripple effects. I sincerely hope that any ripple effects of this proposal will not result in immediate drastic impacts to our Navajo workers employed at NGS and the mine. Unfortunately, some federal rulemakings result in economic impacts that are hard to recover from. I hope this will not be the case here.”

I suppose that in the realm of political advocacy, truth is optional.

Another interesting confluence: President Obama has nominated Sally Jewell to be the next Secretary of the Interior. Ms. Jewell has been a long-standing member of the board of the National Parks Conservation Association. It’s a small world.

It seems that the EPA is again colluding with environmental groups and manufacturing an issue to serve a specific purpose.

P.S. The Wall Street Journal has an article on Sally Jewell here.

“The president knows he can rely on Ms. Jewell to do for the federal government exactly what she’s done at an activist level: Lock up land, target industries, kill traditional jobs.”

Update: CAP officials discuss impact of EPA action, see story in Arizona Daily Star here.

See also:

An open letter challenging the EPA on CO2 regulation

Electricity supply endangered by EPA regulations

BREAKING: Court tosses EPA Cross-state air pollution rule

EPA versus Arizona on regional haze issue

EPA war on coal threatens Tucson water supply

EPA fuel standards costly and ineffective

The EPA is destroying America

Obama’s undercover EPA regulations

EPA Admits CO2 Regulation Ineffective

EPA sued in federal court over illegal human testing

The EPA is destroying America

Last month, the Environmental Protection Agency (EPA), defying a court order, mandated that petroleum companies must add 14 million gallons of cellulosic ethanol to gasoline, in spite of the fact that commercial quantities of cellulosic ethanol do not exist. The U.S. Court of Appeals for the District of Columbia decided in favor of the American Petroleum Institute, which sued the EPA, deciding that the EPA “exceeded its authority by requiring refiners to purchase cellulosic biofuel despite the fact the next-generation fuel is not commercially available.”

 The Environmental Protection Agency, the home of junk science, environmental radicals, and political zealots, is active on many fronts promulgating regulations that will close down American industries, our electricity supply, and our economy. The EPA is not required by law to consider the economic consequences of its regulations. That oversight should be changed.

 Let’s take a look at some of EPA’s recent actions and proposals.

 The war on coal

 New regulations regarding emissions of nitrogen dioxide, sulfur dioxide, carbon dioxide, and ozone may greatly increase the cost of electricity, cause some power plants to close, and endanger our ability to produce adequate power.

 In Arizona, EPA is using alleged haze in the Grand Canyon as an excuse to target coal-fired electric plants and is particularly targeting the Navajo Generating station, near Page, AZ. EPA rejected Arizona’s proposal for modifying the plant and instead wants the plant to install “selective catalytic reduction” to control nitrogen oxides, at an added cost of $48 million per year. In spite of the additional cost, the EPA proposal will have no noticeable effect on haze as shown in my post: EPA versus Arizona on regional haze issue. This one plant supplies the electricity to run the pumps bringing water from the Colorado River to Tucson along the Central Arizona Project canal. If the plant survives and installs the mandated catalytic devices, the cost will raise our water rates (See Arizona Daily Star).

 The EPA is also harassing other coal-fired plants in Arizona. The State of Arizona is suing the EPA over this issue (see here). Arizona Attorney General Tom Horne said of the EPA, “”This is an absurd action that would significantly raise utility rates for most Arizonans without providing any benefit to anyone.”

 In Georgia, the Georgia Power company said it will close 15 fossil-fuel-fired electric units, impacting nearly 500 jobs in the state, due to the high cost of complying with EPA regulations. In Texas, because of the EPA, Chase Power cancelled plans for a $3 billion coal-fired plant near Corpus Christi which would have employed 3,900 workers.

 Biofuels and invasive species

 The EPA protection of the environment apparently doesn’t apply in the realm of biofuels. The Heartland Institute reports that the EPA is proposing the introduction of two invasive grass species Arundo donax (giant reed) and Pennisetum purpureum (elephant grass), as advanced biofuel feedstock under the federal renewable fuel standard. Pennisetum purpureum is an African grass that thrives in warm climates, multiplies rapidly, and crowds out other vegetation. Arundo donax, native to India, is already a feared invasive plant well beyond the subcontinent. California, Colorado, Nevada, and Texas, classify Arundo donax as a noxious weed.

 “These two species are already harmful invaders in parts of the United States and should not be incentivized for biofuel use,” said Doria Gordon, director of conservation for Nature Conservancy Florida. “Both species can become so dominant that they crowd out native species and alter habitats.” A group of more than 200 scientists have sent a letter to EPA warning them of the danger and unintended consequences of this proposed action.

 Maybe the EPA wants the invasive species because its mandate for use of non-corn, cellulosic (plant waste) ethanol has not been realistic. Use of cellulosic ethanol, made with crop residue, grasses or wood chips, is a provision of the 2007 Renewable Fuels Standard (RFS) enacted by Congress. In 2012, EPA mandated that 8.7 million gallons of cellulosic ethanol be blended into gasoline. However, the ethanol industry was able to produce only about 20,000 gallons in 2012. Even though is was impossible to comply with the EPA mandate, the EPA none-the-less fined gasoline producers for compliance failure and will require they use 14 million gallons in 2013.

 Ethanol and your automobile

 There is more trouble with ethanol. Currently, gasoline is blended with 10% ethanol to supposedly curb air pollution. Now the EPA wants to increase that to 15%. However, the American Automobile Association (AAA) warns that use of E15 as the new blend is called, will damage the engines of most vehicles on the road.

 “The number of vehicles approved to use E15 – only about 12 million out of the more than 240 million light-duty vehicles – is limited, while the use of the fuel blend in non-approved vehicles can compromise a vehicle’s warranty:

 “Less than 5 percent of cars on the road are approved by automakers to use E15. Approved vehicles include flex-fuel models, 2001 model-year and newer Porsches, 2012 model-year and newer GM vehicles and 2013 model-year Ford vehicles.

 “Five manufacturers (BMW, Chrysler, Nissan, Toyota and Volkswagen) say their warranties will not cover fuel-related claims caused by the use of E15.

 “Seven additional automakers (Ford, Honda, Hyundai, Kia, Mazda, Mercedes-Benz and Volvo) have stated that the use of E15 does not comply with the fuel requirements specified in their owner’s manuals and may void warranty coverage.”

 “AAA automotive engineering experts believe that sustained use of E15 in both newer and older vehicles could result in significant problems such as accelerated engine wear and failure, fuel-system damage and false ‘check engine’ lights for any vehicle not approved by its manufacturer to use E15.”

 Burning food for fuel

 Ethanol mandates are essentially burning food for fuel. Even the New York Times has noticed some unintended consequences:

 “Recent laws in the United States and Europe that mandate the increasing use of biofuel in cars have had far-flung ripple effects, economists say, as land once devoted to growing food for humans is now sometimes more profitably used for churning out vehicle fuel.”

 “With its corn-based diet and proximity to the United States, Central America has long been vulnerable to economic riptides related to the United States’ corn policy. Now that the United States is using 40 percent of its crop to make biofuel, it is not surprising that tortilla prices have doubled in Guatemala, which imports nearly half of its corn.”

 “In a country where most families must spend about two thirds of their income on food, ‘the average Guatemalan is now hungrier because of biofuel development,’ said Katja Winkler, a researcher at Idear, a Guatemalan nonprofit organization that studies rural issues. Roughly 50 percent of the nation’s children are chronically malnourished, the fourth-highest rate in the world, according to the United Nations.”

Soot and Dust and illegal human testing

 Another EPA campaign is about fine particulate matter in the air, soot and dust, the so-called PM2.5 standard, which the EPA sets at 35 millionths of a gram (micrograms) in a 24-hour period. Most air in the U.S. averages about 10 micrograms.

 According to a story by Steve Milloy in the Washington Times, Outgoing EPA Administrator Lisa P. Jackson testified about PM2.5 before Congress in September 2011: “Particulate matter causes premature death. It doesn’t make you sick. It is directly causal to you dying sooner than you should.” “In scientific documents, the EPA has repeatedly concluded that any exposure to PM2.5 can kill, and it can kill people within hours or days of inhalation.” How does the EPA know? It conducted illegal human testing.

 But, Milloy asks, if the particulate matter is so dangerous, where are the bodies? He was referring to recent air pollution in China: “Beijing’s PM2.5 levels peaked at 886 micrograms per cubic meter — an incredible 89 times greater than the U.S. daily average. Based on EPA risk estimates, we should expect the daily death toll in Beijing to have skyrocketed by 89 percent on a same-day and next-day basis.” Yet there have been no reports of a spike in deaths caused by breathing the heavily polluted air. Has the EPA has been exaggerating the danger?

Tucson doctor Jane Orient, in a Wall Street Journal article, “EPA Science Is the ‘New Homeopathy,’ Doctors State,” says:

The “evidence” for the harm is very weak correlations seen in epidemiologic studies done in 1993 and 1995. Findings are contradicted by other studies. The EPA is now apparently trying to prove harm by subjecting human subjects to diesel exhaust in an apparatus some say resembles a gas chamber.

“Either the EPA is lying to Congress about the lethality of PM2.5, or it is engaged in illegal and unethical human experiments, subjecting vulnerable patients to a substance it believes could kill them instantly,” states Jane Orient, M.D., president of Physicians for Civil Defense.

 EPA colluding with radical greens

 On another front, we see that the EPA (and other government agencies) are colluding with radical environmental groups.

 From SPPI:

 U.S. Sen. David Vitter (R-La.) is warning of more secret “sue and settle” deals with the U.S. Environmental Protection Agency and environmental groups. In a letter today, Vitter encourages Louisiana Attorney General Buddy Caldwell to join the 13 states’ AGs who recently filed a Freedom of Information Act (FOIA) request with EPA asking for any and all correspondence between EPA and a list of 80 environmental, labor union and public interest organizations that had been party to litigation since the start of the Obama Administration.

 “The collusion between federal bureaucrats and far-left environmental organizations entering legal agreements under a shroud of secrecy is the opposite of a transparent government,” Vitter said. “This is a problem across the country, but could quickly become a threat to Louisianans if we see the full weight of the EPA and Fish and Wildlife Service come crashing down on private landowners.”

EPA regulations are costly:

 A recent study commissioned by the National Association of Manufacturers critically assessed the U.S. Environmental Protection Agency’s cost- benefit analysis with respect to six key regulations: Utility MACT, Boiler MACT, Coal Combustion Residuals, the Cross-State Air Pollution Rule, Cooling Water Intake Structures, and Ground-Level Ozone. The NAM study details the significant differences between EPA’s cost estimates and those of industry sources, while highlighting problems and inconsistencies with EPA’s methodology. Most importantly for manufacturers, the study estimates the impact of EPA rules on the manufacturing industry, directly and through indirect macroeconomic effects.

A key finding of the report is that “the annual compliance costs for all six regulations range from $36 billion to $111.2 billion (by EPA estimates) and from $63.2 billion to $138.2 billion (by industry estimates).” Notably, the study was picked up in the trade press and recognized by the House Energy and Commerce Committee, which reiterated the study’s finding that “major new EPA rules could cost manufacturers hundreds of billions of dollars and eliminate millions of American jobs.” (MasterResource)

 Pretending that carbon dioxide is a pollutant

 Of course, the biggest EPA stick is its “endangerment finding” contending that carbon dioxide emissions pose some danger in spite of there being no physical evidence to support that contention. The EPA violated both the scientific method and the Scientific Advisory Board statute intended to enforce the scientific method when it made its highly influential scientific assessment in the Endangerment Finding. That the endangerment finding is purely political is shown by the fact that the EPA is getting all worked up about carbon dioxide levels of around 400ppm. But submarine crews work efficiently in carbon dioxide levels over10,000ppm. A group of scientists is challenging the EPA’s endangerment finding.

 The EPA has long been a rogue, radical agency, and a very expensive one at that. They seem incapable of exercising common-sense and are now merely an unscientific political tool.  Proper environmental protection is important and desirable, but we are not getting it from the EPA. It is time to defund the EPA.

 See also: The EPA’s Lisa Jackson: The Worst Head of the Worst Regulatory Agency, Ever

An open letter challenging the EPA on CO2 regulation

This post is an opinion piece republished, with permission, from the Watts Up With That? blog. The list of authors/signers is at the bottom

The Supreme Court, in Mass. v. EPA, stated that the EPA must treat CO2 and other Greenhouse Gases (GHGs), as “pollutants” and then carry out an analysis to determine whether the increasing concentrations in atmospheric CO2 may reasonably be anticipated to endanger human health and welfare. The Court did not mandate regulation; rather it mandated that EPA go through an Endangerment Finding process.

EPA did so and on December 15, 2009 issued its ruling that CO2 and other GHGs must be regulated. This EPA finding and associated rulings were immediately challenged in the DC Circuit Court. The DC Circuit ruled in favor of EPA, but given the two dissents from the December 20, 2012 decision denying rehearing en banc, the matter will very likely go to the Supreme Court.

If allowed to stand, the very existence of EPA’s Endangerment Finding requires regulation that significantly increases U.S. fossil fuel and electricity prices–negatively impacting job creation as well as energy, economic and national security.

To many scientists this situation seems incredible given the ample evidence that EPA’s finding is grossly flawed. In its finding, EPA claimed with 90-99% certainty that observed warming in the latter half of the twentieth century resulted from human activity. EPA bases its finding upon Three Lines of Evidence (LoE.)

Using the most credible empirical data available, it is relatively straightforward to soundly reject each of EPA’s Three LoE.

1.) EPA claims that the Global Average Surface Temperature (GAST) has been rising in a dangerous fashion over the last fifty years, in large part due to human- caused increases in atmospheric CO2 concentrations. But “Global Warming” has not been global and has not set records in the regions where warming has occurred. For example, over this time period, while the Arctic has warmed, the Tropical oceans had a flat trend, and the Antarctic was slightly cooling. The most significant warming during this period occurred in the Northern Hemisphere, north of the Tropics. But, as the figure shows, over the last 130 years, the decade of the 1930’s still has the most U.S. State High Temperatures records. And, over the past 50 years, there were more new State Record Lows set than Record Highs. In fact, roughly 70% of the current State Record Highs were set prior to 1940.

2.) EPA’s Greenhouse Gas Fingerprint Theory is that in the Tropics, the upper troposphere is warming faster than the lower troposphere, and the lower troposphere is warming faster than the surface, all due to rising CO2 concentrations. This is totally at odds with multiple robust, consistent, independently-derived empirical datasets, all showing no statistically significant positive (or negative) trend in temperature and thus, no difference in trend by altitude. Therefore, EPA’s theory as to how CO2 impacts GAST must be rejected.

3.) EPA relied upon Climate Models, all predicated on this Fingerprint Theory, that all fail standard model validation and forecast reliability tests. The models all forecast rising temperatures beyond 2000 although GAST has actually been flat. This is not surprising because EPA never carried out any published forecast reliability tests.

Bottom –Line: No scientist or team of scientists has come up with an empirically validated theory proving that higher Atmospheric CO2 Levels will lead to higher GAST–not EPA’s team and certainly not to the EPA’s 90-99% certainty. Moreover, if the causal link between higher atmospheric CO2 concentrations and higher GAST is broken by invalidating EPA’s Three LoE, then EPA’s claim that higher CO2 concentrations also cause sea level increases and more frequent and severe storms, floods and droughts is also disproved. Such causality claims require a validated theory that higher CO2 concentrations cause increases in GAST. Lacking such a validated theory, EPA’s entire house of cards collapses.

More generally, EPA violated both the scientific method and the Scientific Advisory Board statute intended to enforce the scientific method when it made its highly influential scientific assessment in the Endangerment Finding.

EPA’s own Inspector General stated as follows:

“EPA did not conduct a peer review of the TSD [Technical Support Document] that met all recommended steps in the Peer Review Handbook for peer reviews of influential scientific information or highly influential scientific assessments. The handbook provides examples of ‘independent experts from outside EPA,’ that include NAS, an established Federal Advisory Committee Act mechanism (e.g., Science Advisory Board), and an ad hoc panel of independent experts outside the Agency.”

EPA’s outsourcing of the science to international organizations beyond the reach of U.S. laws has also been challenged. Moreover, the ClimateGate saga is testimony to the dedication of some to subvert the science for their own agenda. And, a Hockey Stick is now famous as a symbol of temperature data manipulated to generate public alarm.

In summary, it is not incorrect to argue that further study of the role GHGs play in climate is in order. However, with what is known now, it certainly seems that a new Endangerment Finding analysis is required, using, for example, the far more rigorous Science Advisory Board process suggested by EPA’s Inspector General. A Remand of EPA’s Endangerment Finding by the U.S. Supreme Court would be appropriate.

Wryheat Note: That the endangerment finding is purely political is shown by the fact that the EPA is getting all worked up about carbon dioxide levels of around 400ppm. But submarine crews work efficiently in carbon dioxide levels over 10,000 ppm. See “Does carbon dioxide make you dumb?

Opinion Piece Signer List (alphabetically)

Dr. Timothy Ball
Climatologist & Environmental Consultant
Ph.D. (Faculty of Science), University of London, England

Joseph S. D’Aleo
Chief Meteorologist
WeatherBell Analytics

Dr. Donald Easterbrook (Emeritus)
Professor of Geology
Western Washington University

Dr. Gordon J. Fulks
La Center, WA

Dr. Laurence I. Gould
Professor of Physics
University of Hartford

Dr. William M. Gray (Emeritus)
Professor of Atmospheric Science
Colorado State University

Dr. Anthony R. Lupo
Professor of Soil, Environmental, and Atmospheric Sciences
University of Missouri

Dr. Thomas P. Sheahen
Western Technology Inc.
Deer Park Maryland

Dr. S. Fred Singer (Emeritus)
Professor of Environmental Sciences
University of Virginia

George H. Taylor,
Certified Consultant Meteorologist
President, Applied Climate Services

Dr. James P. Wallace III
President, & CEO, Jim Wallace & Associates LLC
Ph.D., Economics, Minor in Engineering, Brown University
M.S., Mechanical Engineering, Brown University
B.S., Aeronautical Engineering, Brown University

Anthony Watts
Former TV Meteorologist and founder of

SurfaceStations.org, Intelliweather, WattsUpWithThat