Once again REASON delights. Michael Fumento's "Polluted Science" (August/September) is excellent for both its content and its clear writing. The exposure of the nonsense that is Carol Browner's position was excellent.
The proliferation of numbers (frequently conflicting) cited by Fumento is typical of legal and political advocacy, and exemplifies the uncertainty that inevitably accompanies big decisions. In politics those in power inevitably win arguments about numbers because they can implement their policies despite well-reasoned objections. Even when faced with the abundant evidence, they simply do not admit to uncertainty about the results of their proposed policy. It is not necessary, nor is it good science, to base regulations on the most extreme estimates. Because the EPA does not consider uncertainty, it is forcing us to make a bad bet. Without consideration of the uncertainty, we don't know how bad the bet is.
The EPA can effectively bet with someone else's money--our money. It can force this bad bet on companies and state and local governments with no accountability for the outcomes. The EPA doesn't have to provide funds to implement its new regulations.
The money diverted to meeting these new regulations will be unavailable for improving health coverage, providing day care, or other voluntary expenditures that might directly benefit individuals and communities. The sensible trade-offs that we might make locally will never occur to the EPA, but the EPA can certainly prevent them with its regulations. Here's hoping Congress can force Ms. Browner to take aim before firing.
Vertex Associates Inc.
San Diego, CA
Michael Fumento's article seems reasonable at first sight but fails to recognize the nature of the problem we face with regulation of air pollution and, in particular, the hazard of fine particulates.
Fumento notes that the EPA thinks "a mere 5 percent to 10 percent apparent increase in risk is enough to justify foisting new regulations on the public." During the past 20 years, the EPA has implemented many regulations to reduce a hypothetical risk of 0.0001 percent. Indeed, if the risk of particulates averaged over all Americans is the several percent that many scientists believe, then the new fine particulate regulations will improve public health more than the sum total of all EPA regulations to date. The EPA could not ignore such a problem, even though the proof is less than ideal.
Moreover, the reliability of this calculation is greater than the reliability of most of the EPA's risk calculations. Unlike with many pollutants the EPA regulates, we are sure that air pollution at high levels has killed people (not merely rodents). Four thousand five hundred "excess deaths" occurred in London in the air pollution incident of December 1952. But scientists have been arguing for 45 years about two questions: First, if the pollutant levels are reduced from December 1952 levels by a factor of 50, will the fraction of people affected drop by the same factor (in a linear dose response), or will the number of people affected drop to zero? Scientists increasingly believe the fraction does not drop to zero, if it ever does, until air pollution is below present levels. Second, what part of the air pollution causes the effects? Dr. Suresh Moolgavkar, quoted in Fumento's article, is right: We do not know for sure.
In addition to the direct evidence that epidemiologists such as Dr. Douglas Dockery adduce, there is indirect evidence about the way particles behave in the lung, and auxiliary animal evidence, that fine particles are the proximate cause. But we are much more certain that the culprits are some mixture of products of fossil fuel combustion. This argument is the subject of a book I edited with Jack D. Spengler, Particles in Our Air: Concentrations and Health Effects (Harvard University Press, 1996).
The EPA does not propose remedies, yet neither does your article or our book. Most scientists would suggest that a reduction in the burning of fossil fuels is important, and may be easier than burning them more cleanly. This need not be expensive, and not even as expensive as EPA calculates. Several economists have independently argued that a carbon tax would encourage greater efficiency in fuel use and more use of less-polluting alternatives. Nuclear power produces no air pollution and does not add to greenhouse gases. In the past 25 years, draconian regulations have increased the cost of electricity from nuclear power by a factor of 2.5 in real (inflation-corrected) terms. I invite Michael Fumento to address the question of why so many people will not accept nonpolluting nuclear power but are willing to accept one of the biggest risks of our industrial society.
Although there are many features of the EPA proposal I would do differently, the agency should be commended for (at last) addressing one of the bigger risks society faces, rather than merely nibbling at the small risks to suit some special nonscientific interest.
Mallinckrodt Professor of Physics
I waded through the entire 14 pages of Michael Fumento's treatise on why particulate air pollution is not a problem. Perhaps some libertarians are pleased that particulate air pollution might not need government intervention since, according to Fumento, it is nothing to worry about. I am getting tired of this approach. Fumento has made quite a career telling us that social, health, and environmental problems are nothing to worry about, but I expect a bit more from REASON. Perhaps we might benefit from articles on proactive, nongovernmental solutions rather than boring, nitpicking articles that wish problems away?
Michael Fumento replies: Pages 32 through 34 of my article deal specifically with Richard Wilson's statement about a small risk being substantial if spread over a large population. It's true but irrelevant. The point is that the small risk is hypothetical, was deduced from a handful of studies, and pushes epidemiology well beyond its limits. I noted that studies finding a 50 percent increase in breast cancer associated with induced abortion were pooh-poohed as being too small an increase to mean anything, even as the 5 to 10 percent increase in deaths associated with PM2.5 is thought to be powerful enough to be the basis for hundreds of billions of dollars in new regulations.
Further, as I noted, there are only four studies with a direct measurement of PM2.5 that look at premature mortality. Of these, one is highly flawed but on its face shows a statistically significant association between PM2.5 increases and deaths. Two show no such associations. The fourth shows an association in three cities and none in the other three. In other words, there is no epidemiological evidence that there is the tiniest increase in deaths caused by a rise in PM2.5 matter.
As to toxicological evidence, "Available toxicological studies provide few clues in explaining acute mortality at low particle concentrations," according to Dr. Mark Utell, a member of the EPA's scientific advisory board. He and Mark Frampton, like Utell an M.D. at the University of Rochester Medical Center, have concluded: "Controlled clinical studies with acidic particles at concentrations greater than twenty times ambient [levels] fail to produce [lung inflammation] in healthy individuals," and "subjects with [chronic obstructive pulmonary disease], the group at presumably highest risk [to judge from] the epidemiological data, show no reduction of lung function with similar acute exposures."
Similarly, notes University of British Columbia professor of medicine Dr. Sverre Vedal: "There is no known mechanism whereby exposure to very low concentrations of inhaled particles would produce such severe outcomes as death, even from respiratory disease, and certainly not from cardiovascular disease."
Even the EPA's own staff paper admits, "One of the most notable aspects of the available information on PM is the lack of demonstrable mechanisms that would explain how such relatively low concentrations of ambient PM might cause the health effects reported in the epidemiological literature."
As to nuclear power, I'm all for it. But it is, alas, a dead issue in this country.
Finally, as to the EPA's not proposing remedies, I'd like to know how else to classify these utterly indefensible new regulations that studies from the Reason Public Policy Institute and others have shown are far more likely to cost lives (by draining the economy) than to save any.
Regarding Dr. LaBedz's snippet, the purpose of those 14 pages was to show in myriad ways that no evidence exists that there is anything to worry about in this case--except for worthless, onerous, lifestyle-changing, people-killing new regulations. Why should I be obligated to come up with a solution, governmental or nongovernmental, to a problem the EPA has failed to show even exists? As to my "career," I have done a great deal of writing warning about social and health problems, including my new book on the obesity epidemic, The Fat of the Land. But the fact is, virtually all major environmental problems are already improving, leaving the EPA and the activist groups feeling they have to grossly exaggerate what's left. In so doing, they distract us from the social and health problems that are all too real.
Gun Rights and Wrongs
T. Markus Funk's review of Don Kates and Gary Kleck's excellent The Great American Gun Debate ("Straight Shooters," August/September) is a valuable and well-written summary of the case for the social utility of private gun ownership, and of the ideological, data-be-damned bias against guns by the country's journalistic elite. Those of us who travel outside the country frequently know that this bias is not limited to America. I am an American by birth who was raised in Canada, and my frequent travels to the country of my youth serve as constant reminders of this.
My only complaint with Kates and Kleck's generally fine book, and with Funk's praiseworthy review of it, is that it gives short shrift to the most important justification for the freedom to own a gun. That reason is theoretical and deontological, not consequential. Citizens have a natural right to self-defense. Guns are great equalizers which enable physically weak citizens to more effectively stand up to bullies (including bullying governments). One citizen's natural right to self-defense is simply not dependent on another's misuse of his guns. Our Constitution enshrined the right to keep and bear arms for these reasons of natural right. By abandoning them, gun-rights defenders play into the hands of the public policy elite, which scorns natural right and natural law.
Michael I. Krauss
Professor of Law
George Mason University