A Publication of The Electricity Journal
Volume 8, Number 56 Tuesday, March 25, 1997
(Go to Front Page)
Could the Environmental Protection Agency's proposed tough new standards for ozone and small particulates actually cause greater harm than benefit to public health? In comments on the proposals, the Competitive Enterprise Institute, a conservative Washington think-tank, raises that possibility. "All regulations impose costs, economic and otherwise," says CEI. "In this instance, the EPA has failed to consider whether the proposed standard may actually increase mortality due to reductions in disposable income that compliance efforts may produce."
As have other critics, CEI zeros in on the alleged health benefits of the new standard for particulate matter, which would regulate particulates as small as 2.5 microns. The proposal, notes CEI, "is based upon two studies that allegedly document a weak association between current levels of particulate matter and mortality. [S]uch weak associations are rarely the basis for federal rulemaking, nor should they be."
The two studies EPA cites report risk factors of 1.17 and 1.26. In other words, the researchers observed a 17 percent increase in risk in one study and 26 percent in the other. These factors, notes CEI, "are well below those that are generally accepted to demonstrate a potential cause-and-effect link between an environmental factor and mortality." Most scientific professionals are highly skeptical of studies that purport to demonstrate a cause-and-effect link based on such a weak association. According to Dr. Lynn Rosenberg of the Boston University School of Medicine, "A relative risk of 1.3 (this is a 30 percent increase in risk) is, in epidemiological terms, virtually indistinguishable from a risk of 1.0 (that is, no increase in risk)."
With risks of such tiny magnitude, says CEI, it is plausible that the economic harm caused by the new rules would overwhelm any public health benefits. "In the area of public health protection," says CEI, "there is always a risk that regulations designed to increase protection of human health may have the opposite effect. In particular, regulations that diminish economic growth and disposable income can have negative consequences for public health. There is a strong correlation between incomes and health status. Across and within populations, as incomes rise, health improves and as incomes fall, mortality and morbidity increase."
CEI notes that academic studies generally suggest that "an economic loss to the economy of approximately $5 million to $10 million will result in an additional premature fatality." Supreme Court Justice Stephen Breyer has made the same point in work he published before President Clinton named him to the court. So, says CEI, the EPA should take a closer look at unintended consequences "including an increase in mortality caused by excessive regulatory expenditures" before it issues a final rule. "Indeed," argues the think-tank, "it would be a violation of the agency's implicit obligation to safeguard human health were such potential impacts not to be considered."