Category Archives: Air Pollution

Post from the past: “Justice Janice Rogers Brown gets it right on the GHG endangerment finding”

I posted this on December 12, 1012….the USEPA GHG endangerment finding was unwarranted (and incorrect).

“USEPA has embarked on issuing a variety of regulations to control emission of greenhouse gases using the Clean Air Act (CAA). This flurry of activity results from an earlier Supreme Court ruling that upheld USEPA’s GHG endangerment finding under the CAA.  The endangement finding was a clear stretch of the imagination by the court. A legal challenge to GHG rules was filed in the US District Court of Appeals, DC Circuit, and a panel of judges upheld their legality. A petition was filed requesting that the entire court rule on the appeal, which was recently denied. In her desent, Justice Janice Rogers Brown provides a good explanation of why the Supreme Court erred in their ruling on the GHG endangerment finding, which indeed they did. The broad expanse of the term “pollutant” in that ruling is well-beyond the original context and intent of the Clean Air Act statute.

I have provided the full written dissent of Justice Brown below. As during the 1990s in litigation involving the Safe Drinking Water Act, the prevailing opinion explained by Sentelle provides political cover for a lawless agency (USEPA), rather than recognizing and honoring the rule of law as intended by the CAA. If congress intended GHG emissions to be regulated, congress could have explicitly enacted legislation to do so. (Click here for the full ruling.)

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Domestic livestock have no significant effect on atmospheric methane

“The main source of atmospheric methane since 1995 is from natural sources with great variability. It is not from domestic livestock as noted by Albrecht Glatzle[6]. However it is possible fracking and increased transport of natural gas may make a contribution to the methane in the atmosphere.” click here

Meta-analyses are very squishy when something is made up out of nothing

S. Stanley Young and Warren B. Kindzierski. Evaluation of a meta-analysis of air quality and heart attacks, a case studyCritical Reviews in Toxicology  https://doi.org/10.1080/10408444.2019.1576587

It is generally acknowledged that claims from observational studies often fail to replicate. An exploratory study was undertaken to assess the reliability of base studies used in meta-analysis of short-term air quality-myocardial infarction risk and to judge the reliability of statistical evidence from meta-analysis that uses data from observational studies. A highly cited meta-analysis paper examining whether short-term air quality exposure triggers myocardial infarction was evaluated as a case study. The paper considered six air quality components – carbon monoxide, nitrogen dioxide, sulphur dioxide, particulate matter 10 lm and 2.5 lm in diameter (PM10 and PM2.5), and ozone. The number of possible questions and statistical models at issue in each of 34 base papers used were estimated and p-value plots for each of the air components were constructed to evaluate the effect heterogeneity of p-values used from the base papers. Analysis search spaces (number of statistical tests possible) in the base papers were large, median 1⁄4 12,288 (interquartile range 1⁄4 2496 ” 58,368), in comparison to actual statistical test results presented. Statistical test results taken from the base papers may not provide unbiased measures of effect for meta-analysis. Shapes of p-value plots for the six air components were consistent with the possibility of analysis manipulation to obtain small p-values in several base papers. Results suggest the appearance of heterogeneous, researcher-generated p-values used in the meta-analysis rather than unbiased evidence of real effects for air quality. We conclude that this meta-analysis does not provide reliable evidence for an association of air quality components with myocardial risk.

Preoccupation with decarbonization is diverting attention in the wrong direction

PM2.5 not likely associated with premature deaths

James E. Enstrom. Scientific Distortions in Fine Particulate Matter Epidemiology. Journal of American Physicians and Surgeons Volume 23 Number 1 Spring 2018

The theoretical prevention of premature deaths from the inhalation of fine particulate matter is being used by the U.S. Environmental Protection Agency (EPA) to justify the National Ambient Air Quality Standard (NAAQS) and multibillion dollar regulations across the U.S., including the EPA Clean Power Plan and the California Air Resources Board (CARB) Truck and Bus Regulation. The epidemiology is severely flawed. Fine particulates probably make no significant contribution to premature mortality in the U.S. The publication of null findings has been blocked or marginalized and studies claiming excess mortality need to be reassessed. click here

USEPA revises New Source Review (NSR) guidance, simplifies permitting

The Environmental Protection Agency issued a guidance to clear up uncertainties in obtaining air quality permits required to build or modify facilities, like power plants and refineries. click here

Junk Science Supported by New England Journal of Medicine

“This letter is not a letter to the editor, hoping for publication, so that the authors might comment on or criticize some article in the NEJM. We write to complain that there is a continuing scandal of scientific integrity at the NEJM—junk science in air pollution epidemiology is being sponsored by what most would consider the iconic medical journal of America.” click here