In fact, the risk is likely lower. No biologically plausible mechanism exists to explain how particulate matter, at current concentrations, contributes to mortality. In the absence of any information about possible toxic mechanisms, the EPA relies upon a statistical inference that includes not a single measurement of an individual’s particulate matter exposure. It is conceivable that the risk is zero at current exposures, and it is certain that particulate matter levels will continue to fall — as they have been for years — because of the modernization of American industry.
Few if any benefits can be expected from the proposed regulation.
In contrast, the costs are high, especially when the costs are measured in lives. Many economists have pioneered analyses that demonstrate regulatory costs include deaths. Individuals bear the costs of regulations through higher taxes and higher costs. Those burdens reduce disposable income, and mortality rates go up as disposable income goes down. Put simply, “wealthier is healthier.”
The EPA estimates that its regulation would cost $7.5 billion annually, and Keeney and Kenneth Green of the Reason Public Policy Institute have calculated that 1,650 regulation-“induced fatalities” would be the result. The greatest impact would be on less wealthy people. They calculate 940 deaths among those earning less than $15,000 annually, 540 among those earning $15,000-$35,000 and 170 among those earning more than $35,000.
Economist Anne E. Smith of Decision Focus, a California consulting firm, disagrees with the EPA’s cost estimate (as do many other individuals and organizations). She calculates the costs would be between $90 billion and $150 billion. Those costs translate into 27,000 induced fatalities each year, with the majority of deaths occurring among the less wealthy.
The lowest estimate of the number of induced fatalities to be expected from the particulate matter regulation — 1,640 — is just about double the number of lives, 840, that would be “saved” by the regulation. As the costs go higher, the discrepancy will widen. In the absence of any biologically plausible explanation for an association between particulate matter and mortality, the estimated number of lives saved must be viewed with skepticism.
Mary Nichols, the EPA assistant administrator for air and radiation, told Chemical and Engineering News that the proposed regulations show “we care.” What’s caring about wasteful spending that costs lives? Made aware of the tiny benefits and huge costs of their proposed regulation, Nichols and her EPA colleagues should question their march toward regulations. They probably won’t.
Either Congress forces that question, or we face a future with high costs and regulation‐caused deaths.