Lethal At Any Dose?

DDP Newsletter January 2015 Vol. XXXIII, No. 1

The linear no-threshold (LNT) hypothesis, which declares that there is no safe dose of ionizing radiation, is being applied to other things regulators would like to control, such as chemicals and small particulates (dust). With radiation and chemicals, a 50% lethal dose (LD50) can generally be determined. Harm can accumulate at lower doses, especially cancer with a latency period of years to decades. By extrapolating the dose-response graph linearly to zero, a harm proportional to dose can be calculated.

For small particulates, I have never seen an LD50. Instead, the U.S. Environmental Protection Agency simply makes the astonishing assumption that a tiny dose can be instantly lethal, provoking a “premature” death from respiratory or heart disease.

In the 1990s, there was a movement to let states “set their own environmental priorities” and to receive block grants to address them. An “expert panel” was appointed by then-governor Fife Symington, and the Arizona Comparative Environmental Risk Project (ACERP) was supposed to rank the risks—which had already been selected by someone (see Civil Defense Perspectives, May 1994, http://tinyurl.com/ohw9tlt).

One of the predetermined concerns was PM-10 (particulate matter less than 10 microns). Very small particles are said to be “the most biologically threatening to humans” because they are inhaled deep into the lungs. The American Lung Association assumed a 1.5% increase in “premature” mortality for every 10 microns/m3 in PM-10. (A volume of 10 cubic microns is one-trillionth the volume of one cubic meter.) Lowering the level from the EPA standard of an annual average of 50 microns/m3 to the California standard of 20 microns/m3 would result in 37 fewer premature deaths in Arizona, according to the 1995 report of ACERP. Assuming that there is no threshold, 963 Arizonans were purportedly dying prematurely every year from PM-10s. Now, even tinier particles, PM-2.5, which are even costlier to remove, are the focus of EPA regulatory concern.

What is in these particles that can be deadly at such a tiny dose? That is not chemically defined. Engine exhaust and soot are part of the mix. Still, reduction of whatever it is accounts for virtually all the purported benefits of almost all of the new air-quality regulations to cut levels of CO2, ozone, and mercury—except for preventing the 0.02 °C increase in global temperature by 2100 that is predicted by models.

And what does “premature” mean? The goal of preventing premature death applies to all regulation (and medicine), but noticeably absent for the EPA Clean Power Plan, its costliest regulation ever, is any calculation of the cost per year of life saved. “Premature” might mean a few days early, or death on a day with a higher-than-average death rate (CDP, July 2014, http://tinyurl.com/pg5pnt6).

The foundational studies by D.W. Dockery, used for the EPA’s regulatory crusade in the 1990s, used data mining to find a small association that could be announced as a threat. The EPS particulate-matter rule based on such studies is “cargo-cult science,” writes John Dale Dunn, M.D., J.D., in an extensive critique. EPA is now carrying out unethical experiments in an effort to show harm from exposing human subjects to diesel exhaust (J Amer Phys Surg, spring 2014, http://tinyurl.com/p5convz).

Statistician S. Stanley Young of the Bioinformatics National Institute of Statistical Sciences examines the question of mortality co-benefits to the Clean Power Plan (http://tinyurl.com/ok3eseq). The EPA created a natural experiment by imposing stricter limits on particulates in certain counties. There were large reductions in PM-2.5, but no reduction in death rates, compared with control counties. Contrary claims of reduced mortality are based on national trends of air quality and mortality, which are much more likely to be confounded by other factors, Young explains. He concludes that: “The science literature, when covariates are controlled, is on the side that increased ozone and PM2.5 are not associated with increased deaths.”

Young also examines the relationship between income levels and life expectancy. The $900/person annual cost of the Clean Power Plan in 2020 would be expected to reduce life expectancy by two months. The correlation between income and longevity is brilliantly illustrated in a video by Hans Rosling (http://tinyurl.com/bc9pld8). Interactive graphs by Rosling at www.gapminder.org can be used to explore data from many different countries over time. The 100 available axes to choose from include health statistics, CO2 emissions, education, and energy use.


  • Gallons of water to produce 1 million BTUs: from soy biodiesel: 14,000 to 75,000; from corn ethanol: 2,500 to 29,000; from hydraulic fracturing: 0.6 to 6 (http://tinyurl.com/pqdsyem).
  • Fuel subsidies: In the U.S., dollars of subsidy per billion BTUs produced: for coal, oil, and gas: $68.72; for renewables: $1,724. Outside the U.S., the ratio is only 3:1 in favor of renewables. “Fossil fuels” get $523 billion in subsidies while producing more than 80% of the energy; renewables get $88 billion, while modern “green” technology accounts for only 5% of energy production. Most of the fossil-fuel subsidies are in non-Western countries, where they buy political stability by reducing consumer costs. In Venezuela, for example, gasoline sells at 5.8 cents/gallon.(Forbes 11/13/13, http://tinyurl.com/omy84r6).
  • Earthquake potential: Induced seismic activity has been attributed to many human activities including the impoundment of large reservoirs behind dams, controlled explosions related to mining or construction, and underground nuclear tests. Energy technologies that involve injection or withdrawal of fluids from the subsurface can also create induced seismic events that can be measured and felt. Geothermal technology at The Geysers in southern California has resulted in significant induced seismic activity. Very few felt induced seismic events have occurred at 151,000 U.S. injection wells, where “waterflooding” or CO2 injection is used for enhanced oil recovery. Felt seismic activity was suspected in only one case of hydraulic fracturing in the U.S., and is not confirmed. There is a higher potential for significant seismic activity when large net volumes are injected under pressure over long periods, as with carbon capture and sequestration. CCS is intended for long-term storage, so fluid is not withdrawn (Murray Hitzman, testimony to U.S. Senate Energy and Natural Resources Committee, June 19, 2012, http://tinyurl.com/ompdomv).
  • More expensive than a bail-out: The cost of renewable energy infrastructure in Europe as of 2012, excluding additional fees for grid connections and upgrades, came to €600 billion, greater than the cost of the Irish and Greek bailouts combined (Breitbart.com 2/5/15, http://tinyurl.com/oslb87u).
  • Green “progress”: The world’s most efficient gas turbines are being shut down because they cannot make a profit under German rules allowing them to operate only when wind and solar aren’t producing (http://tinyurl.com/qxb99km).

DDP, 1601 N. Tucson Blvd. Suite 9, Tucson, AZ 85716, 520.325.2680, www.ddponline.org. Follow us on Twitter @d4dp.

Leave a Reply

Your email address will not be published. Required fields are marked *