Foley Hoag LLP - Environmental Law

Last month, I posted that EPA’s decision to retain the current PM2.5 NAAQS of 12 ug/m3 was the single worst decision by Trump’s EPA.  Since then, I have not received any comments suggesting that my ranking was incorrect.  In case anyone was still in doubt, Environmental Research recently released an on-line Pre-proof of A National Difference in Differences Analysis of the Effect of PM2.5 on Annual Death Rates.  The “difference in differences” approach is intended to address critics’ arguments that prior studies may have demonstrated an association between PM2.5 concentrations and mortality, but could not be used to demonstrate causality.

The study looked at excess mortality in the US Medicare population.  The results aren’t pretty.  For each 1 ug/m3 increase in PM2.5 concentrations, there are roughly an additional 14,000 deaths per year in the United States.  With my typical gift for understatement, I’ll note that it’s difficult to review this work and conclude that the current standard of 12 ug/m3 protects the public with “with an adequate margin of safety.”

On the plus side, I can only suggest that everyone undertake a visualization exercise, and try to imagine what the world will look like when it is powered almost entirely by non-polluting electricity.  How much cleaner the air will be.  How many fewer asthma cases there will be.  How much lower mortality will be.  How much greater the quality of life will be.

It won’t be easy to get there, but we’ve got to start somewhere.

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