EPA’s new regulatory impact analysis for its particle soot standard confirms that the agency’s chosen standard will mean a higher death toll than better alternatives.
It’s easy to do the math. Compare table 5-16 (analyzing what EPA actually did) to table 5-18 (analyzing a somewhat better alternative – an annual standard of 14 coupled with a daily standard of 35).
By EPA’s calculation, its standard (15/35) would mean at least an additional 1,900 premature deaths a year compared to a standard of 14/35. (The weakest possible alternative endorsed by EPA’s science advisers.)
That’s based on the so-called American Cancer Society study, which EPA has traditionally used to project such benefits. Other methods of evaluation show the same trend, but an even bigger death toll – and a bigger difference between what EPA did and the better standard. For example, EPA’s “expert elicitation” panel predicted much greater benefits from a 14/35 standard. (EPA ignored that panel, as it did its official science advisers.)
EPA, of course, did not even try to estimate the results of the better standards (12/25) endorsed by the American Medical Association and other groups.
But it’s pretty darned obvious that better standards would mean fewer premature deaths.