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When confronted with the suggestion of reducing the number of Delaware’s school districts to lower the state’s budget deficit of $400 million, Governor Carney and many legislators respond that there really is no cost saving in the reduction primarily due to the need to “level up” the various teacher salary scales.  Delaware has 19 school districts while New York City and Los Angeles have 1 each.  We will have to address officials’ concerns with our recommendation to limit Delaware’s school districts to 5 (1 in Sussex County, 1 in Kent County, 2 in New Castle County, and 1 for Vo-tech schools).

This reduction must be accompanied by significantly increasing the operational authority of building administrators.  Remaining district officials will provide oversight and will be much more supportive and less directive.  Suppose a new analysis shows little or no cost savings.  Should we still reduce the number of school districts?  Absolutely!

The district expenditures for Superintendents, Assistants, Directors, supportive staff, office expenses, etc. has thus far produced lackluster educational results.  This is not an indictment of the personnel as much as it is of the antiquated system.  Some legislators have suggested improvements like combining district purchases.  This would be comparable to closing the portholes on the Titanic to keep the water out.  Our current educational and economic situation calls for BOLD action and not tweaks.

Shifting financial resources to teachers’ salaries will help to retain good teachers and to provide incentives to attract the best candidates to Delaware.  And just what is the most important factor for improving education?  Yep, you got it.  Great teachers!

This move to local control of schools was started back in 1995.  Charter schools, per se, were not the solution but, rather, the model for changing all traditional public schools.  Regarding this local control concept the Delaware Department of Education said, “Reliance on bureaucratic decisions would be a thing of the past.” “Teachers can have a voice in how their school should meet the challenging academic standards, and they can minimize the bureaucracies that perhaps once stifled their creativity.” “Parents and teachers are less restricted by decisions made at a district or state level…..”

There doesn’t appear to be a downside to downsizing Delaware’s educational bureaucracy.  Either we improve education and save money or we just improve educational performance.  This decision is not that difficult to make.

Ron Russo, Senior Fellow, Caesar Rodney Institute

Founding President, Charter School of Wilmington

Former Principal, St. Mark’s High School

Federal energy policy is based on failed models of increasing global temperatures.  High estimates of future temperature lead to exaggerated estimates of sea level rise, droughts and other weather impacts, and heat related health impacts.  The exaggerations were used to create an EPA Endangerment Finding for carbon dioxide emissions in 2009 that is the basis for all climate related regulations, and to determine the future Social Cost of Carbon emissions that is used to justify the cost of new regulations.  Unwinding climate regulations requires revisiting these foundational studies.

There is a small direct impact on global temperatures from adding more carbon dioxide to the atmosphere.  Dire estimates of global warming are based on a hypothesis that a small temperature increase will be magnified by increasing water vapor in a positive feedback loop that leads to a runaway greenhouse effect.  Naturally occurring water vapor accounts for 95% of the earth’s greenhouse effect.

The federal government has invested over $40 billion in grants for research to prove the feedback hypothesis is true, billions more on regulations to restrict conventional fuels, and tax subsidies for renewable energy assuming it is true.  Nothing has been invested in research to consider the feedback hypothesis is false.  The graph below shows the average of over a hundred results from organizations that ran computer models based on the feedback hypothesis compared to real world measurements of global temperatures.  The model fails miserably!

DaveStevensonPIC

Good stewardship requires some effort to reduce emissions and the United States is leading the way.  Between 2005 and 2015 the U. S. has reduced emissions at twice the rate of all the other developed countries combined, 0.7 million tons, or a 12% reduction, compared to 0.5 million tons, or 6% for the rest of the Organization for Economic Cooperation & Development countries.  Meanwhile, the rest of the world has increased emissions by 7.4 million tons, or 45%.  Our success rests on the natural gas production revolution which not only reduced emissions but brought down all energy prices saving an estimated $1500 a year for American families.  The expansion of natural gas use will continue.  Beyond fuel switching, we need to shift federal expenditures to research on non-CO2 emitting power sources, such as on more efficient solar panels, better batteries, and small, modular nuclear generators.

 President Trump issued an Executive Order ending the use of the current calculation of the Social Cost of Carbon as no longer representing government policy.  Any future calculation must use science that meet standards of openness and review, and must also use guidelines laid out by the U.S. Office of Management & Budget.  Most of the negative impacts begin many decades away.  The OMB guidelines require domestic costs of compliance of new regulations not exceed the domestic benefits in current dollars.  The OMB guidelines require a 7% a year discount factor be used for future benefits to determine current value.  Previous calculations have used a 3% discount factor and have compared domestic compliance cost to global benefits.  This may seem insignificant, but the difference reduces the benefit calculation by 60 fold!  We estimate a $30 billion benefit used to justify the Clean Power Plan drops to $0.5 billion.

To date no recalculation of the Social Cost of Carbon has been scheduled.  A review of the Endangerment Finding has also not been announced.  Courts have already ruled the EPA must review regulation of carbon dioxide emissions based on these documents.  As long as the current documents stand uncorrected they will be used to force regulation.  We urge President Trump, and EPA Administrator Scott Pruitt, to begin the review of both the Endangerment Finding and the Social Cost of Carbon.

David T. Stevenson, CRI Director 

Member Trump Administration EPA Transition Team

E-Mail:  DavidStevenson@CaesarRodney.org

 

                                               

The Beatles 1966 release of the album Revolver began with a George Harrison song that has become synonymous with April 15th.  At the time, “Taxman” was a protest against the progressive tax policies in the United Kingdom.  Back home today in Delaware, the song could be repurposed as the theme song for our Democratic caucus answer to all of our State’s financial woes.  Unfortunately, much like the Beatles, those with means (money) have options and can choose to relocate rather than bear the brunt of the burden, created by an inept government that continues to irresponsibly spend their money.  The proposals on the table to institute a more progressive income tax structure, coupled with proposals that would remove state funding to the counties and school districts – who in turn will have to increase property taxes across the board will only serve to further damage a weakened economy.  The Beatles moved to the U.S. to avoid the taxman and many residents of the First State are choosing to leave Delaware.  Those who remain in Delaware will be squeezed until there is nothing left.

The average household income in Delaware in 2008 was $63,800 dollars.  That number declined to $61,255 in 2015.  Inflation adjusted, the average household income has declined by nearly $10,000 dollars over the past decade.  In short, the average Delawarean is making less money.  This in itself is an issue that decreases the tax base straining the government’s revenue stream.  In basic terms using round numbers, 10% of $63,800 ($6,380) is more than 10% of $61,255 ($6,125) so any decrease in average wages hurts the government’s coffers.  Our “leadership’s” answer to this quandary is to raise taxes.  The problem here is that the highest earners, those that provide the most revenue to the state, are moving out of Delaware, and taking with them their money and the tax revenue that comes with it.  This will only lead to a viscous cycle of lower government revenues, higher taxes, flight of wealth…wash rinse repeat – welcome to the “Race to the Bottom.”

Delaware currently has the 12th worst foreclosure rate in the country.  One out of every 380 homes is in foreclosure.  Homes in foreclosures on average sell for 15-20% less than other homes on the market.  When a home sells below market, it drives down the value of other homes in the area.  The average sale price for a home in Delaware is about $215,000.   The real estate tax in Delaware nets to about 0.51%.  On a $215,000 home, that equates to $1,095 of taxes per year.  Raising income taxes and increasing real estate taxes will undoubtedly increase the rate of foreclosure and decrease housing values.  For most Delawareans, their home is their single biggest investment.  A decline in home values in a state with decreasing average wage rates is a vicious blow to the middle class many of which are already struggling to make ends meet.  Similarly, declining home values will only serve to decrease the tax base and compound our states financial crisis.

Our state government has a spending problem.  The state spends over $10,000 per person on government services, the seventh highest rate per person in the country.  Our state spends nearly $16,000 per public school student yet 40% of our graduates are not prepared to enter the work force or college.  The largest employer in the state is the state and two of the top 15 employers are state supported secondary education providers (the University of Delaware and Del Tech).  This is not a sustainable construct.  Couple this with the fact that we only receive 50 cents worth of federal government services for every dollar of taxes we send to the federal government, and we can quickly see that the issue is more about our efficacy than it is about income.  Our state government is a shopaholic with a maxed-out credit card, seeking more credit.  No matter how much money we give the state, they will find a way to spend it.

Until we deal with our spending problem, no amount of money will solve our problem.  There will always be another bike path to build, or intrastate to construct, or another standardized test to proctor.  Until we hold our representation in Dover accountable for what they spend our money on, they will always find a new pet project that needs funding.  Until we stop the frivolity and take away the credit card, we will continue the “Detroit-ification” of Delaware.  Rife with debt, failing programs and crime, we will descend into the depths of poverty at an accelerating rate.

There are no more quick fix solutions, no more casinos, or abandoned property, no more Transportation Trust Funds to loot…tax, tax, tax… is what we are headed for until we make tough decisions, decisions that hold people accountable and force accountable efficient allocation of limited resources.  Otherwise, John, Paul, George, and Ringo’s 1966 song will in fact become our defacto State Song.  If you drive a car, I’ll tax the street, If you try to sit, I’ll tax your seat, If you get too cold, I’ll tax the heat, If you take a walk, I’ll tax your feet….

by Matt Lenzini, CRI Advisory Council Member

Costs in any market, including health care, are reduced by raising productivity. The best way to achieve this is to release the forces of competition inherent in free markets. Proposed reforms of the Affordable Care Act (aka Obamacare) seek to do this on the demand side by incentivizing patients/consumers to shop for the best and lowest-priced care via i.e., health savings accounts (HSAs) and cross-state-border sales of health insurance. However, less attention has been paid to supply side reforms.

When suppliers in any market are protected from competition they can charge higher prices.  They are also less efficient, adopt cost-saving technology more slowly and provide lower-quality services. Thus, the project of freeing the demand side is likely to backfire unless the supply side is also freed. A certificate-of-need program is an anti-competitive supply-side barrier under state control.

What is a Certificate-of-Need Program?

Under these programs applicants must establish to the state that there is a need for additional capacity before a certificate is granted to build additional health care facilities or make major equipment purchases. This was due to a mistaken idea that excess capacity raises prices, a plausible possibility under Medicare cost-plus pricing. Medicare reimbursement has since been reformed. Moreover, there was no evidence that health care costs were, in fact, restrained. For these reasons the federal government eliminated the incentive to establish certificate-of-need (CON) programs in 1987 after creating it in 1974. Nevertheless, state CON programs linger on in 34 states, including Delaware.

This planned-economy approach to health care supply is equivalent to denying a grocery store (like Walmart) a permit to build because there is already adequate grocery store supply in the area. A new, more efficient store enters because it can underprice existing stores. This creates excess capacity which forces less efficient stores to close. Even the threat of a new store will force existing stores to become more efficient, in order to deny the new entrant a market opportunity. This is how Walmart drove productivity gains in the retail sector throughout the US in the 1990s.[1]

Clearly, it is advantageous to existing health care providers to convince lawmakers to retain CON programs. One justification is that providers are required to provide free care to indigents. However, this is very inefficient.  Just as we provide EBT (food stamp) cards so families can shop at the best value grocery store, it would be more efficient and fair to switch to an explicit tax on health care providers to fund health care vouchers/HSAs for the indigent. Otherwise this anti-competitive barrier reduces the threat of entry, and insulates existing providers from price competition.

Delaware’s Certificate of Public Review (CON) Program[2]

Title 16, Chapter 93 of the Delaware Code establishes the program. It covers the construction or establishment of any health care facility, the acquisition of a nonprofit health facility, the expenditure of more than $5.8 million by a health care facility (with some exceptions), a change in bed capacity of 10 beds or more than 10% of licensed capacity (whichever is less), and the acquisition of major medical equipment (excluding replacement and with some exceptions).  The review process considers the ‘need of the population’, the effect on existing providers, the effect on cost and quality of health care, and the availability of less costly/more effective alternatives in-state or out and co-ordination with the Delaware Health Resources Management Plan (§9304-6).

In the application kit, applicants are asked to provide demographic data, utilization rates of existing providers, and impacts on existing providers. They also get the opportunity to describe the impact of the project on cost and quality of health care in the service area. There are even some irrelevant questions (e.g. Has the Applicant evaluated alternative uses to which these monies,..could be used…? Does the Applicant intend to employ energy conservation principles..?). Extensive financial data are expected and any other studies/analysis that Applicants may have conducted to reach the decision to file the application. More serious hurdles lurk in the Delaware Health Resources Management Plan.

The Plan (last updated in 2014) explicitly prohibits the establishment of hospitals in Delaware for 5 years based on current versus projected capacity needs. Capacity needs are calculated using explicit formulas in the Plan. CPR applicants’ requirements for indigent (charity) care are laid out. While there is some discussion of other considerations, the major consideration appears to be whether additional capacity is justified based on demographic data and current capacity (existing providers). However, it is not really possible to determine how much weight is given to any one factor, including cost.

It is fair to conclude that Delaware’s CPR program is an anti-competitive barrier. Undue weight is given ‘current capacity’, i.e., existing providers. Applicants must provide highly detailed data, which will be made public thereby possibly giving away competitive advantage. Applications can be denied on a wide range of factors. Although only two applications of 47 were denied (2005-2016), there are no data on withdrawn and deterred applications.

Evidence of Effects

Statistical studies on the impact of CON programs such as Delaware’s CPR program on health care costs indicate that costs are not reduced. There is some evidence that costs are increased.[3] Studies on quality are mixed. However, it is difficult to measure the true impact of CON programs statistically because they are widespread (small control group) and their effect is through the deterrence of cost-saving activity which is hard to measure. Anecdotal evidence is easier to come by. The Federal Trade Commission and the Anti-Trust Division of the US Department of Justice make a very strong case for elimination of state CON programs, and cite specific instances of anti-competitive behavior by health providers that was facilitated by CON regulations.[4]

Conclusion

It is impossible to see any upside for health care consumers or insurers to Delaware’s Certificate of Public Review program, other than to ensure that providers are qualified and licensed to provide care. Excess capacity should not be a consideration, indeed, it is the mechanism through which new entrants to the market puts pressure on suppliers to reduce price. Nor should the financial/economic viability of new entrants or existing suppliers be a factor since it is better for consumers if inefficient providers are driven from the market. Right now, most care is paid for by third parties such as the State itself, or Highmark Blue Cross-Blue Shield. This may account for the failure to eliminate this program already. However, demand side pressure is likely to intensify as health care costs increase and the Affordable Care Act is reformed, as it must be to remain viable. The State of Delaware should eliminate this costly anti-competitive barrier as soon as possible.

by Stacie Beck, Associate Professor of Economics, University of Delaware

& Member of CRI Advisory Board

Footnotes:

[1] The income gain through lower prices, especially to lower income families, has been established in the economic literature (Hausman and Leibtag, 2007)

[2] This information is available at dhss.delaware.gov/dhss/dhcc/hrb/cprpinfo.html

[3] See National Conference of State Legislatures at www.ncsl.org/research/health/con-certificate-of-need-state-lasws.aspx and Mitchell, Matthew “Do Certificate-of-Need Laws Limit Spending?” Mercatus Working Paper, September 2016.

[4] Joint Statement of the Federal Trade Commission and the Anti-Trust Division of the US Department of Justice to the Virginia Certificate of Public Need Work Group, October 26, 2015.

 

 

“I get no respect!” That was the signature comment of comedian Rodney Dangerfield as he complained that no one really understood him.  The same could be said for Delaware’s gifted and talented population.   Attempts to focus on their special needs are usually met with “Oh, they don’t need any help, they’ll be just fine.”  Really?

A 2008 Fordham Institute report found that, while low-achieving students have made gains under No Child Left Behind, advanced-learners were “languishing”.  A 1991 study at the University of Connecticut found that between 18 and 25% of gifted and talented students drop out of school.  The National Research Center on the Gifted and Talented in a project involving the University of Connecticut, the University of Virginia, and Yale University reported that the drop outs were 27% Black, 17.9% Hispanic and 50% came from the lowest socio-economic status quartile.  If not adequately challenged, gifted and talented students become bored, frustrated, unruly, and develop poor study habits that limit their potential.  The main reasons stated for dropping out included boredom, failures, and “not liking school”.

Gifted and talented students have special needs.  The Delaware Code (Title 14, Chapter 31) defines an exceptional child as “a child with a disability or a gifted and talented child”.  The law further states that the gifted and talented child, “may require differentiated educational programs or services beyond those normally provided by the regular school program in order to realize that individual’s full contribution to self and society.”  In Delaware, giftedness could include general intellectual ability, specific academic aptitude, creative productive thinking, leadership ability, visual and performing arts, as well as, psychomotor ability.

Many states have established special schools to address the unique needs of gifted and talented students and to take advantage of the synergistic effect of gathering such students together.  According to the National Association for Gifted Children, “Gifted students benefit from classroom interactions with peers at similar performance levels.”  Some individuals consider gathering gifted and talented students together as elitist.  In a publication of the Pennsylvania Association for Gifted Education it was noted that no school official has argued that singling out talented athletes for sports team membership to the exclusion of others is elitist.  In fact, school districts and local community agencies go to great lengths applauding these athletes’ efforts and supporting them in their development.  Why not treat gifted and talented students the same way?

These special schools have admission requirements to assure that the special needs of the students will be met by the special programs being offered.  This “matching process” is similar to the college or employment application process.  Applicants to Delaware’s School for the Deaf, for example, must first establish that they are hearing impaired.  It wouldn’t make sense to accept a student with no hearing problems and reject a hearing impaired student.  Nationally recognized schools such as Thomas Jefferson High School in Virginia, Stuyvesant and the Bronx High School of Science in New York, etc. have acceptance criteria such as an admissions test, SAT scores, grades, recommendations, interviews, essays, etc.   The process is designed to determine if the student will benefit from the special and very challenging program being offered.

It’s important that our best and brightest are not at a disadvantage when competing against the top students from other states and countries.  In a February 2006 report from the University of Delaware Education Research and Development Center authored by Cheryl M. Ackerman, Ph.D. on Delaware’s Public Opinion of Education: Gifted Education, Finance, and Parent Involvement, the polls yielded interesting information.  “While 84% of Delawareans surveyed believe that gifted and talented students have special educational needs, only 14% indicated they thought these needs were being met in the public schools.  In addition, there was strong support (78%) to increase funding to create educational programs for gifted and talented children in Delaware.  In 2003 and 2005 nearly four out of five Delaware residents greatly or somewhat supported providing more funds to create such programs (79% and 78%, respectively).”

Maximizing the potential of gifted and talented students requires a new way of addressing their needs.  If we continue to use the old traditional methods it will result in a condition previously described by Albert Einstein.  According to Jan and Bob Davidson, founders of the Davidson Institute for Talent Development, “The ideal solution for meeting the needs of gifted students is creating schools specifically for them.  These islands of excellence will remain few and far between until the nation as a whole recognizes the cost of squandering its brightest students’ talents and time.”

In their book, Genius Denied, the Davidsons commented on one of Delaware’s high schools that for several years has ranked in the top 100 best public schools in the nation according to Newsweek and U.S. News and World Report.  In a report commissioned by the Delaware State Board of Education and the Delaware Department of Education conducted by Western Michigan University it was stated that the school’s students “are outperforming their counterparts at similarly matched traditional public schools” and “the school was able to advance the learning of their students at a faster rate than demographically similar students in traditional public schools.”  The Davidsons noted, “Gifted students thrive best in a place like this.  For their sake (gifted and talented) this country needs a lot more schools like (this one)”.  It seems our state may have already taken the first step to meet the special needs of Delaware’s Rodney Dangerfields.

In 2012, through a House Concurrent Resolution, a task force, chaired by Debora Hansen, Education Associate for Gifted and Talented Programs, was formed to address this issue.  Several recommendations were made that are in the process of implementation.  They include:  training all teachers to recognize giftedness (a Fordham Institute April 2017 article reported that students who come from poverty or are from a racial or ethnic group are 250% less likely to be identified for gifted programs), districts will have established programs to meet the needs of the gifted, teachers of the gifted and talented will obtain specific certification, etc.

Our educational goal should be to help every student to fully become what they are and not what we want them to be.  Maybe our goal should simply be to, “Max Every Child”.

Ron Russo, Senior Fellow, Caesar Rodney Institute

Founding President, Charter School of Wilmington

Former Principal, St. Mark’s High School

James Watt’s 1775 improved steam engine allowed the efficient removal of water from coal mines kicking off the industrial revolution.  The age of cheap, abundant energy saw global life expectancy double, and real personal income grow twenty-five fold.  The United Nations Economic Development Index compares the development stage of countries to the amount of electricity available to its citizens.  Access to cheap energy could free the 20% of the world’s population still living at subsistence levels to lower infant mortality and birth rates, and to increase income, education, health, and life expectancy.  Innovations continue today.  The combination of horizontal drilling and hydraulic fracturing unleashed natural gas production that saw an 80% price drop which forced other fuels to follow saving the average American family $1500 a year.

The United Nations Paris Climate Accord is specifically designed to end the use of coal, oil, and natural gas globally over time, in essence trapping billions in extreme poverty, for no real environmental gain.  Expensive and intermittently available wind and solar power are not a suitable replacement for low cost, reliable conventional fuels.  President Obama signed the agreement by executive action, ignoring the fact it was a treaty requiring two thirds approval in the Senate, knowing the Senate would not approve.

Candidate Donald Trump promised to remove us from this treaty and to expunge pervasive climate related regulations adopted by the Obama Administration.  Now President Trump is meeting with principle members of his staff to decide whether to keep his promise.  Several key members of the Administration are urging we stay in the agreement to avoid diplomatic blow back, and to have a seat at the table for future negotiations.  They claim we can repeal domestic regulations while staying in the Paris Treaty.  Pulling out of the Treaty might lead to diplomatic blow back once.  Staying in, but not meeting the commitments, will be a constant irritation.  As a major energy producer and consumer we will always have a seat at the diplomatic table.  We didn’t join the Kyoto Climate Agreement, but continued as a key player in future negotiations.

President Obama bragged the Paris agreement created enforceable carbon dioxide emission reduction commitments that would make his domestic climate agenda “bullet proof” from future efforts at repeal.  We agree.  Article 4 of the agreement requires a review of commitments every five years, and only allows changes in one direction – tighter.  The initial goals are not enough to have any significant impact on future global temperatures.  They are just a down payment on future cuts.  There is also a U.S. commitment to pay large sums into a wealth transfer fund for poor countries, but past such efforts mainly fed graft.  Section 115 of the U.S. Clean Air Act requires the EPA and individual states to meet goals established in foreign agreements.  Environmental groups are lining up lawsuits to force compliance with the commitments.

The President needs to keep his campaign promise and get out of the Paris Climate Treaty.  The most effective way to accomplish that is to send the Treaty to the Senate for a vote that would certainly lead to a rejection in U.S. participation.  We can then move on to review and repeal domestic regulations that do nothing for the environment, but raise energy costs, hurt electric grid reliability, and impede economic growth.

David T. Stevenson, CRI Director 

Member Trump Administration EPA Transition Team

E-Mail:  DavidStevenson@CaesarRodney.org

                                               

The number one goal of the Presidential EPA Transition Team was to restore the integrity of the scientific process.  Over the last two decades the EPA has moved away from using science to determine safe air and water quality standards to using manipulated science to justify regulations that met political goals.  Peer review became pal review by scientists receiving EPA grants, and often by peers affiliated with the researchers they are reviewing.  Key experimental data has been hidden.  President Trump’s recent Executive Order starts the process of restoring integrity by restoring unbiased peer review, and requiring public access for science studies and their underlying data.

The most egregious example of using junk science is the last administrations “War on Coal”, established as a campaign promise.  Unable to pass a national tax on carbon dioxide emissions with his own party’s legislative super majority, President Obama wrote an executive order to the EPA to create a regulation that would force states to adopt a carbon tax.  The EPA found they couldn’t do enough at the power plant level to meet their goal.  So, they used an obscure regulation to take over managing the entire electric grid with the Clean Power Plan.  They also ignored federal rules and calculated $30 billion in benefits when following the calculation rules yielded only $0.5 billion in benefits.  Fortunately the Supreme Court put a stay on implementation, and President Trump has ordered a review of the rule, and it will likely be overturned.  The President also requires cost/benefit calculation rules be followed.

Unable to close coal-fired power plants with existing regulations the EPA set out to create new regulations to do so.  However, not even the EPA can write a regulation without at least a fig leaf of cover for scientific justification, and a positive cost/benefit analysis.  A rule to limit mercury emissions that wound up closing hundreds of older, smaller coal-fired power plants showed only a $6 million dollar benefit compared to $9 billion in implementation cost.  No problem.  The expensive filtration systems needed to remove mercury would also remove fine particle pollution as a by-product.  The EPA merely included the exaggerated health benefits from lowered fine particle pollution to justify the mercury rule.

Those exaggerated health benefits are a good example of bad science.  The Harvard Six Cities Study on mortality from exposure to fine particulate matter is used to support the health benefits.  We have a rigorously determined air quality standard that says you can be exposed to up to 12 micrograms per cubic meter of fine particles all the time without injury, and certainly not death.  The Harvard study claims premature deaths occur from any exposure down to zero ignoring the standard.  No one gets to see the data or review its accuracy.  The Scientific Advisory Board tasked with reviewing the study is packed with EPA grantees and even reviewers from Harvard, and also never saw the supporting data.  Meanwhile human exposure studies, and real world exposure at levels way above the standard don’t confirm the Harvard results.

The EPA has used $380 billion in claimed health benefits from reducing fine particle exposure below the air quality standards to justify almost every major regulation of the last decade.  These include the new ozone standards, the cross state air pollution standards, and the carbon dioxide endangerment finding.  Part of the reason the EPA got away with using the Harvard study is the issue is complex and hard to understand without a lot of study.  If you want a detailed explanation of the problems with this study read the just published book “Scare Pollution” by Steve Milloy.

There are those who are claiming President Trump has started a war on science.  He is waging war, but it is against the use of junk science!

David T. Stevenson, CRI Director 

Member Trump Administration EPA Transition Team

E-Mail: DavidStevenson@CaesarRodney.org