07/12/2018 - CleanLaw Podcast - Federal Policy Analysis

Podcast with Francesca Dominici on Air Quality, Public Health, and Science

Click here for a full transcript of this episode.

Our executive director, Joe Goffman, interviewed Dr. Francesca Dominici recently to talk about public health, pollution, and science. Dominici is Professor of Biostatistics at the Harvard T.H. Chan School of Public Health and Co-Director of the Data Science Initiative at Harvard University. Listen below, or scroll down to read key points from our interview on rollbacks and public health, new science on air pollution exposure, and the recent Trump administration proposal to suppress public health studies.

Examining Public Health Impacts of Rule Rollbacks
  • Dominici’s work goes to the heart of the public health issues, now controversies, at EPA and proposals by former EPA Administrator Scott Pruitt.
  • Dominici recently co-authored an article with Dr. David Cutler looking at the body of rules that Pruitt was trying to weaken or reverse related to air quality, water quality, and chemicals.
  • They consider these rule rollbacks from a public health perspective rather than how they are often framed, from an administrative law perspective, to explain what is at stake.
  • The article is not a full investigation of all ramifications. It is a high-level preview of the public health impacts of actual and proposed rule rollbacks in key areas.
  • Dominici and Dr. Cutler focused on air pollution and emission levels, looking at EPA’s own cost-benefit analyses for implementing rules in order to calculate the health impacts of the rollbacks.
  • Every time a rule is proposed or finalized, a regulatory impact analysis is produced which reflects the effects on the mortality rate and rates of occurrence and hospitalization for various illnesses.
  • Dominici and her co-author added up the potential health impacts for all of the air quality-related rules to provide a snapshot of the cumulative effects of these actions since the rollbacks have generally been discussed individually.
  • They arrived at what they call “an extremely conservative estimate” of 80,000 additional, avoidable deaths and respiratory problems for more than 1 million US residents over the next decade if EPA’s air quality deregulation actions to date were fully implemented.
  • The estimate is conservative for a variety of reasons. Co-benefits, for example, were not fully considered by the administration. (Actions like installing better pollution controls for one pollutant can result in the reduction of many other pollutants, these reductions are known as “co-benefits.”)
  • The work done by Dr. Dominici and Dr. Cutler provides a necessary public health perspective on the regulatory changes EPA is currently undertaking.
New Landmark Study on Health Impacts of Pollution in “Clean” Air Quality Regions: short term exposure to small increments of PM2.5 and warm season ozone below the NAAQS led to an increase in mortality.
  • It remains urgent to continue to make progress on improving scientific understanding and our public health and environmental regulations. Yet, we have seen EPA begin to question whether specific increments of pollution reduction have value or benefit the public, in monetary and health terms.
  • Specifically, the administration has sent strong signals that it questions the value in reducing air pollution below the current National Ambient Air Quality Standards.
  • Dominici firmly believes the best way to understand the value of regulation and to inform policy is through science and data – regardless of any given administration’s preferences.
  • Dominici led a major study, released last December, Association of Short-term Exposure to Air Pollution With Mortality in Older Adults.
  • The study relies on a large amount of data from satellites to pinpoint air quality levels across the U.S. with regard to ozone and fine particulate matter (PM5) pollution.
    • Her team used computer science and machine learning with satellite data to create a grid across the U.S. in 1-kilometer areas of ozone and particle pollution.
    • This allowed them to identify areas below the NAAQS with great specificity.
  • Health data from the Medicare system was used in the study to examine the relationship between health impacts and particulate matter and ozone pollution levels.
    • More than 96% of the U.S. population over 65 is enrolled in Medicare and the data shows where they live and when they go to the doctor or hospital and why.
  • Thirteen million Americans live in areas that are always below the NAAQS for particulate matter.
  • The study found that short term exposure to small increments of PM5 and warm season ozone below the NAAQS led to an increase in mortality.
  • Translating this study into the administrative law and policy process, it demonstrates that people living in areas with ozone and PM5 pollution below the NAAQS experience detrimental health impacts and are adding costs to the healthcare system.
  • The idea that the benefits of reducing pollution below the NAAQS is zero has been impugned by this study, which is consistent with many other studies.
Proposal to Suppress Public Health Studies
  • As part of the effort to repeal and weaken EPA rules based on science and data, Pruitt targeted the studies that have been relied upon to support existing rules. Specifically, his science transparency proposal would prevent the EPA from taking account of studies that show that particulate matter pollution harms public health based on their use of confidential data. Most notably, the Harvard Six Cities study and the American Cancer Society’s Cancer Prevention Study II.
  • There have been thousands of studies that are all consistent in showing that ambient air quality affects health. The proposal represents an attempt to remove many of the studies from consideration.
  • Although the December 2017 study led by Dr. Dominici relies on publicly-available data and is insulated from such attacks, the studies that require confidentiality for the data they used are important and should continue. Those studies document, for example, more detailed health impacts because the confidentiality of the studies allows them to collect more detailed medical information from participants and study their responses to pollution in greater depth.