Former Commissioner Dennis Linthicum

Jul 7, 2012 — by: Commissioner Linthicum

Redtape-usLast week, in Clearing the Air - Part 2, I touched on the biased and exaggerated data that is being used by the Environmental Protection Agency (EPA) despite Federal requirements to the contrary. Specifically, the Federal Data Quality Act (DQA) was legislation put in place by Congress to ensure that federal agencies use and disseminate accurate information.

The DQA requires the EPA to issue and follow information quality guidelines that ensure the quality, utility, objectivity and integrity of the information that they disseminate. Additionally, the EPA must provide mechanisms for affected persons to correct invalid, inaccurate, and specious information.

The agency must also present the information in the proper context and identify the source along with the supporting data or models so that the public can assess for itself whether there may be some reason to question the objectivity of the sources.

This is not a new requirement for the EPA. In a 1985 article, Risk, Science, and Democracy, former EPA administrator William Ruckelshaus discusses how the EPA, under the authority of the Clean Air Act,  often imposes costly solutions across vast regional geographies (i.e.., counties) where certain pollution criteria have only been exceeded twice in a 12 month period.  Ruckelshaus notes these rules will apply even when the air-quality monitoring devices don’t reflect the general air quality because of their placement.

In other words, even if the “community strongly opposes the action” and “there is no discernible health effect,” the regulation must be enforced, regardless of the cost or inconvenience.

This scenario, from 25 years ago, is exactly what is occurring in Klamath County today –  verbatim.

Ruckelshaus writes:

“The law does not allow the federal government to distinguish between (for example) Los Angeles and Spokane, Washington, in this regard—a restriction that defies common sense... In other words, the law does not permit us to act sensibly.”1

Since passage of the 1970 Clean Air Act, progress on air quality has been made, but progress was already well underway. In fact, progress is often more rapid and more cost-effective when designed to address local problems and administered under local control.


Real world experience and a myriad of research articles indicate that environmental quality improves as income rises. This is because increased income allows societies to provide public goods as individuals have more per capita income and can successfully invest in conservation. This means that any economic sanctions levied against the citizen’s of Klamath County, by the EPA, will degrade public health, not improve it.

I believe that improving the local economy, per capita income, and profitability of our local businesses will lead to similar improvements in our quality of life and local environment.

The first long-term global map of PM2.5 was published in a recent issue of Environmental Health Perspectives. The map shows blended measurements from two NASA satellite instruments with information about the vertical distribution of aerosols from a computer model. The map focuses on PM2.5, but the economic prosperity of a free North America is strikingly handsome when combined with its clean air standing.


(Click to read NASA report, and see full sized image.)

Over the past several articles I’ve provided a myriad of details that must make you wonder - How come this stuff never gets reported?

I’ll offer some final insights in Clearing the Air - Part 4...   (The Last Part - I promise!)


1William D. Ruckelshaus, “Risk, Science, and Democracy,” Issues in Science and Technology, vol. 1, no. 3 (Spring, 1985), p. 33. Cited in Theodore S. Glickman, Michael Gough, “Readings in Risk” (Abingdon, Oxon: RFF Press, 1988), p. 105-118.

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Commissioner Dennis Linthicum

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