American Oil and Gas Reporter - August 2020 - 32

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this death as "premature" and caused by
particle pollution.
Our nation's air is remarkably clean
today. Health incidents from serious air
pollution are rare. The EPA's six criteria
air pollutants-lead, nitrogen dioxide,
sulfur dioxide, ozone and particulates-
were down a combined 77% percent in
2019 compared with 1980 (Figure 1).
These improvements in air quality
have been achieved with U.S. residents
using more than 50% more natural gas
today than in 1980.
PM 2.5 pollution typically is below
the EPA national standard of 12 micrograms per cubic meter, and is down 43%
since 2000.
Twelve micrograms per cubic meter
is not very much. Dr. James Enstrom, a
retired researcher from the UCLA School
of Public Health, points out that a person
breathing in 12 micrograms of small particles per cubic meter of air would inhale
less than 5 grams, or less than one teaspoon
full, of these microscopic particles over
an 80-year life span. The EPA's assertion
that this tiny dose of particles causes premature death is not credible.
Questionable Conclusions
How do the EPA, the California Air
Resources Board, and other organizations
conclude that thousands of Americans
die prematurely each year from particle
pollution? No coroner ever attributes a
cause of death to small particles. Instead,
the EPA relies on epidemiological observational studies that find statistical
associations between particle pollution
and death.
Epidemiological studies look for associations between exposure to an agent
and appearance of disease in a population.
An example is the Doll and Hill study in
the 1950s that found cigarette smoking
caused lung cancer in a population of
41,000 British medical doctors. The EPA
has concluded that associations found in
epidemiological studies show that inhaling
small particles causes premature death.
The Harvard Six Cities study of
1993 and the American Cancer Society
study of 1995 are two of the studies
that form the basis of EPA small particle
science. These studies found an increase
in relative risk of less than 20%
(RR=1.2). An increase in death rates
of less than 20% is almost statistically
indistinguishable from zero.
In comparison, the Doll and Hill study
found smokers had 10 times the rate of
32 THE AMERICAN OIL & GAS REPORTER

lung cancer of nonsmokers, a relative
risk of RR=10. The weak association
(small relative risk) between death and
particle pollution that the EPA judges to
be causal could be the result of other factors in measured populations, or even
random chance.
Other studies have found no causal
association between small particle pollution and death. For example, Cox (2017)
analyzed small particles and death of
persons 75 years or older in Boston and
Los Angeles during periods from 2007
to 2013. That study found that ambient
PM 2.5 concentrations did not predict
average elderly mortality rates in either
Boston or Los Angeles.
The underlying data from the Harvard
Six Cities study and the American Cancer
Society study have never been released.
As a result, other scientists are not able
to replicate and verify their results.
The EPA has released a supplemental
notice of proposed rule making titled,
"Strengthening Transparency in Regulatory
Science." This proposed rule is a followon effort to a 2018 NPRM intended to
base regulatory policy on scientific studies
that release their underlying data for reanalysis and critique. This certainly is
needed in the case of epidemiological
studies claiming associations between
low levels of particle pollution and death.
The UCLA paper projects that if gas
appliances are replaced by electric appliances in California buildings, outdoor
levels of PM 2.5 will be reduced by 0.11
micrograms per cubic meter. But airborne
particulate pollution is dominated by
other sources of particles.
On Jan. 1, 2018, California legalized
the recreational use of marijuana. A person
who smokes a single marijuana joint or a
single tobacco cigarette inhales more particles than one would inhale from breathing
a year's worth of particles in California
air. In only two days, the 2017 Napa
Valley fire produced an estimated 10,000
tons of PM 2.5, which is the amount
emitted by California's 35 million vehicles
in a year.
Eliminating gas appliances from 13
million residences would reduce California
outdoor airborne particle pollution by
less than 1%. Such a small change in air
quality could not be detected by any
measurement system.
Misguided Climate Concerns
It appears the real goal of the UCLA
paper is to support climate change policies

with arguments about projected improvements in air quality and illusory health
benefits. The paper describes natural gas
as primarily methane, "a potent greenhouse
gas," and contends "buildings are responsible for an estimated 25% of GHG emissions in California."
But California gas appliances are an
insignificant part of world energy usage,
comprising only 0.33% of world natural
gas consumption. If all California residential appliances were converted from
gas to electric, the effect on global gas
usage and global GHG emissions would
be negligible.
While gas and electric appliances both
have advantages, usage shows that California residents overwhelmingly prefer
gas. Gas stoves offer better temperature
control than do electric stoves. Consumer
Affairs Research points out that gas
clothes dryers use 30% percent less energy
than do electric dryers. Gas water heaters
heat water twice as fast as do electric
water heaters.
But the biggest advantage of gas appliances is lower cost of operation. Think
Energy reports homeowners can save
$1,000-$2,000 annually with a gas furnace compared with an electric furnace.
Water heater savings can be $200 annually, and dryer and stove savings each
can be $100 annually, when using gas
instead of electric.
On Sept. 10, 2018, then California
Governor Jerry Brown signed SB 100,
mandating that the state obtain 100% of
its electricity from "clean energy sources"
by 2045. But wind and solar cannot
replace traditional coal, natural gas and
nuclear power plants if continuity in the
electric supply is to be maintained. Wind
and solar are intermittent generators.
Wind output varies greatly from high to
zero, depending on weather conditions.
Solar output is available only about
six hours each day when the sun is overhead, and disappears completely on cloudy
days or after a snowfall. Hydro power
can replace traditional plant output, but
even this source is insufficient in years
of low snow runoff or drought.
Because of intermittency, utilities can
count on only about 10% of the nameplate
capacity of a wind or solar facility. For
example, wind output for the state of
Texas in March 2014 varied from more
than 8,000 megawatts to less than 500
megawatts in a few hours.
Green energy advocates recognize renewable intermittency and propose grid-

American Oil and Gas Reporter - August 2020

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