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Press Release: Will the National Academy of Sciences Allow EPA to Get Away with Murder?

September 7, 2016

"I see this US EPA air pollution research project as a gigantic deceit, built on uncontrolled observational studies and projecting non-proof small associations to create big claims of deaths in particular." - Dr. John Dale Dunn, M.D., J.D.

EPA Building
On August 24, 2016, Heartland Institute Policy Advisor John Dale Dunn, M.D., J.D., testified before a special committee of the National Research Council of the National Academy of Sciences on scientific misconduct by the Environmental Protection Agency. According to Dr. Dunn and others who testified, EPA has been sponsoring experiments on human subjects involving exposures to small particle air pollution that EPA has declared publicly and repeatedly to be toxic, lethal, and carcinogenic.

This creates a dilemma for EPA: Either it broke the law by sponsoring human experiments forbidden under law and medical ethics, or its repeated claims to Congress and the American people about the health threat of exposure to low levels of particulate matter were a lie.

According to Dr. Dunn’s written testimony" (edited lightly by The Heartland Institute with the author’s approval):

“I assert that ambient small particle air pollution is benign and isn’t killing anybody. In 45 years of medical practice I am still waiting for a death from small particle exposure. Unreliable epidemiology makes possible the scare about air pollution, but it is an empty vessel.

“Epidemiology is not junk science, it’s just limited to be less than proof of causation because it is so uncontrolled, but epidemiology can become deceitful if done without recognizing the limits of the methods and the uncertainties. I see this US EPA air pollution research project – that has been funded by billions, from mostly government sources – as a gigantic deceit, built on uncontrolled observational studies and projecting non-proof small associations to create big claims of deaths in particular. ...”

In a Tuesday op-ed for Breitbart News, Heartland Institute President Joseph Bast wrote:

“The Environmental Protection Agency (EPA) has been twisting science and epidemiology to fit an extreme environmental agenda for years, but finally, finally!, it may be about to be hoisted with its own petard. Assuming, that is, that the National Academy of Sciences (NAS) doesn’t ignore its legal and ethical mandate to perform an honest evaluation of EPA’s misconduct.”

The following statements from other Heartland Institute environment experts at The Heartland Institute – a free-market think tank – may be used for attribution. For more comments, refer to the contact information below. To book a Heartland guest on your program about this topic, please contact Director of Communications Jim Lakely at and 312/377-4000 or (cell) 312/731-9364.

“Either EPA has been lying all along – and low levels of small particulates from coal-fired power plants and other sources do not constitute a public health hazard, and do not warrant the costly, draconian, extremely strict standards that EPA is imposing. “Or the agency and its hired researchers are guilty of violating legal and ethical standards by having human test subjects (including people with heart and respiratory problems, senior citizens, and even children) breathe what the agency claims are dangerous, carcinogenic, toxic, and lethal air contaminants.

“EPA cannot have it both ways, and the National Academy of Sciences and its National Research Council must not allow EPA to do so. Moreover, either way, EPA officials have clearly violated their oaths of office, by misleading the public and their test subjects. There have to be repercussions for this.”

Paul Driessen
Senior Policy Advisor
Committee For a Constructive Tomorrow
Policy Advisor, Energy and Environment Policy
The Heartland Institute

“The root of this scandal is not about the ‘what,’ but about the ‘why.’ Over the decades, EPA’s primary mission has morphed from preservation of the environment and protection of human health into preservation of the EPA and protection of its funding. In that context, the agency cannot allow the story of the ‘great clean up’ – America’s incredibly successful efforts to drastically reduce air, water, and ground pollution over the last 50 years – to be become part of our national narrative. The EPA needs a continuing crisis, or rather the appearance of a continuing crisis, in order to justify its self-proclaimed mission and funding.

“Pretending to practice science by exposing ill-informed test subjects to harmless concentrations of air pollutants and then twisting logic into knots by claiming those subjects were not harmed even though the pollutant concentrations were harmful and thus justified new regulations is par for the environmentalist course. Like any creature, EPA’s top priority is self-preservation. Thus almost any measure, no matter how ridiculous or unethical, can be justified in the agency’s eyes if that measure serves what it perceives to be the greater good.”

Richard J. Trzupek
Policy Advisor, Environment
The Heartland Institute

“It is very simple: EPA is either lying or it sponsors deadly human experiments. Either this is just another example of agenda-driven ‘findings’ or EPA is channeling Dr. Mengele. Which is it? If NAS is to have any credibility, this question must be asked and answered.

“I also urge Congress and state legislatures to demand an answer from EPA. Our elected representatives must stand up for the people.”

Bette Grande
Research Fellow, Energy Policy
The Heartland Institute

Ms. Grande represented the 41st District in the North Dakota Legislature from 1996 to 2014.

“Life is a risk. The human mortality rate is 100 percent. Obsessing over the safety of low or dubious risks is a delusion. Diverting limited resources and imposing costly regulations to address such risks to the neglect of more certain and serious ones is inexcusable mismanagement. Firing of those responsible would be both eminently deserved and serve as an effective deterrent to such maladministration in the future. To just apply another coat of whitewash or impose some quickly forgotten token disapproval will only assure further malfeasance and take the national economy one step closer to a national Darwin award.”

Walter Starck
Policy Advisor, Environment
The Heartland Institute

The Heartland Institute is a 32-year-old national nonprofit organization headquartered in Arlington Heights, Illinois. Its mission is to discover, develop, and promote free-market solutions to social and economic problems. For more information, visit our website or call 312/377-4000.

Article Tags
John Dale Dunn, M.D., J.D., is an emergency physician in Brownwood, Texas. He is board-certified in emergency medicine and legal medicine and has been an inactive attorney for 35 years.
Joseph Bast is a Senior Fellow at The Heartland Institute. He cofounded Heartland in 1984, serving as executive director then as president & CEO until January 2018. His research and writing focuses on climate change and energy policy. @JosephLBast
Paul Driessen is a senior policy advisor with the Committee For A Constructive Tomorrow (CFACT) and the Center for the Defense of Free Enterprise.
Richard J. Trzupek is a chemist who has been employed as an environmental consultant to industry for more than 25 years.
Bette Grande is a State Government Relations Manager at The Heartland Institute. Prior to coming to Heartland, she served as a North Dakota state representative from 1996–2014, representing the 41st district. @BetteGrande
Walter Starck is one of the pioneers in the scientific investigation of coral reefs. He grew up in the Florida Keys and received a PhD in marine science from the University of Miami in 1964.

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