Clean Air Villain of the Month

December 2002


First Two-Time 'Winner' Seeks to Devalue Life of Seniors

(Washington, D.C.) - You might call him the regulatory Grinch that tried to steal Christmas -- and the rest of their lives -- from seniors.

We are referring to John Graham, the politically appointed boss of the White House Office of Management and Budget's office that oversees federal regulations.

Today we are naming Graham our "

Clean Air Villain of the Month

" for December 2002 -- making him the first two-time winner of this fame-for-shame award. 1 Graham earned this dubious distinction for muscling the U.S. Environmental Protection Agency to drastically reduce the agency's calculations of the benefits of clean-air controls. (Graham admitted he did this in an interview this week with the Washington Post.)

In the process, Graham has declared that the life of senior citizens is not worth as much as that of younger people. He has also given the lie to the Bush Administration's claim to support "sound science" -- because he has promoted a view that isn't sound science at all -- he is simply wielding a political axe aimed at helping corporate polluters avoid pollution controls.

Graham began this march towards ignominy in a presentation he made in October 2001 to the National Academy of Sciences. In that presentation, Graham asserted that EPA should not rely on studies that linked premature death to long-term exposure to fine particle soot (something EPA has done to calculate the benefits of most major air quality rules in recent years).

Graham also asserted that EPA should begin calculating the benefits of air pollution cleanup on the "quality-adjusted" years of life that might be preserved by cleanup. Put simply, the Graham method would assign a lower value to the life of seniors and those who are disabled -- since, in his view, the "quality" of their life isn't worth as much as that of younger, healthier people. His twisted view has its roots in the brutal world of ancient Sparta. 2

Significantly, Graham's presentation to the National Academy notes -- and apparently dismisses -- that one of the "limitations" of his method is that it "raises concerns about fairness to the disabled and the elderly."

Earlier this year, the National Academy published its own assessment of EPA's attempts to calculate the benefits of air quality controls. The National Academy flatly rejected Graham's call to ignore the link between premature death and long-term exposure to particle soot.

Undaunted by "sound science," Graham has worked behind closed doors to demand that EPA develop "alternative" ways of calculating the benefits of clean air controls -- including pretending there is no link between long-term exposure to particle soot and premature death. Graham also prodded EPA to adopt the anti-seniors "quality-adjusted" approach to measuring benefits.

Graham's machinations -- as one might expect -- lead to radically different results when it comes to calculating the benefits of clean air. In a recent rule affecting all-terrain vehicles and some other gasoline-based engines, EPA calculated the cumulative benefits at $77 billion -- but that number got chopped to $8.8 billion under the Graham alternative. (The standard EPA method valued a life at up to $6 million. "Accounting for discounting and lower-quality years later in life might bring this figure closer to $250,000 per QALY [Quality-Adjusted Life Years] saved," Graham noted in his presentation to the National Academy.) Applying the anti-senior Graham method led to similar reductions in the expected benefits of the Bush Administration's power plant proposal.

One question at this point is will Grinch Graham demand that his anti-seniors method become the standard, preferred way of calculating the expected benefits of pollution cleanup? The upcoming EPA proposal to clean up heavy diesel equipment and fuel could become an interesting test case.

Another question is whether groups representing senior citizens and the disabled protest this vicious assault, which is being cloaked in esoteric bureaucratic euphemisms.

Of course, what has being lost in this discussion is a different sort of bottom line -- that public health and environmental protection is a moral and ethical commitment. Unfortunately, Grinch Graham and the Bush administration don't appear to agree with that view.

1 Graham was also "Villain of the month" in October 2001 for attacking a proposed EPA rule on all-terrain vehicles and other engines. He later proved he deserved the award by weakening an already-anemic EPA proposal.

2 In ancient Sparta, unhealthy children were taken from their parents and left exposed on a hillside to die.