StratComPa Consulting Services, Allentown, PA
Susan Mickley presented at the Schnecksville DRBC hearing calling for the DRBC to stop using junk science to try to pass a permanent fracking ban.
It is a safe bet that virtually all epidemiology-based federal regulatory efforts over the past 25 years or so may be considered as “fake science” or “junk science.” This is because federal agencies, especially the EPA and the DRBC’s current regulatory efforts have taken actions or issued regulations based on the statistical noise that is weak association epidemiology. This “fake science” should be held up to new robust federal epidemiology standards, and then validated or discarded based on its actual merits.
The data used in epidemiology studies is often of such poor quality that epidemiologists refuse to share their data with independent researchers for purposes of replicating and verifying results, known as Peer Review, which is a tradition fundamental to the scientific method.
The first effort to issue standards for interpreting epidemiology studies was articulated by famed British epidemiologist Sir Austin Bradford Hill in 1965. Hill almost uncannily foresaw the most common abuse of epidemiology we see today ⎯ i.e., inappropriate reliance on weak statistical correlations (also called “weak associations”) that likely reflect only poor data quality or chance, versus meaningful results.
The adage “correlation is not causation” should come to mind here. Not only is the adage true, but also weak correlations (or weak associations) never portend causation. Weak associations are just meaningless, statistical noise. There is not a single example in the scientific literature of a weak association epidemiology study whose reported association turned out to be scientifically valid.
Regulatory-happy federal agencies often disregard Hill’s standards and misinterpret statistical noise as cause-and-effect relationships in order to justify their (over)regulatory agendas. Though the federal courts have received some guidance on the interpretation of epidemiology from the National Academy of Sciences, federal regulatory agencies have remained oblivious and their misuse and abuse of epidemiology is ongoing.
Epidemiology has been grossly abused by regulators and university researchers for so long, the vast majority of epidemiologists no longer care whether their work is charitably described as “garbage-in, garbage-out.” That situation may be fine for agenda-driven regulators and non-science-based Interest Groups like we see here today but it is a terribly destructive situation for the economy, taxpayers and science and sets a dishonorable precedent against all development and industry.
This process could easily be compared to the Salem Witch Trial with the O&G industry and its workers as the responsible citizens being convicted by mass hysteria.
Real world results trump fake science every time. You have real world proof in the Susquehanna River Basin right next door that natural gas development and production can be conducted in a safe manor without harming public health or water. Stop relying on junk science to overregulate citizens in the DRBC and targeting a specific industry for this overregulation.
Editor’s Note: Sue Mickley informed us we should give credit to Steve Milloy, MHS, JD, LLM for most of the writing, as they were excerpts from his petition to D.C., A Petition for Fact-Based Regulation. He is the author of Junk Science.