CARB science

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Posted by john dale dunn md on August 15, 2009 at 23:30:02

I am happy to contribute what I can to the debate and discussion. I am a 37 year physician and 30 year attorney, and I am writing here about misconduct in public health toxicology research that California Air Resources Board (CARB) promulgates to justify their overreach and new regs that will burden industry and commerce.

The bottom line is that CARB claims that they will prevent thousands of premature deaths in California that now occur becasue of particles in the air from engines. There are no thousands of premature deaths, in fact the studies do not show any deaths at all because they fail to achieve proof of any effect according to the rules on scientific evidence published in the Reference Manual on Scientific Evidence, published by the Federal Judges' Educational Center and available for free on line at their website or you can buy it for 17 bucks from West Publishing of Minneapolis.

The science that is used by the CA EPA and California Air Resources Board is public health research on populations across the nation. The studies include California, but are not California focused. They show very small effects on health that fail to meet rules of admissibility of scientific evidence in a court of law because in population studies one must show an effect of 100 percent increase in disease or premature death to even have threshold of proof. None of the CARB studies have that magnitude of effect.

In addition the studies CARB relies on fail to meet the evidence rules for proof of toxic effect because small particles are not uniform in chemical structure--varying from soot and smoke from fires and fireplaces to dust from agriculture and all told coming from 13 categories of sources.

of those 13 sources the EPA's own research shows that on road emissions from cars and trucks, gas and deisel is less than 5 percent of the total production fo small particle air pollution, dust from the world around us is the largest contributor. So the small particle burden is not homogeneous, and varies in chemical composition. Therefore there is no way that CARB is relying on good toxicology studies.

The rate of premature deaths in California is so low that no argument can be made that Californians suffer from any toxic exposure that impacts life span.

The cumulative effect of CARB regulatory aggression and scientific misconduct creates unjustified new regulations that damage and burden business and unjustified public concern.

Diversion of public resources to unnecessary new air pollution regulations will mean hardship for the public that will have a real impact on welfare and life expectancy.

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