Comment Log Display

Dear Sir or Madam:

CARB has implemented a voluntary survey to establish an inventory
of diesel emissions. CARB knows that this survey is inaccurate and
has used a 28% estimate of under-reporting. The data obtained by
voluntary surveys is not accurate, and it is impossible to estimate
accurately what the “real” numbers are. CARB is using and arbitrary
percentage (28%) to estimate what the actual data should be. This
is not a scientific use of statistics; one cannot determine any
voluntary survey to be an accurate sample of the population. It is
unethical to use this data to implement any kind of regulation. We
demand that CARB suspend the implementation, and rule-making
processes of all PM2.5 regulations until and accurate emissions
inventory number can be obtained from the Franchise Tax Board,
which maintains data for every diesel sale in California.

Hien Thanh Tran was the lead scientist on the study of “Premature
Mortalities from the exposure of PM2.5”, which is the basis for the
PM2.5 regulations. He claimed to have a PhD from UC Davis, when in
fact, he had a mail-order, fraudulent PhD from a fake university
that lists a UPS store as its address. We demand that CARB suspend
the implementation and rule-making processes of all PM2.5
regulations until a new study can be completed, peer-reviewed, and
is made available for public comment. 

Furthermore, there is discussion within the scientific community
regarding whether or not diesel is the largest emitter of PM2.5.
Frederick W. Lipfert, in the Symposium on PM2.5 and Mortality
presented on the 26th of February 2010 that no single source emits
PM2.5, but rather PM2.5 particles come from many sources, which
cannot be identified directly. In the same presentation, Lipfert
also held the conclusion that national studies cannot be applied to
California where pollutants and populations differ from states in
the nation.

CARB does not have accurate data regarding how much PM2.5 is
emitted in California. CARB does not have any conclusive study
linking health risks to exposure of PM2.5. CARB does not have any
conclusive study that suggests diesel emissions are responsible for
the majority of PM2.5 pollution. 

CARB has misused public money during the course of its writing and
implementation of diesel PM2.5 regulations through fraudulent
actions of its employees and possibly some board members. CARB has
misused tax-payer money by creating regulations before it has
obtained accurate data. Especially in the current state of the
California budget, CARB must utilize public funds in a more
responsible manner. Furthermore, CARB must recognize that
California businesses are in a time of extreme hardship because of
the recession. Though the members and employees of CARB have not
received any pay-cuts, the private industries in California have.
California cannot afford to lose jobs and businesses because of
unnecessary regulations. We demand that CARB suspend all
rule-making processes and implementation of PM2.5 regulations until
all the data has been collected and the studies have been
completed, peer-reviewed and commented upon by the stakeholders.


Sincerely,


Justin D. Young