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Comment 10 for Southern California Consolidation Project (socalproject2016) - Non-Reg.

First NamePatrick
Last NameFrost
Email Addresspfrost@ucla.edu
Affiliation
SubjectWhy I oppose the Recommendation for Consolidation Project
Comment
While it is clear that the ARB has made great strides in meeting
the air quality needs of Californians, there is a huge risk of
undermining these accomplishment by failing to recognize and
maintain the appropriate mission priorities and goals.  The ARB's
current focus on relocating their facilities is one such problem,
as allocating massive amounts of resources simply to gain "new
buildings and more space" do not reflect the ARB's core mission of
improving air quality and meeting mandated goals. I have reviewed
the statements and documents made by the ARB to justify these
expensive moves and find them problematic and unconvincing.  

For example, one factor cited in this move is that the ARB will be
better suited to building a world class research program that will
benefit if situated close to an academic institution.  This is
absurd on its face, as the ARB is a government agency that has
absolutely none of the rigorous academic and research checks and
balances.  Rather, I fear that the ARB would simply pick and chose
science that supports its own political mandate to advance the
internal goals of the ARB at the expense of real scientific debate.
 

I am a well published scientist with a Veterans Administration
funded laboratory who is also associated with UCLA.  When advocacy
government (as clearly the ARB has become) begins to "associate"
itself with science, it tends to ignore anything that goes against
its best interest and bias research to further its now ends. 

Thus, for these reasons, I would urge that the ARB recognize that
it fills an important role as a government regulatory agency and
NOT get entangled in trying to buff itself into a research
institute. 

That being said, it is also clear to me as an active researcher
that the government can form collaborative interactions with the
scientific and academic communities, but that these relationships
should be maintained as desecrate and independent entities, such
that one can either support or correct the other.  Moving the ARB
into an academic environment doesn't serve this purpose and blurs
those lines between regulation and science.

Next, the funding of this move is questionable. I find the
arguments that this move will have minimal financial impact on the
State to be unpersuasive and self serving.  At this time, the
financial health of California is poor and the clearly the money to
be spent on moving a perfectly good institution to another place
could be better used elsewhere. Especially since the major
rationale for this move is to burnish the academic credentials of
the ARB as opposed to actually address the air quality needs of
Californians.

Millions of dollars spent on moving to another facility while most
Californians struggle with health care costs (ironically put at
risk because of exposure to toxic air contaminants), housing,
transportation and daily living expenses seems cruelly insensitive.
 I would think that the ARB ought to worry less about putting its
name on new buildings and rather maintain its focus on reducing air
pollution, improving air and living quality and developing more
common sense regulatory policies.  

Finally, if the ARB has actually outgrown its space, then they
would be better served to find cheaper alternatives than moving to
Riverside or Pomona, especially since the only reason these areas
seem to have been selected is to try to associate the ARB with an
academic institution.

In summary, I would urge that the ARB take a closer look at what
exactly it hopes to achieve by making these moves, why they chose
the areas they did and make a stronger case for the use of State
monies which is really outside the primary mission goals of the
ARB.  Those millions of dollars could be much better spent to
upgrade current facilities, research could be outsourced, and the
ARB could focus on its duty to improve air quality.

For these reasons, I would be strongly opposed to these moves and
hope that the ARB reconsider.

Sincerely Yours

Patrick Frost, PhD
Greater Los Angeles VA Healthcare System
Department of Hematology/Oncology
Laboratory of Multiple Myeloma Research
and
Adjunct Professor
UCLA School of Medicine

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Date and Time Comment Was Submitted 2016-03-13 18:41:44

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