Comment Log Display

On 1/13/2025 5:28 PM, ARB SIP Planning wrote:
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> John Dale Dunn MD JD
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> Diplomate ABEM, ABLM
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> Admitted but inactive, Texas and Louisiana Bars
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> Texas Courts Certified Mediator
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> Consultant Emergency Services, Peer Review
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>            
>                                                           401
Rocky Hill Road                                                    
                 Lake Brownwood, Texas 76801
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> Phone                                                            
                                                325 784-6697
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>                    E-mail jddmdjd@web-access.net
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>  
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> January 5, 2025
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> Ladies and Gents of the CARB and its researchers,
>
> I respond to the CARB invitation to a workshop public comment
session, apparently intended to explain and justify another
reduction in small particle allowable levels.  I am reminded of a
similar event in 2010 when CARB was engaged in a debate with
members of the scientific and business community in the midst of a
CARB campaign to show small particles were lethal and harmful and
CA must control small particle air pollution to reduce the deaths
and toxic effects. 
>
> CARB lost that debate when their all-star panel couldn't prove
its case.  They lost the debate because a bunch of us who know junk
science when we see it came to the party and showed up the CARB
shills.  However, not to be deterred CARB and its designated
science officials and operatives licked their wounds and
commissioned Dr. Jarrett and others to gin up another study to
prove they were right and the critics were wrong.  Jarrett did a
typical uncontrolled population study and data dredged
temporal-spatial data to get a small non-proof relative risk/hazard
ratio--it was a joke study that cost 750 K.
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> I am a physician attorney and I know how multiple sampling (data
dredging) in uncontrolled population studies can create
"associations" measured as relative risk.  I am familiar with CARB
scientist use of small associations from big studies  cobbled
together so that the researcher can claim a small p value and
sacred "statistical significance."   Jarrett et.al ginned up small
associations by data dredging combined with p hacking to produce a
hilarious repeat of other CARB studies, but the researchers proudly
announced that the study results were "statistically significant"
pretending that was the equivalent of material, relevant, competent
and probitive evidence.  The magic proposed was that statistical
significance is equivalent to reliable truth on the issue of
causation.  Stop the music--that is not so and everyone who reads
this email knows that it is not so. Even a college level student of
epidemiological methods would know what CARB was doing--big
uncontrolled studies, multiple sampling, p hacking, bragging on
inadequate relative risk results, Richard Feynman called it cargo
cult science.
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> Best part of the story is publishing results with confidence
intervals that included a RR of 1.0, the researchers putting
lipstick on a statistical pig.  
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> Here are the commentary and letters I wrote in 2011, not new
because CARB is still the same junk science research and 
policy/regulation making machine, popping out bad studies and regs
like a PEZ dispenser while beating the big scare drum:
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> ·       Critiques of Final Report for CARB Contract No. 06-332
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(http://www.scientificintegrityinstitute.org/JerrettCriticism102811.pdf)
> (http://www.scientificintegrityinstitute.org/Dunn060911.pdf) 
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> ·       October 26, 2011 Second Dunn Critique
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> (Summary read by Hank de Carbonel on October 28, 2011
(http://www.scientificintegrityinstitute.org/Dunn102611.pdf)
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> ·       June 9, 2011 verbal comments by Dr. Enstrom, Dr. Matthew
A. Malkan of UCLA, Mr. Brown,
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> and Dr. Dunn as read by Hank de Carbonel
(http://www.scientificintegrityinstitute.org/CARBRSC060911.mp3)
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> ·       October 28, 2011 verbal comments read for Drs. Enstrom,
Malkan, Dunn, Lipfert, and Fulks, and Mr. Brown 
(http://www.scientificintegrityinstitute.org/CARBRSC102811.mp3)
or(http://www.cdtoa.org/CARBdocs/2011-10-28-SRatCARBreJerret.MP3)
>
> In these commentaries I point out Michael Jarrett's team's
creative effort to do spatial-temporal jiggering and sampling to
produce small no proof but positive associations.  I think it a
shame and disgrace that CARB and its hired research operatives have
no respect for the rules advocated in the Reference Manual on
Scientific Evidence, published by the Federal Judicial Center that
advocates respecting the Bradford Hill rules on proving causation
and basic rules on how to manage and evaluate data. Small relative
risks in uncontrolled population studies are well known to be no
proof and legitimate epidemiology requires Relative Risks of 3 or
more as robust enough.  CARB continues to just pretend they are
sponsoring good science in the public interest--nonsense, they are
promoting junk science so they can promote regulations they want to
see burden citizens, business and industry. 
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> I know the well credentialed and educated readers of this letter
know the rules that they are violating by sponsoring and promoting
these enviro scare studies about killer this or that, including the
focus of this letter, CARB sponsored small particles studies used
to justify CARB's aggressive recommendations on small particles
regulations. How is it that the new small particle proposal and its
supporting science would be shown to fail with a letter I wrote in
2011--well because the CARB and USC small particle fanatics haven't
improved on their junk science methods and their treacherous
perfidious policy advocacy?
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> I would gladly show up for another debate to show that CARB
produces the same junk research now as it did more than 10 years
ago that I discussed in my letter of 2011 that details the same
criticisms and exposes the same silliness of today. CARB and its
paid "scientists" lost the old debate convincingly and the risible
Jarrett study that followed on was an effort to rehabilitate but it
came a cropper, another undisciplined effort to make small
particles out to be a lethal threat to civilization and the human
race.
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> Political tyrants can't let a scare/crisis go to waste.  The regs
proposed now are just as misguided and inappropriate as the ones
proposed in 2010.  The new ones will pile on more negative economic
impact and be evidence that CARB continues to be mendacious,
malignant, misanthropic and destructive in its regulatory conduct
and policies.   
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> I have no hope CARB and its scientists will withdraw from this
latest regulatory move; however a new administration in Washington
and a new EPA may be the therapy that people at USC and CARB need. 
I would skip a meal or two to help deliver that cure for CARB's
addiction to junk science and misguided policies. The addressees on
this email would be well advised to shut down the project to
promote new more stringent and certainly unnecessary new
regulations, retire to reconsider their scientific misconduct,
however if they insist they should be required to engage a debate,
not the usual sleep walking public comment event, and another
debate will remove all doubt that that CARB sponsors and promotes
junk science and bad policies and regulations because it is
motivated by perverse environmentalist ideological agendas. 
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> Set a date for the debate and remove all doubt about CARB
research's lack of scientific integrity.  It won't take me but a
few minutes to update my letter of 2011 since CARB still engages in
the same small particle research scientific fraud.  I may ask
cement pumper/writer-columnist Hank de Carbonel to read my updated
letter into the debate record so I don't have to endure the
depressing experience of spending time in a failing state that once
represented the American dream and success story. There was a time
in my life that traveling to CA was a pleasure.  No longer--CA is
failing fast, thanks to the apparatchiks and nomenklatura in CA
government and academia.
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                                 Cordially,
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>                                                                  
                                 /JDunn MD/  

-- 
John Dale Dunn MD JD
401 Rocky Hill Road
Brownwood, Texas 76801
(325) 784-6697