I am Dr. XXX, an Anesthesiologist practicing in North County. In a previous life I worked under Surgeon General C. Everett Koop in the Office of Disease Prevention and Health Promotion (ODPHP) as a health risk analyst. I am also a member of the World Wildlife Federation and the Sierra Club. We have a friend in common in XXX, so you can verify with him who I am.
I have been following CARB’s effort to force owners of commercial diesel vehicles to retro-fit these vehicles with incredibly expensive “smog” equipment, and after reviewing the studies that Ms. Nichols uses to say these measures will save lives ( written by a CARB staffer with a bogus Phd), I am appalled at the shoddy science. These rules will not effect me, nor am I a paid hack for some special interest group. I am a Physician Scientist that is also an automotive enthusiast, so I believe I have a valuable and unique insight on this situation. I applaud CARB for it’s pushing of Manufacturers to produce better vehicles. The cars of the past 3 years are dramatically better than anything from the 70’s and 80’s, and CARB mandates are a big part of that improvement. But this switch to penalizing end users of already CARB certified vehicles, which will knowingly cost people their jobs, is draconian at best, especially when the expected benefit is non existent and the human toll is very real.

Please consider running my response to Ms. Nichols editorial piece of 11/05.

CARB’s 3% Solution

The California Air Resources Board (CARB) is pushing through Diesel emission regulations which will force California taxpayers and small businesses to pay billions of dollars to hopefully remove 3% of the dust in California’s air. The other 97% of this dust, called PM 2.5 ( particulate matter 2.5 micron), will still be with us even after this massive expenditure on pre-2007 Heavy Duty diesel vehicles. Board member’s, such as own Supervisor Ron Roberts, relied upon a report to justify this expenditure that was written by a CARB staffer that lied about having his Phd. “Dr.” Tran’s report relied upon outdated studies of railway workers from the 1950’s, and completely ignored current EPA studies which clearly show NO correlation to premature death and diesel emission PM 2.5 exposure in California- none whatsoever. I can only conclude that “Dr.” Tran told CARB what they wanted to hear to get his job, then wrote a report he thought they wanted to see to keep his job. But in his defense, ignoring EPA studies does seem to be part of the culture among the permanently appointed CARB Science Review Panel. These folks are supposed to be rotated out and have new appointees every 3 years, but it is the same folks for the past 20 years.

Ms. Nichol’s rightfully pointed to CARB’s expert hand in forcing manufacturers to push forward better engine technology since the 1970’s, when she was first Chair. Creating ever cleaner future emission standards for manufacturers to meet became the model for the rest of the world. Manufacturers responded by paying the “upfront costs” and we now have much better vehicles today. But CARB’s new tactic, of retro-actively creating tougher emission standards for vehicles already in use makes end users responsible for finding the “best available certified technology” to meet these standards. Many vehicles have no retro-fit kits available, and the ” up front cost” of retro-fits are ridiculously expensive. The retro-fits actually increase the amount of diesel used to get the same work done. How is that helping global warming? Where is the “better energy efficiency” in that? Is this what the NRDC and the Sierra Club really want?

The cost of these regulations are already being born by the California Taxpayer in several ways. For several years State bonds from Prop 1B have been for sale to raise money for school districts to retrofit buses. ARB “allocated” $192 million of these funds to districts to pay for the costs, but only $17 million has actually been paid out, because no one is willing to buy our State’s Bonds.. (http://www.arb.ca.gov/bonds/gmbond/docs/2009_05_20_external_prop_1b_funds_distribution.pdf)
Small business fleet owners are as strapped for cash as the State, so many will be forced to move out of California or just close up for good, because they cannot afford these retro-fits, and the credit market is non existent for this non productive expenditure. There is obviously no money for Ms. Nichol’s 3% solution, but she wants it anyways.

“Dr.” Tran’s report is absent analysis of the health impacts of the certain job losses these regulations will bring. HIgher morbidity and mortality rates among the jobless and their families is an outcome that is documented daily in the Emergency Rooms across our State- which are already overrun with uninsured, unemployed Californians. Taxpayers will end up footing those bills as well, to say nothing of the human toll. If the point of the regulation is to improve the health of Californians,
Remember this is all part of California’s insatiable appetite on AGW. The bottom line, these vehicles as equiped will use much more fuel negating the benefits of the laws purpose. Is everybody going mad on this issue?