Talk:2008 California Statewide Truck and Bus Rule

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Article Feedback
This article is still being revised and expanded and should be completed by May 10, 2011. Please feel free to provide feedback and comments on this page so we know how it can be improved. Thanks! User:Elsnthesea (User talk:Elsnthesea) California Dump Truck Owners Association 334 N. Euclid Avenue, Upland, California 91786 (909) 982-9898   Fax (909) 985-2348 web: cdtoa.org

April 27, 2011

California Air Resources Board Clerk of the Board P.O. Box 2815 1001 "I" Street Sacramento, CA 95812

Subject: PM2.5 SIP – Why Didn’t EPA Calculate a Separate and Exact Cancer Risk from Diesel Emissions if it so Dangerous?

California Air Board Members and Staff:

As an industry totally subjugated to CARB diesel engine emission science and regulations dating back to at least 1998, we are interested as to why the EPA released its National Air Toxics Assessment (NATA) Friday, March 18, and they have not or will not calculate a separate and exact cancer risk from diesel emissions when it is as supposedly deadly as CARB science and researchers claim? Today, the CARB Board is being tasked with potentially approving a PM2.5 standard that is lower than the existing standard while the federal standard is more than reasonable at this point. The NATA was interestingly released two days after the CDC made public its annual U.S. mortality report, titled Deaths: Preliminary Data for 2009. The NATA report draws on 2005 (six-year-old, pre-recession) data to examine potential health risks from airborne toxic air containments (TAC) and vaguely concludes that vehicle emissions – including diesel exhaust – pose “significant” health risks, even though the report added that U.S. industries’ emissions of airborne toxics from industrial and mobile sources fell more than 42% between 1990 and 2005. This is all according to an updated computer database released on March 11 by U.S. EPA. Our industry has now seen all the epidemiologically studies, even those not favored or cherry picked by CARB. We hold firm that the true studies, especially those specific to California do not support these CARB conclusions. We have to also note that new diesel engines are among the cleanest and greenest – cleaner than even gas engines – and diesel emissions are already heavily regulated to achieve public health goals well into the future. If the EPA with a $10-billion budget can’t scientifically make this conclusion, how did CARB 13 years ago do it? In fact how does CARB justify any of their regulations of diesel emissions when no other state and even the federal governments EPA can’t do it? The EPA assessment is now being looked at closely by our industry. In it, the EPA noted that “all Americans have an increased cancer risk of greater than 10 in a million or 1 in 100,000 because of airborne toxics.” To put that in context, EPA toxics regulations are drafted for substances found to present a cancer risk to greater than 1 in a million. “This means that, on average,” EPA wrote, “approximately 1 in every 20,000 Americans have an ‘increased likelihood’ of contracting cancer as a result of breathing all air toxics (not just diesel emissions) from outdoor sources if they were exposed to 2005 emission levels over the course of their lifetime.” According to this EPA NATA report, this equates to 50 in every million people having an increased “likelihood” of death by diesel emissions related cancer. Typical of EPA and CARB science, the report does not state whether there is any direct scientific proof that diesel emissions “cause” cancer. According to the CDC report released in late March, there were a total of 1,736 malignant neoplasm’s (all cancers) deaths in the U.S. per 1 million in 2009. The EPA’s report implies that as much as 3% of the population has an increased likelihood of cancer death caused by “air toxics,” but there is no mention of diesel emissions. Of course, the CDC does not identify diesel or vehicle emissions as a separate cause or sub-cause of cancer deaths within their report. There are approximately 153 causes and sub-causes of death in this report. Specifically, the EPA report highlighted two substances in vehicle emissions as being particularly dangerous: formaldehyde and benzene, as well as diesel exhaust in general, with its 200-plus components, but never makes a final scientific determination.

Contrary to these exaggerated cancer and death claims coming from EPA, the CDC report showed that life expectancy in the U.S. has hit another all-time high, for the 10th year in a row, up to approximately 78 years and two months. In addition, about 36,000 fewer people died in 2009 compared to 2008, and the infant mortality rate hit a record low of 6.42 deaths per 1,000 live births. This translates to a 3% decrease from the year before. The report also noted that for all three of these primary causes of death, each has decreased from the previous period, some significantly. The primary causes are diseases of the heart, which dropped 3.7%; malignant neoplasm’s “cancer,” which dropped 1.1%; and chronic lower respiratory diseases, which dropped by 4.1%. So, why didn’t EPA calculate a separate cancer risk in their report from diesel emissions? The reason, according to the EPA, is that no specific unit risk estimate is available to do so. What, they can not scientifically determine a specific unit risk, but CARB can regulate thousands of businesses here, under the SRP determination that diesel emissions “may” be a toxic air contaminants? Instead taking the typical non-scientific leap of faith, EPA focused on the effects of diesel soot or particulate matter on respiratory problems and not cancer directly. There are differences, big differences. The report aggressively attacks diesel as an evil substance but does not differentiate between clean, ultra low-sulfur diesel (ULSD) and new technology diesel engines from older diesel formulations and engine technology. It’s just all bad, politically speaking! The report ackwardly states that, “EPA has concluded that diesel exhaust is among a variety of substances that ‘may’ pose the greatest risk to the U.S. population,” the agency said. Greatest risk of what? Many industry associations, groups, and those most affected by these absurd claims question EPA’s calculations. And while EPA did not calculate diesel exhaust’s cancer risk, not surprisingly, an environmental group called the Clean Air Task Force (CATF) has – with, of course, the help of CARB. Yes, the Clean Air Task Force (CATF) combined the confusing NATA data with the diesel cancer risk factor developed by the Hien T. Tran types within the California Air Resources Board (CARB) and found it to be three times greater than the risks of all air toxics tracked by EPA combined. Anyone who has recently dealt with CARB knows it deservedly has no scientific integrity or credibility whatsoever and is far more activism- and survival-focused than science-based. To utilize anything from CARB is absurd. The Clean Air Task Force (CATF) is a Boston-based nonprofit established in 1996, basically another lobbying non-profit. Yes, CATF, in their separate study with the help of CARB, found that the average lifetime cancer risk from diesel exhaust to be 159 times greater than EPA’s acceptable one-in-a-million cancer risk standard for air toxics. Diesel industry groups are pushing back against the EPA assessment and the environmental group’s political science study. The CATF study is so implausible, it is a joke! Allen Schaeffer, the executive director of the Diesel Technology Forum (DTF), said NATA is based on 2005 (old) data that does not take into account major strides made by the diesel industry to clean up its fuel and engines. “A lot of these [claims] are very retrospective views,” he said. “In the case of diesel, it’s especially retrospective when you’ve had so much change so fast.” Specifically, Schaeffer pointed to developments since the 2005 diesel engine standards. New standards for both clean diesel and engine emissions, especially for particulate matter from on-and off-highway vehicles have been significantly reduced, Schaeffer said. Further, new diesel engines have near-zero toxic emissions. He pointed out that EPA failed to calculate a specific risk assessment for diesel exhaust because of the “complexities and uncertainties” of evaluating the toxic values of diesel exhaust. Industry questions if the EPA, with all its resources and activist brainpower, can’t do anything to find the exact premature deaths and health risks, how can some environmental activist nonprofit organization with CARB’s guidance do it? They can’t of course – it is all junk science endemic of the problems we have within the public health sciences community, especially within the UC School System.

Sincerely,

Rob McClernon CDTOA President


 * Dear Rob - thank you for your input on behalf of the CDTOA. We've been looking for press releases and articles on organizations who have opposed this regulation and your note is extremely helpful. We will include information you provided in the article as we continue to expand it. User talk:Elsnthesea —Preceding undated comment added 18:48, 29 April 2011 (UTC).

this should be DYK eligible
This article should be eligible for appearing on the main page as a "Did you know" entry, if it is nominated it soon; it is supposed to be nominated within 5 days of being created or significantly (5x) expanded.

The instructions for nominating it are at Template talk:Did you know. Basically, all you need to do is take this code if you created a new article:

or this code if you expanded it

and write the hook, a concise and interesting bit of info from the article beginning with "... that" and ending with a question mark. The info from the hook has to be present in the article and supported (in the article) with a citation. Someone will double-check to make sure the source says what it's claimed to say.

Once you've come up with a hook, fill in your username as the author and fill the title of the article, then add the above code, including your hook following the "hook=" part, to the top of the appropriate section for the day the article was started on the DYK template talk page. The code will produce an entry formatted like the others. After that, just keep an eye on the entry; if anyone brings up an issue with it, try to address it. I'll keep an eye out as well. If everything goes well, it will appear on the Main Page for several hours a few days from now.

--Sage Ross - Online Facilitator, Wikimedia Foundation (talk) 01:37, 27 April 2011 (UTC)

Peer feedback
Hi Sonam and Elyane! Your article looks good and it's interesting! You will need to fix your references so that the same ones aren’t listed twice at the bottom.

The background section seems a bit long. This isn’t absolutely necessary but maybe you could divide part of it into a subsection, such as Goals or Savings or Projected Achievements for part of the second paragraph.

Under Regulation, you can list out the 3 options with one option on each line. Look at the format of ours. This just makes it easier to read.

Minor grammatical errors: Under “Reporting training” add comma’s after the dates. By April 29, 2011, Also by April 29, 2011,

Last paragraph, first sentence under health impacts. It should say “with”.. The areas of California “with”...

Slum125 (talk) 06:54, 3 May 2011 (UTC)

Peer Review
Hey Elyane and Sonam-  The article looks absolutely fabulous; it’s quite insightful with well documented information. I only have a few suggestions about the article.   Other than that I think that your hard work has really shown through in this wiki article. Kkihara (talk) 21:13, 3 May 2011 (UTC)
 * I think that adding a small introduction before the background will set the tone for the rest of the article and give readers a fast comprehensive look at what type of information is going to be presented.
 * I also agree with Steph, I think that adding subsections in the background will break-up the bulk of the information and allow readers to absorb the material in categories instead paragraphs.
 * The idea of listing information is also another suggestion. I think that readers want to pull the information they need from wiki articles in the most efficient way.  A list will help readers find the information quickly.

Feedback
Overall, I find the article to be informative and well written. There are some ideas I would like to share with you to improve the overall layout of the article.

- You need to redo the reference section by combining the same reference as to prevent the same reference listed multiple times. If you want to reference something start by typing this code:. Next time you want to use the same reference again, simply just type the code that's it! The reference will appear as superscript letters proceeded by the name of the reference.

- The section titled, "Fleet Compliance Assistance Tools" could be combined as a subsection under reporting. Based on the reading they seemed to relate to one another and I also think it will give your article a better overall look.

Hope this helps and good luck with class! Hle37 (talk) 02:23, 4 May 2011 (UTC)hle37


 * To re-use a ref, do e.g. the first time and to re-use it, without the citation or final . In the re-use, the / is crucial. I insert a space before / so I can easily see it, but that's because my eyesight is lousy. --Philcha (talk) 07:33, 4 May 2011 (UTC)
 * PS to make the refs show as wiki-markup rather than real refs, I used  etc. - look at it in edit mode. --Philcha (talk) 07:33, 4 May 2011 (UTC)

Suggestions
Good start! Here a few suggestions:

You may want to consider renaming the article to California Statewide Truck and Bus Rule since that is how you describe the topic in the lead paragraph. In general, the topic should be mentioned at the very beginning of the lead paragraph, but you begin with the date and agency name rather than mentioning the topic itself. Link early on to the basic terms like "diesel", "truck", "bus" and "gross vehicle weight rating", being sure that the article you link to best describes these concepts. The lead itself should be a brief overview of the topic, including an assertion of notability, and I am not sure that the level of detail regarding the implementation dates belongs in the lead paragraph.

Please review the section of the manual of style called Manual of Style (abbreviations). I recommend spelling out abbreviations such as "CARB" as "California Air Resources Board" because this is a jargon term that may be unfamiliar to many readers. We don't need to save paper on Wikipedia, so unless an abbreviation is recognizable to almost all English language readers, the full term should be used.

Notes such as "(More information coming soon)" are not appropriate in an article in the main Wikipedia space, although they are fine for articles in sandboxes. Please focus your immediate attention on expanding such sections, and removing such informal tags. In this case, the neutral point of view requires an accurate characterization of the opposition's point of view, even if we as environmentalists may differ personally. You reference a press release issued by the opponents. This is a primary source. Coverage of their opposition is secondary sources (independent newspapers for example) would be far better.

Link to Best Available Control Technology.

The phrase "by achieving PM or NOx reductions" is jargon, and the relevant terms should be spelled out and Wikilinked for the average reader who may be bewildered by this terminology. Read and edit your entire text from the point of view of the average reader who does not have expertise in the area.

"Records must be kept" What sort of records? Is record-keeping a concern of the opponents?

"Vehicles that are exempt from the regulation include:" Elaborate and Wikilink this section as appropriate. Some of the examples may not be clear. For example, what constitutes an "historic" vehicle under these regulations? What, for example, is title 13? There are many possible "title 13s".

Expand your external links to give the title of the website, rather than the bare url.

More to come. ..