Letter to CARB Executive Officer James Goldstene and Board Members-----Original Message-----
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Sent: Wed, Mar 24, 2010 10:39 pm
Subject: CARB AB 32 Economic Study
Dear Mr. Goldstene,
I am writing you today regarding the recent release of CARB's most recent Economic Study of the impacts of AB 32. I must say that I have never been more frustrated and insulted by the blatant arrogance displayed by CARB regarding the REAL economic impacts that's CARB's implementation of AB 32 will have on the State of California.
Time and time again, CARB refuses to acknowledge the economic devastation that these regulations are having on the citizens of California. There have been countless studies conducted by independent organizations & Universities that show the true impact that CARB's regulations will have on this state, yet CARB continuously disregards any study that does not provide data that will promote their agenda. No matter how qualified the Author's of the reports are, CARB automatically disregards the study and tries to discredit the data just because it does not come out the way the Board Members think it should. The fact that there have been studies done by CSUS, UCLA, and a number of other CREDIBLE, UNBIASED organizations that all come to the conclusion that CARB's regulations WILL KILL hundreds of thousands, if not millions, of jobs in California cannot just be disregarded because it does not sugar coat the devastating reality of CARB's actions.
The truly insulting part of this is that CARB just continues to pump out these reports & studies that have been discredited every single time they are analyzed, whether it is because of unqualified employees conducting the studies, "Independent Scientists" being cherry picked by board members, "Peer Reviewers" being cherry picked by board members, "Peer Reviewers" being asked to review reports that are based on their own analysis, data being "Mined" in order to throw out any data that does not match the desired results of the board, etc. The incestuous nature of the "Reports" and "Analysis" that come from CARB is a very troubling problem, especially considering that the livelihood of over 1,000,000 California citizens rests on the accuracy of these studies.
The fact that the only time there is a study released that concludes that CARB's regulations will have a positive effect on jobs and the overall economy of California is when that study is done by CARB. Every single other study that has been done has clearly stated that these regulations will in fact kill hundreds of thousands of jobs, increase energy costs, increase food costs, drive thousands of people & businesses out of State, prevent new businesses from coming to our State, and do irreparable damage to California as a whole. If CARB is truly conducting their studies with the utmost integrity, then why do the results of the CARB studies ALWAYS come to conclusions that are the exact opposite of those studies conducted by qualified independent researchers? Why is it that CARB always understates the damage that is being done to the people of California and over exaggerate the POSSIBLE benefits that might take place?
We have stood in from of you and every other board member countless time over the last few years and have begged you to listen to us. We told you in the beginning that these regulations were not financially feasible, and that was when the economy was doing alright. CARB did not listen and you continued to do precisely what you wanted to do. When the rules started to be phased in and the economy started to free fall, we stood in front of you and told you once again that we simply have no way of being able to afford the costs associated with these regulations, and once again, CARB did not listen and continued to do as they pleased. Companies started going bankrupt, closing their doors, leaving the state, laying off long time employees, and we stood before you and begged you to stop and take a look at what these regulations were doing to us, yet once again CARB marched on. Now the few small companies that have managed to survive to this point have stood before you and pointed out that everything we said would happen did happen, and continues to happen, and what does CARB do now that we are on our knees begging CARB to not take away our only means of supporting our families? You parade out another incestuous studies compiled of "best case scenario" benefits and "little to no" damages, as if that is supposed to make it OK that we are being offered up as the sacrificial lambs. Talk about rubbing salt in our wounds.
The parts of your analysis that you continuously highlight is all of these "Green Jobs" that are going to be created. It makes me wonder if you have ever stopped to look at areas that have attempted similar "Green" initiatives. For example, reports from Spain have stated that for every 1 "Green Job" that was created by Spain's government regulations, their Country LOST 2.2 private sector jobs. To make matters even worse, only 1 out of 10 of those "Green Jobs" were PERMANANT. That means that for every 1 permanent "Green Job" that was created, there were 22 jobs LOST. The fact that a couple of "Green Jobs" might eventually be created does absolutely nothing for the people who are losing their jobs because of CARB. The people who are losing their jobs are Laborers, Operating Engineers, Truck Drivers, Etc., and none of those "Green Jobs" will be going to these people. These people have specialized talents, which don't include pointing remote control mirrors at Heliostats or harvesting algae to make bio-diesel. These men and women drive tractors, dig trenches, pour concrete, drive trucks, etc. and they do a damn good jobs to. These new green jobs will be going to people that currently live in other states. The companies that have developed these technologies are from other states and countries. All of this means that CARB is willing to sacrifice the current jobs of 22 Californians in order to create 1 job for a person that does not even live in this state. Those new "Green Jobs" are going to be producing energy that costs well above the current market rate for energy, which means us 22 people that lost our jobs will also be forced to pay more for energy so the extreme markups on that energy can be sent to a company in Europe so they can have record profits. I'm pretty sure those 22 people are not going to be happy about that, and there is no reason why they should be. I know that many of the CARB "Green Job Creation" numbers are over inflated due to speculation about future technology being invented, but you cannot put millions of people out of work in hopes of something being invented to offset the damage. If we had stopped building highways 20 years ago because we thought someone would have invented a flying car by now, we would be pretty screwed now wouldn't we. Do not make that same mistake with these regulations. CARB needs to concentrate more on not killing jobs that really exist right now, rather than betting everything that "Green Jobs" will save the day.
The fact that CARB has made no attempt to sit down with the scientists who wrote those other studies and figure out why there is such a big discrepancy is just proof that CARB is going to do what they want no matter what and they will just forge the science as they see fit. The reason why CARB's studies are always so different from the other studies is simple, "Garbage in, Garbage out." CARB wants to be able to parade around these studies that make then look like the saviors of the Earth, so they just plug in hyper inflated job creation numbers and miniscule job loss numbers and VIOLA! A study that fits CARB's agenda just right.
Mr. Goldstene, I am begging you to please pay attention to these other studies, they contain a lot of valuable information. CARB cannot simply just manipulate analysis over and over again, have it reread by a few of their friends, then expect us to believe the Official CARB study over the 10 Independent Studies that have much different conclusions, with more credibility. I think credibility is one thing that CARB has lost sight of since being granted Carte Blanche from AB 32. The "Just Trust Me" method of justifying actions may work in Kindergarten, but it does not work when your actions are going to devastate Millions of people. Please do not continue to only rely on studies that are created with the end result known well before any data analysis has been done. Please work with the Authors of these other studies. Plug your information into their models and see what the results are. Compare CARB's input data to the other Authors input data and see if it is the data being input that is creating the discrepancies or if it is the statistical model that is being used. Rather than just having a pointless war of words, try to work together. See if you can come to a general consensus about what the input data should look like, or even develop a range with one end being their data and the other end of the spectrum being CARB's data. With all of the problems surrounding the legitimacy of the science and ethics behinds CARB's studies, there needs to be some sort of concessions made by CARB in order to ensure the public that they are not just manipulating data to back their agenda. Trying to circumvent critical data by having Board Members hand pick a few scientists to do a report, then hand picking the scientists to review it is not a satisfactory method of really addressing the differences in the studies. As any 6th grader can tell you, nothing about this most recent report, or any previously released reports, satisfies the scientific method. Aside from how the authors are chosen or how the analysis is carried out, the fact that the "Peer Reviewers" are hand picked completely discredits the process, especially considering the very few degrees of separation between the many of the authors and the reviewers. These studies should be done by scientists who are chosen by an independent organization, not the Board Members themselves. The peer review process should be open to any and all qualified scientists, not just some acquaintances of Board Members. Eliminating the nepotism from CARB studies would be a tremendous help in re-establishing credibility to the internal studies released by your organization.
The fact that CARB would rather try to disprove an overwhelming number of credible studies, and the direct testimony of the people who are in the trenches dealing with the consequences of CARB's actions every day, comes off as extremely condescending on the part of the Board and does not address the fact that these CARB regulations have gone for the jugular of all small businesses in California. We are being absolutely devastated and we are relaying all of this information to you along the way, and rather than work with us and try to really address the issues at hand, you try to come up with information that proves us wrong or tries to justify the sacrificing of our jobs because of the potential of jobs that may come in the future. This is not a responsible or acceptable method of dealing with this situation. There is absolutely no statistical extrapolation that you can show to a group of Operating Engineers, Laborers, or Truckers that is going to convince them, or any other reasonable person, that it is worth sacrificing 22 of their jobs in order to possibly create a job for 1 person they don't even know.
Please start working on coming up with some legitimate projections by working with the other Authors rather than trying to one up each other about who did a better job and why you are right and they are wrong. That does absolutely nothing to fix the real problems. I have lost count of how many studies have been released by CARB regarding AB 32 and the Diesel Regulations and then those studies being retracted, redone, or revised. Rather than trying to sneak some fictitious study by your critics, how about listening to us people who you are hurting. Sit down with us and really listen to our solutions. Sit down with scientists that have no ties to CARB or any Environmental group so you can get an honest analysis and conclusion. It is not the ideas from the extreme fringes of each group that are going to solve any of the current problems, you are going to have to listen to us people in the middle who have actually been in the private industry and have actually applied different business strategies, not just contemplated the pros and cons of different theories in academia.
A response explaining how CARB plans to move forward in dealing with the huge discrepancies in the available Economic Analysis of AB 32's effects on California, and also about what CARB plans to do to slow, or stop, the current hemorrhaging of jobs because of these regulations. I would assume that no public policy could be, in good conscience, made based on this recent study considering the inconsistency and what is at stake here, but I would like to hear it from you so I know for sure. Thank you very much for taking the time to read this e-mail, and I look forward to receiving your response.