Citizen's Independent Review Board 1/28/98
Quotes from the Scientists who reviewed the Dammes and Moore Report:

Dr. Jerry Wyss:"Frankly , after reading the report, I was first struck by the thought that I had been sent the educational brochure by mistake. The report is so imprecise in its explanations of its methodology and draws so many unsupported gratuitous conclusions that it seems more like a Public Relations press release than an actual scientific report.....It is impossible to determine the validity of the analysis because it is not clearly defined, its appropriateness for this data base is not supported, it is not consistently applied, and it doesn't appear to draw meaningful or valid conclusions.

Dr. Robert Howd: The data made available in this report are inadequate to support any conclusion as to the impact on emissions through the use of tire- derived fuel.

Dr. Richard Satterlie: Lack of knowledge concerning the proportion of tire fuel to primary fuel is, in itself, a fatal flaw in the report. Since the report pools such a variable data set, and the standard deviations are absolutely huge, statistical significance in any test is a virtual impossibility. Therefore, across-the board approval based on the report would not be a scientifically sound action, and could be quite dangerous for some population centers.

Dr. Paul Okamoto: Although the data in Table 4-1, on which the D&M report is based, are voluntary submissions from facilities with vested economic interests in promoting tire burning, no attempt was made to determine whether or not the data is unbiased. However, even if unfavorable data were not withheld, the quality of the data in Table 4- 1 is so poor that any relative comparison of toxic emissions with and without TDF, based solely on Table 4-1, will be statistically meaningless. To make matters worse, D&M assume that all the parameters used in risk assessment are the same for the baseline and TDF condition, and that the only difference is the emission rate. There is no evidence that this key assumption is true. 


Dr. Stephen Casey: I regularly review research reports submitted for publication in reputable scientific journals. This report simply does not (underlined twice) provide a scientifically-derived answer to the hypothesis (questions) presented at the outset. The study is such that no(underlined) valid and reliable conclusions can be drawn from the results.

Dr. Jack Peters: The Board should hire an independent group like SRI International or the like to evaluate this report. I strongly recommend that Dames and Moore change their name to Dames and Less.

Dr. Neil Carman: As a state official who reviewed stack performance tests for twelve years, the Dames & Moore report would not be considered acceptable to determine compliance status, take enforcement action by issuing violations of permit conditions, or be used in a lawsuit by the state attorney general. To be acceptable, it would be necessary to review the whole stack test report of all 29 used by the Dames & Moore. But it would not be accepted in court to confirm violations or compliance status!
And not acceptable for permit approval either.

FInally, the D & M report has reached conclusions that are possible essentially by carefully designing its approach, and is weighted in reaching conclusions of transparent safety to support the use of TDF in California. The report's conclusions simply demonstrate how data can be used to support whatever conclusions one might want to write, but they are certainly not based on statistically significant correlations. Review of TDF related emissions from several tests reviewed by Dames & Moore yield different conclusions challenging the transparent safety opinion in this report.