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Research Misconduct Complaint Against California State University, Fullerton

Professors Jane V. Hall and Victor Brajer

James E. Enstrom, Ph.D., M.P.H.

School of Public Health

University of California, Los Angeles

Los Angeles, CA 90095-1772

jenstrom@ucla.edu

(310) 825-2048

 

November 7, 2012

This document represents my research misconduct complaint against two Professors in the 

California State University, Fullerton (CSUF) Department of Economics: Jane V. Hall, Ph.D. 

(http://business.fullerton.edu/Economics/faculty-profile.aspx?ID=HallJane) and Victor Brajer, 

Ph.D. (http://business.fullerton.edu/Economics/faculty-profile.aspx?ID=BrajVicto). I am filing 

this complaint in accord with the CSUF University Policy Statement UPS 630.000 “POLICY 

FOR INVESTIGATING INSTANCES OF POSSIBLE RESEARCH MISCONDUCT”

(http://www.fullerton.edu/senate/documents/PDF/600/UPS630-000.pdf). Both the text and the 

included web links need to be read in detail in order to fully assess the content of this document. 

I allege that since 2007 Drs. Hall and Brajer have repeatedly engaged in the form of research 

misconduct that is defined in Section II.A.2. of UPS 630.000: falsification in reviewing research 

and in reporting research results, specifically, omitting data or results such that the research is 

not accurately represented in the research record. This complaint is based on four publications 

co-authored by Drs. Hall and Brajer since 2007 that have falsified the relationship between fine 

particulate air pollution (PM2.5) and total mortality (“premature death”) in California. These 

publications have been used to influence multi-billion dollar California air pollution regulatory 

policy, particularly regarding the California Air Resources Board (CARB) diesel vehicle 

regulations and the South Coast Air Quality Management District (AQMD) Air Quality 

Management Plan (AQMP) (https://aqmd.gov/aqmp/AQMPintro.htm). Both CARB and AQMD

implement costly and complex regulations that are largely driven by the National Ambient Air 

Quality Standards (NAAQS) that are set by the U.S. Environmental Protection Agency (EPA). 

The four CSUF-based publications that contain alleged evidence of falsification of research 

results are listed below, along with web links to the full publications:

Hall 2007. Jane V. Hall, Victor Brajer, and Frederick W. Lurmann.

“Measuring the gains from improved air quality in the San Joaquin Valley.” Journal of 

Environmental Management Volume 88, Issue 4, Pages 1003-1015 September 1, 2008.

doi:10.1016/j.jenvman.2007.05.002 Online June 21, 2007

(http://www.sciencedirect.com/science/article/pii/S0301479707001843) or 

(http://www.researchgate.net/publication/6247744_Measuring_the_gains_from_improved_air_q

uality_in_the_San_Joaquin_Valley)
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Hall 2008. Jane V. Hall, Victor Brajer, and Frederick W. Lurmann. “The Benefits of Meeting 

Federal Clean Air Standards in the South Coast and San Joaquin Valley Air Basins.” California 

State University, Fullerton, November 13, 2008, 108 pages 

(http://calstate.fullerton.edu/news/2008/091-air-pollution-study.html) and 

(http://business.fullerton.edu/centers/iees/reports/Benefits_of_Meeting_Clean_Air_Standards_11

-13-08.pdf) or (http://www.aqmd.gov/news1/2008/JaneHallStudy2008.pdf)

Hall 2010. Jane V. Hall, Victor Brajer, and Frederick W. Lurmann. “Air pollution, health and 

economic benefits: Lessons from 20 years of analysis.” Ecological Economics Volume 69, Issue 

12, pages 2590-2597 October 15, 2010

(http://www.sciencedirect.com/science/article/pii/S0921800910003277) or

(http://EconPapers.repec.org/RePEc:eee:ecolec:v:69:y:2010:i:12:p:2590-2597)

Brajer 2011. Victor Brajer, Jane V. Hall, and Frederick W. Lurmann. “Valuing health effects: 

the case of ozone and fine particles in Southern California.” Contemporary Economic Policy

Volume 29, Issue 4, pages 524-535 October 1, 2011

(http://onlinelibrary.wiley.com/doi/10.1111/j.1465-7287.2010.00240.x/full) or

(http://onlinelibrary.wiley.com/doi/10.1111/j.1465-7287.2010.00240.x/pdf)

(http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1931333) or

(http://dx.doi.org/10.1111/j.1465-7287.2010.00240.x) 

Drs. Hall and Brajer have consistently and seriously falsified the relationship between PM2.5 

and total mortality in California in their publications. The falsification occurs in section “2.2.3. 

Mortality” on page 1008 of Hall 2007, section “III.1.4 PM2.5 Mortality” on pages 63-65 of Hall 

2008, section “4. Health Concentration–Response Functions” on pages 2592-2594 of Hall 2010, 

and section “PM2.5 Mortality” on pages 528-529 of Brajer 2011. A complete summary of

California-specific evidence on PM2.5 and total mortality is contained in my September 28, 

2012 paper "Particulate Matter is Not Killing Californians" (Enstrom 2012). This paper is 

scheduled to be published in December 2012 in the American Statistical Association 2012 Joint 

Statistical Meeting Proceedings (http://www.scientificintegrityinstitute.org/ASAS092812.pdf). 

The Hall and Brajer publications do not cite the null results from the following studies that are 

contained in my Table 1: Figures 5 and 21 of Krewski 2000, McDonnell 2000, Enstrom 2005, 

Enstrom 2006, Zeger 2008, Jerrett 2010, Krewski 2010, Jerrett 2011, Lipsett 2011, and Ostro 

2011. These null results are based on the epidemiologic studies of 26 highly qualified doctoral 

level scientists, including myself (http://www.scientificintegrityinstitute.org/AMQP092012.pdf). 

In addition, I contend that this falsification has been deliberate because Drs. Hall and Brajer must 

have followed the intense two decade long PM2.5 epidemiology controversy. This controversy

has been repeatedly described, such as, in the August/September 1997 Reason article "Polluted 

Science" by Michael Fumento (http://reason.com/archives/1997/08/01/polluted-science) and in 

my April 24, 2012 talk, “Pseudoscientific Aspects of Fine Particulate Matter Epidemiology, 

1993-2012,” at the International Dose-Response 2012 Conference (http://www.doseresponse.org/conference/2012/pdf/Enstrom_Dose_Response_Fine_Particulate.pdf).
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For instance, Dr. Hall acknowledged knowing about the Enstrom 2005 and Zeger 2008 studies in 

a January 21, 2009 email message to me and in a January 20, 2009 email message to blogger 

Thomas Frantz, aka “airqualityguy” (http://www.scientificintegrityinstitute.org/Hall012109.pdf). 

Dr. Hall’s January 20, 2009 email message was posted by Frantz as a blog comment, now 

removed, in response to the January 18, 2009 Bakersfield Californian Column and Blog by Lois 

Henry “Hype clouds our real air pollution picture”

(http://www.bakersfieldcalifornian.com/columnists/lois-henry/x361189600/Lois-Henry-Hypeclouds-our-real-air-pollution-picture).

The wide-spread knowledge of the null PM2.5 mortality risks in California is illustrated by the

February 17, 2009 letter, entitled "Temporary Suspension of CARB On-Road and Off-Road 

Diesel Truck Regulations," to the California Air Resources Board that was co-signed by CSUF 

economics graduate and State Senator Lou Correa: “There is substantial epidemiologic evidence 

from six independent sources that there is no current relationship between fine particulate air 

pollution (PM2.5) and premature deaths in California.” (http://www.arb.ca.gov/lists/siprev09/1-

carb_devore_villines_correa_letter_regarding_diesel_regs_021709.pdf).

On November 28, 2009 Dr. Hall acknowledged a second email message that I sent to her

regarding additional evidence and commentary indicating that PM2.5 is not related to total 

mortality in California (http://www.scientificintegrityinstitute.org/Hall112809.pdf). In addition,

many qualified California scientists, including myself, were invited to participate in a February 

26, 2010 CARB Symposium "Estimating Premature Deaths from Long-term Exposure to 

PM2.5” (http://www.arb.ca.gov/research/health/pm-mort/pm-mort-ws_02-26-10.htm). Drs. Hall 

and Brajer must certainly have been aware of this major and highly influential symposium, 

which critiqued the very epidemiologic evidence that they have used in their four publications.

In spite of the overwhelmingly null PM2.5 mortality findings within California that have been 

published since 2000 and in spite of the February 26, 2010 CARB Symposium on PM2.5 deaths, 

Drs. Hall and Brajer published 2010 and 2011 journal papers that focused on non-Californiaspecific evidence and concluded that there was a positive relationship between PM2.5 and total 

mortality in California. In particular, they focused on Pope 2002, Jerrett 2005, Laden 2006, and 

Krewski 2009, with mention of earlier results by these authors (Dockery 1993, Pope 1995, and 

Krewski 2000). They came to the exact same conclusion in both their 2010 and 2011 papers: 

“Given the differing strengths of the primary underlying health studies and the conclusions from 

the expert elicitation, we use a weighted average of Jerrett et al. (RR = 1.17), Laden et al. (RR = 

1.16), and Pope et al. (RR= 1.06). This results in an RR [relative risk] factor of 1.10 . . .”

Drs. Hall and Brajer knew that they were not using California-specific evidence because footnote 

5 on page 528 of Brajer 2011 states “Although these studies are conducted both at the national 

level and for various cities in the United States (and not all in southern California), we follow the 

standard assumption that ozone and particulates cause basically the same health outcomes in 

southern California that they cause elsewhere in the United States At present, there is

no consistent pattern of evidence to suggest otherwise.”
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However, their statements “the standard assumption that ozone and particulates cause basically 

the same health outcomes in southern California that they cause elsewhere in the United States” 

and “At present, there is no consistent pattern of evidence to suggest otherwise” are both

UTTERLY FALSE. As of September 20, 2011, the date that Brajer 2011 was last modified, 

there was an UNEQIVOCALLY “consistent pattern of evidence to suggest otherwise.” Indeed, 

an OVERWHELMING amount of null California-specific evidence was published before 

September 20, 2011 and all of it is cited in Table 1 of Enstrom 2012. If they had cited this 

evidence and had done a properly weighted assessment, Drs. Hall and Brajer would have had to 

conclude that the California-specific RR was 1.00, meaning no “premature deaths” in California. 

In turn, the lack of “premature deaths” means that the following statements on page 530 of 

Brajer 2011 are incorrect and need to be changed: “Not surprisingly, given the large value that 

individuals, and society more broadly, place on avoiding premature deaths, the overall economic 

benefits of attaining the NAAQS are dominated by mortality. Across the SoCAB [South Coast 

Air Basin], it is estimated that 3,000 people would avoid premature death each year, accounting 

only for the effect of PM2.5 and only for the population aged 30 and older. With a value for each 

statistical life of $6.63 million, this effect by itself offers an attainment benefit of nearly $20 

billion each year.”

My allegations of falsification have both scientific and societal significance because Drs. Hall 

and Brajer wrote their four papers with full knowledge of the socioeconomic hardship caused by 

CARB and AQMD regulations that have been and will continue to be implemented to reduce 

particulate matter levels in California. For instance, the authors themselves state in Hall 2010: 

“The impetus for the study [Hall 1989] was the need for quantitative benefits estimates to inform 

the policy debate. The regional regulatory agency [AQMD] was under increasing pressure to 

back away from aggressive and costly control measures needed to attain the NAAQS, on the 

grounds that the costs would wreak economic havoc. The benefit assessment [Hall 1989] 

essentially provided a counter weight to claims of catastrophic control costs, since the potential 

economic benefits of regulation had never been adequately quantified . . .”

The Hall 1989 study is featured at the beginning of the AQMD “Smog and Health” webpage:

“A 1989 study funded by AQMD and conducted by Dr. Jane Hall of Cal State Fullerton found 

that meeting federal clean air standards for ozone and fine particulates in the South Coast region 

would provide $9.4 billion in health-related benefits each year. The study found that 98% of the 

four-county basin's population of 13 million is exposed to unhealthful air, with children 

especially vulnerable. In addition, 1,600 people die prematurely as a result of exposure to air 

pollution, according to the study.”(http://www.aqmd.gov/smog/historical/smog_and_health.htm). 

This June 1989 study was entitled “Economic Assessment of the Health Benefits from 

Improvements in Air Quality in the South Coast Air Basin, Final Report,” was authored by Jane 

V. Hall, Arthur M. Winer, and Minn P. Poe, and was cited in Hall 2010 and is in the EPA library

(http://yosemite.epa.gov/ee/epalib/eelib.nsf/8b0118ba1065662a85256a290076d16a/7b77ee0573

94e2d485256d0800524ebd!OpenDocument).
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Dr. Hall has been doing economic assessments for AQMD since 1989 and she currently serves as 

a member of the AQMD Scientific, Technical & Modeling Peer Review Advisory Group for the 

2012 AQMP (http://aqmd.gov/gb_comit/stmpradvgrp/2012stmprpadvgrpmembership.html) . 

The Draft 2012 AQMP Socioeconomic Report released on September 28, 2012 

(http://aqmd.gov/aqmp/2012aqmp/DraftSocioeconomicReport.pdf) contains her September 17, 

2012 review as a “peer-review economist” on pages F-28 to F-30. Her review cites Hall 2008 

and Brajer 2011, but it makes no reference to the overwhelmingly null California-specific 

evidence regarding PM2.5 mortality cited in Enstrom 2012.

Furthermore, Dr. Hall’s September 17, 2012 review does not address the serious socioeconomic 

concerns expressed in the 91comment letters that have been submitted regarding the AQMP as of 

October 31, 2012 (http://aqmd.gov/aqmp/2012aqmp/commentletters/commentlist.html). Most of 

these letters were available for her to read before she wrote her review. A sample of the serious 

socioeconomic concerns are described in the 5-page August 31, 2012 and the 6-page October 22, 

2012 comment letters from the 27-member Southern California Business Coalition 

(http://www.bizfed.org/sites/default/files/so_cal_business_coalition_comment_ltr._8-31-12.pdf). 

These two letters begin by stating “The final 2012 Air Quality Management Plan, and the rule 

making that will eventually stem from it, will directly affect many of these businesses’ interests.” 

The members of the Southern California Business Coalition represent hundreds of thousands of 

individual businesses and millions of individual employees in Southern California.

A simple comparison of the text and references in their four publications with the Table 1 and 

references in my 2012 paper reveals that Drs. Hall and Brajer have not cited or reviewed the vast 

amount of California-specific evidence on PM2.5 deaths that has been published since 2000. 

Based on my own interpretation of UPS 630.000, they have falsified the relationship between 

PM2.5 and total mortality in California in their publications. Thus, I request a formal CSUF 

assessment of my allegations of falsification.

Thank you very much for your prompt and full consideration of my research misconduct

complaint.