Due to lack of data on actual real-world exposures, EPA has proposed a highly sophisticated alternative “framework” which instead would evaluate the probability that children might someday be exposed to lead paint dangers in a commercial building. NAR, as part of the Commercial Properties Coalition, asked scientists at Exponent to review EPA’s approach for technical credibility, and they concluded a) that EPA’s models are only as good as the assumptions they use and b) no amount of probabilistic analysis can overcome their data limitations. NAR’s concern is that EPA justifies a regulations based on “Rube Goldberg” like models which because they are so complex, appear to have a veneer of credibility when in fact the results they produce are inflated, unreliable and not sound science grounded. The attached technical comments appear to validate NAR’s concerns and will be included in the rulemaking record for the Agency to explain in court should it reach that far.
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