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  • Comment Detail

  • Date: 11/15/21
    First Name: James
    Last Name: Gibbs
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AB17

  • Comment

    I laughed at your strategic approach in this decision making. You combined a scientific approach and an unscientific approach. If you suspect your scientific approach is not solid, you either refine it or abandon it. You never use it to support your unscientific approach to reach a predetermined goal before any analysis.

    When the next Director changes PLBA from 0.5% to 2.5%, how would GSEs cope with it? PLBA is not defensible at all.

    My suggestion: you always use ONLY a good scientific approach. No PLBA.

    (Here I'm NOT hinting your current scientific method is accurate enough. It only seems scientific. )

    Thank you.