Investigations resulting in alternate tower collapse explanations, and critiques of
NIST's WTC investigation by knowledgeable people who are not conspiracy theorists

Main 9/11 links page 

Investigations resulting in alternate tower collapse theories

FEMA World Trade Center Building Performance Study Index

FEMA/ASCE "pancaking floor" theory (examined and rejected by NIST investigation)
See FEMA 403 Chapter 2, pgs 24-25 and 35 (pdf)


Arup Fire & University of Edinburgh Studies
Concluded that towers could have collapsed from fire alone

How did the WTC Towers Collapse: A New Theory (Collapse could have occurred from fire alone; thermal expansion. By Usmani, Chung, Torero, Arup, U. Edinburgh. PDF)

Arup Study Sees WTC Collapse Likely Even Without Loss of Fireproofing (Consulting-Specifying Engineer, 10/5/2005)
Dr. Barbara Lane, an expert in structural fire design solutions with London-based global consulting and engineering firm Arup, has presented the firm's findings that the collapse of the WorldTradeCenter towers due to fire could have occurred even without the loss of structural fireproofing caused by aircraft impact.

Dr. Lane presented the results of Arup's detailed structural fire collapse study at a two-day National Institute of Standards and Technology (NIST) technical conference on the FederalBuilding and Fire Safety Investigation of the World Trade Center (WTC) Disaster. She spoke at the public comment period of the session on Structural Fire Response and Collapse Analysis on Sept.15.
Arup WTC study
Arup commended the work of NIST to model the WTC collapse—a vast undertaking. However, Arup's review of NIST's findings and its own analysis led it to conclude that NIST has not satisfactorily demonstrated its main conclusion that the impact-induced loss of fireproofing was the deciding factor in the collapse.

Quantifying the performance of the structure in real fire scenarios is key in designing structures to withstand progressive collapse. For several years, Arup has been working with the University of Edinburgh to model the performance of structural frames in realistic building fires using finite-element analysis. This approach has been used by Arup to model a building with very similar structural design and fire characteristics to WTC Tower 1.

Arup’s analysis concluded that the effect of thermal expansion on the perimeter columns of the towers—even without the airplane impact—could have led to collapse due to the severity of fire occurring on multiple floors and the resulting thermal expansion of structural elements, particularly the floor systems. The Arup analysis conclusively illustrates that even with code-approved fire protection, a severe fire—without aircraft impact—could still lead to collapse.

Thermal expansion, an integral parameter of Arup’s modeling of the event, was not included in the NIST model—a likely reason for the differing conclusions. Arup supports the widespread application of such in-depth structural detailing for future tall building design and construction, as opposed to more prescriptive code- or materials-based solutions. This form of analysis can bring additional robustness to a structural design. Quantifying the response of a structural design subjected to fire allows a designer to determine the strengths and weaknesses of the design and make alternative detailing or other alterations to the structure to improve its performance.
The Royal Society of Edinburgh Fire and Structures: The Implications of the World Trade Center Disaster (PDF, 2004)

Page 23: STRUCTURAL FIRE PROTECTION-FROM PRESCRIPTION TO THE PERFORMANCE BASED APPROACH Dr Susan Lamont, Fire Engineer, Arup Fire. Co-Authors: Dr Asif Usmani, Dr Barbara Lane, Dr Jose Torero
Due to its simplicity the standard fire resistance test misses vital structural phenomena found in the 3D behaviour of real buildings including;
• Large deflections and nonlinear geometry
• Restrained thermal expansion and thermal bowing.
• Membrane and catenary load carrying mechanisms in slabs and beams
These phenomena can be captured in finite element models and structures designed for fire in an engineering manner. In the case of low risk, medium rise buildings this can lead to savings in passive fire protection.
G.P. Cherepanov's fracture wave theory

Cherepanov, G.P. (2006). On the collapse of the World Trade Center on September 11, 2001. J. of Applied Physics.(pdf)

G.P. Cherepanov's "fracture wave" theory: (2006). September 11 and fracture mechanics. Int. J. of Fracture, Vol 132 (2), pp. L25--L26

Zdenek Bazant responds to G.P. Cherepanov's critique


See below for information on Dr. James Quintiere's conclusion that the towers could have collapsed from fire alone.


Critiques of NIST's WTC investigation by
knowledgeable people who are not conspiracy theorists


Ryan Mackey on investigations with different results, and his own issues with the NIST report: "On Debunking 9/11 Debunking" (PDF – see page numbers below)
  • NIST vs. University of Edinburgh and Arup on Thermal Modeling – p. 147
  • Modeling Fuel at Impact – p. 151
  • Purdue University response to limitations in NIST simulation capability – p. 155
  • The role of chemical attack (includes discussion of sulfidized steel and iron spherules) – P. 156
  • What if NIST is wrong? – p. 159
Dr. Frank Greening on problems with the NIST report

Ryan Mackey's response to Dr. Greening's problems with NIST report


Dr. James Quintiere, John L. Bryan Professor of Fire Protection Engineering, University of Maryland. Chairman of the International Association for Fire Safety Science (IAFSS), member, NIST advisory committee.

Chief findings:
  • Towers could have collapsed with no fireproofing removed.
  • NIST greatly underestimated building fuel loads
  • NIST didn't investigate enough alternative collapse hypotheses
  • NIST didn't sufficiently justify its estimates of fireproofing removal
  • NIST fire testing of trusses inconclusive: should have done larger-scale tests
  • NIST underestimated importance of discarded steel to their investigation
  • NIST new simulation software needs to be proven accurate for less complex incidents
June, 2002 statement at early public meeting regarding NIST's involvement in WTC collapses. Quintiere makes several recommendations.

February, 2004 statement at NIST public meeting in NYC
Excerpt: Okay. I’ll just say, there are some clear areas of scrutiny in the NIST investigative effort, namely: The South Tower fell in about 56 minutes and the North in about 104. The North had double the insulation. You don't have to be a mental giant to realize the correlation there. A heat transfer analysis of the truss rods, the weakest link in the structure, yield similar failure times. Two independent United Kingdom analyses show the role of the floor truss in the failure mechanism. The NIST photographic evidence shows the necessary floor deflections to support these theories.

NIST plans a test of the floor truss system in a standard furnace test. It is well known that these furnaces tests offer uneven results. In other words, one furnace test does not necessarily agree with the other. And they do not represent a real fire. So if you do a test and it says you get a three-hour rating,that doesn't mean it corresponds to three hours in a real fire. And if I had more time, I could tell the technically inclined in the audience why. So NIST has the obligation to scrutinize these areas and reach complete, independent, and supportive conclusions.
November, 2004 statement to NIST advisory committee (PDF)
October, 2005 statement to House Committee on Science (Full text follows)
In my opinion, the WTC investigation by NIST falls short of expectations by not definitively finding cause, by not sufficiently linking recommendations of specificity to cause, by not fully invoking all of their authority to seek facts in the investigation, and by the guidance of government lawyers to deter rather than develop fact finding.

I have over 35 years of fire research in my experience. I worked in the fire program at NIST for 19 years, leaving as a division chief. I have been at the University of Maryland since. I am a founding member and past-Chair of the International Association for Fire Safety Science—the principal world forum for fire research. I have followed the investigation from onset of the incident, as I was about to teach fire investigators at the ATF Academy (FLETC) in Georgia on the morning of 9/11. I joined the SSC team of Sally and Monica after we mutually discovered each other by speaking our concerns on the WTC collapse. I have published in the area of the WTC incident, our students built a scale-model of the fire on a floor of the North Tower, and I have followed the NIST activities from before their special funding. I assisted NIST early in 2002 in viewing photographs and video held by the NY Times. I had wished for clear and complete analyses and evidence to determine the full cause of the factors behind and the reasons for the collapse of the WTC buildings, as they bear on the fire safety design of current and future buildings. I am also concerned about the lack of sufficient government support for fire research and its implementation in fire safety design, codes and standards.

Concerns about the NIST Investigation

Scientists at NIST should be commended for their individual efforts in rising to the occasion of the WTC investigation. NIST should be commended for organizing an activity of this scale for the first time. However, there are some issues of concern that I will summarize. All of these have been submitted to NIST, but never acknowledged or answered. I will list some of these.

1. Why is not the design process of assigning fire protection to the WTC towers fully called out for fault? The insulation thickness of the truss members varied from 0.5 inches at its construction, changed to a specification of 1.5 inches in 1995, and was taken on its face as 2.5 inches for the North tower fire floors based on a PA report. This extraordinary range of thicknesses bears an in depth investigation. Why were no hearings held or witness testimonies heard on this critical design process?

2. Why were not alternative collapse hypotheses investigated and discussed as NIST had stated repeatedly that they would do? Their current explanation for the collapse of the towers is critically based on an assumption that the insulation was removed from the steel in the path of the aircraft, particularly the core columns. NIST does not show calculations or experiments to satisfactorily confirm that the insulation was removed in the core. As some large aircraft components went directly through the buildings, and NIST indicates the others were splintered on impact, can they explain why these small splinters could still denude the steel?

3. Spoliation of a fire scene is a basis for destroying a legal case in an investigation. Most of the steel was discarded, although the key elements of the core steel were demographically labeled. A careful reading of the NIST report shows that they have no evidence that the temperatures they predict as necessary for failure are corroborated by findings of the little steel debris they have. Why hasn't NIST declared that this spoliation of the steel was a gross error?

4. NIST used computer models that they said have never been used in such an application before and are the state of the art. For this they should be commended for their skill. But the validation of these modeling results is in question. Others have computed aspects with different conclusions on the cause mechanism of the collapse. Moreover, it is common in fire investigation to compute a time-line and compare it to known events. NIST has not done that.

5. Testing by NIST has been inconclusive. Although they have done fire tests of the scale of several work stations, a replicate test of at least & of a WTC floor would have been of considerable value. Why was this not done? Especially, as we have pointed out to NIST that they may have underestimated the weight of the furnishings in the North Tower by a factor of 3. As fire effects on structure depend on temperature and time, this likely longer burning time is significant in the NIST analyses. Other tests of the trusses in the UL furnaces show that the steel attains critical temperatures in short times, and these temperatures correspond to NIST's own computation of truss failure for a single truss. Why have these findings seemingly been ignored in the NIST analyses?

6. The critical collapse of WTC 7 is relegated to a secondary role, as its findings will not be complete for yet another year. It was clear at the last NIST Advisory Panel meeting in September that this date may not be realistic, as NIST has not demonstrated progress here. Why has NIST dragged on this important investigation?

On the Recommendations

The eight group-headings of the NIST recommendations are not specific, as they cannot connect directly to their findings. Instead they speak to developing, improving or advancing technology for safety from fire. Hence, they really cry out for more research, technology adaptation, and education with respect to fire. This is understandable as the NIST role has been to be a leader in research, and a source of new knowledge for codes and standards. The Science Committee and the Congress should take note of the needs underlying the nature of these recommendations. They are more a need for research to assist standards.

NFPA testified at the Hearing that the implementation of new performance-based codes requires tools that have not yet been developed and nor are there sufficient people to understand how to use them. Congressman Boehlert pointed out to Sally Regenhard many are ''do-gooders'' that serve on the standard committees, but few come to the table with technical information that is needed for a full discussion. This transfer of technical information for standards in fire safety is only a role that government can effectively support. The Science Committee should thoughtfully consider how that support could be implemented.

I point out some alarming facts. The fire program at NIST received a boost in the 1970's under the confluence of several forces: NSF advancing $2 million per year for fire research, consumer product safety legislation (CPSC), and the funding advanced by industry and government agencies for fire research (about $ 2–3 million per year). This funding has considerably dropped in real dollars. The NIST fire program continues to survive by taking contracts from government and the private sector that could otherwise support academic or private industry. The extramural research program of NIST, inherited from NSF, has shrunk from effectively $2 million to about $500k in 1970 dollars. The NSF has defaulted a fire program to NIST so investigators in academia have no program to turn to at NSF. The NASA microgravity program had taken up the slack in fire research beginning about 1985, but its current fire research budget has been decimated in a shift from space station needed research to a Mars human flight program. The Science Committee has oversight over NSF, NASA, and NIST. It should investigate how it can best support the needed fire research.

NIST speaks to the need for education. I left NIST to contribute to that goal. The U.S. produces about 50 fire protection engineers per year when about 500 are really needed. If the fire service would incorporate fire engineers this number would double. There is a big lack of knowledge here, and it contributes to an infrastructure of fire safety that is currently fraught with good intentions, special interests, and ignorance. The Science Committee should recognize this deficiency.

Summary of Dr. Quintiere's presentation “Questions on the WTC Investigations” at the 2007 World Fire Safety Conference.

Excerpt: Dr. Quintiere then presented his and his students’ research that contradicts the NIST report and points to a different cause for the collapses; the application of insufficient fire-proofing insulation on the truss rods in the Twin Towers. “I suggest that there’s an equally justifiable theory and that’s the trusses fail as they are heated by the fire with the insulation intact. These are two different conclusions and the accountability for each is dramatically different,” he said.


Glenn Corbett, Assistant Professor of Fire Science, John Jay College of Criminal Justice, member of NIST's National Construction Safety Team Advisory Board.

October, 2005 statement to House Committee on Science
Thank you, Chairman Boehlert. Chairman Boehlert and Members of the House Committee on Science, my name is Glenn Corbett. I want to thank you for the opportunity to testify again before you concerning NIST and the World Trade Center disaster investigation. Before I discuss the investigation, I would first like to extend my thanks to you, Chairman Boehlert, and the House Science Committee, for initiating the creation of the National Construction Safety Team Act, and shepherding it through Congress to final approval by President Bush. The American public is the beneficiary of this critical legislation, and will reap the benefits of your labors through the savings of lives and the construction of safer buildings.

Additionally, I must also note that although I am a Member of the Federal Advisory Committee to the National Construction Safety Team, I do not speak on their behalf. My testimony represents only my own opinions. I recommend that the House Committee on Science review the annual reports of the NCST Advisory Committee for details on their perspective.

Over three years have passed since NIST began its investigation into the World Trade Center disaster. We now have come to the conclusion of this $16 million effort of a search for answers about what happened in the twin towers. The investigation has taken much longer than anticipated, including the fact that the World Trade Center Building Number 7 investigation will likely not be completed until next summer.

Although NIST has done quite a bit of work and has amassed many thousands of pages of useful research, I feel that the investigation has fallen far short of what is needed. From the beginning, I had hoped for a true investigation with a tight set of specific recommendations at the conclusion, that could be immediately passed to our national code writing groups and trade associations. Instead of passing a blazing torch of detailed recommendations, this lengthy marathon race has resulted in NIST giving our model code writing groups only a handful of flickering embers that, although generally good in principle, are entirely too vague. The model code writing groups now have to wait even longer while NIST hires an outside organization to prepare a set of recommendations that actually can be assimilated into our construction codes.

During the course of the WTC investigation, I have had serious concerns about some of the findings and conclusions that NIST has drawn. Other individuals, including some people on the Federal Advisory Committee, have also had concerns. While this hearing is not the appropriate place to debate technical issues, I would suggest that a more formal mechanism be developed to officially address comments from the public. Such a protocol should include the technical basis for which NIST rejects or accepts the content of a public comment.

Overall, I have been disappointed by the lack of aggressiveness that has characterized not only the World Trade Center investigation, but the Rhode Island Station Nightclub investigation as well. Instead of a gumshoe inquiry that has left no stone unturned, I believe the investigations were treated more like research projects, in which they waited for information to flow to them. In both investigations, they were reluctant to use the subpoena given to them under the NCST Act. To some extent, this lack of assertiveness was likely the result of legal opinions given to NIST by staff attorneys.

Recently, this situation was greatly amplified by NIST's reluctance to respond to Hurricanes Katrina and Rita under the banner of the NCST Act. I suggested to NIST that they assemble an NCST team for Katrina before it struck the Gulf Coast. They actually sent a handful of people a week after Katrina hit, and only recently sending a much larger group of researchers to the area. Curiously, they have decided not to respond under the NCST Act.

To their credit, NIST has brought many talented people to the WTC investigation. They have expended a tremendous amount of effort, compiled a great deal of technical data, pushed the technical limits of computer models, and identified the general areas of concern where improvements in safety regulation and practice are called for. They are to be commended for their extraordinary research efforts, given the immensity of the project.

With respect to the 30 recommendations that NIST has developed, despite being vague, they are areas of significant importance. I feel the following particular ones deserve greater attention. These recommendations concern enhanced structural fire resistance, redundancy for fire protection systems in tall buildings, enhanced egress capabilities, including dealing with stairwell counterflow, remoteness of exits, and full building evacuation capacity, hardened elevators for egress, as well as robust communication capabilities for emergency responders.

Where do we go from here with regard to the World Trade Center? The ball is in NIST's court, and it is up to them, with their contractor, to quickly whittle the desirable but too general recommendations into well-defined code language that can be quickly moved through the model code review process. I strongly encourage them to be bold, use their best engineering judgment, and come up with clear and concise code language. High rise fire safety and safety in general is held in the balance.

When I look to the future of the NCST Act, sadly, I find it necessary to recommend that serious consideration be given to finding a new agency to implement the Act. I don't think that NIST is the right place for the NCST. Their nonaggressiveness, their absence of investigative instinct, and the palatable lack of interest they have shown in the Act has brought me to this conclusion. NIST is an organization of exceptional scientists and engineers, not detectives.

Short of creating an entirely new Construction Safety Team Board, I would recommend that serious consideration be given to moving the NCST to the U.S. Chemical Safety and Hazard Investigation Board. They are a close fit. They investigate explosions and chemical disasters in and around structures. They deal with many of the same code writing bodies that NIST deals with, including some of the organizations represented on this panel today. More importantly, they are solely an investigative agency that issues recommendations. Perhaps their purview could be expanded to include the NCST Act.

In conclusion, I want to again thank you, Chairman Boehlert, and the House Committee on Science, for taking the leadership role in creating the NCST Act. The fact that it has drawn the attention of many people sitting here today, and the organizations included on this panel today from the safety and construction fields, is a testament to its importance.

Thank you.

[The prepared statement of Mr. Corbett follows:]

PREPARED STATEMENT OF GLENN P. CORBETT

Chairman Boehlert and Members of the House Committee on Science: My name is Glenn Corbett. I want to thank you for the opportunity to testify before you concerning NIST and the World Trade Center disaster investigation. Before I discuss the investigation, I would like first extend my thanks to you, Chairman Boehlert, and the House Committee on Science for initiating the creation of the National Construction Safety Team Act and shepherding it through Congress to final approval by President Bush. The American public is the beneficiary of this critical legislation and will reap the fruits of your labors through the saving of lives and construction of safer buildings.

Additionally, I must also note that although I am a member of the Federal Advisory Committee to the National Construction Safety Team, I do not speak on the committee's behalf. My testimony represents only my opinions. I recommend that the Committee on Science review the annual reports of the NCST Advisory Committee for details on their perspective.

Over three years has passed since NIST began its investigation into the World Trade Center disaster. We have now come to the conclusion of this $16 million effort search for answers about what happened in the twin towers. The investigation has taken much longer than anticipated, including the fact that the World Trade Center (building) 7 investigation will likely not be completed next summer.

Although NIST has done quit a bit of work and has amassed many thousands of pages of useful research, I feel that the investigation has fallen far short of what is needed. From the beginning, I had hoped for a true investigation with a tight set of specific recommendations at the conclusion that could immediately be passed to our national code-writing groups and trade associations. Instead of passing a blazing torch of detailed recommendations, this lengthy marathon race has resulted in NIST giving our model code-writing groups a handful of flickering embers that although are generally good in principle are entirely too vague. The model code-writing groups now have to wait even longer while NIST hires an outside organization to prepare a set of recommendations that can actually be assimilated into our construction codes.

During the course of the WTC investigation, I have had serious concerns about some of the findings and conclusions that NIST has drawn. Other individuals, including some people on the federal advisory committee, have also had concerns. While this hearing is not the appropriate place to debate technical issues, I would suggest that a more formal mechanism be developed to officially address comments from the public. Such a protocol should include the technical basis for which NIST rejects or accepts the content a public comment.

Overall, I have been disappointed by the lack of aggressiveness that has characterized not only the World Trade Center investigation but the Rhode Island Station Nightclub investigation as well. Instead of a ''gumshoe'' inquiry that left no stone unturned, I believe the investigations were treated more like research projects in which they waited for information to flow to them. In both investigations, they were reluctant to use the subpoena power given to them under the NCST Act. To some extent, the lack of assertiveness was the likely the result of the legal opinions given to NIST by staff attorneys.

Recently, this situation was greatly amplified by NIST's reluctance to respond to hurricanes Katrina and Rita under the banner of the NCST Act. I suggested to NIST that they assemble a NCST team for Katrina before it struck the Gulf Coast. They actually sent a handful of people a week after Katrina hit, only recently sending a larger group of researchers to the area. Curiously, they have decided not to respond under the NCST Act.

To their credit, NIST has brought many talented people to the WTC investigation. They have expended a tremendous amount of effort, compiled a great deal of technical data, pushed the technical limits of computer models, and identified the general areas of concern where improvement in safety regulations and practice are called for. They are to be commended for their extraordinary research efforts, given the immensity of the project.

With respect to the 30 recommendations that NIST has developed—despite being vague, they are areas of significant importance—I feel the following particular ones deserve greater attention. These recommendations concern enhanced structural fire resistance; redundancy for fire protection systems in tall buildings; enhanced egress capabilities including dealing with stairwell counterflow, remoteness of exits, and full building evacuation capacity; hardened elevators for egress; and robust communications capabilities for emergency responders.

Where do we go from here with regard to the World Trade Center? The ball is in NIST's court, and it is up to them (with their contractor) to quickly whittle the desirable but too general recommendations down into well-defined code language that can be quickly moved through the model code review process. I strongly encourage them to be bold, to use their best engineering judgment, and come up with clear and concise code language. High-rise safety is held in the balance.

When I look to the future of the NCST Act, sadly I find it necessary to recommend that serious consideration be given to finding a new agency to implement the Act. I don't think that NIST is the right place for the NCST. Their non-aggressiveness, their absence of investigative instinct, and the palatable lack of interest they have shown in the Act have brought me to this conclusion. NIST is an organization of exceptional scientists and engineers, not detectives.

Short of creating an entirely new National Construction Safety Team Board, I would recommend that serious consideration be given to moving the NCST to the U.S. Chemical Safety and Hazard Investigation Board. They are a close fit: they investigate explosions and chemical disasters in and around structures. They deal with many of the same code-writing organizations that NIST deals with, including some of the organizations represented on this panel today. Most importantly, they are solely an investigative agency that issues recommendations. Perhaps their purview could be expanded to include the NCST Act.

In conclusion I want to again thank you, Chairman Boehlert, and the House Committee on Science for taking the leadership role in creating the NCST Act. The fact that it has drawn the attention of many people and organizations from the safety and construction fields is a testament to its importance.

Sally Regenhard, Chairperson, Skyscraper Safety Campaign, 9/11 widow.

October, 2005 statement to House Committee on Science
Ms. REGENHARD. Okay. Thank you. Good morning, Chairman Boehlert and Members of the House Science Committee. It is truly an honor and a privilege to address you today.

I must first begin by thanking Chairman Sherwood Boehlert and this committee for listening with compassion and concern to the families of the victims of 9/11. When we first came here in March and May of 2002, we were desperately seeking leadership for an investigation of what happened to our loved ones on 9/11. We had sought this on the local level in New York City, but found no one to help us answer the painful questions regarding what happened to our loved ones in the World Trade Center on that dreaded day of infamy.

Chairman Boehlert and the Science Committee, you have redeemed our belief in the system, and renewed our faith in the process of representative government in our beloved country, and for this, we profoundly thank you. The families of the victims as well as the American public remain in your debt for your efforts in authorizing a WTC investigation through the National Construction Safety Team Act.

I must also begin by thanking NIST for interacting with us on a regular basis over the past three years, via conference calls and meetings, with myself and my SSC co-chair, Monica Gabrielle, who is out of the country and cannot be here today. I know that it has not always been easy to deal with me and with other victims' families, but I appreciate the tolerance and respect shown to us by NIST. I also appreciate the vast technical research abilities of this organization and the enormous task of embarking upon the WTC investigation.

In totality, however, while some very valuable results were achieved, the overall mode and findings of the investigation was not what I had hoped for. I had certain hopes regarding NIST in the investigation, but I and others were somewhat disillusioned regarding what NIST was willing and able to do. I had hoped for more specific and comprehensive recommendations that could easily be translated into code reform and change, but this was not the case. The recommendations, I feel, are very general and lack specifics. I feel that the vagueness of the language was influenced by a need for political correctness and a general reluctance or an inability to investigate, use subpoena power, lay blame, or even point out the deadly mistakes of 9/11 in the World Trade Center.

The following are five areas of concern of the Skyscraper Safety Campaign, and these concerns have been compiled by input from my professional advisors, as well as my own experience during the last four years.

The first area of concern is the role of the Port Authority of New York and New Jersey and its exemptions from immunities and codes. The failure of the NIST investigation to comprehensively examine what role these immunities played in the design, construction, maintenance, and ultimate collapse of the World Trade Center, is of great concern to me.

Secondly, the lack of more intense emphasis on the fireproofing issues, the premature disposal of the steel evidence, the heavy reliance on computer modeling for the fire testing, and the reluctance to focus on cause, blame, and resultant implications are troubling to us.

Number three, the reliance on the voluntary cooperation of key figures in the investigation to provide needed information, putting the WTC chief structural engineer on the payroll to facilitate his involvement in the investigation, utilizing researchers to the exclusion of true investigators going into the field to obtain evidence is also problematic to me. On this last point, I want to note that I have been married to an NYPD detective sergeant for over 30 years, and I can recognize an investigation when I see one. I feel the inherent character of the NIST as a research rather than an investigative agency was a factor in this situation.

Number four, the lack of focus on evacuation issues of the World Trade Center, such as the remoteness of the exits, the behavior of fleeing persons in the stairwells, and the avoidance of first person accounts of stairwell evacuation, and the length of time it took to evacuate the building was a shortcoming.

Finally, the relative secrecy of the investigation and the withholding of all materials and documents used by NIST to arrive at the study's conclusions is very disturbing. These materials should be made available to professionals to further study and to analyze, and to question and verify the findings according to the scientific method. And they should not be locked away in the National Archives or anywhere else. I certainly hope that I could call on the Science Committee to help unlock this information for the American public in the future.

In conclusion, for these and for other reasons, I feel that government must take a larger role in developing stronger codes and standards for building and public safety, by being a true resource to the code industry. Government representatives should be part of code writing groups, to provide advice and guidance, and to help develop standards and practices. As it stands now, it is largely a battle of the do-gooders, like me and the Skyscraper Safety Advisors, versus the business interests, in a never-ending conflict regarding public safety. The NIST investigation should not be an end. It should be just the beginning of a new era, in which we see the real and meaningful role that government must play in the safety and wellbeing of the American people. In addition to the laudable creation of the National Construction Safety Team Act, this participation can be an additional legacy for the innocent victims of 9/11, including my beautiful son, Probationary Firefighter Christian Michael Otto Regenhard, whose godmother is holding his picture here today. He continues to be the inspiration for the work and the accomplishments of the Skyscraper Safety Campaign.

I thank you all for this opportunity to speak to you today. God bless you all in your work.

[The prepared statement of Ms. Regenhard follows:]

PREPARED STATEMENT OF SALLY REGENHARD

Good morning Chairman Boehlert and Members of the House Science Committee. It is truly an honor and a privilege to address you today. I must first begin by thanking Chairman Sherwood Boehlert and this committee, for listening with compassion and concern to the families of the victims of 9/11. When we first came here in March and May of 2002, we were desperately seeking leadership for an investigation of what happened to our loved ones on 9/11/01. We had sought this on the local level in NYC, but found no one to help us answer the painful questions regarding what happened to our loved ones in the WTC on that dreaded day of infamy.

Chairman Boehlert and the Science Committee redeemed our belief in the system, and renewed our faith in the process of representative government in our beloved country, and for this, we profoundly thank you. The families of the victims, as well as the American public, remain in your debt for your efforts in authorizing a WTC Investigation through the National Construction Safety Team Act.

I must begin by thanking NIST for interacting with us on a regular basis over the past three years, via conference calls and meetings, with myself and my SSC co-chair, Monica Gabrielle, who is out of the country, and cannot be here today. I know it has not always been easy to deal with me and other victims' families, but I appreciate the tolerance and respect showed by NIST. I also appreciate the vast technical research abilities of this organization, and the enormous task of embarking upon the WTC Investigation.

In totality however, while some very valuable results were achieved, the overall mode and findings of the investigation was not what I had hoped for. I had certain hopes regarding NIST and the investigation, but I and others were disillusioned regarding what NIST was willing and able to do. I had hoped for more specific and comprehensive recommendations that could easily be translated into code reform and change, but this is not the case. The recommendations are very general and lack specifics. I feel that the vagueness of the language was influenced by political correctness and a general reluctance or inability to ''investigate,'' use subpoena power, ''lay blame,'' or even point out the deadly mistakes of 9/11 in the WTC.

The following are five areas of concern for the Skyscraper Safety Campaign: (While I have an understanding of these issues in concept, for answers to specific, technical questions, I would like to confer with two of my technical advisors who are with me here today.)

1) The role of the Port Authority of NYNJ and its' exemptions from immunities and codes. The failure of the NIST Investigation to comprehensively examine what role these immunities had in the design, construction, maintenance and ultimate collapse of the WTC is of great concern to me.

2) The lack of more intense emphasis on fireproofing issues, premature disposal of steel evidence, the heavy reliance on computer modeling for fire testing, and the reluctance to focus on cause, blame, and resultant implications are troubling.

3) The reliance on the voluntary cooperation of key figures in the investigation to provide needed information; placing the former WTC chief structural engineer on the payroll to facilitate his involvement in the investigation, utilizing researchers to the exclusion of true investigators going into the field to obtain evidence is problematic to me. On this last point, I have been married to a NYPD detective sergeant for over 30 years, and I can recognize an Investigation when I see one. I feel the inherent character of NIST as a research rather than investigative agency was a factor in this situation.

4) The lack of focus on evacuation issues of the WTC such as remoteness of exits, behavior of fleeing persons in the stairwells, and the avoidance of first person accounts of stairwell evacuation, and length of time it took to evacuate the building was a shortcoming.

5) The relative secrecy of the investigation, and the withholding of all materials and documents used by NIST to arrive at the study's conclusions is very disturbing. These materials should be made available to professionals for further study and analysis, to question and/or duplicate the findings, according to the scientific method, and should not be locked away in the National Archives or anywhere else. I hope I can call on the Science Committee to unlock this information for the American public.

In conclusion, for these and other reasons, I feel that government must take a larger role in developing stronger codes and standards for building and public safety. Government representatives should be part of code writing groups, and help to develop standards and practices. As is stands now, it is a battle of the ''do-gooders'' like me and the Skyscraper Safety Advisors vs. business interests, in a never ending conflict regarding public safety. The NIST investigation should not be an end; it should be just the beginning of a new era in which we see the real and meaningful role that government must play in the safety and well being of the American people. In addition to the laudable creation of the National Construction Safety Team Act, this participation can be an additional legacy for the innocent victims of 9/11, including my beautiful son, Probationary Firefighter Christian Michael Otto Regenhard, who continues to be the inspiration for the work and accomplishments of the Skyscraper Safety Campaign. Thank you for this opportunity to speak today. God bless you all.