He said that excluding those complaints, the most serious the board can consider, leads to faulty analysis of the department's disciplinary practices.
People who read his reports say that is not the only example of faulty analysis.
"If the Commission wants to change its approach, it must do so through changes to its regulations, not through a faulty and incorrect legal analysis."
Mr. Turnbull and his allies have a history of faulty analyses.
As a result, the commission suggested that the entire basis for granting Con Ed the delay in 1999 rested on faulty analysis.
Mr. Birch's initial statistic, labor economists say, was based on faulty analysis.
Others had inappropriate trial design or were marred by faulty statistical analysis.
Junk science is faulty scientific analysis used to advance a specific viewpoint.
A faulty analysis, however, is easy to dismantle.
"You have corrected the faulty analysis of others."