Pavel Kroupa, a leading MOND researcher, published an article in the IAI news, directed at a broader audience on July 12, 2022 forthrightly titled "Dark Matter Doesn't Exist" that makes some less commonly discussed arguments for this position. It states in some notable parts:
This dark-matter-based model (for each gram of normal matter there are 25 grams of the exotic dark matter) is about 20 years old, but the strong belief in the scientific community that dark matter exists goes back 30 years. . . .The many searches worldwide for evidence of dark matter particles, going on since at least 30 years, have come up empty handed. . . .there is a simple test that these scientists are ignoring and which has already been applied and it tells us that dark matter does not exist. This test goes back to Subrahmanyan Chandrasekhar who, in 1943, showed that a massive body (e.g. a dwarf galaxy) that moves through a background of comparatively low mass particles (e.g. dark matter particles), will slow down. This process of "Chandrasekhar dynamical friction" is exceedingly well understood. . . .With my collaborators and students, we have applied a number of observed galaxy systems to the calculations of Chandrasekhar dynamical friction we would expect to see if dark matter existed, and in all and every case it turns out that the slow-down is not in the data. . . . Rather than observing the slow down of galaxies through Chandrasekhar dynamical friction, we observed a speed-up as the galaxies fall towards each other. This is the same as two stars that fall towards each other in a star cluster. They get faster until they pass each other and then they recede again from each other. . . .satellite galaxies are typically orbiting their host galaxies in vast disks of satellites, much like the planets orbit the Sun in one plane, while according to the dark matter models, they should be orbiting in all possible directions. . . .the research community has largely ignored these falsificationsThree other very major tests of the dark-matter based models have been published recently:(A) One test relies on how rapidly a dark-matter-filled universe can form extremely massive clusters of galaxies that also penetrate each other. The El Gordo galaxy cluster is immensely heavy, weighing a thousand times the mass of the Milky Way and Andromeda together. This cluster is actually composed of two such clusters which have formed and transgressed through each other at a time when the Universe was only half its present age. It turns out that the dark-matter-based models cannot, under any circumstances, grow such massive clusters and also have them falling through each other by that time, falsifying the dark-matter based models rigorously.(B) Astronomers have also discovered that the local Universe expands more rapidly than the distant Universe. This problem, known as the "Hubble Tension", has triggered many concurrent conferences and hugely long texts written by hundreds of scientists in which all possible solutions are being discussed and explained. Very exotic dark-matter-based models are being developed, with additional processes being speculated to act on dark matter (e.g. dark matter could be decaying, there could be dark photons) or that dark energy has some complex time behaviour or multiple dark forms. Impressive is that this vast expert community, that includes or is driven by major-prize-winning scientists, is entirely ignoring the obvious solution to the Hubble Tension: we are in a region spanning more than a billion lightyears across which contains fewer galaxies by about a factor of two than should be there. Galaxies in this void fall towards its sides (like apples falling to the ground) which is why we witness an apparently faster expanding Local Universe. While this "KBC Void" naturally accounts for the Hubble Tension, the KBC Void is entirely incompatible with the dark-matter-based models because these constitute a model universe which is homogeneous and isotropic on scales larger than a few dozen million lightyears.(C) Another test of the dark matter models is to compare the thickness of galaxies with those observed in the real Universe in which more than 90 per cent of all galaxies are very thin spiral, or disk, galaxies. In the dark matter models galaxies grow over time mostly by merging with other galaxies. These galaxy-crashes typically destroy the thin disks. Our sophisticated analysis of thousands of observed galaxies show the dark matter based models to be totally incompatible with the real Universe, as the model produces galaxies that are typically too roundish compared to the profusive thin disk galaxies in the real Universe.Other problems between the real Universe and the dark-matter models include massive galaxies to have been observed at an early time at which they should not yet exist,
that modern observations tell us there to be dust between galaxies which challenges the interpretation of the cosmic microwave back ground as being the photosphere of the Hot Big Bang and that the cosmic microwave background has features in it that are incompatible with an inflationary origin, suggest that the Universe is structured on all scales (like a fractal perhaps) such that it may be understandable in terms of dust emission rather than a Hot Big Bang.Three implications arise from the above:(a) Modern cosmological theory is totally wrong and we need to develop a new theory based on MOND. MOND is a modern non-relativistic theory of gravitation which extends that of Newton by incorporating data from galaxies which were neither available to Newton nor to Einstein, both of whom had to base their deductions on data limited to the Solar System only. All predictions made 40 years ago by Mordehai Milgrom in the foundation papers have been verified, and in Prague and Bonn we (with Nils Wittenburg and Nick Samaras) are now performing the first ever full cosmological calculations with star formation of a MOND universe.
MOND comes from a simple space-time scale symmetry and may be a consequence of the quantum vacuum, opening a possible path towards unifying gravitation with standard-model particle physics. A major recent review for further in-depth reading has just been published.
Some of the criticisms are familiar, but a few are less commonly discussed.
The case against dark matter from a lack of evidence of "Chandrasekhar dynamical friction"is a rarely raised by solid and fairly global and robust challenge of a wide variety of dark matter paradigms.
The argument that too many galaxies are thin disks for a LambdaCDM galaxy assembly history to make sense is also a good and rarely raised argument.
The Hubble tension argument is less compelling, because there are so many competing and plausible explanations for it from systemic measurement biases, to overlooked GR effects, to various forms of new physics and it needs to be sorted out and lots of researchers are working in good faith to do that.
The other criticisms are long standing and familiar (and his list omits some of my favorites).
Kroupa's article lacks a bit in not recognizing the importance of having a fundamental foundation for MOND which is a non-relativistic toy model in its original form and which needs to be generalized into a relativistic theory that can be integrated more easily with existing Standard Model and GR physics (which may not even require modification of GR). In truth, there are many ways to create models that largely recreate MOND's results.
It also lacks a bit for failing to recognize that dark matter particle theories are evolving to address their short fallings with more elaborate models, setting up something of a straw man argument.
Greater clarity on what exactly is being falsified would be helpful and is possible to do.
Still, on the merits, for reasons that extend beyond those in the article itself, I do think that he is right that there is no dark matter and the scientific community is too locked into the dark matter paradigm, even though I would make some of those arguments more tightly and would focus on somewhat different conflicts that he does.
I'll close this post by recapping his references, highlighting the most critical ones, such as those that support the stronger points above:
 "Galaxies as simple dynamical systems: observational data disfavor dark matter and stochastic star formation" Kroupa, P., 2015CaJPh..93..169K "Fast galaxy bars continue to challenge standard cosmology" Roshan, M. et al., 2021MNRAS.508..926R "The Dark Matter Crisis: Falsification of the Current Standard Model of Cosmology" Kroupa, P., 2012PASA...29..395K "Phase-Space Correlations among Systems of Satellite Galaxies" Pawlowski, M., 2021Galax...9...66P "Are Disks of Satellites Comprised of Tidal Dwarf Galaxies?" Bilek, M., et al., 2021Galax...9..100B "A massive blow for ΛCDM - the high redshift, mass, and collision velocity of the interacting galaxy cluster El Gordo contradicts concordance cosmology" Asencio, E. et al., 2021MNRAS.500.5249A "The KBC void and Hubble tension contradict ΛCDM on a Gpc scale - Milgromian dynamics as a possible solution" Haslbauer, M. et al., 2020MNRAS.499.2845H "The High Fraction of Thin Disk Galaxies Continues to Challenge ΛCDM Cosmology" Haslbauer, M., et al., 2022ApJ...925..183H "The Impossibly Early Galaxy Problem" Steinhardt, C.L., et al., 2016ApJ...824...21S "Universe opacity and CMB" Vavrycuk, V., 2018MNRAS.478..283V "CMB anomalies after Planck" Schwarz, D., et al., 2016CQGra..33r4001S "A modification of the Newtonian dynamics as a possible alternative to the hidden mass hypothesis." Milgrom, M., 1983ApJ...270..365M "A modification of the Newtonian dynamics - Implications for galaxies." Milgrom, M., 1983ApJ...270..371M "A modification of the newtonian dynamics : implications for galaxy systems." Milgrom, M., 1983ApJ...270..384M "The Mond Limit from Spacetime Scale Invariance" Milgrom, M., 2009ApJ...698.1630M "The modified dynamics as a vacuum effect" Milgrom, M., 1999PhLA..253..273M "From Galactic Bars to the Hubble Tension: Weighing Up the Astrophysical Evidence for Milgromian Gravity" Banik, I. and Zhao, H.S., 2022Symm...14.1331B "A Philosophical Approach to MOND: Assessing the Milgromian Research Program in Cosmology" Merritt, D., 2020, Cambridge University Press, ISBN: 9781108492690, 2020
Subrahmanyan Chandrasekhar who, in 1943, showed that a massive body (e.g. a dwarf galaxy) that moves through a background of comparatively low mass particles (e.g. dark matter particles), will slow down. This process of "Chandrasekhar dynamical friction" is exceedingly well understood.
low mass particles (e.g. dark matter particles),
but not black holes
Black holes are effectively ruled out as the source of DM.
Also please look at Stacy McGaugh's site:
"This is like putting a band-aid on a Tyrannosaurus. It’s already dead and fossilized. And if it isn’t, well, you got bigger problems."
"Prof. Loeb offers another pertinent example:
When I ask graduating students at their thesis exam whether the cold dark matter paradigm will be proven wrong if their computer simulations will be in conflict with future data, they almost always say that any disagreement will indicate that they should add a missing ingredient to their theoretical model in order to “fix” the discrepancy.
explains gravitational lenses
Black holes are effectively ruled out as the source of DM.
Professor, Departments of Astronomy and Physics, Yale University
Director, Franke Program in Science and the Humanities, Yale University
My research interests in black hole physics are focused the formation, fueling and feedback from supermassive black holes over cosmic time. I develop empirically motivated models for understanding the growth and evolution of black hole populations with a view to integrating fundamental physical processes that operate over a range of scales from sub-pc to Mpc, that are relevant to the physics of accretion, including angular momentum transfer and the alignment of spins. Having proposed several new channels for the formation of seed black holes and intermediate mass black holes that include direct collapse of pristine gas-disks and amplified growth in the dense gas-rich environments of nuclear star clusters, I work on predictions of multi-wavelength observational signatures of these processes.
Priyamvada (Priya) Natarajan is a professor in the departments of astronomy and physics at Yale University. She is noted for her work in mapping dark matter and dark energy, particularly with her work in gravitational lensing, and in models describing the assembly and accretion histories of supermassive black holes. She authored the book Mapping the Heavens: The Radical Scientific Ideas That Reveal the Cosmos.
Exploring the high-redshift PBH-ΛCDM Universe: early black hole seeding, the first stars and cosmic radiation backgrounds
Nico Cappelluti (1,2), Günther Hasinger (3), Priyamvada Natarajan (4,5,6) ((1) Department of Physics, University of Miami, (2) INAF Osservatorio di Astrofisica e Scienza dello Spazio di Bologna, (3) European Space Astronomy Centre (ESA/ESAC), (4) Department of Astronomy, Yale University, (5) Department of Physics, Yale University, (6) Black Hole Initiative, Harvard University)
We explore the observational implications of a model in which primordial black holes (PBHs) with a broad birth mass function ranging in mass from a fraction of a solar mass to ∼106 M⊙, consistent with current observational limits, constitute the dark matter component in the Universe. The formation and evolution of dark matter and baryonic matter in this PBH-\LambdaCDM~Universe are presented. In this picture, PBH DM mini-halos collapse earlier than in standard \LambdaCDM, baryons cool to form stars at z∼15−20, and growing PBHs at these early epochs start to accrete through Bondi capture. The volume emissivity of these sources peaks at z∼20 and rapidly fades at lower redshifts. As a consequence, PBH DM could also provide a channel to make early black hole seeds and naturally account for the origin of an underlying dark matter halo - host galaxy and central black hole connection that manifests as the Mbh−σ correlation. To estimate the luminosity function and contribution to integrated emission power spectrum from these high-redshift PBH DM halos, we develop a Halo Occupation Distribution (HOD) model. In addition to tracing the star formation and reionizaton history, it permits us to evaluate the Cosmic Infrared and X-ray Backgrounds (CIB and CXB). We find that accretion onto PBHs/AGN successfully accounts for the detected backgrounds and their cross-correlation, with the inclusion of an additional IR stellar emission component. Detection of the deep IR source count distribution by the JWST could reveal the existence of this population of high-redshift star-forming and accreting PBH DM.
Comments: 32 pages, 20 figures, accepted by ApJ on 10/22/2021
Subjects: Cosmology and Nongalactic Astrophysics (astro-ph.CO); High Energy Astrophysical Phenomena (astro-ph.HE)
Cite as: arXiv:2109.08701 [astro-ph.CO]
Other studies constrain it. For example:
One compelling possibility is DM being composed of primordial black holes (PBHs), given the tight limits on some types of elementary particles as DM. There is only one remaining window of masses available for PBHs to constitute the entire DM density, 10^17 - 10^23 g.
Here, we show that the kernel population in the cold Kuiper belt rules out this window, arguing in favor of a particle nature for DM.
Amir Sirajh, Abraham Loeb, "Eliminating the Remaining Window for Primordial Black Holes as Dark Matter from the Dynamics of the Cold Kuiper Belt" arXiv (March 8, 2021). https://arxiv.org/abs/2103.04995
there are additional papers
Primordial Black Holes as Dark Matter Candidates
Bernard Carr, Florian Kuhnel
We review the formation and evaporation of primordial black holes (PBHs) and their possible contribution to dark matter. Various constraints suggest they could only provide most of it in the mass windows 1017 - 1023g or 10 - 102M⊙, with the last possibility perhaps being suggested by the LIGO/Virgo observations. However, PBHs could have important consequences even if they have a low cosmological density. Sufficiently large ones might generate cosmic structures and provide seeds for the supermassive black holes in galactic nuclei. Planck-mass relics of PBH evaporations or stupendously large black holes bigger than 1012M⊙ could also be an interesting dark component.
Comments: 56 pages, 16 figures, 265 references; Published in SciPost Physics Lecture Notes, Les Houches Summer School Series. arXiv admin note: substantial text overlap with arXiv:2006.02838
Subjects: Cosmology and Nongalactic Astrophysics (astro-ph.CO); General Relativity and Quantum Cosmology (gr-qc); High Energy Physics - Phenomenology (hep-ph)
Cite as: arXiv:2110.02821 [astro-ph.CO]
Various constraints suggest they could only provide most of it in the mass windows 1017 - 1023g or 10 - 102M⊙, with the last possibility perhaps being suggested by the LIGO/Virgo observations.
Planck-mass relics of PBH evaporations or stupendously large black holes bigger than 1012M⊙ could also be an interesting dark component.
Another recent paper acknowledges that all DM can't be PBH (and I don't disagree that some small percentage of the matter in the universe could be PBH but it doesn't explain the DM issue for a variety of reasons, direct and indirect detection papers overshadow issues general to DM that interacts only via gravity shared with basic Cold Dark Matter, e.g., that inferred DM haloes have the wrong shapes). There is also evidence from the non-disruption of stars that would happen much more frequently if PBH were common enough to be an important answer to DM phenomena. (Even though I see the attraction as PBH doesn't require beyond the Standard Model Physics, unlike other exotic DM candidates.)
"We propose a way to constrain the primordial black hole (PBH) abundance in the range of PBH masses m around 10^20g based on their capture by Sun-like stars in dwarf galaxies, with subsequent star destruction. We calculate numerically the probability of a PBH capture by a star at the time of its formation in an environment typical of dwarf galaxies. Requiring that no more than a fraction ξ of stars in a dwarf galaxy is destroyed by PBHs translates into an upper limit on the PBH abundance. For the parameters of Triangulum II and ξ=0.5 we find that no more than ∼30% of DM can consist of PBHs in the mass range 10^18−(a few)×10^21g. The constraints depend strongly on the parameter ξ and may significantly improve if smaller values of ξ are established from observations. An accurate determination of ξ from dwarf galaxy modeling is thus of major importance."
Nicolas Esser, Peter Tinyakov, "Constraints on primordial black holes from observation of stars in dwarf galaxies" arXiv:2207.07412 (July 15, 2022)
The bigger point is that many new papers proposing that PBH DM is allowed don't comprehensively include all of the many constraints in the literature, just the data from their particular set of observations. And, to make the PBH DM hypothesis work, you need to consider all available constraints in the literature.
there is Planck-mass relics of PBH evaporations
Planck-mass black holes evaporate quickly via Hawking radiation. And, to still exist now, they would have had to be large to start with, which is contrary the evidence suggesting that in a DM model the amount of DM has been more or less constant since Big Bang Baryogenesis maybe 15 minutes after the Big Bang or less.
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