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I have been in the plating industry for many years and what is
being done to this industry is nothing short of criminal, I don't
have the ability to check data points on emissions as CARB or even
claim to have the time to calculate such emission values if that
information was provided. However, CARB has not provided accurate
data to stakeholders on emissions or even the current number of
facilities in operation.
This proposed ban is being based off 2019 pre pandemic data at
best, which leads to the question as to why we are not using
current emission data for accuracy when all of that information is
readily available? Every year we must submit amp/hr. usage to our
local air resources boards all across the state. How hard can it be
for CARB to have the local agencies send current year end reports
for 2022 to obtain accurate emission data?
I have briefly reviewed just local data provided by CARB staff in
the San Joaquin Valley APCD and the Permitted Annual Throughput
Amp/Hrs. reported column is flawed by a huge number. Two facilities
that were permitted for a total of 10,500,000-amp hrs. in 2019 are
not even in business now. That is two facilities out of the six
that have closed and it took about an hour of my time to confirm.
Another data point that jumps out is one decorative facility
permitted for 41,328,000 amp-hrs. and have throughput of that exact
amount?  And this is not the only example as there are eight
facilities by CARB's numbers that are running at maximum allowable
permitted numbers in the decorative columns alone.
My experience in this industry of over 4 decades tells me this is
highly unlikely; it is more likely that staff didn't have
throughput emission numbers and plugged in maximum allowable to
complete the chart. This causes incorrect data points and elevates
emission values across the decorative side of the industry. 
I can only surmise that if these emission values are used in the
decorative side, then what kind of errors are being made in the
hard chrome and anodizing emission charts? As stakeholders how do
we know that the input data is correct? CARB staff don't seem to
have to check their work for accuracy as we do as stakeholders. If
we supply incorrect data to a regulatory agency, we are held
accountable or fined even for a mathematical mistake.
It has become obvious that the goal is to push this rule through at
all costs as soon as possible even if the facts don't support
CARB's claim that the chrome finishing industry is a major
contributor of hexavalent chrome emissions in the state.
Time has come to pause this draconian rule and reevaluate the
emission data with accuracy and integrity before moving forward
with any proposed new regulations, let alone a ban date that will
severely harm the finishing industry here in California while
providing no meaningful reduction of hexavalent chrome emissions in
the state.

Sincerely,
Art Holman
Sherm's Custom Plating