Comment Log Display

Wildfires are the largest threat to California's air resources.
CalFire is the agency responsible for responding to wildfires.
Aviation equipment is CalFire's most responsive and effective tool
for combatting wildfire. Aviation equipment is manufactured and
kept in good repair using hard chrome plating processes. CalFire's
aviation fleet cannot fly without properly maintained propeller
systems, main and tail rotor controls and servos, landing systems,
and thrust reversers to name only a few flight critical systems
reliant on hard chrome plating. These systems are pervasive across
the entire CalFire fixed wing and helicopter fleets and across the
fleets of contract aviation companies used by CalFire in response
to major incidents. These systems require frequent inspections,
sometimes during incidents, and those inspections can dictate
removal and replacement of the component before the aircraft can
fly again. Removed components can be (and are) repaired with hard
chrome plating processes and returned to "rotable pools" to assure
rapid replacement of flight critical components during fire season
and major fire incidents. Rapid and effective repairs are a
contributing factor to CalFire readiness. 
There is not a technological alternative to the use of hard chrome
plating in the manufacture and repair of these fire-fighting
aircraft. The aircraft are certified as safe by the Federal
Aviation Administration because of engineering designs and repair
and maintenance schemes which utilize hard chrome applications. So,
not only is hard chrome the only technology available to support
these firefighting assets, hard chrome is the only legal method to
support these assets. 
The California Air Resources Board has banned chrome plating in
California. The ban for hard chrome is effective January 1, 2039.
The ban was instituted by CARB with knowledge that no technological
substitute has been invented/discovered. CARB is also aware that if
a technological substitute is found, the substitute method must be
found acceptable to aircraft design engineers and the FAA prior to
the use of that method in future designs and repair schemes. Even
the newest aircraft designs of airplanes coming off assembly lines
today use chrome plating. This means that chrome plating will be a
necessary part of infrastructure for at least 30 years and since
fire-fighters like to use aged aircraft designs as platforms
(C-130, UH-1 are over 60 years old), it is easy to see that CalFire
will rely on chrome plating well past 2039.
California chrome plating firms who support CalFire face
elimination. They are on death row. Each dollar invested in
facility or equipment is wasted. CalFire may have expanding needs
for fire suppression, but chrome platers are not incentivized to
invest in capacity. They are incentivized to close - an expensive
proposition. Closing and moving is even more expensive. They will
close and they won't wait until 2039 to do so. 
The work of supporting CalFire will fall to chrome platers in other
states and countries - Locations with less robust regulatory
controls than California. Locations with no rule 1469, the toughest
chrome rule in the world. So, if CARB is correct about deadly
emissions, CARB will have shifted those emissions to locations
where they will be even more deadly. CARB says it believes in the
equality of all people but this is a concrete example of explicit
CARB policy to move emissions to areas where people are
disadvantaged by less stringent regulatory regimes in addition to
all the other disadvantages they may encounter in life. In October,
a CARB Board member posted on "X" her thanks to aviation
firefighters for saving her community. Her future posts will need
to also extend thanks to the people of Mexico, Arizona, and Nevada
for their sacrifice in using a process that she banned to protect
her.
It is reasonable to conclude that other states and countries will
not put up with California's behavior forever. Policy makers in
those states, countries, and at the US federal level are likely to
understand the bigger-picture practical necessity to maintain
aircraft to put out fires. California and CARB should expect to
encounter funding and policy difficulties as this situation
persists.
By the way, chrome plating is not just used on fire-fighting
aircraft. Chrome plating is also used on all transport aircraft,
freight aircraft, military aircraft, and coast guard aircraft. CARB
is destroying the infrastructure of America and to some extent the
world. It is time to correct CARB's mistake. It is time to
recognize that HEPA controlled chrome platers who comply with AQMD
Rule 1469 (the toughest chrome plating rule in the world) who don't
use PFAS/PFOS (and never did), and who are not located near
sensitive receptors are an acceptable and reasonable risk
considering the damage done by fires in California. 
This is yet another attempt to create constructive dialog with a
motivated CARB. One introductory phone call is an extremely poor
look for you. Responsible board members should feel embarrassed.
Public comment is not dialog. It is proof of the lack of dialog.