Comment Log Display

West Long Beach is a heavily impacted community. It is the poster
child for nearly every CARB communication about air pollution
impacts. Images of the ports, trucks, rail, and refineries in this
community are used in CARB communications and by politicians to
elicit funding and gain public support for improvements. The
community conditions were used to stimulate AB617 which spawned the
CAPP. Here is what happened in West Long Beach.

WCWLB was the first AB 617 CSC. It identified the concerns of the
community as DPM and other oil related emissions from Ports, Rail,
Freeways, Refineries. Many of these large organizations
(corporations) had sufficient budget to assure that their
representatives sat on and/or coordinated with the WCWLB CSC and as
a result, no port, rail, trucking, freeway, or refinery in WCWLB
has been banned by CARB.

Secondarily, the WCWLB CSC mentioned a much smaller concern about
hex chrome emissions resulting from brake dust (freeway/truck
related). The CERP did not identify chrome plating as an issue. 

But CARB did ban chrome plating! EVEN THOUGH THE WCWLB CERP DID NOT
IDENTIFY IT AS A CONCERN. CARB ignored industry comments during the
CARB ATCM rule making, ignored the reality of source test results
which they did not bother to get from SC AQMD to inform the rule
making, created a concept of "fugitive emissions" which they based
on air sniffing in another city with plenty of other bigger hex
chrome sources. Even though chrome platers make up less than 2% of
the hex chrome emissions in the state, they banned chrome
plating...and haven't banned any other hex chrome sources!

My small hard chrome plating business is banned. The business has
invested well over $200,000 in pollution control equipment,
procedures, and effort. Our chrome plating process has followed
every SCAQMD rule and registered a "non-detect" for hex chrome in
the latest pollution source test. We repair the flight critical
aircraft and helicopter parts which keep the CalFire aircraft
operating to put out the fires that produce FAR more hex chrome
emissions than we do. BUT CARB BANNED US!
 
Five generations of my family have lived in West Long Beach. We
invested by starting our business in the community. We invested in
state of the art pollution control equipment. We hire from the
community. We have hired the homeless! Our equipment meets the SC
AQMD rules and yet CARB banned us. Why?

We are legally required by the FAA (a FEDERAL agency) to repair
parts only with Hex Chrome plating. There is no technological
substitute available. I am unable to create or invent other
processes to meet customer needs. I will have to go out of
business. It is too expensive to move the business. The ban impacts
my ability to sell the business (who would buy a banned business
and what would they pay?). Sale of the business is part of my
retirement plan. I am at retirement age. How can the CAPP be deemed
a success when it does not ban the central concerns of a community
(all big corporations) and instead bans a small business owned by
private individuals? Where is justice? How can CARB say it cares
about equity and justice? Does CARB justice not apply to small
businesses? How is it possible that I can make so many comments to
CARB and follow CARB processes exactly as they are laid out and yet
receive no action, no response, and ultimately no justice through a
"community" program such as this. Does anyone of any intellect read
these comments and act upon them?