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Comment 4 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-1.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectWARNING - Compliance is not a success strategy in California
Comment
CARB's March modification of the proposed new chrome plating rule
failed to delete the ban. The message from CARB to business remains
the same...

Businesses that adopt a compliance based strategy to do business in
California are not safe. CARB will ban you anyway, and they will do
it with full knowledge that the replacement technology for your
process has not been invented yet. They will do it even if your
site selection process selects a non-residential location. This
warning is applicable to any business that works not only with
chromium but also stainless steel.

Southern California has the strictest and most effective chrome
plating rule in the world already (Rule 1469). Chrome plating firms
in Southern California are already in compliance with Rule 1469 (if
they are not, CARB and AQMD are not effectively enforcing existing
regulations). CARB's proposed ATCM continues to impose a ban on
these compliant businesses. They cannot grow and they will be
eliminated with no alternative paths to comply.

Heed this warning if you are considering investment in California.
Compliance will not save you.


Attachment
Original File Name
Date and Time Comment Was Submitted 2023-03-31 06:25:45

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