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Comment 6 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
SubjectSRIA Cost / Benefit Relationship no longer relevant
Comment
The SRIA painted the picture that implementation of the proposed
ATCM will provide an annual hex chrome emission reduction benefit
of 10.15 pounds annually at a cost of $688 Million. That works out
to $68 million per pound of hex chrome reduced.

Subsequent publishing of the ISOR in November of 2022 and now the
revised emissions inventory in March of 2023 reveal that there are
only 0.19 pounds of hex chrome actually emitted annually. So, this
is a 53-fold reduction in the benefit for the same cost. 

Let's assume for now, that CARB's March 27 emission inventory is
correct and that the costs originally assumed in the SRIA have not
changed. We can calculate the benefit at 0.19 pounds per year and
the cost at $688 million and determine that the cost of the ATCM is
now $3.621 Billion per pound of hex chrome reduced. Considering all
the non-chrome plating sources and emissions which have not been
addressed by CARB yet, California is looking at an absolutely
crushing economic hit to come in the range of more than $100
Billion.

How does the Department of Finance feel about this proposal now?

 

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-03 15:37:03

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