First Name | Jim |
---|---|
Last Name | Meyer |
Email Address | jmeyer@aviation-repair.com |
Affiliation | |
Subject | SRIA 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? |
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Date and Time Comment Was Submitted | 2023-04-03 15:37:03 |
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