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CARB has not defined what a technology review is. What is CARB's
definition of a technology review? What criteria would be used to
ascertain that an alternative technology is viable in terms of
capability, reliability, market acceptance, economics, and
environment? (not a comprehensive list of criteria). 

Who would be the participants in a technology review? We can see
who participated in the technology review which led to where we are
on Page 230 of the ISOR. I suggest that reviews of materials and
processes which keep transport aircraft airworthy should be
weighted towards scientists and engineers. The LA Times published
an article on Jan 27 in which an environmental and community
justice advocate and attorney is quoted as saying "We would be
working with the industry and the military to actually identify new
coatings. That's precedent setting". Indeed it is.

CARB does not seem to realize that hexavalent chrome is used in a
variety of chemical solutions to process parts constructed of a
wide range of base materials and alloys (some ferrous and some
non-ferrous) for a wide range of applications. There will not be a
singular magic technology that will replace hex chrome across all
applications at the same time. Change will occur incrementally
process by process. Change will not occur facility type by facility
type. CARB's references to technology reviews in the posted
materials are little more than a punt. A dangerous punt if you rely
on commercial aircraft for transportation.

CARB points to an apparent comment by Boeing that a 2039 phase-out
date is OK with Boeing so long as there are technology reviews.
Boeing has reason to be confident they can overwhelm CARB in a
technology review, however, we have not seen any concurrence by
Lockheed, Raytheon, Airbus, Parker, Honeywell, Northrup, DOD, the
FAA or anyone else with the requisite technical expertise. Many of
the supply chains supporting these entities have already left
California.

At what point leading into 2039 will CARB relax the ban when a
technological substitute is not found?