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Comment 9 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-1.

First NameBobbiProposed
Last NameBurns
Email Addressbobbiburns@sbcglobal.net
AffiliationGlobal Plating Inc
SubjectProposed Ban on Hex Chrome ATCM
Comment
Contempt prior to investigation is the best way to summarize the
latest revisions made to the proposed amendment to the ATCM. CARB's
presentation from June 2022 stated that "Chrome Plating emissions
account for less than 1%" in the State of California. The slides
presented to the public showed our Industry responsible for 10 lbs
annually of Hex Chrome. Now in March 2023, CARB has stated we are
.19 percent and approximately 1 lb annually. The CARB Board and
public have been mis-informed. Several journalists have published
articles with the inaccurate data quoted directly from CARB's
presentations. Our Industry has been prejudicially singled out and
the proposed BAN renders our assets to CARB's favorite word "ZERO"

It is CARB Staff's opinion that there is no safe level therefore
none of the proposed options to add more controls to achieve an
even lower emission is worth discussing. This proposed BAN has been
generated by an attempt to calm the emotional outcry of
disadvantaged communities. Communities that are mostly affected by
mobile sources of pollution that we all contend with. Communities
that have been built around industrial areas due to poor city
planning and greedy land developers. 
I see my neighborhood over the last three years developing
thousands of homes, not low-income housing, very expensive high
rise type homes right in the center of the industrial area, between
two freeways in Fremont, CA. This mixture is problematic and when
government officials introduce flawed data, there is panic and
outrage by all parties affected.  I am embarrassed and disappointed
that CARB has not removed the BAN from this proposed rule, mostly
because CARB Staff knows the truth about the emissions in our
Industry. The fact that CARB would use our Industry for a political
glory is a shame. I urge CARB to keep this amendment an emission
base rule, not a ban. Please do not abandoned decades progress in
the road to lowering emissions by terminating an entire industry,
an Industry that has invested in the ATCM and has proven there is a
way to keep Chrome Plating in this State.


Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-07 12:33:22

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