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Comment 10 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-1.

First NameArt
Last NameHolman
Email Addressart@shermsplating.com
AffiliationSherm's Custom Plating
SubjectIncorrect data
Comment
The CARB board has a responsibility to hold staff accountable for
accurate data to base this rule making process that will affect the
lives of thousands of people here in the state and beyond. To date
the emission rate data that's been shared have been flawed,
therefor it is impossible for the board to make an educated
decision on this very aggressive rule.
Using staff's table III.1 as an example, why are we even looking at
estimated emission rates? Local air districts have actual reported
amp hours and emission rates as required by law. CARB staff must
input the correct data to comprise a true representative sample of
industry emissions, only then would the board have the information
required to make a decision that will impact so many lives.
The first working group meeting was held Sept. 11, 2020, and still
we are being presented with flawed emission rate numbers. Initial
data submitted by staff for this rule was the Chrome Plating
Industry as a whole emitted 10.15 lbs. of hexavalent chrome
annually. That information was shared with the public and created
an outcry within communities and environmental groups. Now in the
15-day comment period, data is shared and emission rates are 0.19
lbs. annually, but the damage has already been done.
CARB Board members must hold staff accountable to provide accurate
information regarding emission rates before a decision is made that
will affect so many lives and jobs here in California. As a CEO of
a company, you would require your staff to present accurate data
for the basis of making a decision that will impact your business
livelihood and that of your employees. Inaccuracies would not be
tolerated, but CARB staff faces no consequences for reporting these
inaccuracies or failing to provide requested information to
stakeholders.
I urge the Board to delay this rulemaking process until such time
as the true emission numbers have been calculated using accurate
amp hrs. and source test emission rates as reported to local Air
Districts.

Respectfully,
Art Holman                                                         
                                                                   
                                                                   
                              
Sherm's Custom Plating

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-10 12:13:26

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