First Name | Art |
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Last Name | Holman |
Email Address | art@shermsplating.com |
Affiliation | Sherm's Custom Plating |
Subject | Incorrect 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 |
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Date and Time Comment Was Submitted | 2023-04-10 12:13:26 |
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