First Name | Tracey |
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Last Name | Coss |
Email Address | traceycoss@scpci.com |
Affiliation | |
Subject | ATCM for hex chrome |
Comment | I urge the California Air Resources Board [CARB] to NOT move forward with the proposed amendment to the Airborne Toxic Control Measure for Chromium Electroplating and Chromic Acid Anodizing Operations [CrVI ATCM], and instead to revise the ATCM to provide emission control measures that will be effective in further reducing the negligible amount of air emissions of hexavalent chromium from metal finishing facilities, recognize the extremely negative consequences of proposed bans, and provide a reasoned, science-based approach and emission-based rule moving forward. The proposed ban on CrVI plating fails to acknowledge the importance of this segment of manufacturing in California, the significant emission reductions the industry has achieved to date and can obtain through further emission reduction efforts, and the increase in emissions (from commercial trucks transporting products for CrVI plating) that will result from plating operations moving to other states and countries with less, if any, emission requirements. Further, bans will leak significant businesses and associated jobs away from California! CrVI plating facility emissions have been significantly reduced over the years to the extent that chrome metal finishing comprises significantly less than 1% of total annual CrVI emissions for the entire state. No other state or country has CrVI emission limits anywhere near the level of protections already established in California. CARB should acknowledge that protection of the environment is best achieved in California by working WITH industry. I urge CARB to remove the ban, correct the data, SAVE JOBS, and prevent business from closing down and/or leaving the state. |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2023-04-10 13:58:41 |
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