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Comment 3 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 15-2.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectEnvironmental Analysis needs to be changed
Comment
In the Environmental Analysis section of the documents released
last night, CARB staff states, DIRECT QUOTE "Since these values
were not used in the evaluation of environmental impacts in the
Draft EA, staff has determined that these changes would not require
new or modified compliance responses and would not result in any
new reasonably foreseeable significant environmental impacts or
substantially increase the severity of an already identified
environmental impact in he Draft EA."

Wow, we are talking about CARB's estimate of ACTUAL emission
levels. Not baseline emission levels, not permitted emission
levels, we are talking about CARB's estimate of ACTUAL emission
levels so keep that in mind and re-read the quote above.

CARB is saying that they don't need to change the environmental
analysis due to a change in ACTUAL emissions "since these values
were not used in the evaluation of environmental impacts in the
Draft EA." in the first place!

Did you know that the State can ignore actual current environmental
conditions when preparing an Environmental Analysis? I didn't. But
CARB admits here that they paid no attention to ACTUAL emissions
when they prepared the Draft Environmental Analysis so they don't
have to react when the estimate of ACTUAL emissions changes (in
this case by 50%)! 

Does CARB think this is legal?
Do any other attorneys out there think this is legal?

Every day of my life I learn something new. I am learning so much
about environmentalism.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-04-27 14:21:00

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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