Comment Log Display

The result of the State's business case for this rule proposal is
found in the SRIA on page SRIA 2. It shows that rule implementation
will achieve a cumulative benefit of 132 pounds of potential
emissions over the next 20 years. The backup year by year savings
that drive this number are found in Table 2.3 on page SRIA 23. You
will need to total the values across the rows of Table 2.3 and
multiply by the years represented and add them at the bottom. If
you do that math, you will be rewarded. The numbers will add up and
support CARB's assertion of a 132 pound reduction in potential
chrome emissions over the next 20 years. It is important to note
that the baseline CARB uses to support this calculation is set at
10.15 pounds per year. 

CARB's re-computation of the actual emissions by chrome platers was
recently made available on April 26. It tells us in Table VI.1 on
page 21 of the 15 day 2nd release that actual industry emissions
from all sources are 1.05 pounds per year (see the lower right
corner of the table). If we look to the left by two columns on the
same table we can see that CARB is still using the 10.15 pound
annual baseline. If the baseline is 10.15 and the actual emission
is 1.05, then the difference between these values is 9.1 pounds.
So, we are getting 9.1 pounds of chrome reduction per year already.
If we extend our current savings for the next 20 years, we will
achieve 182 pounds of benefit. 

It is possible to put this on a table for easier understanding...

                                                            ATCM   
            Do Nothing
Reduced Potential Hex Chrome         132 lbs.                 182
lbs.
Cost to the California Economy       $ 688 Million                $
0
 
CARB data and logic support the case that doing absolutely nothing
is preferable to the proposed ATCM with a ban.

This analysis was enabled by the flawed assumptions and faulty
logic that CARB (with cooperation from the California Department of
Finance) has employed regularly throughout this rulemaking. It
should be apparent to the reader that CARB's estimate of actual
industry emissions proves a ban is not necessary.