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SRIA 1.6, pages 14-16 describe the construction of CARB's baseline
for this rule. CARB has stated that the annual baseline is 10.15
pounds per year. On page SRIA 15, the last sentence of the third
paragraph states, and I quote:

"Considering BASELINE EMISSIONS CALCULATIONS WERE BASED ON SOURCE
TESTING INFORMATION in 2019 or earlier, outside of the pandemic
timeframe, staff estimates that emissions will remain the same in
future years in the baseline scenario".

Again, the SRIA states that the "BASELINE EMISSIONS CALCULATIONS
WERE BASED ON SOURCE TESTING INFORMATION".

But this is not true. 

As clearly shown on the third version of the still incorrect Table
1, the computation of the baseline in Column 6 is:

"(permitted annual throughput) X (2007 emission factor) =
(Potential to emit) = 10.15 pounds"

Do you see any reference to source test information in that
formula? I do not.

Because of this explicit statement "BASELINE EMISSIONS CALCULATIONS
WERE BASED ON SOURCE TESTING INFORMATION", Along with our
reasonable expectation that computation of a baseline should
incorporate consideration of actual conditions, the metal finishing
community had an expectation that the third correction of Table 1
would incorporate a comprehensive review of the entire data set and
the computations and assumptions used within it. We expected
two-way communication from a staff concerned about accuracy and
truth, but communication was not forthcoming. Staff chose to modify
only a single value which they have labeled as the "average" hard
chrome source test result. The modified value did have cascading
effects, and did change calculated total annual emissions, but the
aggregate actual emission sum (1.05 pounds) is still incorrect and
overstated. It is incorrect due to errors of omission, errors of
assumptions, and logic errors which still exist in the table(s)
(inclusive of Table 2).  

Why is CARB playing this game wherein they do not engage in
dialogue with industry on this rule? Why are our written inputs,
provided in these public (and many non-public emails) being
ignored?

Is CARB staff under direction to not work with industry on this
rule?

Why does CARB state that the baseline is computed based on source
tests, when it clearly is not? Why does the baseline exceed actual
emissions by a factor of 10X?

Has CARB notified the California Department of Finance that the
data used to construct the SRIA baseline is not based on actual or
source tested emissions? 

Has the decision to ban chrome plating in California already been
made? Were the SRIA, ISOR, emissions inventory, health risk
assessment generated to document, after the fact, a decision
already made by the legislature? Or CARB? Or the governor?

Is there an audit function within the State of California which
reviews agency procedure, practice, and engagement with the
public?

Is science in California a political process?