Comment Log Display

Consider the marginal benefit to the public of including the
future-dated 2039 ban in the rule. Especially consider that the ban
is subject to "technology reviews" which will require CARB staff
and industry to come to agreement about factual truths. The ban is
15 years away. There is no imminent benefit, only the cost of
industry leaving the state and costing jobs in the communities the
board believes they are protecting. CARB staff and industry do not
agree today that the emissions inventory presented by CARB is
factual. The source test average for hard chrome platers, in
reality, is not the 0.000588 mg per amp-hour that CARB has
presented. This is a fact that the board can verify prior to a
vote. The board should insist that CARB staff provide them the
source test data for all facilities for verification. The board has
a duty to base decisions on facts. If decisions are not based on
verifiable truth, of what value is a technology review? It serves
no purpose except to appear to mitigate the impact of a ban which
has a political motivation rather than a factual motivation. A ban
does not spur investment by small plating firms to invent the
replacement for hexavalent chrome. Each board member must decide
where her moral axis is with respect to truth. Choose truth. Why is
there a need for CARB to present untruthful and misleading data to
the public in order to enact this rule? Are you a part of it? Why
are you on the CARB board? Are you a tool of a political patron or
an independent thinker?