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Comment 11 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameWilliam
Last NameGanahl
AffiliationSouth City Rod and Custom
SubjectChromium Plating Ban in California

 To whom it may concern,

I own a small business here in California restoring classic cars.  I restore and customize cars from the 1920's through the 1960's, all of which have many chrome pieces.  We restore these cars to an extremely high level, and they have been shown around the country, and some around the world.  We compete for awards, which is a big part of our business, and the finish and texture of the chrome on these cars is a detrimental component of our ability to compete at a high level.  I know that there are many shops here in California (the epicenter of custom and classic car culture) that share the same experience and produce the same level of quality as we do.  We absolutely cannot use any other method or quality of chrome plating than hexavalent chromium to complement the quality of our builds.
I understand that if Hex Chrome is banned in CA, we could potentially send our parts out of state to be chromed.  First, we currently do not ship any parts to chrome; we personally deliver all parts so as not to damage or lose any of these valuable pieces.  Many of the parts are hand-made from scratch and have countless hours into their fabrication and manufacture.  And many of the parts are very rare, very valuable original pieces that cannot be duplicated or replaced.  For this reason, we cannot take the risk of shipping parts and having them damaged or lost.  And second, it is typically California's intention to set precedent by example; if other states follow suit and hex chrome is banned in America for good, it would seriously affect the entire industry of classic and custom car building and restoration.  This could mean job losses in both the chrome industry AND the classic and custom car industry, which I think you will find is a very large industry (just look at the number of car events and TV shows currently).
All of this said, the amount of pollution caused by the hex chrome process is miniscule compared to the large-scale production of mass-produced commodities.  We are building one to three cars per year, which means our collective use of the chrome process is very small.  It is an essential part of these builds, yet a very small portion of the overall output of chrome shops in general.  But there are chrome shops that specialize in our specific, very high standard requirements, and they would be devastated by this ban.  They are all upstanding businesses (the ones we deal with) that already comply with state and federal laws, and some of which would already comply with proposed laws, as they want to stay ahead of the curve and curtail pollution and emissions.
Please consider amending your proposed legislation to allow for concessions for my industry.  If this might mean allowing small production numbers, while banning production over a certain limit, I am positive that the businesses in my industry would fall well below any threshold of significant pollution.  Car culture, while not appreciated by everyone, is an integral and important element of Californian and American popular culture.  It is part of our history that we are trying to maintain and carry on, and it represents a huge industry that affects multitudes of businesses that contribute to the craft.
Thank you for your consideration,
Bill Ganahl


South City Rod & Custom
22432 Thunderbird Place
Hayward, CA 94545
(510) 783-6300

Original File Name
Date and Time Comment Was Submitted 2022-12-13 09:18:08

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