To whom it may
concern:
My name is Jason Wenig and I am the owner of The Creative
Workshop. The Creative Workshop is a nationally recognized, highly
specialized car workshop business – noted for the forensic
restoration of rare, exotic and unique, historically significant
automobiles.
I am
writing this letter as a representative of a billion dollar
industry that works hand and hand with the decorative chrome
industry – an integral and critical part of the highly
specialized work we conduct.
Specifically, it seems California is looking to ban
all use of Hexavalent Chrome. The subject of this initiative
through CARB is “Hexavalent Chromium Airborne Toxic Control Measure (ATCM)
for Chrome Plating and Chromic Acid Anodizing
Operations”.
I have
been deeply involved in the automotive world for over two decades
and have worked with countless suppliers, craftsmen and supporting
industries. My company was named a “Top 20 Restoration
Company” in the country in 2018 by one of the
industry’s leading publications and I was awarded
“Master Craftsmen of the year” in 2019 by the
America’s Automotive Trust. My biography is attached for
further reference.
The
vehicles entrusted to my company are some of the rarest and most
valuable in the world, and require a diverse set of skills and
supporting infrastructure to work on them. Akin to rare
artwork or historic building restoration, the vehicles we work on
are meticulously and authentically rebuilt – using historical
archives, original factory drawings and documents and numerous
other, sometimes rather arcane methods. In addition, the materials,
supplies and technology utilized to restore and maintain these
historic artifacts are equally obscure.
Vintage
cars touch all walks of life – and have become something much
more than a niche hobby. To further reinforce this reality and the
nature of these vehicles, we work with the Historic Vehicle
Association, which is working in collaboration with the U.S.
Department of the Interior in developing a National Historic
Vehicle Register to carefully and accurately document and recognize
America’s most historically significant automobiles,
motorcycles, trucks and commercial vehicles. This project is the
first of its type to create a permanent archive of significant
historic automobiles within the Library of Congress.
As you
can imagine, working with historically significant vehicles –
and in turn, our collective history – details matter. As
historians entrusted with this responsibility, when considering
these details, “close enough” is not good enough. There
is “correct” and “incorrect”,
“right” and “wrong”. We work incredibly
hard to ensure that restorative work is done correctly and right.
Along these lines, the coatings used throughout the history of the
automobile is very much a part of our responsibility to get right,
and quite simply put – there is no substitute for proper,
Hexavalent Chrome. Historians, collectors, aficionados, curators
– we all know the difference between “proper decorative
chrome” vs alternatives. Alternatives cannot be used and
should not be used on these incredibly valuable and coveted
assets.
Said
another way, house paint would not be used to restore a Picasso
just as plywood would not be used to restore a Tall Ship. To the
untrained or uneducated eye, paint is paint and wood is wood
– but for the integrity of our history, there is obviously a
rather large difference when it comes to “correct” and
“right”.
How we
protect our history comes down to the front lines of the craftsmen
that are entrusted to restore and maintain it – and the
“tool kit” we have available to us, simply cannot be
diminished.
What
further complicates this situation is that the number of businesses
dedicated to automotive decorative chrome continues to shrink
– with a troubling few businesses left that are capable of
doing this kind of work. The few that do remain, simply must be
protected - we can’t afford to lose any more plating
companies – wherever they may be located. For instance, we
work with Sherm’s Custom Plating in Sacramento, California
(www.shermsplating.com). It
took us years to find them. We performed tests with numerous
companies located around the country, and only Sherm’s had
the skills, capabilities and understanding of how to deliver
correct, authentic chrome for historic cars.
An
outright ban on this industry in California will cause irreparable
repercussions that will ripple throughout the industry – not
just for the plating companies located in California, but to and
through all of the companies that rely on their services to
“get the job done right” across the Country.
Massive
events around the world celebrate the automobile – including
the most prestigious car event in the world - the Pebble Beach
Concours d’Elegance located in Monterrey, California. Cars
invited to and displayed at Pebble, set the standard for the
history books. The wealthiest individuals in the world attend, and
the most valuable vehicles in the world are on display. Hundreds of
millions of dollars of automotive history are on display every
August – and simply put, chrome alternatives would never be
accepted during the judging process – whereby the best and
correctly restored vehicles are awarded. This reality would repeat
itself at events the world over.
What’s interesting and salient is that the volume
of materials and supplies used for this critical work is small
compared to its importance, and pales in comparison to the volumes
used in general industry, where chrome alternatives could readily
be accepted. Penalizing small boutique businesses (and the low
volume of supplies they use) to solve a problem that is
fundamentally not caused by this group - that is already tightly
regulated - is both near-sighted and counter-intuitive. The benefit
to result ratio is completely off by targeting the decorative or
even specifically, the automotive show chrome industry.
The
decorative chrome industry, as well as other supporting disciplines
to the automotive world, are used to operating under regulations
and controls – including proper hazardous waste disposal,
limitations on volume, specialty filtration and particulate
control, etc. We understand this is done so a partnership between
business and protecting our environment can establish itself. This
balance and partnership is in place and evolves as necessary. An
all out ban, of the entire industry in California – combining
low-volume automotive businesses along with larger commercial or
industrial platers, again, seems counter-intuitive.
For the
record, I am particularly sensitive to this subject matter and
debate. I am originally from New York, where my Father, the late
Dr. Jeffrey Wenig, was director of Environmental Protection during
the 1970’s. I grew up with the environment and our care of
it, as an integral part of our lives. I take these matters very
seriously and I am not writing this letter and voicing my opinion
arbitrarily. I am hoping that healthy debate and logical terms can
be established for the benefit of all parties involved.
All
said, I implore you to understand the true nature of our industry
and its reliance on a small portion of the Hexavalent Chrome that
we use – and to engage with the vested community, so that we
can continue forward in collaboration and partnership –
considering all implications to our industry, our history, jobs and
of course the environment.
I am
available to provide any additional information or discuss in any
way to help further this process along.
Thank
you,
Jason Wenig
Owner and
President
The Creative
Workshop
118 Hill Street
Dania Beach, FL 33004
954-920-3303
jpw@TheCreativeWorkshop.com