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Comment 27 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameRich
Last NameRoberson
SubjectCARB Chrome Plating ATCM
Re: CARB Chrome Plating ATCM

I would like to express concern of a complete ban of Hexavalent
Hard Chrome plating on behalf of our Team members here at Roll
Technology West (RTW).
Our Team members invested time into their profession and have made
it not just a job, but a career.
Our team members are puzzled why the career they chose, is being
targeted for a complete ban. They are bewildered why an industry
that makes up less than 1% of hex chromium emissions nationally, is
being targeted for elimination. 
RTW's Team members have always done the right thing and followed
all the rules, procedures, and permits.
"And we must recognize that communities of color have a range of
views and concerns. "-CARB Chair Randolph
RTW's team members have children and grandchildren who are all are
part of a community of color. They work in this community. They
have homes in this community. 
"We cannot fail in our efforts to listen, engage, and work towards
equitable solutions as best we can. "-Chair Randolph
The complete ban of Hexavalent chrome plating is the exact opposite
of equitable solution. There is no alternative for the Hexavalent
Hard chrome plating of Work rolls.
Our team members would be laid off and because their career is
banned, the skills, which they have worked so hard to hone, would
be worthless. 
This would be traumatic for our Team members, families, and

I understand CARB's quest to look for an alternative to Hexavalent
Hard chrome plating. However, there is no viable alternative for
the Hexavalent Chrome plating of Work rolls. 
Therefore, I ask CARB not to institute a complete ban on Hexavalent
Hard chrome but rather, consider a more equitable solution and
adopt the European model and grant conditional exemptions until a
viable and proven alternative is found. 
If granted, a conditional exemption would give RTW the ability to
remain in operation until a viable and proven alternative is


Richard Roberson

Original File Name
Date and Time Comment Was Submitted 2023-01-04 14:48:12

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