|Subject||CARB Chrome Plating ATCM|
Re: CARB Chrome Plating ATCM Eugene, 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 community. 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 found. Sincerely, Richard Roberson
|Original File Name|
|Date and Time Comment Was Submitted||2023-01-04 14:48:12|
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