|Subject||Technology Reviews are undefined and vaguely timed|
The proposed rule establishes the timing of two "technology reviews" which will be used to determine when and whether functional and hard chrome platers should be eliminated earlier than 2039. The rule includes no definition of "technology review". It should be obvious this is a problem. The rule states only that the first technology review must be "complete...by January 1, 2032." Therefore, the first technology review could occur in 2023 and the rule would be met. Hard chrome platers and anodize facilities could be eliminated before decorative per this rule. There is no basis for any business to invest capital (or stay) in California if CARB can eliminate them by performing an undefined process, maybe tomorrow, or maybe sometime in the next ten years. What is a reasonable person (and business, and concerned citizen, and etc.) to conclude? Is this how CARB writes rules now? After more than three years of effort? The only thing we can know about CARB's intended "technology review" is what we see has occurred with respect to the decorative chrome platers and the review of trivalent chrome plating technology. What was the venue in which this occurred? Who organized and conducted the review? Who was asked to participate in the review? How much diversity of opinion was allowed in the process and how was it dealt with to reach conclusions? How did CARB assess the needs of customers in the marketplace? Were decorative platers involved in the review? Who advocated that trivalent chrome was an acceptable substitute? When, how, and who made the decision that "trivalent chrome" could substitute? Do CARB, CARB staff, CARB board members have any economic interest in research or firms associated with trivalent chrome technology? So many unanswered questions. The proposed undefined and vaguely timed "technology reviews" are unacceptable.
|Original File Name|
|Date and Time Comment Was Submitted||2023-01-06 07:29:57|
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