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Comment 30 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectTechnology 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
" 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

Original File Name
Date and Time Comment Was Submitted 2023-01-06 07:29:57

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