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Comment 32 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
Email Addressjmeyer@aviation-repair.com
Affiliation
SubjectWhy has CARB stopped updating Hex Chrome Statistics?
Comment
Any discussion about hex chrome rules should be based on data and
that data should be made available to the public in a transparent
and accurate manner.

CARB has posted data about Hex Chrome at their own website here:
(https://www.arb.ca.gov/adam/toxics/statepages/cr6state.html).
Thank you CARB. The data include helpful computations for MEAN
levels of hex chrome and ESTIMATED RISK of hex chrome statewide
since 1991. Please note the improvements made over that time. For
reasons which are not clear to this reader, CARB has stopped
supplying the MEANS and the ESTIMATED RISKS since the beginning of
this rulemaking. I could guess that this is because some months do
not contain data but this is curious given the higher number of
observations shown. Even more baffling is the lack of data
observations shown in the second half of 2022. Why would CARB stop
sharing data with the public concurrent with this rule making and
leading up to a CARB board decision? Coincidence? It is hard to see
this as coincidence and it is especially troubling when we have
also learned from CARB that the data in appendix B is not correct.
Why is data about hex chrome emissions less available and less
reliable just as the CARB board and the public and the impacted
parties are approaching decision?

Um... We deserve answers.


Attachment
Original File Name
Date and Time Comment Was Submitted 2023-01-09 15:13:52

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