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Comment 4 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectAB 617 Community Emissions Reduction Plan

Attention CARB board members. 

South Coast AQMD and leaders in this community spent many months, days, and hours to create a Community Emissions Reduction Plan under AB 617. Please have your staff take a look at it. It is for the Wilmington, Carson, West Long Beach Community which CARB consistently uses as a poster child for disadvantage relative to the environment. The Cal Enviro Score in West Long Beach near Cabrillo High School is in the 96th percentile.  

Here is the final CERP published in 2019.

On page 3a-9, the chart shows the total cancer risk in our area by cause. It shows that cancer risk from diesel is more than 1000 in a million but that cancer risk from ALL OTHER SOURCES COMBINED (INCLUDING HEX CHROME) is less than 240 per million. So, why does CARB, in the ISOR document take pains to point out that hex chrome is 500 times more cancer potent than diesel? That is a very misleading way to present potency information. The AQMD method of presentation is much more honest. CARB staff should be ashamed of that. Why bring up diesel in the hex chrome ISOR document at all? Your staff knows these numbers and this data but has consciously chosen to present it in the most fear provoking way possible. Is diesel so prevalent that we measure and express cancer risks relative to diesel in ATCMs so people can understand? Has diesel pollution become the standard to which other risks are compared? Pretty pathetic approach to science and to communication of real risk if you ask me. It is certainly not representative of an organization purporting to be the World Standard in air pollution control.

An astute reader will go on to note that the same cancer risk chart on page 3a-9 shows the relationship between diesel and other air toxics IN THE ENTIRE SOUTH COAST BASIN which is home to 86 of the 113 hex chrome facilities in this ATCM. This isn't just an isolated area this is the vast majority of what your decision will impact with the ATCM. The data shows diesel FAR outweighs hex chrome in terms of cancer risk to the entire South Coast community. 

But let's talk about hex chrome a little bit more. Look at Page 3b-1 of the CERP. I am intrigued by the information in the box that states hexavalent chromium is a key air toxic in this community and that the cause is MOSTLY FROM BRAKE WEAR... yet we should BAN chrome platers. If you ban chrome platers the employees who live here will become unemployed, how does that help them or the people in this community?

Original File Name
Date and Time Comment Was Submitted 2022-12-06 16:20:07

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