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.
https://www.aqmd.gov/docs/default-source/ab-617-ab-134/steering-committees/wilmington/cerp/final-cerp-wcwlb.pdf?sfvrsn=8
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?