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Comment 42 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectATCM & SRIA Technology Assumptions Invalid
The CARB ATCM SRIA estimates a benefit of 10 pounds of hex chrome
per year. 86% of that benefit is derived from the impact of the
ATCM on hard chrome platers. Yet, the ATCM does not identify any
technology which is capable of replacing hard hex chrome plating. A
technology is imagined for the purpose of cost and benefit
estimation in the SRIA. 

We are able to determine from the SRIA that the attributes of the
imagined hard chrome plating technology are as follows:

Emissions - None
Implementation Cost - $4 Million per facility
Method of applying the technology - undefined
On-going operational cost - Same as current technology
On-going operational process time - Same as current technology
Effectiveness of technology attributes - Same as current technology
(with no analysis of hardness, lubricity, coefficient of friction,
wear resistance, corrosion, porosity, method of application,
Technology adoption rate - immediate at implementation of the new
Technology adoption scope - all applications simultaneously

Technology development as it relates to hard chrome alternatives
has been ongoing for more than 25 years and is well understood. The
assumptions above are NOT consistent with the most likely
technological development path for a hard chrome alternative in the
future. The most likely technology development path will not have a
binary yes/no ability to change technological attributes (named
above) all at once across all applications. 

This SRIA completely fails to recognize how technology change
occurs and is implemented, yet it allows CARB to take credit for
86% of a benefit without associated recognition of cost. 

There is no analysis of the costs to other supply chain
participants (manufacturers, maintainers, etc...) from changing to
the imagined technology in the this SRIA.

Original File Name
Date and Time Comment Was Submitted 2023-01-15 07:39:23

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