|Subject||ATCM & 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, etc..) Technology adoption rate - immediate at implementation of the new technology 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.
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|Date and Time Comment Was Submitted||2023-01-15 07:39:23|
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