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Comment 74 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameJim
Last NameMeyer
SubjectNext Up? The 99%
Imagine that the CARB Board approves this non-emission based ATCM. 
The EJ's can run a victory lap and 1% of the hex chrome problem
will be solved in 2039. But what about the 99% of hex chrome
emitters still out there. CARB will now be in a position wherein
they have discredited the best available control technologies for
dealing with Hex Chrome. HEPA filtration isn't adequate anymore and
since 99% of the problem is still there, the EJ's won't be
satisfied (unless this was just an isolated witch hunt). The EJ's
will demand action and eventually, CARB will need to acknowledge
that hex chrome emission do come from the manufacture, use of, and
destruction of cement and concrete; that the working of stainless
steels including welding and machining cause hex chrome emissions;
that even electric vehicles need brakes. What then CARB? You will
need a list of imagined replacement technologies to use as excuses
for banning cement, stainless steel, and coatings. Is that even
achievable? There are practical people and independent thinkers in
your organization, they know the reality of the world we live in
and while we would all like things to be better, we must focus on
the things that are achievable if we are to make progress. We are
not going to stop construction of buildings, roads, and vehicles
and CARB will not have the political power to ban them. The only
alternative is to eventually be honest with the EJ's and show them
that the numbers and science don't support the fear that has been
created. That the politicians who benefit from the fears are
manipulators. That other risks are far more powerful in our lives.
If CARB can't be honest, you will no longer be a science focused
organization. Perceptions of CARB will continue the shift from
being science based to being politics based. Is that what CARB

Original File Name
Date and Time Comment Was Submitted 2023-01-17 19:22:25

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