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Comment 80 for Proposed Amendments to the ATCM for Chromium Electroplating and Chromic Acid Anodizing Operations (chromeatcm2023) - 45 Day.

First NameEd
Last NameAppleton
Email Addressedd@thechromeplace.com
Affiliation
SubjectTRIVALENT CHROME IS NOT AN ALTERNATIVE YET
Comment
Granted, decorative trivalent chrome has improved over the years
and may be suitable for some applications.  

HOWEVER...
The motorcycle and automotive industry, in which we serve, is not
only decorative but needs to be functional as well.  The chrome
plated finish needs to have both that beautiful appearance and also
be able to withstand the effects of the environment.

The two types of trivalent chrome that are available do not provide
the characteristics required for both the aesthetic and
anti-corrosive properties in comparison to hexavalent chrome.

The trivalent chrome that looks closer to the hexavalent chrome
does not have the anti-corrosive properties and durability while
the other one that has better anti-corrosive properties but does
not have the aesthetic appearance.   

Neither one of these "alternatives" will serve our customer's
needs... 

Banning hexavalent chrome is not the answer !!!

- Customers and revenue will be driven to other states.
- Businesses, such as ours that strictly serves this clientele,
will close and jobs will be lost.
- Banning hexavalent chrome in California will not protect the
environment, it will actually increase the overall environmental
damage due to looser environmental standards in other states.

There needs to be a balance...

The implementation of proven measures throughout California that
have been established in cooperation between the agencies and
industry, such as SCAQMD Rule 1469, would provide responsible
stewardship of the environment, health standards and businesses.

Therefore, we do not need to eliminate an entire industry that
provides beneficial products and services to many companies and
consumers in addition to providing thousands of jobs within the
State of California.

Thank you for your consideration in this matter.

Attachment
Original File Name
Date and Time Comment Was Submitted 2023-01-17 22:44:22

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