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Comment 21 for Perchloroethylene Dry Cleaning Operations 2006 (perc06) - 45 Day.

First NameJames
Last NameRoybal
Email Addresslcabrales@verizon.net
AffiliationResidents of Pico Rivera for EJ
SubjectProposed amendments to the ATCM
Comment
Residents of Pico Rivera for Environmental Justice
3658 Gangel Ave. Pico Rivera, CA 90660
(213) 427-5973


May 24, 2006


Mr. Bob Fletcher
Division chief
California Air Resources Board-Stationary Source Division
1001 I Street, P.O. Box 2815
Sacramento, CA 95812

Dear Mr. Fletcher,

I am writing to express my concern over the Air Resources Board
(ARB) staff’s proposed amendments to the Airborne Toxic Control
Measure (ATCM) for perchloroethylene in dry cleaning. The
scientific data shows that perchloroethylene (“perc”) is very
harmful to human health, and dry cleaners using this chemical pose
an unacceptable health risk to their employees, their customers and
our neighborhoods. The control measure that the ARB has proposed is
not enough to protect Californians from this toxic chemical. 

It has been our experience that local communities cannot always
rely on their local governments or regional agencies for
protection from toxics, unless toxics are phased out. In the past,
our local government, which lacks knowledge of the threats some
small business present to the community, has failed to stay in
contact with our regional regulatory agencies for this type of
information. At least the SCAQMD has made the right move to phase
out this toxic. However, most communities throughout the state are
still waiting for a similar action. 

I urge you to replace the current proposal with an expeditious
phase-out of perc in dry cleaning.

Perchloroethylene is known to the state of California to cause
cancer. Also, the non-cancer health effects include headaches,
dizziness, nausea, vomiting, fainting, fluid buildup in the lungs,
and damage to the central nervous system, kidneys, liver and
reproductive system.  

ARB estimates that about 3 million pounds of perc are released
into California’s air each year by the dry cleaning industry
alone. Based on EPA data, perc is one of the top 10 most toxic air
contaminants in California.

I am in favor of alternatives to the use of the toxic chemical
perc, such as wet cleaning. Professional wet cleaning uses only
water and non-toxic biodegradable detergents that are
environmentally friendly, less costly and may even save energy.
Wet cleaning is effective in washing delicate garments but does
not melt buttons or ornamentation on garments. 

Furthermore, AB 998, legislation that took effect in January 2003,
directed ARB to apply a fee on the perc used in dry cleaning, use
some of the funds collected to establish a demonstration program
of non-toxic, non-smog forming alternatives, and use the
additional funds for grants to cleaners which are making the
transition to these safer alternatives.   

Unfortunately, more than two years after this law took effect, ARB
has not made sufficient progress to implement the program. Coupled
with the weak Dry Cleaning ATCM, this raises serious questions
about ARB’s commitment to pollution prevention and to the
protection of public health from toxic chemicals.  

Local communities cannot rely on their local governments and/or
agencies alone. We will not be able to protect workers, customers
and our communities, unless your agency acts immediately to phase
out perc in dry cleaning. Please phase out perc in dry cleaning.

Thank you for your consideration.

Sincerely,

James Roybal
President

Attachment
Original File Name
Date and Time Comment Was Submitted 2006-05-24 10:58:30

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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