First Name | Scott |
---|---|
Last Name | Watson |
Email Address | sowatson@earthlink.net |
Affiliation | IPMG |
Subject | Don't Let Perfect be the Enemy of Good... |
Comment | Firstly, so that everyone understands how I am a stakeholder in this issue: I am a resident of the State of California, my Corporation is a California corporation, and I am a taxpayer. My company is sales representatives for importers of hardwood plywood. However, it should be noted that our sales DO NOT take place in California but I feel so strongly about this issue that I wanted to address the board. Please understand that I think that the idea of reducing formaldehyde emissions from wood panels is a noble pursuit that I am totally in support of – but these regulations remind me of the adage “Don’t let perfect be the enemy of good” It is my opinion from my participation in the workshops that this regulation is overreaching, very costly, and I have the opinion that it is being ramrodded through by CARB staff There is currently only one standard with regard to formaldehyde emissions in the United States and that is the HUD Standard that has been used in mobile home and RV construction for years. There are limits set in that Standard that have already addressed this issue and current technologies are able to manufacture product to these levels. The HUD limits set in that standard are twice what the CARB regulation is requiring. Because this regulation applies to every manufacturer and importer and user throughout California I would like to suggest that to truly accomplish this task, that CARB will need to create a new enforcement agency called the CPP – The California Panel Police – and I would love to apply to be a member of the force because it will be a total bureaucracy that will make very little difference but will offer good wages and benefits that the state taxpayers will have to pay for. It is my opinion that the cost models that staff have offered are seriously flawed. There are so many areas where I believe these models to be flawed that it I could spend my entire time refuting the models alone. Therefore, I will address only three points. These products are commodities. Their value is determined by only two things – supply and demand. If and when California implements this regulation, you will have a single manufacturer presently that could supply everyone in the state of California. As demand increases for the product so does the price. Not only in California, but throughout the country as well, as more of the currently available production is consumed into California. What is behind this effort is perhaps a sense of goodwill to reduce formaldehyde emissions, but in my opinion it is really about Profit. If we can regulate folks to NEED our product it becomes more valuable to the company making it and they sell it for more. Secondly, the cost to administer this program as well as the reduced production cycles and third-party administration costs are going to be enormous. Those factors have not been addressed in my opinion and added to the cost models that CARB staff is providing. The product or consumer ultimately will have to bear these additional costs and to not address them a s a real cost component just seems silly. Lastly, the cost of this program I had seen in the staff reports is estimated to swell from 154 million dollars per year to over 1.5 Billion if I recall correctly. I am concerned that this becomes an additional cost to the taxpayers of California an “unseen tax” if you will. An expenditure of this size I would hope would require greater oversight by the state budget process. And this leads me to my final point…. My allegation of a sense of Ramrodding I do truly appreciate the candor and openness of the CARB staff that I have seen participate in this process. What I do not understand is the pervasive attitude that this is the regulation that is going to go into effect….PERIOD. In my short period of participation in this issue it seems that staff has an answer for every question that comes up to explain away that particular issue. However, the fundamental assumptions are flawed and the assumptions that are made on top of those flawed assumptions are further flawed and so on. To put it in other words, I am flabbergasted at the explanations that CARB staff has offered as fact. These are not facts - these are opinions based upon assumptions. What I also fail to understand is that the California ports are a gateway to the Western part of North America. Under this proposal we will still allow the materials to come through the ports of California and he stored there, as long as the material is to be sold out of state. Do you see the hypocrisy in this? We are willing to let this “dangerous material” into the ports but it can’t be sold in the state of California. Can you imagine the number of lawsuits that California might eventually face from the dock workers unions at the port? It is as if because they are the through-way of the product its okay for them to be around the chemical but its not okay to keep it here. I just don’t understand that. It is as if California is willing to allow the handling of a supposedly dangerous substance through the port because of the revenue and jobs it produces, but it has to leave the state to be sold. If the objective is to reduce the amount of formaldehyde through California, then why not ban it from arriving in the first place? Banning the importation to the port of a dangerous substance altogether would make a lot more sense to me. Conclusion I appreciate the amount of work that staff has put into this effort. However, I ask each and everyone of you on the board to table this regulation until such time that we can further debate the science, costs, and merits of this proposal. While it is a noble pursuit for us to want to reduce a potentially harmful chemical, I would urge you to adopt the HUD regulation that currently exists until such time that we can further debate the issue and come to a more comprehensive agreement. I believe it fair to say that the Europeans that have the most restrictive emissions limitation in the world today. I for one as a taxpayer in the state of California do not want to even begin to think about setting the most restrictive standard in the world today. Are we going to be admired for it? I don’t think so. I believe this will be seen as another in a long line of items that the rest of the country will see with contempt as a move by the “California Wackos”. I honestly believe that CARB could do more good for the state by getting 10 persons to stop smoking than they will with a 1 ½ Billion dollar program, that is overreaching, unenforceable and seriously flawed. Please, I urge you, be practical, don’t let perfect be the enemy of good – adopt the current HUD standards and let’s get back to work implementing a known standard as well as discussing this issue and science further so that in the future we can make an even better decision. I thank you for your attention. Scott Watson IPMG, Inc. PO Box 2738 Oroville, CA 95965 530-589-4816 |
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Date and Time Comment Was Submitted | 2007-04-25 10:46:18 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.