Comment Log Display

Two years ago, the Board decided to take the regional SCAQMD Rule
1469, the toughest rule in the world, and apply it statewide. The
resulting ATCM could have positioned CARB as a leader in fighting
toxics. However, simultaneously, the board banned (future date) the
hard chrome plating companies that were already complying with SC
AQMD Rule 1469. The ban included companies who were located in
non-residential areas, not near schools or sensitive receptors, not
using PFAS, with fully compliant BACT and who obviously were
capable of meeting the toughest regulatory standards in the world!


The implications of this action were immense. CARB's willingness to
ban compliant firms with the demonstrated capability to meet the
toughest standard in the world proves that CARB does not view
business as partners in the effort to improve the environment. How
can you ban the most capable firms in the world and call yourselves
leaders? It should be obvious that without the participation of
industry, the world's environment cannot improve. The banning
decision is two years old, plating companies are making plans to
transfer work to Mexico and other less regulated environments. As a
result, net air pollution will increase and as we all know, air is
not stationary. There has been no progression that I am aware of in
the ability of trivalent chrome plating to replace hexavalent
chrome plating for flight critical aviation parts.

I remain available to work with staff to amend the rule to
eliminate the ban for hard chrome applications where a
technological and legal (FAA) alternative does not exist. 

I would appreciate an acknowledgement of this comment and an
assignment to staff that they work to amend the rule to eliminate
the hard chrome plating ban.

P.S. Immediately following the LA Fires, we used hard chrome
plating to repair aircraft used to fight the fires. The repairs we
made will enable the aircraft to fight future fires and by doing
so, will eliminate more hex chrome than we emit annually.