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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