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CARB banned hard chrome plating in California in the May 2023 board
meeting. The ban became law on January 1, 2024. This board meeting
marks a year since the decision was made.

As a direct result of CARB's decision, Hawker Pacific Aerospace has
announced closure. They employ 350 people. As an aircraft landing
gear overhaul facility, a critical piece of their value chain was
an in-house hard chrome plating process. A small minority of the
employees work in the chrome work cell but because it is central to
the entire overhaul process, and because other processes cannot be
performed without it, the entire facility will be shut down. Assets
will be auctioned in June.

When CARB received input from the Aerospace industry that a ban of
hard chrome platers and anodizers would be highly detrimental
because trivalent chrome plating was not technologically feasible,
CARB's solution was to kick the can down the road by implementing
"technology reviews". CARB saw this as the way to satisfy industry
concerns. Industry disagreed with CARB in public comment and
predicted CARBs decision would result in closures of business which
are high value to the people of California and their communities in
terms of wages, benefits, and infrastructure support. 

CARB had a choice, it could:
1)	ban hard chrome platers and offer to modify the ban based on
future technology review, or 
2)	it could hold future reviews to inform a decision, and then ban
based on the future technology review.

CARB chose to be uninformed and the rule is structured around
concept 1. 

So, now we see that an aerospace employer with 350 people, of whom
only a couple handfuls worked in the plating operation, will close
and that thousands of people (including families and other
supporting businesses) in a disadvantaged community (95%
CalEnviroScore 4.0) will pay the price. 

The company closing the facility is based in Europe and is rated in
the top quartile by a reputable environmental sustainability rating
firm. They are not irresponsible operators. They utilized BACT as
required by the SC AQMD. CARB failed to analyze Hawker's BACT
source test in the rule making and presented data to the public
which overstated emissions from the facility. As a result, there
will be very little improvement in hex chrome levels in the
community at this cost of 350 jobs.

The underlying market for Hawker's services (landing gear overhaul)
is very strong at present, especially with the ongoing Boeing 737
Max issues and Airbus A320 series engine issues. New aircraft are
not being delivered to airlines and therefore older aircraft are in
great demand. Older aircraft require landing gear overhauls. Yet,
this viable aviation maintenance business is closing in California.


CARB used the statement, "there is no safe level of hex chrome
emissions" to justify the knee jerk implementation of this rule.
But this rule impacts less than 2% of hex chrome emitters. CARB has
not taken equivalent action on the remaining 98% of hex chrome
emitters over this past year. This dichotomy, urgent rhetoric about
a dangerous condition, contrasted with a complete lack of CARB
action tell us what we need to know. Actions speak louder than
words. The urgent threat statement by CARB should not be believed.
Governor Newsom's recent announcement of a new steel plant
development tells us that he is also not concerned about hex chrome
emissions.  So why did CARB do what it did?

Does the CARB board have a learning loop in which poor decisions
and the process steps which led to them are critically examined and
corrected?

When will the board correct the flaws in the chrome plating ATCM?