TELEPHONE:
847-214-2100
W.
R.
MEADOWS,
INC.
1
SEA1I1GHT®J”
RO.
BOX
338 • HAMPSHIRE,
IL 601 40-0338
Website:
www.wrmeadows.com
e-mail:
wrmil@wrmeadows.com
November 14, 2008
John Therriault, Chief Clerk
Clerks
Office
Attention Docket
#R09-08
NOV
142008
Illinois
109
W.
Pollution
Randolph,
Control
Suite
11-500
Board
pouT
E
0
sr
Control
Board
Chicago, Illinois 60601
RE:
Illinois EPA
Architectural and Industrial Maintenance
(AIM)
Coatings;
Dear Mr. Therriault:
Docket
#Rø98
t
7
W.R. MEADOWS, INC. is
a
manufacturer of architectural coatings utilized in the commercial concrete
construction market and has
a
manufacturing operation in Hampshire, Illinois.
W.R. MEADOWS, INC. is
a
member of the National Paint
&
Coatings Association (NPCA) and supports
NPCA’s request
to
extend the implementation date of the AIM rulemaking from January 1, 2009
to
July 1,
2009
to
allow Illinois
adequate
time to finalize and
adopt
the amendments
to
the AIM rule, and more
importantly,
provide
adequate
time for industry
to
make necessary changes in order
to comply with the
amendments.
With the new
AIM
amendments,
in addition
to
changing
thousands of formulations, paint manufacturers
will need
to
develop and print new labels for the reformulated products, Further, computer
systems and
other
“lock-out” systems need
to be
upgraded
to
prevent shipment of
“non-compliant” products into
Illinois.
In addition, it
will take significant time for
manufacturers
to
properly communicate the new
VOC
limits to all distributors, customers, and specifiers
in
order
to
ensure their compliance with the new
products. It is impossible for manufacturers
to
make these necessary
changes
and properly
communicate
the
details
of
the
Illinois ATM rule without having
a
final
adopted rule in hand, particularly,
as
additional
changes
may occur between
now and the final adoption.
Therefore, W.R. MEADOWS, iNC. strongly
believes that the implementation
date
must
be
moved
to
July 1, 2009.
Thank
you
for your consideration of our
request.
If
you have any questions or require additional
information please contact me
at
(847) 214-2232.
Dave
Sincerely,
Carey, CHMM,
Q
Vic-President
Plant
Operations
CC: Jim Dwyer, Matt Price, Harry Meadows, Brent
Weber, Dave Duewel
ENVIRONMENTALLY
RESPONSIBLE
CONCRETE
PERFORMANCE
PRODUCTS