Draft
    Bulletin
    Page
    1
    of2
    John
    Therriault
    - ILlmplementationdatefinal.doc
    October
    8,
    2008
    Clerk’s
    Office
    Attention
    Docket #2008-017
    Illinois
    Pollution
    Control
    Board
    James R.
    Thompson
    Center
    100
    W. Randolph,
    Suite
    11-500
    Chicago,
    Illinois
    60601
    OCT
    082008
    \ii
    n1
    /i!!
    f
    /);
    RE
    Illinois EPA
    Architectural
    and Industrial
    Maintenance
    (AIM)
    Coatings;
    Docket
    #2008-017;
    NPCA
    Comments
    To Whom
    it May
    Concern:
    li-i
    The National
    Paint
    and Coatings
    Association
    (NPCA)
    submits
    the
    following comments
    on the
    final
    draft
    amendments
    to the
    Illinois
    EPA
    (ILEPA)
    AIM
    rulemaking.
    NPCA
    appreciates
    the
    changes
    that
    ILEPA
    has made
    to the
    AIM
    rulemaking
    in response
    to our
    comments.
    It is our understanding
    that
    before the
    AIM
    rulemaking
    can
    be adopted
    it must
    first
    go
    through
    a
    first
    and
    second
    notice period.
    Further,
    it is our
    understanding
    that the
    first and
    second
    notice period
    could
    take
    several
    months
    to
    complete
    and it likely
    that
    the final
    adoption
    of the
    rule
    may
    occur
    simultaneously
    with
    or
    after
    the currently
    proposed
    January
    1, 2009 implementation
    date.
    Thus,
    NPCA
    respectively
    requests
    that the
    current implementation
    date be
    extended
    to at least
    July 1,
    2009
    to
    allow
    IL
    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
    need
    to
    develop
    and
    print new
    labels for the
    reformulated
    products.
    Since
    labels
    and manufacturing
    costs
    are very
    expensive,
    paint manufacturers
    try to
    manage
    changes
    to products
    to prevent
    costs
    associated
    with obsolete
    products
    and
    labels. Further,
    most
    paint
    manufacturers
    now utilize
    extensive
    computer
    systems that
    need to be
    upgraded
    to prevent
    shipment
    of “non-compliant”
    products
    into areas
    with
    new
    VOC limits.
    In addition,
    it
    will
    take
    significant
    time
    for
    manufacturers
    to properly
    communicate
    the
    new VOC
    limit changes
    to all distributors,
    customers
    and specifiers
    in
    order
    to ensure
    their
    compliance
    with
    the
    new products.
    From:
    To:
    Date:
    Subject:
    CC:
    “Dave Darling”
    <ddarling@paint.org>
    <therriajipcb.state.il.us>
    10/8/2008
    1:11 PM
    ILlmplementationdatefinal4oc
    <foxt@ipcb.state.il.us>
    PoUutjo
    STATE
    OP
    Controi
    ILLINOIS
    Board
    file
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    Draft
    Bulletin
    Page 2
    of 2
    It is
    impossible for manufacturers to make these
    necessary changes and properly communicate the
    details of the IL AIM
    rule without
    having a final adopted rule in hand, particularly, as additional
    changes
    may occur between first notice
    and
    final
    adoption.
    NPCA strongly believes that to allow IL adequate time to complete the first and
    second notice periods,
    and to allow industry
    adequate
    time to meet all of the new rule requirements, as well as changing
    computer systems, notif,ring supply chains, and making label changes and other administrative
    procedures that
    accompany
    a new rule, the implementation date must be moved to July 1, 2009.
    Thank you for your consideration of our request. Please do not hesitate to contact
    us if you have any
    questions or need additional information.
    Sincerely,
    Is!
    Is!
    David F. Darling, P.E.,
    Alison Keane
    Director,
    Environmental Affairs
    Counsel, Government
    Affairs
    **
    Sent via email and in hard-copy
    **
    Ui
    NPCA is a voluntary,
    nonprofit trade association representing some 350 manufacturers of paints, coatings, adhesives,
    sealants, and
    caulks, raw materials
    suppliers to the industry, and product distributors. As the preeminent organization representing
    the coatings industry
    in the United
    States, NPCA’s primary role is to
    serve
    as ally and
    advocate
    on legislative, regulatory and judicial issues at the
    federal, state,
    and local
    levels. In addition, NPCA
    provides
    members
    with
    such
    services
    as research and technical information, statistical management
    information,
    legal
    guidance, and community service project support.
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