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21901

South

CentraIAveue

Matteson,

Illinois

60443

1-08-20-0600

Sax

‘-708-720-1967

November

13,

2008

John

Therriault,

Chief

Clerk

CLERK’S

OFFICE

Clerk’s

Office

Attention

Docket

#R09-08

.

Illinois

100

W.

PollutionRandolph,

ControlSuite

11-500

Board

IitIon

irILUNOjc

Control

8od

Chicago,

Illinois 60601

RE:

Illinois

EPA

Architectural

and

Industrial

Maintenance

(AIM) Coatings;

Docket

#RO9tO8

J

7

Dear

Mr.

Therriault:

The

Ace

Hardware

Paint

Division

produces

the

Ace

brand

paint

for

over

4,500

Ace

Hardware

stores

in all

50

states

and

in

50

countries

worldwide

from

our

two

plants

in

Matteson,

IL

and

Chicago

Heights,

IL.

We

produce

over

9,000,000

gallons

of

Ace

brand

paint

per

year.

Ace

Paint

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 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.

Further, computer

systems

and

other

“lock-out”

systems

need

to

be

upgraded

to prevent

shipment

of

“non-compliant”

products

into

IL.

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.

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

now

and

the

final

adoption.

Therefore,

Ace

Paint

strongly

believes

that

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,

Jack

Wickharn

Director