Department of Commerce
    and Economic
    Opportunity
    620 East Adams
    Street,
    S-6
    Springfield,
    Illinois 62704
    AUG
    0
    2009
    STATE
    OF ILIJNOIS
    Pollution
    Control
    Board
    Re:
    Request for
    Economic
    Impact
    Study
    for: Reasonably Available
    Control
    Technology
    (RACT)
    for Volatile Organic
    Material
    Emissions from Group
    II
    Consumer
    & Commercial
    Products:
    Proposed Amendments
    to
    35
    Iii.
    Adm.
    Code
    211, 218, and 219,
    (Ri 0-08)
    Dear Director
    Ribley:
    C
    -
    Sirns
    .
    Thons
    ‘Ves
    R.jupi
    Suite
    Chica, tJ_
    or
    312-S14-?620
    FAX
    TY
    3I2Ai
    6032
    On August
    6,
    2009, the Board
    accepted for
    hearing a proposal
    in Reasonably
    Available Control
    Technology
    (RACT)
    for
    Volatile
    Organic Material
    Emissions
    from Group II
    Consumer
    &
    Commercial Products:
    Proposed
    Amendments to
    35 Ill.
    Adm. Code
    211, 218, and 219,
    (R09-21).
    This
    rulemaking was
    filed with the Board
    on July
    9,
    2009,
    by the Illinois
    Environmental
    Protection Agency.
    Generally,
    the
    Agency proposes
    to adopt air
    pollution regulations
    to control
    emissions of volatile
    organic
    material
    for Group
    II Consumer
    & Commercial Products
    in ozone
    nonattainment
    areas
    classified
    as moderate and
    above.
    Group
    II products include
    industrial
    cleaning solvents,
    flat wood paneling
    coatings,
    flexible packaging
    printing
    materials,
    lithographic
    printing materials, and
    letterpress
    printing materials.
    I write
    to request
    that your Department
    conduct
    an economic impact
    study concerning
    this
    proposal.
    Since
    1998,
    Section
    27(b)
    of the Environmental
    Protection
    Act has required
    the Board to:
    1) request
    that
    the Department
    of Commerce
    and
    Economic
    Opportunity
    (formerly
    the Department
    of Commerce
    and
    Community
    Affairs) conduct
    a
    study of
    the
    economic
    impact of the
    proposed rules.
    The
    Department
    may
    within
    30 to 45
    days of such request
    produce
    a study
    of the economic
    impact
    of the proposed
    rules. At a minimum,
    the economic
    impact study shall
    address a) economic,
    environmental,
    and public
    health benefits
    that may
    be
    achieved
    through
    compliance with
    the proposed
    rules,
    b) the
    effects of the
    proposed rules
    on employment
    levels, commercial
    productivity,
    the
    economic
    growth
    of small
    businesses
    with 100 or less
    employees, and
    the State’s
    overall economy,
    and
    c)
    the
    cost
    per
    unit
    of pollution reduced and
    the
    variability
    of company revenues
    expected to
    be used to implement
    the
    proposed rules;
    and
    August
    6,
    2009
    Warren
    Ribley, Director
    OVE
    CLERKS
    OFFICE
    WEB
    SITE
    w’.ipcbstaeiJ

    (2)
    conduct
    at least
    one public
    hearing
    on
    the
    economic
    impact
    of those
    rules.
    At
    least 20
    days
    before
    the hearing,
    the
    Board
    shall notify
    the public
    of
    the hearing
    and
    make the economic
    impact
    study,
    or
    the Department
    of
    Commerce
    and
    Economic
    Opportunity’s
    explanation
    for
    not producing
    an
    economic
    impact
    study,
    available
    to the public.
    Such public
    hearing
    may
    be
    held
    simultaneously
    or as a
    part
    of
    any
    Board
    hearing
    considering
    such
    new
    rules.
    415
    ILCS
    5/27(b)
    (2008).
    The Board
    is
    in the process
    of scheduling
    a hearing
    in
    this
    rulemaking.
    Although
    there
    is no
    decision deadline
    in
    this
    rulemaking,
    the Board
    intends
    to
    proceed
    promptly
    with
    this
    rulemaking,
    and
    asks that
    you respond
    to this
    request
    as
    soon as you
    conveniently
    can.
    If I,
    or my staff,
    can
    provide
    you
    with any
    additional
    information,
    please
    let me know.
    Thank
    you
    in
    advance
    for your prompt
    response.
    Sincerely,
    G.
    Tanner
    Girard
    Acting
    Chairman
    Pollution
    Control Board
    cc:
    John
    T. Therriault,
    Assistant
    Clerk
    of
    the
    Board

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