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COUNTY DEPARTMENT, LAW DIVISION
IN THE MATTER OF:
PROPOSED NEW 35 ILL, ADM. CODE
PART 223 STANDARDS AND
LIMITATIONS FOR ORGANIC MATERIAL
EMISSIONS FOR AREA SOURCES
R08-17
(Rulemaking
Air)
TRANSCRIPT OF PROCEEDINGS held in the
above-entitled cause before Hearing Officer Timothy
Fox, called by the Illinois Pollution Control Board,
pursuant to notice, taken before Rebecca Graziano,
CSR, within and for the County of Cook and State of
Illinois, at the Thompson Center, 100 West Randolph,
Room 2-025, Chicago, Illinois, on the 4th Day of
June, A.D., 2008, commencing at 9:00 a.m.
Page 2
1?
APPEARANCES
2
ILLINOIS POLLUTION CONTROL BOARD
3
Mr. Timothy J. Fox
4?
Ms. Andrea Moore
Mr. Nicholas Melas
5?Mr. Anad Rao
6
THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
7
Mr. Rory Davis
8?
Mr. Charles Matoesian
9
THE CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
10
Ms. Lisa Frede
11
12?
W.R. MEADOWS, INC.
13?
Mr. Dave Carey
14
THE NATIONAL PAINT AND COATINGS ASSOCIATION
15
Mr. David Darling
16
17
?
HODGE, DWYER, ZEMAN,
3150 Roland Avenue
18
?
Post Office Box 5776
Springfield, IL 62705
19?
(217) 523-4900
BY: MS. KATHERINE HODGE
20?
MS. LAUREN LURKINS
21
?
Appeared on behalf of the Illinois Environmental
Regulatory Group.
22
23
24
Page 3
1?
MR. FOX: The time of 9:00 o'clock having
2
?
come and just passed, I want to call this hearing to
3
?
order. Good morning, and welcome to the Illinois
4
?
Pollution Control Board hearing. My name is Tim
5
?
Fox, and I am the hearing officer for this
6
?
proceeding entitled Proposed New 35 Illinois
7
?
Administrative Code 223, Standards and Limitations
8
?
for Organic Material Emissions for Area Sources.
9
?
The board docket number for this rulemaking is
10
?
R-0817. The proposal was filed by the Illinois
11
?
Environmental Protection Agency on January 2nd of
12
?
2008, and the Board accepted it for hearing in an
13
?
order dated January 24th of 2008. Also present from
14
?
the board today are, at my far left, board member
15
?
Andrea S. Moore, who is the lead board member for
16
?
this rulemaking, and to my immediate left is Board
17
?
member, Nicholas J. Melas, to my right is Anand Rao
18
?
of the Board's technical staff.
19
?
Today we are holding the second
20?
hearing in this rulemaking. The first hearing took
21?
place Wednesday, April 30th, 2008, in Springfield.
22?
This proceeding is governed by the Board's
23
?
procedural rules. All information that is relevant
24
?
and not repetitious or privileged will be admitted
Page 4
1?
into the record. Please note that any questions
2
?
that are posed today either by the Board members or
3
?
the Board staff are intended solely to help develop
4
?
a clear and complete record for the Board's decision
5
?
and do not reflect any judgment or prejudgement or
6
?
conclusion regarding the proposal.
7
?
The Board did not receive
8
?
pre-filed testimony for this second hearing. If any
9
?
participant wishes to testify today, there is a
10
?
signup sheet and pens sitting directing in front of
11
?
our court reporter. If you do wish to testify, you
12
?
certainly would be sworn in and may be asked
13
?
questions about your testimony as any other witness
14
?
would be.
15
?
We will begin this hearing with
16
?
the Agency. There are questions, clearly, that the
17
?
participants have for them on the basis of their
18
?
proposal, and after that, as time permits, any
19
?
person who wishes to testify may do so. And as a
20
?
housekeeping matter for the benefit of our court
21
?
reporter, please speak clearly. I don't think
22
?
amplification will be an issue in this room with
23
?
this many people, and avoid speaking at the same
24
?
time as any other person so that we can have a
Page 5
1?
transcript that is clear -- that is as clear as
2?
possible. Do we have any questions before we
3?
proceed to the Agency for questions at all? Very
4?
well. Mr. Matoesian, if you would like to begin.
5
?
MR. MATOESIAN:
Okay. Thank you, sir.
6?
Good morning. My name is Charles Matoesian.
I'm
7?
appearing for the Illinois Environmental Protection
8?
Agency. With me today is Mr. Rory Davis, an
9?
engineer with the Agency. Having providing
10?
testimony at the first hearing, we are here mainly
11?
to answer questions from the Board and the public.
12?
I
would state for the record, however, having spoken
13?
to the USEPA, the federal aerosol rule is beyond
14
?
legal challenge at this point. So with the Board's
15?
permission we will be filing an errata sheet to
16?
withdraw our portion of the rule dealing with
17?
aerosol codings, which is subpart D, starting at
18?
223.400
and going on. So that's -- just that for
19?
the record.
20?
And I would note we filed a second
21
?
errata sheet on Monday. I'm not -- I hope
22?
everyone's gotten it, but the Board may not have
23
?
gotten it yet. This concerns a lot of the, sort of,
24?
housekeeping issues that came up with the first
Page 6
1
?
draft of the rule. And with that I will send it --
2
?
some things back over to the Board.
3
?
MR. FOX: Very well. For the record,
4
?
Mr. Matoesian and I, in discussing procedural
5
?
matters before hearing began, did mention the
6
?
Agency's errata sheet No. 2 to one another. To the
7
?
best of my knowledge, that mail service has not been
8?
completed on the Board. What we discussed was if
9?
there is interest in seeing it in the course of this
10?
hearing today, we could adjourn for a brief break,
11?
make copies, and have it admitted in the record so
12?
that it was in front of us at the matter of the
13?
discussion. I plainly see some indication that we
14
?
would like that to happen, and that participants
15
?
would like to have the errata sheet in front of them
16
?
today for the purpose ' of the hearing. So we can
17
?
break at an appropriate time so that is part of your
18
?
record here this morning, Mr. Matoesian. Thank you.
19
?
MS. HODGE:
Oh, we do have a copy of
20?
it.
21?
MR. MATOESIAN:
They have a copy of
22?
it.
23?
MR. FOX: I apologize. It may very
24?
well be arriving in our Chicago office as we speak.
Page 7
1?
MR. MATOESIAN: Okay.
2?
MR. FOX: And I believe the Board and
3
?
its staff would be content to await that --
4?
MR. MATOESIAN: Okay.
5
?
MR. FOX: -- based on the technical
6?
and housekeeping nature of the errata sheet. But it
7
?
appears that I was mistaken that there is not at
8
?
this point specific interest in having it admitted
9
?
this morning as a hearing exhibit. Mr. Matoesian,
10
?
thanks for letting me interrupt. Did you have
11
?
anything further you wished to add?
12
?
MR. MATOESIAN: No. That's okay.
13
?
MR. FOX: We certainly can field --
14
?
Mr. Matoesian, on behalf of the Agency, can field
15?
any questions. If anyone does have a question, if
16
?
would they please raise their hand so that I may
17
?
recognize them. And please, if they would, for your
18
?
first question, indicate who you may represent and
19
?
in what capacity you may do so in addition to your
20
?
name. Miss Hodge, I believe you have a question.
21
?
MS. HODGE: My name is Katherine
22
?
Hodge, H-o-d-g-e, and I'm with the law firm Hodge,
23
?
Dwyer, Zeman, here today representing the Illinois
24
?
Environmental Regulatory Group.
Page 8
1?
MR. FOX: And Ms. Hodge, I should have
2?
done this first of all. Before the Agency does
3
?
accept questions, it would be best, I think, for the
4?
court reporter to swear them both in.
5
?
MR. MATOESIAN: Swear him in.
6?
MR. FOX: Swear him in.
7?
(Witness sworn.)
8?
MS. HODGE: I have a few questions for
9?
Mr. Davis, and the first question goes to the
10?
statement in the Agency's technical support
11?
document -- and would it be better if I moved up for
12?
this? Okay. And as I said, this goes to the
13
?
Agency's technical support document, and in
14
?
particular, Mr. Davis, in the Section 2.7, reduction
15?
of the Illinois emissions in Illinois, it's on
16
?
Page 29 of the TSD. The Agency says that the
17?
emission reduction from this proposed rule will help
18?
Illinois attain the eight hour national ambient air
19
?
quality standard by 2010. The TSD further states
20
?
that such emission reductions will amount to
21
?
14.2 percent for the consumer and commercial
22?products rule that's proposed here beyond those
23
?
achieved by the federal rule. Has the Agency used
24?
the 14.2 percent reduction from the consumer and
Page 9
1?
commercial products rule in the attainment
2?
demonstration modeling as conducted and recently
3
?
completed?
4
?
MR. DAVIS: I would have to respond to
5
?
that in writing. I'm not -- I wasn't involved with
6?
attainment demonstration.
7
?
MR. FOX: Mr. Davis, I'm sorry. If
8?
you could give us a little more volume.
9
?
MR. DAVIS: I wasn't involved with the
10?
attainment demonstration. I believe we probably
11?
did, but I couldn't say for certain, and I can --
12
?
MR. MATOESIAN: We can answer that in
13?
writing.
14
?
MR. DAVIS: Yeah.
15
?
MS. HODGE: Okay. That's fine.
16
?
MR. FOX: And we can deal with the
17
?
timing deadlines for filing of post hearing before
18
?
we leave today.
19
?
MS. HODGE: The proposed rule has a
20
?
compliance date of January 1, 2009. Does the Agency
21
?
believe that there is sufficient time for effective
22
?
parties to implement the provisions of this rule?
23
?
MR. DAVIS: I believe that was the
24?
assumption, yes.
Page 10
1?
MS. HODGE: Okay. Thank you. If
2
?
compliance with the ozone standard is to be
3
?
demonstrated by June 15th, 2010, as required by
4
?
federal rule, is it correct that only the 2009 ozone
5
?
season could potentially be influenced by the
6
?
provisions of this rule?
7
?
MR.
DAVIS:
Could you repeat the
8
?
question?
9
?
MR. FOX: And, Mr. Davis, I'm sorry to
10?
interrupt again. We really need to have you speak a
11
?
little more clearly, please.
12?
MR. DAVIS: She's sitting right here.
13?
MS. HODGE: Yeah. If compliance with
14?
the ozone standard is to be demonstrated by
15?June 15th, 2010 -- which is my understanding as the
16?
requirement of the federal rule, and I think you
17?
offered testimony in that regard to the first
18?
hearing -- is it correct, then, that only the 2009
19
?
ozone season could potentially be influenced by the
20
?
provisions of this rule? Meaning, is it true that
21?we would only get the benefit from the 2009 season?
22?
MR. DAVIS: Yes.
23?
MS. HODGE: Okay. Thank you. Why has
24?
the Agency waited until this point in time to
Page 11
1?
propose the rule?
2?
MR. DAVIS: I think we proposed the
3
?
rule and tried to get it filed as soon as -- as soon
4
?
as was possible with all the input we took from
5
?
industry and tried to get everything consistent --
6
?
MR. MATOESIAN: And if I could,
7
?
Mr. Rory isn't involved in the policy making -- or
8
?
Mr. Davis -- in the policy making decision, so we
9
?
could answer that after discussing with the
10
?
management.
11?
MS. HODGE: That's fine. Thank you.
12?
MR. FOX: Fair enough.
13
?
MS. HODGE: That's fine. When does
14?
the Agency expect the USEPA to propose and
15?
promulgate its federal consumer products rule?
16
?
A.?
That we are not sure about. Last year
17
?
we heard that it would be in May of last year. More
18
?
recently, we heard that it would be in May of this
19
?
year. I think I testified to that at the first
20
?
hearing. Now I've been told it will be somewhere in
21
?
July. It keeps getting pushed back. So I don't
22
?
really know.
23?
MS. HODGE: Okay. Thank you.
24?
MR. FOX: Mr. Davis, if I may, when
Page 12
1
?
you referred to July, is that July of this year,
2?
2008?
3?
MR.
DAVIS: Yes.
4?
MR. FOX:
Thank you.
5
?
MR. DAVIS: But again, we aren't
6?
really counting on seeing it in July.
7?
MS. HODGE: Does the Agency have an
8?
expectation that the compliance date for the federal
9
?
consumer products rule will be beyond January 1,
10
?
2009, or do you -- or do you know?
11
?
MR. DAVIS: I couldn't speculate on
12?
that based on what they'll find in the ruling.
13?
MS.
HODGE: Okay. The Agency has
14?
stated in its statement of reasons, and also I think
15
?
at the first hearing, that it's basing its proposed
16
?
rule in this proceeding on the ozone transport
17?
commission, or the OTC model rule. Could you
18
?
clarify whether the Agency's proposed rule in this
19
?
proceeding and the supporting documentation that's
20
?
been permitted as based upon the 2001 version of the
21?
OTC
model rule, or is it based upon the 2006 version
22?
of the OTC model rule?
23?
MR. DAVIS: I believe that when we
24?
started it was more based on 2001. As we went
Page 13
1?
through the process, we took lot of input from
2
?
industry on what changes could be made to make our
3
?
rule most consistent with the current OTC rules. We
4
?
do write our rules in our own format, so it's not
5
?
precisely the OTC model rule. We tried to make the
6
?
limits and the technical aspects of the rule very
7
?
consistent with the -- with the current OTC model
8?
rules. So I would say that the -- it is probably
9?
closer to the 2006 and its limits, but I think a lot
10
?
of the technical support might have come from
11?
earlier, and I believe that there wasn't much
12?
updating to that technical support for the 2006
13?
ruling.
14
?
MS. HODGE: Okay. Thank you. So that
15
?
-- you went into my next question. Why is the 2001
16
?
OTC model rule cited by the Agency at reference 16
17
?
in its TSD and in Attachment A documents relied upon
18
?
of the initial proposal, and why is the 2006 OTC
19
?
rule not included as a reference?
20?
MR.
DAVIS: I would have to check on
21?
each document.
22
?
MS. HODGE: Okay. Let's do that.
23
?
Let's take a look at the -- -- here's the Agency --
24
?
the Illinois EPA's TSD, and if you'll look at
Page 14
1?
Page 63 and then over to Page 64, Item No. 16, we
2
have the model rule for consumer products, ozone
3
?
transfer commission of November 29th, 2001.
4
?
MR.
DAVIS: Like I said, I believe
5
?
that we started before we had a 2006 final model
6
?
rule from the OTC, and I believe that most of our
7
?
technical support was for -- was from that time
8
?
period, the -- we certainly could include 2006 rule
9
in our references. But like I said, neither rule
10
?
was the sole basis for our rule. We write our
11
?
rules, you know, in our own format, and we relied a
12?
lot on the industry input to get our OTC -- or our
13?
rule to be consistent with the OTC.
14?
MS.
HODGE: Okay. I would just like
15
?
to clarify on one of your statements. So is it your
16
?
position that the Agency relied primarily upon the
17
?
2001 version of the rule?
18
?
MR.
DAVIS: No, I wouldn't say that.
19
?
I -- we probably should have included that in the
20
?
records to get to where many of our limits were.
21
?
And like I said, we can include that now if it would
22
?
be helpful for comparison.
23
?
MR. FOX:
Mr. Davis, from the Board's
24
?
perspective, that would be helpful if it's part of a
Page 15
1
?
post-hearing comment that was asked --
2
?
MR. DAVIS: Sure.
3
?
MS. HODGE: And that's part of what
4
?
I'll be addressing in a few minutes too. Thank you.
5
?
Okay. Again, in the TSD, in Attachment A, the
6
?
Agency states that it relied upon Mack Tech interim
7
?
white paper for the course category of consumer
8
?
commercial products called the Mack Tech white
9
?
paper, and that's reference number three, and again,
10?
this would be on Page 63 of the TSD. In particular,
11
?
the Mack Tech white paper side is the basis for the
12
?
14.2 percent reduction VOM emissions that will
13
?
result from implementing the OTC model rule. Do you
14
?
know if the information in the Mack Tech white paper
15
?
was based on the 2001 or the 2006 version of the OTC
16
?
model rule?
17?
MR. DAVIS: I'm not certain not having
18?
a copy in front of me. Those white papers are
19
?
updated from time to time, and we get new copies and
20
?
we certainly try to keep up with the latest copy.
21
?
My guess would be that's probably not the most
22
?
recent we have today. I could probably come up with
23
?
that and submit that also if it would be helpful.
24
?
MR. FOX: And am I correct, Mr. Davis,
Page 16
1
?
if I may interrupt a moment Ms. Hodge, that the
2?
reference number three refers to an interim white
3
?
paper dated December 1st, 2005. Is that correct?
4?
MR. DAVIS: Yeah. I would say that
5
?
probably -- well, I can't speculate on it.
6?
MR. FOX: Very good. Thank you.
7
?
Ms. Hodge, I'm sorry for interrupting.
8?
MS. HODGE: Oh, that's all right.
9
?
MR. FOX:
Please go ahead.
10
?
MS. HODGE:
That was my next question.
11
?
So would you agree that perhaps that this reference
12
?
from the interim white paper that, again, as Mr. Fox
13
?
said is dated January 1, 2005, don't you think that
14
?
this would indicate that the 2001 OTC model rule was
15
?
the basis for the Mack Tech white paper?
16?
MR. DAVIS:
It could, but that's not
17?
always the case. Many times they -- Mack Tech works
18?
for Labco (phonetic), who does a lot of our research
19?
for us. Many times they anticipate what kind of
20?
reductions would be achieved by different rules. I
21
?
would have to check with them to see if they were
22?
basing that on 2001 or 2006.
23
?
MS. HODGE: Is that --
24?
MR. DAVIS:
But being December 2005, I
Page 17
1
?
really couldn't say.
2?
MS. HODGE: Thank you. Is that
3?
something that the Agency could also address in
4?
writing --
5?
MR. DAVIS: Yeah.
6?
MS. HODGE: -- as well as if there
7
?
have been any updates provided that are in the
8?
record?
9?
MR. FOX: And in this case, you
10?
anticipated my question, Ms. Hodge, so I thank you
11?
for doing so.
12
?
MS. HODGE: Okay. And we're going to
13?
go back and look at this list of references one more
14
?
time, and reference number 18, which is a report
15?
prepared by EH Pechan and Associates Inc., entitled
16?
Control Measure Development Support Analysis of
17?
Ozone Transport Commission Model Rule, and I'm going
18?
to call this the Pechan document, and it's dated
19?
March 31st, 2001. Because of its date, wouldn't it
20 .
make sense to assume that this document was also
21
?
prepared in reference to the 2001 OTC model rule and
22?
not to the 2006 OTC model rule?
23
?
MR. DAVIS: Yes.
24?
MS. HODGE: Okay. And -- Pechan?
Page 18
1
?
MR. DAVIS: Yes.
2?
MS. HODGE: Thank you. And would you
3
?
also agree that the Mack Tech white paper sites to
4
?
the EH Pechan report, in particular in support of
5
?
the 14.2 percent emission reduction?
6
?
MR. DAVIS: Yes.
7?
MS. HODGE: Okay. Thank you.
8?
MR. RAO: May I ask, Mr. Davis, are
9?
you familiar with this in your version of the OTC
10?
model rule?
11
?
MR. DAVIS: Yes.
12
?
MR. RAO: Could you, just for the
13
?
record, comment on how significant the changes are
14
?
from the 2001 rule to the 2006 rules?
15?
MR. DAVIS: I don't know what you
16?
would call significant. I know that some of the
17
?
limits were changed. I know that a few categories
18
?
were added. I believe we added those categories.
19
?
Some of the definitions were changed to include
20
?
certain products and to put certain products in
21
?
different categories. There were significant
22
?
changes, I guess, but not -- structurally I think
23
?
it's essentially the same.
24
?
MR. RAO: And some of these changes
Page 19
1?
are reflected in your proposal?
2
?
MR. DAVIS: Yes, yes. But as I said,
3?
those changes -- and I apologize for not including
4
?
the 2006 rule -- most of those changes were made
5?
upon comment by an industry when they submit
comments to us saying "You should really change this
7
?
part to reflect the new OTC rule," and our goal
8
?
certainly was to stay consistent with the most
9
?
current OTC model rules and California rules, and I
10
?
believe Mr. Biel complimented us for taking their
11
?
comments seriously and implementing those changes.
12
?
MR. RAO: Okay. Since you will be
13?
submitting that document later in your comment,
14?
would it be possible for you to highlight some of
15
?
these significant changes and how they're reflected
16?
in your rules?
17
?
MR. DAVIS: Sure.
18
?
MR. RAO: Since it will be
19
?
post-hearing, it would be helpful to see where those
20?
things are.
21
?
MR. DAVIS: Sure.
22
?
MR. RAO: Thank you.
23
?
MR. DAVIS: I believe there's a red
24
?
line version from 2006 to 2001. I don't know that
Page 20
1?
that would be an official document that OTC
2?
released, but it may be helpful. I might be able to
3?
come up with that. I know that I had it personally.
4
?
That could be helpful --
5? MR. RAO: Yeah.
6
?
MR. DAVIS: -- just to see they're
7
?
highlighted in yellow and blue. So that's -- it was
8
?
helpful to me certainly.
9
?
MR. RAO: If you could get the release
10
?
for the document or something like that, that would
11
?
be helpful for us. Thank you.
12?
MS. HODGE: Thank you. And I do have
13
?
a copy of that document that we're discussing, and I
14
?
apologize it's in black and white. So if you go to
15
?
the web page, you can actually see, you know, the
16
?
highlighted colors. I've given a copy to counsel
17
?
for the Agency, and then here's a copy for the Board
18
?
that I'd like to move have this admitted as an
19
?
Exhibit for today. Do you want me to describe it?
20
?
MR. FOX: Actually I think we've had
21
?
probably a sufficient description of what it is and
22
?
we can certainly rely on that, Ms. Hodge.
23
?
MS. HODGE: Thank you.
24?
MR. FOX: Thanks for your willingness.
Page 21
1?
We do have a motion from Ms. Hodge on behalf of IERG
2?
to admit as what would be Exhibit No. 3, as she
3?
described the 2006 version of the OTC draft or model
4?
rule. Is there any objection to admission of that
5
?
into the record of this hearing as Exhibit No. 3?
6?
Neither seeing nor hearing any, it will be so marked
7
?
and admitted as hearing Exhibit No. 3. Thank you,
8?
Ms. Hodge, for the copy of that document.
9?
MS. HODGE: Thank you. Mr. Davis, are
10?
you familiar with this document?
11?
MR. DAVIS: Yes.
12?
MS. HODGE: Did the Agency rely on
13?
this document in developing the regulatory proposal
14
?
for this proceeding?
15?
MR. DAVIS: I would say yes, and I
16?
would have to apologize for not including that in
17?
the reference the documents relied on. I don't
18?
think we relied on it solely for changes from 2001
19?
to 2006, but yes.
20?
MS. HODGE: Okay. Thank you. I would
21
?
ask you to turn to Page 1 of this document, and
22?
about mid-way down the page there's some notes, five
23
?
notes, and I think I'm going to read this statement
24
?
from this cover page, cover Page 1 of the document,
Page 22
1?
into the record. "This model rule was developed by
2?
the Ozone Transport Commission as part of a regional
3
?
effort to attain and maintain the eight hour ozone
4?
standard and reduce eight hour ozone levels. This
5?
is an amendment to the November 29th, 2001, model
6?
rule, developed by the OTC states to address the one
7
?
hour standard in areas." And then I would ask you
8?
to look at notes, in particular one, two, and three,
9
?
and would you mind reading those into the record for
10?
us?
11
?
MR. DAVIS: Notes one, two, and three?
12
?
MS.
HODGE:
Mm-hmm, yes.
13?
MR.
DAVIS:
"Certain compounds
14
?
affected by this model rule may not cause or
15
?
contribute to formation of ozone, but due to their
16
?
hazardous nature are included in this model for
17
?
convenience of the state, which may regulate such
18
?
compounds are under other state authorities. Such
19
?
compounds are noted with an asterisk, and is up to
20
?
each state to decide whether it wishes to include
21
?
regulation of said compound and its state-specific
22
?
rulemaking. OTC takes no position on whether to
23
?
include these pounds in such a way.
24
?
States opting to promulgate rules
Page 23
1
?
based on this model rule must comply with
2?
state-specific administrative requirements and
3?
procedures, underline text, and are changes made to
4?
the original OTC model rule dated November 2nd,
5?
2001, in bold text, our references to agencies
6?
outside the OTC. OTC states, sections, titles, and
7?
for special points of interest. The term OTC state
8?
or an OTC state agency are placeholders for
9?
individual statement names.
10?
MS. HODGE: Thank you very much.
11?
Could you go to Page 20 of this document now,
12
?
please? And down at the bottom of the page, number
13?
three standards, and then it starts with a table of
14
?
standards. And then if we go over to the next page,
15?
Page 21, is it -- is it your understanding, then,
16?
that the items that are underlined that these are
17?
the new categories that were added in the 2006
18
?
version of the rule?
19
?
MR. DAVIS: Yes.
20
?
MS. HODGE: Okay. And are these --
21
?
these underlined items, are they included in the
22?
Agency's proposal in this proceeding?
23?
MR. DAVIS: I believe they are.
24?
MS. HODGE: Okay. So we have -- on
Page 24
1?
Page 21, is it correct that we have new product
2
?
category for adhesive removers?
3?
MR. DAVIS: Yes.
4
?
MS. HODGE: Okay. And we have some
5?
subcategories under adhesives for contact general
6
?
purpose and contact special purpose?
7
?
MR. DAVIS: Yes.
8?
MS. HODGE: Okay. Under air
9
?
fresheners, we have a new subcategory for
10?
semisolids?
11?
MR. DAVIS: Right.
12?
MS. HODGE: We have a brand new
13
?
category for anti-static products, non-aerosol. And
14
?
if you go over to Page 22, we have several --
15
?
several more new categories that are in the 2006
16
?
rule, but not in the 2001?
17
?
MR. DAVIS: Right.
18
?
MS. HODGE: We have electrical cleaner
19
?
and electronic cleaner. Is that correct?
20
?
MR. DAVIS: Yup.
21
?
MS. HODGE: Okay. We also have -- the
22
?
fabric refreshener category is new, footwear leather
23?
care products is new. Is that correct?
24?
MR. DAVIS: Yes.
Page 25
1
?
MS. HODGE: Another new category here,
2?
graffiti remover. On Page 23, similarly, we have a
3
?
--
is it correct that we have a new category for
4?
hairstyling products?
5
?
MR. DAVIS: Yes.
6?
MS. HODGE: Do we have a new category
7
?
for shaving gel?
8?
MR. DAVIS: Yes.
9
?
MS. HODGE: Do we have a new category
10?
for toilet/urinal care?
11
?
MR. DAVIS: Yes.
12?
MS. HODGE: And then finally on this
13
?
page, do we have a new category for wood cleaner?
14?
MR. DAVIS: Yes.
15?
MS. HODGE: On Page 24 -
16
?
MR. DAVIS: I believe that's --
17?
MS. HODGE: I'm sorry. Those are
18?
subcategories of wood cleaner, I believe. So all of
19?
these categories that we've just identified, these
20
?
are all -- these are some of the significant changes
21?
in the '06 rule versus the '01 rule. Is that
22?
correct?
23
?
MR. DAVIS: Yes. And I should
24?
clarify, some of these were included in the previous
Page 26
1?
rule, and they're more specific categories than were
2?
in the previous rule. For instance, the hairstyling
3?
products might have been under hairstyling gels
4?
before, or shaving gels might have been under
5?
shaving creams. They've got a seven percent max. I
6?
believe that was added because shaving creams had a
7
?
five percent maximum percentage and shaving gels got
8?
seven percent. So some of those are -- were
9
?
included in the -- the products themselves were
10?
included in the original rule, but then were given a
11
?
more specific category.
12?
MS. HODGE:
Okay. Thank you. Could
13?
we turn to Page 29 of this document now, please?
14?
And in section No. 4 on Page 29, we have a list of
15?
exemptions, and I would turn your attention down to
16
?
item No. I, and would you agree that the
17?
strikethrough in this provision changes an exception
18?
from the '01 rule to the '06 rule?
19?
MR. DAVIS: Yes.
20?
MS.
HODGE:
So is it accurate that
21?
under the 2001 rule the exemption would apply to air
22?
fresheners and insecticides containing at least
23
?
98 percent paradichlorobenzene?
24
?
MR. DAVIS:
Yes.
Page 27
1
?
MS. HODGE: Is that true?
2?
MR. DAVIS: Yes.
3?
MS. HODGE: But for the 2006 rule, the
4?
exemption only applies to insecticides containing
5?
98 percent paradichlorobenzene. Is that correct?
6?
MR.
DAVIS: That's correct.
7
?
MS.
HODGE: Okay. Thank you. Since
8
?
it appears, at least to me here today, that the
9
?
Agency based the technical support for its
10
?
rulemaking on the 2001 OTC model rule, including the
11
?
emission reductions achieved by the 2001 OTC model
12
?
rule, and that rule did not include these new
13
?
categories, and in at least one exemption was
14
?
significantly modified, is it true that the Agency's
15
?
goal of the Illinois emission reductions could be
16
?
achieved without these categories?
17?
MR. DAVIS: I would say it's possible,
18
?
but the categories that are added, like I said, some
19
?
of them are more specific categories than were in
20
?
the original. I believe in my testimony and in the
21
?
technical support document, we said that the
22
?
reductions could be less than 14.2 percent because
23
?
we have products that are being sold in Illinois now
24
?
that are compliant because of the California and OTC
Page 28
1?
model rules. So 14.2 percent wouldn't be an exact
2?
figure. I believe that's in the TSD and in the --
3
?
my testimony. And also to include them while -- if
4
?
you wanted to take that 14.2 percent to be an exact
5
?
number, then the additional categories would be
6
?
additional reductions, which would also be helpful
7
?
with the attainment demonstration.
8
?
MR. MATOESIAN: And I think beyond
9
?
that, we'll get more fully into this in writing.
10
?
MS. HODGE: That's fine. Thank you.
11
?
I'd like to turn back now to the Agency's technical
12
?
support document, and could we go to Page 30 of that
13?
document, please? I'm sorry. Let's go back to
14
?
Page 29 to start with. Section 2.7 here is
15?
reduction of the Illinois emissions in Illinois.
16?
There's a narrative, and then there's a table over
17
?
on Page 30, table 2.7.1. estimating the Illinois
18?
emission reductions for consumer products. Is that
19
?
correct?
20?
MR. DAVIS: Yes.
21?
MS. HODGE: Could you tell me what the
22
?
number ten footnote means? Is that a reference to
23?
your reference document number ten?
24
?
MR. DAVIS: It could be, yes.
Page 29
1
?
MS. HODGE:
And could you tell me what
2?
that document is, please?
3
?
MR. DAVIS:
That is a technical
4
?
support document from the state of New Jersey that
5
?
listed all of the categories that were in the rule
6
?
at that time, and the reason that I used the
7
?
document from New Jersey was it was the most concise
8
?
table. It's actually taken from California data,
9?
but it was nicely put together, and that's why I
10?
used those.
11?
MS. HODGE: So the Agency didn't do
12
?
its own independent analysis of emission reductions
13?
for its consumer products rule?
14
?
MR. DAVIS: No.
15?
MS. HODGE: And what's the date of
16?
this New Jersey document?
17?
MR. DAVIS: 2003.
18?
MS. HODGE: Do you think it's likely
19
?
that this 2003 New Jersey report covered only the
20
?
categories in the 2001 OTC rule?
21
?
MR. DAVIS: I think that's likely,
22?
yes.
23?
MS. HODGE: So if I go back and look
24?
at this table, 2.7.1, does this table include these
Page 30
1?
new categories that we identified just a few minutes
2?
ago from the OTC 2006 rule? Does this table include
3?
those new categories?
4?
MR. DAVIS: I would say some and not
5
?
others.
6?
MS. HODGE: Okay. Could you go
7?
through and show us, please, where it doesn't show
8?
the new categories? And if that would be something
9?
that would be easier to address in writing --
10?
MR. MATOESIAN: That would probably be
11?
much easier.
12
?
MS. HODGE: All right. I would ask
13?
that we do that.
14
?
MR. DAVIS: Sure.
15?
MS. HODGE: So if a category is not
16?
listed in this table, is it correct to state that
17?
the Agency really did not consider emission
18?
reductions associated with that category?
19?
MR. DAVIS: As I said, some of the --
20?
some of the categories are more specific categories.
21
?
So I would say perhaps and perhaps not, because some
22?
of the new categories would be included in here.
23?
MS. HODGE: All right. Thank you. So
24?
is it accurate to say that the Agency did not
Page 31
1?
include the ozone reducing impact of reduction -- of
2?
emission reductions from at least some of these
3?
categories?
4?
MR. DAVIS: Yes.
5?
MS. HODGE: Does the Agency know the
6?
emission reductions to be achieved from adding these
7?
additional categories?
8?
MR. DAVIS: I would say no. The
9
?
Agency doesn't really have the resources to do it
10?
case by case. As a determination, we did rely on
11?
New Jersey and Mack Tech, Labco, and California.
12?
MS. HODGE: Do you know whether the
13?
OTC estimated emission reductions for these
14?
additional categories for its '06 rule?
15?
MR. DAVIS: That I would have to check
16?
on.
17
?
MS. HODGE: Okay. And that's
18
?
something to be submitted, right?
19
?
MR. MATOESIAN: Okay.
20
?
MS. HODGE: We would need that too.
21
?
Since it appears that the Agency, at least to me
22
?
here today, based its rulemaking on the 2001 OTC
23
?
model rule, and the 2001 OTC model rule does not
24
?
include these additional categories, is it true that
Page 32
1?
the Agency did not consider the cost for compliance
2?
associated with regulating these additional
3?
categories?
4
?
MR.
DAVIS: Could you repeat that?
5
?
MS.
HODGE: Certainly. We've been
6
?
talking about whether or not the Agency considered
7
?
the emission reductions associated with the
8
?
additional categories, and this question goes to
9
?
whether the Agency analyzed the cost -- the
10
?
compliance cost associated with adding these
11
?
additional categories.
12
?
MR.
DAVIS: Sure.
13
?
MS. HODGE: And so the question is:
14
?
Did the Agency consider the cost associated with
15
?
compliance for the cost of these additional
16
?
categories?
17?
MR.
DAVIS: I would say as far as they
18
?
were considered by the other resources that I have
19
?
mentioned previously.
20
?
MS. HODGE: Thank you. So if the
21?
other resources did not consider the costs, then the
22?
Agency would not have considered the cost. Is that
23?
correct?
24?
MR. DAVIS: Yes.
Page 33
1
?
MS. HODGE: Okay. Thank you. Also,
2?
we had mentioned early on in this OTC document -- is
3
?
that Exhibit No. 3?
4?
MR. FOX: Number three, yes.
5
?
MS. HODGE: Thank you, Mr. Fox. We
6?
had mentioned the change to the exemption for
7
?
paradichlorobenzene. So is it also true that the
8?
Agency did not consider the cost of compliance as
9?
associated with this modified exemption?
10?
MR. DAVIS: That's possible. I would
11?
have to -- I would have to retrace where we were
12?
getting our cost effective numbers -- where our cost
13
?
impact numbers from. If they were from a document
14?
that that did include that, then I would say it was
15?
included. If they were not, then I would say they
16
?
were not.
17?
MS. HODGE: Okay. Thank you.
18?
MR. DAVIS: And as I stated, neither
19?
one nor the other was the sole basis. I think a few
20?
questions ago, that's why I was asking you to repeat
21
?
it. I think you've said a number of times that we
22
?
are basing it on 2001. But I don't think that's
23
?
wholly accurate.
24?
MS. HODGE: Okay. Thank you. Thanks
Page 34
1
?
for that clarification. Do you know whether the OTC
2
estimated the cost for compliance for adding these
3?
additional categories?
4
MR.
DAVIS: I would have to check on
5
?
that.
6?
MS. HODGE: If you could, please.
7
?
Okay. I would -- and I'm sorry for this jumping
8
around, but I just -- I want to keep the subject
9?
category together. Could we turn back to the
10?
Exhibit 3, and in particular the note number one,
11
?
and just to go back and revisit it. So is it your
12
understanding that the newly listed categories that
13?
include an asterisk beside it in this document, that
14
?
OTC
is saying it's up to the state to decide whether
15?
it wishes to include regulation of those categories?
16?
MR.
DAVIS:
That is my understanding,
17?
yes.
18
?
MS. HODGE: And isn't it true that the
19
?
OTC also concluded that certain of these compounds
20
?
may not cause or contribute to formation of ozone
21
?
but are listed here only for their hazardous nature?
22
?
MR.
DAVIS: Yes.
23
?
MS.
HODGE:
Okay. Did the Agency do
24
?
any independent analysis of these compounds with the
Page 35
1
?
asterisks beside to determine whether there was
2?
really any air quality impact from -- on ozone
3
?
formation?
4?
MR. DAVIS: I don't believe so.
MS. HODGE: Okay. And could we just
6
?
take a look, for the record, and identify some of
7
?
these that have the asterisks beside them, please?
8
?
I would ask you to go to page --
9
?
MR. DAVIS: 24?
10?
MS. HODGE: Thank you. I think that's
11
?
where I'm going. I thought I had all of my tabs
12
?
here. Please let's start on Page 24. If you could
13
?
just describe some of these that are optional.
14
?
MR. DAVIS: If I could describe them?
15?
MS. HODGE: Mm-hmm. Just identify
16
?
them -- just identify them, please, for the record.
17
?
MR. DAVIS: Well, there's
18
?
antiperspirants and deodorants that contain any
19
?
compound identified in Title 17, 3 chapter 1,
20
?
subchapter 7, Section 93000 as a topic air
21
?
contaminant. There's also solid air fresheners and
22
?
toilet/urinal products that contain
23
?
paradichlorobenzene?
24
?
MS. HODGE: So excuse me, Mr. Davis.
Page 36
1?
Would you agree that those things were probably
2?
listed only because of their hazardous nature as
3
?
determined by California, the state of California?
4?
MR. DAVIS: Yes.
5
?
MS. HODGE: Could we go over to
6
?
Page 27, and I would direct your attention to the
7
?
subcategory I -- the age is stricken through --
8?
products containing ozone did he completing
9
?
compound. So is it your understanding that these,
10?
too, would've been something that would've been
11?
optional?
12?
MR. DAVIS: I don't know that that
13
?
would be optional, or -- yes, I guess it would b
e
14?
MS. HODGE: Okay. And did Illinois
15
?
EPA make any kind of independent analysis on that?
16
?
MR. DAVIS: I don't believe we
17?
included the table, and yes, there was some -- there
18
?
was some analysis of whether we should include it or
19?
not. I would have to check and see if I had any
20
?
notes on that. I believe that I thought that these
21
?
compounds were already covered under something else,
22
?
but I would have to check back and see -- and we
23
?
just thought it was extraneous to include it again.
24
?
MR. MATOESIAN: We can do that in
Page 37
1?
writing, perform that in writing.
2?
MR. FOX: Thank you.
3
?
MS. HODGE: That's fine. Thank you so
4
?
much. On to Page 28, this subcategory L,
5
?
requirements for contact adhesives, electronic
6
?
cleaners, footwear, leather care products, and
7
?
all-purpose degreasers. So you're understanding
8
?
that the OTC, too, is indicating that this is
9
?
optional for the sates, these categories?
10
?
MR. DAVIS: Yes.
11
?
MS. HODGE: And down on M, middle of
12
?
page on two, requirements for adhesive removers,
13
?
cleaners, and graffiti removers, is it your
14
?
understanding, too, that those would be optional for
15
?
regulation?
16
?
MR. DAVIS: That's right.
17?
MS. HODGE: Okay. Page 29, at the top
18?
of the page, N, subsection N, requirements for solid
19
?
air fresheners and toilet/urinal care products. Is
20
?
it your understanding that this category that -- I'm
21
?
sorry -- the OTC had determined that this category
22
?
was optional by the states as well?
23
?
MR. DAVIS: Yes.
24
?
MS. HODGE: Are you aware that the
Page 38
1?
Agency's proposal includes the category of nail
2
?
polish removers at proposed Section 223.205?
3?
MR. DAVIS: Sure, yes.
4
?
MS. HODGE: However, it's not in the
5?
TSD at table 2.2.1, which is proposed regulated
6?
product category and limits. Was that just an
7?
omission?
8?
MR. DAVIS: That may have been an
9?
inadvertent admission.
10?
MS. HODGE: So it's the Agency's
11?
intent to regulate nail polish removers?
12?
MR. DAVIS: Yes.
13
?
MS. HODGE: Okay. Has the Agency
14?
considered amending its proposal to be consistent
15
?
with the technical and economic information provided
16
?
in this record to support the 2001 OTC model rule?
17?
MR. DAVIS: I don't believe I
18?
understand what you're asking me. As far as --
19?
MS. HODGE: Is it the Agency's intent
20
?
to maintain its proposal to adopt a state version of
21?
the 2006 OTC rule?
22
?
MR. DAVIS: I thought you said 2001.
23?
MS. HODGE: Well, I did, I did.
24
?
MR. DAVIS: All right.
Page 39
1?
MS. HODGE: And it's my understanding
2
?
that -- and I know that you don't necessarily agree
3
?
with me about this today -- but again, it appears to
4
?
me that a lot of the support here that's in this
5
?
record is in support of the 2001 OTC model rule, and
6
?
yet it's also my understanding that the Agency's
7
?
actual regulatory proposal is modeled after the 2006
8
?
OTC model rule. So my question is really two parts.
9
?
One, does the Agency -- has the Agency considered
10
?
amending its proposal so that it would be consistent
11
?
with the support, or in the alternative has it
12
?
considered offering the additional support for the
13
?
2006 version?
14?
MR. DAVIS: I believe that we've
15
?
stated that we would be willing to provide any of
16
?
the additional support we can find for the 2006
17
?
rule. And as I've stated before, obviously both
18
?
rules were considered, and we worked with the
19
?
industry mainly to try to get a very consistent rule
20
?
for Illinois.
21?
MR. MATOESIAN: We can get that back
22?
to you.
23?
MS. HODGE: Thank you. And where --
24?
where the resource material -- you've stated that
Page 40
1?
you relied upon other entities and other states in
2
?
conducting some of the analysis here, and where some
3
?
of those entities and states perhaps did not address
4
?
the impact either, you know, the technical support
5
?
or the economic information for these newly added
6
?
categories, will the Agency go forth and do it's own
7
?
analysis to support those additional categories?
8?
MR. DAVIS: I -- I couldn't promise
9?
that today.
10?
MR. MATOESIAN: We can answer that one
11?
in writing too.
12
?
MS. HODGE: Okay. And this is a
13?
policy question, too, Mr. Matoesian. In the event
14
?
that the Agency doesn't have the resources to go
15
?
forth and do that, would it be the Agency's position
16
?
that the Board should move forward with adoption of
17?
this rule without that kind of analysis?
18?
MR. MATOESIAN: We'll respond to that.
19?
MS. HODGE: Thank you. That's all I
20?
have today.
21
?
MR. FOX: Very well. Thank you,
22
?
Ms. Hodge. There were other persons, I know, who
23?
were interested in asking questions, and if I may
24
?
make one quick housekeeping announcement first of
Page 41
1?
all, we did have some folks who arrived after the
2?
hearing began. Posted directly in front of the
3?
court reporter is a form on which you can sign up if
4?
you wish to testify. And like other witnesses,
5?
persons who wish to testify will be sworn in and may
6?
be asked questions on the part of other
7
?
participants. I wanted to make sure that anyone who
8?
did arrive after we began knew that that was a
9
?
possibility, although no one is required to testify
10?
if they don't wish to do so. But I believe someone
11?
indicated that they wanted to ask a question, and,
12?
sir, if you wouldn't mind before beginning, just
13?
identifying yourself by name and association so that
14?
the court reporter may know who you are.
15?
MR. DARLING: Actually, I gave her a
16?
business card.
17?
MR. FOX:
Very good. Thank you for
18?
doing that.
19
?
MR. DARLING: I'm David Darling,
20?
director of environmental affairs for the National
21?
Paint and Coatings Association. If I could just ask
22?
a couple questions.
23?
MR. FOX:
Would you like to do so from
24?
there, or come up to the chair?
Page 42
1?
MR. DARLING: Okay. I'll come up.
2?
MR. FOX: Whichever works for you.
3?
MR. DARLING: Hopefully I'll be a
4?
little bit shorter. We appreciate all the changes
5?
that Illinois EPA has made with regards to the EOC
6?
rule. I just have a couple clarifying questions.
7?
Well, as far as appreciation, you clarified VOM and
8
?VOC that they are identical, which is a good step
9?
forward. You also clarified that instead of
10?
allowing or requiring industry to respond with a
11
?
30 days of a written notice, you've now gone to
12?
90 days. Again, we appreciate -- that's consistent
13?
with our comments. I do have two other comments for
14
?
your consideration. We sent in a letter on May
15?
19th. To be consistent with OTC, there is one
16
?
category that we missed with all the back and forth.
17
?
MR. FOX: Mr. Darling, if I could
18
?
interrupt you for one second, that is marked in the
19
?
Board's record as public comment, or PC number two.
20
?
But I apologize for interrupting. Please go on.
21
?
MR. DARLING: No problem. Thank you
22
?
very much for the clarification. And -- yes. And
23
?
so -- just that I understand the intent is to try to
24
?
be like the OTC states, so we request -- we would
Page 43
1?
appreciate if Illinois EPA can include the category
2
?
concrete surface retarder as a definition, a limit
3?
of 780 grams per liter, and include concrete surface
4
?
retarder in the most restrictive limit as identified
5?
in the letter. Again, this is to be consistent with
6
?
the OTC states or model rule.
7?
I did have one other comment.
8
?
Like the aerosol rule you spoke about earlier, will
9?
Illinois EPA -- it was our understanding that
10?
Illinois EPA, when the national aim rule is revised
11?
hopefully in a year or so, that Illinois would also
12
?
rescind their rule and adopt the national rule.
13
?
That was our understanding in the past. Could you
14
?
clarify?
15
?
MR. DAVIS: That --
16?
MR. MATOESIAN: We'd have to make a
17?
decision once we see the federal rule.
18?
MR. DARLING: Our understanding is
19
?
hopefully it's going to be very much like the OTC
20
?
model rule.
21?
MR. DAVIS: That's our understanding
22
?
also.
23?
MR. DARLING: Okay.
24
?
MR. MATOESIAN: We couldn't speculate
Page 44
1?
until we see it in writing.
2?
MR. DARLING: Is it your understanding
3?that hopefully if it is consistent with the OTC,
4?
would that be a better or easier decision on your
5
?
part, or it's hard to say?
6?
MR. MATOESIAN: Hard to say at this
7
?
point.
8
9
10
11
12
13
14
15
16?
MR. DARLING: I do not know. We
17
?
submitted the comment. We would certainly hope that
18
?
to be consistent with the OTC rule.
19
?
MR. DAVIS: Sure. We'll have to check
20
?
on that and make sure that's something that would be
21
?
consistent with the OTC model rule.
22
?
MR. FOX: And if that could also be
23
?
addressed in a post-hearing comment, that would be
24
?
certainly helpful to the Board.
MR. DARLING: That's it for me.
MR. FOX: Mr. Darling, if I may
interrupt just for a moment. Your public comment
had included a definition of concrete surface
retarder and in the company limit. Do you know
whether the agency agrees with the inclusion of the
language you had proposed in that rule, or perhaps
Mr. Davis could answer that question?
Page 45
1?
MR. DAVIS: Sure.
2?
MR. DARLING: Just to clarify, this
3
?
came out of directly, I believe, New York and
4?
Pennsylvania.
5
?
MR. FOX: And specifically, the
6
?
definition is consistent with those two states.
7
?
MR. DARLING: Right, correct.
8
?
Actually, all three, the definition, the limit, and
9
?
-- there's three parts.
10
?
MR. FOX: And that last categorization
11
?
is under the most restrictive limit as well. Very
12
?
well. Thank you, Mr. Darling. Did you have more
13
?
questions for the Agency at this time?
14
?
MR. DARLING: No.
15?
MR. FOX: Very well.
16
?
MR. DARLING: Thank you.
17?
MR. FOX: Thank you very much. I see
18
?
one more indicating that they'd like to make a
19?
question, and also if you'd like to ask for --
20
?
MS. FREDE: I just have one quick
21?
question. My name is Lisa Frede. I'm with the
22?
Chemical Industry Council of Illinois. In the
23
?
Illinois EPA second errata sheet to its proposal for
24?
the addition of 35 Illinois Administrative Code 223
Page 46
1?
contained an inadvertent error on number 14 on Page
2?
7. Specifically the explanation states that the
3?
proposed amendment is intended to clarify the
4?
requirement of Section 223.320, i.e., the
5?
architectural and industrial maintenance code and
6?
regulation. This reference is not correct. The
7
?
proposed amendment actually pertains to provisions
8
?
of Section 223.255, i.e., the consumer products
9?
regulation. Is this something that the Agency can
10?
correct for us?
11?
MR. FOX: If I may interrupt, Ms.
12?
Frede, you referred to Page 7, and my attention may
13?
have lapsed just for a second. That's Page 7 of
14
?
which document?
15?
MS. FREDE: Of the errata sheet that
16?
was just --
17?
MR. FOX: Thank you, very much.
18?
MR. DAVIS: And that was 14?
19?
MS. FREDE: Yes, sir.
20?
MS. HODGE: Would you like a copy of
21?
that.
22?
MR. RAO: We don't have the errata
23?
sheet here. Could you please --
24?
MS. HODGE: We have an extra copy.
Page 47
MR. DAVIS: I think that's a typo in
errata, and I think we can correct that easily.
MS. FREDE: Thank you.
MR. FOX: Mr. Matoesian, Ms. Hodge has
kindly made available a duplicate copy of the errata
sheet, of course not yet received through mail
service. Would you be willing to offer a motion to
admit that as Exhibit No. 4 so that was part of our
hearing today?
MR. MATOESIAN: Sure. That's fine.
MR. FOX: Hearing Mr. Matoesian's
motion to admit errata Sheet Number 2 dated
June 2nd, 2008, as Exhibit No. 4 in this proceeding,
is there any objection to its admission as that
exhibit number? Neither seeing nor hearing any, it
will be admitted and marked as Exhibit No. 4. And
Ms. Hodge, thank you again for making a copy
available. Ms. Frede, did that wrap up your
questioning?
MS. FREDE: That was all. Thank you
1
2?
the errata. So that would be an error in the
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22?
very much.
23?
MR. FOX: Absolutely. Sir, if you
24?
would also please identify yourself and pose any
Page 48
1?
question for the Agency that you may have.
2?
MR. CAREY: My name is Dave Carey. I
3
?work for W.R. Meadows. We're a family manufacturing
4
?
company here in Illinois. We've actually been in
5?
business since 1926 in the State of Illinois. We
6?
have manufacturing facilities, kind of, scatted
7
?
throughout the U.S. We're, kind of, regionally
8?
based, and we make products used in commercial
9
?
contact construction, architectural codings that are
10?
used to cure concrete. We also make vapor proofing
11?
and water proofing membranes.
12?
One of the things that struck me
13?
about the proposed rule is that we have this federal
14
?
rule, kind of, on the back burner that's, you know,
15
?
coming down the pipe. And one of the things
16?
wanted to -- just wanted bring up is as a
17?
manufacturing company, one of the challenges we face
18?
is complying with the different rules we see around
19
?
the country. There are rules in south coasts that
20
?
we deal with, the OTC rules have already been
21?
mentioned, and for us as a manufacturing company,
22?
there are significant costs associated with
23?
reformulating products, retrofitting and changing
24?
equipment, and one of the things that hurts us as a
Page 49
1?
company is inconsistency from one region on of the
2?
country to the next.
3?
MR. FOX: Sir, let me interrupt if I
4?
may. Since you're offering testimony about your
5?
work and your company, may I have the court reporter
6?
swear you in? Certainly we'll let you continue and
7?
ask whatever questions the agency would like.
8?
MR. CAREY: Sure.
9?
(Witness sworn.)
10
?
MR. FOX: Sir, thank you for letting
11?
me interrupt. Please go ahead.
12
?
MR. CAREY: So one of the challenges
13?
we face is just the costs associated with doing that
14?
and then complying with all these different rules.
15?
I guess the question and the comment I have is why
16
?
not wait until the federal rule comes out,
17
?
especially if it's going to be more restrictive than
18?
the Illinois rule and it would preempt the Illinois
19
?
rule, as opposed to possibly requiring manufactures
20?
machines, you know, formulations and retrofit
21?
equipment for a one or 18-month period.
22?
Also I'd like to just say that we
23
?
have two drivers in the marketplace right now that
24
?
are actually forcing our industry to voluntarily
Page 50
1?
reduce VOC content in our products. One is,
2
?
obviously, the solvents. You know, a gallon of gas
3?
is $4 a gallon. When you buy solvents in the
4?
marketplace, we've seen some of our costs go up by
5?
100 percent. So that's one driver, and the other is
6
?
with the lead program and rebuildings. More and
7?
more construction activities are looking to use
8?
products that are more environmentally friendly. So
9?that's driving us towards that end anyway.
10
?
So I guess one of the issues that
11?
we'd like the Agency to consider would be just
12?
waiting until the federal rule comes out so it makes
13
?
that transition a little bit easier for industry.
14?
MR. FOX: Sir, did you wish to pose a
15
?
specific question to the Agency?
16?
MR. CAREY: No.
17
?
MR. FOX: Okay. Very good. Thank you
18
?
for your comments. Was there any other participant
19
?
this morning that wished to pose questions to the
20
?
Agency while they're available to do so? Very good.
21
?
The Board itself does have some questions, and in
22
?
discussing procedural matters briefly before the
23
?
hearing, I did let Mr. Matoesian know that these
24
?
were in the nature of technical or housekeeping
Page 51
1?
questions about the language of the rule, and I
2
?
indicated to Mr. Matoesian that these are probably
3
?
most suitable for responding to post-hearing
4
?
comments, and that that would certainly be
5
?
acceptable to the Board.
6
?
I apologize in advance if they are
7
?
a bit tedious to listen to, and Mr. Matoesian, I'm
8
?
going to try to avoid raising anything that was
9
?
raised in the errata sheet, but certainly please
10
?
tell me if I'm asking something that has been
11
?
addressed there. Mr. Matoesian, I wanted to raise
12
?
what appears to be addressed in the errata sheet --
13
?
MR. MATOESIAN: Okay.
14
?
MR. FOX: -- but perhaps not
15?
completely. There are in subparts B, C, and D,
16
?
addressing the three different categories, several
17
?
definitions that include the phrase "for purposes of
18
?
this part," when it appeared to be the Agency's
19
?
intent to have those applied for the purposes of
20
?
this subpart. If I may note quickly for the
21
?
record --
22
?
MR. MATOESIAN: Okay. Sure.
23?
MR. FOX: -- what those are.
24
?
Certainly if they're all addressed in the errata
Page 52
1?
sheet, it would not be necessary to address them.
2?
MR. MATOESIAN: We addressed quite a
3?
few of those, but if you want --
4
?
MR. FOX: I'd be delighted. In
5
?
Section 223.203, which is subpart B, the definitions
6
?
that appear to have the word "part" were adhesive,
7
?
architectural coding, hairspray, hairstyling
8
?
product, and sanding sealer. The same issue arose
9
?
in section 223.307, which is part of subpart C, with
10
?
the definitions of coding, concrete curing compound,
11
?
primer, sanding sealer, and sealer. And in
12
?
Section 223.407, which is part of subpart D, that
13
?
issue appeared to arise with regard to the
14
?
definitions of primer and retail outlets.
15
?
I also had a question about a
16
?
number of questions, frankly, about Section 223.120,
17
?
which is the section addressing incorporations by
18
?
reference. Question number one: In subsection A
19
?
through E, which incorporate materials from the code
20
?
of federal regulations, may the Board ask that you
21
?
make those five incorporations consistent with one
22
?
another?
23
?
MR. MATOESIAN: Oh, okay.
24
?
MR. FOX: Particularly with regard to
Page 53
1?
the federal -- specific federal register citations
2
?
as these are not?
specifically not including any
3?
later amendments or additions.
4
?
MR. MATOESIAN: Okay.
5?
MR. FOX: And secondly, for the
6
?
incorporation of the materials from the South Coast
7?
Air Quality Management District, the Bay Area Air
8?
Quality Management District, and the California Air
9?
Resources Board, can you supply an address for those
10?
entities as you have done with the incorporation --
11?
MR. MATOESIAN: Okay.
12?
MR. FOX: -- of the ASTM materials, to
13
?
which the public can obtain copies of those
14?
materials that are incorporated by reference?
15
?
MR. MATOESIAN: Okay.
16?
MR. FOX: Number three in subsection
17?
I, which incorporates the South Coast Air Quality
18?
Management District method, the document that was
19?
filed with the Agency's proposal indicates approval
20
?
in July of 1996, but the proposed subsection refers
21?
to approval on August 10th of 1998, and we would ask
22
?
that you clarify whether there is a subsequent
23?
version of this method that the Board would need to
24
?
obtain as part of its record in its proceeding.
Page 54
1
?
And number four, similarly in
2?
subsections J and K, which incorporate the Bay Area
3
?
Air Quality Management District methods, the
4?
documents filed with the proposal both indicate that
5?
they were amendments proposed on February 4th, 2004,
6?
but this proposed subsection refers to amendments of
7
?
May 18th of 2005, and I would ask simply that you
8?
clarify again whether there is a subsequent version
9
?
of the method that the Board would need to obtain a
10?
copy of for the record in this proceeding.
11
?
MR. MATOESIAN: Okay.
12?
MR. FOX: Number five, in subsection
13?
M, incorporating South Coast Air Quality Management
14?
District Rule 1174, the documents filed indicate
15?
that it was adopted on October 5th of 1990, but the
16
?
proposed subsection 120 suggested adoption on
17?
February 27th of 1991, and again, if you could
18
?
clarify whether there is some subsequent version,
19?
updated version, of that document that the Board
20?
would need to obtain.
21?
And finally under this section,
22?
question number six, subsection N incorporates a
23
?
provision of the California Administrative Code. In
24?
the copy filed with the Board, however, there were
Page 55
1?
five images which appeared to contain the VOC
2
?
content limits that appear in the document as not
3
?
available for printing, and we would ask that in
4
?
order to complete that document, of course, if you
5
?
could supply a copy of the document that does
6
?
contain those images that appear to be quite
7
?
relevant, of course.
8
?
MR. MATOESIAN: Okay.
9
?
MR. FOX: If I
may move on to
10
?
Section 223.203, which refers to specific
11
?
definitions for subpart B, the definition of
12
?
colorant in this section refers to the purposes of
13
?
subpart C, and if you would be willing to clarify
14
?
that reference, indicating whether there is an
15
?
inadvertent error, or whether it should be moved to
16
?
subpart C, we would be grateful if you would clear
17
?
that up for us.
18
?
MR. MATOESIAN: Okay.
19
?
MR. FOX: And similarly, the
20
?
definition of lacquer in 223.203 refers to the
21
?
purposes of subpart C and D. So if you would
22
?
similarly clarify that reference as well, we would
23
?
appreciate it. And number three, the definition of
24
?
VOM content also refers here in subpart B to the
Page 56
1
?
purposes of subpart B. And if you could similarly
2
?
clarify that, we would appreciate that as well.
3
?
Moving on to Section 223.208,
4
?
subsection A refers in a list of cross references
5
?
twice to Section 223.207, and I see that it does so
6
?
in the errata sheet as well, and we would ask simply
7
?
that you clarify whether that was an unintended
8
?
duplication or whether there was intent to cross
9
?
reference another section of the proposed rule.
10
?
MR. MATOESIAN: Okay.
11
?
MR. FOX: Okay. Thank you for
12
?
waiting, Mr. Matoesian. In both Sections 223.250
13
?
regarding product dating and Sections 223.255,
14
?
additional product dating requirements, the errata
15
?
that sheet does not appear to address the issue with
16
?
the product dating requirements, specifically that
17
?
they require display of that data no later than 12
18
?
months prior to the effective date of the applicable
19
?
standard.
20?
MR. MATOESIAN: We're looking for that
21
?
one.
22
?
MR. FOX: And I know I didn't phrase
23
?
that as clearly as I might have. So I appreciate
24?
that. All right. And moving on to Section 223.285,
Page 57
1?
test methods, subsection E refers to an ASTM method
2
?
incorporated by reference, although it does not
3
?
appear to be listed among the ASTM methods that are
4
?
incorporated by reference in Section 223.120. And
5
?
if you would clarify that for us, we would
6
?
appreciate it.
7
?
And moving on to subpart C,
8
?
specifically section 223.307, and forgive me if I'm
9
?
mispronouncing some terms. It's entirely possible
10
?
that I may do so. The definition is it calcabine
11
?
recoaters (phonetic) refers to the phrase "flat
12
?
solvent borns codings," B-o-r-n-s, which is unclear
13
?
to us. And if you could clarify the meaning of that
14
?
reference, we would appreciate it.
15
?
Number two, the definition of
16
?
nuclear coding refers to two ASTM methods, a
17
?
different version of which -- different versions of
18
?
which appear to be incorporated by reference in
19
?
Section 223.120, and if you would clarify, please,
20
?
whether the Agency intended to incorporate
21
?
additional methods, we would be grateful for that as
22
?
well.
23?
Number three, the definition of
24?
traffic marking coding refers to the term Berets,
Page 58
1?
B-e-r-e-t-s, which was unclear to us. If you could
2?
clarify the use of that term, we would appreciate
3?
that.
4
?
Number six, the definition of VOM
5
?
content refers to, quote, "Procedures specified in
6
?
sub Section 223.400A," close quote, which is the
7
?
purposes section under aerosol codings, and we would
8
?
appreciate any clarification of that cross
9
?
referenced, please.
10
?
And finally, number seven, the
11
?
definition of varnish in this section refers to the
12
?
term fetal sheen, F-e-t-a-1, new word, S-h-e-e-n,
13
?
which was not entirely clear to us. And if you
14
?
could offer any clarification of technical meetings
15
?
that might have eluded us, that would be great.
16
?
With regard to Section 223.340,
17
?
compliance provisions and test methods, subsection B
18
?
refers to the Agency's requirement that a
19
?
manufacture conduct a, quote, "Method 24," close
20
?
quote, analysis. Could you please clarify whether
21
?
the Agency intended to include language regarding
22
?
when it would require that analysis, any deadlines
23
?
or requirements relating to it.
24
?
Then under Section 223.370, test
Page 59
1?
methods, subsection E incorporates ASTM method
2?
D 1613-96, but Section 223.120 incorporates ASTM
3?
D 1613-03 under the same title. And if you could
4?
please clarify those two incorporations, we would
5?
appreciate it.
6
?
Similarly, under subsection F,
7
?
there's an incorporation of ASTM method D 1640-95,
8
?
but it refers to two specific definitions, first
9
?
quick dry enamel, and second quick dry primer,
10
?
sealer, and undercoating, both of which include
11
?
testing according to a different ASTM standard,
12
?
1640-03. And again, if we could ask for a
13
?
clarification, please.
14
?
Subsection H incorporates the Bay
15
?
Area Air Quality Management District method 43, a
16
?
different version of which is incorporated in
17
?
Section 223.120. And if you would please clarify
18
?
whether the agency intended to incorporate different
19
?
versions, and if so, to file both versions with the
20
?
Board for its record of this proceeding.
21
?
Section H also refers to a
22
?
definition of volatile organic material in
23
?
Section 223.307 where it is not defined, and if you
24
?
would also please clarify that reference.
Page 60
1?
Subsection I refers to compliance
2?
with Section 223.400, which is the purposes language
3
?
under aerosol codings. And if you would clarify
4
?
that cross reference as well, please. Subsection I
5
?
also incorporates South Cost Air Quality Management
6
?
District method number 303-91, a subsequent version
7
?
of which is incorporated by reference in
223.120,
8
?
and again, if you would clarify whether the Agency
9
?
intended to incorporate different versions, and if
10
?
so, whether -- indicate whether both versions have
11
?
been filed with the Board.
12
?
And under this subsection -- under
13
?
this section, finally, subsection M incorporates an
14
?
appendix in the Code of Federal Regulations, which
15
?
is incorporated under Section 223.120 with another
16
?
date in the citation. And if you would clarify the
17
?
correct version of that, we would appreciate that
18
?
very much.
19
?
Moving on to Section
223.407,
20
?
these are definitions for subpart D. The definition
21
?
of aviation or marine primer refers to federal
22
?
specification TT-P-1757. And if you would please
23
?
clarify that reference and its source in the federal
24
?
authorities, please. Second under that section, the
Page 61
1?
definition of product weighted MIR refers to a
2?
product subject to this article. And if you could
3?
clarify whether that's meant to refer to a product
4?
subject to this subpart or part.
5
?
And nearing the end,
6?
Section 223.410, limits and requirements for aerosol
7?
coding products. Mr. Rao kindly reminds me that you
8?
refer to the federal rule in addressing these
9?
products as being beyond legal challenge at this
10?
point, and unless I misunderstood there was an
11
?
intent to withdraw that, which would ineffectively
12
?
moot these questions about the wording of the
13?
proposed rule. So I appreciate the reminder that
14
?
those are not necessary to clear up.
15?
Mr. Matoesian, I know that was a
16
?
large number of questions, and appreciate your
17?
patience. And listening to those, as I said, if
18?
those were addressed in a post-hearing comment, I
19?
hope that the transcript made those about as clear
20?
as possible as they could for you.
21
?
MR. MATOESIAN:
Okay. Thank you.
22?
MR. FOX: Did I raise any questions
23?
in, kind of, rushing through those?
24?
MR. MATOESIAN: No. We can do the
Page 62
1?
ones that weren't corrected already.
2?
MR. FOX: Very good. I hope I didn't
3?
raise any that were addressed in the errata sheet.
4?
We certainly tried to avoid that. If there is
5?
anyone I have not at this point put to sleep that
6?
had any additional questions for the Agency, I'm
7?
sure that Mr. Davis would be happy to answer any of
8?
those. I did not want to move ahead while anyone
9
?
had questions that they wanted to pose. Are there
10
?
any further questions that anyone had for Mr. Davis
11
?
for either the Board members, member Moore, member
12
?
Melas, or the Board staff, Mr. Rao, were there any
13
?
further questions? I note that the sign up sheet
14
?
for persons who did not pre-file testimony but who
15
?
may wish to testify today remains blank, so we do
16
?
not have any further witnesses to testify here
17
?
today.
18?
I can move on, then, to the issue
19
?
of the economic impact study. Since 1998, section
20?
27B
of the Environmental Protection Act is required
21?
that the Board request that the department now known
22?
as the Department of Commerce and Economic
23
?
Opportunity conduct an economic impact study of
24?
proposed rules before the Board adopts them. The
Page 63
1?
Board must make either of the economic impact study
2
?
performed, or the department's explanation for not
3
?
conducting one, available for the public at least
4
?
20 days before a public hearing.
5
?
In this rulemaking proceeding, the
6
?
Board, in a letter dated January 24th of 2008,
7
?
requested that the department conduct an economic
8
?
impact study on this rulemaking proposal. To date
9?
the Board has received no response from the
10?
testimony with regard to that request. Is there
11?
anyone who would like to testify or offer comment
12?
regarding that request filed by the Board with the
13
?
department of commerce and economic opportunity?
14
?
Seeing or hearing no indication that anyone would
15
?
like to do so, what I would like to do at this point
16
?
is to go off the record just for a moment or two to
17
?
address some procedural issues.
18
?
(Whereupon, a discussion was had
19
?
off the record.)
20
?
MR. FOX: The participants in this
21
?
hearing went off the record specifically to discuss
22
?
procedural issues related to the filing of
23
?
post-hearing comments. Before it takes action on
24
?
the Agency's proposal, the Board will hold open a
Page 64
1?
period specifically for post-hearing comments ending
2?
30 days after the Board receives the transcript of
3
?
this hearing, which is expected on or about Tuesday,
4?
June 10th. In order to -- in addition, forgive
5?
me -- we will also hold open a period for responses
6?
to the Agency's post-hearing comment in a period for
7
?
those ending 14 days after the Board receives the
8?
post hearing comment from the Agency approximately
9?
July 24th, I believe we determined.
10
?
In order to set those deadlines
11?
more clearly and to avoid setting deadlines on
12?
weekends or holidays, I will issue a hearing officer
13?
order very quickly after we receive the hearing
14?
transcript so that those dates are as clear as
15
?
possible to all of the participants. The copies,
16
?
again, are expected in approximately six days on
17?
Tuesday, June 10th. And as soon as it is filed with
18?
the Board, it will be placed electronically on the
19
?
clerk's office online as soon. As it is posted
20
?
there, you can view it, download it, and copy it
21?
free of charge at any time.
22
?
In addition, anyone may file more
23?
general public comments on this proposal that has
24?
been filed by the Agency. Those may be filed
Page 65
1?
electronically through the Board's clerk's office
2
?
online, the COOL system that you heard reference to,
3?
and any questions about the use of the COOL system
4
?
should be directed to the check's office. Filings
5
?
with the Board, whether paper or electronic, must
6
?
also be served on the hearing officer and on those
7
?
persons on the service list. For filing with the
8
?
clerk, please contact the clerk's office to ensure
9
?
that you have the most recent version of the service
10
?
list, and if anyone has questions about procedural
11
?
aspects, they may certainly contact with the contact
12
?
information contained on the web, and certainly on
13
?
any hearing officer order.
14
?
While no other hearings are not
15
?
scheduling in this rulemaking, I did want to address
16
?
very, very, quickly one other non-substantive issue.
17
?
The Board is fortunate to have working with it this
18
?
summer an intern, Katie Kindel (phonetic). She
19
?
arrived with Marie Tipsord, who is the attorney
20
?
assistant for acting chairman, Tanner Gerard, and I
21
?
was remise in not recognizing them earlier, and I'm
22
?
sure Marie's face, that is entirely familiar to
23
?
virtually everyone in the room.
24
?
With that, are there any other
Page 66
1?
matters that need to be addressed at this time?
2
?
Seeing none, thank you certainly to Mr. Davis,
3
?
Mr. Matoesian, Ms. Hodge, and all of the other
4
?
participants who are here today. I know the Board
5?
appreciates your time, your effort, and your input,
6?
and we can adjourn. Thank you.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 67
1?
STATE OF ILLINOIS )
SS
2
?
COUNTY OF COOK
3
4
?5?
REBECCA A. GRAZIANO, being first
6
?
duly sworn on oath says that she is a court reporter
7?
doing business in the City of Chicago; that she
8?
reported in shorthand the proceedings given at the
9
?
taking of said hearing and that the foregoing is a
10?
true and correct transcript of her shorthand notes
11?
so taken as aforesaid and contains all the
12?
proceedings given at said hearing.
13
14
15?
,4-0647/4,m
REBECCA A. GRAZIANO, CSR
16?
29 South LaSalle Street, Suite 850
Chicago, Illinois 60603
17
?
License No.: 084-004659
18
19
?
SUBSCRIBED AND SWORN TO
before me this 4th day
20
?
of June, A.D., 2008.
21
-e-}J
Notary Public
22
23
?
F
DIANA
a
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24
?
Notary
?
-
?
1',
?
■S
NV
Commission
t
Page 68
A
added
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ambient
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11:16
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64:3 65:3
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64:4,22
admit
21:2
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2:6
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among
50:9
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47:9,13
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apologize
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28:5,6
admitted
5:3,8,9
ago
30:2
amount
6:23 19:3
47:23
31:7,14
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33:20
8:20
20:14
accept
8:3
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agree
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32:2,8,11
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34:3
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39:12,16
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17:16
52:6 55:2
according
40:7
43:12
13:16,23
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29:12
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59:11
56:14
adopted
14:16
ahead
16:9
34:24
56:15
accurate
57:21
54:15
15:6 17:3
49:11
36:15,18
57:3,18
26:20
62:6
adoption
20:17
62:8
40:2,7,17
appeared
30:24
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40:16
21:12
aim
43:10
58:20,22
2:21
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53:3
54:16
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1:7 8:18
analyzed
51:18
achieved
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29:11
24:8
32:9
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17:3 22:6
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30:17,24
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55:1
16:20
30:9 40:3
advance
31:5,9,21
35:2,20
3:17
appearing
27:11,16
52:1 53:9
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32:14,22
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62:20
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60:3 61:6
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54:3,13
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39:3
action
44:23
affairs
39:9,9
59:15
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51:11,12
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51:24
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44:13
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56:9
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39:7
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20:15,20
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50:11,15
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41:15
51:16
41:1,8
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48:20
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64:2,7,13
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62:1
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apply
48:4
61:8
again
59:18
alternative
anticipate
26:21
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adhesive
10:10
60:8 62:6
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16:19
appreciate
add
7:11
24:2
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although
anticipated
42:4,12
37:12
15:9
Agency's
41:9 57:2
17:10
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Page 69
55:23
associated
2:17
6:5 8:2
beyond
54:4
45:3
56:2,23
30:18
aviation
9:17 14:5
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capacity
57:6,14
32:2,7,10
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61:9
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24:23
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48:22
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await
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apprecia...
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63:4,23
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brand
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41:8
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4:12
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Page 70
43:1
cause
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64:21
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4:16,21
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33:8 34:2
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considered continue
44:17,24
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64:11
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32:22
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51:9,24
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65:8
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41:24
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67:7
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53:6
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38:14
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42:22
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48:17
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42:13,13
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6:11
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51:4
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41:21
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12:9 14:2
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contact
64:20
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company
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59:4,17
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59:24
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Page 71
16:3 24:1
24:19,23
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29:19
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creams
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56:4
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Page 72
duplicati...
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Page 73
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Page 74
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