Benjamin

A

Moore®

Paints

November

19, 2008

John

Therriault,

Chief

Clerk

C

/

FlOE

Clerk’s

Attention

Office

Docket

#R09-08

smr

NOV

24

2008

Illinois

Pollution

Control

Board

Po,i,jti

0

fOiS

100 W.

Randolph,

Suite

11-500

oar

Chicago,

fllinois

60601

RE:

Illinois

EPA

Architectural

and

Industrial

Maintenance

(AIM)

Coatings;

Docket

#R4

og,—17

Dear

Mr.

Therriault:

Benjamin

Moore

&

Co.

has

been

making

quality

paints

for over

125

years.

Through

those

years,

we

have

adapted

to and

complied

with

ever changing

environmental

regulations.

Currently

Benjamin

Moore

has

one

warehouse

located

in

the state

of

Illinois.

We

believe

that

it is

unrealistic

to

be

able

to

comply

with

the

short

compliance timeframe

because

sufficient

time

is needed

to

convert

our

warehouse

to compliant

stock,

communicate

changes

internally,

to

independent

retailer,

contractors,

architects,

and

do-it-yourself

consumers,

and revise

internal

systems

and

procedures.

Also

with

the new

AIM

amendments,

in addition

to

changing

formulations,

we

will

need

to

develop

and

print

new

labels

for

the

reformulated

products.

Benjamin

Moore

&

Co.

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

the

state

of 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.

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,

W.

Kip Cleverley,

CHMM

Director,

Environment,

Health

&

Safety,

Product

Stewardship

&

Facilities

kip.cleverley

@benjaminmoore.com

Benjamin

Moore

& Co.,

360 Route

206, P.O.

Box 4000,

Flanders, Ni

07836-4000

(t)

973

927-8600

(f) 973 252-2660

---

225

Carpenter

Avenue

LI

Wheeling

Illinois

60090-6095

Li

847 I 541-5700

LI

FAX

#

847

/ 541

-9043

November 21, 2008

fc

REOVED

Mr. John Therriault

\

CLERK

OFFIC

Chief Clerk; Clerk’s

Office

Illinois Pollution

Control

Board

NOV

2

‘

2008

100

W.

Randolph,

Suite 11-500

STATE

OF

IWNOS

Chicago, Illinois

60601

Pollution

Contrd Board

Re:

Illinois EPA

Architectural

and Industrial

Maintenance

(AIM) Coatings;

Docket #RO-ê8

Dear Mr.

Therriault:

Sunnyside Corporation

is a fourth generation,

family-owned

business

founded

in Chicago in 1893,

and

first

incorporated in the State

in 1921.

We

are

proud of our Illinois

heritage,

our

dedicated employees

and

our role

as a

good neighbor and

responsible

corporate

citizen.

As

a

long-standing

member of

the

National Paint

& Coatings Association

(NPCA),

Sunnyside

Corporation supports

NPCA’s request

to extend the implementation

date of the AIM rulemaking

from

January 1, 2009,

to allow adequate

time

to

finalize

and adopt effective,

achievable objectives

for

the

amendments

to the

AIM

rule,

and

allow Industry time

to make necessary

product

changes in order

to

comply with

the finalized AIM Amendments.

Paint

& coatings

manufacturers,

as well as manufacturers

of allied

products,

will reformulate literally

thousands

of products

and

conduct testing

to confirm not

only compliance,

but confirm that

new,

reformulated

products actually

perform

for the end user.

New product labels

will need writing,

and

computer

systems and other

“lock-out”

tools

upgraded

to prevent

shipment of “non-compliant”

product

into

the State of Illinois. Additionally,

effectively

communicating

the new AIM

Amendments

and their

significance

to all downstream

participants

in the market channel

requires

precious corporate resources,

already

stretched

because of

the

current economy,

and

time.

Finally, a “sell-through”

period

is typically

established

so product

in the process of manufacture

and product

in the market channel

can be sold

prior

to the

effective

date

of the Amendments.

Sunnyside

Corporation

respectfully requests

that

the AIM

rulemaking

implementation

date be

moved to

a

date following adoption

of a final rule,

and to a date that also

gives

consideration

to the practical

issues

outlined

above.

Thank

you for your consideration

and

you may feel free to contact

me directly,

should

you have any

questions or comments.

Ro

ert

J. Lueders

President

Solvents,

Chemicals, Oils

---

<

SUPERiOR

COATING SYSTEMS

Manufacturer

of

Bruning

and

Kyanize

Paints

November

19,

2008

John

Therriault,

Chief

Clerk

Clerk’s

Office

‘7’

Attention

Docket

#R09-08

ç

NOV

24

2008

Illinois

Pollution

Control

Board

V

L-

STATE

OF

ILUNO

Chicago,

100

W.

Randolph,Illinois

60601

Suite

11-500

)

OIIUtIon

Control

Bod

RE:

Illinois

EPA

Architectural

and

Industrial

Maintenance

(AIM)

Coatings;

Docket

Dear

Mr.

Therriault:

My

name

is

Jim

Boyce

and

I

represent

Insl-x

Products

Corp.

We

are

the

parent

company

of

Bruning

Paint,

Insl-x

Products,

Coronado

Paint,

Lenmar

Wood

Finishes,

and

Trinity

Coatings.

Although

we

do

not

manufacture

in

Illinois,

we

do

operate

a rather

large

distribution

center

in

Elk

Grove

Village,

IL

Insl-x

Products

Corp.

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.

The

logistics

of

implementing

the

steps

needed

to

meet

this

regulation

in

less

than

2 months

would

be

very

difficult

for

any

company

and

puts

an

unnecessary

burden

on

our

industry

during

a

very

difficult

time

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,

Insl-x

Products

Corp.

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,

oim

iioyce

/

I

Director

of Technical

Services

lnsl-x

Products

Corporation

50

Holt

Drive,

P.O.

Box

694,

Stony

Point,

NY

10980

(845)

786-5000

FAX:

(845)

786-5831

601

South

Haven

Street,

Baltimore,

MD

21224

(410)

342-3636

FAX:

(410)

675-0368