ED
DEC
012008
PPG
Architectural
Finishes,
Inc.
STATE
OlIUtjo
OP
Control
ILLINOIS
Board
151
Colfax
Street,
Springdale,
PA 15144
Robert
S.
Gross
Manager,
Environmental
Stewardship
Architectural Finishes
(724)
274-3416
November25, 2008
John
Therriault,
Chief
Clerk
Clerk’s
Office
Attention
Docket
#R09-08
Illinois
Pollution
Control
Board
100 W.
Randolph,
Suite
11-500
Chicago,
Illinois
60601
RE:
Illinois
EPA
Architectural
and
Industrial
Maintenance
(AIM)
Coatings;
Docket
#Ru4rr
Dear
Mr.
Therriault:
PPG
Architectural
Finishes,
Inc.
is
a
wholly
owned
subsidiary
of
PPG
Industries,
Inc.,
with
many
manufacturing,
distribution,
and
retail
facilities
throughout
Illinois,
including
an
architectural
coatings
manufacturing
facility
located
in
Batavia,
IL.
PPG
Industries,
Inc.
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 ATM
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,
PPG
Architectural
Finishes,
Inc.
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,
Robert
S. Gross
November24
2008
CLERKS
OFFICE
DEC
012008
John
Therriault, Chief
Clerk
Clerk’s
Office
STATE
OF
ILLINOIS
Attention
Docket
#R09-08
Pollution
Control
Board
Illinois
Pollution
Control
Board
Q
;/
100
W.
Randolph,
Suite
11-500
Chicago, illinois
60601
RE:
illinois
EPA
Architectural
and Industrial
Maintenance
(AIM)
Coatings;
Docket
#RolT
Dear
Mr. Therriault:
Sika
Corporation
(formerly
Vaispar
Flooring)
has
been
a
presence
in
the
Industrial
Coating
and Sports
Floor Finish
market
for
nearly 100
years. Our
production
facility was
on the near
South Side
of Chicago for
many
years
and
our
management
and operations
had run
out
of
Wheeling,
Illinois
for
years.
Sika Corporation
is
a
member
of the
National Paint
&
Coatings
Association
(NPCA)
and does NOT
support
NPCA’s request
to extend
the implementation
date of
the AIM
rulemaking
from
Januaiy
1, 2009
to July
1, 2009.
Paint
and
coatings
companies
have
had sufficient
time
and
notice
to
respond
to the
rule
which
was
to
originally
be
implemented
on January
1 of 2008.
It is
regretable
that
other companies
have
not
taken this
opportunity
to
better
themselves
and
their technology
in
order
to
support
the
impending
EPA
regulations.
It is also
regretable
that
those of
us
who
took the rulemaking
seriously
and
spent
the time,
energy and
funds necessary
to revamp
our product
lines
in
order
to
support
the
new
regulations
will
suffer for our
compliance
by
not being
able to take
advantage
of the
first
to
market
opportunities
which we
counted
on
to
help
to
offset
the
cost
of timely compliance.
Pushing
back
this
rule
is
causing
us to
have
to
support
two
duplicate
product
lines
in
the
field.
One of
the
product
lines is
a
fully
compliant
line
released
prior
to
2008
and
the other is our
original
non compliant
line
which
needs
to be
left in
place in order
to
compete
with
others who
continue
to
offer
the
noncompliant
versions
as
regulations
continue
to
be
pushed
back.
We, as
industry,
HAVE
HAD
adequate
time
to
make necessary
changes
in order
to
comply
with
the amend
ments
and should
not be
granted extentions
due to
lack of
effort.
Further,
those
of
us
who
are
in
compliance
have
already made
changes
to our products,
labels and
computer
system
lock outs
in order
to
comply
with the original
2008
and
then January,
2009
dates.
We have already
communicated
changes
to
our
customers,
distributors
and specifiers.
Therefore,
Sika
Corporation
strongly believes
that
the
imple
mentation
date
should
be
held
at January
1st,
2009.
Thank
you for
your
consideration
of our request.
Please do
not
hesitate to
contact
me
if
you have
any
questions
or
need
additional
information.
Sincerely,
David
DeLarso
Sr.
Sales Representative
— NE Market
Sika
Industrial
Flooring
215-429-2871
Sika
Corporation, 201
Polito
Avenue,
Lyndhurst
NJ
07071
USA
Tel:
201
933 8800,
Fax: 201 933 6225,
sikausa.com
November24, 2008
CEIVED
CLERK’S
OFFICE
John
Clerk’s
Therriault,Office Chief Clerk
\
DEC 01
\/‘\
Attention
Docket
#R09-08
.TMTE
OF
ILLINOIS
Illinois Pollution Control Board
OUuflor
Control
Board
100
W.
Randolph, Suite 11-500
Chicago,
Illinois
60601
RE: Illinois EPA
Architectural
and
Industrial
Maintenance (AIM)
Coatings;
Docket
#1
Dear Mr. Therriault:
Sika
Corporation (formerly Vaispar Flooring) has been a presence in
the
Industrial Coating and Sports
Floor Finish
market for
nearly 100 years. Our production facility was on
the
near
South Side of Chicago for many years
and our
management
and operations had run
out
of Wheeling, Illinois for years.
Sika Corporation is a
member of the National Paint
& Coatings
Association (NPCA) and
does
NOT
support
NPCA’s request to
extend the implementation date of the AIM rulemaking from January 1, 2009 to July 1, 2009.
Paint and coatings
companies have had sufficient time and notice to respond to the rule, which was to originally
be
implemented on January
1
st
of 2008. It is regrettable that other companies
have
not
taken this opportunity
to better
themselves and their
technology
in order
to
support
the
impending EPA regulations. It is also regrettable
that
those
of us
who took the rulemaking seriously and spent the time, energy and
funds necessary
to
revamp our product
lines
in order to support the new
regulations will suffer for our compliance
by
not being able to take advantage of the first
to market
opportunities which we counted on to help to offset the cost of
timely compliance. Pushing back
this
rule
is
causing us to have to
support
two
duplicate product lines in the field. One of the product
lines is
a
fully
compliant
line
released prior to 2008 and
the other is our original non compliant line which needs to be
left in place
in order to
compete with others
who continue to offer the noncompliant
versions
as
regulations continue to be pushed back.
We, as
industry, hAVE
HAD
adequate
time
to
make necessary changes
in order
to
comply with the amend
ments and should not be
granted extensions
due to
lack of effort.
Further, those
of
us
who are in
compliance
have
already made changes to
our products, labels and computer system
lockouts in
order
to
comply with the
original 2008 and then January 2009
dates. We have already communicated
changes
to
our customers,
distributors and specifiers. Therefore,
Sika Corporation
strongly
believes that the imple
mentation
date should be held at
January
1
st
2009.
Thank you
for your
consideration
of our request. Please do not hesitate
to contact
me if you have any questions or
need
additional
information.
Sincerely
Jeff
Trench
Sports
Flooring Manager
trench.jeff@sika-corp.com
210-408-0709
A
2104157687
Sika
Corporation, 201 Polito Avenue,
Lyndhurst
NJ
07071, USA
Tel:
201 933 8800,
Fax: 201 933 6225,
www.sikausa.com
November
24, 2008
John
Clerk’s
Therriault,Office
Chief Clerk
DEC
0
200
Attention
Docket #R09-08
\Th’
STATE
OF
ILLINOIS
Illinois
Pollution
Control
Board
‘ \JOIIUtiori
Control
Board
Chicago,
100 W. Randolph,
illinois
60601
Suite
11-500
C —
RE:
Illinois
EPA
Architectural
and
Industrial
Maintenance
(AL’ll) Coatings; Docket
,ç-t1
Dear
Mr. Therriault:
V
Sika Corporation
(formerly
Valspar
Flooring)
has
been
a presence in the Industrial
Coating and
Sports Floor
Finish
market for nearly
100 years. Our production
facility
was
on the
near
South
Side of Chicago for
many years
and our
management
and operations had
run out of Wheeling,
Illinois for years.
Sika
Corporation
is
a
member
of the
National
Paint & Coatings Association
(NPCA) and does
NOT
support
NPCA’s
request to extend
the
implementation date
of the AIM rulemaking
from January
1, 2009
to July 1, 2009.
Paint and coatings
companies
have had
sufficient time and notice
to respond to
the
rule which
was to originally
be
implemented
on January
1
st
of 2008.
It is regrettable that other
companies have
not taken this
opportunity
to better
themselves
and their technology
in
order to support the
impending EPA regulations.
It is also
regrettable
that those
of
us
who
took the rulemaking
seriously and spent
the time, energy and funds
necessary
to
revamp
our
product lines
in order
to support the new
regulations
will suffer
for our compliance
by not being able to take
advantage
of the
first
to
market opportunities
which we
counted on
to help to offset the
cost of timely compliance.
Pushing
back this
rule
is causing us
to
have
to
support two
duplicate
product lines in the field.
One of the
product lines
is a fully compliant
line released prior
to 2008
and
the
other
is our original non
compliant line which
needs
to be left
in place in order
to
compete with
others who continue
to
offer the noncompliant
versions as regulations
continue to
be pushed
back.
We, as
industry, HAVE
HAD
adequate time to make
necessary
changes
in order to comply
with
the amend
ments
and
should
not
be granted
extensions
due to
lack
of effort.
Further,
those of us who
are in
compliance have already
made changes
to our products,
labels and computer system
lock outs in order to
comply with
the
original
2008 and then January,
2009
dates.
We have
already communicated
changes
to our customers,
distributors
and
specifiers.
Therefore,
Sika Corporation strongly
believes that the imple
mentation
date
should
be held at January
1
st,
2009.
Thank you
for
your
consideration of
our request.
Please do
not hesitate to contact
me if you
have
any questions
or
need additional
information.
Sincerely,
David
Orser
Senior Chemist
orser.david@sika-corp.com
201-508-6921
Sika
Corporation,
201 Polfto
Avenue, Lyndhurst
NJ 07071, USA
Tel: 201 933
8800, Fax:
201
933
6225,
wwwsikausa.com
