November 24,

2008

John Therriault, Chief

Clerk

Clerk’s

Office

Attention

Docket #R09-08

ILLIN

1

Illinois Pollution

Control Board

°fltroi

BOard

100

W. Randolph, Suite 11-500

Chicago, Illinois

60601

RE:

Illinois

EPA

Architectural

and Industrial

Maintenance

(AIM) Coatings

Docket

#U9

pt)g

()

Dear Mr. Therriault:

The Sherwin-Williams

Company is one of

the largest coating manufacturers

in

the world, with 2007

sales

of

about

8

billion

dollars. We

maintain manufacturing

facilities

and company-owned

and

operated

Stores

throughout

the country and

employ about

26,000

people. In

addition

to our

company-owned stores,

we

own and operate

a

major

manufacturing

facility

and a large distribution

center within

the State of Illinois.

Our

stores are the exclusive

distributors

/ retailers for the

Sherwin-Williams

brand. In addition

to

this

distribution,

our products,

under a

variety

of

additional brand names,

are

distributed

through

mass

merchandisers, do-it-yourself

outlets,

hardware

stores,

and by independent

distributors.

Our product

lines

include

some of the brands

best

known

to the American people,

including

— but not limited to —

Minwax®, Thompsons®,

Pratt &

Lambert®,

Martin-Senour®,

Dutch

Boy®,

Rust

Tough®,

Cuprinol®,

and H&C®.

In the architectural

and

industrial

maintenance

product areas

these coatings are

used for

their

decorative

and protective

properties.

The

Sherwin-Williams

Company 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.

More

importantly, this will

provide adequate time

for our company and

customers to

make necessary

changes in

order to

comply with the amendments.

Normally, we

expect

a time

period of no

less than

one

year from

the

final adoption

of a rule to the effective

date

of the

rule, in order to insure

that

all customers

understand

their

requirements.

Thus,

we

believe our request

for a 5-6 month

time

period

to be very reasonable.

With this

new AIM rule,

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

r

SHERWIN-

WILLIAMS.

101 Prospect

Avenue NW

Cleveland,

Ohio

44115-1075

Facsimile: (216) 566-2730

9

DEC

o

12008

---

distributors,

customers

and

specifiers

in

order to

ensure

their

compliance

with

the

new

products.

It is

impossible

for

manufacturers

to make

these

necessary

changes.

Even more

important,

it is

impossible

for

us

to properly

communicate

the

details

of the

IL AIM

rule

without

a final

adopted

rule!

This

is

especially

an

issue since

additional

changes

may

occur

between

now and

the final

adoption.

Therefore,

The

Sherwin-

Williams

Company

strongly

believes

that

the

implementation

date must

be moved

to

July

1,

2009

or

later.

Thank

you for

your

consideration

of

our request.

If you

have

any

questions

or need

additional

infonriation,

please

do

not

hesitate

to

contact

me

by

telephone

at 216-566-2630

or

by

email

at

mkharding(sherwin.com.

Scerely,

Madelyn

K.

Harding,

Corporate

anager

Regulatory

Affairs