November
    24,
    2008
    CLERK’S
    OFFICE
    John
    Themault,
    Chief
    Clerk
    08
    Attention
    Clerk’s
    Office
    Docket
    #R09-08
    ?oIlticr,
    STATE
    OF
    Control
    ILLINOIS
    Board
    c
    Illinois
    100 W.
    Pollution
    Randolph,Control
    Suite
    11-500
    Board
    /
    1)
    Chicago,
    Illinois
    60601
    RE: Illinois
    EPA
    Architectural
    and
    Industrial
    Maintenance
    (AIM)
    Coatings;
    Docket
    #R09-08
    Dear
    Mr. Therriault:
    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
    that
    was
    to originally
    be
    im
    plemented
    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,
    Timothy
    Filas
    Senior
    Production
    Planner
    fflas.timsika-corp.com
    740-387-9224 ext. 174
    740-387-3084 (fax)
    Sika
    Corporation,
    201
    Polito Avenue,
    Lyndhurst
    NJ 07071,
    USA
    Tel:
    201
    933 8800,
    Fax: 201 933
    6225,
    www.sikausa.com

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