ECEgVED

CLERK’S

OFFICE

DECj

52008

December11,

2008

STATE

O’WNOIS

John

Therriault,

Chief

Clerk

Controi

Board

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

#R9O8

Dear Mr.

Therriault:

Dave

Darling

from

the

NPCA

called

me to inform

me that

Sika Corporation’s

purchase

of

the Vaispar

Flooring

Division

did

not

included

a

continued

membership

in the

National

Paint and Coatings

Association.

Although

I had assumed

we

continued

to be

a

member

of

NPCA

when I

sent my

original

letter, it appears

that I may

not

be speaking my

opinion

as

a

member

of

NPCA

unless Sika Corporation

chooses

to joing

the organization

in

the next

few

days. My comments

stand

as a formulator,

producer

and marketer

of AIM

regulated

paint

and

coating products.

I continue

to support

an Illinois

AIM

Rule

go live date

of

January

1, 2009.

To

reiterate, Silca

Corporation

does NOT

support a 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

1st

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

fuiiy 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

amendments

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 afready

communicated

changes

to

our

customers,

distributors

and

specifiers.

Therefore,

Sika Corporation

strongly

believes that

the implementation

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,

Lisa

E

Director

of Business

szczupaj

.lisa@sika-corp.com

847-221-5691

773-677-1840