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Illinois

December

18, 2008

DEC

222008

STATE

OF

WNOS

John Therriault

PoUuton

Control

Board

Illinois

Pollution

Control

Board

James

R. Thompson

Center

100

W. Randolph

Street,

Suite 11-500

Chicago,

IL

60601

Re:

R08-17,

Proposed

Standards

and Limitations

for Organic

Material

Emissions

for

Area Sources

(35

III

Adm. Code 223; 32

III Reg. 17301)

Dear Illinois

Pollution

Control

Board

Members,

The

Chemical

Industry

Council

of

Illinois

(‘CICI”) would like

to

register

its voice

in

support of the

National

Paint

and Coatings

Association’s (NPCA)

request of the change

of the

implementation

date.

CICI

is

a

statewide

trade association

representing

the

chemical

and the

paint industry in

Illinois. CICI has

198 member

companies

employing

over 49,000

workers

in 726

manufacturing facilities

and 877

wholesale

and

distribution

facilities

in Illinois.

NPCA’s

request

to extend

the implementation

date

of

the

architectural

and

industrial

maintenance

(AIM)

coatings rulemaking

from

January 1, 2009 to

July 1,

2009

will

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.

Since

the

1

st

Notice

comments

are

not due until December

22, 2008 and the

proposed rule

will need

to

be sent

to JCAR

for

2

Notice,

this does not

allow

enough

time for

the state

of Illinois

to meet

the set

implementation

date of January

1, 2009 for

finalization

of

the

rule. It

seems

reasonable

then

to

allow for

both

the

state

and industry

the time to

ensure

that

the

implementation

of the proposed

rule will occur smoothly.

It

is therefore

that

CICI

supports

the

NPCA’s

petition designated

R08-017.

Respectfully

submitted,

isa Frede

Director

of

Regulatory

Affairs

Chemical

Industry

Council

of

Illinois

[lcadq

u:i

rters

400

13.

Touliv Ave.,

Suite

110.

Des Plaines. II.

60018

• Tel:

(847)

544-5995

e Fax:

(847)

544-5999

Springuieki

400

W,

Monroe.

Suite 205.

Springfield.

II. 62704

• Tel:

(217)

522-5805

• Fax:

(2 7)522-5815

Website:

ww

v.ccil.ne{