Document 85v6qbQmXypMEYoOgOLzOBevm
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Heidi McAuliffe [hmcauliffe@paint.org] 3/22/2018 11:18:47 PM Dravis, Samantha [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=ece53f0610054e669d9dffe0b3a842df-Dravis, Sam] Bolen, Brittany [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=31e872a691114372b5a6a88482a66e48-Bolen, Brit] Thank you and ACA's Petition for Rulemaking (3) ACA Second Petition to Add Compounds to EPA's Aerosol Coatings Tables (002).pdf
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Follow up
Samantha,
Thank you for responding to all of the questions posed to you during the association roundtable earlier this month. I always learn quite a bit from the whole discussion. It was very generous of you, and Brittany, to give us so much time to explore our issues.
I wanted to follow up with you regarding ACA's petition for rulemaking which seeks to add compounds to the Reactivity Table in the aerosol coatings regulation. I realize that my very short presentation at the roundtable may have raised more questions than I answered. I have attached the most recent petition filed by ACA in July of 2017.
We had originally drafted a more complex petition, requesting changes to the standards as well as additional product categories. On the advice of EPA, we pared down the requested changes and focused on the more narrow issue of adding compounds to the table. This was done to facilitate more efficient handling by EPA and our hope was that a direct final rule would be pursued. We have been told recently, however, that other priorities will supercede any action at all on our petition.
I would like to talk with you further about the aerosol coatings regulation. I know that there are some restrictions on moving forward with a regulation due to the "2 for 1" requirement but there are good opportunities in this rule to eliminate a burdensome requirement which could help facilitate action.
Please feel free to give me a call at your leisure or drop me an email. I am happy to talk with you more about this issue. As always, thank you for your assistance.
Best regards,
Heidi K. McAuliffe American Coatings Association Vice President, Government Affairs
202- 719-3686
Ex. " |m) I 202-263-1102 (fax) | hmcauiiffe@paint.org |www.paint.org
901 New York Ave. NW, Suite 300 West Washington, DC 20001 Coatings protect. Coatings preserve. Coatings provide.
Sierra Club v. EPA 18cv3472 NDCA
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