Document darGKpYzQQzQQGzQXedy2vxqR

From: Heidi McAuliffe [hmcauliffe@paint.org] ent: 2/20/2025 2:13:13 PM o: Tardif, Abigale (Abbie) [Tardif.Abigale@epa.gov] object: RE: Request for a Meeting: American Coatings Association ttachments:ACA.2024 EPA External Meeting Request Form.pdf Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open attachments or click on provided links. Hi Abbie, I received the meeting request form from OAR Invitations and have already sent it back to them. Thank you for forwarding my meeting request. In addition to the information provided on the form, I want to provide you some additional background on this issue. The very short compliance deadline is the only part of the rule that is problematic for the industry. We worked very hard with EPA over the last 7-8 years to get this rule finalized. It began with a petition for a rulemaking to EPA in 2017, during President Trump's first term but was just published as final on January 17, 2025. Most of the requirements of the rule, with the exception of the compliance deadline, are appropriate and science-based. The industry is not asking for any changes to the substantive parts of the final rule. However, the very short compliance deadline has made it impossible for some companies to produce compliance coatings before July 17, 2025. While it is true that some companies are already in compliance with the newly finalized requirements, this is not true across the industry. EPA acknowledges this in the preamble to the rule in Section IV Response to Significant Comments. Companies who private label aerosol coatings or toll manufacture these products are particularly at risk with this very short compliance deadline. Typically, those companies have a large inventory of SKUs and there isn't enough time to complete an audit of these private label products to determine if they are in compliance and then reformulate, test, and relabel them if they are not. We are searching for the most appropriate way to address the sole issue of the compliance deadline. Here is a link to the rule: Federal Register :: National Volatile Organic Compound Emission Standards for Aerosol Coatings Amendments During the rulemaking, the rule manager at EPA was Kaye Whitfield at EPA. I am looking forward to talking with you about this issue and will wait to hear from your scheduling team. Please do not hesitate to reach out to me if you have additional questions prior to our meeting. Best regards, Heidi K. McAuliffe, Esq. American Coatings Association Senior Vice President, Government Affairs 202- 719-3686 202-329-1065 (m) 202-263-1102 (fax) amcauliffe(c4paintorg www.paint.org 901 New York Ave. NW, Suite 300 West Washington, DC 20001 Coatings protect. Coatings preserve. Coatings provide. Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003637-00001 SC_FOIA_0001311 From: Heidi McAuliffe Sent: Monday, February 17, 2025 11:24 AM To: Tardif.Abigale@epa.gov Subject: Request for a Meeting: American Coatings Association Dear Abbie, Congratulations on your appointment to EPA. ACA's Air Quality team is eager to meet with you to discuss the priorities of the paint and coatings industry. However, I have a more urgent request for a meeting due to a final rule for aerosol coatings issued on January 17, 2025. We worked very cooperatively with EPA's rulemaking team on this effort, providing extensive comments over an extended rulemaking timeframe. The issue with the final rule is solely focused on the effective date. As I indicated above, the rule was published in the FR on January 17, 2025, and the effective date is July 17, 2025 -- a mere six months. Six months does not give industry members the necessary time to conduct inventory audits, develop formula changes where required, audit labels and make the required changes, and ensure that the distribution chain is informed of the final rule changes. In addition, for companies who private label or toll manufacture aerosol coatings and are required to provide warranties and assurances of compliance with all applicable laws, the six-month compliance period is particularly problematic. Can we find a time to discuss this in person, or by a virtual means soon? The matter is particularly urgent due to the short time frame for compliance with the rule. I am happy to answer any questions and look forward to talking with you as soon as possible. Best regards, Heidi K. McAuliffe, Esq. American Coatings Association Senior Vice President, Government Affairs 202- 719-3686 202-329-1065 (m) 202-263-1102 (fax) ,imcauliffe@paint.org www.paint.org 901 New York Ave. NW, Suite 300 West Washington, DC 20001 Coatings protect. Coatings preserve. Coatings provide. Sierra Club FOIA Request: 2025-EPA-04193 ED_018475D_00003637-00002 SC_FOIA_0001312