| Action | Consumer and Commercial Products (Rev. J07) |
| Stage | NOIRA |
| Comment Period | Ended on 2/6/2008 |
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1 comments
January 7, 2007
Ms. Cindy M. Berndt
Virginia Department of Environmental Quality
629 East Main Street
P.O. Box 1105
Richmond, VA 23218
RE: Virginia Architectural and Industrial Maintenance (AIM) Rule;
9 VAC 5-40-7230 A – G - Notification, Records and Reporting Requirements
Dear Ms. Berndt:
The National Paint and Coatings Association (NPCA)[1] requests on behalf of our members either the deletion of or a waiver from the burdensome “automatic” annual reporting requirements found in Sections 9 VAC 5-40-7230 A – G. These requirements originated from the California Air Resources Board (CARB) 2000 AIM Suggested Control Measure and were subsequently included in the Ozone Transport Commission (OTC) “model rule”. It is important to note however that only two OTC states actually adopted these requirements. Further in October 2007 – CARB deleted these requirements from the 2007 AIM SCM since it felt that this information was no longer needed. Finally, the collection of this information is burdensome and much of the information is confidential information that will need to be handled as such.
Thank you for your consideration of our request.
Sincerely,
/s/ /s/
David F. Darling, P.E., Alison Keane
Director, Environmental Affairs Counsel, Government Affairs
Cc: Todd Alonzo
[1]NPCA is a voluntary, nonprofit trade association representing some 350 manufacturers of paints, coatings, adhesives, sealants, and caulks, raw materials suppliers to the industry, and product distributors. As the preeminent organization representing the coatings industry in the United States, NPCA’s primary role is to serve as ally and advocate on legislative, regulatory and judicial issues at the federal, state, and local levels. In addition, NPCA provides members with such services as research and technical information, statistical management information, legal guidance, and community service project support.