June 25, 1996
Honorable James M. Talent
U.S. House of Representatives
1022 Longsworth House Office Building
Washington, D.C. 20515
Dear Congressman Talent:
In response to your inquiry about the Environmental Protection Agency's proposal regarding the architectural coatings rule, I am providing you with a copy of the proposed rule. The rule was signed by the EPA Administrator last week, and is scheduled to appear this week in the Federal Register. To its credit, the agency did consult with us during the formulation of the proposal, and incorporated several of our suggestions in the proposal and regulatory analyses. My staff has also been working with the trade associations and some individual paint manufacturers on the rule.
The proposed rule places limits on the amount of volatile organic compound (VOC) emissions from architectural and industrial maintenance coatings. According to the National Paint and Coatings Association, the primary industry association affected by the rule, the limits are very closely patterned after the industry recommendations. On the other hand, we are concerned that small regional and local companies may not be able to reformulate their coatings, particularly their smaller product lines, in a cost-effective manner.
As a result of this concern, we suggested two significant changes to the EPA proposal, which EPA included. First, we asked that the EPA reduce its proposed emissions fee (fee to EPA to pay for coatings with VOC content in excess of the standards) from $5000/ton to $2500/ton. Second, we requested that EPA include a small volume "exemption" for product lines below a certain size, e.g. 5,000 gallons/year. In this manner, the paint company would not need to spend $25,000 to reformulate a small product line, while the increased emissions resulting from the exemption would be insignificant.
The comment period will last until August 30. We intend to work with industry members, particularly smaller firms, to address the regulatory issues. I hope this information has been helpful to you.
Sincerely,
Jere W. Glover
Chief Counsel for Advocacy
* Last Modified: 6/14/01