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Letters & Comments

Read ³Ô¹ÏºÚÁÏÍø’s letters and comments submitted to regulatory bodies and elected officials.
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³Ô¹ÏºÚÁÏÍø Submits Comments to the Minnesota Pollution Control Agency

³Ô¹ÏºÚÁÏÍø submitted comments to the Minnesota Pollution Control Agency (MPCA) regarding the agency’s development of new rules governing implementation of the Packaging Waste and Cost Reduction Act (PWCRA). In its comments, ³Ô¹ÏºÚÁÏÍø urged the agency to clarify that the definition under § 115A.1441(16)(12) of the PWCRA refers to packaging for products subject to the state’s PaintCare program.

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³Ô¹ÏºÚÁÏÍø Comments on Washington State Recycling Reform Rulemaking

³Ô¹ÏºÚÁÏÍø submitted comments to the Washington State Department of Ecology regarding the agency’s proposal to adopt new regulations related to recycling. In its comments, ³Ô¹ÏºÚÁÏÍø recommended that section 173-950-030 of the Proposed Regulations be revised to provide that the term ‘covered material’ does not include any secondary and tertiary packaging associated with products subject to Washington’s paint stewardship program. This modification would reduce additional burdens for manufacturers’ compliance efforts with Washington's Recycling Reform Act and other states’ existing packaging and paint stewardship programs.

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³Ô¹ÏºÚÁÏÍø Submits Comments to New York Senate Finance Committee

³Ô¹ÏºÚÁÏÍø submitted comments to the New York Senate Finance Committee on Senate Bill 1464A, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. In its comments, ³Ô¹ÏºÚÁÏÍø urged the committee to amend the definition of ‘packaging material,’ ‘packaging,’ or ‘covered material,’ to clarify that packaging for products subject to a post-consumer paint program under N.Y. Env’t Conserv. Law § 27-20 are not included under S1464A.

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³Ô¹ÏºÚÁÏÍø Supports Amended 21st Century ROAD to Housing Act

³Ô¹ÏºÚÁÏÍø strongly supports the comprehensive housing legislative package currently under consideration by Congress. In a letter to Congressional leaders, ³Ô¹ÏºÚÁÏÍø underscored the need for expanding and preserving the country’s housing supply, improving housing affordability, and driving job growth, and urged Congress pass the amended 21st Century ROAD to Housing Act.

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³Ô¹ÏºÚÁÏÍø Joins Coalition Comments on EPA’s RMP Proposal

³Ô¹ÏºÚÁÏÍø joined a coalition of organizations in comments submitted to the U.S. Environmental Protection Agency (EPA) on its proposal related to the Risk Management Programs (RMP). The comments, which address the agency’s accidental release prevention requirements under the RMP, underscore that any final rule stemming from EPA’s proposal should be fully consistent with statutory authority; supported by the administrative record; and structured to preserve the effectiveness of the performance-based RMP framework.

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³Ô¹ÏºÚÁÏÍø Comments on New York Senate Bill 1464A

³Ô¹ÏºÚÁÏÍø submitted comments to the New York Senate's Environmental Conservation Committee on Senate Bill 1464A, An Act to Amend the Environmental Conservation Law, in Relation to Enacting the Packaging Reduction and Recycling Infrastructure Act. In its comments, ³Ô¹ÏºÚÁÏÍø urged the committee to amend the definition of ‘packaging material,’ ‘packaging,’ or ‘covered material,’ to clarify that packaging for products subject to a post-consumer paint program under N.Y. Env’t Conserv. Law § 27-20 are not included under S1464A.

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³Ô¹ÏºÚÁÏÍø, AAI Coalition Support Congressional Efforts for TSCA Improvements

³Ô¹ÏºÚÁÏÍø joined the American Alliance for Innovation (AAI) letter to members of Congress expressing support for efforts to improve the Toxic Substances Control Act (TSCA). The letter signed by more than 100 organizations lauded Congressional committee work to enhance TSCA to ensure a chemical regulatory program at U.S. EPA is properly resourced, does not impede or create unnecessary barriers to technological innovation while avoiding unreasonable risks of injury, and supports growth in the manufacturing sector.

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³Ô¹ÏºÚÁÏÍø Comments on Maryland's Proposed Packaging Regulations

³Ô¹ÏºÚÁÏÍø submitted comments to the Maryland Department of Environment (MDE) on the agency's proposed Producer Responsibility Packaging and Paper Products Regulations. ³Ô¹ÏºÚÁÏÍø urged MDE to define ‘de minimis producer’ as an individual that, in the most recent fiscal year, has generated less than a total gross revenue of $5,000,000. ³Ô¹ÏºÚÁÏÍø also sought clear exemptions under the regulations for all primary, secondary, and tertiary packaging associated with products subject to Maryland’s paint stewardship program.

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³Ô¹ÏºÚÁÏÍø Supports USMCA Extension in Letter to Senate Leaders

In a letter to leaders of the U.S. Senate Committee on Finance, ³Ô¹ÏºÚÁÏÍø expressed strong support for the U.S.-Mexico-Canada Agreement (USMCA), as Canada and Mexico are the two largest trading partners for the U.S. coatings industry. ³Ô¹ÏºÚÁÏÍø urged extension of the agreement for 10 to 16 years and that the United States focus on continued implementation of the USMCA during the Joint Review effort rather than a broad renegotiation of its elements, underscoring that preservation of the USMCA's key tax and tariff provisions are paramount.

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³Ô¹ÏºÚÁÏÍø Comments on CARB's Proposed Regs for Climate Disclosure

³Ô¹ÏºÚÁÏÍø submitted comments to California's Air Resources Board on the agency’s Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation for the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). ³Ô¹ÏºÚÁÏÍø underscored in its comments that businesses in the paint and coatings industry should be exempt from the reporting requirements of SB 253 and SB 261, since they are already subject to a plethora of reporting requirements in air quality and toxics regulations in the state.

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