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Letters & Comments

Read ³Ô¹ÏºÚÁÏÍø’s letters and comments submitted to regulatory bodies and elected officials.
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Coalition Letter to House Judiciary to Support Invalidation of FTC Premerger Notification Rules

³Ô¹ÏºÚÁÏÍø joined a coalition of organizations in a letter sent to the House Judiciary Committee supporting the use of the Congressional Review Act (CRA) to overturn the Federal Trade Commission's (FTC) recent premerger notification rules. These rules have been challenged in court for violating the Administrative Procedures Act as being unnecessary and overly burdensome.

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³Ô¹ÏºÚÁÏÍø, Coalition Oppose New Mexico HB 212

³Ô¹ÏºÚÁÏÍø joined a coalition letter in opposition to a New Mexico bill, HB 212, which would create a sweeping and complex new regulatory program to regulate all commercial and consumer products, as well as any industrial manufacturing processes that may use perfluoroalkyl and polyfluoroalkyl (PFAS) substances.

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³Ô¹ÏºÚÁÏÍø, Coalition Seek Meeting with EPA Administrator to Discuss Amendments RMP Rule

³Ô¹ÏºÚÁÏÍø and 15 other organizations sent a letter to new EPA Administrator Lee Zeldin requesting a meeting to discuss the recent amendments to the Risk Management Program (RMP) rule. Some RMP rule requirement are already in effect while others go into effect in May 2027. Since 2017, the RMP requirements have been in flux based on the changing presidential administrations. The coalition seeks to work with U.S. EPA to develop a lasting process that will address safety concerns with the final RMP Rule amendments.

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³Ô¹ÏºÚÁÏÍø Comments to Green Seal on PFAS in GS-11 Standard for Paints, Coatings, Stains and Sealers

³Ô¹ÏºÚÁÏÍø submitted comments to Green Seal on the organization's proposed changes to GS-11 related to per- and polyfluoroalkyl substances (PFAS) in paints, coatings, stains and sealers. In its comments, ³Ô¹ÏºÚÁÏÍø noted that the proposed changes to GS-11 do not accurately reflect the marketplace for PFAS in coatings, nor are they indicative of environmental or human health impact of coatings with fluorinated chemistries.

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³Ô¹ÏºÚÁÏÍø Submits Comments on LEED v5, Second Round

³Ô¹ÏºÚÁÏÍø submitted a second round of comments to U.S. Green Building Council (USGBC) on the Leadership in Energy and Environmental Design (LEED) v5. The LEED system is the most widely-recognized and widely-used green building system in the world. Earlier in 2024, USGBC released the first draft version of the LEED v5 rating systems for public comment.

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³Ô¹ÏºÚÁÏÍø Comments on Maine's draft PFAS bill and Report to Legislature

³Ô¹ÏºÚÁÏÍø submitted comments to Vermont’s Department of Environmental Conservation (DEC), which is developing a draft PFAS bill and a report to the legislature. Maine's Act 131, Phase Out of PFAS Added Products, would establish a general prohibition of PFAS added products that will take effect six (6) months after one of the other Northeast states adopts similar legislation, affecting at least 10,000,000 people. ³Ô¹ÏºÚÁÏÍø underscored the need for the definition of PFAS to be aligned with EPA’s definition under its TSCA Section 8(a)(7) reporting rule, with a structural definition based on compounds with two or more fluorinated carbon atoms.

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