The NPCA said it has developed a "form" letter for comments that association member companies can download from the NPCA website and submit to the EPA.
The NPCA said the rule, as proposed, will require coatings and resin manufacturers to install costly add-on air-pollution-control equipment to reduce emissions of hazardous air pollutants. The EPA has estimated that over the next 15 years, the regulation will cost the coatings-manufacturing industry $57 million in capital equipment and $16 million annually. The cost to the chemical industry to reduce emissions from resin-manufacturing processes is estimated at $122 million in capital expenditures and $75 million in annual expenditures. The NPCA said the EPA's cost estimates are believed to be conservative.
"Given the significant impact of the MON, the paint and coatings industry must do whatever it can to reduce the stringency of this rulemaking," the NPCA said. The association's MON Work Group is developing comments to submit to the EPA, but the association is also urging member companies to submit comments on their own as well.
The NPCA's form letter can be downloaded from the association website at www.paint.org/member/committee/emc.htm. More information is available from the NPCA's David Darling, e-mail firstname.lastname@example.org or Alison Keane, email@example.com; phone 202/462.6272.