RCMA GOVERNMENT AFFAIRS COMMITTEE

Transcription

1 RCMA GOVERNMENT AFFAIRS COMMITTEE Greg Johnson, Sherwin Williams Will Lorenz, General Coatings Monday, February 15, 2016 #WeAreRCMA

2 FEDERAL GOVERNMENT AFFAIRS - National Ozone Standard, 70 ppb

3 RCMA Government Affairs Strategy Next Steps Regulatory and Congressional Outreach Implementation & Revision of the Clean Air Act (CAA) Education! Team up with Coalitions and Industry Groups (the NAM, ACC, etc.)

4 RCMA Government Affairs Strategy Congressional Bills Early Action Compact (EAC) Ozone Bill Senators Hatch (R-UT) and McCaskill (D-MO) - bipartisan bill that will implement an EPA program to have state and local districts develop EAC plans. Ozone National Ambient Air Quality Standard Deadline Harmonization Act Representative Flores (R-TX) - bill that seeks a realistic timeline to implement the 2015 standard and harmonize 2008 & 2015 standards. Clean Air Implementation Act Reps. Pete Olson (R-TX), Bob Latta (R-OH), Ann Kirkpatrick (D-AZ), and Henry Cuellar (D-TX) - bipartisan legislation that will update EPA s ozone requirements in the CAA by suspending 2015 NAAQS, extending review from 5 to 8 years, and adding technological feasibility considerations.

5 RCMA Government Affairs Strategy Senate Energy Policy Modernization Bill Ozone Amendments Included: Harmonize requirements of the 2008 and 2015 air quality standards (Flores Bill). Delay EPA from using 2015 final rule until improvements made (CASE Act). Repeal or amend the rule before issuing the next rule (Olson Bill). Protect consumers by prohibiting EPA s Administrator from promoting energy-related rules that have adverse economic consequences. Require a EPA Administrator to prepare report re: expected ozone environmental impacts and economic costs of final rule.

6 How You Can Help Build or Keep Relationships with Congressional Allies Host Site Visits in Plant Locations Tell Us Your Stories!

7 RCMA Congressional Ozone Allies Senators Boozman (R-AR) Cassidy (R-LA) Heller (R-NV) Hatch (R-UT) Inhofe (R-OK) Donnelly (D-IN) McCaskill (D-MO) Representatives Latta (R-OH) Flores (R-TX) Olson (R-TX) Whitfield (R-KY)

8 #WeAreRCMA EPA TEST METHOD 24

9 EPA Method 24 Industry Concerns Members identified inconsistencies such as error determinations and content variations in products at lower-voc content levels using Method 24. By switching to more water-based formulations, members observed a difference in the Method 24 VOC content reporting, and the actual VOC formulation contents. Appears that Method 24 penalizes environmental innovations, such water and encourages exempt solvents in coatings.

10 EPA Method 24 Timeline September 21, 2015: RCMA meeting letter request to the EPA October 19, 2015: Teleconference meeting with EPA s Lead Test Scientific Researcher November 19, 2015: Second teleconference with Lead Researcher January 26, 2016: Third teleconference with Rule Writer for Architectural Coatings VOC Emission Standards to amend national rule March 4, 2016: Scheduled teleconference with Rule Writer and Policy Assistant on revising the rule

11 QUESTIONS #WeAreRCMA

12 STATE GOVERNMENT AFFAIRS - SCAQMD and CARB 2007 SCM (SMAQMD and San Diego)

13 South Coast Air Quality Management District (SCAQMD)

14 SCAQMD Rule 1113 Feb 5: SCAQMD Governing Board approved adoption of proposed amendments (passed 7-6). Picture via Citizendium.com

15 SCAQMD Overview Rule 1113 Updates to the Proposed Rule: Amendments adopted in February 5, 2016, implemented 2018/2019. Roof Coatings at 50 g/l Aluminum Roof Coatings at 100 g/l Bituminous Roof Primers at 350 g/l TBAC industrial maintenance exemption pending OEHHA

16 SCAQMD Overview Rule 1113 Updates to the Proposed Rule: Small Container Exemption (SCE): Flats, Non-flats and Rust Preventatives Includes two year sell-through period Two test methods added: ASTM D6886 Resolution to have Method 313 finalized with roundrobin, exclusionary pathway, and non-film forming oil concerns

17 SCAQMD Filing Requirements Manufacturer reports of sales data are due May 30 each year as stated in Section (i) of Rule 314: (i) Fee Payments and Late Surcharge (1) Fee payments are the responsibility of the manufacturer. (2) If both the fee payments and the Annual Quantity and Emissions Report for the previous calendar year are not received by May 30, they shall be considered late; and a surcharge for late payment shall be imposed for fees past due as set forth in paragraph (i)(3). Architectural coatings manufacturers subject to paragraph (d)(2) on or after July 1 of the reporting year shall have an additional 6 months to submit the fee payments and the Annual Quantity and Emissions Report for the acquired architectural coatings manufacturer.

18 SCAQMD Filing Requirements However, relative to submission of distributor lists to whom coating manufacturers supply architectural coatings, those should have been received by January 31 as stated in section (o) of Rule 314: (o) Distributor(s) List On or before January 31 st, all architectural coatings manufacturers subject to this rule shall provide to the District a list of all U.S. distributors to whom they supply architectural coatings. (1) Once the initial list of all U.S. distributors has been submitted, the architectural coatings manufacturer shall provide any changes to that list for subsequent reporting years. (2) If there are no changes to the list of all U.S. distributor(s), the architectural coatings manufacturer in subsequent reporting years shall report no changes.

19 California Air Resources Board 2007 SCM Rule Overview

20 Current California AIM Coatings Regulations

21 Current California AIM Coatings Regulations San Diego - effective January 1, 2016 Sacramento - effective March 24, 2016 Roof Coatings, 50 g/l Bituminous Roof Primers, 350 g/l Industrial Maintenance Coatings, 250 g/l

22 Ozone Transport Commission (OTC) Phase II

23 OTC Phase II Model Rule Overview In 2010, the Ozone Transport Commission adopted the OTC Phase II Model Rule, following the 2002 Phase I States moving towards Phase II are Maryland, Delaware, DC Proposing SIP Voluntary Credits to use Nationally

24 OTC Phase II Model Rule Adoption Maryland - COMAR Proposed rule released in September 21, Public hearing in February 22, Effective date is January 1, 2017 Delaware Second to Adopt Phase II - Proposed rule released on January 15, Finalized February 1, Effective date is February 21, 2016 Roof Coatings 250 g/l Bituminous Roof Coatings 300 g/l Bituminous Roof Primers 350 g/l

25 QUESTIONS

26 GHS/ HAZCOM TASK FORCE UPDATE #WeAreRCMA

27 GHS/HazCom Timeline April 2015: Met with OSHA and DOT June 2015: GHS/HazCom Task Force created RCMA Reference Document For Labeling Clarification. July 2015: OSHA and GHS Representatives spoke to members at RCMA Summer Meeting. September 2015: Industry response letter that cited inconsistencies with compliance timeline, cost considerations, further guidance on Flammable 3 category, push back compliance date from Dec 1 to June 1, February 2016: OSHA and DOT publish joint guidance document.

28 RCMA Advocacy Considerations #WeAreRCMA

29 California Advocacy Project Update RCMA is considering a California PAC or Issue Advocacy Fund. The Board of Directors voted in June 2015 Results showed (11-3) in favor to do something. Split on PAC or Issue Advocacy Fund (4-5) To help flesh out the options, RCMA circulated an advocacy fund / PAC management RFP to Washington, DC and California based firms. RCMA collected proposals by October 23, Board reviewed and created smaller Working Group to narrow down to 3 options. Firms will present proposals with Board within next month.

30 FURTHER QUESTIONS?