Mr. Alex Ryan-Bond

Page 1

April 30, 2011

April 30, 2011

Mr. Alex Ryan-Bond

Environmental Associate

Ozone Transport Commission

444 N. Capitol Street, NW

Suite 638

Washington, DC 20001

Dear Mr. Ryan-Bond,

Thank you for the opportunity to further respond to the proposed changes to OTC Model Rule for Solvent Cleaning. Below, I will raise two additional issues that were not covered in my original comments; the database used by the OTC as it relates to open top vapor degreasers, and the proposed exemption from the regulation for a small number of specific industries.

Related to the database, it is our understanding thatthe OTC used California’s 2003 – 2004 data to determine the number of vapor degreasers in the Northeast in 2011. It is our understanding that a ratio was developed between the number of degreasers in the California region and the population of the area at that time. If the time and resources were available, we would have liked to have investigated the means by which Californiaestablished their numbers. We would hope that the numbers were the result of an extensive collection of data, as opposed to being based on yet another set of numbers from another region atan even earlier time.Assuming that the datareflecting the number of degreasers in Southern California in 2003 was accurate at that time however, we question the viability of a statistical relationship between the number of operational vapor degreasers in a given area and the number of people residing in thatarea.

However, if we temporarily accept the original California data as being accurate, we are still confronted with the fact that the new regulation will be based on the business climate that was present 8 years ago and three thousand miles from the area it will regulate. Having witnessed a major decline in the U.S. manufacturing industry during that time, we see no reason to believe that those numbers reflect today’s reality in the Northeast.

Given that degreaser operators are required to acquirepermits and submit records that report solvent usage, we would expect that the emission estimates being used to institute such arestrictive regulation would be based on the actual emissions reported by the actual permit-holders in the actual states where this regulation will take effect. We would also expect the commission to use the most recent year for which this information was available. Any other approach would seem togenerate the proverbial ‘garbage-in/garbage-out’ scenario, and frankly, the effects of this regulation are far to reaching to acquiesce to that possibility.

To our second point, we view the granting of exemptions to specific industries as a tacit acknowledgement thatin some manufacturing processes, the use of a vapor degreaser presents the only means by which to attain an acceptable level of cleaning. The fact is, many non-exempt industries have similar requirements and challenges. That being the case, we question the logic, if not the constitutionality, of forcing certain industries to comply with the new regulation while exempting others from it. If specific industries are to be exempted while others are forced to comply, we would appreciatea clear statement related to the criteria the commission uses to justify exemptions.

I have no doubt that the industries that were exempted in the California regulation must produce parts that are clean and completely free of residue. But as stated above, many other industries have similar requirements. Why then, were only certain industries exempted from the California regulation? Perhapsthe California regulators understood that many of the companies covered by this regulation would either shut down or leave the state, and perhaps the industries they exempted were those they most feared losing.We can find no other logical explanation for theexemption of the motion picture film industry from the California regulation.

Additionally, we believe that providing regulatory agencies with the authority to grant exemptions on a case-by-case basissimply opens the door to potential political manipulation at local levels.

If a reduction in VOC emissions is absolutely necessary at this precarious time in our economic history, we request that you begin your analysis by usingviable data on which to base the changes. If the analysis of the actual data results in the need to tighten regulations on the use of VOC’s in vapor degreasers, the new regulation must present a fair and logical approach to VOC reduction. It should account for the vapor pressure of the solvents in questionrather than simply banning the use of all solvents with a specific VOC content. It should alsobe based on the actual amountof VOC that is presently being generated by vapor degreaser emissionsin the region covered by the regulation, rather than on questionable 8-year-old data from 3,000 miles away.

The new regulation should not penalize some industries while exempting others, and it should offer the open top degreaser operator some options by which to comply; perhaps with improved control systems or by further isolating the atmosphere from the opening of the machine.

Finally, please note that the manufacturers in this region who have survived the latest economic downturn have been forced to overcome some major obstacles over the last several years. Many of them are barely surviving and are one additional obstacle away from dismissing their employees and closing their operation. When considering the new regulation, we request that you weigh the potential benefit against the economic hardship it will place on these manufacturers andon the labor force they employ.

Thank you again for the opportunity to comment.

Sincerely,

Greco Brothers, Inc.

Ralph M. Greco, Jr.

President