Comment submitted by Doug Raymond, National Aerosol Association (NAA)

David Sanders Office of Air Quality Planning & Standards Research Triangle Park, NC 27711 Subject: VOC Exemption for HFO 1234ze Attention: Docket ID No. EPA-HQ-OAR-2010-0605 The National Aerosol Association (NAA) appreciates the opportunity to comment on the VOC status of HFO-1234ze. The information on HFO-1234ze demonstrates that the compound is negligibly reactive with respect to its contribution to tropospheric ozone formation. NAA supports the request for compound HFO-1234ze (CAS 29118-24-9) to be exempted from VOC control, based on its low reactivity relative to ethane. In addition HFO-1234ze exhibits no ozone depletion, low global warming potential, is non-flammable and has low toxicity risks. NAA supports the exemption of this propellant for use in aerosols. This propellant will be another tool that aerosol manufacturers can use to formulate their products. Each compound that is exempt provides our members further tools to create the best possible products for the consumer. In conclusion, the NAA supports the HFO-1234ze VOC exemption. Any questions or comments please feel free to contact me at djraymond@reg-resources.com or at 440-474-4999. On behalf of the NAA Doug Raymond