Comment submitted by David F. Darling, Director, Environmental Affairs, National Paint & Coatings Association

In response to EPA’s recent decision to delay the effective date of the SPCC amendments, and its request for comments on the extension of the effective date and its duration, as well as on the regulatory amendments contained in the final rule please find attached the letter from NPCA to Susan Bodine dated October 9, 2008 and supported by 25 additional Industry Associations. While we have had EPA commitment in the past to work on this important issue, now that the recent rule has been finalized we would hope that EPA could now address the definition of oil issue. Finally, EPA has extended the effective date from February 3, 2009 to April 4, 2009 - we recommend that EPA at least maintain the current compliance date of November 20, 2009 or to avoid possible confusion over the delay in the effective date - extend the compliance date to January 1, 2010. Please let me know if you have any questions. Best regards, David F. Darling, P.E. Director, Environmental Affairs National Paint and Coatings Association Phone - 202-462-6272 Fax 202-462-8549