Comment submitted by Ken Zarker, Co-Chair, P2 and Intergrated Committee, National Pollution Prevention Roundtable (NPPR)

Thank you for the opportunity to submit comments on behalf to the National Pollution Prevention Roundtable's (NPPR) P2 Policy and Integration Committee. The NPPR supports the mission of the DfE program to promote the development and use of safer and high performing products. The NPPR encourages EPA to work with state and local goverments to promote teh SDSI program, including active participation in program development and implementation. State and local governments are interested in this initiative to support environmental preferrable purchsing programs. One potential use is to use SDSI to give preference for the purchase of nonylphenol-free products. Many states are working on green cleaning standards and this initiative will help support this effort. EPA should consider incentives to encourage states to enter into a MOA to establish a voluntary committment to phase out the use of these products by a target date, in partnership with manufactures, retailers, and users of these products. This approach could be adopted for state and local goverment operations, regional watersheds, or statewide. EPA should consider how this program impact the adoption of state water quality standards and if statewide adoption of SDSI would be given equalivalent credit. EPA HQ should coordinate with the regional office to provide staff and contractor support for program implementation. EPA should consider state funding opportunities to help implement the program, including the state Pollution Prevention Grant or Source Control Grant programs. EPA should consider how this program can be leveraged with other EPA voluntary programs like Performance Track and the Resource Conservation Challenge. Thank you for this opportunity to comment. Please include the NPPR on future stakeholder meetings. Contact Jeff Burke, NPPR Executive Director, at jeff@p2.org or 202-299-9701. I can be reached at kar461@ecy.wa.gov or 360-407-6724 if you have any questions. Sincerly, Ken Zarker, Co-chair P2 and Integration Committee National Pollution Prevention Roundtable