Comment from Jamie Dziczkowski

As a resin supplier, the proposed designation of intermediate categories for specific end use applicaitons is an attractive approach. As a leader in alkyd latex chemistry, a chemistry that combines the benefits of bibased materials with low VOC, it is a challenge to gain market share when we are not the end user of the products. The USDA BioPreferred program and labelling has added value to our customers choosing this procuct line over non-biobased materials. By designating categories for procurement in application areas where these products can be used in place of non-biobased materials, it is a great way to introduce biobased resins into new markets. It should be considered that limits of certain performance applications or compliance with federal specifications in some end use applications may not allow for the final product to contain 50% of the biobased material. This lower limit should be considered case by case. The proposed methodology for determining biobased content of products based on intermediates could use some additional requirements. Testing should still be required on these materials to ensure the biobased content is truly what is claimed. The testing fee for procurement is very inexpensive compared to other certification programs and the rules that are currently in place as far as changes in formulations and products similar to compostions that already have certification cuts down on multiple testing fees. Another alternative could be to develop simpler test methods based on NMR data/IR spectra to determine the amount of a specific biobased material in a complex mixture.