Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Comments on Maine's draft PFAS bill and Report to Legislature

ACA submitted comments to Vermont’s Department of Environmental Conservation (DEC), which is developing a draft PFAS bill and a report to the legislature. Maine's Act 131, Phase Out of PFAS Added Products, would establish a general prohibition of PFAS added products that will take effect six (6) months after one of the other Northeast states adopts similar legislation, affecting at least 10,000,000 people. ACA underscored the need for the definition of PFAS to be aligned with EPA’s definition under its TSCA Section 8(a)(7) reporting rule, with a structural definition based on compounds with two or more fluorinated carbon atoms.

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ACA, Coalition Support NO IRIS Act of 2024

ACA joined a coalition letter of support to Congressional sponsors of the “No Industrial Restrictions In Secret (NO IRIS) Act of 2024” (S. 3724/H.R. 7284). Increasingly, the Environmental Protection Agency’s Integrated Risk Information System program (IRIS) is being used to justify overly burdensome regulations on critical chemistries essential for everyday products. The NO IRIS Act would protect American manufacturing and ensure regulations are based on sound science.

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ACA Comments on Maine’s Reposted Draft Rule for Packaging Stewardship Program

ACA submitted comments to Maine's Department of Environmental Protection on the agency's reposted draft rule: Stewardship Program for Packaging. The department made changes to the draft rules based on the comments received in late 2023 and early 2024 and reposted them to allow for additional public comment. These draft rules provide details for implementing the Stewardship Program for Packaging that aims to reduce the burden on municipalities for managing packaging material.

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ACA Urges Senate Leadership to Include CFATS Reauthorization in NDAA

ACA joined several organizations in a letter to Senate leaders urging the inclusion of language from the Carper-Peters amendment in the National Defense Authorization Act (NDAA) for Fiscal Year 2024 (S. 4638), which reauthorizes the Chemical Facility Anti-Terrorism Standards (CFATS through October 1, 2026, into the substitute NDAA bill that will be filed soon.

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ACA Supports California SB 1143, PaintCare Expansion

The bill makes technical but important changes to California’s PaintCare architectural paint recovery program. Specifically, the proposed changes incorporate non-industrial coatings and coatings-related products as product categories that can be managed under the scope of California’s existing PaintCare program.

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