Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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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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ACA Responds to EPA’s Request on Unpublished Health and Safety Studies

EPA is proposing to add 16 chemical substances to lists at 40 CFR 716.120, triggering a reporting requirement within 90 days of finalizing the rule. Chemical substances include those undergoing prioritization and chemicals that EPA may select for future prioritization. Manufacturers and importers would be required to submit health and safety studies “known to” them or lists of studies where appropriate, including studies describing physical characteristics, environmental degradation, general population monitoring, etc.

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ACA Submits Comments to USGBC on LEED v5

This letter consolidates ACA’s comments to U.S. Green Building Council (USGBC) on LEED v5, which is the newest version of LEED. LEED (Leadership in Energy and Environmental Design) is the world's most widely used green building rating system and is globally recognized as such.

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ACA Comments on FHWA Proposed Rulemaking Related to BABA

ACA submitted comments to the Federal Highway Administration's (FHWA) proposed rule to discontinue the general waiver of Buy America requirements for manufactured products and require FHWA recipients to apply Buy America requirements to manufactured products. ACA urged the agency to continue to operate under the General Waiver of Buy America requirements for manufactured products as it has since 1983, and not apply BABA requirements to manufactured products at this time.

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