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Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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鶹ƵSeeks Congressional Action on Miscellaneous Tariff Bill

The Miscellaneous Tariff Bill will temporarily eliminate and reduce border taxes on a set of products that have been found through a transparent and rigorous process at the U.S. International Trade Commission to not to be produced at all or in sufficient capacity in the United States. Many raw materials used in paint and coatings formulas are produced solely outside of the United States.

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鶹ƵUrges Senate Action on Miscellaneous Tariff Bill

The Miscellaneous Tariff Bill will temporarily eliminate and reduce border taxes on a set of products that have been found through a transparent and rigorous process at the U.S. International Trade Commission to not to be produced at all or in sufficient capacity in the United States. Many raw materials used in paint and coatings formulas are produced solely outside of the United States.

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鶹ƵComments to OMB on BABA Guidance for Grants and Agreements

On March 13, 鶹Ƶsubmitted comments to the White House Office of Management and Budget on its proposed Guidance for Grants and Agreements supporting the implementation of the Build America, Buy America Act (BABA) provisions of the Infrastructure Investment and Jobs Act. 鶹Ƶcomments focused on paints and coatings as construction materials.

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Opposition to Minnesota HF-1000

On March 3, 鶹Ƶjoined a coalition letter in opposition to Minnesota HF 1000, legislation that would impose broad reporting requirements on manufacturers of all products containing PFAS sold in Minnesota; ban the sale of products containing PFAS in a variety of product categories; and establish a future regulatory scheme to ban additional product categories containing PFAS.

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Opposition to Minnesota SF 834

鶹Ƶjoined a coalition letter opposing Minnesota legislation, SF 834, which would impose broad reporting requirements on manufacturers of all products containing PFAS sold in Minnesota; ban the sale of products containing PFAS in a variety of product categories; and establish a future regulatory scheme to ban additional product categories containing PFAS.

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Opposition Letter to Congress on FTC's Non-Compete Proposal

On Feb. 28, 鶹Ƶjoined a long list of organizations in a letter to Congress oppose the Federal Trade Commission’s (FTC) proposed rule to impose a nationwide ban on almost all noncompete clauses. The letter seeks Congressional oversight and close examination of the FTC’s proposed rulemaking.

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鶹ƵComments on Washington Senate Bill 5369

On Feb. 17, 鶹Ƶsubmitted written comments to the Washington State Senate Ways and Means Committee, in advance of a hearing on Senate Bill 5369, reassessing standards for polychlorinated biphenyls in consumer products.

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鶹ƵUrges Greater Airport Infrastructure Funding

As part of the Beyond the Runway coalition, 鶹Ƶurged Congress to prioritize additional airport infrastructure funding in the upcoming FAA reauthorization bill in a recent letter to leaders of the House Committee on Transportation & Infrastructure.

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鶹ƵComments on PFAS TRI Reporting

On Feb. 3, 鶹Ƶsubmitted comments to U.S. EPA on proposed changes to PFAS reporting in the Toxics Release Inventory (TRI) and supplier notification requirements. 鶹Ƶis concerned that listing the specified 189 PFAS chemicals as chemicals of special concern with no de minimis reporting threshold is beyond scope contemplated in EPCRA and authorization for listing in the 2020 National Defense Authorization Act.

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Comments on Washington State Bills for PCBs in Consumer Products

鶹Ƶsubmitted written comments to the Washington State Legislature at it considers a measure to reassess standards for polychlorinated biphenyls in consumer products. “鶹Ƶsupports further analysis of significant contributors to PCB contamination in Washington, but requests that paint is removed from the scope of SB 5369/HB 1314. Regulation of paint, with trace levels of inadvertent PCBs, will not significantly decrease the amount of PCB contamination in the Spokane River and other waterways in Washington or in the environment generally.”

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