Wed Sep 02 08:50:24 EDT 2015 Moritz.Brigette@epamail.epa.gov FW: Clean Wisconsin support for NRDC/NEWMOA TSCA mercury petition To: CMS.OEX@epamail.epa.gov

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From: Amber Meyer Smith [mailto:asmith@cleanwisconsin.org] Sent: Tuesday, September 01, 2015 6:10 PM To: Mccarthy, Gina Subject: Clean Wisconsin support for NRDC/NEWMOA TSCA mercury petition

Attached please find a letter of support from Clean Wisconsin for the NRDC/NEWMOA TSCA petition for rulemaking. Thank you for your consideration.

Amber Meyer Smith

Director of Programs and Government Relations

Clean Wisconsin

634 W. Main St, Suite 300

Madison, WI 53703

(608) 251-7020 ext. 16
asmith@cleanwisconsin.org634 W. Main Street #300
, Madison, WI 53703 608

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- 7020 | www.cleanwisconsin.org September 1, 2015

Gina McCarthy, Administrator (Mail Code 1101A) Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Re: NRDC/NEWMOA TSCA Petition for Rulemaking Dear Administrator McCarthy,

I write on behalf of Clean Wisconsin’s 30,000 members and supporters to support the June 24, 2015 petition of the Natural Resources Defense Council (NRDC) and the Northeast Waste Management Officials' Association (NEWMOA ) to issue a rule requiring companies which import, produce, or use mercury (or mercury compounds) in manufacturing processes to provide data regarding these activities. Collection of this data is important to establish the national mercury inventory that EPA promised almost ten years ago.

Clean Wisconsin has been working for years to prevent mercury from polluting our
environment . We continue to advocate for state

- level policies that advance protections from toxic mercury.

But those advancements are diffi cult when EPA still does not know how much is produced by the United States or imported each year, or how much is used and for what purposes. The only significant data on mercury use are currently compiled by NEWMOA, which manages the Interstate Mercury E ducation and Reduction Clearinghouse (IMERC).While that data is valuable it leaves us without a complete picture of mercury use in all states.

IMERC targets only mercury use in products, and thus does not collect data on mercury production or imports; or m ercury compounds manufactured or imported for use in industrial processes. Moreover, IMERC is no longer collecting data on most switches and relays, the largest mercury use in products, and its program contains other significant data gaps due to underrepo rting and non

- reporting.

The TSCA rule sought by the petition will fill these gaps, and produce needed information on questionable mercury uses, such as in children's products, building upon the data now collected by the State of Washington. And it will collect the data needed to inform US Government action under the Minamata Convention to phase

- down mercury use in polyurethane manufacturing,634 W. Main Street #300
, Madison, WI 53703 608

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- 7020 | www.cleanwisconsin.org identify large mercury stocks in storage or annually produced, and discourage new mercury uses in products or indu strial processes.

Until now, most mercury use data collection and regulatory activity has been undertaken by the IMERC states. The reporting rule requested by NRDC and NEWMOA is designed to coordinate with and complement the IMERC activities, and will the refore be both efficient and effective.

Clean Wisconsin urges EPA to grant the petition.

Sincerely,

Amber Meyer Smith Director of Programs and Government Relations Clean Wisconsin