ENVIRONMENTAL PROTECTION AGENCY HEARING

Proposed Rule, National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride and Copolymers Products as published in the Federal Register on May 201, 2011

Testimony Presented by:

C. Dean Thompson, President Resilient Floor Covering Institute 115 Broad Street, Suite 201 LaGrange GA 30240 (706) 882

- 3928 dean.thompson@rfci.com JUNE 9, 2011

Good morning. My name is Dean Thompson and I am here today in my capacity as President of the
Resilie nt Floor Covering Institute, a non

- profit trade organization that represents the North American Resilient Flooring Industry.

I want to thank the EPA for the opportunity to provide my testimony at this important hearing.

Just to clarify, the resilient fl ooring category includes hard

- surface flooring products that are constructed to have varying degrees of resiliency, hence the name resilient flooring. Specific products include vinyl sheet, vinyl composition tile, luxury vinyl tiles and planks, rubber shee t

, rubber tile, and
linoleum flooring. Stone, ceramic, wood, and terrazzo are not included in the resilient flooring category.

Approximately 90% of the resilient flooring sold in North American contains PVC. The amount of PVC depends on the product typ e, but by weight , the estimated range is between 10% and 50%. Based on product mix, we estimate the industry PVC content average to be in the 20% to 25% range by weight of the product

.

The popularity of resilient flooring has increased significantly ove r the past decade. In 2000, the market share for resilient flooring compared to all flooring categories including carpet was 13.7%

. I n 2010 the estimated market share for resilient flooring was 18.8%. Consumers and specifiers are selecting vinyl flooring at the expense of other flooring categories.

The market is demanding vinyl flooring because of its important benefits including long

- lasting performance, sustainability, safety, value, and aesthetics. Health care, education, and government are key comme rcial market segments for vinyl flooring. Ease of maintenance, cleanliness, and minimizing bacterial and pathogen presence are especially important benefits for health care and schools.

Over 50% of the resilient flooring sold in North America is used in residential environments. New technologies for improved aesthetic realism, lower cost installation, and overall value are making vinyl flooring the product of choice for consumers.

Significant industry investment is a strong indicator of the growing p opularity of PVC flooring. In May of this year, IVC US, opened a new $73 million state

- of

- the art facility in Dalton, Georgia that is producing exclusively PVC flooring products.As directed by Federal Executive Order 13514, government agencies are inc reasing their procurement of

environmentally preferable products

. The generally accepted environmental hierarchy is reduce, reuse, and recycle. The long

- lasting performance of PVC flooring significantly impacts reduced consumption, the most important ele ment of the environmental hierarchy. It is very common for PVC flooring to provide well over 15 years of very useful life before replacement. In addition, resilient flooring manufacturers are actively recycling resilient flooring products.

In today’s economy, consumers, specifiers, and purchasers are increasingly searching for products that provide the very best value: products that look good, are easy to maintain, that last a long time and are very affordable. In terms of average value per square foo t sold, data from 2009 shows resilient flooring at 64 cents per square foot to be the lowest, followed by square foot values sold of carpet and area rugs at $.88, ceramic tile at $1.00, laminate flooring at $1.00, wood flooring at $2.30, and stone floori ng at $3.98.

The facts show that the market has clearly spoken in favor of PVC flooring products. We urge EPA to adopt reasonable requirements for the updated NESHAP to avoid any unwarranted economic costs on PVC producers that would adversely affect the economical use of PVC in resilient flooring.

Thank you.