Fri Aug 28 15:21:40 EDT 2015 Leavy.Jacqueline@epamail.epa.gov FW: NRDC/NEWMOA TSCA Petition for Rulemaking To: CMS.OEX@epamail.epa.gov

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From: Susan Eastwood [mailto:seastwood@cleanwater.org] Sent: Friday, August 28, 2015 3:12 PM To: Mccarthy, Gina Cc: Jones, Jim Subject: NRDC/NEWMOA TSCA Petition for Rulemaking

Dear Administrator McCarthy,

Please accept the attached letter , signed by numerous Connecticut organizations representing thousands of CT citizens, in support of the NRDC/NEWMOA TSCA Petition for Rulemaking on mercury.

Thank you, Susan Eastwood

_____________________________________ Susan Eastwood Director of Communications and Outreach Coalition for a Safe and Healthy Connecticut Clean Water Action www.cleanwateraction.org www.safehealthyct.org 2074 Park Street, Suite 308 Hartford, CT 06106 W: (860)232-6232; C: (860)428-5304

This message (including any attachments) is intended only for the use of the person(s) to whom it is addressed, and may contain information that is privileged, confidential, and exempt from disclosure under applicable law. If you receive this message in error, please notify me immediately by email, telephone, or fax, and delete the original message from your records. Thank you.Phone 860-232- 6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT August 26 , 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, We, the undersigned, representing thousands of members and citizens across Connecticut who care deeply about public health, wildlife and the environment , strongly urge your support of 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. These data will become the national mercury inventory that EPA promised almost ten years ago. Mercury, of course, is a powerful neurotoxin but EPA does not know how much is produced by the United States or imported each y ear, 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 Education and Reduction Clearinghouse (IMERC). IMERC targets only mercury use in products, and thus does not collect data on mercury production or imports ; or mercury compounds manufactured or imported for use in industrial process es. 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 underreporting 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, identify large mercury stocks in storage or annually produced, and discourage new mercury uses in products or industrial 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 therefore be both efficient and effective. We urge EPA to grant the petition.

Sincerely, Coalition for a Safe and Healthy CT Connecticut Clean Water ActionPhone 860-232- 6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT Anne Hulick , CT State Director

Connecticut Citizen Action Group Tom Swan, Executive Director

Connecticut Coalition for Environmental Justice Sharon Lewis, Executive Director

Connecticut Nurses’ Association Kimberly A. Sandor, MSN, FNP, RN, Executive Director

Connecticut Public Interest Research Group Evan Preston, Executive Director

Citizens’ Campaign for the Environment Louis Burch, Program Director

Ashford Clean Energy Task Force Susan Eastwood, Chair Janet Bellamy, Treasurer

ConnFact , (CT Families Against Chemical Trespass) Beth Beisel Tara Cook Littman Christine O'Day

New Haven Environmental Justice Network Lynne Bonnett

Rivers Alliance of CT Margaret Miner, Executive Director

Sierra Club Connecticut Chapter John Calandrelli, State Program DirectorPhone 860-232- 6232 | ahulick@cleanwater.org

www.CleanWaterAction.org/CT The Watershed Partnership, Inc. Jerry Silbert , M.D., Executive Director

Toxics Action Center Sylvia Broude , Executive Director