### CondenseIt! ""`

1 STATE OF MAINE 2 BOARD OF ENVIRONMENTAL PROTECTION 3 4 5 6********************* IN RE : CHAPTER 152 : CONTROL OF 7 VOLATILE ORGANIC COMPOUNDS 8 FROM

CONSUMER PRODUCTS ********************* 10 11 , 

### Page 1

12 PRESIDING OFFICER : VIRGINIA PLUMMER, CHAIRWOMAN 13
14 This hearing was held pursuant to Notice at the 15 Holiday Inn, Civic Center Drive, Augusta, Maine, 16 on August 2, 2007, beginning at 9:00 a.m

. 17 18 19 20 21 22 23 24 25

1 2 3 4 5 

### *****
6 HEARING EXAMINER: Good morning, 

### 7 everyone, and we're going to do, again, an agenda 8 a little differently today

. We're going to start 9 with a public hearing and then we will go into a 10 discussion of the Androscoggin river appeals and 11 then we'll have our regular consent agenda -- our 12 regular agenda items

. 13 My name is Ginny Plummer of the Board of 14 Environmental Protection, and we are holding a 15 public hearing today on the proposed Department of 16 Environmental Protection amendments to Chapter 17 152, Control of Volatile Organic Compounds from 18 Consumer Products

. I will be the presiding 19 officer for today's hearing and other members here 20 today are to my far right Ernie Hilton from Starks 21 and next to him is Nancy Anderson from Cumberland 22 Foreside, Elizabeth Ehrenfeld from Falmouth, 23 Richard Gould from Greenville and Don Guimond from 24 Fort Kent, and then Board Member Sue Lessard from 25 Hampden, Nancy Ziegler from South Portland and



# 1) ORIGINAL

Page 2 (This hearing was held before the Board of Environmental Protection, Holiday Inn, Civic Center Drive, Augusta, Maine, on August 2, 2007, beginning at 9:00 a.m

.) Page 3 1 Matt Scott fromBelgrade, and to my right is Peggy 2 Bensinger, our assistant attorney general, and to 3 my left is Cindy Bertocci, the executive analyst, 4 and seated next to Matt is our administrative 5 assistant, Terry Hanson

. Our recorder today is 6 Joanne Alley of Alley & Morrisette Recording 7 Services

. Also present are Jeff Crawford and 8 Andrea Lani and Ron Severance of the Department 9 staff

. 10 Today's hearing is being held pursuant to 38 11 M .R.S .A., section 585, 585-A and Public Law 12 Chapter 384, Section 14

. In addition, because 13 these amendments will be submitted as a revision 14 of Maine's State Implementation Plan for Air 15 Quality, today's hearing will be conducted 16 pursuant to the requirements of Title 40, Part 51 17 of the Code of Federal Regulations

. Notice of 18 today's hearing was published in the Kennebec 19 Journal on July 2nd, 2007 and in the Kennebec 20 Journal, Lewiston Daily Sun, Waterville Morning 21 Sentinel, Portland Press Herald and Bangor Daily 22 News on July 11, 2007

. Notice of today's hearing 23 was also sent to all persons on the Department's 24 regulatory notice mailing list, all licensed air 

### 25 emission sources and to others who have expressed Page 4 1 interest in the rules that are the subject of 2 today's hearing

. The record for written comments 3 shall remain open until 5 p .m

. on August 13th, 4 2007

. All written testimony should be addressed 5 to the Bureau of Air Quality and clearly marked 6 for inclusion in the August 2nd, 2007 Chapter 152 7 public hearing record

. Today's hearing will be 8 transcribed and made available to all Board 9 members

. Based on the complete record, the Board 10 will vote to approve, deny or amend the proposed 11 amendments at a regularly-scheduled Board 12 meeting

. Copies of the final staff recommendation 13 will be available upon request before the rule is 14 presented for adoption

. An attendance sheet is 15 presently circulating the room

. Please indicate 16 on the sheet if you wish to receive a copy of the 17 draft final rules

. Following adoption of these 18 rules, the Department will prepare a formal 19 submittal to the U .S

. Environmental Protection 20 Agency for inclusion in the State Implementation 21 Plan

. 

### 22 At this time I would ask all persons who 23 plan to testify to please stand to be sworn in and 24 raise your right hand

. Do you affirmthat the 25 testimony y ou are about to give is the truth and 

### Page 1 - Page 4

## Condenselt! TT' Page 5 Page 7 I 1 nothing but the truth? 1 institutional settings such as beauty shops, 2 (Witnesses respond in affirmative)

. 2 schools and hospitals

. Examples of the types of 3 CHAIRWOMAN PLUMNIER: Thank you

. Procedures 3 products affected include personal care products, 

### 4 call for presentations, first, by proponents, 4 household products, automotive after-market 5 second, by opponents and, third, by other 5 products, adhesives, sealants, insecticides and 6 interested parties neither for nor against

. If 6 other miscellaneous products

. VOC emissions from 7 you plan to speak and have not already done so 7 these products result fromevaporation of 8 please sign in now

on the appropriate speakers' 8 propellant and organic solids during use

. 9 sheet which I believe is next to the podium

. 9 There are current regulations that do impact 1o Following each presentation there will be an 10 consumer products

. The federal regulation which 11 opportunity for Members of the Board to direct 1 I has been in effect since 1998 covers 24 product 12 questions through the chair

. Copies of the 12 categories which is about 48 percent of the 13 proposed rule are available also on the side table 13 national consumer product inventory and reduces 14 and that's it

. Are there any questions? We will 14 VOC emissions by 20 percent

. The existing State 15 hear testimony first from Andrea Lani of the 15 Chapter 152 was adopted in September of 2004 and 16 Bureau of Air Quality

. Good morning

. 16 expands on the federal rule

. It covers 45 17 MS

. LANI : Good morning, Chairman Plummer, 17 consumer product categories -- it covers 

### 18 Members of the Board

. 18 approximately 80 different types of products 19 MS

. BERTOCCI : You'll have to bring that 19 within 45 consumer product categories and places 20 perhaps a little closer to you

. 20 more stringent voC limits than the federal rule

. 21 Ms

. LANE Is that okay? I'mAndrea Lani, 21 The state rule -- the initial rule reduced VoC 22 I'mwith the Department of Environmental 22 emissions by approximately two percent a day -- 23 Protection Bureau of Air Quality, ProgramPlanning 23 two tons per day, I'msorry

. 24 Division

. I'mhere today to discuss the 24 The proposed amendments increase the 25 Department's proposed amendments to Chapter 152, 25 categories by approximately 20 and also add the Page 6 Page 8 1 Control of Volatile Organic Compounds from 1 toxic limits that I mentioned earlier

. These 2 Consumer Products Regulation

. 2 proposed amendments are based on the model rule 3 VOCs or volatile organic compounds react with 3 developed by the Ozone Transport Commission which 4 nitrogen oxides in the presence of sunlight to 4 covers the Northeast and Mid Atlantic States

. 5 form ozone

. Breathing ozone can irritate the 5 Their rules are based on emission limits already 6 respiratory system, reduce lung function, 6 in place in California

. In the OTC Region, 7 aggravate asthma, inflame and damage the lining of 7 Connecticut, Delaware, Maryland, Massachusetts, 8 the lungs and aggravate chronic lung disease

. 8 New Hampshire, New

Jersey, New

York, Rhode Island 9 Children, the elderly and those with chronic 9 and Virginia are all currently in the process of 10 respiratory problems are most at risk

. Healthy 10 adopting similar regulations

. In Maine consumer I1 individuals may also experience increased 11 products are responsible for approximately 11 tons 12 respiratory symptoms when exposed to ozone while 12 of VOC emissions per day and the proposed 13 engaged in physical exertion

. The proposed 13 amendments will reduce those emissions by 14 amendments establish emission limits for volatile 14 approximately two-tenths of one ton, and as far as 15 organic compound content of approximately 20 15 compliance goes, the manufacturers are required to 

### 16 additional categories of consumer products, and 16 date or date code their products and submit a date 17 you can see those in the table in the rule, and 17 code explanation to the Department so that we'll 18 the proposed amendments also include limits on 18 know that the date -- that the products 19 certain toxic compounds in some consumer 19 manufactured after the effective date meet the 20 products

. The amendments also modify the date 20 requirements

. To make this requirement a little 21 coding requirements to make record keeping and 21 bit less onerous, if manufacturers use a Julian 22 recording less onerous for manufacturers

. 22 date that's described in the rule, then they don't 23 Consumer products include products sold to retail 23 have to send in their explanations

. The 24 customers along with products marketed by 24 manufacturers are responsible for developing and 25 wholesale distributors for use in commercial or 25 distributing compliant products for sale at the 

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### Page 9 retail and wholesale level, and the reporting provisions require manufacturers to submit additional information if the Department requests it

. They also have the option of submitting variances, innovative product exemptions or alternate control plans that have been issued by CRB or another state with a similar regulation subject to approval by DEP and the EPA, and in addition to compliance obligations by the manufacturers, retailers and distributors will be held accountable for stocking compliant products

. Chapter 152 should be transparent to consumers

. They should not notice any changes in product performance or quality and the cost increases of the additional product requirements should add up to less than 50 cents per customer per year in Maine, and many of the products with the proposed vOC limits are currently available in California and other states and they should be technologically feasible, and if the Board has any questions at this time, I'll try to answer them

. CHAIRWOMAN PLUMMER : Any questions? Yes, Matt

. 

### MR

. SCOTT: Andrea, a couple of questions

. You mentioned 11 tons per day produced vOCs? Page 10 1 MS

. LANI : Yes

. 

### 2 MR

. SCOTT: And that reduction number again 3 would be what? 4 MS

. LANI : It would be two-tenths of a 

### 5 ton

. It's pretty small when you think of it that 6 way

. 7 MR

. SCOTT: Okay

. I just wondered how much 8 of a reduction that would be

. So it's two-tenths 9 and the other question that I have is for the 10 retailers or producers, I'm sure that they must 11 have to understand or have a list of these 12 products that would have to come under this rule? 13 MS

. LANI : Yes

. The advantage of doing 14 this at a regional level is that the distribution 15 networks will kind of cover a lot of the states 16 that have this rule in effect so that makes it 17 easier for the products to come into the state

. 18 When we initially passed -- adopted the first 19 version of Chapter 152 we sent a letter to any 20 retailer in the state or distributor that might 21 sell these type of products just to alert themto 22 the rule being in effect, but if Massachusetts and 23 New Hampshire and Connecticut all have the same 24 rule, it's likely that the distribution network 25 should cover the states and the retailers in all Page 11 

### 1 likelihood won't have to do a lot of proactive 2 effort to make sure their products are compliant

. 3 MR

. SCOTT : Thank you

. 4 CHAIRWOMAN PLUMMER : Yes, Elizabeth

. 5 MS

. EHRENFELD

: A follow-up question to 6 Matt's, so the actual limits for all these 

### 7 compounds are the same in the proposed legislation 8 in all the different states? 9 MS

. LANM

: Yeah, unless there are some lo states that have modified theirs that we're not 11 12 13 14 15 16 17 18 19 20 

### aware of, but that's the idea behind the model rule is to keep it consistent across the broad swath

. MS

. EHRENFELD

: And the one we're looking at there haven't been changes? 

### MS

. LANI : We haven't changed anything in Maine fromthe model

. MS

. EHRENFELD

: Thank you

. CHAIRWOMAN PLUMMER : Other questions? Yes, Sue

. 

### MS

. LESSARD

: You mentioned that there are a number of other states that currently were considering this? Have these all been adopted in those states or are they -- what ones are they adopted in and what ones are they not? 21 22 23 24 25 

### Page 1 MS

. LANI : Well, they're in the process in 2 all of those states, and I was just talking to my 3 colleague fromthe Consumer Products Commission 4 and he mentioned that -- he might have more 5 details but some of themhave adopted

. Every 6 

### state has a different process

. Some have to go through legislation after they've gone through their rulemaking process

. New Jersey has just started theirs

. Connecticut has not quite passed theirs yet

. I believe Massachusetts has adopted theirs

. The effective date is January I st, 2009 so there's a year and a half before -- almost a year and a half before the effective date to give those other states time to get theirs adopted

. MS

. LESSARD

: But at this point -- 

### MS

. LANI : At this point some of themhave adopted and some haven't

. The information isn't completely clear on that

. CHAIRWOMAN PLUMMER : Yes, Matt

. MR

. SCOTT : So the bottomline then, 

### Andrea, we, the consumers, will -- the only change we might see is the cost of the product then? MS

. LANI : Potentially, yes

. 

### MR

. SCOTT: Which might be a small increase 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 or some items might be more but that's what the 

### 12



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## Condenselt! T"` Page 13 1 end result would be? 2 MS

. LANI : Right, there shouldn't be any 3 different in the effectiveness of the products or 4 anything that you would notice unless you pay 5 attention to the date code labels : 6 MR

. SCOTT : All right

. 7 CHAIRWOMAN PLUMMER : Other questions? 8 MR

. SCOTT: That's very good

. Thank you

. 9 CHAIRWOMAN PLUMMER : I just have one, and I 10 think you answered it before but I can't remember 11 and it's agricultural use

. Could you explain -- 12 it's on the first page 043 of the packet

. 13 MR

. LANI : Yup

. 14 CHAIRWOMAN PLUMMER : Agricultural use does 15 not include the sale or use of pesticides in 16 properly labeled packages

. So those are included 17 or -- 

### 18 MS

. LANI : Agricultural use pesticides 19 would be exempt

. It would just be a home use, 20 insect fogger or something like that

. 21 CHAIRWOMAN PLUMMER : Okay, and is that done 

### 22 somewhere else? 23 MS

. LANI : Yes

. Agriculture is under a 24 different -- in Maine it's the Board of Pesticide 25 Control

. Federally there's another

. Page 15 for agricultural use and that's where the agriculture comes into effect, and those items that require structural pest control license which would be if you were a company that eliminated termites or something like that and then other restricted materials

. So it's less in terms of an agricultural use than a home use, a small container size or household product type

. So that's where the agriculture comes into play as an exemption

. MR

. SCOTT: Since we have a Pesticides Control Board, all of that would come under their jurisdiction then? 

### MS

. LANI : Yup, and none of that has changed in this go-around but the first time we went through we worked with the Board of Pesticide Control to make sure that none of this conflicted with anything that they do

. MR

. SCOTT: Thank you for explaining that

. That's good

. CHAIRWOMAN PLUMMER : Ernie

. 

### MR

. HILTON : So this rule -- did California write the rule and that became the model rule? MS

. LANI : California's rules, the way I understand it, I think it was sort of more I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### Page 14 1 CHAIRWOMAN PLUMMER: Okay

. Now I 2 remember

. You told us that, yup

. 3 MS

. LANI : So it's just the things that we 

### 4 use in the home and that's only in terms of the 5 VOC content of those products not anything else 6 that's related to how those operate

. I7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR

. SCOTT : That raises another question, Ginny

. CHAIRWOMAN PLUMMER : Okay

. 

### MR

. SCOTT: Under the federal regulations
we have what we called the FIFA Act which is the Federal Insecticide and Fungicide Act

. So all of those products then would not -- would be exempt under this rule I assume if all of those come under the agricultural activities? MS

. LANI : Not necessarily

. MR

. SCOTT

: Okay

. 

### MS

. LANI : I think if you look under -- let me find the page, if you don't mind taking a second

. There are a lot of pages and definitions

. If you g6 to 59 of the Board packet

-- the previous Board packet that this was in, it has a definition for insecticide and it means a pesticide product that's designed for use against insects or other arthropods but existing products I ' Page 1 piecemeal, and California has different area's of 2 control districts that pass rules at different 3 times, but the OTC took the limits that California 4 has and used those in the basis for writing the 5 model rule and then they also had stakeholder 6 groups to help implement -- to figure out how 7 those will work out in the Northeast but it's not 8 an exact copy of what California has

. 9 MR

. HILTON : So California's sensibilities 1 o about agriculture versus consumer really provided 11 the structure for this rule that we're seeing here 12 today probably? 13 MS

. LANI : Probably

. 14 MR

. HILTON: So out of the 11 tons a day 15 of vOC which I guess is that all consumer or is 16 that -- 17 MS

. LANI : That's just consumer products, 18 just these product categories that are in this 19 rule

. 20 MR

. HILTON

: And if we were to include all 21 of the agriculture use, do you have any idea how 

### 22 many more tons a day that would be? It's seasonal 23 I'm sure

. 24 MS

. LANI : I Can't speak to that rate, and 25 because their products are applied differently, 

### 16

Page 13 - Page 16

## Condenselt! ' Page 1 they may have -- because they're not pressurized

. 2 Part of the vOC may be due to propellant and 3 that's something that may not come into play for 4 agriculture on a large scale

. 5 MR

. HILTON

: I'mreally kind of surprised 6 that they aren't able to reduce the vOCs 7 substantially more

. They did it with paint

. 8 Ms

. LANI : Right

. Well, the first rule we 9 did was two tons so this is an additional 10 1o percent of that

. 11 MR

. HILTON

: Oh, I see

. 12 MS

. LANI : Or about

. We have about 25 

### 13 percent more categories and about 10 percent more 14 reductions

. So we started with the lowhanging 15 fruit, if you will, and we're reaching a little 16 higher up the tree now

. 17 MR

. HILTON: We're glad you're over there

. 18 CHAIRWOMAN PLUMMER : And Cindy

. 19 MS

. BERTOCCI : I was just looking at the 

### 20 definition of consumer product on page 2 of the 21 rule and the last sentence that's added regarding 17 Page 19 1 CHAIRWOMAN PLUMMER : Make sure you speak 2 up

. 3 MS

. LANI : I'msorry

. There's also an OTC 

### 4 model rule that applies specifically to adhesives 5 and may have some interplay with this

. I'll look 6 into that

. 7 CHAIRWOMAN PLUMMER : Okay

. Other 

### 8 questions? I'm

just so impressed that on page 16 9 there's so many hair products

. I've never heard 10 of half of these

. Anyway, okay, if there are no 11 other questions, thank you very much and we have a 12 speaker in support -- oh, neither support or 13 opposition, Joe Yost, and Consumer Specialty

. 14 Products Association

. 15 MR

. YOST : Yes, ma'am, that's correct

. 

### 16 Thank you, Chairwoman Plummer, and other 17 distinguished Members of the Board

. My name is 18 19 20 21 22 23 24 25 Joe Yost

. I'm

with the Consumer Specialty Products Association or CSPA, and in general CSPA represents a broad range of companies, 260 companies, that manufacture, distribute, formulate and sell many different types of consumer products, also products that are sold in 

### institutions and in commercial facilities

. In summary, the current regulation in Maine 22 aerosol adhesives, and my question is that the 23 rule as a whole seems to really be focused on the 24 homeowner and institutions that I'm assuming use 25 fairly small quantities of these products but in

I 1 this one we've got industrial uses as well

. So ' 2 adhesives I'm assuming are maybe used in large 3 enough quantities that you really wanted to pull 4 in the bigger industrial uses on adhesives or can 5 you explain kind of why it's broader for that 6 category than just the consumer? 7 MS

. LANI : I think if you also turn to the 8 page 6 of the rule or 48 of the Board packet it 9 has a definition for adhesive and it still has lo limitations on the quantities that are -- that are 11 subjected to the limits

. 12 MS

. BERTOCCI : Okay

. 

### 13 MS

. LANI : So I'mnot 100 percent sure why 14 they added the aerosol adhesives used in 15 commercial/industrial uses to that but there's 

### Page 18
I1 2 3



### ,16 still a limitation on those products -- wait, no, 17 those are minimums, aren't they? I'msorry, I 18 should be more familiar with that

. I can find out 19 the answer to that question and get back to you

. 20 I'm not sure why they added industrial uses for 21 aerosol adhesives

. 22 MS

. BERTOCCI : Okay, thank you

. 23 MS

. LANI : Because there is also an OTC 24 adhesive rule that we haven't decided if we're 25 going to pursue as well

. 

### Page 20 and the proposed regulation directly affects about two-thirds -- two-thirds of the standards set under the current and proposed regulation have a 4 direct effect on CSPA member company products

. 5 Before I begin, I'djust like to maybe clarify a 6 couple points that were raised in the discussion

. 7 At this stage no state has adopted a final 8 regulation that incorporates the provisions of the 9 revised OTC model rule

. That's the revisions that 10 you all are considering here that the Department 11 is proposing

. Massachusetts started a rulemaking 12 in early January, Maryland started rulemaking in 13 April and Maine is one -- is at the forefront of 14 this issue by starting this rulernaking right now

. 15 So the other states are sort of following Maine's 16 lead but Maine in no way is behind any other 17 state, in fact, Maine is at the forefront of the 18 effort to consider revisions to the Ozone 19 Transport Commission's volatile rule

. Secondly, 20 regarding FIFA regulated products, as was 21 correctly stated, many FIFA regulated products are 22 consumer products, they are subject to regulation 23 by both the U

.S

. Environmental Protection Agency 24 and the Maine Board of Pesticide Control, and 25 actually as true in Maine and any other state 

### Page 17 - Page 20

## Condenselt! Tm

I Page 21 1 quite truthfully, the largest number of products 2 registered are consumer products

. So not all 3 those products are directly subjected to this rule 4 but clearly many consumer products are subject, 5 actually mostly insecticides and some herbicides

. 6 And finally in terms of CRB, California Resources 7 Board, in terms of regulation of consumer 8 products, CRB regulates consumer products on a 9 statewide basis

. Other types of products such as 10 paint, for instance, may be regulated on a 11 district by district, there are 35 air districts 12 in California, but as pertains to consumer 13 products, they all are subject to one statewide 14 regulation by statute and that regulation is 15 administered by the California Resources Board, 16 and the current OTC model or revised OTC model are 17 premised on the California regulations

. They took 18 the vOC limits in California but they scaled back 

### 19 some of the administrative provisions because 2o quite truthfully CRB has a very large staff that 21 deals with these regulations

. There are 67 22 full-time equivalent staffers that administer and 23 enforce consumer product regulations in 24 California

. It's mind boggling

. No other state 25 has that level of commitment in terms of personnel Page 23 1 nationwide distribution of products untenable, but ' 2 CSPA also represents a number of small companies, 3 companies that manufacture on a regional basis

. 4 We don't represent any Maine only companies but 5 there are a number of those companies that may be 6 subject to this regulation so I think that the 7 Department's proposal to establish a January 1, 8 2009 effective date is quite reasonable

. So it 9 would allow these regional companies that may not 10 be subject to this regulation now in California a 11 sufficient amount of time to reformulate their 12 products to comply with these very tough 13 standards

. 14 If I may start the comments to say that I 

### 15 think as a threshold matter CSPA would urge the 16 Board and the Department to consider a second and 17 possible more efficient option of working with the 18 U .S

. Environmental Protection Agency and other 19 states as EPA revises the current national 

### 20 consumer products rule, the rule that Ms

. Lani 21 explained was in effect or has been in effect 22 since 1998

. EPA is currently in the process of 23 revising this rule

. They are revising it in a way 24 that is consistent with what the Board is 

### 25 currently proposing, this revised OTCmodel, so Page 22 or financial resources, but California also has the most significant challenges in dealing with air quality so that's probably quite reasonable

. MR

. HILTON: And that is just consumer products? 

### MR

. YOST: Yes, sir, consumer products

-- let me rephrase that, consumer products and architectural coatings

. California groups the two and that was -- that's not my estimate, that's a report that the Air Resources Board provided to the legislature

. So, again, for the two, consumer products and architectural coatings, 67 FrES so it's understandable that the OTC model would scale back some of those administrative requirements in California but, again, the vOC limits are very similar, and as I mentioned, CsPA represents a wide range of companies

. Many of our companies market products on a nationwide basis

. So uniformity of regulation is of paramount importance, and while these standards are very tough, make no mistake about they are very stringent technology forcing standards, we would rather have one uniformset of standards to deal with than a patchwork of potentially differing state regulations because that would make the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### Page 24 that Maine would benefit fromthe reduction in vOCs that the Board -- excuse me, that the Department is proposing but this would save a considerable amount of administrative effort and expense for Maine if it were to rely on a national rule as opposed to a state specific rule, and from our perspective, again, the uniformnational standards and the uniforminterpretation of definitions and enforcement provisions is of paramount importance

. As a practical matter, even slight differences between state regulations could potentially make these vOC limits unworkable

. In the alternative, if the Board decides to go forward with the proposed amendments that the Department has put forward, we would like to suggest that in addition to what is before you that the Board consider revising the definition of volatile organic compound or vOC in Maine so that it is -- it incorporates the definition put forth by the U.S

. Environmental Protection Agency

. Currently the Maine definition is similar but it's , not entirely consistent and this definition of vOC ', is central to ensuring uniforminterpretation and enforcement of this regulation

. Other states such as New Hampshire and Pennsylvania make express 1 I 2 i3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### Page 21 - Page 24

### CondenseIt! T"' Page 25 1 reference and incorporate the EPA definition

. 2 It's a very straightforward way to do it and while 3 I say Maine's definition is relatively consistent, 4 it lists a number of chemical compounds that have 5 negligible photoreactive impact and exempts those 6 but as EPA goes forward and occasionally changes 7 its definition, Maine would have to change its 8 definition as well to be consistent which is an 9 additional administrative step; whereas, if Maine 10 were to expressly incorporate the EPS definition, 11 it would be much more efficient and eliminate this 12 additional step

. 13 Second, as I mentioned before, we think that 14 if the Board goes forward, the January 1, 2009 15 effective date is essential and, again, it's 16 particularly essential for small companies and 17 specifically for Maine only companies

. Although 18 we don't represent them, as a matter of 19 fundamental fairness we think it's important that 20 those companies not be adversely impacted by a 21 regulation that may cause themto reformulate 22 their products

. 23 Third, CSPA supports the current provisions 24 in the regulation that provide F1FA regulated 25 products one additional year to comply with vOC Page 27 1 request that the final rule be revised to state 2 that this -- the FIFA regulated products are 3 subject to the voC limits and other provisions to, 4 quote, one year after the date specified in the 5 Table of Standards

. This is language straight out 6 of the OTC model and again provides necessary 7 flexibility

. 8 Fourth, CSPA does not support adoption of 9 the proposed restriction on certain chlorinated

-- 10 use of certain chlorinated compounds in electrical 11 cleaner

. Specifically perchloroethylene and 12 methylene chloride are sometimes used by 13 manufacturers to formulate nonflammable products

. 114 There is a definition for a product called 15 energized electrical cleaner but -- and this 16 specific narrowsub-category of products are 17 exempted from the vOC limit for electrical cleaner 18 but the problemis while energized electrical 19 cleaner are supposed to be labeled in a certain 20 way that clearly states that they are to be used 21 on energized surfaces and not used on automobiles, 22 et cetera, the practical realities are such that 23 not everybody follows the manufacturer's advice

. 24 Manufacturers always say read the label and follow 25 the instructions but you and I know that sometimes 

### Page 26 1 limits and other related enforcement provisions

. 2 This provision is in Maine's rule, it's also in 3 the federal rule, it's in California's rule and 4 it's in every other state rule that deals with 5 consumer product regulation, and it's reasonable 6 because there are two levels of review that these 7 products have to go through if they reformulate 8 products

. On the one hand they must receive 9 approval from the U.S

. Environmental Protection 10 11 12 13 14 15 16 17 18 19 

### Agency and on the other hand in Maine they must receive approval from the Maine Board of Pesticide Control

. This is time consiuning

. We, thus, support the retention of this and, furthermore, we would suggest that there is a technical error though and I have other technical errors but I won't be so descriptive

. We will file written comments and I will detail those, but I'll be very brief for the Board

. Currently on page 27 of the revised rule, the newsection 3-E makes explicit reference to May 1 st, 2006

. That was the one year additional time to comply when this rule was first adopted

. The rule initially took effect May 1, 2005

. Unfortunately by locking it into that 2006 deadline, it undercuts and undermines the intended purpose of providing an additional rule

. We would 20 21 22 23 24 25 

### Page 28 1 people don't always do that and an electrical 2 cleaner versus an energized electrical cleaner may 3 not be immediately discernible to an average 4 citizen, and it's quite possible that somebody may 5 pick up an electrical cleaner that is not 6 formulated to be nonflammable and use it on an 7 8 9 10 11 12 13 14 15 16 17 18 19 

### energized electrical surface or a surface with energized electricity and this could cause a health and safety issue ; thus, we would suggest that the rule be revised to remove the restriction on electrical cleaner

. There are six other product categories that are subject to restrictions on the use of chlorinated solvents

. We don't object to those but, again, for health and safety reasons we think the electrical cleaner issue needs additional work and we would like to work with the Department to further express our concerns

. Again, there are several different technical issues

. I mentioned one

. If I may mention one other that I think is fairly significant, the definition for existing product, the termexisting product, this is found at page 3 of the new

section 2-A, Subsection 20

. The date referred to is September 1, 2004

. That's when the current rul e was approved as a final regulation 20 21 22 23 24 25 

### Page 25 - Page 28

## CondenseIt! T"`

I Page 29 1 but that's not when the current rule -- the 2 effective date of the current rule of standards 3 took effect

. Those standards took effect May 1, 4 2005

. So this is an error

. It's a minor 5 technical error but it could have significant 6 consequence
. Instead of identifying a specific 7 date as is done here, again this is the wrong 8 date, it would be better to follow what the OTC 9 model has done and state that it should take lo effect as of the date of the applicable standards, 11 the table of standards

. As you'll see in the rule 12 before the proposed rule, there are two columns, 13 one that says May 1, 2005, a second that says 14 January 1, 2009

. The term existing product is 15 important and it really needs to have that 16 flexibility so that you know which effective date 17 that existing product is held to, and by making 18 this change it's to say that, again, the 19 applicable date in the table of standards resolves 20 the problemvery nicely

. 21 All right, again, in conclusion, CSPA will 22 be submitting detailed written comments to 23 identify several technical issues that need to be 24 resolved

. In summary, Maine -- when the 

### 25 Department and the Board considered the current Page 30 rule, CSPA worked very closely with the Department and other stakeholders

. In summary, we felt that Maine DEP was very reasonable in the way that they adopted a very comprehensive and very technology forcing regulation back in 2004, and we look forward to working with the Department and other stakeholders as it goes forward and consider whether to adopt revisions to this existing rule

. I'd like to thank you very much for this opportunity to present our concerns and, again, we look forward to working cooperatively with your Department as it goes forward on this very important issue

. I'd be happy to answer any questions

. CHAIRWOMAN PLUMMER : Thank you

. Questions? Ernie

. MR

. HILTON

: To what degree -- you seemto have enunciated a number of areas in which the I1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 

### Page existing product, for instance

. As pertains to the vOC limits, the Department is dead on consistent with the OTC model

. In fact, I think the Department did a rather extraordinary job of ensuring consistency which is one of the real benefits of the Ozone Transport Commission

. I mean, it provides a forum for Maine and other states to work on a common problemozone transport and to do it in a way that is consistent and very thorough, and so they're minor technical errors that I think can be corrected

. This is a very comprehensive amendment so it's not altogether surprising that there may be a few minor errors, and I guess it goes to the adage that many eyes make the job easier or many hands make work easy

. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 

### 16 We have a lot of people reviewing this, they may 17 identify technical errors and we will work with 18 the Department to bring these issues to their 19 attention

. 

### 20 MR

. HILTON : Were you involved or your 21 organization involved in the OTC's drafting of 22 these rules? 23 MR

. YOST : As a stakeholder, yes

. The OTC 

### 24 had a very open and transparent process to develop 25 the model rule

. I knowthe Maine Department of

19 Department's proposed rule deviates fromthe model 20 rule

. 21 MR

. YOST : Yes

. 22 MR

. HILTON: In terms of the date issues 23 and some of these other issues? 24 MR

. YOST : Yes, that was in terms of just 25 specifically with the definition of the term 1

, 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### 31

Page 32 Environmental Protection was a very active member within the Ozone Transport Commission's consumer products work group as they developed these rules, and fortunately we were able to express our concerns throughout the development of this

. MR

. HILTON: And, yet, there are a number 

### of ways in which you want us to deviate fromthose in adhering more closely to the EPA proposals or prospects? MR

. YOST: Well, Mr

. Hilton, actually within the model rule there are -- well, let's address the first issue, the definition of vOCs

. The OTC model rule has three options, to either adopt the EPA definition, to have a state specific definition or have California's definition

. MR

. HILTON: I see

. 

### MR

. YOST: I would submit to you the California definition is really a non-starter in that they, again, have a very different set of issues and they are a different state, but in terms of option one and two, we would hardly suggest that the Department consider option one and following the EPA definition

. As pertains to the energized electrical cleaner versus electrical cleaner issue we expressed our concerns at the 

### Page 29 - Page 32

### CondenseIt! ' Page 33 I OTC, and they said that -- first of all, the OTC 2 deals with ozone

. They put this other issue

-- 3 the restriction on chlorinated solvents use as a 4 toxic air contaminant issue

. We agree that these 5 chemical compounds, the use of those compounds, 6 should be restricted but in certain limited 7 instances there are legitimate reasons why you 8 might want to have that option to use them and 9 we're just suggesting with this one limited case 10 with electrical cleaner that the Department might 11 want to consider that

. Aside fromthat, our goal 12 is to ensure consistency and I go from state to 13 state in this and that's why when I was citing off , 14 what these other states were doing, I had the 15 opportunity to go and testify at their hearings or 16 submit written comments

. We want to make sure 17 that states followthis OTC model

. It's a tough 18 model, we don't like everything in it, but now 19 that it's a done deal uniformity is far more 20 important than trying to address some of the 21 problems in this model

. 22 MR

. HILTON: I see

. 23 CHAIRWOMAN PLUMMER : Other questions? 24 Elizabeth

. 25 MS

. EHRENFELD : I wanted to go over a



### I little bit your suggestions for the changes 2 definition of volatile organic compound

. 3 that in the -- Page 34 in the Where is

4 MR

. YOST: Unfortunately I copied the 5 definition but I didn't put the citation here, 1 6 apologize, but for Maine it lists a number of the 7 chemical compounds that EPA exempts such as 8 acetone, methane, ethane -- oh, let me rephrase 9 that

. Thank you very much

. 10 CHAIRWOMAN PLUMMER : The only definition I 1 I could find was the high volatility organic 12 compound

. 

### 13 MR

. YOST: It's defined in a separate 14 section of the Maine regulation

. 15 CHAIRWOMAN PLUMMER : Andrea, could you
-- 16 MS

. LANI : I think Joe wasjust about to 

### 17 address this

. It's in Chapter 100 definitions and 18 we didn't include it in there because, like he 19 mentioned, it changes frequently

. 20 MS

. EHRENFELD : So it's not part of this 21 rule? 22 MS

. LANI : It's not in this rule

. If we 

### 23 have a definition in Chapter 100 we usually don't 24 include those in the specific rules unless there's 25 some change and I don't have that

. 1 2 3 4 5 6 7 8 9 10 11 12 13 

### Page 35 MS

. ANDERSON

: So this isn't before us at this point

. It's not part of the regulations that are being addressed? 

### MS

. LANI : We could potentially define it differently in this rule fromhow we have it in Chapter 100

. MR

. YOST: And, again, the way it's defined currently in this general definition section is largely consistent with EPA

. It's just not quite consistent and other states that have addressed this issue have resolved that problem by expressly referencing EPA definition

. It's a matter of administrative efficiency really

. MR

. HILTON: Doesn't that create a consistency problem though across state lines for your manufacturers? I mean, they're manufacturing to EPA standards here and manufacturing to a local standard in California and -- 14 15 16 17 18 19 MR

. YOST : Actually, Mr

. Hilton, 

### 20 fortunately in California it's not local, it's 21 statewide which is a big plus, believe me

. If it 22 were local, we'd be out of business in California 23 but by and large most states are similar to EPA

. 24 For instance, there may be one or two compounds 25 that EPA exempts that may not be exempt in Maine, 

### Page 36 1 for instance

. I'm thinking t butyl acetate I 2 believe

. There may be another but that's the 3 first example that pops into my mind, and I think 4 the intent when this definition -- and I'm just 5 guessing but it seems obvious by reading the 6 definition, the intent was to be relatively 7 consistent with the EPA definition but EPA's definition has apparently changed since this definition was put in place in Maine a number of years ago

. I'mnot a Maine lawyer so I don't know exactly when this regulation was put in place but I'm just suggesting this is an option for the Board to consider

. Since you're working on a consumer products regulation that is directly relevant to the definition of vocs, I'm just raising this for an option that you may want to address

. 8 9 10 11 12 13 14 15 16 17 18 CHAIRWOMAN PLUMMER : And in your written 19 comments you can address that more specifically 20 21 22 23 24 25 

### with the citation to Maine

. MR

. YOST : Yes, Ms

. Plummer, I'll make sure I do that

. CHAIRWOMAN PLUMMER : That will help us

. MR

. YOST : Yes, ma'am

. Thank you

. CHAIRWOMAN PLUMMER : Any other questions? 

### Page 33 - Page 36

## CondenseIt! Tm Page 37 1 Thank you very much

. 2 MR

. YOST: Thank you

. 3 CHAIRWOMAN PLUMMER : Are there any others 

### 4 that wish to speak at this time? Seeing none, the 5 hearing is closed

. 6 (Whereupon, the above-named hearing was concluded 7 at 9:50 a.m

.) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 

### Page 38 1 CERTIFICATE 2 

### 3 1, Joanne P

. Alley, a Notary Public in and 4 for the State of Maine, hereby certify that on the 5 2nd day of August, 2007, personally appeared 6 before me the within-named witnesses who were 7 sworn to testify to the truth, the whole truth, 8 and nothing but the truth in the aforementioned 9 cause of action and that the foregoing is a true 

### 10 and accurate record as taken by me by means of 11 computer-aided machine shorthand

. 12 

### 13 1 further certify that I am a disinterested 14 person in the event or outcome of the 15 aforementioned cause of action

. 16 17 IN WITNESS HEREOF, I have hereunto set my 

### 18 hand this 1 da of September, 2007

. 19 20 

### 21 oar e P

. Alley 22 C rt Reporter/Notary Pubk/ 23 

### 24 My commission expires : July 18, 2008 25 

### Page 37 - Page 38

## -0-

043 [i] 13 :12 

### -1- 1 [71 23 :7 25 :14 26 :22 28 :24 29:3,13,14 I10[2] 17 :9,13 ! 100 [4) 18:13 34

:17,23 35:6 11 [41 3 :22 8 :11 9:25 16:14 13th[l] 4:3 14 Ill 3 :12 l4th [il 38:18 152 [71 1 :7 2 :17 4:6 5 :25 7 :15 9:12 10

:19 16 [il 19:8 18 [ii 38:24 

### 1998 [21 7:11 23 :22 1 st [2] 12 :11 26:20 

### -2- 2 13] 1 :16 2 :3 17 :20 2-A [il 28:23 20 [41 6:15 7 :14,25 28:23 2004 [31 7 :15 28:24 30:5 2005 [31 26:23 29:4,13 2006 [21 26:20,23 2007 [8l 1 :16 2:3 3 :19,22 4 :4,6 38:5,18 

### 2008 [11 38:24 2009 [4] 12 :11 23 :8 25 :14 29:14 24 [il 7 :11 25 Ill 17 :12 260 Ill 19:20 27 Ill 26:18 2nd [31 3 :19 4:6 38:5 

## -3- 3 [11 28:22 3-E Ill 26:19 35 [i] 21 :11 38 Ill 3:10 384 [il 3:12 

### -4- 40 [il 3 :16 45 [21 7 :16,19 48 [21 7 :12 18 :8 

## -5- 5 Ill 4:3 50 [il 9:16 51 Ill 3 :16 585 [1l 3 :11 585-A [tl 3 :11 59 Ill 14:21 

## -6- 6 [il 18:8 67 [2] 21 :21 22 :12

80 [il 7:18 

## -8-

-9- 9:00 [2] 1 :16 2 :4 9:50 [i] 37 :7

## -AI, a .m [31 1 :16 2 :4 37:7 able [21 17 :6 32:4 above-named [ii 37 :6 accountable Ill 9:11 accurate [il 38:10 acetate Ill 36

:1 acetone Ill 34:8 Act [2] 14 :11,12 action [21 38:9,15 active [il 32:1 activities [i] 14 :15 actual [il 11 :6 adage Ill 31 :14 add [21 7 :25 9:16 added [31 17 :21 18:14,20 addition [31 3 :12 9:9 24 :16 additional poi 6:16 9 :3 9:15 17 :9 25 :9,12,25 26:21,25 28:16 address [51 32 :12 33 :20 34:17 36:17,19 addressed [31 4

:4 35:3 35 :10 adhering [il 32:8 adhesive [21 18:9,24 adhesives pi 7:5 17 :22 18:2,4,14,21 19

:4 administer [i] 21 :22 administered [il 21 :15 administrative [61 3 :4 21 :19 22 :14 24:4 25:9 35 :13 adopt [21 30:8 32 :14 adopted [Ill 7 :15 10:18 11 :23,25 12 :5,10,14,17 20:7 26:22 30:4 adopting [il 8:10 adoption [sl 4 :14,17 27 :8 advantage [i] 10:13 adversely [1] 25

:20 advice [1] 27 :23 aerosol [3] 17 :22 18:14 18:21 affected[l] 7:3 affects [ii 20:1 affirm

[i 1 4 :24 

## Condenselt! '

~ aforementioned [2] ' 38:8,15 after-market [il 7 :4 again [is] 2 :7 10:2 22 :11 22 :15 24:7 25:15 27:6 28:14,18 29:7,18,21 30:10 32:19 35:7 against [21 5 :6 14 :24 Agency [51 4:20 20:23 23 :18 24:20 26:10 agenda [31 2 :7,11,12 aggravate [2] 6 :7,8 ago Ill 36:10 I~ agree [i] 33 :4 agricultural [6] 13 :11 13 :14,18 14 :15 15 :1,7 agriculture r61 13 :23 15 :2,9 16:10,21 17 :4 air [91 3 :14,24 4:5 5 :16,23 21 :11 22 :3,10 33 :4 alert [11 10:21 Alley [41 3 :6,6 38 :3,21 allow [i] 23 :9 almost Ill 12 :12 along [il 6:24 ' alternate [il 9:6 alternative Ill 24:13 altogether[i] 31 :12 always [21 27 :24 28:1 amend pi 4 :10 amendment [il 31 :12 amendments [Ill 2 :16 3 :13 4 :11 5 :25 6 :14,18,20 7 :24 8 :2,13 24:14 amount [2] 23 :11 24:4 analyst [il 3 :3 Anderson [21 2 :21 35:1 Andrea [61 3 :8 5 :15,21 9:24 12 :21 34 :15 Androscoggin [1] 2

:10 answer [3] 9:21 18 :19 30:13 answered [il 13 :10 Anyway [il 19:10 apologize [1l 34:6 appeals[l] 2:10 appeared [l] 38 :5 applicable [21 29:10,19 applied [il 16:25 applies [i] 19:4 Association [21 19 :14 19:19
assume Ill 14 :14 assuming [21 17 :24 18:2 asthma [il 6:7 Atlantic [i] 8:4 attendance [il 4 :14 attention [21 13 :5 31 :19 attorney [il 3 :2 August [sl 1 :16 2 :3 4:3 4:6 38:5 Augusta [2] 1 :15 2 :3 automobiles Ill 27 :21 automotive Ill 7 :4 available [41 4 :8,13 5 :13 9:18 average Ill 28:3
aware p] 11 :11

### -BBangor [il 3 :21 based [31 4:9 8:2,5 basis [41 16:4 21 :9 22 :18 23:3 beauty [il 7 :1 became [il 15 :23 begin [il 20:5 beginning [21 1 :16 2 :4 I behind [21 11 :11 20:16 Belgrade [i] 3:1 benefit Ill 24:1 benefits [il 31 :6 Bensinger [i) 3 :2 Bertocci [s] 3:3 5:19 17 :19 18 :12,22 better pi 29:8 between [il 24:11 big [il 35 :21 I bigger pi 18:4 bit [21 8:21 34:1 Board [311 1 :2 2 :1,13,24 4 :8,9,11 5 :11,18 9 :20 13 :24 14 :21,22 15 :12,16 18:8 19 :17 20:24 21 :7,15 22 :10 23 :16,24 24 :2,13 24 :17 25 :14 26:11,18 29:25 36:13 

### boggling [11 21 :24 bottom

pi 12 :20 

### Breathing [il 6:5 I, appropriate [i] 5:8 approval [3] 9

:8 26:9,11 approve [il 4:10 approved [l) 28 :25 April [11 20:13 architectural [21 22 :8 22 :12 area's [ii 16:1
areas [i] 30

:18 arthropods Ill 14 :25 Aside [11 33 :11 assistant [21 3 :2,5 brief [11 26:18 bring [21 5 :19 31 :18 broad [21 11 :12 19:20 broader [il 18

:5 Bureau [3] 4:5 5 :16,23 business [1l 35 :22 butyl [il 36:1 

## _C_ California [2o1 8:6 9 :19 15 :22 16 :1,3,8 21 :6,12,15 21 :17,18,24 22 :1,8,15 

### 043 - columns 23 :10 32 :18 35:18,20,22 California's [41 15 :24 16:9 26:3 32 :15
care [i] 7 :3
case [1] 33 :9 categories [sl 6 :16 7 :12 7 :17,19,25 16 :18 17 :13 28:12 category Ill 18:6 Center [2] 1 :15 2:3 central [il 24:23 cents [ii 9:16 certain [51 6:19 27 :9,10 27 :19 33 :6 CERTIFICATE [~l 38:1 certify [21 38 :4,13 cetera [1] 27 :22 chairp] 5 :12 Chairman [il 5 :17 Chairwoman [2s] 1 :12 5 :3 9:22 11 :4,19 12 :19 13 :7,9,14,21 14:1,9 15 :21 17:18 19:1,7,16 30:15 33 :23 34:10,15 36:18,23 36:25 37 :3 Ichallenges [1l 22 :2 change [41 12 :21 25:7 29:18 34:25 changed [31 11 :16 15 :15 36:8 changes [51 9

:13 11 :15 25:6 34:1,19 Chapter [iil 1 :7 2 :16 3 :12 4 :6 5 :25 7 :15 9:12 10:19 34:17,23 35:6 chemical [31 25 :4 33 :5 34:7 

### Children [ii 6:9 I~ chloride [il 27 :12 chlorinated [41 27 :9,10 28:13 33 :3 chronic [21 6 :8,9 Cindy [21 3 :3 17 :18 circulating Ill 4 :15 citation [2] 34:5 36:20 citing Ill 33 :13 citizen [il 28 :4 Civic [21 1 :15 2 :2 clarify [il 20:5 cleaner [121 27 :11,15,17 27 :19 28:2,2,5,11,15 32 :24,25 33 :10 clear [i] 12 :18 clearly [31 4:5 21 :4 27 :20 closed [1] 37 :5 closely [zl 30:1 32:8 closer [il 5 :20 coatings [21 22 :8,12 code [41 3 :17 8:16,17 13 :5 coding [il 6:21 colleague [1l 12 :3 Columns [il 29:12 

### Index Page 1

## CondenseIt! ' comments - forcing

comments [6] 4:2 23 :14 contaminant [i) 33 :4 Department's [4] 3:23 efficient [2] 23 :17 25 :11 exemptions [1] 9 :5 26:17 29:22 33 :16 36:19 content [2] 6:15 14 :5 5:25 23 :7 30 :19 effort [3] 11 :2 20 :18 24:4 exempts [3] 25:5 34:7 

### commercial [2] 6:25 control [ill 1 :7 2 :17 6 :1 described [i 1 8:22 Ehrenfeld [61 2:22 11 :5 35 :25 19:24 9:6 13 :25 15 :3,12,17 16 :2 descriptive [11 26:16 11 :14,18 33 :25 34:20 exertion [1] 6 :13 commercial/industrial 20:24 26:12 designed [i] 14 :24 either [i) 32 :13 existing [s) 7 :14 14 :25 [i) )8:15 cooperatively [1] 30:1) detail [1] 26 :17 elderly [11 6:9 28:21,22 29:14,17 30 :8 commission [4] 8:3 12 :3 copied [i] 34:4 detailed [1] 29:22 electrical [13] 27 :10,15 31 :1 3] :6 38:24 ' Copies[2] 4 :]2 5 :12 details [i] 12:5 27 :]7,18 28:1,2,5,7,11,15 expands [i] 7 :16



### s [z] Commission copy [z] 4 :16 16:8 develop i p [ ] 3) :24 32 :24,24 33 :10 expense [1] 24:5 20:)9 32 :2 commitment [1) 2) :25 correct [1] 19:15 developed [21 8 :3 32:3 electricity [1] 28:8 experience [i] 6:11

common [1] 31 :8 corrected [i) 31 :11 develop in g [ll 8:24 eliminate [i] 25:11

eliminated [i] 15:4 expires [1) 38:24 explain [z] 13 :11 18 :5 companies [1z] 19:20

17 23 :2 4 19:21 22 :17 3 5 correctly [i] 20:21 Cost [21 9:]4 12 :22 development[i] 32 :5 deviate [i] 32:7 Elizabeth [3] 2 :22 11 :4 explained [i] 23 :2)

, , , , 23:9 25 :16,17,20 couple[2] 9:24 20:6 deviates [i) 30:19 33 :24 ex plaining [i] 15 :19 company [z] 15 :4 20:4 Court [l] 38:22 differences [i] 24:11 emission [3] 3 :25 6 :]4 8'S explanation [i] 8:17 

### complete [i) 4:9 cover [z] 10:15,25 different [i 1) 7 :18 11 :8 emissions [s) 7 :6,14,22 ex p lanations [i) 8 :23 ex plicit [i] 26:19 completely [i 1 12 :18 covers [41 7 :11,16,17 8 :4 12 :6 13 :3,24 16 :1,2 19:22 8:12,13 compliance [2) 8:15 9:9 Crawford [i) 3 :7 28:18 32 :19,20 end [i] 13 :1 exposed [i] 6:12 compliant [3) 8:25 9:11 CRB [41 9 :7 21 :6,8,20 differently [3] 2:8 16:25 energized [~] 27 :15,18 express [3] 24 :25 28 :17 11 :2 comply [3] 23 :12 25 :25 create[i] 35 :)4 CSPA [~o] 19:19,19 20:4 35 :5 differing [i] 22 :24 27 ;2) 28:2,7,832 :24 enforce [1] 21 :23 32 :4 expressed [z] 3 :25 32 :25 26:21 22:16 23 :2,15 25 :23 27 :8 direct [z] 5:11 20:4 enforcement [3] 24:9 expressly [z] 25:10 compound [41 6:15 29:21 30:1 directly [3] 20:1 21 :3 24 :24 26 :1 35 :11 24 :18 34:2,12 Cumberland [i] 2 :21 36:14 engaged [i1 6 :13 extraordinary [1] 31 :4 compounds [1z] 1 :7 current po] 7:9 19:25 discernible [1] 28:3 ensure [~] 33 :12 eyes [i] 31 :14 2 :17 6:1,3,19 11 :7 25:4 20 :3 21 :16 23 :19 25 :23 discuss [11 5 :24 27:10 33 :5,5 34:7 35:24 28;25 29:1,2,25 discussion [a] 2:)0 20 :6 24

:23 31 :5 ensuring [2] 24 :22 entirel 1 

### -Fcomprehensive [2) 30:4 31 :12 customer [i] 9:16 disease [1] 6 :8 y [ ]

enunciated [i) 30:18 facilities [1) 19 :24 

### computer-aided [l) customers [i) 6 :24 disinterested [i] 38:13 

### nvironmental [~~] 1 :2 fact [z] 20:17 31 :3



### uished i ]9 17 distin 38:11

_ -D 

### [ )

g : 2 :2,14,16 4 :19 5 :22 20 :23 fairly [2] 17 :25 28:20 4 28:18 30:10 concerns distribute [1] 19 :21 23 :18 24 :20 26:9 32 :1 fairnes 25 19

] [ s p] : 32 :5,25 Daily [z) 3 :20,21 distributing [i] 8:25 EPA [is) 9:8 23 :19,22 Falmouth [i] 2 :22 concluded [11 37 :6 damage [1] 6 :7 distribution [3] 10:)4 25 :1,6 32 :8,14,23 34:7 familiar[i] 18:18 conclusion [i] 29 :21 date [211 6:20 8:16,16,16 10:24 23:1 35 :9,12,17,23,25 36:7 ' far[3) 2:208:1433:]9 

### conducted [~] 3:15 8:18,19,2212 :11,]313 :5 distributor [,1 10 :20 EPA s [11 36:7 

### feasible [1] 9:20 conflicted [i) 15:17 23 :8 25 :]5 27 :4 28:23 29:2,7,8,10,16,19 30:22 distributors [z] 6 :25 9:10 EPS [i] 25 :10 equivalent [1] 21 :22 federal [7] 3 :17 7:10,16 Connecticut[3] 8:7 10:23 12 :9 dead [i] 31 :2 district [z] 21 :11,11 Ernie [3] 2 :20 15 :21 7 :2014 :10,)226:3 Federally [i] 13 :25 consent [i] 2:11 deadline [i] 26:24 districts [2] 16:2 21 :11 30:16 

# felt[il30:2

consequence [i) 29:6 deal [z) 22 :23 33 :19 Division [i) 5 :24 error [3) 26:14 29:4,5 few [i] 3) :13 consider[7] 20:)823:]6 dealing [1] 22:2 Doesn't [1] 35:]4 errors[4] 26:1531 :10,13 FIFA [s] 14 :11 20:20 21 24:)7 30:7 32 :22 33:11 36:13 deals [3] 21 :21 26:4 33 :2 18 :24 decided i Don [~] 2 :23 31 :17 essential [z] 25: ] 5, ) 6 , 25:24 27 :2 

# considerable[i]24:4

[ ) decides [i] 24 :13 done [5] 5 :7 13 :21 29 :7,9 33 :19 establish [z] 6 :14 23 :7 figure [i) 16:6
considered [i] 29:25 define [1) 35 :4 draft [i) 4 :17 estimate [1] 22:9 file [~) 26:]6 final [s] 4 :12 17 20:7 27 :1 considering [z] 11 :23 defined [z] 34 :13 35 :7 drafting [i] 31 :21 et [i] 27 :22 8 , 20:10 definition [33] 14 :23 Drive [z) 1 :15 2 :3 ethane [i] 34:8 finally [i] 21 :6 consistency [3] 31 :5 17 :20 18:9 24 :17,19,21 due [i 1 17 :2 evaporation [i) 7 :7 financial [i] 22:1 33 :12 35 :15 consistent[io] 1] :12 24 :22 25 :1,3,7,8,10 27 :14 28:21 30:25 32 :12,14,15 32 15 18 23 34 2 10 23

5 during [1] 7 :8

g event [i] 38:14 everybody [i) 27 :23 firstpo] 5 :4,]5 10:18 13 :12 15 :15 17 :8 26:21 23 :24 24:22 25:3,8 31 :3,9 35 :9,10 36 :7 : : , , , , , 35 :8,12 36:4,6,7,8,9,15 -E- exact [1] 16:8 32 :12 33:1 36:3

consumer [35) 1 :8 2 :18 definitions [3] 14:21 early [i] 20:12 exactly [1] 36:11 

### flexibility [2] 27 :7 6:2,16,19,23 7:10,13,17 7:19 8:10 12 :3 16

:10,15 24:9 34:17

degree [i] 30:17 easier[21 10:17 31 :15 EXAMINER [1] 2:6 example [i] 36:3 29:16 focused [i] 17 :23 16:17 )7 :20 18:6 19:13 Delaware [1] 8 :7 easy [1] 31 :]5

effect [ill 7 :11 10:16 22 Examples [11 7:2 fogger[r] 13 :20 19:18,22 20:22 21 :2,4,7,8 21 :12,23 22 :4,6,7,11 den [i] 4 :10 3' , 15 :2 20:4 23 :21,21 26:22 excuse [i) 24:2 follow [3) 27 :24 29:8 33 :17 23 :20 26:5 32:2 36:14 DEP [z) 9:8 30:3 29 :3,3,10 executive [i] 3 :3 

### follow-up [i] 11 :5 consumers[z) 9:13 Department[21] 2:15 effective [7) 8:19 12 :11 exempt [3] 13 :19 14 :13 

### following [4] 4:17 5:10 12 :21 3:8 4:18 5:22 8:17 9 :3 12 :13 23:8 25 :15 29:2,16 35 :25 20:]5 32 :23 consuming [i] 26:)2 20:10 23 :16 24 :3,15 28:17 4 12 31 :2 18 29:25 30:1 6 effectiveness [i) 13:3 exempted [l] 27 :17 follows [i] 27 :23 containerp] 15 :8 , , , , 31 :25 32 :22 33 :10 efficiency [i] 35 :13 exemption [i) 15 :10 forcing [z] 22 :22 30:5 

### Index Page 2forefront [21 20:13,17

foregoing [il 38:9 Foreside [1l 2:22 form Ell 6:5 formal [il 4 :18 formulate [21 19:21 27 :13 formulated pl 28:6 Fort Ell 2:24 forth [il 24 :19 fortunately [21 32 :4 35 :20 ' forum

[il 31 :7 forward [81 24 :14,15 25 :6,14 30:6,7,11,12 found [il 28:22 Fourth [il 27 :8 frequently (i 1 34 :19 fruit Ell 17 :15 FTES Ell 22 :12 full-time Ell 21 :22 function [i] 6:6 fundamental [i] 25 :19 Fungicide Ell 14:12 furthermore p1 26:13

## -GI general [31 3 :2 19:19 35 :8 Ginny [21 2 :13 14:8 glad (il 17 :17 go-around [il 15 :15 goal Ell 33 :11 goes [61 8 :15 25 :6,14 30:7 30:12 31 :14 gone [i1 12 :7 good [sl 2 :6 5:16,17 13 :8 15 :20 Gould [1l 2 :23 Greenville (il 2:23 group Ell 32:3 groups [2] 16:6 22 :8 guess [2] 16:15 31 :14 guessing [il 36:5 Guimond [il 2 :23

### -Hhair pi 19:9 half [31 12 :12,13 19:10 Hampden [il 2 :25 Hampshire [31 8:8 10:23 24 :25 hand [41 4 :24 26:8,10 38:18 hands pi 31 :15 hanging [il 17 :14 Hanson [il 3 :5 happy [il 30:13 hardly Ell 32

:21 health [21 28 :9,14 Healthy Ell 6 :10 hear Ell 5:15 heard pi 19 :9 hearing [isl 1 :152 :1,6,9 2 :15,19 3 :10,15,18,22 4:2 4 :7,7 37 :5,6 hearings Ell 33 :15 held (51 1 :15 2:1 3 :10 9 :11 29:17 help [21 16:6 36:23 Herald [i] 3:21 herbicides [1l 21 :5 hereby [il 38:4 hereunto [i] 38:17 ' high Ell 34 :11 higher [il 17 :16 Hilton [18] 2:20 15 :22 16:9,14,20 17 :5,11,17 22 :4 30:17,22 31 :20 32 :6 32 :10,16 33 :22 35 :14,19 holding [il 2 :14 Holiday [2] 1 :15 2 :2 home (31 13 :19 14:4 15 :7 homeowner [il 17 :24 hospitals [1l 7:2 household [21 7:4 15:8

-I- ! idea [21 11 :11 16:21 identify [21 29:23 31 :17 identifying Ell 29:6 immediately [il 28 :3 impact [21 7 :9 25:5 impacted Ell 25 :20 implement Ell 16:6 Implementation [z] 3 :14 4 :20 importance [21 22

:20 24 :10 important [4] 25 :19 29:15 30:13 33 :20 I impressed [il 19

:8 include [71 6:18,23 7:3 13 :15 16 :20 34 :18,24 included Ell 13 :16 inclusion [21 4 :6,20 incorporate [21 25 :1,10 incorporates [21 20:8 24 :19 increase (21 7:24 12 :24 increased pi 6 :11 increases vi 9:15 indicate [il 4:15 individuals Ell 6:11 industrial [3] 18:1,4,20 inflame (i] 6

:7 information [2] 9:3 12 :17 initial Ell 7 :21 Inn [2] 1 :15 2 :2 innovative Ell 9 :5 insect Ell 13 :20 insecticide [21 14 :12,23 

### CondenseIt! ' insecticides [21 7:5 21 :5 insects Ell 14 :25 instance (41 21 :10 31 :1 35 :24 36:1 instances [il 33 :7 Instead (i] 29:6 institutional [ii 7

:1 institutions [21 17 :24 19 :24 instructions [il 27 :25 intended [il 26:24 intent [2] 36:4,6 interest [il 4:1 interested [i] 5 :6 interplay [i] 19 :5 interpretation [21 24 :8 24:23 inventory [il 7 :13 involved [21 31 :20,21 irritate [il 6

:5 Island Ell 8

:8 issue [9l 20

:14 28:9,16 30:13 32 :12,25 33 :2,4 35 :11 issued [il 9 :6 issues [6] 28:19 29:23 30:22,23 31 :18 32 :20 items [3] 2 :12 12 :25 15 :2 

### _j_ January [sl 12 :11 20:12 23:7 25 :14 29:14 Jeff [i] 3 :7 Jersey [2] 8

:8 12 :8 Joanne [31 3:6 38:3,21 job [21 31 :4,15 Joe (31 19

:13,18 34:16 Journal [21 3 :19,20 Julian Ell 8:21 July [31 3:19,22 38:24 jurisdiction Ell 15 :13



### -Klarge [41 17 :4 18 :2 21 :20

35 :23 largely Ell 35 :9 largest [il 21 :1 last Ell 17 :21 Law [i] 3 :11 lawyer [il 36:10 lead [il 20:16 left [il 3 :3 legislation [21 11 :7 12 :7 legislature Ell 22 :11 legitimate [il 33 :7 less [4] 6:22 8:21 9:16 15 :6 Lessard [s] 2 :24 11 :21 12 :15 letter [il 10:19 level [31 9

:1 10:14 21 :25 levels Ell 26:6 Lewiston Ell 3:20 license (il 15:3 licensed Ell 3:24 likelihood [i] 11 :1 ! likely Ell 10:24 limit Ell 27 :17 limitation Ell 18 :16 limitations Ell 18:10 limited [21 33 :6,9 limits [151 6 :14,18 7 :20 8:1,5 9 :18 11 :6 16:3 18

:11 21 :18 22 :15 24:12 26:1 27 :3 31 :2 line Ell 12 :20 lines Ell 35 :15 lining [il 6:7 list [21 3 :24 10:11 liStS [2] 25:4 34:6 local [31 35 :17,20,22 locking [i] 26:23 look [4] 14 :18 19

:5 30:5 30:11 looking [2] 11 :14 17 :19 low [i] 17 :14 lung [zl 6

:6,8 keepp] 11 :12 keeping [i] 6:21 Kennebec [21 3 :18,19 Kent Ell 2 :24 kind [31 10:15 17 :5 18:5

### -Llabel Ell 27 :24 labeled [21 13 :16 27:19 labels Ell 13 :5 language Ell 27 :5 Lani [s5] 3 :8 5 :15,17,21 5 :21 10:1,4,13 11 :9,16 12 :1,16,23 13 :2,13,18,23 14 :3,16,18 15 :14,24 16:13 16:17,24 17 :8,12 18:7,13 18:23 19:3 23 :20 34:16 34:22 35 :4 lungs [i] 6 :8 I

### -MM .R .S .A [1] 3:11 ma'am [21 19:15 36:24 machine [11 38:11 mailing Ell 3:24 Maine [341 1 :1,15 2:3 8 :10 9:17 11 :17 13 :24 19:25 20:13,16,17,24,25 23 :4 24 :1,5,18,21 25 :7,9 25 :17 26:10,11 29:24 30 :3 31 :7,25 34 :6,14 35 :25 36:9,10,20 38:4 Maine's [4] 3 :14 20:15 25:3 26:2 makes [2] 10:16 26 :19 manufacture [2] 19:21 

### forefront - Ms 23 :3 manufactured [ii 8:19 manufacturer's Ell 27 :23 manufacturers [91 6 :22 8:15,21,24 9:2,10 27 :13 27 :24 35 :16 manufacturing [2] 35 :16,17 marked (il 4:5 market Ell 22 :18 marketed (i] 6:24 Maryland [21 8:7 20:12 Massachusetts [41 8:7 10:22 12 :10 20:11 materials pi 15:6 Matt [4] 3 :1,4 9:23 12 :19 Matt's Ell 11 :6 matter [41 23 :15 24 :10 25 :18 35 :12 may [231 6 :11 17 :1,2,3 19:5 21 :10 23 :5,9,14 25 :21 26:20,22 28:2,4,19 29 :3,13 31 :13,16 35 :24 35 :25 36:2,16
mean [2] 31 :7 35 :16
means [21 14 :23 38:10 meet Ell 8:19 meeting Ell 4 :12 member [31 2 :24 20:4 32 :1 members [sl 2 :19 4:9 5 :11,18 19:17 mention Ell 28:20 mentioned [sl 8:1 9:25 11 :21 12:4 22 :16 25 :13 28:19 34 :19 methane Ell 34:8 methylene [1l 27 :12 Mid Ell 8

:4 might pl 10:20 12 :4,22 12 :24,25 33 :8,10 mind [3] 14 :19 21 :24 36:3 minimums Ell 18:17 minor [31 29

:4 31 :10,13 miscellaneous Ell 7 :6 mistake [il 22 :21 model [21] 8:2 11 :11,17 15 :23 16:5 19:4 20:9 21 :16,16 22 :13 23 :25 27 :6 29:9 30:19 31 :3,25 32 :11 32 :13 33 :17,18,21 modified (il 11 :10 modify [il 6

:20 morning [41 2:6 3 :20 5:16,17 Morrisette Ell 3 :6 Most [31 6:10 22 :2 35 :23 mostly [j] 21 :5 MS [44] 5 :17,19,21 10:1,4 10:13 11 :5,9,14,16,18,21 12 :1,15,16,23 13 :2,18,23 14 :3,16,18 15 :14,24 16 :13 16:17,24 17 :8,12,19 18:7 

### Index Page 318:12,13,22,23 19:3 23 :20

33 :25 34:16,20,22 35 :1,4 36:21 must [31 10:10 26:8,10

## -Nname [2] 2 :13 19 :17 Nancy [21 2 :21,25
narrow

[i] 27 :16 national [4] 7 :13 23 :19 24 :5,7 nationwide [2] 22 :18 23:1 necessarily (i1 14 :16 necessary [i] 27:6 need [1] 29:23 needs [21 28:16 29:15 negligible [1] 25:5 neither [2] 5:6 19:12 network [i] 10:24 networks [i] 10:15 never [i] 19 :9
new [81 8:8,8,8 10:23 12 :8 24 :25 26:19 28:23 News [1] 3 :22 next [3] 2:21 3 :4 5:9 nicely [1] 29:20 nitrogen [i] 6

:4 non-starter [i] 32 :18 none [3] 15 :14,17 37 :4 nonflammable [2] 27:13 28:6 nor[i] 5 :6 Northeast [2] 8:4 16:7 Notary [i] 38 :3 nothing [2] 5:1 38:8 notice [61 1 :15 3 :17,22 3 :24 9:13 13 :4
now [6] 5 :8 14:1 17 :16 20:14 23 :10 33 :18 number [io] 10:2 11 :22 21 :1 23:2,5 25:4 30:18 32:6 34:6 36:9

-0- object [1] 28:14 obligations [i] 9 :9 obvious [1] 36:5 occasionally [1] 25 :6 off (i] 33 :13 officer [2] 1 :12 2 :19
one [i9] 8:14 11 :14 13 :9 18:1 20:13 21 :13 22 :23 25 :25 26 :8,20 27 :4 28:19 28:20 29 :13 31 :5 32 :21 32 :22 33 :9 35 :24
onerous [2] 6:22 8:21
ones [2] 11 :24,25 open [21 4:3 31 :24 operate [i] 14:6 opponents [1] 5 :5 opportunity [3] 5 :11 30:10 33 :15

, opposed [i] 24:6 opposition [i] 19 :13 option [7] 9

:4 23 :17 32 :21,22 33 :8 36:12,16 options [i] 32 :13 organic [9] 1 :7 2 :17 6:1 6 :3,15 7 :8 24:18 34 :2,11 organization [i] 31 :21 OTC [171 8:6 16:3 18:23 19:3 20:9 21 :16,16 22 :13 23 :25 27 :6 29:8 31 :3,23 32 :13 33 :1,1,17 OTC's [11 31 :21 outcome [i] 38:14 oxides [i] 6 :4
ozone [9] 6:5,5,12 8:3 20:18 31 :6,8 32 :2 33 :2 

### _P_

~ P[21 38:3,21 p.m [i] 4 :3 packages [i] 13 :16 packet [41 13 :12 14 :21 ]4 :22 18:8 page [71 13 :12 14 :19 17 :20 18:8 19:8 26:18 28:22 pages (i] 14 :20 paint [2] 17 :721 :10 paramount [2] 22

:19 24 :10 part [4] 3 :16 17 :2 34 :20 35 :2 particularly [i] 25:16 parties fil 5:6 pass [i] 16:2 passed [2] 10:18 12 :9 patchwork [i] 22 :24 pay [i] 13 :4 Peggy [l] 3:1 Pennsylvania [i] 24 :25 people [2] 28:1 31 :16 per [s] 7 :23 8:12 9:16,17 9:25 percent [7] 7 :12,14,22 17 :10,13,13 18 :13 perchloroethylene [i] 27 :11 performance p] 9:14 perhaps [1] 5:20 person [1] 38:14 personal [i] 7

:3 personally [i] 38 :5 personnel [i1 21 :25 persons [2] 3:23 4:22 perspective [1] 24

:7 pertains [3] 21 :12 31 :1 32 :23 pest [i] 15 :3 pesticide [5] 13 :24 14 :24 15 :16 20:24 26:11 

## CondenseIt! T' pesticides [3] 13 :15,18 15 :11 photoreactive [i] 25:5 physical [1] 6:13 pick [i] 28:5 piecemeal [i] ]6:1 place [31 8

:6 36:9,11 places [1] 7:19 plan [4] 3 :14 4

:21,23 5:7 Planning [i] 5:23 plans [i] 9

:6 play [2] 15 :9 17 :3 Plummer [281 1 :12 2 :13 5 :3,17 9:22 11 :4,19 12 :19 13 :7,9,14,21 14:1,9 15 :21 17 :18 19:1,7,16 30:15 33 :23 34 :10,15 36 :18,21 36:23,25 37 :3 plus [i] 35 :21 podium

[i] 5:9 point [3] 12 :15,16 35 :2 points [i] 20 :6 pops [i] 36:3 Portland [21 2 :25 3 :21 possible [2] 23 :17 28:4 potentially [4] 12 :23 22 :24 24 :12 35:4 practical [2] 24 :10 27 :22 premised [i] 21 :17 prepare [i] 4 :18 presence [1] 6

:4 present [2] 3:7 30:10 presentation [i] 5:10 presentations [i] 5:4

~ presented [i] 4:14 presently [i] 4:15 presiding [2] 1 :12 2:18 Press [1] 3 :21 pressurized [1] 17 :1 pretty [1] 10:5 previous [i] 14 :22 proactive [i] 11 :1 problem

[51 27 :18 29:20 31 :8 35 :11,15 problems [2] 6:10 33 :21 Procedures [i] 5 :3 process [6] 8:9 12 :1,6,8 23 :22 31 :24 produced [i] 9:25 producers [i] 10:10 product [211 7 :11,13,17 7 :19 9 :5,14,15 12 :22 14 :24 15:8 16:18 17 :20 21 :23 26 :5 27 :14 28:12 28:21,22 29:14,17 31 :1 products [69] 1 :8 2 :18 6 :2,16,20,23,23,24 7 :3,3 7 :4,5,6,7,10,18 8 :11,16 8 :18,25 9:11,17 10:12,17 10:21 11 :2 12 :3 13 :3 14 :5 14 :13,25 16:17,25 17 :25 18:16 19:9,14,19,23,23 20:4,20,21,22 21 :1,2,3,4 21 :8,8,9,13 22 :5,6,7,12 22 :18 23 :1,12,20 25 :22 25 :25 26 :7,8 27 :2,13,16 32 :3 36:14 Program

[i] 5:23 propellant [2] 7 :8 17 :2 properly [i] 13 :16 proponents [i] 5:4 proposal [1] 23 :7 proposals [i] 32 :8 proposed [17] 2:15 4:10 5 :13,25 6 :13,18 7 :24 8:2 8 :12 9:18 11 :7 20:1,3 24 :14 27 :9 29:12 30:19 proposing [s] 20:11 23 :25 24:3 prospects [i] 32 :9 Protection [n] 1 :2 2:2 2 :14,16 4:19 5 :23 20:23 23 :18 24 :20 26 :9 32 :1 provide [i] 25:24 provided [2] 16:10 22 :10 provides [2] 27 :6 31 :7 providing [1] 26:25 provision [i] 26

:2 provisions [7] 9

:2 20:8 21 :19 24:9 25:23 26:1 27 :3 public [61 2:9,15 3 :11 4 :7 38:3,22 published [i] 3:18 pull [i] 18:3 purpose [1] 26:25 pursuant [3] 1 :15 3:10 3:16 pursue [i] 18:25 put [6] 24:15,19 33 :2 34:5 36:9,11 II

quality [61 3:15 4

:5 5 :16 5:23 9:14 22:3 quantities [3] 17 :25 18:3 18:10 questions [13] 5 :12,14 9:21,22,24 11 :19 13 :7 19:8,11 30

:14,16 33 :23 36 :25 quite [7] 12 :9 21 :1,20 22 :3 23 :8 28:4 35 :9 quote [i] 27 :4

### -Rraise [i] 4 :24 raised [i] 20:6 raises (1] ]4:7 raising [i] 36:16 range [2] 19:20 22 :17 rate [i] 16:24 rather [2] 22 :23 31 :4 RE [i] 1 :7 reaching [1] 17 :15 react 1j] 6

:3 read [11 27 :24 

### must - require reading [il 36:5 real [i] 31 :5 realities [i] 27 :22 really [7] 16:10 17 :5,23 18 :329:1532:1835:13 reasonable [4] 22:3 23 :8 26:5 30:3
reasons [2] 28:15 33 :7 receive [3] 4 :16 26:8,11 recommendation [i] 4 :]2 record [5] 4 :2,7,9 6:21 38:10 recorder p] 3:5 recording [2] 3:6 6:22 reduce [31 6

:6 8:13 17 :6 reduced [1] 7:21 reduces p] 7 :13 reduction [s] 10:2,8 24:1 reductions [i] 17 :14 reference [2] 25:1 26:20

~ referencing [1] 35 :12 referred [i] 28:24 reformulate [3] 23 :11 25:21 26 :7 regarding [2] 17 :21 20:20 Region [1] 8

:6 regional [3] 10

:14 23 :3,9 registered [i] 21 :2 regular (2] 2:11,12 regularly-scheduled [i] 4:11 I regulated [5] 20:20,21 21 :10 25 :24 27 :2 regulates [i] 21 :8 regulation [23] 6:2 7 :10 9:7 19 :25 20:1,3,8,22 21 :7 21 :14,14 22 :19 23 :6,10 24 :24 25 :21,24 26:5 28 :25 30:5 34 :14 36:11,14 regulations [1o] 3 :17 7 :9 8 :10 14 :10 21 :17,21,23 22 :25 24:11 35 :2 regulatory [1] 3 :24 related [2] 14:6 26

:1 relatively [21 25:3 36:6 relevant [i] 36:15 rely [i] 24:5 remain [i] 4:3 remember [2] 13 :10 14 :2
remove p] 28:10 rephrase [2] 22 :7 34:8 report [1] 22 :10 Reporter/Notary (i] 38:22 reporting [1] 9

:1 represent [21 23 :4 25:18 represents [3] 19:20 22:16 23:2 request [2] 4 :13 27:1 requests [i] 9:3 require [2] 9:2 15 :3 

### Index Page 4Irequired [il 8:15

requirement pi 8:20 requirements [sl 3:16 6:21 8 :20 9:15 22 :14 resolved [21 29:24 35 :11 resolves [1l 29:19
resources [41 21 :6,15 22 :1,10 respiratory [31 6 :6,10 6:12 respond [il 5

:2 responsible [2] 8:11,24 restricted [2] 15:6 33 :6 restriction [31 27 :9 28:10 33 :3 restrictions [1l 28:13 result [21 7 :7 13 :1 retail [2] 6:23 9:1 retailer [il 10:20 retailers [3] 9:10 10:10 10:25 retention [il 26:13 review [il 26:6 reviewing [il 31 :16 revised [61 20:9 21 :16 23 :25 26:19 27 :1 28:10 revises pi 23 :19 revising [31 23 :23,23 24 :17 revision [il 3:13 revisions [31 20

:9,18 30:8 Rhode [i] 8:8 Richard [il 2 :23 right [8l 2 :20 3 :1 4 :24 13 :2,6 17 :8 20:14 29:21 risk [ii 6:10 river p1 2:10 Ron [i] 3:8 room[il 4:15 rule [6ol 4 :13 5 :13 6:17 7 :16,20,21,21 8:2,22 10:12,16,22,24 11 :12 14 :14 15 :22,23,23 16:5 16:11,19 17 :8,21,23 18:8 18:24 19:4 20:9,19 21 :3 23 :20,20,23 24:6,6 26:2,3 26:3,4,19,21,22,25 27 :1 28:10,25 29:1,2,11,12 30:1,8,19,20 31 :25 32 :11 32 :13 34 :21,22 35 :5 rulemaking [41 12:8 20:11,12,14 rules [91 4 :1,17,18 8:5 15 :24 16:2 31 :22 32:3 34 :24 

### _S_ safety [2] 28 :9,15 sale [21 8 :25 13 :15
save [il 24:3 says [21 29:13,13 scale [21 17 :4 22 :13 scaled [il 21 :18 schools [1l 7:2 Scoff [i41 3 :1 9:24 10:2,7 11 :3 12 :20,24 13 :6,8 14 :7 14 :10,17 15 :11,19 'sealants [il 7 :5 seasonal [i] 16:22 seated [1] 3 :4 second [sl 5 :5 14 :20 23 :16 25 :13 29:13 Secondly[l] 20:19 section [sl 3 :11,12 26:19 28:23 34 :14 35:8 See [61 6:17 12 :22 17 :11 29:11 32 :16 33 :22 seeing [2] 16:11 37 :4
seem [l] 30:17 sell [21 10:21 19:22 send [ii 8:23 sensibilities p] 16:9 sent [21 3 :23 10:19 sentence [i] 17 :21 Sentinel [il 3 :21 separate [i] 34 :13 September [31 7 :15 28:24 38:18 Services [il 3 :7 set [41 20:2 22 :23 32 :19 38:17 settings [1l 7:1 several [21 28:18 29:23 Severance [1] 3:8 shall [il 4:3 sheet [31 4 :14,16 5 :9 shops [1l 7:1 shorthand [il 38:11 side [i] 5 :13 sign [il 5:8 significant [sl 22:2 28:21 29:5 similar [sl 8:10 9

:7 22 :16 24:21 35 :23 six [il 28:11 size [il 15 :8 slight[l] 24 :11 small [61 10:5 12 :24 15 :7 17 :25 23 :2 25 :16 sold [21 6:23 19:23 solids [11 7 :g solvents [21 28:13 33 :3 sometimes [21 27 :12,25 somewhere [i] 13 :22 sorry [31 7 :23 18:17 19:3 sort [21 15 :25 20:15 sources p1 3 :25 South [il 2 :25 speak [41 5 :7 16:24 19:1 37 :4 speaker [l] 19:12 speakers' p1 5 :8 Specialty [2] 19:13,18 specific [sl 24:6 27 :16 29:6 32 :14 34 :24 

## CondenseIt! ' specifically [sl 19 :4 25 :17 27 :11 30:25 36:19 specified [11 27 :4 staff [31 3 :9 4 :12 21 :20 staffers [il 21 :22 stage [i] 20:7 

### stakeholder [z] 16:5 31 :23 stakeholders [21 30:2,7 stand [i] 4 :23 standard [l] 35 :18 standards [i31 20:2 22 :20,22,23 23:13 24:8 27 :5 29:2,3,10,11,19 35 :17 Starks [i] 2 :20 start [21 2 :8 23:14 started [41 12:9 17 :14 20:11,12 starting [il 20:14 state [2s1 1 :1 3 :14 4 :20 7 :14,219:7 10:17,20 12 :6 20:7,17,25 21 :24 22 :25 24:6,11 26:4 27 :1 29

:9 32 :14,20 33 :12,13 35 :15 38:4 states [19] 8:4 9:19 10:15 10:25 11 :8,10,22,24 12 :2 12 :14 20:15 23:19 24:24 27 :20 31 :8 33 :14,17 35 :10 35 :23 statewide [31 21 :9,13 35 :21 statute [i] 21 :14 step [2] 25 :9,12 Still [21 18:9,16 stocking [1l 9

:11 straight [ii 27:5 straightforward [il 25 :2 stringent [2] 7 :20 22 :22 structural [il 15 :3 structure [il 16:11 sub-category [il 27 :16 subject [9] 4:1 9:8 20:22 21 :4,13 23 :6,10 27 :3 28:12 subjected [2] 18 :11 21 :3 I submit [41 8 :16 9:2 32 :17 33 :16 submittal [il 4 :19 submitted [i1 3 :13 submitting [2] 9 :4 29:22 Subsection [1l 28:23 substantially [1] 17 :7 such [51 7 :1 21 :9 24:24 27 :22 34 :7 Sue [21 2 :24 11 :20 sufficient [il 23 :11 suggest [41 24 :16 26:14 28:9 32 :22 suggesting [2] 33:9 36:12 suggestions [i] 34:1 summary [3] 19:25 29:24 30:2 Sun [1l 3:20 sunlight[l] 6

:4 support [41 19

:12,12 26:13 27 :8 supports [1] 25 :23 supposed [i] 27 :19 surface [21 28:7,7 surfaces [il 27 :21 surprised [i] 17 :5 surprising [il 31 :13 swath [il 11 :13
sworn [21 4 :23 38:7 symptoms [i] 6:12 system

[1l 6 :6

-Tt [il 36 :1 table [5l 5 :13 6 :17 27 :5 29:11,19 taking [il 14 :19 technical [71 26:14,15 28:19 29:5,23 31 :10,17 technologically [il 9:20 technology [21 22 :22 30:4 term [3] 28:22 29:14 30:25 termites [i] 15 :5 terms [8] 14 :4 15 :6 21 :6 21 :7,25 30:22,24 32:21 Terry [il 3:5 testify [31 4 :23 33 :15 38:7 testimony [31 4:4,25 5:15 thank [14] 5

:3 11 :3,18 13 :8 15 :19 18:22 19:11 19:16 30:9,15 34:9 36:24 37 :1,2 theirs [51 11 :10 12 :9,10 12 :11,14 they've [il 12 :7 thinking [il 36:1 third [21 5 :5 25 :23 thorough p] 31 :10 three [11 32 :13 threshold [i] 23 :15 through [5l 5 :12 12 :7,7 15 :16 26:7 throughout [il 32 :5 times pi 16:3 Title [il 3:16 today [6] 2 :8,15,20 3 :5 5 :24 16 :12 today's [7] 2 :19 3 :10,15 3 :18,22 4 :2,7 ton [21 8:14 10:5 tons [61 7 :23 8:11 9:25 16:14,22 17 :9 took [51 16:3 21 :17 26:22 

### required - VOC 29:3,3 tough [3] 22 :21 23 :12 33 :17 toxic [31 6:19 8:1 33 :4 transcribed[l] 4 :8 transparent [2] 9:12 31 :24 transport [sl 8:3 20:19 31 :6,8 32:2 tree [1] 17 :16 true [2] 20:25 38:9 truth [51 4:25 5:1 38 :7,7 38:8 truthfully [2] 21 :1,20 try [il 9:21 trying [ij 33 :20 turn [i] 18:7 two [9] 7 :22,23 17 :9 22 :8 22 :11 26:6 29:12 32 :21 35 :24 two-tenths [31 8:14 10:4 10:8 two-thirds [21 20:2,2 type [2] 10:21 15 :8 types [41 7 :2,18 19:22 21 :9 

### _U_ U .S [51 4 :19 20:23 23 :18 24:20 26:9 under [81 10:12 13 :23 14 :10,14,15,18 15

:12 20:3 undercuts [i] 26:24 undermines [il 26:24 understand [21 1 o:11 15 :25 understandable [il 22:13 Unfortunately [21 26 :23 34:4 uniform

[41 22 :23 24:7,8 24 :23 uniformity [21 22:19 33 :19 unless [s] 11 :9 13 :4 34 :24 untenable [i] 23 :1 unworkable [i] 24 :12 up [41 9:16 17 :16 19

:2 28:5 urge [i] 23 :15 used [61 16:4 18:2,14 27 :12,20,21
uses [4] 18:1,4,15,20 usually [il 34 :23 

### _V_ variances [il 9:5 version [il 10:19
versus [31 16 :10 28:2 32 :24 Virginia [21 1 :12 8:9 VOC [ia] 7 :6,14,20,21



### Index Page 5

## CondenseIt! "" VOCs - Ziegler

8:12 9 :18 14 :5 16:15 17 :2 21 :18 22 :15 24 :12,18,22 25 :25 27 :3,17 31 :2 VOCS [6] 6 :3 9:25 17 :6 24:2 32 :12 36:15 volatile [8] 1 :7 2 :17 6:1 6:3,14 20:19 24:18 34 :2 volatility pi 34 :11 vote p] 4 :10

# -wwait pi 18:16 Waterville [il 3:20 ways [i] 32 :7 whereas pi 25 :9 

### WHEREOF [1l 38:17 whole [2] 17 :23 38:7 wholesale [21 6 :25 9:1 wide [i] 22 :17 wish [21 4 :16 37 :4 within [31 7:19 32 :2,11 within-named pi 38:6 

### WITNESS [1l 38:17 witnesses [2] 5:2 38:6 wondered [il 10:7 worked [2] 15 :16 30:1 write [11 15 :23 writing [il 16:4 written [6] 4:2,4 26

:16 - 29:22 33 :16 36:18 wrong [i] 29:7

### -yyear [61 9:17 12 :12,13 25 :25 26:20 27:4 years [i] 36:10 yet [21 12 :10 32 :6 York p1 8:8 Yost 116] 19:13,15,18 22 :6 30 :21,24 31 :23 32 :10 32 :17 34 :4,13 35 :7,19 36:21,24 37 :2 yup [sl 13 :13 14:2 15 :14

### -ZZiegler [il 2:25



### Index Page 6