April 15, 2011 Alexander Ryan-Bond Environmental Associate Ozone Transport Commission 444 North Capitol St. NW, Suite 638 Washington, DC 20001 arbond@otcair.org Subject: Solvent Degreasing Raymond Regulatory Resources (3R) appreciates the opportunity to comment on the Ozone Transport Commission (OTC) proposed Model Rule on Solvent Degreasing. In addition 3R appreciates the efforts of the OTC to delay the adoption of this Model Rule to accept supplemental comments as discussed in the March 16 meeting in Baltimore. During the meeting Ali Mirzakhalili requested the need for the industry to supply specific changes that are needed to the rule. On February 28, 2011, 3R sent correspondence to you on this Model Rule. In an effort to not repeat these issues, the following suggestions are in response to Mr. Mirzakhalili plea for specific changes. Reasoning for these changes were detailed in my February 28 letter which was based on a review of District regulations in California. The Model Rule 2011 should add the following Exempt up to 110 gallons per year of non-compliant solvent usage per establishment. Exempt niche applications for the following o Medical o Optics o Electronics o Aerospace o Precision cleaning Provide an alternative Reactivity limit using Maximum Incremental Reactivity limit Exempt Aerosol Products from the rule Incorporating the above changes will lesson the regulatory burden on smaller and specialty establishments as well as lesson the enforcement challenges for the agency on small volume user. Thank you for your attention to this issue and I look forward to working with you on this. Any questions or comments feel free to call or e-mail. Doug Raymond Raymond Regulatory Resources (3R), LLC Home office: 440-474-4999 Mobile: 440-339-4539 djraymond@reg-resources.com