Comment Log Display

October 23, 2006

Clerk of the Board
Air Resources Board
1001 I Street
P.O. Box 2815
Sacramento, California  95812

Subject:  Rubber & Vinyl Protectant Definition Change

Dear Clerk of the Board,   


Four Star appreciates the opportunity to comment on the current
rulemaking.  Four Star is a small business in California and a
filler of aerosol products.  We fill products for the automotive
market.  Our customers rely on us to formulate effective and
efficient products for the consumer’s use.

The proposed change in the Technical Support Document involving
the Rubber and Vinyl Protectant will have a substantial impact on
our tire coating product. The proposed change will classify our
coating product as a protectant.  Our coating product will not be
effective at the VOC level for protectants.  Currently our coating
product meets the aerosol coating regulation definition of
containing a resin and producing a film.  If the proposed
definition is not modified our product will be banned.

Furthermore, Four Star was under the understanding that the Rubber
and Vinyl Protectant (aerosol) was not to be surveyed until the
next survey.  However, the Technical support document states that
some marketers reported early.  Was there a formal notice of this
survey?  Four Star was unaware of this opportunity. We request
that this issue be postponed until the next survey as previously
noticed.

Thank you for your time and consideration to this issue.  

Sincerely,

 
Jerry Ulrich                                           
Four Star Chemical                                       
President            









cc:	Robert D. Fletcher, P.E., Division Chief, Stationary Source
Division
	Robert D. Barham, Ph.D., Assistant Division Chief, Stationary
Source Division
	Janette M. Brooks, Chief, Air Quality Measures Branch, Stationary
Source Division
	David Mallory, Manager, Measures Development, Stationary Source
Division