The Great Lakes Coal Tar Sealcoat PAH Reduction Project: Comments and Recommendations of the Pavement Coatings Technology Council

Comments Submitted to EPA Region 5 and State Agencies Involved in the Great Lakes Coal Tar Sealcoat PAH Reduction Project

The Minnesota Pollution Control Agency and the other Collaborators in the “Sealcoat PAH Reduction Project” received an EPA grant to run the program. They are not being paid to determine whether coal tar sealants should be replaced with asphalt sealants. Apparently, that determination has already made by someone or a group of people at EPA Region 5 whose identities are unknown. What those people at the EPA relied upon in arriving at their determination is also unknown. What is known is that neither the PCTC nor any other trade organization or stakeholder representing the RTS industry had an opportunity to present its position to the EPA. There was no hearing, no solicitation of comments, and no draft proposal. Just a determination that coal tar sealants should be replaced and a group of willing Project Collaborators who have agreed to accept tax dollars to pursue this agenda. With the usual avenues for comment and interaction with government agencies thus closed, PCTC submits comments to the Project organizers and the public at large. Read details in full cover letter here and the detailed comments and recommendations here