UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Rulemaking

for the

California State Implementation Plan

Feather River Air Quality Management District Rule 3.15

Architectural Coatings

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

September 2015
1

RULE IDENTIFICATION -

Agency Feather River Air Quality Management District (FRAQMD)

SIP Approved 

Rule

Sutter County Air Pollution Control District (SCAPCD)

Rule 3.15 - Architectural Coatings.

Submitted - January 28, 1981.

EPA Approved - May 3, 1982 (47 FR 18856).

Yuba County Air Pollution Control District (YCAPCD)

Rule 3.15 - Architectural Coatings.

Submitted - March 30 1981.

EPA Approved - November 10, 1982 (47 FR 50865).

Subject of this 

TSD

Rule 3.15 - Architectural Coatings.

Amended - August 4, 2014.

Submitted - November 6, 2014.

Completeness 

Finding

Date of Completeness Letter - December 18, 2014.

BACKGROUND

According to the Staff Report associated with adoption of this rule, “Feather River

Air Quality Management District (District) is a Bi-County agency that administers

local, state, and federal air quality management programs for Yuba and Sutter

Counties which had separate air pollution control districts (APCD) each with its 

own state implementation plan (SIP) approved architectural coating rule. Because

portions of the FRAQMD have been designated as nonattainment for failure to

meet the federal 8-hour ground-level ozone standard, the United States

Environmental Protection Agency (EPA) requires the District to implement

measures to reduce ozone precursors.”

1 Before the FRAQMD was created, both 

the SCAPCD and the YCAPCD had an architectural coatings rule that was SIP 

approved in 1982. The new FRAQMD Rule 3.15 will supersede the SCAPCD Rule 

3.15 and YCAPCD Rule 3.15 in the SIP.

Architectural coatings are considered area sources of VOC and are not subject to 

federal Clean Air Act (CAA) section 182(b)(2) reasonably available control 

techniques (RACT) requirements, since there are no major architectural coating 

sources and there are no relevant EPA control techniques guidelines (CTG) 

documents. There are, however, national VOC content limits for architectural 

coatings that apply largely to coating manufacturers, importers and purveyors. 

These limits are described in Code of Federal Regulations, Title 40, Part 59.400, 

Subpart D - National Volatile Organic Compound Emission Standards for 

Architectural Coatings (40 CFR §59.400). 

 

1. Staff Report Rule 3.15, Architectural Coatings, FRAQMD, July 3, 2014.
2

FRAQMD has adopted the California Air Resources Board (CARB) 2007

Suggested Control Measure (SCM) for Architectural Coatings as a template for

Rule 3.15, which contains significantly more stringent VOC limits than 40 CFR 

§59.400.

2

The intent of the amendments to Rule 3.15 is to reduce VOC emissions from

coatings used in the painting of buildings and other structures. The District 

expects the proposed amendments to Rule 3.15 will reduce VOC emissions by 

approximately 1.095 tons per year.3

RULE SUMMARY - FRAQMD Rule 3.15 controls VOC emissions from 

architectural coatings by establishing VOC limits on any architectural coating that 

is supplied, sold, offered for sale or manufactured for use within the FRAQMD. 

Architectural coatings are coatings that are applied to stationary structures and 

their accessories. They include house paints, stains, industrial maintenance 

coatings, traffic coatings, and many other products. VOCs are emitted from the 

coatings during application and curing, and from the associated solvents used for 

thinning and clean-up.

EVALUATION CRITERIA -

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency –As discussed above, FRAQMD Rule 3.15 has no obligation to 

implement RACT because architectural coating is an area source and there 

is no relevant CTG guidance. Nonetheless, we have evaluated the rule for 

RACT-level controls and against 40 CFR Part 59 Subpart D, and CARB’s

SCM, which is the basis for most of the most stringent architectural coating 

requirements in California.

3. SIP Relaxation - CAA §110(l) prohibits EPA from approving any SIP revision 

that would interfere with any applicable requirement concerning attainment 

and reasonable further progress (RFP) or any other applicable requirement 

of the CAA. In addition, CAA §193 prohibits the modification of any SIPapproved control requirement in effect before November 15, 1990, in a 

nonattainment area.

In applying these criteria to the submitted rule, we referred to the following 

guidance and policy documents:

 

2. 40 CFR Part 59 Subpart D, Table 1.

3. Staff Report, FRAQMD Rule 3.15, Architectural Coatings, July 3, 2014.
3

1. Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations

(the "Blue Book"), US EPA, OAQPS (May 25, 1988).

2. Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies, EPA Region IX (August 21, 2001, the “Little Bluebook”).

3. State Implementation Plans; General Preamble for the Implementation of 

Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 

1992); 57 FR 18070 (April 28, 1992).

4. Final Rule To Implement the 8-Hour Ozone NAAQS – Phase 2, 70 FR 

71612 (Nov. 25, 2005).

EPA EVALUATION - A summary of our evaluation of the three criteria follows.

1. To help ensure enforceability, the rule requirements and applicability are 

clear, and the monitoring, recordkeeping, reporting and other provisions 

sufficiently ensure that affected sources and regulators can evaluate and 

determine compliance with Rule 3.15 consistently. 

2. Rule 3.15 is as stringent as the SCM and more stringent than 40 CFR Part 

59 Subpart D. Therefore, we determine that it implements RACT-level 

controls. 

3. Rule 3.15 is more stringent than the existing requirements in the old SIPapproved versions of SCAPCD Rule 3.15 and YCAPCD Rule 3.15. 

Therefore, we propose to determine that our approval of the submittal would 

comply with CAA §§110(l) and 193 because (1) the proposed SIP revision 

would not interfere with the on-going process for ensuring that requirements 

for RFP and attainment of the NAAQS are met, and (2) the emission limits 

in the submitted rule are more stringent than the existing SIP-approved 

control requirements that they would replace. 

RULE DEFICIENCIES - We find no deficiencies with Rule 3.15 to preclude a full 

approval of Rule 3.15.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION - The 

following revision is not currently the basis for rule disapproval, but is 

recommended for the next time the rule is amended:

To prevent the practice of “bundling” small containers, we recommend replacing 

paragraph A.4(b) with the following text:

With the exception of containers packed together for shipping to a retail outlet, 

warehouse, or a military distribution or redistribution facility, this rule does

not apply to any architectural coating that is sold in a container with a
4

volume of one liter (1.057 quart) or less provided the following requirements

are met:

a. The container is not bundled together to be sold as a unit that

exceeds one liter (1.057 quarts), excluding containers packed

together for shipping to a retail outlet.

b. The label or any other product literature does not suggest

combining multiple containers so that the combination exceeds

one liter (1.057 quarts).

EPA ACTION – The submitted Rule 3.15 strengthens the SIP, and the associated 

District staff report projects that it will reduce VOC emissions by approximately

1.095 tons per year. The rule fulfils the relevant CAA §110 and part D 

requirements. Therefore, EPA staff recommends full approval of Rule 3.15

pursuant to CAA §110(k)(3) and §301(a)

REFERENCES

1. SCAPCD Rule 3.15, Architectural Coatings, submitted January 28,1981 

and approved by the EPA May 3, 1982 (47 FR 18856).

2. YCAPCD Rule 3.15, Architectural Coatings, submitted March 30, 1981 and 

approved by the EPA November 10,1982 (47 FR 50865). 

3. FRAQMD Rule 3.15, Architectural Coatings, Adopted June 19, 2014,

Submitted November 6, 2014.

4. Staff Report Rule 3.15, Architectural Coatings, FRAQMD, July 3, 2014.

5. CARB SCM for Architectural Coatings, Approved October 26, 2007.

6. EPA’s National Volatile Organic Compound Emission Standard for 

Architectural Coatings (40 CFR Part 59 Subpart D).

7. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 

(http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf).

8. “Guidance Document for Correcting Common VOC & Other Rule

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf).

9. 40 CFR §81.305.