2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX B:

2000 SUGGESTED CONTROL MEASURE FOR
ARCHITECTURAL COATINGS2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 072000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-1 Sept - 07 

### California Air Res ources Board (ARB) Suggested Control Measure for Architectural Coatings

1. APPLICABILITY

1.1 Except as provided in subsection 1.2, this rule is applicable to any person who supplies, sells, offers for sale, or manufactures any architectural coating for use within the District, as well as any person who applies or solicits the application of any architectural coating within the District.

1.2 This rule does not apply to:

1.2.1 Any architectural coating that is sold or manufactured for use outside of the District or for shipment to other manufacturers for reformulation or repackaging. 1.2.2 Any aerosol coating product. 1.2.3 Any architectural coating that is sold in a container with a volume of one liter (1.057 quart) or less.

2. DEFINITIONS

2.0 Adhesive: Any chemical substance that is applied for the purpose of bonding two surfaces together other than by mechanical means.

2.1 Aerosol Coating Product: A pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held application, or for use in specialized equipment for ground traffic/marking applications.

2.2 Antenna Coating: A coating labeled and formulated exclusively for application to equipment and associated structural appurtenances that are used to receive or transmit electromagnetic signals.

2.3 Antifouling Coating: A coating labeled and formulated for application to submerged stationary structures and their appurtenances to prevent or reduce the attachment of marine or freshwater biological organisms. To qualify as an antifouling coating, the coating must be registered with both the U.S. EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. Section 136, et

seq .) and with the California Department of Pesticide Regulation.

2.4 Appurtenance: Any accessory to a stationary structure coated at the site of installation, whether installed or detached, including but not limited to: bathroom and kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand railings; heating equipment, air conditioning equipment, and other fixed mechanical equipment or stationary tools; lampposts; partitions; pipes and piping systems; rain gutters and downspouts; stairways, fixed ladders, catwalks, and fire escapes; and window screens.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-2 Sept - 07 

### 2.5 Architectural Coating: A coating to be applied to stationary structures or their appurtenances at the site of installation, to portable buildings at the site of installation, to pavements, or to curbs. Coatings applied in shop applications or to non-stationary structures such as airplanes, ships, boats, railcars, and automobiles, and adhesives are not considered architectural coatings for the purposes of this rule.

2.6 Bitumens: Black or brown materials including, but not limited to, asphalt, tar, pitch, and asphaltite that are soluble in carbon disulfide, consist mainly of hydrocarbons, and are obtained from natural deposits or as residues from the distillation of crude petroleum or coal.

2.7 Bituminous Roof Coating: A coating which incorporates bitumens that is labeled and formulated exclusively for roofing.

2.8 Bituminous Roof Primer: A primer which incorporates bitumens that is labeled and formulated exclusively for roofing.

2.9 Bond Breaker: A coating labeled and formulated for application between layers of concrete to prevent a freshly poured top layer of concrete from bonding to the layer over which it is poured.

2.10 Clear Brushing Lacquers: Clear wood finishes, excluding clear lacquer sanding sealers, formulated with nitrocellulose or synthetic resins to dry by solvent evaporation without chemical reaction and to provide a solid, protective film, which are intended exclusively for application by brush, and which are labeled as specified in subsection 4.1.5.

2.11 Clear Wood Coatings: Clear and semi-transparent coatings, including lacquers and varnishes, applied to wood substrates to provide a transparent or translucent
solid film.

2.12 Coating: A material applied onto or impregnated into a substrate for protective, decorative, or functional purposes. Such materials include, but are not limited to, paints, varnishes, sealers, and stains.

2.13 Colorant: A concentrated pigment dispersion in water, solvent, and/or binder that is added to an architectural coating after packaging in sale units to produce the
desired color.

2.14 Concrete Curing Compound: A coating labeled and formulated for application to freshly poured concrete to retard the evaporation of water.

2.15 Dry Fog Coating: A coating labeled and formulated only for spray application such that overspray droplets dry before subsequent contact with incidental surfaces in the vicinity of the surface coating activity. 2.16 Exempt Compound: A compound identified as exempt under the definition of Volatile Organic Compound (VOC), subsection 2.60. Exempt compounds2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-3 Sept - 07 

### content of a coating shall be determined by U.S. EPA Method 24 or South Coast Air Quality Management District (SCAQMD) Method 303-91 (Revised February 1993), incorporated by
reference in subsection 6.5.10.

2.17 Faux Finishing Coating: A coating labeled and formulated as a stain or glaze to create artistic effects including, but not limited to, dirt, old age, smoke damage, and simulated marble and wood grain.

2.18 Fire-Resistive Coating: An opaque coating labeled and formulated to protect the structural integrity by increasing the fire endurance of interior or exterior steel and other structural materials, that has been fire tested and rated by a testing agency approved by building code officials for use in bringing assemblies of structural materials into compliance with federal, state, and local building code requirements. The fire-resistive coating and the testing agency must be approved by building code officials. The fire-resistant coating shall be tested in accordance with ASTM Designation E 119-98, incorporated by reference in
subsection 6.5.2.

2.19 Fire-Retardant Coating: A coating labeled and formulated to retard ignition and flame spread, that has been fire tested and rated by a testing agency approved by building code officials for use in br inging building and construction materials into compliance with federal, state and local building code requirements. The fire-retardant coating and the testing agency must be approved by building code officials. The fire-retardant coating shall be tested in accordance with ASTM Designation E 84-99, incorporated by reference in subsection 6.5.1.

2.20 Flat Coating: A coating that is not defined under any other definition in this rule and that registers gloss less than 15 on an 85-degree meter or less than 5 on a 60-degree meter according to ASTM Designation D 523-89 (1999), incorporated by reference in subsection 6.5.3.

2.21 Floor Coating: An opaque coating that is labeled and formulated for application to flooring, including, but not limited to, decks, porches, steps, and other horizontal surfaces which may be subject to foot traffic.

2.22 Flow Coating: A coating labeled and formulated exclusively for use by electric power companies or their subcontractors to maintain the protective coating systems present on utility transformer units.

2.23 Form-Release Compound: A coating labeled and formulated for application to a concrete form to prevent the freshly poured concrete from bonding to the form. The form may consist of wood, metal, or some material other than concrete.

2.24 Graphic Arts Coating or Sign Paint: A coating labeled and formulated for handapplication by artists using brush or roller techniques to indoor and outdoor signs (excluding structural components) and murals including lettering enamels, poster colors, copy blockers, and bulletin enamels.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-4 Sept - 07 

### 2.25 High-Temperature Coating: A high performance coating labeled and formulated for application to substrates exposed continuously or intermittently to temperatures above 204 o 

### C (400 o 

### F).

2.26 Industrial Maintenance Coating: A high performance architectural coating, including primers, sealers, undercoaters, intermediate coats, and topcoats, formulated for application to substrates exposed to one or more of the following extreme environmental conditions listed in subsections 2.26.1 through 2.26.5, and labeled as specified in subsection 4.1.4:

2.26.1 Immersion in water, wastewater, or chemical solutions (aqueous and nonaqueous solutions), or chronic exposure of interior surfaces to moisture condensation; 2.26.2 Acute or chronic exposure to corrosive, caustic or acidic agents, or to chemicals, chemical fumes, or chemical mixtures or solutions; 2.26.3 Repeated exposure to temperatures above 121 o 

### C (250 o 

### F); 2.26.4 Repeated (frequent) heavy abrasion, including mechanical wear and repeated (frequent) scrubbing with industrial solvents, cleansers, or scouring agents; or 2.26.5 Exterior exposure of metal structures and structural components.

2.27 Lacquer: A clear or opaque wood coating, including clear lacquer sanding sealers, formulated with cellulosic or synthetic resins to dry by evaporation without chemical reaction and to provide a solid, protective film.

2.28 Low Solids Coating: A coating containing 0.12 kilogram or less of solids per liter (1 pound or less of solids per gallon) of coating material.

2.29 Magnesite Cement Coating: A coating labeled and formulated for application to magnesite cement decking to protect t he magnesite cement substrate from erosion by water.

2.30 Mastic Texture Coating: A coating labeled and formulated to cover holes and minor cracks and to conceal surface irregularities, and is applied in a single coat
of at least 10 mils (0.010 inch) dry film thickness.

2.31 Metallic Pigmented Coating: A coating containing at least 48 grams of elemental metallic pigment per liter of coating as applied (0.4 pounds per gallon), when tested in accordance with SCAQMD Method 318-95, incorporated by reference in
subsection 6.5.4.

2.32 Multi-Color Coating: A coating that is packaged in a single container and that exhibits more than one color when applied in a single coat.

2.33 Nonflat Coating: A coating that is not defined under any other definition in this rule and that registers a gloss of 15 or greater on an 85-degree meter and 5 or greater on a 60-degree meter according to ASTM Designation D 523-89 (1999), incorporated by reference in subsection 6.5.3.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-5 Sept - 07 

### 2.34 Nonflat - High Gloss Coating: A nonflat coating that registers a gloss of 70 or above on a 60-degree meter according to ASTM Designation D 523-89 (1999), incorporated by reference in subsection 6.5.3.

2.35 Nonindustrial Use: Nonindustrial use means any use of architectural coatings except in the construction or maintenance of any of the following: facilities used in the manufacturing of goods and commodities; transportation infrastructure, including highways, bridges, airports and railroads; facilities used in mining activities, including petroleum extraction; and utilities infrastructure, including power generation and distribution, and wate r treatment and distribution systems.

2.36 Post-Consumer Coating: A finished coating that would have been disposed of in a landfill, having completed its usefulness to a consumer, and does not include manufacturing wastes.

2.37 Pre-Treatment Wash Primer: A primer that contains a minimum of 0.5 percent acid, by weight, when tested in accordance with ASTM Designation D 1613-96, incorporated by reference in subsection 6.5.5, that is labeled and formulated for application directly to bare metal surfaces to provide corrosion resistance and to promote adhesion of subsequent topcoats.

2.38 Primer: A coating labeled and formulated for application to a substrate to provide a firm bond between the substrate and subsequent coats.

2.39 Quick-Dry Enamel: A nonflat coating that is labeled as specified in subsection 4.1.8 and that is formulated to have the following characteristics:

2.39.1 Is capable of being applied directly from the container under normal conditions with ambient temperatures between 16 and 27 o 

### C (60 and
80 o 

### F); 2.39.2 When tested in accordance with ASTM Designation D 1640-95, incorporated by reference in subsection 6.5.6, sets to touch in 2 hours or less, is tack free in 4 hours or less, and dries hard in 8 hours or less by the mechanical test method; and 2.39.3 Has a dried film gloss of 70 or above on a 60 degree meter.

2.40 Quick-Dry Primer, Sealer, and Undercoater: A primer, sealer, or undercoater that is dry to the touch in 30 minutes and can be recoated in 2 hours when tested in accordance with ASTM Designation D 1640- 95, incorporated by reference in
subsection 6.5.6.

2.41 Recycled Coating: An architectural coating formulated such that not less than 50 percent of the total weight consists of secondary and post-consumer coating,
with not less than 10 percent of the total weight consisting of post-consumer coating.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-6 Sept - 07 

### 2.42 Residence: Areas where people reside or lodge, including, but not limited to, single and multiple family dwellings, condominiums, mobile homes, apartment complexes, motels, and hotels.

2.43 Roof Coating: A non-bituminous coating labeled and formulated exclusively for application to roofs for the primary purpose of preventing penetration of the substrate by water or reflecting heat and ultraviolet radiation. Metallic pigmented roof coatings which qualify as metallic pigmented coatings shall not be considered to be in this category, but shall be considered to be in the metallic pigmented coatings category.

2.44 Rust Preventative Coating: A coating formulated exclusively for nonindustrial use to prevent the corrosion of metal surfaces and labeled as specified in subsection
4.1.6.

2.45 Sanding Sealer: A clear or semi-transparent wood coating labeled and formulated for application to bare wood to seal the wood and to provide a coat that can be abraded to create a smooth surface for subsequent applications of coatings. A sanding sealer that also meets the definition of a lacquer is not included in this category, but is included in the lacquer category.

2.46 Sealer: A coating labeled and formulated for application to a substrate for one or more of the following purposes: to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by
materials in the substrate.

2.47 Secondary Coating (Rework): A fragment of a finished coating or a finished coating from a manufacturing process t hat has converted resources into a commodity of real economic value, but does not include excess virgin resources of the manufacturing process.

2.48 Shellac: A clear or opaque coating formulated solely with the resinous secretions of the lac beetle ( Laciffer lacca ), thinned with alcohol, and formulated to dry by evaporation without a chemical reaction.

2.49 Shop Application: Application of a coating to a product or a component of a product in or on the premises of a factory or a shop as part of a manufacturing, production, or repairing process (e.g., original equipment manufacturing coatings).

2.50 Solicit: To require for use or to specify, by written or oral contract.

2.51 Specialty Primer, Sealer, and Undercoater: A coating labeled as specified in subsection 4.1.7 and that is formulated for application to a substrate to seal fire, smoke or water damage; to condition excessi vely chalky surfaces, or to block stains. An excessively chalky surface is one that is defined as having a chalk rating of four or less as determined by ASTM Designation D 4214-98, incorporated by reference in
subsection 6.5.7.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-7 Sept - 07



### 2.52 Stain: A clear, semitransparent, or opaque coating labeled and formulated to change the color of a surface but not conceal the grain pattern or texture.

2.53 Swimming Pool Coating: A coating labeled and formulated to coat the interior of swimming pools and to resist swimming pool chemicals.

2.54 Swimming Pool Repair and Maintenance Coating: A rubber based coating labeled and formulated to be used over existing rubber based coatings for the repair and maintenance of swimming pools.

2.55 Temperature-Indicator Safety Coating: A coating labeled and formulated as a color-changing indicator coating for the purpose of monitoring the temperature and safety of the substrate, underlying piping, or underlying equipment, and for application to substrates exposed continuously or intermittently to temperatures
above 204 o 

### C (400 o 

### F).

2.56 Tint Base: An architectural coating to which colorant is added after packaging in sale units to produce a desired color.

2.57 Traffic Marking Coating: A coating labeled and formulated for marking and striping streets, highways, or other traffic surfaces including, but not limited to, curbs, berms, driveways, parking lots, sidewalks, and airport runways.

2.58 Undercoater: A coating labeled and formulated to provide a smooth surface for subsequent coatings.

2.59 Varnish: A clear or semi-transparent wood coating, excluding lacquers and shellacs, formulated to dry by chemical reaction on exposure to air. Varnishes may contain small amounts of pigment to color a surface, or to control the final sheen or gloss of the finish.

2.60 Volatile Organic Compound (VOC): Any volatile compound containing at least one atom of carbon, excluding carbon m onoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, and excluding the following: 2.60.1 methane; methylene chloride (dichloromethane); 1,1,1-trichloroethane (methyl chloroform); trichlorofluoromethane (CFC-11); dichlorodifluoromethane (CFC-12); 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113); 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114); chloropentafluoroethane (CFC-115); chlorodifluoromethane (HCFC-22); 1,1,1-trifluoro-2,2-dichloroethane (HCFC-123); 2-chloro-1,1,1,2-tetrafluoroethane (HCFC-124); 1,1-dichloro-1-fluoroethane (HCFC-141b); 1-chloro-1,1-difluoroethane (HCFC-142b);2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-8 Sept - 07 

### trifluoromethane (HFC-23); pentafluoroethane (HFC-125); 1,1,2,2-tetrafluoroethane (HFC-134); 1,1,1,2-tetrafluoroethane (HFC-134a); 1,1,1-trifluoroethane (HFC-143a); 1,1-difluoroethane (HFC-152a); cyclic, branched, or linear completely methylated siloxanes; the following classes of perfluorocarbons: (A) cyclic, branched, or linear, completely fluorinated alkanes; (B) cyclic, branched, or linear, completely fluorinated ethers with no unsaturations; (C) cyclic, branched, or linear, complete ly fluorinated tertiary amines with no unsaturations; and (D) sulfur-containing perfluorocarbons with no unsaturations and with the sulfur bonds only to carbon and fluorine; and 2.60.2 the following low-reactive organic compounds which have been exempted by the U.S. EPA: acetone; ethane; parachlorobenzotrifluoride (1-chloro-4-trifluoromethyl benzene); perchloroethylene; and methyl acetate.

2.61 VOC Content: The weight of VOC per volume of coating, calculated according to the procedures specified in subsection 6.1.

2.62 Waterproofing Sealer: A coating labeled and formulated for application to a porous substrate for the primary purpose of preventing the penetration of water.

2.63 Waterproofing Concrete/Masonry Sealer: A clear or pigmented film-forming coating that is labeled and formulated for sealing concrete and masonry to provide resistance against water, alkalis, acids, ultraviolet light, and staining.

2.64 Wood Preservative: A coating labeled and formulated to protect exposed wood from decay or insect attack, that is registered with both the U.S. EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (7 United States Code (U.S.C.) Section 136, et seq. ) and with the California Department of Pesticide Regulation.

3. STANDARDS

3.1 VOC Content Limits: Except as provided in subsections 3.2, 3.3, 3.8, 3.9, and 3.10, no person shall: (i) manufacture, blend, or repackage for sale within the district; (ii) supply, sell, or offer for sale within the district; or (iii) solicit for application or apply within the district, any architectural coating with a VOC content in excess of the corresponding limit specified in Table 1, after the specified effective date in
Table 1.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-9 Sept - 07



### 3.2 Most Restrictive VOC Limit: If anywhere on the container of any architectural coating, or any label or sticker affixed to the container, or in any sales, advertising, or technical literature supplied by a manufacturer or anyone acting on their behalf, any representation is made that indicates that the coating meets the definition of or is recommended for use for more than one of the coating categories listed in Table 1, then the most restrictive VOC content limit shall apply. This provision does not apply to the coating categories specified in subsections 3.2.1 through 3.2.15.

3.2.1 Lacquer coatings (including lacquer sanding sealers). 3.2.2 Metallic pigmented coatings.
3.2.3 Shellacs. 3.2.4 Fire-retardant coatings. 3.2.5 Pretreatment wash primers. 3.2.6 Industrial maintenance coatings. 3.2.7 Low-solids coatings. 3.2.8 Wood preservatives

. 

### 3.2.9 High temperature coatings. 3.2.10 Temperature-indicator safety coatings. 3.2.11 Antenna coatings. 3.2.12 Antifouling coatings. 3.2.13 Flow coatings. 3.2.14 Bituminous roof primers. 3.2.15 Specialty primers, sealers, and undercoaters.

3.3 Sell-Through of Coatings: A coating manufactured prior to the effective date specified for that coating in Table 1 may be sold, supplied, or offered for sale for up to three years after the specified effective date. In addition, a coating manufactured before the effective date specified for that coating in Table 1 may be applied at any time, both before and after the specified effective date, so long as the coating complied with the standards in effect at the time the coating was manufactured. This subsection 3.3 does not apply to any coating that does not display the date or date-code required by subsection 4.1.1.

SCM Clarification - New subsection “3.3.1” (See June 7, 2001 letter to all districts by Mike Kenny, ARB Executive Officer) 3.3.1 A coating included in an approved Averaging Program that does not comply with the specified limit in Table 1 may be sold, supplied, or offered for sale for up to three years after the end of the compliance period specified in the approved Averaging Program. In addition, such a coating may be applied at any time, both during and after the compliance period. This subsection 3.3.1 does not apply to any coating that does not display on the container either the statement: “This product is subject to architectural coatings averaging provisions in California,” or a substitute symbol specified by the Executive Officer of the ARB. This subsection 3.3.1 shall remain in effect until January 1, 2008.

3.4 Painting Practices: All architectural coating containers used to apply the contents therein to a surface directly from the container by pouring, siphoning, brushing, rolling, padding, ragging or other means, shall be closed when not in2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-10 Sept - 07 

### use. These architectural coating containers include, but are not limited to, drums, buckets, cans, pails, trays or other application containers. Containers of any VOC-containing materials used for thinning and cleanup shall also be closed
when not in use.

3.5 Thinning: No person who applies or solicits the application of any architectural coating shall apply a coating that is thinned to exceed the applicable VOC limit specified in
Table 1.

3.6 Rust Preventative Coatings: Effective January 1, 2004, no person shall apply or solicit the application of any rust prev entative coating for industrial use, unless such a rust preventative coating complies with the industrial maintenance coating VOC limit specified in Table 1.

3.7 Coatings Not Listed in Table 1: For any coating that does not meet any of the definitions for the specialty coatings categories listed in Table 1, the VOC content limit shall be determined by classifying the coating as a flat coating or a nonflat coating, based on its gloss, as defined in subsections 2.20, 2.33, and 2.34 and the corresponding flat or nonflat VOC limit shall apply.

3.8 Industrial Maintenance Coatings:

3.8.1 After January 1, 2004, a manufacturer, seller, or user may petition the APCO to apply an industrial maintenance coating with a VOC content up to 340 g/l if all of the following conditions are met:

3.8.1.1 The industrial maintenance coating is to be applied in a district located within the North Central Coast, San Francisco Bay Area,
or North Coast Air Basins. 3.8.1.2 The petition submitted to the APCO contains the following information, as applicable: job requirements and description, volume of coating, maximum VOC content, and a certification that a complying coating meeting the job performance requirements is not available. 3.8.1.3 If the APCO grants written approval, such approval shall contain volume and VOC limit conditions. Until written approval is granted by the APCO and received by the petitioner, all provisions of this rule shall apply.

3.8.2 The APCO shall not approve any petition under subsection 3.8.1 if the approvals previously granted by t he APCO during the calendar year, when combined with the petition under consideration, would result in excess VOC emissions for that calendar year which would be greater than 5 percent of the annual emission reduction achieved within the district from implementing the January 1, 2004, VOC limit for industrial maintenance coatings.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-11 Sept - 07 

### 3.8.3 Coatings subject to this provision shall be sold only if an approved petition (or a copy of it) is provided prior to the sale. Coatings subject to this provision shall not be available to the general public.

3.9 Lacquers: Notwithstanding the provisions of subsection 3.1, a person or facility may add up to 10 percent by volume of VOC to a lacquer to avoid blushing of the finish during days with relative humidity greater than 70 percent and temperature
below 65 o 

### F, at the time of application, provided that the coating contains acetone
and no more than 550 grams of VOC per liter of coating, less water and exempt compounds, prior
to the addition of VOC.

3.10 Averaging Compliance Option: On or after January 1, 2003, in lieu of compliance with the specified limits in Table 1 for floor coatings; industrial maintenance coatings; primers, sealers, and undercoaters; quick-dry primers, sealers, and undercoaters; quick-dry enamels; roof coatings; rust preventative coatings; stains; waterproofing sealers, as well as flats and non-flats (excluding recycled coatings), manufacturers may average designated coatings such that their actual cumulative emissions from the averaged coatings are less than or equal to the cumulative emissions that would have been allowed under those limits over a compliance period not to exceed one year. Such manufacturers must also comply with the averaging provisions contained in Appendix A, as well as maintain and make available for inspection records for at least three years after the end of the compliance period. This subsection 3.10 and Appendix A shall cease to be effective on January 1, 2005, after which averaging will no longer be allowed.

4. CONTAINER LABELING REQUIREMENTS

4.1 Each manufacturer of any architectural coating subject to this rule shall display the information listed in subsections 4.1.1 through 4.1.8 on the coating container (or label) in which the coating is sold or distributed.

4.1.1 Date Code: The date the coating was manufactured, or a date code representing the date, shall be indicated on the label, lid, or bottom of the container. If the manufacturer uses a date code for any coating, the manufacturer shall file an explanation of each code with the Executive
Officer of the ARB.

4.1.2 Thinning Recommendations: A statement of the manufacturer’s recommendation regarding thinning of the coating shall be indicated on the label or lid of the container. This requirement does not apply to the thinning of architectural coatings with water. If thinning of the coating prior to use is not necessary, the recommendation must specify that the coating is to be applied without thinning.

4.1.3 VOC Content: Each container of any coating subject to this rule shall display either the maximum or the actual VOC content of the coating, as supplied, including the maximum thinning as recommended by the2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-12 Sept - 07 

### manufacturer. VOC content shall be displayed in grams of VOC per liter of coating. VOC content displayed shall be calculated using product formulation data, or shall be determined using the test methods in subsection 6.2. The equations in
subsection 6.1 shall be used to calculate VOC content.

4.1.4 Industrial Maintenance Coatings: In addition to the information specified in subsection 4.1.1, 4.1.2, and 4.1.3, each manufacturer of any industrial maintenance coating subject to this rule shall display on the label or lid of the container in which the coating is sold or distributed one or more of the descriptions listed in subsections 4.1.4.1 through 4.1.4.3.

4.1.4.1 “For industrial use only.” 4.1.4.2 “For professional use only.”
4.1.4.3 “Not for residential use or Not intended for residential use.”

4.1.5 Clear Brushing Lacquers: Effective January 1, 2003, the labels of all clear brushing lacquers shall promin ently display the statements “For brush application only,” and “This product must not be thinned or sprayed.”

4.1.6 Rust Preventative Coatings: Effective January 1, 2003, the labels of all rust preventative coatings shall prominently display the statement “For Metal Substrates Only.”

4.1.7 Specialty Primers, Sealers, and Undercoaters: Effective January 1, 2003, the labels of all specialty prim ers, sealers, and undercoaters shall prominently display one or more of the descriptions listed in subsection 4.1.7.1 through 4.1.7.5.

4.1.7.1 For blocking stains. 4.1.7.2 For fire-damaged substrates. 4.1.7.3 For smoke-damaged substrates

. 

### 4.1.7.4 For water-damaged substrates

. 

### 4.1.7.5 For excessively chalky substrates

.



### 4.1.8 Quick Dry Enamels: Effective January 1, 2003, the labels of all quick dry enamels shall prominently display the words “Quick Dry” the dry hard
time.

4.1.9 Nonflat - High Gloss Coatings: Effective January 1, 2003, the labels of all nonflat - high gloss coatings shall prominently display the words “High
Gloss.”

5. REPORTING REQUIREMENTS

5.1 Clear Brushing Lacquers: Each manufacturer of clear brushing lacquers shall, on or before April 1 of each calendar year beginning in the year 2004, submit an annual report to the Executive Officer of the ARB. The report shall specify the2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-13 Sept - 07 

### number of gallons of clear brushing lacquers sold in the State during the preceding calendar year, and shall describe the method used by the
manufacturer to calculate State sales.

5.2 Rust Preventative Coatings: Each manufacturer of rust preventative coatings shall, on or before April 1 of each calendar year beginning in the year 2004, submit an annual report to the Executive Officer of the ARB. The report shall specify the number of gallons of rust preventative coatings sold in the State during the preceding calendar year, and shall describe the method used by the
manufacturer to calculate State sales.

5.3 Specialty Primers, Sealers, and Undercoaters: Each manufacturer of specialty primers, sealers, and undercoaters shall, on or before April 1 of each calendar year beginning in the year 2004, submit an annual report to the Executive Officer of the ARB. The report shall specify the number of gallons of specialty primers, sealers, and undercoaters sold in the State during the preceding calendar year, and shall describe the method used by the manufacturer to calculate State sales.

5.4 Toxic Exempt Compounds: For each architectural coating that contains perchloroethylene or methylene chloride, the manufacturer shall, on or before April 1 of each calendar year beginning with the year 2004, report to the Executive Officer of the ARB the following information for products sold in the State during the preceding year:

5.4.1 the product brand name and a copy of the product label with legible usage instructions; 5.4.2 the product category listed in Table 1 to which the coating belongs; 5.4.3 the total sales in California during the calendar year to the nearest gallon; 5.4.4 the volume percent, to the nearest 0.10 percent, of perchloroethylene and methylene chloride in the coating.

5.5 Recycled Coatings: Manufacturers of recycled coatings must submit a letter to the Executive Officer of the ARB certifying their status as a Recycled Paint Manufacturer. The manufacturer shall, on or before April 1 of each calendar year beginning with the year 2004, submit an annual report to the Executive Officer of the ARB. The report shall include, for all recycled coatings, the total number of gallons distributed in the State during the preceding year, and shall describe the method used by the manufacturer to calculate State distribution.

5.6 Bituminous Coatings: Each manufacturer of bituminous roof coatings or bituminous roof primers shall, on or before April 1 of each calendar year beginning with the year 2004, submit an annual report to the Executive Officer of ARB. The report shall specify the number of gallons of bituminous roof coatings or bituminous roof primers sold in the State during the preceding calendar year, and shall describe the method used by the manufacturer to calculate State sales.

6. COMPLIANCE PROVISIONS AND TEST METHODS2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-14 Sept - 07



### 6.1 Calculation of VOC Content: For the purpose of determining compliance with the VOC content limits in Table 1, the VOC content of a coating shall be determined by using the procedures described in subsection 6.1.1 or 6.1.2, as appropriate. The VOC content of a tint base shall be determined without colorant
that is added after the tint base is manufactured.

6.1.1 With the exception of low solids coatings, determine the VOC content in grams of VOC per liter of coating thinned to the manufacturer's maximum recommendation, excluding the volume of any water and exempt compounds. Determine the VOC content using equation 1 as follows:

Where: VOC Content = grams of VOC per liter of coating
W s = weight of volatiles, in grams

W w = weight of water, in grams

W ec = weight of exempt compounds, in grams

V m = volume of coating, in liters

V w = volume of water, in liters

V ec = volume of exempt compounds, in liters

6.1.2 For low solids coatings, determine the VOC content in units of grams of VOC per liter of coating thinned to the manufacturer's maximum recommendation, including the volume of any water and exempt compounds. Determine the VOC content using equation 2 as follows:

Where:
VOC Content ls = the VOC content of a low solids coating in grams of VOC per liter of coating
W s = weight of volatiles, in grams

W w = weight of water, in grams

W ec = weight of exempt compounds, in grams

V m = volume of coating, in liters

6.2 VOC Content of Coatings: To determine the physical properties of a coating in order to perform the calculations in subsection 6.1, the reference method for
VOC content is U.S. EPA Method 24, incorporated by reference in subsection 6.5.11, except as provided in subsections 6.3 and 6.4. An alternative method to determine the VOC content of coatings is SCAQMD Method 304-91 (Revised February 1996), 

### (1) ) V ec - V w - V m ( ) W ec - W w - W s (

= Content VOC

(2) ) V m ( ) W ec - W w - W s (

= ls Content VOC2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-15 Sept - 07 

### incorporated by reference in subsecti on 6.5.12. The exempt compounds content shall be determined by SCAQMD Method 303-91 (Revised August 1996), incorporated by reference in subsection 6.5.10. To determine the VOC content of a coating, the manufacturer may use U.S. EPA Method 24, or an alternative method as provided in subsection 6.3, formulation data, or any other reasonable means for predicting that the coating has been formulated as intended (e.g., quality assurance checks, record keeping). However, if there are any inconsistencies between the results of a Method 24 test and any other means for determining VOC content, the Method 24 test results will govern, except when an alternative method is approved as specified in subsection 6.3. The District Air Pollution Control Officer (APCO) may require the manufacturer to conduct a Method 24 analysis.

6.3 Alternative Test Methods: Other test methods demonstrated to provide results that are acceptable for purposes of determining compliance with subsection 6.2, after review and approved in writing by the staffs of the District, the ARB, and the U.S. EPA, may also be used.

6.4 Methacrylate Traffic Marking Coatings: Analysis of methacrylate multicomponent coatings used as traffic marking coatings shall be conducted according to a modification of U.S. EPA Method 24 (40 CFR 59, subpart D, Appendix A), incorporated by reference in subsection 6.5.13. This method has not been approved for methacrylate multicomponent coatings used for other purposes than as traffic marking coatings or for other classes of multicomponent coatings.

6.5 Test Methods: The following test methods are incorporated by reference herein, and shall be used to test coatings subject to the provisions of this rule:

6.5.1 Flame Spread Index: The flame spread index of a fire-retardant coating shall be determined by ASTM Designation E 84-99, “Standard Test Method for Surface Burning Characteristics of Building Materials” (see section 2, Fire-Retardant Coating).

6.5.2 Fire Resistance Rating: The fire resistance rating of a fire-resistive coating shall be determined by ASTM Designation E 119-98, “Standard Test Methods for Fire Tests of Building Construction Materials” (see section 2, Fire-Resistive Coating).

6.5.3 Gloss Determination: The gloss of a coating shall be determined by ASTM Designation D 523-89 (1999), “Standard Test Method for Specular Gloss” (see section 2, Flat Coating, Nonflat Coating, Nonflat - High Gloss Coating, and Quick-Dry Enamel).

6.5.4 Metal Content of Coatings: The metallic content of a coating shall be determined by SCAQMD Method 318-95, “Determination of Weight Percent Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD Laboratory Methods of Analysis for Enforcement Samples (see section 2, Metallic Pigmented Coating).2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-16 Sept - 07 

### 6.5.5 Acid Content of Coatings: The acid content of a coating shall be determined by ASTM Designation D 1613-96, “Standard Test Method for Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, and Related Products” (see section 2, Pre-treatment Wash Primer).

6.5.6 Drying Times: The set-to-touch, dry-hard, dry-to-touch, and dry-to-recoat times of a coating shall be determined by ASTM Designation D 1640-95, “Standard Test Methods for Drying, Curing, or Film Formation of Organic Coatings at Room Temperature” (see section 2, Quick-Dry Enamel and Quick-Dry Primer, Sealer, and Undercoater). The tack-free time of a quick-dry enamel coating shall be determined by the Mechanical Test Method of ASTM Designation D 1640-95.

6.5.7 Surface Chalkiness: The chalkiness of a surface shall be determined using ASTM Designation D 4214-98, “Standard Test Methods for Evaluating the Degree of Chalking of Exterior Paint Films” (see section 2, Specialty Primer, Sealer, and Undercoater).

6.5.8 Exempt Compounds--Siloxanes: Exempt compounds that are cyclic, branched, or linear completely methylated siloxanes, shall be analyzed as exempt compounds for compliance with section 6 by BAAQMD Method 43, “Determination of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks, and Related Materials,” BAAQMD Manual of Procedures

, Volume III, adopted 11/6/96 (see section 2, Volatile Organic Compound, and subsection 6.2).

6.5.9 Exempt Compounds--Parachlorobenzotrifluoride (PCBTF) : The exempt compound parachlorobenzotrifluoride, shall be analyzed as an exempt compound for compliance with section 6 by BAAQMD Method 41, “Determination of Volatile Organic Compounds in Solvent Based Coatings and Related Materials Containing Parachlorobenzotrifluoride,” BAAQMD
Manual of Procedures , Volume III, adopted 12/20/95 (see section 2, Volatile Organic Compound, and subsection 6.2).

6.5.10 Exempt Compounds: The content of compounds exempt under U.S. EPA Method 24 shall be analyzed by SCAQMD Method 303-91 (Revised 1993), “Determination of Exempt Compounds,” SCAQMD Laboratory Methods of Analysis for Enforcement Samples (see section 2, Volatile Organic Compound, and subsection 6.2).

6.5.11 VOC Content of Coatings: The VOC content of a coating shall be determined by U.S. EPA Method 24 as it exists in appendix A of 40 Code of Federal Regulations (CFR) part 60, “Determination of Volatile Matter Content, Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings” (see subsection 6.2).2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-17 Sept - 07 

### 6.5.12 Alternative VOC Content of Coatings: The VOC content of coatings may be analyzed either by U.S. EPA Method 24 or SCAQMD Method 304-91 (Revised 1996), “Determination of Volatile Organic Compounds (VOC) in Various Materials,” SCAQMD Laboratory Methods of Analysis for Enforcement Samples (see subsection 6.2).

6.5.13 Methacrylate Traffic Marking Coatings: The VOC content of methacrylate multicomponent coatings used as traffic marking coatings shall be analyzed by the procedures in 40 CFR part 59, subpart D, appendix A, “Determination of Volatile Matter Content of Methacrylate Multicomponent Coatings Used as Traffic Marking Coatings” (September 11, 1998) (see subsection 6.4).2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

B-18 

### Table 1
VOC CONTENT LIMITS FOR ARCHITECTURAL COATINGS

Limits are expressed in grams of VOC per liter a of coating thinned to the manufacturer’s maximum recommendation, excluding the volume of any water, ex empt compounds, or colorant added to tint bases. “Manufacturer’s maximum recommendation” means the maximum recommendation for thinning that is indicated on the label or lid of the coating container.

Coating Category Effective 1/1/2003 Effective 1/1/2004

Flat Coatings 100

Nonflat Coatings 150

Nonflat - High Gloss Coatings 250

Specialty Coatings

Antenna Coatings 530

Antifouling Coatings 400

Bituminous Roof Coatings 300

Bituminous Roof Primers 350

Bond Breakers 350

Clear Wood Coatings

• Clear Brushing Lacquers

• Lacquers (including lacquer sanding sealers)

• Sanding Sealers (other than lacquer sanding sealers)

• Varnishes 680
550
350

350

Concrete Curing Compounds 350

Dry Fog Coatings 400

Faux Finishing Coatings 350

Fire Resistive Coatings 350

Fire-Retardant Coatings:

• Clear

• Opaque 650
350

Floor Coatings 250

Flow Coatings 420

Form-Release Compounds 250

Graphic Arts Coatings (Sign Paints) 5002000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

B-19 

### Table 1 Continued

Coating Category Effective 1/1/2003 Effective 1/1/2004

High Temperature Coatings 420

Industrial Maintenance Coatings 250

Low Solids Coatings b 120

Magnesite Cement Coatings 450

Mastic Texture Coatings 300

Metallic Pigmented Coatings 500

Multi-Color Coatings 250

Pre-Treatment Wash Primers 420

Primers, Sealers, and Undercoaters 200

Quick-Dry Enamels 250

Quick-Dry Primers, Sealers, and Undercoaters 200

Recycled Coatings 250

Roof Coatings 250

Rust Preventative Coatings 400

Shellacs:

• Clear

• Opaque 730
550

Specialty Primers, Sealers, and Undercoaters 350

Stains 250

Swimming Pool Coatings 340

Swimming Pool Repair and Maintenance Coatings 340

Temperature-Indicator Safety Coatings 550

Traffic Marking Coatings 150

Waterproofing Sealers 250

Waterproofing Concrete/Masonry Sealers 400

Wood Preservatives 350

a Conversion factor: one pound VOC per ga llon (U.S.) = 119.95 grams VOC per liter. b Units are grams of VOC per liter ( pounds of VOC per gallon) of coating, including water and exempt compounds.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-20 Sept - 07 

## APPENDIX A:
AVERAGING PROVISION2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-21 Sept - 07 

### A. AVERAGING PROVISION

A.1 The manufacturer shall demonstrate that actual emissions from the coatings being averaged are less than or equal to the allowable emissions, for the specified compliance period using the following equation:



### ≤ ∑ n

1 = i GiMi

∑ n

1 = i GiViLi

Where:



### ∑ = n

1 = i Emissions Actual GiMi

∑ = n

1 = i Emissions Allowable GiViLi

V m Vec Vw Vm Vi − −

=

) Regulatory VOC as known also ( VOC Coating ) Actual VOC as known also ( VOC Material Vi =



### : Coatings VOC For Zero V m Wec Ww Ws Mi − −

=

Vec

- Vw

- V m Wec

- Ww

- Ws VOC Coating : Where = gallon; per pounds in (i), Product of Content VOC Material Mi Averaging; subject to (i) Product of Gallons Total Gi

= =



### (i); Product in VOC and Solids Volume by Percent Vi =



### gallons. in are volumes and pounds in are eights Appendix w in this t except tha 6.1, subsection in defined are Vec and Vw, Vm, Wec, Ww, Ws, : Where

: Coatings VOC Zero

- Non For

1) Table in listed (as gallon per pounds in (i), Product for Limit Content VOC Regulatory Li = 

### Volume by Solids Percent Vi =2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-22 Sept - 07 

### The averaging is limited to coatings that are designated by the manufacturer. Any coating not designated in the averaging Program shall comply with the VOC
limit in Table 1. The manufacturer shall not include any quantity of coatings that it knows or should have known will not be used in the State, if statewide coatings data are used. If district-specific coatings data are used, the manufacturer shall not include any quantity of coatings that it knows or should have known will not
be used in the district.

SCM Clarification - New Section “A.1.1” (See June 7, 2001 letter to all districts by Mike Kenny, ARB Executive Officer)

A.1.1 In addition to the requirements specified in subsection A.1, manufacturers shall not include in an Averaging Program any coating with a VOC content in excess of the following maximum VOC contents, for the applicable categories.

Averaging Category VOC Limit (Li) 1 

### grams/liter Maximum
VOC Content

grams/liter
Flat 100 250 Nonflat (Excludes High Gloss) 150 250

Floor 250 400
Industrial Maintenance 250 420 Primer, Sealer,
Undercoater 200 350

Quick Dry Primer, Sealer,
Undercoater 200 450

Quick Dry Enamel 250 400
Roof 250 300
Bituminous Roof 300 300
Rust Preventative 400 400
Stains 250 350 Waterproofing sealers 250 400 1. As listed in Table 1. Used when determining allowable emissions in
subsection A.1.

A.2 AVERAGING PROGRAM (PROGRAM)

At least six months prior to the start of the compliance period, manufacturers shall submit an Averaging Program to the Executive Officer of the Air Resources Board. As used in this Appendix A, “Executive Officer” means the Executive Officer of the Air Resources Board. Averaging may not be implemented until the Program is approved in writing by the Executive Officer.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-23 Sept - 07 

### Within 45 days of submittal of a complete Program, the Executive Officer shall either approve or disapprove the Program. The Program applicant and the Executive Officer may agree to an extension of time for the Executive Officer to take action on the Program.

A.3 GENERAL REQUIREMENTS

The Program shall include all necessary information for the Executive Officer to make a determination as to whether the manufacturer may comply with the averaging requirements over the specif ied compliance period in an enforceable manner. Such information shall include, but is not limited to, the following:

A.3.1 An identification of the contact persons, telephone numbers, and name of the manufacturer who is submitting the Program. A.3.2 An identification of each coating that has been selected by the manufacturer for inclusion in this program that exceeds the applicable
VOC limit in Table 1, its VOC content specified in units of both VOC actual and VOC regulatory, and the designation of the coating category. A.3.3 A detailed demonstration showing that the projected actual emissions will not exceed the allowable emissions for a single compliance period that the Program will be in effect. In addition, the demonstration shall include VOC content information for each coating that is below the compliance limit in Table 1. The demonstration shall use the equation specified in subsection A.1 of this Appendix for projecting the actual emissions and allowable emissions during each compliance period.
The demonstration shall also include all VOC content levels and projected volume within the State for each coating listed in the Program during each compliance period. The requested data can be
summarized in a matrix form. A.3.4 A specification of the compliance period(s) and applicable reporting dates. The length of the compliance period shall not be more than one year or less than six months.

A.3.5 An identification and description of all records to be made available to the Executive Officer upon request, if different than those identified
under subsection A.3.6. A.3.6 An identification and description of specific records to be used in calculating emissions for the Program and subsequent reporting, and a detailed explanation as to how those records will be used by the manufacturer to verify compliance with the averaging requirements. A.3.7 A statement, signed by a responsible party for the manufacturer, that all information submitted is true and correct, and that records will be made available to the Executive Officer upon request.

A.4 REPORTING REQUIREMENTS

A.4.1 For every single compliance period, the manufacturer shall submit a mid-term report listing all coatings subject to averaging during the first2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-24 Sept - 07 

### half of the compliance period, detailed analysis of the actual and allowable emissions at the end of the mid-term, and an explanation as to how the manufacturer intends to achieve compliance by the end of the compliance period. The report shall be signed by the responsible party for the manufacturer, attesting that all information submitted is true and correct. The mid-term report shall be submitted within 45 days after the midway date of the compliance period. A manufacturer may request, in writing, an extension of up to 15 days for submittal of the mid-term report.

A.4.2 Within 60 days after the end of the compliance period or upon termination of the Program, whichever is sooner, the manufacturer
shall submit to the Executive O fficer a report listing all coatings subject to averaging during the compliance period, providing a
detailed demonstration of the balance between the actual and allowable emissions for the compliance period, any identification and description of specific records used by the manufacturer to verify compliance with the averaging requirement, and any other information requested by the Executive Officer to determine whether the manufacturer complied with the averaging requirements over the specified compliance period. The report shall be signed by the responsible party for the manufacturer, attesting that all information submitted is true and correct, and that records will be made available to the Executive Officer upon request. A manufacturer may request, in writing, an extension of up to 30 days for submittal of the final report.

A.5 RENEWAL OF A PROGRAM

A Program automatically expires at the end of the compliance period. The manufacturer may request a renewal of the Program by submitting a renewal request that shall include an updated Program, meeting all applicable Program requirements. The renewal request w ill be considered conditionally approved
until the Executive Officer makes a final decision to deny or approve the renewal request based on a determination of whether t he manufacturer is likely to comply with the averaging requirements. The Executive Officer shall base suchdetermination on all available information, including but not limited to, the midterm and the final reports of the preceding compliance period. The
Executive Officer shall make a decisi on to deny or approve a renewal request no later than 45 days from the date of the final report submittal, unless the manufacturer and the Executive Officer agree to an extension of time for the Executive Officer to take action on the renewal request.

A.6 MODIFICATION OF A PROGRAM

A manufacturer may request a modification of the Program at any time prior to the end of the compliance period. The Executive Officer shall take action to approve or disapprove the modification request no longer than 45 days from the date of its submittal. No modification of the compliance period shall be allowed.2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-25 Sept - 07 

### A Program need not be modified to specify additional coatings to be averaged that are below the applicable VOC limits.

A.7 TERMINATION OF A PROGRAM

A.7.1 A manufacturer may terminate its Program at any time by filing a written notification to the Executive Officer. The filing date shall be considered the effective date of the termination, and all other provisions of this rule including the VOC limits shall immediately thereafter apply. The
manufacturer shall also submit a final report 60 days after the termination date. Any exceedance of the actual emissions over the allowable emissions over the period that the Program was in effect shall constitute a separate violation for each day of the entire compliance period.

A.7.2 The Executive Officer may terminate a Program if any of the following
circumstances occur:

A.7.2.1 The manufacturer violates the requirements of the approved Program, and at the end of the compliance period, the actual
emissions exceed the allowable emissions. A.7.2.2 The manufacturer demonstrates a recurring pattern of violations and has consistently failed to take the necessary steps to correct those violations.

A.8 CHANGE IN VOC LIMITS

If the VOC limits of a coating listed in the Program are amended such that its effective date is less than one year from the date of adoption, the affected manufacturer may base its averaging on the prior limits of that coating until the end of the compliance period immediately following the date of adoption.

A.9 LABELING

Each container of any coating that is included in averaging program, and that exceeds the applicable VOC limit in Table 1 shall display the following statement: "This product is subject to architectu ral coatings averaging provisions in California.” A symbol specified by the Executive Officer may be used as a
substitute.

A.10 VIOLATIONS

The exceedance of the allowable emissions for any compliance period shall constitute a separate violation for each day of the compliance period. However, any violation of the requirements of the Averaging Provision of this rule, which the violator can demonstrate, to the Executive Officer, did not cause or allow the emission of an air contaminant and was not the result of negligent or knowing activity may be considered a minor violation.

A.11 SUNSET OF AVERAGING PROVISION2000 SCM As Approved by the ARB on June 22, 2000. Also incorporates recommended changes identified in the ARB June 7, 2001 letter to all local air districts signed by Mike Kenny, ARB Executive
Officer.

California Air Resources Board B-26 Sept - 07 

### The averaging provision set forth in Appendix A shall cease to be effective on January 1, 2005, after which averaging will no longer be allowed.2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX C:

AIR QUALITY STANDARDS AND
NONATTAINMENT AREAS2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 072007 ARB SCM for Architectural Coatings

California Air Resources Board C-1 Sept - 07 

### AIR QUALITY STANDARDS

C.1. Current Ozone and Particulate Matter Standards

To protect California’s population from the harmful effects of ozone and PM, federal and State air quality standards for these contaminants have been
established. These standards are shown in Table C-1.

The ARB adopted new PM standards in June of 2002, responding to requirements of the Children's Environment al Health Protection Act (Senate Bill 25, Escutia 1999). This Act requires the evaluation of all health-based ambient air quality standards to determine if the standards adequately protect human health, particularly that of infants and child ren. The subsequent review of the PM
standards resulted in the recommendation of more health-protective ambient air quality standards for PM 10 

### and a new standard for PM 2.5 

### . The new PM standards
became effective in 2003.

For ozone, the ARB approved a new ei ght-hour standard of 0.070 ppm and
retained the one-hour ozone standard of 0.09 ppm in April 2005. These updated
standards resulted from an extensive review of the scientific literature, which indicated that significant harmful health effects could occur among both adults and children if exposed to levels above these standards.

Table C-1 Ambient Air Quality Standards for Ozone, PM 10 , and PM 2.5 Pollutant Averaging Time State Standard National Standard

1 Hour 0.09 ppm (180 μ g/m 3 ) ---- Ozone

8 Hour 0.070 ppm (137 μ g/m 3 ) 0.08 ppm (157 μ g/m 3 )

24 Hour 50 μ g/m 3 150 μ g/m 3 PM 10 Annual Arithmetic Mean 20 μ g/m 3

---- 24 Hour ---- 35 μ g/m 3 PM 2.5 Annual Arithmetic Mean 12 μ g/m 3 15 μ g/m 3



### C.2. California Clean Air Act

The California Clean Air Act (CCAA) was enacted in 1988 and has the fundamental goal that all areas of California are to attain the State ambient air quality standard for ozone by the earliest pr acticable date. The State eight-hour ozone standard is set by the ARB, and is more stringent than the federal eighthour ozone standard. As specified in t he CCAA, the ARB has designated areas
of California to be in “attainment” or “nonattainment” for the State ozone
standard. Local districts that are nonatta inment for the State ozone standard are required by the CCAA to prepare plans, which must be designed to achieve and maintain the standard by the earliest prac ticable date. In developing their plans2007 ARB SCM for Architectural Coatings

California Air Resources Board C-2 Sept - 07 

### each district determines which measures are necessary to include, as well as the specific details of each included measure.

C.3. Status of Air Quality – State Standards

State law indicates that the California Legislature intends progress toward clean air to be made as quickly as possible. The CCAA specifically declares that it is the intent of the Legislatur e that the state air qualit y standards be achieved “...by the earliest practicable date...” (Heal th and Safety Code, sections 40910 and 40913(a)). Unhealthy levels of ozone and PM are not limited to urban areas, but can be found in nearly every county in Calif ornia as seen in Figures C-1, C-2, and C-3. These figures highlight areas t hat exceed the State ambient air quality standards (i.e. “nonattainment areas”).

The 35 districts in California have air quality planning responsibilities. Of the 35 districts, 30 are nonattainment for t he State 1-hour/8-hour ozone standard,
31 are nonattainment for the State 24-hour/annual PM 10 

### standard, and 11 are
nonattainment for the State annual PM 2.5 

### standard. For the State ozone and
PM 10 

### standards, a district is designated “ nonattainment” for ozone if it does not
meet either the 1-hour or 8-hour standard and “nonattainment” for PM 10 

### if it does
not meet either the 24-hour or annual standard. Table C-2 lists the districts that have been designated “nonattainment” because they exceed State standards for
ozone or PM. Of the 30 ozone nonattainment districts, all but eight already have an architectural coatings rule. These eight districts are the Great Basin Unified, Amador County, Calaveras County, Mariposa County, Tuolumne County, Northern Sierra, Siskiyou County, and Glenn County Districts. Some of these districts are impacted by upwind distri cts and will have no requirements to adopt an architectural coating rule based on the proposed SCM. Of the 31 PM 10 

### nonattainment districts, all but ten have an architectural rule. These ten districts include the above eight ozone nonattainment districts with the exception of Amador County and Siskiyou County and the addi tion of the North Coast Unified, Mendocino County, Modoc County, and La ssen County Districts. The only PM 2.5 

### nonattainment district without an architectura l rule is the Northern Sierra AQMD.2007 ARB SCM for Architectural Coatings

California Air Resources Board C-3 Sept - 07 

### Figure C-1 2006 Area Designations for State Ambient Air Quality Standard for Ozone

(ARB, 2006b) 

### Attainment

Unclassified

Nonattainment-Transitional

Nonattainment2007 ARB SCM for Architectural Coatings

California Air Resources Board C-4 Sept - 07 

### Figure C-2 2006 Area Designations for State Ambient Air Quality Standard for PM 10

(ARB, 2006b) 

### Attainment

Unclassified

Nonattainment-Transitional

Nonattainment2007 ARB SCM for Architectural Coatings

California Air Resources Board C-5 Sept - 07 

### Figure C-3 2006 Area Designations for State Ambient Air Quality Standard for PM 2.5

(ARB, 2006b) 

### Attainment

Unclassified

Nonattainment-Transitional

Nonattainment2007 ARB SCM for Architectural Coatings

California Air Resources Board C-6 Sept - 07 Table C-2 2006 State Nonattainment Areas for Ozone, PM 10 , and PM 2.5 State
Nonattainment Air Basin Air District County Ozone PM 10 PM 2.5 1 Great Basin Great Basin Unified Alpine X Valley APCD Inyo X X

Mono X X

2 Lake Tahoe Placer County
APCD Placer (eastern portion) X El Dorado County AQMD El Dorado (eastern portion) X

3 Mojave Desert Mojave Desert AQMD San Bernardino (central portion) X X X Kern County APCD Kern (eastern portion) X X

South Coast AQMD Riverside (eastern portion) X X Antelope Valley AQMD Los Angeles (northeast portion) X X

4 Mountain
Counties Amador County
APCD Amador X Calaveras County
APCD Calaveras X X Mariposa County APCD Mariposa X X 2
Tuolumne County
APCD Tuolumne X El Dorado County AQMD El Dorado (western portion) X X Placer County APCD Placer (central portion) X X
Northern Sierra Nevada X X
AQMD Plumas X X 4

Sierra X 5 North Central Monterey Bay Santa Cruz X X Coast Unified APCD Monterey X X
San Benito X X

6 North Coast Northern Sonoma County APCD Sonoma (northern portion) X
North Coast Unified Del Norte X
AQMD Humboldt X Trinity X
Mendocino AQMD Mendocino X

7 Northeast
Plateau Siskiyou County APCD Siskiyou X
Modoc APCD Modoc X
Lassen APCD Lassen X2007 ARB SCM for Architectural Coatings

California Air Resources Board C-7 Sept - 07 Table C-2 2006 State Nonattainment Areas for Ozone, PM 10 , and PM 2.5 State
Nonattainment Air Basin Air District County Ozone PM 10 PM 2.5

8 Sacramento Butte County AQMD Butte X X X Valley Colusa County
APCD Colusa X 1 X Glenn County
APCD Glenn X 1 X Shasta County AQMD Shasta X X

Feather River AQMD Sutter X X

Yuba X X Tehama County
APCD Tehama X X
Sacramento Metro AQMD Sacramento X X X Placer County
APCD Placer (western portion) X X X

Yolo-Solano AQMD Solano (eastern portion) X X

Yolo X X

9 Salton Sea South Coast AQMD Riverside (central portion) X X Imperial County APCD Imperial X X X 3

10 San Diego San Diego County APCD San Diego X X X 11 San Francisco Bay Area AQMD Alameda X X X

Bay Area Contra Costa X X X

Marin X X X Napa X X X
San Francisco X X X
San Mateo X X X
Santa Clara X X X Solano (western portion) X X X Sonoma (southern portion) X X X 12 San Joaquin San Joaquin Valley Fresno X X X

Valley 5 APCD Kern (western portion) X X X Kings X X X
Madera X X X
Merced X X X San Joaquin X X X
Stanislaus X X X

Tulare X X X2007 ARB SCM for Architectural Coatings

California Air Resources Board C-8 Sept - 07 Table C-2 2006 State Nonattainment Areas for Ozone, PM 10 , and PM 2.5 State
Nonattainment Air Basin Air District County Ozone PM 10 PM 2.5

13 South Central
Coast San Luis Obispo County APCD San Luis Obispo X X
Santa Barbara County APCD Santa Barbara X X Ventura County
APCD Ventura (continental portion) X X X

14 South Coast South Coast AQMD Los Angeles (western portion) X X X Orange X X X Riverside (western portion) X X X
San Bernardino (southwestern portion) X X X (ARB, 2006a; 2006b)

1. Nonattainment-Transitional 2. Yosemite National Park Only 3. City of Calexico Only 4. Portola Valley Only 5. In April 2007, the Governing Board of the San Joaquin Va lley Air District voted to ask the U.S. EPA to designate
the air basin as “Extreme” nonattainment for ozone. This designation would create a deadline of 2024 for the
basin to meet the federal 8-hour ozone standard.



### In many of the nonattainment districts, substantial additional emission reductions will be necessary in order to achieve and maintain the State ozone standard. The SCM will be available for adoption by t he above districts in order to reduce
VOC emissions and attain or maintain the State ozone and PM standards.

C.3. Status of Air Quality – Federal Standards

Federal law also indicates that the U.S. Congress intends progress toward clean air to be made as quickly as possible. The federal Clean Air Act declares that the federal air quality standards are to be achieved “...as expeditiously as practicable...” (Federal Clean Air Act, sections 172(a)(2), 181(a), and 188(c)).

Thirty-five counties or portions of c ounties are designated as nonattainment for
the federal 8-Hour Ozone standard with a ttainment dates ranging from 2007 to
2021. Table C-3 lists the districts that have been designated “nonattainment” because they exceed federal standards for ozone. The San Joaquin Valley and South Coast air basins are expected to have until 2023 to attain the federal standard, by invoking the “bump-up” pr ovision in the federal Clean Air Act.

For particulate matter, the South Coast Air Basin and the San Joaquin Valley Air Basin are the only two areas in the Stat e that exceed the annual federal PM 2.5 standard. These areas are required by federal law to develop SIPs describing how they will attain the standards by 2015. The U.S. EPA further requires that all necessary emission reductions be achieved one calendar year sooner – by 20142007 ARB SCM for Architectural Coatings

California Air Resources Board C-9 Sept - 07 

### – in recognition of the annual average form of the standard. The Owens Valley is the only federal PM10 nonattainment area. It did not meet its December 31, 2006 attainment date and must submit pl an revisions by December 31, 2007 detailing how it will reach attainment.

Table C-3
8-Hour Federal Ozone Nonattainment Areas

Federal
Nonattainment Area Air District County Federal 8-Hr
Ozone Designation (Attainment Year)

1 Amador and Calaveras Counties Amador County APCD Amador Subpart 1 (2009) (Central Mountain) Calaveras County
APCD Calaveras

2 Chico Butte County AQMD Butte Subpart 1 (2009) 3 Imperial County Imperial County APCD Imperial Marginal (2007)

4 Kern County (Eastern Kern) Kern County APCD Kern (eastern portion) Subpart 1 (2009)

5 Los Angeles South Coast Air Basin South Coast AQMD Los Angeles (western portion) Severe-17 (2021) Orange Riverside (western portion)
San Bernardino (southwestern portion)

6 Los Angeles – San Bernardino Antelope Valley AQMD Los Angeles (northeastern portion) Moderate (2010) Counties (Western Mojave) Mojave Desert AQMD San Bernardino (central portion)

7 Mariposa and Tuolumne Counties Mariposa County APCD Mariposa Subpart 1 (2009)

(Southern Mountain) Tuolumne County
APCD Tuolumne

8 Nevada County (Western Part) Northern Sierra AQMD Nevada (western portion) Subpart 1 (2009)

9 Riverside County (Coachella Valley) South Coast AQMD Riverside (central portion) Serious (2013)

10 Sacramento Metro El Dorado County AQMD El Dorado (western portion) Serious (2013) Placer County APCD Plac er (western portion)
Sacramento Metro AQMD Sacramento Yolo-Solano AQMD Solano (eastern portion)

Yolo

11 San Diego San Diego County APCD San Diego Subpart 1 (2009)2007 ARB SCM for Architectural Coatings

California Air Resources Board C-10 Sept - 07 Table C-3
8-Hour Federal Ozone Nonattainment Areas

Federal
Nonattainment Area Air District County Federal 8-Hr
Ozone Designation (Attainment Year)

12 San Francisco Bay Bay Area AQMD Alameda Marginal (2007)
Area Contra Costa

Marin Napa
San Francisco
San Mateo
Santa Clara Solano (western portion) Sonoma (southern portion) 13 San Joaquin Valley San Joaquin Valley Fresno Serious (2013)

APCD Kern (western portion) Kings
Madera
Merced San Joaquin
Stanislaus

Tulare

14 Sutter County (Sutter Buttes) Feather River AQMD Sutter (Sutter Buttes portion) Subpart 1 (2009)

15 Ventura County Ventura County APCD Ventura (continental portion) Moderate (2010)

15 Federal
Nonattainment
Areas 20 Air Districts 35 Counties (U.S. EPA, 2007)



### C.5. Improving Air Quality

Over the past 40 years, air pollution control agencies in California have been working diligently to improve air quality. Much of the effort was directed towards the more traditional sources of air polluti on such as mobile sources (e.g., cars, trucks, etc.) and stationary sources (e.g ., factories, power plants, etc.) While there have been dramatic gains in reducing emissions from these traditional sources, there is a need for fu rther reductions from other sources of emissions, including architectural coatings , to continue to make progress toward meeting the State and Feder al ambient air quality standards and protecting the public health of California citizens. Emi ssions from all other sources, including architectural coatings, have become more significant as emissions from the
traditional sources are further reduced. Therefore, the emissions from these
sources must be evaluated for further reductions.2007 ARB SCM for Architectural Coatings

California Air Resources Board C-11 Sept - 07 

### Architectural coatings comprise an import ant source of emissions in California because they are widely distributed, emit VOCs when used, and contribute to the air pollution problem in California. Alt hough each container of paint may seem to be a small source of emissions, when the total number of users in California is aggregated, the total VOC emissions become significant. Implementation of the proposed SCM will continue the progress towa rd meeting California’s air quality goals.

C.6. State Implementation Plan Commitments

For areas with unhealthy levels of air pollut ants, clean air laws require districts to develop plans to describe how they will attain ambient air quality standards. The CCAA requires districts that hav e been designated nonattainment for the State ambient air quality standards to pr epare and submit plans for attaining and maintaining the standards (see Health and Safety Code §40910 et seq .). In addition, the federal Clean Air Ac t requires that districts designated
nonattainment for the federal ambient air quality standards prepare State Implementation Plans (SIPs) to demons trate attainment with the federal standards. SIPs are a compilation of several documents, including new and previously submitted plans, programs (e .g., monitoring, modeling, permitting, etc.), district rules, State regulations and federal controls. State law makes ARB the lead agency for submittal of California’ s SIPs. Local air districts and other agencies (e.g., Bureau of Automotive Repair) prepare SIP elements and submit them to ARB for review and approval. AR B forwards the compiled SIP revisions to U.S. EPA for approval.

There are 15 non-attainment areas for the federal ozone standard and 2 nonattainment areas for the PM2.5 standar d. For these areas, Ozone SIPs and PM2.5 SIPs must be adopted and sent to the U.S. EPA by June 2007 and April 2008, respectively. The SIPs must show how each area will attain the federal standards. To do this, the SIPs will identify the amount of emissions that
must be reduced in each area to meet the standard and the emission controls needed to reduce the necessary emissions. Emission reductions from district rules, including architectural coatings rule s, are an essential part of California’s effort to attain air quality standards for ozone.

Six local air districts in two federal ozone nonattainment areas included control measures for architectural coatings in their draft or final 2007 Ozone SIPs.
These districts are:

• El Dorado AQMD 1 

### • Sacramento Metropolitan AQMD 1



### • Feather River AQMD 1 

### • San Joaquin Valley Unified APCD 2



### • Placer County APCD 1 

### • Yolo-Solano AQMD 1

1. The Sacramento Federal Ozone Nonattainment Ar ea includes all of Sacramento and Yolo Counties,

portions of Placer and El Dorado Counties, eas tern Solano County and southern Sutter County. 2. San Joaquin Valley Unified AP CD adopted its ozone SIP in April 20072007 ARB SCM for Architectural Coatings

California Air Resources Board C-12 Sept - 07 

### Table C-4 lists the emission reduction commi tments for architectural coatings in
the draft or final 2007 Ozone SIPs for each district.

Table C-4
2007 Ozone SIP Commitments For VOC Emission Reductions From Architectural Coating Measures District Implementation
Year 2012 ROG Planning Inventory 2
(tpd) Emission
Reductions
in 2012

(tpd) %
Reductions

El Dorado County AQMD 1 2012 0.38 0.06 16%
Feather River AQMD Pre-2012 0.02 0.003 15% Placer County APCD 3 2013 0.89 0.13 15% Sacramento Metropolitan AQMD 2012 4.12 0.62 15% San Joaquin Valley Unified APCD 2012 9.7 2.0 21% Yolo-Solano County AQMD 2011 0.96 0.14 15%
TOTAL: 16.1 2.95 18%
1. El Dorado County had not yet adopted the 2000 SCM limits at the time that the draft 2007 SIP was developed. Therefore, their SIP Commitment value is actually larger, but for the purpose of this table we are only including the
2007 SCM commitment. 2. The 2012 ROG Planning Inventory is based on ARB’s 2001 Ar chitectural Coating Survey and does not reflect the data from ARB’s 2005 Architectural Coating Survey that was used to develop the proposed SCM. 3. For Placer County, values represent the 2018 ROG Planning Inventory and t he 2018 Emission Reductions.



### ARB staff believes that the proposed SCM will achieve reductions that are in line with emission reductions claimed by dist ricts in their draft 2007 Ozone SIPs (see Table C-5). The proposed SCM is expected to achieve about a 28 percent
emission reduction. The values in Tabl e C-5 assume that the emissions from architectural coatings are approximatel y 95 tpd statewide, on an annual average basis, not including emissions from thinning and clean-up (ARB, 2006c). Statewide emissions are apportioned to dist ricts, based on population. Districts outside of the South Coast AQMD repres ent 56% of the State’s population which corresponds to 53 tpd of VOC emissions fr om architectural coating usage. The South Coast AQMD is not expected to adopt the proposed SCM because its architectural coatings Rule 1113 includes VO C limits that are, in most cases, at least as stringent as the proposed SCM. Since the non-South Coast districts are the primary target for adoption of the SCM, we are only estimating emission
reductions for those districts. The emission reductions from the SCM are estimated to be about 4.3 tpd for the six districts with SIP commitments and about 10.7 tpd from the remaining non-South Coast districts for a total estimated emission reduction of 15 tpd, in the non-S outh Coast AQMD portion of the State.2007 ARB SCM for Architectural Coatings

California Air Resources Board C-13 Sept - 07 Table C-5 Comparison of Estimated Emission Reductions From the Proposed SCM
and the 2007 Ozone SIP Commitments [A] [B] [C] [D] [E] [F] =[A]*[95 tpd] = [B]*[C] = [A]/[56%] =[E]*[15 tpd]

Districts with
SIP
Commitments % of CA Population 2 Emission Inventory

(TPD in 2004) 3 SIP
Commitment (%) SIP
Commitment (TPD in 2004) % of Total
SCM
Reductions Reductions
From SCM (TPD in 2004)
El Dorado (part) 1 0.50% 0.48 16% 0.08 0.89% 0.13

Feather River 0.40% 0.38 15% 0.06 0.71% 0.11 Placer County 0.80% 0.76 15% 0.11 1.43% 0.21

Sacramento
Metro 3.70% 3.52 15% 0.53 6.61% 0.99

San Joaquin 9.80% 9. 31 21% 1.96 17.50% 2.63

Yolo-Solano 0.90% 0.86 15% 0.13 1.61% 0.24

TOTAL: 16.1% 15.3 2.9 4.3

1. El Dorado County had not yet adopted the 2000 SCM limits at the time that the draft 2007 SIP was developed. Therefore, their SIP Commitment value includes reductions from the 2000 SCM and the proposed 2007 SCM. 2. The “% of CA Population” may not represent the entire district population. For some districts in the Sacramento Nonattainment Area, only a portion of the distri ct population is included for SIP planning purposes. 3. Emission Inventory data are based on data from ARB’s 2005 Architectural Coating Survey. These data are for coatings only and do not include em issions from thinning solvents, cleanup solvents, or additives.



### REFERENCES

Air Resources Board. The California Alm anac of Emissions and Air Quality, 2006 Edition. Online, Internet at http://www.arb.ca.gov/aqd/almanac/almanac.htm

. 2006. (ARB, 2006a)

Air Resources Board. “Area Designati ons and Maps”. Online Internet at http://www.arb.ca.gov/regact/area06/adisor.pdf and http://www.arb.ca.gov/regact/area06/appc.pdf . September, 2006. (ARB, 2006b)

Air Resources Board. “2005 Architectura l Coatings Survey, Draft Report.” September, 2006. (ARB, 2006c)

United States Environmental Protection Agency. “Classifications of 8-Hour
Ozone Nonattainment Areas”. Online internet at http://www.epa.gov/air/oaqps/greenbk/gnc.html . August 16, 2007. (U.S. EPA, 2007)2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX D:

SUMMARY OF CURRENT VOC LIMITS2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07California Air Resources Board D-1 Sept - 07NOTE: This summary is provided for comparison purposes ONLY. Please refer to the official rule language for compliance purposes.Table D-1: Summary of Architectural Coating Rules and VOC Limits1in CaliforniaAgencyU.S.EPA CARB AntelopeBayArea Butte ColusaElDoradoFeatherRiver Imperial Kern Mojave MontereyNorthernSonomaPlacerSacra-mentoSanDiegoSanJoaquinSanLuisObispoSantaBarbaraShastaSouthCoastThe-hama VenturaYolo-SolanoRuleReference63 FR176:48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426485 218 442 67 4601 433 323 3:31 1113 4:39 74.2 2.14AdoptedSep98Jun77 Jul 97 Mar 78July79 1979 Sep 94June91 Nov 82Apr72 Feb 79 May 79 Apr-02Jun79 Dec 78Nov77 Apr 91 Mar-02 Oct 71May02Sep77Aug-02 Jun 79 Nov-01Last AmendedFeb00Jun00 Mar-03 Nov 01Aug02 Jul-02 Sep 94 Nov-02 Feb-05Sep-06 Feb-03 Apr-02Dec-01May-01Dec-01 Oct-01 Nov-01Jun-06 Nov-01Antenna 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530 530Anti-Fouling 450 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400Anti-Graffiti 600 340BituminousCoatings andMastics500BituminousRoof Coatings 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300BituminousRoof Primers 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350Bond Breakers 600 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350CalcimineRecoaters 475ChalkboardResurfacers 450ConcreteCuringCompounds 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 100 350 350 350ConcreteCuringCompoundsfor Roadwaysand Bridges350ConcreteCuring andSealingCompounds700ConcreteProtective 400ConcreteSurfaceRetarders780ConversionVarnishes 725Dry Fog 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 150 400 400 400Extreme HighDurability 800Faux Finishing/Glazing(Japans) 700 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350California Air Resources Board D-2 Sept - 07Table D-1: Summary of Architectural Coating Rules and VOC Limits1in CaliforniaAgencyU.S.EPA CARB AntelopeBayArea Butte ColusaElDoradoFeatherRiver Imperial Kern Mojave MontereyNorthernSonomaPlacerSacra-mentoSanDiegoSanJoaquinSanLuisObispoSantaBarbaraShastaSouthCoastThe-hama VenturaYolo-SolanoRuleReference63 FR176:48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426485 218 442 67 4601 433 323 3:31 1113 4:39 74.2 2.14Fire Proofing,Exterior 350Fire Resistive 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350Fire Retardant,Clear 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650 650Fire Retardant,Opaque(Pigmented) 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350Fire Retardant/Resistive,Clear 850Fire Retardant/Resistive,Opaque 450Flats 250 100 100 100 100 100 (250)2100 100 100 100 100 100 100 100 100 100 100 100 100 503100 100 100Flats, Specialty 400Floor 400 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 50 250 250 250Flow 650 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420Form ReleaseCompounds450 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250Graphic Arts(Sign Paints) 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500Heat Reactive 420HighTemperatureIndustrialMaintenance420 420HighTemperature 650 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420ImpactedImmersion 780IndustrialMaintenance450 250 250 250 250 250 420 250 250 250 250 250 250 250 250 250 250 250 250 250 1003250 250 250Lacquers,Clear Brushing 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 680 275 680 680 680Lacquers,Clear orOpaque/Pigmented(including clearlacquersandingsealers) 680 550 550 550 550 550 680 550 550 550 550 550 550 550 550 550 550 550 550 550 275 550 550 550Low SolidsCoatings1120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120 120Low SolidsStains1120 120Low Solids 120 120California Air Resources Board D-3 Sept - 07Table D-1: Summary of Architectural Coating Rules and VOC Limits1in CaliforniaAgencyU.S.EPA CARB AntelopeBayArea Butte ColusaElDoradoFeatherRiver Imperial Kern Mojave MontereyNorthernSonomaPlacerSacra-mentoSanDiegoSanJoaquinSanLuisObispoSantaBarbaraShastaSouthCoastThe-hama VenturaYolo-SolanoRuleReference63 FR176:48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426485 218 442 67 4601 433 323 3:31 1113 4:39 74.2 2.14WoodPreservatives1MagnesiteCement600 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450 450Mastic Texture 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300 300MetallicPigmented 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500 500Multi-Color 580 250 250 250 250 250 420 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250NonferrousOrnamentalMetalLacquers andSurfaceProtectants870NonflatCoatings 380 150 150 150 150 150 (250)2150 150 150 150 150 150 150 150 150 150 150 150 150 50 150 150 150Nonflat HighGloss Coatings 250 250 250 250 250 (250)2250 250 250 250 250 250 250 250 250 250 250 250 250 50 250 250 250Nuclear 450Pre-TreatmentWash Primers 780 420 420 420 420 420 675 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420 420Primers andUndercoaters 350Primers,Sealers, andUndercoaters 200 200 200 200 200 350 200 200 200 200 200 200 200 200 200 200 200 200 200 100 200 200 200Quick DryEnamels 450 250 250 250 250 250 400 250 250 250 250 250 250 250 250 250 250 250 250 250 50 250 250 250Quick DryPrimers,Sealers, andUndercoaters450 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 200 100 200 200 200RecycledCoatings 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250Repair andMaintenanceThermoplastic650Roof 250 250 250 250 250 250 300 250 250 250 250 250 250 250 250 250 250 250 250 250 50 250 250 250Roof,Aluminum 100RustPreventative 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 100 400 400 400SandingSealers 275SandingSealers (NonLacquer)550 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350Sealers 400California Air Resources Board D-4 Sept - 07Table D-1: Summary of Architectural Coating Rules and VOC Limits1in CaliforniaAgencyU.S.EPA CARB AntelopeBayArea Butte ColusaElDoradoFeatherRiver Imperial Kern Mojave MontereyNorthernSonomaPlacerSacra-mentoSanDiegoSanJoaquinSanLuisObispoSantaBarbaraShastaSouthCoastThe-hama VenturaYolo-SolanoRuleReference63 FR176:48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426485 218 442 67 4601 433 323 3:31 1113 4:39 74.2 2.14(includinginterior clearwood sealers)Shellacs, Clear 730 730 730 730 730 730 730 730 730 730 730 750 730 730 730 730 730 730 730 730 730 730 730 730Shellacs,Opaque/Pigmented550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550SpecialtyPrimers 100SpecialtyPrimers,Sealers, andUndercoaters 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350Stains 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250 250Stains, Clear 550Stains, Exterior 100Stains, Interior 250Stains, Semitransparent 550 350Stains,Opaque 350 350StainControllers720SwimmingPool 600 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340SwimmingPool Repair &Maintenance 340 340 340 340 340 650 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340 340TemperatureIndicatorSafety 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550 550ThermoplasticRubber andMastics 550Traffic 150 150 150 150 150 150 250 150 150 150 150 150 150 150 150 150 150 150 150 150 100 150 150 150Varnishes 450 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 275 350 350 350WaterproofingSealers 250 250 250 250 250 400 250 250 250 250 250 250 250 250 250 250 250 250 250 100 250 250 250WaterproofingConcrete/MasonrySealers 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 100 400 400 400Water ProofingSealers andTreatments 600California Air Resources Board D-5 Sept - 07Table D-1: Summary of Architectural Coating Rules and VOC Limits1in CaliforniaAgencyU.S.EPA CARB AntelopeBayArea Butte ColusaElDoradoFeatherRiver Imperial Kern Mojave MontereyNorthernSonomaPlacerSacra-mentoSanDiegoSanJoaquinSanLuisObispoSantaBarbaraShastaSouthCoastThe-hama VenturaYolo-SolanoRuleReference63 FR176:48848 SCM 1113 8-3 230 2.26 215 3.15 424 410.1 1113 426485 218 442 67 4601 433 323 3:31 1113 4:39 74.2 2.14Water ProofingSealers andTreatments,Opaque 600WoodPreservatives 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350 350WoodPreservatives,Below Ground 550 350 350WoodPreservatives,Clear andSemitransparent550 350WoodPreservatives,Opaque 350 350Zinc RichIndustrialMaintenancePrimers 100Zone Marking 450Notes:1. Volatile Organic Compound (VOC) limits are expressed as “VOC Regulatory” or “Coating VOC” (gramsof VOC per liter of coating, less water and exempt compounds) for allcategories except Low Solids. The VOC limit for Low Solids is expressed as VOC Actual or Material VOC (grams VOC per liter ofcoating, including water and exemptcompounds)2. Parentheses indicate 250 g/l VOC limitsthat are based on El Dorado’s default provision, but the limitsare not specificallystated in the rule.3. The South Coast AQMD Rule 1113 VOC limitfor Flat coatings becomes effective on 7/1/08.Rule 1113 allows for the use of tertiary Butyl Acetate as an exempt solvent to meetthe 100 g/l VOC limit for the Industrial Maintenance category only.4. The EPA rule states that ifa coating is not included in their table of VOC limits, it is classified as either a Flat (250 g/l) or Nonflat (380 g/l) based on the gloss level.The ARB 2000 SCM and many district rules state that, if a coating is not included in their table of VOC limits, it is classified as either a Flat (100 g/l) or Nonflat (150 g/l) based onthe gloss level.5. California districts not mentioned in this table are subject to the VOC limits inthe U.S. EPA National Architectural Coating Rule2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX E:

EMISSION REDUCTION CALCULATION METHODOLOGY2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 072007 ARB SCM for Architectural Coatings

California Air Resources Board E-1 Sept - 07 

### Emission Reduction Calculations

ARB staff estimated emission reductions based on 2004 sales data, as reported in the 2005 Survey. For each category with a proposed reduction in VOC limit, ARB staff calculated the expected emissi on reductions for each product that was reported in that category. For each reported product in the survey,

[Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions]

where
“Pre-Limit Emissions” are calculated dire ctly from survey data for each product, as reported
“Post-Limit Emissions” are estimates based on the potent ial impact of the lower
VOC limit

ARB staff used the following assumpti ons and protocols to perform emission
reduction calculations:

• When estimating “Post-Limit Emissions ”, we assumed that the volume percent of solids remained constant for each product after it was reformulated to meet the proposed VOC limit.

• When estimating “Post-Limit Emissi ons”, we assumed that the sales volume remained constant for each product after it was reformulated to meet the proposed VOC limit.

• When estimating “Post-Limit Emissions ”, we assumed a portion of the VOC in each product was replaced by either water or exempt compounds after the product was reformulated to meet the proposed VOC limit.

• If a product was included in an averaging program and had a high VOC
content that exceeded t he limit in the 2000 SCM, we did not calculate emission reductions from the produc t’s high VOC content. For high-VOC products in averaging programs, we only calculated emission reductions
from the VOC limit in the 2000 SCM down to the proposed VOC limit.

• If a product was noncompliant and had a high VOC content that exceeded the limit in the 2000 SCM, we did not calculate emission reductions from the product’s high VOC content. Fo r high-VOC noncompliant products, we only calculated emission reductions from the VOC limit in the 2000 SCM down to the proposed VOC limit.

• If a product was “overcompliant” and had a low VOC content that was below the limit in the 2000 SCM, but above the proposed limit, we only
calculated emission reductions from the product’s actual VOC content down to the proposed VOC limit.

• If a product was “overcompliant” and had a low VOC content that was already below the proposed limit, no em ission reductions were calculated.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-2 Sept - 07 

### • Emission reductions were only calc ulated for products sold in large containers (greater than one liter), because small c ontainers (one liter or less) are exempt from the SCM VOC limits.

The next section of this appendix contains a document with a detailed explanation of the met hodology that was used to calculate emissions and
emission reductions.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-3 Sept - 07 

### NOTE: The following document was su bmitted to the United States Environmental Protection Agency in December, 2005, in response to a request for comments regarding emission reducti on calculations methods. This
document describes ARB’s recommended methodology for calculation of
emission reductions.

California Air Resources Board (ARB) Comments

Reference: Federal Register, Vol. 70, No. 168, August 31, 2005, U.S. Environmental Protection Agency (U.S . EPA), “Advance Notice to Solicit Comments, Data and Information for De termining the Emissions Reductions
Achieved In Ozone Nonattainment and Maintenance Areas From the Implementation of Rules Limiting the VOC Content of AIM Coatings” (i.e., ANPR)

Background: U.S. EPA is soliciting comments, data and information for determining how to calculate the reducti ons in volatile organic compound (VOC)
emissions achieved in ozone nonattain ment and maintenanc e areas from the implementation of rules which limit the VOC content of architectural coatings (commonly referred to as architectura l and industrial maintenance, or AIM, coatings). In response to the ANPR, ARB is submitting a recommended methodology that is detailed below.

ARB’s Recommended Methodology for Ca lculating Emission Reductions

ARB has completed seven surveys of AIM c oatings sold in California, and we are currently working on our eighth AIM surv ey. A summary of the surveys is provided below:

Surveyed
Calendar
Year Sales
Volume (gallons) VOC
Emissions (pounds) 1 

### VOC Emissions per Gallon Sold

(lb VOC/gal)
1975 48,206,000 82,417,000 1.71
1980 57,247,000 91,949,000 1.61
1984 58,481,000 97,718,000 1.67
1988 77,876,000 84,124,000 1.08
1990 77,056,000 77,236,000 1.00
1996 87,496,000 72,594,000 0.83
2000 98,455,172 80,104,000 0.81 2004 In progress - -
1. Emissions do not include emissions from thinning and cleanup solvents.



### The most recent three surveys have collected particularly detailed data, including: VOC ingredient weight percentages; VOC ACTUAL 

### (a.k.a., Material VOC); VOC REGULATORY 

### (a.k.a., Coating VOC); and Volume Percent Solids. ARB and the local air districts have used this survey data to characterize specific2007 ARB SCM for Architectural Coatings

California Air Resources Board E-4 Sept - 07 

### coating categories and conduc t detailed analyses of the impacts that may result
from lower VOC limits.

Based on our experience, we believe that the methodology for calculating emission reductions is dependent upon the ty pe of data that are available to support the calculation. If detailed survey data are available that include specific product information, a detailed analysis of potential reductions can be conducted for each product. If no detailed data are av ailable, it will be necessary to use a more general approach that relies on em ission factors and estimated product parameters, as illustrated in the following table.

AVAILABLE DATA EMISSION REDUCTION
CALCULATION METHOD Option
1: Detailed Product Information is Available, Including:

• VOC ACTUAL



### • VOC REGULATORY



### • Volume % Solids

• Sales Volume Calculate potential emission reductions for each reported product in each coating category.

Option
2: Only General Data are Available:

• e.g., Nationwide Sales and Population Calculate overall emission reductions for entire coating category.

Each of these approaches is discussed below.

Option 1: Detailed Emission Inventory

Step 1: Identify the available data. Conducting a survey of coating manufacture rs is one of the best ways to collect detailed data on the AIM coatings being so ld in the area of concern. It is important that survey data be representative of the geographic area and the appropriate VOC limits. Fo r example, the most re cent survey data from California may not be representative of c oatings that are being sold elsewhere in the United States, because California ’s longstanding VOC limits have been generally lower than those in other states. In addition, coatings that have high sales volumes in California may have lowe r sales volumes in other parts of the country.

Available data should include a detailed survey with the following information for each reported AIM product:

• VOC ACTUAL 

### (Material VOC)

• VOC REGULATORY 

### (Coating VOC)

• Volume % Solids

• Sales Volume (gallons)2007 ARB SCM for Architectural Coatings

California Air Resources Board E-5 Sept - 07 

### Step 2: Calculate emission reductions for each product. (see Appendix for details)

Emission reductions represent the differ ence between the VOC emissions before a limit is adopted and the emissi ons after a limit is adopted.

For each reported product in the survey,

[Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions]

“Pre-Limit Emissions” can be calculated directly from survey data for each product:

[Pre-Limit Emissions, lbs VOC] = [VOC ACTUAL 

### , lb VOC/gal coating]*[Sales Volume, gals coating]

“Post-Limit Emissions” are estimates based on the potent ial impact of the lower
VOC REGULATORY 

### limit. When the VOC REGULATORY 

### limit is lowered, some coatings will need to be reformulated and, cons equently, they will have a new VOC ACTUAL 

### value. It’s possible to predict a new VOC ACTUAL 

### value using the following equation:

[NEW VOC ACTUAL 

### ] = [Avg. VOC Density, g/l]*[VOC REGULATORY 

### Limit, g/l]*[Vol. % Solids] ([Avg. VOC Density, g/l]-[VOC REGULATORY 

### Limit, g/l])



### where Average VOC Density = 880 grams/liter
VOC REGULATORY 

### Limit = New VOC REGULATORY 

### Limit, grams/liter
Vol. % Solids = Volume Percent So lids, as reported for each product

[Post-Limit Emissions, lbs VOC] = [NEW VOC ACTUAL 

### , lb VOC/gal co ating]*[Sales Volume, gals coating]

Calculation of the predicted new VOC ACTUAL 

### is based on the following assumptions:

• Maintain constant Volume % Solids. It is assumed that the volume perc entage of solids in the reformulated coating will be the same as the volume percentage of solids for the coating reported in the survey. When analyzing our survey data, we
have not found a linear correlation between VOC ACTUAL 

### values and volume percentage of solids. This is illustrated in Figure 1, a scatter diagram that shows volume percentage of solids vs. VOC ACTUAL 

### content for Flat and Nonflat architectu ral coatings. Therefore, we see no need to adjust solids contents when analyzing the effects of lower
VOC limits.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-6 Sept - 07 

### Because we are assuming the volume percentage of solids remains constant in the coatings, we use t he reported volume of coatings when estimating the “Post-Limit Emissions ”. There is no need to adjust the reported volume up or down to account for the same amount of overall solids being applied to surfaces.

• Maintain constant sales volume. As just mentioned, it is assumed that the volume of reformulated coating will be the same as the volume of existi ng coatings reported in the survey. However, some have argued that this approach
underestimates future sales volume , because they believe it takes more low-VOC waterborne coating (e .g., 90%-100% more) to provide the same amount of hiding power as a high-VOC solventborne coating. A gallon of waterborne coating gener ally contains a lower volume percentage of solids than a gallon of solventborne coating, and it is assumed that less solids means less hiding power. ARB recently sponsored a research project that di sproves this claim. The project tested the hiding properties of te n solventborne coatings and twenty waterborne coatings by determini ng the quantity of coating that was required to provide equivalent hiding. On average, it took approximately 1.3 gallons of wate rborne coating and 1.1 gallons of solventborne coating, a difference of only 18%, to provide equivalent hiding when painting a typical room . (Incidentally, the waterborne coating only emitted an average of 0.3 lbs of VOCs, while the solventborne coating emitted 2.9 lbs of VOCs.) Therefore, we believe this study also supports our assumption to keep the coating volume
constant. Some results from this research project are provided in Figure 2, which contains graphs that illustrate the gallons of coating required to provide hiding vs. VOC content.

• Assume a portion of the VOC in th e product is replaced by either water or exempt compounds to meet the new VOC REGULATORY 

### limit.

Step 3: Determine Overall Emission Reduction Percentage.

After emission reductions are calculated for each product, add up the individual reductions to determine the overall emission reduction percentage:

[% Reduction] = ([Total Pre-Limit Emissi ons] – [Total Post-Limit Emissions]) [Total Pre-Limit Emissions]2007 ARB SCM for Architectural Coatings

California Air Resources Board E-7 Sept - 07 

### Figure 1: Volume % Solids vs. VOC ACTUAL 

### *

FLATS [Volume % Solids] vs. [VOC ACTUAL ]

0 10 20 30 40 50 60 70 80 90 100

0 20 40 60 80 100 120 140 160 180

VOC ACTUAL (g/l)Volume % Solids

NONFLATS - HIGH, MEDIUM & LOW GLOSS [Volume % Solids] vs. [VOC ACTUAL ]

0 10 20 30 40 50 60 70 80 90 100

0 50 100 150 200 250 300

VOC ACTUAL (g/l)Volume % Solids

*Data obtained from ARB 2001 Architectural Coating Survey. Note: Charts do not include coatings with VOC REGULATORY greater than 250 g/l.2007 ARB SCM for Architectural CoatingsCalifornia Air Resources BoardE-8Sept - 07Figure 2: Gallons of Coating Required to Provide Adequate Hiding When Painting a Typical Room*Architectural Coatings - WATERBORNE[Gallons to Hide] vs. [VOCACTUAL]0.81.01.21.41.61.80 20 40 60 80 100 120VOCACTUAL(g/l)

Gallons of Coating to Hide 352 square feetArchitectural Coatings - SOLVENTBORNE[Gallons to Hide] vs. [VOCACTUAL]0.81.01.21.41.61.80 50 100 150 200 250 300 350 400VOCACTUAL(g/l)

Gallons of Coating to Hide 352 square feetArchitectural Coatings - WATERBORNE[Gallons to Hide] vs. [VOCREGULATORY]0.81.01.21.41.61.80 50 100 150 200 250VOCREGULATORY(g/l)

Gallons of Coating to Hide 352 square feetArchitectural Coatings - SOLVENTBORNE[Gallons to Hide] vs. [VOCREGULATORY]0.81.01.21.41.61.80 50 100 150 200 250 300 350 400VOCREGULATORY(g/l)

Gallons of Coating to Hide 352 square feet* Dimensions of a typical room are 10 ft. x 12 ft. with an 8-footceiling (352 sq. ft.) Data obtained from: Censullo, A.C., D.R. Jones, M.T. Wills, “Correlation Between Solids Content andHiding as it Relates to Calculation of VOC Content inArchitectural Coatings”, Table 14, dated December 2004.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-9 Sept - 07 

### Option 2: General Emission Inventory

Step 1: Identify the available data. If detailed local survey data are not available, emission reductions can be estimated using general publicly-available information. At a minimum, the available data should include the following, both of which can be obtained from the U.S. Census website:

• Nationwide Sales Volume

• Population or Housing Unit Data (state and national)

Nationwide coating sales volume can be obt ained from the followi ng report that is
available on the U.S. Census website:

• Current Industrial Report, MA325F – Paint and Allied Products http://www.census.gov /industry/1/ma325f04.pdf

(Note: When using this report, AIM coat ings include those titled “Architectural Coatings”, “Industrial New Construction and Maintenance Paints”, and “Traffic Marking Paints”.)

After using the Current Industrial Report to identify total AIM sales nationwide, it’s possible to assign a portion of the nationwide sales to an i ndividual state, by using the state’s percentage of national population or housing units. P opulation data and housing
unit data can be found on the follo wing U.S. Census website:

• http://www.census.gov/popest/sta tes/tables/NST-EST2003-01.pdf http://factfinder.census. gov/home/saff/main.html

Step 2: Determine appr opriate emission factors. Use an emission factor based on pounds VOC emitted per gallon of coating (i.e., VOC ACTUAL 

### .) ARB Architectural Coating Surveys can be used to identify salesweighted average values for VOC ACTUAL 

### in various categories. Survey reports are readily available online which include data su mmaries for coating sales that occurred during calendar years 1990, 1996, and 2000. For some ca tegories, the types of coatings that were reported in older ARB surveys may be similar to the types of coatings being sold currently in other states where VOC limits are higher. However, it is important to note that coatings sold in California have hi storically been subject to more stringent VOC limits than coatings sold elsewhere in the United States. For example, in 1990, Nonflat architectural coatings in Ca lifornia were being regulated with a 250 g/l VOC limit. This limit is significantly lo wer than the 380 g/l VOC limit that was adopted
under the U.S. EPA’s 1998 National Vola tile Organic Compound Emission Standards for Architectural Coatings, which is currently in place in much of the U.S. Due to these differences, emission factors based on California survey data may be lower than the appropriate factors for other areas of the Un ited States. Alternat ively, the summary2007 ARB SCM for Architectural Coatings

California Air Resources Board E-10 Sept - 07 

### table on page 1 of this document can be used to estimate an ov erall emission factor for architectural coatings.

ARB staff do not recommend using ARB’s on- line emission inventor y data to determine emission factors on a per capita basis. Th is data incorporates highly localized information that may not be appropriate for other areas. For example, the growth percentages that are used to develop emission forecasts are specific to different California county government organizations. In addition, California has 35 air districts
and these districts can have different architec tural coating regulations, which result in
different control factors within the emissions inventory. Air distri cts in California can have one of the following three types of architectural coating ru les: (1) A rule that is based on ARB’s 2000 Suggested Control M easure; (2) U.S. EPA’s 1998 National Volatile Organic Compound Emission Standards for Architectural Coatings; or (3) the South Coast Air Quality Management Distric t’s Rule 1113. For these reasons and others, we believe that state wide survey data from actual survey reports are the best source of information when trying to develop general emission factors.

Step 3: Determine appropriate control factors. The supporting documentation for architectural coating regulations will usually contain the expected percent reduction in VOC emissions that will result when the regulation is implemented (i.e., the control fa ctor.) Sources of control factors include the following:

• ARB Staff Report for the Proposed Suggested Control Measure for Architectural Coatings, Exec utive Summary; June 6, 2000; http://www.arb.ca.gov/coati ngs/arch/sreport/vol1-2.pdf

• South Coast Air Quality Management District Rule 1113, amendments adopted on: Nov. 8, 1996; May 14, 1999; and Dec. 5, 2003. SCAQMD staff reports are available at http://www.aqmd.gov

It is also possible to estimate control factor s, using a variation of the method discussed previously in Option #1 and the following equations:

[Control Factor, %] = [Pre-Limit VOC ACTUAL 

### , g/l]-[NEW VOC ACTUAL 

### , g/l] [Pre-Limit VOC ACTUAL 

### , g/l]

where

Pre-Limit VOC ACTUAL 

### , g/l = The VOC ACTUAL 

### value for a typical coating, prior to adoption
of a new limit. In some ca ses, sales-weig hted average VOC ACTUAL 

### values can be obtained from ARB su rvey reports. However, it is important to note that the ARB values may be lower than those found in other parts of the United States.

[NEW VOC ACTUAL 

### ] = [Avg. VOC Density, g/l]*[VOC REGULATORY 

### Limit, g/l]*[Vol. % Solids] ([Avg. VOC Density, g/l]-[VOC REGULATORY 

### Limit, g/l])2007 ARB SCM for Architectural Coatings

California Air Resources Board E-11 Sept - 07 

### Average VOC Density = 880 grams/liter
VOC REGULATORY 

### Limit = New VOC REGULATORY 

### Limit, grams/liter Vol. % Solids = Volume Percent Solids, % for a typical coating. In some cases, sales-weighted average Volume % Solids values can be obtained from ARB survey reports. However, it is important to not e that the ARB values may be different than those found in other parts of the United States.

Step 4: Calculate overall emission reductions.

Determine potential emission reductions (see Appendix for details.)

For the entire inventory, [Emission Reductions, lbs] = [Coating Sales, gals]*[Emission Factor, lb/gal]*[Control Factor, %]

Conclusion: ARB staff believes that the methodolog y that is used for calculation of emission reductions for AIM coatings s hould be flexible enough to accommodate the type of data that are available to support the analysis. It is unlikely that there is one method that will be suitable for all regions of the country, because the types of coatings and the available data vary widely depending on location. Therefore, we encourage U.S. EPA to develop guidance on this topic that gives states and regions the flexibility to account for these differences, rather than adopting a rule that would result in a prescriptive approach.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-12 Sept - 07 

### This Appendix contains detailed emissi on reduction calculations, based on the two approaches discussed in the main document.

Option 1: Detailed Emission Inventory

Step 1: Identify the available data.

Product VOC ACTUAL 

### (g/l) VOC REGULATORY 

### (g/l) Volume %
Solids Sales Volume (gals) #1 78 190 33% 10,000 #2 110 220 39% 7,500 #3 350 350 55% 5,000 #4 55 140 34% 2,500

Step 2: Calculate emission reductions for each product.

Eqn. 1: [Pre-Limit Emissions, lbs VOC] = [VOC ACTUAL 

### , lb VOC/gal coating]*[Sales Volume, gals coating]

Eqn. 2: [NEW VOC ACTUAL 

### , g/l] = [Dvoc, g/l]*[VOC REGULATORY 

### Limit, g/l]*[Vs] ([Dvoc, g/l]-[VOC REGULATORY 

### Limit, g/l])
where Dvoc = Average VOC Density, which is assumed to be approximately 880 grams/liter
VOC REGULATORY 

### Limit = New VOC REGULATORY 

### Limit, grams/liter Vs = Volume Percent Solids, %

To convert from units of (g rams/liter) to (lbs/gal):

[VOC ACTUAL , lbs VOC ] = [VOC ACTUAL , grams VOC ] * [1 lb VOC] * [3.785 liters coating] gal coating liter coating [454 grams VOC i [1 gal coating]



### Eqn. 3: [Post-Limit Emissions, lbs VOC] = [NEW VOC ACTUAL 

### , lb VOC/gal]*[Sales Volume, gals coating]

Eqn.4: [Emission Reductions] = [Pre-Limit Emissions] – [Post-Limit Emissions]

Example Calculation for Product #1:

[Pre-Limit Emissions] = [78 gram s/liter]*[1 lb/ 454 grams]*[3.785 liters/gal]*[10,000 gal s] = 6,503 lbs VOC

Assume the New VOC REGULATORY 

### Limit is 150 g/l.

[NEW VOC ACTUAL 

### ] = [880 g/l]*[150 g/l]*[33%] = 60 g/l ([880 g/l]-[150 g/l])2007 ARB SCM for Architectural Coatings

California Air Resources Board E-13 Sept - 07



### [Post-Limit Emissions] = [60 g/l]*[1 lb/454 grams]*[3.785 liters/gallon]*[10,000 gals] = 5,002 lbs VOC

[Emission Reductions] = [6,503] – [5,002] = 1,501 lbs VOC

A summary of the emission reduction ca lculations for Products #1- #4 is provided below. All products are in the same coating category with a new
VOC REGULATORY 

### Limit of 150 g/l.

Product Pre-Limit
Emissions (lbs VOC) NEW
VOC ACTUAL 

### (g/l) Post-Limit
Emissions (lbs VOC) Emission
Reduction (lbs VOC) #1 6,503 60 5,002 1,501 #2 6,878 71 4,440 2,438 #3 14,590 100 4,169 10,421

#4 1,146 No reductions were calculated for Product #4, because it already complied with the new
VOC REGULATORY 

### limit. 0 TOTAL: 29,117 14,360

Step 3: Determine Overall Emission Reduction Percentage.

For these four products, the overa ll emission reduction percentage:

[% Reduction] = ([29,117] – [14,360]) = 51% [29,117]

Option 2: General Emission Inventory

Step 1: Identify the available data.

For example, the following table illustrates how to estimate coating usage data
for Arizona:

United States Arizona Population in 2004 285,691,501 5,633,997 (2% of United States) Housing Units 122,671,734 2,458,231 (2% of United States)
Sales Volume:

Architectural Coatings 822,186,000 gals 16,443,720 gals
Industrial New Construction and Maintenance Paints - Interior 22,492,000 gals 449,840 gals
Industrial New Construction and Maintenance Paints - Exterior 35,167,000 gals 703,340 gals Traffic Marking Paints 35,907,000 gals 718,140 gals2007 ARB SCM for Architectural Coatings

California Air Resources Board E-14 Sept - 07 

### Step 2: Determine appr opriate emission factors.

Category Emission Factors*, based

on 1990 sales

(lb VOC/gal) Emission Factors*, based

on 1996 sales

(lb VOC/gal) Architectural Coatings 0.93 0.74
Industrial New Construction
and Maintenance Paints –
Interior & Exterior 2.86 2.43 Traffic Marking Paints 0.90 0.93
*Emission factors are based on data reported in ARB Architectural Coating surveys and they do not
include emissions from the use of thinning and cleanup solvents.



### Example emission calculations are prov ided below, using emission factors based
on ARB 1996 data:

Category Example Emissions Calculations

Architectural Coatings [16,443,720 gals]*[0. 74 lb/gal] = 12,168,353 lbs
Industrial New Construction
and Maintenance Paints –
Interior & Exterior [449,840+703,340 gals] *[2.43 lb/gal] = 2,802,227 lbs Traffic Marking Paints [718,140 gal s]*[0.93 lb/gal] = 667,870 lbs

Total Pre-Limit Emissions = 12,168,353 + 2,802,227 + 667,870 lbs = 15,638,450 lbs emitted

Step 3: Determine appropriate control factors.

Listed below are the AIM VOC limit reductions from ARB’s 2000 Suggested Control Measure. For California, these r eductions resulted in a control factor of approximately 20% from a 1996 baseline. However, control factors can vary, depending on the particular em ission inventory for an area and the combination
of old limits and new limits.

Category Control Factor = 20%, based on
ARB SCM

Old Limit New
Limit
Flat 250 100
Industrial Maintenance 420 250 Lacquers 680 550
Multi-Color 420 2502007 ARB SCM for Architectural Coatings

California Air Resources Board E-15 Sept - 07 

### Category Control Factor = 20%, based on
ARB SCM

Old Limit New
Limit Nonflat: High Gloss 250 250
Nonflat: Low Gloss 250 150
Nonflat: Medium Gloss 250 150 Primer, Sealer, Undercoater 350 200 Quick Dry Enamel 400 250 Quick Dry Primer, Seal er, Undercoater 450 200
Roof 300 250
Rust Preventative 420 400 Stains: Clear/Semitransparent & Opaque 350 250

Swimming Pool Repair & Maintenance 650 340 Traffic Marking Paints 250 150 Waterproofing Sealers 400 250

Alternatively, control factors for indivi dual categories can be estimated using the following equations:

[Control Factor, %] = [Pre-Limit VOC ACTUAL 

### , g/l]-[NEW VOC ACTUAL 

### , g/l] [Pre-Limit VOC ACTUAL 

### , g/l]

where

Pre-Limit VOC ACTUAL 

### , g/l = The VOC ACTUAL 

### value for a typical coating, prior to adoption of a new limit. In so me cases, sales-weighted average VOC ACTUAL 

### values can be obtained from ARB survey reports. However, it is import ant to note that the ARB values may be lower than those found in other parts of the United
States.

[NEW VOC ACTUAL ] = [Avg. VOC Density, g/l]*[VOC REGULATORY Limit, g/l]*[Vol. % Solids] ([Avg. VOC Density, g/l]-[VOC REGULATORY Limit, g/l])



### Average VOC Density = 880 grams/liter
VOC REGULATORY 

### Limit = New VOC REGULATORY 

### Limit, grams/liter
Vol. % Solids = Volume Percent Solids , % for a typical coating. In some cases, sales-weighted average Volu me % Solids values can be obtained from ARB survey reports. However, it is important to note that the ARB values may be different than those f ound in other parts of the United
States.2007 ARB SCM for Architectural Coatings

California Air Resources Board E-16 Sept - 07 

### This alternative method has the advantage of being able to provide estimated emission reductions for individual categories, rather than using an overall control factor for all categories. To use this me thod, it is necessary to identify typical coatings that provide representat ive values for the Pre-Limit VOC ACTUAL 

### and Volume % Solids. This information can be obtained by working with
manufacturers and reviewi ng product data sheets.

Provided below is an example of estimated control factors for several categories. These factors were estimated using ARB architectural coating survey data, but the same approach can be used by inputti ng data obtained fr om manufacturers
and different values for the old and new VOC limits.

ARB SURVEY DATA - 1996 SALES

Coating Category SWA
VOC REG

(g/l) SWA
VOC ACTUAL (g/l) SWA Vol.
% Solids Old VOC REG Limit (g/l) New
VOC REG Limit (g/l) NEW
VOC ACTUAL (g/l) Estd.
Control
Factor Flats 98 40 35% 250 100 39 1%
Industrial Maintenance 300 291 60% 420 250 210 28% Lacquer – Clear 649 626 20% 680 550 293 53% Lacquer – Opaque 545 527 27% 680 550 396 25%
Multi-Color 263 163 33% 420 250 115 29% Nonflat - High Gloss 248 160 40% 250 250 N/A N/A
Nonflat – Low Gloss 134 61 36% 250 150 65 0%*
Nonflat - Medium Gloss 155 69 37% 250 150 67 3% Primer, Sealer,
Undercoater 170 118 37% 350 200 96 19% Quick Dry Enamels 403 393 50% 400 250 175 56% Quick Dry PSUs 303 272 44% 450 200 114 58%
Roof 23 16 45% 300 250 157 0%*
Rust Preventative 371 367 48% 420 400 352 4%
Stains – Clear 285 240 34% 350 250 119 51% Stains – Semitransparent 401 357 38% 350 250 133 63% Stains – Opaque 157 82 36% 350 250 126 0%* Swimming Pool Repair &
Maintenance 569 569 29% 650 340 161 72% Traffic Marking 154 111 58% 250 150 105 6% Waterproofing Sealers –
Clear 347 234 36% 400 250 126 46% Waterproofing Sealers – Opaque 219 191 47% 400 250 164 14%

* No estimated control factor c ould be calculated because the predicted “NEW VOC Actual” value was higher than the existing “SWA VOC Actual” value. Calc ulation of a control factor by this method requires
that the “NEW VOC Actual” be lower than the existing “SWA VOC Actual”. “N/A” = Not Applicable because the VOC limit was not changed. Nonflat – High Gloss is included for informational purposes only.



### Step 4: Calculate overall emission reductions.

[Emission Reductions, lbs] = [Coating Sa les, gals]*[Emission Factor, lb/gal]* [Control Factor, %]2007 ARB SCM for Architectural Coatings

California Air Resources Board E-17 Sept - 07 

### Category Example Emission Reduction Calculations

Architectural Coatings [16,443,720 gals]*[0.74 lb/gal]*[20%] = 2,433,671 lbs
Industrial New Construction
and Maintenance Paints –
Interior & Exterior [449,840+703,340 gals]*[2. 43 lb/gal]*[20%] = 560,446 lbs

Traffic Marking Paints [718,140 gals]*[0.93 lb/gal]*[20%] = 133,574 lbs

Total Reductions = 2,433,671 + 560,446 + 133,574 lbs = 3,127,691 lbs reduced

Assumptions: (1) Arizona’s current product mix is si milar to California’s 1996 product mix. (2) Arizona’s current VOC limits are similar to Calif ornia’s pre-2000 SCM limits. (3) The overall control factor is 20%.2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX F:

SCM WORKSHOP NOTICES2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07Linda S. Adams Secretary for
Environmental Protection

The energy challenge facing California is real . Every Californian needs to take imm ediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov

. 

### California Environmental Protection Agency

Printed on Recycled Paper 

# Air Resources Board

Robert F. Sawyer, Ph.D., Chair

1001 I Street • P.O. Box 2815 Sacramento, California 95812 • www.arb.ca.gov Arnold Schwarzenegge r Governor



### November 7, 2006

Dear Sir or Madam:

You are invited to participate in a public workshop to discuss proposed changes to the Air Resources Board’s (ARB or Board) Su ggested Control Measure for Architectural Coatings (SCM). The SCM is a model rule which has been used by California air pollution control districts to develop architec tural coating rules. Currently, twenty air
districts have rules based on the SCM that was approved by the Board in 2000.

At the workshop ARB staff will discuss the following:

• Project timeline and development activities;

• ARB’s architectural coating survey analysis;

• Districts’ State Implem entation Plan commitments;

• Coating category definitions and other SCM areas of concern; and

• Concept of reactivity-based standards.

The date, time, and location of the workshop are:

Date: Tuesday, December 12, 2006 Time: 10:00 a.m. to 12:00 p.m. Location: Training 2 West and East, 2nd Floor Address: Cal/EPA Headquarters
1001 I Street Sacramento, California 95812

If you wish to participate by phone, please c ontact Lynna Negri at (916) 324-8018 or at lnegri@arb.ca.gov to ensure that adequate phone lines are available. The dial-in number for phone participants is (866) 755-6191, passcode 2181331.

At least one week prior to the works hop, we will post an agenda and handouts on our
website at http://www.arb.ca.gov/coatings/arch/arch.htm . To be notified of when these materials are posted, please sign up for the Architectura l Coatings ListServe at http://www.arb.ca.gov/ listserv/arch-ctgs.htm

.

### Sir or Madam November 7, 2006 Page 2

We look forward to your participation in this workshop. If you have special accommodations or language needs, please c ontact Lynna Negri at (916) 324-8018 or

at lnegri@arb.ca.gov . TTY/TTD/Speech-to-Speech users may dial 7-1-1 for the California Relay Service. For public transpo rtation information, pl ease contact Regional Transit at (916) 321-BUSS or view the tr ansportation information on the California Environmental Protection Agency’s web site at http://calepa.ca.gov/epabldg/location.htm

.

If you have any questions about the workshop, please contact Mr. Jim Nyarady, Manager, Strategy Evaluation Section, at (916) 322-8273 or jnyarady@arb.ca.gov.

Sincerely,

Barbara Fry, Chief
Measures Assessment Branch

cc: Mr. Jim Nyarady, Manager Strategy Evaluation SectionLinda S. Adams Secretary for
Environmental Protection

The energy challenge facing California is real . Every Californian needs to take imm ediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov

. 

### California Environmental Protection Agency

Printed on Recycled Paper 

# Air Resources Board

Robert F. Sawyer, Ph.D., Chair

1001 I Street • P.O. Box 2815 Sacramento, California 95812 • www.arb.ca.gov A r nold Schwarzenegge r Governor



### February 8, 2007

Dear Sir or Madam:

You are invited to participate in a public workshop to discuss proposed changes to the Air Resources Board’s (ARB or Board) Su ggested Control Measure for Architectural Coatings (SCM). The SCM is a model rule which has been used by California air pollution control districts to develop architec tural coating rules. Currently, twenty air
districts have rules based on the SCM that was approved by the Board in 2000.

At the workshop ARB staff will discuss the following:

• Project timeline and development activities;

• Preliminary propos ed VOC limits; and

• Preliminary proposed revisions to coating categor y definitions.

The date, time, and location of the workshop are:

Date: Tuesday, March 13, 2007 Time: 1:30 p.m. to 3:30 p.m. Location: Training 1 East and West, 1st Floor Address: Cal/EPA Headquarters
1001 I Street Sacramento, California 95812

If you wish to participate by phone, please cont act Sarah Penfield at (916) 324-8181 or

at spenfiel@arb.ca.gov to ensure that adequate phone lines are available. The dial-in number for phone participants is (866) 755-6191, passcode 2181331.

Prior to the workshop, we will pos t an agenda and handouts on our website at http://www.arb.ca.gov/coatings/arch/arch.htm . To be notified of when these materials are posted, please sign up for the Ar chitectural Coatings ListServe at http://www.arb.ca.gov/ listserv/arch-ctgs.htm

.

### Sir or Madam February 8, 2007 Page 2

We look forward to your participation in this workshop. If you have special accommodation needs, please contact ARB’s Disab ility Coordinator at (916) 323-4916. If you are a person with limited English and would like to request interpreter services, please contact ARB’s Bilingual Manager at (916) 323-7053. TTY/TTD/Speech-toSpeech users may dial 7-1-1 for the Californi a Relay Service. For public transportation information, please contact Regional Tr ansit at (916) 321-BUSS or view the transportation information on the California En vironmental Protection Agency’s web site
at http://calepa.ca.gov/epabldg/location.htm

.

If you have any questions about the workshop, please contact Mr. Jim Nyarady, Manager, Strategy Evaluation Section, at (916) 322-8273 or jnyarady@arb.ca.gov.

Sincerely,

Barbara Fry, Chief
Measures Assessment Branch

cc: Mr. Jim Nyarady, Manager Strategy Evaluation SectionLinda S. Adams Secretary for
Environmental Protection

The energy challenge facing California is real . Every Californian needs to take imm ediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov

. 

### California Environmental Protection Agency

Printed on Recycled Paper 

# Air Resources Board

Robert F. Sawyer, Ph.D., Chair

1001 I Street • P.O. Box 2815 Sacramento, California 95812 • www.arb.ca.gov Arnold Schwarzenegge r Governor



### May 1, 2007

Dear Sir or Madam:

You are invited to participate in a public workshop to discuss proposed changes to the Air Resources Board’s (ARB or Board) Su ggested Control Measure for Architectural Coatings (SCM). The SCM is a model rule which has been used by California air pollution control districts to develop architec tural coating rules. Currently, twenty air
districts have rules based on the SCM that was approved by the Board in 2000.

At the workshop ARB staff will discuss the following:

• Project timeline and development activities;

• Draft proposed revisions to the SCM rule language;

• Draft proposed VOC limits; and

• Draft proposed revisions to coating category definitions.

The date, time, and location of the workshop are:

Date: Wednesday, June 6, 2007 Time: 9:00 a.m. to 12:00 p.m. Location: Training 1 East and West, 1st Floor Address: Cal/EPA Headquarters
1001 I Street Sacramento, California 95812

If you wish to participate by phone, please cont act Sarah Penfield at (916) 324-8181 or

at spenfiel@arb.ca.gov to ensure that adequate phone lines are available. The dial-in number for phone participants is (866) 755-6191, passcode 2181331.

Prior to the workshop, we will pos t an agenda and handouts on our website at http://www.arb.ca.gov/coatings/arch/arch.htm . To be notified of when these materials are posted, please sign up for the Ar chitectural Coatings ListServe at http://www.arb.ca.gov/ listserv/arch-ctgs.htm

.

### Sir or Madam May 1, 2007 Page 2

The energy challenge facing California is real . Every Californian needs to take imm ediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov

. 

### California Environmental Protection Agency

Printed on Recycled Paper 

### We look forward to your participation in this workshop. If you have special accommodation needs, please contact ARB’s Disab ility Coordinator at (916) 323-4916. If you are a person with limited English and would like to request interpreter services, please contact ARB’s Bilingual Manager at (916) 323-7053. TTY/TTD/Speech-toSpeech users may dial 7-1-1 for the Californi a Relay Service. For public transportation information, please contact Regional Tr ansit at (916) 321-BUSS or view the transportation information on the California En vironmental Protection Agency’s web site
at http://calepa.ca.gov/epabldg/location.htm

.

If you have any questions about the workshop, please contact Mr. Jim Nyarady, Manager, Strategy Evaluation Se ction, at (916) 322-8273 or jnyarady@arb.ca.gov

.

Sincerely,

Barbara Fry, Chief
Measures Assessment Branch

cc: Mr. Jim Nyarady, Manager Strategy Evaluation Section2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 07 

# APPENDIX G:

ECONOMIC ANALYSIS DETAILS2007 ARB SCM for Architectural Coatings

California Air Resources Board Sept - 072007 ARB SCM for Architectural Coatings

California Air Resources Board G-1 Sept - 07 

### Summary of Economic Analysis Methodology

Summary

The total cost of the proposed SCM to af fected businesses is estimated to be $4 million per year in annualized nonrecu rring costs and $8.3 million per year in recurring costs. This equates to $12.3 milli on dollars annually over the project horizon. This represents the cost of raw materials, research and development, equipment, testing, and training to arch itectural coatings manufacturers.

This appendix covers the methodology us ed in the Economic Analysis presented in Chapter 7. The methodology is sim ilar to what was used in previous ARB regulations (ARB, 1990; ARB, 1991; AR B, 1997; ARB, 1999; ARB, 2000; ARB, 2003; ARB, 2004; ARB, 2005) and follows guidelines recommended by Cal/EPA for economic analysis (Cal/EPA, 1996).

Methodology

For this analysis, we considered the impact to architectural coatings manufacturers. Although other entities such as distributors, retailers, end users and raw material suppliers may be impacted, coating manufacturers will be the primary entities affected.

First, we analyzed data from the 2005 Ar chitectural Coatings Survey to determine complying and noncomplying volume for the 16 categories that have a proposed change to the VOC limit, and a pr ojected emission reduction of more than .01 tons per day (tpd) outside of the South Coast Air Quality Management District (SCAQMD). We assumed that cost s would not be incurred for coatings in a category that did not hav e a proposed limit. We also determined the number of noncomplying products and the expected emi ssion reductions for each of these categories based on the survey data. T hese data are summarized in Table G-1.

Table G-1 Survey Data Inputs for Cost Calculations Outside of SCAQMD for Categories
with Greater Than .01 TPD Emission Reduction

Coating Category Proposed
Limit (g/l) Emission
Reductions (Tons/Day) Estimated # of Non-Compliant
Products Estimated # of Non-Compliant

Gallons per
Year 

### Aluminum Roof 400 0.19 48 193,566 Bituminous Roof 50 0.17 42 79,722 Concrete Masonry
Sealer 100 0.54 243 647,318 Dry Fog 150 0.31 39 120,535 Flat 50 3.12 2,079 19,213,031 Floor 100 0.07 167 100,8342007 ARB SCM for Architectural Coatings

California Air Resources Board G-2 Sept - 07 

### Table G-1 Survey Data Inputs for Cost Calculations Outside of SCAQMD for Categories
with Greater Than .01 TPD Emission Reduction

Coating Category Proposed
Limit (g/l) Emission
Reductions (Tons/Day) Estimated # of Non-Compliant
Products Estimated # of Non-Compliant

Gallons per
Year 

### Mastic Texture 100 0.10 22 79,316 Non Flat 100 2.79 2,121 12,649,813 Non Flat High Gloss 150 0.91 362 1,074,079 PSU 100 1.12 323 3,747,874 Roof 50 0.07 87 135,698 Rust Preventative 250 1.57 303 832,567 Specialty PSU 100 2.62 70 859,266 Traffic Marking 100 0.09 87 320,397 Waterproofing
Membrane 250 0.09 13 98,848 Wood Coatings 275 1.41 940 736,786 Total 15.2 6,946 40,889,649



### We collected data from manufacturers with the 2007 Economic Impacts Survey. This survey was sent to all manufacturers who responded to the 2005 Architectural Coatings Survey who manuf actured products in one of the affected categories. This survey collected in formation on the number of products that
would need to be reformulated due to the proposed limits of the SCM and the cost to reformulate those products.

Based on responses to the ARB Ec onomic Survey and discussions with manufacturers, more than half of the non-complying products that will be reformulated will be in response to the pr oposed limits of the SCAQMD. This is confirmed by comparing the portion of non-complying products in the ARB 2005 survey and the responses to the Economic Survey. For the purposes of this analysis, we assumed that half of the non-complying products would be reformulated due to the propos ed limits of the SCM.

From these responses, we sorted t he recurring and non-recurring costs by category where applicable, and applied the average of all responses in categories that did receive a specific response. This data is summarized in
Table G-2.2007 ARB SCM for Architectural Coatings

California Air Resources Board G-3 Sept - 07 

### Table G-2 Non-Recurring and Recurring Cost from 2007 ARB Economic Impacts Survey

Coating Category ARB Economic Survey Reported Nonrecurring Cost
to Reformulate (Dollars per Product) ARB Economic Survey Reported Non-Raw Material Recurring Costs (Dollars per Year per Product) 

### Aluminum Roof 11,625 $86,328 Bituminous Roof 17,171 $75,537 Concrete Masonry Sealer 6,068 $437,036 Dry Fog 7,332 $70,142 Flat 3,642 $3,739,082 Floor 14,893 $300,350 Mastic Texture 7,332 $39,567 Nonflat 4,014 $3,814,619 Nonflat High Gloss 4,719 $651,057 PSU 5,681 $580,916 Roof 17,281 $156,470 Rust Preventative 7,332 $544,946 Specialty PSU 4,263 $125,895 Traffic Marking 8,533 $156,470 Waterproofing
Membrane 7,332 $23,381 Wood Coatings 5,391 $1,690,590



### Based on the ARB survey, product data sheets and discussions with manufacturers, staff determined the ingr edients of typical complying and noncomplying formulations for the 20 categories. These formulations were sent out to industry for comments.

Data on the raw materials were obta ined from chemical manufacturers, distributors of raw materials, Chemical Market Reporter (CMR) Magazine, and
discussions with manufacturers. Resin co sts are the primary influence on raw materials cost for most coatings and, bec ause there are a variety of resins with differing costs, resins have the most variable impact on raw materials cost.
Resin costs were taken from the CMR chem ical prices in 2000, and were inflated by the producer price i ndex between 2000 and 2007 for plastic material and resin manufacturers (BLS, 2007).

In cases where there were no data ava ilable for an ingredient, a default price of $1.50 per pound was used.

Comparing the difference in raw materi al costs between typical complying and non-complying formulations gave us the amount of cost or cost savings in raw
materials a manufacturer would incur if changing from a typical non-compliant2007 ARB SCM for Architectural Coatings

California Air Resources Board G-4 Sept - 07 

### coating to a typical complying coating. These costs are summarized in
Table G-3.

Table G-3 Raw Material Cost Differential Between Complying and Non-Complying
Products

Coating Category Raw Material
Cost of a Typical Complying
Formulation Raw Material
Cost of aTypical NonComplying
Formulation Difference of Raw
Material Cost of Complying and Non-Complying per
Gallon 

### Aluminum Roof $3.17 $3.66 -$0.49 Bituminous Roof $2.57 $2.96 -$0.39 Concrete Masonry
Sealer $2.35 $3.52 -$1.17 Dry Fog $6.87 $8.71 -$1.85 Flat $4.13 $4.45 -$0.32 Floor $5.24 $4.24 $1.00 Mastic Texture $5.85 $4.43 $1.42 Nonflat $5.58 $4.86 $0.72 Nonflat High Gloss $4.35 $5.99 -$1.64 PSU $4.64 $4.23 $0.42 Roof $5.54 $7.48 -$1.94 Rust Preventative $5.98 $7.57 -$1.59 Specialty PSU $4.53 $6.30 -$1.77 Traffic Marking $3.79 $3.55 $0.24 Waterproofing
Membrane $12.27 $8.35 $3.90 Wood Coatings $5.00 $9.67 -$4.67



### These costs were multiplied by the non-complying volume to determine the recurring raw material related cost of the proposed limits.

The recurring costs from Table G-2 were multiplied by the number of products
that would need to be reformulated for each category. The total annual cost is
the sum of the raw material related cost s, the recurring non-raw material costs and annualized non-recurring costs. Thes e calculations are summarized in
Table G-4.2007 ARB SCM for Architectural Coatings

California Air Resources Board G-5 Sept - 07 

### Table G-4
Calculated Annual Cost

Coating Category Annual Recurring Costs (Raw

Material) Dollars per
Year Annual Recurring Costs (Non-raw Material) Dollars per
Year Annualized Nonrecurring
Cost Dollars

per Year Total Annual Cost per Year


### Aluminum Roof -$94,785 $86,328 $64,441.97 $55,985


### Bituminous Roof -$30,718 $75,537 $83,287.43 $128,106 

### Concrete Masonry
Sealer -$749,150 $437,036 $170,288.94 -$141,826 

### Dry Fog -$222,428 $70,142 $33,023 -$119,264


### Flat -$6,189,405 $3,739,082 $874,438 -$1,575,886



### Floor $100,339 $300,350 $287,232 $687,922


### Mastic Texture $112,598 $39,567 $18,629 $170,794


### Nonflat $9,120,928 $3,814,619 $983,224 $13,918,771 

### Nonflat High Gloss -$1,758,417 $651,057 $197,285 -$910,076


### PSU $1,563,126 $580,916 $211,915.10 $2,355,957


### Roof -$263,878 $156,470 $173,629 $66,220



### Rust Preventative -$1,324,934 $544,946 $256,566 -$523,423 

### Specialty PSU -$1,517,941 $125,895.00 $34,463 -$1,357,584 

### Traffic Marking $78,066 $156,470 $85,735 $320,271 

### Waterproofing
Membrane $385,012 $23,381 $11,008 $419,401 

### Wood Coatings -$3,443,964 $1,690,590 $585,185 -$1,168,189



### Total -$4,235,550 

### $12,492,381 $4,070,350 $12,327,181



### The cost effectiveness is determined by taking the total annual cost of a category and dividing by the annual emission reduction. Assuming all costs are passed on to consumers, we calculate the cost in crease per gallon. The cost increase per gallon to end users is determined by taking t he total cost of the category, dividing by the number of non-compliant gallons, and mu ltiplying by a factor of 4X. This represents the assumption that the co st of a product is doubled from the manufacturer to the distributor, and is doubled again from the distributor to the end user. Taking the raw material costs for complying and non-complying products, and using the same 4X multiplier gives cost increase per gallon. This
data is summarized in Table G-5.2007 ARB SCM for Architectural Coatings

California Air Resources Board G-6 Sept - 07 

### Table G-5
Calculated Cost-Effectiveness and Cost Increase Per Gallon

Coating Category Individual
Cost
Effectiveness
for Each Limit (Dollars

per Pound
VOC Reduced) Cost Increase to Consumers per Gallon (4X) Typical NonComplying Cost per Gallon Typical Complying Cost per Gallon


### Aluminum Roof $0.41 $1.16 $14.63 $12.67


### Bituminous Roof $1.02 $6.43 $11.84 $10.30 

### Concrete Masonry
Sealer -$0.36 -$0.88 $14.09 $9.40 

### Dry Fog -$0.52 -$3.96 $34.86 $27.47



### Flat -$0.69 -$0.33 $17.81 $16.52


### Floor $13.90 $27.30 $16.96 $20.94


### Mastic Texture $2.37 $8.61 $17.72 $23.40



### Non Flat $7.03 $4.40 $19.44 $22.32 

### Non Flat High
Gloss -$1.37 -$3.39 $23.96 $17.41


### PSU $2.73 $2.51 $16.90 $18.57


### Roof $1.38 $1.95 $29.94 $22.16



### Rust Preventative -$0.46 -$2.51 $30.30 $23.93 

### Specialty PSU -$0.71 -$6.32 $25.19 $18.12 

### Traffic Marking $4.76 $4.00 $14.18 $15.16 

### Waterproofing
Membrane $6.56 $16.97 $33.38 $48.96 

### Wood Coatings -$1.13 -$6.34 $38.70 $20.00 

### Weighted Average $1.12 $1.21



### A sensitivity analysis was conducted to determine the impacts on the annual costs from assumed changes to resin co sts, the primary va riable influence on
raw material costs. We conducted this analysis with four different runs, one
baseline and three assumed increases in resin prices. As Table G-6 shows, even with an extreme assumption of 50% increase in compliant resin price, the
overall cost-effectiveness of the proposed limits are still consistent with the cost effectiveness values for past ARB regulat ions shown earlier in Table 7-3.

We assumed the resin costs for complying coatings would increase by a certain level. Resin costs are the primary in fluence on raw materials cost for most coatings and, because there are a variety of resins wit h differing costs, resins have the most variable impact on raw mate rials cost. The resin portion of a coating typically represents about 20% to 50% or more of the total raw materials cost of a gallon of coati ng. With current ingredient prices as the baseline scenario, we conducted complete cost-effectiveness calculations at 10%, 20%, and 50% assumed increases in compli ant resin costs. The 10% and 20%2007 ARB SCM for Architectural Coatings

California Air Resources Board G-7 Sept - 07 

### assumed resin price increases are cons istent with the socioeconomic impacts analysis conducted by the SCAQMD and confidential comments provided by
some manufacturers. To be conservative , we use the 20% resin price increase assumption wherever we re fer to the “average” cost-e ffectiveness of each limit
and the overall cost-effectiveness. The 50% assumed resin price increase is intended as an extreme upper boundary for pur poses of the sensitivity analysis and is not suggested by any information av ailable to staff as reflective of projected actual resin prices when the proposed limits become effective.

Table G-6 Cost-Effectiveness of Proposed Limits Under Sensitivity Analysis

Baseline 10% Increase 20% Increase 50%
Increase
Coating Category RCM = 1.0 RCM = 1.1 RCM = 1.2 RCM = 1.5

Aluminum Roof $0.41 $0.41 $0.41 $0.41



### Bituminous Roof $1.02 $1.02 $1.02 $1.02 

### Concrete Masonry Sealer -$0.60 -$0.48 -$0.36 -$0.01 

### Dry Fog -$0.86 -$0.69 -$0.52 -$0.01



### Flat -$1.76 -$1.23 -$0.69 $0.92



### Floor $13.06 $13.50 $13.94 $15.26



### Mastic Texture $1.80 $2.09 $2.37 $3.24



### Non Flat $4.65 $5.84 $7.03 $10.61 

### Non Flat High Gloss -$1.92 -$1.65 -$1.37 -$0.55



### PSU $1.40 $2.06 $2.73 $4.71



### Roof $0.12 $0.75 $1.38 $3.26



### Rust Preventative -$0.80 -$0.63 -$0.46 $0.06 

### Specialty PSU -$0.83 -$0.77 -$0.71 -$0.53 

### Traffic Marking $3.47 $4.11 $4.76 $6.70 

### Waterproofing Membrane $4.70 $5.63 $6.56 $9.34 

### Wood Coatings -$1.48 -$1.31 -$1.13 -$0.62


### Overall CostEffectiveness $0.20 $0.65 $1.11 $2.49



### On the following pages, we present ty pical formulations for complying and non-complying products. As noted earlier, these formulations were developed based on survey data, product datasheets, and input from manufacturers. In cases where an ingredient comprised le ss than 5% of the total weight of a formulation, the ingredient was changed to “A ll Other VOCs” or “All Other Solids.” The formulations shown have an assumed 20% increase in resin prices for the future complying product.2007 ARB SCM for Architectural Coatings

California Air Resources Board G-8 Sept - 07 

### References

Air Resources Board. Technical Suppor t Document. “Proposed Regulation to Reduce Volatile Organic Compound Emissions from Consumer Products.” (a.k.a. “Phase I Consumer Products Regul ation). August 1990. (ARB, 1990)

Air Resources Board. Technical S upport Document. “Proposed Amendments to the Statewide Regulation to Reduce Vo latile Organic Compound Emissions from Consumer Products – Phase II.” (a.k.a. “Phase II Consumer Products Regulation). October 1991. (ARB, 1991)

Air Resources Board. Executive Summa ry and Technical Support Document.
“Initial Statement of Reasons for Proposed Amendments to the California Consumer Products Regulation.” (a.k.a. “Mid-Term Measures I”). June 6, 1997. (ARB, 1997)

Air Resources Board. Introduction and Executive Summary and Technical Support Document. “Initial Statement of Reasons for Proposed Amendments to the California Consumer Products Regulatio n.” (a.k.a. “Mid-Term Measures II”). September 10, 1999. (ARB, 1999)

Air Resources Board. Staff Report for the 2000 Suggested Control Measure for Architectural Coatings. June, 2000. (ARB, 2000)

Air Resources Board. “Initial St atement of Reasons for the Proposed
Amendments to the California Aerosol C oatings Products, Antiperspirants and Deodorants, and Consumer Products Regulations, Test Method 310, and
Airborne Toxic Control Measure for Pa ra-Dichlorobenzene Solid Air Fresheners
and Toilet/Urinal Care Products.” May 7, 2004. (ARB, 2004)

Air Resources Board. Staff Report for the Suggested Control Measure for Automotive Coatings. Oc tober, 2005. (ARB, 2005)

Air Resources Board. 2005 Architectural Coatings Survey, Draft Report. September, 2006. (ARB, 2006)

U. S. Department of Labor, Bureau of Labor Statistics. Pr oducer Price Index Industry Data – Plastics Material and Re sin Manufacturing. July 11, 2007. (BLS, 2007)

California Environmental Protection Ag ency. Memorandum from Peter M. Rooney, Undersecretary, to Cal/EPA Ex ecutive Officers and Directors. Economic Analysis Requirements for the A doption of Administrative Regulations. Appendix C (Cal/EPA Guidelin es for Evaluation Alternatives to Proposed Major Regulations). December 6, 1996. (Cal/EPA, 1996)Category Aluminum Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 43% 30% VOC Limit (g/l): 500 400 VOC Reg. for Sample Formulation (g/l): 433 302

Density (lbs/gallon): 8.4 8.4

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E) Asphalt $0.17 32% $0.05 30% $0.05

Calcium Carbonate $0.17 7% $0.01 25% $0.04

Aluminum $0.90 17% $0.15 15% $0.14

All Other Solids $0.65 3% $0.02 Mineral Spirits $0.50 22% $0.11 30% $0.15

Aromatic 100 $0.50 13% $0.06 Medium Aliphatic Solvent Naphtha $0.42 9% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.44 $0.38

% Cost Differential Relative to Current Product -13.4%

Total Cost, $/Gallon $3.66 $3.17

Total Cost Differential per Gallon Relative to Current Product -$0.49

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Bituminous Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Weight % VOC: 28% 0% VOC Limit (g/l): 300 50 VOC Reg. for Sample Formulation (g/l): 292 0

Density (lbs/gallon): 8.7 8.7

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E) Asphalt $0.17 65% $0.11 40% $0.07

Cellulose Fiber $1.50 5% $0.08 Clay Bentonite $2.00 11% $0.22

All Other Solids $0.90 2% $0.02 1% $0.01

Water $0.00 48% $0.00

Stoddard Solvent $0.50 28% $0.14

Sum 100% 100%

Total Cost, $/Pound $0.34 $0.30

% Cost Differential Relative to Current Product -13.0%

Total Cost, $/Gallon $2.96 $2.57

Total Cost Differential per Gallon Relative to Current Product -$0.39

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Compliant Typical Non-CompliantCategory Concrete Masonry Sealer Assumed Resin Cost Multiplier (RCM) 1.2

(Water Repellent/Weather Resistance) Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 25% 3% VOC Limit (g/l): 400 100 VOC Reg. for Sample Formulation (g/l): 389 84

Density (lbs/gallon): 13.0 11.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 5% $0.06 5% $0.06

Cement $0.06 25% $0.02

Silica $0.65 20% $0.13

Calcium Carbonate $0.17 20% $0.03 27% $0.05 Acrylic Resin $0.85 1.2 5% $0.04 25% $0.25

Water $0.00 40% $0.00 Hydrocarbon Solvent (Naphtha) $0.46 18% $0.08

Aromatic Solvent $0.50 7% $0.04

All Other VOCs $0.60 2% $0.01 Additives (VOC) $1.50 1% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.40 $0.39

% Cost Differential Relative to Current Product -2.6%

Total Cost, $/Gallon $5.16 $4.26

Total Cost Differential per Gallon Relative to Current Product -$0.91

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Concrete Masonry Sealer Assumed Resin Cost Multiplier (RCM) 1.2

(Decorative/Stain Resistance) Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 7% 0% VOC Limit (g/l): 400 100 VOC Reg. for Sample Formulation (g/l): 372 0

Density (lbs/gallon): 8.6 8.4

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E) Acrylic Resin $0.85 15% $0.13

Siloxane Resin $1.50 1.2 3% $0.05

Water $0.00 78% $0.00 97% $0.00 Diethylene Glycol Monomethyl

Ether $1.28 5% $0.06

All Other VOCs $1.35 1% $0.01 Additives (VOC) $1.50 1% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.22 $0.06

% Cost Differential Relative to Current Product -74.7%

Total Cost, $/Gallon $1.90 $0.47

Total Cost Differential per Gallon Relative to Current Product -$1.43

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Dry Fog Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Weight % VOC: 29% 3% VOC Limit (g/l): 400 150 VOC Reg. for Sample Formulation (g/l): 400 85

Density (lbs/gallon): 11.5 11.5

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 26% $0.31 20% $0.24 Alkyd Resin $0.71 45% $0.32

Vinyl Acrylic Copolymer Resin $0.71 1.2 $0.00 40% $0.34

Water $0.00 $0.00 37% $0.00 VM&P Naptha $0.46 28% $0.13

All Other VOCs 1% $0.01 3% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.76 $0.60

% Cost Differential Relative to Current Product -21.2%

Total Cost, $/Gallon $8.71 $6.87

Total Cost Differential per Gallon Relative to Current Product -$1.85

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Flat Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Weight % VOC: 4% 2% VOC Limit (g/l): 100 50 VOC Reg. for Sample Formulation (g/l): 90 47

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 19% $0.22 17% $0.20

Calcium Carbonate $0.17 16% $0.03 $0.00

Silicates $0.65 9% $0.06 15% $0.10

Talc $0.15 16% $0.02 Vinyl Acrylic Resin $0.71 1.2 13% $0.09 9% $0.08

Water $0.00 39% $0.00 41% $0.00

All Other VOCs 4% $0.05 2% $0.02

Sum 100% 100%

Total Cost, $/Pound $0.45 $0.41

% Cost Differential Relative to Current Product -7.2%

Total Cost, $/Gallon $4.45 $4.13

Total Cost Differential per Gallon Relative to Current Product -$0.32

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Floor Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 6% 3% VOC Limit (g/l): 250 100 VOC Reg. for Sample Formulation (g/l): 180 95

Density (lbs/gallon): 10.0 11.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 14% $0.17 16% $0.19

Calcium Carbonate $0.17 10% $0.02 14% $0.02 Acrylic Resin $0.85 1.2 20% $0.17 23% $0.23

Water $0.00 50% $0.00 44% $0.00

All Other VOCs 6% $0.07 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.42 $0.48

% Cost Differential Relative to Current Product 12.2%

Total Cost, $/Gallon $4.24 $5.24

Total Cost Differential per Gallon Relative to Current Product $1.00

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Mastic Texture Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 15% 3% VOC Limit (g/l): 300 100 VOC Reg. for Sample Formulation (g/l): 239 74

Density (lbs/gallon): 9.5 11.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 8% $0.09 8% $0.09

Mica $0.45 20% $0.09 26% $0.12

Perlite $0.45 5% $0.02 Acrylic Resin $0.85 1.2 28% $0.28 Alkyd Resin $0.71 1.2 27% $0.19

Water $0.00 25% $0.00 35% $0.00 Hydrocarbon Solvent (Naphtha) $0.46 15% $0.07

All Other VOCs 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.47 $0.53

% Cost Differential Relative to Current Product 14.0%

Total Cost, $/Gallon $4.43 $5.85

Total Cost Differential per Gallon Relative to Current Product $1.42

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Non Flat Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Weight % VOC: 6% 4% VOC Limit (g/l): 150 100 VOC Reg. for Sample Formulation (g/l): 153 104

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 17% $0.20 21% $0.25

Silicates $0.65 8% $0.05

All Other Solids 3% $0.02

Calcium Carbonate $0.17 7% $0.01 Acrylic Resin $0.85 1.2 23% $0.19 22% $0.22

Water $0.00 44% $0.00 45% $0.00

All Other VOCs 6% $0.05 4% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.48 $0.56

% Cost Differential Relative to Current Product 15.6%

Total Cost, $/Gallon $4.83 $5.58

Total Cost Differential per Gallon Relative to Current Product $0.75

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified.

Typical Non-Compliant Typical Compliant

Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Non Flat High Gloss Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 6% 3% VOC Limit (g/l): 250 150 VOC Reg. for Sample Formulation (g/l): 154 106

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 18% $0.21 11% $0.13 Acrylic Resin $0.85 1.2 27% $0.23 20% $0.20

Silica $0.65 5% $0.03 11% $0.07

Water $0.00 44% $0.00 55% $0.00

All Other VOCs 6% $0.12 3% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.60 $0.44

% Cost Differential Relative to Current Product -27.3%

Total Cost, $/Gallon $5.99 $4.35

Total Cost Differential per Gallon Relative to Current Product -$1.64

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory PSU Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 4% 2% VOC Limit (g/l): 200 100 VOC Reg. for Sample Formulation (g/l): 120 60

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 13% $0.15 15% $0.18

All Other Solids 6% $0.07 5% $0.06 Acrylic Resin $0.85 1.2 15% $0.13 18% $0.18

Talc $0.15 12% $0.02 10% $0.02

Water $0.00 50% $0.00 50% $0.00

All Other VOCs 4% $0.05 2% $0.03

Sum 100% 100%

Total Cost, $/Pound $0.42 $0.46

% Cost Differential Relative to Current Product 10.6%

Total Cost, $/Gallon $4.20 $4.64

Total Cost Differential per Gallon Relative to Current Product $0.44

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Roof Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 20% 2% VOC Limit (g/l): 250 50 VOC Reg. for Sample Formulation (g/l): 252 51

Density (lbs/gallon): 10.5 10.5

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 10% $0.12 10% $0.12

Zinc Oxide $2.20 5% $0.11 5% $0.11 Acrylic Resin $0.85 1.2 30% $0.25 25% $0.25

Calcium Carbonate $0.17 35% $0.06 18% $0.03

Water $0.00 40% $0.00

All Other VOCs 2% $0.03 2% $0.02 Aliphatic Hydrocarbons $0.50 12% $0.06 Propylene Glycol $1.35 6% $0.08

Sum 100% 100%

Total Cost, $/Pound $0.71 $0.53

% Cost Differential Relative to Current Product -26.0%

Total Cost, $/Gallon $7.48 $5.54

Total Cost Differential per Gallon Relative to Current Product -$1.94

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Rust Preventative Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 33% 5% VOC Limit (g/l): 400 250 VOC Reg. for Sample Formulation (g/l): 391 127

Density (lbs/gallon): 9.9 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 25% $0.30 23% $0.27

All Other Solids $0.65 4% $0.03 Alkyd Resin $0.71 38% $0.27 Acrylic resin $0.85 1.2 28% $0.28

Water $0.00 44% $0.00

Stoddard Solvent $0.50 31% $0.16

All Other VOCs 2% $0.02 5% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.77 $0.60

% Cost Differential Relative to Current Product -21.8%

Total Cost, $/Gallon $7.57 $5.98

Total Cost Differential per Gallon Relative to Current Product -$1.59

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Specialty PSU Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 26% 2% VOC Limit (g/l): 350 100 VOC Reg. for Sample Formulation (g/l): 312 61

Density (lbs/gallon): 10.0 11.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 8% $0.09 15% $0.18

Talc $0.15 37% $0.06 23% $0.03

All Other Solids 4% $0.06 3% $0.05 Acrylic Resin $0.85 1.2 14% $0.14 Alkyd Resin $0.71 25% $0.18

Water $0.00 43% $0.00

All Other VOCs 1% $0.01 2% $0.01 Mineral Spirits $0.95 25% $0.24

Sum 100% 100%

Total Cost, $/Pound $0.63 $0.41

% Cost Differential Relative to Current Product -34.6%

Total Cost, $/Gallon $6.30 $4.53

Total Cost Differential per Gallon Relative to Current Product -$1.77

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Traffic Marking Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 7% 5% VOC Limit (g/l): 150 100 VOC Reg. for Sample Formulation (g/l): 110 78

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Titanium Dioxide $1.18 7% $0.08 7% $0.08

Calcium Carbonate $0.17 52% $0.09 53% $0.09 Acrylic Resin $0.85 1.2 14% $0.12 16% $0.16

Water $0.00 20% $0.00 19% $0.00

All Other VOCs 7% $0.06 5% $0.04

Sum 100% 100%

Total Cost, $/Pound $0.35 $0.38

% Cost Differential Relative to Current Product 6.9%

Total Cost, $/Gallon $3.55 $3.79

Total Cost Differential per Gallon Relative to Current Product $0.24

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Waterproofing Membrane Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 32% 20% VOC Limit (g/l): 400 250 VOC Reg. for Sample Formulation (g/l): 383 240

Density (lbs/gallon): 10.0 10.0

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E) Butyl Benzyl Phthalate $1.50 10% $0.15 Asphalt $0.17 10% $0.02

Carbon Black $2.29 10% $0.23

Calcium Carbonate $0.17 18% $0.03 20% $0.03 Polyurethane Resin $1.50 1.2 40% $0.60 40% $0.72

Water $0.00 Hydrocarbon Solvent (Naphtha) $0.46 28% $0.13 20% $0.09

All Other VOCs $1.50 4% $0.06

Sum 100% 100%

Total Cost, $/Pound $0.83 $1.22

% Cost Differential Relative to Current Product 46.7%

Total Cost, $/Gallon $8.35 $12.24

Total Cost Differential per Gallon Relative to Current Product $3.90

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Lacquer Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 33% 10% VOC Limit (g/l): 550 275 VOC Reg. for Sample Formulation (g/l): 545 265

Density (lbs/gallon): 8.3 8.7

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Nitrocellulose $1.50 20% $0.30 Acrylic Resins $0.85 1.2 20% $0.20 Polyurethane Resins $1.50 1.2 8% $0.14

Additives $1.50 5% $0.08 4% $0.06

Water $0.00 $0.00 58% $0.00

Acetone $0.70 42% $0.29 Methyl-n-Amyl Ketone $1.50 10% $0.15 Butyl Acetate $1.50 10% $0.15 $0.00

All Other VOCs 13% $0.05 10% $0.13

Sum 100% 100%

Total Cost, $/Pound $1.11 $0.54

% Cost Differential Relative to Current Product -51.4%

Total Cost, $/Gallon $9.36 $4.71

Total Cost Differential per Gallon Relative to Current Product -$4.65

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Varnish Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 36% 10% VOC Limit (g/l): 350 275 VOC Reg. for Sample Formulation (g/l): 349 271

Density (lbs/gallon): 8.1 8.6

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E) Polyurethane Resins $1.50 1.2 56% $0.82 24% $0.42

Additives $1.50 8% $0.12 6% $0.09

Water $0.00 $0.00 60% $0.00 Distillate (Petroleum), Hydrotreated Light $0.95 14% $0.13

Stoddard Solvent $1.50 10% $0.15 Medium Aliphatic Solvent Naphtha $0.42 10% $0.04

All Other VOCs 2% $0.02 10% $0.15

Sum 100% 100%

Total Cost, $/Pound $1.28 $0.66

% Cost Differential Relative to Current Product -48.8%

Total Cost, $/Gallon $10.39 $5.65

Total Cost Differential per Gallon Relative to Current Product -$4.74

Assumptions: (1) Cost of "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-CompliantCategory Opaque Lacquer Assumed Resin Cost Multiplier (RCM) 1.2

Physical Properties Typical Non-Compliant Typical Compliant Weight % VOC: 19% 6% VOC Limit (g/l): 550 275 VOC Reg. for Sample Formulation (g/l): 438 107

Density (lbs/gallon): 8.5 8.5

Formulation and Cost Comparison

W t% (D) Cost

(B) X (D) W t%

(E) Cost (B) X (C) X (E)

Nitrocellulose $1.50 24% $0.36

Titanium Dioxide $1.18 10% $0.12 10% $0.12

Additives $1.50 2% $0.03 3% $0.05

Silicates $0.65 6% $0.04 6% $0.04 Acrylic Resin $0.85 1.2 26% $0.26

Calcium Carbonate $0.17 6% $0.01 7% $0.01

Water $0.00 42% $0.00

Acetone $0.70 16% $0.11

All Other VOCs 12% $0.12 6% $0.08 Isobutyl Isobutyrate $1.50 5% $0.08 Butyl Acetate 1- $1.50 8% $0.12 Isobutyl Acetate $1.50 6% $0.09 VM&P Naphtha $0.46 5% $0.02

Sum 100% 100%

Total Cost, $/Pound $1.10 $0.56

% Cost Differential Relative to Current Product -49.4%

Total Cost, $/Gallon $9.33 $4.72

Total Cost Differential per Gallon Relative to Current Product -$4.61

Assumptions: (1) Cost of "All Others" or "Additives" remains at $1.50 per pound (2) Average unit size = 1 gallons (3) RCM: Assumed Compliant Resin Cost Multiplier. RCM = 1.0 unless otherwise specified. Typical Compliant Component (A) Unit Cost

($/lb) (B) RCM

(C) Typical Non-Compliant