# Final Environmental Impact Report

FOR THE PROPOSED AMENDMENTS TO RULE 67.0 (ARCHITECTURAL COATINGS)
OF THE RULES AND REGULATIONS OF
SAN DIEGO COUNTY AIR POLLUTION
CONTROL DISTRICT

LOG NO. 01-00-001;
SCH # 2001061037

December 12, 2001

### FINAL

ENVIRONMENTAL IMPACT REPORT

FOR THE PROPOSED AMENDMENTS TO

RULE 67.0 OF THE RULES AND REGULATIONS

OF THE SAN DIEGO COUNTY

AIR POLLUTION CONTROL DISTRICT

LOG NO. 01-00-001

SCH NO. 2001061037

December 12, 2001

APCD Staff Contact:

Mr. Robert Reider, Supervising Air Resources Specia list San Diego County Air Pollution Control District

9150 Chesapeake Drive San Diego, CA 92123-1096 (858) 650-4670Table of Contents

i 

### Table of Contents

SUMMARY ............................................

................................................... ........ S-1

Project Synopsis...................................

................................................... ....... S-1

Project Description ................................ .............................................. S-1

Project Objectives................................. ............................................... S-1

Project Location and Setting....................... ........................................ S-1

Summary of Significant Environmental Effects and Mi tigation Measures that Reduce the Significant Effects ................ .................................... S-2

Project Alternatives ...............................

................................................... ...... S-2

“No Project” Alternative ........................... ........................................... S-3

“Extended Compliance Deadlines” Alternative........ ......................... S-3

“Further Reduction of VOC Content Limits” Alternati ve.................. S-3

Areas of Controversy ...............................

................................................... ... S-4

Issues to be Resolved by the Decision-Making Body .. ............................... S-4

CHAPTER 1.0 - PROJECT DESCRIPTION AND ENVIRONMENTAL
SETTING............................................

................................................... ..1-1

1.1 - Project Description and Location

................................................... ........1-1

1.2 - Project Objectives

................................................... ................................1-2

1.3 - Intended Uses of the EIR

................................................... ......................1-2

1.3.1 - Matrix of Project Approvals/Permits ........ ................................1-3

1.4 - Environmental Setting

................................................... ..........................1-3

1.4.1 - Consistency of Project with Applicable Regi onal and General

Plans ..............................................

................................................... .....1-5Table of Contents

ii CHAPTER 2.0 - SIGNIFICANT ENVIRONMENTAL EFFECTS .... ....................2-1

CHAPTER 3.0 - CUMULATIVE IMPACTS................... .....................................3-1

CHAPTER 4.0 - PROJECT ALTERNATIVES ................. ..................................4-1

4.1 - Rationale for Alternative Selection

................................................... .....4-1

4.1.1 - Performance-Based Standards................ .................................4-2

4.1.2 - Seasonal Regulation........................ ..........................................4-2

4.1.3 - Regional Regulation ........................ ..........................................4-2

4.1.4 - Exceedance Fees ............................ ...........................................4-3

4.1.5 - Tonnage Exemption.......................... .........................................4-3

4.1.6 - Low Vapor Pressure (Low Volatility) Exempti on.....................4-3

4.1.7 - Reactivity- Based VOC Limits............... ....................................4-4

4.2 - Analysis of the “No Project” Alternative ...............................................4-4

4.2.1 - Alternative Description and Setting ........ .................................4-4

4.2.2 - Comparison of the Effects of the “No Projec t” Alternative to the Proposed Project ................ ....................................4-4

4.2.3 - Staff’s Rationale for Rejection of the “No Project”
Alternative........................................

................................................... ...4-5

4.3 - Analysis of the “Extended Compliance Deadline s” Alternative ..........4-5

4.3.1 - Alternative Description and Setting ........ .................................4-5

4.3.2 - Comparison of the Effects of the “Extended Compliance Deadlines” Alternative to the Proposed P roject ...........4-5

4.3.3 - Staff’s Rationale for Rejection of the “Ext ended Compliance Deadlines” Alternative.................. ...................................4-7Table of Contents

iii 4.4 - Analysis of the “Further Reduction of VOC Con tent Limits”

Alternative

................................................... .................................... 4.4 - -7

4.4.1 - Alternative Description and Setting ........ .................................4-7

4.4.2 - Comparison of the Effects of the “Further R eduction of VOC Content Limits” Alternative to the Proposed Project ...........4-7

4.4.3 - Staff’s Rationale for Rejection of the “Fur ther
Reduction of VOC Content Limits” Alternative ....... ...........................4-9

CHAPTER 5.0 - LONG-TERM ENVIRONMENTAL EFFECTS ...... ...................5-1

5.1 - Growth Inducing Impacts

................................................... .....................5-1

5.2 - Significant Irreversible Environmental Change s Resultant from Project Implementation

................................................... .......................5-1

CHAPTER 6.0 - ENVIRONMENTAL EFFECTS FOUND NOT TO BE
SIGNIFICANT ........................................ .................................................6- 1

6.1 - Effects found not to be Significant as Part o f the EIR Process ...........6-1

6.1.1 - Air Quality................................

................................................... 6-1

6.1.2 - Water Resources............................ ..........................................6-10

6.1.3 - Public Services ............................ ............................................6-14

6.1.4 - Transportation/Circulation ................. .....................................6-16

6.1.5 - Solid and Hazardous Waste .................. ..................................6-18

6.1.6 - Hazardous Substances....................... .....................................6-19

6.2 - Effects found not to be Significant During In itial Study .....................6-21Table of Contents

iv CHAPTER 7.0 - LIST OF REFERENCES ................... ......................................7-1

CHAPTER 8.0 - LIST OF EIR PREPARERS AND PERSONS AND
ORGANIZATIONS CONTACTED............................ ...............................8-1

CHAPTER 9.0 - LIST OF MITIGATION MEASURES AND ENVIR ONMENTAL
DESIGN CONSIDERATIONS.............................. ...................................9-1



### List of Figures

Figure 1-1: Project Location Map...................

................................................... ...........1-7



### List of Tables

Table 1-1: Matrix of Project Approvals/Permits .....

................................................... ...1-3



### Appendices

Appendix A: Proposed Amendments to Rule 67.0 Appendix B: Notice of Preparation Appendix C: Initial Study

Under Separate Cover - Comments and ResponsesSummary

S-1 

### Summary

Project Synopsis

Project Description

The San Diego County Air Pollution Control District (APCD) proposes to adopt amendments to Rule 67.0, Architectural Coatings, as part of its Rules and Regulations. The Rule 67.0 amendments incorporate content limits for volatile organic compounds (VOC) and other requirements contained in the Sugge sted Control Measure (SCM) for Architectural Coatings, approved by the California Air Resources Board (ARB) on June 22, 2000. The SCM sets allowable VOC content limit s and other requirements that are feasible (based on existing and currently developin g coating technologies) and that will achieve significant reductions in VOC emissions fro m architectural coatings.

Prior to approving the SCM, ARB prepared and certif ied a Programmatic Environmental Impact Report (PEIR). San Diego County APCD staff has reviewed and considered ARB’s PEIR, including the technical analyses, comme nts, and responses to comments, and concur with the methodologies and determination s made therein. Accordingly, this analysis incorporates the ARB PEIR by reference. R elevant sections of the ARB PEIR are summarized as appropriate throughout this EIR. 1

Project Objectives

The purpose of the project is to reduce VOC emissio ns by incorporating lower VOC limits and other requirements for architectural coa tings without significantly diminishing usability of the coatings in question. The emissio n reductions are necessary for San Diego County to continue progress toward attaining the state ambient air quality standard for ozone, as required by the state Clean Air Act. The estimated total countywide reduction in VOC emissions from these proposed revi sions to Rule 67.0 is approximately 1.5 tons per day.

Project Location and Setting

The project applies within the jurisdiction of the San Diego County APCD, which covers the entire area within the incorporated and the uni ncorporated portions of San Diego County, the southwestern-most county in the State o f California. San Diego County encompasses approximately 4,260 square miles and is bounded on the north by Orange and Riverside Counties, on the east by Imperial Cou nty, on the west by the Pacific Ocean, and on the south by the State of Baja Califo rnia Norte, Mexico.

The political boundaries of the County of San Diego also form the extents of the San Diego Air Basin. The climate of the San Diego Air Basin, as with all of Southern California, is largely dominated by the strength an d position of the semi-permanent highpressure system over the Pacific Ocean (known as th e Pacific High). The favorable

1 The ARB PEIR, and all its supporting documents, ar e available at the APCD offices at 9150 Chesapeake Drive, San Diego, CA. In addition, these documents are available on the internet at www.arb.ca.gov/coatings/arch/CEQA/FEIR.htm.Summary

S-2 climate of San Diego also works to create air pollu tion problems. Sinking, or subsiding air from the Pacific High creates a temperature inv ersion (known as a subsidence inversion), which acts as a lid to vertical dispers ion of pollutants. Weak summertime pressure gradients further limit horizontal dispers ion of pollutants in the mixed layer below the subsidence inversion. Poorly dispersed a nthropogenic emissions, including emissions of VOC, combine with strong sunshine lead to photochemical reactions that creates ozone in this surface layer.

National and state air quality standards are set fo r criteria pollutants, which are widespread common pollutants known to be harmful to human health and welfare. Standards are set to protect the elderly, very youn g, and chronically sensitive portions of our population. Areas not meeting a particular sta ndard are referred to as a nonattainment area for the pollutant. Of the six air pollutants regulated by the U.S. Environmental Protection Agency (EPA), and eight re gulated by ARB, only ozone (smog) and inhalable particulate matter (PM 10 ) occur in concentrations sufficient to

violate either federal or state standards in San Di ego County.

San Diego County has experienced substantial improv ement in ambient ozone levels over the past several years. The number of days above t he federal one-hour ozone standard has decreased from 39 days in 1990 to none in 2000. Similarly, the number of days above the more stringent state standard has decreas ed from 139 days in 1990 to 24 days

in 2000.

Summary of Significant Environmental Effects and Mi tigation Measures that Reduce the Significant Effects

San Diego County APCD staff has reviewed and consid ered the PEIR prepared by ARB, including the technical analyses, and concurs with the methodologies and determinations made therein. Further, APCD staff has considered t he technical analyses referred to in the ARB PEIR (and adopted by reference herein) for applicability to the conditions that exist in San Diego County, and has determined that the implementation of the proposed rule changes to APCD Rule 67.0 would not have a pot entially significant adverse effect on any resource area. A discussion and analysis fo r each of the resource area impacts identified in the Initial Study/Environmental Analy sis as requiring further analysis, but determined during the EIR process to be less than s ignificant, is discussed in Section 6.1

of this document.

Project Alternatives

The ARB Final PEIR examined a total of 11 alternati ves. Seven of these alternatives

were determined to be infeasible. APCD staff has r eviewed these seven alternatives and

the reasons for their dismissal as feasible alterna tives, and agrees with the determination. The remaining four alternatives were determined to be feasible by both the ARB and APCD staff. The fourth alternative analyzed in the PEIR (Product Line Averaging) was included in the SCM approved by ARB and is also inc luded in the proposed Rule 67.0 amendments analyzed in this EIR. The three remaini ng feasible alternatives discussed inSummary

S-3 the ARB Final PEIR were also considered feasible fo r the project area, and are discussed briefly in Section 4.2, Section 4.3, and Section 4. 4 below. They are as follows:

“No Project” Alternative

The “No Project” alternative assumes that the propo sed revisions to Rule 67.0 would not be implemented, and that the VOC limits in the curr ent Rule 67.0 will remain in effect. As a result, approximately 1.5 tons per day of VOC emission reductions from architectural coatings would not be achieved throug hout the project area. This scenario would potentially jeopardize the ability of the reg ion to expeditiously attain and maintain the state ozone standard. However, implementation of the “No Project” Alternative impacts to other resource areas would remain at exi sting levels. Staff rejects the “No Project” alternative (Alternative A) since it would not achieve the long-term air quality benefits (e.g., VOC reductions) of the proposed rev isions to Rule 67.0, which are needed by the APCD to achieve the mandated state and feder al ozone standards.

“Extended Compliance Deadlines” Alternative

This alternative would extend all of the effective dates for the VOC content limits to January 1, 2004. The VOC content limits for affect ed coatings would be identical to those in the current version of the proposed revisi ons to Rule 67.0. APCD staff does not support this alternative since the VOC limits in th e proposed rule are feasible by January 1, 2003 (January 1, 2004 for Industrial Mai ntenance Coatings), and that it is not necessary to allow additional time to comply. Both the federal and California Clean Air Acts mandate that air quality standards be attained as expeditiously as practicable, and the region’s air quality problems required that any delay in achieving emission reductions must be technically or economically justified. Bas ed on all the information received by APCD staff to date, such a delay is not warranted.

“Further Reduction of VOC Content Limits” Alternati ve

This alternative would further reduce the VOC conte nt limits for affected coatings categories (adoption of the “final” limits as descr ibed in Table 1 of Appendix C of the Notice Of Preparation/Initial Study for the ARB PEI R; see Appendix B of the ARB Final PEIR). The other proposed changes in the current p roposed version of Rule 67.0 would be maintained. Alternative C, “Further Reduction o f VOC Content Limits” Alternative, is not recommended by APCD staff because it would r equire the APCD focus limited staff resources on the technical, environmental, an d economic issues associated with adoption of interim limits. Based on the informati on and analyses in this EIR and the ARB Final PEIR, APCD staff has concluded that the p roposed revisions to Rule 67.0 are necessary and the best alternative for the APCD to achieve the further VOC reductions

needed to attain the state and federal ozone standa rd. Moreover, if the APCD does not adopt the proposed revisions to Rule 67.0, the APCD will have to find other emission sources from which to obtain the necessary VOC emis sion reductions.Summary

S-4 Areas of Controversy

The adoption and implementation of the proposed rul e amendments is expected to produce substantial, long-term, VOC emission reduct ions, without resulting in any significant, adverse environmental impacts. As req uired by §15123 of the State CEQA Guidelines, areas of controversy must be identified . Some companies in the architectural coatings industry have claimed that there will be a number of adverse impacts to resource areas from the implementation of this rule amendmen t. These assertions by architectural coating manufacturers include the following claims:

• By lowering the VOC content of coatings, there will be an increase in VOC emissions for a variety of reasons including, but n ot limited to, increased coating thickness, more thinning, more topcoats, more touch -ups, more priming, more frequent re-coating, more substitution with higher VOC coatings, and greater reactivity;

• The new formulations will result in more coating us e, resulting in an overall increase in VOC emissions for a specific area cover ed or over time;

• More reactive solvents will be used in compliant fo rmulation than those used in existing coatings, thus contributing to increased o zone formation;

• The proposed rule could result in public hazards an d environmental impacts due to potential additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Further, the reformulation of coatings to utilize acetone co uld result in hazardous impacts due to its flammability;

• Increased water demand from the manufacturing and u se of compliant waterborne coatings, the use of exempt solvents (solvent s not considered to be VOC, such as acetone and Oxsol 100) and water quality im pacts from future compliant water-borne coatings associated with manufacturing and cleanup practices could involve environmental impacts.

• The proposed rule could result in Transportation/Ci rculation impacts due to potential additional vehicle trips caused by the di sposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities.

Extensive technical analyses were conducted by ARB as part of its Final PEIR. APCD

staff has reviewed and considered ARB's technical a nalyses and concurs with the

conclusions and recommendations in the ARB PEIR. A complete discussion of these

issues can be found in Section 6.1 of this EIR.

Issues to be Resolved by the Decision-Making Body

Issues to be resolved by the decision-maker include the choice among alternatives and whether or how to mitigate any significant environm ental effects (State CEQA Guidelines, §15123(b)(3)). No significant and miti gated, or significant unmitigatedSummary

S-5 impacts have been identified from either the propos ed project, or any of the three identified, feasible alternatives. However, APCD s taff has reviewed the alternatives and believes that the proposed project is the environme ntally superior alternative and the only alternative which adequately meets the project goal s in a timely manner as required pursuant to the California Health and Safety Code.Project Description & Environmental Setting

1-1 CHAPTER 1.0 - PROJECT DESCRIPTION AND ENVIRONMENTAL SETTING

1.1 - Project Description and Location

The San Diego County Air Pollution Control District (APCD) proposes to adopt amendments to Rule 67.0, Architectural Coatings (at tached as Appendix A). Amended Rule 67.0 would apply to any person who supplies, s ells, offers for sale, or manufactures an architectural coating for use, as well as any pe rson who applies or solicits the application of any architectural coating within the jurisdiction of the San Diego County APCD. The jurisdiction of the APCD covers all of t he incorporated and the unincorporated portions of San Diego County, the so uthwestern-most county in the State of California (Figure 1-1). San Diego County encom passes approximately 4,260 square miles and is bounded on the north by Orange and Riv erside Counties, on the east by Imperial County, on the west by the Pacific Ocean, and on the south by the State of Baja California Norte, Mexico.

Architectural coatings are defined as coatings appl ied to stationary structures and their accessories (usually for beautification and protect ion) and include such coatings as house paints, stains, varnishes, industrial maintenance c oatings, and traffic marking coatings. When applied, the solvents in the coatings evaporat e into the atmosphere, emitting volatile organic compounds (VOC), which contribute to the formation of ozone. San Diego County has been designated by ARB as a “Serio us” nonattainment area for the State ambient air quality standard for ozone.

The proposed Rule 67.0 amendments incorporate VOC l imits and other requirements contained in the Suggested Control Measure (SCM) fo r Architectural Coatings, approved by ARB on June 22, 2000. The SCM is largely consis tent with the U.S. EPA’s National Volatile Organic Compound Emission Standards for Ar chitectural Coatings. The SCM sets allowable VOC content limits and other require ments that are feasible (based on existing and currently developing coating technolog ies) and that will achieve significant

reductions in VOC emissions from architectural coat ings. Local implementation would reduce VOC emissions in San Diego County by an esti mated 1.5 tons per day.

Amended Rule 67.0 would continue to apply to any pe rson who supplies, sells, offers for sale, or manufactures an architectural coating for use within San Diego County, as well as any person who applies or solicits the application of any architectural coating within San Diego County. The proposed rule amendments will lo wer the VOC content limit for a number of architectural coating categories and incl ude additional coating categories with VOC limits consistent with the SCM. The proposed V OC limits for most categories would become effective on January 1, 2003 (January 1, 2004, for industrial maintenance coatings.)

The lowered VOC limits are consistent with the corr esponding limits in the SCM and pertain to clear wood coatings (lacquers and sandin g sealers); high temperature coatings; industrial maintenance coatings; magnesite cement c oatings; multi-color coatings; pre-Project Description & Environmental Setting

1-2 treatment wash primers; primers sealers and underco aters; quick dry enamels; quick-dry primers, sealers, and undercoaters; roof coatings; stains; swimming pool coatings; swimming pool repair and maintenance coatings; traf fic marking coatings (indicated as traffic paints in existing rule 67.0); waterproofin g sealers; and wood preservatives. Added coating categories include flat, nonflat-high gloss, antenna, antifouling, bituminous roof, bituminous roof primers, clear bru shing lacquer, faux finishing, fire resistive, floor, flow (electrical transformers), l owsolids, recycled, rust preventative, temperature-indicator safety coatings, and waterpro ofing concrete/masonry sealers.

Provisions for product-line averaging are included in the proposed rule amendments (consistent with the SCM), allowing manufacturers t o average designated coatings such

that their actual statewide cumulative emissions fr om the averaged coatings are less than or equal to the statewide cumulative emissions that would be allowed under individual limits over a compliance period not exceeding one y ear. The averaging provision will only be in effect from January 1, 2003, until Janua ry 1, 2005. VOC ceilings (maximum allowable VOC content limits) are applicable when a veraging. Ceiling limits would protect against regional differences that could res ult in high VOC products being sold in San Diego.

Proposed Rule 67.0 amendments do not include the SC M provision pertaining to petitioning the Air Pollution Control Officer to al low application of an industrial maintenance coating with a VOC content up to 340 gr ams per liter, since that provision only applies to the North Central Coast, San Franci sco Bay Area, and the North Coast Air

Basins.

1.2 - Project Objectives

The purpose of the project is to reduce VOC emissio ns by incorporating lower VOC limits and other requirements for architectural coa tings without significantly diminishing usability of the coatings in question. These emiss ion reductions are necessary for San Diego County to continue progress toward attaining the state ambient air quality standards for ozone, as required by the state Clean Air Act. The estimated total countywide reduction in VOC emissions from these pr oposed revisions to Rule 67.0 is approximately 1.5 tons per day.

1.3 - Intended Uses of the EIR

Pursuant to the requirements of the California Envi ronmental Quality Act (CEQA), an Environmental Impact Report (EIR) must identify the potentially environmental effects that may result from implementation of a proposed p roject. The EIR analysis must include direct and indirect significant effects of a project, as well as short and long-term impacts. The discussion of environmental impacts s hould include, but is not limited to, the resources involved; physical changes; alteratio ns of ecological systems; health and safety problems caused by physical changes; and oth er aspects of the resource base, including water, scenic quality, and public service s. If the lead agency identifies potentially significant adverse environmental impac ts, the EIR must discuss mitigationProject Description & Environmental Setting

1-3 measures that could either avoid or substantially r educe any adverse environmental impacts.

The degree of specificity required in a CEQA docume nt depends on the type of project being proposed. For example, the environmental doc ument for projects such as the adoption or amendment of a comprehensive zoning ord inance or a local general plan should focus on the secondary effects that can be e xpected to follow from the adoption or amendment. However, the analysis need not be as de tailed as the analysis of the specific construction projects that might follow. The CEQA and the State CEQA Guidelines establish the categories of environmental impacts t hat should generally be evaluated. The CEQA Guidelines include a checklist for use by publ ic agencies, which lists 16, specific environmental categories, which should be addressed when determining whether to prepare an EIR. This checklist is known as an Init ial Study/Environmental Analysis (IS/EA) and is intended to provide sufficient infor mation regarding the project to support the determination on the type of document required to satisfy CEQA, and, when necessary, provide guidance toward the scope of an EIR. The ARB prepared an initial study, based upon this checklist, prior to preparin g it’s Draft PEIR.

San Diego County APCD staff reviewed the ARB Initia l Study when it conducted its own IS/EA to determine the scope of this EIR. On June 11, 2001, the APCD issued a Notice of Preparation (NOP) to responsible and trustee age ncies, along with a brief summary of the potential environmental effects of the rule ado ption and a copy of the IS/EA. The NOP and associated documents are included as Append ix B of this document. Of the 16 potential environmental impact categories on the ch ecklist, APCD determined that an EIR should be prepared to address potential adverse effects on the following environmental categories: air quality, water, publi c services, transportation/circulation, solid waste/hazardous waste, hazards, irreversible environmental changes, potential growth inducing impacts, and consistency with other plans. This document analyzes the potential adverse environmental impacts associated with implementing the proposed Amendments to Rule 67.0 – Architectural Coatings.



### 1.3.1 - Project Approvals/Permits

Proposed amendments to Rule 67.0 need approval by t he San Diego County Air Pollution Control Board. The San Diego APCD implements Rule 67.0. However, Appendix A.2 of amended Rule 67.0 requires coating manufacturers to submit an averaging program to the Executive Officer of ARB for approval.

Table 1-1: Matrix of Project Approvals/Permits

Permit Type/Action Agency Rule Approval San Diego County APCD*

* CEQA Lead Agency

1.4 - Environmental Setting

The boundaries of the San Diego Air Basin are conti guous with the political boundaries of San Diego County. The County of San Diego encom passes approximately 4,260Project Description & Environmental Setting

1-4 square miles and is bounded on the north by Orange and Riverside Counties, on the east by Imperial County, on the west by the Pacific Ocea n, and on the south by the Mexican State of Baja California. The county is divided by the Laguna Mountain Range which runs approximately parallel to the coast about 45 m iles inland and separates the coastal area from the desert portion of the county. The La guna Mountains reach peaks of over 6,000 feet with Hot Springs Mountain peak rising to 6,533 feet, the highest point in the county. The coastal region is made up of coastal t erraces that rise from the ocean into wide mesas which then, moving farther east, transit ion into the Laguna Foothills. Farther east, the topography gradually rises to the rugged mountains. On the east side, the mountains drop off rapidly to the Anza-Borrego Dese rt, which is characterized by several broken mountain ranges with desert valleys in betwe en. To the north of the county are the Santa Ana Mountains which run along the coast o f Orange County, turning east to join with the Laguna Mountains near the San Diego-O range County border.

The climate of the San Diego Air Basin, as with all of Southern California, is largely dominated by the strength and position of the semi- permanent high-pressure system over the Pacific Ocean, known as the Pacific High. This high-pressure ridge over the West Coast often creates a pattern of late-night and ear ly-morning low clouds, hazy afternoon sunshine, daytime onshore breezes, and little tempe rature variation year-round. The climatic classification for San Diego is a Mediterr anean climate, with warm, dry summers and mild, wet winters. Average annual precipitatio n ranges from approximately 10

inches on the coast to over 30 inches in the mounta ins to the east (the desert regions of San Diego County generally receive between 4 and 6 inches per year).

The favorable climate of San Diego also works to cr eate air pollution problems. Sinking, or subsiding air from the Pacific High creates a te mperature inversion, known as a subsidence inversion, which acts as a lid to vertic al dispersion of pollutants. Weak summertime pressure gradients further limit horizon tal dispersion of pollutants in the mixed layer below the subsidence inversion. Poorly dispersed anthropogenic emissions, combined with strong sunshine lead to photochemical reactions, which results in the creation of ozone in this surface layer.

Daytime onshore flow (i.e., sea breeze) and nightti me offshore flow (i.e., land breeze) are quite common in Southern California. The sea breez e helps to moderate daytime temperatures in the western portion of San Diego Co unty, which greatly adds to the climatic draw of the region. This also leads to em issions being blown out to sea at night and returning to land the following day. Under cer tain conditions, this atmospheric oscillation results in the offshore transport of ai r from the Los Angeles region to San Diego County, which often results in high ozone con centrations being measured at San Diego County air pollution monitoring stations. Tr ansport of air pollutants from Los Angeles to San Diego has also been shown to occ ur aloft within the stable layer of the elevated subsidence inversion. In this layer, removed from fresh emissions of oxides of nitrogen (NOx), which would scavenge and reduce ozone concentrations, high levels of ozone are transported into San Diego County.

National and state air quality standards are set fo r criteria pollutants, which are widespread common pollutants known to be harmful to human health and welfare.Project Description & Environmental Setting

1-5 Standards are set to protect the elderly, very youn g, and chronically sensitive portions of our population. Areas not meeting a particular sta ndard are referred to as a nonattainment area for the pollutant. Of the six air pollutants regulated by the federal Environmental Protection Agency, and eight regulate d by ARB, only ozone (smog) and inhalable particulate matter (PM 10 ) occur in concentrations sufficient to violate eit her federal or state standards in San Diego County.

San Diego County has experienced substantial improv ement in ambient ozone levels over the past several years. The number of days above t he federal one-hour ozone standard has decreased from 39 days in 1990 to none in 2000. Similarly, the number of days above the more stringent state standard has decreas ed from 139 days in 1990 to 24 days

in 2000.

Federal standards for PM 10 (particulate matter equal to or less than 10 micron s in size) have never been exceeded. However, the stricter st ate standards are not met at this time.



### 1.4.1 - Consistency of Project with Applicable Regi onal and General

Plans

CEQA Guidelines §15125(d) states that “[t]he EIR sh all discuss any inconsistencies between the proposed project and applicable general plans and regional plans. Such regional plans include, but are not limited to, the applicable air quality attainment or maintenance plan or State Implementation Plan, area -wide waste treatment and water quality control plans, regional transportation plan s, regional housing allocation plans, habitat conservation plans, natural community conse rvation plans and regional land use plans for the protection of the Coastal Zone, Lake Tahoe Basin, San Francisco Bay, and Santa Monica Mountains.” The following is a brief d iscussion of how revised Rule 67.0 is consistent with these plans.

San Diego County General Plan and San Diego County Zoning Ordinance

The implementation of the amendments to Rule 67.0 w ould not directly result in the need for new development and does not propose any development in San Diego County. As such, the prop osed project is consistent with the San Diego County General Plan a nd the San Diego County Zoning Ordinance.

Consistency with Regional Air Quality Plans

The primary purpose of the APCD’s adopted air quali ty plans, the Regional Air Quality Strategy (RAQs) and the State Implementation Plan ( SIP), is to apply strategies for reducing ozone precursor emissions (including VOC) to attain and maintain the state and national ozone air quality standards. The proposed Rule 67.0 amendments will achieve

additional reductions in VOC emissions and are iden tified in the RAQs as a feasible emission control measure. Thus, the Rule 67.0 amen dments are consistent with the regional air quality plans.Project Description & Environmental Setting

1-6 Consistency with Regional Transportation Plans (RTP s)

Since no significant adverse impacts to transportat ion/circulation are anticipated from the implementation of revised Rule 67.0, the project is consistent with regional transportation plans, including the Circulation Element of the Cou nty’s General Plan. While some companies in the architectural coatings industry ha ve asserted that some traffic and congestion may be generated from the disposal of sm all quantities of architectural coatings due to shelf life, pot-life, and freeze-th aw problems, APCD analysis contained here indicates any such effects would be negligible and would not create significant adverse impacts to transportation/circulation. Fur thermore, since compliant low-VOC coatings have performance characteristics that are comparable to their higher-VOC counterparts, additional trips are not expected to result over and above current trips associated with conventional coatings.

Consistency with Regional Housing Allocation Plans

Implementation of revised Rule 67.0 would not creat e or cause the need for additional housing in the project area. Furthermore, the revi sed rule would not affect how housing is planned or allocated within the project area. T herefore, the revised rule is considered to be consistent with Housing Element of the San Di ego County General Plan.

Consistency with Habitat Conservation Plans and Nat ural Community
Conservation Plans

Implementation of revised Rule 67.0 would not resul t in new construction or activities that would create or cause impacts to sensitive hab itats of plants or animals. Since the proposed amendments to APCD Rule 67.0 will result i n a net benefit to air quality in San Diego County, through the reduction of VOC, the pro ject will have a positive impact on plant and animal life through the reduction of regi onal ozone levels. Therefore, the

revised rule is considered to be consistent with th e Conservation Element of the San Diego County General Plan, as well as the County’s Multiple Species Conservation Program, and the Natural Communities Conservation P rogram.

Consistency with the Regional Water Quality Control Board, San Diego Region Basin Plan

Implementation of revised Rule 67.0 would not resul t in an increase in impacts to the quality of water resources in San Diego County. Th e implementation would not impede or hinder the attainment of goals set forth in the Basin Plan, and as such is considered to be consistent with the plan.Project Description & Environmental Setting1-7Figure 1-1: Project Location Map

P a c i f i c O c e a nOC E A NSI DEVIS TASA N M A RC O SESC O ND ID OPO W A YSA NTE EEL C A JO NCH U LA VISTALEM O N GRO V ELA M ES AIM PER IA L BEA C HCO R O NA D OCA R LSB A DENC I NIT A SSO LA NA B EA C HDEL M A RR I V E R S I D E C O UN T Y I M P E R I A L C O U N T Y

E s t a d o s U n i d o s M e x i c a n o s / B a j a C a l i f o r n i aNA TI O NA L C IT Y7 0 7 14 MilesDate: 08/17/2001File: /staff/staff4/apcd/apcd.aprN100 0 100 200 MilesNSan Diego CountyCountiesUnincorporated Areas of San Diego CountyOther Incorporated Cities within San Diego CountyCity of San DiegoFreewaysAPCD Jurisdictional BoundaryProject Location MapSignificant Environmental Effects

2-1 CHAPTER 2.0 - SIGNIFICANT ENVIRONMENTAL EFFECTS

As indicated in Chapter 1, San Diego County APCD st aff considered the ARB Initial Study when it conducted its own IS/EA to determine the scope of this EIR. On June 11, 2001, the APCD issued a Notice of Preparation to re sponsible and trustee agencies, along with a brief summary of the potential environmental effects of the rule adoption and a copy of the IS/EA. Of the 16 potential environment al impact categories on the IS/EA checklist, APCD determined that an EIR should be pr epared to address potential adverse effects on the following environmental categories: air quality, water, public services, transportation/circulation, solid waste/hazardous w aste, hazards, irreversible environmental changes, potential growth inducing im pacts, and consistency with other plans.

Based on the San Diego County EIR Format and Conten t Guidelines, Chapter 2 should provide a “detailed discussion of those subject are as which could be potentially impacted by the proposed project” and is intended to satisfy §15125 and §15126 (a), (b), and (c) of the State CEQA Guidelines. However, issues conclud ed to be not significant after analysis during the EIR process are discussed in Se ction 6.1, and not discussed here in accordance with the requirements of the County EIR Format and Content Guidelines. Further, effects clearly dismissed during the initi al study process as clearly insignificant and unlikely to occur are included in Section 6.2.

San Diego County APCD staff has reviewed and consid ered the Final Programmatic EIR (PEIR) prepared by ARB (adopted by reference herein ) and concurs with the methodologies and determinations made therein. Fur ther, APCD staff has considered the technical analyses (adopted by reference herein) re ferred to in the ARB PEIR for applicability to the conditions here in San Diego C ounty, and has determined that the implementation of the proposed rule changes to APCD Rule 67.0 would not have a potentially significant adverse effect on any resou rce area. A brief discussion and summary analysis for each of the resource area impa cts identified in the IS/EA as requiring further analysis but determined, during t he APCD EIR process, to be less than significant is discussed in Section 6.1 of this doc ument.Cumulative Impacts

3-1 CHAPTER 3.0 - CUMULATIVE IMPACTS

Section 15130 of the State CEQA Guidelines states t hat, “an EIR shall discuss cumulative impacts of a project when the project’s incremental effect is cumulatively considerable.” Further, the Guidelines state “wher e a lead agency is examining a project

with an incremental effect that is not “cumulativel y considerable” a lead agency need not consider that effect significant but shall briefly describe its basis for concluding that the incremental effect is not cumulatively considerable .” Section 15130(a)(1) further states that, “an EIR should not discuss impacts which do n ot result in part from the project

evaluated in this EIR.”

As discussed in Chapter 1, the architectural coatin gs rule is included in the APCD’s Regional Air Quality Strategy (RAQS), which outline s strategies for attainment of the state ambient air quality standard for ozone. The proposed amendments to APCD Rule 67.0 will result in a net benefit to air quality in San Diego County, through the reduction of volatile organic compound emissions from archite ctural coatings. After consideration of the technical studies prepared by ARB as part of its PEIR and consideration of the claims made by architectural coatings manufacturers in the context of ARB’s PEIR, APCD staff has determined that the proposed rule am endments would not result in any significant impact to any of the 16 resources areas identified in the IS/EA. Since the proposed rule amendments would result in a net air quality benefit, they are not considered cumulatively considerable, and no furthe r analysis is warranted.Project Alternatives

4-1 CHAPTER 4.0 - PROJECT ALTERNATIVES

This Chapter implements the requirements set forth in §15126 of the State CEQA Guidelines, which requires a description of a range of reasonable alternatives to the project that would feasibly attain most of the basi c objectives of the project but would avoid or substantially lessen any of the significan t effects of the project, and an evaluation of the comparative merits of the alterna tives. CEQA also requires consideration of a reasonable range of potentially feasible alternatives; it does not require

consideration of alternatives that are not reasonab le. The discussion and analyses of project alternatives presented below are consistent with the analyses of project alternatives in the ARB Final PEIR, which APCD staf f considered and adopts by

reference.

4.1 - Rationale for Alternative Selection

Pursuant to CEQA Guidelines Section 15126.6 (d), a matrix displaying the major characteristics and significant environmental effec ts of each alternative may be used to summarize the comparison. Table V-4 (page V-172) i n the CARB Final PEIR lists the alternatives considered by APCD staff and how they compare to the SCM. Table V-5 (page V-173) of the ARB Final PEIR presents a matri x that lists the significant adverse impacts as well as the cumulative impacts associate d with the proposed project and the project alternatives for all the environmental topi cs analyzed. The table also ranks each impact section as to whether the proposed project o r a project alternative would result in greater or lesser impacts relative to on another.

The ARB Final PEIR included an evaluation of four f easible alternatives (APCD staff adopts by reference ARB’s evaluation and the matrix described above and ARB’s discussion of alternatives found infeasible). The fourth alternative analyzed in the ARB PEIR, Alternative D – Product Line Averaging, was i ncluded in the SCM approved by ARB and also is included in the proposed Rule 67.0 analyzed in this EIR. The three remaining feasible alternatives discussed in the AR B Final PEIR were also considered feasible for the project area and are discussed in Section 4.2, Section 4.3, and Section 4.4

below.

The ARB Final PEIR examined seven alternatives that were found to be infeasible.

APCD staff has reviewed these seven alternatives an d the reasons for their dismissal as feasible alternatives and agrees with the determina tion. The project objectives as

identified in Section 1.2 is to reduce VOC emission s by incorporating lower VOC limits and other requirements for architectural coatings w ithout significantly diminishing usability of the coatings in question. The followi ng is a brief description of alternatives and a discussion of why these alternatives were fou nd to be infeasible for the project area.Project Alternatives

4-2 

### 4.1.1 - Performance-Based Standards

Rather than establish lower VOC content requirement s for specified categories of coatings, this alternative would establish emission standards based on performance standards such as “emissions per area covered” or “ coating durability.” This alternative has been rejected as infeasible because it would be too difficult to reach a consensus among involved parties as to how to create the stan dards to cover the multitude of coatings reformulations with varying performance ch aracteristics.



### 4.1.2 - Seasonal Regulation

Under this alternative, the VOC content limits prop osed for various coatings in Rule 67.0 would be in effect during the “high ozone season" ( typically the summer months). During the “low ozone season” (typically the winter months), coatings formulators could sell and distribute and contractors and do-it-yours elf consumers could use coatings with higher VOC contents.

This alternative was found infeasible for the proje ct area because it is too difficult to implement and enforce. It would be difficult for c oatings formulators, distributors, and retail stores to manage their inventories to ensure that only complying coatings are sold during the high ozone season. Knowledge of and enf orcement of these requirements at the end-user level would be difficult and would req uire significant additional enforcement resources. In addition, there have bee n State violations (“high ozone”) in all months of the year except January, based on data si nce 1995. As such, identifying specific seasonal duration would be difficult, at b est.



### 4.1.3 - Regional Regulation

Under this alternative, areas within the region tha t do not have an ozone problem or contribute to the region’s ozone problem would be e xempted from the VOC requirements of Rule 67.0. This alternative was rejected as inf easible for two main reasons. First, in order to determine the viability of such an approac h, the APCD would have to conduct an extensive analysis involving ambient air quality mo deling to determine which geographical areas would be subject to the lower VO C requirements and which would be exempted. This type of analysis would be difficult to complete due to the inherent variability of meteorological conditions within San Diego County. Different meteorological scenarios would drastically alter th e determination of those geographical areas. In addition, there have been state ozone vi olations throughout the area.

Secondly, even if a reliable technical determinatio n could be made regarding the geographical areas, the problem of enforcing this r egulatory approach remains. Enforcement at the retail level, as well as the end -user level would be difficult and would require significant additional enforcement resource s, as identified in the “Seasonal Regulation” alternative.Project Alternatives

4-3 

### 4.1.4 - Exceedance Fees

This alternative would allow purchases of noncompli ant coatings on payment of a fee, similar to the system that exists in the national A rchitectural and Industrial Maintenance (AIM) coatings rule. The system used in the nation al AIM rule allows coatings manufacturers and importers to sell coatings that e xceed the applicable VOC limit if they pay a fee of $0.0028 per gram of excess VOC. Essen tially, this is a “pay-to-pollute” approach. APCD does not support such an approach b ecause it does nothing to bring the air into compliance with state standards and may ac tually hinder efforts to attain both the state and federal ozone standards. This type of ap proach could eliminate or substantially reduce the emission reductions expected from the pr oposed revisions to Rule 67.0. Additional problems include concern regarding wheth er the fee is high enough to discourage the manufacture and sale of high-VOC coa tings, enforcement at the districtwide level, and extensive record keeping requiremen ts. For all of these reasons, an exceedance fee approach is not considered a feasibl e alternative.



### 4.1.5 - Tonnage Exemption

As with the “Exceedance Fees” alternative, this typ e of alternative is part of the national AIM coatings rule. A tonnage exemption would allow coatings manufacturers and importers to sell limited quantities of coatings th at exceed the applicable VOC limit in Rule 67.0, without paying an “exceedance fee.” The calculation would be based on the total mass of VOC contained in all exempt coatings. The limit of the exemption, on a “per manufacturer” or “per importer” basis, would b e on a sliding scale that would decrease in future years. Like the “Exceedance Fee ” approach, a tonnage exemption would do nothing to bring the air into compliance w ith state standards, and may actually

hinder efforts to attain both the state and federal ozone standards, and could substantially reduce the emission reductions expected from the pr oposed revisions to Rule 67.0. Additional problems include enforcement, record kee ping, and reporting requirements. For these reasons, a tonnage exemption is not consi dered a feasible alternative.



### 4.1.6 - Low Vapor Pressure (Low Volatility) Exempti on

Under this alternative, VOCs with low vapor pressur es (i.e., “low vapor pressure VOCs” or “LVP-VOCs”) would be exempted as VOCs in determi ning the overall VOC content of a coating. This type of exemption is based on a n assumption that low vapor pressure VOCs volatilize more slowly and, as a result, emit less VOCs to the atmosphere and contribute very little to ozone formation in the at mosphere. The ARB Final PEIR identified a number of reasons why this alternative should be rejected as infeasible. Due

to the extensive and technical nature of the reason ing behind this determination, the reasons have not been fully summarized in this repo rt. For an extensive explanation of ARB’s determination of infeasibility, the reader sh ould reference the ARB Final PEIR, Pages V-142 to V-151, which APCD staff adopts by re ference. The same reasons identified in the ARB Final PEIR are applicable to the proposed project. Staff has

concluded that this alternative is not feasible bec ause exempting LVP-VOCs would not achieve regulatory consistency, LVP-VOCs in archite ctural coatings will eventuallyProject Alternatives

4-4 evaporate and enter the atmosphere, and EPA’s Test Method 24 automatically excludes VOCs that do not evaporate into the atmosphere.



### 4.1.7 - Reactivity-Based VOC Limits

This alternative would involve establishing coating VOC limits based on the reactivity characteristics (i.e., the tendency to react in the atmosphere to form ozone) of the compounds contained in the coating, instead of the mass-based VOC limits that are used in the proposed revisions to Rule 67.0. Historical ly, in the State of California and in San Diego County in particular, control of VOC emission s has been through mass-based reductions. The ARB has committed to evaluating th e feasibility of reactivity-based regulations for certain VOC source categories, and a number of specific studies relating to VOC photochemical activity are listed on Pages V -152 and V-153 of the ARB Final PEIR. In addition, ARB has begun to incorporate re activity characteristics of compounds into some of its existing and proposed regulations. However, at this time, a number of issues need to be addressed before this type of con trol strategy could be developed for architectural coatings. These issues are described in the ARB Final PEIR (Pages V-155 to V-158), which APCD staff adopts by reference. A s discussed in the PEIR, additional data are necessary before assessing the feasibility of a reactivity-based control strategy for architectural coatings. Because additional red uctions are needed in the near term, and

historical data indicate mass-based controls effect ively reduce ozone formation, it is necessary to proceed with mass-based VOC limits at this time.

4.2 - Analysis of the “No Project” Alternative



### 4.2.1 - Alternative Description and Setting

This alternative assumes that the proposed revision s to Rule 67.0 would not be implemented, and that the existing VOC limits in Ru le 67.0 would continue to apply.



### 4.2.2 - Comparison of the Effects of the “No Projec t” Alternative to the Proposed Project

As a result of the implementation of the “No Projec t” alternative, VOC emissions from architectural coatings within the project area woul d likely remain at the same level or may increase if the volume of architectural coating s used in the project area increased. As a result, approximately 1.5 tons per day of VOC emi ssion reductions from architectural coatings would not be achieved throughout the proje ct area. This scenario would potentially jeopardize the ability of the region to expeditiously attain and maintain the state ozone standard. However, implementation of t he “No Project” Alternative would not create any new or additional impacts to water r esources or public facilities, or create any new or additional hazards. Since the No Projec t alternative (Alternative A) would not achieve the long-term air quality benefits (e.g ., VOC reductions) of the proposed revisions to Rule 67.0, which are needed by the reg ion to achieve the mandated state and federal ozone standards, it is not the environmenta lly superior alternative.Project Alternatives

4-5 

### 4.2.3 - Staff’s Rationale for Rejection of the “No Project” Alternative

APCD staff does not support the “No Project” Altern ative because it would result in fewer emission reductions than the proposed project and the region needs the emissions reductions that the proposed project will provide t o continue progress toward achieving

the state ozone standard.

4.3 - Analysis of the “Extended Compliance Deadline s” Alternative



### 4.3.1 - Alternative Description and Setting

This alternative would extend all of the effective dates for the VOC content limits to January 1, 2004. The VOC content limits for affect ed coatings would be identical to those in the current version of the proposed revisi ons to Rule 67.0.



### 4.3.2 - Comparison of the Effects of the “Extended Compliance Deadlines” Alternative to the Proposed Project

Air Quality

The “Extended Compliance Deadlines” Alternative (Al ternative B) would extend the VOC content limits to January 1, 2004. This altern ative would ultimately achieve the same VOC emission reductions as the SCM; however, t he reductions would be achieved one year later.

Water Resources

Water Demand

For Alternative B, the affected coatings categories would be reformulated with the same waterborne technology as they would be for the prop osed project to meet the VOC content limits. Therefore, this alternative would result in similar insignificant water demand impacts as the proposed project, but the imp acts would occur one year later.

Water Quality

For Alternative B, the affected coatings categories would be reformulated with the same waterborne technology as they would be for the prop osed project to meet the VOC content limits. Therefore, this alternative would result in similar insignificant water quality impacts as the proposed project, but the im pacts would occur one year later.

Public Facilities

Public Facility Maintenance

For Alternative B, the affected coatings categories would be reformulated with the same waterborne technology as they would be for the prop osed project to meet the VOCProject Alternatives

4-6 content limits. Therefore, this alternative would result in similar insignificant public facility maintenance impacts as the proposed projec t, but the impacts would occur one year later.

Fire Protection

For Alternative B, it is expected that some resin m anufacturers and coatings formulators would use waterborne technology containing less fla mmable solvents. The exception to this would be the use of acetone in some specific c oating categories. However, fire departments treat all NFPA 3 flammable liquids the same. Because the same replacement and coalescing solvents used to meet the proposed p roject VOC content limits would be used to meet the Alternative B VOC content limits, this alternative would result in similar insignificant impacts to fire departments as the pr oposed project, but the impacts would occur one year later.

Transportation/Circulation

For Alternative B, it is expected that the same rep lacement and coalescing solvents used to meet the proposed project VOC content limits wou ld be used to meet the Alternative B VOC content limits. Thus, any additional trips ass ociated with the potential disposal of reformulated low-VOC waterborne coatings due to fre eze-thaw, shelf life, or pot-life problems would be the same as for the SCM. Therefo re, Alternative B may result in similar insignificant transportation/circulation im pacts as the proposed project, but the impacts would occur one year later.

Solid Waste/Hazardous Waste

For Alternative B, it is expected that the volume o f solid waste/hazardous waste generated from the manufacturing, distribution, and use of architectural coatings would be identical to that generated by the proposed proj ect. Therefore, Alternative B would result in similar insignificant solid waste/hazardo us waste impacts as the proposed project, but the impacts would occur one year later

.

Hazards

Risk of Upset

For Alternative B, it is expected that some resin m anufacturers and coatings formulators would use waterborne technology containing less fla mmable solvents. The exception to this would be the use of acetone in some specific c oating categories. However, as mentioned above, fire departments treat all NFPA 3 flammable liquids the same. For some coatings categories, more toxic but less flamm able solvents may be used to meet the VOC limits in the proposed project. The use of these solvents, when balanced against

the use of more flammable but less toxic convention al solvents would result in similar insignificant risk of upset impacts as the proposed project. The same replacement and coalescing solvents used to meet the proposed proje ct VOC content limits would be used

to meet the Alternative B VOC content limits. Ther efore, this alternative would result inProject Alternatives

4-7 similar insignificant risk of upset impacts as the proposed project, but the impacts would occur one year later.

Human Health

For Alternative B, it is anticipated that the same replacement and coalescing solvents used to meet the proposed project VOC content limit s would be used to meet the Alternative B VOC content limits. However, in the context of the complaint, twocomponent, waterborne industrial maintenance system s containing some toxic compounds, since formulators have additional time t o develop coatings, they may be able to formulate systems containing less toxic compound s or develop better application techniques to further reduce human exposure to thes e compounds. Therefore, Alternative B would result in slightly fewer human health impac ts as compared to the insignificant health impacts of the proposed project.



### 4.3.3 - Staff’s Rationale for Rejection of the “Ext ended Compliance

Deadlines” Alternative

APCD staff does not support Alternative B since the VOC limits in the proposed rule are feasible by January 1, 2003 (January 1, 2004 for in dustrial maintenance coatings), and since additional time to comply is not necessary. Both the federal and California Clean Air Acts mandate that air quality standards be atta ined as expeditiously as practicable, and the region’s air quality problems require that any delay in achieving emission reductions must be technically or economically just ified. Based on all the information received by APCD staff to date, such a delay is not warranted.

4.4 - Analysis of the “Further Reduction of VOC Con tent Limits” Alternative



### 4.4.1 - Alternative Description and Setting

This alternative would further reduce the VOC conte nt limits for affected coatings categories (adoption of the “final” limits as descr ibed in Table 1 of Appendix C of the NOP/IS for the ARB SCM EIR; see Appendix B of the A RB Final PEIR). The other proposed changes in the current proposed version of Rule 67.0 would be maintained.



### 4.4.2 - Comparison of the Effects of the “Further R eduction of VOC Content Limits” Alternative to the Proposed Project

Air Quality

The “Further Reduction of VOC Content Limits” Alter native (Alternative C) would implement lower VOC content limits than those inclu ded in the proposed revisions to

Rule 67.0. This alternative would further aid the APCD’s efforts to meet and maintain

the federal and state ozone standards.Project Alternatives

4-8 Water Resources

Water Demand

For Alternative C, the final lower VOC content limi ts associated with this alternative may require increased use of waterborne technology. Ho wever, the worst-case scenario analyzed in this EIR and the ARB PEIR, that all aff ected coatings would be reformulated using waterborne technology, showed that water dema nd impacts were insignificant for the proposed project. Therefore, Alternative C wou ld result in similar insignificant water demand impacts.

Water Quality

For Alternative C, the final lower VOC content limi ts associated with this alternative may require increased use of waterborne technology. Ho wever, the worst-case scenario analyzed in this EIR and the ARB PEIR, that all aff ected coatings would be reformulated using waterborne technology, showed that water qual ity impacts were insignificant for the proposed project. Therefore, Alternative C wou ld result in similar insignificant water quality impacts.

Public Services

Public Facility Maintenance

For Alternative C, end-users would eventually be re quired to use coatings with a lower VOC content than those in the proposed project. Ho wever, based on the SCAQMD’s technology assessment for Rule 1113 (SCAQMD, 1999), these lower VOC coatings perform as well as higher VOC coatings (APCD staff has considered that SCAQMD assessment concurs in its conclusions, and adopts i t by reference. It is available at the APCD offices, 9150 Chesapeake Drive, San Diego, CA 92123). Therefore, Alternative C would result in similar insignificant public facili ty maintenance impacts as the proposed project.

Fire Protection

For Alternative C, the final VOC content limits may require the increased use of waterborne technology. Manufacturers would be requ ired to reformulate all solventborne coatings containing more flammable solvents w ith waterborne technology containing less flammable solvents. Therefore, Alt ernative C would result in fewer fire department impacts than would be expected with the proposed project.

Transportation/Circulation

For Alternative C, the final VOC content limits may require the increased use of waterborne technology. Thus, any additional trips associated with the disposal of reformulated low-VOC waterborne coatings due to fre eze-thaw, shelf life, or pot-life problems could potentially be greater than for the proposed project. However, the worstcase scenario analyzed in this EIR and the ARB PEIR , that all affected coatings would be reformulated using waterborne technology, showed th at transportation/circulationProject Alternatives

4-9 impacts were insignificant. Therefore, Alternative C would result in similar insignificant transportation/circulation impacts to those associa ted with the proposed project.

Solid Waste/Hazardous Waste

For Alternative C, the final VOC content limits may require the increased use of waterborne technology. Thus, there could be potent ial additional coatings landfilled as a result of freeze-thaw, shelf life, or pot life prob lems associated with the use of reformulated low-VOC waterborne coatings. However, the worst-case analyzed in this EIR and the ARB PEIR, that all affected coatings wo uld be reformulated using waterborne technology, found that solid waste/hazar dous waste impacts were insignificant. Therefore, Alternative C would resu lt in similar insignificant solid waste/hazardous waste impacts to those associated w ith the proposed project.

Hazards

Risk of Upset

For Alternative C, the final VOC content limits may require the increased use of waterborne technology. In the context of flat, non flat, and rust preventative coatings, resin manufacturers and coatings formulators would be replacing current coalescing

solvents with less toxic and less flammable solvent s in their waterborne formulations. Conversely, in the context of industrial maintenanc e coatings, coatings formulators would be incrementally increasing the use of two-componen t polyurethane waterborne systems containing toxic solvents. Therefore, when balanci ng the loss of solvents that are more toxic and more flammable against the incremental in crease in the use of certain coatings containing more toxic solvents, Alternative C would result in similar insignificant risk of upset impacts as the proposed project.

Human Health

For Alternative C, the final VOC content limits may require the increased use of waterborne technology. In the context of flat, non flat, and rust preventative coatings, resin manufacturers and coatings formulators would be replacing current coalescing

solvents with less toxic and less flammable solvent s in their waterborne formulations. Conversely, in the context of industrial maintenanc e coatings, coatings formulators would be incrementally increasing the use of two-componen t polyurethane waterborne systems containing toxic solvents. Therefore, when balanci ng the loss of solvents that are more toxic and more flammable against the incremental in crease in the use of certain coatings containing similar toxic solvents, Alternative C wo uld result in similar insignificant human health impacts as the proposed project.



### 4.4.3 - Staff’s Rationale for Rejection of the “Fur ther Reduction of
VOC Content Limits” Alternative

Alternative C, “Further Reduction of VOC Content Li mits” Alternative, is not recommended by APCD staff due to the need to focus limited staff resources on theProject Alternatives

4-10 technical, environmental, and economic issues assoc iated with adoption of the interim limits. Based on the information and analyses in t his EIR and the ARB Final PEIR adopted by reference herein, APCD staff has conclud ed that the proposed revisions to Rule 67.0 are necessary and the best alternative fo r the APCD to achieve the further VOC

reductions needed to attain the state and federal o zone standard. Moreover, if the APCD does not adopt the proposed revisions to Rule 67.0, the APCD will have to find other, potentially more costly VOC emission reductions to offset the foregone emission

reductions.Long-Term Environmental Effects

5-1 CHAPTER 5.0 - LONG-TERM ENVIRONMENTAL EFFECTS

5.1 - Growth Inducing Impacts

CEQA Guidelines §15126(d) requires an environmental analysis to consider the “growthinducing impact of the proposed action.” CEQA Guide lines §15126.2(d) states that the EIR shall “[d]iscuss the ways in which the proposed project could foster economic or population growth, or the construction of additiona l housing, either directly or indirectly, in the surrounding environment.”

Implementing revised Rule 67.0 would primarily affe ct existing coatings formulation companies and would not, by itself, have any direct or indirect growth-inducing impacts on California businesses because it is not expected to foster economic or population growth or the construction of additional housing.

5.2 - Significant Irreversible Environmental Change s Resultant from Project Implementation

CEQA Guidelines §15126(c) requires an environmental analysis to consider “any significant irreversible environmental changes whic h would be involved if the proposed action should be implemented.” In particular, CEQA Guidelines §15126.2(c) indicates that “[u]ses of nonrenewable resources during the i nitial and continued phases of the project may be irreversible since a large commitmen t of such resources makes removal or nonuse thereafter unlikely. Primary impacts and, p articularly, secondary impacts (such as highway improvement which provides access to a prev iously inaccessible area) generally commit future generations to similar uses. Also, i rreversible damage can result from environmental accidents associated with the project . Irretrievable commitments of

resources should be evaluated to assure that such c urrent consumption is justified.”

The following impact areas have been evaluated in t his EIR, as well as in the CARB Final PEIR: air quality, water, public services, tr ansportation/circulation, solid waste/hazardous waste, and hazards. The analyses p resented in this EIR and in the ARB Final PEIR adopted by reference indicate that no si gnificant adverse project-specific or cumulative impacts would occur to any of these envi ronmental areas.

For example, the air quality impacts analysis inclu ded an evaluation of eight issues identified by industry regarding the potential air quality impacts of the project. After considering these issues, APCD staff determined tha t the project would not have a significant effect on air quality. The analysis of water impacts indicated that an

incremental increase in the amount of wastewater fr om cleaning coating equipment could occur but that this increase would not be significa nt. The analysis of public services and transportation/circulation concluded that revised R ule 67.0 would not create any significant adverse impacts to these areas.Long-Term Environmental Effects

5-2 Likewise, the solid waste/hazardous waste analysis included an evaluation of the potential for an incremental increase in solid wast e impacts resulting from some types of coatings that may have a shorter pot life or shorte r shelf life or may be less able to

withstand freeze-thaw conditions than conventional coatings. A worst-case analysis was performed and it was determined that even if there were an incremental increase in solid waste impacts, this increase would not be significa nt. The analysis of hazard impacts indicated that future compliant low-VOC coatings co uld be formulated with hazardous materials. However, solvents used in low-VOC coati ngs are typically no more hazardous than solvents used in conventional coatings. There fore, hazards impacts are considered to be insignificant. Further, because Industrial M aintenance coatings are typically applied in industrial settings where safety equipme nt, training, and procedures are in place, workplace exposures to potentially hazardous coatings would be minimal. In addition, because architectural coatings are applie d on an as-needed basis, continuous exposures would not occur. As a result, no signifi cant cancer or noncancer human health impacts are anticipated.

As can be seen by the information presented in this EIR and in the ARB PEIR adopted by reference herein, the proposed project would not re sult in irreversible environmental changes or the irretrievable commitment of resource s.Environmental Effects Found Not To Be Significant

6-1 CHAPTER 6.0 - ENVIRONMENTAL EFFECTS FOUND NOT TO BE
SIGNIFICANT

6.1 - Effects found not to be Significant as Part o f the EIR Process

As indicated in Chapter 1, San Diego County APCD st aff reviewed the Initial Study prepared by ARB when it conducted its own IS/EA to determine the scope of this EIR. On June 11, 2001, the APCD issued a Notice of Prepa ration to responsible and trustee agencies, along with a brief summary of the potenti al environmental effects of the rule adoption and a copy of the IS/EA. Of the 16 potent ial environmental impact categories on the IS/EA checklist, APCD determined that a Draf t EIR should be prepared to address potential adverse effects on the following environm ental categories: air quality, water, public services, transportation/circulation, solid waste/hazardous waste, hazards, irreversible environmental changes, potential growt h inducing impacts, and consistency with other plans.

San Diego County APCD staff has reviewed and consid ered the PEIR prepared by ARB, including the technical analyses, and concurs with the methodologies and determinations made therein. Further, APCD staff has considered t he technical analyses referred to in the ARB PEIR (and adopted by reference herein) for applicability to the conditions that exist here in San Diego County, and has determined that the implementation of the proposed rule changes to APCD Rule 67.0 would not h ave a potentially significant effect

on any resource area.

Section §15128 of the State CEQA Guidelines states that an EIR “shall contain a statement briefly indicating the reasons that vario us possible significant effects of a project were determined not to be significant and w ere therefore not discussed in detail in the EIR.” The following is a summary analysis for each of the resource area impacts identified in the IS/EA as requiring further analys is but determined, during the EIR process, to be less than significant.



### 6.1.1 - Air Quality

Existing Conditions

VOC emissions contribute to the formation of both o zone and PM 10 (particulate matter less than 10 microns equivalent aerodynamic diamete r). Ozone formation in the lower atmosphere results from a series of chemical reacti ons between VOC and NOx in the presence of sunlight. PM 10 is the result of both direct and indirect emission s. Direct

sources of PM 10 include emissions from fuel combustion and wind ero sion of soil.

Indirect PM 10 emissions result from the chemical reaction of VOC, NOx, sulfur oxides and other chemicals in the atmosphere.

Of the six air pollutants regulated by the federal Environmental Protection Agency, and eight regulated by ARB, only ozone and inhalable pa rticulate matter (PM 10 ) occur inEnvironmental Effects Found Not To Be Significant

6-2 concentrations sufficient to violate either federal or state standards in San Diego County. The efforts of the San Diego APCD are focused prima rily on attainment of state and federal standards for these pollutants and maintain ing the standards for all criteria pollutants. Below is a brief description of each n on-attainment pollutant.

Ozone

Ozone, the main component of photochemical smog, is primarily a summer and fall pollution problem. Ozone is not emitted directly i nto the air but is formed through a complex series of chemical reactions involving othe r compounds that are directly emitted. These directly emitted pollutants (also k nown as ozone precursors) include VOC and NOx. The time period required for ozone fo rmation allows the reacting compounds to spread over a large area, producing a regional pollution problem. Once formed, ozone generally remains in the atmosphere f or one or two days. Ozone is then eliminated through chemical reaction with plants (r eacts with chemicals on the leaves of plants), rainout (attaches to water droplets as the y fall to earth), and washout (absorbed by water molecules in clouds and later falls to ear th with rain).

The total contribution of VOC emissions from archit ectural coatings in San Diego County is estimated at 10.3 tons per day in 2000 (a nnual average). Assuming existing controls, the annual average VOC emissions from arc hitectural coatings are expected to grow to 11.5 tons per day by 2005.

Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse air quality impacts. Air quality impacts will be considered significant if the propo sed rule amendments would conflict with or obstruct implementation of the applicable a ir quality plan; violate any air quality standard or contribute to an existing or projected air quality violation; expose sensitive receptors to substantial pollutant concentrations; expose off-site receptors to significant concentrations of hazardous air pollutants; result in a cumulatively considerable net increase of any criteria pollutant for which the pr oject region is nonattainment; or create objectionable odors affecting a substantial number of people.

Analysis of Project Effects and Determination as to Significance

Industry Concerns

The following is a discussion and analysis of archi tectural coatings industry issues related to air quality impacts from the proposed project. For each issue area, APCD staff reviewed the detailed analysis of these issues prep ared by ARB and contained in Section IV, Subsection C of the PEIR prepared by ARB staff for the SCM for architectural coatings. Staff also reviewed the comments receive d by ARB and ARB’s responses to comments. In addition, staff considered the inform ation compiled to date through ongoing studies by the SCAQMD with National Technic al Systems (NTS), a testing program by the essential public service agencies (E PSA) and an analysis of the HarlanEnvironmental Effects Found Not To Be Significant

6-3 Associates Study prepared by Stan Cowen of the Vent ura County Air Pollution Control

District. 2 The analysis and discussion in this EIR also cons ider the following update of the studies prepared since certification of the ARB PEIR.

SCAQMD Phase II Assessment Study of Architectural C oatings (NTS)

In 1998, the South Coast Air Quality Management Dis trict (SCAQMD) initiated a performance study with National Technical Systems ( NTS) to evaluate the following six architectural coating categories: Industrial Maint enance, Non-flats, Primers/Sealers/Undercoaters, Quick Dry Enamels, Qu ick Dry Primers/Sealers/Undercoaters and Waterproofing Seal ers. The objective of the performance study was to conduct side-by-side labor atory and outdoor exposure tests for coatings with varying VOC contents.

The performance study involved 31 manufacturers or brands, 94 coatings, 46 coating systems (e.g., primer and topcoat), and over 3000 t est panels. The laboratory portion of the study was completed in 1999, and is summarized in Appendix E of the ARB staff report for the proposed Suggested Control Measure f or Architectural Coatings, approved by the Board on June 22, 2000. In general, the lab oratory portions of the study revealed similar performance among high and low VOC coatings

.

The outdoor real-time exposure testing is ongoing a nd includes a desert and coastal environment. The outdoor real-time exposure will l ast for two years, and will not be completed until 2002. ARB staff will summarize the data at that time.

Essential Public Service Agencies (EPSA) Testing Pr ogram

In response to comments provided by the essential p ublic service agencies (EPSA), the SCAQMD’s May 1999 architectural coatings rule amend ments established a new specialty category called “essential public service coating.” The category is for protective coatings applied to components of power, municipal wastewater, water, bridges and other roadways, transmission or distribution systems duri ng repair and maintenance procedures. The category includes coatings used by the EPSA that were previously included in the industrial maintenance coatings cat egory. The essential public service category was created to allow additional time for E PSA to complete its lengthy administrative processes to identify and evaluate n ew coatings to replace those currently used for the public infrastructure. The category’s VOC limit decreases to 100 g/l by 2006, which matches the industrial maintenance cate gory limit. Thus, the ESPA testing program will primarily focus on coatings capable of meeting the 100-g/l VOC limit. However, the program is also evaluating some coatin gs at the 250-g/l level.

Earlier this year, the members of EPSA entered into a memorandum of understanding (MOU) to accomplish their common coating performanc e testing goals. The EPSA

consist of:

• Caltrans (California Department of Transportation);

2 All of these analyses, responses, and studies are incorporated herein by reference, and are available at the APCD offices located at 9150 Chesapeake Drive, San Diego, CA.Environmental Effects Found Not To Be Significant

6-4 • California Department of Water Resources (DWR);

• Los Angeles Department of Water and Power (LADWP);

• Metropolitan Water District of Southern California (MWD).

A technical steering committee consisting of repres entatives from each public service agency, SCAQMD, and ARB has been established. The technical steering committee has approved a test program design that includes test s equences, test procedures, and performance evaluation criteria. Coating selection and application is ongoing. The scope of testing will involve laboratory and field tests of compliant coatings and is expected to last a number of years even with expedited testing efforts. For example, the coating evaluation process at Caltrans entails a laboratory screening and characterization, including health and safety review (4 months), cycl ic corrosion testing in the laboratory (8 months), field application tests (2 years), and specification development (2 years).

Southern California Alliance of Publicly Owned Trea tment Works (SCAP) Testing Program

The Southern California Alliance of Publicly Owned Treatment Works (SCAP) represents over 55 government agencies involved in the treatment and recycling of water and wastewater. These agencies operate facilities and equipment that are exposed to a harsh environment. As a result of VOC limits speci fied in SCAQMD Rule 1113 and ARB’s Architectural Coatings SCM, SCAP has committe d to evaluate the performance of low VOC coatings suitable for wastewater environ ments. Their testing program includes laboratory and field tests that are being conducted to evaluate the performance, durability, and application requirements of low VOC coatings. The coatings included in this test program have VOC contents that range from less than 100 g/L to 340 g/L. This testing program is scheduled to conclude in 2003.

Harlan Associates Study

In February 1995, ARB published the results of perf ormance testing of architectural coatings by Harlan Associates, Inc. The purpose of the study was to determine the physical properties and performance of representati ve products in eight coating categories. A total of 110 coating products, purch ased during late 1993 and throughout 1994, were tested in the following categories: indu strial maintenance primers and topcoats, high-temperature industrial maintenance c oatings, lacquers, varnishes, non-flats (including quick-dry enamels), primer/sealers (incl uding quick-dry primer/sealers), sanding sealers and waterproofing sealers (wood and concrete).

While the raw data from this study were published i n 1995, an analysis of the overall comparison of the coatings' test performance was no t published. In developing the proposed SCM, ARB and district staffs analyzed and summarized the raw data. This performance study, although somewhat dated, is used to supplement the newer NTS study.

Industry Concern No. 1 – Increase in Thickness of C oatings

Some companies in the architectural coatings indust ry have commented that, in order to meet the VOC limits proposed, manufacturers would n eed to reformulate many of theirEnvironmental Effects Found Not To Be Significant

6-5 coatings to increase the amount of solids contained in those coatings. According to industry, this increase in solids content would lea d to increased thickness of the low-VOC coatings being sprayed. Increased coating thicknes s would have two main effects. First, the coatings would become more difficult to handle during application due to increased viscosity. Secondly, a set amount of coating would cover less surface area, also due in part to increased viscosity. Industry contends tha t it is mainly high-solid, solvent-based alkyds, non-flats in particular that will have this problem. During the review period of the ARB draft PEIR for the architectural coatings S CM, ARB received comments from industry that ARB had misinterpreted earlier commen ts that addressed this issue. Industry stated that ARB had focused too narrowly o n increased thickness as it applied to waterborne coatings, not high solid, solvent-based alkyds.

ARB’s response to these comments indicated that mor e attention was paid to water-borne coatings because water-borne coatings made up a ver y large percentage (95%) of nonflats. ARB also stated that there are a number of options manufacturers could choose which would allow them to reformulate coatings that would comply with the rule while not increasing solids. These include using exempt solvents, or moving to a water-based system. If a manufacturer does decide to reformula te a coating to increase solids content, less viscous resins exist which would allow complia nt coatings to be manufactured while not increasing overall thickness. In evaluating pr oduct data sheets from 500 different coatings and the results of its 1998 Architectural Coatings Survey, there was no apparent relationship between VOC content and the amount of solids that are present in the coating and no relationship between solids content and cove rage. ARB also stated that an accurate way to determine whether low-VOC levels co rresponded to increased solids and

increased thickness was to see whether there had be en an increase in overall sales over time. ARB found that coatings sales had remained c onstant on a per-capita basis over the last 12 years.

ARB’s analysis of this issue in the PEIR is relevan t to San Diego County (and is adopted by reference herein). APCD staff examined this iss ue to see if there were any local issues that might alter APCD’s conclusion and found that A RB's analysis is equally applicable to San Diego County. There is nothing to suggest t hat reformulated coatings that work in other parts of the state would not also work in San Diego County. Furthermore, according to test data accumulated by ARB, many wat er-based, compliant coatings are available. These coatings would not have the probl em of increased thickness. Companies that do business in San Diego also do bus iness in other parts of the state, so there is no reason to believe that these coatings w ould not be available in the San Diego region from the manufacturers of these coatings.

Industry Concern No. 2 – Illegal Thinning

When commenting on ARB’s draft EIR, industry also r aised the issue of possible illegal thinning that would occur if the proposed VOC limit s were adopted. The coatings affected by this are supposedly the same kinds of c oatings that would be affected by the increased thickness problem discussed previously. According to industry, individual users will add illegal amounts of thinner to produc ts that have been made more viscous due to increased solids content. Industry also com mented that the ARB field study onEnvironmental Effects Found Not To Be Significant

6-6 thinning was flawed due to inaccurate sampling wher e the focus was on higher-VOC specialty coatings that are less likely to be thinn ed.

APCD staff considered and adopts by reference ARB’s analyses and responses on this

issue. As stated in the ARB discussion on increase d thickness, the low-VOC coatings referenced by industry were found to exhibit simila r thickness and coverage to higher VOC coatings when applied. APCD staff considered a nd adopts by reference ARB’s analysis and responses on this issue. ARB used pro duct data sheets in part to determine the coverage exhibited by these products. These pr oducts should behave and perform in

a manner that is consistent with what is described by their manufacturers. Also, these products should exhibit coverage qualities in San D iego County that are either identical or very similar to the qualities exhibited in any o ther part of the state. These would

indicate that there would be no need for users to t hin coatings in excess of legal limits. Also, ARB has stated that its 1991 study focused on coatings that were found being used in the field and that users indicated they had been thinned with VOC containing material.

The low-VOC coatings referred to by industry have b een found to have coverage qualities similar to that of higher-VOC coatings; t hinning to reduce viscosity should not be an issue. ARB's analysis also concluded that th inning also inhibits hiding properties, increases drying time and, that when thinning occur red, the VOC limits were rarely exceeded. Additionally, most of the products on th e market are water-based. Because water-borne coatings are thinned with water and are not usually thinned with solvent, low-VOC water-borne products would not be expected to result in illegal thinning.

Industry Concern No. 3 – Increase in Priming Needed

Industry has commented that adopting the proposed V OC limits will lead to an increase in the amount of priming necessary to apply low-VOC water-based latex enamels. Industry contends that the increased priming would be necessary because the water-based latex enamels have poorer adhesion when being used to coat difficult substrates, and because the coatings have poor sealing and stain-bl ocking properties.

APCD staff considered and adopts by reference ARB’s analyses and responses on this issue. The product data sheets that ARB used in pa rt to make its determination of the performance capabilities of low-VOC coatings do not state that primers are recommended prior to application of latex enamel on an enamel surface. Also, the NTS study demonstrated that adhesion characteristics of low-VOC coatings are similar to conventional coatings. Also, data sheets for these products list, as some of their performance characteristics, “excellent adhesion to aged enamels.”

Furthermore, no increase in primer sales has been d emonstrated in a way that corresponds with previous attempts to increase the stringency o f VOC levels for architectural coatings. These facts contradict the suggestion th at adopting the proposed VOC levels would lead to an increase in the use of primers. F inally, there is nothing to suggest increased priming will be needed in San Diego Count y.Environmental Effects Found Not To Be Significant

6-7 Industry Concern No. 4 – Additional Topcoats Requir ed

Industry has commented that they expect the propose d VOC reductions will result in an increased amount of topcoat use. This is because i ndustry contends that low-VOC products will not exhibit satisfactory coverage, bu ild, or flow-and-level. Industry indicates that the problems that would lead to more topcoat use are mostly exhibited in water-based latex topcoats whereas ARB relied in pa rt on studies that focused mostly on solvent-based products. Industry also stated that the NTS study used by ARB was flawed because test panels were coated by draw down method that does not reflect real-world application, and because industrial maintenance top coats were not subjected to real-world exposure levels for a sufficient amount of time. I t should also be noted that industry was represented on the NTS technical advisory committee that approved the testing protocol, including draw downs.

APCD staff considered and adopts by reference ARB’s analysis and responses on this issue. ARB data showed that water-based latex prod ucts did not demonstrate the deficiencies enumerated by industry. These product s make up the majority of latex nonflats available on the market. The use of the draw down method to coat test panels was thought to be appropriate because this helps to sta ndardize the application process. Industry was involved in a technical advisory commi ttee for choosing test protocol. ARB also concluded that tests represent a reasonable le vel of exposure, and that to subject coatings to all possible types of exposure would be an unrealistic undertaking. The length of exposure was not deemed to be an importan t factor for measuring characteristics such as coverage, flow-and-level, a nd build.

Tests done by ARB evaluated a sample of products th at reflect the type of coatings being manufactured and sold in California. An advisory c ommittee that included many members of industry selected these coatings to be t ested and the testing protocols. Since using consistent methods is important for conductin g a valid test, using the draw down method of application is reasonable for coating tes t panels. Additionally, the time frame of the study was applicable for evaluating performa nce characteristics such as coverage, flow-and-level, and build. The tests upon which AR B relied for data are reasonable and do not indicate that more topcoat use will result f rom adopting the proposed VOC limits.

APCD staff considered this issue to see if there we re any local issues that might alter APCD’s conclusion and concluded that ARB's analysis is equally applicable to San Diego County.

Industry Concern No. 5 – More Touch-Ups and Repair Work

Some coatings manufacturers and contractors have cl aimed that water-borne and lowVOC solvent-borne formulations do not dry as fast a s conventional coatings and, therefore, are susceptible to damage such as saggin g, wrinkling, alligatoring, or becoming scraped and scratched. Some industry representativ es contend that low-VOC, acetoneborne lacquers, water-borne topcoats, and substitut es will require more touch-up repair work because longer drying times allow for the cont amination of the coated surface with airborne dust and construction debris. Industry re presentatives also claim that highsolids, solvent-based alkyd enamels tend to yellow in dark areas, and that water-based coatings tend to blister or peel and result in seve re blocking problems. Because of theseEnvironmental Effects Found Not To Be Significant

6-8 problems discussed above, industry representatives claim that there will be a need to apply additional coatings.

APCD staff considered and adopts by reference ARB’s analysis and responses on this issue. According to the product data sheets review ed by ARB staff, the average drying time between coats for low-VOC coatings was similar or less than the average drying time for conventional coating in all categories exc ept lacquers. Additionally, per capita coatings sale has not increased since 1988, which i ndicates that there is no increase in touch-up and repair due to the use of water-borne c oatings. Also, the NTS study demonstrated that blocking characteristics of low-V OC coatings are similar to conventional coatings. APCD staff looked at this i ssue to see if there were any local issues that might alter APCD’s conclusion and it wa s determined that ARB's analysis is equally applicable to San Diego County.

Industry Concern No. 6 – More Frequent Re-coating

Some coating manufacturers and contractors have ass erted that durability of compliant water-borne and low-VOC solvent-borne coatings are inferior to that of traditional solvent-borne coatings. They claim that the new co atings have many finish problems such as cracking, peeling, excessive chalking, and color fading and, therefore, will require more frequent re-coating, resulting in more VOC emissions than traditional coatings.

APCD staff considered and adopts by reference ARB’s analysis and responses on this issue. The durability of a coating is affected by many factors, such as surface preparation, application method, environment (mecha nical stress, thermal weathering), type of binder in the formulation, and the substrat e coated. Results of the NTS study show that compliant coatings have similar performan ce and application characteristics as conventional coatings. APCD staff examined this is sue to see if there were any local issues that might alter APCD’s conclusion and found that results of the NTS study are equally applicable to San Diego County.

Industry Concern No. 7 – Substitution

Some coating manufacturers and contractors have ass erted that because water-borne and low-VOC solvent-borne coatings are inferior in dura bility and more difficult to apply than conventional coatings, consumers and contracto rs will substitute allegedly better performing, higher VOC coatings from other categori es for use in categories with low VOC compliance limits (e.g., use of a rust preventi ve coating, which has a higher VOC content limit requirement, in place of an industria l maintenance coating or nonflat coating.)

APCD staff considered and adopts by reference ARB’s analysis and responses on this issue. Widespread substitution is not expected to occur as a result of adopting the rule amendments for the following reasons:Environmental Effects Found Not To Be Significant

6-9 • The results from the NTS study show that low-VOC co atings with similar performance characteristics to conventional coating s are currently available.

• The amended rule will not allow the application of certain coatings in specific settings (e.g., rust preventative coatings cannot b e used in industrial settings.)

• The amended rule will require that when a coating c an be used in more than one coating category, the lower limit of the two catego ries is applicable (except for specified categories).

APCD staff does not expect that contractors and con sumers will substitute higher-VOC coatings for low-VOC coatings. Low-VOC coatings wi th similar performance characteristics to conventional coatings are availa ble on the market. APCD staff examined this issue to see if there were any local issues that might alter APCD’s conclusion and found that ARB's analysis is equally applicable to San Diego County.

Industry Concern No. 8 – More Reactivity

Some industry representatives have claimed that req uiring manufacturers to reformulate to water-borne technology will lead to increases in ozone formation because the VOCs used in water-borne coatings are more reactive than those used in solvent-borne coatings. Industry also suggested that the VOCs used in archi tectural coatings, such as mineral spirits, have low reactivity and, thus, does not co ntribute to ozone formation. Industry also suggested that NOx control alone might be most appropriate for reducing groundlevel ozone. Industry representatives have also cl aimed that mass-based controls may not be effective and that reducing VOCs under certain c onditions may actually lead to ozone

nonattainment.

APCD staff considered and adopts by reference ARB’s analyses and responses on this issue. Existing data do not support the claim that water-borne coatings are more reactive than solvent-borne based. A typical VOC used in wa ter-borne coatings, such as propylene glycol, may be two to three times more re active, on a per-gram basis, than a typical mineral spirit used in a solvent-based coat ing. However, when comparing the total, or weighted, reactivity of a product or prod uct category (water-borne vs. solventborne), ARB staff found out that solvent-borne coat ings are over two times more reactive than water-borne coatings. In addition, the reacti vity of propylene glycol is approximately three times less reactive (on a per-g ram basis) than that of other VOCs used extensively in solvent-borne coatings, such as xylenes and toluene. Analysis also showed that the reactivity of some solvents used in water-borne coatings is similar to a typical mineral spirit used in solvent-borne coatin gs. A conclusion that VOC control

causes more ozone cannot be substantiated under rea l-world atmospheric conditions since certain atmospheric conditions characterized by ver y high VOC to NOx ratios must exist in order for VOC control to exhibit an enhancing ef fect on ozone formation. These conditions are not likely to occur in urban regions such as San Diego County.

ARB’s analysis of the available data indicates ther e is no validity to the claim that waterborne coatings are more reactive than solvent-borne coatings. APCD staff examined thisEnvironmental Effects Found Not To Be Significant

6-10 issue to see if there were any local issues that mi ght alter APCD’s conclusion and found that ARB's analysis is equally applicable to San Di ego County. The solvent-borne coatings are over two times as reactive than water- borne coatings. Therefore, the reformulation to water-borne coatings is likely to decrease ozone formation. The analysis also concluded that mass-based VOC regulations have been effective at reducing groundlevel ozone concentrations.

Industry Concern No. 9 – Synergistic Effects of the Eight Issues

Industry representatives have stated that the syner gistic effect of the eight issues discussed above should be analyzed. Synergy occurs when two or more effects interact to produce a subsequent effect and the subsequent e ffect is not evident in any individual

effect. APCD staff reviewed information submitted by industry as well as ARB staff analysis of NTS data and product data sheets. APCD staff concludes that low-VOC coatings have similar performance characteristics a s conventional coatings. There is no evidence that a significant adverse air quality imp act will result from the combined effect of two or more of the eight issues that is not evid ent in the effects analyzed of any singular issue.

Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse air quality impacts. Based on the information contained in thi s EIR and the ARB PEIR and associated technical studies, it has been determine d that proposed Rule 67.0 amendments would result in a VOC reduction and no significant thresholds would be exceeded. Specifically, proposed Rule 67.0 amendments would n ot conflict with or obstruct implementation of the applicable air quality plan, violate any air quality standard or contribute to an existing or projected air quality violation, expose sensitive receptors to substantial pollutant concentrations, expose off-si te receptors to significant concentrations of hazardous air pollutants, result in a cumulatively considerable net increase of any criteria pollutant for which the pr oject region is nonattainment, or create objectionable odors affecting a substantial number of people.



### 6.1.2 - Water Resources

Existing Conditions

Water resources will be divided into two categories —water demand and water quality.

Water Demand

The majority of the water consumed in San Diego Cou nty is imported through the San Diego County Water Authority (SDCWA) from the Metro politan Water District (MWD). MWD is a wholesale supplier of the supplemental imp orted water to Southern California. The MWD supplies water to an area approximately 5,2 00 square miles encompassing six counties (Los Angeles, Orange, Riverside, San Berna rdino, Ventura and San Diego).Environmental Effects Found Not To Be Significant

6-11 There are two primary water supply sources to the M WD: the Colorado River via the Colorado River Aqueduct and the State Water Project via the Edmund G. Brown California Aqueduct. Water supplied to San Diego C ounty by the MWD is received by the SDCWA and transported to its 23 member cities a nd individual water districts for distribution to retail customers through two aquedu cts containing five large-diameter pipelines.

The SDCWA is the major water supplier in the San Di ego region, supplying from 70 to 90 percent of the San Diego region’s water needs, w ith the balance being primarily annual runoff into local reservoirs. According to the 1997 Water Resources Plan, the Authority’s service area covers the western third o f San Diego County, approximately 909,959 acres (1,420.3 square miles). The SDCWA is comprised of 23 member agencies that directly or indirectly purchase water for use at the retail level. The SDCWA is governed by a 34-member Board of Directors represen ting the member agencies. The County of San Diego, which does not deliver water, is an ex-officio member. The member agencies are comprised of six cities, four w ater districts, three irrigation districts, a public utility district, and a military reservati on (Camp Pendleton Military Reservation).

Water usage in San Diego County is closely linked t o the local economy, population growth, and changes in weather. Historically, expa nsion of local economy has stimulated regional population, which has produced a relativel y steady increase in water demand.

The demand for water in the SDCWA service area is d ivided into two basic categories: municipal/industrial, and agricultural. Municipal and industrial water usage constitutes approximately 80 to 85 percent of the regional wate r consumption. Agricultural water usage, used primarily for the irrigation of groves and cropland, accounts for the remaining 15 to 20 percent of the water demand. In 1989, the SDCWA initiated the preparation of a Capital Improvement Program (CIP) in order to plan and implement projects necessary to meet the region’s water deman ds to the year 2010.

Reclaimed Water

Reclaimed water is an important and growing compone nt of the Region’s water supply. Reclaimed water is obtained through extensive treat ment of municipal wastewater to produce a safe and reliable water supply for non-po table uses. Reclaimed water is used to irrigate parks, agriculture, planned community g reenbelt areas, golf courses, and freeway landscaping. Reclaimed water is an importa nt water supply and leaves the Region less vulnerable to imported water supply sho rtages.

Water Quality

In recognition of the regional differences in water quality and quantity, the state is divided into nine regions for the purposes of regio nal administration of California’s water quality control program. The San Diego Region is d ivided into 11 major hydrologic units, 54 hydrologic areas, and 147 hydrologic suba reas. The boundaries were initially designated by the State Department of Water Resourc es (DWR) and described in the

report Names and Areal Code Numbers of Hydrologic areas in the Southern District which was published in April 1964. The hydrologic units, areas, and subareas were subsequently enumerated by the State Board in the e arly 1970’s. In accordance with theEnvironmental Effects Found Not To Be Significant

6-12 early DWR definitions, hydrologic units are the ent ire watershed of one or more streams; hydrologic areas are major tributaries and/or major groundwater basins within the hydrologic unit; and hydrologic subareas are major subdivisions of hydrologic areas including both water-bearing and non-water-bearing formations.

The water resources in the San Diego Region are cla ssified as coastal waters, surface waters, and reclaimed water. Fresh water supplied with the Region is obtained from local surface and ground water development projects and i mported surface water programs.

Coastal Waters

Coastal waters in the Region include bays, harbors, estuaries, beaches, and open ocean. Deep draft commercial harbors include San Diego Bay and Oceanside Harbor. Shallower small craft harbors include Mission Bay and Dana Po int Harbor. Important estuaries are represented by coastal lagoons such as Tijuana Estu ary, Sweetwater Marsh, San Diego River flood control channel, Kendall-Frost wildlife reserve, San Dieguito River Estuary, San Elijo Lagoon, Batiquitos Lagoon, Agua Hedionda Lagoon, Buena Vista Lagoon, San Luis Rey River Estuary, and Santa Margarita River E stuary.

Surface Waters

The San Diego Region has thirteen principal stream systems originating in the western highlands which flow to the Pacific Ocean. From no rth to south, these stream systems are Aliso Creek, Santa Margarita River, San Luis Re y River, San Marcos Creek, Escondido Creek, San Dieguito River, San Diego Rive r, Sweetwater River, Otay River, and the Tijuana River. Most of the streams of the San Diego Region are interrupted in character having both perennial and ephemeral compo nents due to the rainfall pattern and the development of surface water impoundments. Sur face water impoundments capture flow from nearly all the Region’s major surface wat er streams. Many of the major surface water impoundments are a blend of natural r unoff and imported water.

Groundwater

All major drainage basins in the San Diego Region c ontain ground water basins. The basins are relatively small in area and usually sha llow. Although these ground water basins are limited in size, the ground water yield from the basins has been historically important to the development of the Region. A numb er of the larger ground water basins can be of future significance in the Region for sto rage of both imported waters and reclaimed wastewaters. Nearly all of the local gro und waters of the Region have been intensively developed for municipal and agricultura l supply purposes.

Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse impacts to water resources. Water impacts will be considered significant if the y cause changes in the course of water movements or of drainage or surface runoff patterns that would result in erosion or flooding; exceed the capacity of existing or planne d stormwater drainage systems or provide substantial additional sources of polluted runoff; substantially degrade water quality; deplete groundwater supplies, or interfere with groundwater recharge efforts;Environmental Effects Found Not To Be Significant

6-13 violate any water quality standards or waste discha rge requirements, or exceed wastewater treatment requirements of the California Regional Water Quality Control Board, San Diego Region; require the construction o f new, or expansion of existing, water, wastewater, or stormwater drainage facilitie s, the construction of which could cause significant environmental effects; require ne w or expanded water entitlements and resources; or exceed a wastewater treatment provide r’s existing commitments.

Potential water demand impacts include increased wa ter demand from the manufacturing and use of compliant water-borne coatings. Potenti al water quality impacts include the impact of solvents and architectural coatings.

Analysis of Project Effects and Determination as to Significance

Water Demand

A projected increase in water demand as a result of the proposed project could occur based on the manufacturing, use, and cleanup of wat er-borne coatings. Based on ARB’s worst-case scenario, water demand for the South Coa st region could increase by 56,684 gallons per day in 2010. This translates to an inc rease of 0.00110% for the South Coast region, which represents a negligible impact on wat er demand, even under the worst-case scenario. San Diego County's portion of this incre ase would be even less. Although the San Diego County region is expected to experience a shortage of water during drought years in 2020, this shortage would occur with or wi thout the proposed project.

No additional stormwater drainage facilities are re quired as a result of the proposed project. In addition, the increases in the wastewa ter flow to the regional wastewater treatment plant that are expected to occur as a res ult of the proposed project are negligible. No additional capacity in the wastewat er treatment plant is necessary. Further, the increase in water demand resulting fro m the proposed project is expected to be negligible and no additional water entitlements or resources are warranted. Therefore, potential impacts of the proposed project on water demand would not be significant.

Water Quality

Potential impacts that might occur as a result of i mplementing the proposed rule include increased improper disposal of waste. A significan t impact could result if there were difficulties associated with waste disposal; howeve r, it is relatively easy for sources to safely dispose of waste generated from architectura l coatings. As described in ARB's EIR for the Suggested Control Measure, based on the South Coast Air Quality Management District's unannounced site visits condu cted for its 1996 Rule 1113 amendments, the majority of contractors either disp ose of the waste material properly or recycle the waste material.

As a result of implementing the San Diego’s Stormwa ter Quality Improvement Plan, combined with efforts by the National Paint and Coa tings Association, the amount of improper disposal of waste products associated with this rule are expected to decline. In addition, the trend in the paint and coatings indus try is to replace more toxic solvents with less toxic and water-based solvents, resulting in less impact on the environment forEnvironmental Effects Found Not To Be Significant

6-14 any waste materials that are improperly disposed. ARB’s staff report concludes that manufacturers will be able to formulate coatings th at will meet the proposed VOC limits without increasing the amount of toxic air contamin ants (TACs). However, as a safety measure, the proposed rule institutes new annual re porting requirements for coatings containing perchloroethylene and/or methylene chlor ide.

Results of the proposed annual reporting for these TACs will be used to evaluate the need for further toxic regulation. Another potential co ncern is the impact of the waste materials associated with manufacture, use, and cle anup that are properly disposed and that flows to the wastewater treatment system. As Table IV-9 of ARB's PEIR indicates, the projected impact to the San Diego County’s Regi onal Wastewater Treatment Plant, under a worst-case scenario, is expected to be an i ncrease of 0.0016% in wastewater flow

in 2010.

Significant groundwater and surface water quality i mpacts are not expected as a result of implementing the amendments to Rule 67.0 in San Die go County. Both the volume and toxicity of improperly disposed of waste products i s expected to decline as a result of ongoing efforts by the paint and coatings industry and implementation of the San Diego County Stormwater Quality Improvement Plan.

Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse impacts to

water resources. Based on the information containe d in this EIR and the ARB PEIR and associated technical studies, it has been determine d that no significance thresholds would be exceeded. Specifically, proposed Rule 67.0 amen dments would not cause changes in the course of water movements or of drainage or sur face runoff patterns that would result in erosion or flooding; exceed the capacity of exis ting or planned stormwater drainage systems or provide substantial additional sources o f polluted runoff; substantially degrade water quality; deplete groundwater supplies or inte rfere with groundwater recharge efforts; violate any water quality standards or was te discharge requirements or exceed wastewater treatment requirements of the California Regional Water Quality Control Board, San Diego Region; require the construction o f new, or expansion of existing, water, wastewater, or stormwater drainage facilitie s, the construction of which could cause significant environmental effects; require ne w or expanded water entitlements and resources; or exceed a wastewater treatment provide r’s existing commitments.



### 6.1.3 - Public Services

Existing Conditions

Residents of San Diego County are provided with a n umber of essential public services. These services include fire protection, police prot ection, schools, water, and library services. The services are provided by either spec ial districts, the cities within San Diego County, or, in the unincorporated areas, the County itself.Environmental Effects Found Not To Be Significant

6-15 Public facilities in San Diego County that use arch itectural coatings for maintenance include schools, libraries, and various government buildings. In addition, many parks and public areas exist in the County as well.

Fire protection is provided to residents of the Cou nty by 21 individual entities. Seventeen of these provide protection to the public at large within their jurisdictions. The remaining four do not provide protection to the general publi c, but instead have more narrowly defined jurisdictions such as prisons, military bas es, or open space in certain areas.

Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse impacts to public services. Public services impacts will be considered significant if they will result in adverse physical impacts associated with the provision of new or alt ered public facilities in order to maintain acceptable service ratios or response time s for fire protection, police protection, schools, parks, or other public facilities. Potent ial impacts include impacts on public facilities and fire protection services – including impacts associated with the use of potentially flammable solvents.

Analysis of Project Effects and Determination as to Significance

Additional Maintenance of Public Facilities

A potential significant impact could occur if local agencies were forced to use inferior coatings which would lead to increased maintenance under the proposed rule. Industry has commented that the proposed VOC limits for coat ings may cause local agencies to use coatings that are of an inferior quality or lac k the durability of coatings that are currently used but would be exempt under the propos ed amended rule. This could lead to an overall greater use of architectural coatings.

Data collected by ARB shows that there are many coa tings available in all coatings categories that will meet the VOC limits proposed, and that these coatings will perform at a level equal to that of coatings with higher VOC l imits. In fact, these tests conclude that low-VOC coatings compare well with other coatings i n all areas of performance. Furthermore, the product information sheets for low -VOC coatings list performance characteristics for these coatings that are similar to those of higher-VOC coatings. ARB also found that a fairly large percentage of the co atings marketed meet the proposed VOC

limits.

Results of the NTS study showed that low-VOC coatin gs had durability qualities comparable to that of higher VOC products currently used. The tests also showed that water-borne coatings on the market had similar dryi ng times to conventional coatings. Manufacturers that sell their products nation-wide market the low-VOC coatings tested in these studies, so low-VOC coatings would be availab le in San Diego County.

Since low-VOC coatings perform well and would be re adily available in San Diego County, there should be no increase in the amount o f work needed to maintain publicEnvironmental Effects Found Not To Be Significant

6-16 facilities. Also, the similarity in drying times m eans that facilities will not need to be painted or repainted predominantly during the warme r summer months. In keeping with the results of the independent tests, no adverse im pacts due to increased maintenance of public facilities would result from lowering the VO C limits as proposed, and the significance criteria for public services would not be exceeded.

Fire Protection

In its PEIR, ARB demonstrated that the National Fir e Protection Association gives a flammability classification to acetone that is iden tical to other solvents currently used in the formulation of architectural coatings according to the Uniform Fire Code. This standard is used nationwide and, therefore, is appl icable in San Diego County. There is no reason to believe that there are any differences between San Diego County and the rest of the state that would increase the danger of acet one as a fire hazard. Directions for use and hazard warnings appear on coating cans in San D iego County just as they would throughout the state, so there is no increased risk of misuse that could contribute to an increased fire risk. Since ARB’s analysis is appli cable to San Diego County in all respects, there is no significant impact from fire hazard associated with the proposed

VOC limits.

According to the National Fire Protection Associati on, acetone is considered to have the same flammability classification as the solvents it would replace when formulating lowVOC coatings. Since there would be no increased ri sk of fire hazard due to increased use of acetone, there will be no significant impact to fire protection services in San Diego County, and no significance threshold will be excee ded.

Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse impacts to public services. Based on the information containe d in this EIR and the ARB PEIR and associated technical studies, it has been determine d that no significant thresholds would be exceeded. Specifically, proposed Rule 67.0 amen dments would not result in adverse physical impacts associated with the provision of n ew or altered public facilities in order to maintain acceptable service ratios or response t imes for fire protection, police protection, schools, parks, or other public facilit ies.



### 6.1.4 - Transportation/Circulation

Existing Conditions

San Diego County has a well-established and compreh ensive transportation system to serve the diverse travel needs of the County. It i ncludes federal and state highways, county roads, urban arterials, rural highways and s treets, light rail and bus transit services, freight rail, port facilities and airport s.Environmental Effects Found Not To Be Significant

6-17 Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse impacts to transportation/circulation. Transportation/circula tion impacts will be considered significant if they cause a substantial increase in traffic related to the existing traffic load and street capacity; exceed a level of service stan dard for designated roads or highways; substantially increase hazards due to a design feat ure or incompatible uses; result in inadequate emergency access, parking capacity, or h azards or barriers for pedestrians or bicyclists; or conflict with adopted alternative tr ansportation policies, plans, or programs.

Potential transportation and circulation impacts in clude additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freezethaw capabilities.

Analysis of Project Effects and Determination as to Significance

Concern was expressed by industry that the cost ana lysis by ARB was over-simplified

and did not take into account the additional distri bution costs associated with the new rule requirements. APCD staff considered and adopts by reference ARB’s analyses and responses on this issue. Based on available data, there is no reason to believe distribution costs would increase in a significant way.

One area analyzed for potential transportation/circ ulation impacts was increased trips to landfills due to disposal of additional waste mater ials. This waste, it was proposed, would come from coatings and containers due to prob lematic performance characteristics, including shelf life, pot life, an d freeze-thaw of certain low-VOC coatings. Comments were also received by ARB indic ating that out-of-state manufacturers would have to ship coatings during th e three non-winter seasons to avoid potential freezing en route. It was proposed that this would cause an increase in traffic during high ozone periods.

Data regarding freeze-thaw characteristics shows th at manufacturers have indicated that addition of surfactants will improve freeze-thaw ca pabilities of water-borne coatings. The NTS study also showed that the compliant water- borne waterproofing wood sealers included in the study passed freeze-thaw stability tests. Based on this information, it is determined that there would be no significant incre ase in landfill trips. Thus, trips generated would be minimal.

Another comment received by ARB stated that drying times would be longer for the lowVOC coatings. As a result, more trips would be req uired due to the additional days required to complete a project. Thus, additional c ommute trips would be generated. However, the NTS evaluation of coating products ind icates that low-VOC coatings in all categories except lacquers have comparable drying t imes to conventional coatings. Thus, additional commute trips would not be required for the workers applying the low-VOC coatings.Environmental Effects Found Not To Be Significant

6-18 Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse impacts to transportation/circulation. Based on the informati on contained in this EIR and the ARB PEIR and associated technical studies, it has been determined that no significance thresholds would be exceeded. Specifically, propos ed Rule 67.0 amendments would not:

cause a substantial increase in traffic related to the existing traffic load and street capacity; exceed a level of service standard for de signated roads or highways; substantially increase hazards due to a design feat ure or incompatible uses; result in inadequate emergency access, parking capacity, or h azards or barriers for pedestrians or bicyclists; or conflict with adopted alternative tr ansportation policies, plans, or programs.



### 6.1.5 - Solid and Hazardous Waste

Existing Conditions

San Diego County currently has several active solid waste disposal facilities. Coatings that have dried are disposed of as municipal solid waste. Coatings which have not dried (i.e. disposed in liquid form) are treated has hazardous waste and must be transported out of San Diego County to a Class I Landfill. However , the requirement of the California Integrated Waste Management Act of 1989, to reduce the waste stream to landfills by 50% in the year 2000, is expected to reduce the amo unt of hazardous waste disposed in

landfills.

Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse solid and hazardous waste impacts. Solid waste/hazardous waste impacts will be considered significant if the proposal would not be served by a landfill with suf ficient permitted capacity to accommodate the project’s solid and/or hazardous wa ste disposal needs, or would not comply with federal, state, and local statutes and regulations related to solid and

hazardous wastes. Potential solid and hazardous wa ste impacts include impacts on the disposal capacity arising from increased disposal o f compliant coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities.

Analysis of Project Effects and Determination as to Significance

The potential environmental impacts for the propose d rule amendments deal mainly with the increased generation of solid waste/hazardous w aste and its disposal. APCD staff considered and adopts by reference ARB’s analysis a nd responses on this issue. Comments received by ARB for the PEIR regarding thi s matter alleged the following:

• Compliant lower-VOC coatings targeted by the SCM wi ll not have the same freeze-thaw capabilities as existing coatings and, therefore, may “go bad” duringEnvironmental Effects Found Not To Be Significant

6-19 transport from mild climates to extreme climates, r esulting in that load being

discarded into a landfill.

• Compliant lower-VOC coatings targeted by the SCM wi ll have shorter shelf lives, and, therefore, a percentage of the manufacturers’ inventory will have to be landfilled because the coatings have “gone bad” in the can over time.

• As a result of the lower-VOC content limits for ind ustrial maintenance and floor coatings, manufacturers will formulate more two-com ponent systems that may have, on average, a shorter pot life compared to co nventional coatings. As a result, low-VOC coatings could solidify in the can during the application process, resulting in an unusable portion of coating that wo uld need to be discarded into a

landfill.

• Because the SCM would require the use of water-born e technologies, more surface preparation in the form of sandblasting wil l be required. This in turn will increase the amount of wastes deposited in landfill s.

ARB's analysis demonstrated that even if some compl iant coatings are landfilled due to freeze-thaw, shelf life, or pot life problems, the total amount of solid waste and hazardous waste materials deposited in landfills would not cr eate a significant solid waste or hazardous waste impact. For San Diego County, anti cipated solid waste impacts associated with implementing the SCM are 0.007% (AR B PEIR) of the total permitted throughput. Since the entire permitted solid waste throughput per day for San Diego County is 12,665 tons, this 0.007% increase represe nts a countywide increase of 0.9 tons per day of solid waste. The average capacity of a refuse truck in San Diego County is

10 tons. A 0.9-ton increase would use less than 10 % of the capacity of one average refuse truck in the county. This increase would no t pose a significant impact for waste disposal.

Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse solid and hazardous waste impacts. Based on the information contained in this EIR and the ARB PEIR and associated technical studies, it has been determined that no significance thresholds would be exceeded. Specifically, the pr oject would be served by a landfill with sufficient permitted capacity to accommodate t he project’s solid and/or hazardous waste disposal needs, and would comply with federal , state, and local statutes and regulations related to solid and hazardous wastes.



### 6.1.6 - Hazardous Substances

Existing Conditions

The proposed rule amendments will require the refor mulation of non-compliant coatings

in order to achieve reduced VOC standards. In orde r to achieve the reduced standards, coatings manufacturers may need to utilize exempt s olvents in their coatings formulae. To the extent that future compliant coatings would be formulated with exempt solvents orEnvironmental Effects Found Not To Be Significant

6-20 other potentially hazardous materials, and to the e xtent that these materials could be accidentally released into the environment, the pot ential that implementing the VOC limits in the proposed rule amendments could create significant adverse hazardous substances impacts in San Diego County has been eva luated

Thresholds of Significance

Criteria were developed based on Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential for significant, adv erse hazardous substances impacts. Hazardous substance impacts will be considered sign ificant if they create a significant hazard to the public or the environment through the transport, use, disposal, or other handling of hazardous materials, or through reasona bly foreseeable upset and accident conditions involving the release of hazardous mater ials; result in the handling of

hazardous materials or wastes within 1/4 mile of an existing or proposed school; are

located on a site included on a list of hazardous m aterials sites compiled pursuant to Government Code section 65962.5; impair implementat ion of an adopted emergency response or evacuation plan; or increase fire hazar d in areas with flammable materials.

Potential hazardous substance impacts include the r isk of an upset or accidental release of hazardous substances, and human health impacts. Hu man health impacts include potential increased long-term (carcinogenic and chr onic) and short-term (acute) human health impacts associated with the use of various r eplacement solvents in compliant coatings formulations.

Analysis of Project Effects and Determination as to Significance

As a result of being delisted as a VOC by the U.S. EPA, ARB, and the San Diego APCD, acetone usage as a solvent has been increasing. Al though acetone is expected to be used to reformulate some compliant coatings, ARB indicat es that it is unlikely that implementation of the proposed rule amendments will substantially increase the future use of acetone. APCD staff considered and adopts by reference ARB’s analysis and responses on this issue.

Increases in acetone usage may increase the number of trucks or rail cars that transport acetone in San Diego County; however, individual tr ucks and rail cars are equipped to safely handle these coatings and would not be affec ted by the proposed rule amendments. The consequences (exposure) of an accidental releas e of acetone are directly proportional to the size of the individual transport trucks or r ail cars and the release rate. While the probability of an accidental release of acetone in San Diego County could increase as a result of increased acetone transport, the severity of any one incident involving acetone transport would not change as a result of implement ing the proposed rule amendments.

Similarly, the severity of an accident involving th e storage of acetone is not expected to change from existing conditions. With regard to ot her possible replacement solvents, ARB indicated that the trend in coatings technology is to replace Ethylene Glycol Monobutyl Ether (EGBE) solvents with less toxic/les s hazardous coalescing solvents such as Texanol and propylene glycol. Additionally , ARB indicated that a majority ofEnvironmental Effects Found Not To Be Significant

6-21 water-based formulations (flats and nonflats) do no t contain solvents that are hazardous air pollutants (HAPs). APCD staff looked at this i ssue to see if there were any local issues that might alter APCD’s conclusion and it wa s determined that ARB's analysis is equally applicable to San Diego.

According to ARB, some reformulated two-component i ndustrial maintenance coating systems may contain diisocyanate compounds. While the use of diisocyanate compounds does not reflect the trend of using less hazardous compounds, there should be no significant increase in the risk of upset in San Di ego County due to the increased use of these compounds. Like Texanol, Oxsol 100, propylen e glycol, and ethylene glycol, diisocyanates are significantly less flammable than currently used, highly flammable conventional solvents. Therefore, any potential ha zards created by the increased use of compliant coatings containing diisocyanates would b e offset by the decreased use of

more flammable solvents.

The ARB analysis determined that manufacturers woul d be able to reformulate coatings in order to comply with the proposed VOC limits wit hout increasing the use of toxic air contaminants. As a precautionary measure, however, the proposed Rule 67.0 amendments also require manufacturers to report usa ge for the following categories: Clear Brushing Lacquers, Rust Preventative Coatings , Specialty Primers, Sealers, and Undercoaters, Recycled Coatings, Bituminous Roof Co atings, Bituminous Roof Primers, and all coatings containing perchloroethylene and m ethylene chloride. This reporting will allow tracking of usage of products with highe r VOC limits and tracking usage of toxic compound. Adoption of the rule amendments is not expected to cause any significant adverse impacts concerning hazardous su bstances.

Determination of Significance

As discussed above, criteria were developed based o n Appendix G of the Guidelines for Implementation of CEQA to evaluate the potential fo r significant, adverse hazardous substances impacts. Based on the information conta ined in this EIR and the ARB PEIR and associated technical studies, it has been deter mined that no significance thresholds would be exceeded. Specifically, amended Rule 67.0 implementation would not create a significant hazard to the public or the environment through the transport, use, disposal, or other handling of hazardous materials, or through r easonably foreseeable upset and accident conditions involving the release of hazard ous materials; result in the handling of

hazardous materials or wastes within 1/4 mile of an existing or proposed school; are

located on a site included on a list of hazardous m aterials sites compiled pursuant to Government Code section 65962.5; impair implementat ion of an adopted emergency response or evacuation plan; or increase fire hazar d in areas with flammable materials.

6.2 - Effects found not to be Significant During In itial Study

During the preparation of the Initial Study for the proposed project, it was determined that the proposed project would have no significant impact on the following resource

areas:

• Aesthetics;Environmental Effects Found Not To Be Significant

6-22 • Agriculture Resources;

• Biological Resources;

• Cultural Resources;

• Geology /Soils;

• Land Use / Planning;

• Mineral Resources;

• Noise;

• Population / Housing; and

• Recreation.

A copy of the Initial Study/Environmental Analysis Checklist Form prepared for the proposed project, including brief discussions relat ing to these resource areas, is included as Appendix B of this EIR.List of References

7-1 CHAPTER 7.0 - LIST OF REFERENCES

Air Resources Board (ARB). “Final Program Environm ental Impact Report: Suggested Control Measure for Architectural Coatings.” June 2000. (ARB, 2000).

______. “Documentation for ARB’s June 2000 Architec tural Coatings Suggested Control

Measure.” June 2000.

______. “1998 Air Pollution Research, 1989-Present .” (ARB, 1998a).

______. “1998 Architectural Coatings Survey Result s Final Report.” September 1999. (ARB, 1999c)

County of San Diego, Department of Planning and Lan d Use, Environmental Impact Report Format and Content Guidelines, February 1997

.

______. Code Zoning and Land Use Regulation Divisi on. Zoning Ordinance.

San Diego County Water Authority (SDCWA). “Urban W ater Management Plan.” December 2000. (SDCWA, 2000)

Sacramento Metropolitan Air Quality Management Dist rict (SMAQMD). “Final Environmental Impact Report: Proposed Amendments: Rule 442 Architectural Coatings.” May 2001. (SMAQMD, 2001)

State of California, California Code of Regulations , Title 14, Chapter 3, “Guidelines for California Environmental Quality Act, as Amended De cember 1, 2000.

______. California Environmental Quality Act, Publ ic Resources Code, Division 13, Environmental Quality. South Coast Air Quality Management District (SCAQMD ). “Staff Report for: Proposed Amendments to Rule 1113 – Architectural C oatings.” May 14, 1999.List of EIR Preparers and Persons and Organizations Contacted

8-1 CHAPTER 8.0 - LIST OF EIR PREPARERS AND PERSONS AND
ORGANIZATIONS CONTACTED

EIR Preparers

This EIR was prepared under the direction of the Sa n Diego County APCD located at 9150 Chesapeake Drive, San Diego California 92123-1 096. The following professional staff was directly involved in the preparation of t his EIR.

San Diego County APCD

Robert Reider, Supervising Air Resources Specialist Project Supervision/Coordination, Principal Public Contact

Robert Mross, Associate Air Resources Specialist Document Research; Quality Assurance/Quality Contr ol

Laura Yannayon, Senior Air Pollution Control Engine er Project/Rule Development

Adeline Suson, Associate Air Pollution Control Engi neer Project/Rule Development

County of San Diego Department of Planning and Land Use

Joseph DeStefano II, Environmental Management Speci alist III Environmental Coordinator; Principal Document Prep arer

Kristin Eberwein, Environmental Management Trainee Document Preparation, Environmental Analyst

San Diego County Office of County Counsel

Terence Dutton, Sr. Deputy County Counsel Legal Conformance Review

Persons and Organizations Contacted

Additionally, the following State and Regional Agen cies were consulted.

California Air Resources Board

Robert Jenne, Sr. Staff Counsel Jim Nyarady, Manager, Strategy Evaluation Section Cheryl Young, Stationary Sources Division
Sacramento Metropolitan Air Quality Management Dist rict

Greg Tholen, Program Coordination DivisionList of Mitigation Measures and Environmental Desig n Considerations

9-1 CHAPTER 9.0 - LIST OF MITIGATION MEASURES AND ENVIR ONMENTAL
DESIGN CONSIDERATIONS

The proposed project would not result in any signif icant impacts that require the implementation of mitigation measures. As such, no mitigation measures have been identified for the proposed project. Further, no e nvironmental design considerations are required for the implementation of the proposed pro ject.Appendix A



### Appendix A: Proposed Amendments to Rule 67.0Appendix A

-1-

- PROPOSED AMENDMENTS TO RULE 67.0

Amendments are to read as follows:

RULE 67.0. ARCHITECTURAL COATINGS

(a) APPLICABILITY

(1) Except as provided in Section (b), t T his rule is applicable to any person who

manufactures , supplies, sells, offers for sale, applies, or sol icits the application of, any architectural coating for use within San Diego Coun ty

.

(2) Rule 66 shall not apply to any coating subject to this rule.

(b) EXEMPTIONS

The provisions of Section (d) of this rule shall n ot apply to the following coatings:

(1) This rule shall not apply to:

(i) Any architectural coating that is sold or manufact ured for use outside of San Diego County or for shipment to other manufactu rers for reformulation or repackaging.

(ii) Any non-refillable aerosol coating product.

(iii) Any architectural coating that is sold in a contai ner with a volume of one liter (1.057 quart) or less.

(1) Architectural coatings supplied in containers havi ng capacities of one liter or less;

(2) Architectural coatings sold in non

- refillable aerosol container s having capacities of one liter or less:

(iv 3 ) Emulsion-type bituminous pavement sealers.

(2) The provisions of Subsection (d)(1) shall not appl y to lacquers applied on days with relative humidity greater than 70 percent and temperatures below 65°F. On such days, up to 10 percent by volume of VOC may be adde d, at the time of application, provided that the lacquer contains acetone and no m ore than 550 grams of VOC per liter of lacquer, less water and exempt compounds, prior to the addition of VOC.Appendix A

-2-

- (c) DEFINITIONS

(1) “Adhesive” means any chemical substance that is applied for t he purpose of bonding two surfaces together other than by mechani cal means.

(2) “Aerosol Coating Product” means a pressurized coating product containing pigments or resins that dispenses product ingredien ts by means of a propellant, and is packaged in a disposable can either for hand-held a pplication or use in specialized equipment for ground traffic/marking applications.

(3) “Antenna Coating” means a coating labeled and formulated exclusively for application to equipment and associated structural appurtenances that are used to receive or transmit electromagnetic signals.

(4) “ Antifouling Coating ” means a coating labeled and formulated for applic ation to submerged stationary structures and their appurt enances to prevent or reduce the attachment of marine or freshwater biological organ isms. To qualify as an antifouling coating, the coating must be registered with both t he U.S. Environmental Protection Agency (EPA) under the Federal, Insecticide, Fungic ide, and Rodenticide Act (7 U.S.C. Section 136, et seq.) and with the California Depar tment of Pesticide Regulation.

(5) “ Appurtenance ” means any accessory to a stationary structure coa ted at the site of installation, whether installed or detached , including but not limited to: bathroom and kitchen fixtures; cabinets; concrete forms; doo rs; 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 fir e escapes; and window screens.

(1) "Appurtenance" means an accessory to an architectural structure i ncluding but

not limite d to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters and down spouts, window screens, lamp posts, heatin g and air conditioning equipment, large fixed stationary tools, and concrete forms.

(6 2 ) “ Architectural Coating ” means any coating to be applied to stationary

structures and/or

their appurtenances at the site of installation (s tationary source), to portable buildings including mobile homes, at the s ite of installation, coated onsite or in close proximity to the intended ins talled location, to mobile homes, to pavement, or to
curbs. Adhesives are not considered architectural coatings for the purposes of this rule.

(3) "Below

- Ground Wood Preservative" means a coating formulated to protect

below

- ground wood from decay or i nsect attack and which contains a wood preservative chemical registered by the California Department of Food and Agriculture.

(7) “ Bitumens ” means black or brown materials including, but not limited to, asphalt, tar, pitch, and asphaltite that are solubl e in carbon disulfide, consisting mainly of hydrocarbons, and obtained from natural deposits or as residues from the distillation of crude petroleum or coal.Appendix A

-3-

- (4) “Bituminous Coating” means a black or brownish coating material, solubl e in

carbon disulfi de, consisting mainly of hydrocarbons and which is obtained from natural deposits or as residue from the distillation of cru de petroleum oils or of low grades of coal.

(8) “ Bituminous Roof Coating ” means a coating which incorporates bitumens that is labeled and formulated exclusively for roofing.

(9) “ Bituminous Roof Primer ” means a primer which incorporates bitumens that is labeled and formulated exclusively for roofing.

(10 5 ) “Bond Breaker” means a coating labeled and formulated for applica tion applied between layers of concrete to prevent a the freshly poured top layer of concrete from bonding to the layer over which it is poured.

(11) “ Clear Brushing Lacquers ” mean clear wood finishes, excluding clear lacquer sanding sealers, formulated with nitrocellulose or synthetic resins to dry by solvent evaporation without chemical reaction and to provid e a solid, protective film, which are intended exclusively for application by brush, and which are labeled as specified in Subsection (e)(1)(v).

(12) “ Clear Wood Coatings ” mean clear and semi-transparent coatings, includi ng lacquers and varnishes, applied to wood substrates to provide a transparent or translucent

solid film.

(13) “ Coating ” means a material applied onto or impregnated into a substrate for protective, decorative, or functional purposes. Su ch materials include, but are not limited to paints, varnishes, sealers, and stains.

(14) “ Colorant ” means a concentrated pigment dispersion in water, solvent and/or binder that is added to an architectural coating af ter packaging to produce the desired color.

(15 6 ) “ Concrete Curing Compound ” means a coating labeled and formulated for application applied to freshly poured concrete to retard the evaporation of water.

(16 7 ) “ Dry Fog Coating (M ill White Coating) ” means a coating labeled and formulated only for spray application such that ove rspray droplets dry before subsequent

contact with incidental other surfaces in the vicinity of the surface coating ac tivity

.

(17 8 ) “Exempt Compound Solve nt ” means the same as defined in Rule 2.

(18) “Faux Finishing Coating” means 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.Appendix A

-4-

- (19) “ Fire-Resistive Coating ” means an opaque coating labeled and formulated to protect structural integrity by increasing the fire endurance of interior or exterior steel and other structural materials, and that has been regis tered with the State Fire Marshall.

(20 9 ) “Fire-Retardant Coating” means a coating labeled and formulated to retard ignition and which has a

flame spread, and that has been registered with the State Fire

Marshall. index of less than 25 when tested in accordance with the current v ersion of ASTM Designation E 84

- 87, “Standard Test method for Surface Burning Chara cteristics of Building Material,” after application to Douglas fi r according to the manufacturer’s

recommendation.

(21) “ Flat Coating ” means a coating that is not defined under any oth er definition in this rule and that registers a gloss of less than 1 5 on an 85° meter, or less than 5 on a 60°

meter.

(22) “ Floor Coating ” means an opaque coating that is labeled and formu lated for application to flooring, including, but not limited to, decks, porches, steps, and other horizontal surfaces which may be subject to foot tr affic.

(23) “ Flow Coating (Electrical Transformers)” means a coating labeled and formulated exclusively for use by electric power co mpanies or their subcontractors to maintain the protective coating systems present on utility transformer units.

(24 10 ) “Form-Release Compound” means a coating labeled and formulated for application applied to a concrete form to prevent the freshly poured c oncrete from bonding to the form. The form may consist of wood, metal o r some material other than concrete.

(25 11 ) “ Graphic Arts Coating or ( Sign Paint Coating) ” means a coating which is

labeled and formulated for and hand application -applied by artists using brush or roller techniques to indoor and outdoor signs (excluding s tructural components) and murals, excluding structural components, including lettering enamels, poster colors, copy b lockers,

and bulletin enamels.

(26 12 ) “ High-Temperature Industrial Maintenance Coating ” means a high performance an industrial maintenance coating which is labeled and formulated for application and applied to substrates exposed continuously or intermittent ly to temperatures above 400°F (204°C). degrees Fahrenheit.

(13 ) “ Industri al Maintenance Anti

- graffiti Coating ” means a two

- component clear industrial maintenance coating which is formu lated for and applied to exterior walls and murals to resist repeated scrubbing and exposur e to harsh solvents.

(27 14 ) “ Industrial Maintenance Coating ” means a high performance architectural coating which is formulated for and applied , including primers, sealers, undercoaters, intermediate coats, and topcoats, formulated for ap plication to substrates exposed to one or more of the following extreme environmental conditi ons and labeled as specified in Subsection (e)(1)(iv) :Appendix A

-5-

- (i) (ii) Immersion in water, wastewater or chemical solutio ns (aqueous and nonaqueous solutions), or chronic exposure of interior surfaces to moisture condensation;

(ii) (ii i) Acute or chronic exposure to corrosive, caustic, o r acidic agents, or to chemicals, chemical fumes, or chemical mixtures or solutions;

(iii) (iv) Repeated exposure to temperatures above in excess of 250°F (121°C) ; or

(iv) (i) Repeated (frequent) heavy abrasion, including mech anical wear and repeated (frequent) scrubbing with industrial solvent s, cleansers, or scouring agents; or

(v) Exterior exposure of metal structures and stru ctural components

.

(28 15 ) “Lacquer ” means a clear or opaque wood pigme nted coating, including clear lacquer sanding sealers, formulated with cellulosic nitrocellulose or synthetic resins to dry by evaporation without chemical reaction and to pro vide a solid, protective film

.

(29) “ Low-Solids Coating ” means a coating that contains 1 pound or less of solids per gallon (120 grams or less of solids per liter) of coating material.

(30 16 ) “Magnesite Cement Coating” means a coating labeled and formulated for application and applied

to magnesite cement decking to protect the magnesi te cement substrate from erosion by water.

(31) “Manufacturer’s Maximum Thinning Recommendation” means the maximum recommended thinning ratio that is indicate d on the label or lid of the coating

container or in the technical data sheet for the co ating.

(32 17 ) “Mastic Texture Coating” means a coating labeled and which is formulated to

cover holes and minor cracks and to conceal surface irregularities, and is applied in a single coat

thickness of at least 0.010 inch ( 10 mils) dry film thickness (d ry, single coat)

.

(33 18 ) “Metallic-Pigmented Coating” means a coating containing at least 0.4 pounds of elemental metallic pigment metal particles per gallon (48 grams of elemental metallic pigment per liter) of coating as applied.

(34 19 ) “Multi-Colored Coating” means a coating that which exhibits more than one color when applied and which is packaged in a single container, and exhibits mo re than

one color when applied in a single coat.

(35 20 ) “Nonflat Non

- Flat Architectural Coating” means a coating that is not defined under any other definition in this rule, and that which registers a gloss of 15 or greater on an 85° meter or 5 or greater on a 60° meter, and wh ich is identified on the label as a gloss,

semi

- gloss, or eggshell enamel coating

.Appendix A

-6-

- (36) “ Nonflat-High Gloss Coating ” means a nonflat coating that registers a gloss of

70 or above on a 60° meter.

(37) “ 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 infrastructur e, including highways, bridges, airports and railroads; facilities used in mining activities , including petroleum extraction; and utilities infrastructure, including power generatio n and distribution, and water treatment and distribution systems.

(21) "Opaque Stain" means any stain that is not classified as a semi

- transparent
stain.

(22) "Opaque Wood Preservative" means any wood preservative that is not

classified as a semi

- tra nsparent wood preservative or as a below

- ground wood preservative.

(38) “Post-Consumer Coating” means the unused portion of coating after completion of a consumer’s project that would have been disposed of in a landfill, having completed its usefulness to a consumer. Post-consu mer coating does not include manufacturing wastes.

(39 25 ) “Pre-Treatment Pretreatment Primer ( Wash Primer) ” means a coating primer that

which contains a minimum of 0.5 percent acid, by weight, and is labeled and formulated for application applied directly to bare metal surfaces and is necessary to provide corrosion resistance and to promote adhesio n of subsequent topcoats surface etching

.

(40 26 ) “Primer” means a coating labeled and formulated for applica tion to a substrate

whi ch is intended to be applied to a surface to provide a firm bond between the substrate and subsequent coats.

(41 24 ) “Quick-Dry Enamel” means a nonflat coating that is labeled as specified in Subsection (e)(1)(viii) and that is formulated to have the following characteristics: which can be applied directly from the container by brush or roller at ambient temperatures

between 60 o F and 80 o F and which is formulated to have a gloss of 70 or greater on a 60 o

meter and to have the following drying characteri stics when tested in accordance with the

current version of ASTM D 1640 :

(i) Capable of being applied directly from the contain er under normal conditions at ambient temperatures between 60 and 8 0°F (16 and 27°C);

(ii) When tested in accordance with ASTM Designati on D 1640-95, sets to touch in 2 hours or less, is tack free in 4 hours o r less, and dries hard in 8 hours or less by the mechanical test method; and

(iii) Has a dried film gloss of 70 or above on a 60° mete r.Appendix A

-7-

- (i) Set to touch in not more t han two hours; be tack

- free (mechanical tester)

in not more than four hours; and

(ii) Dry hard in not more than eight hours.

(42 23 ) “Quick-Dry Primer, Sealer, and Undercoater” means a primer, sealer, or undercoater that

which is dry to the touch in 30 minutes one

- half hour and can be recoated in two hours, as determined under the current versi on of ASTM D1640 and which is intended to be applied to a surface for one or more of the following reasons: to provide a

firm bond between the substrate and subs equent coats, or to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by materials in the substrate, or to provide a smooth surface for subsequent coats

.

(43) “Recycled Coating” means an architectural coating formulated such tha t not less than 50 percent of the total weight consists o f secondary and post-consumer coating, with not less than 10 percent of the total weight c onsisting of post-consumer coating.

(44 27 ) “ Roof Coating ” means a non-bituminous coating labeled and which is formulated exclusively for application to for and applied to exterior roofs for the primary purpose of preventing penetration of the substrate by water, or reflecting heat and reflecting ultraviolet radiation. Metallic

- pigmented R r oof coatings, which qualify as

M m etallic P p igmented C c oatings shall not be considered to be in this category, bu t shall be

considered to be in the M m etallic P p igmented C c oatings category.

(45) “ Rust Preventative Coating ” means a coating formulated exclusively for nonindustrial use to prevent the corrosion of metal surfaces and labeled as specified in Subsection (e)(1)(vi).

(46 28 ) “ Sanding Sealer ” means a clear or semi-transparent wood coating labeled and formulated for application and appl ied to bare wood for sanding and to seal the wood and to provide a coat that can be abraded (sanded) to c reate a smooth surface for subsequent applications of coatings varnish . To be considered a sanding sealer a coating must be clearly labeled as such. A sanding sealer that also meets the definition of a lacquer is not included in this category, but is included in the l acquer category.

(47 29 ) “Sealer” means a coating labeled and formulated for application and applied to
a substrates for either of the following purposes: to prevent subsequent coatings from being absorbed by the substrate, or to prevent harm to subsequent coatings by mater ials in the

substrate.

(48) “Secondary Coating (Rework)” means the fragment of a finished coating or the finished coating from a manufacturing process t hat has converted resources into a commodity of real economic value, but does not include excess virgin resource s of the manufacturing process.Appendix A

-8-

- (30) "Semi

- Transparent Stain" means a coating which is formulated to c hange the

color of a surface but not conceal the surface.

(31) "Semi

- Transparent Wood Preservative" means a wood preservative stain, including clear wood preservatives, which is formul ated and used to protect exposed wood from decay or insect attack by the addition of a wood preservative chemical regist ered by the California Department of Food and Agriculture, and which changes the color of a

surface but does not conceal the surface.

(49 32 ) “Shellac” means a clear or opaque pigmented coating formulated solely with the resinous secretions of the lac beetle ( L l accifer lacca ), thinned with alcohol, and formulated to dry by evaporation without a chemical reaction.

(50 33 ) “Solicit” means to require for use or to specify, by written or oral contract.

(51) “ Specialty Primer, Sealer, and Undercoater” means a coating that is labeled as specified in Subsection (e)(1)(vii) and formulat ed for application to a substrate to seal fire, smoke or water damage; to condition excessive ly chalky surfaces, or to block stains. An excessively chalky surface is one that is define d as having a chalk rating of four or less.

(52) “ Stain ” means a clear, semitransparent, or opaque coating labeled and formulated to change the color of a surface but not conceal the grain pattern or texture.

(53 34 ) “ Swimming Pool Coating ” means a coating labeled and formulated and used to coat the interior of swimming pools and to resis t swimming pool chemicals.

(54 35 ) “ Swimming Pool Repair and Maintenance Coating ” means a rubber based

chl orinated rubber

- based coating labeled and formulated to be used over existing rubber based coatings for the repair and maintenance of swimming pools ov er existing chlorinated

rubber

- based coatings

.

(55) “Temperature-Indicator Safety Coating” means a coating labeled and formulated as a color-changing indicator coating fo r 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 400°F (204°C).

(56) “ Tint Base ” means an architectural coating to which colorant is added after packaging to produce a desired color.

(57 36 ) “ Traffic Marking Coating” means a coating labeled and which is formulated for marking and stripping and applied to public streets, highways, or other traffic surfaces including, but not limited to, curbs, berms, driveways, and parking lots, sidewalks, and airport runways

.

(58 37 ) “ Undercoater” means a coating labeled and which is formulated for and applied to substrates to provide a smooth surface for subsequent coats.Appendix A

-9-

- (59 38 ) “ Varnish” means a clear or semi-transparent wood coating finish , excluding lacquers and shellacs, formulated with various resins to dry by chemical reaction on exposure to air. Varnishes may contain small amoun ts of pigment to color a surface, or to control the final sheen or gloss of the finish.

(60 39 ) “Volatile Organic Compound (VOC)” means the same as defined in Rule 2. any compound of carbon which may be emitted to the atmosphere during the application of or subsequent drying or curing of coatings subject to this rule, except methane, carbon monoxide, carbon dioxide, carbonic acid, metallic c arbides or carbonates, ammonium carbonate, and exempt compounds. VOC content of coatings is expressed in grams of VOC per liter of coating, as applied, less water an d less exempt compounds. (Rev. Effective 5/15/96)

(61) “VOC Content Per Volume of Coating, Less Water and Exempt Compounds” means the same as defined in Rule 2.

(62) “VOC Content Per Volume of Material” means the same as defined in

Rule 2.

(40) "Waterproofing Mastic Coating" means a weatherproof or waterproof coating which is formulated to cover holes and mino r cracks and to conceal surface irregul arities and which is to be applied in thicknesses o f at least 15 mils.

(63) “Waterproofing Concrete/Masonry Sealer” means a clear or pigmented filmforming coating that is labeled and formulated for sealing concrete and masonry to provide resistance against water, alkalis, acids, ultraviol et light, and staining.

(64 41 ) “Waterproofing Sealer” means a colorless coating labeled and which is formulated for application to a and applied for the sole purpose of protecting porous substrates for the primary purpose of by preventing the penetration of water. and which does not alter surface appearance or texture.

(65) “Wood Preservative” means a coating labeled and formulated to protect exposed wood from decay or insect attack, that is r egistered with both the U.S. EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (7 United States Code Section 136,

et seq. ) and with the California Department of Pesticide R egulation.

(d) STANDARDS AND REQUIREMENTS

(1) VOC CONTENT LIMITS

Except as provided in Subsections (b)(2) , (d)(2), (d)(3), and (d)(5) (d)(4) , no a person shall not :

(i) manufacture, blend, or repackage for sale within San Diego County;Appendix A

-10-

- (ii) supply, sell, or offer for sale within San Diego County; apply, or

(iii) solicit for

the application or apply within San Diego County, of any architectural coating with a VOC content in excess of the corresponding limits specified in Table 1 after the specified effective dates. for use within San Diego County which at the time o f sale or manufacture contains more than 250 grams of VOC per liter of coating (excluding wa ter and exempt solvents and any colorant added to tint bases).Appendix A

-11-

- Table 1 - VOC Standards

Effective (Date of Adoption)

Limit 1,2 Effective

1/1/2003

Limit 1,2 Effective

1/1/2003

Limit 1,2
Coating Categories lb/gal (g/l) lb/gal (g/l) lb/gal (g/l) General Coatings: Flat Coatings 2.1 (250) 0.8 (100) Nonflat Coatings 2.1 (250) 1.3 (150) Nonflat Coatings – High Gloss 2.1 (250)

Specialty Coatings: Antenna Coatings 4.4 (530) Antifouling Coatings 3.3 (400) Bituminous Roof Coatings 2.5 (300)

Bituminous Roof Primers 2.9 (350)

Bond Breakers 2.9 (350) Clear Wood Coatings: Clear Brushing Lacquer 5.7 (680) Lacquers 5.7 (680) 4.6 (550) (including lacquer sanding sealers) Sanding Sealers 2.9 (350) (other than lacquer sanding sealers)

Varnishes 2.9 (350) Concrete Curing Compounds 2.9 (350) Dry Fog Coatings 3.3 (400) Faux Finishing Coatings 2.9 (350) Fire Resistive Coatings 2.9 (350) Fire Retardant Coatings:

Clear Opaque 5.4

2.9 (650) (350) Floor Coatings 2.1 (250) Flow Coatings 3.5 (420) Form-Release Compounds 2.1 (250) Graphic Arts Coatings (Sign Paints) 4.2 (500) High Temperature Coatings 3.5 (420) Industrial Maintenance Coatings 2.8 (340) 2.1 (250) Low-Solids Coatings 3 1.0 (120) Magnesite Cement Coatings 3.8 (450) Mastic Texture Coatings 2.5 (300) Metallic Pigmented Coatings 4.2 (500) Multi-Color Coatings 3.5 (420) 2.1 (250)

Pre-Treatment Wash Primers 3.5 (420) Primers, Sealers, and Undercoaters 2.9 (350) 1.7 (200) Quick-Dry Enamels 3.3 (400) 2.1 (250) Quick-Dry Primers, Sealers, Undercoaters 3.8 (450) 1.7 (200) Recycled Coatings 2.1 (250) Roof Coatings 2.1 (250) Rust Preventative Coatings 4 3.3 (400)

Shellacs:

Clear Opaque 6.1

4.6 (730) (550) Specialty Primers, Sealers, and Undercoaters 2.9 (350)

Stains 2.9 (350) 2.1 (250) Swimming Pool Coatings 2.8 (340)Appendix A

-12-

- Effective (Date of Adoption)

Limit 1,2 Effective

1/1/2003

Limit 1,2 Effective

1/1/2003

Limit 1,2
Coating Categories lb/gal (g/l) lb/gal (g/l) lb/gal (g/l)

Swimming Pool Repair & Maintenance Coatings 2.8 (340) Temperature-Indicator Safety Coatings 4.6 (550) Traffic Marking Coatings 1.3 (150) Waterproofing Sealers 3.3 (400) 2.1 (250) Waterproofing Concrete/Masonry Sealers 3.3 (400)

Wood Preservatives 2.9 (350)

1 Remains in effect unless revised limits are indicat ed in subsequent columns. The VOC content limits t ake into account the “Manufacturer’s Maximum Thinning Recomm endation,” if any.

2 Expressed in lb VOC per gallon (or grams VOC per li ter) of coating, as applied, less water and exempt compounds.

3 VOC content limits are expressed in lb of VOC per g allon (or grams of VOC per liter) of coating, as ap plied, including water and exempt compounds.

4 Effective January 1, 2004, this category only appli es to non-industrial uses. Industrial uses are regu lated under Industrial Maintenance Coatings on or after January 1, 2004.

.

(2) COATINGS NOT LISTED IN TABLE 1

For any coating that does not meet any of the defin itions 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, bas ed on its gloss, as defined in Subsections (c)(21), (c)(35) and (c)(36) and the corresponding flat or nonflat VOC content limit shall apply.

(3) MOST RESTRICTIVE VOC LIMITS

If anywhere on the container of any architectural c oating, or any label or sticker affixed to the container, or in any sales, advertis ing, 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 reco mmended 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 coatin g categories specified below:

(i) Antenna coatings, (ii) Bituminous roof primers, (iii) Fire-retardant coatings, (iv) Flow coatings (Electrical Transformers), (v) High-temperature coatings, (vi) Industrial maintenance coatings, (vii) Lacquers (including lacquer sanding sealers), (viii) Low-solids coatings, (ix ) Metallic pigmented coatings,Appendix A

-13-

- (x) Pre-treatment wash primers,

(xi) Shellacs, (xii) Specialty primers, sealers, and undercoaters, (xiii) Temperature-indicator safety coatings, or (xiv) Wood preservatives.

(4) SELL-THROUGH OF COATINGS

(i) A coating manufactured prior to the January 1, 200 3 or January 1, 2004 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 fo r that coating in Table 1 may be applied at any time, both before and after the spec ified effective date, so long as the coating complied with the standards in effect at th e time the coating was manufactured. This Subsection does not apply to any coati ng that does not display the date or date-code required by Subsection (e)(1)(i).

(ii) A coating included in an approved Averaging Progra m that does not comply with the specified limit in Table 1 may be s old, supplied, or offered for sale for up to three years after the end of the complian ce 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 Subse ction does not apply to any coating that does not display on the container eith er the statement: “This product is subject to architectural coating averaging provisio ns in California” or a substitute symbol specified by the Executive Officer of the CA RB. This Subsection shall remain in effect until January 1, 2008.

(5) RUST PREVENTATIVE COATINGS

Effective January 1, 2004, no person shall apply or solicit the application of any rust preventative coating for industrial use, unless suc h a rust preventative coating complies with the industrial maintenance VOC limit specified in Table 1.

(6) STATEWIDE AVERAGING COMPLIANCE OPTION

On or after January 1, 2003, in lieu of compliance with the limits specified in Table 1 for floor coatings; industrial maintenance coatings ; primers, sealers, and undercoaters; quick-dry primers, sealers, and undercoaters; quick -dry enamels; roof coatings; bituminous roof coatings; rust preventative coatings; stains; waterproofing sealers, as well as flats and nonflats (excluding recycled coatings), manufacture rs may average designated coatings

such that their actual statewide cumulative emissio ns from the averaged coatings are less than or equal to the cumulative statewide 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 statewide 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 and Appendi x A shall cease to be effective on January 1, 2005, after which averaging will no long er be allowed.Appendix A

-14-

- Table of Standards (grams of VOC per liter)

Effective

12/1/87 Effective

2/2/90

Below

- Ground Wood Preservative 600

Bond Breakers 350

Concrete

- Curing Compounds 350 350 Dry

- Fog Coatings 400 400

Fire

- Retar dant Coating

Clear Pigmented 650

350

Form

- Release Compounds 250 Graphics Arts (Sign) Coatings 500 High Temperature Industrial Maint. Coatings 650

Industrial Maintenance Anti

- graffiti Coatings 600 Industrial Maintenance Coatings 420 420 Lacquer 680 680 Magnesite Cement Coatings 600 Mastic Texture Coatings 300

Metallic

- Pigmented Coatings 500

Multi

- Color Coatings 580 Opaque Stains 350 350 Opaque Wood Preservatives 350 350 Pretreatment (Wash) Primer 780 Primers, Sealers & Undercoaters 350 350 Quick Dry Enamels 400 400 Quick Dry Primers, Sealers & Undercoaters 525 Roof Coatings 300 300 Sanding Sealers 550

Semi

- Transparent Stains 350 350

Semi

- Transparent & Clear Wood

Preservatives 350 350

Shellac

Clear Pigmented 730

550

Swim ming Pool Coatings 650 Swimming Pool Repair & Maintenance Coatings 650

Traffic Paints 250

Varnish 350 350 Waterproofing Sealers 400 400 Waterproofing Mastic Coatings 300 300

(2) A person shall not manufacture, blend or repackage for use or sale within San Diego County any architectural coating listed in th e table of standards below which contains VOC (excluding water and exempt solvents, and exclu ding any colorant added to tint bases), in excess of the corresponding limit specif ied in the follow ing table, after the corresponding date specified.

(3) A person shall not supply, ship or distribute into San Diego County any architectural coating, for use within San Diego Cou nty, subject to the requirements of Sub

section (d)(2) which contains VOC (excluding water and exempt solvents, and excludin g any colorant added to tint bases) in excess of the corresponding limit specified in the Table of Standards in Subsection (d)(2) for more than thr ee months after December 4, 1990.Appendix A

-15-

- (4) A person shall not sell, offer for sale, apply or solicit the applicat ion of any architectural coating subject to the requirements o f Subsection (d)(2) for use within San Diego County which, at the time of sale, contains V OC (excluding water and exempt solvents, and excludin g any colorant added in tint bases) in excess of th e corresponding new or revised limit that is effective on February 2, 1 990 specified in the Table of Stan dards in Subsection (d)(2) for more than three years after t he effective date of the standard.

(5) A person shall not sell, offer for sale, or supply any architectural coating for use within San Diego County unless the coating containe r displays the date of manufac ture of the contents or a code indicating the dates of manu facture. The manufacturers o f such coatings shall file an explanation of each code wit h the Air Pollution Control Officer and

the Executive Officer of the CARB.

(6) A person shall not sell, offer for sale, or supply any architectural coating for use within San Diego County unless th e coating container carries a statement of the manufacturer's recommendation regarding thinning of the coating. This requirement shall not apply to the thinning of architectural coatings with water. A person shall not sell or offer for sale any architect ural coating for use within San Diego County unless the thinning

recommended on the label for normal environmental a nd application conditions would not cause the coating to exceed its applicable standard

.

(7) A person shall not manufacture, sell, or offe r for sale any architectural coating manufactured after December 4, 1991 for use within San Diego County unless the coating container or top of the lid displays the maximum VO C content of the coating as applied and after any thinning as recommended by the manufacturer. The VOC content shall be displayed as grams of VOC per liter of coating (les s water and exempt solvents and excluding any colorant added to tint bases). The V OC content displayed may be calculated using product formulation data or may be de termined using the test method in Section (h).

(e) ADMINISTRATIVE REQUIREMENTS

(1) CONTAINER LABELING REQUIREMENT:

Each manufacturer of any architectural coating subj ect to this rule shall display the information listed in Subsections (e)(1)(i) through (e)(1)(ix) on the coating container (or label) in which the coating is sold or distributed.

(i) DATE CODE: The date the coating was manufactured, or a date code representing the date, shall be indicated on the la bel, lid, or bottom of the container. If the manufacturer uses a date code for any coatin g, the manufacturer shall file an explanation of each code with the Executive Officer of the CARB.Appendix A

-16-

- (ii) 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 require ment 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.

(iii) VOC CONTENT: Each container of any coating subject to this rul e shall display either the maximum or the actual VOC content of the coating, as supplied, including the maximum thinning as recomme nded by the manufacturer. VOC content shall be displayed as grams of VOC per liter of coating. VOC content displayed shall be calculated using product formula tion data or determined using the test methods in Subsection (f)(2). The equations i n Subsection (e)(2) shall be used to

calculate VOC content.

(iv) INDUSTRIAL MAINTENANCE COATINGS: In addition to the information specified in Subsections (e)(1)(i), (e) (1)(ii) and (e)(1)(iii), each manufacturer of any industrial maintenance coating subject to this rule shall display

on the label or lid of the container in which the c oating is sold or distributed one or more of the descriptions listed in Subsections (e)( 1)(iv)(A) through (e)(1)(iv)(C).

(A) “For industrial use only.” (B) “For professional use only.” (C) “Not for residential use” or “Not intended for res idential use.”

(v) CLEAR BRUSHING LACQUERS: Effective January 1, 2003, the labels of all clear brushing lacquers shall promine ntly display the statements “For brush application only,” and “This product must not be thinned or sprayed.”

(vi) RUST PREVENTATIVE COATINGS: Effective January 1, 2003, the labels of all rust preventative coatings shall prom inently display the statement “For Metal Substrates Only.”

(vii) SPECIALTY PRIMERS, SEALERS, AND UNDERCOATERS: Effective January 1, 2003, the labels of all specia lty primers, sealers, and undercoaters shall prominently display one or more of the descriptions listed in Subsections (e)(1)(vii)(A) through (e)(1)(vii)(E).

(A) For blocking stains. (B) For fire-damaged substrates. (C) For smoke-damaged substrates. (D) For water-damaged substrates. (E) For excessively chalky substrates.

(viii) QUICK-DRY ENAMELS: Effective January 1, 2003, the labels of all quick dry enamels shall prominently display the wor ds “Quick Dry” and the dry hard

time.Appendix A

-17-

- (ix) NONFLAT – HIGH GLOSS COATINGS: Effective January 1, 2003,

the labels of all nonflat – high gloss coatings sha ll prominently display the words “High Gloss.”

(2) 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 Subsections (e)(2)(i) or (e)(2)(ii), as appropriate . The VOC content of a tint base shall be

determined without colorant that is added after the tint base is manufactured.

(i) With the exception of low solids-coatings, determi ne the VOC content in grams of VOC per liter of coating thinned to the ma nufacturer’s maximum thinning recommendation, excluding the volume of any water a nd exempt compounds. Determine the VOC content using the following equat ion :

VOC Content = (W
s - W
w - W
ec ) / (V

m - V
w - V
ec )

Where: VOC content = grams of VOC per liter of coating

W
s = weight of all 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

(ii) For low-solids coatings, determine the VOC content in units of grams of VOC per liter of coating thinned to the manufacture r’s maximum recommendation, including the volume of any water and exempt compou nds. Determine the VOC content using the following equation:

VOC Content ls = (W

s - W

w - W
ec ) / (V

m )

Where: VOC content ls = the VOC content of a low solids coating in grams of VOC per liter of coating

W
s = weight of all 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

(f) MONITORING AND RECORDS

(1) REPORTING REQUIREMENTS

(i) CLEAR BRUSHING LACQUERS: Each manufacturer of clear brushing lacquers shall, on or before April 1 of ea ch calendar year beginning in theAppendix A

-18-

- year 2004, submit an annual report to the Executive Officer of the CARB. The report

shall specify the number of gallons of clear brushi ng lacquers sold in California during the preceding calendar year, and shall descr ibe the method used by the

manufacturer to calculate State sales.

(ii) RUST PREVENTATIVE COATINGS: Each manufacturer of rust preventative coatings shall, on or before April 1 o f each calendar year beginning in the year 2004, submit an annual report to the Execu tive Officer of the CARB. The report shall specify the number of gallons of rust preventative coatings sold in California during the preceding calendar year, and shall describe the method used by

the manufacturer to calculate State sales.

(iii) SPECIALTY PRIMERS, SEALERS, AND UNDERCOATERS: Each manufacturer of specialty primers, sealers, and und ercoaters 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 CARB. The report shall sp ecify the number of gallons of specialty primers, sealers, and undercoaters sold i n California during the preceding calendar year, and shall describe the method used b y the manufacturer to calculate

State sales.

(iv) TOXIC EXEMPT COMPOUNDS: For each architectural coating that contains perchloroethylene or methylene chloride, t he manufacturer shall, on or before April 1 of each calendar year beginning in t he year 2004, report to the Executive Officer of the CARB the following informa tion for products sold in California during the preceding year:

(A) the product brand name and a copy of the product l abel with legible usage instructions;

(B) the product category listed in Table 1 to which th e coating belongs;

(C) the total sales in California during the calendar year to the nearest gallon; the volume percent, to the nearest 0.10 per cent, of perchloroethylene and methylene chloride in the coating.

(v) RECYCLED COATING: Manufacturers of recycled coatings must

submit a letter to the Executive Officer of the CAR B certifying their status as a Recycled Paint Manufacturer. The manufacturer shal l, on or before April 1 of each calendar year beginning in the year 2004, submit an annual report to the Executive Officer of the CARB. The report shall include, for all recycled coatings, the total number of gallons distributed in California during the preceding year, and shall describe the method used by the manufacturer to cal culate California’s distribution.

(vi) BITUMINOUS COATINGS: Each manufacturer of bituminous roof coatings or bituminous roof primers shall, on or be fore April 1 of each calendar year beginning in the year 2004, submit an annual report to the Executive Officer of theAppendix A

-19-

- CARB. The report shall specify the number of gallo ns of bituminous roof coatings

or bituminous roof primers sold in California durin g the preceding calendar year, and shall describe the method used by the manufacturer to calculate California’s sales.

(2) TESTING PROCEDURES

(i) VOC CONTENT: To determine the physical properties of a coating in order to perform the Subsection (e)(2)calculations, the reference method for VOC content is U.S. EPA Method 24, incorporated by refe rence in Subsection (f)(2) (iv)(K), except as provided in Subsections (f)(2)(i i) and (f)(2)(iii). An alternative method to determine the VOC content of coatings is SCAQMD Method 304-91 (Revised February 1996), incorporated by reference in Subsection (f)(2)(iv)(L). The exempt compounds content shall be determined by Sou th Coast Air Quality Management District (SCAQMD) Method 303-91 (Revised Au gust 1996), incorporated by reference in Subsection (f)(2)(iv)(J). To deter mine the VOC content of a coating, the manufacturer may use U.S. EPA Method 24, or an alternative method as provided in Subsection (f)(2)(ii), formulation data, or any other reasonable means for predicting that the coating has been formulated as intende d (e.g. quality assurance checks, recordkeeping). However, if there are any inconsis tencies 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 alternativ e method is approved as specified in Subsection (f)(2)(ii). The Air Pollution Contro l Officer may require the manufacturer to conduct a Method 24 analysis.

(ii) ALTERNATIVE TEST METHOD: Other test methods demonstrated to provide results that are acceptable for purposes of determining compliance with Subsection (f)(2)(i), after review and approval in writing by the staffs of the District, the CARB, and the U.S. EPA, may also be used.

(iii) METHACRYLATE TRAFFIC MARKING COATINGS: Analysis of methacrylate multicomponent coatings used as traffi c marking coatings shall be conducted according to a modification of U.S. EPA M ethod 24 (Appendix A), incorporated by reference in Subsection (f)(2)(iv)( M). This method has not been approved for methacrylate multicomponent coatings u sed for purposes other than as traffic marking coatings or for other classes of mu lti-component coatings.

(iv) TEST METHODS: The following test methods are incorporated by reference herein, and shall be used to test coating s subject to provisions of this rule:

(A) Flame Spread Index: The flame spread index of a fire-retardant coating shall be determined by ASTM Designation E 8 4-99, “Standard Test Method for Surface Burning Characteristics of Build ing Materials,” (see Subsection (c)(20), Fire-Retardant Coating).

(B) Fire Resistance Rating: The fire resistance rating of a fireresistive coating shall be determined by ASTM Desig nation E 119-98,Appendix A

-20-

- “Standard Test Methods for Fire Tests of Building C onstruction Materials,”

(see Subsection (c)(19), Fire-Resistive Coating).

(C) Gloss Determination: The gloss of a coating shall be determined by ASTM Designation D 523-89 (1999), “Standard Test Method for Specular Gloss,” (see Subsections (c)(21), (c)(35), (c)(36) and (c)(41), Flat Coating, Nonflat Coating, Nonflat-High Gloss Coating, and Qu ick-Dry Enamels).

(D) Metal Content of Coatings: The metallic content of a coating shall be determined by SCAQMD Method318-95, “Determ ination of Weight Percent Elemental Metal in Coatings by X-Ray Diffra ction,” SCAQMD “Laboratory Methods of Analysis for Enforcement Sam ples,” (see Subsection (c)(33), Metallic Pigmented Coating).

(E) 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 Intermedi ates Used in Paint, Varnish, Lacquer, and Related Products,” (see Subse ction (c)(39), PreTreatment Wash Primers).

(F) 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 F ilm Formation of Organic Coatings at Room Temperature,” (see Subsections (c) (41) and (c)(42), QuickDry Enamel and Quick-Dry Primer, Sealer, and Underc oater). The tack-free time of a quick-dry enamel coating shall be determi ned by the Mechanical Test Method of ASTM Designation D 1640-95.

(G) Surface Chalkiness: The chalkiness of a surface shall be determined using ASTM Designation D 4214-98, “Stand ard Test Methods for Evaluating the Degree of Chalking of Exterior Paint Films,” (see Subsection (c)(51), Specialty Primer, Sealer, and Undercoater)

.

(H) Exempt Compounds – Siloxanes: Exempt compounds that are cyclic, branched, or linear completely methylated s iloxanes, shall be analyzed as exempt compounds (for compliance with Subsection (e)(2)) by Bay Area Air Quality Management District (BAAQMD) District Metho d 43, “Determination of Volatile Methylsiloxanes in Solvent-Based Coatin gs, Inks, and Related Materials,” BAAQMD Manual of Procedures, Volume III , adopted 11/6/96, (see Subsection (c)(60), Volatile Organic Compounds and Subsection (e)(2)(i)).

(I) Exempt Compounds – Parachlorobenzotrifluoride (PCBT F): The exempt compound parachlorobenzotrifluoride, sha ll be analyzed as an exempt compound for compliance with Subsection(f)(2 ) by BAAQMD Method 41, “Determination of Volatile Organic Compounds in Solvent-Based Coatings and Related Materials Containing Parachlorobenzotri fluoride,” BAAQMDAppendix A

-21-

- Manual of Procedures, Volume III, adopted 12/20/95, (see Subsection (c)(60),

Volatile Organic Compound and Subsection (f)(2)(i))

.

(J) Exempt Compounds: The content of compounds exempt under U.S. EPA Method 24 shall be analyzed by SCAQMD Met hod 304-91 (Revised 1993), “Determination of Exempt Compounds,” SCAQMD “Laboratory Methods of Analysis for Enforcement Samples,” (see Subsection (c)(60), Volatile Organic Compound and Subsection (f)(2)(i))

.

(K) 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 o f Volatile Matter Content, Water Content, Density, Volume Solids, and Weight S olids of Surface Coatings,” (see Subsection (f)(2)(i)).

(L) 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 O rganic Compounds (VOC) in Various Materials,” SCAQMD “Laboratory Met hods of Analysis for Enforcement Samples,” (see Subsection (f)(2)(i)).

(M) Methacrylate Traffic Marking Coatings: The VOC content of methacrylate multicomponent coatings used as traffi c marking coatings shall be analyzed by the procedures in 40 CFR Part 59, Subpa rt D, Appendix A,

“Determination of Volatile Matter Content of Methac rylate Multicomponent Coatings Used as Traffic Marking Coating,” (Septemb er 11,1998), (see Subsection (f)(2)(i)).

Existing Sections (e), (f) and (g) are deleted in t heir entirety. (e) If anywhere on the container of any coating listed on the Table of Standards, on any sticker or label affixed thereto, or in any sales o r advertising literature, any representation is made that the coating may be used as, or is suitabl e fo r use as, a coating for which a lower VOC standard is specified in the table or in Subsection (d)(1), then the lowest VOC standard shall apply. This requirement does not apply to the repr esentation of the following coatings in the manner specified:

(1) H igh Temperature Industrial Maintenance Coatings, wh ich may be represented

as metallic

- pigmented coatings for use consistent with the defi nition of high temperature industrial maintenance coatings;

(2) Lacquer Sanding Sealers, which may be recommended f or use as sanding sealers in conjunction with clear lacquer topcoats;

(3) Metallic

- Pigmented Coatings, which may be recommended for us e as primers, sealers, undercoaters, roof coatings, or industrial maintenance coatings;

(4) Shellacs; andAppendix A

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- (5) Fire Retarda nt Coatings.

(f) Rule 66 shall not apply to the sale or application of coatings subject to this rule.

(g) TEST METHODS

Measurement of VOC in architectural coatings shall be conducted and reported in accor dance with EPA Test Method 24 (40 CFR 60, Appendix A ) as it exists on December 4, 1990.

Measurement of the water content and exempt solvent content shall be conducted and reported in

accordance with ASTM Test Methods D 4457

- 85 and D 3792

- 86.

Calculation of the VOC content of coatings less wat er and exem pt solvents shall be performed in

accordance with ASTM Standard Practice D 3960

- 87.

Measurement of acid content shall be conducted and reported in accordance with ASTM Test

Method D 1613

- 81.

Measurement of elemental metal content shall be con ducted and r eported in accordance with the Spectrographic Method used by Pacific Spectrochemic al Laboratory, Inc. for the analysis of carbon dust and carbon laminates, as it exists on December 4, 1 990.Appendix A

-23-

- 

### New proposed Appendix A is added to Rule 67.0.

Appendix A

A.1 AVERAGING PROVISION

The manufacturer shall demonstrate that actual emi ssions from the coatings being averaged are less than or equal to the allowable emissions, for the s pecified 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

Gi = Total Gallons of Product (i) subject to Ave raging;

Mi = Material VOC Content of Product (i), in pound s per gallon;

Vm Wec

- Ww

- Ws Mi =

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

Vm Vec

- Vw

- Vm Vi =

Where: Ws, Ww, Wec, Vm, Vw, and Vec are defined in Subsection (e)(2), except that in this Appendix weights are in pounds and volumes are in gallons.

For Non-Zero VOC Coatings:

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

-24-

- Where: Vec

- Vw

- Vm Wec

- Ww

- Ws VOC Coating =

For Zero VOC Coatings:

Vi = Percent Solids by Volume

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

The averaging is limited to coatings that are desig nated by the manufacturer. Any coating not designa ted in the averaging Program shall comply with the VOC limit i n Table 1. The manufacturer shall not include any quantity of coatings that it knows or should have k nown will not be used in California, if statewide c oatings data are used. If district-specific coatings data are used, the manufacturer shall not include any qu antity of coatings that it knows or should have known will no t be used in the District.

A.1.1 In addition to the requirements specified in Section A.1, manufacturers shall not include in an Averaging

Program any coating with a VOC content in excess of the following maximum VOC content, for the applica ble categories.

Averaging Categories and VOC Ceiling (Maximum VOC A llowed)

Category Rule / VOC Limit (In effect or effective 1/1/2003 or 1/1/2004) Averaging VOC Ceiling (Maximum)

Flat Coating 100 250

Nonflat Coating 150 250

Floor Coatings 250 400

Industrial Maintenance Coatings 250 420

Primers, Sealers, and Undercoaters 200 350

Quick-Dry Primers, Sealers, & Undercoaters 200 450

Quick-Dry Enamels 250 400

Roof Coatings 250 300

Bituminous Roof Coatings 300 300

Rust Preventative Coatings 400 400

Stains 250 350

Waterproofing Sealers 250 400Appendix A

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- A.2 AVERAGING PROGRAM (PROGRAM)

At least six months prior to the start of the com pliance period, manufacturers shall submit an Averaging Program to the Executive Officer of the A ir 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 writin g by the Executive Officer.

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 informatio n for the Executive Officer to make a determination as to whether the manufacturer may comply with the averaging requirements over the specified compliance period in an enforceable manner. Such i nformation shall include, but is not limited to, th e following:

A.3.1 An identification of the contact persons, te lephone numbers, and name of the manufacturer who i s submitting the Program.

A.3.2 An identification of each coating that has b een selected by the manufacturer for inclusion in t his program that exceeds the applicable VOC limit in Ta ble 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 pr ojected actual emissions will not exceed the allowa ble emissions for a single compliance period that the P rogram 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 Section A.1 of this Appendix for projecting the actual emissions and allowable e missions during each compliance period. The

demonstration shall also include all VOC content le vels and projected volume sold within the State for each coating listed in the Program during each comp liance 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 o r less than six months.

A.3.5 An identification and description of all rec ords to be made available to the Executive Officer upon request, if different than those identified under S ection A.3.6.

A.3.6 An identification and description of specifi c records to be used in calculating emissions for t he Program and subsequent reporting, and a detailed ex planation as to how those records will be used by the manufacturer to verify compliance with the aver aging requirements.

A.3.7 A statement, signed by a responsible party f or the manufacturer, that all information submitted is true and correct, and that records will be made availabl e to the Executive Officer upon request.Appendix A

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- A.4 REPORTING REQUIREMENTS

A.4.1 For every single compliance period, the manuf acturer shall submit a mid-term report listing all coatings subject to averaging during the first half of the compliance period, detailed analysis of the

actual and allowable emissions at the end of the mi d-term, and an explanation as to how the manufacturer intends to achieve compliance by the e nd of the compliance period. The report shall be signed by the responsible party for the manufacture r, attesting that all information submitted is true and correct. The mid-term report shall be submitted wi thin 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 complianc e period or upon termination of the Program, whiche ver is sooner, the manufacturer shall submit to the Exe cutive Officer a report listing all coatings subjec t to averaging during the compliance period, providing a detailed demonstration of the balance between the actual and allowable emissions for the compliance p eriod, any identification and description of specif ic records used by the manufacturer to verify complian ce with the averaging requirement, and any other information requested by the Executive Officer to d etermine whether the manufacturer complied with the averaging requirements over the specified compl iance period. The report shall be signed by the responsible party for the manufacturer, attesting t hat all information submitted is true and correct, and

that records will be made available to the Executiv e 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 re quest that shall include an updated Program, meeting all applicable Program requirements. The r enewal request will 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 the manufacture r is likely to comply with the averaging requirements. The Executive Officer shall base suc h determination on all available information, including but not limited to, the mid-term and the final reports of the preceding compliance period. The Executive Officer shall make a decision to deny or approve a renewal request no later than 45 days from the date of the final report submittal, u nless the manufacturer and the Executive Officer agree to an extension of time for the Executive Off icer to take action on the renewal request.

A.6 MODIFICATION OF A PROGRAM

A manufacturer may request a modification of the P rogram at any time prior to the end of the compliance period. The Executive Officer shall tak e 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. A Program need not be mod ified to specify additional coatings to be averaged that are below the applicable VOC limits.Appendix A

-27-

- A.7 TERMINATION OF A PROGRAM

A.7.1 A manufacturer may terminate its Program at a ny time by filing a written notification to the Exe cutive Officer. The filing date shall be considered the e ffective 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 per iod that the Program was in effect shall constitute a separate violation for each day of the entire com pliance 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 comp liance period, the actual emissions exceed the allowable e missions.

A.7.2.2 The manufacturer demonstrates a recurring p attern 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 Progr am are amended such that its effective date is less than one year from the date of adoption, the affect ed manufacturer may base its averaging on the prior limits of that coating until the end of the complia nce 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 the table in Section 301 shall display the following statement: “This product is subject to architectural coatings averaging provisions in C alifornia.” 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. H owever, any violation of the requirements of the Averaging Provision of this rule, which the violato r can demonstrate, to the Executive Officer, did no t
cause or allow the emission of an air contaminant a nd was not the result of negligent or knowing activity may be considered a minor violation.

A.11 SUNSET OF AVERAGING PROVISION

The averaging provision set forth in Appendix A sh all cease to be effective on January 1, 2005, after which averaging will no longer be allowed.Appendix B



### Appendix B: Notice of PreparationAppendix B

-1-

- Air Pollution Control Board Greg Cox District 1

Dianne Jacob District 2

Pam Slater District 3

Ron Roberts District 4

Bill Horn District 5

Air Pollution Control District

R. J. Sommerville Director

NOTICE OF PREPARATION OF AN ENVIRONMENTAL IMPACT RE PORT

June 8, 2001

NOTICE IS HEREBY GIVEN that the San Diego County Ai r Pollution Control District is the Lead Agency and will prepar e an Environmental Impact Report in accordance with the California Env ironmental Quality Act for the following project. The District is seeking public and agency input on the scope and content of the environmental infor mation to be contained in the EIR. A Notice of Preparation document, whic h contains a description of the probable environmental effects o f the project, can be reviewed at Room 102, Air Pollution Control Distric t, 9150 Chesapeake Drive, San Diego, California 92123-1096. Comments on the Notice of Preparation document must be sent to the APCD addre ss listed above and should reference the project number and name.

ER 01-00-001, SECOND TIER EIR FOR AMENDMENTS TO APC D RULE 67.0, ARCHITECTURAL COATINGS. The District proposes to adopt amendments to Rule 67.0, Architectural Coatin gs, as part of its Rules and Regulations. The Rule 67.0 amendments wi ll incorporate VOC content limits and other requirements contained in the Suggested Control Measure (SCM) for Architectural Coatings, adopted b y the ARB on June 22, 2000. The SCM sets allowable VOC content limit s and other requirements, based on existing and currently devel oping coating technologies, for a number of architectural coating categories, including flats, non-flats, industrial maintenance, lacquers, floor, roof, rust preventative, stains, and primers, sealers, and und ercoatings. Prior to approving the SCM, ARB prepared and certified a Pro grammatic Environmental Impact Report (PEIR). The EIR being prepared by APCD
will tier from the ARB PEIR. Comments on this Noti ce of Preparation document must be received no later than July 10, 20 01, at 5:00 p.m. (a 30-day public review period). For additional infor mation, please contact Mr. Robert Mross by telephone at (858) 650-4672 or by e-mail at rmrossha@co.san-diego.ca.us.Appendix B

-2-

- Air Pollution Control Board Greg Cox District 1

Dianne Jacob District 2

Pam Slater District 3

Ron Roberts District 4

Bill Horn District 5

Air Pollution Control District

R. J. Sommerville Director

NOTICE OF PREPARATION DOCUMENTATION

DATE: June 8, 2001

PROJECT NAME: Second Tier EIR for Amendments to APCD Rule 67.0, Architectural Coatings

PROJECT NUMBER: ER 01-00-001

PROJECT APPLICANT: San Diego County Air Pollution Control District 9150 Chesapeake Drive San Diego, CA 92123-1096

ENV. REVIEW NUMBER: ER 01-00-001

PROJECT DESCRIPTION:

The San Diego County Air Pollution Control District (APCD) proposes to adopt amendments to Rule 67.0, Architectural Coatings, as part of its Rules and Regulations. Architectural coatings are coatings applied to stat ionary structures and their appurtenances, and include such coatings as house p aints, stains, varnishes, industrial maintenance coatings, and traffic marking coatings. When applied, the solvents in the coatings evaporate into the atmosphere and emit vol atile organic compounds (VOC),
which contribute to the formation of ozone. San Di ego County has been designated by the California Air Resources Board (ARB) as a Serio us nonattainment area for the State ambient air quality standard for ozone.

The Rule 67.0 amendments will incorporate VOC content limits and other requirements contained in the Suggested Control Measure (SCM) fo r Architectural Coatings, adopted by the ARB on June 22, 2000. The SCM is based on e xisting and currently developing coating technologies for a number of architectural coating categories, including flats, non-flats, industrial maintenance, lacquers, floor, roof, rust preventative, stains, and primers, sealers, and undercoaters. Local implemen tation of the SCM would reduce VOC emissions in San Diego County by an estimated 1 .5 tons per day. Deleted: and particulate matter (PM)

Deleted: does not yet attain the California ambient air quality
standards for ozone and PM.

Deleted: Amendment of

Deleted: statewide

Deleted: California Air Resources Board (

Deleted: )Appendix B

-3-

- Prior to adopting the SCM, ARB prepared and certifi ed a Program Environmental Impact Report (PEIR). The EIR being prepared by th e San Diego County APCD will tier from the ARB PEIR. A copy of that report is availa ble through either the APCD or ARB, as well as on the ARB website at the following addr esses.

Street Address: San Diego County Air Pollution Con trol District 9150 Chesapeake Drive San Diego, CA 92123-1096
Or
California Air Resources Board CalEPA Headquarters Building
1001 I Street Sacramento, CA 95814

Internet Address: www.arb.ca.gov/arch/CEQA/FEIR.htm

Amended Rule 67.0 would continue to apply to any person who supplies, sells, offers for sale, or manufactures any architectural coating for use within San Diego County, as well as any person who applies or solicits the appl ication of any architectural coating within San Diego County. The proposed rule amendme nts will lower the VOC content limit for a number of architectural coating categor ies, and include additional coating categories with VOC limits consistent with the SCM. The proposed VOC limits for most categories would become effective on January 1, 200 3 (January 1, 2004, for industrial maintenance coatings.)

Provisions for product-line averaging are included in the proposed rule amendments (consistent with the SCM), allowing manufacturers t o average designated coatings such that their average cumulative emissions are less th an or equal to the cumulative

emissions that would be allowed under the rule. Th e averaging provision will only be in effect from January 1, 2003, until January 1, 2005. Additionally, the APCD is considering establishing a VOC ceiling (maximum all owable VOC content limit) when averaging. Ceiling limits would protect against re gional differences that could result in high VOC products being sold in San Diego.

Amended Rule 67.0 does not include the SCM provisio n pertaining to petitioning the Air Pollution Control Officer to allow application of a n industrial maintenance coating with a VOC content up to 340 grams per liter, since that p rovision only applies to the North Central Coast, San Francisco Bay Area, and the Nort h Coast Air Basins.

PROJECT LOCATION:

The project applies within the jurisdiction of the San Diego County APCD, which covers the entire area within the incorporated and the uni ncorporated portions of San Diego County, the southwestern-most county in the State o f California (Figure 1-1). San Diego County encompasses approximately 4,260 square miles and is bounded on the Deleted: The APCD is considering implementing capped limits for VOCs rather than state averaging stipulations imposed by the SCM. By implementing capped limits, APCD is insuring the region will achieve the
amended California ambient air quality standards.Appendix B

-4-

- north by Orange and Riverside Counties, on the east by Imperial County, on the west by the Pacific Ocean, and on the south by the State of Baja California Norte, México.

PROBABLE ENVIRONMENTAL EFFECTS:

The potential environmental effects that could resu lt from the project are identified in the attached Environmental Initial Study, which was dev eloped based on review of ARB’s PEIR. All questions answered “Potentially Signific ant Impact” or “Less than Significant with Mitigation Incorporated” will be analyzed furt her in the Environmental Impact Report. All questions answered “Less than Signific ant Impact” or “Not Applicable” will not be analyzed further in the Environmental Impact Report.

The following is a summary of the subject areas to be analyzed in the EIR and the particular issues of concern. In each instance, th e EIR will focus on localized impacts that were not adequately addressed in the ARB PEIR, which had a broader, statewide

scope.

I. AIR QUALITY

Air quality impacts will be considered significant if the proposed rule amendments would conflict with or obstruct implemen tation of the applicable air quality plan; violate any air qualit y standard or contribute to an existing or projected air quality violation; exp ose sensitive receptors to substantial pollutant concentrations; expose off-si te receptors to significant concentrations of hazardous air pollutants; result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment;; or create objectionable o dors affecting a substantial number of people.

The adoption and implementation of the proposed rul e amendments is expected to produce substantial, long-term, VOC emi ssion reductions. However, some companies in the architectural coatin gs industry have claimed that by lowering the VOC content of coating s, there will be an increase in VOC emissions for a variety of reasons including increased coating thickness, more thinning, more topcoats, mo re touch-ups, more priming, more frequent re-coating, more substitutio n with higher VOC coatings, and greater reactivity. These and other air quality issues will be

addressed as appropriate

.

II. WATER RESOURCES

Impacts on water resources will be divided into two categories—water demand and water quality. Water impacts will be co nsidered significant if they cause changes in the course of water movements or of drainage or Deleted: The APCD will evaluate whether adoption and implementation of the proposed rule amendments is expected to produce substantial, long-term, VOC emission reductions. Additionally, comments made by the architectural coatings industry during the ARB PEIR process will be

addressed.Appendix B

-5-

- surface runoff patterns that would result in erosio n or flooding; exceed the

capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; substantially degrade water quality; deplete groundwater supplies, or int erfere with groundwater recharge efforts; violate any water quality standar ds or waste discharge requirements, or exceed wastewater treatment requir ements of the California Regional Water Quality Control Board, Sa n Diego Region; require the construction of new, or expansion of ex isting, water, wastewater, or stormwater drainage facilities, the construction of which could cause significant environmental effects; requ ire new or expanded water entitlements and resources; or exceed a waste water treatment provider’s existing commitments.

Potential water demand impact areas include increas ed water demand from the manufacturing and use of compliant water-b orne coatings. Potential water quality impacts include the impact of solvents and architectural coatings.

III. PUBLIC SERVICES

Public services impacts will be considered signific ant if they will result in adverse physical impacts associated with the provis ion of new or altered public facilities in order to maintain acceptable s ervice ratios or response times for fire protection, police protection, schoo ls, parks, or other public facilities. Potential impacts include impacts on p ublic facilities and fire protection services – including impacts associated with the use of potentially flammable solvents.

IV. TRANSPORTATION/CIRCULATION

Transportation/circulation impacts will be consider ed significant if they
cause a substantial increase in traffic related to the existing traffic load and street capacity; exceed a level of service stan dard for designated roads or highways; substantially increase hazards d ue to a design feature or incompatible uses; result in inadequate emergenc y access, parking capacity, or hazards or barriers for pedestrians or bicyclists; or conflict with adopted alternative transportation policies, p lans, or programs.

Potential transportation and circulation impacts in clude additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabiliti es. Deleted: on water quality, as well as the impact of architectural coatings are not expected to adversely impact water quality.Appendix B

-6-

- V. SOLID AND HAZARDOUS WASTE

Solid waste/hazardous waste impacts will be conside red significant if the proposal would not be served by a landfill with suf ficient permitted capacity to accommodate the project’s solid and/or hazardous waste disposal needs, or would not comply with federal, s tate, and local statutes and regulations related to solid and hazardous wast es.

Potential solid and hazardous waste impacts include impacts on the disposal capacity arising from increased disposal o f compliant coatings due to the possibility of shorter shelf or pot live s or lesser freeze-thaw capabilities.

VI. HAZARDOUS SUBSTANCES

Hazardous substance impacts will be considered sign ificant if they create a significant hazard to the public or the environme nt through the transport, use, disposal, or other handling of hazardous mater ials, or through reasonably foreseeable upset and accident condition s involving the release of hazardous materials; result in the handl ing of hazardous materials or wastes within 1/4 mile of an existing or proposed school; are
located on a site included on a list of hazardous m aterials sites compiled pursuant to Government Code section 65962.5; impair implementation of an adopted emergency response or evacuation plan; o r increase fire
hazard in areas with flammable materials.

Potential hazardous substance impacts include the r isk of an upset or accidental release of hazardous substances, and hum an health impacts. Human health impacts include potential increased lo ng-term (carcinogenic and chronic) and short-term (acute) human health im pacts associated with the use of various replacement solvents in complian t coatings
formulations.

VII. OTHER AREAS

In addition to the subject areas summarized above, the EIR will assess, as appropriate, the following environmental issues: i rreversible environmental changes, potential growth inducing im pacts, consistency with other plans, and project mitigation measures a nd alternatives.Appendix B

-7-

- VIII. ENVIRONMENTAL EFFECTS THAT DO NOT REQUIRE ANA LYSIS

The APCD has determined that the following areas ne ed not be analyzed in the EIR.

1. Land Use and Planning 2. Population and Housing 3. Geophysical 4. Biological Resources 5. Energy and Mineral Resources

6. Noise

7. Aesthetics
8. Cultural Resources

9. Recreation

Attachments: Project Location Map

Environmental Initial StudyAppendix B

-8-

- 

# Project

Location Map

● Los Angeles ● Sacramento



# San Diego

Mexico

Figure 1-1 Project Location San Diego County 

# ★ ★Appendix C



### Appendix C: Initial StudyAppendix C

-1- Air Pollution Control Board

Greg Cox District 1

Dianne Jacob District 2

Pam Slater District 3

Ron Roberts District 4

Bill Horn District 5

Air Pollution Control District

R.J. Sommerville Director

June 1, 2001 

### CEQA Initial Study - Environmental Checklist Form
(Based on the State CEQA Guidelines, Appendix G Rev . 10/98)

1. Project Number(s)/Environmental Record Number/Ti tle:
ER 01-00-001/Proposed Amendments to Air Pollution C ontrol District (APCD) Rule 67.0; Architectural Coatings

2. Lead agency name and address:
San Diego County Air Pollution Control District 9150 Chesapeake Drive San Diego, California 92123-1096

3. a. Lead Agency Contact: Robert Reider b. Title: Supervising Air Specialist, APCD c. Phone number: (858) 650-4670 d. E-mail: rreideha@co.san-diego.ca.us

4. Participants in the preparation of this Initial Study: San Diego County APCD Robert Reider, Supervising Air Pollution Specialist Robert Mross, Associate Air Pollution Specialist Laura Yannayon, Senior Air Pollution Control Engine er Adeline Suson, Associate Air Pollution Control engi neer

San Diego County Department of Planning and Land Us e Joseph M. DeStefano II, Environmental Management Sp ecialist III Kristin Eberwein, Environmental Management Trainee

San Diego County Office of County Counsel
Terence Dutton, Esq., Sr. Deputy County Counsel

5. Project location:

The project applies within the jurisdiction of the San Diego County APCD, which covers the entire area within the incorporated and the unincorporated portions of San Diego County, the southwestern-most county in t he State of CaliforniaAppendix C

-2- (Figure 1-1). San Diego County encompasses approxi mately 4,260 square miles and is bounded on the north by Orange and Riv erside Counties, on the east by Imperial County, on the west by the Pacific Ocean, and on the south by the State of Baja California Norte, Mexico.

6. Project sponsor’s name and address:

San Diego Air Pollution Control District 9150 Chesapeake Drive San Diego, CA 92123-1095

7. General Plan Designation Community Plan: Varies throughout San Diego Coun ty Land Use Designation: Varies throughout San Diego County Density: Varies throughout San Diego County

8. Zoning Use Regulation: Varies throughout San Diego Coun ty Density: Varies throughout San Diego County Special Area Regulation: Varies throughout San Di ego County

9. Description of project (Describe the whole actio n involved, including but not limited to later phases of the project, and any sec ondary, support, or off-site features necessary for its implementation):

The San Diego County Air Pollution Control District (APCD) is proposing to adopt amendments to APCD Rule 67.0, Architectural C oatings. Architectural coatings are defined as coatings applied to station ary structures and their accessories (usually for beautification and protect ion), and include such coatings as house paints, stains, varnishes, indust rial maintenance coatings, and traffic marking coatings. When applied, the so lvents in the coatings evaporate into the atmosphere and emit volatile org anic compounds (VOCs),
which contribute to the formation of ozone. San Di ego County has been designated by the California Air Resources Board (A RB) as a “Serious” nonattainment area for the State ambient air qualit y standard for ozone.

The Rule 67.0 amendments will incorporate VOC limit s and other requirements contained in the Suggested Control Mea sure (SCM) for Architectural Coatings, adopted by the ARB on June 22, 2000. The SCM sets VOC content limits and other requirements that are feasible (based on existing and currently developing coating technolog ies) and that will achieve significant reductions in VOC emissions from archit ectural coatings. Local implementation would reduce VOC emissions in San Di ego County by an estimated 1.5 tons per day.

Amended Rule 67.0 would continue to apply to any pe rson who supplies, sells, offers for sale, or manufactures an architec tural coating for use withinAppendix C

-3- San Diego County, as well as any person who applies or solicits the application of any architectural coating within San Diego County. The proposed rule amendments will lower the VOC content limit for a number of architectural coating categories, and include addit ional coating categories with VOC limits consistent with the SCM. The propo sed VOC limits for most categories would become effective on January 1, 200 3 (January 1, 2004, for industrial maintenance coatings.)

The lowered VOC limits are consistent with the corr esponding limits in the SCM, and pertain to: clear wood coatings, (lacquers and varnishes); high temperature coatings; industrial maintenance coatin gs; magnesite cement coatings; multi-color coatings; pre-treatment wash primers; primers, sealers and undercoaters; quick dry enamels; quick-dry prim ers; roof coatings; stains; swimming pool coatings; swimming pool repair and ma intenance coatings; traffic marking coatings (indicated as traffic pain ts in existing rule 67.0); waterproofing sealers; and wood preservatives. Add ed coating categories include antenna coatings, anti-fouling coatings; fa ux finishing compounds, flow coatings, rust preventative coatings, and temp erature-indicator safety coatings.

Provisions for product-line averaging are included in the proposed rule amendments (consistent with the SCM), allowing manu facturers to average designated coatings such that their average cumulat ive emissions are less than or equal to the cumulative emissions that woul d be allowed under the rule. The averaging provision will only be in effe ct from January 1, 2003 until January 1, 2005. Additionally, the APCD is conside ring establishing a VOC ceiling (maximum allowable VOC content limit) when averaging. Ceiling limits would protect against regional differences that cou ld result in high VOC products being sold in San Diego.

Amended Rule 67.0 does not include the SCM provisio n pertaining to petitioning the Air Pollution Control Officer to al low application of an industrial maintenance coating with a VOC content up to 340 gr ams per liter, since that provision only applies to the North Central Coast, San Francisco Bay Area,
and the North Coast Air Basins.

10. Regulatory and Environmental Issues:

San Diego County has been designated a Serious nona ttainment area for the State ambient air quality standard for ozone. Acco rdingly, the APCD proposes amending Rule 67.0 in order to meet the “e very feasible control measure” requirement imposed on nonattainment areas by State law (California Health and Safety Code (H&SC) Section 4 0914), as well as the Best Available Retrofit Control Technology (BARCT) requirement (H&SC Section 40919). Section 40914 requires the APCD to adopt the most
effective control measure to reduce VOC emissions f rom architectural coatings. Section 40919 requires the APCD to adopt an emission limitationAppendix C

-4- that is based on the maximum degree of reduction ac hievable, taking into account environmental, energy, and economic impacts by each class or category of sources.

11. Environmental Setting:

The San Diego Air Basin is contiguous with the poli tical boundaries of San Diego County. The County of San Diego encompasses approximately 4,260 square miles and is bounded on the north by Orange and Riverside Counties, on the east by Imperial County, on the west by the Pacific Ocean, and on the south by the Mexican State of Baja California. The County is divided by the Laguna Mountain Range which runs approximately para llel to the coast about 45 miles inland and separates the coastal area from the desert portion of the County. The Laguna Mountains reach peaks of over 6 ,000 feet with Hot Springs Mountain peak rising to 6,533 feet, the hig hest point in the county. The coastal region is made up of coastal terraces t hat rise from the ocean into wide mesas which then, moving farther east, tr ansition into the Laguna Foothills. Farther east, the topography gradually rises to the rugged mountains. On the east side, the mountains drop of f rapidly to the AnzaBorrego Desert, which is characterized by several b roken mountain ranges with desert valleys in between. To the north of th e County are the Santa Ana Mountains which run along the coast of Orange Count y, turning east to join with the Laguna Mountains near the San Diego-Orange County border.

The climate of the San Diego Air Basin, as with all of Southern California, is largely dominated by the strength and position of t he semi-permanent highpressure system over the Pacific Ocean (known as th e Pacific High). This high-pressure ridge over the West Coast often creat es a pattern of late-night and early-morning low clouds, hazy afternoon sunshi ne, daytime onshore breezes, and little temperature variation year-roun d. The climatic classification for San Diego is a Mediterranean cli mate, with warm, dry summers and mild, wet winters. Average annual prec ipitation ranges from approximately 10 inches on the coast to over 30 inc hes in the mountains to the east (the desert regions of San Diego County ge nerally receive between 4 and 6 inches per year).

The favorable climate of San Diego also works to cr eate air pollution problems. Sinking, or subsiding air from the Pacif ic High creates a temperature inversion (known as a subsidence invers ion), which acts as a lid to vertical dispersion of pollutants. Weak summert ime pressure gradients further limit horizontal dispersion of pollutants i n the mixed layer below the subsidence inversion. Poorly dispersed anthropogen ic emissions, combined with strong sunshine lead to photochemical reaction s, which create ozone in this surface layer.

Daytime onshore flow (i.e., sea breeze) and nightti me offshore flow (i.e., land breeze) are quite common in Southern California. T he sea breeze helps toAppendix C

-5- moderate daytime temperatures in the western portio n of San Diego County, which greatly adds to the climatic draw of the regi on. This also leads to emissions being blown out to sea at night and retur ning to land the following day. Under certain conditions, this atmospheric os cillation results in the offshore transport of air from the Los Angeles regi on to San Diego County, which often results in high ozone concentrations be ing measured at San Diego County air pollution monitoring stations. Tr ansport of air pollutants from Los Angeles to San Diego has also been shown t o occur aloft within the stable layer of the elevated subsidence inversion. In this layer, removed from fresh emissions of oxides of nitrogen, which would scavenge and reduce ozone concentrations, high levels of ozone are tran sported into San Diego County.

National and state air quality standards are set fo r criteria pollutants, which are widespread common pollutants known to be harmfu l to human health and welfare. Standards are set to protect the elderly, very young, and chronically sensitive portions of our population. Areas not me eting a particular standard are referred to as a non-attainment area for the po llutant. Of the six air pollutants regulated by the federal Environmental P rotection Agency, and eight regulated by the California Air Resources Boa rd, only ozone (smog) and inhalable particulate matter (PM 10 ) occur in concentrations sufficient to violate either federal or state standards in San Diego Coun ty.

San Diego County has experienced substantial improv ement in ambient ozone levels over the past several years. The numb er of days above the
federal one-hour ozone standard has decreased from 39 days in 1990 to none in 2000. Similarly, the number of days above the more stringent state standard has decreased from 139 days in 1990 to 24 days in 2000.

Federal standards for PM 10 (particulate matter equal to or less than 10 microns in size) have never been exceeded. However , the stricter state

standards are not met at this time.

12. Public Agency Involvement a. Other public agencies whose approval is, or may be, required (e.g., permits, financing approval, or participation agree ment):

Permit Type/Action Agency Rule Approval California Air Resources Board SIP Approval Environmental Protection Agency

b. State agencies (not included in #11) that have j urisdiction by law over

natural resources potentially affected by the project:

California Department of Transportation California Regional Water Quality Control BoardAppendix C

-6- ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages. 

#  Aesthetics 

#  Agriculture Resources 

# Air Quality 

#  Biological Resources 

#  Cultural Resources 

#  Geology /Soils

# Hazards & Haz.

Materials 

# Hydrology/Water Quality 

#  Land Use / Planning



#  Mineral Resources 

#  Noise 

#  Population / Housing

# Public Services 

#  Recreation 

# Transportation/Traffic

# Utilities / Service Systems 

# Mandatory Findings of SignificanceAppendix C

-7- DETERMINATION: (To be completed by the Lead Agency)
On the basis of this initial evaluation:



#  On the basis of this Initial Study, the Department of Planning and Land Use finds that the proposed project COULD NOT have a si gnificant effect on the environment, and a NEGATIVE DECLARATION will be prepared.



#  On the basis of this Initial Study, the Department of Planning and Land Use finds that although the proposed project could have a significant effect on the environment, there will not be a significant ef fect in this case because revisions in the project have been made by or agree d to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.



# On the basis of this Initial Study, the Department of Planning and Land Use finds that the proposed project MAY have a signific ant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.



#  I find that the proposed project MAY have a “potent ially significant impact” or “potentially significant unless mitigated" impac t on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis a s described on
attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.



#  On the basis of this Initial Study, the Department of Planning and Land Use finds that although the proposed project could have a significant effect on the environment, because all potentially significan t effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE D ECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATIO N, including revisions or mitigation measures that are imposed u pon the proposed project, nothing further is required.



#  On the basis of this Initial Study, the Department of Planning and Land Use believes the following: there are no new significa nt environmental effects and no substantial increase in severity of effects identified in an earlier
NEGATIVE DECLARATION or ENVIRONMENTAL IMPACT REPORT for the proposed project or property are present as the result of either 1) changes in the project; 2) changes in circumstances under which the project is undertaken; or 3) new information which could no t have been known without the exercise of reasonable diligence at the time the previous Negative Declaration was adopted or Environmental I mpact Report was certified. Therefore, the previously adopted NEGAT IVE DECLARATION or
certified ENVIRONMENTAL IMPACT REPORT will be consi dered adequate upon completion of an ADDENDUM to reflect minor tec hnical changes.Appendix C

-8- 

#  On the basis of this Initial Study, the Department of Planning and Land Use believes the following: new significant environmen tal effects or an substantial increase in severity of effects identif ied in an earlier Negative Declaration or Environmental Impact Report for the proposed project or property are present as the result of either 1) cha nges in the project; 2) changes in circumstances under which the project is undertaken; or 3) new
information which could not have been known without the exercise of reasonable diligence at the time the original earli er Negative Declaration or Environmental Impact Report was adopted. Therefore , a SUBSEQUENT/SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT is required.

Signature

Robert Reider Date

Supervising Air Specialist

Printed Name TitleAppendix C

-9- INSTRUCTIONS ON EVALUATION OF ENVIRONMENTAL IMPACTS

1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a l ead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported
if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project f alls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project wil l not expose sensitive receptors to pollutants, based on a project-specific screening a nalysis).

2. All answers must take account of the whole actio n involved, including off-site as well as on-site, cumulative as well as project-level, in direct as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a parti cular physical impact may occur,
then the checklist answers must indicate whether th e impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evid ence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

4. “Less Than Significant With Mitigation Incorpora ted” applies where the incorporation of mitigation measures has reduced an effect from “Pot entially Significant Impact” to a “Less Than Significant Impact.” The lead agency mus t describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level.

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discu ssion should identify the following: a) Earlier Analysis Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which eff ects from the above checklist were within the scope of and adequately a nalyzed in an earlier document pursuant to applicable legal standards, an d state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation mea sures that were incorporated or refined from the earlier document a nd the extent to which they address site-specific conditions for the proje ct.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., ge neral plans, zoning ordinances). Reference to a previously prepared or outside docum ent should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. The explanation of each issue should identify: a) The significance criteria or threshold, if any, used to evaluate each question;

and b) The mitigation measure identified, if any, to re duce the impact to less than significanceAppendix C

-10- I. AESTHETICS -- Would the project? a) Have a substantial adverse effect on a scenic vi sta? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to aesthetics are anticipated.

b) Substantially damage scenic resources, including , but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to aesthetics are anticipated.

c) Substantially degrade the existing visual charac ter or quality of the site and its surroundings? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to aesthetics are anticipated.

d) Create a new source of substantial light or glar e, which would adversely affect day or nighttime views in the area? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-11- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. The proposed ame ndments are not anticipated to create new, or increase existing, li ght sources.

II. AGRICULTURE RESOURCES -- Would the project: a) Convert Prime Farmland, Unique Farmland, or Farm land of Statewide Importance Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the Cali fornia Resources Agency, to non-agricultural use? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . No conversion of farmland will occur as a result of this rule change

.

b) Conflict with existing zoning for agricultural u se, or a Williamson Act contract? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . No conflict with zoning will occur as a result of this rule change.

c) Involve other changes in the existing environmen t, which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . No changes in the environment, which would result in conversion of fa rmland, will occur as a result of this rule change.Appendix C

-12- III. AIR QUALITY -- Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The adoption and implementation of the proposed rul e amendments is expected to produce substantial, long-term, VOC emi ssion reductions. However, some companies in the architectural coatin gs industry have claimed that by lowering the VOC content of coatings, there will be an increase in VOC emissions for a variety of reasons including in creased coating thickness, more thinning, more topcoats, more touch-ups, more priming, more frequent re-coating, more substitution with higher VOC coati ngs, and greater reactivity. These companies claim that the new formulations wil l result in more coating use, resulting in an overall increase in VOC emissi ons for a specific area covered or over time. Industry also asserts that m ore reactive solvents will be used in compliant formulation than those used in ex isting coatings, thus contributing to increased ozone formation.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Ar chitectural Coatings, adopted by the ARB on June 22, 2000. Further revie w of these issues to ensure that District level impacts have been adequa tely assessed is beyond the scope of an Initial Study. Consequently, air q uality plan impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

b) Violate any air quality standard or contribute s ubstantially to an existing or projected air quality violation?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

As discussed above, the adoption and implementation of the proposed rule amendments is expected to produce substantial, long -term, VOC emission reductions. However, some companies in the archite ctural coatings industry have claimed that by lowering the VOC content of coating s, there will be an increase in VOC emissions for a variety of reasons including in creased coating thickness, more thinning, more topcoats, more touch-ups, more priming, more frequent recoating, more substitution with higher VOC coatings , and greater reactivity. These companies claim that the new formulations will resu lt in more coating use, resulting in an overall increase in VOC emissions for a speci fic area covered or over time. Industry also asserts that more reactive solvents w ill be used in compliantAppendix C

-13- formulation than those used in existing coatings, t hus contributing to increased
ozone formation.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Ar chitectural Coatings, adopted by the ARB on June 22, 2000. Further revie w of these issues to ensure that District level impacts have been adequa tely assessed is beyond the scope of an Initial Study. Consequently, air q uality impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

c) Result in a cumulatively considerable net increa se of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing e missions which exceed quantitative thresholds for ozone precursors)?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

As discussed above, the adoption and implementation of the proposed rule amendments is expected to produce substantial, long -term, VOC emission reductions. However, some companies in the archite ctural coatings industry have claimed that by lowering the VOC content of co atings, there will be an increase in VOC emissions for a variety of reasons including increased coating thickness, more thinning, more topcoats, mo re touch-ups, more priming, more frequent re-coating, more substitutio n with higher VOC coatings, and greater reactivity. These companies claim that the new formulations will result in more coating use, resul ting in an overall increase in VOC emissions for a specific area covered or over t ime. Industry also asserts that more reactive solvents will be used in complia nt formulation than those used in existing coatings, thus contributing to inc reased ozone formation.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Ar chitectural Coatings, adopted by the ARB on June 22, 2000. Further revie w of these issues to ensure that District level impacts have been adequa tely assessed is beyond the scope of an Initial Study. Consequently, air q uality impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

d) Expose sensitive receptors to substantial pollut ant concentrations?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

As discussed above, the adoption and implementation of the proposed rule amendments is expected to produce substantial, long -term, VOC emission reductions. However, some companies in the archite ctural coatings industry haveAppendix C

-14- claimed that by lowering the VOC content of coating s, there will be an increase in VOC emissions for a variety of reasons including in creased coating thickness, more thinning, more topcoats, more touch-ups, more priming, more frequent recoating, more substitution with higher VOC coatings , and greater reactivity. These companies claim that the new formulations will resu lt in more coating use, resulting in an overall increase in VOC emissions for a speci fic area covered or over time. Industry also asserts that more reactive solvents w ill be used in compliant formulation than those used in existing coatings, t hus contributing to increased
ozone formation. This increase basin-wide has the potential to significantly impact sensitive populations.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Ar chitectural Coatings, adopted by the ARB on June 22, 2000. Further revie w of these issues to ensure that District level impacts have been adequa tely assessed is beyond the scope of an Initial Study. Consequently, air q uality impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

e) Create objectionable odors affecting a substanti al number of people?



# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

As a result of the change in VOC content required b y this rule change, increased application of acetone-based coatings may be necessary which has the potential to increase objectionable odors.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Ar chitectural Coatings, adopted by the ARB on June 22, 2000. Further revie w of these issues to ensure that District level impacts have been adequa tely assessed is beyond the scope of an Initial Study. Consequently, objec tionable odor impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

IV. BIOLOGICAL RESOURCES -- Would the project: a) Have a substantial adverse effect, either direct ly or through habitat modifications, on any species identified as a candi date, sensitive, or special status species in local or regional plans, policies , or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife Service? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-15- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impact exi sting plant or animal species or communities, unique or endangered plant or anima l species, or agricultural crops. Improvements in air quality from implementa tion of these rule changes are expected to provide health benefits to plant an d animal species as well as the human residents of the state. Further, the propose d amendments will not result in any new construction or increase impacts to biol ogical resources.

b) Have a substantial adverse effect on any riparia n habitat or other sensitive natural community identified in local or regional p lans, policies, regulations or by the California Department of Fish and Game or US Fi sh and Wildlife Service? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impact exi sting plant or animal species or communities, unique or endangered plant or anima l species, or agricultural crops. Improvements in air quality from implementa tion of these rule changes are expected to provide health benefits to plant an d animal species as well as the human residents of the state. Further, the propose d amendments will not result in any new construction or increase impacts to biol ogical resources.

c) Have a substantial adverse effect on federally p rotected wetlands as defined by Section 404 of the Clean Water Act (including, b ut not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t existing plant or animal species or communities, unique or endangered plant or animal species, or agricultural crops. Improvements in air quality fr om implementation of these rule changes are expected to provide health benefit s to plant and animal species as well as the human residents of the state . Further, the proposed amendments will not result in any new construction or increase impacts to biological resources.Appendix C

-16- d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nur sery sites? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t existing plant or animal species or communities, unique or endangered plant or animal species, or agricultural crops. Improvements in air quality fr om implementation of these rule changes are expected to provide health benefit s to plant and animal species as well as the human residents of the state . Further, the proposed amendments will not result in any new construction or increase impacts to biological resources.

e) Conflict with any local policies or ordinances p rotecting biological resources, such as a tree preservation policy or ordinance? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t existing plant or animal species or communities, unique or endangered plant or animal species, or agricultural crops. Improvements in air quality fr om implementation of these rule changes are expected to provide health benefit s to plant and animal species as well as the human residents of the state . Further, the proposed amendments will not result in any new construction or increase impacts to biological resources.

f) Conflict with the provisions of an adopted Habit at Conservation Plan, Natural Community Conservation Plan, or other approved loca l, regional, or state habitat conservation plan? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t existing plant or animal species or communities, unique or endangered plant or animal species, orAppendix C

-17- agricultural crops. Improvements in air quality fr om implementation of these rule changes are expected to provide health benefit s to plant and animal species as well as the human residents of the state . Further, the proposed amendments will not result in any new construction or increase impacts to biological resources.

V. CULTURAL RESOURCES -- Would the project: a) Cause a substantial adverse change in the signif icance of a historical
resource as defined in 15064.5? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t cultural resources since the proposed amendments will not result in any new construction or increase existing impacts to such resources.

b) Cause a substantial adverse change in the signif icance of an archaeological resource pursuant to 15064.5? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t cultural resources since the proposed amendments will not result in any new construction or increase existing impacts to such resources.

c) Directly or indirectly destroy a unique paleonto logical resource or site or unique geologic feature? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings. The i mplementation of this rule change is not expected to adversely impact cultural resources since the proposedAppendix C

-18- amendments will not result in any new construction or increase existing impacts to

such resources.

d) Disturb any human remains, including those inter red outside of formal
cemeteries? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The implementation of this rule change is not expected to adversely impac t cultural resources since the proposed amendments will not result in any new construction or increase existing impacts to such resources.

VI. GEOLOGY AND SOILS -- Would the project: a) Expose people or structures to potential substan tial adverse effects, including the risk of loss, injury, or death involving: i. Rupture of a known earthquake fault, as delineat ed on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued b y the State Geologist
for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publ ication 42. 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

ii. Strong seismic ground shaking? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction and, th erefore, will not have any significant effects on geologic resources.Appendix C

-19- iii. Seismic-related ground failure, including liqu efaction? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

iv. Landslides? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

b) Result in substantial soil erosion or the loss o f topsoil? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

c) Be located on a geologic unit or soil that is un stable, or that would become unstable as a result of the project, and potentiall y result in on- or off-site landslide, lateral spreading, subsidence, liquefact ion or collapse? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings. Impl ementation of these rule changesAppendix C

-20- will not result in any construction and, therefore, will not have any significant effects on geologic resources.

d) Be located on expansive soil, as defined in Tabl e 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

e) Have soils incapable of adequately supporting th e use of septic tanks or alternative wastewater disposal systems where sewer s are not available for the disposal of wastewater? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not have any significant effects on geologic resources.

VII. HAZARDS AND HAZARDOUS MATERIALS -- Would the project: a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous ma terials?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in public hazards an d environmental impacts due to potential additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Further, the reformulation of coatings to utilize a cetone could result in hazardous impacts due to its flammability. Althoug h the California ARB has analyzed these issues in a Tier I Environmental Imp act Report prepared for the statewide SCM for Architectural Coatings, adopt ed by the ARB on June 22, 2000. Further review of these issues to ensure that District level impacts have been adequately assessed is beyond theAppendix C

-21- scope of an Initial Study. Consequently, public an d environmental hazard impacts will be analyzed in a Tier II EIR prepared for proposed amendments

to Rule 67.0.

b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident condition s involving the release of
hazardous materials into the environment?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in public hazards an d environmental impacts due to potential additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Further, the reformulation of coatings to utilize a cetone could result in hazardous impacts due to its flammability. Althoug h the California ARB has analyzed these issues in a Tier I Environmental Imp act Report prepared for the statewide SCM for Architectural Coatings, adopt ed by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, public hazard impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in public hazards an d environmental impacts due to potential additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Further, the reformulation of coatings to utilize a cetone could result in hazardous impacts due to its flammability. Althoug h the California ARB has analyzed these issues in a Tier I Environmental Imp act Report prepared for the statewide SCM for Architectural Coatings, adopt ed by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, hazardous emission impacts wi ll be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67. 0.Appendix C

-22- d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962. 5 and, as a result, would it create a significant hazard to the public or the environment?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in public hazards an d environmental impacts due to potential additional vehicle trips caused by the disposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Further, the reformulation of coatings to utilize a cetone could result in hazardous impacts due to its flammability. Althoug h the California ARB has analyzed these issues in a Tier I Environmental Imp act Report prepared for the statewide SCM for Architectural Coatings, adopt ed by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, public hazard impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airp ort or public use airport, would the project result in a safety hazard for peo ple residing or working in the project area? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not create a safety hazard associated with development near an a irport.

f) For a project within the vicinity of a private a irstrip, would the project result in a safety hazard for people residing or working in t he project area? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not create a safety hazard associated with development near an a irport.Appendix C

-23- g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes will not result in any construction an d, therefore, will not interfere with emergency response plans.

h) Expose people or structures to a significant ris k of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized
areas or where residences are intermixed with wildl ands? 

#  Potentially Significant Impact 

# Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Implementation of these rule changes could result in the reformulation of c oatings to utilize acetone could result in hazardous impacts due to its flamma bility. However, proper use and/or storage of this coatings regulated under this rule will not result in an increase in a significant risk of loss, injury o r death involving wildland fires, including where wildlands are adjacent to urbanized areas or where
residences are intermixed with wildlands.

VIII. HYDROLOGY AND WATER QUALITY -- Would the project: a) Violate any water quality standards or waste dis charge requirements?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:
Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond theAppendix C

-24- scope of an Initial Study. Consequently, water qua lity impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

b) Substantially deplete groundwater supplies or in terfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby wells would drop to a level whi ch would not support existing land uses or planned uses for which permit s have been granted)?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, groundwater impacts will be a nalyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

c) Substantially alter the existing drainage patter n of the site or area, including through the alteration of the course of a stream or river, in a manner that

would result in substantial erosion or siltation on - or off-site? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction that will alter drainage patterns or a course of a stream or river, therefore, will not have any significant water quality
effects.

d) Substantially alter the existing drainage patter n of the site or area, including through the alteration of the course of a stream or river, or substantially
increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-25- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction that will incre ase the rate or amount of surface runoff, therefore, will not have any signif icant flooding effects.

e) Create or contribute runoff water which would ex ceed the capacity of existing or planned stormwater drainage systems or provide s ubstantial additional sources of polluted runoff? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction that will excee d the capacity of stormwater drainage systems, therefore, will not have any sign ificant polluted runoff
effects.

f) Otherwise substantially degrade water quality?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:
Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the ARB has already analyzed these issues in the Tier I Environmental I mpact Report prepared for the statewide SCM for Architectural Coatings, adopt ed by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, water quality impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

g) Place housing within a 100-year flood hazard are a as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map o r other flood hazard delineation map? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-26- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The amendments to this rule will not result in any construction, and therefore will not create a flood hazards.

h) Place within a 100-year flood hazard area struct ures which would impede or
redirect flood flows? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The amendments to this rule will not result in any construction, and there fore will not create a flood

hazards.

i) Expose people or structures to a significant ris k of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or
dam? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The amendments to this rule will not result in any construction, and there fore will not create a flood

hazards.

j) Inundation by seiche, tsunami, or mudflow? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The amendments to this rule will not result in any construction, and there fore will not create an

inundation hazard.

IX. LAND USE AND PLANNING -- Would the project: a) Physically divide an established community? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-27- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The amendments to this rule will not result in any construction, and there fore will not physically divide an established community.

b) Conflict with any applicable land use plan, poli cy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ord inance) adopted for the purpose of avoiding or mitigating an environmental effect? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to land use and planning are anticipated.

c) Conflict with any applicable habitat conservatio n plan or natural community conservation plan? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to conservation plans are anticipated.

X. MINERAL RESOURCES -- Would the project: a) Result in the loss of availability of a known mi neral resource that would be of value to the region and the residents of the state? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-28- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to mineral resources are anticipated.

b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, s pecific plan or other land use plan? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no impacts to mineral resources are anticipated.

XI. NOISE -- Would the project result in: a) Exposure of persons to or generation of noise le vels in excess of standards established in the local general plan or noise ordi nance, or applicable standards of other agencies? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

b) Exposure of persons to or generation of excessiv e groundborne vibration or groundborne noise levels? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-29- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

c) A substantial permanent increase in ambient nois e levels in the project vicinity above levels existing without the project? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airp ort or public use airport, would the project expose people residing or working in the project area to
excessive noise levels? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No ImpactAppendix C

-30- Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

f) For a project within the vicinity of a private a irstrip, would the project expose people residing or working in the project area to e xcessive noise levels? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed amendments will not result in any new construction or the addition of any new equipment to existing facilities. Any new activity associated with the amendments will occur in existing facilities. Ther efore, no noise impacts are anticipated.

XII. POPULATION AND HOUSING -- Would the project: a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectl y (for example, through extension of roads or other infrastructure)? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed project is not expected to increase the need for infrastructur e improvement. Therefore, no housing impacts are anticipated.

b) Displace substantial numbers of existing housing , necessitating the construction of replacement housing elsewhere? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings. The p roposed project is not expectedAppendix C

-31- to increase the need for infrastructure improvement . Therefore, no housing impacts are anticipated.

c) Displace substantial numbers of people, necessit ating the construction of replacement housing elsewhere? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . The proposed project is not expected to increase the need for infrastructur e improvement. Therefore, no housing impacts are anticipated.

XIII. PUBLIC SERVICES a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered gov ernmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in o rder to maintain acceptable service ratios, response times or other performance service ratios, response times or other performance objectives for any of the public services: i. Fire protection? ii. Police protection?
iii. Schools?

iv. Parks? v. Other public facilities?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule presents the potential for increa sed maintenance at public facilities and increased need for fire protection d ue to use of exempt solvents or other replacement solvents from implementing the proposed rule amendments. Although the California ARB has analyz ed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, adopted by the ARB on June 22, 2000. Further
review of these issues to ensure that District leve l impacts have been adequately assessed is beyond the scope of an Initi al Study. Consequently, public utility impacts will be analyzed in a Tier I I EIR prepared for proposed

amendments to Rule 67.0.Appendix C

-32- XIV. RECREATION a) Would the project increase the use of existing n eighborhood and regional parks or other recreational facilities such that su bstantial physical deterioration of the facility would occur or be acc elerated? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project is not expected to create addi tional demand on existing or proposed recreational facilities because it does not require facility expansion.

b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might ha ve an adverse physical
effect on the environment? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project is not expected to create addi tional demand on existing or proposed recreational facilities because it does not require facility expansion.

XV. TRANSPORTATION/TRAFFIC -- Would the project: a) Cause an increase in traffic which is substantia l in relation to the existing traffic load and capacity of the street system (i.e ., result in a substantial increase in either the number of vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in Transportation/Ci rculation impacts due to potential additional vehicle trips caused by the di sposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Although the California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Architect ural Coatings, adopted by the ARB on June 22, 2000. Further review of these issu es to ensure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, traffic impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.Appendix C

-33- b) Exceed, either individually or cumulatively, a l evel of service standard established by the county congestion management age ncy for designated roads or highways?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in Transportation/Ci rculation impacts due to potential additional vehicle trips caused by the di sposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. Although the California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Architect ural Coatings, adopted by ARB on June 22, 2000. Further review of these issu es to ensure that District level impacts have been adequately assessed is beyo nd the scope of an Initial Study. Consequently, traffic impacts will be analy zed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

c) Result in a change in air traffic patterns, incl uding either an increase in traffic levels or a change in location that results in subs tantial safety risks? 

#  Potentially Significant Impact 

# Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule could result in Transportation/Ci rculation impacts due to potential additional vehicle trips caused by the di sposal of coatings due to the possibility of shorter shelf or pot lives or lesser freeze-thaw capabilities. However, these impacts are expected to occur to gro und transportation, with minimal increases, if any, to air traffic patterns. As such the impact to air traffic patterns, including either an increase in t raffic levels or a change in location that results in substantial safety risks, is less than significant.

d) Substantially increase hazards due to a design f eature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g. , farm equipment)? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings. Comp liance with this rule will not result in any construction or new road design featu res and, therefore, will not
create additional traffic hazards.Appendix C

-34- e) Result in inadequate emergency access? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction or new roa d design features and, therefore, will not create inadequate emergency acc ess.

f) Result in inadequate parking capacity? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction or new road des ign features and, therefore, will not create inadequate parking capacity.

g) Conflict with adopted policies, plans, or progra ms supporting alternative transportation (e.g., bus turnouts, bicycle racks)? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction or new roa d design features and, therefore, will not conflict with policies regardin g alternative transportation.

XVI. UTILITIES AND SERVICE SYSTEMS -- Would the project: a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No ImpactAppendix C

-35- Discussion/Explanation:
Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, wastewater treatment impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rul e 67.0.

b) Require or result in the construction of new wat er or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:
Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, wastewater treatment impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rul e 67.0.

c) Require or result in the construction of new sto rm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

The proposed project consists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings . Compliance with this rule will not result in any construction of any kin d, including storm water drainage facilities, therefore, will not have any s ignificant environmental
effects.Appendix C

-36- d) Have sufficient water supplies available to serv e the project from existing entitlements and resources, or are new or expanded entitlements needed?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, water supply impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0.

e) Result in a determination by the wastewater trea tment provider, which serves or may serve the project that it has adequate capac ity to serve the project’s projected demand in addition to the provider’s exis ting commitments?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

Increased water demand from the manufacturing and u se of complaint waterborne coatings, the use of exempt solvents (solvent s not considered to be VOCs, such as acetone and Oxsol 100) and water qual ity impacts from future compliant water-borne coatings associated with manu facturing and cleanup practices could involve environmental impacts. Alth ough the California ARB has analyzed these issues in a Tier I Environmental Impact Report prepared for the statewide SCM for Architectural Coatings, a dopted by the ARB on June 22, 2000. Further review of these issues to e nsure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently, wastewater treatment impacts will be analyzed in a Tier II EIR prepared for proposed amendments to Rul e 67.0.

f) Be served by a landfill with sufficient permitte d capacity to accommodate the project’s solid waste disposal needs?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No ImpactAppendix C

-37- Discussion/Explanation:

The proposed rule change could involve potential im pacts from increased disposal of compliant coatings due to the possibility of shorte r shelf or pot lives or lesser freezethaw capabilities and increased water demand from t he manufacturing and use of compliant water-borne coatings. Although the Calif ornia ARB has analyzed these issues in a Tier I Environmental Impact Report prep ared for the statewide SCM for Architectural Coatings, adopted by the ARB on June 22, 2000. Further review of these issues to ensure that District level impacts have b een adequately assessed is beyond the scope of an Initial Study. Consequently, landf ill capacity impacts will be analyzed in a Tier II EIR prepared for proposed amendments to R ule 67.0.

g) Comply with federal, state, and local statutes a nd regulations related to solid waste?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

The proposed rule change could involve potential im pacts from increased disposal of compliant coatings due to the possibility of shorte r shelf or pot lives or lesser freezethaw capabilities and increased water demand from t he manufacturing and use of compliant water-borne coatings. Although the Calif ornia ARB has analyzed these issues in a Tier I Environmental Impact Report prep ared for the statewide SCM for Architectural Coatings, adopted by the ARB on June 22, 2000. Further review of these issues to ensure that District level impacts have been adequately assessed is beyond the scope of an Initial Study. Consequently , solid waste impacts will be analyzed in a Tier II EIR prepared for proposed ame ndments to Rule 67.0.

XVII. MANDATORY FINDINGS OF SIGNIFICANCE --: a) Does the project have the potential to degrade t he quality of the environment, substantially reduce the habitat of a fish or wildl ife species, cause a fish or wildlife population to drop below self-sustaining levels, th reaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? 

#  Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

# No Impact

Discussion/Explanation:

As discussed in the sections regarding Biological R esources, Cultural, and Paleontological Resources, the proposed project con sists of amendments to the APCD Rule 67.0, which limits the amount of VOCs in architectural coatings. The implementation of these rule changes will not degra de the quality of the environment and will not substantially reduce the habitat of a fish or wildlife species. The project will not cause a fish or wildlife population to dro p below self-sustaining levels and willAppendix C

-38- not threaten to eliminate a plant or animal communi ty. Also, the project would not reduce the number or restrict the range of a rare o r endangered plant or animal and will not eliminate important examples of the major periods of California history or prehistory.

b) Does the project have impacts that are individua lly limited, but cumulatively considerable? (“Cumulatively considerable” means th at the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effe cts of probable future projects)?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

As a result of the possible adverse effects possibl e adverse effects on air quality, water resources, hazards, transportation/circulatio n, hazardous wastes, and public utilities/serves, the proposed project has t he potential to adversely affect the quality of the environment. There may be adver se human health impacts associated with exposure to both carcinogenic and n on-carcinogenic toxic air contaminants (TACs). These impacts may occur indiv idually, such as elevated exposure to TACs, or cumulatively, if different env ironmental impacts reinforce

each other.

The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Architect ural Coatings, adopted by the ARB on June 22, 2000. However, further review of t hese issues to ensure that District level impacts have been adequately assesse d is required. As such, a Tier II Environmental Impact Report should be prepared to a ssess local impacts from the

Rule 67.0 amendments.

c) Does the project have environmental effects, whi ch will cause substantial adverse effects on human beings, either directly or indirec tly?

# Potentially Significant Impact 

#  Less than Significant Impact



#  Less than Significant Impact with Mitigation Incorporated 

#  No Impact

Discussion/Explanation:

As a result of the possible adverse effects possibl e adverse effects on air quality, water resources, hazards, transportation/circulatio n, hazardous wastes, and public utilities/serves, the proposed project has the pote ntial to adversely affect the quality of the environment. There may be adverse h uman health impacts associated with exposure to both carcinogenic and n on-carcinogenic toxic air contaminants (TACs). These impacts may occur indiv idually, such as elevated exposure to TACs, or cumulatively, if different env ironmental impacts reinforce

each other.Appendix C

-39- The California ARB has analyzed these issues in a T ier I Environmental Impact Report prepared for the statewide SCM for Architect ural Coatings, adopted by the

ARB on June 22, 2000. However, further review of t hese issues to ensure that District level impacts have been adequately assesse d is required. As such, a Tier II Environmental Impact Report should be prepared to a ssess local impacts from the

Rule 67.0 amendments.