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 Specialist 

San Diego County Air Pollution Control District 

9150 Chesapeake Drive 

San Diego, CA 92123-1096 

(858) 650-4670 
Table 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 Mitigation 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” Alternative.................. 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 Regional and General 

Plans ......................................................................................................1-5
Table 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) Exemption.....................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 Project” 

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 Deadlines” 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 Project ...........4-5

4.3.3 - Staff’s Rationale for Rejection of the “Extended 

Compliance Deadlines” Alternative.....................................................4-7
Table of Contents 

iii 

4.4 - Analysis of the “Further Reduction of VOC Content Limits”

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

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

4.4.2 - Comparison of the Effects of the “Further Reduction 

of VOC Content Limits” Alternative to the Proposed Project ...........4-7

4.4.3 - Staff’s Rationale for Rejection of the “Further 

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 Changes 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 of 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 Initial Study.....................6-21
Table 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 ENVIRONMENTAL 

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 Responses
Summary 

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 Suggested Control Measure (SCM) for 

Architectural Coatings, approved by the California Air Resources Board (ARB) on June 

22, 2000. The SCM sets allowable VOC content limits and other requirements that are 

feasible (based on existing and currently developing coating technologies) and that will 

achieve significant reductions in VOC emissions from architectural coatings. 

Prior to approving the SCM, ARB prepared and certified a Programmatic Environmental 

Impact Report (PEIR). San Diego County APCD staff has reviewed and considered 

ARB’s PEIR, including the technical analyses, comments, and responses to comments, 

and concur with the methodologies and determinations made therein. Accordingly, this 

analysis incorporates the ARB PEIR by reference. Relevant sections of the ARB PEIR 

are summarized as appropriate throughout this EIR.1

Project Objectives

The purpose of the project is to reduce VOC emissions by incorporating lower VOC 

limits and other requirements for architectural coatings without significantly diminishing 

usability of the coatings in question. The emission 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 revisions 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 unincorporated portions of San Diego 

County, the southwestern-most county in the State of 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 County, on the west by the Pacific 

Ocean, and on the south by the State of Baja California 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 and position of the semi-permanent highpressure system over the Pacific Ocean (known as the Pacific High). The favorable 

 

1

 The ARB PEIR, and all its supporting documents, are 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 pollution problems. Sinking, or subsiding 

air from the Pacific High creates a temperature inversion (known as a subsidence 

inversion), which acts as a lid to vertical dispersion of pollutants. Weak summertime 

pressure gradients further limit horizontal dispersion of pollutants in the mixed layer 

below the subsidence inversion. Poorly dispersed anthropogenic 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 for criteria pollutants, which are 

widespread common pollutants known to be harmful to human health and welfare. 

Standards are set to protect the elderly, very young, and chronically sensitive portions of 

our population. Areas not meeting a particular standard 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 regulated by ARB, only ozone 

(smog) and inhalable particulate matter (PM10) occur in concentrations sufficient to 

violate either federal or state standards in San Diego County. 

San Diego County has experienced substantial improvement in ambient ozone levels over 

the past several years. The number 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. 

Summary of Significant Environmental Effects and Mitigation Measures 

that Reduce the Significant Effects 

San Diego County APCD staff has reviewed and considered the PEIR prepared by ARB, 

including the technical analyses, and concurs with the methodologies and determinations 

made therein. Further, APCD staff has considered the 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 potentially significant adverse effect 

on any resource area. A discussion and analysis for each of the resource area impacts 

identified in the Initial Study/Environmental Analysis as requiring further analysis, but 

determined during the EIR process to be less than significant, is discussed in Section 6.1 

of this document. 

Project Alternatives 

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

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

the reasons for their dismissal as feasible alternatives, 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 included in the proposed Rule 67.0 

amendments analyzed in this EIR. The three remaining feasible alternatives discussed in 
Summary 

S-3 

the ARB Final PEIR were also considered feasible for 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 proposed revisions to Rule 67.0 would not 

be implemented, and that the VOC limits in the current 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 throughout the project area. This scenario 

would potentially jeopardize the ability of the region to expeditiously attain and maintain 

the state ozone standard. However, implementation of the “No Project” Alternative 

impacts to other resource areas would remain at existing 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 revisions to Rule 67.0, which are needed 

by the APCD to achieve the mandated state and federal 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 affected coatings would be identical to 

those in the current version of the proposed revisions to Rule 67.0. APCD staff does not 

support this alternative since the VOC limits in the proposed rule are feasible by 

January 1, 2003 (January 1, 2004 for Industrial Maintenance 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. Based on all the information received by 

APCD staff to date, such a delay is not warranted. 

“Further Reduction of VOC Content Limits” Alternative

This alternative would further reduce the VOC content limits for affected coatings 

categories (adoption of the “final” limits as described in Table 1 of Appendix C of the 

Notice Of Preparation/Initial Study for the ARB PEIR; see Appendix B of the ARB Final 

PEIR). The other proposed changes in the current proposed version of Rule 67.0 would 

be maintained. Alternative C, “Further Reduction of VOC Content Limits” Alternative, 

is not recommended by APCD staff because it would require the APCD focus limited 

staff resources on the technical, environmental, and economic issues associated with 

adoption of interim limits. Based on the information and analyses in this EIR and the 

ARB Final PEIR, APCD staff has concluded that the proposed 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 standard. 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 emission reductions. 
Summary 

S-4 

Areas of Controversy 

The adoption and implementation of the proposed rule amendments is expected to 

produce substantial, long-term, VOC emission reductions, without resulting in any 

significant, adverse environmental impacts. As required 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 amendment. 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 not 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 use, resulting in an overall 

increase in VOC emissions for a specific area covered or over time; 

• More reactive solvents will be used in compliant formulation than those used in 

existing coatings, thus contributing to increased ozone formation; 

• The proposed rule could result in public hazards and 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 could result in hazardous impacts 

due to its flammability; 

• Increased water demand from the manufacturing and use of compliant waterborne coatings, the use of exempt solvents (solvents not considered to be VOC, 

such as acetone and Oxsol 100) and water quality impacts from future compliant 

water-borne coatings associated with manufacturing and cleanup practices could 

involve environmental impacts. 

• The proposed rule could result in Transportation/Circulation 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. 

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

staff has reviewed and considered ARB's technical analyses 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 environmental effects (State CEQA 

Guidelines, §15123(b)(3)). No significant and mitigated, or significant unmitigated 
Summary 

S-5 

impacts have been identified from either the proposed project, or any of the three 

identified, feasible alternatives. However, APCD staff has reviewed the alternatives and 

believes that the proposed project is the environmentally superior alternative and the only 

alternative which adequately meets the project goals 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 (attached as Appendix A). Amended 

Rule 67.0 would apply to any person who supplies, sells, offers for sale, or manufactures 

an architectural coating for use, as well as any person 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 the incorporated and the 

unincorporated portions of San Diego County, the southwestern-most county in the State 

of California (Figure 1-1). 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 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 applied to stationary structures and their 

accessories (usually for beautification and protection) and include such coatings as house 

paints, stains, varnishes, industrial maintenance coatings, and traffic marking coatings. 

When applied, the solvents in the coatings evaporate 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 “Serious” nonattainment area for the 

State ambient air quality standard for ozone. 

The proposed Rule 67.0 amendments incorporate VOC limits and other requirements 

contained in the Suggested Control Measure (SCM) for Architectural Coatings, approved 

by ARB on June 22, 2000. The SCM is largely consistent with the U.S. EPA’s National 

Volatile Organic Compound Emission Standards for Architectural Coatings. The SCM 

sets allowable VOC content limits and other requirements that are feasible (based on 

existing and currently developing coating technologies) and that will achieve significant 

reductions in VOC emissions from architectural coatings. Local implementation would 

reduce VOC emissions in San Diego County by an estimated 1.5 tons per day. 

Amended Rule 67.0 would continue to apply to any person 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 lower the VOC content limit for a 

number of architectural coating categories 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, 2003 (January 1, 2004, for industrial maintenance 

coatings.) 

The lowered VOC limits are consistent with the corresponding limits in the SCM and 

pertain to clear wood coatings (lacquers and sanding sealers); high temperature coatings; 

industrial maintenance coatings; magnesite cement coatings; multi-color coatings; pre-
Project Description & Environmental Setting 

 1-2

treatment wash primers; primers sealers and undercoaters; quick dry enamels; quick-dry 

primers, sealers, and undercoaters; roof coatings; stains; swimming pool coatings; 

swimming pool repair and maintenance coatings; traffic marking coatings (indicated as 

traffic paints in existing rule 67.0); waterproofing sealers; and wood preservatives. 

Added coating categories include flat, nonflat-high gloss, antenna, antifouling, 

bituminous roof, bituminous roof primers, clear brushing lacquer, faux finishing, fire 

resistive, floor, flow (electrical transformers), lowsolids, recycled, rust preventative, 

temperature-indicator safety coatings, and waterproofing concrete/masonry sealers. 

Provisions for product-line averaging are included in the proposed rule amendments 

(consistent with the SCM), allowing manufacturers to average designated coatings such 

that their actual statewide cumulative emissions from 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 year. The averaging provision will 

only be in effect from January 1, 2003, until January 1, 2005. VOC ceilings (maximum 

allowable VOC content limits) are applicable when averaging. Ceiling limits would 

protect against regional differences that could result in high VOC products being sold in 

San Diego. 

Proposed Rule 67.0 amendments do not include the SCM provision pertaining to 

petitioning the Air Pollution Control Officer to allow application of an industrial 

maintenance coating with a VOC content up to 340 grams per liter, since that provision 

only applies to the North Central Coast, San Francisco Bay Area, and the North Coast Air 

Basins. 

1.2 - Project Objectives

The purpose of the project is to reduce VOC emissions by incorporating lower VOC 

limits and other requirements for architectural coatings without significantly diminishing 

usability of the coatings in question. These emission 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 proposed 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 Environmental Quality Act (CEQA), an 

Environmental Impact Report (EIR) must identify the potentially environmental effects 

that may result from implementation of a proposed project. 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 should include, but is not limited to, 

the resources involved; physical changes; alterations of ecological systems; health and 

safety problems caused by physical changes; and other aspects of the resource base, 

including water, scenic quality, and public services. If the lead agency identifies 

potentially significant adverse environmental impacts, the EIR must discuss mitigation 
Project Description & Environmental Setting 

 1-3

measures that could either avoid or substantially reduce any adverse environmental 

impacts. 

The degree of specificity required in a CEQA document depends on the type of project 

being proposed. For example, the environmental document for projects such as the 

adoption or amendment of a comprehensive zoning ordinance or a local general plan 

should focus on the secondary effects that can be expected to follow from the adoption or 

amendment. However, the analysis need not be as detailed as the analysis of the specific 

construction projects that might follow. The CEQA and the State CEQA Guidelines 

establish the categories of environmental impacts that should generally be evaluated. The 

CEQA Guidelines include a checklist for use by public agencies, which lists 16, specific 

environmental categories, which should be addressed when determining whether to 

prepare an EIR. This checklist is known as an Initial Study/Environmental Analysis 

(IS/EA) and is intended to provide sufficient information 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 preparing it’s Draft PEIR. 

San Diego County APCD staff reviewed 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 (NOP) to responsible and trustee agencies, along with a brief summary of 

the potential environmental effects of the rule adoption and a copy of the IS/EA. The 

NOP and associated documents are included as Appendix B of this document. Of the 16 

potential environmental impact categories on the checklist, APCD determined that an 

EIR should be prepared to address potential adverse effects on the following 

environmental categories: air quality, water, public 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 the 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 contiguous with the political boundaries 

of San Diego County. The County of San Diego encompasses approximately 4,260 
Project 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 Ocean, 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 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 highest point in the 

county. The coastal region is made up of coastal terraces that rise from the ocean into 

wide mesas which then, moving farther east, transition 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 Desert, which is characterized by several 

broken mountain ranges with desert valleys in between. To the north of the county are 

the Santa Ana Mountains which run along the coast of Orange County, 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 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 early-morning low clouds, hazy afternoon 

sunshine, daytime onshore breezes, and little temperature variation year-round. The 

climatic classification for San Diego is a Mediterranean climate, with warm, dry summers 

and mild, wet winters. Average annual precipitation ranges from approximately 10 

inches on the coast to over 30 inches in the mountains 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 create air pollution problems. Sinking, 

or subsiding air from the Pacific High creates a temperature inversion, known as a 

subsidence inversion, which acts as a lid to vertical dispersion of pollutants. Weak 

summertime pressure gradients further limit horizontal 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 nighttime offshore flow (i.e., land breeze) are 

quite common in Southern California. The sea breeze helps to moderate daytime 

temperatures in the western portion of San Diego County, which greatly adds to the 

climatic draw of the region. This also leads to emissions being blown out to sea at night 

and returning to land the following day. Under certain conditions, this atmospheric 

oscillation results in the offshore transport of air from the Los Angeles region to San 

Diego County, which often results in high ozone concentrations being measured at San 

Diego County air pollution monitoring stations. Transport of air pollutants from 

Los Angeles to San Diego has also been shown to occur 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 for 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 young, and chronically sensitive portions of 

our population. Areas not meeting a particular standard are referred to as a nonattainment area for the pollutant. Of the six air pollutants regulated by the federal 

Environmental Protection Agency, and eight regulated by ARB, only ozone (smog) and 

inhalable particulate matter (PM10) occur in concentrations sufficient to violate either 

federal or state standards in San Diego County. 

San Diego County has experienced substantial improvement in ambient ozone levels over 

the past several years. The number 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 PM10 (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. 

1.4.1 - Consistency of Project with Applicable Regional and General 

Plans 

CEQA Guidelines §15125(d) states that “[t]he EIR shall 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 plans, regional housing allocation plans, 

habitat conservation plans, natural community conservation 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 discussion 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 would not directly 

result in the need for new development and does not propose any 

development in San Diego County. As such, the proposed project is 

consistent with the San Diego County General Plan and the San Diego 

County Zoning Ordinance. 

Consistency with Regional Air Quality Plans 

The primary purpose of the APCD’s adopted air quality 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 identified in the RAQs as a feasible 

emission control measure. Thus, the Rule 67.0 amendments are consistent with the 

regional air quality plans. 
Project Description & Environmental Setting 

 1-6

Consistency with Regional Transportation Plans (RTPs) 

Since no significant adverse impacts to transportation/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 County’s General Plan. While some 

companies in the architectural coatings industry have asserted that some traffic and 

congestion may be generated from the disposal of small quantities of architectural 

coatings due to shelf life, pot-life, and freeze-thaw problems, APCD analysis contained 

here indicates any such effects would be negligible and would not create significant 

adverse impacts to transportation/circulation. Furthermore, 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 create or cause the need for additional 

housing in the project area. Furthermore, the revised rule would not affect how housing 

is planned or allocated within the project area. Therefore, the revised rule is considered 

to be consistent with Housing Element of the San Diego County General Plan. 

Consistency with Habitat Conservation Plans and Natural Community 

Conservation Plans 

Implementation of revised Rule 67.0 would not result in new construction or activities 

that would create or cause impacts to sensitive habitats of plants or animals. Since 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 VOC, the project will have a positive impact on 

plant and animal life through the reduction of regional ozone levels. Therefore, the 

revised rule is considered to be consistent with the Conservation Element of the San 

Diego County General Plan, as well as the County’s Multiple Species Conservation 

Program, and the Natural Communities Conservation Program. 

Consistency with the Regional Water Quality Control Board, San Diego 

Region Basin Plan 

Implementation of revised Rule 67.0 would not result in an increase in impacts to the 

quality of water resources in San Diego County. The 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 Sett

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Figure 1-1: Project Location Map 

Pacific Ocean

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Project Location Map
Significant Environmental Effects 

 2-1

CHAPTER 2.0 - SIGNIFICANT ENVIRONMENTAL EFFECTS 

As indicated in Chapter 1, San Diego County APCD staff 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 responsible 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 environmental impact categories on the IS/EA 

checklist, APCD determined that an EIR should be prepared to address potential adverse 

effects on the following environmental categories: air quality, water, public services, 

transportation/circulation, solid waste/hazardous waste, hazards, irreversible 

environmental changes, potential growth inducing impacts, and consistency with other 

plans. 

Based on the San Diego County EIR Format and Content Guidelines, Chapter 2 should 

provide a “detailed discussion of those subject areas 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 concluded to be not significant after 

analysis during the EIR process are discussed in Section 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 initial study process as clearly insignificant 

and unlikely to occur are included in Section 6.2. 

San Diego County APCD staff has reviewed and considered the Final Programmatic EIR 

(PEIR) prepared by ARB (adopted by reference herein) and concurs with the 

methodologies and determinations made therein. Further, APCD staff has considered the 

technical analyses (adopted by reference herein) referred to in the ARB PEIR for 

applicability to the conditions here in San Diego County, 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 resource area. A brief discussion and 

summary analysis for each of the resource area impacts identified in the IS/EA as 

requiring further analysis but determined, during the APCD EIR process, to be less than 

significant is discussed in Section 6.1 of this document. 
Cumulative Impacts 

 3-1

CHAPTER 3.0 - CUMULATIVE IMPACTS 

Section 15130 of the State CEQA Guidelines states that, “an EIR shall discuss 

cumulative impacts of a project when the project’s incremental effect is cumulatively 

considerable.” Further, the Guidelines state “where a lead agency is examining a project 

with an incremental effect that is not “cumulatively 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 not result in part from the project 

evaluated in this EIR.” 

As discussed in Chapter 1, the architectural coatings rule is included in the APCD’s 

Regional Air Quality Strategy (RAQS), which outlines 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 architectural 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 amendments 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 further 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 basic objectives of the project but would 

avoid or substantially lessen any of the significant effects of the project, and an 

evaluation of the comparative merits of the alternatives. CEQA also requires 

consideration of a reasonable range of potentially feasible alternatives; it does not require 

consideration of alternatives that are not reasonable. The discussion and analyses of 

project alternatives presented below are consistent with the analyses of project 

alternatives in the ARB Final PEIR, which APCD staff 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 effects of each alternative may be used to 

summarize the comparison. Table V-4 (page V-172) in 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 matrix that lists the significant adverse 

impacts as well as the cumulative impacts associated with the proposed project and the 

project alternatives for all the environmental topics analyzed. The table also ranks each 

impact section as to whether the proposed project or a project alternative would result in 

greater or lesser impacts relative to on another. 

The ARB Final PEIR included an evaluation of four feasible 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 included 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 ARB 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 and the reasons for their dismissal as 

feasible alternatives and agrees with the determination. The project objectives as 

identified in Section 1.2 is to reduce VOC emissions by incorporating lower VOC limits 

and other requirements for architectural coatings without significantly diminishing 

usability of the coatings in question. The following is a brief description of alternatives 

and a discussion of why these alternatives were found to be infeasible for the project area. 
Project Alternatives 

 4-2

4.1.1 - Performance-Based Standards 

Rather than establish lower VOC content requirements 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 standards to cover the multitude of 

coatings reformulations with varying performance characteristics. 

4.1.2 - Seasonal Regulation 

Under this alternative, the VOC content limits proposed 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-yourself consumers could use coatings with 

higher VOC contents. 

This alternative was found infeasible for the project area because it is too difficult to 

implement and enforce. It would be difficult for coatings 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 enforcement of these requirements at 

the end-user level would be difficult and would require significant additional 

enforcement resources. In addition, there have been State violations (“high ozone”) in all 

months of the year except January, based on data since 1995. As such, identifying 

specific seasonal duration would be difficult, at best. 

4.1.3 - Regional Regulation 

Under this alternative, areas within the region that do not have an ozone problem or 

contribute to the region’s ozone problem would be exempted from the VOC requirements 

of Rule 67.0. This alternative was rejected as infeasible for two main reasons. First, in 

order to determine the viability of such an approach, the APCD would have to conduct an 

extensive analysis involving ambient air quality modeling to determine which 

geographical areas would be subject to the lower VOC 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 the determination of those geographical 

areas. In addition, there have been state ozone violations throughout the area. 

Secondly, even if a reliable technical determination could be made regarding the 

geographical areas, the problem of enforcing this regulatory approach remains. 

Enforcement at the retail level, as well as the end-user level would be difficult and would 

require significant additional enforcement resources, as identified in the “Seasonal 

Regulation” alternative. 
Project Alternatives 

 4-3

4.1.4 - Exceedance Fees 

This alternative would allow purchases of noncompliant coatings on payment of a fee, 

similar to the system that exists in the national Architectural and Industrial Maintenance 

(AIM) coatings rule. The system used in the national AIM rule allows coatings 

manufacturers and importers to sell coatings that exceed the applicable VOC limit if they 

pay a fee of $0.0028 per gram of excess VOC. Essentially, this is a “pay-to-pollute” 

approach. APCD does not support such an approach because it does nothing to bring the 

air into compliance with state standards and may actually hinder efforts to attain both the 

state and federal ozone standards. This type of approach could eliminate or substantially 

reduce the emission reductions expected from the proposed revisions to Rule 67.0. 

Additional problems include concern regarding whether the fee is high enough to 

discourage the manufacture and sale of high-VOC coatings, enforcement at the districtwide level, and extensive record keeping requirements. For all of these reasons, an 

exceedance fee approach is not considered a feasible alternative. 

4.1.5 - Tonnage Exemption 

As with the “Exceedance Fees” alternative, this type 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 that 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 be 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 with 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 proposed revisions to Rule 67.0. 

Additional problems include enforcement, record keeping, and reporting requirements. 

For these reasons, a tonnage exemption is not considered a feasible alternative. 

4.1.6 - Low Vapor Pressure (Low Volatility) Exemption 

Under this alternative, VOCs with low vapor pressures (i.e., “low vapor pressure VOCs” 

or “LVP-VOCs”) would be exempted as VOCs in determining the overall VOC content 

of a coating. This type of exemption is based on an 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 atmosphere. 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 reasoning behind this determination, the 

reasons have not been fully summarized in this report. For an extensive explanation of 

ARB’s determination of infeasibility, the reader should reference the ARB Final PEIR, 

Pages V-142 to V-151, which APCD staff adopts by reference. The same reasons 

identified in the ARB Final PEIR are applicable to the proposed project. Staff has 

concluded that this alternative is not feasible because exempting LVP-VOCs would not 

achieve regulatory consistency, LVP-VOCs in architectural coatings will eventually 
Project 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. Historically, in the State of California and in San 

Diego County in particular, control of VOC emissions has been through mass-based 

reductions. The ARB has committed to evaluating the 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 reactivity 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 control 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. As discussed in the PEIR, additional 

data are necessary before assessing the feasibility of a reactivity-based control strategy 

for architectural coatings. Because additional reductions are needed in the near term, and 

historical data indicate mass-based controls effectively 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 revisions to Rule 67.0 would not be 

implemented, and that the existing VOC limits in Rule 67.0 would continue to apply. 

4.2.2 - Comparison of the Effects of the “No Project” Alternative to 

the Proposed Project 

As a result of the implementation of the “No Project” alternative, VOC emissions from 

architectural coatings within the project area would likely remain at the same level or 

may increase if the volume of architectural coatings used in the project area increased. As 

a result, approximately 1.5 tons per day of VOC emission reductions from architectural 

coatings would not be achieved throughout the project area. This scenario would 

potentially jeopardize the ability of the region to expeditiously attain and maintain the 

state ozone standard. However, implementation of the “No Project” Alternative would 

not create any new or additional impacts to water resources or public facilities, or create 

any new or additional hazards. Since the No Project 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 region to achieve the mandated state and 

federal ozone standards, it is not the environmentally 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” Alternative 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 to continue progress toward achieving 

the state ozone standard. 

4.3 - Analysis of the “Extended Compliance Deadlines” 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 affected coatings would be identical to 

those in the current version of the proposed revisions 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 (Alternative B) would extend the 

VOC content limits to January 1, 2004. This alternative would ultimately achieve the 

same VOC emission reductions as the SCM; however, the 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 proposed project to meet the VOC 

content limits. Therefore, this alternative would result in similar insignificant water 

demand impacts as the proposed project, but the impacts 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 proposed project to meet the VOC 

content limits. Therefore, this alternative would result in similar insignificant water 

quality impacts as the proposed project, but the impacts 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 proposed project to meet the VOC 
Project Alternatives 

 4-6

content limits. Therefore, this alternative would result in similar insignificant public 

facility maintenance impacts as the proposed project, but the impacts would occur one 

year later. 

Fire Protection 

For Alternative B, it is expected that some resin manufacturers and coatings formulators 

would use waterborne technology containing less flammable solvents. The exception to 

this would be the use of acetone in some specific coating categories. However, fire 

departments treat all NFPA 3 flammable liquids the same. Because the same replacement 

and coalescing solvents used to meet the proposed project 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 proposed project, but the impacts would 

occur one year later. 

Transportation/Circulation

For Alternative B, it is expected that the same replacement and coalescing solvents used 

to meet the proposed project VOC content limits would be used to meet the Alternative B 

VOC content limits. Thus, any additional trips associated with the potential disposal of 

reformulated low-VOC waterborne coatings due to freeze-thaw, shelf life, or pot-life 

problems would be the same as for the SCM. Therefore, Alternative B may result in 

similar insignificant transportation/circulation impacts 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 of solid waste/hazardous waste 

generated from the manufacturing, distribution, and use of architectural coatings would 

be identical to that generated by the proposed project. Therefore, Alternative B would 

result in similar insignificant solid waste/hazardous 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 manufacturers and coatings formulators 

would use waterborne technology containing less flammable solvents. The exception to 

this would be the use of acetone in some specific coating categories. However, as 

mentioned above, fire departments treat all NFPA 3 flammable liquids the same. For 

some coatings categories, more toxic but less flammable 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 conventional 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 project VOC content limits would be used 

to meet the Alternative B VOC content limits. Therefore, this alternative would result in 
Project 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 limits would be used to meet the 

Alternative B VOC content limits. However, in the context of the complaint, twocomponent, waterborne industrial maintenance systems containing some toxic 

compounds, since formulators have additional time to develop coatings, they may be able 

to formulate systems containing less toxic compounds or develop better application 

techniques to further reduce human exposure to these compounds. Therefore, Alternative 

B would result in slightly fewer human health impacts as compared to the insignificant 

health impacts of the proposed project. 

4.3.3 - Staff’s Rationale for Rejection of the “Extended 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 industrial 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 attained as expeditiously as practicable, 

and the region’s air quality problems require that any delay in achieving emission 

reductions must be technically or economically justified. 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 Content Limits” Alternative

4.4.1 - Alternative Description and Setting 

This alternative would further reduce the VOC content limits for affected coatings 

categories (adoption of the “final” limits as described in Table 1 of Appendix C of the 

NOP/IS for the ARB SCM EIR; see Appendix B of the ARB 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 Reduction of VOC 

Content Limits” Alternative to the Proposed Project

Air Quality 

The “Further Reduction of VOC Content Limits” Alternative (Alternative C) would 

implement lower VOC content limits than those included 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 limits associated with this alternative may 

require increased use of waterborne technology. However, the worst-case scenario 

analyzed in this EIR and the ARB PEIR, that all affected coatings would be reformulated 

using waterborne technology, showed that water demand impacts were insignificant for 

the proposed project. Therefore, Alternative C would result in similar insignificant water 

demand impacts. 

Water Quality

For Alternative C, the final lower VOC content limits associated with this alternative may 

require increased use of waterborne technology. However, the worst-case scenario 

analyzed in this EIR and the ARB PEIR, that all affected coatings would be reformulated 

using waterborne technology, showed that water quality impacts were insignificant for 

the proposed project. Therefore, Alternative C would result in similar insignificant water 

quality impacts. 

Public Services 

Public Facility Maintenance

For Alternative C, end-users would eventually be required to use coatings with a lower 

VOC content than those in the proposed project. However, 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 it 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 facility 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 required to reformulate all solventborne coatings containing more flammable solvents with waterborne technology 

containing less flammable solvents. Therefore, Alternative 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 freeze-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 that transportation/circulation 
Project Alternatives 

 4-9

impacts were insignificant. Therefore, Alternative C would result in similar insignificant 

transportation/circulation impacts to those associated 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 potential additional coatings landfilled as a 

result of freeze-thaw, shelf life, or pot life problems 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 would be reformulated using 

waterborne technology, found that solid waste/hazardous waste impacts were 

insignificant. Therefore, Alternative C would result in similar insignificant solid 

waste/hazardous waste impacts to those associated with 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, nonflat, and rust preventative coatings, 

resin manufacturers and coatings formulators would be replacing current coalescing 

solvents with less toxic and less flammable solvents in their waterborne formulations. 

Conversely, in the context of industrial maintenance coatings, coatings formulators would 

be incrementally increasing the use of two-component polyurethane waterborne systems 

containing toxic solvents. Therefore, when balancing the loss of solvents that are more 

toxic and more flammable against the incremental increase 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, nonflat, and rust preventative coatings, 

resin manufacturers and coatings formulators would be replacing current coalescing 

solvents with less toxic and less flammable solvents in their waterborne formulations. 

Conversely, in the context of industrial maintenance coatings, coatings formulators would 

be incrementally increasing the use of two-component polyurethane waterborne systems 

containing toxic solvents. Therefore, when balancing the loss of solvents that are more 

toxic and more flammable against the incremental increase in the use of certain coatings 

containing similar toxic solvents, Alternative C would result in similar insignificant 

human health impacts as the proposed project. 

4.4.3 - Staff’s Rationale for Rejection of the “Further Reduction of 

VOC Content Limits” Alternative 

Alternative C, “Further Reduction of VOC Content Limits” Alternative, is not 

recommended by APCD staff due to the need to focus limited staff resources on the 
Project Alternatives 

 4-10

technical, environmental, and economic issues associated with adoption of the interim 

limits. Based on the information and analyses in this EIR and the ARB Final PEIR 

adopted by reference herein, APCD staff has concluded that the proposed 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 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 Guidelines §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 additional housing, either directly or indirectly, 

in the surrounding environment.” 

Implementing revised Rule 67.0 would primarily affect 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 Changes Resultant from Project 

Implementation

CEQA Guidelines §15126(c) requires an environmental analysis to consider “any 

significant irreversible environmental changes which 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 initial and continued phases of the 

project may be irreversible since a large commitment of such resources makes removal or 

nonuse thereafter unlikely. Primary impacts and, particularly, secondary impacts (such as 

highway improvement which provides access to a previously inaccessible area) generally 

commit future generations to similar uses. Also, irreversible damage can result from 

environmental accidents associated with the project. Irretrievable commitments of 

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

The following impact areas have been evaluated in this EIR, as well as in the CARB 

Final PEIR: air quality, water, public services, transportation/circulation, solid 

waste/hazardous waste, and hazards. The analyses presented in this EIR and in the ARB 

Final PEIR adopted by reference indicate that no significant adverse project-specific or 

cumulative impacts would occur to any of these environmental areas. 

For example, the air quality impacts analysis included an evaluation of eight issues 

identified by industry regarding the potential air quality impacts of the project. After 

considering these issues, APCD staff determined that 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 from cleaning coating equipment could 

occur but that this increase would not be significant. The analysis of public services and 

transportation/circulation concluded that revised Rule 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 waste impacts resulting from some types of 

coatings that may have a shorter pot life or shorter 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 significant. The analysis of hazard impacts 

indicated that future compliant low-VOC coatings could be formulated with hazardous 

materials. However, solvents used in low-VOC coatings are typically no more hazardous 

than solvents used in conventional coatings. Therefore, hazards impacts are considered 

to be insignificant. Further, because Industrial Maintenance coatings are typically 

applied in industrial settings where safety equipment, training, and procedures are in 

place, workplace exposures to potentially hazardous coatings would be minimal. In 

addition, because architectural coatings are applied on an as-needed basis, continuous 

exposures would not occur. As a result, no significant 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 result in irreversible environmental 

changes or the irretrievable commitment of resources. 
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 of the EIR Process

As indicated in Chapter 1, San Diego County APCD staff 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 Preparation to responsible 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 environmental impact categories 

on the IS/EA checklist, APCD determined that a Draft EIR should be prepared to address 

potential adverse effects on the following environmental categories: air quality, water, 

public services, transportation/circulation, solid waste/hazardous waste, hazards, 

irreversible environmental changes, potential growth inducing impacts, and consistency 

with other plans. 

San Diego County APCD staff has reviewed and considered the PEIR prepared by ARB, 

including the technical analyses, and concurs with the methodologies and determinations 

made therein. Further, APCD staff has considered the 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 have 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 various possible significant effects of a 

project were determined not to be significant and were 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 analysis 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 ozone and PM10 (particulate matter 

less than 10 microns equivalent aerodynamic diameter). Ozone formation in the lower 

atmosphere results from a series of chemical reactions between VOC and NOx in the 

presence of sunlight. PM10 is the result of both direct and indirect emissions. Direct 

sources of PM10 include emissions from fuel combustion and wind erosion of soil. 

Indirect PM10 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 particulate matter (PM10) occur in 
Environmental Effects Found Not To Be Significant 

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concentrations sufficient to violate either federal or state standards in San Diego County. 

The efforts of the San Diego APCD are focused primarily on attainment of state and 

federal standards for these pollutants and maintaining the standards for all criteria 

pollutants. Below is a brief description of each non-attainment pollutant. 

Ozone

Ozone, the main component of photochemical smog, is primarily a summer and fall 

pollution problem. Ozone is not emitted directly into the air but is formed through a 

complex series of chemical reactions involving other compounds that are directly 

emitted. These directly emitted pollutants (also known as ozone precursors) include 

VOC and NOx. The time period required for ozone formation allows the reacting 

compounds to spread over a large area, producing a regional pollution problem. Once 

formed, ozone generally remains in the atmosphere for one or two days. Ozone is then 

eliminated through chemical reaction with plants (reacts with chemicals on the leaves of 

plants), rainout (attaches to water droplets as they fall to earth), and washout (absorbed 

by water molecules in clouds and later falls to earth with rain). 

The total contribution of VOC emissions from architectural coatings in San Diego 

County is estimated at 10.3 tons per day in 2000 (annual average). Assuming existing 

controls, the annual average VOC emissions from architectural 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, adverse air quality impacts. Air quality 

impacts will be considered significant if the proposed rule amendments would 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-site 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 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 architectural 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 prepared 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 received by ARB and ARB’s responses to 

comments. In addition, staff considered the information compiled to date through 

ongoing studies by the SCAQMD with National Technical Systems (NTS), a testing 

program by the essential public service agencies (EPSA) and an analysis of the Harlan 
Environmental Effects Found Not To Be Significant 

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Associates Study prepared by Stan Cowen of the Ventura County Air Pollution Control 

District.2 The analysis and discussion in this EIR also consider the following update of 

the studies prepared since certification of the ARB PEIR. 

SCAQMD Phase II Assessment Study of Architectural Coatings (NTS)

In 1998, the South Coast Air Quality Management District (SCAQMD) initiated a 

performance study with National Technical Systems (NTS) to evaluate the following six 

architectural coating categories: Industrial Maintenance, Non-flats, 

Primers/Sealers/Undercoaters, Quick Dry Enamels, Quick Dry 

Primers/Sealers/Undercoaters and Waterproofing Sealers. The objective of the 

performance study was to conduct side-by-side laboratory 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 test 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 for Architectural Coatings, approved 

by the Board on June 22, 2000. In general, the laboratory portions of the study revealed 

similar performance among high and low VOC coatings. 

The outdoor real-time exposure testing is ongoing and includes a desert and coastal 

environment. The outdoor real-time exposure will last 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 Program

In response to comments provided by the essential public service agencies (EPSA), the 

SCAQMD’s May 1999 architectural coatings rule amendments 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 during repair and maintenance 

procedures. The category includes coatings used by the EPSA that were previously 

included in the industrial maintenance coatings category. The essential public service 

category was created to allow additional time for EPSA to complete its lengthy 

administrative processes to identify and evaluate new 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 category 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 coatings 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 performance 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 

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• 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 representatives from each public service 

agency, SCAQMD, and ARB has been established. The technical steering committee has 

approved a test program design that includes test sequences, 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), cyclic corrosion testing in the laboratory 

(8 months), field application tests (2 years), and specification development (2 years). 

Southern California Alliance of Publicly Owned Treatment 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 specified in SCAQMD Rule 1113 and 

ARB’s Architectural Coatings SCM, SCAP has committed to evaluate the performance 

of low VOC coatings suitable for wastewater environments. 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 performance testing of architectural 

coatings by Harlan Associates, Inc. The purpose of the study was to determine the 

physical properties and performance of representative products in eight coating 

categories. A total of 110 coating products, purchased during late 1993 and throughout 

1994, were tested in the following categories: industrial maintenance primers and 

topcoats, high-temperature industrial maintenance coatings, lacquers, varnishes, non-flats 

(including quick-dry enamels), primer/sealers (including quick-dry primer/sealers), 

sanding sealers and waterproofing sealers (wood and concrete). 

While the raw data from this study were published in 1995, an analysis of the overall 

comparison of the coatings' test performance was not 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 Coatings 

Some companies in the architectural coatings industry have commented that, in order to 

meet the VOC limits proposed, manufacturers would need to reformulate many of their 
Environmental Effects Found Not To Be Significant 

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coatings to increase the amount of solids contained in those coatings. According to 

industry, this increase in solids content would lead to increased thickness of the low-VOC 

coatings being sprayed. Increased coating thickness 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 that 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 SCM, ARB received comments from 

industry that ARB had misinterpreted earlier comments that addressed this issue. 

Industry stated that ARB had focused too narrowly on increased thickness as it applied to 

waterborne coatings, not high solid, solvent-based alkyds. 

ARB’s response to these comments indicated that more attention was paid to water-borne 

coatings because water-borne coatings made up a very 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 reformulate a coating to increase solids content, 

less viscous resins exist which would allow compliant coatings to be manufactured while 

not increasing overall thickness. In evaluating product 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 coverage. ARB also stated that an 

accurate way to determine whether low-VOC levels corresponded to increased solids and 

increased thickness was to see whether there had been an increase in overall sales over 

time. ARB found that coatings sales had remained constant on a per-capita basis over the 

last 12 years. 

ARB’s analysis of this issue in the PEIR is relevant to San Diego County (and is adopted 

by reference herein). 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. There is nothing to suggest that 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 water-based, compliant coatings are 

available. These coatings would not have the problem of increased thickness. 

Companies that do business in San Diego also do business in other parts of the state, so 

there is no reason to believe that these coatings would 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 raised the issue of possible illegal 

thinning that would occur if the proposed VOC limits were adopted. The coatings 

affected by this are supposedly the same kinds of coatings that would be affected by the 

increased thickness problem discussed previously. According to industry, individual 

users will add illegal amounts of thinner to products that have been made more viscous 

due to increased solids content. Industry also commented that the ARB field study on 
Environmental Effects Found Not To Be Significant 

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thinning was flawed due to inaccurate sampling where the focus was on higher-VOC 

specialty coatings that are less likely to be thinned. 

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

issue. As stated in the ARB discussion on increased thickness, the low-VOC coatings 

referenced by industry were found to exhibit similar thickness and coverage to higher 

VOC coatings when applied. APCD staff considered and adopts by reference ARB’s 

analysis and responses on this issue. ARB used product data sheets in part to determine 

the coverage exhibited by these products. These products 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 Diego County that are either identical 

or very similar to the qualities exhibited in any other part of the state. These would 

indicate that there would be no need for users to thin 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 been found to have coverage 

qualities similar to that of higher-VOC coatings; thinning to reduce viscosity should not 

be an issue. ARB's analysis also concluded that thinning also inhibits hiding properties, 

increases drying time and, that when thinning occurred, the VOC limits were rarely 

exceeded. Additionally, most of the products on the 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 VOC 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-blocking properties. 

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

issue. The product data sheets that ARB used in part 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 demonstrated in a way that corresponds 

with previous attempts to increase the stringency of VOC levels for architectural 

coatings. These facts contradict the suggestion that adopting the proposed VOC levels 

would lead to an increase in the use of primers. Finally, there is nothing to suggest 

increased priming will be needed in San Diego County. 
Environmental Effects Found Not To Be Significant 

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Industry Concern No. 4 – Additional Topcoats Required 

Industry has commented that they expect the proposed VOC reductions will result in an 

increased amount of topcoat use. This is because industry contends that low-VOC 

products will not exhibit satisfactory coverage, build, 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 part 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 topcoats were not subjected to real-world 

exposure levels for a sufficient amount of time. It 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 products did not demonstrate the 

deficiencies enumerated by industry. These products 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 standardize the application process. 

Industry was involved in a technical advisory committee for choosing test protocol. ARB 

also concluded that tests represent a reasonable level 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 important factor for measuring 

characteristics such as coverage, flow-and-level, and build. 

Tests done by ARB evaluated a sample of products that reflect the type of coatings being 

manufactured and sold in California. An advisory committee that included many 

members of industry selected these coatings to be tested and the testing protocols. Since 

using consistent methods is important for conducting a valid test, using the draw down 

method of application is reasonable for coating test panels. Additionally, the time frame 

of the study was applicable for evaluating performance characteristics such as coverage, 

flow-and-level, and build. The tests upon which ARB relied for data are reasonable and 

do not indicate that more topcoat use will result from adopting the proposed VOC limits. 

APCD staff considered this issue to see if there were 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 claimed that water-borne and lowVOC solvent-borne formulations do not dry as fast as conventional coatings and, 

therefore, are susceptible to damage such as sagging, wrinkling, alligatoring, or becoming 

scraped and scratched. Some industry representatives contend that low-VOC, acetoneborne lacquers, water-borne topcoats, and substitutes will require more touch-up repair 

work because longer drying times allow for the contamination of the coated surface with 

airborne dust and construction debris. Industry representatives 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 severe blocking problems. Because of these 
Environmental Effects Found Not To Be Significant 

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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 reviewed 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 except lacquers. Additionally, per capita 

coatings sale has not increased since 1988, which indicates that there is no increase in 

touch-up and repair due to the use of water-borne coatings. Also, the NTS study 

demonstrated that blocking characteristics of low-VOC coatings are similar to 

conventional coatings. APCD staff looked at this issue to see if there were any local 

issues that might alter APCD’s conclusion and it was 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 asserted 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 coatings 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 (mechanical stress, thermal weathering), 

type of binder in the formulation, and the substrate coated. Results of the NTS study 

show that compliant coatings have similar performance and application characteristics as 

conventional coatings. APCD staff examined this issue 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 asserted that because water-borne and 

low-VOC solvent-borne coatings are inferior in durability and more difficult to apply 

than conventional coatings, consumers and contractors will substitute allegedly better 

performing, higher VOC coatings from other categories for use in categories with low 

VOC compliance limits (e.g., use of a rust preventive coating, which has a higher VOC 

content limit requirement, in place of an industrial 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 

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• The results from the NTS study show that low-VOC coatings with similar 

performance characteristics to conventional coatings are currently available. 

• The amended rule will not allow the application of certain coatings in specific 

settings (e.g., rust preventative coatings cannot be used in industrial settings.) 

• The amended rule will require that when a coating can be used in more than one 

coating category, the lower limit of the two categories is applicable (except for 

specified categories). 

APCD staff does not expect that contractors and consumers will substitute higher-VOC 

coatings for low-VOC coatings. Low-VOC coatings with similar performance 

characteristics to conventional coatings are available 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 requiring 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 architectural coatings, such as mineral 

spirits, have low reactivity and, thus, does not contribute to ozone formation. Industry 

also suggested that NOx control alone might be most appropriate for reducing groundlevel ozone. Industry representatives have also claimed that mass-based controls may not 

be effective and that reducing VOCs under certain conditions 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 water-borne coatings, such as 

propylene glycol, may be two to three times more reactive, on a per-gram basis, than a 

typical mineral spirit used in a solvent-based coating. However, when comparing the 

total, or weighted, reactivity of a product or product category (water-borne vs. solventborne), ARB staff found out that solvent-borne coatings are over two times more reactive 

than water-borne coatings. In addition, the reactivity of propylene glycol is 

approximately three times less reactive (on a per-gram 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 coatings. A conclusion that VOC control 

causes more ozone cannot be substantiated under real-world atmospheric conditions since 

certain atmospheric conditions characterized by very high VOC to NOx ratios must exist 

in order for VOC control to exhibit an enhancing effect 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 there is no validity to the claim that waterborne coatings are more reactive than solvent-borne coatings. APCD staff examined this 
Environmental Effects Found Not To Be Significant 

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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. 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 synergistic 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 effect 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 as conventional coatings. There is no 

evidence that a significant adverse air quality impact will result from the combined effect 

of two or more of the eight issues that is not evident in the effects analyzed of any 

singular issue. 

Determination of Significance

As discussed above, criteria were developed based on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for significant, adverse air quality 

impacts. Based on the information contained in this EIR and the ARB PEIR and 

associated technical studies, it has been determined 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 not 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-site 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 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 County is imported through the San 

Diego County Water Authority (SDCWA) from the Metropolitan Water District (MWD). 

MWD is a wholesale supplier of the supplemental imported water to Southern California. 

The MWD supplies water to an area approximately 5,200 square miles encompassing six 

counties (Los Angeles, Orange, Riverside, San Bernardino, Ventura and San Diego). 
Environmental Effects Found Not To Be Significant 

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There are two primary water supply sources to the MWD: 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 County by the MWD is received by 

the SDCWA and transported to its 23 member cities and individual water districts for 

distribution to retail customers through two aqueducts containing five large-diameter 

pipelines. 

The SDCWA is the major water supplier in the San Diego region, supplying from 70 to 

90 percent of the San Diego region’s water needs, with 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 of 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 representing 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 water districts, three irrigation districts, 

a public utility district, and a military reservation (Camp Pendleton Military Reservation). 

Water usage in San Diego County is closely linked to the local economy, population 

growth, and changes in weather. Historically, expansion of local economy has stimulated 

regional population, which has produced a relatively steady increase in water demand. 

The demand for water in the SDCWA service area is divided into two basic categories: 

municipal/industrial, and agricultural. Municipal and industrial water usage constitutes 

approximately 80 to 85 percent of the regional water 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 demands to the year 2010. 

Reclaimed Water 

Reclaimed water is an important and growing component of the Region’s water supply. 

Reclaimed water is obtained through extensive treatment of municipal wastewater to 

produce a safe and reliable water supply for non-potable uses. Reclaimed water is used 

to irrigate parks, agriculture, planned community greenbelt areas, golf courses, and 

freeway landscaping. Reclaimed water is an important water supply and leaves the 

Region less vulnerable to imported water supply shortages. 

Water Quality

In recognition of the regional differences in water quality and quantity, the state is 

divided into nine regions for the purposes of regional administration of California’s water 

quality control program. The San Diego Region is divided into 11 major hydrologic 

units, 54 hydrologic areas, and 147 hydrologic subareas. The boundaries were initially 

designated by the State Department of Water Resources (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 early 1970’s. In accordance with the 
Environmental Effects Found Not To Be Significant 

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early DWR definitions, hydrologic units are the entire 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 classified 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 imported 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 Point Harbor. Important estuaries are 

represented by coastal lagoons such as Tijuana Estuary, 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 Estuary. 

Surface Waters 

The San Diego Region has thirteen principal stream systems originating in the western 

highlands which flow to the Pacific Ocean. From north to south, these stream systems 

are Aliso Creek, Santa Margarita River, San Luis Rey River, San Marcos Creek, 

Escondido Creek, San Dieguito River, San Diego River, 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 components due to the rainfall pattern and 

the development of surface water impoundments. Surface water impoundments capture 

flow from nearly all the Region’s major surface water streams. Many of the major 

surface water impoundments are a blend of natural runoff and imported water. 

Groundwater 

All major drainage basins in the San Diego Region contain ground water basins. The 

basins are relatively small in area and usually shallow. 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 number of the larger ground water basins 

can be of future significance in the Region for storage of both imported waters and 

reclaimed wastewaters. Nearly all of the local ground waters of the Region have been 

intensively developed for municipal and agricultural 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, adverse impacts to water resources. 

Water impacts will be considered significant if they 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 planned 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 discharge requirements, or exceed 

wastewater treatment requirements of the California Regional Water Quality Control 

Board, San Diego Region; require the construction of new, or expansion of existing, 

water, wastewater, or stormwater drainage facilities, the construction of which could 

cause significant environmental effects; require new or expanded water entitlements and 

resources; or exceed a wastewater treatment provider’s existing commitments. 

Potential water demand impacts include increased water demand from the manufacturing 

and use of compliant water-borne coatings. Potential 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 water-borne coatings. Based on ARB’s 

worst-case scenario, water demand for the South Coast region could increase by 56,684 

gallons per day in 2010. This translates to an increase of 0.00110% for the South Coast 

region, which represents a negligible impact on water demand, even under the worst-case 

scenario. San Diego County's portion of this increase 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 without the proposed project. 

No additional stormwater drainage facilities are required as a result of the proposed 

project. In addition, the increases in the wastewater flow to the regional wastewater 

treatment plant that are expected to occur as a result of the proposed project are 

negligible. No additional capacity in the wastewater treatment plant is necessary. 

Further, the increase in water demand resulting from 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 implementing the proposed rule include 

increased improper disposal of waste. A significant impact could result if there were 

difficulties associated with waste disposal; however, it is relatively easy for sources to 

safely dispose of waste generated from architectural 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 conducted for its 1996 Rule 1113 

amendments, the majority of contractors either dispose of the waste material properly or 

recycle the waste material. 

As a result of implementing the San Diego’s Stormwater Quality Improvement Plan, 

combined with efforts by the National Paint and Coatings 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 industry is to replace more toxic solvents 

with less toxic and water-based solvents, resulting in less impact on the environment for 
Environmental 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 that will meet the proposed VOC limits 

without increasing the amount of toxic air contaminants (TACs). However, as a safety 

measure, the proposed rule institutes new annual reporting requirements for coatings 

containing perchloroethylene and/or methylene chloride. 

Results of the proposed annual reporting for these TACs will be used to evaluate the need 

for further toxic regulation. Another potential concern is the impact of the waste 

materials associated with manufacture, use, and cleanup 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 Regional Wastewater Treatment Plant, 

under a worst-case scenario, is expected to be an increase of 0.0016% in wastewater flow 

in 2010. 

Significant groundwater and surface water quality impacts are not expected as a result of 

implementing the amendments to Rule 67.0 in San Diego County. Both the volume and 

toxicity of improperly disposed of waste products is 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 on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for significant, adverse impacts to 

water resources. 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, proposed Rule 67.0 amendments would not 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 planned stormwater drainage 

systems or provide substantial additional sources of polluted runoff; substantially degrade 

water quality; deplete groundwater supplies or interfere with groundwater recharge 

efforts; violate any water quality standards or waste discharge requirements or exceed 

wastewater treatment requirements of the California Regional Water Quality Control 

Board, San Diego Region; require the construction of new, or expansion of existing, 

water, wastewater, or stormwater drainage facilities, the construction of which could 

cause significant environmental effects; require new or expanded water entitlements and 

resources; or exceed a wastewater treatment provider’s existing commitments. 

6.1.3 - Public Services 

Existing Conditions

Residents of San Diego County are provided with a number of essential public services. 

These services include fire protection, police protection, schools, water, and library 

services. The services are provided by either special 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 architectural 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 County 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 public, but instead have more narrowly 

defined jurisdictions such as prisons, military bases, 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, adverse 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 altered public facilities in order to 

maintain acceptable service ratios or response times for fire protection, police protection, 

schools, parks, or other public facilities. Potential 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 coatings may cause local agencies to 

use coatings that are of an inferior quality or lack the durability of coatings that are 

currently used but would be exempt under the proposed amended rule. This could lead to 

an overall greater use of architectural coatings. 

Data collected by ARB shows that there are many coatings 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 limits. In fact, these tests conclude that 

low-VOC coatings compare well with other coatings in 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 coatings marketed meet the proposed VOC 

limits. 

Results of the NTS study showed that low-VOC coatings 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 drying 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 available in San Diego County. 

Since low-VOC coatings perform well and would be readily available in San Diego 

County, there should be no increase in the amount of work needed to maintain public 
Environmental Effects Found Not To Be Significant 

 6-16

facilities. Also, the similarity in drying times means that facilities will not need to be 

painted or repainted predominantly during the warmer summer months. In keeping with 

the results of the independent tests, no adverse impacts due to increased maintenance of 

public facilities would result from lowering the VOC limits as proposed, and the 

significance criteria for public services would not be exceeded. 

Fire Protection

In its PEIR, ARB demonstrated that the National Fire Protection Association gives a 

flammability classification to acetone that is identical 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 applicable 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 acetone as a fire hazard. Directions for use 

and hazard warnings appear on coating cans in San Diego 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 applicable 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 Association, 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 risk 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 exceeded. 

Determination of Significance

As discussed above, criteria were developed based on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for significant, adverse impacts to 

public services. Based on the information contained in this EIR and the ARB PEIR and 

associated technical studies, it has been determined that no significant thresholds would 

be exceeded. Specifically, proposed Rule 67.0 amendments would not result in adverse 

physical impacts associated with the provision of new or altered public facilities in order 

to maintain acceptable service ratios or response times for fire protection, police 

protection, schools, parks, or other public facilities. 

6.1.4 - Transportation/Circulation 

Existing Conditions 

San Diego County has a well-established and comprehensive transportation system to 

serve the diverse travel needs of the County. It includes federal and state highways, 

county roads, urban arterials, rural highways and streets, light rail and bus transit 

services, freight rail, port facilities and airports. 
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, adverse impacts to 

transportation/circulation. Transportation/circulation 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 standard for designated roads or highways; 

substantially increase hazards due to a design feature or incompatible uses; result in 

inadequate emergency access, parking capacity, or hazards or barriers for pedestrians or 

bicyclists; or conflict with adopted alternative transportation policies, plans, or programs. 

Potential transportation and circulation impacts include 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 analysis by ARB was over-simplified 

and did not take into account the additional distribution 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/circulation impacts was increased trips to 

landfills due to disposal of additional waste materials. This waste, it was proposed, 

would come from coatings and containers due to problematic performance 

characteristics, including shelf life, pot life, and freeze-thaw of certain low-VOC 

coatings. Comments were also received by ARB indicating that out-of-state 

manufacturers would have to ship coatings during the 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 that manufacturers have indicated that 

addition of surfactants will improve freeze-thaw capabilities 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 increase 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 required due to the additional days 

required to complete a project. Thus, additional commute trips would be generated. 

However, the NTS evaluation of coating products indicates that low-VOC coatings in all 

categories except lacquers have comparable drying times 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 on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for significant, adverse impacts to 

transportation/circulation. 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, proposed 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 designated roads or highways; 

substantially increase hazards due to a design feature or incompatible uses; result in 

inadequate emergency access, parking capacity, or hazards or barriers for pedestrians or 

bicyclists; or conflict with adopted alternative transportation 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 amount 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, adverse 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 sufficient permitted capacity to 

accommodate the project’s solid and/or hazardous waste disposal needs, or would not 

comply with federal, state, and local statutes and regulations related to solid and 

hazardous wastes. Potential solid and hazardous waste impacts include impacts on the 

disposal capacity arising from increased disposal of 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 proposed rule amendments deal mainly with 

the increased generation of solid waste/hazardous waste and its disposal. APCD staff 

considered and adopts by reference ARB’s analysis and responses on this issue. 

Comments received by ARB for the PEIR regarding this matter alleged the following: 

• Compliant lower-VOC coatings targeted by the SCM will not have the same 

freeze-thaw capabilities as existing coatings and, therefore, may “go bad” during 
Environmental Effects Found Not To Be Significant 

 6-19

transport from mild climates to extreme climates, resulting in that load being 

discarded into a landfill. 

• Compliant lower-VOC coatings targeted by the SCM will 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 industrial maintenance and floor 

coatings, manufacturers will formulate more two-component systems that may 

have, on average, a shorter pot life compared to conventional coatings. As a 

result, low-VOC coatings could solidify in the can during the application process, 

resulting in an unusable portion of coating that would need to be discarded into a 

landfill. 

• Because the SCM would require the use of water-borne technologies, more 

surface preparation in the form of sandblasting will be required. This in turn will 

increase the amount of wastes deposited in landfills. 

ARB's analysis demonstrated that even if some compliant 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 create a significant solid waste or 

hazardous waste impact. For San Diego County, anticipated solid waste impacts 

associated with implementing the SCM are 0.007% (ARB 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 represents 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 not pose a significant impact for waste 

disposal. 

Determination of Significance

As discussed above, criteria were developed based on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for 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 project would be served by a landfill 

with sufficient permitted capacity to accommodate the 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 reformulation of non-compliant coatings 

in order to achieve reduced VOC standards. In order to achieve the reduced standards, 

coatings manufacturers may need to utilize exempt solvents in their coatings formulae. 

To the extent that future compliant coatings would be formulated with exempt solvents or 
Environmental Effects Found Not To Be Significant 

 6-20

other potentially hazardous materials, and to the extent that these materials could be 

accidentally released into the environment, the potential that implementing the VOC 

limits in the proposed rule amendments could create significant adverse hazardous 

substances impacts in San Diego County has been evaluated 

Thresholds of Significance 

Criteria were developed based on Appendix G of the Guidelines for Implementation of 

CEQA to evaluate the potential for significant, adverse hazardous substances impacts. 

Hazardous substance impacts will be considered significant 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 reasonably foreseeable upset and accident 

conditions involving the release of hazardous 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 materials sites compiled pursuant to 

Government Code section 65962.5; impair implementation of an adopted emergency 

response or evacuation plan; or increase fire hazard in areas with flammable materials. 

Potential hazardous substance impacts include the risk of an upset or accidental release of 

hazardous substances, and human health impacts. Human health impacts include 

potential increased long-term (carcinogenic and chronic) and short-term (acute) human 

health impacts associated with the use of various replacement 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. Although acetone is expected to be used 

to reformulate some compliant coatings, ARB indicates 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 trucks and rail cars are equipped to 

safely handle these coatings and would not be affected by the proposed rule amendments. 

The consequences (exposure) of an accidental release of acetone are directly proportional 

to the size of the individual transport trucks or rail 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 implementing the proposed rule amendments. 

Similarly, the severity of an accident involving the storage of acetone is not expected to 

change from existing conditions. With regard to other possible replacement solvents, 

ARB indicated that the trend in coatings technology is to replace Ethylene Glycol 

Monobutyl Ether (EGBE) solvents with less toxic/less hazardous coalescing solvents 

such as Texanol and propylene glycol. Additionally, ARB indicated that a majority of 
Environmental Effects Found Not To Be Significant 

 6-21

water-based formulations (flats and nonflats) do not contain solvents that are hazardous 

air pollutants (HAPs). APCD staff looked at this issue to see if there were any local 

issues that might alter APCD’s conclusion and it was determined that ARB's analysis is 

equally applicable to San Diego. 

According to ARB, some reformulated two-component industrial 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 Diego County due to the increased use of 

these compounds. Like Texanol, Oxsol 100, propylene glycol, and ethylene glycol, 

diisocyanates are significantly less flammable than currently used, highly flammable 

conventional solvents. Therefore, any potential hazards created by the increased use of 

compliant coatings containing diisocyanates would be offset by the decreased use of 

more flammable solvents. 

The ARB analysis determined that manufacturers would be able to reformulate coatings 

in order to comply with the proposed VOC limits without increasing the use of toxic air 

contaminants. As a precautionary measure, however, the proposed Rule 67.0 

amendments also require manufacturers to report usage for the following categories: 

Clear Brushing Lacquers, Rust Preventative Coatings, Specialty Primers, Sealers, and 

Undercoaters, Recycled Coatings, Bituminous Roof Coatings, Bituminous Roof Primers, 

and all coatings containing perchloroethylene and methylene chloride. This reporting 

will allow tracking of usage of products with higher VOC limits and tracking usage of 

toxic compound. Adoption of the rule amendments is not expected to cause any 

significant adverse impacts concerning hazardous substances. 

Determination of Significance

As discussed above, criteria were developed based on Appendix G of the Guidelines for 

Implementation of CEQA to evaluate the potential for significant, adverse hazardous 

substances 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, 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 reasonably foreseeable upset and 

accident conditions involving the release of hazardous 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 materials sites compiled pursuant to 

Government Code section 65962.5; impair implementation of an adopted emergency 

response or evacuation plan; or increase fire hazard in areas with flammable materials. 

6.2 - Effects found not to be Significant During Initial 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 relating 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 Environmental Impact Report: Suggested 

Control Measure for Architectural Coatings.” June 2000. (ARB, 2000). 

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

Measure.” June 2000. 

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

______. “1998 Architectural Coatings Survey Results Final Report.” September 1999. 

(ARB, 1999c) 

County of San Diego, Department of Planning and Land Use, Environmental Impact 

Report Format and Content Guidelines, February 1997. 

______. Code Zoning and Land Use Regulation Division. Zoning Ordinance. 

San Diego County Water Authority (SDCWA). “Urban Water Management Plan.” 

December 2000. (SDCWA, 2000) 

Sacramento Metropolitan Air Quality Management District (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 December 1, 2000. 

______. California Environmental Quality Act, Public Resources Code, Division 13, 

Environmental Quality. 

South Coast Air Quality Management District (SCAQMD). “Staff Report for: 

 Proposed Amendments to Rule 1113 – Architectural Coatings.” 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 San Diego County APCD located at 

9150 Chesapeake Drive, San Diego California 92123-1096. The following professional 

staff was directly involved in the preparation of this 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 Control 

Laura Yannayon, Senior Air Pollution Control Engineer 

 Project/Rule Development 

Adeline Suson, Associate Air Pollution Control Engineer 

 Project/Rule Development 

County of San Diego Department of Planning and Land Use

Joseph DeStefano II, Environmental Management Specialist III 

 Environmental Coordinator; Principal Document Preparer 

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 Agencies 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 District

Greg Tholen, Program Coordination Division 
List of Mitigation Measures and Environmental Design Considerations 

9-1 

CHAPTER 9.0 - LIST OF MITIGATION MEASURES AND ENVIRONMENTAL 

DESIGN CONSIDERATIONS 

The proposed project would not result in any significant impacts that require the 

implementation of mitigation measures. As such, no mitigation measures have been 

identified for the proposed project. Further, no environmental design considerations are 

required for the implementation of the proposed project. 
Appendix A 

Appendix A: 

Proposed Amendments to Rule 67.0 
Appendix 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), tThis rule is applicable to any person who 

manufactures, supplies, sells, offers for sale, applies, or solicits the application of, any 

architectural coating for use within San Diego County. 

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

(b) EXEMPTIONS

 The provisions of Section (d) of this rule shall not apply to the following coatings:

 (1) This rule shall not apply to:

 (i) Any architectural coating that is sold or manufactured for use outside of 

San Diego County or for shipment to other manufacturers for reformulation or 

repackaging.

 (ii) Any non-refillable aerosol coating product. 

 (iii) Any architectural coating that is sold in a container with a volume of one 

liter (1.057 quart) or less.

 (1) Architectural coatings supplied in containers having capacities of one liter or 

less;

 (2) Architectural coatings sold in non-refillable aerosol containers having 

capacities of one liter or less:

 (iv3) Emulsion-type bituminous pavement sealers. 

 (2) The provisions of Subsection (d)(1) shall not apply 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 added, at the time of application, 

provided that the lacquer contains acetone and no more 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 the purpose of 

bonding two surfaces together other than by mechanical means.

 (2) “Aerosol Coating Product” means a pressurized coating product containing 

pigments or resins that dispenses product ingredients by means of a propellant, and is 

packaged in a disposable can either for hand-held application 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 application 

to submerged stationary structures and their appurtenances to prevent or reduce the 

attachment of marine or freshwater biological organisms. To qualify as an antifouling 

coating, the coating must be registered with both the U.S. Environmental Protection 

Agency (EPA) under the Federal, Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 

Section 136, et seq.) and with the California Department of Pesticide Regulation. 

 (5) “Appurtenance” means any accessory to a stationary structure coated at the 

site of installation, whether installed or detached, including but not limited to: bathroom 

and kitchen fixtures; cabinets; concrete forms; doors; elevators; fences; hand railings; 

heating equipment, air conditioning equipment, and other fixed mechanical equipment or 

stationary tools; lampposts; partitions; pipes and piping systems; rain gutters and downspouts; stairways, fixed ladders, catwalks, and fire escapes; and window screens. 

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

not limited to: hand railings, cabinets, bathroom and kitchen fixtures, fences, rain gutters 

and down spouts, window screens, lamp posts, heating and air conditioning equipment, 

large fixed stationary tools, and concrete forms.

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

structures and/or their appurtenances at the site of installation (stationary source), to 

portable buildings including mobile homes, at the site of installation, coated onsite or in 

close proximity to the intended installed 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 insect 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 soluble 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, soluble in 

carbon disulfide, consisting mainly of hydrocarbons and which is obtained from natural 

deposits or as residue from the distillation of crude 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. 

 (105) “Bond Breaker” means a coating labeled and formulated for application

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 provide 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, including 

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. Such 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 after packaging to produce the desired color. 

 (156) “Concrete Curing Compound” means a coating labeled and formulated for 

application applied to freshly poured concrete to retard the evaporation of water. 

 (167) “Dry Fog Coating (Mill White Coating)” means a coating labeled and

formulated only for spray application such that overspray droplets dry before subsequent 

contact with incidental other surfaces in the vicinity of the surface coating activity. 

 (178) “Exempt Compound Solvent” 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 registered with the State Fire Marshall.

(209) “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 version of 

ASTM Designation E 84-87, “Standard Test method for Surface Burning Characteristics of 

Building Material,” after application to Douglas fir according to the manufacturer’s 

recommendation.

 (21) “Flat Coating” means a coating that is not defined under any other definition in 

this rule and that registers a gloss of less than 15 on an 85° meter, or less than 5 on a 60° 

meter. 

 (22) “Floor Coating” means an opaque coating that is labeled and formulated for 

application to flooring, including, but not limited to, decks, porches, steps, and other 

horizontal surfaces which may be subject to foot traffic. 

 (23) “Flow Coating (Electrical Transformers)” means a coating labeled and 

formulated exclusively for use by electric power companies or their subcontractors to 

maintain the protective coating systems present on utility transformer units.

 (2410) “Form-Release Compound” means a coating labeled and formulated for 

application applied to a concrete form to prevent the freshly poured concrete from bonding 

to the form. The form may consist of wood, metal or some material other than concrete. 

 (2511) “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 structural components) and murals, 

excluding structural components, including lettering enamels, poster colors, copy blockers, 

and bulletin enamels. 

 (2612) “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 intermittently to 

temperatures above 400°F (204°C). degrees Fahrenheit. 

 (13) “Industrial Maintenance Anti-graffiti Coating” means a two-component 

clear industrial maintenance coating which is formulated for and applied to exterior walls 

and murals to resist repeated scrubbing and exposure to harsh solvents. 

 (2714) “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 application to substrates exposed to one or 

more of the following extreme environmental conditions and labeled as specified in 

Subsection (e)(1)(iv): 
Appendix A 

-5- 

- 

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

 (ii)(iii) Acute or chronic exposure to corrosive, caustic, or 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 mechanical wear and repeated (frequent) scrubbing with industrial solvents, cleansers, or scouring agents; or

 (v) Exterior exposure of metal structures and structural components. 

 (2815) “Lacquer” means a clear or opaque wood pigmented coating, including clear 

lacquer sanding sealers, formulated with cellulosic nitrocellulose or synthetic resins to dry 

by evaporation without chemical reaction and to provide 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. 

 (3016) “Magnesite Cement Coating” means a coating labeled and formulated for 

application and applied to magnesite cement decking to protect the magnesite cement 

substrate from erosion by water. 

 (31) “Manufacturer’s Maximum Thinning Recommendation” means the 

maximum recommended thinning ratio that is indicated on the label or lid of the coating 

container or in the technical data sheet for the coating. 

 (3217) “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 (dry, single coat). 

 (3318) “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. 

 (3419) “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 more than 

one color when applied in a single coat. 

 (3520) “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 which 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 infrastructure, including highways, bridges, airports 

and railroads; facilities used in mining activities, including petroleum extraction; and 

utilities infrastructure, including power generation 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-transparent 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-consumer coating does not include 

manufacturing wastes. 

 (3925) “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 adhesion of subsequent topcoats surface 

etching. 

 (4026) “Primer” means a coating labeled and formulated for application to a substrate

which is intended to be applied to a surface to provide a firm bond between the substrate 

and subsequent coats. 

 (4124) “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 60o F and 80o F and which is formulated to have a gloss of 70 or greater on a 60o

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

current version of ASTM D 1640: 

 (i) Capable of being applied directly from the container under normal 

conditions at ambient temperatures between 60 and 80°F (16 and 27°C);

 (ii) When tested in accordance with ASTM Designation D 1640-95, sets to 

touch in 2 hours or less, is tack free in 4 hours or less, and dries hard in 8 hours or 

less by the mechanical test method; and

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

-7- 

- 

 (i) Set to touch in not more than two hours; be tack-free (mechanical tester) 

in not more than four hours; and 

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

 (4223) “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 version 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 subsequent 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 that not 

less than 50 percent of the total weight consists of secondary and post-consumer coating, 

with not less than 10 percent of the total weight consisting of post-consumer coating. 

 (4427) “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 Rroof coatings, which qualify as 

Mmetallic Ppigmented Ccoatings shall not be considered to be in this category, but shall be 

considered to be in the Mmetallic Ppigmented Ccoatings 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). 

 (4628) “Sanding Sealer” means a clear or semi-transparent wood coating labeled and 

formulated for application and applied to bare wood for sanding and to seal the wood and 

to provide a coat that can be abraded (sanded) to create 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 lacquer category. 

 (4729) “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 materials in the 

substrate. 

 (48) “Secondary Coating (Rework)” means the fragment of a finished coating or 

the finished coating from a manufacturing process that has converted resources into a 

commodity of real economic value, but does not include excess virgin resources of the 

manufacturing process. 
Appendix A 

-8- 

- 

 (30) "Semi-Transparent Stain" means a coating which is formulated to change 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 formulated and used to protect exposed wood 

from decay or insect attack by the addition of a wood preservative chemical registered by 

the California Department of Food and Agriculture, and which changes the color of a 

surface but does not conceal the surface.

 (4932) “Shellac” means a clear or opaque pigmented coating formulated solely with 

the resinous secretions of the lac beetle (Llaccifer lacca), thinned with alcohol, and 

formulated to dry by evaporation without a chemical reaction. 

 (5033) “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 formulated for application to a substrate to seal 

fire, smoke or water damage; to condition excessively chalky surfaces, or to block stains. 

An excessively chalky surface is one that is defined 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. 

 (5334) “Swimming Pool Coating” means a coating labeled and formulated and used

to coat the interior of swimming pools and to resist swimming pool chemicals. 

 (5435) “Swimming Pool Repair and Maintenance Coating” means a rubber based

chlorinated rubber-based coating labeled and formulated to be used over existing rubber 

based coatings for the repair and maintenance of swimming pools over existing chlorinated 

rubber-based coatings. 

 (55) “Temperature-Indicator Safety Coating” means a coating labeled and 

formulated as a color-changing indicator coating for the purpose of monitoring the 

temperature and safety of the substrate, underlying piping, or underlying equipment, and 

for application to substrates exposed continuously or intermittently to temperatures above 

400°F (204°C). 

 (56) “Tint Base” means an architectural coating to which colorant is added after 

packaging to produce a desired color. 

 (5736) “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. 

 (5837) “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- 

- 

 (5938) “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 amounts of pigment to color a surface, or to 

control the final sheen or gloss of the finish. 

 (6039) “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 carbides 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 and 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 minor cracks and to conceal surface 

irregularities and which is to be applied in thicknesses of 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, ultraviolet light, and staining. 

 (6441) “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 registered 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 Regulation. 

(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 of sale or manufacture contains more than 

250 grams of VOC per liter of coating (excluding water and exempt solvents and any 

colorant added to tint bases). 
Appendix A 

-11- 

- 

Table 1 - VOC Standards

Effective

(Date of 

Adoption)

Limit1,2

Effective

1/1/2003

Limit1,2

Effective

1/1/2003

Limit1,2

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 Coatings3 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 Coatings4

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)

Limit1,2

Effective

1/1/2003

Limit1,2

Effective

1/1/2003

Limit1,2

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 indicated in subsequent columns. The VOC content limits take into 

account the “Manufacturer’s Maximum Thinning Recommendation,” if any.

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

compounds.

3 VOC content limits are expressed in lb of VOC per gallon (or grams of VOC per liter) of coating, as applied, 

including water and exempt compounds.

4 Effective January 1, 2004, this category only applies to non-industrial uses. Industrial uses are regulated 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 definitions for the specialty coatings 

categories listed in Table 1, the VOC content limit shall be determined by classifying the 

coating as a flat coating or a nonflat coating, based on its gloss, as defined in Subsections 

(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 coating, or any label or sticker 

affixed to the container, or in any sales, advertising, or technical literature supplied by a 

manufacturer or anyone acting on their behalf, any representation is made that indicates 

that the coating meets the definition of or is recommended for use for more than one of the 

coating categories listed in Table 1, then the most restrictive VOC content limit shall 

apply. This provision does not apply to the coating categories specified 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, 2003 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 for that coating in Table 1 may be 

applied at any time, both before and after the specified effective date, so long as the 

coating complied with the standards in effect at the time the coating was manufactured. This Subsection does not apply to any coating that does not display the date or 

date-code required by Subsection (e)(1)(i).

 (ii) A coating included in an approved Averaging Program that does not 

comply with the specified limit in Table 1 may be sold, supplied, or offered for sale 

for up to three years after the end of the compliance period specified in the approved 

Averaging Program. In addition, such a coating may be applied at any time, both 

during and after the compliance period. This Subsection does not apply to any 

coating that does not display on the container either the statement: “This product is 

subject to architectural coating averaging provisions in California” or a substitute 

symbol specified by the Executive Officer of the CARB. 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 such 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), manufacturers may average designated coatings 

such that their actual statewide cumulative emissions 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 Appendix A shall cease to be effective on 

January 1, 2005, after which averaging will no longer 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-Retardant 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

Swimming 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 the table of standards below which contains 

VOC (excluding water and exempt solvents, and excluding any colorant added to tint 

bases), in excess of the corresponding limit specified in the following 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 County, subject to the requirements of Subsection (d)(2) which contains VOC (excluding water and exempt solvents, and excluding 

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 three months after December 4, 1990.
Appendix A 

-15- 

- 

(4) A person shall not sell, offer for sale, apply or solicit the application of any 

architectural coating subject to the requirements of Subsection (d)(2) for use within San 

Diego County which, at the time of sale, contains VOC (excluding water and exempt 

solvents, and excluding any colorant added in tint bases) in excess of the corresponding new 

or revised limit that is effective on February 2, 1990 specified in the Table of Standards in 

Subsection (d)(2) for more than three years after the 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 container displays the date of manufacture of 

the contents or a code indicating the dates of manufacture. The manufacturers of such 

coatings shall file an explanation of each code with 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 the 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 architectural coating for use within San Diego County unless the thinning 

recommended on the label for normal environmental and application conditions would not 

cause the coating to exceed its applicable standard.

 (7) A person shall not manufacture, sell, or offer 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 VOC 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 (less water and exempt solvents and 

excluding any colorant added to tint bases). The VOC content displayed may be 

calculated using product formulation data or may be determined using the test method in 

Section (h).

(e) ADMINISTRATIVE REQUIREMENTS

(1) CONTAINER LABELING REQUIREMENT:

Each manufacturer of any architectural coating subject 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 label, lid, or bottom of the container. 

If the manufacturer uses a date code for any coating, the manufacturer shall file an 

explanation of each code with the Executive Officer of the CARB.
Appendix A 

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 (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 requirement does not apply to the thinning 

of architectural coatings with water. If thinning of the coating prior to use is not 

necessary, the recommendation must specify that the coating is to be applied without 

thinning.

 (iii) VOC CONTENT: Each container of any coating subject to this rule 

shall display either the maximum or the actual VOC content of the coating, as 

supplied, including the maximum thinning as recommended by the manufacturer. 

VOC content shall be displayed as grams of VOC per liter of coating. VOC content 

displayed shall be calculated using product formulation data or determined using the 

test methods in Subsection (f)(2). The equations in 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 coating 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 residential use.”

 (v) CLEAR BRUSHING LACQUERS: Effective January 1, 2003, the

labels of all clear brushing lacquers shall prominently 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 prominently display the statement “For 

Metal Substrates Only.” 

 (vii) SPECIALTY PRIMERS, SEALERS, AND UNDERCOATERS:

Effective January 1, 2003, the labels of all specialty 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 words “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 shall 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, determine the VOC content in 

grams of VOC per liter of coating thinned to the manufacturer’s maximum thinning 

recommendation, excluding the volume of any water and exempt compounds. 

Determine the VOC content using the following equation: 

VOC Content = (Ws - Ww - Wec) / (Vm - Vw - Vec)

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

Ws = weight of all volatiles, in grams .

Ww = weight of water, in grams

Wec = weight of exempt compounds, in grams 

Vm = volume of coating, in liters 

Vw = volume of water, in liters

Vec = 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 manufacturer’s maximum recommendation, 

including the volume of any water and exempt compounds. Determine the VOC 

content using the following equation:

VOC Contentls = (Ws

 - Ww - Wec) / (Vm)

Where: VOC contentls = the VOC content of a low solids coating in grams

of VOC per liter of coating

 Ws = weight of all volatiles, in grams

 Ww = weight of water, in grams

 Wec = weight of exempt compounds, in grams 

 Vm = 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 each calendar year beginning in the 
Appendix A 

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

shall specify the number of gallons of clear brushing lacquers sold in California 

during the preceding calendar year, and shall describe 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 of each calendar year beginning in 

the year 2004, submit an annual report to the Executive 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 undercoaters shall, on or before April 

1 of each calendar year beginning in the year 2004, submit an annual report to the 

Executive Officer of the CARB. The report shall specify the number of gallons of 

specialty primers, sealers, and undercoaters sold in California during the preceding 

calendar year, and shall describe the method used by the manufacturer to calculate 

State sales. 

 (iv) TOXIC EXEMPT COMPOUNDS: For each architectural coating that 

contains perchloroethylene or methylene chloride, the manufacturer shall, on or 

before April 1 of each calendar year beginning in the year 2004, report to the 

Executive Officer of the CARB the following information for products sold in 

California during the preceding year:

 (A) the product brand name and a copy of the product label with

legible usage instructions;

 (B) the product category listed in Table 1 to which the coating 

belongs;

 (C) the total sales in California during the calendar year to the nearest 

gallon; the volume percent, to the nearest 0.10 percent, 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 CARB certifying their status as a 

Recycled Paint Manufacturer. The manufacturer 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 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 calculate California’s distribution. 

 (vi) BITUMINOUS COATINGS: Each manufacturer of bituminous roof 

coatings or bituminous roof primers 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 
Appendix A 

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CARB. The report shall specify the number of gallons of bituminous roof coatings 

or bituminous roof primers sold in California during 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 reference in Subsection (f)(2) 

(iv)(K), except as provided in Subsections (f)(2)(ii) 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 South Coast Air Quality Management District (SCAQMD) Method 303-91 (Revised August 1996), incorporated 

by reference in Subsection (f)(2)(iv)(J). To determine the VOC content of a coating, 

the manufacturer may use U.S. EPA Method 24, or an alternative method as provided 

in Subsection (f)(2)(ii), formulation data, or any other reasonable means for predicting that the coating has been formulated as intended (e.g. quality assurance checks, 

recordkeeping). However, if there are any inconsistencies between the results of a 

Method 24 test and any other means for determining VOC content, the Method 24 

test results will govern, except when an alternative method is approved as specified 

in Subsection (f)(2)(ii). The Air Pollution Control 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 traffic marking coatings shall be 

conducted according to a modification of U.S. EPA Method 24 (Appendix A), 

incorporated by reference in Subsection (f)(2)(iv)(M). This method has not been 

approved for methacrylate multicomponent coatings used for purposes other than as 

traffic marking coatings or for other classes of multi-component coatings. 

 (iv) TEST METHODS: The following test methods are incorporated by 

reference herein, and shall be used to test coatings 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 84-99, “Standard Test 

Method for Surface Burning Characteristics of Building 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 Designation E 119-98, 
Appendix A 

-20- 

- 

“Standard Test Methods for Fire Tests of Building Construction 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 Quick-Dry Enamels).

 (D) Metal Content of Coatings: The metallic content of a coating 

shall be determined by SCAQMD Method318-95, “Determination of Weight 

Percent Elemental Metal in Coatings by X-Ray Diffraction,” SCAQMD 

“Laboratory Methods of Analysis for Enforcement Samples,” (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 Intermediates Used in Paint, 

Varnish, Lacquer, and Related Products,” (see Subsection (c)(39), PreTreatment Wash Primers).

 (F) Drying Times: The set-to-touch, dry-hard, dry-to-touch, and dryto-recoat times of a coating shall be determined by ASTM Designation D 1640-

95, “Standard Test Methods for Drying, Curing, or Film Formation of Organic 

Coatings at Room Temperature,” (see Subsections (c)(41) and (c)(42), QuickDry Enamel and Quick-Dry Primer, Sealer, and Undercoater). The tack-free 

time of a quick-dry enamel coating shall be determined by the Mechanical Test 

Method of ASTM Designation D 1640-95.

 (G) Surface Chalkiness: The chalkiness of a surface shall be 

determined using ASTM Designation D 4214-98, “Standard Test Methods for 

Evaluating the Degree of Chalking of Exterior Paint Films,” (see Subsection 

(c)(51), Specialty Primer, Sealer, and Undercoater).

 (H) Exempt Compounds – Siloxanes: Exempt compounds that are 

cyclic, branched, or linear completely methylated siloxanes, shall be analyzed 

as exempt compounds (for compliance with Subsection (e)(2)) by Bay Area Air 

Quality Management District (BAAQMD) District Method 43, “Determination 

of Volatile Methylsiloxanes in Solvent-Based Coatings, Inks, and Related 

Materials,” BAAQMD Manual of Procedures, Volume III, adopted 11/6/96, 

(see Subsection (c)(60), Volatile Organic Compounds and Subsection (e)(2)(i)).

 (I) Exempt Compounds – Parachlorobenzotrifluoride (PCBTF): 

The exempt compound parachlorobenzotrifluoride, shall 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 Parachlorobenzotrifluoride,” BAAQMD 
Appendix A 

-21- 

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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 Method 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 of Volatile Matter Content, 

Water Content, Density, Volume Solids, and Weight Solids 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 Organic Compounds 

(VOC) in Various Materials,” SCAQMD “Laboratory Methods of Analysis for 

Enforcement Samples,” (see Subsection (f)(2)(i)).

 (M) Methacrylate Traffic Marking Coatings: The VOC content of 

methacrylate multicomponent coatings used as traffic marking coatings shall be 

analyzed by the procedures in 40 CFR Part 59, Subpart D, Appendix A, 

“Determination of Volatile Matter Content of Methacrylate Multicomponent 

Coatings Used as Traffic Marking Coating,” (September 11,1998), (see 

Subsection (f)(2)(i)).

Existing Sections (e), (f) and (g) are deleted in their 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 or advertising literature, any representation is 

made that the coating may be used as, or is suitable for 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 representation of the following coatings in the 

manner specified:

(1) High Temperature Industrial Maintenance Coatings, which may be represented 

as metallic-pigmented coatings for use consistent with the definition of high temperature 

industrial maintenance coatings;

(2) Lacquer Sanding Sealers, which may be recommended for use as sanding 

sealers in conjunction with clear lacquer topcoats;

(3) Metallic-Pigmented Coatings, which may be recommended for use as primers, 

sealers, undercoaters, roof coatings, or industrial maintenance coatings;

(4) Shellacs; and
Appendix A 

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(5) Fire Retardant 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 accordance 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 water and exempt 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 conducted and reported in accordance with the 

Spectrographic Method used by Pacific Spectrochemical Laboratory, Inc. for the analysis of carbon dust

and carbon laminates, as it exists on December 4, 1990.
Appendix A 

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New proposed Appendix A is added to Rule 67.0. 

Appendix A

A.1 AVERAGING PROVISION

 The manufacturer shall demonstrate that actual emissions from the coatings being averaged are less 

than or equal to the allowable emissions, for the specified compliance period using the following 

equation: 

∑ ≤

n

i = 1

GiMi ∑

n

i =1

GiViLi

Where: 

∑ =

n

i = 1

GiMi Actual Emissions

∑ =

n

i =1

GiViLi AllowableEmissions

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

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

 

Vm

Ws - Ww - Wec Mi =

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

 

Vm

Vm - Vw - Vec

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: 

 

Coating VOC(also known as VOC Regulatory)

Material VOC(also known as VOC Actual)

Vi =
Appendix A 

-24- 

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 Where: 

Vm - Vw - Vec

Ws - Ww - Wec

Coating VOC =

 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 designated by the manufacturer. Any coating not designated in the 

averaging Program shall comply with the VOC limit in Table 1. The manufacturer shall not include any 

quantity of coatings that it knows or should have known will not be used in California, if statewide coatings 

data are used. If district-specific coatings data are used, the manufacturer shall not include any quantity of 

coatings that it knows or should have known will not be used in the District. 

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 applicable 

categories. 

Averaging Categories and VOC Ceiling (Maximum VOC Allowed)

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 250 400 
Appendix A 

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A.2 AVERAGING PROGRAM (PROGRAM)

 At least six months prior to the start of the compliance period, manufacturers shall submit an 

Averaging Program to the Executive Officer of the Air Resources Board. As used in this Appendix A, 

“Executive Officer” means the Executive Officer of the Air Resources Board. Averaging may not be 

implemented until the Program is approved in writing by the Executive Officer. 

 Within 45 days of submittal of a complete Program, the Executive Officer shall either approve or 

disapprove the Program. The Program applicant and the Executive Officer may agree to an extension 

of time for the Executive Officer to take action on the Program. 

A.3 GENERAL REQUIREMENTS

 The Program shall include all necessary information for the Executive Officer to make a determination

as to whether the manufacturer may comply with the averaging requirements over the specified 

compliance period in an enforceable manner. Such information shall include, but is not limited to, the 

following: 

A.3.1 An identification of the contact persons, telephone numbers, and name of the manufacturer who is 

submitting the Program. 

A.3.2 An identification of each coating that has been selected by the manufacturer for inclusion in this 

program that exceeds the applicable VOC limit in Table 1, its VOC content specified in units of both 

VOC actual and VOC regulatory, and the designation of the coating category. 

A.3.3 A detailed demonstration showing that the projected actual emissions will not exceed the allowable 

emissions for a single compliance period that the Program will be in effect. In addition, the 

demonstration shall include VOC content information for each coating that is below the compliance 

limit in Table 1. The demonstration shall use the equation specified in Section A.1 of this Appendix 

for projecting the actual emissions and allowable emissions during each compliance period. The 

demonstration shall also include all VOC content levels and projected volume sold within the State for

each coating listed in the Program during each compliance period. The requested data can be 

summarized in a matrix form. 

A.3.4 A specification of the compliance period(s) and applicable reporting dates. The length of the 

compliance period shall not be more than one year or less than six months. 

A.3.5 An identification and description of all records to be made available to the Executive Officer upon 

request, if different than those identified under Section A.3.6. 

A.3.6 An identification and description of specific records to be used in calculating emissions for the 

Program and subsequent reporting, and a detailed explanation as to how those records will be used by 

the manufacturer to verify compliance with the averaging requirements. 

A.3.7 A statement, signed by a responsible party for the manufacturer, that all information submitted is true 

and correct, and that records will be made available to the Executive Officer upon request. 
Appendix A 

-26- 

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A.4 REPORTING REQUIREMENTS

A.4.1 For every single compliance period, the manufacturer shall submit a mid-term report listing all 

coatings subject to averaging during the first half of the compliance period, detailed analysis of the

actual and allowable emissions at the end of the mid-term, and an explanation as to how the 

manufacturer intends to achieve compliance by the end of the compliance period. The report shall be 

signed by the responsible party for the manufacturer, attesting that all information submitted is true and 

correct. The mid-term report shall be submitted within 45 days after the midway date of the 

compliance period. A manufacturer may request, in writing, an extension of up to 15 days for 

submittal of the mid-term report. 

A.4.2 Within 60 days after the end of the compliance period or upon termination of the Program, whichever 

is sooner, the manufacturer shall submit to the Executive Officer a report listing all coatings subject to 

averaging during the compliance period, providing a detailed demonstration of the balance between the 

actual and allowable emissions for the compliance period, any identification and description of specific 

records used by the manufacturer to verify compliance with the averaging requirement, and any other 

information requested by the Executive Officer to determine whether the manufacturer complied with 

the averaging requirements over the specified compliance period. The report shall be signed by the 

responsible party for the manufacturer, attesting that all information submitted is true and correct, and 

that records will be made available to the Executive Officer upon request. A manufacturer may 

request, in writing, an extension of up to 30 days for submittal of the final report. 

A.5 RENEWAL OF A PROGRAM

 A Program automatically expires at the end of the compliance period. The manufacturer may request 

a renewal of the Program by submitting a renewal request that shall include an updated Program, 

meeting all applicable Program requirements. The renewal request 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 manufacturer is likely to comply with the averaging 

requirements. The Executive Officer shall base such 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, unless the manufacturer and the Executive Officer 

agree to an extension of time for the Executive Officer to take action on the renewal request. 

A.6 MODIFICATION OF A PROGRAM

 A manufacturer may request a modification of the Program at any time prior to the end of the 

compliance period. The Executive Officer shall take action to approve or disapprove the modification 

request no longer than 45 days from the date of its submittal. No modification of the compliance 

period shall be allowed. A Program need not be modified to specify additional coatings to be 

averaged that are below the applicable VOC limits. 
Appendix A 

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A.7 TERMINATION OF A PROGRAM

A.7.1 A manufacturer may terminate its Program at any time by filing a written notification to the Executive 

Officer. The filing date shall be considered the effective date of the termination, and all other 

provisions of this rule including the VOC limits shall immediately thereafter apply. The manufacturer 

shall also submit a final report 60 days after the termination date. Any exceedance of the actual 

emissions over the allowable emissions over the period that the Program was in effect shall constitute

a separate violation for each day of the entire compliance period. 

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

A.7.2.1 The manufacturer violates the requirements of the approved Program, and at the end of the compliance 

period, the actual emissions exceed the allowable emissions. 

A.7.2.2 The manufacturer demonstrates a recurring pattern of violations and has consistently failed to take the 

necessary steps to correct those violations. 

A.8 CHANGE IN VOC LIMITS

 If the VOC limits of a coating listed in the Program are amended such that its effective date is less

than one year from the date of adoption, the affected manufacturer may base its averaging on the prior

limits of that coating until the end of the compliance period immediately following the date of 

adoption. 

A.9 LABELING

 Each container of any coating that is included in averaging program, and that exceeds the applicable 

VOC limit in the table in Section 301 shall display the following statement: “This product is subject

to architectural coatings averaging provisions in California.” A symbol specified by the Executive 

Officer may be used as a substitute. 

A.10 VIOLATIONS

 The exceedance of the allowable emissions for any compliance period shall constitute a separate 

violation for each day of the compliance period. However, any violation of the requirements of the 

Averaging Provision of this rule, which the violator can demonstrate, to the Executive Officer, did not 

cause or allow the emission of an air contaminant and was not the result of negligent or knowing 

activity may be considered a minor violation.

A.11 SUNSET OF AVERAGING PROVISION

 The averaging provision set forth in Appendix A shall cease to be effective on January 1, 2005, after

which averaging will no longer be allowed. 
Appendix B 

Appendix B: 

Notice of Preparation 
Appendix 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 REPORT 

June 8, 2001 

NOTICE IS HEREBY GIVEN that the San Diego County Air Pollution 

Control District is the Lead Agency and will prepare an Environmental 

Impact Report in accordance with the California Environmental Quality Act 

for the following project. The District is seeking public and agency input 

on the scope and content of the environmental information to be contained 

in the EIR. A Notice of Preparation document, which contains a 

description of the probable environmental effects of the project, can be 

reviewed at Room 102, Air Pollution Control District, 9150 Chesapeake 

Drive, San Diego, California 92123-1096. Comments on the Notice of 

Preparation document must be sent to the APCD address listed above 

and should reference the project number and name. 

ER 01-00-001, SECOND TIER EIR FOR AMENDMENTS TO APCD 

RULE 67.0, ARCHITECTURAL COATINGS. The District proposes to 

adopt amendments to Rule 67.0, Architectural Coatings, as part of its 

Rules and Regulations. The Rule 67.0 amendments will incorporate VOC 

content limits and other requirements contained in the Suggested Control 

Measure (SCM) for Architectural Coatings, adopted by the ARB on June 

22, 2000. The SCM sets allowable VOC content limits and other 

requirements, based on existing 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 undercoatings. Prior to 

approving the SCM, ARB prepared and certified a Programmatic 

Environmental Impact Report (PEIR). The EIR being prepared by APCD 

will tier from the ARB PEIR. Comments on this Notice of Preparation 

document must be received no later than July 10, 2001, at 5:00 p.m. (a 

30-day public review period). For additional information, 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 stationary structures and their 

appurtenances, and include such coatings as house paints, stains, varnishes, industrial 

maintenance coatings, and traffic marking coatings. When applied, the solvents in the 

coatings evaporate into the atmosphere and emit volatile organic compounds (VOC), 

which contribute to the formation of ozone. San Diego County has been designated by 

the California Air Resources Board (ARB) as a Serious 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) for Architectural Coatings, adopted 

by the ARB on June 22, 2000. The SCM is based on existing 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 implementation 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 certified a Program Environmental 

Impact Report (PEIR). The EIR being prepared by the San Diego County APCD will tier 

from the ARB PEIR. A copy of that report is available through either the APCD or ARB, 

as well as on the ARB website at the following addresses. 

Street Address: San Diego County Air Pollution Control 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 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 additional coating 

categories with VOC limits consistent with the SCM. The proposed VOC limits for most 

categories would become effective on January 1, 2003 (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 to average designated coatings such 

that their average cumulative emissions are less than or equal to the cumulative 

emissions that would be allowed under the rule. The 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 allowable VOC content limit) when 

averaging. Ceiling limits would protect against regional differences that could result in 

high VOC products being sold in San Diego.

Amended Rule 67.0 does not include the SCM provision pertaining to petitioning the Air 

Pollution Control Officer to allow application of an industrial maintenance coating with a 

VOC content up to 340 grams per liter, since that provision only applies to the North 

Central Coast, San Francisco Bay Area, and the North 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 unincorporated portions of San Diego 

County, the southwestern-most county in the State of 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 result from the project are identified in the 

attached Environmental Initial Study, which was developed based on review of ARB’s 

PEIR. All questions answered “Potentially Significant Impact” or “Less than Significant 

with Mitigation Incorporated” will be analyzed further in the Environmental Impact 

Report. All questions answered “Less than Significant 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, the 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 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-site 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 odors affecting a 

substantial number of people. 

The adoption and implementation of the proposed rule amendments is 

expected to produce substantial, long-term, VOC emission reductions. 

However, some companies in the architectural coatings 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 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. 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 considered 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 erosion 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 interfere with groundwater 

recharge efforts; violate any water quality standards or waste discharge 

requirements, or exceed wastewater treatment requirements of the 

California Regional Water Quality Control Board, San Diego Region; 

require the construction of new, or expansion of existing, water, 

wastewater, or stormwater drainage facilities, the construction of which 

could cause significant environmental effects; require new or expanded 

water entitlements and resources; or exceed a wastewater treatment 

provider’s existing commitments. 

Potential water demand impact areas include increased water demand 

from the manufacturing and use of compliant water-borne coatings. 

Potential water quality impacts include the impact of solvents and 

architectural coatings. 

III. PUBLIC SERVICES 

Public services impacts will be considered significant if they will result in 

adverse physical impacts associated with the provision of new or altered 

public facilities in order to maintain acceptable service ratios or response 

times for fire protection, police protection, schools, parks, or other public 

facilities. Potential impacts include impacts on public facilities and fire 

protection services – including impacts associated with the use of 

potentially flammable solvents. 

IV. TRANSPORTATION/CIRCULATION 

Transportation/circulation 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 standard for designated 

roads or highways; substantially increase hazards due to a design feature 

or incompatible uses; result in inadequate emergency access, parking 

capacity, or hazards or barriers for pedestrians or bicyclists; or conflict 

with adopted alternative transportation policies, plans, or programs. 

Potential transportation and circulation impacts include additional vehicle 

trips caused by the disposal of coatings due to the possibility of shorter 

shelf or pot lives or lesser freeze-thaw capabilities. 

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 considered significant if the 

proposal would not be served by a landfill with sufficient permitted 

capacity to accommodate the project’s solid and/or hazardous waste 

disposal needs, or would not comply with federal, state, and local statutes 

and regulations related to solid and hazardous wastes. 

Potential solid and hazardous waste impacts include impacts on the 

disposal capacity arising from increased disposal of compliant coatings 

due to the possibility of shorter shelf or pot lives or lesser freeze-thaw 

capabilities. 

VI. HAZARDOUS SUBSTANCES 

Hazardous substance impacts will be considered significant 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 

reasonably foreseeable upset and accident conditions involving the 

release of hazardous 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 materials sites compiled 

pursuant to Government Code section 65962.5; impair implementation of 

an adopted emergency response or evacuation plan; or increase fire 

hazard in areas with flammable materials. 

Potential hazardous substance impacts include the risk of an upset or 

accidental release of hazardous substances, and human health impacts. 

Human health impacts include potential increased long-term (carcinogenic 

and chronic) and short-term (acute) human health impacts associated with 

the use of various replacement solvents in compliant coatings 

formulations. 

VII. OTHER AREAS 

In addition to the subject areas summarized above, the EIR will assess, as 

appropriate, the following environmental issues: irreversible 

environmental changes, potential growth inducing impacts, consistency 

with other plans, and project mitigation measures and alternatives. 
Appendix B 

-7- 

- 

VIII. ENVIRONMENTAL EFFECTS THAT DO NOT REQUIRE ANALYSIS 

The APCD has determined that the following areas need 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 Study
Appendix B 

-8- 

- 

Project

Location

Map

● Los Angeles

● Sacramento

San Diego

Mexico

Figure 1-1 Project Location San Diego County

★ ★
Appendix C 

Appendix C: 

Initial Study 
Appendix 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/Title: 

ER 01-00-001/Proposed Amendments to Air Pollution Control 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 Engineer 

Adeline Suson, Associate Air Pollution Control engineer 

San Diego County Department of Planning and Land Use

Joseph M. DeStefano II, Environmental Management Specialist 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 the State of California 
Appendix C 

-2- 

(Figure 1-1). 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 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 County 

 Land Use Designation: Varies throughout San Diego County 

 Density: Varies throughout San Diego County 

8. Zoning 

 Use Regulation: Varies throughout San Diego County 

 Density: Varies throughout San Diego County 

 Special Area Regulation: Varies throughout San Diego County 

9. Description of project (Describe the whole action involved, including but not 

limited to later phases of the project, and any secondary, 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 Coatings. Architectural 

coatings are defined as coatings applied to stationary structures and their 

accessories (usually for beautification and protection), and include such 

coatings as house paints, stains, varnishes, industrial maintenance coatings, 

and traffic marking coatings. When applied, the solvents in the coatings 

evaporate into the atmosphere and emit volatile organic compounds (VOCs), 

which contribute to the formation of ozone. San Diego County has been 

designated by the California Air Resources Board (ARB) as a “Serious” 

nonattainment area for the State ambient air quality standard for ozone. 

The Rule 67.0 amendments will incorporate VOC limits and other 

requirements contained in the Suggested Control Measure (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 technologies) and that will achieve 

significant reductions in VOC emissions from architectural coatings. Local 

implementation would reduce VOC emissions in San Diego County by an 

estimated 1.5 tons per day. 

Amended Rule 67.0 would continue to apply to any person who supplies, 

sells, offers for sale, or manufactures an architectural coating for use within 
Appendix 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 additional coating categories 

with VOC limits consistent with the SCM. The proposed VOC 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 corresponding limits in the 

SCM, and pertain to: clear wood coatings, (lacquers and varnishes); high 

temperature coatings; industrial maintenance coatings; magnesite cement 

coatings; multi-color coatings; pre-treatment wash primers; primers, sealers 

and undercoaters; quick dry enamels; quick-dry primers; roof coatings; stains; 

swimming pool coatings; swimming pool repair and maintenance coatings; 

traffic marking coatings (indicated as traffic paints in existing rule 67.0); 

waterproofing sealers; and wood preservatives. Added coating categories 

include antenna coatings, anti-fouling coatings; faux finishing compounds, 

flow coatings, rust preventative coatings, and temperature-indicator safety 

coatings. 

Provisions for product-line averaging are included in the proposed rule 

amendments (consistent with the SCM), allowing manufacturers to average 

designated coatings such that their average cumulative emissions are less 

than or equal to the cumulative emissions that would be allowed under the 

rule. The 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 allowable VOC content limit) when averaging. Ceiling limits 

would protect against regional differences that could result in high VOC 

products being sold in San Diego. 

Amended Rule 67.0 does not include the SCM provision pertaining to 

petitioning the Air Pollution Control Officer to allow application of an industrial 

maintenance coating with a VOC content up to 340 grams 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 nonattainment area for the 

State ambient air quality standard for ozone. Accordingly, the APCD 

proposes amending Rule 67.0 in order to meet the “every feasible control 

measure” requirement imposed on nonattainment areas by State law 

(California Health and Safety Code (H&SC) Section 40914), 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 from architectural 

coatings. Section 40919 requires the APCD to adopt an emission limitation 
Appendix C 

-4- 

that is based on the maximum degree of reduction achievable, 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 political 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 parallel 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 highest point in the county. 

The coastal region is made up of coastal terraces that rise from the ocean 

into wide mesas which then, moving farther east, transition 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 AnzaBorrego Desert, which is characterized by several broken mountain ranges 

with desert valleys in between. To the north of the County are the Santa Ana 

Mountains which run along the coast of Orange County, 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 the semi-permanent highpressure 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 early-morning low clouds, hazy afternoon sunshine, daytime onshore 

breezes, and little temperature variation year-round. The climatic 

classification for San Diego is a Mediterranean climate, with warm, dry 

summers and mild, wet winters. Average annual precipitation ranges from 

approximately 10 inches on the coast to over 30 inches in the mountains 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 create air pollution 

problems. Sinking, or subsiding air from the Pacific High creates a 

temperature inversion (known as a subsidence inversion), which acts as a lid 

to vertical dispersion of pollutants. Weak summertime pressure gradients 

further limit horizontal dispersion of pollutants in the mixed layer below the 

subsidence inversion. Poorly dispersed anthropogenic emissions, combined 

with strong sunshine lead to photochemical reactions, which create ozone in 

this surface layer. 

Daytime onshore flow (i.e., sea breeze) and nighttime offshore flow (i.e., land 

breeze) are quite common in Southern California. The sea breeze helps to 
Appendix C 

-5- 

moderate daytime temperatures in the western portion of San Diego County, 

which greatly adds to the climatic draw of the region. This also leads to 

emissions being blown out to sea at night and returning to land the following 

day. Under certain conditions, this atmospheric oscillation results in the 

offshore transport of air from the Los Angeles region to San Diego County, 

which often results in high ozone concentrations being measured at San 

Diego County air pollution monitoring stations. Transport of air pollutants 

from Los Angeles to San Diego has also been shown to 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 transported into San Diego 

County. 

National and state air quality standards are set for criteria pollutants, which 

are widespread common pollutants known to be harmful to human health and 

welfare. Standards are set to protect the elderly, very young, and chronically 

sensitive portions of our population. Areas not meeting a particular standard 

are referred to as a non-attainment area for the pollutant. Of the six air 

pollutants regulated by the federal Environmental Protection Agency, and 

eight regulated by the California Air Resources Board, only ozone (smog) and 

inhalable particulate matter (PM10) occur in concentrations sufficient to violate 

either federal or state standards in San Diego County. 

San Diego County has experienced substantial improvement in ambient 

ozone levels over the past several years. The number 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 PM10 (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 agreement): 

Permit Type/Action Agency

Rule Approval California Air Resources Board 

SIP Approval Environmental Protection Agency 

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

natural resources potentially affected by the project: 

 California Department of Transportation 

 California Regional Water Quality Control Board 

 
Appendix 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 Significance 
Appendix 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 significant 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 effect in this case because 

revisions in the project have been made by or agreed 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 significant effect on the 

environment, and an ENVIRONMENTAL IMPACT REPORT is required. 

 I find that the proposed project MAY have a “potentially significant impact” 

or “potentially significant unless mitigated" impact 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 as 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 significant effects (a) have been 

analyzed adequately in an earlier EIR or NEGATIVE DECLARATION 

pursuant to applicable standards, and (b) have been avoided or mitigated 

pursuant to that earlier EIR or NEGATIVE DECLARATION, including 

revisions or mitigation measures that are imposed upon 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 significant 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 not have been known 

without the exercise of reasonable diligence at the time the previous 

Negative Declaration was adopted or Environmental Impact Report was 

certified. Therefore, the previously adopted NEGATIVE DECLARATION or 

certified ENVIRONMENTAL IMPACT REPORT will be considered adequate 

upon completion of an ADDENDUM to reflect minor technical changes. 
Appendix C 

-8- 

 On the basis of this Initial Study, the Department of Planning and Land Use 

believes the following: new significant environmental effects or an 

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 not have been known without the exercise of 

reasonable diligence at the time the original earlier 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 Title 
Appendix 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 lead 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 falls 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 will not expose sensitive receptors to 

pollutants, based on a project-specific screening analysis). 

2. All answers must take account of the whole action involved, including off-site as well 

as on-site, cumulative as well as project-level, indirect as well as direct, and 

construction as well as operational impacts. 

3. Once the lead agency has determined that a particular physical impact may occur, 

then the checklist answers must indicate whether the impact is potentially significant, 

less than significant with mitigation, or less than significant. “Potentially Significant 

Impact” is appropriate if there is substantial evidence 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 Incorporated” applies where the incorporation of 

mitigation measures has reduced an effect from “Potentially Significant Impact” to a 

“Less Than Significant Impact.” The lead agency must 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 discussion should identify the following: 

a) Earlier Analysis Used. Identify and state where they are available for review. 

b) Impacts Adequately Addressed. Identify which effects from the above 

checklist were within the scope of and adequately analyzed in an earlier 

document pursuant to applicable legal standards, and 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 measures that were 

incorporated or refined from the earlier document and the extent to which 

they address site-specific conditions for the project. 

6. Lead agencies are encouraged to incorporate into the checklist references to 

information sources for potential impacts (e.g., general plans, zoning ordinances). 

Reference to a previously prepared or outside document 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 reduce the impact to less than 

significance 
Appendix C 

-10- 

I. AESTHETICS -- Would the project? 

a) Have a substantial adverse effect on a scenic vista? 

 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. Therefore, 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. Therefore, no impacts to 

aesthetics are anticipated. 

c) Substantially degrade the existing visual character 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. Therefore, no impacts to 

aesthetics are anticipated. 

d) Create a new source of substantial light or glare, 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 Impact 
Appendix 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 amendments are not 

anticipated to create new, or increase existing, light sources. 

II. AGRICULTURE RESOURCES -- Would the project:

a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide 

Importance Farmland), as shown on the maps prepared pursuant to the 

Farmland Mapping and Monitoring Program of the California 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 use, 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 environment, 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 farmland, 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 rule amendments is 

expected to produce substantial, long-term, VOC emission reductions. 

However, some companies in the architectural coatings 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 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. 

These companies claim that the new formulations will result in more coating 

use, resulting in an overall increase in VOC emissions for a specific area 

covered or over time. Industry also asserts that more reactive solvents will be 

used in compliant formulation than those used in existing coatings, thus 

contributing to increased ozone formation. 

The California ARB has analyzed 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, air quality plan impacts will be 

analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0. 

b) Violate any air quality standard or contribute substantially 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 architectural coatings 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 increased 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 result in more coating use, resulting 

in an overall increase in VOC emissions for a specific area covered or over time. 

Industry also asserts that more reactive solvents will be used in compliant 
Appendix C 

-13- 

formulation than those used in existing coatings, thus contributing to increased 

ozone formation. 

The California ARB has analyzed 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, air quality impacts will be 

analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0. 

c) Result in a cumulatively considerable net increase of any criteria pollutant for 

which the project region is non-attainment under an applicable federal or state 

ambient air quality standard (including releasing emissions 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 architectural coatings 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 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. These companies claim that the new 

formulations will result in more coating use, resulting in an overall increase in 

VOC emissions for a specific area covered or over time. Industry also asserts 

that more reactive solvents will be used in compliant formulation than those 

used in existing coatings, thus contributing to increased ozone formation. 

The California ARB has analyzed 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, air quality impacts will be 

analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0. 

d) Expose sensitive receptors to substantial pollutant 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 architectural coatings industry have 
Appendix C 

-14- 

claimed that by lowering the VOC content of coatings, there will be an increase in 

VOC emissions for a variety of reasons including increased 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 result in more coating use, resulting 

in an overall increase in VOC emissions for a specific area covered or over time. 

Industry also asserts that more reactive solvents will be used in compliant 

formulation than those used in existing coatings, thus 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 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, air quality impacts will be 

analyzed in a Tier II EIR prepared for proposed amendments to Rule 67.0. 

e) Create objectionable odors affecting a substantial 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 by 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 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, objectionable 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 directly or through habitat 

modifications, on any species identified as a candidate, 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 Impact 
Appendix 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 existing plant or animal species 

or communities, unique or endangered plant or animal species, or agricultural 

crops. Improvements in air quality from implementation of these rule changes 

are expected to provide health benefits 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. 

b) Have a substantial adverse effect on any riparian habitat or other sensitive 

natural community identified in local or regional plans, policies, regulations or by 

the California Department of Fish and Game or US Fish 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 existing plant or animal species 

or communities, unique or endangered plant or animal species, or agricultural 

crops. Improvements in air quality from implementation of these rule changes 

are expected to provide health benefits 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. 

c) Have a substantial adverse effect on federally protected wetlands as defined 

by Section 404 of the Clean Water Act (including, but 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 impact existing plant or animal 

species or communities, unique or endangered plant or animal species, or 

agricultural crops. Improvements in air quality from implementation of these 

rule changes are expected to provide health benefits 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 nursery 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 impact existing plant or animal 

species or communities, unique or endangered plant or animal species, or 

agricultural crops. Improvements in air quality from implementation of these 

rule changes are expected to provide health benefits 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 protecting 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 impact existing plant or animal 

species or communities, unique or endangered plant or animal species, or 

agricultural crops. Improvements in air quality from implementation of these 

rule changes are expected to provide health benefits 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 Habitat Conservation Plan, Natural 

Community Conservation Plan, or other approved local, 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 impact existing plant or animal 

species or communities, unique or endangered plant or animal species, or 
Appendix C 

-17- 

agricultural crops. Improvements in air quality from implementation of these 

rule changes are expected to provide health benefits 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 significance 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 impact 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 significance 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 impact 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 paleontological 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 implementation of this rule 

change is not expected to adversely impact cultural resources since the proposed 
Appendix C 

-18- 

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

such resources. 

d) Disturb any human remains, including those interred 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 impact 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 substantial adverse effects, including 

the risk of loss, injury, or death involving: 

i. Rupture of a known earthquake fault, as delineated on the most recent 

Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist 

for the area or based on other substantial evidence of a known fault? 

Refer to Division of Mines and Geology Special Publication 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 and, 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, therefore, will not have any 

significant effects on geologic resources. 
Appendix C 

-19- 

iii. Seismic-related ground failure, including liquefaction? 

 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, 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 and, therefore, will not have 

any significant effects on geologic resources. 

b) Result in substantial soil erosion or the loss of 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 and, therefore, will not have 

any significant effects on geologic resources. 

c) Be located on a geologic unit or soil that is unstable, or that would become 

unstable as a result of the project, and potentially result in on- or off-site 

landslide, lateral spreading, subsidence, liquefaction 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. Implementation of these rule changes 
Appendix 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 Table 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 and, therefore, will not have 

any significant effects on geologic resources. 

e) Have soils incapable of adequately supporting the use of septic tanks or 

alternative wastewater disposal systems where sewers 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 and, 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 materials? 

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 and 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 could result in 

hazardous impacts due to its flammability. Although the California ARB has 

analyzed 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 level impacts 

have been adequately assessed is beyond the 
Appendix C 

-21- 

scope of an Initial Study. Consequently, public and 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 conditions 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 and 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 could result in 

hazardous impacts due to its flammability. Although the California ARB has 

analyzed 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 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 and 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 could result in 

hazardous impacts due to its flammability. Although the California ARB has 

analyzed 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 level 

impacts have been adequately assessed is beyond the scope of an Initial 

Study. Consequently, hazardous emission impacts will 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 and 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 could result in 

hazardous impacts due to its flammability. Although the California ARB has 

analyzed 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 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 airport or public use airport, 

would the project result in a safety hazard for people 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 and, therefore, will not create a 

safety hazard associated with development near an airport. 

f) For a project within the vicinity of a private airstrip, would the project result in 

a safety hazard for people 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 and, therefore, will not create a 

safety hazard associated with development near an airport. 
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 and, therefore, will not interfere 

with emergency response plans. 

h) Expose people or structures to a significant risk of loss, injury or death 

involving wildland fires, including where wildlands are adjacent to urbanized 

areas or where residences are intermixed with wildlands? 

 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 coatings to utilize acetone 

could result in hazardous impacts due to its flammability. 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 or 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 discharge 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 level 

impacts have been adequately assessed is beyond the 
Appendix C 

-24- 

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. 

b) Substantially deplete groundwater supplies or interfere 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 which would not support 

existing land uses or planned uses for which permits 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 level 

impacts have been adequately assessed is beyond the scope of an Initial 

Study. Consequently, groundwater impacts will be analyzed in a Tier II EIR 

prepared for proposed amendments to Rule 67.0. 

c) Substantially alter the existing drainage pattern 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 pattern 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 Impact 
Appendix 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 increase the rate or amount of 

surface runoff, therefore, will not have any significant flooding effects. 

e) Create or contribute runoff water which would exceed the capacity of existing 

or planned stormwater drainage systems or provide substantial 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 exceed the capacity of stormwater 

drainage systems, therefore, will not have any significant 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the ARB has already 

analyzed these issues in the 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 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 area as mapped on a federal 

Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard 

delineation map? 

 Potentially Significant Impact  Less than Significant Impact 



Less than Significant Impact with 

Mitigation Incorporated No Impact 
Appendix 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 structures 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 therefore will not create a flood 

hazards. 

i) Expose people or structures to a significant risk 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 therefore 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 therefore 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 Impact 
Appendix 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 therefore will not physically divide 

an established community. 

b) Conflict with any applicable land use plan, policy, 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 ordinance) 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. Therefore, no impacts to land use 

and planning are anticipated. 

c) Conflict with any applicable habitat conservation 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. Therefore, no impacts to 

conservation plans are anticipated. 

X. MINERAL RESOURCES -- Would the project: 

a) Result in the loss of availability of a known mineral 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 Impact 
Appendix 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. Therefore, 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, specific 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. Therefore, no impacts to mineral 

resources are anticipated. 

XI. NOISE -- Would the project result in: 

a) Exposure of persons to or generation of noise levels in excess of standards 

established in the local general plan or noise ordinance, 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. Therefore, no noise impacts are 

anticipated. 

b) Exposure of persons to or generation of excessive groundborne vibration or 

groundborne noise levels? 

 Potentially Significant Impact  Less than Significant Impact 



Less than Significant Impact with 

Mitigation Incorporated No Impact 
Appendix 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. Therefore, no noise impacts are 

anticipated. 

c) A substantial permanent 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. Therefore, 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. Therefore, 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 airport 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 Impact 
Appendix 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. Therefore, no noise impacts are 

anticipated. 

f) For a project within the vicinity of a private airstrip, 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 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. Therefore, 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 indirectly (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 infrastructure 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 proposed project is not expected 
Appendix C 

-31- 

to increase the need for infrastructure improvement. Therefore, no housing 

impacts are anticipated. 

c) Displace substantial numbers of people, 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 proposed project is 

not expected to increase the need for infrastructure 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 governmental facilities, need for 

new or physically altered governmental facilities, the construction of which 

could cause significant environmental impacts, in order 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 increased maintenance at public 

facilities and increased need for fire protection due to use of exempt solvents 

or other replacement solvents from implementing the proposed rule 

amendments. Although the California ARB has analyzed 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 level impacts have been 

adequately assessed is beyond the scope of an Initial Study. Consequently, 

public utility impacts will be analyzed in a Tier II EIR prepared for proposed 

amendments to Rule 67.0. 
Appendix C 

-32- 

XIV. RECREATION 

a) Would the project increase the use of existing neighborhood and regional 

parks or other recreational facilities such that substantial physical 

deterioration of the facility would occur or be accelerated? 

 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 additional 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 have 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 additional 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 substantial 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/Circulation 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. Although 

the California ARB has analyzed 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 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 level of service standard 

established by the county congestion management agency 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/Circulation 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. Although 

the California ARB has analyzed these issues in a Tier I Environmental Impact 

Report prepared for the statewide SCM for Architectural Coatings, adopted by 

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, traffic impacts will be analyzed in a Tier II EIR prepared for 

proposed amendments to Rule 67.0. 

c) Result in a change in air traffic patterns, including either an increase in traffic 

levels or a change in location that results in substantial 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/Circulation 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. 

However, these impacts are expected to occur to ground transportation, with 

minimal increases, if any, to air traffic patterns. As such the impact to air 

traffic patterns, including either an increase in traffic levels or a change in 

location that results in substantial safety risks, is less than significant. 

d) Substantially increase hazards due to a design feature (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. Compliance with this rule will not 

result in any construction or new road design features 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 road design features and, 

therefore, will not create inadequate emergency access. 

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 design features and, therefore, 

will not create inadequate parking capacity. 

g) Conflict with adopted policies, plans, or programs 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 road design features and, 

therefore, will not conflict with policies regarding 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 Impact 
Appendix C 

-35- 

Discussion/Explanation: 

Increased water demand from the manufacturing and use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 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 Rule 67.0. 

b) Require or result in the construction of new water 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 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 Rule 67.0. 

c) Require or result in the construction of new storm 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 kind, including storm water 

drainage facilities, therefore, will not have any significant environmental 

effects. 
Appendix C 

-36- 

d) Have sufficient water supplies available to serve 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 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 treatment provider, which serves 

or may serve the project that it has adequate capacity to serve the project’s 

projected demand in addition to the provider’s existing 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 use of complaint waterborne coatings, the use of exempt solvents (solvents not considered to be 

VOCs, such as acetone and Oxsol 100) and water quality impacts from future 

compliant water-borne coatings associated with manufacturing and cleanup 

practices could involve environmental impacts. Although the California ARB 

has analyzed 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 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 Rule 67.0. 

f) Be served by a landfill with sufficient permitted 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 Impact 
Appendix C 

-37- 

Discussion/Explanation: 

The proposed rule change could involve potential impacts from increased disposal of 

compliant coatings due to the possibility of shorter shelf or pot lives or lesser freezethaw capabilities and increased water demand from the manufacturing and use of 

compliant water-borne coatings. Although the California ARB has analyzed 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 level impacts have been adequately assessed is beyond 

the scope of an Initial Study. Consequently, landfill capacity impacts will be analyzed in 

a Tier II EIR prepared for proposed amendments to Rule 67.0. 

g) Comply with federal, state, and local statutes and 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 impacts from increased disposal of 

compliant coatings due to the possibility of shorter shelf or pot lives or lesser freezethaw capabilities and increased water demand from the manufacturing and use of 

compliant water-borne coatings. Although the California ARB has analyzed 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 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 amendments to Rule 67.0. 

XVII. MANDATORY FINDINGS OF SIGNIFICANCE --: 

a) Does the project have the potential to degrade the quality of the environment, 

substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife 

population to drop below self-sustaining levels, threaten 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 Resources, Cultural, and 

Paleontological Resources, the proposed project consists 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 degrade 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 drop below self-sustaining levels and will 
Appendix C 

-38- 

not threaten to eliminate a plant or animal community. Also, the project would not 

reduce the number or restrict the range of a rare or 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 individually limited, but cumulatively 

considerable? (“Cumulatively considerable” means that 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 effects 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 possible adverse effects on air quality, 

water resources, hazards, transportation/circulation, hazardous wastes, and 

public utilities/serves, the proposed project has the potential to adversely affect 

the quality of the environment. There may be adverse human health impacts 

associated with exposure to both carcinogenic and non-carcinogenic toxic air 

contaminants (TACs). These impacts may occur individually, such as elevated 

exposure to TACs, or cumulatively, if different environmental impacts reinforce 

each other. 

The California ARB has analyzed 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. However, further review of these issues to ensure that 

District level impacts have been adequately assessed is required. As such, a Tier II 

Environmental Impact Report should be prepared to assess local impacts from the 

Rule 67.0 amendments. 

c) Does the project have environmental effects, which will cause substantial adverse 

effects on human beings, either directly or indirectly? 

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 possible adverse effects on air quality, 

water resources, hazards, transportation/circulation, hazardous wastes, and public 

utilities/serves, the proposed project has the potential to adversely affect the 

quality of the environment. There may be adverse human health impacts 

associated with exposure to both carcinogenic and non-carcinogenic toxic air 

contaminants (TACs). These impacts may occur individually, such as elevated 

exposure to TACs, or cumulatively, if different environmental impacts reinforce 

each other. 
Appendix C 

-39- 

The California ARB has analyzed 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. However, further review of these issues to ensure that 

District level impacts have been adequately assessed is required. As such, a Tier II 

Environmental Impact Report should be prepared to assess local impacts from the 

Rule 67.0 amendments.