UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District Rule 323.1

Architectural Coatings

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

September 2015
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RULE IDENTIFICATION -

Agency Santa Barbara County Air Pollution Control District

(SBCAPCD)

SIP Approved 

Rule

There is no previous version of this rule

Subject of this 

TSD

Rule 323.1 Adopted June 19, 2014

Submitted – November 6, 2014

Completeness 

Finding

Determination of Completeness letter: December 18, 

2014

Effective Date

of Rule

January 1, 2015

BACKGROUND – The SBCAPCD has been classified for the 8-hour ozone 

standard as unclassifiable/ attainment. According to the Staff Report,”The intent

of new Rule 323.1 is to reduce volatile organic compound (VOC) emissions from

coatings used in the painting of buildings and other structures.”

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“The Santa Barbara County Air Pollution Control District (District) expects Rule

323.1 will reduce VOC emissions by about 98 tons per year (TPY) in planning

year 2020, thereby cleaning the air and allowing progress toward meeting state

health standard for ozone. The estimated 98 TPY emission reduction is in 

addition to the emission reduction already achieved by the existing Rule 323.”2

“Current Rule 323 established limits on the VOC content of architectural coatings 

supplied, sold, offered for sale, applied, solicited for application, or manufactured 

for use within the District. We propose to update the architectural coatings rule 

requirements in a new Rule 323.1 and ultimately phase out Rule 323. With this 

approach, stores can sell existing Rule 323-compliant coatings up to three years 

after Rule 323.1 becomes effective.”

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“Staff proposes to lower architectural coating VOC content limits for consistency

with the California Air Resources Board Suggested Control Measure (SCM) for 

Architectural Coatings (adopted October 26, 2007), which other air districts have 

adopted and implemented.”

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This is being accomplished by an alignment that is almost identical to the SCM 

except for section numbers, headings, added definitions, updated VOC 

exemptions and updated testing methods.

RULE SUMMARY – SBCAPCD Rule 323.1 controls VOC emissions from 

architectural coatings by establishing VOC limits on any architectural coating that 

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

Architectural coatings are coatings that are applied to stationary structures and 

 

1 Project Description Summary of the Effects of New Rule 323.1, Architectural Coatings (Staff 

Report), SBCAPCD, May 15, 2014. P1.

2 Ibid.

3 Ibid.

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

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

coatings during application and from the associated solvents used for thinning and 

clean-up. Rule 323.1 establishes more stringent VOC limits than SBCAPCD’s 

existing architectural coating Rule 323, but Rule 323.1 allows sources to sell 

existing stock of higher-VOC coatings for three years. After the three-year sellthrough period expires, SBCAPCD intends to remove Rule 323 and rely only on 

the more stringent Rule 323.1

EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule.

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

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

Bluebook (Guidance Document for Correcting Common VOC & Other Rule 

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

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

2. Stringency – SBCAPCD has been classified for the 8-hour ozone standard 

as unclassifiable/attainment. The district has no obligation to satisfy Clean 

Air Act (CAA) section 182 Reasonably Available Control Techniques 

(RACT) or other similar CAA stringency thresholds because architectural 

coating is an area source and not a stationary source and because the area 

is not a moderate or above ozone nonattainment area. Nonetheless, we 

have evaluated the rule for RACT-level controls as well as against EPA’s 

National Volatile Organic Compound Emission Standard for Architectural 

Coatings (40 CFR Part 59 Subpart D), and against the California Air 

Resources Board’s (CARB) Suggested Control Measures (SCM) for 

Architectural Coatings, which is the basis for most of the most stringent 

architectural coating requirements in California.

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

that would interfere with any applicable requirement concerning attainment 

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

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

nonattainment area.

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

guidance and policy documents:

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

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

2. Guidance Document for Correcting Common VOC and Other Rule 

Deficiencies, EPA Region IX (August 21, 2001, the “Little Bluebook”).
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3. State Implementation Plans; General Preamble for the Implementation of 

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

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

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

71612 (Nov. 25, 2005).

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

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

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

sufficiently ensure that affected sources and regulators can evaluate and 

determine compliance with Rule 323.1 consistently. 

2. Rule 323.1 is as stringent as the SCM and more stringent than 40 CFR Part 

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

controls. 

3. Rule 323.1 is more stringent than the existing requirements in Rule 323. 

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

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

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

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

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

control requirements that they would replace.

RULE DEFICIENCIES – We find no deficiencies with Rule 323.1 to preclude 

anything but a full approval of Rule 323.1.

EPA ACTION - The submitted Rule 323.1 strengthens the SIP, and the 

associated District staff report projects it will reduce VOC emissions by 

approximately 98 tons/year in 2020. The rule largely fulfils the relevant CAA §110 

and part D requirements. Therefore, EPA staff recommends full approval of Rule 

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

REFERENCES

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

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

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

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

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

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

3. Project Description Summary of the Effects of New Rule 323.1, 

Architectural Coatings (Staff Report), SBCAPCD, May 15, 2014.
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4. SBCAPCD Rule 323, Architectural Coatings, adopted November 15, 2001; 

granted a limited approval limited disapproval into the SIP, January 2, 2004 

(69 FR 34).

5. SBCAPCD Rule 323.1 Architectural Coatings, Adopted June 19, 2014,

Submitted November 6, 2014.

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

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

Architectural Coatings (40 CFR Part 59 Subpart D).