SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-1 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

APPENDIX C 

Cost Effectiveness Analysis 

September 16, 2010 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

This page intentionally blank. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-3 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

I. SUMMARY 

Rule 4653 applies to any person who supplies, sells, offers for sale, or applies any 

adhesive product, or associated solvents for use within the San Joaquin Valley Air 

Basin (SJVAB). Amendments to Rule 4653 would make the VOC content limits of some 

types of adhesives more stringent than they currently are to fulfill commitments in the 

District 2007 Ozone Plan. Amendments to Rule 4653 will also add sealants and sealant 

primers to rule language as newly regulated sources. 

The California Health and Safety Code 40920.6(a) requires the San Joaquin Valley 

Unified Air Pollution Control District to conduct both an "absolute" cost effectiveness 

analysis and an “incremental” cost effectiveness analysis of available emission control 

options prior to adopting each Best Available Retrofit Control Technology (BARCT) rule. 

The purpose of conducting a cost effectiveness analysis is to evaluate the economic 

reasonableness of the pollution control measure or rule as it applies to operators in the 

San Joaquin Valley Air Basin. The analysis also serves as a guideline in developing the 

control requirements of a rule. 

Incremental cost effectiveness is intended to measure the change in costs (in $/year) 

and emissions reductions (in tons reduced/year) between two progressively more 

effective control options or technologies. For this rule project, the limits are considered 

the lowest achieved in practice, therefore, no incremental cost effectiveness analysis 

was conducted. 

For this project the compliance costs are associated with purchasing new adhesive, 

adhesive primer, sealant and sealant primer products with complaint VOC content 

limits. District staff used available cost information obtained from Internet searches, 

store visits, and staff reports from other Air Districts to conduct a cost effectiveness 

analysis of the proposed-amendments to Rule 4653. Products with proposed adhesive 

and sealant VOC content limits are readily available at the same price points as 

adhesives products with current VOC content limits that will become non-compliant 

upon rule implementation on January 1, 2012. Availability of product, combined with the 

proposed sell through period of 12 months for existing products and 24 month provision 

for use of no longer compliant materials has led staff to conclude that there would be no 

significant adverse impacts on the profitability of businesses affected by the rule. 

II. COST EFFECTIVENESS ANALYSIS 

A. Absolute Cost Effectiveness Analysis 

Absolute cost effectiveness of a control option is the added cost of a control technology 

or technique, divided by the emission reduction achieved (in tons reduced per year). 

The costs typically include capital equipment costs, engineering costs, labor and 

maintenance costs. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-4 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

This cost effectiveness analysis accounts for the costs associated with this ruleamending project. Proposed rule language indicates that the VOC content limits for 

certain adhesive categories will become more stringent on and after January 1, 2011. 

The costs associated with the amendments effective on and after January 1, 2011 were 

accounted for during the previous rule-amending project to adopt EPA CTG 

requirements. 

It is important to note that the proposed VOC content limits for Adhesives and Adhesive 

Primers are not more stringent than existing VOC content limits of the same adhesive 

categories in other air districts. The proposed VOC content limits have been in effect 

for several years in other air districts, for example, South Coast Air Quality Management 

District (SCAQMD), Bay Area Air Quality Management District (BAAQMD), San Diego 

Air Pollution Control District (SCAPCD), and Ventura County Air Pollution Control 

District (VCAPCD). As indicated in table C-1, the proposed VOC content limits have 

been in rule language of adhesives rules in other air districts for five to eight years. 

Therefore, these products are readily available and currently sold in stores. Searches 

have indicated that the adhesives with the proposed VOC content limits are available in 

stores, and at the same price points as adhesives with VOC contents that will become 

non-compliant upon rule implementation on January 1, 2012. 

Table C-1 Adhesives Rules in Other Air Districts 

Air 

District Adhesive Rule Number 

Rule 

Adoption 

Date 

Last Amendment 

Date 

BAAQMD Regulation 8 Rule 51 11/18/92 7/17/02 

SDAPCD 67.21 12/16/98 5/14/08 

SCAQMD 1168 4/7/89 1/7/05 

VCAPCD 74.2 6/8/93 1/11/05 

The following tables illustrate the adhesive product categories that would become more 

stringent with this rule-amending project effective on and after January 1, 2012. Also, 

Table C-4 indicates the new categories of sealants and sealant primers that would be 

added to rule language as newly regulated categories. The tables include current VOC 

content limits, as appropriate, and new VOC content limits that would become effective 

on and after January 1, 2012. 

In Table C-2 some of the adhesive products listed are currently regulated as a different 

adhesive category. These adhesive categories would be new to regulation even though 

the product is currently regulated under a different category. In such instances, the 

previous adhesive product category is listed in the second column of the table. 

Adhesives with an “n/a” listed for the 2011 VOC content limit are categories that are 

new to regulation and were previously unregulated. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-5 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table C-2 Adhesive Categories with Current and Proposed VOC Content Limits 

VOC Limit 

Effective on and 

after January 1, 

2011 

VOC Limit 

Effective on and 

after January 1, 

2012 

Adhesive Category 

Previous Adhesive 

Category (Grams per Liter) (Grams per Liter) 

Multipurpose Construction 200 70 

Ceramic Tile Adhesive 130 65 

Cove Base Installation 150 50 

Dry Wall and/or Panel Adhesive Multipurpose Construction 200 50 

Ceramic Floor Tile Installation 130 65 

Indoor Carpet Adhesive Floor Covering Installation 150 50 

Carpet Pad Adhesive Floor Covering Installation 150 50 

Rubber Flooring Adhesive Floor Covering Installation 150 60 

Subfloor Adhesive Floor Covering Installation 150 50 

VCT and Asphalt Tile Adhesive Floor Covering Installation 150 50 

Wood Flooring Adhesive Floor Covering Installation 150 100 

Non-Membrane Roof Adhesive n/a 300 

Structural Wood Member 

Adhesive Multipurpose Construction 200 140 

Contact Adhesive 250 80 

Motor Vehicle Weatherstrip 

Adhesive n/a 750 

Traffic Marking Tape Adhesive/ 

Primer 

Contact 

Adhesive/Adhesive Primer 250 150 

Top and Trim Adhesive n/a 540 

Thin Metal Laminating Adhesive n/a 780 

Elastomeric Adhesive n/a 750 

ABS Welding Adhesive 400 325 

Cellulosic Plastic Welding 

Adhesive n/a 100 

Styrene-Acrylonitrile Welding 

Adhesive n/a 100 

Plastic Cement Welding 

Adhesive Primer 650 400 

Other Plastic Cement Welding 

Adhesive 450 250 

Automotive Glass Primer n/a 700 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix C: Cost Effectiveness Analysis September 16, 2010 

C-6 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4653 

Table C-3 VOC Content Limits for Adhesive Products

VOC Limit Effective on 

and after January 1, 

2011 

VOC Limit Effective on 

and after January 1, 

2012 Material Bonded 

[Grams Per Liter] [Grams Per Liter] 

Porous Materials 120 50 

Plastic Foam 120 50 

Fiberglass 250 80 

Table C-4 VOC Content Limits for Sealants and Sealant Primers 

VOC Limit Sealant Product (grams per liter) 

Architectural Sealant 250 

Architectural Non Porous Sealant Primer 250 

Architectural Porous Sealant Primer 775 

Marine Deck Sealant and Sealant Primer 760 

Modified Bituminous Sealant Primer 500 

Non-Membrane Roof Sealant 300 

Single-Ply Roof Sealant 450 

Roadway Sealant 250 

Other Sealants 420 

Other Sealant Primers 750 

B. Incremental Cost Effectiveness Analysis 

Incremental cost effectiveness (ICE) is intended to measure the change in costs (in 

$/year) and emissions reductions (in tons reduced/year) between two progressively 

more effective control options or technologies. ICE compares the differences in costs 

and the differences in emissions reductions of candidate control options. ICE does not 

reveal the emission reduction potential of the control options. Unlike the absolute cost 

effectiveness analysis that identifies the control option with the greatest emission 

reduction, ICE does not present any correlation between emission reductions and cost 

effectiveness. Therefore, the relative values produced in the ICE analysis and the 

absolute cost effectiveness values are not comparable and cannot be evaluated 

similarly. 

The District is required to conduct an ICE analysis for BARCT rules or emission 

reduction strategies in accordance with Health and Safety Code Section 40920.6 when 

there is more than one control option. No incremental cost increases are expected to 

occur since there are no other lower emission control options. As such, staff did not 

conduct an ICE analysis.