ATTACHMENT VI 

COMPARISON OF PROPOSED RULE REQUIREMENTS 

WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS 

Health and Safety Code Section 40727.2 requires air districts to compare the requirements of 

a proposed revised rule with other air pollution control requirements. These other air 

pollution control requirements include federal regulations, Best Available Control 

Technology (BACT), and any other district rule applying to the same equipment or process. 

The proposed amendments to Rule 67.0 are based on the Air Resources Board Suggested 

Control Measure for Architectural Coatings (SCM). The proposed amendments establish 

more stringent VOC content limits than those found in the United States Environmental 

Protection Agency’s (EPA) National Architectural Coatings Rule. Architectural coating 

operations are exempt from permits and, therefore, not subject to Best Available Control 

Technology requirements. No other District rules have air pollution control requirements that 

would conflict with Rule 67.0 requirements. 

Comparison with EPA’s National Architectural Coatings Rule

There are several significant differences between the proposed amended Rule 67.0 and the 

National Architectural Coatings Rule, which became effective on September 13, 1999. The 

National Rule only applies to manufacturers and importers of architectural coatings while Rule 

67.0 has, in the past, and will continue to apply to manufacturers, distributors, retailers, and 

users of architectural coatings. The National Rule generally has less stringent VOC limits than 

Rule 67.0. For example, the VOC content limits in the National Rule for the three largest 

categories (flats, non-flats, and industrial maintenance coatings) are 250, 380, and 450 grams 

per liter, respectively. The VOC limits for the same categories in the proposed amendments to 

Rule 67.0 are 100, 150 (excluding high-gloss nonflats), and 250 grams per liter, respectively. 

The National Rule includes 16 additional specialty coating categories not included in the state 

SCM nor the proposed amendments to Rule 67.0. ARB has analyzed these additional national 

categories and found it was not necessary to add them to the SCM because either: (1) they are 

included in other specialty coating categories in existing district rules; (2) they are not 

architectural coatings; or, (3) they are not sold in California. The District has reviewed the 

additional National Rule categories and concurs with ARB’s analysis. 

Comparison of Air Pollution Control Requirement Elements

Health and Safety Code Section 40727.2.(c) requires review of the following elements in the 

comparative analysis: 

• Averaging provisions, units, and any other pertinent provisions associated with 

emission limits. 

• Operating parameters and work practice requirements. 

• Monitoring, reporting and recordkeeping requirements, including test methods, 

format, content, and frequency. 

• Any other element the district determines warrants review. 
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The coating (emission) limits in proposed amendments to Rule 67.0 are stated in units of 

grams of VOC per liter of coating, which are identical to the units in the state SCM and the 

EPA National Rule. 

There are no air pollution control requirements involving operating parameters in any of the 

rules subject to this analysis. The proposed amendments to Rule 67.0 do not include the state 

SCM’s work practice requirement to close coating and solvent containers when not in use. 

However, this requirement is already addressed under existing District Rule 67.17. 

There are no monitoring or recordkeeping requirements (except for the optional manufacturer 

averaging provisions) in the proposed amendments to Rule 67.0. ARB reporting requirements 

have been included for manufacturers to report sales of the following specialty coatings: clear 

brushing lacquers; rust preventative coatings; specialty primers, sealers and undercoaters; 

recycled coatings; and bituminous coatings. In addition, manufacturers of coatings containing 

perchloroethylene or methylene chloride must report sales in California for the prior year. 

These reporting requirements are not required by EPA’s National Rule but were included in the 

state SCM. 

The proposed amendments to Rule 67.0 include test methods needed to determine VOC 

content and other coating characteristics. These test methods do not conflict with test methods 

cited in the National Rule. 

The District has determined there are no other air pollution control requirements of proposed 

amended Rule 67.0 subject to review in this comparative analysis.