ATTACHMENT B

SOCIOECONOMIC IMPACT ASSESSMENT

PROPOSED AMENDED RULE 67.11 -

WOOD PRODUCTS COATING OPERATIONS

August 2011

Prepared by

San Diego County Air Pollution Control District

10124 Old Grove Road

San Diego, CA 92131
SOCIOECONOMIC IMPACT ASSESSMENT

PROPOSED AMENDED RULE 67.11 -

WOOD PRODUCTS COATING OPERATIONS 

TABLE OF CONTENTS

PAGE

EXECUTIVE SUMMARY 1

I. INTRODUCTION 2

II. NECESSITY OF AMENDING RULE 67.11 3

III. SUMMARY OF PROPOSED AMENDED RULE 67.11 3

IV. TYPE OF INDUSTRIES AFFECTED BY AMENDED RULE 67.11 4

V. EMISSION REDUCTION POTENTIAL AND COST-EFFECTIVENESS OF PROPOSED AMENDED RULE 5

VI. RANGE OF PROBABLE COSTS TO INDUSTRY INCLUDING SMALL BUSINESS 6

REFERENCES
SIA for SDAPCD Rule 67.11 B - 1

EXECUTIVE SUMMARY

This report represents the results of a socioeconomic impact assessment (SIA) of the San Diego 

County Air Pollution Control District’s (District) proposed amended Rule 67.11 – Wood 

Products Coating Operations. The proposed amended rule will help fulfill State law requiring 

the adoption of all feasible control measures and federal law requiring Reasonably Available 

Control Technology (RACT).

The proposed amended rule will lower the volatile organic compound (VOC) content limit for 

several wood coating categories, and surface preparation and cleaning materials. The small 

usage exemption limit for stationary sources will be reduced from 500 gallons to 20 gallons of 

coatings per consecutive 12 months. The new 20 gallon limit is consistent with the permitting

exemption threshold in Rule 11 – Exemptions from Rule 10 Permit Requirements, and will not 

result in any additional facilities being subject to Rule 67.11. The amended rule also includes 

new and revised definitions and updated test methods for determining compliance. Additionally, 

the District proposes to repeal outdated Rule 67.11.1 – Large Coating Operations for Wood 

Products, which applies only to facilities that emit 25 tons or more of VOC per calendar year. 

These same large sources are also subject to existing Rule 67.11, and therefore the repeal will 

have no impact on existing facilities or on VOC emissions in the County of San Diego. 

The rule applies to 125 permitted facilities in San Diego County involved in wood products 

coating operations. Of these 125 facilities, about 80 will have to replace their higher VOC 

content wood coatings with lower VOC content coatings. The other 45 facilities are either 

already complying with the proposed limits or have operations that are exempt from the 

standards of the rule. Compliant coatings are widely available in the marketplace at prices not 

much different from the products complying with the existing rule.

The total annual VOC emissions from wood coating operations in San Diego County are 

approximately 157 tons per year (0.43 tons per day). Lowering the VOC content limit of several

wood coatings and reducing the rule applicability limit will result in emission reductions of 

approximately 19 tons of VOC per year, a 12% reduction. 

The proposed amendments are not expected to have a significant socioeconomic impact on 

affected industries. The SIA also demonstrates that proposed emission limits in the rule are

feasible and that compliant materials are available in the marketplace. The estimated costeffectiveness of Rule 67.11 amendments will range from $0.51 to $1.78/lb of VOC emissions 

reduced, well within the District threshold for rules regulating VOC emissions that reflect 

Reasonably Available Control Technology. 
SIA for SDAPCD Rule 67.11 B - 2

I. INTRODUCTION

California law requires air pollution control districts (excluding those with populations of less 

than 500,000 people) to perform a socioeconomic impact assessment (SIA) when adopting, 

amending, or repealing rules and regulations that will significantly affect air quality and emission 

limitations. 

Health and Safety (H&S) Code Section 40728.5, subdivision (b), specifies the following 

elements to be included in the socioeconomic impact assessment:

1. The type of industries or business, including small business, affected by the rule or 

regulation.

2. The impact of the rule or regulation on employment and the economy of the region affected 

by the adoption of the rule or regulation.

3. The range of probable costs, including costs to industry or business, including small business, 

of the rule or regulation.

4. The availability and cost-effectiveness of alternatives to the rule or regulation.

5. The emission reduction potential of the rule or regulation.

6. The necessity of adopting, amending, or repealing the rule or regulation in order to attain 

State and federal ambient air quality standards.

Pursuant to H&S Code Section 40728.5(e), the analyses specified in paragraphs (2) and (4) 

above are not required, upon approval by a majority vote of the District Board, if the proposed 

rule is substantially similar to, or required by, a state or federal law, regulation, or formal 

guidance document, including federal Control Techniques Guidelines (CTGs)

The proposed amendments to Rule 67.11 are required by federal law. Specifically, the District 

must require Reasonably Available Control Technology (RACT) on all sources covered by a 

federal CTG. The wood furniture CTG was issued 15 years ago (in 1996) and its requirements

have since become outdated and no longer represent RACT, according to EPA. In this case, the 

District must determine RACT by reviewing the existing wood coating regulations in other air 

districts in California. If a more stringent requirement in another district would be technically 

feasible and cost-effective for local sources, then that requirement is considered RACT and must 

be implemented by the District. The proposed amendments to Rule 67.11 were developed to 

satisfy this federal RACT requirement. Therefore, the analyses specified in paragraphs (2) and 

(4) above are not required, upon approval by a majority vote of the District Board.
SIA for SDAPCD Rule 67.11 B - 3

II. NECESSITY OF AMENDING RULE 67.11

San Diego County does not meet the National and State Ambient Air Quality Standards for 

ozone and is classified as an ozone nonattainment area. Consequently, emissions of air 

pollutants that form ozone, including VOCs, must be reduced. State and federal laws require the 

District to implement new rules or amend existing rules to control VOC emissions from 

stationary sources as control technologies improve or control costs are reduced.

The existing Rule 67.11 regulates VOC emissions resulting from the coating of wood products 

and associated cleaning operations. The rule was first adopted in 1989 and last amended in 

2002. Since then, several other air districts in California have amended their corresponding rules 

to further reduce VOC emissions from wood coating operations. Proposed amended Rule 67.11 

will reflect the current availability of coating and cleaning materials with lower VOC content and 

will generally update the rule, where necessary.

The amended rule will also help to fulfill the District’s commitment in the San Diego County 

Regional Air Quality Strategy to implement all feasible emission control measures as required by 

State law, as well as the federal requirement for implementing Reasonably Available Control 

Technology in rules regulating sources of VOC emissions. 

III. SUMMARY OF PROPOSED AMENDED RULE 67.11

Amended Rule 67.11 will:

 Reduce the small usage exemption limit for a stationary source from 500 gallons to 20 

gallons or less of coatings per consecutive 12-month period, provided that the specified 

records are kept. 

 Exempt wood coating operations that emit 150 pounds or less of VOC per consecutive 

12-month period, excluding emissions from surface preparation, cleanup, and stripping 

materials, from most sections of the rule, provided that the required records are kept. 

 Exempt wood coating operations that use no more than 20 gallons of non-compliant 

coatings per consecutive 12-month period from most sections of the rule, provided that 

not more than 20 gallons of such non-compliant coatings are used at the stationary source 

and the specified records are kept.

 Update definitions for major terms used in the rule.

 Reduce VOC content limits for specified wood coatings applied to new wood products, 

including low-solids coatings.

 Remove outdated references and the subsection specifying VOC content limits for 

coatings used in large coating operations. These separate limits are no longer needed 

because the same VOC content limits will apply to all facilities, regardless of their size.
SIA for SDAPCD Rule 67.11 B - 4

 Reduce the VOC content limit for surface preparation and equipment cleaning materials 

to 25 grams or less of VOC per liter of material.

 Reduce the total VOC vapor pressure limit for stripping materials to 2 mm Hg or less, at 

20°C (68°F).

 Clarify and update record keeping requirements for persons conducting operations 

subject to this rule.

 Update the test methods for determining compliance.

Additionally, the District proposes to repeal outdated Rule 67.11.1 – Large Coating Operations 

for Wood Products, which applies only to facilities that emit 25 tons or more of VOC per 

calendar year. These same large sources are also subject to existing Rule 67.11, and therefore 

the repeal will have no impact on existing facilities or on VOC emissions in the County of San 

Diego. 

IV. TYPE OF INDUSTRIES AFFECTED BY AMENDED RULE 67.11

Proposed amended Rule 67.11 will affect owners and operators of companies involved in wood 

products coating operations. The following table presents the list of industries, and their North 

American Industry Classification System (NAICS) codes, that could be impacted by the 

proposed amended rule. 

Table 1. NAICS Classification of Industries

Type of Industries NAICS Code

Wood Window and Door Manufacturing 321911

Other Millwork (including Flooring) 321918

All Other Miscellaneous Wood Product Manufacturing 321999

Wood Kitchen Cabinet and Countertop Manufacturing 337110

Upholstered and Non-upholstered Wood Household Furniture Manufacturing 337121, 337122

Institutional Furniture Manufacturing 337127

Wood Office Furniture Manufacturing 337211

Custom Architectural Woodwork and Millwork Manufacturing 337212

Re-upholstery and Furniture Repair 811420

There are approximately 125 permitted facilities in San Diego County involved in wood coating 

operations and subject to current Rule 67.11. These facilities vary in size from one and two 

person shops engaged in cabinet making or furniture refinishing to manufacturing facilities 

employing over 100 people. About half of all facilities subject to Rule 67.11 employ less than 

10 employees. Approximately 25% of companies employ over 100 people. 
SIA for SDAPCD Rule 67.11 B - 5

Affected businesses also vary in the types of products they manufacture. About 80% of facilities 

are involved in either kitchen cabinet or furniture making (including refinishing operations). The 

remaining 20% of facilities are involved in window and door manufacturing or other millwork 

manufacturing. A few businesses manufacture musical instruments and therefore are exempt 

from the VOC content coating limits in the rule.

Businesses in the wood coating industry also vary greatly in the type of coatings they use. Wood 

coatings include various stains, sealers, paints, lacquers and specialty coatings which are applied 

to numerous types of wood products. Some examples of wood products typically coated include 

bookcases, desks, entertainment centers, bedroom furniture, spa housings, shutters, kitchen and 

bathroom cabinets, and custom household and church furniture. 

 

Wood coatings are primarily air-dried coatings, though some coatings require drying with heated 

air or lamps. Depending upon the quality of the final wood product, several different types of 

coating processes are used. While a coating system may be as simple as a single stain 

application, the most common system consists of three parts, and typically contains a stain, 

sealer and topcoat. A few high quality systems may require seven or eight coating steps. Most 

coatings are applied with high transfer efficiency equipment such as High Volume-Low Pressure 

(HVLP) spray guns, flow coating, hand wiping, rollers or brushes.1 

Coating application equipment such as spray guns, hoses, cups and pots are typically cleaned by 

soaking, wiping, flushing, or spraying the equipment within an enclosed container with organic 

solvents (i.e., acetone). For equipment used with water-based coatings, water is often used to 

clean the equipment. 

V. EMISSION REDUCTION POTENTIAL AND COST-EFFECTIVENESS OF 

PROPOSED AMENDED RULE

1. Emission reductions.

The proposed amendments to Rule 67.11 will reduce the VOC content limit of five wood coating 

categories: fillers, high-solids stains, multi-colored coatings, sealers, and low-solids coatings. 

The amendments will also lower the small usage exemption for a stationary source from 500 

gallons to 20 gallons of coatings or less per consecutive 12-months, requiring those currently 

exempt facilities to comply with the VOC content standards of the rule. The new 20 gallon limit 

is consistent with the permitting exemption threshold in Rule 11 – Exemptions from Rule 10 

Permit Requirements, and will not result in any additional facilities being subject to Rule 67.11. 

In addition, the amendments will require surface preparation and equipment cleaning materials to 

comply with a VOC content limit of 25 grams per liter, reduced from 200 grams per liter.

According to the District’s files, the proposed amendments will impact approximately 80 of the 

total 125 permitted facilities subject to the rule. The other 45 facilities are either already 

complying with the proposed limits or have operations that are exempt from the standards of the 

rule. The total annual VOC emissions from wood coating operations in San Diego County are

approximately 157 tons per year (0.43 tons per day).

2

Lowering the VOC content limit of the 
SIA for SDAPCD Rule 67.11 B - 6

above mentioned wood coatings will result in emission reductions of approximately 19 tons of 

VOC per year, a 12% reduction. 

No significant emission reductions are expected from lowering the VOC content limit of surface 

preparation and equipment cleaning materials from 200 grams per liter to 25 grams per liter. The 

majority of permitted facilities already use either acetone (an exempt compound) or water for 

cleaning or surface preparation. The lower VOC content limit was included in the proposed 

amended rule to reflect the availability of low VOC content cleaning materials and for 

consistency with other District rules regulating VOC emissions and with other regions.

2. Cost-Effectiveness of the proposed rule.

Many air districts in California, including large districts such as Bay Area and South Coast Air 

Quality Management District (SCAQMD), have very similar or more stringent wood products 

coating rules. Consequently, low VOC content wood coatings and cleaning materials are widely 

available in the marketplace at prices not much different from products with higher VOC content 

sold.

The information obtained from local wood coating manufacturers show that there is no 

significant difference between the cost of wood coatings that comply with the proposed amended 

rule and those presently being used. For example, a high VOC content sealer is sold for about 

$16 per gallon, while a low VOC content product costs about $17 per gallon. 

Some of the 50 permitted facilities currently using less than 500 gallons of wood coatings per 

year, and thus exempt from portions of the current rule, may need to replace their current spray 

guns with High-Volume Low-Pressure (HVLP) spray guns to comply with the proposed 

amended rule. For this analysis, it was assumed that 10% of these previously exempt facilities 

will have to purchase HVLP spray guns at a cost of $500 per facility. 

The estimated cost-effectiveness of Rule 67.11 amendments will range from $0.51/lb of VOC 

emissions reduced for facilities only replacing their high VOC content coatings, to $1.78/lb of 

VOC emissions reduced for facilities also having to upgrade to an HVLP spray gun. These

values are significantly lower than the District’s cost-effectiveness threshold of $6/lb of VOC 

reduced for prohibitory rules reflecting RACT.

VI. RANGE OF PROBABLE COSTS TO INDUSTRY INCLUDING SMALL 

BUSINESS

Historically, for purposes of SIAs, the District has defined a small business as an entity that 

meets all of the conditions below.

1. The business is independently owned and operated. (California Government Code,

Section 11342.610, Small Business definition)

2. The business is not dominant in its field of operation. (Same)
SIA for SDAPCD Rule 67.11 B - 7

3. The business has gross annual receipts not more than $500,000. (SCAQMD, Rule 102)

4. The business employs ten persons or less. (SCAQMD Rule 102)

5. The business has total annual VOC emissions less than 10 tons. (H&S Code, Section 42323, 

Small Stationary Source)

According to the District’s permit files and information obtained from the California 

Employment Development Department,

3

57 of the total 125 permitted facilities subject to the 

proposed amended rule meet all conditions mentioned above. 

As mentioned previously, all wood coatings complying with the VOC content limits in the 

proposed amended rule are presently available in the marketplace. This is due to other districts 

in California having adopted similar wood product coating regulations, in particular by the 

adjacent SCAQMD. Those facilities that have to replace their high VOC content wood coatings 

can find compliant coatings at comparable prices. 

The estimated cost-effectiveness of Rule 67.11 amendments will range from $0.51 to $1.78/lb of 

VOC emissions reduced. It is expected that the cost-effectiveness for small business will fall in 

the higher end of the range at $1.78/lb of VOC reduced, because they are more likely to have to 

upgrade to an HVLP spray gun. Therefore, the proposed amendments are not expected to have a 

significant impact on affected facilities, including small business. 
SIA for SDAPCD Rule 67.11 B - 8

References

1. San Diego Air Pollution Control District. Final Staff Report for the SDAPCD Rule 67.11 –

Wood Parts & Products Coating Operations, July 1995.

2. California Air Resources Board, Almanac Emission Projection Data by EIC, San Diego 

County APCD, for 2008. http://www.arb.ca.gov/app/emsinv

3. California Employment Development Department, Labor Market Information.

http://www.labormarketinfo.edd.ca.gov