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 

9150 Chesapeake Drive – San Diego – California 92123-1096 – (858) 650-4700 

FAX (858) 650-4659 – Smoking Vehicle Hotline – 1-800-28-SMOKE

DATE: December 12, 2001 

TO: San Diego County Air Pollution Control Board 

 

SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

 

SUMMARY: 

 

Overview 

 Rule 67.0 was first adopted in 1977 to regulate volatile organic compounds (VOC) 

emissions from architectural coatings. The rule applies to the manufacture, sale, and 

use of architectural coating, which include a variety of residential, commercial, and 

industrial paints, stains, varnishes, and other coatings. 

In an effort to develop an architectural coatings rule that could be implemented by all air 

districts in the state, a Suggested Control Measure (SCM) was developed by the districts, 

through the California Air Pollution Control Officers Association (CAPCOA), and the 

Air Resources Board (ARB) staff over a two-year period. The ARB adopted the SCM in 

June 2000. The SCM is based on work related to a similar rule adopted by the South 

Coast Air Quality Management District. 

The proposed amendments also implement a state-mandated requirement for all 

feasible control measures, necessary because the District is not yet in attainment of the 

state ambient air quality standard for ozone. The 2001 Regional Air Quality Strategy 

Update adopted by the Air Pollution Control Board on August 8, 2001 (APCB #1), 

includes a commitment to adopt these revisions. 

As part of this effort, the District utilized many of the analyses and documents prepared 

by ARB in support of the SCM after finding that these materials were applicable to San 

Diego. The proposed changes are consistent with the SCM provisions to provide for: 

consistent definitions and VOC limits to facilitate coating manufacturers’ ability to 

comply, an optional, statewide VOC emissions averaging program, and avoiding 

possible litigation that might be brought by certain industry groups opposed to more 

stringent rules. 

Similar rules have been adopted by other California air pollution control districts, 

including South Coast, Sacramento, Bay Area, Ventura, Santa Barbara, and the San 

Joaquin Valley. South Coast was sued over its more stringent rule. South Coast 

prevailed in the trial court, but the case is still on appeal. Sacramento, the first air district
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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to adopt ARB’s SCM in May of this year, was not sued over its rule. Coating 

manufacturer representatives will likely attend the Rule 67.0 hearing to comment on the 

proposed amendments. 

Nineteen (19) new coating categories have been added; the allowable VOC content 

limits for 18 coating categories decrease on January 1, 2003, and one coating category 

on January 1, 2004; container labeling specifications (e.g. date of manufacture code, 

VOC content, thinning recommendations) and manufacturer reporting requirements 

for selected coating categories have been added; and various definitions and test 

methods updated. Manufacturers may use a temporary emissions averaging program, 

operated statewide by the ARB, to comply with the new VOC content limits from 

January 2003 through 2005. 

The amendments will reduce VOC emissions by approximately 1.5 tons per day 

(approximately 500 tons per year) when fully implemented in 2005. The estimated 

cost-effectiveness of the rule is $3.28 per pound of VOC emissions reduced, comparable 

to the cost-effectiveness of other District VOC regulations and control measures 

identified in the Regional Air Quality Strategy. Overall, adopting the amended rule is 

not expected to pose significant economic impacts on affected industry in San Diego 

County. Neither of two local architectural coating manufacturers objected to the 

amendments. 

Pursuant to the California Environmental Quality Act (CEQA), an Environmental 

Impact Report (EIR) was prepared evaluating the potential environmental 

consequences resulting from the proposed amendments. No significant adverse 

environmental effects were identified. The Board must review and consider the 

information in the EIR and certify that the EIR reflects the Board’s independent 

judgment and analysis of potential environmental consequences resulting from 

adopting the proposed amendments. 

A public workshop was held on September 6, 2001. The workshop report is provided 

in Attachment VIII. 

Issues 

Two primary issues were raised by industry. Several manufacturers requested that the 

2005 sunset provision contained in the VOC averaging program be deleted to ensure 

availability of the averaging provisions if coating technology does not evolve in time 

to allow the future VOC limits to be met. They also expressed concern that EPA 

might disapprove a future repeal or extension of the sunset date as a relaxation of the 

federal SIP. 

The averaging provisions must sunset in 2005 to ensure that certain air districts (not 

San Diego) meet their 2005 SIP commitments. Since the averaging program will be a 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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statewide program, implemented by ARB, consistency among the California air 

districts is important. Consequently, it is not recommended that the sunset date for the 

averaging provision be extended at this time. 

In San Diego, evolving technology can be addressed in two ways. First, ARB intends 

to reassess coating technologies prior to the effective dates of the future limits. ARB 

and the South Coast Air Quality Management District will be working jointly to 

identify any problems industry may have in meeting the proposed limits, which 

become effective in South Coast six months earlier than the effective date in Rule 

67.0. The District will follow these efforts and, if necessary, recommend appropriate 

changes prior to the effective date of the future standards. Second, there is the 

flexibility to make future amendments because EPA will not be able to disapprove any 

such changes since the amended rule will not be submitted to EPA as part of the SIP. 

The amended rule reflects more stringent emission standards than required by federal 

regulations, and is not needed to attain the one-hour federal ozone standard. Were the 

amended rule included in the SIP, EPA could object to any necessary future rule 

changes. 

Also, several coating manufacturers requested that EPA’s National Architectural 

Coating Rule limits be used as the ceiling (upper) limits for the proposed VOC 

averaging program. This proposal is unacceptable because it would relax VOC 

content limits that have been in effect in California for over ten years. 

 

Recommendation(s)

AIR POLLUTION CONTROL OFFICER 

1. Consider the Final Environmental Impact Report (EIR) and adopt the associated 

Resolution: (a) finding that the Final EIR has been completed in compliance with 

the California Environmental Quality Act and that the Report reflects the 

independent judgment and analysis of the Board; and (b) certifying the Final EIR 

as a true and complete statement of environmental impacts of adopting the 

proposed amendments to Rule 67.0 and making findings that there is no 

substantial evidence in the entire record before the Board that the proposed 

amendments will have a significant adverse effect on the environment; and (c) 

finding that there is no evidence that adopting the proposed amendments will have 

potential for an adverse effect on wildlife resources or the habitat on which the 

wildlife depends, and, on the basis of substantial evidence, that the presumption 

of adverse effect in California Code of Regulations, Title 14, Section 753.5(d) has 

been rebutted. 

2. Approve the Certificate of Fee Exemption for De Minimis Impact Finding 

exempting the District from payment of fees to the California Department of Fish 

and Game. (ii) that an analysis of existing requirements applicable to the 

source or category is not required by Section 40727.2 of the Health and Safety 

Code because the proposed amendments do not impose new or more stringent 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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requirements; 

3. After adopting the Resolution approving the Final Environmental Impact Report 

and Certificate of Fee Exemption, adopt the resolution adopting amended Rule 

67.0 into the District Rules and Regulations and make appropriate findings: 

(i) of necessity, authority, clarity, consistency, non-duplication and reference as 

required by Section 40727 of the State Health and Safety Code; 

(ii) that adopting amended Rule 67.0 will alleviate a problem and will promote 

attainment of ambient air quality standards (Section 40001 of the State 

Health and Safety Code); 

(iii) that an assessment of the socioeconomic impacts of the proposed 

amendments has been prepared and that the socioeconomic impacts of the 

proposed new rule have been actively considered and the District has made a 

good faith effort to minimize adverse socioeconomic impacts; and 

(iv) that an analysis of the effectiveness of the proposed amended rule, including 

an analysis of the cost-effectiveness of the potential control options, has 

been prepared pursuant to Health and Safety Code Section 40920.6, and that 

the proposed rule emission limits represent cost-effective options. 

Fiscal Impact

 The recommended action will have no fiscal impact on the District. 

Business Impact Statement 

 The proposed amendments are consistent with state guidance and adoption is 

mandated by state law. The regulated business community will be affected by more 

stringent VOC content limits for some architectural coatings. There are only two 

architectural coating manufacturers located in San Diego County. One company 

specializing in house paints already manufactures compliant coatings. The other 

company manufactures some specialty coatings subject to the rule and is in the process 

of reformulating their coatings to comply with the proposed standards. Neither 

company raised any objections to the proposed amendments. 

Advisory Board Statement 

 The Air Pollution Control Advisory Committee recommended adopting amended Rule 

67.0 at its November 14, 2001, meeting. 

 

BACKGROUND: 

Attachment I contains background information, information on compliance with Board policy 

on adopting new rules, and information on compliance with the California Environmental 

Quality Act and Health and Safety Code Sections 40727.2 and 40920.6. 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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Additional Information: 

Attachment II contains the Resolution adopting the Environmental Impact Report. 

Attachment III contains the Environmental Impact Report prepared for the proposed 

amendments to Rule 67.0. 

Attachment IV contains the Resolution and Change Copy adopting amended Rule 67.0 

into the District's Rules and Regulations. 

Attachment V contains the Socioeconomic Impact Assessment of Rule 67.0 prepared 

pursuant to Health and Safety Code Section 40728.5.

Attachment VI contains the Comparative Analysis of Rule 67.0 prepared pursuant to 

Health and Safety Code Section 40727.2. 

Attachment VII contains the Incremental Cost-Effectiveness Analysis of Rule 67.0 

prepared pursuant to Health and Safety Code Section 40920.6. 

Attachment VIII contains the report on the public workshop held on September 6, 

2001. 

Attachment IX contains the Comments and Responses document addressing rule 

feasibility comments received during the Draft EIR public comment period. 

ROBERT R. COPPER 

Deputy Chief Administrative Officer 

Respectfully submitted,

R. J. SOMMERVILLE 

Air Pollution Control Officer
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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AGENDA ITEM INFORMATION SHEET 

CONCURRENCE(S) 

COUNTY COUNSEL REVIEW [X] Yes 

Written disclosure per County Charter 

 Section 1000.1 required [ ] Yes [X] No 

GROUP/AGENCY FINANCE DIRECTOR [ ] Yes [X ] N/A 

CHIEF FINANCIAL OFFICER [ ] Yes [X] N/A 

 Requires Four Votes [ ] Yes [X] No 

GROUP/AGENCY INFORMATION 

 TECHNOLOGY DIRECTOR [ ] Yes [X] N/A 

CHIEF TECHNOLOGY OFFICER [ ] Yes [X] N/A 

DEPARTMENT OF HUMAN RESOURCES [ ] Yes [X] N/A 

Other Concurrence(s): N/A 

ORIGINATING DEPARTMENT: Air Pollution Control District, County of San Diego

CONTACT PERSON(S):

 R. J. Sommerville

Name 

 (858) 650-4500

Phone 

 (858) 650-4657

Fax 

 O176 

Mail Station 

 rsommeha@co.san-diego.ca.us

E-mail 

AUTHORIZED REPRESENTATIVE: 

R. J. Sommerville, Air Pollution Control Officer 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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AGENDA ITEM INFORMATION SHEET 

(continued) 

PREVIOUS RELEVANT BOARD ACTIONS: 

August 8, 2001 (APCB #1) Approved adoption of 2001 RAQS Update. 

May 15, 1996 (APCB #2) Approved adoption of amended Rule 67.0.

BOARD POLICIES APPLICABLE: 

N/A 

BOARD POLICY STATEMENTS: 

N/A 

CONTRACT NUMBER(S): 

N/A
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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ATTACHMENT I 

BACKGROUND INFORMATION

Rule 67.0 regulates volatile organic compounds (VOC - ozone precursors) emissions from the 

manufacture, sale, and use of architectural coatings which include a variety of residential, 

commercial, and industrial paints, stains, varnishes, and other coatings. The California Clean Air 

Act requires the District adopt all feasible measures for reducing emissions at all existing 

stationary sources. The 2001 Regional Air Quality Strategy Update adopted by the Air Pollution 

Control Board on August 8, 2001 (APCB #1), includes a commitment to adopt these revisions. 

Over the last two years, ARB, in cooperation with the California Air Pollution Control Officers 

Association's Architectural Coating Work Group and the architectural coatings industry, has been 

re-evaluating the 1989 Suggested Control Measure (SCM) for architectural coatings. The 

decision to revisit the control measure arose because of advances in coating technology and the 

need for additional emission reductions to attain the state’s ozone standard in many areas of 

California. As a result, a new SCM has been developed to serve as a model for local 

architectural coating rules. The District participated on the Architectural Coatings Working 

Group during the development of the SCM. 

The amendments are consistent with the SCM approved by the Air Resources Board on June 22, 

2000. The District utilized many of the analyses and documents prepared by ARB in support of the 

SCM, including analyses of environmental and socioeconomic impacts, after finding that these 

materials were applicable to San Diego. Consistency with the SCM is important because consistent 

definitions and VOC limits facilitate coating manufacturers’ ability to comply, the rule amendments 

include an optional, statewide VOC emissions averaging program, and the District is seeking to 

avoid litigation that might be brought by certain industry groups opposed to more stringent rules. 

Similar rules have been adopted by several other California air pollution control districts, including

South Coast, Sacramento, Bay Area, Ventura, Santa Barbara, and the San Joaquin Valley. South 

Coast was sued over its more stringent rule by members of the coating industry. South Coast 

prevailed in the trial court, but the case is still on appeal. The Sacramento air district was the first 

district to adopt ARB’s SCM, which it did in late May of this year, and was not sued over its rule. 

Coating manufacturing representatives will likely attend the Rule 67.0 public hearing to make 

comments similar to those made at the public hearings held by other air districts, however. 

There are two architectural coating manufacturers located in San Diego County. One specializes 

in house paints that already comply with the proposed new VOC limits. This company should 

incur few, if any, costs. The other manufacturer is owned by a national paint company which 

will likely absorb most of the reformulation costs, though they will be somewhat impacted by 

possible higher costs of raw materials. Neither of the two local coating manufacturers objected 

to the proposed amendments. Overall, adopting the amended rule is not expected to pose 

significant economic impacts on the affected industry sectors in San Diego County. 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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The proposed amendments will add 19 new coating categories that reflect the specialized nature 

of certain architectural coating applications. For 18 new and existing coating categories, the 

allowable VOC content limits will be decreased effective January 1, 2003. For one existing 

category, industrial maintenance coatings, the allowable VOC content limit will be decreased 

effective January 1, 2004. Table 1 of this attachment lists the new coating categories and the 

proposed changes to VOC content limits. The proposed amendments also add specific container 

labeling requirements (e.g. a code identifying the date of manufacture, the VOC content, and 

thinning recommendations). Various definitions and test methods are also updated. 

A temporary (until January 1, 2005) compliance option has been added allowing manufacturers 

to average the VOC contents of specified coating categories to provide equivalent or lower 

emissions. This is important to coating manufacturers as a transition to fully compliant coating 

products across all categories. The rule requires sales reporting associated with the statewide 

averaging compliance option as well as for certain specialty coatings to allow ARB and the 

districts to monitor usage, emissions, and compliance progress. 

The amendments will reduce VOC emissions in San Diego County by approximately 1.5 tons per 

day (approximately 500 tons per year) when fully implemented in 2005. The estimated costeffectiveness of the amended rule is $3.28 per pound of VOC emissions reduced, comparable to the 

cost-effectiveness of other District VOC regulations and control measures identified in the Regional 

Air Quality Strategy. 

Current Rule 67.0 has been approved as part of the federal State Implementation Plan (SIP). The 

amended rule is not being recommended to be included in the SIP because it reflects more 

stringent emission standards than required by federal regulations and is not needed to attain the 

one-hour federal ozone standard. This will give the District greater flexibility to make future rule 

changes should problems arise with coating technology development.

ISSUES 

The following were the two primary issues raised during the public workshop on the proposed 

Rule 67.0 amendments. Other comments at the workshop were directed at specific specialty 

coating categories or sought clarification of rule requirements. These latter comments were 

addressed in the workshop report and in the proposed amendments. 

Several coating manufacturers requested that the District delete the 2005 sunset provision in the 

VOC averaging program. They were concerned that if coating technology did not evolve to 

allow the VOC limits contained in the rule to be met, and compliance could only be achieved by 

using an averaging program, districts would need to repeal the sunset provisions prior to the 

sunset date. If EPA disapproved this repeal as a relaxation of the federal SIP, coating 

manufacturers could be in violation of the rule. 

The averaging provisions must sunset in 2005 to be consistent with the SCM and ensure that 

certain air districts (not San Diego) meet their 2005 SIP commitments. Since the averaging 

program will be a statewide program, implemented by ARB, consistency among the California 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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air districts is important. Consequently, it is not recommended that the sunset date for the 

averaging provision be extended at this time. 

In San Diego, evolving technology can be addressed in two ways. First, ARB plans to conduct 

technology assessments for each coating category with a more stringent future VOC limit prior to 

the effective dates (2003 or 2004). In addition, ARB and the South Coast Air Quality 

Management District will jointly be identifying any problems industry may have in meeting the 

South Coast’s VOC limits which become effective six months earlier than the effective date in 

Rule 67.0. The District will follow these efforts and, as necessary, recommend appropriate 

changes to Rule 67.0 prior to the effective date of the future standards. Second, there is the 

flexibility for the District to make future amendments because EPA will not be able to 

disapprove changes since the amended rule will not be submitted as part of the SIP. 

Also, several coating manufacturers requested EPA’s National Architectural Coating Rule limits 

be used as the ceiling (upper) VOC limits for the proposed VOC averaging program. This 

proposal is unacceptable because it would relax VOC content limits that have been in effect in 

California for over ten years. These limits prevent high VOC coating formulations, new or old, 

from being marketed in San Diego County. 

Socioeconomic Impact Assessment 

A Socioeconomic Impact Assessment was prepared to evaluate the effects of proposed amended 

Rule 67.0. The amendments would potentially impact paint, varnish, enamel, allied products 

manufacturers, users of architectural coatings, suppliers, sellers, and solicitors of architectural 

coatings. The cost of compliance was evaluated based on studies performed by ARB and 

SCAQMD. The District reviewed these studies and found they are applicable to San Diego 

County. The economic factors affecting architectural coating manufacturers, wholesalers, 

retailers, and painting contractors are similar to those in other areas of California. 

ARB concluded the cost of complying with the proposed VOC limits will not have a significant 

impact on employment or business creation, elimination, or expansion. ARB also concluded that 

the new standards would not adversely impact the competitiveness of California-based 

businesses. These conclusions are based on ARB’s analysis of coating manufacturers’ increased 

costs to reformulate coatings. ARB calculated that the financial impact on the coating 

manufacturers’ profitability will be small; therefore, the manufacturers will likely absorb most if 

not all of the increased costs so that their products will remain competitive with already available 

compliant coatings. 

ARB has estimated that architectural coating manufacturers, most of which are located outside 

San Diego County, will spend approximately $43 million to reformulate coatings to comply with 

the SCM’s VOC limits, based on California sale volumes. The annualized cost to provide county 

customers with architectural coatings that comply with the proposed Rule 67.0 VOC limits will 

be about $3.6 million. ARB has estimated that the increased costs due to reformulation, and 

other one-time costs required to comply with the Rule 67.0 amendments and other similar rules 

throughout the state, would range from zero to $7.90 per gallon of coating depending on the 

coating category. For consumers using flat and non-flat house paints, there should be little price 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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increase since there are already many compliant paints available. As a worst case, ARB has 

estimated that consumers may see increases of up to 20 percent in the retail price of non-flat 

coatings, primers, sealers, and stains. Again, such price increases are unlikely since compliant 

coatings are already available and the competition among suppliers will likely constrain price 

increases. 

Costs of specialty coatings used for industrial maintenance and other specialized, commercial 

coating uses could increase by up to an average of 12 percent. This may represent a worst case 

since there are already some compliant coatings available in many of the specialty coating 

categories. Even if coating manufacturers pass on a majority of these increased costs, they likely 

represent a small percentage of overall painting project costs, especially compared to labor costs. 

ARB’s economic analysis estimates the average change in the Return on Owners Equity (a 

standard for measuring profitability) for coating manufacturers will decline by an average 1.1 

percent. This represents a minor change in the average profitability of coating manufacturers. 

ARB, EPA, and other government agencies typically use a predicted reduction of more than ten 

percent to indicate the potential for significant adverse economic impacts. Since overall 

profitability will decline only slightly, most manufacturing companies will absorb some or all of 

their increased costs in order to remain competitive with coatings already complying with the 

lower VOC content limits. Moreover, the option for coating manufacturers to use the temporary 

alternative averaging program in amended Rule 67.0 will afford manufacturers additional 

flexibility to moderate their costs. 

There are two architectural coating manufacturers located in San Diego County. One specializes 

in house paints that already comply with the proposed new VOC limits. This company should 

incur few, if any, costs. The other manufacturer is owned by a national paint company which 

will likely absorb most of the reformulation costs, though they will be somewhat impacted by 

possible higher costs of raw materials. Neither of the two local coating manufacturers objected 

to the proposed amendments. Overall, adopting the amended rule is not expected to pose 

significant economic impacts on the affected industry sectors in San Diego County. 

The VOC emission reductions are estimated to be 1.5 tons per day. The estimated costeffectiveness of the proposed amendments is $3.28 per pound of VOC emissions reduced, 

comparable to the cost-effectiveness of other District VOC regulations. 

The Socioeconomic Impact Assessment is presented in Attachment V. 

Compliance with Board Policy on Adopting New Rules 

On February 2, 1993, the Board directed that, with the exception of a regulation requested by 

business or a regulation for which a socioeconomic impact assessment is not required, no new or 

revised regulation shall be implemented unless specifically required by federal or state law. The 

adoption of amended Rule 67.0 is required by state law and is, therefore, consistent with this 

Board directive. 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

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California Environmental Quality Act 

Pursuant to the California Environmental Quality Act (CEQA), an Environmental Impact Report 

(EIR) has been prepared evaluating the potential environmental consequences resulting from the 

proposed amendments to Rule 67.0. No significant adverse environmental effects were 

identified. Pursuant to CEQA, the Board must certify that it reviewed and considered the 

information in the EIR and that the EIR reflects the Board’s independent judgment and analysis 

of potential environmental consequences resulting from implementing the proposed amendments. 

A Certificate of Fee Exemption for De Minimis Impact Finding has been prepared pursuant to 

California Code of Regulations, Title 14, Section 753.5(c). The District will be exempted from 

payment of fees to the California Department of Fish and Game for reviewing the EIR if, after 

considering the record as a whole, the Board finds that there is no evidence that adopting the 

amendments to Rule 67.0 will have potential for an adverse effect on wildlife resources or the 

habitat on which the wildlife depends, and the Board finds, on the basis of substantial evidence, 

that the presumption of adverse effect in California Code of Regulations, Title 14, Section 

753.5(d) has been rebutted. No significant adverse environmental effects were identified in the 

EIR. 

The EIR is presented in Attachment III. 

Comments were received during the Draft EIR comment period. The comments pertained to 

technical and feasibility aspects of the proposed amendments to Rule 67.0, but not to the 

environmental analyses contained in the EIR. The comments have been considered, and 

responses are provided in Attachment IX. No changes to the EIR are warranted. 

Comparative Analysis of Existing Requirements 

Prior to adopting, amending, or repealing a rule or regulation, California Health and Safety Code 

Section 40727 requires findings of necessity, authority, clarity, consistency, non-duplication, and 

reference. As part of the consistency finding to ensure proposed rule requirements do not 

conflict with or contradict other District or federal regulations, Health and Safety Code Section 

40727.2 requires the District to perform a written analysis comparing the air pollution control 

standards and other provisions of proposed amended Rule 67.0 with existing or proposed District 

rules and guidelines, and with existing federal rules, requirements, and guidelines applying to the 

same source category. 

The requirements of amended Rule 67.0 have been compared to the requirements of the federal 

National Architectural Coating Rule and the state Suggested Control Measure for Architectural 

Coatings. Rule 67.0 is consistent with the Suggested Control Measure and is more stringent but 

does not contradict the National Architectural Coating Rule. The analysis is presented in 

Attachment VI.

Incremental Cost-Effectiveness Analysis 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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Health and Safety Code Section 40920.6 requires the District to identify one or more potential 

control options which achieve the emission reduction objectives for the regulation, calculate the 

incremental cost-effectiveness for the potential control options, and consider and review in a 

public meeting the effectiveness of the proposed control option and the incremental costeffectiveness between the potential control options. This analysis has been done. 

One control option is to make no amendments to Rule 67.0. This would forego 1.5 tons per day 

of additional VOC emission reductions needed as part of efforts to comply with the state ambient 

air quality standard for ozone. Another control option is to adopt even more stringent VOC 

control requirements for architectural coatings similar to those in the South Coast Air Quality 

Management District’s Rule 1113. This could result in greater emission reductions if all VOC 

limits prove to be technologically feasible. However, the incremental cost-effectiveness of this 

option versus the recommended amendments is more than $10 per additional pound of VOC 

emissions reduced. This is significantly greater than other VOC control measures adopted by the 

Board and, considering the uncertainty that the more stringent South Coast VOC limits will be 

achievable, is not recommended. 

The analysis is presented in Attachment VII. 
SUBJECT: ADOPTION OF AMENDED RULE 67.0 – ARCHITECTURAL COATINGS 

(District: All) 

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Table 1 

New and Revised Rule 67.0 Coating Categories and VOC Content Limits1

Current 

Rule 67.0 

Effective 

Upon 

Adoption 

Effective 

1/1/2003 

Effective

1/1/2004

Coating Categories 

New (N) or 

Existing (E)2(g/l) (g/l) (g/l) (g/l) 

Antenna Coatings N 250 530 

Antifouling Coatings N 250 400 

Bituminous Roof Coatings N 300 300 

Bituminous Roof Primers N 350 350 

Clear Wood Coatings: 

Clear Brushing Lacquer N 680 680 

Lacquers E 680 680 550 

Sanding Sealers E 550 550 350 

Faux Finishing Coatings N 250 350 

Fire Resistive Coatings N 350 350 

Flat Coatings N 250 250 100 

Floor Coatings N 250 400 250 

Flow Coatings N 250 420 

High Temperature Coatings E 650 650 420 

Industrial Maintenance Coatings E 420 420 250 

Low-Solids Coatings3

 N 250 120 

Nonflat Coatings N 250 250 150 

Nonflat Coatings – High Gloss N 250 250 

Magnesite Cement Coatings E 600 600 450 

Multi-Color Coatings E 580 580 250 

Pre-Treatment Wash Primers E 780 780 420 

Primers, Sealers, and Undercoaters E 350 350 200 

Quick-Dry Enamels E 400 400 250 

Quick-Dry Primers, Sealers, Undercoaters E 525 525 200 

Recycled Coatings N 250 250 

Roof Coatings E 300 300 250 

Rust Preventative Coatings (Previously 

Industrial Maintenance Coating) N 420 400 

Specialty Primers, Sealers, and Undercoaters N 350 350 

Stains E 350 350 250 

Swimming Pool Coatings E 650 650 340 

Swimming Pool Repair & Maintenance 

Coatings E 650 650 340 

Temperature-Indicator Safety Coatings N 250 550 

Traffic Marking Coatings E 250 250 150 

Waterproofing Sealers E 400 400 250 

Waterproofing Concrete/Masonry Sealers N 250 400 

Wood Preservatives (Below Ground 

Wood Preservative deleted)

E 350 

(600) 

350 

 

1. VOC content limits expressed in grams VOC per liter of coating, as applied, less water and exempt compounds. 

2. Coatings in newly added categories previously were regulated as general coatings with a VOC content limit of 250 gm/liter or were 

included in an existing specialty coating category.

3. VOC content limits expressed in grams of VOC per liter of coating, as applied, including water and exempt compounds.