PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT

STAFF REPORT

RULE 218

ARCHITECTURAL COATINGS

PROPOSED RULE AMENDMENTS

OCTOBER 14, 2010
Staff Report – Revision to Rule 218

October 14, 2010

Page 2

BACKGROUND

Rule 218, ARCHITECTURAL COATINGS, limits the volatile organic compound (VOC) content of 

architectural coatings that may be used, sold, or manufactured in the District. The rule was last 

amended by the District on December 13, 2001.

The District is proposing amendments to Rule 218 based on a “Suggested Control Measure for 

Architectural Coatings” (SCM) issued on October 26, 2007, by the California Air Resources Board.

The SCM provides VOC limits for 19 coating categories that are more stringent than those in 

current Rule 218. The SCM is intended for Districts, like Placer County, which need VOC 

emission reductions for attainment of State and Federal ozone standards. The SCM is 

considered Best Available Retrofit Control Technology, which is part of the District’s plan to meet 

ozone reduction requirements as required under California Health and Safety Code Section 

40919; and meets the District’s requirement under California Health and Safety Code Section 

40914 to implement “every feasible measure”.

This Staff Report addresses amendments that are proposed to Rule 218 based on the SCM. This 

is an early meeting of the SIP commitment to adopt the SCM’s provisions by 2012.

The coating category and VOC limits based on the SCM are proposed to be effective July 1, 

2011.

DISCUSSION

Rule amendments, in underline/strikeout format, are shown in Attachment #1. Specific changes 

to the Rule include:

Section 100. General

Section 102. Applicability. The provision covering “blends or repackages” has been 

added to expand Rule applicability to those activities.

Section 200. Definitions

Changes to definitions were made based on SCM coating categories:

Seventeen (17) definitions of existing coating categories will no longer be 

effective after July 1, 2011, including: Antenna Coating, Antifouling Coating, Clear 

Brushing Lacquers, Clear Wood Coatings, Fire Retardant Coatings, Flow 

Coating, Lacquer, Non-industrial Use, Quick Dry Enamel, Quick Dry Primer 

Sealer Undercoater, Sanding Sealer, Sealer, Secondary Coating, Temperature 

Indicator Safety Coating, Undercoater, Varnish, Waterproofing Concrete/Masonry 

Sealer

Twenty (20) new definitions of coating categories have been added which will be 

effective after July 1, 2011, including: Aluminum Roof Coating, Basement 

Specialty Coating, Concrete Masonry Sealer, Driveway Sealer, Manufacturer’s 

Maximum Thinning Recommendation, Medium Density Fiberboard, Particle 

Board, Pearlescent, Plywood, Reactive Penetrating Sealer, Secondary Industrial 

Materials, Semitransparent Coating, Stone Consolidant, Tub and Tile Finish 

Coating, Veneer, Virgin Materials, VOC Regulatory Content, VOC Actual Content, 

Wood Coating, Zinc-Rich Primer

Section 300. Standards

Section 301. VOC Content Limits. Coating categories and VOC limits under the existing 

Rule are amended to be effective until July 1, 2011. Effective after July 1, 2011, new 
Staff Report – Revision to Rule 218

October 14, 2010

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coating categories and VOC limits from the SCM have been added which replace the 

existing categories and limits. A list of the categories which will no longer be effective

after July 1, 2011, has been added.

Section 302. Most Restrictive VOC Limits. Exemptions from this section were made 

consistent with the coating categories of the SCM.

Section 303. Sell Through of Coatings. The “Averaging Program” provision was deleted.

Section 306. Rust Preventative Coatings. This section was deleted because the SCM 

does not differentiate between non-industrial and industrial use.

Section 306. Coatings not Listed in Section 301. A new category was added -- Non-Flat 

High Gloss -- as a potential option for categorization of non-listed coatings.

Section 307. Early Compliance. A new section is added allowing compliance with the 

new SCM-based VOC limits prior to July 1, 2011.

Section 308. Lacquers. This section was deleted as it is no longer consistent with 

established coating compliance operations, is not part of the SCM, and is not used in 

practice.

Section 309. Averaging Compliance Option. This provision was deleted as it is no longer 

consistent with established coating compliance operations, is not part of the SCM, and is 

not used in practice.

Section 400. Administrative Requirements

Section 401.3. VOC Content. Labeling requirements were modified based on the SCM.

Section 401.4. – 401.14 Various Coating Categories. Various product labeling 

requirements were added, modified, and deleted based on the SCM.

Section 402. Calculation of VOC Content. This provision was moved to the definition

section.

Section 500. Monitoring and Records

Section 501. Reporting Requirements. Deleted various CARB annual reporting 

requirements. Replaced with new Section 501.1. “Sales Data”, requiring that coating 

manufacturers provide, within 180 days of request of the CARB or District, information of 

product volume sales and product VOC composition.

Section 502. Recordkeeping. New section has been added requiring the reporting in 

Section 501 be kept for 3 years.

Section 503. Test Procedures. This sections title was changed to “Test Methods and 

Compliance Provisions.”

Section 503.1. Calculation of VOC Content. A new section was created from the current 

Rule Section 402 and the SCM.

Section 503.4 Test Methods. Reference was added to numerous additional test methods, 

and minor changes were made to the references of methods in the current Rule.
Staff Report – Revision to Rule 218

October 14, 2010

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Appendix A - Averaging Provision

This section was eliminated, as this averaging provision is not part of established coating 

compliance operations, is not part of the SCM, and is not used in practice.

ANALYSIS

The following Analysis and the subsequent Findings are intended to address the requirements set 

forth in the Health and Safety Code relating to adoption of a new or amended District Rule, as well as 

other State statutes referenced herein.

1. Cost-Effectiveness of a Control Measure

California Health & Safety Code (H&S) Section 40703 requires a District to consider and 

make public “the cost-effectiveness of a control measure”. The cost effectiveness has been 

estimated at $1.00 per lb of VOC reduced.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic 

impact of any new or amended rule if air quality or emission limits are significantly affected. 

The estimated cost of meeting the amended proposed rule was estimated at the time of 

SCM development to be an increase, on average, of $1.00 per gallon to the consumer

(about a 5% increase from current consumer price). Today’s actual price increase will be 

significantly less that this outdated estimate, as many currently available products have been 

reformulated to meet the SCM standards and manufacturers continue to develop and offer 

compliant coating products.

3. Environmental Review and Compliance

California Public Resources Code Section 21159 requires an environmental analysis of 

the reasonably foreseeable methods of compliance should be conducted. Compliance of 

the proposed rule amendment is expected to be achieved by the replacement of current 

coating products with compliant compounds. Application of these compliant compounds 

will generally result in less VOC emissions from the coating activities. Therefore, the 

proposed rule amendment will reduce emissions from sources and will not cause any 

significant adverse effects on the environment. Staff has concluded that no adverse 

environmental impacts will be caused by compliance with the proposed rule amendment.

According to the above conclusion, Staff finds that the proposed rule amendment is 

exempt from the California Environmental Quality Act (CEQA) because (1) it can be seen 

with certainty that there is no possibility that the activity in question may have a significant 

adverse effect on the environment (CEQA Guidelines §15061(b)(3)) and (2) it is as an 

action by a regulatory agency for protection of the environment (Class 8 Categorical 

Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity: The adoption of proposed amended Rule satisfies the Districts objective to 

implement “Suggested Control Measures” for the reduction of VOCs to achieve 

attainment with ambient air standards for ozone, and meets the District’s requirements to 

implement “every feasible measure” and “Best Available Retrofit Control Technology” as 

required under California Health and Safety Code Sections 40919 and 40914.

B. Authority: California Health and Safety Code, Sections 40000, 40001, 40701, 40702, 

40716, 41010, and 41013, are provisions of law that provide the District with the authority 

to adopt this proposed amended Rule.
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October 14, 2010

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C. Clarity: There is no indication, at this time, that the proposed amended Rule is written in 

such a manner that persons affected by the Rule cannot easily understand them.

D. Consistency: The proposed amended Rule is in harmony with, and not in conflict with or 

contradictory to, existing statutes, court decisions, or state or federal regulations.

E. Non-duplication: The proposed amended Rule does not impose the same requirements 

as an existing state or federal regulation.

F. Reference: All statutes, court decisions, and other provisions of law used by the District in 

interpreting this proposed amended Rule is incorporated into this analysis and this finding 

by reference.

SUMMARY

Rule 218, ARCHITECTURAL COATINGS, has been amended to address the “Suggested Control 

Measure for Architectural Coatings” issued on October 26, 2007 by the California Air Resources 

Board. The SCM-based coating category and VOC limit requirements are proposed effective July 

1, 2011.

Attachment 1: Proposed Rule 218 Amendments.
ATTACHMENT #1

Amended Rule 218, Architectural Coatings