Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

(530)757-3650

www.ysaqmd.org

PROPOSED AMENDMENTS TO

RULE 2.26, MOTOR VEHICLE AND MOBILE EQUIPMENT 

COATING OPERATIONS

FINAL STAFF REPORT

November 26, 2008

Prepared by: Nancy Fletcher

nfletcher@ysaqmd.org

Reviewed by: Susan K. McLaughlin

smclaughlin@ysaqmd.org
Table of Contents Page

I. EXECUTIVE SUMMARY ...............................................................................................03

II. BACKGROUND ...............................................................................................................04

III. DISCUSSION OF PROPOSED RULE REQUIREMENTS.............................................05

IV. COMPARISON TO OTHER APPLICABLE REGULATIONS AND REQUIREMENTS10

V. IMPACTS OF THE PROPOSED RULE ..........................................................................11

VI. ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE...........................12

VII. REGULATORY FINDINGS.............................................................................................13

VIII. PUBLIC COMMENTS AND STAFF RESPONSES........................................................14

IX. REFERENCES ..................................................................................................................17

ATTACHMENT A PROPOSED AMENDMENTS TO RULE 2.26, MOTOR VEHICLE AND 

MOBILE EQUIPMENT COATING OPERATIONS; STRIKE-OUT 

UNDERLINE VERSION

ATTACHMENT B NOTICE OF EXEMPTION FROM CEQA GUIDELINES 

ATTACHMENT C RESOLUTION NO. 08-12

ATTACHMENT D WRITTEN COMMENTS RECEIVED
Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

I. EXECUTIVE SUMMARY

On December 10, 2008, the Yolo-Solano Air Quality Management District (District) 

Board of Directors will consider the proposed amendments to Rule 2.26 Motor Vehicle 

and Mobile Equipment Coating Operations. 

The District is revising the rule to incorporate the California Air Resources Board 

(CARB) Suggested Control Measure for Automotive Coatings (SCM). District Staff is 

also proposing to incorporate other minor changes resulting in improvement to rule 

clarity, effectiveness, and consistency with other agencies.

The main revisions to Rule 2.26 will include the following:

1. Group I and Group II categories will be combined. The same Volatile Organic 

Compound (VOC) limits will apply for passenger vehicles, heavy -duty vehicles, 

and mobile equipment,

2. The composite VOC limit for multi-stage systems will be eliminated and replaced 

with specific VOC limits for clear coatings and color coatings,

3. Coating categories will be simplified,

4. The exemption for touch-up coatings will be removed,

5. Sunset provisions will be created for current requirements which will not apply 

when the new limits take effect,

6. A prohibition of possession provision will be added, and

7. Recordkeeping and labeling requirements will be modified for consistency with 

other Districts and improved enforcement.

Amendments to the aforementioned rules are expected to lower VOC emissions from 

automotive coating operations in the District by approximately 42 tons per year.

The proposed changes will affect anyone who supplies, sells, offers for sale, 

manufactures, or distributes any automotive coating within the District, as well as anyone 

who applies or solicits the application of any automotive coating in the District. The 

cost-effectiveness of the SCM was estimated by the CARB to be approximately $1.43 per 

pound of VOC reduced. Currently, the District permits approximately 78 facilities for 

motor vehicle and mobile equipment coating. Compliance with the new standards is 

expected partly through the conversion to waterborne technologies. The average annual 

cost of compliance for automotive refinishing facilities is expected to be $3,400. 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

The proposed amendments will neither have a significant nor detrimental effect on the 

environment. Therefore, staff has prepared a Notice of Exemption to satisfy the 

requirements of the California Environmental Quality Act (CEQA). The notice states that 

the revisions to the Rules are exempt from the requirements of CEQA pursuant to Section 

15308, Actions by Regulatory Agencies for Protection of the Environment.

II. BACKGROUND

Overview of Source Category

In October 2005, the CARB adopted the SCM. The SCM was developed by CARB in 

cooperation with air districts, the United States Environmental Protection Agency (EPA), 

and the affected industry. It was created to serve as a model for all Districts adopting or 

amending automotive coatings rules, in order to provide consistency among districts 

rules, increase rule enforceability, and to achieve significant VOC emission reductions 

for the category. The SCM has currently been adopted by the South Coast Air Quality 

Management District (SCAQMD), San Joaquin Valley Air Pollution Control District 

(SJVAPCD), Santa Barbara Air Pollution Control District (SBAPCD) and Ventura 

County Air Pollution Control District (VCAPCD). In addition, Sacramento Metropolitan 

Air Quality Management District (SMAQMD) and the Bay Area Air Quality 

Management District (BAAQMD) are in the process of revising their automotive coating 

rules.

The SCM applies to anyone who sells, supplies, offers for sale, or manufactures any 

automotive coating, as well as any person who applies or solicits the application of any 

automotive coating in the applicable District. Manufacturers of the coatings and facilities 

applying the coatings are expected to be the most impacted by the SCM. 

According to surveys performed by the CARB during the SCM development, 

approximately 3.7 million gallons of automotive coatings were sold in California. It is 

estimated 95 percent of these sales were supplied by seven manufacturers, Akzo Nobel, 

BASF, DuPont, Ellis Paint, PPG, Sherwin Williams and Strandox/Spies Heckler. 

Automotive coatings are generally supplied to automotive refinishers through local or 

regional distributors. These distributors can be independent from the coating 

manufacturer. CARB determined that only one paint company manufactures automotive 

coatings in the State. This company is not located in the District. 

Facilities applying the coatings include auto-body repair/paint shops, new car dealer 

repair /paint shops, fleet operator repair/paint shops, custom restoration, and mobile 

equipment manufacturers/dealers. Currently, the District permits approximately 74 

facilities for automotive coating. The majority of these are small businesses utilizing 

paint booths for the applications. Historically, the District requires permits for all 

facilities using paint booth regardless of the volume of coatings used. There are other 

operations such as mobile painting operations which may not require permits if they are 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

using under a gallon of coatings and associated products per day, but will still be subject 

to the regulations. 

The SCM does not apply to the application of original equipment manufacture (OEM) 

automotive coatings. OEM coatings refer to the coatings applied to the car during 

manufacturing. Currently there are no automotive manufacturing facilities in the District 

applying OEM automotive coatings. Districts with these facilities have separate rules for 

these operations. 

In addition, the SCM does not apply to aerosol consumer products and aerosol coatings. 

These products are regulated by the CARB=s consumer products and aerosol coatings 

programs. Therefore, consistent with the SCM, the application of aerosol coating 

products is exempted from the rule.

Traditionally, emissions from automotive coating operations have been regulated by 

limiting the VOC content of the materials used. Automotive coating operations are given 

the option to use emission control equipment to comply with standards, but the majority 

of facilities comply through the use of compliant products. During the development of the 

SCM, CARB staff reviewed existing rules and regulations including individual District 

rules and national standards for automotive coatings. They assessed and evaluated 

existing coating technologies for coatings, to develop standards that are both 

technologically and commercially feasible. For most coating categories, it was 

determined complying coatings would be widely available by January 1, 2009. The 

effective date was delayed until January 1, 2010 for three categories including primer 

sealers, single-stage coatings, and adhesion promoters.

Compliance with the SCM is expected through the reformulation of some products. 

Suppliers and distributers can be impacted due to requirements that assign responsibility 

to the suppliers and distributors to sell or distribute only compliant products in the 

District. In addition, individual shops applying the coatings will also be effected. The 

transition to waterborne coatings can involve modifications to spray booths used during 

application as well as training to adapt to the coatings.

The SCM establishes standards for cleaning operations, including surface preparation, 

and spray gun cleaning. The SCM includes a 25 gram per liter VOC limit for surface 

preparation and cleanup consistent with the most stringent limits for this category 

established by the SCAQMD. The District recently revised the surface preparation and 

cleanup portion of several rules including Rule 2.26. The District removed the surface 

preparation and cleanup requirement from the individual rules and placed them in Rule 

2.31 Surface Preparation and Cleanup. The District also established VOC limits for 

surface preparation and cleanup for automotive refinishing. The District adopted a step 

down approach, a 50 grams per liter VOC content effective July 1, 2009, and 25 grams 

per liter VOC content effective January 1, 2011 for materials used for surface preparation 

and cleanup. These limits are consistent with the most restrictive limits established by 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

SCAQMD and therefore the District is not proposing any changes to this category during 

this rule development.

The SCM includes provisions to exempt tertiary butyl acetate from the VOC definition 

for automotive refinishing to provide compliance flexibility. In December 2005, the 

District amended the definitions in Rule 1.1 General Provisions and Definitions to 

include tertiary butyl acetate (t-butyl acetate) as an exempt compound. The definitions 

established in Rule 1.1 pertain to all the rules therefore the District does not need to 

include any provisions to exempt t-butyl acetate from the definition of VOC in Rule 2.26. 

III. DISCUSSION OF PROPOSED RULE REQUIREMENTS

Listed below are descriptions of the proposed revisions and the intended purposes of the 

revisions.

Rule 2.26 Motor Vehicle and Mobile Equipment Coating Operations

Section 100 General

Staff is proposing to amend Section 101 Purpose and Section 102 Applicability, to update 

terminology for rule consistency, and to expand the applicability. Staff is proposing to 

add Section 103 Severability.

Staff is proposing to remove the exemption for touch-up operations. Currently, a 

touch-up operation is defined as an area less than four square feet. This is a source of 

confusion because the definition does not quantify or specify a frequency for the 

exemption. If the coating area exceeds four square feet than the source is required to 

comply with the rule standards. Anyone performing touch-up operations will now be 

required to comply with the provisions of the rule. 

Staff is proposing to remove the exemption for graphic design application for consistency 

with the SCM. The District believes the exemption from the entire rule is no longer 

needed by industry. The District is proposing to add Section 111, Exemption Application 

Requirements which exempts graphic design applications from coating methods. This 

exemption was added to allow airbrushing for these types of specialized applications 

which is otherwise a noncompliant application method. In addition to graphic design 

applications, the exemptions is applicable to underbody coatings, truck bed liner coatings 

or any coating use of less than one fluid ounce, consistent with the SCM.

Staff is proposing to remove the exemption for coating military vehicles and ground 

support equipment. The SCM does not have an exemption for this source category. The 

SCM examined the types of coatings used in the State and set limits based on coating 

performance. The District does not have any facilities coating military vehicles. The 

coating ground support equipment is subject to Rule 2.25 Metal Parts and Coating 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Operations. 

The District is proposing to remove the exemption for the coating of radiators and engine 

components. These operations are subject to Rule 2.25 Metal Parts and Coating 

Operations. The rule contains definitions clarifying the sources subject to the rule.

Staff is proposing to add an exemption (Section 110.2) for coatings sold, supplied, or 

offered for sale in 0.5 fluid ounce or smaller containers. As stated in the rule, this 

exemption is intended to for the general public to repair limited imperfections. 

Staff is proposing to add an exemption (Section 110.3) for coatings applied to motor 

vehicles or mobile equipment, or their associated parts and components during the 

manufacture on an assembly line. Currently, the District is unaware of any facility 

coating any vehicle or mobile equipment during manufacture, however the section will be 

added for consistency with the SCM.

Staff is proposing to add an exemption (Section 110.4) for standards and administrative 

requirements. This section will exempt coatings or associated solvents that are offered for 

sale, sold or manufactured for use outside of the District. This exemption has been added 

to clarify the intent of the rule is to restrict the final product used for application. 

Staff is proposing to add an exemption (Section 111) for the prohibition of sale or 

manufacture. This section will exempt coatings that are offered for sale, sold or shipped 

for reformulation or repackaging. It will also exempt coatings that are used with an 

emission control system which meets the requirements outlined Section 305.

Staff is proposing to add an exemption from coating application requirements for specific 

specialty applications. The coatings applied still must meet the VOC requirements 

outlined in Section 300.

Staff is proposing to remove former Section 111 Exemption - Transfer Efficiency. Staff is 

proposing to add exemptions from application requirements for specific coating 

categories for consistency with the SCM. 

In addition, staff is proposing to remove former Section 112 Exemption - Small 

Production/Utility Bodies for consistency with the SCM.

Section 200 Definitions

Staff is proposing to amend the definitions for consistency with the SCM. One of the 

reasons behind the development of the SCM was to standardize the categories for 

automotive coatings between air districts. Staff is proposing to 1) add several 

definitions to define the new coating categories and clarify rule requirements 2) delete 

definitions that will no longer be necessary and 3) standardize definitions with the 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

definitions in the SCM.

Additionally Staff is proposing to retain the term graphic design application instead of 

using the term graphic arts operation from the SCM. The District defines the term graphic 

arts operation in Rule 2.29 Graphic Arts Printing Operation. The definition in Rule 2.29 

is different from the definition proposed in the SCM. Therefore, to avoid confusion the 

District will retain graphic design application. The definition for graphic design 

application in Rule 2.26 will be consistent with the SCM definition for graphic arts 

operation except the District will retain the phrase >with or without the use of a template=.

Section 300 Standards

Staff is proposing to amend Section 301 Coating Limits, by adding language which will 

sunset the provisions of this section on July 1, 2009 when the first phase of the new limits 

go into effect. Staff is proposing to replace the term pretreatment wash primer with 

pretreatment coating consistent with the change in Section 200. In addition, staff is 

proposing to add specialty coating and temporary protective coating limits to the table. 

The VOC limits for specialty coatings was previously placed in former Section 306 

Specialty Coatings. These limits will be removed from this section and placed in the 

table. The VOC content limits for temporary protective coating was previously placed in 

former Section 307 Temporary Protective Coating. The VOC content limits were defined 

as grams per liter excluding water. The limits for the category will be placed in the table 

and the VOC content limit will be calculated as grams per liter excluding water and 

exempt compounds consistent with the SCM.

Staff is proposing to add Section 302 Coating Limits. This section includes a table with 

the updated coating categories and limits consistent with the SCM. The requirements in 

this section will become effective July 1, 2009.

Staff is proposing to add Section 303 Most Restrictive VOC Limit. This section clarifies 

if a product is labeled as having multiple uses which fall into separate categories, the 

product must meet the lowest VOC content limit.

Staff is proposing to incorporate changes to Section 304 Application Requirements, for 

consistency with the SCM.

Staff is proposing to delete Section 308 Specialty Coatings. The applicable VOC content 

limits will be placed in the tables in Sections 301 and 302. In addition, staff is proposing 

to delete the requirement that the amount of specialty coatings used shall not exceed five 

percent of all the coatings applied when the lower VOC content limits go into effect July 

1, 2009. Limiting the amount of specialty coatings used is not consistent with the SCM. 

Staff is proposing to delete Section 307 Temporary Protective Coating. The section is no 

longer necessary since staff is proposing to place the VOC content limits in sections 301 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

and 302.

Staff is proposing to delete former Section 308 Precoat Limitation. The requirements are 

not consistent with the SCM.

Staff is proposing to add Section 308 Toxic Air Contaminant to reinforce existing state 

regulations which prohibit the use of coatings containing hexavalent chromium and 

cadmium. This prohibition is consistent with other air district rules.

Section 400 Administrative Requirements

Staff is proposing to add Section 401, Prohibition of Possession. This section prohibits 

any auto refinishing facility from having any noncompliant automotive coatings onsite. 

This section will allow facilities to be cited even without evidence of product use.

Staff is proposing to incorporate minor language changes to Section 402 (formerly 

Section 401) Prohibition of Specification. Staff is proposing to replace Group I and II 

vehicles with the term motor vehicles. There are no proposed changes to the 

requirements. 

Staff is proposing minor modifications to the language in Section 403 (formerly Section 

402) Prohibition of Sale or Manufacture. Staff is proposing to expand the applicability to 

clarify the intent of the requirements. Staff is proposing to remove language clarifying the 

section is only applicable to any location within the District. This language is not needed 

because the rule applicability is already stated in the rule.

Staff is also proposing modifications to section 404 (formerly Section 403) Compliance 

Statement Requirement. The District will require manufacturers and repackers to include 

on product sheets or an equivalent medium the actual VOC content and the regulatory 

VOC content. In addition, they will need to supply the weight percentage of volatiles, 

water and exempt compounds and the density of the material.

Staff is proposing modifications to the language in Section 406 (formerly Section 404) 

HVLP Marking. The District will allow an alternative to a permanent marking on a 

HVLP gun for identification purposes.

Section 500 Monitoring and Records

Staff is proposing to modify existing record keeping requirements. Rule 2.26 will 

distinguish record keeping requirements for facilities using the coatings and requirements 

for facilities claiming an exemption to the prohibition of sale requirements. Facilities 

using coatings will be required to maintain a list of all coatings and additives subject to 

the rule including the material name and manufacturer, the application method, the 

coating category and mix ratios, and the actual and regulatory VOC contents for coatings 

used. In addition, facilities will be required to maintain MSDS, technical sheets or air 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

quality data sheets which list both the actual and regulatory VOC contents of each 

coating. The VOC content will be required for solvents used. The facilities will now be

required to maintain purchase records identifying the coating type, name, and volume of 

coating purchased. Anyone claiming an exemption to the prohibition of sale requirements 

will be required to keep a log of the quantity of coating manufactured, blended, 

repackaged for sale, supplied, sold offered for sale, or distributed including the size and 

number of containers, The actual and regulatory VOC contents, whom they supplied, 

sold, offered for sale, or distributed, or for whom they were manufactured, blended, or 

repackaged for sale, including the name address, phone number, retail tax license 

number, and valid district permit number, and the specific exception being utilized.

Section 600 Test Methods

Staff is proposing to modify Section 602 VOC Content and Section 604 Exempt 

Compounds -Methyl Acetate, Acetone, T-Butyl Acetate, and Parachlorobenzotrifluoride 

(PCBTF), by including the titles in the referenced test methods.

Staff is proposing to modify Section 605 Calculation of VOC Content. Staff is proposing 

to define regulatory VOC content for coatings by using the existing calculation for VOC 

content less water and exempt compounds. Staff is also proposing to add the calculation 

for actual VOC content to provide clarity for record keeping requirements.

Staff is adding a sunset provision to Section 606 Calculation for VOC Content of Coating 

System. This section will only be applicable prior to July 1, 2009, when the first phase of 

the new requirements for coatings go into effect. The Section will not be needed after 

because the VOC content will no longer be calculated for a system, each constituent will 

have a separate limit.

Staff is proposing to add Section 608 HVLP Equivalency. 

IV. COMPARISON WITH OTHER APPLICABLE REGULATIONS AND 

REQUIREMENTS

California Health and Safety Code (CH&SC) Section 40727.2 requires districts to 

perform a comparative alternative analysis of any new control standard. Specifically, the 

District is required to prepare a written analysis that identifies all existing federal air 

pollution control requirements, including, but not limited to emission control standards 

constituting best available control technology (BACT) that applies to the same equipment 

or source type as the rule or regulation proposed for adoption or modification by the 

District. In addition, the analysis shall identify any other District rule, regulation, or 

guideline that applies to the same equipment or source type.

The California Clean Air Act requires the District to develop a plan to achieve attainment 

with the state ozone standard. The plan requires the District to implement Best Available 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Retrofit Control Technology (BARCT), defined in the CH&SC as Aan emission limitation 

that is based on the maximum degree of reduction achievable, taking into account 

environmental, energy and economical impacts by each class or category of source.@

Additionally, the District=s strategy for attainment must achieve a 5% ozone precursor 

emission reduction or adopt all feasible control measures. The District identified adopting 

requirements from the SCM as part of the plan to satisfy these regulations.

The 2005 SCM adopted by CARB is considered BACT for automotive refinishing. The 

SCM was developed to provide consistency with requirements for automotive refinishing 

throughout the state while achieving the maximum feasible VOC reductions. The 

proposed amendments to the rule are based on and contain the requirements of the SCM.

The EPA promulgated a final rule in 1998 to control VOC emissions from automotive

coatings pursuant to Section 183(e) of the Clean Air Act. This rule was published in the 

Federal Register on September 11, 1998. Regulated entities in all states must comply 

with national standards. However, this rule allows states or local governments to adopt 

VOC standards more stringent than the national rule to assist in achieving attainment 

with federal ambient air quality standards for ozone. Standards in the national rule range 

from 550 grams per liter to 840 grams per liter. The VOC limits proposed by the SCM 

are more stringent than the national standards. 

On January 9, 2008, EPA adopted National Emission Standards for Hazardous Air 

Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area 

Sources. Motor vehicle and mobile equipment surface coating operations were identified 

as sources subject to the standards. Sources subject to the standards include paint 

stripping using methylene chloride, motor vehicle and mobile equipment coating 

operations and other miscellaneous coating operations using the target hazardous air 

pollutants (HAPs). Requirements for motor vehicle and mobile equipment coating 

operations include spray gun requirements, use of spray booths with filters meeting a 

98 percent filter efficiency, painter training, and gun cleaning requirements. Rule 2.26 

has similar standards for spray guns and Rule 2.31 contains similar standards for cleanup. 

The rules do not contain requirements for the use of booths or painter training. However, 

owners of motor vehicle and mobile equipment coating operations can petition for an 

exemption if they can demonstrate they use no coatings containing the following HAPS: 

chromium (CR), lead (Pb), manganese (Mn), Nickel (Ni), or cadmium (Cd). Many of the 

new compliant coatings have been reformulated without these compounds.

In addition, the California Code of Regulations (CCR) Title 17, Section 93112, contains 

an airborne toxic control measure for motor vehicle and mobile equipment coatings. This 

state regulation prohibits the use, manufacture or sale of coatings in California containing 

hexavalent chromium or cadmium. The District added a provision in Rule 2.26 

prohibiting the application of coatings containing hexavalent chromium or cadmium to 

reinforce the state standard.

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

V. IMPACTS OF THE PROPOSED RULE

Emissions Impacts

In 2002 CARB conducted a survey of automotive coatings products used in California. 

CARB used this data to estimate VOC emissions from the use of products. Emissions 

from automotive coatings, excluding emissions from solvents used for surface 

preparation and cleanup, were estimated to be 7,631 tons per year or 20.7 tons per day in 

California. Emission reductions from statewide implementation was estimated to be 

about 13.4 tons per day, equating to a 63 percent reduction in total VOC emissions from 

the coating categories. Correcting the emissions based on District population yields an 

emission reduction of 42 tons per year or 0.12 tons per day. 

Cost Effectiveness

CH&SC Section 40703 requires the District, in the process of the adoption of any rule or 

regulation, to consider and make public its findings related to the cost effectiveness of the 

rule. Cost effectiveness for rulemaking purposes is calculated by dividing the cost of air 

pollution controls required by the rule by the amount of air pollution reduced.

The 2005 CARB staff report analyzed the economic impacts of adopting the SCM. The 

analysis examined the impact to manufacturers of automotive coatings and to automotive 

refinishing facilities. The analysis did not include potential costs from complying with 

limits for solvents. CARB estimated over-all cost-effectiveness of adopting the proposed 

to be $1.43 per pound of VOC reduced. The average annual cost for automotive 

refinishing facilities is estimated to be about $3,400. 

Socioeconomic Impacts

CH&SC Section 40728.5 (a) requires the District, in the process of the adoption of any 

rule or regulation, to consider the socioeconomic impact if air quality or emission limits 

may be significantly affected. However, districts with a population of less than 500,000 

persons are exempt from the provisions of Section 40728.5 (a). The District=s population 

is estimated to be approximately 320,000 and well below the 500,000 person threshold. 

Therefore, a socioeconomic analysis for this rulemaking is not required. 

Incremental Cost Effectiveness

CH&SC Section 40920.6 requires an assessment of the incremental cost-effectiveness for 

proposed regulations relative to ozone, Carbon Monoxide (CO), Sulfur Oxides (SOx), 

Nitrogen Oxides (NOx), and their precursors. Incremental cost-effectiveness is defined as 

the difference in control costs divided by the difference in emission reductions between 

two potential control options that can achieve the same emission reduction goal of a 

regulation.

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

The proposed amendments result in a VOC reduction of approximately 0.12 tons per day. 

These amendments are based on the most stringent viable VOC limits and there are no 

other viable control options that can achieve the same amount of emission reductions. 

Therefore, the incremental cost-effectiveness analysis does not apply.

Impacts to the District

The proposed amendments are expected to result in an increased workload for the 

permitting and compliance sections to implement and enforce the regulations. District 

expects that existing staff can absorb the increased work load.

VI. ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE

California Public Resource Code Section 21159 requires the District to perform an 

environmental analysis of the reasonably foreseeable methods of compliance. The 

analysis must include the following information for the proposed amendments to Rule 

2.26.

A. An analysis of the reasonably foreseeable environmental impacts of the methods 

of compliance.

B. An analysis of the reasonably foreseeable mitigation measures.

C. An analysis of the reasonably foreseeable alternative means of compliance with 

the rule or regulation.

Table 1 lists all reasonably foreseeable compliance methods, the environmental impacts 

of those methods, and measures that could be used to mitigate the environmental impacts.

TABLE 1. Environmental Impacts, Mitigation Measures, and Alternatives

Compliance 

Methods

Reasonably Foreseeable Environmental Impacts Reasonably Foreseeable 

Mitigation Measures

Reformulatio

n of coatings

Air Quality Impacts: All compliance methods are 

aimed at lowering VOC emissions

No mitigation necessary

Water Impacts: Compliance methods will not 

increase potential water impacts. Disposal of spent 

coatings containing hazardous substances is not 

allowed in public sewer systems

Human Health Impacts: Coating formulation may be 

replaced with more toxic compounds, however with 

less emissions of VOCs there is expected to be less 

emissions of HAPs. Compliance with OSHA safety 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Compliance 

Methods

Reasonably Foreseeable Environmental Impacts Reasonably Foreseeable 

Mitigation Measures

guidelines reduces any potential impact.

Solid Waste Disposal Impacts: Compliance methods 

will not increase potential solid waste disposal 

impacts. Spent solutions used for cleaning can 

contain hazard waste from materials cleaned. The 

hazardous waste has to be properly disposed of and 

can not be legally discharged in public sewer 

systems. Contaminants from the materials cleaned 

must be disposed of properly regardless if the 

solution used was a solvent or an aqueous solution. 

Contractors provide waste handling services for 

both spent aqueous and solvent solutions

Noise Impacts: Implementation and use of some 

equipment have potential to increase noise levels 

that would effect persons in the vicinity of the 

cleaning system. Equipment components including 

noise buffering devices can be used. Proper 

installation and proper safety equipment would 

result in a less than significant impact.

This analysis demonstrates the adoption of the amendments to Rule 2.26 will not have a 

significant effect on the environment or humans due to unusual circumstances. In 

addition, the proposed amendments to Rule 2.26 are considered an action taken to protect 

the environment. Therefore, staff have determined that the project is categorically 

exempt from the requirements of the CEQA pursuant to Section 15308, Actions by 

Regulatory Agencies for Protection of the Environment. Staff prepared a Notice of 

Exemption (NOE) to meet the CEQA Guidelines (Attachment B). 

VII. REGULATORY FINDINGS

Section 40727(a) of the CH&SC requires that prior to adopting or amending a rule or 

regulation, an air district=s board make findings of necessity, authority, clarity, 

consistency, nonduplication, and reference. The findings must be based on the 

following:

1. Information presented in the District=s written analysis, prepared pursuant to 

CH&SC Section 40727.2;

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

2. Information contained in the rulemaking records pursuant to CH&SC Section 

40728; and

3. Relevant information presented at the Board=s hearing for adoption of the rule.

The required findings are:

Necessity: The rules amendments are required in order to meet the state=s Best Available 

Retrofit Control Technology requirements (section 40919(a)(3) of the CH&SC) and 

Aevery feasible measures@ requirement (Section 40914 of the CH&SC) for reducing 

volatile organic compound emissions from automotive coating operations. (CH&SC 

Section 40727 (b)(1)).

Authority: The District is authorized to adopt rules and regulations by CH&SC, Sections 

40001, 40702, 40716, 41010 and 41013. (CH&SC Section 40727 (b)(2)).

Clarity: District staff have reviewed the proposed rule and determined it can be easily 

understood by the affected industries. In addition, the record contains no evidence that 

the persons directly affected by the rule cannot understand the rule. (CH&SC Section 

40727(b)(3)).

Consistency: The proposed rule does not conflict with and is not contradictory to, 

existing statutes, court decisions, or state or federal regulations. (CH&SC Section 

40727(b)(4)).

Non-Duplication: The proposed rule does not duplicate any state laws or regulations, 

regarding the attainment and maintenance of state and federal air quality limits. 

(CH&SC Section 40727(b)(5)).

Reference: The District must refer to any statute, court decision, or other provision of law 

that the District implements, interprets, or makes specific by adopting, amending or 

repealing the rule. The proposed rule is consistent with the provisions of the CAA and the 

CH&SC.

VIII. PUBLIC COMMENTS AND STAFF RESPONSES

Staff held a public workshop on October 15, 2008, to discuss the proposed amendments 

to the rule. Notification was sent to surrounding Air Districts, City Managers within the 

District, building/planning/community development departments within the District, all 

city and county libraries within the District, city Chambers of Commerce within the 

District, District Board members and subscribers to the mailing list. In addition, notices 

were sent to sources permitted to coat motor vehicles, and other interested parties 

including coating distributors, spray booth manufacturers, and coating manufacturers. 

The workshop notice was published in the Vacaville Reporter, River News Herald (Rio 

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Vista area), Dixon Tribune, Daily Democrat (Woodland area), West Sacramento Press 

and Davis Enterprise newspapers. A copy of the public workshop notice, the draft staff 

report, and draft rule language were posted on the District=s web page.

The public workshop was attended by two (2) representatives from CARB, one (1) staff 

member from SMAQMD, one (1) representative from the United States Post Office 

(USPS), two (2) coating distributors, and two (2) permitted facilities.

District Staff will attempt to paraphrase the verbal comments that were discussed during 

the workshop and respond to each comment. 

Comment 1. CARB expressed concern that the exemption in Section 110.5 as written, 

exempts any automobile coating reformulated or repackaged by 

manufacturers from the entire rule. This could allow a manufacturer to sell 

non-compliant products within the District claiming the product was 

reformulated or repackaged.

Response 1. The District=s intent was to allow non-compliant products to be 

reformulated or repackaged in the District to compliant products. The 

District worked with CARB developing language to allow a manufacturer 

to sell non-compliant products within the District for reformulation or 

repackaging. This exemption will only be from the prohibition of sale or 

manufacture, the other rule requirements will still be applicable. In 

addition, record keeping provisions will be added for any person claiming 

the exemption.

Comments 2 and 3.

Industry asked for clarification regarding graphic design applications. 

Industry inquired about compliant application methods and if there was a 

limit on the quantity of coating used in regards to graphic design 

applications.

Response 2 and 3.

The District exempts graphic arts applications from Section 304 

Application Requirements. In addition, Definition 218 Graphic Design 

Application includes application methods. Therefore, coatings used for 

graphic design applications are not limited to the methods outlined in 

Section 304. The coatings can be brushed, rolled or airbrushed. The rule 

does not limit the amount of coating that can be used for graphic design 

application. All coatings used for graphic design application must be 

compliant with the VOC content limits outlined in the Rule.

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Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Comment 4. The USPS commented that purchase records may not be stored onsite at 

all facilities where the coating is actually applied. The USPS also asked to 

clarify what purchase records are required. 

Response 4. The rule language states the records need to be onsite. This language is 

consistent with the SCM. The rule does not state the records need to be the 

original copies. A copy of the orders is adequate. The District will also 

accept copies of records from the Distributor. The District will work with 

facilities to achieve compliance. 

Comment 5. Industry inquired if a MSDS could be from the internet or does it have to 

be a hard copy.

Response 5. The District will accept all MSDS in an electronic format however other 

agencies such as the Fire Department or the Occupational Safety and 

Health Administration may have other requirements.

Comment 6. Industry inquired if SMAQMD has adopted the rule. Concern was 

expressed the six month period from the adoption date may not be long 

enough for all sources to become compliant with the new rule, especially 

if Sacramento is adopting the limits at the same time. Concern was 

expressed about distributors being able to meet the demands of new 

products. 

Response 6. SMAQMD attended the workshop. SMAQMD stated their rule was in the 

process of being revised and the workshop was not yet scheduled. 

SMAQMD stated many of their facilities were in the process of converting 

to compliant products prior to the adoption date. 

The District responded that outreach with the new requirements started 

prior to the rule development. The District has been informing permitted 

facilities and distributors about the District=s intent to adopt the standards 

in the SCM. The District committed in the Draft October 2006 Sacramento 

Regional 8-hour Ozone Attainment Plan to adopt the SCM in 2008. The 

SCM was adopted by CARB back in 2005. CARB worked with the 

affected industry during the time the SCM was developed and extensive 

outreach was performed by CARB. The District has also informed 

suppliers that a six month period would be given for facilities to get into 

compliance with the new standards after the rule is adopted. Yolo-Solano 

is a smaller District and it is expected suppliers will be able to meet the 

demands of facilities required to use compliant coatings. The District 

wants all the facilities to be in compliance within six months of adoption 

so all facilities will be at the same competitive level. 

Page 17
Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Comment 7. The USPS inquired about the limits in Section 302 for Single-Stage 

Coatings. The table was not clear as to what limits would be in effect for 

this category July 1, 2009.

Response 7. The District amended the table to include a VOC content limit of 420 g/l 

for this category effective July 1, 2009.

Comment 8. Industry inquired why the rule defines Group I and Group II vehicles 

when the rule is changing to group these categories together. 

Response 8. The District is retaining the definitions because the new rule requirements 

do not go into effect until six months after the expected adoption date. The 

Rule will still have different requirements for Group I and Group II 

vehicles until the new requirements take effect. Therefore, the definitions 

need to be retained. 

Comment 9. Industry inquired about requirements for transfer efficiency for spray 

guns. 

Response 9. When the rule was previously revised in May 2008, the application 

requirement section was amended to include other spray guns that aren=t 

HVLP, so long as the gun meets the HVLP definition in Section 221. In 

addition other methods are considered compliant if they can demonstrate a 

transfer efficiency equivalent or higher than the listed application 

methods. The alternative application method has to be approved by the 

District prior to use. Test methods to demonstrate transfer efficiency and 

HVLP equivalency are listed in Section 600. The requirements are 

consistent with the SCM.

No formal written comments were received by the District from the workshop.

After the workshop the rule language was modified and sent for review to CARB and 

EPA. EPA submitted formal comments addressing the changes and the rule language in 

general. The EPA comment letter is included in Attachment D. Following is the District 

response to the comments received.

To avoid a potential SIP relaxation, the District will change the rule language in Section 

306 to retain the 5% limit for specialty coatings until July 1, 2009. In addition, although it 

was not identified as a potential relaxation, Staff will retain the 25% limit for precoat in 

Section 308 until July 1, 2009, to be consistent with the draft language presented at the 

workshop. 

The EPA recommends the District reference Test Method Section 611, Overall Capture 

and Control Efficiency in Section 305, Emission Control Systems. This has not been 

Page 18
Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

identified as an approvability issue. The District will keep the language as is to be 

consistent with other District rules. 

The District included the additional language in Section 402 as suggested by the EPA. 

The EPA recommends records to be retained for a three year period, however this is not 

identified as an approvability issue. The EPA will accept a minimum record retention 

period of two years. The District will keep the record retention period of two years for all 

non Title V facilities for consistency with other District rules. 

IX. REFERENCES

1. California Code of Regulations, Title 17, Division 3, Chapter 1, Subchapter 7.5, 

_93112.

2. Sacramento Regional 8-Hour Ozone Attainment Plan Proposed Control Measured 

Draft (October 2006).

3. San Joaquin Valley Air Pollution Control District Rule 4602 Motor Vehicle and 

Mobile Equipment Refinishing Operations -(Adopted April 11,1991; Amended 

September 19, 1991; Amended December 17, 1992; Amended December 

15,1994; Amended June 15, 1995; Amended September 17, 1997; Amended 

December 20, 2001).

4. San Joaquin Valley Air Pollution Control District Rule 4612 Motor Vehicle and 

Mobile Equipment Coating Operations -Phase II (Adopted September 21, 2006; 

Amended September 20, 2007).

5. Santa Barbara County Air Pollution Control District Board Agenda Item Proposed 

Amended Rule 339, Motor Vehicle and Mobile Equipment Coating Operations 

(June 19, 2008).

6. South Coast Air Quality Management District Rule 1151 -Motor Vehicle and 

Mobile Equipment Non-Assembly Line Coating Operations (December 2005).

7. South Coast Air Quality Management District Staff Report for Proposed 

Amended Rule 1151 -Motor Vehicle and Mobile Equipment Non-Assembly Line 

Coating Operations (December 2005).

8. State of California. California Air Resources Board, 2005 and 2006 Emission 

Inventory.

9. State of California. California Air Resources Board, ARB Solvent Evaporation 

Page 19
Proposed Staff Report - Motor Vehicle and Mobile Equipment Coating Operations November 26, 2008

Methodologies -Architectural Coatings and Cleaning/Thinning solvents (Revised 

October 2003). 

10. State of California. California Air Resources Board, Staff report for the Proposed 

Suggested Control Measure for Automotive Coatings (2005).

11. State of California. California Air Resources Board, California Air Pollution 

Control Laws 2007 Edition.

12. United States Environmental Protection Agency. Code of Federal Regulations, 

Title 40, Part 63, Subpart HHHHHH, National Emissions Standards For 

Hazardous Air Pollutants (NESHAPs): Paint Stripping and Miscellaneous Surface 

Coating Operations at Area Sources.

13. United States Environmental Protection Agency. Federal Register Volume 63, 

Number 176, National Volatile Organic Compound Emission Standards for 

Automobile Refinish Coatings (September 11, 1998).

14. Ventura County Air Pollution Control District Rule 74.18, Motor Vehicle and 

Mobile Equipment Coating Operation (April 2008 Draft).

15. Ventura County Air Pollution Control District Staff Report Revisions to Rule 

74.18, Motor Vehicle and Mobile Equipment Coating Operation (April 2008 

Draft).

Page 20
ATTACHMENT A

PROPOSED AMENDMENTS TO RULE 2.26, MOTOR VEHICLE AND 

MOBILE EQUIPMENT COATING OPERATIONS;

STRIKE-OUT UNDERLINE VERSION
RULE 2.26

MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS

ADOPTED April 27, 1994

REVISED November 9, 1994

REVISED August 13, 1997

REVISED May 14, 2008

REVISED December 10, 2008

INDEX

100 GENERAL

101 PURPOSE

102 APPLICABILITY

103 SEVERABILITY

110 EXEMPTION - GENERAL

111 EXEMPTION - TRANSFER EFFICIENCY PROHIBITION OF SALE 

OR MANUFACTURE

112 EXEMPTION - SMALL PRODUCTION/UTILITY BODIES

APPLICATION REQUIREMENTS

200 DEFINITIONS

201 ADHESION PROMOTER

202 AEROSOL COATING PRODUCT

2013 ANTIGLARE/SAFETY COATING

204 ASSEMBLY LINE

205 ASSOCIATED PARTS AND COMPONENTS

206 AUTOMOTIVE COATING

207 AUTOMOTIVE COATING COMPONENT

208 AUTOMOTIVE REFINISHING FACILITY

2029 CATALYST

210 CLEAR COATING

211 COATING

212 COLOR COATING

2013 CONTROL DEVICE

2014 COLOR MATCH

2015 ELECTROSTATIC SPRAY APPLICATION

2016 EMISSION CONTROL SYSTEM

2017 EXEMPT COMPOUNDS

208 FINISHING

209 FINAL STAGE MANUFACTURE

2108 GRAPHIC DESIGN APPLICATION

211 GROUND SUPPORT

2129 GROUP I VEHICLES
21320GROUP II VEHICLES AND EQUIPMENT

21421HIGH-VOLUME, LOW-PRESSURE (HVLP) SPRAY EQUIPMENT

21522LARGE/HEAVY DUTY TRUCKS

21623LIGHT AND MEDIUM DUTY TRUCKS AND VANS

21724METALLIC/IRIDESCENT TOPCOAT

21825MOBILE EQUIPMENT

226 MOTOR VEHICLE

227 MULTI-COLOR COATING

21928MULTI-STAGE TOPCOAT SYSTEM

2209 PRECOAT

22130PRETREATMENT WASH PRIMER COATING

22231PRIMER

2232 PRIMER SEALER

22433PRIMER SURFACER

22534REDUCER

226 REFINISHING

235 SINGLE-STAGE COATING

236 SOLVENT

22737SPECIALTY COATINGS

238 SPOT REPAIR

22839SURFACE PREPARATION AND CLEANUP

22940TEMPORARY PROTECTIVE COATING

23041TOPCOAT

231 TOUCH-UP COATING

23242TRANSFER EFFICIENCY

243 TRUCK BED LINER COATING

244 UNDERBODY COATING

245 UNIFORM FINISH COATING

233 UTILITY BODY

2346 VOLATILE ORGANIC COMPOUNDS(VOC)

23547VOLATILE ORGANIC COMPOUND (VOC) CONTENT

300 STANDARDS

301 COATING LIMITS

302 COATING LIMITS

303 MOST RESTRICTIVE VOC LIMIT

3024 APPLICATION REQUIREMENTS

3035 EMISSION CONTROL SYSTEM

3046 STORAGE AND DISPOSAL - GENERAL

3057 REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP 

MATERIALS

3068 SPECIALTY COATINGS

307 TEMPORARY PROTECTIVE COATING

3089 PRECOAT LIMITATION
310 TOXIC AIR CONTAMINANT

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF POSSESSION

4012 PROHIBITION OF SPECIFICATION

4023 PROHIBITION OF SALE OR MANUFACTURE

4034 COMPLIANCE STATEMENT REQUIREMENT

405 LABELING REQUIREMENTS

4046 HVLP MARKING

4057 OPERATION AND MAINTENANCE PLAN (O&M PLAN)

500 MONITORING AND RECORDS

501 RECORD KEEPING - GENERAL

502 RECORD KEEPING - EMISSION CONTROL SYSTEM

503 RECORD KEEPING - PROHIBITION OF SALE OR MANUFACTURE

5034 BURDEN OF PROOF

5045 REPORTING

600 TEST METHODS AND CALCULATIONS

601 GENERAL

602 VOC CONTENT

603 EXEMPT COMPOUNDS

604 EXEMPT COMPOUNDS -METHYL ACETATE, ACETONE, 

T-BUTYL ACETATE, AND PARACHLOROBENZOTRIFLUORIDE 

(PCBTF)

605 CALCULATION OF VOC CONTENT

606 CALCULATION OF VOC CONTENT OF COATING SYSTEM

607 TRANSFER EFFICIENCY

608 HVLP EQUIVALENCY

6089 CAPTURE EFFICIENCY

6109 CONTROL EFFICIENCY

6110 OVERALL CAPTURE AND CONTROL EFFICIENCY

6112 IRIDESCENT PARTICLES IN METALLIC/IRIDESCENT TOPCOAT

6132 ACID CONCENTRATION IN PRETREATMENT WASH PRIMER
100 GENERAL

101 PURPOSE: The purpose of this rule is to limit the emission of volatile organic 

compounds (VOCs) from the finishing or refinishing of Group I and Group II 

Vehicles and Equipment as defined in this Rule coating operations associated 

with motor vehicles, mobile equipment, and associated parts and components.

102 APPLICABILITY: The provisions of this rule are applicable to any owner or 

operator of a facility person who uses, applies or solicits the use or application of 

any coating on motor vehicles using coatings in the finishing of Group I Vehicles 

and Group II vehicles and or mobile equipment, and their parts and components, 

or any person who supplies, sells, offers for sale, manufactures or distributes 

within the District, any material subject to the provisions of this rule.

103 SEVERABILITY: If any provision, clause, sentence, paragraph, section or part 

of this rule for any reason is judged to be unconstitutional or invalid, such 

judgement shall not affect or invalidate the remainder of the rule.

110 EXEMPTION - GENERAL: The provisions of this rule, except for Section 503, 

Burden of Proof, shall not apply to the following:

110.1 Touch-up operations;

110.2 Graphic design applications;

110.3 Coating of military vehicles and ground support equipment which 

is subject to the provisions of District Rule 2.25, METAL PARTS 

AND COATING OPERATIONS. Military vehicles include tanks 

and armored personnel carriers but do not include passenger 

vehicles;

110.4 Coating of radiators and engine components which is subject to the 

provisions of District Rule 2.25, METAL PARTS AND 

COATING OPERATIONS;

110.51 Application of aerosol paint coating products.

110.2 Any automotive coating that is sold, supplied, or offered for sale in 

0.5 fluid ounce or smaller containers intended to be used by the 

general public to repair tiny surface imperfections.

110.3 Any coating applied to motor vehicles or mobile equipment, or 

their associated parts and components during manufacture on an 

assembly line.
110.4 Any automotive coating that is offered for sale, 

sold or manufactured for use outside of the District.

111 EXEMPTION - PROHIBITION OF SALE OR MANUFACTURE: The 

provisions of Section 403 shall not apply to any automotive coating that is offered 

for sale, sold or shipped for reformulation or repackaging, or any coating whose 

emissions to the atmosphere are controlled by an emission control system that 

meets the requirements of Section 305.

112 EXEMPTION - APPLICATION REQUIREMENTS: The provisions of 

Section 304 of this Rule shall not apply to the application of underbody coatings, 

graphic design applications, truck bed liner coatings, or any coating use of less 

than one (1) fluid ounce (29.6 milliliters).

111 EXEMPTION - TRANSFER EFFICIENCY: The provisions of Section 302 of 

this Rule shall not apply to the application of high viscosity or thixotropic 

coatings with application equipment that is supplied with and is an integral part of 

the coating container or to the application of corrosion protective coatings to 

enclosed interior spaces.

112 EXEMPTION - SMALL PRODUCTION/UTILITY BODIES: The provisions 

of Section 301.1 of this Rule, shall not apply to the coating of utility bodies where 

the coating must match that of the vehicle they will be mounted on provided 

production is less than 20 vehicles per day.

200 DEFINITIONS

201 ADHESION PROMOTER: A coating which is labeled and formulated to be 

applied to uncoated plastic surfaces to facilitate bonding of subsequent coatings, 

and on which, a subsequent coating is applied.

202 AEROSOL COATING PRODUCT: A pressurized coating product containing 

pigments or resins that dispenses product ingredients by means of a propellant, 

and is packaged in a disposable can for hand-held application, or for use in 

specialized equipment for ground traffic/marking applications.

2013 ANTIGLARE/SAFETY COATING: A coating which minimizes light 

reflection for safety purposes.

204 ASSEMBLY LINE: An arrangement of industrial equipment and workers in 

which the product passes from one specialized operation to another until 

complete, by either automatic or manual means.

205 ASSOCIATED PARTS AND COMPONENTS: Any structures, devices, 

pieces, modules, sections, assemblies, subassemblies, or elements of motor 
vehicles or mobile equipment that are designed to be a part of motor vehicles or 

mobile equipment but which are not attached to motor vehicles or mobile 

equipment at the time of coating the structure, device, piece, module, section, 

assembly, subassembly, or element. AAssociated parts and components@ does not 

include circuit boards.

206 AUTOMOTIVE COATING: Any coating or coating component used or 

recommended for use in motor vehicle or mobile equipment refinishing, service, 

maintenance, repair, restoration, or modification, except metal plating activities. 

Any reference to automotive refinishing or automotive coating made by a person 

on the container or in product literature constitutes a recommendation for use in 

motor vehicle or mobile equipment refinishing. 

207 AUTOMOTIVE COATING COMPONENT: Any portion of a coating 

including, but not limited to, a reducer or thinner, toner, hardener, and additive, 

which is recommended by any person to distributors or end-users for use in an 

automotive coating, or which is supplied for or used in an automotive coating. 

The raw materials used to produce the components are not considered automotive 

coating components.

208 AUTOMOTIVE REFINISHING FACILITY: Any shop, business, location, or 

parcel of land where motor vehicles or mobile equipment or their associated parts 

and components are coated, including autobody collision repair shops. 

AAutomotive Refinishing Facility@ does not include the original equipment 

manufacturing plant where the motor vehicle or mobile equipment is completely 

assembled. 

2029 CATALYST: A substance whose presence initiates the reaction between 

chemical compounds.

210 CLEAR COATING: Any coating that contains no pigments and is labeled and 

formulated for application over a color coating or clear coating.

211 COATING: A material which is applied to a surface and forms a film in order to 

beautify, preserve, repair, or protect such a surface.

212 COLOR COATING: Any pigmented coating, excluding adhesion promoters, 

primers, and multi-color coatings, that requires a subsequent clear coating and 

which is applied over a primer, adhesion promoter, or color coating. Color 

coatings include metallic/iridescent color coatings. 

2013 CONTROL DEVICE: Equipment such as an incinerator or adsorber used to 

prevent air pollutants from reaching the ambient air.
2014 COLOR MATCH: The ability of a repair coating to blend into an existing 

coating so that color difference is not visible.

2015 ELECTROSTATIC SPRAY APPLICATION: The application of charged 

atomized paint droplets which are deposited by electrostatic attraction. Any 

method of spray application of coatings where an electrostatic attraction is created 

between the part to be coated and the paint particles. 

2016 EMISSION CONTROL SYSTEM: A control device and its associated 

collection system.

2017 EXEMPT COMPOUNDS: As defined in District Rule 1.1, General Provisions 

and Definitions. 

208 FINISHING: The coating of incomplete vehicles, their parts and components, or 

mobile equipment for which the original coating was not applied from an Original 

Equipment Manufacturing (OEM) plant coating assembly line.

209 FINAL STAGE MANUFACTURE: An incomplete vehicle chassis is delivered 

to a manufacturer for installation and paint of a truck body and/or components to 

form a completed vehicle.

2108 GRAPHIC DESIGN APPLICATION: The application of logos, letters, 

numbers and graphics to a painted surface, with or without the use of a template

by brush, roller, or airbrush.

211 GROUND SUPPORT: Vehicles used in support of aircraft activities at airports.

2129 GROUP I VEHICLES: Passenger cars, large/heavy duty truck cabs and chassis, 

light and medium duty trucks and vans, and motorcycles.

21320GROUP II VEHICLES AND EQUIPMENT: Public transit buses and mobile 

equipment.

2214 HIGH-VOLUME, LOW-PRESSURE (HVLP) SPRAY EQUIPMENT: Spray 

equipment used to apply coatings by means of a gun permanently labeled as such 

and which is designed and operated between 0.1 and 10 pounds per square inch 

(psig) air atomizing pressure measured dynamically at the center of the air cap 

and at the air horns.

21522LARGE/HEAVY DUTY TRUCKS: Any truck having a manufacturer's gross 

vehicle weight rating of over 30,000 pounds.

21623LIGHT AND MEDIUM DUTY TRUCKS AND VANS: Any truck or van 
having a manufacturer's gross vehicle weight rating of 30,000 pounds or less.

21724METALLIC/IRIDESCENT TOPCOAT: Any coating which contains more than 

5 g/l (0.042 lb/gal) of metal or iridescent particles, as applied, where such 

particles are visible in the dried film.

21825MOBILE EQUIPMENT: Any equipment which may be drawn or is capable of 

being driven on rails or on a roadway, including, but not limited to, trains, 

railcars, truck bodies, truck trailers, camper shells, mobile cranes, bulldozers, 

street cleaners, golf carts and implements of husbandry or agriculture.

226 MOTOR VEHICLE: Any self-propelled vehicle, including but not limited to, 

cars, trucks, buses, golf carts, vans, motorcycles, tanks, and armored personnel 

carriers.

227 MULTI-COLOR COATING: Any coating that exhibits more than one color in 

the dried film after a single application, is packaged in a single container, and 

hides surface defects on areas of heavy use, and which is applied over a primer or 

adhesion promoter.

21928MULTI-STAGE TOPCOAT SYSTEM: A topcoat system composed of either a 

basecoat / clearcoat (2 stage), a basecoat / midcoat / clearcoat (3 stage), or a 

groundcoat / basecoat / midcoat / clearcoat (4 stage).

2209 PRECOAT: Any coating which is applied to bare metal primarily to deactivate 

the metal surface prior to application of a subsequent water-base primer surfacer. 

A precoat shall be a coating that dries by oxidation or chemical polymerization.

22130PRETREATMENT WASH PRIMER COATING: Any coating which contains 

a minimum of one half (0.5) percent acid by weight and not more than 16 percent 

solids by weight, is necessary to provide surface etching and is applied labeled 

and formulated for application directly to bare metal surfaces to provide corrosion 

resistance and adhesion.

22231PRIMER: Any coating applied prior to the application of a topcoat for the purpose 

of corrosion resistance and adhesion of the topcoat. Primer surfacer and primer 

sealer shall be considered as primer when applied to Group II vehicles Any 

coating, which is labeled and formulated for application to a substrate to provide 

1) a bond between the substrate and subsequent coats, 2) corrosion resistance, 3) a 

smooth substrate surface, or 4) resistance to penetration of subsequent coats, and 

on which a subsequent coating is applied. Primers may be pigmented.

2232 PRIMER SEALER: Any coating applied for the purpose of sealing the 

underlying metal, primer system, or OEM finish prior to the application of a 
topcoat. One of the purposes of a primer sealer is to promote the ability of an 

undercoat to resist penetration by the topcoat which is labeled and formulated for 

application prior to the application of a color coating for the purpose of color 

uniformity, or to promote the ability of the underlying coating to resist penetration 

by the color coating.

22433PRIMER SURFACER: Any coating applied prior to the application of a topcoat 

for the purpose of corrosion resistance, adhesion of the topcoat, and which 

promotes a uniform surface by filling in surface imperfections.

22534REDUCER: The solvent used to thin enamel.

226 REFINISHING: Any coating of vehicles, their parts and components, or mobile 

equipment, including partial body collision repairs, for the purpose of protection 

or beautification and which is subsequent to the original coating applied at an 

Original Equipment Manufacturing (OEM) plant coating assembly line.

235 SINGLE-STAGE COATING: Any pigmented coating, excluding primers and 

multi-color coatings, labeled and formulated for application without a subsequent 

clear coat. Single-stage coatings include single-stage metallic/iridescent coatings. 

236 SOLVENT: A VOC-containing fluid used to perform surface preparation and 

cleaning operations.

22737SPECIALTY COATINGS: Unique coatings and compliant coatings with 

additives which are necessary due to unusual job performance requirements. 

Said coatings include, but are not limited to, adhesion promoters, uniform finish 

blenders, elastomeric materials, gloss flatteners, bright metal trim repair, and 

anti-glare/safety coatings.

238 SPOT REPAIR: Repair of an area on a motor vehicle, piece of mobile 

equipment, or associated parts or components of less than 1 square foot (929 

square centimeters).

22839SURFACE PREPARATION AND CLEANUP: The removal of contaminants 

such as dust, soil, oil, grease, etc., prior to any step in a manufacturing process 

from parts, products, tools, machinery, equipment, and general work areas.

22940TEMPORARY PROTECTIVE COATING: A coating applied for the purpose 

of protecting adjacent areas to that being painted from overspray. The temporary 

protective coating is removed after primer or topcoat application. Any coating 

which is labeled and formulated for the purpose of temporarily protecting areas 

from overspray or mechanical damage.
23041TOPCOAT: Any coating applied over a primer, primer system, or an original 

OEM finish for the purpose of protection or appearance. For the purposes of this 

Rule, solid color and metallic/iridescent topcoats are single stage applications, the 

VOCAVERAGE of a multi stage topcoat system will determine compliance with the 

VOC standards in Section 301 of this Rule.

231 TOUCH-UP COATING: A coating applied by brush, air brush, or hand held, 

non-refillable aerosol cans to repair minor surface damage and imperfections of 

less than four square feet.

23242TRANSFER EFFICIENCY: The ratio of the amount of coating solids adhering 

to the object being coated to the total amount of coating solids used in the 

application process sprayed, expressed as a percentage.

243 TRUCK BED LINER COATING: Any coating, excluding clear, color, 

multi-color, and single stage coatings, labeled and formulated for application to a 

truck bed to protect it from surface abrasion.

244 UNDERBODY COATING: Any coating labeled and formulated for application 

to wheel wells, the inside of door panels or fenders, the underside of a trunk or 

hood, or the underside of the motor vehicle.

245 UNIFORM FINISH COATING: Any coating labeled and formulated for 

application to the area around a spot repair for the purpose of blending a repaired 

area=s color or clear coat to match the appearance of an adjacent area=s existing 

coating.

233 UTILITY BODY: A special purpose service compartment or unit that will be 

bolted, welded, or affixed onto an existing cab and chassis. The compartment may 

serve as storage for equipment or parts.

2346 VOLATILE ORGANIC COMPOUNDS(VOC): As defined in Rule 1.1, 

General Provisions and Definitions.

23547VOLATILE ORGANIC COMPOUND (VOC) CONTENT: Weight of VOC per 

volume of material as calculated pursuant to the applicable Sections of 600. 

300 STANDARDS

301 COATING LIMITS: Until July 1, 2009, Aany person who applies coatings to 

Group I or II vehicles, mobile equipment, their parts and components, shall 

comply with Sections 301.1 or 301.2 of this Rule.

301.1 Group I Vehicles. A person shall not refinish Group I vehicles, 

their parts and components, or Group II vehicles and mobile 
equipment where color match is required, using any coating with a 

regulatory VOC content in excess of the following limits, 

expressed as grams of VOC per liter (or pounds per gallon) of 

coating applied, excluding water and exempt compounds

COATING REGULATORY VOC 

Pretreatment Wash Primer Coating 780 /l (6 5 lb / l) Precoat 600 g/l (5.0 lbs/gal)

Primer/Primer surfacer 250 g/l (2.1 lbs/gal)

Primer Sealer 420 g/l (3 5 lbs/gal) Solid Color Topcoat 420 g/l (3 5 lbs/gal) Metallic/Iridescent Topcoat 520 g/l (4.3 lbs/gal)

Multi Stage Topcoat System 540 g/l (4.5 lbs/gal)

Specialty Coating 840 g/l (7.0 lbs/gal)

Temporary Protective Coating 60 g/l (0.5 lbs/gal)

301.2 Group II Vehicles and Mobile Equipment. A person shall not 

finish or refinish Group II vehicles and equipment or their parts 

and components where color match is not required, using any 

coating with a regulatory VOC content in excess of the following 

limits, expressed as grams of VOC per liter (or pounds per gallon) 

of coating applied, excluding water and exempt compounds.

COATING REGULATORY VOC 

CONTENT

Pretreatment Wash Primer Coating 780 g/l (6.5 lbs/gal)

Precoat 600 g/l (5.0 lbs/gal)

Primer 250 g/l (2.1 lbs/gal)

Primer Sealer 340 g/l (2.8 lbs/gal)

Topcoat 420 g/l (3.5 lbs/gal)

Metallic/Iridescent Topcoat 420 g/l (3.5 lbs/gal)

Specialty Coating 840 g/l (7.0 lbs/gal)

Temporary Protective Coating 60 g/l (0.5 lbs/gal)

302 COATING LIMITS: Effective July 1, 2009, no person shall apply to any motor 

vehicle, mobile equipment, or associated parts and components, any coating with 

a VOC regulatory content, as calculated pursuant to section 605, in excess of the 

following limits, except as provided in Section 305:
COATING CATEGORY REGULATORY VOC 

CONTENT

grams/liter (pounds/gallon)

Effective 

7/1/2009

Effective 

7/1/2010

Adhesion Promoter 840 (7.0) 540 (4.5)

Clear Coating 250 (2.1) 250 (2.1)

Color Coating 420 (3.5) 420 (3.5)

Multi-Color Coating 680 (5.7) 680 (5.7)

Pretreatment Coating 660 (5.5) 660 (5.5)

Primer 250 (2.1) 250 (2.1)

Primer Sealer 340 (2.8) 250 (2.1)

Single-Stage Coating 420 (3.5) 340 (2.8)

Temporary Protective Coating 60 (0.5) 60 (0.5)

Truck Bed Liner Coating 310 (2.6) 310 (2.6)

Underbody Coating 430 (3.6) 430 (3.6)

Uniform Finish Coating 540 (4.5) 540 (4.5)

Any Other Coating Type 250 (2.1) 250 (2.1)

303 MOST RESTRICTIVE VOC LIMIT: If anywhere on the container of any 

automotive coating, or any label or sticker affixed to the container, or in any sales, 

advertising, or technical literature supplied by a person, any representation is 

made that indicates that the coating meets the definition of or is recommended for 

use for more than one of the coating categories listed in section 302, then the 

lowest VOC content limit shall apply.

3024 APPLICATION REQUIREMENTS: A No person shall not apply any 

coatings to any Group I or II vehicles motor vehicle, or mobile equipment, or their 

associated parts and components unless the coatings are applied using properly 

operated equipment and by using one of the following application methods is 

used:

302.1 Electrostatic application equipment, operated in accordance with 

the manufacturer's recommendations;

302.2 HVLP spray equipment, operated in accordance with the 

manufacturer's recommendations;

302.3 Any other coating application method demonstrated, in accordance 

with the provisions of Section 607 to have a transfer efficiency 

equivalent to or greater than the coating application method listed 
in Section 302.2, and is approved in writing by the EPA and 

APCO.

304.1 Brush, dip, or roller;

304.2 Electrostatic spray;

304.3 HVLP spray equipment;

304.4 Use of a spray gun: If a spray gun is used, the end user must 

demonstrate that the gun meets the HVLP definition in Section 221 

in design and use. A satisfactory demonstration must be based on 

the manufacturer=s published technical material on the design of 

the gun and by a demonstration of the operation of the gun using 

an air pressure tip gauge from the manufacturer of the gun. 

304.5 Any alternative method that achieves a transfer efficiency 

equivalent to, or higher than, the application methods listed in 

sections 304.1, 304.2, or 304.3 as determined per section 608. 

Written approval from the Executive Officer or Air Pollution 

Control Officer of the District shall be obtained for each alternative 

method prior to use.

3035 EMISSION CONTROL SYSTEM: In lieu of complying with the applicable 

provisions VOC content limits of Section 300 301 or 302, an operator person may 

use a VOC emission control system that controls emissions from the source 

operation provided the following conditions are met:

3035.1 The VOC emission control system shall be approved in writing by 

the APCO,

3035.2 The VOC emission control system shall be operated with an 

overall capture and control efficiency of at least 85 percent by 

weight during periods of emission producing activity.

3046 STORAGE AND DISPOSAL - GENERAL: All VOC-containing materials, 

whether in its form for intended use or as a waste or used product, including items 

such as cloth or paper laden with VOC containing materials, shall be stored in 

non-absorbent, non-leaking containers which shall be kept closed at all times, 

except when filling or emptying, and disposed of in a manner to prevent 

evaporation of VOCs into the atmosphere at the facility.

3057 REQUIREMENTS FOR SURFACE PREPARATION AND CLEANUP 

MATERIALS: Any solvent cleaning of application equipment, parts, products, 

tools, machinery, equipment, general work areas, and the storage and disposal of 

VOC-containing materials used in surface preparation and cleanup operations 
shall be carried out pursuant to Rule 2.31, Surface Preparation and Cleanup.

3068 SPECIALTY COATINGS: Until July 1, 2009, A person shall not use any 

specialty coating with a VOC content in excess of 840 g/l (7.0 pounds per gallon), 

excluding water and exempt compounds. Uuse of all specialty coatings except 

antiglare/safety coatings shall not exceed 5.0 percent of all coatings applied, on a 

monthly basis. The application of topcoats with a specialty coating used as an 

additive shall be subject to the topcoat limits in Sections 301.1 and 301.2 of this 

Rule.

307 TEMPORARY PROTECTIVE COATING: A person shall not use any 

temporary protective coating with a VOC content in excess of 60 g/l (0.5 lb/gal), 

excluding water.

3089 PRECOAT LIMITATION: Until July 1, 2009, aA person shall not use precoat 

in excess of 25 %, by volume, of the amount of primer surfacer used on a monthly 

basis. Purchase invoices to verify this limitation shall be presented to the Air 

Pollution Control Officer upon request.

308 TOXIC AIR CONTAMINANT: No person shall apply a coating to any motor 

vehicle, mobile equipment, or associated parts and components, containing 

cadmium or hexavalent chromium. 

400 ADMINISTRATIVE REQUIREMENTS

401 PROHIBITION OF POSSESSION: Effective 7/1/2009, no person shall possess 

at any automotive refinishing facility, any automotive coating that is not in 

compliance with section 302 or 305, as applicable. 

4012 PROHIBITION OF SPECIFICATION: A No person shall not specify the use 

of any coating to be applied to a Group I or Group II vehicle motor vehicle, 

mobile equipment, or part or component subject to the provisions of this rule that 

does not meet the limits and requirements of this rule where such applications 

result in a violation of this rule. The requirements of this Section shall apply to all 

written or oral contracts, including, but not limited to, job orders, under the terms 

of which any coating or solvent that is subject to the provisions of this rule is to 

be used or applied.

4023 PROHIBITION OF SALE OR MANUFACTURE: A No person shall not

manufacture, blend, repackage for sale, supply, sell, offer for sale or sell distribute

within the District any coating if such product is prohibited by any of the 

provisions of this Rule. The prohibition of this Section shall apply to the sale of 

any coating which will be applied at any physical location within the jurisdiction 

of the local air pollution control agencies. This requirement shall not apply to the 
application of coatings where emissions to the atmosphere are controlled to an 

equivalent level of this Rule by an emission control system that has been 

approved in writing by the APCO.

4034 COMPLIANCE STATEMENT REQUIREMENT: The manufacturer or 

repacker of coatings subject to this Rule shall provide the following: on separate 

data sheets the designation of VOC content (as supplied) including any 

recommended thinning ratio. The VOC content shall be expressed as grams per 

liter of coating less water and less exempt compounds and may be determined by 

either calculation or analysis. 

404.1 Until July 1, 2009, separate data sheets designating the VOC 

content (as supplied) including any recommended thinning ratio. 

The VOC content shall be expressed as grams per liter of coating 

less water and less exempt compounds and may be determined by 

either calculation or analysis.

404.2 Effective July 1, 2009, product data sheets or an equivalent 

medium containing the following information:

a. The actual VOC content and the regulatory 

VOC content for coatings expressed in grams 

per liter;

b. The weight percentage of volatiles, water, and exempt 

compounds; 

C. The volume percentage of water and exempt compounds; 

and

d. The density of the material in grams per liter.

405 LABELING REQUIREMENTS: Effective July 1, 2009, the manufacturer and 

repackager of automotive coatings or automotive coating components shall 

include on all containers the applicable use category(ies), and the VOC actual for 

coatings and VOC regulatory for coatings, as supplied, expressed in grams per 

liter. 

4046 HVLP MARKING: A person shall not sell, or offer for sale, or distribute for use 

within the District any HVLP gun without a permanent marking, or accurate 

information provided on company letterhead or in the form of technical literature 

clearly identifying the spray gun manufacturer, salesperson or distributer,

denoting the maximum inlet air pressure in psig at which the gun will operate 

within the parameters specified in Section 2214 of this Rule.

4057 OPERATION AND MAINTENANCE PLAN (O&M Plan): Any person using 

an emission control device pursuant to Section 3053 of this Rule, as a means of 

complying with this rule, must submit with the application for Authority to 
Construct, pursuant to Rule 3.1, GENERAL PERMIT REQUIREMENTS, an 

O&M Plan for the emission control device to the APCO for approval. The O&M 

Plan shall specify operation and maintenance procedures which will demonstrate 

continuous operation of the control device during periods of emission producing 

operations. The O&M Plan shall also specify which records must be kept to 

document these operation and maintenance procedures. These records shall 

comply with the requirements of Sections 501.5 and 5021.6 of this Rule. Any 

person using an emission control device must fully comply with all O&M Plans 

submitted for approval, even if such O&M Plans have not yet been approved, 

unless notified in writing by the APCO.

500 MONITORING AND RECORDS

501 RECORD KEEPING - GENERAL: Any person using coatings subject to 

Section 300 of this Rule shall maintain and have available at all time on site the 

following comply with the following requirements:

501.1 The person shall maintain and have available during an inspection, 

the listed category of each of the coatings and the type of vehicle 

or equipment to which each coating was applied.

501.2 The person shall maintain and have available during an inspection, 

a current list of coatings in use which provides all of the coating 

data necessary to evaluate compliance, including the following 

information, as applicable:

a. Coating, catalyst, additives, and reducer used.

b. Mix ratio of components used.

c. VOC content of coating as applied.

501.3 The person shall maintain records on a daily basis including the 

following information:

a. Coating and mix ratio of components in the coating used.

b. Quantity of each coating applied.

501.1 A current list of all coatings and additives used subject to this rule, 

including the following:

a. Material name and manufacturer;

b. Application method;

c. Coating category and mix ratio specific to the coating; and

d. Actual VOC content for coatings and the regulatory VOC 

content for coatings, as applied.

501.2 Current manufacturer specification sheets, material data sheets, 

technical data sheets, or air quality data sheets, which list the 
actual VOC content for coatings and regulatory VOC content for 

coatings of each ready-to-spray coating (based on the 

manufacturer=s stated mix ratio) and automotive coating 

components, and the VOC content of each solvent.

501.3 The person shall maintain records on a daily basis including the 

following information:

a. Coating and mix ratio of components in the coating used.

b. Quantity of each coating applied.

501.4 Purchase records identifying the coating type, name, and volume 

of coating.

502 RECORD KEEPING - EMISSION CONTROL SYSTEMS: If compliance 

with this rule is achieved through the use of an emission control system, in 

addition to the provisions of Section 501, the owner or operator shall maintain:

502.1 Daily usage records of all materials used such as coatings, 

catalysts, additives, and reducers.

502.2 Daily records of key operating parameters such 

as temperatures, pressures, flowrates, and hours of operation of 

the control device to verify compliance of the capture and control 

device.

502.3 Maintenance work which interferes with the 

operation of the control device.

503 RECORD KEEPING - PROHIBITION OF SALE OR MANUFACTURE:

Any person claiming an exemption under Section 111 shall keep a detailed log of 

each automotive coating component and automotive coating manufactured, 

blended, repackaged for sale, supplied, sold, offered for sale, or distributed 

showing: 

503.1 The quantity manufactured, blended, repackaged for sale, supplied, 

sold, offered for sale, or distributed, including size and number of 

containers;

503.2 The regulatory VOC content for coatings;

503.3 The actual VOC content for coatings;

503.4 To whom they were supplied, sold, offered for sale, or distributed, 

or for whom they were manufactured, blended, or repackaged for 
sale including the name, address, phone number, retail tax license 

number, and valid District permit number; and

503.5 The specific exemption being utilized under Section 111.

5034 BURDEN OF PROOF: Any person claiming an exemption pursuant to Section 

1120, or 111 or 112 shall have information available such as product data or 

material safety data sheets or records that would allow the APCO to verify the 

eligibility of the exemption.

5045 REPORTING: All records required by this Rule shall be maintained on site for a 

period of two years and made available to the APCO upon request.

600 TEST METHODS AND CALCULATIONS

601 GENERAL: For the purposes of this Rule, the following test methods or 

calculation methods shall be used. Other test methods determined to be equivalent 

and approved in writing by the District and the EPA may also be used. VOC 

emissions or other parameters determined to exceed any limits established by this 

Rule through the use of any of the following test methods or calculations shall 

constitute a violation of this Rule.

602 VOC CONTENT: The VOC content of coatings, subject to the provisions of this 

Rule, shall be determined by procedures contained in EPA Reference Test 

Method 24 (40 CFR 60, Appendix A ADetermination of Volatile Matter Content, 

Water Content, Density, Volume Solids, and Weight Solids of Surface Coatings@).

603 EXEMPT COMPOUNDS: Measurement of exempt compounds shall be 

determined by using ARB Method 432, ADetermination of Dichloromethane and 

1,1,1-Trichlorethane in Paints and Coatings,@ September 12, 1998: ARB Method 

422 ADetermination of Volatile Organic Compounds in Emission from Stationary 

Sources,@ January 22, 1987; or South Coast Air Quality Management District 

(SCAQMD) Method 303-91 ADetermination of Exempt Compounds,@ February 

1993.

604 EXEMPT COMPOUNDS -METHYL ACETATE, ACETONE, T-BUTYL 

ACETATE, AND PARACHLOROBENZOTRIFLUORIDE (PCBTF):

Measurement of methyl acetate, acetone t-butyl acetate and PCBTF, shall be 

determined by using ASTM D6133-02, AStandard Test Method for Acetone, 

p-Chlorobenzotrifluoride, Methyl Acetate or t-Butyl Acetate Content of 

Solventborne and Waterborne Paints, Coatings, Resins, and Raw Materials by 

Direct Injection Into a Gas Chromatograph@. 

605 CALCULATION OF VOC CONTENT: The VOC content per volume of 
coating shall be calculated less water and less exempt compounds as follows:

Grams of VOC per liter of coating = Ws - Ww - Wes

less water and less exempt compounds Vm - Vw - Ves

Where: Ws = Weight of volatile compounds in 

grams

Ww = Weight of water in grams

Wes = Weight of exempt compounds in grams

Vm = Volume of coating materials in liters

Vw = Volume of water in liters

Ves = Volume of exempt compounds in liters

605.1 The regulatory VOC content per volume of coating shall be 

calculated less water and less exempt compounds as follows:

VOCcon = Ws - Ww - Wec

Vm - Vw - Vec

Where:VOCcon= Grams of VOC per liter of material

Ws = Weight of volatile compounds in grams

Ww = Weight of water in grams

Wec = Weight of exempt compounds in grams

Vm = Volume of coating materials in liters

Vw = Volume of water in liters

Vec = Volume of exempt compounds in liters

605.2 The actual VOC content per volume of coating shall be calculated 

by the following equation:

VOCcon = ( Ws - Ww - Wec )

Vm

Where:VOCcon= Grams of VOC per liter of material

Ws = Weight of volatile compounds in grams

Ww = Weight of water in grams

Wec = Weight of exempt compounds in grams

Vm = Volume of material in liters

606 CALCULATION OF VOC CONTENT OF COATING SYSTEM: Until July 

1, 2009, Tthe VOC content of a basecoat/clearcoat coating system shall be 

calculated according to the following formula:
VOCAVERAGE = VOCBC + 2VOCCC

3

The VOC content of a three stage coating system shall be calculated according to 

the following formula:

VOCAVERAGE = VOCBC + VOCMC + 2VOCCC

 4 

The VOC content of a four stage coating system shall be calculated according to 

the following formula:

VOCAVERAGE = VOCGC + VOCBC + VOCMC + 2VOCCC

5

Where:

VOCAVERAGE = The average of the VOC content, as applied, and 

used to determine compliance with the standards in Section 

301 of this Rule.

VOCGC = The VOC content, as applied, of a 

pigmented groundcoat or tinted primer sealer.

VOCBC = The VOC content, as applied, of a 

pigmented basecoat.

VOCMC = The VOC content, as applied, of a 

translucent midcoat.

2VOCCC = The VOC content, as applied, of a 

transparent clearcoat.

607 TRANSFER EFFICIENCY: Transfer efficiency as required by Section 302.3 of 

this Rule shall be determined in accordance with the SCAQMD method "Spray 

Equipment Transfer Efficiency Test Procedure for Equipment User,@ May 24, 

1989.

608 HVLP EQUIVALENCY: Spray equipment HVLP equivalency shall be 

determined by using South Coast Air Quality Management District AGuidelines 

for Demonstrating Equivalency with District Approved Transfer Efficient Spray 

Guns@ September 26, 2002.

6089 CAPTURE EFFICIENCY: The capture efficiency of a VOC emission control 

system=s collection device shall be determined according to EPA=s AGuidelines 

for Determining Capture Efficiency,@ January 9, 1995 and 40 CFR 51, Appendix 

M, Methods 204-204F, as applicable.

6109 CONTROL EFFICIENCY: The control efficiency of a VOC emission control 
system=s collection device shall be determined by using EPA Methods 2, 2A, or 

2D for measuring flow rates and EPA Method 25, 25A, or 25B for measuring 

total gaseous organic concentrations at the inlet and outlet of the control device. 

EPA Method 18 or CARB Method 422 shall be used to determine the emissions 

of exempt compounds.

6101 OVERALL CAPTURE AND CONTROL EFFICIENCY: For VOC emission 

control systems that consist of a single VOC emission control device, the overall 

capture and control efficiency shall be calculated by using the following equation: 

CEoverall = [CEcapture x CEcontrol] / 100% 

Where: CEoverall = Overall Capture and Control 

Efficiency

CEcapture = Capture Efficiency of the collection 

device*

CEcontrol = Control Efficiency of the collection 

device**

*As determined in Section 6089 

**As determined in Section 6109

6112 IRIDESCENT PARTICLES IN METALLIC/IRIDESCENT TOPCOAT:

Iridescent particles in metallic/iridescent topcoat as defined, in Section 21924 of 

this Rule shall be determined by the SCAQMD Method 318 "Determination of 

Weight Percent Elemental Metal in Coatings by x-Ray Diffraction.@

6123 ACID CONCENTRATION IN PRETREATMENT WASH PRIMER: Acid 

concentration in pretreatment wash primer coating as defined in Section 2230 of 

this Rule shall be determined by using ASTM D1613-06 AStandard Test Method 

for Acidity in Volatile Solvents and Chemical Intermediates Used in Paint, 

Varnish, Lacquer, and Related Products@.
ATTACHMENT B

NOTICE OF EXEMPTION FROM CEQA GUIDELINES
Notice of Exemption

To: G Office of Planning and Research

1400 Tenth Street., Room 121

Sacramento, CA 95814

G County Clerk : County Clerk

County of Yolo Solano 

County

625 Court Street Room 105 675 Texas Street, Ste. 1900

Woodland, CA 95695 Fairfield, CA 94533

From: Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

Project Title: Revision of Rule 2.26, Motor Vehicle and Mobile Equipment Coating 

Operations

Project Location: Yolo-Solano Air Quality Management District

Project description: The Yolo-Solano Air Quality Management District (District) is proposing to amend Rule 

2.26, Motor Vehicle and Mobile Equipment Coating Operations to incorporate the 

California Air Resources Board Suggested Control Measure for Automotive Coatings. 

Adopting the control measures will limit emissions of volatile organic compound (VOCs) 

from automotive coating operations.

Name of Public Agency Approving Project: Yolo-Solano Air Quality Management 

District

Name of Person or Agency Carrying Out Project: Yolo-Solano Air Quality Management 

District

Exempt Status:

G Ministerial

G Emergency Project

: Categorical Exemption (CEQA Guidelines Section 15308, Action by Regulatory Agency for 

Protection of the Environment)

G Statutory Exemption

Reason why project is exempt: The revision of Rule 2.26 is an action taken to protect the environment and is 

therefore exempt from CEQA because it constitutes a Class 8 categorical 

exemption pursuant to CEQA Guidelines 15308.

Lead Agency Contact Person: Mat Ehrhardt, Air Pollution Control Officer

Telephone Number: (530) 757-3650

Signature: Date: Title: 
Notice of Exemption

To: G Office of Planning and Research

1400 Tenth Street., Room 121

Sacramento, CA 95814

: County Clerk G County Clerk

County of Yolo Solano 

County

625 Court Street Room 105 675 Texas Street, Ste. 1900

Woodland, CA 95695 Fairfield, CA 94533

From: Yolo-Solano Air Quality Management District

1947 Galileo Court, Suite 103

Davis, CA 95618

Project Title: Revision of Rule 2.26, Motor Vehicle and Mobile Equipment Coating 

Operations

Project Location: Yolo-Solano Air Quality Management District

Project description: The Yolo-Solano Air Quality Management District (District) is proposing to amend Rule 

2.26, Motor Vehicle and Mobile Equipment Coating Operations to incorporate the 

California Air Resources Board Suggested Control Measure for Automotive Coatings. 

Adopting the control measures will limit emissions of volatile organic compound (VOCs) 

from automotive coating operations.

Name of Public Agency Approving Project: Yolo-Solano Air Quality Management 

District

Name of Person or Agency Carrying Out Project: Yolo-Solano Air Quality Management 

District

Exempt Status:

G Ministerial

G Emergency Project

: Categorical Exemption (CEQA Guidelines Section 15308, Action by Regulatory Agency for 

Protection of the Environment)

G Statutory Exemption

Reason why project is exempt: The revision of Rule 2.26 is an action taken to protect the environment and is 

therefore exempt from CEQA because it constitutes a Class 8 categorical 

exemption pursuant to CEQA Guidelines 15308.

Lead Agency Contact Person: Mat Ehrhardt, Air Pollution Control Officer

Telephone Number: (530) 757-3650

Signature: Date: Title: 
ATTACHMENT C

RESOLUTION NO. 08-12
RESOLUTION NO. 08-12

RESOLUTION ADOPTING YOLO-SOLANO AIR QUALITY MANAGEMENT DISTRICT 

RULES 2.26, MOTOR VEHICLE AND MOBILE EQUIPMENT COATING OPERATIONS

WHEREAS, California Health and Safety Code section 40702 provides that an air 

quality management district shall adopt rules and regulations, and do such acts as may be 

necessary or proper to execute the powers and duties granted to, and imposed upon, the district 

by Division 26 of the Health and Safety Code; and

WHEREAS, Health and Safety Code section 40727 provides that before adopting, 

amending, or repealing a rule or regulation, a district board shall make findings of necessity, 

authority, clarity, consistency, nonduplication, and reference, based upon information developed 

pursuant to section 40727.2, information in the rulemaking record maintained pursuant to section 

40728, and relevant information presented at the public hearing required by section 40725; and

WHEREAS, section 15308 of the California Environmental Quality Act (CEQA) 

Guidelines provides that actions taken by regulatory agencies as authorized by state law to assure 

the maintenance, restoration, or enhancement of the environment where the regulatory process 

involves procedures for protection of the environment, are categorically exempt from CEQA 

review (Class 8 Categorical Exemption); and

WHEREAS, California Health and Safety Code sections 39002 and 4000 provides that 

an air quality management district shall have the responsibility to control air pollution from all 

sources other than vehicular sources; and

WHEREAS, the purpose of adopting District Rule 2.26 is being proposed to meet the 

requirements of Health and Safety Code sections 40914 and 40920.

NOW, THEREFORE, BE IT RESOLVED that the Board of Directors of the 

Yolo-Solano Air Quality Management District hereby finds, authorizes, directs and declares as 

follows:

1. The Board of Directors has considered and hereby adopts by reference the staff 

report prepared in this matter.

2. The Board of Directors makes the following findings pursuant to Health and 

Safety Code section 40727:

a. Necessity: Information in the District=s rulemaking record maintained 
pursuant to Health and Safety Code section 40728 demonstrates a need for 

adopting Rule 2.26;

b. Authority: Health and Safety Code section 40702 permits the District to 

adopt Rule 2.26;

c. Clarity: District Rule 2.26, as proposed is written so that its meaning can 

be easily understood by the persons directly affected by it;

d. Consistency: District Rule 2.26, as proposed is in harmony with, and not 

in conflict with or contradictory to, existing statutes, court decisions, or 

state or federal regulations;

e. Nonduplication: District Rule 2.26, as proposed does not impose the same 

requirements as an existing state or federal regulation;

f. Reference: District Rule 2.26 is consistent with provisions of the Clean 

Air Act.

3. The Board of Directors finds that the District has complied with the procedural 

requirements set forth in Chapters 6 and 6.5 of Part 3 of Division 26 of the Health 

and Safety Code.

4. The Board of Directors finds that adopting District Rule 2.26 is an action taken by 

a regulatory agency as authorized by state law to assure the maintenance, 

restoration, or enhancement of the environment where the regulatory process 

involves procedures for protection of the environment, and is therefore 

categorically exempt from CEQA review as a Class 8 Categorical Exemption.

5. The Board of Directors hereby adopts District Rule 2.26, Motor Vehicle and 

Mobile Coating Operations as set forth in Exhibit 1 (Attachment A of the Staff 

Report), which is attached and incorporated by reference. The amendment is 

effective Decmber 10, 2008.

PASSED AND ADOPTED by the Board of Directors of the Yolo-Solano Air Quality 

Management District this 10th day of December, 2008, by the following vote:

Ayes:

Noes:

Absent:

Abstain:

________________________________
John Vasquez, Chair

Board of Directors

Yolo-Solano Air Quality Management 

District

Attest: Approved as to Form:

__________________________ ______________________________ 

Kay Mahorney, Clerk Hope Welton, District Counsel

Board of Directors

G:\ENGINEER\WPDATA\RULES\Rule2.26\2008 Dec\Rule 2.26 Final Staff Report2.wpd
ATTACHMENT D

WRITTEN COMMENTS RECEIVED
United States Environmental Protection Agency

Region IX

75 Hawthorne Street

San Francisco, CA 94105-3901

November 18, 2008

Transmittal of EPA Rule Review Comments

To: 

Susan McLaughlin, Yolo-Solano Air Quality Management District 

smclaughlin@ysaqmd.org

Mike Guzzetta, California Air Resources Board

mguzzett@arb.ca.gov

From: 

Andrew steckel, Rulemaking Office Chief

steckel.andrew@epa.gov

Re: 

Rule 2.26, Motor Vehicle and Mobile Equipment Coating Operations, October 

27, 2008 Version

We are providing comments based on our preliminary review of the draft 

rule identified above. In general, we note the forty-two tons per year of 

emission reductions attributed to the proposed changes in the District's 

staff report and commend and support the District's efforts to obtain 

these additional reductions by adopting the more stringent limits in the 

CARB's Suggested Control Measure (SCM) for Automotive Coatings. Unless 

otherwise indicated, paragraph numbers refer to the draft rule referenced 

above. Please direct any questions about our comments to me at (415) 

947-4115 or to Sona Chilingaryan at (415) 972-3368.

Section 306, Specialty Coatings, has been crossed out in the draft rule. 

In addition to specifying an 840 g/l limit for specialty coatings, this 

section includes a requirement for the use of all specialty coatings 

except antiglare/safety coatings to not exceed 5% of all coatings applied 

on a monthly basis and also clarifies that the application of topcoats 

with a specialty coating used as an additive shall be subject to the 420 

g/L topcoat limit in Section 301.2. In order to avoid a potential SIP 

relaxation issue, please change rule language to require that both of 

these requirements remain in effect until the more stringent limits in 

Section 302 apply effective July 1, 2009. We do not believe that these two 

requirements in Section 306 being removed pose a SIP relaxation issue once 

the lower limits become effective on July 1, 2009. 

In order to further align rule language with the SCM and to clarify which 

test methods are applicable, we recommend referencing Section 611, Overall 

Capture and Control Efficiency, in Section 305, Emission Control Systems. 

In order to further align rule language with the SCM and to clarify rule 

requirements, we recommend inserting the following phrase from Section 4.6 

of the SCM in Section 402 of the rule: "The requirements of this Section 
shall apply to all written or oral contracts, including, but not limited 

to, job orders, under the terms of which any coating or solvent that is 

subject to the provisions of this rule is to be used or applied." 

We understand that the District will be correcting the reference in 

Section 503.5 from Section 112 to Section 111. 

In order to further align rule requirements with the SCM and to strengthen 

the rule, we recommend changing the requirement in Section 505 to maintain 

records for a period of two years to a period of three years.