From: Bruce Springsteen

To: Molly Johnson

Subject: FW: AIM Rule

Date: Tuesday, October 19, 2010 2:23:52 PM

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District

3091 County Center Drive, Suite 240

Auburn, CA 95603

Direct: (530) 745-2337

Main Office: (530) 745-2330 

Fax: (530) 745-2373

E-Mail: bsprings@placer.ca.gov

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and destroy all copies of the communication.

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Wednesday, June 16, 2010 7:42 AM

To: Bruce Springsteen

Subject: AIM Rule

Bruce - I have been contacting the CA Air Districts about their adoption of the 2007 SCM -

can you let me know if your considering adopting this year. Also and could you please add

me to your AIM stakeholder list. Finally, the coatings industry is under constant pressure to

reformulate products to lower and lower VOC content. As a result there is a critical and

urgent need for safe, effective and affordable exempt solvents and coating formulators need

all available tools to formulate both lower VOC and reactivity coatings. The American

Coatings Association requests that TBAC, Dimethyl Carbonate (DMC) and Propylene

Carbonate be added to the list of exempt compounds in your District. These compounds

were exempted by the US EPA based on their negligible contribution to tropospheric ozone

formation. 

Best regards,

David Darling, P.E.

Director, Environmental Affairs

American Coatings Association

1500 Rhode Island Ave., NW

Washington, DC 20005

202-462-6272

202-719-3689 (direct)

ddarling@paint.org
From: Bruce Springsteen

To: Molly Johnson

Subject: FW: ACA Comments

Date: Tuesday, October 19, 2010 2:20:16 PM

Attachments: Placer82010comments.pdf

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District

3091 County Center Drive, Suite 240

Auburn, CA 95603

Direct: (530) 745-2337

Main Office: (530) 745-2330 

Fax: (530) 745-2373

E-Mail: bsprings@placer.ca.gov

=======================================

CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or

legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized

interception, review, use or disclosure is prohibited and may violate applicable laws including the

Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender

and destroy all copies of the communication.

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Thursday, August 05, 2010 10:56 AM

To: Bruce Springsteen; Nyarady, Jim@ARB

Subject: ACA Comments

Bruce/Jim - please find attached ACA comments on Rule 218 - I'll mention these at the workshop on

Monday

thanks

David Darling, P.E.

Director, Environmental Affairs

American Coatings Association

202-462-6272

202-719-3689 (direct)

ddarling@paint.org




1

Molly Johnson

From: Bruce Springsteen

Sent: Thursday, August 12, 2010 8:07 AM

To: Todd Nishikawa; Molly Johnson

Subject: FW: Additional comments 

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District 

3091 County Center Drive, Suite 240 

Auburn, CA 95603 

Direct: (530) 745-2337 

Main Office: (530) 745-2330 

Fax: (530) 745-2373 

E-Mail: bsprings@placer.ca.gov

=======================================

CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged 

information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is 

prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the 

intended recipient, please contact the sender and destroy all copies of the communication.

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Wednesday, August 11, 2010 7:24 AM 

To: Bruce Springsteen 

Cc: Jim Nyarady 

Subject: Additional comments 

Bruce - it was a pleasure speaking with you at the workshop - here are the two additional comments I promised:

 

1. Early compliance option - several of the new niche categories are needed now - so we were able to convince 

the other Air Districts to allow the sale of products prior to the compliance date as long as the products met the 

new limits - here is the language from the San Joaquin rule: 

 

5.8 Prior to January 1, 2011, any coating that meets a definition in Section 3.0 for a coating category listed in 

the Table of Standards 2 and complies with the applicable VOC limit in the Table of Standards 2 and with 

Sections 5.2 and 6.1 (including those provision of Section 6.1 otherwise effective on January 1, 2011) shall be 

considered in compliance with this rule. 

2. Specialty Primer labeling transition language - since the Specialty primer labeling requirements change - 

we were able to convince the other Air Districts to include transitional language in the rules - here is language 

from San Joaquin:

6.1.8 Specialty Primers, Sealers and Undercoaters: Effective until December 31, 2010, the labels of all specialty

primers, sealers and undercoaters shall prominently display one or more of the descriptions listed in

Section 6.1.8.1 through 6.1.8.5. Effective on and after January 1, 2011, the labels of all specialty primers,

sealers, and undercoaters shall prominently display one or more of the descriptions listed in Sections

6.1.8.1 through 6.1.8.3. On and after January 1, 2011, Sections 6.1.8.4 and 6.1.8.5 will be no longer

effective. 

6.1.8.1 For fire-damaged substrates. 
2

6.1.8.2 For smoke-damaged substrates. 

6.1.8.3 For water-damaged substrates. 

6.1.8.4 For excessively chalky substrates. 

 6.1.8.5 For blocking stains 

 

Please let me know if you have any questions, 

 

David Darling, P.E.

Director, Environmental Affairs

American Coatings Association 

202-462-6272

202-719-3689 (direct)

ddarling@paint.org

 
From: Bruce Springsteen

To: Todd Nishikawa; Molly Johnson

Subject: FW: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

Date: Tuesday, October 12, 2010 1:02:52 PM

These are the other last minute Rule 218 changes requested by the National Coating Association. 

Bruce

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Thursday, October 07, 2010 4:53 AM

To: Bruce Springsteen

Cc: Jim Nyarady

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural

Coating

Bruce - I did receive the following minor comments, I am waiting for another member - I hope to hear

back tomorrow

1. Transitional paragraph after the table of standards (for clarity): 

Effective July 1, 2011, the following coating categories in the Table of Standards 1 are

eliminated, and these coatings will be subject to the VOC limit for the applicable

category in the Table of Standards 2, except as provided in Sections 302 and 303:

2. Also, it seems that Rust Preventative Coatings and Specialty Primers are unregulated from July 1,

2011 to January 1, 2012 -- no limit is given in the Table 2 column effective July 1, just the final limit in

the column effective January 1. The limit in the previous Table 1 would no longer apply, since that

table is labeled "Effective until July 1, 2011." This can be corrected by inserting the current limits into

the Table 2 column effective July 1, 2011. 

3. Section 303 -- Sell-through of Coatings -- should be revised to delete the parenthetic reference to

Table of Standards 1 (because "standards in effect at the time the coating was manufactured" may be

found either in Table 1 or in Table 2).

thanks

David 

From: Bruce Springsteen [mailto:BSprings@placer.ca.gov] 

Sent: Tuesday, October 05, 2010 4:40 PM

To: Dave Darling

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural

Coating

Dave: Final proposed amended rule and support document attached, please let me know as soon as you can

with any issues. Thanks. Bruce

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District

3091 County Center Drive, Suite 240

Auburn, CA 95603
Direct: (530) 745-2337

Main Office: (530) 745-2330 

Fax: (530) 745-2373

E-Mail: bsprings@placer.ca.gov

=======================================

CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally

privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use

or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act.

If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Tuesday, October 05, 2010 10:31 AM

To: Bruce Springsteen

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

thank you

From: Bruce Springsteen [mailto:BSprings@placer.ca.gov] 

Sent: Tuesday, October 05, 2010 1:31 PM

To: Dave Darling

Cc: Jim Nyarady

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

Dave: Sorry for the delay in response. Yes, we have changed the compliance dates as you requested. We are

finalizing the rule, I will forward you it as soon as it is ready. Bruce

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District

3091 County Center Drive, Suite 240

Auburn, CA 95603

Direct: (530) 745-2337

Main Office: (530) 745-2330 

Fax: (530) 745-2373

E-Mail: bsprings@placer.ca.gov

=======================================

CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally

privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use

or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act.

If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Dave Darling [mailto:ddarling@paint.org] 

Sent: Monday, October 04, 2010 7:25 AM

To: Bruce Springsteen

Cc: Jim Nyarady

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

Bruce - just checking in on the AIM rule - last time we communicated your were going to set the compliance date
at 7/1/11 for all categories except Primer, Sealer, Undercoaters (PSUs) and Rust Preventatives - which were going

to be 1/1/2012 - is this still the case? Is the Board package available for review?

thanks

David Darling, P.E.

Senior Director, Environmental Affairs

American Coatings Association

202-462-6272

202-719-3689 (direct)

ddarling@paint.org

From: Dave Darling 

Sent: Thursday, September 02, 2010 9:54 AM

To: 'Bruce Springsteen'

Cc: Jim Nyarady

Subject: RE: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

Bruce - I sent this out to my group - I asked them to get back to me by Wednesday of next

week - so far the only comment that came back was that the Rust Preventative and SPSU

limits kick in on July 1, 2011, 6 months before Jan 1, 2012 of the other Air District rules -

Bay Area, San Joaquin, Kern, Ventura and Imperial - I should have realized this at the

meeting. Could I please ask that the rust Preventative and SPSU categories limits be pushed

to 1/1/2012 to be consistent with the other Air Districts? This could be accomplished by

adding another column to Table of Standards 2 - I am sorry for any confusion

thanks 

David Darling

From: Bruce Springsteen [mailto:BSprings@placer.ca.gov] 

Sent: Monday, August 30, 2010 7:45 PM

To: Dave Darling

Subject: Placer County Air Pollution Control District -- Amendments to Rule 218 Architectural Coating

David: Thank you for participating in the District rulemaking workshop to amendment Rule 218, held a couple of

weeks ago. Find attached a revised rule based on comments received at the workshop. Please review and

provide additional comment through e-mail or telephone. Could you also please distribute to your workgroup

members too, as appropriate. Thank you ! Regards,

Bruce Springsteen

Associate Engineer

Placer County Air Pollution Control District

3091 County Center Drive, Suite 240

Auburn, CA 95603

Direct: (530) 745-2337

Main Office: (530) 745-2330 

Fax: (530) 745-2373
E-Mail: bsprings@placer.ca.gov

=======================================

CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally

privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use

or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act.

If you are not the intended recipient, please contact the sender and destroy all copies of the communication.
From: Bruce Springsteen

To: Molly Johnson

Subject: FW: Placer County VOC Comments

Date: Friday, October 15, 2010 11:09:57 AM

Attachments: Letter to the Placer County--v2.pdf

Final Rule 218 public comment.

From: Baker, James [mailto:JBaker@kellencompany.com] 

Sent: Thursday, October 14, 2010 1:02 PM

To: Bruce Springsteen

Subject: Placer County VOC Comments

Dear Mr. Springsteen,

Sorry for the last minute comments but here is the Roof Coatings Manufacturers Association

comments regarding the adoption of the 2007 SCM. Please confirm receipt—I can be reached

at 202-352-3867.

Thank you,

Jim

James (Jim) Baker

Director of Industry Affairs

Roof Coatings Manufacturers Association

750 National Press Building

529 14th Street, NW

Washington, DC 20045

Direct: 202.207.1114

Fax: 202.223.9741

E-mail: jbaker@kellencompany.com

Web: www.roofcoatings.org

<<Letter to the Placer County--v2.pdf>>
RCMA Comment Letter 

May 19, 2010 

Page 1 of 5 

May 11, 2010 

Thomas J. Christofk 

Air Pollution Control Officer 

3091 County Center Dr., Suite 240 

DeWitt Center, Auburn, CA 95603. 

Mr. Bruce Springsteen 

Associate Engineer 

3091 County Center Dr., Suite 240 

DeWitt Center, Auburn, CA 95603. 

Dear Mssrs. Christofk and Springsteen; 

The Roof Coatings Manufacturers Association (RCMA) is the North American trade association representing the 

producers of bituminous and non-bituminous (acrylic and elastomeric) roof coatings and cements, which are used in 

new and resurfacing roofing systems, including repair and maintenance, for the primary purposes of preventing water 

penetration, protecting the substrate from ultraviolet radiation degradation and/or reflecting solar radiation (infrared 

heat) away from the surface. 

Thank you for allowing the RCMA the opportunity to present its concerns about Placer County’s adoption of the 

2007 California Air Resources Board Suggested Control Measures (CARB SCM). The 2007 SCM limits are simply 

too restrictive at 50 g/L for both bituminous roof coatings and roof coatings; since this level is tantamount to 

converting all of these products over to water based emulsions. 

In an effort to assist Placer County with its emission reduction strategy, RCMA requests that the limits for the 

categories effecting roof coatings be adjusted to the following levels, which our members feel that they can achieve 

with the current technology available to them and without compromising the products’ durability and waterproofing 

capabilities. 

RCMA would like to propose the following: 

Category 2004 SCM 2007 SCM RCMA Recommends

Aluminum Previously Metallic 

Pigmented 500 

400 g/L 450 g/L

Bituminous Roof Coatings 300 g/L 50 g/L 270 g/L

Roof Coatings 250 g/L 50 g/L 250 g/L

These proposed VOC limits allow for the reformulation of RCMA member products without the use of exempt 

solvents; take into account Placer County’s climatic conditions; and provide for the fair and equitable treatment of our 

products in comparison to other waterproofing product categories listed in the SCM. 

RCMA objects to proposals for changing solvents. 

1. RCMA does not recommend the use of Tert Butyl Acetate as a replacement solvent for 

reformulation in Solvent Borne Bituminous Roof Coatings.
RCMA Comment Letter 

May 19, 2010 

Page 2 of 5 

Tert Butyl Acetate (TBAc) is not an option for reformulating conventional bituminous roof coatings for two reasons: 

1.) it is not an effective solvent for the bituminous resin binder in these coatings, and 2.) it is considered a "red label" 

(DOT Flammable Liquid). 

TBAc is a short (C6), polar solvent. It is not effective at reducing the viscosity of bitumens, which are blends of 

long- to very-long chain aliphatic oils and aromatic resins. 

More importantly, TBAc has a flash point of 4.4 oC (40 oF), essentially the same as that of 200 proof ethanol (roughly 

9 oC). This classifies TBAc, and any product made from TBAc, as a Flammable Liquid under the Department of 

Transportation regulations. Since almost all Fire Protection Associations and Building Codes use the DOT definitions 

as part of their regulations, this has severe consequences throughout the production and distribution chain, including: 

• Most manufacturers of roof coatings do not have facilities which are occupancy-rated for the storage and 

handling of flammable liquids. Obtaining a permit for this more restrictive occupancy may require 

extensive, and costly structural modifications as well as significant upgrades to the fire suppression systems. 

(As an extreme example, one manufacturer was told by their local fire code officials as a “going-in” position 

that they would have to rebuild their facility from scratch.) 

• Because the roof coatings would be reclassified as flammable liquids in containers, they would have to be 

transported as a higher class of hazardous material. The reformulation of solvent-based roof coatings, with a 

solvent such as TBAc would eliminate the Class 3, Combustible Liquid rating that roofing coatings are 

covered by and would void the current exemption provided for through DOT, which allows the shipment of 

most solvent-based roof coatings as non-hazardous combustible liquids. The reformulation and 

reclassification by DOT would increase costs for upgraded packaging and cartage several times those 

presently paid, which have not been accounted for by Placer County in its socio-economic impact. 

• Many distributors use warehouses that are not rated for Flammable Liquid occupancy. They would face 

similar building permit issues and substantial costs to upgrade their fire suppression systems, although 

probably less severe than what a manufacturer would face. 

• Many contractors are not experienced with or formally trained in the use of flammable liquids. Using such 

materials on a project generally requires a more restrictive (and more expensive) permit from the local 

building and fire officials, as well as ongoing training and upgraded equipment to meet OSHA requirements. 

2. RCMA does not recommend the reformulation of bituminous based coatings with other exempt 

solvents such as parachlorobenzotrifluoride (PCBTF). 

Acetone, like TBAc, is a very small, highly polar molecule. It has no effect on reducing the viscosity of asphalt. It 

also has an even lower flash point than TBAc and would raise the same red label regulatory problems. 

Many of the historical chlorinated exempt solvents, such as 1,1,1-trichloroethane, are good to very good solvents for 

asphalt products. However, these solvents are not generally available; production and/or new uses were banned 

because of their ozone-depletion reactivity. 

An exception to this is parachlorobenzotrifluoride (PCBTF), which was fairly recently exempted. PCBTF is a 

reasonably good solvent for bitumen, approximately as efficient as an equivalent volume of Rule 66 mineral spirits. 

However, the use of these type of exempt solvents is extremely costly for a product that has a relatively low cost. 

Further, many of these exempt solvents have a low flash point, which would threaten the Department of 

Transportation exemption for the cartage of roof coatings. 

Placer County Climatic Conditions 

Another concern that RCMA would like to address is that the due to Placer County’s extreme variation in elevations 

and precipitation/snow, water based roof coatings are being set up for failure as waterproofing agents due to their 

higher susceptibility for failure under these conditions. The Placer County Department of Public Works website 

http://www.placer.ca.gov/Departments/Works/SnowRemove.aspx indicates: 
RCMA Comment Letter 

May 19, 2010 

Page 3 of 5 

General Information

The elevation of Placer County ranges from near sea level to over 7,000 feet. The County maintains over 

1,100 miles of roadways. About 200 miles of these roads fall within expected “normal” snowfall areas on 

both sides of the Sierra Crest. Snowfall amounts in these areas range from less than 100 inches to over 500 

inches annually depending on location and elevation. 

FACTS:

1. Placer County has the highest average annual snowfall of any County in the lower 48 states.

2. In California, Placer County consistently ranks in the top 3, behind CALTRANS, for annual 

expenditures on snow removal – this includes all Cities and Counties! 

Higher VOC products allow for the application of roof coating products which are primarily designed and used as 

waterproofing and maintenance coatings in colder wetter climates. Additionally, these higher VOC products will 

afford the building the ability to better withstand the high snow loads and provide the ability to withstand ponding 

water. 

Unlike water based emulsions, solvent based products form a non-breathable, non-permeable film. They will not 

easily wash off if rain occurs soon after application, and most importantly they can better withstand freeze/thaw 

cycles without sacrificing performance. 

Solvent borne bituminous roof coatings and roof coatings are used for a variety of different purposes in California. 

While much of the roof inventory is compatible with water based roofing emulsions, there remains a fraction of roofs 

to which water based emulsions simply cannot be applied. There are a number of reasons for this, including 

chemical/material incompatibility of the substrate, the inability to perform adequate surface preparation, and roof 

slope. In addition, climate conditions (cool and damp) limit the curing and ultimately, functionality and performance 

of water based roofing emulsions. Finally, there are instances when unsuspected roof leaks are discovered where a 

water-based product cannot be used to effect repairs before the next rain or snowfall. 

RCMA believes that roofing emulsions have already displaced virtually all applications in California for which they 

are well suited, and that much of the residual 15% of users will be unable to successfully convert to emulsion-based 

products if solvent-borne products are banned from the marketplace. 

During the revision process, CARB staff acknowledged that climate differences have the ability to impact the 

application of water based emulsion roof coatings because of low to freezing temperatures, high relative humidity, 

and frequency of rain, dew, and/or snowfall. For example, an excerpt from the Chapter 5 Technical Assessment of 

Categories, Section 3 Bituminous Roof Coatings, Subsection 3 Coating Description reads: 

“...other parts of the country (e.g. Northeast and Midwest) are subject to colder or less temperate climates 

that may not permit the use of waterborne emulsions. Emulsion Bituminous Roof coatings can be adversely 

impacted by unexpected rain, heavy dew, thick fog, and extremely cold temperatures due to slower cure 

times compared to solvent borne coatings. Traditional solvent borne bituminous products may be beneficial 

in less temperate climates because they have the potential to adhere better and withstand sudden shifts in 

climate.” 

RCMA believes the same can be said regarding the variation that is found within the state of California. 

Fair and Equitable Treatment of Water-proofing Products 

RCMA’s proposed VOC limits for Bituminous Roof Coatings and Roof Coatings Categories above allow our coating 

products to be treated equitably compared with other waterproofing type products. RCMA has reviewed the proposed 

category definitions and believes that the aforementioned two product categories have a similar purpose; to protect a 

substrate or surface from water penetration. The primary purpose of any roof and/or roof coating is to form a 

monolithic membrane to protect the structure from water penetration. As support to this position, both Bituminous 

Roof Coatings and Roof Coatings, as defined below, have waterproofing as their primary function: 
RCMA Comment Letter 

May 19, 2010 

Page 4 of 5 

Bituminous Roof Coating: A coating which incorporates bitumens that is labeled and formulated exclusively for 

roofing “for the primary purpose of preventing water penetration.” (NOTE RCMA WOULD LIKE TO MODIFIY 

THE DEFINITION TO MORE ACCURATELY REFLECT THE PURPOSE.) 

Roof Coating: A non-bituminous coating labeled and formulated for application to roofs for the primary purpose of 

preventing water penetration, reflecting ultraviolet light, or reflecting solar radiation. 

The category definitions below are examples of products in the CARB SCM that exhibit a similar waterproofing 

purpose as our products and which have VOC limits comparable to RCMA’s proposal. 

Industrial 

Maintenance 

Coatings 

A high performance architectural coating, including primers, sealers, 

undercoaters, intermediate coats, and topcoats, formulated for 

application to substrates, including floors, exposed to one or more of 

the following extreme environmental conditions listed below in 

subsections 2.26.1 through 2.26.5 subsections 2.34.1 through 2.34.5., 

and labeled as specified in subsection 4.1.45: 

2.35.1. Immersion in water, wastewater, or chemical solutions

(aqueous and non-aqueous solutions), or chronic exposures of interior 

surfaces to moisture 

condensation; 

250 g/L

Swimming Pool 

Coatings 

A coating labeled and formulated to coat the interior of swimming 

pools and to resist swimming pool chemicals. Swimming pool 

coatings include coatings used for swimming pool repair and 

maintenance. 

340 g/L

Waterproofing 

Membrane 

 

A clear or opaque coating that is labeled and formulated for 

application to concrete and masonry surfaces to provide a seamless 

waterproofing membrane that prevents any penetration of liquid 

water into the substrate. Waterproofing Membranes are intended for 

the following waterproofing applications: below-grade surfaces, 

between concrete slabs, inside tunnels, inside concrete planters, and 

under flooring materials. Waterproofing Membranes must meet the 

following criteria: 

2.86.1. Coating must be applied in a single coat of at least 25 mils (at 

least 0.025 inch) dry film thickness; and 

2.86.2. Coatings must meet or exceed the requirements contained in 

ASTM C836- 06. (incorporated by reference in subsection 6.5.19). 

2.86.3. The Waterproofing Membrane category does not include 

topcoats that are included in the Concrete/Masonry Sealer category 

(e.g., parking deck topcoats, pedestrian deck topcoats, etc.). 

250 g/L

All of these products must be able to withstand contact with water and resist water penetration. Bituminous Roof 

Coatings and Roof Coatings must also withstand ponding water, snow loads/melts, rain and resist water penetration 

into the roofing system and thus, like the aforementioned categories, should be afforded a higher VOC limit. 

The RCMA proposed VOC limits would also help maintain and thousands of square feet of roofs, reducing tear-offs 

and disposal and landfill impacts. RCMA, Reflective Roof Coatings Institute (RRCI) and the National Roof 

Contractors Association (NRCA) stipulate that there are specific coatings for specific roofing systems and a need for 

both water-based and solvent based products. We have enclosed a chart from the NRCA Guide to Coating 

Application—it is a cursory chart to help the installer determine what type of coating is best for their roofing system. 

As an example, coal tar built-up roofs require specific bituminous coatings to remediate, maintain and extend the 

roof’s useful service life. Because these roof systems can have well over 30 years of field exposure on them, only 

solvent-borne bituminous coatings are effective at coating and rejuvenating these systems. Further, these roof 

systems are generally low or no slope in design and require coatings that are highly resistant to standing water. Water 

based roof coatings can not conform to these demands. 
RCMA Comment Letter 

May 19, 2010 

Page 5 of 5 

RCMA respectively requests Placer County incorporate the RCMA’s proposed VOC limits of: 

Aluminum 450 g/L 

Bituminous Roof Coatings 270 g/L 

Roof Coatings 250 g/L 

which allows for the reformulation of many of the RCMA member products without the significantly higher cost of 

exempt solvents and the ancillary costs associated with upgrading fire protection requirements of facilities, upgrading 

packaging and cartage requirements; provides equitable treatment of our waterproofing products in comparison to 

other regulated waterproofing products; and satisfies the need for a variety of coating products both water-borne and 

solvent-borne to meet the many types of roofing systems in the market place. 

Should Placer County not find these limits acceptable, RCMA would formally request that VOC limits for roofing 

coatings at the October 14, 2010 meeting and postpone the adoption until later this year in order to provide additional 

time to work on the roof coating categories. 

Should you have any questions please contact me at 202-207-1114 or via e-mail at jbaker@kellencompany.com. 

Regards, 

James Baker 

Director of Industry Affairs 

CC: Robert Brenk, Past President, Reflective Roof Coatings Institute 

David Darling, American Coatings Association 

Reed Hitchcock, Executive Director, RCMA 

Brock Landry, Venable LLP