AVAQMD Rule 1113 C-1

Final Staff Report, 07/18/2013

Appendix “C”

Public Comments and Responses

1. Email from Nancy Adams (CARB), March 6, 2013. Subject: Antelope Valley 

AQMD Rule 1113.

2. Letter from American Coatings Association, May 3, 2013, RE: Rule 1113 

Architectural and Industrial Maintenance (AIM) Coatings; Proposed Amendments; 

ACA Comments.

3. Email from Ed Stewart (LACSD), May 6, 2013, Subject: LACSD Comments on 

Proposed Amendment to AVAQMD Rule 1113-Architectural Coatings.

4. Email from American Coatings Association, May 20, 2013, Tim Serie, Esq., RE: 

Rule 1113 Architectural and Industrial Maintenance (AIM) Coatings; Proposed 

Amendments; ACA Comments-Additional Comments
C-2 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

This page intentionally left blank.
AVAQMD Rule 1113

C-3

Final Staff Report, 07/18/2013
C

-4 AVAQMD Rule 1113

Final Staff Report, 07/18/2013
AVAQMD Rule 1113

C-5

Final Staff Report, 07/18/2013
C-6 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

District Response to CARB Email dated 3/6/13

1. (B)(4) Test method referenced has been changed.

2. (B)(44) Sub-section reference has been changed.

3. (B)(49) Definition updated to align with SCM.

4. (B)(52) & (B)(53) The test method for these categories is not referenced in section 

(G). The test method has been left in the definitions because these categories will be 

eliminated.

5. (B)(68) & (B)(69) Definition for Swimming Pool Repair and Maintenance Coating 

has been eliminated.

6. (B)(73) Subsection referenced has been corrected.

7. (B)(79) A definition has been incorporated into Equation 1 and Equation 2 of section 

(G)(1)(a) for clarification.

8. (B)(83) Definition updated as suggested for clarity.

9. The table was reformatted for clarity to include existing categories and new exempt 

categories per the SCM.

10. The dates will match.

11. (D)(1)(e)(i) Original rule language retained. CARB comment to MDAQMD on 

07/25/2011 also recommended that the working not be stricken. This language is 

retained in the 04/23/2012 MDAQMD Rule 1113 as well as SJVUAPCD Rule 4601 

as amended 12/17/2009. Although not consistent with SCM language, it does not 

appear to be in conflict with SCM language.

12. (G)(1)(a) Dates and place holders have been removed.

13. (G)(2)(c) Referenced test method section has been changed.

14. (G)(5)(a) ASTM designation was corrected to reflect SCM

15. Corrected (G)(5)(k) to reflect coating category Metallic Pigmented Coating.

16. (G)(5)(t) This test method was not eliminated. It needs to remain for the overlap 

period.

17. Footnote was added, and changed from f to a as other designated footnotes were 

eliminated.
AVAQMD Rule 1113

C-7

Final Staff Report, 07/18/2013
C

-8 AVAQMD Rule 1113

Final Staff Report, 07/18/2013
AVAQMD Rule 1113

C-9

Final Staff Report, 07/18/2013
C-10 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

District Response to ACA Letter dated 05/03/2013

1. The AVAQMD is proposing an effective date for implementation of one year from 

date of amendment.

2. The red-line discussion is adequately describes effective dates. In addition, Table 1 

includes and effective date for new categories.

3. (B)(27) The language used for this coating is consistent with the SCM and will be 

retained.

4. (B)(41)Suggested language has been included. See new rule draft.

5. (B)(60)Suggested language has been included. See new rule draft.

6. (B)(66) Suggested language has been included. See new rule draft.

7. Definition (B) (79) for VOC Content has been modified for clarification, and 

(G)(1)(a)(i) and (G)(1)(a)(ii) have been more clearly identified.

8. Section (C)(3)(a) was added for clarity. While it was not specific language from the 

SCM, it is not in conflict with the SCM.

9. Provided clarification by removing subsection in (D)(1)(c)(iii).

10. (D)(h)(i) Suggested language has been included. See new rule draft. (D)(h)(ii) 

ASTM reference updated.

11. (E)(1)(a) Suggested language has been included. See new rule draft.

12. (G)(1)(a)(i) & (G)(1)(a)(ii) Suggested language has been included. See new rule 

draft.

13. (G)(5)(t) ASTM reference updated.
AVAQMD Rule 1113 C-11

Final Staff Report, 07/18/2013

1

2

3
C-12 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

District Response to Email from LACSD, dated 05/06/2013

1. The AVAQMD’s portion of the estimated 15.2 tons per day of VOCs is 0.33 tons per day 

as reflected in the statewide emissions inventory as estimated by CARB. Please see 

section (VI)(B) of the staff report.

2. SCAQMD limit for Driveway Sealers has been updated to 50 ppm in “Table 1 

Comparison of Coating Limits”. SCAQMD VOC limit for Low Solids Coating is correct 

at 120 ppm

3. .The definition of Rust Preventative Coating (B)(58) has been updated to reflect the 

SCM. The SCM removed the restriction for non-industrial use, so therefore we cannot 

add that language as it would conflict with the definition.
AVAQMD Rule 1113 C-13

Final Staff Report, 07/18/2013

1
C-14 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

2

3
AVAQMD Rule 1113 C-15

Final Staff Report, 07/18/2013

District Response to email from ACA dated 05/20/2013

1. We reorganized (C)(2) for clarification that fulfills the intent of the comment. Strike out 

language was inadvertently removed, replaced as noted in comment.

2. The proposed rule language is consistent with the SCM, and has the same intent as 

SJVUAPCD language. Existing proposed language to be retained.

3. Original rule language retained pursuant to comment. CARB comment to MDAQMD on 

07/25/2011 also recommended that the working not be stricken. This language is retained in the 

04/23/2012 MDAQMD Rule 1113 as well as SJVUAPCD Rule 4601 as amended 12/17/2009.
C-16 AVAQMD Rule 1113

Final Staff Report, 07/18/2013

This page intentionally left blank.