Air Pollution Control Board

San Diego County Air Pollution Control District

AGENDA ITEM

Governing Body

GREG COX

First District

DIANNE JACOB

Second District

PAM SLATER-PRICE

Third District

RON ROBERTS

Fourth District

BILL HORN

Fifth District

Documentum Version 3.1

DATE: June 27, 2012 AP01

TO: Air Pollution Control Board

SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO 

RULE 67.11 – WOOD PRODUCTS COATING OPERATIONS, AND 

REPEAL OF RULE 67.11.1 – LARGE COATING OPERATIONS FOR 

WOOD PRODUCTS (DISTRICT: All)

SUMMARY: 

Overview

The Air Pollution Control Board (Board) is requested to adopt proposed amendments to 

Rule 67.11, to tighten limits on the amount of volatile organic compounds (VOCs) that 

can be present in coatings and cleaning solvents used in the finishing of new wood 

products. Affected industries are primarily cabinet, furniture, and window and door 

manufacturers. Residential non-commercial operations are not affected.

The application of wood coatings and cleaning solvents results in emissions of VOCs,

which contribute to the formation of ground-level ozone. Despite substantial air quality 

improvement over the past two decades, San Diego County does not yet attain all state 

and federal air quality standards for ozone. Consequently, rules to control VOC 

emissions are required to be updated to reflect the current state of control technology.

Rule 67.11 was last updated in 2002. Since then, the performance of lower-emitting 

coatings and cleaning materials used in the finishing of new wood products has 

improved considerably. The proposed tighter VOC limits are already in place 

throughout much of California, and compliant materials are readily available for similar 

prices as conventional materials. If adopted, the amendments will not take effect for 12 

months, allowing time for affected businesses to use and deplete their inventories of 

non-compliant materials and transition to the new standards. Refinish coatings, such as 

those used to restore antiques or other existing wood products, are not affected.

The Board is also requested to repeal outdated Rule 67.11.1, which was adopted in 

2002 and applies only to large-scale wood coating operations. The Rule 67.11.1 

requirements are duplicative of existing Rule 67.11 standards that took effect in 2005 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

- 2 -

for both larger and smaller operations. Consequently, Rule 67.11.1 is no longer needed.

Recommendation(s)

AIR POLLUTION CONTROL OFFICER

1. Find that the adoption of amendments to Rule 67.11 and repeal of Rule 67.11.1 are 

categorically exempt from the provisions of the California Environmental Quality 

Act pursuant to California Code of Regulations, Title 14, Section 15308, as an 

action taken to assure the protection of the environment, where the regulatory 

process involves procedures for protection of the environment, and pursuant to 

California Code of Regulations Title 14, Section 15061(b)(3), since it can be seen 

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

significant effect on the environment.

2. Adopt the resolution entitled RESOLUTION AMENDING RULE 67.11 – WOOD 

PRODUCTS COATING OPERATIONS, AND REPEALING RULE 67.11.1 –

LARGE COATING OPERATIONS FOR WOOD PRODUCTS, OF 

REGULATION IV OF THE RULES AND REGULATIONS OF THE SAN DIEGO 

COUNTY AIR POLLUTION CONTROL DISTRICT.

Fiscal Impact

Funds for this request are included in the Fiscal Year 2011-12 Operational Plan in the 

Air Pollution Control District (District). If adopted, the proposed amendments to Rule

67.11 will be implemented and enforced with existing District staff and will not have a 

significant fiscal impact on the District.

Business Impact Statement

Adopting the proposed amendments to Rule 67.11 will not significantly impact the 

business community. The proposed wood coatings and cleaning materials with a lower 

content of VOCs are widely available and priced similarly to their conventional 

counterparts. Many wood coating operations already comply with the proposed 

amendments due to the market availability of compliant materials. 

If adopted, the amendments will not take effect for 12 months, thus allowing time for 

affected businesses to use and deplete their inventories of non-compliant materials and 

transition to the new standards. Furthermore, the amendments allow each coating 

operation to use up to 20 gallons per year of non-compliant coatings. This allowance 

addresses future situations where a coating with a higher content of VOCs may be 

preferred to achieve a desired finish.

District staff conducted substantial outreach to affected facilities during development of 

the proposed rule amendments, including conducting a public workshop and 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

- 3 -

participating in an industry symposium, and is not aware of any significant concerns

with the proposal. If the rule amendments are adopted by the Board, District staff will 

issue an advisory to further inform potentially affected sources of the new requirements 

and their future effective date.

Advisory Board Statement

At its meeting on November 1, 2011, with all members present, the Air Pollution 

Control District Advisory Committee voted unanimously in support of the District’s 

recommendations.

BACKGROUND:

Concentrations of ground-level ozone have been cut nearly in half in San Diego County over the 

past 25 years even while the region's population and motor vehicle use have substantially grown, 

clearly showing that air pollution control measures are working. Notwithstanding this air quality 

improvement, the region does not currently meet all National and State Ambient Air Quality 

Standards for ozone and therefore is classified as an ozone nonattainment area. National and 

state laws therefore require the District to periodically update its rules pertaining to emissions of 

ozone precursors – VOCs and oxides of nitrogen – to reflect the current state of air pollution 

control technology.

Amendments to Rule 67.11

Existing Rule 67.11 regulates VOC emissions resulting from the coating of wood products and 

associated cleaning operations. The rule was first adopted in 1989 and last revised in 2002. The 

primary objectives in amending Rule 67.11 are to ensure ongoing compliance with federal 

requirements to implement current Reasonably Available Control Technology (RACT) and state 

requirements to adopt all feasible measures applicable to the wood products coating industry. 

The proposed amendments reflect the current market availability of coating and cleaning 

materials with lower VOC content and satisfactory performance. Many air districts throughout 

California are already implementing the tighter VOC limits for wood coating operations in their 

regions.

The proposed amendments to Rule 67.11 lower the VOC content limit for five types of coatings

applied to new wood products: fillers, high-solid stains, multi-colored coatings, sealers, and lowsolids coatings. The proposal does not affect refinish coatings, such as those used to restore 

antiques or other existing wood products that were previously coated. 

The proposed rule amendments also require surface preparation and equipment cleaning 

materials to comply with a VOC content limit of 25 grams per liter. In addition, the small usage 

exemption limit for stationary sources will be reduced from 500 gallons to 20 gallons of coatings 

per consecutive 12 months. These amendments are comparable to existing requirements 

throughout much of California.
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

- 4 -

The proposed rule amendments also update the test methods for determining the VOC content 

and exempt compounds in coatings and cleaning materials. In addition, the amendments include 

updated definitions and record keeping requirements.

There are 125 permitted facilities in San Diego County that are currently subject to Rule 67.11, 

based on data collected at the time of the public workshop on the proposed rule amendments. 

The total VOC emissions from permitted wood coating operations in the County are 

approximately 157 tons per year. The rule amendments will reduce VOC emissions from these 

operations by approximately 19 tons per year, which is a 12% reduction.

If adopted by the Board, amended Rule 67.11 will be submitted through the California Air 

Resources Board to the U.S. Environmental Protection Agency for approval and inclusion into 

the State Implementation Plan (SIP). 

Repeal of Rule 67.11.1

Rule 67.11.1 was adopted in 2002 to implement federal requirements applying at that time only 

to large-scale wood coating operations. Specifically, the rule applies to wood coating facilities 

that emit 25 tons or more of VOCs per year. There are currently no such facilities in San Diego 

County. 

At the time of its adoption in 2002, Rule 67.11.1 specified lower federal VOC limits (compared 

to Rule 67.11) for large wood coating operations. However, in 2005 those same lower VOC 

limits took effect for all permitted operations (regardless of size) pursuant to Rule 67.11. 

Consequently, Rule 67.11.1 is now redundant and unnecessary. Furthermore, Rule 67.11.1 will 

become obsolete upon adoption of the proposed amendments to Rule 67.11.

The requested action to repeal Rule 67.11.1 will have no impact on sources or emissions. If 

repealed, Rule 67.11.1 will be requested for removal from the SIP.

Socioeconomic Impact Assessment

Section 40728.5 of the State Health and Safety Code requires the District to assess the 

socioeconomic impacts when adopting, amending, or repealing a rule that will significantly affect 

air quality or emission limitations. The assessment must include an evaluation of small business 

impacts. The proposed amendments to Rule 67.11 contain new, lower VOC emission limitations 

for wood coating and cleaning materials used in wood coating operations. Accordingly, a 

Socioeconomic Impact Assessment has been prepared (Attachment B), which shows that the rule 

amendments will not have significant economic impact on the affected industry, including small 

businesses.

Environmental Statement

The amendment of Rule 67.11 and repeal of Rule 67.11.1 is exempt from the California 

Environmental Quality Act pursuant to California Code of Regulations, Title 14, Section 15308, 
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

- 5 -

as an action taken to assure the protection of the environment, where the regulatory process 

involves procedures for protection of the environment. In this case, this action is being taken in 

response to federal and state requirements to reduce emissions of VOCs in order to achieve 

ambient air quality standards. Additionally, this action is also exempt pursuant to California 

Code of Regulations Title 14, Section 15061(b)(3), since it can be seen with certainty that there 

is no possibility that the activity in question may have a significant adverse effect on the 

environment. Many affected facilities already comply with the proposed requirements and 

compliant materials are widely available and in use.

Linkage to the County of San Diego Strategic Plan

Today's proposed action supports the Environment Strategic Initiative in the County of San 

Diego's 2011-2016 Strategic Plan with an objective to cost-effectively protect air quality. The 

proposed amendments to Rule 67.11 will codify the use of wood coating materials with lower 

emissions of VOCs without negatively impacting the local business community. The rule 

balances air quality preservation and economic development needs.

ATTACHMENT(S)

Attachment A – RESOLUTION AMENDING RULE 67.11 – WOOD PRODUCTS COATING 

OPERATIONS, AND REPEALING RULE 67.11.1 – LARGE COATING 

OPERATIONS FOR WOOD PRODUCTS, OF REGULATION IV OF THE 

RULES AND REGULATIONS OF THE SAN DIEGO COUNTY AIR 

POLLUTION CONTROL DISTRICT

Attachment B – Socioeconomic Impact Analysis

Attachment C – Comparative Analysis

Attachment D – Incremental Cost Effectiveness Analysis

Attachment E – Workshop Report

Attachment F – Rule 67.11 Change Copy

Attachment G – Rule 67.11.1 to be Repealed
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

- 6 -
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

AGENDA ITEM INFORMATION SHEET

REQUIRES FOUR VOTES: [] Yes [X] No

WRITTEN DISCLOSURE PER COUNTY CHARTER SECTION 1000.1 REQUIRED

[] Yes [X] No

PREVIOUS RELEVANT BOARD ACTIONS:

September 25, 2002 (APCB #2), Adoption of New Rule 67.11.1 – Large Coating Operations for 

Wood Products and Amendment of Rule 67.11 – Wood Products Coating Operations. 

BOARD POLICIES APPLICABLE:

N/A

BOARD POLICY STATEMENTS:

N/A

MANDATORY COMPLIANCE:

N/A

ORACLE AWARD NUMBER(S) AND CONTRACT AND/OR REQUISITION 

NUMBER(S):

N/A

ORIGINATING DEPARTMENT: Air Pollution Control District

OTHER CONCURRENCE(S): N/A

CONTACT PERSON(S):

ROBERT J. KARD ROBERT REIDER

Name Name

(858) 586-2700 (858) 586-2640

Phone Phone

(858) 586-2701 (858) 586-2701

Fax Fax

O-176 O-176

Mail Station Mail Station
SUBJECT: NOTICED PUBLIC HEARING – ADOPTION OF AMENDMENTS TO RULE 

67.11 – WOOD PRODUCTS COATING OPERATIONS AND REPEAL OF 

RULE 67.11.1 – LARGE COATING OPERATIONS FOR WOOD PRODUCTS 

(DISTRICT: All)

Robert.Kard@sdcounty.ca.gov Robert.Reider@sdcounty.ca.gov

E-mail E-mail