Antelope Valley 

Air Quality Management District 

Final 

Staff Report 

for 

Amendment to 

Rule 1151 – Motor Vehicle and Mobile Equipment 

Coating Operations

As amended on 

June 19, 2012 

43301 DIVISION ST., SUITE 206,

LANCASTER, CALIFORNIA 93535-4649 

PHONE (661) 723-8070 

FAX (661) 723-3450 
This page intentionally left blank. 
AVAQMD Rule 1151 TC-1 

Staff Report, Final 06/04/12 

STAFF REPORT 

TABLE OF CONTENTS 

Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations 

I. PURPOSE OF STAFF REPORT ...........................................................................................1 

II. EXECUTIVE SUMMARY....................................................................................................1

III. STAFF RECOMMENDATION............................................................................................3 

IV. LEGAL REQUIREMENTS CHECKLIST ..........................................................................4 

V. DISCUSSION OF LEGAL REQUIREMENTS...................................................................5 

A. REQUIRED ELEMENTS/FINDINGS ..........................................................................5 

1. State Findings Required for Adoption of Rules & Regulations ......................5 

a. Necessity..............................................................................................5 

b. Authority..............................................................................................5 

c. Clarity ..................................................................................................5 

d. Consistency..........................................................................................5 

e. Nonduplication.....................................................................................7 

f. Reference..............................................................................................7 

g. Public Notice & Comment, Public Hearing ........................................7 

2. Federal Elements (SIP Submittals, Other Federal Submittals)............................7 

a. Satisfaction of Underlying Federal Requirements..................................7 

b. Public Notice and Comment..................................................................8 

c. Availability of Document ......................................................................8 

d. Notice to Specified Entities .................................................................8 

e. Public Hearing ......................................................................................8 

f. Legal Authority to Adopt and Implement ............................................9 

g. Applicable State Laws and Regulations Were Followed ....................9 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS ........................................9 

C. ECONOMIC ANALYSIS ............................................................................................10 

1. General...........................................................................................................10 

2. Incremental Cost Effectiveness ....................................................................10 

D. ENVIRONMENTAL ANALYSIS (CEQA) ................................................................10 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS ...............................................11 

1. Potential Environmental Impacts...................................................................11 

2. Mitigation of Impacts ....................................................................................12 

3. Alternative Methods of Compliance..............................................................12 
TC-2 AVAQMD Rule 1151 

Staff Report, Final 06/04/12

F. PUBLIC REVIEW........................................................................................................12 

VI. TECHNICAL DISCUSSION.............................................................................................12 

A. SOURCE DESCRIPTION ...........................................................................................12 

B. EMISSIONS .................................................................................................................12 

C. CONTROL REQUIREMENTS....................................................................................12 

D. PROPOSED RULE SUMMARY.................................................................................13 

E. SIP HISTORY ..............................................................................................................15 

1. SIP History.....................................................................................................15 

2. SIP Analysis...................................................................................................16

Apendix A – Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

 Iterated Version.................................................................................................................. A-1 

Appendix B - Public Notice Documents .....................................................................................B-1 

Appendix C - Public Comments and Responses .........................................................................C-1 

Appendix D - California Environmental Quality Act Documentation....................................... D-1 

Appendix E - Bibliography..........................................................................................................E-1 
AVAQMD Rule 1151 1

Staff Report, Final 06/04/12

STAFF REPORT 

Rule 1151 - Motor Vehicle and Mobile Equipment Coating Operations

I. PURPOSE OF STAFF REPORT 

A staff report serves several discrete purposes. Its primary purpose is to provide a summary and 

background material to the members of the Antelope Valley Air Quality Management District 

Governing Board (Governing Board). This allows the members of the Governing Board to be fully 

informed before making any required decision. It also provides the documentation necessary for the 

Governing Board to make any findings, which are required by law to be made prior to the approval or 

adoption of a document. In addition, a staff report ensures that the correct procedures and proper 

documentation for approval or adoption of a document have been performed. Finally, the staff report 

provides evidence for defense against legal challenges regarding the propriety of the approval or 

adoption of the document. 

II. EXECUTIVE SUMMARY 

The Governing Board is being requested to conduct a public hearing, make findings, certify the 

Negative Declaration, and then adopt a resolution amending Rule 1151 - Motor Vehicle and Mobile 

Equipment Coating Operations. 

The Antelope Valley Air Quality Management District (AVAQMD) has the authority pursuant to 

California Health and Safety Code (H&S Code) §40702 to adopt, amend or repeal rules and 

regulations. The AVAQMD is proposing to amend Rule 1151 - Motor Vehicle and Mobile Equipment 

Coating Operations. 

Pursuant to Health and Safety Code (H&S Code) § 40106, the, then, Antelope Valley Air Pollution 

Control District (AVAPCD) assumed all air pollution control responsibilities from the South Coast Air 

Quality Management District (SCAQMD) in the Los Angeles County portion of the Mojave Desert Air 

Basin effective July 1, 1997. The rules of the SCAQMD were to remain in effect in AVAPCD until 

such time as the Governing Board adopted, amended, or rescinded rules and regulations to supersede 

those existing rules (H & S Code §40106(e)). 

Rule 1151 was originally adopted by SCAQMD on July 8, 1988 to reduce volatile organic compound 

(VOC) emissions from motor vehicle and mobile equipment coating operations within its jurisdiction 

including the Antelope Valley. Subsequently, the 1990 amendments to the Federal Clean Air Act 

(FCAA) required ozone non-attainment areas to implement Reasonably Available Control Technology 

(RACT) for sources that are subject to Control Technique Guidelines (CTGs) and Alternative Control 

Technologies (ACTs) for major sources of ozone precursors (42 U.S.C. §§7511a). At that time 

SCAQMD, including the Antelope Valley had designated nonattainment for ozone; therefore Rule 

1151, was amended in part to satisfy this federal requirement. At the time of adoption, it was 

recognized that some of the proposed VOC limits of Rule 1151 were, “technologically forcing”, in that 

no compliant products were available to meet the more stringent requirements. In 1994, the SCAQMD 

Governing Board amended Rule 1151 on December 9th to delay the implementation of some 
2 AVAQMD Rule 1151 

Staff Report, Final 06/04/12 

requirements until July 1, 1997. By 1996 it became clear that no products were available for certain 

categories. A product variance from the Hearing Board was granted, extending the compliance 

deadline to December 18, 1997. After the creation of the AVAPCD, the final compliance date for the 

product variance was extended by the AVAPCD Hearing Board until September 8, 1999. In July of 

1999, Rule 1151 was amended to extend the compliance date for certain coating categories to July 1, 

2000. 

Rule 1151 regulates emissions of volatile organic compounds (VOCs) from coating operations of 

motor vehicle and mobile equipment. Rule 1151 applies to both commercial and noncommercial 

refinishing coating applications that include, but are not limited to, auto body repair/paint shops, 

production auto body paint shops, new car dealer repair/paint shops, fleet operators repair/paint shops, 

custom-made car fabrication facilities, truck body builders, and any other motor vehicle or mobile 

equipment painting operations. The current rule establishes VOC limits by coating category and 

vehicle type. The current coating categories include pretreatment wash primer, primer/primer surfacer, 

primer sealer, topcoat, metallic topcoat, multi-stage topcoat system, and extreme performance; and, 

there are currently two vehicle types: Group I and Group II. Group I vehicles include large sized 

trucks, buses and mobile equipment, whereas, Group II vehicles include passenger cars, small-sized 

and medium sized trucks and vans, motor homes, and motorcycles. 

The proposed amendments to Rule 1151 modify the coating categories and VOC limits in accordance 

with the California Air Resources Board’s (CARB) Suggested Control Measure for Automotive 

Refinishing Coatings (SCM) as adopted on October 20, 2005. Specifically, the proposed amendments: 

(1) Combine Group I and Group II vehicle categories and establish VOC limits by coating category 

only; (2) Eliminate the composite VOC limit for multistage coating systems and establish independent 

VOC limit for both the color and clear parts of the multistage coating system; (3) Combine the primer, 

primer surfacer, and primer sealer categories and establish a single VOC limit for primers; and (4) 

Eliminate the general specialty coating category and replace it with specific categories, and VOC 

limits. The proposed amendments are technologically neutral, and the proposed VOC limit for color 

coating is based on waterborne products which are currently available. In addition, the proposed 

amendments incorporate the SCM for Automotive Refinishing Coatings’ establishment of a 25 grams 

per liter VOC limit for cleaning and surface preparation solvents. 

Concurrently with the amendments generated from the SCM, the revision of Rule 1151 includes 

proposed amendments generated from 40 Code of Federal Regulations (CFR) Part 63, Subpart 

HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources (Subpart HHHHHH), as well as, the Air 

Toxic Control Measure for Emissions of Hexavalent Chromium and Cadmium from Motor Vehicle and 

Mobile Equipment Coatings (ATCM) (Title 17 CCR, §93112). These proposed amendments include 

labeling, monitoring, and record requirements for the targeted hazardous air pollutants of Subpart 

HHHHHH, and prohibits the manufacture of automotive coatings in which cadmium or hexavalent 

chromium was introduced as a pigment or as an agent to any part, any property or characteristic to the 

coatings during manufacturing, distribution, or use of the applicable coatings as defined by the ATCM. 

As required by 42 U. S. C. §§7511a (FCAA §182), the revision of Rule 1151 included a close 

examination of all applicable CTGs and ACTs to ensure that RACT is being implemented by sources 
AVAQMD Rule 1151 3

Staff Report, Final 06/04/12

subject to Rule 1151. No amendments were necessary from this analysis, as the revised rule meets or 

exceeds the RACT defined in these applicable documents. 

In addition, former H&S Code §39614(d) required the Antelope Valley Air Quality Management 

District (AVAQMD or District) to adopt the most readily available, feasible, and cost-effective local 

control measures for Particulate Matter (PM) as contained on a list developed by the CARB. CARB 

has identified on its list of local control measures the “Vehicle Refinishing” strategy of limiting VOC 

content of applicable products to between 2.8-7.0 pounds per gallon. In the District’s List and 

Implementation Schedule for District Measures to Reduce PM Pursuant to Health & Safety Code 

§39614(d) the District identified this measure as currently implemented in the July 20, 1999 version of 

Rule 1151; therefore, no additional analysis is necessary. 

The proposed amendments to Rule 1151 addresses the SCM, RACT SIP Analysis, and the PM 

Analysis commitments, in addition to, the federal and state regulations as applicable. The proposed 

amendment of Rule 1151 also updates the definitions; VOC content limits for different coating 

categories; VOC emission control system limits; solvent cleaning operation limits; and, exemptions, 

recordkeeping and test methods. Therefore, the District staff recommends amending Rule 1151. 

III. STAFF RECOMMENDATION 

Staff recommends that the Governing Board adopt the proposed amendments to Rule 1151 and 

approve the appropriate California Environmental Quality Act (CEQA) documentation. This action is 

necessary to modify the coating categories and VOC limits in accordance with CARB’s SCM and to 

implement amendments generated from Subpart HHHHHH and the ATCM. 
4 AVAQMD Rule 1151 

Staff Report, Final 06/04/12 

72 

IV. LEGAL REQUIREMENTS CHECKLIST 

The findings and analysis as indicated below are required for the procedurally correct amendment to 

Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations. Each item is discussed, if 

applicable, in Section V below. Copies of documents are included in the appropriate Appendix. 

FINDINGS REQUIRED FOR 

RULES & REGULATIONS 

 X Necessity 

 X Authority 

 X Clarity 

 X Consistency 

 X Nonduplication 

 X Reference 

 X Public Notice & Comment 

 X Public Hearing 

REQUIREMENTS FOR STATE 

IMPLEMENTATION PLAN 

SUBMISSION (SIP): 

 X Public Notice & Comment 

 X Availability of Document 

 X Notice to Specified Entities (State, 

Air Districts, USEPA, Other States) 

 X Public Hearing 

 X Legal Authority to adopt and 

implement the document. 

 X Applicable State laws and 

regulations were followed. 

ELEMENTS OF A FEDERAL 

SUBMISSION 

 X Elements as set forth in applicable 

Federal law or regulations. 

CALIFORNIA ENVIRONMENTAL 

QUALITY ACT REQUIREMENTS 

(CEQA):

N/A Ministerial Action 

 X Exemption 

N/A Negative Declaration 

N/A Environmental Impact Report 

 X Appropriate findings, if necessary. 

 X Public Notice & Comment 

SUPPLEMENTAL ENVIRONMENTAL 

ANALYSIS (RULES & REGULATIONS 

ONLY): 

 X Environmental impacts of 

compliance. 

N/A Mitigation of impacts. 

N/A Alternative methods of compliance. 

OTHER: 

 X Written analysis of existing air 

pollution control requirements 

 X Economic Analysis 

 X Public Review 
AVAQMD Rule 1151 5

Staff Report, Final 06/04/12

V. DISCUSSION OF LEGAL REQUIREMENTS 

A. REQUIRED ELEMENTS/FINDINGS 

This section discusses the State of California statutory requirements that apply to the proposed 

amendment to Rule 1151. These are actions, that need to be performed, and/or information, 

that must be provided in order to amend the Rule in a procedurally correct manner. 

1. State Findings Required for Adoption of Rules & Regulations: 

Before adopting, amending, or repealing a rule or regulation, the Governing Board is 

required to make findings of necessity, authority, clarity, consistency, non-duplication, 

and reference based upon relevant information presented at the hearing. The 

information below is provided to assist the Board in making these findings. 

a. Necessity: 

The proposed amendments to Rule 1151 are necessary to modify the coating 

categories and VOC limits in accordance with the CARB’s SCM, as well as, 

incorporate amendments generated from Subpart HHHHHH and the ATCM

b. Authority: 

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or 

repeal rules and regulations. 

c. Clarity: 

The proposed amendments are clear in that they are written so that the persons 

subject to the rule can easily understand the meaning. 

d. Consistency: 

The proposed amendments to Rule 1151 are in harmony with, and not in conflict 

with or contradictory to any state law or regulation, federal law or regulation, or 

court decisions. USEPA has issued one CTG, and one ACT which have an 

impact on Rule 1151: CTG for Reduction for Volatile Organic Compound 

Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10), and 

Alternative Control Techniques Document: Automotive Refinishing (EPA 

453/R-94-031, 1994/04). These documents provide information on the 

application processes, VOC emissions and emission reductions, and costs 

associated with the use of alternative coating formulations and equipment used 

in automotive refinishing operations. The proposed VOC emission limits 

resulting from these products and technologies discussed in these documents are 

less stringent than those of the proposed amendments to Rule 1151, and 

therefore, these proposed amendments are not in conflict or inconsistent with the 

applicable CTG and ACT. 
6 AVAQMD Rule 1151

Staff Report, Final 06/04/12

While the following list of CTGs were determined to not be applicable to Rule 

1151, they were reviewed in the rule development process: CTG for Control of 

Volatile Organic Emissions from Existing Stationary Sources – Volume I: 

Control Methods for Surface-Coating Operations (EPA-450/2-76-028, 

1976/11), CTG for Control of Volatile Organic Emissions from Existing 

Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks (EPA-450/2-77-008, 1977/05), 

CTG for Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and 

Products (EPA-450/2-78-015, 1978/06), Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts Coatings (EPA-453/R-08-003, 2008/09), 

and Control Techniques Guidelines for Automobile and Light-Duty Truck 

Assembly Coatings (EPA-453/R-08-006, 2008/09). 

There are no Federal New Source Performance Standards (NSPS) that are 

applicable to Rule 1151. During the rule amendment process, 40 CFR 60 

Subpart MM, Standards of Performance for Automobile and Light Duty Truck 

Surface Coating Operations was examined, but was deemed to not be applicable 

to Rule 1151, as it only applies to assembly line operations. 

There is one National Emission Standard for Hazardous Air Pollutant Maximum 

Achievable Control Technology (MACT) that applies to automotive refinishing: 

40 CFR 63 Subpart HHHHHH - National Emission Standards for Hazardous 

Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations 

at Area Sources. The proposed amendments to Rule 1151 satisfy the 

requirements of this standard; therefore, are not in conflict. 

There is one Air Toxic Control Measure (ATCM) that applies to automotive 

refinishing: Title 17 CCR, Section 93112, Hexavalent Chromium and Cadmium 

Airborne Toxic Control Measure: Motor Vehicle and Mobile Equipment 

Coatings. The proposed amendments to Rule 1151 satisfy the requirements of 

this measure; therefore, are not in conflict. 

The proposed amendments to Rule 1151 modify the coating categories and VOC 

limits in accordance with the California Air Resources Board’s (CARB) 

Suggested Control Measure for Automotive Refinishing Coatings (SCM) as 

adopted on October 20, 2005. Specifically, the proposed amendments: (1) 

Combine Group I and Group II vehicle categories and establish VOC limits by 

coating category only; (2) Eliminate the composite VOC limit for multistage 

coating systems and establish independent VOC limit for both the color and 

clear parts of the multistage coating system; (3) Combine the primer, primer 

surfacer, and primer sealer categories and establish a single VOC limit for 

primers; and (4) Eliminate the general specialty coating category and replace it 

with specific categories, and VOC limits. The proposed amendments are 

technologically neutral, and the proposed VOC limit for color coating is based 
AVAQMD Rule 1151 7

Staff Report, Final 06/04/12

on waterborne products which are currently available. In addition, the proposed 

amendments incorporate the SCM for Automotive Refinishing Coatings’s 

establishment of a 25 grams per liter VOC limit for cleaning and surface 

preparation solvents. 

e. Nonduplication: 

The proposed amendments to Rule 1151 do not impose the same requirements 

as any existing state or federal law or regulation because the District is adopting 

this rule in response to CARB’s SCM, Subpart HHHHHH, and the ATCM. 

f. Reference: 

AVAQMD has the authority pursuant to H&S Code §40702 to adopt, amend or 

repeal rules and regulations. The proposed amendments to Rule1151 implement 

and comply with CARB’s SCM (2005/10), 40 CFR 63 Subpart HHHHHH, and 

the ATCM (Title 17 CCR §93112). 

g. Public Notice & Comment, Public Hearing: 

Notice for the public hearing for the proposed amendments to Rule 1151 was 

originally published June 17, 2011. Since the rule was continued to the August 

16th meeting and then pulled from the agenda at that meeting, a new notice for 

the public hearing for the proposed amendments to Rule 1151 was published on 

April 13, 2012. See Appendix “B” for a copy of the public notice. See Appendix 

“B” for a copy of the public notice. See Appendix “C” for copies of comments, if 

any, and AVAQMD responses. The proposed amendment of Rule 1151 was 

originally scheduled for the July, 19, 2011 Governing Board meeting, which was 

cancelled, so this item was continued to the August 16, 2011 meeting. At that 

meeting, the item was pulled from the agenda in order to readdress comments 

from the public. After addressing the comments from the August 16, 2011 

meeting, the proposed amendments to 1151 were noticed for the May 15, 2012 

meeting. At the May 15, 2012 meeting the Governing Board asked that this 

item be continued to the June 19, 2012 meeting. 

2. Federal Elements (SIP Submittals, Other Federal Submittals). 

Submittals to USEPA are required to include various elements depending upon the type 

of document submitted and the underlying Federal law which requires the submittal. 

The information below indicates which elements are required for the proposed 

amendment to Rule 1151 and how they were satisfied. 

a. Satisfaction of Underlying Federal Requirements: 
8 AVAQMD Rule 1151

Staff Report, Final 06/04/12

The FCAA requires areas designated non-attainment and classified moderate 

and above to implement RACT for sources subject to CTG and ACT documents 

60 

issued by USEPA for major sources of VOCs and oxides of nitrogen (NOX) 

which are ozone precursors. USEPA has issued one CTG, and one ACT which 

have an impact on Rule 1151: CTG for Reduction for Volatile Organic 

Compound Emissions from Automobile Refinishing (EPA 450/3-88-009, 

1988/10), and Alternative Control Techniques Document: Automotive 

Refinishing (EPA 453/R-94-031, 1994/04). These documents provide 

information on the application processes, VOC emissions and emission 

reductions, and costs associated with the use of alternative coating formulations 

and equipment used in automotive refinishing operations. The VOC emission 

limits resulting from these products and technologies discussed in these 

documents are less stringent than those of the amendments to Rule 1151. To 

ensure that the amendments to Rule 1151 will satisfy the RACT requirements 

pursuant to FCAA, the revisions made to the rule are consistent with the 

requirements of San Joaquin Valley Unified Air Pollution Control District’s 

(SJVUAPCD) Rule 4612: Motor Vehicle and Mobile Equipment Coating 

Operations – Phase II, as amended on September 20, 2007 and approved into 

the SIP as RACT by USEPA on January 1, 2010 (75 FR 2796). 

b. Public Notice and Comment: 

Notice for the public hearing for the proposed amendments to Rule 1151 was 

originally published on June 17, 2011. Since the rule was continued to August 

16th meeting and then pulled from the agenda at that meeting, a new notice for 

the public hearing for the proposed amendments to Rule 1151 was published on 

April 13, 2012. See Appendix “B” for a copy of the public notice. 

c. Availability of Document: 

Copies of the proposed amendments to Rule 1151 and the accompanying draft 

staff report was made available to the public on or before April 13, 2012. 

d. Notice to Specified Entities 

Copies of the proposed amendments to Rule 1151 and the accompanying draft 

staff report were sent to all affected agencies. The proposed rule amendments 

were sent to CARB and USEPA on or before April 13, 2012. 

e. Public Hearing: 

The proposed amendment of Rule 1151 was originally scheduled for the July, 19, 

2011 Governing Board meeting, which was cancelled. This item was continued to 

the August 16, 2011. At that meeting, the item was pulled from the agenda in 
AVAQMD Rule 1151 9

Staff Report, Final 06/04/12

order to readdress comments from the public concerning Single-stage Coatings 

and Vinyl Interior Coatings availability for the proposed VOC limits. The 

proposed amendment of Rule 1151 was then re-noticed for the May 15, 2012 

meeting. At the May 15, 2012 meeting the Governing Board asked that this 

item be continued to the June 19, 2012 meeting. 

f. Legal Authority to Adopt and Implement: 

The AVAQMD has the authority pursuant to H&S Code §40702 to adopt, 

amend, or repeal rules and regulations and to do such acts as may be necessary 

or proper to execute the duties imposed upon the AVAQMD. 

g. Applicable State Laws and Regulations Were Followed: 

Public notice and hearing procedures pursuant to H&S Code §§40725-40728 

have been followed. See Section (V)(A)(1) above for compliance with state 

findings required pursuant to H&S Code §40727. See Section (V)(B) below for 

compliance with the required analysis of existing requirements pursuant to H&S 

Code §40727.2. See Section (V)(C) for compliance with economic analysis 

requirements pursuant to H&S Code §40920.6. See Section (V)(D) below for 

compliance with provisions of the California Environmental Quality Act 

(CEQA). 

B. WRITTEN ANALYSIS OF EXISTING REQUIREMENTS 

H & S Code §40727.2 requires air districts to prepare a written analysis of all existing federal 

air pollution control requirements that apply to the same equipment or source type as the rule 

proposed for modification by the District. 

The FCAA requires areas designated non-attainment and classified moderate and above to 

implement RACT for sources subject to CTG and ACT documents issued by USEPA for major 

sources of VOC and NOX which are ozone precursors. USEPA has issued one CTG, and one 

ACT which have an impact on Rule 1151: CTG for Reduction for Volatile Organic Compound 

Emissions from Automobile Refinishing (EPA 450/3-88-009, 1988/10), and Alternative 

Control Techniques Document: Automotive Refinishing (EPA 453/R-94-031, 1994/04). These 

documents provide information on the application processes, VOC emissions and emission 

reductions, and costs associated with the use of alternative coating formulations and equipment 

used in automotive refinishing operations. The VOC emission limits resulting from these 

products and technologies discussed in these documents are less stringent than those of the 

amendments to Rule 1151. To ensure that the amendments to Rule 1151 will satisfy the 

RACT requirements pursuant to FCAA, the revisions made to the rule are consistent with the 

requirements of SJVUAPCD’s Rule 4612: Motor Vehicle and Mobile Equipment Coating 

Operations – Phase II, as amended on September 20, 2007 and approved into the SIP as 

RACT by USEPA on January 1, 2010 under Federal Registration Citation Number 75 FR 

2796. Therefore, rule adoption at the local level and submission as a SIP revision is necessary 

to implement these requirements. 
10 AVAQMD Rule 1151

Staff Report, Final 06/04/12

There is one National Emission Standard for Hazardous Air Pollutant Maximum Achievable 

Control Technology (MACT) that applies to automotive refinishing: 40 CFR Part 63 Subpart 

HHHHHH - National Emission Standards for Hazardous Air Pollutants: Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources. The amendments to Rule 1151 

satisfy the requirements of this standard; therefore, are not in conflict. MACT standards are 

imposed upon existing sources pursuant to the provisions of District Rule 1402 – Control of 

Toxic Air Contaminants from Existing Sources. Thus, many of the existing sources are already 

subject to the same level of control for certain chemicals as those specified in the amendments 

to Rule 1151. Please note that any new or modified stationary source in this category would 

require a Toxic New Source Review analysis as part of its permitting process (see District Rule 

1401) and would thus acquire the same level of control as that provided for by amended 

Rule1151. 

C. ECONOMIC ANALYSIS 

1. General 

The proposed amendments to Rule 1151 is equivalent to SJVUAPCD’s Rule 4612 – 

Motor Vehicle and Mobile Equipment Coating Operations – Phase II, which was 

determined by USEPA to be RACT (75 FR 2796); therefore, cost effectiveness is not 

required. 

2. Incremental Cost Effectiveness 

Pursuant to H&S Code §40920.6, incremental cost effectiveness calculations are 

required for rules and regulations which are adopted or amended to meet the California 

Clean Air Act requirements for Best Available Retrofit Control Technology (BARCT) 

or “all feasible measures” to control volatile compounds, oxides of nitrogen or oxides of 

sulfur. 

The proposed amendment to Rule 1151 are not subject to incremental cost effectiveness 

calculations because this rule does not impose BARCT or “all feasible measures”. 

D. ENVIRONMENTAL ANALYSIS (CEQA) 

Through the process described below, it was determined that a Notice of Exemption would be 

the appropriate CEQA process for the proposed amendment to Rule 1151. 

1. The proposed amendment to Rule 1151 meet the CEQA definition of "project." 

They are not "ministerial" actions. 

2. The proposed amendment to Rule 1151are exempt from CEQA review because 

it will not create any adverse impacts on the environment. The requirements in 

the amendments to Rule 1151 are more stringent than the currently existing 

requirements (see more detailed discussion in Rule Summary §(D)) in that: the 
AVAQMD Rule 1151 11

Staff Report, Final 06/04/12

rule applicability is expanded in accordance with the SCM; definitions are 

updated to make the rule more comprehensive, reflect the current applicability 

of the rule, and provide additional clarity; VOC limits for various categories of 

coatings and solvent coating operations have been modified in accordance with 

the SCM; work practice requirements have been added; and, the monitoring and 

recordkeeping, and test method sections have been strengthened. Concurrently 

with the amendments generated from the SCM, the revision of Rule 1151 also 

includes amendments generated from Subpart HHHHHH and the ATCM which 

includes labeling, monitoring, and record requirements for the targeted 

hazardous air pollutants of Subpart HHHHHH, and prohibits the manufacture, 

sell, offering for sale, distribution for use in the District, and/or application of 

automotive coatings which contain cadmium or hexavalent chromium. This 

includes those coatings in which cadmium or hexavalent chromium was 

introduced as a pigment or as an agent to any part, any property or characteristic 

to the coatings during manufacturing, distribution, or use of the applicable 

coatings as defined by the ATCM. 

In addition, coatings satisfying the limits contained in the rule are readily 

available in commerce and have been shown not to cause either additional usage 

of the coatings themselves or of cleaning solvents. Other air districts have 

adopted similar rules, and neither they, nor USEPA, have identified increased 

usage of coatings or solvents as an issue in supporting documentation. 

 Therefore, no adverse environmental effects are foreseen from the amendments. 

 Copies of the documents relating to CEQA can be found in Appendix “D” 

E. SUPPLEMENTAL ENVIRONMENTAL ANALYSIS 

1. Potential Environmental Impacts 

There are no potential adverse environmental impacts of compliance with the 

adoption of Rule 1151. The amendments to Rule 1151 modify the coating 

categories, and reduce the VOC limits for these coatings and associated solvents 

in accordance with CARB’s SCM. Also in accordance with the SCM, the 

amendments enhance the rule’s applicability and increases clarification through 

definitions and reporting requirements. The revision of Rule 1151 also includes 

amendments generated from Subpart HHHHHH and the ATCM in order to 

strengthen labeling, monitoring, and record requirements for the targeted 

hazardous air pollutants and prohibits the manufacture, sell, offering for sale, 

distribution for use in the District, and/or application of automotive coatings 

which contain cadmium or hexavalent chromium. This includes those coatings 

in which cadmium or hexavalent chromium. These amendments are more 

stringent than the current adopted requirements of Rule 1151, and coatings 

complying with the rule VOC limits are readily available in commerce and 

should not cause additional usage of the coatings themselves or of cleaning 

solvents. These more stringent requirements should help to further abate the 
12 AVAQMD Rule 1151

Staff Report, Final 06/04/12

emission of air contaminants generated from automotive refinishing operations. 

In fact, the District suspects that a high percentage of the facilities in this source 

category are already using compliant coatings, or are prepared to do so upon 

adoption of the amendments, due to availability and the fact that the SCM has 

already been incorporated into the analogous automotive refinishing rules of 

neighboring air districts, such as SCAQMD and SJVUAPCD. 

2. Mitigation of Impacts 

N/A 

3. Alternative Methods of Compliance 

N/A 

F. PUBLIC REVIEW 

See Staff Report Section (V)(A)(1)(g) and (2)(b), as well as Appendix B. 

VI. TECHNICAL DISCUSSION 

A. SOURCE DESCRIPTION 

Rule 1151 is aimed at automotive refinishing operations, and those which manufacture, 

distribute, and sell automotive coatings. Specifically, this rule will be applicable to any person 

who uses, applies, or solicits the use or application of any automotive coating or associated 

solvent within the District, and also, any person who supplies, sells, offers for sale, 

manufacturer’s, or distributes any automotive coating or associated solvent within the District. 

Previously, suppliers, sellers, manufacturers, and distributors were not applicable to Rule 1151. 

 The SCM includes this group in order to promote consistency and uniformity statewide. 

Several facilities in the AVAQMD have operations potentially affected by the amendments to 

Rule 1151. There are approximately 47 automotive refinishing operations within the District 

which are served by about three main suppliers. There are several manufacturers of automotive 

coatings who distribute their products throughout the state, as well as, nationwide. 

B. EMISSIONS 

The amendments to Rule 1151 do not cause the release of additional air contaminants, or create 

any adverse environmental impacts because the amended rule proposes a more stringent 

applicability, as well as, more stringent VOC limits for all coating categories, including solvent 

cleaning operations, than the existing rule. It also places prohibitions and/or restrictions on 

hazardous air pollutants and toxic compounds that may be found in automotive coatings or 

operations, that were not previously regulated by Rule 1151. 

C. CONTROL REQUIREMENTS 
AVAQMD Rule 1151 13

Staff Report, Final 06/04/12

Please see subsections (C)(1) through (C)(8) of the rule (see Appendix “A”) for control 

requirements. Control requirements are in the form of VOC limits for coatings and solvents, 

approved VOC emission control system limits, prohibitions of hazardous air pollutants and 

toxics, approved coating application equipment, prohibition of possession, specification and 

sale, and surface preparation and cleaning operation practices. 

D. PROPOSED RULE SUMMARY 

This section gives a brief overview of the amendments to Rule 1151. The iterated rule version 

is contained in Appendix “A” of this staff report. 

The amendments to Rule 1151 were designed to implement CARB’s SCM, as well as, 

provisions generated from Subpart HHHHHH and ATCM. 

Section (A), General, has been amended to extend applicability to any person who supplies, 

sells, offers for sale, manufactures, or distributes any automotive coating or associated solvent 

within the District. A subsection was also added to specifically state what this rule does not 

apply to.

Section (B), Definitions, is updated. Definitions have been included to make the rule more 

comprehensive, reflect the current applicability of the rule, and provide additional clarity. 

Section (C), Requirements, have been modified as follows: 

VOC Content of Coatings, subsection (C)(1), combines Group I and Group II vehicle categories 

and establish VOC limits by coating category only; eliminates the composite VOC limit for 

multistage coating systems and establish independent VOC limit for both the color and clear 

parts of the multistage coating system; combines the primer, primer surfacer, and primer sealer 

categories and establish a single VOC limit for primers; and eliminates the general specialty 

coating category and replaces it with specific categories, and VOC limits. 

The Most Restrictive VOC Limit requirement of subsection (C)(2) states that the lowest 

applicable VOC content limit in Table 1 shall apply if more than one category of coating is 

described on a container of automotive coating. 

Alternative Compliance, subsection (C)(3), specifically states Emission Control System

requirements are specified in subsection (C)(3)(a) which defines a new control efficiency of 85 

percent and Alternative Emission Control Plan, subsection (C)(3)(b), allows for alternative 

compliance pursuant to Rule 108 – Alternative Emissions Control Plans. 

Prohibited Compounds in subsection (C)(4) and Carcinogenic Materials in subsection (C)(5) 

prohibit automotive coatings containing certain potentially toxic compounds and cadmium and 

hexavalent chromium. 

Approved coating application equipment and methods are discussed under Application 

Methods, subsection (C)(6). This subsection has been modified to require any other coating 
14 AVAQMD Rule 1151

Staff Report, Final 06/04/12

application approved by the Air Pollution Control Officer/Executive Director to be capable of 

achieving a transfer efficiency equivalent to, or higher than, the application methods listed in 

subsections (6)(a)(i) and (6)(a)(ii), but not less than 65 percent. 

Subsection (C)(7), Surface Preparation and Cleaning Operations, has been amended to 

incorporate the SCM establishment of a 25 grams per liter VOC limit for cleaning and surface 

preparation solvents. This subsection has also been amended to clarify that spent solvent shall 

be stored in “vapor tight” and closed containers. Language was also added under this 

subsection to prohibit possession of non-compliant solvents after the compliance date of May 

1, 2013. Language was also added for an exemption of aerosol solvent products, not to exceed 

160 fluid ounces per day per facility. 

Prohibition of Possession, Specification, and Sale, subsection (C)(8), has been modified to 

eliminate language referring to Group I and Group II designation which was removed by the 

SCM, and adds specific language in which subsection (C)(1) does not apply such as if an 

approved Emission Control System is used, the coating is located at a training center for 

educational purposes, or the coating is a prototype. 

The current subsections of Specialty Coatings and Extreme Performance Coating Requirements

have been removed in the amendment to Rule 1151, as these categories have been eliminated 

by the SCM. 

Section (D), Exemptions, has been updated to be more comprehensive and to reflect the 

applicability of the rule. Specific exemptions from the SCM were also incorporated into this 

section under subsections (D)(1)(a), (D)(1)(b), (D)(1)(d), and (D)(1)(e) to exclude assembly 

line coatings, coatings for sale out side the District, aerosol coatings, and coatings sold in 0.5 

fluid ounces or less, respectively. 

Subsection (D)(4) and (D)(5) have been added to exempt automotive coatings applied for 

educational purposes and assembly-line coatings, respectively, with certain restrictions 

consistent with those of the SCM. 

Rule 442 Applicability, subsection (D)(6), has been incorporated under the Exemption section 

from Administrative Requirements section as requested by CARB’s comment on the 

preliminary draft. 

Section (E), Administrative Requirements, has been updated to reflect the applicability. 

Specifically, Manufacturer’s Compliance Statement Requirement, subsection (E)(1), and 

Manufacturer’s Labeling Requirement, subsection (E)(2), have been added to strengthen and 

clarify recordkeeping requirements. The Extreme Performance Coating Petition subsection has 

been removed in the revision of Rule 1151 as the SCM eliminates the “extreme performance” 

coating category. 

Section (F), Monitoring and Records, has also been updated to strengthen and clarify 

recordkeeping requirements in accordance with the SCM and HHHHHH. 
AVAQMD Rule 1151 15

Staff Report, Final 06/04/12

Section (G), Test Methods, has been amended to update the testing methods and protocols to 

the most recent version in accordance with the SCM and those that are USEPA approved. 

Testing methods for the Determination of Methyl Acetate, Acetone, Acetate, and PCBTF

Content (subsection (G)(h)), Exempt Compound Content (subsection (G)(j)), Determination of 

Alternative Compliance (subsection (G)(i)), and HVLP Equivalency (subsection (G)(k)) were 

also added. 

Various format changes were made for consistency with current District rule format, as well as 

correction of typographical errors and several grammatical changes. 

E. SIP HISTORY 

1. SIP History. 

Prior to 1975 the original air district for the Antelope Valley region was the Los 

Angeles County Air Pollution Control District that had jurisdiction covering the entire 

county of Los Angeles. In 1975, the Southern California Air Pollution Control District 

(So. Cal. APCD) was created by a Joint Powers Agreement (JPA) between Los 

Angeles, Orange, Riverside and San Bernardino Counties to replace the previous 

countywide air pollution control districts for those counties. On February 1, 1977, 

pursuant to statute (Cal. Stats. 1976, Ch 324 p. 815), the South Coast Air Quality 

Management District (SCAQMD) was created with an initial jurisdiction that only 

included areas of Los Angeles, Orange, Riverside and San Bernardino Counties 

contained within the South Coast Air Basin (SCAB). Outlying areas remained under 

the So. Cal. APCD (The legislation was thereafter amended to allow non-SCAB areas 

to “opt in”. Los Angeles County exercised this option and thus the Antelope Valley 

became a part of SCAQMD). Also on February 1, 1977 the California Air Resources 

Board (CARB) issued Executive Order G-73 (1977) which adopted a “rule book” for 

those non-SCAB areas of Los Angeles, Riverside and San Bernardino Counties. CARB 

submitted the G-73 rulebook on behalf of the “county” districts. By its terms Executive 

Order G-73 (1977) was only effective until the non-SCAB areas took other action. On 

February 22, 1977 the JPA forming the So. Cal. APCD was formally dissolved. By the 

terms of the JPA upon dissolution each county would regain its county air pollution 

control district with a jurisdiction of the non-SCAB areas of the county and the 

applicable rules being the So. Cal. APCD’s rules in effect upon the date of dissolution. 

This rule book was the initial starting point for the SCAQMD rules applicable to the 

Antelope Valley. 

On July 1, 1997 the Antelope Valley Air Pollution Control District (AVAPCD) 

replaced the SCAQMD as the agency with jurisdiction over the Los Angeles County 

portion of the Mojave Desert Air Basin (MDAB). Pursuant to the statutory change, the 

rules and regulations of the predecessor district were retained until the Governing Board 

adopted, amended or rescinded them. At its first meeting the AVAPCD reaffirmed all 

the existing rules and regulations thus the version in effect at the time of the change was 

the December 13, 1996 version. 
16 AVAQMD Rule 1151

Staff Report, Final 06/04/12

On January 1, 2002 the AVAPCD was replaced by the AVAQMD. Once again, 

pursuant to statute, the rules in effect were retained until the Governing Board adopted, 

amended, or rescinded. Similarly, at the first meeting of the AVAQMD, the Governing 

Boards reaffirmed all the rules and regulations in effect at the time the agency changed. 

 

The jurisdiction of the AVAPCD and the AVAQMD were specified in the statutes as 

the portion of the Los Angeles County contained within the MDAB. The MDAB was 

formerly known as the Southeast Desert Air Basin (SEDAB). In 1997 the SEDAB was 

split into the MDAB and the Salton Sea Air Basin. Descriptions of these air basins can 

be found in 17 Cal. Code Regs. §§60109 and 60144. Since USEPA adopts State 

Implementation Plan (SIP) revisions in California as effective within jurisdictional 

boundaries of local air districts, when the local air district boundaries change the SIP as 

approved by USEPA for that area up to the date of the change remains as the SIP in that 

particular area. Thus, upon creation of the AVAPCD on July 1, 1997 the AVAPCD 

acquired the SIP applicable to the Antelope Valley portion of the SCAQMD that was 

effective as of June 30, 1997. Likewise the AVAQMD acquired the SIP that was 

effective in the jurisdiction of the AVAPCD as of December 31, 2000. Therefore, the 

SIP history for this region is based upon the rules adopted, effective, and approved for 

the Antelope Valley by SCAQMD. 

Rule 1151 was originally adopted on July 8, 1988, and was submitted as an amendment 

to the SIP. Rule 1151 was thereafter amended on May 5, 1989; March 2, 1990; June 

28, 1990; November 2, 1990; December 7, 1990; and August 2, 1991. Rule 1151 was 

further amended on September 6, 1991 and submitted as a SIP amendment which 

promulgated a limited approval/limited disapproval (58 FR 66286; 40 CFR 

52.220(c)(i)(A)(1)). On December 9, 1994 SCAQMD amended Rule 1151 and was 

submitted as a SIP amendment and it was approved into the SIP on June 13, 1995 (60 

FR 31084; 40 CFR 52.220(c)(214)(A)(i)). Since this approval, Rule 1151 has been 

amended by SCAQMD two times times: March 8, 1996 and June 13, 1997. After the 

creation of the AVAPCD the AVAPCD amended Rule 1151 on July 20, 1999. The July 

20, 1999 version was approved into the SIP on April 10, 2000 for the AVAQMD and is 

the current version in the SIP (65 FR 18901; 40 CFR 52.220(c)(270)(i)(E)(1)). 

2. SIP Analysis. 

The District will request CARB to submit the amendments to Rule 1151 to replace the 

SIP version in effect in the AVAQMD. This submission is necessary because the 

District wishes to update the SIP for this category. 

Since there is a previously existing SIP rule for this category the District will request 

that it be superseded. In order to replace existing SIP rules the District is required to 

show that the amendments are not less stringent than the provisions currently in the SIP. 

The amendment of Rule 1151 is more stringent than the provisions currently in the SIP 

because rule applicability has been expanded in accordance with the SCM; definitions 
AVAQMD Rule 1151 17

Staff Report, Final 06/04/12

are updated to make the rule more comprehensive, reflect the current applicability of 

the rule, and provide additional clarity; VOC limits for various categories of coatings 

and solvent coating operations have been modified; work practice requirements have 

been added; and, the monitoring and recordkeeping, and test method sections have been 

strengthened. These amendments conform the current rule to those contained in the 

SCM. 

Concurrently with the amendments generated from the SCM, the revision of Rule 1151 

also includes amendments generated from Subpart HHHHHH and the ATCM which 

consists of labeling, monitoring, and record requirements for the targeted hazardous air 

pollutants of Subpart HHHHHH, and prohibits the manufacture, sell, offering for sale, 

distribution for use in the District, and/or application of automotive coatings which 

contain cadmium or hexavalent chromium. This includes those coatings in which 

cadmium or hexavalent chromium was introduced as a pigment or as an agent to impart 

any property or characteristic to the coatings during manufacturing, distribution, or use 

of the applicable coatings as defined by the ATCM. 
18 AVAQMD Rule 1151

Staff Report, Final 06/04/12

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AVAQMD Rule 1151 A-1

Staff Report, Final 06/04/12

APPENDIX "A"

Rule 1151 – Motor Vehicle and Mobile Equipment Coating Operations

Iterated Version 

The iterated version is provided so that the changes to an existing rule may be easily found. The manner of 

differentiating text is as follows: 

1. Shaded text identifies new or revised language. 

2. Lined out text identifies language which is being deleted. 

3. Normal text identifies the current language of the current rule which will remain unchanged by the 

adoption of the proposed amendments. 

4. Italicized text identifies explanatory material that is not part of the proposed language. 
A-2 AVAQMD Rule 1151

Staff Report, Fianl 06/04/12

This page intentionally left blank. 
(Adopted: 07/08/88; Amended: 05/05/89; Amended: 03/02/90; 

Amended: 06/28/90; Amended: 11/02/90; Amended: 12/07/90; 

Amended: 08/02/91; Amended: 09/06/91; Amended: 12/09/94; 

Amended: 03/08/96; Amended: 06/13/97; Amended: 07/20/99; 

Amended: mmddyy) 

AVAQMD Rule 1151 1151-1 

Motor Vehicle and Mobile Equipment Coating Operations 

D6, 05/14/12 

Rule 1151 

Motor Vehicle aAnd Mobile Equipment Coating Operations 

(A) Purpose and ApplicabilityGeneral

(1) Purpose 

(a) The purpose of this rule is to reduce emissions of Volatile Organic Compounds 

(VOCs), from Coatings and solvents applied associated with the Refinishing on

of Motor Vehicles, Mobile Equipment and their Associated Pparts and 

componentsComponents. [Changes derived from CARB’s SCM for Automotive 

Coatings, section 1]

(2) Applicability 

(a) This ruleThis rule is applicable to:

(i) Any Person who uses, applies, or, solicits the use or application of any 

Automotive Coating or associated solvent within the District.

(ii) Any Person who supplies, sells, offers for sale, manufactures, or 

distributes any Automotive Coating or associated solvent for use within 

the District.

(b) This rule does not apply to:

(i) Any Coating applied to Motor Vehicles or Mobile Equipment, or their 

Associated Parts and Components, during manufacture on an Assembly 

Line.

(ii) Any Automotive Coating or associated solvent that is offered for sale, 

sold or manufactured for use outside of the District or for shipment to 

other manufacturers for reformulation or repackaging.

(iii) Any Stencil Coating Product.

(iv) Any Aerosol Coating Products that are in compliance with regulations 

and requirements adopted by the California Air Resources Board (CCR, 

Title 17, Subchapter 8.5, Section 94522). [Definition modified in 

response to ARB’s comment to do so in review of D2]

(v) Any Automotive Coating that is sold, supplied, or offered for sale in 

one-half (0.5) fluid ounce or smaller containers intended to be used by 
1151-2 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

the general public to repair tiny surface imperfections. [This section 

added in response to USEPA’s comment of the preliminary draft 

requesting to add section here stating what the rule does not apply to. 

Reordering in response to ARB comment of D2]

applies to all Commercial and Non-Commercial Coating Applications to Group I 

Vehicles and Equipment and Group II Vehicles and their parts and components 

at facilities involved in the production, modification, or refinishing of Motor 

Vehicles and Mobile Equipment.

(b) The application of Coatings on a vehicle which is not self-propelled, such as 

trailers and mobile homes, are subject to other source specific rules contained in 

Regulation XI. [Changes derived from CARB’s SCM for Automotive Coatings, 

section 2]

(B) Definitions 

For the purposes of this rule, the following definitions shall apply: 

(1) “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. a Coating applied over both an existing non-sanded 

Topcoat, and the coated area immediately adjacent to the non-sanded Topcoat, to 

promote the adhesion of a subsequent Topcoat. No Topcoat, Primer, or Primer Surfacer 

shall be classified as an Adhesion Promoter. [Changes to definition derived from 

CARB’s SCM for Automotive Coatings, section 3.18. Last sentence deleted as it 

conflicted with definition (B)(19), Coating Categories]

(2) “Aerosol Coating Product” - a 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.

(3) “Air Pollution Control Officer (APCO)” - The person appointed by the Air Pollution 

Control Board and assigned full time to manage and direct the business and operations 

of the district. The Air Pollution Control Officer is also the District Director, and is that 

person described for State purposes as the Air Pollution Control Officer. [Definition 

added for clarification purposes only]

(4) “Alternative Emission Control Plan” - A plan which allows a source to demonstrate an 

alternative method of rule compliance.

(35) “Anti-Glare Safety Coating” - a Coating formulated to eliminate glare for safety 

purposes on interior surfaces of a vehicle and which shows a reflectance of 25 or less on 

a 60° gloss meter.
AVAQMD Rule 1151 1151-3 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(4) “Basecoat” - a pigmented Topcoat which is the first Topcoat applied as part of a 

Multistage Topcoat System. [Deleted as this coating category no longer exists in 

CARB’s SCM for Automotive Coatings]

(5) “Basecoat/Clearcoat Topcoat System” - a Multistage Topcoat System composed of a 

Basecoat portion and a Clearcoat portion.

(a) The Grams of VOC per Liter of Coating Less Water and Less Exempt 

Compounds of a Basecoat/Clearcoat Topcoat System shall be calculated 

according to the following formula:

 VOCbc + 2 VOCcc

VOCms =

3

Where:

VOCms = the composite Grams of VOC per Liter of Coating Less Water and 

Less Exempt Compounds to be used for compliance determination 

under the Multistage Topcoat System Coating category.

VOCbc = the Grams of VOC per Liter of Coating Less Water and Less 

Exempt Compounds as applied, of any given Basecoat.

2 VOCcc = two times the Grams of VOC per Liter of Coating Less Water and 

Less Exempt Compounds as applied, of any given Clearcoat.

(b) The VOC per Volume of Applied Solids of a Basecoat/Clearcoat Topcoat 

System shall be calculated according to the following formula:

 VOC-Sbc + 2 VOC-Scc

VOC-Sms =

3

Where:

VOC-Sms = the composite VOC per Volume of Applied Solids to be used for 

compliance determination under subsection (C)(1)(a)(ii)2.

VOC-Sbc = the VOC per Volume of Applied Solids of any given basecoat, 

calculated according to the formula in subsection (B)(51).

2 VOC-Scc = two times the VOC per Volume of Applied Solids of any given 

clearcoat, calculated according to the formula in subsection 

(B)(51). [Deleted to synchronize definitions with CARB’s SCM for 

Automotive Coatings. Definition is no longer necessary]
1151-4 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(6) “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. [Definition derived from CARB’s SCM for Automotive 

Coatings Section 3.3]

(7) “Associated Parts and Components” - Structures, devices, pieces, modules, sections, 

assemblies, subassemblies, or elements of Motor Vehicles or Mobile Equipment that are 

designed to be 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. The Associated Parts and 

Components definition does not include circuit boards. [Definition derived from 

CARB’s SCM for Automotive Coatings Section 3.4]

(8) “ASTM” - American Society for Testing and Materials [Definition added for 

clarification purposes only]

(9) “Automotive Coating” - Any coating or Automotive 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. [Definition derived from CARB’s SCM for 

Automotive Coatings Section 3.5]

(10) “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. [Definition derived 

from CARB’s SCM for Automotive Coatings Section 3.6]

(11) “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. Automotive Refinishing Facility 

does not include the original equipment manufacturing plant where the Motor Vehicle 

or Mobile Equipment is completely assembled. [Derived from SCAQMD Rule 1151,

section (c)(7)]

(612) “Bright Metal Trim Repair Coating” - a A Coating applied directly to chrome-plated 

metal surfaces for the purpose of appearance.

(713) “Bus” - any Any Motor Vehicle having a manufacturer's gross vehicle weight of more 

than 8600 pounds and which is designed primarily for the transportation of persons, and 

having a design capacity of over 12 persons.
AVAQMD Rule 1151 1151-5 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(8) “Clearcoat” - a Topcoat which contains no pigments or only transparent pigments and 

which is the final Topcoat applied as a part of a Multistage Topcoat System. [Replaced 

with “Clear Coating”]

(14) “CARB” – California Air Resources Board [Definition added in response to USEPA’s 

comment to do so on the preliminary draft.]

(15) “CFR” - Code of Federal Regulations [Definition added for clarification purposes only]

(16) “Cleaning Operations” - The removal of loosely held uncured adhesives, inks, Coatings, 

or contaminants, including, but not limited to, dirt, soil, or grease, from Motor Vehicles, 

Mobile Equipment, Associated Parts and Components, substrates, parts, products, tools, 

machinery, equipment, or general work areas. [Definition derived from CARB’s SCM 

for Automotive Coatings Section 3.9]

(17) “Clear Coating” - Any coating that contains no pigments and is labeled and formulated 

for application over a Color Coating or Clear Coating. [Definition derived from CARB’s 

SCM for Automotive Coatings Section 3.10]

(918) “Coating” - a A material which is applied to a surface and which forms a film in order 

to beautify and/or protect such surface.

(19) “Coating Categories” - The table below shows Coating Categories prior to the 

05/01/2013 compliance deadline, and the corresponding Coating Categories after the 

05/01/2013 compliance deadline:

Comparison of Coating Categories

Coating Categories Prior to 05/01/2013 Coating Categories 05/01/13 and After

Adhesion Promoter Adhesion Promoter

Anti-glare Safety Coating Clear Coating, Color Coating, or SingleStage Coating

Bright Metal Trim Repair Coating Any Other Coating Type

Camouflage Color Coating

Elastomeric Materials Primer, Color Coating, Clear Coating, 

Single-stage Coating, or Underbody 

Coating

General Topcoat Single-Stage Coating

Gloss Flatteners (aka Low-Gloss Coatings) Clear Coating

Heat Resistant Primer, Color Coating, Clear Coating, or 

Single-stage Coating

Impact Resistant Coating Single-Stage Coating, Clear Coating, 

Underbody Coating, or Truck Bed Liner 

Coating
1151-6 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

Jambing Clear Coating

Metallic/Iridescent Topcoat Single-Stage Coating

Multi-Color Coatings Multi-Color Coating

Multi-Color Multi-Stage Multi-Color Coating

Multi-Color Stage System Color Coating & Clear Coating

Multi-Color Topcoat Multi-Color Coating

Precoat Primer

Pretreatment Wash Primer Pretreatment Coating

Primer Primer

Primer Sealer Primer Sealer 

Primer Surfacer Primer

Rubberized Asphaltic Underbody Underbody Coating

Single-Stage Metallic/Iridescent Coating Single-Stage Coating

Single-Stage Nonmetallic/Noniridescent 

Topcoat

Single-Stage Coating

Solid Color Topcoat Single-Stage Coating

Specialty Coatings This generic category has been 

eliminated an replaced with specific 

categories for the various coatings 

previous grouped together and are 

adressed below

Temporary Protective Coating Temporary Protective Coating

Topcoats Single-Stage Coating

Uniform Finish Blenders Uniform Finish Coating

Water Hold-Out Coating Primer

Weld-Thru Coatings Primer

(20) “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. [Definition derived from CARB’s SCM for 

Automotive Coatings Section 3.12. “Color Coating” was added to the definition to 

ARB’s comment on D2]

(10) “Commercial and Non-Commercial Coating Applications” – facilities with Coating 

operations which include, but are not limited to: autobody repair/paint shops, 

production autobody paint shops, new car dealer repair/paint shops, fleet operator 

repair/paint shops, custom-made car fabrication facilities, truck body-builders, and 

residences. [Deleted as this coating application no longer exists in CARB’s SCM for 

Automotive Coatings]
AVAQMD Rule 1151 1151-7 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(1121) “Elastomeric Materials” - Coatings which are specifically formulated and applied over 

coated or uncoated flexible plastic substrates for the purpose of adhesion.

(1222) “Electrostatic Spray Application” - a A method of applying Coatings whereby the 

atomized Coating droplets are charged and subsequently deposited on the substrate by 

electrostatic attraction. [Changes made for clarification purposes only]

(23) “Emission Control System” - Any combination of capture systems and control devices 

used to reduce VOC emissions from Automotive Coating operations. [Changes to 

definition derived from CARB’s SCM for Automotive Coatings Section3.14]

(1324) “Exempt Compounds” - those Those compounds listed in 40 CFR 51.100(sS)(1).

[Changes to definition derived from MDAQMD’s Rule 1116 Section (B)(18)]

(14) “General Topcoat” - any type of Topcoat except Metallic/Iridescent Topcoat, and any 

Topcoat applied as part of a Multistage Topcoat System. [Deleted to synchronize 

definitions with CARB’s SCM for Automotive Coatings. Definition is no longer 

necessary]

(25) “Finish” - The Coating of incomplete vehicles, their parts and components, or Mobile 

Equipment for which the original Coating was not applied from an Original Equipment 

Manufacturer (OEM) plant Coating Assembly Line. [Derived from MDAQMD’s Rule 

1116 Section (B)(19)]

(1526) “Grams oOf VOC per Liter of Coating Less Water and Less Exempt Compounds (VOC 

Content)” - the The weight of VOC per combined volume of VOC and Coating solids 

and shall be calculated by the following equation:

 

M W ES

S W ES

VOC LoC V V V

W W W G  

  / 

Grams of VOC per Liter of Coating, Less Ws - Ww - Wes

Water and Less Exempt Compounds = 

Vm - Vw - Ves
1151-8 AVAQMD Rule 1151 

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D6; 05/14/12 

Where: 

GVOC/LoC = Grams VOC/L of Coating Less Water and Exempt 

WsWS = weight of volatile compounds in grams 

WwWW = weight of water in grams 

WesWES = weight of Exempt Compounds in grams 

VmVM = volume of material in liters 

VwVW = volume of water in liters 

VesVES = volume of Exempt Compounds in liters 

[Changes are for clarification purposes only]

(1627) “Grams of VOC per Liter of Material” - the The weight of VOC per volume of material 

as calculated by the following equation:

M

S W ES

VOC LoM V

W W W G   / 

Ws - Ww - Wes

Grams of VOC per Liter of Material =

Vm

 Where: 

GVOC/LoM = Grams VOC/L of Material 

WsWS = weight of volatile compounds in grams 

WwWW = weight of water in grams 

WesWES = weight of exempt compounds in grams 

VmVM = volume of material in liters 

[Changes are for clarification purposes only]

(17) “Group I Vehicles and Equipment” - large-sized Trucks, Buses, and Mobile Equipment.

[Deleted to synchronize definitions with CARB’s SCM for Automotive Coatings. 

Definition is no longer necessary]

(18) “Group II Vehicles” - Passenger Cars, Small-Sized Trucks and Vans, Medium-Sized 

Trucks and Vans, Motor Homes, and Motorcycles. [Deleted to synchronize definitions 

with CARB’s SCM for Automotive Coatings. Definition is no longer necessary]

(28) “Group II Exempt Compounds” - Compounds that are restricted because they are either 

toxic, potentially toxic, upper-atmosphere ozone depleters, or cause other 

environmental impacts. These compounds are listed as follows:

 methylene chloride (dichloromethane)

 1,1,1-trichloroethane (methyl chloroform)

 Trichlorofluoromethane (CFC-11)
AVAQMD Rule 1151 1151-9 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

 dichlorodifluoromethane (CFC-12)

 1,1,2-trichloro-1,2,2-trifluoroethane (CFC-113)

 1,2-dichloro-1,1,2,2-tetrafluoroethane (CFC-114)

 chloropentafluoroethane (CFC-115)

 cyclic, branched, or linear, completely methylated siloxanes

 tetrachloroethylene (perchloroethylene)

 [Derived from 40 CFR 51.100(S)(1). Compounds removed from the preliminary draft version 

were removed in response to USEPA’s comment to do so.]

(1929) “High-Volume, Low-Pressure (HVLP) Spray” - an Eequipment Permanently Labeled as 

such used to apply Coatings by means of a spray gun which is designed to be operated 

and which is operated between 0.1 and 10 pounds per square inch gauge (psig) air 

pressure measured dynamically at the center of the air cap and at the air horns.

[“Permanetly Labeled” was added to the definition in response to ARB’s comment to 

do so upon the D2 review]

(20) “Highway” - a way or place of whatever nature, publicly maintained and open to the 

public for purposes of vehicular travel. Highway includes street.

(2130) “Impact Resistant Coating” - any Any Coating applied to a rocker panel for the purpose 

of chip resistance to road debris. 

(2231) “Metallic/Iridescent Color CoatingTopcoat” - a TopcoatAny Coating which contains 

iridescent particles, composed of either metal as metallic particles or silicon as mica 

particles, in excess of five (5) g/Lgrams per liter (0.042 lb/gal pounds per gallon) as 

applied, where such particles are visible in the dried film. [Changes to definition 

derived from CARB’s SCM for Automotive Coatings Section 3.18 and for clarification

purposes only.]

(23) “Midcoat” - a semi-transparent Topcoat which is the middle Topcoat applied as part of 

a Three-Stage Topcoat System. [Deleted as this coating category no longer exists in 

CARB’s SCM for Automotive Coatings]

(2432) “Mobile Equipment” - Any self-propelled equipmentdevice which is physically capable 

of being driven on a highway.may be drawn or is capable of being driven on a Roadway

or rails, including but not limited to, trains, railcars, truck bodies, truck trailers, utility 

bodies, camper shells, mobile cranes, bulldozers, street cleaners, and implements of 

husbandry or agriculture. Mobile Equipment includes, but is not limited to: 

construction (mobile crane, bulldozer, concrete mixer), farming (wheel tractor, plow, 

pesticide sprayer), and miscellaneous (street cleaners, golf carts, hauling equipment 

used inside and around an airport, dock, depot, and industrial and commercial plants).

[Changes to definition derived from CARB’s SCM for Automotive Coatings Section 

3.20 and from SJVUAPCD Rule 4612, section (3.23) and SCAQMD Rule 1151, section 

(c)(20]
1151-10 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

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(25) “Motor Home” - any Motor Vehicle originally designed, or permanently altered, and 

equipped for human habitation as defined in Section 362 of the California Vehicle 

Code. [Deleted as this definition is no longer necessary to comply with CARB’s SCM 

for Automotive Coatings]

(2633) “Motor Vehicle” - a vehicle which is self-propelled and which is physically capable of 

being driven on a Highway., including, but not limited to cars, trucks, Buses, golf carts, 

vans, Motorcycles, tanks, and armored personnel carriers. [Changes to definition 

derived from CARB’s SCM for Automotive Coatings Section 3.20]

(2734) “Motorcycle” - any Motor Vehicle other than a tractor having a seat or saddle for the 

use of the rider and designed to travel on not more than three wheels in contact with the 

ground and weighing less than 1500 pounds, except that four wheels may be in contact 

with the ground when two of the wheels are a functional part of a sidecar.

(35) “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. [Derived 

from CARB’s SCM for Automotive Coatings Section 3.21]

(2836) “Multi-Colored Multistage Topcoat System” - A Basecoat/Clearcoat Topcoat System in 

which the basecoat portion is a Multi-Colored Topcoat “Multi-Colored Topcoat” - a 

Coating which exhibits more than one color when applied, and which is packaged in a 

single container and applied in a single coat.

(29) “Multi-Colored Multistage Topcoat System” - a Basecoat/Clearcoat Topcoat System in 

which the basecoat portion is a Multi-Colored Topcoat.

(37) “Multi-Colored Topcoat” - a Coating which exhibits more than one color when applied, 

and which is packaged in a single container and applied in a single coat.

(3038) “Multistage Topcoat System” - any Any Basecoat/Clearcoat Topcoat System or any 

Three-Stage Topcoat System, manufactured as a system, and used as specified by the 

manufacturer.

(3139) “Passenger Car” - any Motor Vehicle designed primarily for transportation of persons 

and having a design capacity of 12 persons or less.

(40) “Person” - Shall have the same meaning as defined in the California Health and Safety 

Code §39047. [Derived from CARB’s SCM for Automotive Coatings Section 3.22]

(41) “Permanently Labeled” - Permanent labeling is in the form of an engraving or a plate 

permanently attached to the equipment.

(3242) “Pretreatment Coating” - a A Coating which contains no more than sixteen (16) percent 

solids, by weight, and at least one-half (0.5) 1/2-percent acid, by weight, is used to 
AVAQMD Rule 1151 1151-11 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

provide surface etching, and is applied directly to bare metal surfaces to provide 

corrosion resistance and promote adhesion for subsequent Coatings. [Changes are for 

clarification purposes only]

(3343) “Primer” - 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.a Coating applied 

for purposes of corrosion resistance or adhesion of subsequent Coatings. [Changes to 

definition derived from CARB’s SCM for Automotive Coatings Section3.24]

(3444) “Primer Sealer” - Anya Coating which is labeled and formulated for application applied 

prior to the application of a Topcoat Color Coating for the purpose of color uniformity, 

or to promote the ability of an underlying Coating to resist penetration by the 

TopcoatColor Coating. [Changes to definition derived from CARB’s SCM for 

Automotive Coatings Section3.25]

(3545) “Primer Surfacer” - a A Coating applied for the purpose of corrosion resistance or 

adhesion, and which promotes a uniform surface by filling in surface imperfections.

(46) “Reducer” - Any volatile liquid used to reduce the viscosity of the Coating, but not used 

for Cleaning Operations. This liquid may be solvents, diluents, or both, and may also 

be referred to as a thinner. [Derived from MDAQMD’s Rule1116, Section (B)(32). 

Changes to this definition made in response to ARB’s comment on D2. Additional 

changes added to distinguish Reducer solvents from cleaning solvents added in 

response to ACA comments of D2.]

(47) “Refinishing” - Any Coating of Motor Vehicles, their Associated 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.

[Derived from MDAQMD’s Rule1116, Section (B)(33)]

(48) “Roadway” - A way or place used for purposes of vehicular travel. [definition was 

changed from “Highway” to “Roadway” and modified to ensure the definition of 

“Mobile Equipment” is not affected by the use of roads.]

(3649) “Rocker Panel” - the The panel area of a Motor Vehicle which is no more than ten 

inches from the bottom of a door, quarter panel or fender. 

(3750) “Rubberized Asphaltic Underbody Coating” - a A Coating applied to wheel wells, the 

inside of door panels or fenders, the underside of a trunk or hood, or the underside of 

the Motor Vehicle itself, for the purpose of sound deadening or protection.

(51) Single-Stage Coating” – Any pigmented coating, excluding Primers and Multi-Color 

coatings, labeled and formulated for application without a subsequent clear coat. 
1151-12 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

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Single-stage coatings include single-stage metallic/iridescent Coatings. [Added to 

conform with SCM, section 3.26]

(3852) “Solvent Cleaning Operations” - the The removal of loosely held uncured adhesives, 

uncured inks, uncured Coatings, and contaminants which include, but are not limited to, 

dirt, soil, and grease from parts, products, tools, machinery, equipment, and general 

work areas. Each distinct method of cleaning in a cleaning process which consists of a 

series of cleaning methods shall constitute a separate Solvent Cleaning Operation. 

(3953) “Specialty Coating” - Aany of the following Coatings: Adhesion Promoters, Uniform 

Finish Blenders, Elastomeric Materials, Anti-Glare Safety Coatings, Impact Resistant 

Coatings, Rubberized Asphaltic Underbody Coatings, Water Hold-Out Coatings, WeldThru Coatings, and Bright Metal Trim Repair Coatings. 

(4054) “Spot Repairs” - Repair of an area on a motor vehicle, piece or mobile equipment, or

associated parts or components of less than an entire panel.repairs to Motor Vehicles in 

which the damaged area to be repaired is limited to only a portion of any given panel so 

that an entire panel need not be repaired. [Change in definition was made in response to 

comment from the American Coatings Association requesting this language to better 

reflect the rationale behind spot repair.]]

(55) “Stripping” - The use of solvent to remove material such as cured adhesives, cured inks, 

cured or dried paint, cured or dried paint residue, or Temporary Protective Coatings. 

[Derived from SJVUAPCD Rule 4612, section (3.36)]

(4156) “Stencil Coating” - an An ink or a pigmented Coating which is rolled or brushed onto a 

template or a stamp in order to add identifying letters, symbols, and/or numbers to 

Motor Vehicles, Mobile Equipment, or their parts and components. 

(57) “Targeted HAP Compounds”- The Hazardous Air Pollutant (HAP) compounds of 

chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium (Cd) targeted by 

40 CFR 63 Subpart HHHHHH – National Emission Standards for Hazardous Air 

Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area 

Sources. [Definition added to comply with 40 CFR 60 Subpart 6H]

(42) “Three-Stage Topcoat System” - a Topcoat system composed of a Basecoat portion, a 

Midcoat portion and a transparent Clearcoat portion. The VOC content of a ThreeStage Topcoat System shall be calculated according to the following formula:

 VOCbc + VOCmc + 2 VOCcc

VOCms =

4
AVAQMD Rule 1151 1151-13 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

 Where:

VOCms = the composite VOC content, less water and less exempt 

compounds, to be used for compliance determination under 

the Multistage Topcoat System Coating category.

VOCbc = the VOC content, less water and less exempt compounds as 

applied, of any given Basecoat.

VOCmc = the VOC content, less water and less exempt compounds as 

applied, of any given Midcoat.

2 VOCcc = two times the VOC content, less water and less exempt 

compounds as applied, of any given Clearcoat.

(58) “Temporary Protective Coatings” - Any Coating which is labeled and formulated for 

the purpose of temporarily protecting areas form overspray or mechanical damage. 

[Derived from CARB’s SCM for Automotive Coatings Section3.29]

(4359) “Topcoat” -– Any Coating applied over a Primer, Primer System or an original OEM 

Finish a Coating applied over any Coating, for the purpose of appearance, 

identification, or protection.

[The definition of “Touch-up” was deleted from this rule as requested by ARB upon their 

review of D2]

(44) “Touch-Up Coating” - a Coating applied by brush, air-brush, or non-refillable aerosol 

can to cover minor surface damage and dispensed in containers of no more than eight 

(8) ounces.

(4560) “Transfer Efficiency” - Tthe ratio of the weight of Coating solids deposited on an object 

to the total weight of Coating solids used in a Coating application step, expressed as a 

percentage. 

(4661) “Truck” - Aa Motor Vehicle designed, used, or maintained primarily for the 

transportation of property. 

(a) “Large-Sized Truck” - a A Truck having a manufacturer's gross vehicle weight 

rating of more than 8600 pounds. 

(b) “Medium-Sized Truck” - a A Truck having a manufacturer's gross vehicle 

weight of 6001 to 8600 pounds. 

(c) “Small-Sized Truck” - any Any Motor Vehicle having a manufacturer's gross 

vehicle weight rating at 6000 pounds or less and which is designed primarily for 

the purposes of transportation of property or is a derivative of such vehicle, or is 

available with special features enabling on-street or off-highway operation and 

use.
1151-14 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(62) “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. [Derived from CARB’s SCM for Automotive Coatings 

Section3.31. “Clear” was added in this definition upon the request of ARB of D2 

review.]

(63) “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.[Derived from CARB’s SCM for Automotive Coatings 

Section3.32]

(4764) “Uniform Finish Blenders” - Any Coating labeled and formulated for applications 

which are applied into the area around a Spot Repairs for the purpose of blending a 

repaired area’s color or clear coat to match the appearance of of an adjacent area’s 

existing Coating.paint overspray area of a repaired Topcoat to match the appearance of 

an adjacent existing Topcoat. On and after 07/01/12 this Coating Category will be 

referred to as Uniform Finish Coating. [The changes in this definition were made in 

response to ARB’s comment of D2 to limit confusion between the definition of “ 

Uniform Finish Blenders” and “Uniform Finish Coating”.]

(65) “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. Prior to 07/01/12 

this Coating Category may be referred to as Uniform Finish Blenders. [The changes in 

this definition were made in response to ARB’s comment of D2 to limit confusion 

between the definition of “ Uniform Finish Blenders” and “Uniform Finish Coating”.]

[Changes to definition derived from CARB’s SCM for Automotive Coatings, Section 3.33]

(4866) “Van” - a closed Truck for carrying property or persons. 

(a) “Medium-Sized Van” - a A Van having a manufacturer's gross vehicle weight 

rating of 6001 to 8600 pounds. 

(b) “Small-Sized Van” - Aa Van having a manufacturer's gross vehicle weight 

rating at 6000 pounds or less and which is designed primarily for purposes of 

transportation of property and/or persons. 

(4967) “Vehicle” - a device by which any person or property may be propelled, moved, or 

drawn upon a HighwayRoadway, excepting a device moved exclusively by human 

power or used exclusively upon stationary rails or tracks.

(68) “VOC Actual” - This definition is the same as the definition of Grams of VOC per Liter 

of Material as listed under subsection (B)(27). [Definition derived from CARB’s SCM 

for Automotive Coatings, Section 3.36.2]
AVAQMD Rule 1151 1151-15 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(69) “VOC Regulatory” - This definition is the same as the definition of Grams of VOC per 

Liter of Coating Less Water and Less Exempt Compounds as listed under subsection 

(B)(26). [Definition derived from CARB’s SCM for Automotive Coatings, Section 

3.36.1]

(5070) “Volatile Organic Compound (VOC)” -– Aany volatile compound containing the 

element carbon, excluding methane, carbon monoxide, carbon dioxide, carbonic acid, 

metallic carbides or carbonates, ammonium carbonate, and Exempt Compounds. 

(51) “VOC per Volume of Applied Solids” – the weight of VOC per volume of applied 

Coating solids, as calculated by the following equation:

Lbs. VOC per WPG * (100 - %NVw - %NOVw - %EVw)

Gallon of Solids = ______________________________________________ 

%NVv

Where:

WPG = weight of a gallon of Coating in pounds

%NVw = percent by weight of non-volatile compounds

%NOV

w

= percent by weight of non-organic volatile compounds

%Evw = percent by weight of Exempt Compounds

%NVv = percent by volume of non-volatile compounds

 [Definition deleted as no longer necessary to conform with CARB’s SCM for Automotive 

Coatings]

(5271) “Water Hold-Out Coating” - a A Coating applied to the interior cavity areas of doors, 

quarterpanels and rocker panels for the purpose of corrosion resistance to prolonged 

water exposure. 

(5372) “Weld-Thru Coating” - a A Coating applied to metal immediately prior to welding to 

provide corrosion resistance. 

(C) Requirements 

(1) VOC Content of Coatings 

(a) Effective on the dates specified, a person shall not apply Coating to a Motor 

Vehicle, Mobile Equipment, or Associated Parts or Components, that has a 

VOC content in excess of the limits contained in Table 1 and Table 2 of this 

subsection except as provided in Section (C)(3)(a) or (b).A person shall not 

apply a Coating to Group I Vehicles and Equipment, and Group II Vehicles, or 

their parts and components, which has a VOC content which exceeds the limits 

contained in subparagraphs (C)(1)(a) and (C)(1)(b). Compliance with the VOC 
1151-16 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

limits shall be based on VOC content, including any VOC material added to the 

original Coating supplied by the manufacturer, less water and Exempt 

Compounds, as applied to the Vehicle, Mobile Equipment, or parts and 

components. [Changes derived from CARB’s SCM for Automotive Coatings, 

Section 4.1] 

(i) Group I Vehicles and Equipment

1. A person who applies Coatings to Group I Vehicles and 

Equipment, or their parts or components, shall not apply a 

Coating which has a VOC content in excess of the limits in Table 

1.

TABLE 1 Table 1 - Coating Categories and VOC Limits

VOC Regulatory Limit, as applied, in grams 

per Liter (pounds per gallon)

Coating Categories Effective on and after 05/01/13

Adhesion Promoter 540 (4.5)

Clear Coating 250 (2.1)

Color Coating 420 (3.5)

Multi-color Coating 680 (5.7)

Pretreatment Coating 660 (5.5)

Primer 250 (2.1)

Primer Sealer 250 (2.1)

Single-stage Coating 340 (2.8)

Temporary Protective Coating 60 (0.5)

Truck Bed Liner Coating 310 (2.6)

Underbody Coating 430 (3.6)

Uniform Finish Coating 540 (4.5)

Any Other Coating Type 250 (2.1)

 [Changes derived from CARB’s SCM for Automotive Coatings, Section 4.1. The extended Singlestage Coating VOC compliance date was removed in response ARB’s comment to do so upon review of 

D2. The Vinyl Interior Coating category was also deleted in response to ARB’s comment for removal 

upon review of D2]

COATING VOC LIMITS

Grams per Liter of Coating,

Less Water and Exempt 

Compounds

on and after January 1, 1997

g/L lb/gal
AVAQMD Rule 1151 1151-17 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

COATING VOC LIMITS

Grams per Liter of Coating,

Less Water and Exempt 

Compounds

on and after January 1, 1997

Pretreatment 780 6.5

Primer/Primer Surfacer/ 

Primer Sealer

250 2.1

Topcoats

General 340 2.8

Metallic/Iridescent 340 2.8

Multi-Colored 680 5.7

Multistage 340 2.8

Specialty Coating 840 7.0

[Changes derived from CARB’s SCM for Automotive Coatings, Section 4.1]

(ii) Group II Vehicles

1. A person who applies Coatings to Group II Vehicles, or their 

parts or components, except the application of Multistage 

Topcoat Systems to Motor Homes as part of their original 

production, shall not apply a Coating which has a VOC content 

in excess of the limits in Table 2.

TABLE 2

COATING VOC LIMITS

Grams per Liter of Coating, Less Water and Exempt 

Compounds

On and After July 20, 1999 On and After July 1, 

2000

g/L lb/gal g/L lb/gal

Pretreatment 780 6.5 780 6.5

Primer/Primer Surfacer 250 2.1 250 2.1

Primer Sealer 340 2.8 340 2.8

Topcoats

General 420 3.5 420 3.5

Metallic/Iridescent 420 3.5 420 3.5

Multi-Colored 680 5.7 680 5.7

Multistage System 540 4.5 420 3.5

Multi-Colored 

Multistage

420 3.5 420 3.5

Specialty Coating 840 7.0 840 7.0

2. A person who applies Coatings to Motor Homes and/or their 

parts and components as part of their original production shall 
1151-18 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

not apply any Multistage Topcoat System that results in VOC per 

Volume of Applied Solids in excess of 15.0 lb/gal. 

Table 2 - Coating Categories and VOC Limits

VOC Regulatory Limit, as applied,

 in grams per Liter (pounds per gallon)

Coating Categories Group 1* Vehicles prior to

05/01/13

Group 2** vehicles prior 

to 05/01/13

Pretreatment Wash Primer 780 (6.5) 780 (6.5)

Primer/Primer Surfacer/ Primer 

Sealer 250 (2.1) 250 (2.1)

Primer Sealer 250 (2.1) 340 (2.8)

Topcoat

 General 340 (2.8) 420 (3.5)

 Metallic/Iridescent 340 (2.8) 420 (3.5)

 Multi-Colored 680 (5.7) 680 (5.7)

 Multistage 340 (2.8) 420 (3.5)

Specialty Coatings 840 (7.0) 840 (7.0)

*Group 1 Vehicles are public transit buses and mobile equipment including but not limited to: truck 

bodies, truck trailers, utility bodies, camper shells, mobile cranes, bulldozers, street cleaners, golf 

carts, and implements of husbandry, where color match is not required.

**Group 2 Vehicles are passenger cars; large/heavy duty truck cabs and chassis with a manufacturer's 

gross vehicle weight over 10,000 pounds; light and medium duty trucks and vans having a 

manufacturer's gross vehicle weight rating of 10,000 pounds or less; and motorcycles; and Group 1 

Vehicles where color match is required.

[Table 2 inserted to maintain current Rule limits until the limits of CARB’s SCM for Automotive 

Coatings come in to effect]

(b) Compliance with the VOC limits shall be based on VOC Content, including any 

VOC material added to the original coating supplied by the manufacturer, less

water and Exempt Compounds, as applied to the Motor Vehicle, Mobile 

Equipment, or Associated Parts or Components (please, refer to subsection 

(B)(26) for the calculation of VOC Content). [Derived from SCAQMD Rule 

1151, section (d)(1). Additional reference to (B)(26) was added in response to 

USEPA’s comment on the preliminary draft suggesting to add reference.]

(2) Most Restrictive VOC Limit

(a) 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, any 

representation is made that indicates that the Coating meets the definition of, or 

is recommended for use of, more than one of the Coating categories listed in 

subsection (C)(1)(a) and (b), then the lowest applicable VOC content limit in 
AVAQMD Rule 1151 1151-19 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

Table 1 and Table 2 shall apply. [Derived from CARB’s SCM for Automotive 

Coatings, Section 4.2].

(3) Alternative Compliance

(a) Emission Control System

 A person may comply with the provisions of section (C)(1) by using an 

approved Emission Control System consisting of collection and control devices, 

that is approved, in writing, by the APCO for reducing emissions of VOC. The 

APCO shall approve such Emission Control Systems only if the Emission 

Control System demonstrates a control efficiency of at least 85 percent. The 

required efficiency of an Emission Control System at which an equivalent or 

greater level of VOC emission reduction will be achieved shall be calculated by 

the following equation: [The reference to achieving a control efficiency of at 

least 85% has been included specifically in the second draft due to USEPA’s 

comment requesting the specific limit be designated in rule language in this 

section.]

 100

1

1

1 ,

,

,









































































































  

D

VOC

D

VOC

VOC

VOC

c

LWc

n Max

LWn Max

LWn Max

LWc CE

 

 Where:

 CE = Control Efficiency, percent

 VOCLWc = VOC Limit of Rule 1116, less water and less 

 Exempt Compounds, pursuant to Section C.1.

 VOCLWn,Max = Maximum VOC content of non-compliant 

 Automotive Coating used in conjunction with a 

 control device, less water and Exempt 

 Compounds.

 Dn,Max = Density of VOC solvent, Reducer, or thinner 

 contained in the non-compliant Automotive 

 Coating containing the maximum VOC.

 Dc = Density of corresponding VOC solvent, Reducer, 

 or thinner used in the compliant Automotive 

 Coating system = 880g/L.

(b) Alternative Emission Control Plan
1151-20 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

 A person may comply with the provisions of paragraph (C)(1)(a) by means of an Alternative 

Emissions Control Plan, pursuant to Rule 108 – Alternative Emissions Control Plans. [Derived from 

SCAQMD Rule 1151, section (d)(4)(A) and CARB’s Suggested Control Measure for Automotive 

Coatings section (4.3)]

(4) Prohibited Compounds

(a) A Person shall not manufacture, sell, offer for sale, distribute for use in the District, or apply 

any Automotive Coating which contains any Group II Exempt Compounds, as defined in subsection 

(B)(28). [Derived from 40 CFR 51.100(s)(1). Compounds removed from the preliminary draft version

were removed in response to USEPA’s comment to do so.]

(25) Carcinogenic Materials 

(a) A person shall not manufactureapply Automotive Coatings in which cadmium 

or hexavalent chromium was introduced as a pigment or as an agent to impart 

any property or characteristic to the Coatings during manufacturing, 

distribution, or use of the applicable Coatings.Coatings as defined by the Air 

Toxic Control Measure (ATCM) for Emissions of Hexavalent Chromium and 

Cadmium from Motor Vehicle and Mobile Equipment Coatings, Title 17 CCR, 

section 93112. [Derived from SCAQMD Rule 1151, section (d)(6)and ATCM: 

Title 17 CCR, section 93112].

(36) Transfer EfficiencyApplication Methods [Change made for clarification purposes only]

(a) Except for Underbody Coatings, graphic arts operations, Truck Bed Liner 

Coatings, or any Coating use of less than one (1.0) fluid ounce (29.6 milliliters), 

noA person shall not apply any Coatings except to Motor Vehicles or Mobile 

Equipment or their Associated Parts and Components unless by the use of one of 

the following methods:[Changes added in response to EPA’s comment to 

include the exception of Underbody Coatings, graphic arts, Truck Bed Liner 

Coatings and Coating use of less than one fluid ounce.]

(i) Brush, dip, or roller; or, [Added to conform with SCM, section 4.7.1]

(ii) electrostatic Electrostatic Aapplication equipment, operated in 

accordance with the manufacturer’s recommendations and in compliance 

with permit conditions;, or, 

(iii) (ii) High-Volume, Low-Pressure (HVLP) Spray, oroperated in 

accordance with the manufacturer’s recommendations and in compliance 

with permit conditions; or,

 a. No Person shall sell or offer for sale, for Automotive Refinishing 

use within the District, any HVLP spray gun without a permanent 

marking denoting the maximum inlet air pressure in pounds per square 

inch gauge (psig) at which the gun will operate within the parameters 

specified in Section (B)(29).

 b. If an Automotive Refinishing gun is not Permanently Labeled, 

the operator must demonstrate that the gun meets the HVLP definition in 
AVAQMD Rule 1151 1151-21 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

Section (B)(29) 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 for the gun using an 

air pressure tip gauge designed specifically for the gun in use. [These 

subsections were added in response to EPA’s comment to do so from the 

review of Draft 2]

(ivii) Any other Coating application which has been demonstrated to the 

satisfaction of the APCO to be capable of achieving a Transfer 

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

subsections (C)(6)(a)(i) and (C)(6)(a)(ii) above, but not less than 65 

percent, as per subsections (G)(2)(e) and (G)(2)(k),such other Coating 

application methods as are demonstrated, in accordance with the 

provisions of subsection (F)(1)(e), to be capable of achieving equivalent 

or better transfer efficiency than the Coating application method listed in 

subsection (C)(3)(a)(ii), and for which written approval of the Air 

Pollution Control OfficerAPCO has been obtained.[Changes derived 

from CARB’s SCM for Automotive coatings, Section 4.7 and 

MDAQMD’s Rule 1116, Section (C)(6)(a)]

(b) A person shall not apply Coatings by any of the methods listed in subparagraph 

(C)(3)(a) unless the Coating is applied with properly operating equipment, 

operated according to procedures recommended by the manufacturer. [Deleted 

as this language as been reworded in the above subsections]

(47) Surface Preparation and Cleaning OperationsSolvent Cleaning Operations; Storage and 

Disposal of VOC-containing Materials [Change incorporated for clarification purposes 

only]

(a) Solvent cleaning of application equipment, parts, products, tools, machinery, 

equipment, general work areas, and the storage and disposal of VOC-containing 

materials used in cleaning operations shall be carried out pursuant to Rule 1171 

- Solvent Cleaning Operations.

(a) The requirements of this subsection shall apply to any Person using solvent for 

Surface Preparation and Cleaning Operations.

(i) Any Person shall not use an organic compound(s), or mixture thereof, 

(excluding Exempt Compounds) for Surface Preparation and Cleaning 

Operations with a VOC content in excess of twenty-five (25) grams per 

liter (0.21 pounds per gallon) of material.

 1. Cleaning with aerosol solvent products shall not be subject to the 

provisions of subsection (C)(7)(a) if 160 fluid ounces or less of aerosol 

solvent products are used per day, per facility. [Aerosol solvent product 
1151-22 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

exemption added in response to ACA comment of review of D2. This 

exemption is from SCAQMD Rule 1171].

(ii) Any Person shall use closed, non-absorbent containers for the storage or 

disposal of any applicator (including brushes, swabs, cloth or paper) 

used for solvent Surface Preparation and Cleaning Operations.

(iii) Any Person shall store all Automotive Coatings, Coating components, 

and fresh or spent solvent in vapor tight and closed containers, except 

while adding or removing them from the containers. [This subsection 

was expanded to include all automotive coatings and components in 

response to EPA’s comment to do so upon review of draft 2]

(iv) Any Person shall not use organic compounds for the Cleaning 

Operations of spray equipment including paint liners unless an enclosed 

system is used for Cleaning Operations. The system shall enclose spray 

guns, cups, nozzles, bowls, and other parts during washing, rinsing and 

draining procedures. Equipment used shall minimize the evaporation of 

organic compounds to the atmosphere. [Changes made to conform with 

the requirements of CARB’s SCM for Automotive Coatings. The old 

solvent VOC requirements referenced in AVAQMD Rule 1171 are less 

stringent than the SCM, therefore, the reference in this rule has been 

removed.]

(b) Effective May 1, 2013, no Person shall possess at any Automotive Refinishing 

Facility, any solvent used for Surface Preparation and Cleaning Operations with 

a VOC content that does not comply with the requirements in subsection 

(C)(7)(a)(i). [Changes made to conform to the requirements of CARB’s SCM for 

Automotive Coatings section 4.4. The old solvent VOC requirements referenced

in AVAQMD Rule 1171 are less stringent than the SCM, therefore, the reference 

in this rule has been removed.]

(5) Approved Emission Control System

(a) A person may comply with the provisions of subsection (C)(1)(a), by using an 

approved emission control system, consisting of collection and control devices, 

which is approved, in writing, by the Air Pollution Control Officer for reducing 

emissions of VOC. The Air Pollution Control Officer shall approve such 

emission control system only if the VOC emissions resulting from the use of 

non-compliant Coatings will be reduced to a level equivalent to or lower than 

that which would have been achieved by the compliance with the terms of 

paragraph (C)(1)(a). The required efficiency of an emission control system at 

which an equivalent or greater level of VOC emission reduction will be 

achieved shall be calculated by the following equation: [This section has been 

moved to Section (C)(3)]
AVAQMD Rule 1151 1151-23 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(VOCLWc) 1 - (VOCLWn,Max/Dn,Max)

C.E. = 1 - _____________ X _______________________ X 100

(VOCLWn,Max) 1 - (VOCLWc/Dc)

Where:

C.E. = Control Efficiency, percent

VOCLWc = VOC Limit of Rule 1151, less water and less 

Exempt Compounds, pursuant to paragraph (c)(1).

VOCLWn,Max = Maximum VOC content of non-compliant Coating 

used in conjunction with a control device, less 

water and Exempt Compounds.

Dn,Max = Density of VOC solvent, reducer, or thinner

contained in the non-compliant Coating containing 

the maximum VOC.

Dc = Density of corresponding VOC solvent, reducer, or 

thinner used in the compliant Coating system = 

880 g/L.

(6) Alternative Emission Control Plan[This section has been moved to Section (C)(3)]

(a) A person may comply with the provisions of paragraph (c)(1) by means of an 

Alternative Emission Control Plan (AECP), pursuant to Rule 108.

(78) Prohibition of Possession, Specification and Sale 

(a) No person shall solicit from, or require any other person to use in the District 

any Coating which, when applied as supplied or thinned or reduced according to 

the manufacturer's recommendation for application, does not meet the applicable 

VOC limits required by subsection (C)(1)(a) for the specific application, or does 

not meet the requirements of subsection (C)(2)(a). [Deletion made here as these 

requirements have been re-worded and expanded to comply with CARB’s SCM 

for Automotive Coatings Sections 4.4, 4.5, 4.6, and 5.6.]

(ab) No Pperson subject to this rule shall posses any Automotive Coating that is not 

in compliance with the requirements of subsection (C)(1), unless one or more of 

the following conditions apply: shall offer for sale, sell, or distribute for use in 

the District any Coating which, when applied as supplied or thinned or reduced 

according to the manufacturer's recommendation for application, does not meet 

the applicable VOC limits required by subsection (C)(1)(a) for the specific 

application, or does not meet the requirements of subsection (C)(2).
1151-24 AVAQMD Rule 1151 

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(i) The Coating is located at a facility that utilizes an approved Emission 

Control System pursuant to subsection (C)(3)(a), and the Coating meets 

the limits specified in permit conditions.

(ii) The Coating is located at a facility that operates in compliance with an 

approved Alternative Emissions Control Plan pursuant to subsection

(C)(3)(b), and the Coating is specified in the plan.

(iii) The Coating is located at a training center and the Coating is used for 

educational purposes, provided that the VOC emissions from Coatings 

not meeting VOC limits of section (C)(1) do not exceed twelve (12) 

pounds per day. 

(iv) The Coating is located at a prototype Motor Vehicle manufacturing 

facility and the Coating is supplied by an assembly-line Motor Vehicle 

manufacturer for use in the Refinishing of a prototype Motor Vehicle, 

provided that the VOC emissions from Coatings not meeting the VOC 

limits of section (C)(1) do not exceed twenty-one (21) pounds per day 

and 930 pounds in any one calendar year. [Changes derived from 

CARB’s SCM for Automotive Coatings section 4.4 and SJVUAPCD Rule 

4612, section (5.5)]

(bc) No person shall solicit from, or require any other Person to use, offer for sale to, 

sell to, or distribute to any other person for use in the District any Automotive 

Coating or solventapplication equipmentwhich, when applied as supplied or 

thinned or reduced according to the manufacturer’s recommendation for 

application, which does not meet the requirements of subsection (C)(3)(a).does 

not meet the:

(i) Applicable VOC limits required by subsection (C)(1) for that specific 

application unless:

a. The Coating is located at a Automotive Refinishing Facility that 

utilizes an approved Emission Control System pursuant to 

subsection (C)(3)(a), and the Coating meets the limits specified 

in permit conditions.

b. The Coating is specifically exempt pursuant to section (D) of this 

rule. [Changes derived from CARB’s SCM for Automotive 

Coatings sections4.5 and 4.6]

(ii) Applicable VOC limits for solvent for Surface Preparation and Cleanup 

Operations pursuant to section (C)(7). [Subsection added in response to 

EPA’s comment to do so upon review of Draft 2 to include solvents in 

this section.]

(c) No Person shall manufacture, blend, supply, repackage for sale, offer for sale, 

sell, or distribute for use in the District any Automotive Coating which, when 

applied as supplied or thinned or reduced according to the manufacturer’s 

recommendation for application, does not meet the [Language was added to 
AVAQMD Rule 1151 1151-25 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

inclue, “manufacture, blend, supply, repackage for sale” in response to EPA’s 

comment to do so upon review of Draft 2]:

(i) Applicable VOC limits required by subsection (C)(1) for the specific 

application, unless:

a. The Coating is located at an Automotive Refinishing Facility that 

utilizes an approved Emission Control System pursuant to 

subsection (C)(3)(a), and the Coating meets the limits specified 

in permit conditions.

b. The Coating is specifically exempt under section (D) of this rule.

c. The Person that offers for sale or distributes the Coating keeps 

the following records for at least five (5) years and makes them 

available to the APCO upon request, the following information:

1. Coating name and manufacturer;

2. Application method;

3. Automotive Coating Category and mix ratio specific to 

the Coating;

4. VOC content of Coating;

5. Documentation that the material is a Coating;

6. Current manufacturer specification sheets, material safety 

data sheets (MSDS), technical data sheets, or air quality 

data sheets, which list the VOC content of each ready-tospray Coating (based on the manufacturer’s stated mix 

ratio), Automotive Coating Components, and VOC 

content of each solvent;

7. Purchase records identifying the Automotive Coating 

category, name, and volume of Coatings; and,

8. The name and address of the Person purchasing the 

Coating, a statement of the basis the purchase will comply 

with this paragraph, including if use is for outside the 

District, and acknowledgement by the purchaser that this 

statement is correct. [Changes derived from SJVUAPCD 

Rule 4612, section (5.7) and CARB’s SCM for Automotive 

Coatings, section 4.5 and 4.6]

(ii) Requirements of subsections (C)(4) and (C)(5). [Changes derived from 

SJVUAPCD Rule 4612, section (5.7) and CARB’s SCM for Automotive 

Coatings, section 4.5 and 4.6 

(d) No Pperson shall solicit from, require, offer for sale to, sell to, or distribute to 

any other Person for the use in the District any Automotive Coating application 

equipment that does not meet the requirements of subsection (C)(6).an HVLP 

spray gun unless the person offering for sale, selling, or distributing the HVLP 

spray gun provides accurate information to the spray gun recipient on the 
1151-26 AVAQMD Rule 1151 

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D6; 05/14/12 

maximum inlet air pressure to the spray gun which would result in a maximum 

10 pounds per square inch gauge air pressure measured dynamically at the 

center of the air cap and the air horns. The information shall be permanently 

marked on the gun, or provided on the company's letterhead or in the form of 

technical literature which clearly identifies the spray gun manufacturer, the 

salesperson, or the distributor. [Changes made for simplification and 

clarification purposes only]

(e) The requirements of subsections (C)(71), (C)(2), and (C)(3)(a)-(d) shall apply to 

all written or oral agreements executed and entered into under the terms of 

which an Automotive Coating or a Coating application equipment shall be used 

at any location within the District. [Changes made for clarification purposes 

only].

(D) Exemptions 

(1) The provisions of subsections (C)(1)(a) and (C)(4) of this rule shall not apply to: 

(a) Touch-Up Coatings. [Deleted as this is addressed in section (D)(1)(e) below]

(a) Any Coating applied to Motor Vehicle or Mobile Equipment, or their 

Associated Parts and Components, during manufacture on an Assembly Line.

(b) Any Automotive Coating that is offered for sale, sold, or manufactured for use 

outside of the District or for shipment to other manufacturers for reformulation 

or repackaging. [Change derived from CARB’s SCM for Automotive Coatings, 

section 2.2.1]

(bc) Any Stencil Coatings Product.

(d) Any Aerosol Coating Product. [Change derived from CARB’s SCM for 

Automotive Coatings, section 2.2.2]

(e) Any Automotive Coating that is sold, supplied, or offered for sale in one-half 

(0.5) fluid ounce or smaller containers. [Change derived from CARB’s SCM for 

Automotive Coatings, section 2.2.3]

(2) The prohibitions specified in subsection (C)(7) shall not apply to Coatings or spray 

equipment which will be used solely outside of the District. [Deleted as it has been 

moved to subsection (D)(1)(b) above]
AVAQMD Rule 1151 1151-27 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(32) The prohibitions specified in subsections (C)(78)(a) or (b) shall not apply to persons 

offering for sale to, selling to, distributing to, or requiring other persons who are 

operating an approved emission Emission control Control system System under 

subsection (C)(53)(a), or complying under subsection (C)(63)(b), or operating pursuant 

to subsection (D)(43). 

(43) The requirements of subsection (C)(1)(a) shall not apply to Coatings applied for 

educational purposes at Coating training centers, which are owned and operated by 

Coating manufacturers, provided that the VOC emissions emitted at a Coating training 

center from Coatings not complying with subsection (C)(1)(a) do not exceed twelve 

(12) pounds per day.

(4) The requirements of subsection (C)(1) shall not apply to Coatings located at a prototype 

Motor Vehicle manufacturing facility and the Coating is supplied by an assembly-line 

Motor Vehicle manufacturer for use in the Refinishing of a prototype Motor Vehicle, 

provided that the VOC emissions from Coatings not meeting the VOC limits of section 

(C)(1) do not exceed twenty-one (21) pounds per day and 930 pounds in any one 

calendar [Changes made to reconcile this subsection with subsection (C)(8)(iv) in 

response to EPA’s comment to do so upon review of Draft 2]

(5) Any facility or Person classified as exempt or claiming to be exempt under this section, 

(D), shall meet the record keeping requirements of this rule so as to be able to prove the 

exemption status. [Added for enforcement purposes]

(6) Rule 442 Applicability

(a) Any Coating, Coating operation, or facility which is exempt from all or a 

portion of the VOC limits of this rule shall comply with the provisions of Rule 

442 if applicable. [Moved from Section G. The words, “if applicable” were 

added to clarify that exempt coatings/solvents from this rule may apply to Rule 

442. This was made in response to USEPA comment requesting clarification]

(5) The provisions of this rule shall not apply to Aerosol Coating Products.[Requirement 

has been moved to subsection (D)(1)(d) 

(6) For Spot Repairs on Group I Vehicles and Equipment, the Grams of VOC per Liter of 

Coating Less Water and Exempt Compounds limits for Metallic/Iridescent and 

Multistage Topcoats are 3.5 lb/gal. [Deleted as VOC limits for Spot Repairs are the 

same as VOC limits for any Automotive Refinishing repair]
1151-28 AVAQMD Rule 1151 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

(E) Administrative Requirements [Section added to conform with CARB’s SCM for 

Automotive Coatings, section 5]

(1) Manufacturer’s Compliance Statement Requirement [Section added to conform with 

CARB’s SCM for Automotive Coatings, section 5.1]

(a) For each individual Automotive Coating, Automotive Coating Component, and 

ready-to-spray mixture (based on the manufacturers stated mix ratio), the 

manufacturer and/or repackager shall include the following information on a 

product data sheet, or an equivalent medium: [“Repackagers” was added to this 

subsection at the request of CARB upon review of Draft 2. Solvents was also 

included in the Manufacturer’s Complinace Statement Requirement upon the 

request of CARB.]

(i) The VOC Actual and the VOC Regulatory for Coatings (in grams per 

liter).

(ii) The weight percentage of volatiles, water, and Exempt Compounds.

(iii) The volume percentage of water and Exempt Compounds.

(iv) The density of the material (in grams per liter).

(v) The weight percentage of all Targeted HAP Compounds. [Section added 

to conform with CARB’s SCM for Automotive Coatings, section 5.1.1 to 

5.1.3. HAP requirement to ensure compliance with NESHAP 6H]

(b) For each solvent used in Solvent Cleaning Operations, the manufacturer and/or 

repackager shall include the following information on a product data sheet, or an 

equivalent medium: [“Solvent” was also included in the Manufacturer’s 

Compliance Statement Requirement upon the request of CARB. In response to 

the American Coating Association, the solvent section was separated out to only 

include the following requirement]

(i) The VOC Actual and the VOC Regulatory for Coatings (in grams per 

liter).

(2) Manufacturer’s Labeling Requirements [Section added to conform with CARB’s SCM 

for Automotive Coatings, section 5.2]

(a) The manufacturer and/or repackager of Automobile Coatings or Automotive 

Coating Components shall include, on all containers, the applicable use Coating 

Category(ies), and the VOC Actual and the VOC Regulatory for Coatings, as 

supplied (in grams per liter). [Section added to conform with CARB’s SCM for 

Automotive Coatings, section 5.2.1]

(b) The manufacturer and/or repackager of solvents subject to this rule shall include 

on all containers the VOC content for solvents, as supplied (in grams per liter)
AVAQMD Rule 1151 1151-29 

Motor Vehicle and Mobile Equipment Coating Operations 

D6; 05/14/12 

[Section added to conform with CARB’s SCM for Automotive Coatings, section 

5.2.2]

[“Repackager” was added to each of these subsections in addition to “manufacturer” 

in response to ARB’s comment on D2]

(EF) Record Keeping Requirements 

(1) Record Keeping for VOC Emissions

(a) Records of Coating usage shall be maintained pursuant to Rule 109. [This 

section has been removed and specific requirements from CARB’s SCM for 

Automotive Coatings sections 5.4, 5.5, and 5.6 have been added. The current 

Rule 109 standards are in conflict with the SCM requirements, thus this 

reference has been removed.]

(2) Record Keeping for Emission Control Systems

(a) Any person using an emission control system as a means of complying with the 

provisions of subsection (C)(1)(a) shall maintain daily records of key system 

operating and maintenance procedures which will demonstrate continuous 

operation and compliance of the emission control system during periods of 

emission producing activities. Key system operating parameters are those 

necessary to ensure compliance with VOC limits. The parameters include, but 

are not limited to, temperatures, pressures, and flow rates. [This section has 

been removed and replaced with the requirements of subsection (E)(1)(b)(iii)]

(1) All Persons subject to this rule and any Person claiming any exemption under sections

(D)(1)(a) and (D)(1)(b) shall comply with the following requirements: [This section has 

been added for enforcement purposes]

(a) Maintain and have available during an inspection, a current list of Automotive 

Coatings and solvents in use which provides all of the Coating data necessary to 

evaluate compliance, including the following information:

(i) The name and manufacturer;

(ii) The Coating Category type and the mix ratio of components used;

(iii) The VOC Actual and the VOC Regulatory content of each Automotive 

Coating as applied, or VOC content for solvent;

(iii) The Targeted HAP Compounds content as applied in weight percentage; 

and,

(v) The application method used.

[The HAP requirement is added in response to 40 CFR 63 Subpart HHHHHH –

National Emission Standards for Hazardous Air Pollutants: Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources. Section expanded 
1151-30 AVAQMD Rule 1151 

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to include solvents in response to ARB’s comment on D2. Subsection 

(F)(1)(a)(ii) was also modified to clarify the requirement of Coating Category 

type in response to ARB’s comments of D2]

(b) Maintain records on a daily basis including:

(i) Automotive Coating and mix ratio of components used in the 

Automotive Coating;

(ii) Quantity of each Automotive Coating applied;

(iii) Application method used to apply Automotive Coating; and,

(iv) Any Person/facility utilizing an add-on Emission Control System as a 

means of complying with provisions of this rule shall also maintain 

records of key system operating and maintenance data for the purpose of 

demonstrating continuous compliance during periods of emission 

producing activities. The data shall be recorded in a manner as 

prescribed by the District. [Changes from CARB’s SCM for Automotive 

Coatings, section 5.4]

(c) Maintain records on a monthly basis for Surface Preparation and Cleaning 

Operations including:

(i) The name and manufacturer of the solvent used, including methylene 

chloride (MeCl).

(i) The amount of each solvent and methylene chloride (MeCl) consumed 

for any use, in gallons.

(ii) The weight percentage of each solvent and methylene chloride (MeCl) 

consumed for any use.

[The MeCl requirement is added in response to 40 CFR 63 Subpart HHHHHH –

National Emission Standards for Hazardous Air Pollutants: Paint Stripping and 

Miscellaneous Surface Coating Operations at Area Sources.]

(d) Such records shall be retained and available for inspection by the APCO for a 

minimum of five (5) years.

(2) Any Person claiming any exemption under sections (D)(1)(c), (D)(1)(d), and (D)(1)(e)

shall comply with the following requirements: [This section has been added for 

enforcement purposes and to single out recordkeeping requirements for Aerosols, halffluid ounce, and Stencil Coatings]

(b) Maintain records on a daily basis including:

(i) Exempt product type (i.e. Stencil Coating, Aerosol Coating Product, 

half-fluid ounce Coating); 

(ii) The name and manufacturer of the exempted Coating type; and,
AVAQMD Rule 1151 1151-31 

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(iii) The amount of the exempted Coating type.

(FG) Test Methods 

(1) A violation of the limits contained in this rule as determined by any one of these test 

methods shall constitute a violation of this rule.

(2) The following specified test methods shall be used to determine compliance with the 

provisions of this rule. [Changes derived from MDAQMD 1116 for enforcement 

purposes]

(1) For the purpose of this rule, the following test methods shall be used to determine 

compliance: 

(a) VOC Content of Coatings or Solvents

(i) The VOC content of Coatings or solvents shall be determined as 

prescribed by United States Environmental Protection Agency 

Reference Method 24 (without correction for Exempt Compounds) as set 

forth in Appendix A of Title 40 of the Code of Federal Reulations (40 

CFR) Part 60, “Determination of Volatile Matter Content, Water 

Content, Density, Volume Solids, and Weight Solids of Surface 

Doatings”. and ASTM Test Method D4457-85, or ARB Method 432 for 

determination of emission of Exempt Compounds. Perfluorocarbon 

compounds shall be assumed to be absent from a product or process 

unless a manufacturer or facility operator identifies the specific 

individual compounds (from the broad classes of perfluorocarbon 

compounds) and the amounts present in the product or process and 

provides a validated test method which can be used to quantify the 

specific compounds.[Changes made to conform with CARB’s SCM for 

Automotive Coatings, section 6.4]

(b) Determination of Iridescent Particles/ in Metallic/Iridescent Topcoat Content

(i) The metal and silicon content of metallic/iridescent topcoat coatings 

shall be determined by South Coast Air Quality Management District

Method 311318-95, (Determination of Percent Metal in Metallic 

Coatings by Spectrographic Method) contained in the SCAQMD 

"Laboratory Method of Analysis for Enforcement Samples" manual.

“Determination of Weight Percent Elemental Metal in Coatings by Xray” (July 1996).[Change made to conform with requirements of CARB’s 

SCM of Automotive Coatings, section 6.7]
1151-32 AVAQMD Rule 1151 

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(c) Acid Content in Pretreatment Coatings

(i) The acid content of Pretreatment Coatings shall be determined by ASTM 

Test Method D1613-96, “Standard Test Method for Acidity in Volatile 

Solvents and Chemical Intermediates Used in Paint, Varnish, Lacquer, 

and Related Products” (May 2003). [Change made to conform with 

requirements of CARB’s SCM of Automotive Coatings, section 6.2. 

Method version was changed from preliminary draft in response to 

USEPA’s comment that this is the only version approved by EPA.]

(d) Reflectance of Anti-Glare Safety Coatings 

(i) The reflectance of Anti-Glare Safety Coatings shall be measured by 

ASTM Test Method D-23C523-89 (1989). [Test method changed in 

response to USEPA’s comment on the preliminary draft to update 

toEPA- approved version.]

(e) Transfer Efficiency 

(i) The transfer efficiency of alternative Coating application methods, as 

defined by subsection (C)(36)(a)(iii), shall be determined in accordance 

with the South Coast Air QMQuality Management District method "TE -

Spray Equipment Transfer Efficiency Test Procedure for Equipment 

User, May 24, 1989." 

(f) Equivalent Test Methods 

(i) Other test methods determined to be equivalent after review by the staffs 

of the District, California Air Resources Board, and the United States 

Environmental Protection Agency, and approved in writing by the Air 

Pollution Control Officer may also be used for methods of analysis. 

(2g) Determination of Efficiency of Emission Control Systems 

(ai) Emissions of VOCs for operations with emission Emission control 

Control systems Systems shall be measured as prescribed by EPA 

Reference Method 25, or 25A, or 25B for determining VOC emissions 

and control device efficiency, in combination with the USEPA method, 

“Guidelines for Determining Capture Efficiency” (January 9, 1995) and 

cited in 5540 CFR 51, Appendix M, Methods 204-204f as applicable

Federal Register (FR) 26865, June 29, 1990, for determination of capture 

efficiency. [Changes made to conform with CARB’s SCM for 

Automotive Coatings, section 6.5]

(h) Determination of Methyl Acetate, Acetone, and PCBTF Content
AVAQMD Rule 1151 1151-33 

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(i) The quantity of methyl acetate , acetone, t-butyl acetate, and 

parachlorobenzotrifluoride shall be determined by using ASTM Method 

D6133-02: “Standard Test Method for Acetone, pChlorobenzotrifluoride, Methyl Acetate or t-Butyl Acetate Content of 

Solventborne and Waterborne Paints, Coatings, Resins, and Raw 

materials by Direct Injection Into a Gas Chromatograph” (February 

2003). [Added to conform with CARB’s SCM for Automotive Coatings, 

section 6.1]

(i) Determination of Alternative Compliance

(i) Alternative compliance shall be determined by USEPA Method 25, 25A, 

or 25B, Title 40 CFR Part 60, Appendix A as applicable. A source is in 

violation if the measured VOC emissions, as measured by any of the test 

methods, exceed the standards specified in Section (C)(1). [Added to 

conform with CARB’s SCM for Automotive Coatings, section 6.6]

(j) Exempt Compound Content

(i) Exempt compound content, other than as determined pursuant to section 

(G)(2)(3), shall be determined by using CARB Method 432, 

“Determination of Dichloromethane and 1,1,1-Trichloroethane in Paints 

and Coatings” (September 12, 1989); CARB Method 422, 

“Determination of Volatile Organic Compounds in Emissions from 

Stationary Sources” (September 12, 1990); or, South Coast Air Quality 

Management District (SCAQMD) Method 303-91, “Determination of 

Exempt Compounds” (August 1996). [Added to conform with CARB’s 

SCM for Automotive Coatings, section 6.8. Updated test version dates in 

response to USEPA’s comments on the preliminary draft to update to 

EPA-approved versions.]

(k) HVLP Equivalency

(i) Transfer Efficiency equivalent to HVLP shall be determined by 

procedures as prescribed in the South Coast Air Quality Management 

District (SCAQMD) document "Guidelines for Demonstrating 

Equivalency with District Approved Transfer Efficient Spray Guns” 

(September 26, 2002). [Added to conform with CARB’s SCM for 

Automotive Coatings, section 6.10]

(3l) Multiple Test Methods 

(ai) When more than one test method or set of test methods are specified for 

any testing, a violation of any requirement of this rule established by any 
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one of the specified test methods or set of test methods shall constitute a 

violation of the rule. 

(G) Rule 442 Applicability

(1) Any Coating operation, subject to this rule which is exempt from all or a portion of the 

VOC limits of this rule shall comply with the provisions of Rule 442. [This section has 

been moved under section (D)(7)]

[See SIP Table at http://www.avaqmd.ca.gov/Modules/ShowDocument.aspx?documentid=921]

[SIP: Approved 04/10/00 65 FR 18901, 40 CFR 52.220(c)(270)(I)(E)(1); Submitted as amended 

03/08/96 on 07/23/96; Approved 06/13/95, 60 FR 31084, 40 CFR 52.220(c)(214)(i)(A)(1); Limited 

Approval/Disapproval 12/20/93, 58 FR 66286, 40 CFR 52.220(c)(193)(i)(A)(1)]
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AVAQMD Rule 1151 B-1

Staff Report, Final 06/04/12

APPENDIX "B" 

PUBLIC NOTICE DOCUMENTS

1. Proof of Publication for Notice of Public Hearing for original Governing Board Hearing of July 19, 

2011. 

2. Proof of Publication for Notice of Public Hearing for Governing Board Hearing of May 15, 2012. 
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APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. Email from Adrianne Borgia, USEPA, 02/22/11 

2. Email attachment from Marla Hughes, AV Paints & Supply, 04/26/11 

3. Email attachment from Marla Hughes, AV Paints & Supply, 04/27/11 

4. Comment letter from Patrick Au, CARB, 06/20/11 

5. Comment letter from American Coatings Association, 07/13/11 

6. Comments on AV 1151, Draft 3, Word Document from Marla Hughes, AV Paints & Supply 

02/08/12 

7. Email attachment from Marla Hughes, AV Paints & Supply, 02/09/12 

8. No comment letter from Patrick Au, CARB, 04/23/12 

9. Email from Adrianne Borgia, USEPA, 04/26/12 

10. Email from Emily Taylor, DPC – US Refinish, 05/09/12 

11. Letter from Marie Hobson, Counsel, Government Affairs, American Coatings Association, 

05/11/12. 
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District response to Comment Letter 1 

1. A specific subsection for what the rule does not apply to was added to the Applicability section 

or the rule as requested under subsection (A)(2)(b). 

2. The definition of CARB was added under subsection (B)(14) as requested. 

3. The following compounds were removed from the definition of Group II Exempt Compounds, 

now under subsection (B)(28) as requested: VMA, HCFC-365, HFC-161, HSF236fa, 

HFC245ca, HFC-245ea, HFC-245eb, HFC-245fa, HFC-236ea, HCFC-31, HCFC123a, and 

HCFC-151a. 

4. The referenced definitions of VOC Actual under subsection (B)(67), correctly corresponds to 

the definition of Grams of VOC per Liter of Material as listed under subsection (B)(27). 

5. The referenced definitions of VOC Regulatory under subsection (B)(68), correctly corresponds 

to the definition of Grams of VOC per Liter of Coating Less Water and Less Exempt 

Compounds as listed under subsection (B)(26). 

6. A reference under subsection (C)(1)(b) has been added to refer to the definition of Grams of 

VOC per Liter of Coating Less Water and Less Exempt Compounds as listed under subsection 

(B)(26) as requested. 

7. A statement specifically requiring at least 85 percent control efficiency has been added under 

subsection (C)(3)(a), Emission Control System, to clarity compliance with the SCM as 

requested. 

8. The definition of Group II Exempt Compounds, now under subsection (B)(28), has been 

updated to properly site 40 CFR 51.100(s)(1). 

9. The words, “if applicable” were added to clarify that exempt coatings/solvents from this rule 

may apply to Rule 442. 

10. Subsection (F)(2)(c)(i) was updated to ASTM D1613-96 as requested as it is the version 

approved currently by EPA. 

11. Subsection (F)(2)(d)(i) was updated to ASTM C523-89 as requested as it is the version 

approved currently by EPA. 

12. The letters, “TE” were added in front of the title of the method listed under subsection 

(F)(2)(e)(i) as requested. 

13. The EPA approved dates were updated in subsection (F)(2)(j) and (i) as requested. 
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District response to Comment Letter 2 

1. An extended compliance date of 07/01/13 was added to Table 1 in subsection (C)(1)(a) of Draft 

2 of the rule for the Coating Category of Single-stage Coating to allow more time for more 

readily available, cost-effective, premium products of this category as requested by the affected 

automotive coating supplier. Several of the affected facilities in the Antelope Valley AQMD 

jurisdiction rely on the knowledge and support of this particular supplier for quality, compliant 

coatings, and the District would like to maintain as smooth a transition into the new lower VOC 

limits as possible with minimal consequences for the affected sources. However, upon ARB’s 

review of the Draft 2 changes, they requested that the extended compliance date be removed, 

stating that other districts have already incorporated the SCM and that product availability is 

sufficient (see Comment Letter 4), so the AVAQMD removed the extended compliance date in 

the proposed Draft 3 of the rule. 
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District response to Comment Letter 3 

1. An additional Coating Category for Vinyl Interior Coatings was added to Table 1 in subsection 

(C)(1)(a) of Draft 2 of the rule to allow a specific VOC limit for this category in response to the 

automotive paint supplier’s comment that there is a very limited production of compliant 

coatings of this nature for the proposed limit, specifically only 11 of the 60 tints necessary. 

Several of the affected facilities in the Antelope Valley AQMD jurisdiction rely on the 

knowledge and support of this particular supplier for quality, compliant coatings, and the 

District would like to maintain as smooth a transition into the new lower VOC limits as 

possible with minimal consequences for the affected sources. However, upon ARB’s review of 

the Draft 2 changes, they requested that the additional coatings category be removed, stating 

that other districts have already incorporated the SCM and that product availability is sufficient 

(see Comment Letter 4), so the AVAQMD removed the additional coating category in the 

proposed Draft 3 of the rule. 
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District response to Comment Letter 4 

1. Section (A)(2)(b) was amended to synchronize with the exemptions of subsection (D)(1) in 

order to clarify what the rule does not apply to. 

2. Section (A)(2)(b)(iv), previously (A)(2)(b)(ii), was amended to read as follows: “Any Aerosol 

Coating Products that are in compliance with regulations and requirements adopted by the 

California Air Resources Board (CCR, Title 17, Subchapter 8.5, Section 94522).” 

3. Section (B)(8) was renumbered to (B)(7). 

4. Section (B)(7) was renumbered to (B)(8) 

5. Section (B)(19), Comparison of Coating Categories, was reworded to: “This generic category 

has been eliminated and replaced with specific categories for the various coatings previously 

grouped together and are addressed below”. 

6. Section (B)(19) has been amended to properly distinguish between the old category of 

“Adhesion Promoter” and the new category of “Primer”. 

7. Section (B)(20), Color Coating, has been amended to reflect: “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.” 

8. Section (B)(29), HVLP, has been amended to include a permanent labeling requirement. In 

addition, a definition of Permanently Labeled was added under Section (B)(41) to clarify this 

requirement. 

9. The definition of Highway was removed from the rule and the definition of Roadway was 

added under section (B)(48). 

10. The definition of Mobile Equipment was modified to include devices other than those that are 

self-propelled, and also to include those that can be drawn or driven on railways. 

11. The definitions of Multi-colored Topcoat and Multistage Topcoat have been reversed to the 

correct alpha-order. 

12. The definition of Reducer has been amended to reflect: “Any volatile liquid used to reduce the 

viscosity of the Coating. This liquid may be solvents, diluents, or both.” 

13. The definition of Touch Up has been deleted from the rule as it is not used in the rule. 

14. The definition of Truck Bed Liner Coating has been modified as follows: “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.” 
AVAQMD Rule 1151 C-17 

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15. The definitions of Uniform Finish Blenders and Uniform Finish Coating were modified to 

clarify that they are the same type of coating. Language was added to each definition to clarify 

what the proper name of the coating will be before and after 07/01/12. 

16. The term Highway was replaced throughout the rule to replace the term Roadway, which was 

deleted from the rule. 

17. The extended compliance date for Single-stage Coatings was removed in Subsection (C)(1). 

The additional Coating Category of Vinyl Interior Coatings was also removed from this 

section. 

18. Subsection (C)(6)(a) was amended to reflect, “Except for Underbody Coatings, graphic arts 

operations, Truck Bed Liner Coatings, or any Coating use of less than one (1.0) fluid ounce 

(29.6 milliliters), no person shall apply any Coating to Motor Vehicles or Mobile Equipment or 

their Associated Parts and Components unless by the use of one of the following methods:”. In 

addition, “brush, dip, and or roller” was added to the Application Methods. Specific language 

was also added to the application method of HVLP to include prohibition of sale of Automotive 

Refinishing guns without Permanently Labeled denotation of inlet air pressures, and an 

alternative compliance demonstration option for unlabeled guns. 

19. Subsection (C)(7)(iii) was expanded to include Automotive Coatings and automotive coating 

components in the requirement of keeping these items in closed, vapor-tight containers. 

20. In subsection (C)(8)(a), the word, “applies” was deleted to clarify that the prohibition is not 

only limited to those who apply coatings. 

21. The prohibition of specification was expanded to include Surface Preparation and Cleanup 

Operations in section (C)(8)(b). 

22. Subsection (C)(8)(c) was modified to include the words, “sale, sell, or distribute for use”. 

23. Subsection (D)(4) was reconciled subsection (C)(8)(iv). 

24. Subsections (E)(1)(a), (E)(2)(b), and (c) were modified to include repackagers. 

25. Subsection (E)(1)(a), Manufacturer’s Compliance Statement Requirement, was expanded to 

include solvent. 

26. Subsection (F)(1)(a) was expanded to include solvents. In addition subsection (F)(1)(a)(ii) was 

modified to clarify the requirement of Coating Category type. 
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District Response to Comment Letter 5: 

1. Subsection (C)(7)(a)(i), states that, “Any Person shall not use an organic compound(s), or 

mixture thereof, (excluding Exempt Compounds) for Surface Preparation and Cleaning 

Operations with a VOC content in excess of twenty-five (25) grams per liter (0.21 pounds per 

gallon) of material.” The definition of Cleaning Operations, subsection (B)(16) states, “The 

removal of loosely held uncured adhesives, inks, Coatings, or contaminants, including, but not 

limited to, dirt, soil, or grease, from Motor Vehicles, Mobile Equipment, Associated Parts and 

Components, substrates, parts, products, tools, machinery, equipment, or general work areas.” 

The District feels that the relation between these two sections satisfies the concern that the 

twenty-five gram per liter solvent is too low for certain cleaning and preparation operations. In 

addition, an aerosol solvent product exemption was added in subsection (C)(7)(a) to offer a 

compliant path for the need of stronger solvent use. 

2. Language was added to the definition of Reducer, subsection (B)(46), to clarify that reducing 

solvents are not synonymous with Cleaning Operation solvents. 

3. The definition of Spot Repair, subsection (B)(54), was amended to change the limit of one 

square foot to one panel as defined in BAAQMD’s Rule 45, Motor Vehicle and Mobile 

Equipment Coating Operations. 

4. Section (E)(1)(A)(v) was not modified in response to this comment, as the purpose of having a 

Target HAP Compound percentage Compliance Statement Requirement is to insure that 

requirements of 40 CFR Part 63 Subpart HHHHHH - National Emission Standards for 

Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at 

Area Sources are met if applicable. This portion of the Compliance Statement Requirement 

can be satisfied with a current MSDS for each Coating, and is not intended to require any 

additional labeling requirements. 
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District Response to Comment Letter 6: 

1. The Coating Category previously defined as Anti-Glare Safety Coating is now referred to as 

Clear Coating, Color Coating, or Single-Stage Coating and their corresponding VOC limits. 

2. Primer Sealer is a distinct Coating Category included in the SCM implementation. The 

reference to Primer Sealer changing to Primer was an error in the definition of Coating 

Categories and has been corrected (please see, Section (B)(19)). 

3. Group II Exempt Compounds, defined under Section (B)(29), are prohibited under Section 

(C)(4)(a). 

4. The final compliance date for the proposed VOC limits is May 1, 2013, approximately one year 

after the expected amendment adoption, which will allow time for manufacturers, suppliers, 

and affected auto body shops to transition to compliant product. 

5. A Multi-Stage Coating is 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. Examples of a MultiStage Coating are some pearlescent type coatings. 

6. The final compliance date for the proposed VOC limits is May 1, 2013, approximately one year 

after the expected amendment adoption. 
AVAQMD Rule 1151 C-27 

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C-28 AVAQMD Rule 1151 

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District Response to Comment Letter 7: 

1. In Draft 2 of the rule, an additional Coating Category for Vinyl Interior Coatings was added to 

Table 1 in subsection (C)(1)(a) of to allow a specific VOC limit for this category in response to 

the automotive paint supplier’s comment that there is a very limited production of compliant 

coatings of this category. However, upon ARB’s review of the Draft 2 changes, they requested 

that the additional coatings category be removed, stating that other districts have already 

incorporated the SCM and that product availability is sufficient (see Comment Letter 4), so the 

AVAQMD removed the additional coating category in the proposed Draft 3 of the rule. 

2. An extended compliance date of 07/01/13 was added to Table 1 in subsection (C)(1)(a) of Draft 

2 of the rule for the Coating Category of Single-stage Coating to allow more time for more 

readily available, cost-effective, premium products of this category as requested by the affected 

automotive coating supplier. However, upon ARB’s review of the Draft 2 changes, they 

requested that the extended compliance date be removed, stating that other districts have 

already incorporated the SCM and that product availability is sufficient (see Comment Letter 

4), so the AVAQMD removed the extended compliance date in the proposed Draft 3 of the 

rule. The District would like to maintain as smooth a transition into the new lower VOC limits 

as possible with minimal consequences for the affected sources. The final compliance date for 

the proposed VOC limits is May 1, 2013, approximately one year after the expected 

amendment adoption, which will allow time for manufacturers, suppliers, and affected auto 

body shops to transition to compliant product. 
AVAQMD Rule 1151 C-29 

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District Response to Comment Letter 9: 

1. The second sentence use of “automotive” in definition (B)(9) was not capitalized as 

“automotive refinishing” is not a definition. Only definitions are capitalized in rule format. 

2. The spelling of “Specialty” was corrected in the table of definition, (B)(19). 

3. The deletion of some of the toxins in definition (B)(28) in the previous drafts will remain in the 

final amendment. The District wishes to be consistent with the SCM. 

4. This comment is not accurate. Perhaps the title of Rule 442, Usage of Solvents, alludes that it 

is only applicable to solvents but the actual applicability is broader. Rule 442, is applicable to 

any person using VOC containing materials which is not subject to the VOC limits of any other 

rule found in District Regulation IV – Prohibitions or in any rule found in the District 

Regulation XI – Source Specific Standards. This includes VOC containing materials include, 

but are not limited to; coatings, resins, adhesives, inks, solvents, thinners, diluents, mold seal 

and release compounds, lubricants, cutting oils and quenching oils. This rule also applies to 

any person using a Non-VOC organic solvent and which is not subject to the limits of any other 

rule found in District Regulation IV – Prohibitions or in any rule found in District Regulation 

XI – Source Specific Standards. 
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District Response to Comment Letter 10: 

1. In response to the above comment letter, the compliance date for the proposed VOC limit for 

solvent has been modified in the current staff report version to reflect May 1, 2013. This was a 

typographical error, as the date in the subsequent staff reports should have been corrected to 

reflect May 1, 2013. This change has been made in this current staff report. 
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District Response to Comment Letter 11: 

1. In response to ACA’s comment on the Compliance Statement including additional 

requirements for solvents than the SCM requires, a separate section was made for solvents 

under (E)(1)(b), which only includes the requirement of VOC Actual as the SCM requires. The 

second comment on the requirements of HAPs Content requirement for Coatings will remain, 

as this is the District’s mechanism to ensure compliance with the NESHAP 6H. 

2. In response to ACA’s request for solvent to be clarified as a ‘cleaning’ solvent, language was 

added to section (C)(7)(b) to read, “Effective May 1, 2013, no Person shall possess at any 

Automotive Refinishing Facility, any solvent used for Surface Preparation and Cleaning 

Operations with a VOC content that does not comply with the requirements in subsection 

(C)(7)(a)(i).” 

3. In response to the ACA’s comment to include a ‘Sell-Through’ provision, the District 

purposefully established a compliance date of twelve months after the proposed adoption date 

to allow a window for the sell and use of products manufactured before the date. 

4. For clarification on the VOC limit for Group I Specialty Coatings (Table 2), the proposed 

interim VOC limit, effective until May, 1, 2013 is 840 g/L. After May 1, 2013, the proposed 

limit for Adhesion Promoter (which includes Uniform Finishing Coating) is 540 g/L (Table 2). 

5. The District notes the ACA’s support of the exemption of TBAC as implemented in this 

proposed revision. 

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APPENDIX "D" 

CALIFORNIA ENVIRONMENTAL QUALITY ACT 

DOCUMENTATION

1. Notice of Exemption, Los Angeles County 
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APPENDIX "E" 

BIBLIOGRAPHY

The following documents were consulted in the preparation of this staff report. 

Statutes and Regulations

EPA 450/2-76-028 (1976/11) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume I: Control Methods for Surface Coating Operations 

EPA 450/2-77-008 (1977/05) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty 

Trucks 

EPA 450/2-78-015 (1978/06) – Control of Volatile Organic Emissions from Existing Stationary 

Sources – Volume VI: Surface Coating of Miscellaneous Metal Parts and Products 

EPA 450/3-88-009 (1988/10) – Reduction of Volatile Organic Compound Emissions from Automobile 

Refinishing 

EPA 453/R-08-003 (2008/09) – Control Techniques Guidelines for Miscellaneous Metal and Plastic 

Parts Coatings 

EPA 453/R-08-006 (2008/09) – Control Techniques Guidelines for Automobile and Light-Duty Truck 

Assembly Coatings 

EPA 453/R-94-031 (1994/04) – Alternative Control Techniques Document: Automobile Refinishing 

40 CFR 63 Subpart HHHHHH – National Emission Standards for Hazardous Air Pollutants: Paint 

Stripping and Miscellaneous Surface Coating Operations at Area Sources; Final Rule (January 9, 

2008) 

40 CFR 60 Subpart MM – Standards of Performance for Automobile and Light Duty Truck Surface 

Coating Operations 

Title 17 CCR, Section 93112 – Hexavalent Chromium and Cadmium Airborne Toxic Control Measure 

– Motor Vehicle and Mobile Equipment Coatings 

Local Air Districts

Rule 45 – Motor Vehicle and Mobile Equipment Coating Operations (Bay Area Air Quality 

Management District, 12/03/08) 
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Rule 1116 – Automotive Refinishing Operations (Mojave Desert Air Quality Management District, 

amended, 08/23/10) 

Rule 1151 – Motor Vehicle and Mobile Equipment Non-assembly Line Coating Operations (South 

Coast Air Quality Management District, amended 12/02/05) 

Rule 1171 – Solvent Cleaning Operations (South Coast Air Quality Management District, amended, 

02/01/09) 

Rule 4612 – Motor Vehicle and Mobile Equipment Coating Operations – Phase II (San Joaquin Valley 

Unified Air Pollution Control District, amended 09/20/07) 

Staff Report for Proposed Amended Rule 1116: Automotive Refinishing Operations (Mojave Desert 

Air Quality Management District, June 2008) 

Staff Report for Proposed Amended Rule 1151: Motor Vehicle and Mobile Equipment Non-assembly 

Line Coating Operations (South Coast Air Quality Management District, December 2005) 

Staff Report for Proposed Amendments to Rules 4602 (Motor Vehicle and Mobile Equipment Coating 

Operations) and 4612 (Motor Vehicle and Mobile Equipment Coating Operations –Phase II) (San 

Joaquin Valley Unified Air Pollution Control District, September 21, 2006) 

SIP Citations

Rule 1116 (Mojave Desert Air Quality Management District) 

 65 FR 18901, Approval of 7/31/99 version 

Rule 1151 (Antelope Valley Air Quality Management District) 

 65 FR 18901, Approval of 07/20/99 version 

Rule 1151 (South Coast Air Quality Management District, for Blythe/Palo Verde Valley) 

 58 FR 66286, Limited approval/limited disapproval of 09/06/91 version 

Rule 4612 (San Joaquin Unified Air Pollution Control District) 

 75 FR 279, Approval of 09/20/07 version 

Technical Support Document for EPA’s Proposed Rulemaking for the California State Implementation 

Plan: San Joaquin Valley Air Pollution Control District, Rule 4612, Motor Vehicle and Mobile 

Equipment Coating Operations – Phase II (United States Environmental Protection Agency, Region IX 

Air Division, May 2009) 

Miscellaneous

8-Hour Reasonably Available Control Technology – State Implementation Plan Analysis (RACT SIP 

Analysis) (Mojave Desert Air Quality Management District, August 2006) 
AVAQMD Rule 1151 E-3 

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List and Implementation Schedule for District Measures to Reduce PM Pursuant to Health & Safety 

Code §39614(d) (Mojave Desert Air Quality Management District, June 27, 2005) 

Staff Report for the Proposed Suggested Control Measure for Automotive Coatings (California Air 

Resources Board, Stationary Source Division Measures Assessment Branch, October, 2005) 

Suggested Control Measure for Automotive Coatings as Approved by the Board on October 20, 2005 – 

Attachment A (California Air Resources Board, Stationary Source Division Measures Assessment 

Branch, October 20, 2005) 
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