UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Rulemaking

for the

California State Implementation Plan

Repeal/Rescission of

San Diego County Air Pollution Control District Rule 67.0

Architectural Coatings

Prepared by: Arnold Lazarus

Reviewed by: Andrew Steckel

July 2016
1

RULE IDENTIFICATION -

Agency San Diego Air Pollution Control District (SDCAPCD)

SIP Approved 

Rule

Rule 67.0 - Architectural Coatings

Adopted - December 12, 2001

Submitted - March 7, 2003

EPA Approved – June 20, 2013 (78 FR 37130)

Subject of this 

TSD

Rule 67.0 - Architectural Coatings Repealed/Rescinded -

June 24, 2015

Submitted - November 13, 2015

Effective - January 1, 2016

Completeness 

Finding

Determination of Completeness Letter: January 19, 2016

BACKGROUND – SDCAPCD regulates air quality in San Diego County, which is 

classified as a “moderate” nonattainment area for the 2008 8-hour ozone National 

Ambient Air Quality Standard (NAAQS).1 The Clean Air Act (CAA) requires that for 

areas classified as moderate nonattainment or greater, the State must submit 

provisions to the State Implementation Plan (SIP) to require implementation of 

reasonably available control technology (RACT) (see sections 182(b)(2). There is 

no Control Techniques Guidance (CTG) for architectural coatings and 

architectural coating sources are considered to be “area sources,” not major 

sources, and therefore RACT requirements do not apply to this rule.

According to Robert J. Kard, air pollution control officer for SDCAPCD, “If 

adopted, Rule 67.0.1 will replace existing Rule 67.0, which was last updated in 

2001. Since 2001, coating manufacturers have developed new architectural 

coatings that contain less VOC while meeting appearance, durability and other 

performance needs. Proposed Rule 67.0.1 reflects the development of new, lower 

VOC content coatings and is based on a Suggested Control Measure (SCM) 

developed in 2007 by the California Air Resources Board that is designed to 

further reduce VOC emissions and encourage consistency in the regulation of 

architectural coatings across the State. Several air districts throughout California 

have already adopted the requirements found in the SCM and as a result 

complying coatings are now readily available.”2

RULE SUMMARY - SDCAPCD Rule 67.0 controls volatile organic compound 

(VOC) emissions from architectural coatings by establishing VOC limits on 

manufacture, distribution and use of various coatings. The rule has been 

amended several times since its initial adoption. Rule 67.0 was repealed in 

SDCAPCD effective January 1, 2016, and Rule 67.0.1 became effective on that 

same date.

 1 40 CFR 81.305. 2 Letter from Robert J. Kard, Air Pollution Control Officer of the SDCAPCD to the San Diego Air 

Pollution Control Board, June 24, 2015, p1.
2

PURPOSE OF RULE REPEAL – SDCAPCD repealed Rule 67.0 because it was 

replaced by the more stringent Rule 67.0.1 “Architectural Coatings.” Rule 67.0.1 

was adopted on June 24, 2015 and became effective on January 1, 2016.

SDCAPCD estimated a reduction of VOC emission from AC in San Diego County 

from replacing Rule 67.0 with Rule 67.0.1 will be approximately 840 tons per year. 

EPA EVALUATION – EPA staff have reviewed the SDCAPCD’s supporting 

documents as well as the replacement Rule 67.0.1 and concur with the SDCAPCD 

that repeal Rule 67.0 of complies with relevant CAA requirements, including

sections 110(l) and 193, because Rule 67.0.1 replaces and improves Rule 67.0,

and will strengthen the SIP.

EPA ACTION – EPA staff recommends approval of CARB’s request to rescind 

Rule 67.0 from the SIP.

REFERENCES

1. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

2. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 

2001.

3. SDCAPCD Rule 67.0 “Architectural Coatings” adopted on December 

12, 2001, submitted on March 7, 2003 and approved into the SIP on 

June 20, 2013 (78 FR 37130).

4. “Suggested Control Measure for Architectural Coatings,” CARB, 

October 2007. 

5. Letter from Robert J. Kard, Air Pollution Control Officer of the 

SDCAPCD to the San Diego County Air Pollution Control Board, 

June 24, 2015.