SACRAMENTO METROPOLITAN 

AIR QUALITY MANAGEMENT DISTRICT 

STAFF REPORT 

Proposed Negative Declarations for 

Control Techniques Guidelines 

Automobile and Light-Duty Truck Assembly Coatings 

Fiberglass Boat Manufacturing Materials 

January 18, 2012 

Prepared by: Jeffery Yang 

Assistant Air Quality Engineer

Reviewed by: Kevin J. Williams, Ph.D. 

 Program Coordinator 

 Aleta Kennard 

 Program Supervisor 

Approved by: Brigette Tollstrup 

 Division Manager 
Staff Report 

CTG Negative Declarations 

January 18, 2012, Page 1 

BACKGROUND 

The District is designated as a severe nonattainment area for the federal 8-hour ozone 

standard. The Federal Clean Air Act (CAA) specifies that State Implementation Plans (SIPs) for 

nonattainment areas must include “reasonably available control measures” (RACM), including 

“reasonably available control technology” (RACT), for sources of emissions1

. The CAA also 

provides that for nonattainment areas classified as “moderate” or worse, states must revise their 

SIPs to include RACT for sources of VOC emissions for each category of VOC sources covered 

by all Control Techniques Guidelines (CTG) documents issued after November 15, 1990, and 

prior to the area’s date of attainment2

. EPA defines RACT as “the lowest emission limitation 

that a particular source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility3

.” EPA periodically 

publishes information regarding available controls4

. In developing CTG documents, EPA 

evaluates, among other things, the sources of VOC emissions and the available control 

approaches for addressing these emissions, including the costs of such approaches. CTG 

documents establish the presumptive minimum recommendations for RACT. Areas may 

deviate from CTG requirements, if justified. 

As an alternative to adopting a RACT rule, a state or local agency may adopt a negative 

declaration documenting that it has no stationary sources or emitting facilities to which the CTG 

is applicable. The negative declaration must go through the same public review requirements 

as any other SIP submittal5,6. The negative declarations become part of California’s State 

Implementation Plan at Title 40 of the Code of Federal Regulations (CFR) Part 52, Section 

52.222. The Board has previously adopted negative declarations for 23 source categories. 

SUMMARY 

There are no sources within the District to which the 2008 CTGs for Automobile and Light-Duty 

Truck Assembly Coatings and Fiberglass Boat Manufacturing Materials are applicable. The 

purpose of this staff report is to provide sufficient analysis to support the adoption of negative 

declarations for these two CTGs. 

CTG CATEGORIES 

This analysis addresses two CTG documents for source categories in which the District has no 

sources: Automobile and Light-Duty Truck Assembly Coatings, and Fiberglass Boat 

Manufacturing Materials. 

Staff’s evaluation process included, for each CTG source category, an analysis of the CTG 

applicability, a review of District permitting records, and the emission inventory for the District’s 

Clean Air Plan. Business listings and yellow pages were searched to identify any unpermitted 

 

1

 Clean Air Act § 172(c)(1) 

2

 Clean Air Act § 182(b)(2)(A) 

3

 Federal Register Notice 44 FR 53761, September 17, 1979 

4

 Clean Air Act §§ 108(b) and (c) 

5

 Clean Air Act §110 

6

 Title 40 Code of Federal Regulations §51.102 
Staff Report 

CTG Negative Declarations 

January 18, 2012, Page 2 

sources. The following sections describe each of the CTGs and evaluations of their applicability 

to sources in the District. 

Automobile and Light-Duty Truck Assembly Coatings

Title: Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly 

Coatings. 

Reference: U.S. EPA Publication No. EPA-453/R-08-006, September 2008. 

The CTG applies to automobile and light-duty truck assembly coating operations. The source 

category includes the coatings that are applied to new automobile or new light-duty truck 

bodies, or body parts for new automobiles or new light-duty trucks. These coatings are applied 

at automobile or light-duty truck assembly plants. The large majority of these coatings are 

specifically formulated, marketed and sold for this purpose. 

The CTG recommends the following VOC reduction measures: VOC emission limits for coating 

operations; work practices for storage and handling of coatings, thinners, and coating waste 

materials; and work practices for the handling and use of cleaning materials. 

Staff searched the District permitting database for automotive assembly operations and found 

no active permits. Furthermore, Staff searched online for information about automobile 

manufacturing in California. The only remaining facility in California is in Fremont. New United 

Motor Manufacturing Inc. (NUMMI) operated there until it closed in early 2010. The facility 

reopened in October 2010 as a manufacturing facility for Tesla Motors, Inc. There are no 

automobile or light-duty truck assembly facilities within the District and none are expected in the 

near future. A negative declaration is proposed for this source category. 

Fiberglass Boat Manufacturing

Title: Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials. 

Reference: U.S. EPA Publication No. EPA-453/R-08-004, September 2008. 

The CTG applies to each fiberglass boat manufacturing facility that manufactures hulls or decks 

of boats from fiberglass or builds molds to make fiberglass boat hulls or decks and emits 2.7 

tons or more of VOC per year. The source category does not include facilities that manufacture 

solely parts of boats (such as hatches, seats, or lockers), or boat trailers, but do not 

manufacture hulls or decks of boats from fiberglass, or build molds to make fiberglass boat hulls 

or decks. 

The CTG recommends control of the following: 

 Open molding operations, including pigmented gel coat, clear gel coat, production resin, 

tooling resin, and tooling gel coat; 

 Closed molding resin operations; 

 Resin and gel coat application equipment cleaning; 

 Resin and gel coat mixing operations. 

The CTG controls do not include surface coatings applied to fiberglass boats nor to industrial 
Staff Report 

CTG Negative Declarations 

January 18, 2012, Page 3 

adhesives used in the assembly of fiberglass boats. However, polyester resin putties are not 

considered to be adhesives and are included in the CTG. The CTG does not apply to boat 

repair operations, only to the manufacture of new fiberglass hulls or decks. 

The CTG recommends the following VOC reduction measures: VOC content limits for resins, 

gel coats, and cleaning solvents; application methods for resins and gel coats; work practices 

for storage and handling of coatings, thinners, and coating waste materials; and work practices 

for the handling and use of cleaning materials. 

Staff searched the District permitting database and found no active permits for fiberglass boat 

manufacturing facilities. Staff searched yellow pages for fiberglass boat manufacturing facilities 

and repair shops. Staff also searched online using terms such as “fiberglass boat 

manufacturing”, “fiberglass boat”, “boat manufacturing” and “custom boats” in the Sacramento 

area. Several boat repair facilities were identified, but only two facilities that potentially 

manufacture fiberglass boats were identified: Classic Marine, located on Folsom Boulevard in 

Sacramento, and Whitcat, located in Rancho Cordova at the California State University, 

Sacramento Aquatic Center. Staff contacted the owners of both facilities to determine the 

nature and size of their businesses. Classic Marine stated the company makes a small number 

of custom fiberglass boats (none manufactured in 2010), and those are built outside the District, 

in El Dorado County. Its primary business is boat repair using epoxy materials. 

Whitcat operates as a side business making custom catamarans and has built 20 catamarans 

since 1986 using a closed molding process. Whitcat built only one boat in 2010, and that boat 

was built outside the District, in Costa Mesa, California. 

 

Typical catamaran sailboats weigh between 200 and 600 pounds, not all of which is due to the 

fiberglass hulls. However, to estimate worst case emissions, Staff calculated the VOC 

emissions from the application of 600 pounds of polyester resin with a monomer content of 

50%. The emission factor was calculated using the formula in Table 4 of the CTG for an 

atomized, open molding application, the most emissive application method. The application of 

600 pounds of polyester resin was estimated to result in VOC emissions of 111 pounds, or 

0.056 tons per year. To exceed the 2.7 tons per year CTG threshold would require building 48 

boats per year using the open molding process. This is more than twice the number of boats 

that Whitcat has built in the last 25 years combined. Furthermore, the catamarans built by 

Whitcat use a closed molding process, which is much less emissive than an open molding 

process. Staff concludes that Whitcat’s VOC emissions are less than the CTG threshold. 

The conversations with Classic Marine, Whitcat, and with a longtime Sacramento area boat 

repair shop (Sacramento Boat Repair) also confirmed that there are no other boat 

manufacturing facilities remaining in Sacramento County. No fiberglass boat manufacturing 

facilities large enough to exceed the CTG emissions threshold are expected in the near future. 

A negative declaration is proposed for this source category. 

 
Staff Report 

CTG Negative Declarations 

January 18, 2012, Page 4 

ENVIRONMENTAL COMPLIANCE

In adopting these negative declarations, the District is not adopting new requirements for 

emission sources. No source will need to change its operations to comply with a requirement. 

Staff finds that the adoption of these negative declarations is not subject to the California 

Environmental Quality Act because it is an activity that will not result in a direct or reasonably 

foreseeable indirect physical change in the environment. (Public Resources Code 21084(a) and 

Preliminary Review, Section 15060(c)(2) State CEQA Guidelines). 

CONCLUSION 

Staff’s analysis shows that there are no sources within the District to which the CTGs for 

Automobile and Light-Duty Truck Assembly Coatings and Fiberglass Boat Manufacturing 

Materials apply. No fiberglass boating manufacturing facilities large enough to exceed the CTG 

emissions threshold of 2.7 tons per year are anticipated in the future. There are no automobile 

or light-duty truck assembly facilities within the District and none are expected in the near future. 

Negative declarations are proposed for these source categories. 

Pursuant to section 182(b) of the Clean Air Act, the District should adopt negative declarations 

for the following CTGs: 

Control Techniques Guidelines for Automobile and Light-Duty Truck Assembly Coatings. 

U.S. EPA Publication No. EPA-453/R-08-006, September 2008. 

Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials. U.S. EPA 

Publication No. EPA-453/R-08-004, September 2008.