## APPENDIX A

Comments and Responses

For Proposed Rule 4601 Dated November 5, 2009

December 17, 2009SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses December 17, 2009

A-2 Final Staff Report with Appendices For

Amendments to Rule 4601 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses December 17, 2009

A-3 Final Staff Report with Appendices For

Amendments to Rule 4601 

### Summary of Significant Comments and District Responses for Proposed Rule 4601

The following is a brief summary significant commen ts received and the District responses to those comments.

US EPA REGION IX STAFF COMMENTS

No comments have been received from EPA for the Pro posed Rule 4601 dated November 5, 2009.

ARB STAFF COMMENTS

1. COMMENT: For clarification ARB recommends the following sect ions be modified to reference the test method and labeling requirements as appropriate as stated in the 2007 ARB SCM. Section 3.2.7, Sect ion 3.44 Section 3.49, Section 3.53, Section 3.57, Section 3.64, Section 3 .66, Section 3.83, and Section

3.86.

RESPONSE: To provide clarification and uniformity of these de finitions with current and proposed definitions, the language has been included as requested by ARB. Please see proposed rule language for amen dments.

2. COMMENT: For clarification ARB recommends Section 3.41 be mo dified to include the reference excluding zinc and to include the test method and Section of the rule that applies to it. Also remove langua ge excluding aluminum roof coatings.

RESPONSE: For clarification Section 3.41 has been modified to include the language excluding zinc, included a reference for t he test method. Language exempting aluminum roof coatings has been deleted a s it is redundant with the exclusion for coatings applied to roofs. Please se e proposed rule language for

amendments.

3. COMMENT: For clarification ARB suggests changing the referen ce sections for

Section 5.2.1 and Section 5.2.2. The reference sec tions should be 5.2.3 .1 through 5.2.3 .18.

RESPONSE: The requested language updates have been made. Ple ase see proposed rule language for amendments.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Significant Comments and District Resp onses December 17, 2009

A-4 Final Staff Report with Appendices For

Amendments to Rule 4601 STAKEHOLDER COMMENTS

Stakeholders sending comments: National Paint Coatings Association (NPCA)

1. COMMENT: Section 5.2.2 has an error in the numbering of the section.

RESPONSE: Please see response to ARB comment number three.

2. COMMENT: Consistent with the 2007 SCM, NPCA suggests that th e district include referenced to VOC actual (Section 3.77), VO C content (3.78), and VOC regulatory (3.79) into Section 6.3.1.

RESPONSE: To align the proposed amendments with the 2007 ARB SCM and to provide clarity to rule requirements the recomme nded language has been added to proposed rule language.

3. COMMENT: For purposes of clarity and consistency, NPCA sugg ests that the District utilize Sell through language similar to t hat in the Ventura County APCD, and BAAQMD rules. As it stands, proposed amended R ule 4601 would allow a coating that did NOT comply with the previous versi on of the rule to be sold, supplied, or offered for sale after the effective d ate of a new limit.

RESPONSE: District staff feels that it is implied due to the limits currently in effect in the Table of Standards I. However, to im prove clarity for our stakeholders the requested language has been added to the proposed rule in

Section 5.8.