APPENDIX A 

Comments and Responses 

For 

Proposed Rule 4601 

Dated November 5, 2009 

December 17, 2009 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses 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 DISTRICT

Appendix A: Significant Comments and District Responses 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 comments received and the District 

responses to those comments. 

US EPA REGION IX STAFF COMMENTS 

No comments have been received from EPA for the Proposed Rule 4601 dated 

November 5, 2009. 

 

ARB STAFF COMMENTS 

1. COMMENT: For clarification ARB recommends the following sections be 

modified to reference the test method and labeling requirements as appropriate 

as stated in the 2007 ARB SCM. Section 3.2.7, Section 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 definitions with 

current and proposed definitions, the language has been included as requested 

by ARB. Please see proposed rule language for amendments. 

2. COMMENT: For clarification ARB recommends Section 3.41 be modified to 

include the reference excluding zinc and to include the test method and Section 

of the rule that applies to it. Also remove language excluding aluminum roof 

coatings. 

RESPONSE: For clarification Section 3.41 has been modified to include the 

language excluding zinc, included a reference for the test method. Language 

exempting aluminum roof coatings has been deleted as it is redundant with the 

exclusion for coatings applied to roofs. Please see proposed rule language for 

amendments. 

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

Section 5.2.1 and Section 5.2.2. The reference sections should be 5.2.3.1 

through 5.2.3.18. 

RESPONSE: The requested language updates have been made. Please see 

proposed rule language for amendments. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix A: Significant Comments and District Responses 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 the district 

include referenced to VOC actual (Section 3.77), VOC 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 recommended language has been 

added to proposed rule language. 

3. COMMENT: For purposes of clarity and consistency, NPCA suggests that the 

District utilize Sell through language similar to that in the Ventura County APCD, 

and BAAQMD rules. As it stands, proposed amended Rule 4601 would allow a 

coating that did NOT comply with the previous version of the rule to be sold, 

supplied, or offered for sale after the effective date 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 improve clarity for our 

stakeholders the requested language has been added to the proposed rule in 

Section 5.8.