SAN DIEGO AIR POLLUTION CONTROL DISTRICT 

11/21/01 -1- 

Comments Received During the Public Review Period for 

The Draft Environmental Impact Report on 

Proposed Amendments to Rule 67.0—Architectural Coatings 

Pursuant to the California Environmental Quality Act, a Draft Environmental Impact Report (EIR) 

was prepared by the San Diego County Air Pollution Control District (SDAPCD) assessing 

potential environmental impacts resulting from implementing the proposed amendments to Rule 

67.0, Architectural Coatings. The Draft EIR was circulated for a 45-day public comment period 

and comments were received from the National Paint and Coatings Association (NPCA) and 

Benjamin Moore & Co., a member of the NPCA, on October 24, 2001. The same NPCA 

comments were previously submitted by NPCA to other agencies for architectural coatings-related 

actions at those agencies. The comments received by the SDAPCD pertain not to the 

environmental analyses in SDAPCD’s Draft EIR but, rather, to technical and economic issues 

associated with the proposed rule amendments. Specifically, the following comments were 

received and can be accessed on the SDAPCD's website at http://www.sdapcd.co.sandiego.ca.us/rules/notices/FinalEIR/responses.pdf. 

Item A. Transmittal letter for the NPCA Comments Received by the SDAPCD on October 

24, 2001. 

Item B. Position of the NPCA Concerning the July 20, 2001, South Coast Air Quality 

Management District (AQMD) Status Report on Rule 1113 - Architectural 

Coatings.

Item C. May 18, 2001, NPCA Comments to the Sacramento Metropolitan AQMD. 

Item D. April 20, 2001, NPCA Comments to the Sacramento Metropolitan AQMD. 

Item E. June 21, 2000, NPCA Comments to the California Air Resources Board (ARB) 

regarding proposed Suggested Control Measure for Architectural and Industrial 

Maintenance Coatings. 

Item F. August 21, 2000, NPCA Comments to the Northeast Ozone Transport Commission 

Architectural and Industrial Maintenance (NE OTC AIM) Workgroup. 

Item G. December 11, 2000, NPCA Comments to the NE OTC AIM Workgroup. 

Item H. August 21, 2000, NPCA Comments to the California ARB on the Draft EIR for 

Suggested Control Measure for Architectural and Industrial Maintenance Coatings. 

Item I. October 24, 2001, Comments from Benjamin Moore & Co. transmitted by NPCA. 
Comments and Responses 

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SDAPCD Responses to Items D through H

Specifically, Item D comments are addressed in responses 1 through 6 of the Sacramento 

Comments and Responses document; Item E comments are addressed in responses 7 through 25 of 

the Sacramento document; Item F comments are addressed in responses 26 through 35 of the 

Sacramento document; Item G comments are addressed in responses 69 through 80 of the 

Sacramento document; and Item H comments are addressed in comments 36 through 68 of the 

Sacramento document. 

The comments in Items D through H were analyzed and addressed in “Sacramento Metropolitan 

Air Quality Management District, Comments and Responses, Rule 442-Architectural Coatings” 

(May 17, 2001) [http://www.sdapcd.co.san-diego.ca.us/rules/notices/FinalEIR/SacR442.pdf]. The 

SDAPCD has reviewed and considered these responses and concurs with the determinations made 

therein. The SDAPCD incorporates the entire Sacramento Comments and Responses document by 

reference. 

SDAPCD Response to Item B

The comments submitted by NPCA in Item B pertain to an annual status report issued by South 

Coast AQMD regarding issues related to their Rule 1113 – Architectural Coatings. Two of the 

major issues discussed in the NPCA comments are not related to SDAPCD’s proposed amended 

Rule 67.0 (Architectural Coatings) for the following reasons: 

1. Unlike Rule 1113, the Rule 67.0 definition of Specialty Primers includes the use of such 

primers for blocking stains [(e)(1)(vii)(A)], and 

2. Unlike Rule 1113, Rule 67.0 proposes a VOC limit of 250 g/l for Floor coatings, which is 

consistent with the current version of Rule 67.0. 

Other comments pertain to South Coast AQMD’s conclusions regarding the results of technical 

assessments performed on Interior Stains, Essential Public Services Coatings and all other coating 

categories conducted by or for South Coast AQMD and ARB. These results will be monitored by 

the SDAPCD to determine if future Rule 67.0 modifications are appropriate based on technical 

feasibility. 

SDAPCD Response to Item C

The NPCA Comments submitted to the Sacramento Metropolitan AQMD on May 18, 2001, 

pertain to a meeting held with NPCA and Sacramento Metropolitan AQMD Staff on May 10, 

2001. The letter summarizes and reiterates positions previously expressed by NPCA in other 

comment letters (see items D thru H). The letter does not contain any comments that are not 

already addressed by the responses to Items D thru H. Accordingly, no additional responses are 

being provided for the Item C comments. 
Comments and Responses 

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SDAPCD Response to Item I

Benjamin Moore & Co. requested a six-month period between rule adoption and implementation, 

followed by at least a three-year sell through or grandfather period for existing products. In 

response to comments received at the Public Workshop held on September 6, 2001, the effective 

date of the proposed lower VOC content limits for Rule 67.0 has been delayed until January 1, 

2003, consistent with the Suggested Control Measure guidance. This new compliance date will 

allow sufficient time to address all of the issues raised in the manufacturer’s comment. 

As proposed, Rule 67.0 (d)(4) contains a sell through provision that allows coatings that were 

compliant at the time of manufacture to be sold for a period of three years after the effective date 

of the new lower VOC content limit. In addition, coatings that were compliant at the time of 

manufacture may be applied at any time.