SAN DIEGO AIR POLLUTION CONTROL DISTRICT

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Comments Received During the Public Review Period f or The Draft Environmental Impact Report on Proposed Amendments to Rule 67.0—Architectural Coat ings

Pursuant to the California Environmental Quality Ac t, a Draft Environmental Impact Report (EIR) was prepared by the San Diego County Air Pollution Control District (SDAPCD) assessing potential environmental impacts resulting from impl ementing the proposed amendments to Rule 67.0, Architectural Coatings. The Draft EIR was ci rculated 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 Octo ber 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 b y the SDAPCD pertain not to the environmental analyses in SDAPCD’s Draft EIR but, r ather, to technical and economic issues associated with the proposed rule amendments. Spec ifically, the following comments were

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

Item A. Transmittal letter for the NPCA Comments Re ceived 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 11 13 - Architectural Coatings.

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

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

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

regarding proposed Suggested Control Measure for Ar chitectural and Industrial Maintenance Coatings.

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

Architectural and Industrial Maintenance (NE OTC AI M) Workgroup.

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

Item H. August 21, 2000, NPCA Comments to the Calif ornia ARB on the Draft EIR for Suggested Control Measure for Architectural and Ind ustrial Maintenance Coatings.

Item I. October 24, 2001, Comments from Benjamin Mo ore & 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 resp onses 1 through 6 of the Sacramento Comments and Responses document; Item E comments ar e addressed in responses 7 through 25 of the Sacramento document; Item F comments are addres sed 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 addres sed 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 Respo nses, Rule 442-Architectural Coatings” (May 17, 2001) [http://www.sdapcd.co.san-diego.ca.u s/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 Sacram ento 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 1 113 – 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 followin g reasons:

1. Unlike Rule 1113, the Rule 67.0 definition of Sp ecialty 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 conclu sions 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 modific ations are appropriate based on technical feasibility.

SDAPCD Response to Item C

The NPCA Comments submitted to the Sacramento Metro politan 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 positio ns previously expressed by NPCA in other comment letters (see items D thru H). The letter d oes 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 b etween rule adoption and implementation, followed by at least a three-year sell through or g randfather period for existing products. In response to comments received at the Public Worksho p held on September 6, 2001, the effective date of the proposed lower VOC content limits for R ule 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 throu gh 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, c oatings that were compliant at the time of manufacture may be applied at any time.