On Dec. 7, 2012, California’s South Coast Air Quality Management District’s (SCAQMD) Governing Board approved the district’s 2012 Air Quality Management Plan (AQMP), which outlines the its strategies for meeting the National Ambient Air Quality Standards (NAAQS) for PM 2.5 and ozone. In particular, the 2012 AQMP establishes control strategies for different source categories and in particular, includes binding emissions reductions targets for architectural coatings.
ACA staff attended the 2012 AQMP hearing and urged the Governing Board to remove the proposed VOC reduction control measures – CTS-01, CTS-02, CTS-03, and CTS-04 – from the 2012 AQMP, considering that the district is not required to address ozone in the 2012 plan. ACA stressed the significant strides the paint and coatings industry has made in reducing its products’ VOC emissions in the past, noting that the district should focus on other source categories for further emissions reductions instead of unfairly targeting the coatings industry.
At the meeting, SCAQMD staff discussed the most recent updates to the outline for the next five years, detailing the district’s proposed measures to bring the Los Angeles Air Basin into attainment with federal ozone standards. The approved 2012 AQMP commits to a reduction of two tons per day for architectural coatings and includes three proposed control measures: 1) reduce the volatile organic compound (VOC) content in flat, nonflat, and primers, sealers and undercoaters from 50 grams per liter to 25 grams per liter; 2) evaluate potential changes or the elimination of the small container exemption; and 3) increase the transfer efficiency of paint spray guns.
ACA worked with district staff and engaged in the development of the draft plan, submitting written comments and providing oral testimony at regular stages during the process. In doing so, ACA successfully convinced SCAQMD to reduce its VOC reduction commitments for architectural and industrial maintenance (AIM) coatings from four tons per day to two tons per day. ACA also worked with district staff to consider a range options for amending the small container exemption in the future, instead of the outright elimination of this critical compliance option for coatings manufacturers
ACA was concerned that if extreme and unproven reductions are approved in the plan, the industry will be forced to achieve the VOC targets regardless of whether the set control measures are technologically feasible. ACA fears that once these reduction estimates are approved in the AQMP and the State Implementation Plan (SIP), the district may sidestep the technical concerns claiming that it has no choice since the reductions are “locked” into the Plan/SIP. Fortunately, the district has added language allowing for flexibility in the future and has assured ACA that any specific numeric goals or targets may be adjusted during the course of future rulemakings based on technical and economic concerns.
Note: SCAQMD will not be amending the actual regulations for a few years.
The SCAQMD Governing Board also removed the Low Vapor Pressure exemption via the CTS-04 control measure for Further Reductions from Consumer Products.
Next, the California Air Resources Board will be considering South Coast’s 2012 AQMP for inclusion into the California State Implementation Plan in January 2013.