ACA is developing comments on the California Antelope Valley Air Quality Management District’s (AQMD) proposed amendments to Rule 1113 for architectural and industrial maintenance (AIM) coatings. The AQMD is set to adopt the revised volatile organic compound (VOC) limits and definitions on May 21. Among the proposed changes, the district is proposing to eliminate the Sealer Coatings category.
ACA will be submitting its comments ahead of the May 20 comment deadline in order for the Antelope Valley AQMD to consider it them seriously.
The proposed amendments to Rule 1113 have been developed to conform the emissions limitations and other requirements of the rule to those set forth in the SCM for Architectural Coatings as adopted by the California Air Resources Board in October, 2007. The proposed amendments mainly lower the VOC content limits for a number of coatings categories; this would result in an estimated 15.2 tons per day reduction in VOC emissions state-wide, which represents a 28 percent overall emissions reduction, according to the Antelope Valley AQMD. The amendments also contain revised definitions for a variety of coating types, either for clarification or to limit the types of products that qualify for inclusion in a category. Some definitions were deleted because the categories have been combined with other categories, were replaced by new categories, or were unnecessary. Additionally, amendments clarify situations where the most restrictive VOC limit is not applicable and update reporting requirements to include sales data. Other amendments include revisions to the section that describes how to determine VOC content, container labeling requirements, a “sell-through” provision, and an early compliance provision.
Antelope Valley’s AQMD proposed rule currently does not have an effective date for the revised limits. ACA will recommend in its comments an effective date of Jan. 1, 2015, to give the district ample time to complete the amendments and adoption process. In addition, a January 2015 date would provide coatings manufacturers at least one year to reformulate coatings to meet the new limits; change computer systems; communicate changes to retailers, distributors, and users; and update labels, among other administrative requirements. ACA underscored that while an effective date of July 1, 2014, might suffice, it would only work if the rule adoption process was completed before July 1, 2013.
ACA will also urge the AQMD to modify language germane to the Metallic Pigmented Coating category, clarifying that the category does not include coatings applied to roofs or zinc-rich primers. ACA will also suggest including definitions for ‘VOC Actual’ and ‘VOC Regulatory’ in the definitions section as opposed to the Compliance Provisions section, in order to assist the regulated community in more easily finding definitions.