The American Coatings Association, ACA, has confirmed that California’s South Coast Air Quality Management District, SCAQMD, is developing its 2012 Air Quality Management Plan, or AQMP. The plan will include potential future measures for volatile organic compound emission limits from architectural and industrial maintenance coatings. The district has delayed presenting its plan to the district’s Board until Nov. 2, 2012. ACA is developing comments on the draft plan for the Aug. 31 comment deadline.
ACA last submitted comments on the draft plan on June 13 and has also met with district staff to discuss further reductions from architectural coatings (Rule 1113). Of note, general emissions from architectural and industrial maintenance coatings have leveled off at around 12 tons per day, even though volumes are starting to increase. The district is looking at a 25 g/l regulatory VOC content limit for flats/nonflats and primer, sealer, undercoaters, or an equivalent material VOC content--approximately 12 g/l material VOC limit.
ACA wants to ensure that appropriate inventory credit is given for the significant reductions already achieved in mass and reactivity of VOC emissions from architectural coatings, and additional reductions to come from requirements for colorants, VOC limit reductions, and thinning/cleaning solvents.
ACA is concerned that if extreme and unproven reductions are approved, 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. Given this significant concern, ACA urged the district to amend the Plan to clearly state that any specific numeric goals or targets are subject to the district’s statutory authority to regulate non-mobile sources and may be adjusted in the future based on technological feasibility analyses.
The district’s next AQMP Advisory Group meeting is scheduled for Sept. 20, 2012.