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The purpose of
Rule 314 - Fees for Architectural Coatings is to recover the
program costs to the AQMD for establishing and implementing Rule 1113 –
Architectural Coatings and include that program’s fair share of AQMD costs that
are apportioned among all AQMD programs, such as personnel, payroll, etc., as
well as costs supported by emissions fees, such as emissions inventory and air
monitoring. The rule will also provide staff with information on architectural
coating quantity used and related emissions for future planning, compliance, and
rule development. The current Rule 1113 Program includes staff assigned to
inspections, planning and rule development, laboratory services, legal,
administrative, and monitoring and analysis as well as support personnel. In
addition to the current program, Rule 1113 Program will be enhanced to include
additional inspectors to conduct a sufficient number of inspections and collect
samples to assess a supportable compliance rate for this emission source.
Additional chemists for sample analysis and an air quality specialist for fee
report audits are also included in the enhanced program. The enhanced program
will be phased-in over three years following the June 6, 2008 rule adoption.
Such enhancements will ensure maintaining a high level of compliance from
architectural coatings, the largest VOC emissions source category under AQMD’s
regulatory authority.
The Rule 1113 Program affects any person who manufactures, supplies, sells,
offers for sale, solicits, or field applies architectural coatings within the
AQMD. Since the application of architectural coatings does not require a permit
or notification to the AQMD, and occurs for short durations throughout the basin
at unknown locations, an Annual Quantity and Emissions Report and fees will be
the responsibility of the manufacturers of architectural coatings, rather than
end-users as suggested by the special Revenue Committee. This same approach has
been implemented in some programs such as water heater certification.
The cost of the Rule 1113 Program, which includes the strengthening of the
enforcement and laboratory efforts dedicated to the program, and a fair share of
costs supported by emissions fees and is projected to be approximately $4.2
million for 2009-10, which equates to approximately 7.1¢ per gallon, based on
estimated quantity of coatings, and is anticipated to be passed on to the
end-user by the manufacturers. Staff estimates the rule will impact
approximately 200 architectural coatings manufacturers.
Although the rule does not explicitly call for emission reductions, the fee
structure may provide an incentive to a manufacturer to lower total emissions by
marketing a larger volume of low volatile organic compound (VOC) coatings.
Experience with other stationary source emissions fee based programs indicate a
similar beneficial trend in terms of lowering emissions. However, such emission
reduction benefits cannot be quantified at this time; since at this time, staff
is unable to estimate the potential quantity shift towards lower VOC coatings
above and beyond the applicable VOC limits, as a result of this fee program.
Click link below to view a list of the manufacturer
that distribute or sell their manufactured architectural coatings into or within
the AQMD for use in the AQMD:
Rule
314 Manufacturers List (pdf-58k)
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