| Comment | We are very disappointed that ARB staff are proposing VOC limts
that are less stringent than SCAQMD Rule 1113, Architectural
Coatings. The South Coast VOC limits have been successfully
implemented since 2013 when averaging provisions sunset. Arguments
from industry that climate conditions in the South Coast do not
apply statewide are rebutted by the fact that quick-drying coatings
are available in low-VOC formulations. Arguments that coating
formulations require the use of air toxic solvents are wrong
because low-VOC coatings are available using non-toxic
formulations. For example, industrial maintenance coatings using
sprayable polyurea coatings are quick-drying,zero VOC and zero
toxic air pollutants and have been available for a long time. As a
nonattainment area for ozone, state law requires that we adopt All
Feasible Measures. SCAQMD Rule 1113 has been demonstrated to be an
All Feasible Measure. Adoption of this SCM will hinder our efforts
to adopt the VOC limits currently effective in the South Coast.
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