December 23, 1999

Dear Sir or Madam:

The Air Resources Board (ARB) staff is currently developing a Suggested Control Measure for Architectural and Industrial Maintenance Coatings (SCM), and we need your help in quantifying the SCM’s economic impacts on affected businesses and consumers in California.  Enclosed is a cost survey that will help us identify and quantify the various sources of cost increases and benefits that may result when manufacturers reformulate coatings to meet the requirements of the proposed SCM.  Since the proposed SCM is similar to Rule 1113 adopted by the South Coast Air Quality Management District, please include the costs you are incurring to comply with  Rule 1113.  Also, include the costs you would incur if t-butyl acetate is exempted from the volatile organic compound (VOC) definition.  Please fill out this survey as accurately and completely as possible.  Without complete and accurate survey responses from affected businesses, we will need to estimate the cost impacts from the SCM through alternate sources of information without the benefit of cost data specific to your particular business and products.

Please note that the enclosed cost survey form is intended only as a simple-to-use, data-gathering tool.  The data gathered from this survey will be used in our two-part analysis: the cost-effectiveness analysis (i.e., the “dollars required to reduce one pound of VOCs”) and the business impacts analysis.  The cost-effectiveness analysis is intended to help the ARB compare how cost-efficient the proposed SCM will be in reducing VOCs relative to other regulatory programs the ARB and local districts have implemented.  The business impacts analysis will be used to determine overall impacts to California business profitability, employment, and competitiveness, and any cost impacts to consumers and State and local agencies. 

If you believe it would be useful to provide us with additional or explanatory information, please feel free to attach such information to your completed survey form.  We will endeavor to use all relevant and reasonably accurate data in our analyses.  When submitting supplemental information, please include information directly related to costs that you anticipate incurring to meet the proposed SCM requirements in California. 

For your coatings that already comply with the applicable SCM requirements, please provide an estimate of the costs you incurred to bring those products to market. 

Please be assured that the survey responses will be treated as confidential data pursuant to our well-established confidentiality procedures (see attached “Confidential Information Submittal Form”).  Our plan is to report the survey data in summarized form so that no cost or sales data specific to any individual company or product will be published.

Thank you for your time and cooperation.  Because of the relatively short timeframe available for this project, we would appreciate it if you could complete and return the survey by January 31, 2000.  If you have any questions regarding the survey, please contact either Floyd Vergara, Staff Air Pollution Specialist, at (916) 327-1503 or Barbara Fry, Manager, Measures Development Section, at (916) 322-8267 (e-mail:  We look forward to reviewing your survey response.


Janette Brooks, Chief
Air Quality Measures Branch

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