THIS CASE STEMS FROM AN ENFORCEMENT INITIATIVE BY EPA REGION 9 UNDER THE CLEAN AIR ACT ( THE ACT ) INVOLVING THE REGULATION OF VOLATILE ORGANIC COMPOUNDS ( VOCS ) IN ARCHITECTURAL COATINGS IN CALIFORNIA. VOCS, WHEN EMITTED INTO THE ATMOSPHERE, REACT WITH SUNLIGHT TO FORM OZONE POLLUTION OR SMOG . THE FEDERALLY-ENFORCEABLE STATE IMPLEMENTATION PLAN ( SIP ) FOR CALIFORNIA CONTAINS RULES IN APPROXIMATELY TWENTY AIR POLLUTION CONTROL DISTRICTS WHICH PROHIBIT THE SALE OR USE OF NON-FLAT NON-SPECIALTY ARCHITECTURAL COATINGS WITH A VOC CONTENT IN EXCESS OF 250 GRAMS PER LITER ( GPL ). THE COMPLIANCE DATES IN THESE RULES VARY BY DISTRIC, RANGING FROM SEPTEMEBER 1980 TO SEPTEMBER 1986. A COMPLETE LIST OF THE RELEVANT DISTRICT RULES AND THEIR EFFECTIVE DATES IS INCLUDED AS ATTACHMENT A. (MANY OF THESE RULES HAVE BEEN REVISED BY THE LOCAL DISTRICTS AND SUBMITTED TO EPA FOR INCLUSION IN THE SIP. THE REGULATORY STATUS OF THE RULES AND ANY REVISIONS IS DISCUSEED BELOW AT SECTION IV(D).) ON JUNE 9, 1987, EPA REGION 9 ISSUED A NOTICE OF VIOLATION ( NOV ) TO OLD QUAKER PAINT COMPANY ( OLD QUAKER ) FOR VIOLATIONS OF THE THE ARCHITECTURAL COATINGS RULES IN THE SIP IN VARIOUS AIR POLLUTION CONTROL DISTRICS IN CALIFORNIA. SPECIFICALLY, THE NOV STATED THAT OLD QUAKER WAS SELLING AND/OR OFFERING FOR SALE IN THREE OF THESE DISTRICTS NON- FLAT ARCHITECTURAL COATINGS WHICH CONT