THIS CASE, WHICH INVOLVES A VIOLATION OF SECTION 114 OF THE CLEAN AIR ACT (THE ACT ), STEMS FROM AN ENFORCEMENT INITIATIVE BY EPA REGION 9 INVOLVING THE REGULATION IN VARIOUS CALIFORNIA AIR QUALITY MANAGEMENT DISTRICTS OF THE AMOUNT OF VOLATILE ORGANIC COMPOUNDS ( VOCS ) IN ARCHITEC- TURAL COATINGS. VOCS, WHEN EMITTED INTO THE ATMOSPHERE, REACT WITH SUNLIGHT TO FORM OZONE POLLUTION OR SMOG. THE FEDRALLY-ENFORCEABLE STATE IMPLEMENTATION PLAN ( SIP ) FOR CALIFORNIA CONTAINS RULES IN APPROXIMATELY TWENTY AIR POLLUTION CONTROL DISTRICT 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 ). A COMPLETE LIST OF THE RELEVANT DISTRICT RULES AND THEIR EFFECTIVE DATES IS INCLUDED AS ATTACHMENT A. IN MAY 1987, EPA REGION 9 SENT INFORMATION DEMANDS, PURSUANT TO SECTION 114 OF THE ACT, 42 U.S.C. 7414, TO APPROXIMATELY 65 COATING MANUFACTURERS WHO MARKET ARCHITEC- TRURAL COATINGS IN CALIFORNIA. ROY ANDERSON PAINT COMPANY ( ANDERSON ) WAS AMONG THOSE MANUFACTURERS WHO RECEIVED INFORMATION DEMANDS. ANDERSON'S RESPONSE TO THE INFORMATION DEMAND DEMONSTRATED THAT IT WAS IN VIOLATION OF THE ARCHITEC TURAL COATING RULE IN THE BAY AREA AIR QUALITY MANAGEMENT DISTRICT ( BAAQMD ). BASED ON THE RESPONSES TO THE INFORMATION DEMANDS, IN JUNE 1987, EPA REGION 9 ISSUED NOTICES OF V