Feather River Air Quality Management District

Rule Development

STAFF REPORT

Regulation III: Rule 3.20 - Wood Products Coating Operations
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 2

BACKGROUND

Under the provisions of the California Clean Air Act (CCAA) of 1988, Yuba County and the northern 

portion of Sutter County and all of the Northern Sacramento Valley Air Basin (NSVAB) have been 

designated as “ moderate” non-attainment areas for failing to meet the state ozone standard. The 

southern portion of Sutter County is designated as “ serious” on-attainment for failing to meet the 

state ozone standard. Ozone occurs w hen volatile organic compounds (VOC) and nitrogen oxides 

react in the atmosphere in the presence of heat and sunlight. Ozone is a strong irritant w hich 

attacks the respiratory system, leading to the damage of lung tissue. Prolonged exposure can cause 

permanent lung damage. Ozone decreases the flow of oxygen in the lungs and increases resistance 

to air passage in the lung tissue. Ozone damages the individual air sacs in the lungs w here the 

exchange of oxygen and carbon dioxide betw een the air and blood takes place. Persons suffering 

from asthma, bronchitis, and other respiratory ailments, as w ell as cardiovascular disease, are 

particularly susceptible to the effects of ozone. Other groups w hich are susceptible include children, 

the elderly, and persons engaged in heavy exercise. 

Other Damage: Ozone causes crop damage estimated to cost at least $330 million dollars per year in 

California. Additionally, ozone has been linked to the damage of certain materials, including paint 

and rubber. 

 

Rule 3.20 - Wood Products Coating Operations regulates the volatile organic content (VOC) of 

coatings and strippers. Generally, the rule affects anyone w ho supplies, sells, offers for sale, or 

uses a w ood products coating or stripper, including surface preparation and cleanup solvents 

regulated under this rule. The rule also applies to anyone w ho solicits, requires the use of, or 

specifies the application of a w ood product coatings or strippers that does not comply w ith this rule.

For consistency among the Northern Sacramento Valley Air Districts, Rule 3.20 is based on 

Sacramento Metropolitan AQMD’s Rule 463, Wood Products Coatings. 

Authority for Stationary Source Rules

The Feather River Air Quality Management District Board of Directors is authorized by Sections 

40000, 40001, 40702, 40716 and 40910 of the California Health and Safety Code to adopt, 

amend, and repeal rules that regulate stationary sources of air pollution.

• Section 40000: Local and regional authorities have the primary responsibility for 

controlling air pollution from stationary sources.

• Section 40001: Air districts shall adopt rules to achieve and maintain state and 

federal ambient air quality standards. 

• Section 40702: An air district shall adopt rules to execute its statutory pow ers and 

duties.

• Section 40716: An air district may adopt rules to reduce or mitigate emissions from 

indirect and area w ide sources.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 3

• Section 40910: Districts shall endeavor to achieve and maintain state ambient air 

quality standards for non-attainment pollutants and their precursors.

Legal Mandates

State Mandates: The District is designated as non-attainment for the state ozone standard. The 

California Clean Air Act requires areas designated as “ moderate” non-attainment for ozone to adopt 

control measures required in Section 40918 of the California Health and Safety Code. California 

Health and Safety Code Section 40913 requires districts to develop a plan to achieve California’s 

ambient air quality standard by the earliest practicable date.

All Feasible Measures Requirement: California Health and Safety Code Section 40914 requires each 

district plan to demonstrate that the plan includes “ every feasible measure” to control emissions. 

Accordingly, districts must adopt the most effective control measures to reduce VOC emissions from 

w ood products coating operations. The District evaluated the standards in the rule against similar 

requirements contained in the feasible measure document and requirements recently adopted by 

other districts. The results are summarized in the section titled “ IDENTIFICATION OF ACHIEVABLE 

PERFORMANCE STANDARDS AND EMERGING TECHNOLOGIES FOR WOOD PRODUCT 

COATINGS.”

IDENTIFICATION OF ACHIEVABLE PERFORMANCE STANDARDS AND EMERGING TECHNOLOGIES 

FOR WOOD PRODUCT COATINGS

The California Clean Air Act requires districts unable to achieve five percent (5%) annual emission 

reductions to demonstrate to the California Air Resources Board (CARB) satisfaction that it has 

included every feasible emission control measure in its plan and has an expeditious rule adoption 

schedule. According to CARB, no district has been able to demonstrate five percent (5%) annual 

reduction in ozone precursors. Therefore, every district’s plan is evaluated on the basis of 

demonstrating adoption of “ Every Feasible Measure.”

CARB has used the definition for “ feasible” from the California Environmental Quality Act (CEQA) 

(14 California Code and Regulations, Section 15364). CEQA defines “ feasible” as: “ capable of being 

accomplished in a successful manner w ithin a reasonable period of time, taking into account 

economic, environmental, legal, social, and technological factors.” According to CARB the adoption 

of every feasible measure involves the adoption of regulations that have been successfully 

implemented elsew here. CARB’s interpretation is explained in length in Identification of Achievable 

Performance Standards and Emerging Technologies for Stationary Sources, March 1998. 

EPA Regulatory Negotiation Committee

The Wood Furniture Regulatory Negotiation Committee began its meetings to discuss w ood products 

coatings in mid-1993. Previously, members of the Committee had participated in a series of public 

meetings w hich laid the groundw ork for the negotiations in terms of identifying information needs 

and beginning to define the scope of issues. Committee members represented Federal and State 

regulators, large and small w ood furniture manufacturers, coatings and resin manufacturers, and the 

environmental community.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 4

The Committee' s charge w as to develop a framew ork of principles to serve as a basis for a draft 

national emission standard for hazardous air pollutants (NESHAP) and a control techniques guideline 

(CTG) covering volatile organic compound emissions for the w ood furniture industry. The U.S. EPA, 

a party to these negotiations, is responsible for issuing the NESHAP and CTG, and agreed to use any 

framew ork and principles, that it and all the other Committee members agreed to during the course 

of these negotiations. The NESHAP, issued on November 14, 1995, covers emissions of HAPs from 

w ood furniture manufacturing sources. The CTG covers VOC emissions from w ood furniture 

finishing and cleanup operations.

2000 Attainment Plan

The proposed rule is included as a control measure in the District' s "2000 Air Quality Attainment 

Plan for the Northern Sacramento Valley Air Basin.

II. WOOD PRODUCTS COATING OPERATIONS:

Coating Operations

Surface coating of w ood products may be completed in a single step or in several steps using 

primers, sealers, topcoats, etc., and/or touch-up operations. These process steps may be done in a 

single spray booth or in a series of booths, separated by flash-off areas and ovens. The flash-off 

area allow s a solvent to rise to the surface of the coating before high temperature curing operations 

can occur. In applications involving air dried coatings, w hich typically do not exceed 194 oF (90oC) 

w hile curing, the flash-off operation and the drying operation become indistinguishable. Typically, it 

is during the flash-off and curing/drying phases that VOC is emitted to the atmosphere. In general, 

multiple coatings are applied in the follow ing order: stain, w ash coat, filler, sealer, highlight coat, 

and top coat. A typical coating contains solids and liquid solvents. The solids portion contains 

pigments and resins (binders or film former) and at times plasticizers. The solvent portion may 

include VOC, exempt solvents, and w ater. Conventional coatings normally contain 70 to 80 percent 

solvent. Waterborne coatings are those that contain w ater as a solvent or diluents. Merely having 

w ater in a coating, how ever, does not ensure that the coating complies w ith applicable regulations, 

as many w ater borne coatings also contain VOC. Coatings w ith "high solids" content (solids content

greater than 60%) have a reduced VOC content. Pow der coatings typically contain less than 1% to 

2% VOC, and may emit small amounts of monomer or low molecular w eight components during the 

cure cycle. Pow der coatings generally require electrostatic application. Emissions occur primarily 

from the solvents used during the coating process.

It is reasonable to assume that all of the solvents used in the coating process eventually reach the 

atmosphere. According to the U.S. Environmental Protection Agency (EPA), the most common 

hazardous air pollutant chemicals contained in the solvents used in w ood coatings are: toluene 

(26%), xylene (15%), methyl isobutyl ketone (7.3%), methyl ethyl ketone (5.5%), and glycol ether 

and esters (1.7%).

Coating Application

Coatings are applied by several different methods, including but not limited to, spray, roller, dip, 

flow , and brush application. In spray coating, electrostatic, air-assisted/airless, airless, High Volume-
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 5

Low Pressure (HVLP), and conventional air-spray methods are used. Coating application methods 

w hich are more efficient in applying coatings are advantageous since they improve transfer 

efficiency w hich decreases coating usage thereby reducing VOC emissions. Application techniques 

w hich have high transfer efficiency include HVLP, electrostatic spray, dip coating, flow coating, and 

roller or brush application.

HVLP is an application method using a high volume of low pressure air (typically 0.1 to 10 psi at the 

nozzle). The low air pressure greatly reduces the amount of over spray, resulting in a transfer 

efficiency greater than 65%.

In electrostatic spray coating, the coating flow s over an electrode w hich charges the paint to 60 -

75 Kilovolts (KV). The parts are grounded and the coating is attracted to the part and w raps it. 

Round parts are almost totally w rapped w hile flat parts get a good w rap at the edges. The operator 

must be grounded and w ear specific clothing w hile painting to bleed off the charge that w ill build up 

in the body. Transfer efficiency is 90% or better.

Dip coating means that a w ood product is dipped into a coating bath to cover the part by 

submerging and upon removal from the bath; the excess coating is allow ed to drain off. This 

process is used for parts that have no fine finish requirements as there are drain marks from the 

coating flow ing off the part. Transfer efficiency is 90% or better.

Flow coating is a method of coating application w here the coating is poured onto the part and the 

excess is drained into a sump for reuse. Transfer efficiency is 90% or better, but the finish is of 

poor quality due to drain marks. "Vacuum coating" is a kind of flow coating. The coating chamber is 

flooded w ith coating and vacuum pulls the coating across the product. "Curtain coating" is also a 

type of flow coating. In this process, the coating is not pumped from all angles but instead cascades 

over the part as a w aterfall. Curtain coating is used mostly for flat goods.

In roller or brush application, the coating is applied by either roller or brush. Transfer efficiency is 

better than 90% w hile maintaining a good finish. A major draw back to roller or brush applications is 

the amount of time involved in coating a part. The process of coating a part by brush or roller is 

very labor intensive.

Control Technology

There are four major categories of control strategies that can be used to reduce VOC emissions from 

w ood coating operations. They are:

1. Add-on control devices

2. Low -solvent reformulated coatings

3. Emerging technologies

4. Improved w ork practices
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 6

Add-on Control Devices

Add-on control devices are incorporated into a process to remove or destroy VOC' s after the coating 

process occurs. There are three add-on control methods: thermal oxidation, catalytic oxidation, and 

adsorption.

Thermal oxidation involves heating VOC contaminants to their auto-ignition temperatures in the 

presence of sufficient oxygen to effectively complete destruction. Although chemicals have different 

auto-ignition temperatures, incinerators are usually operated at a single temperature that w ill result in 

the efficient destruction of most VOC' s found in the exhaust stream. Factors affecting incinerator 

performance are residence time in the combustion zone, mixing, and incinerator temperature. A 

thermal incinerator is typically comprised of a refractory-lined chamber w ith gas burners at one end. 

The chamber is sized to allow a residence time of 0.3 to 1.0 second at the maximum gas flow rate. 

Using flue gases to preheat combustion air and/or vent gases is a common method of heat recovery.

How ever if a heat recovery process is used, insurance regulations require that VOC concentrations 

be kept below 25% of the low er explosive limit of the VOC in order to prevent explosion hazards. 

EPA test results demonstrate that thermal oxidizers can achieve a 98% VOC destruction efficiency 

for most VOC’s at combustion chamber temperatures ranging from 700oC to 1300oC and residence 

times of 0.5 to 1.5 seconds.

Catalytic oxidation introduces a catalyst to dramatically increase the rate of the chemical reaction 

betw een the VOC’s and oxygen. The catalyst itself is not altered during the reaction. The increased 

reaction rate can greatly reduce the auto-ignition temperature w hich, in turn, reduces the minimum 

combustion chamber temperature to a range of 260oC to 427oC. The reduced temperatures result in 

significant fuel savings w hen compared to a thermal incinerator. Catalytic converters can also 

process dilute VOC streams in w hich the concentration of VOC’s is w ell below the low er explosive 

limit of the VOC. The disadvantages of catalytic units include higher installation costs and the 

possibility of catalyst poisoning by sulfur, metals, and phosphorous. Overall destruction efficiency is 

dependent upon space velocity, operating temperature, oxygen concentration and VOC composition 

and concentration. Under proper conditions, a catalytic unit can achieve 95% VOC destruction 

efficiency.

Adsorption is a mass-transfer operation involving the conversion of VOC’s from a gas phase to a 

solid phase. The most common adsorption system uses activated carbon, w hich is effective in 

capturing most VOC' s through a physical adsorption mechanism. In addition, activated carbon can 

be regenerated by steam, nitrogen stripping, or high-vacuum regeneration. At a minimum, tw o 

adsorption beds and a regeneration facility are required for an adsorption process. In practice, 

process vent emissions are directed to the first adsorption bed until equilibrium is reached. The 

emissions are then directed to the second adsorption unit w hile the first is being regenerated. The 

run time on the unit must be longer than the time for completion of the regeneration cycle. Removal 

efficiency by adsorbers can be as high as 95% for certain VOC’s.

Low-solvent Reformulated Coatings

In w ood product coating operations, VOC emissions result from the application and subsequent 

evaporation of the coating materials. The use of reformulated coatings that contain less solvent w ill 

reduce VOC emissions. Currently, most of the low -VOC reformulated coating alternatives available 

are clear coats, w hich could potentially be used to replace nitrocellulose clear lacquer coats in the 

coating process.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 7

The conversion from solvent based coatings to w aterborne coatings involves more than simply 

changing the coating being applied. Waterborne coat ings require the use of spray guns designed for 

spraying w ater borne coatings, or that existing spray guns be retrofitted to include stainless steel or 

plastic parts to prevent rust from forming. In addition, the manner in w hich the coating is applied 

requires additional steps, and new application techniques. Unless some provision is made for drying 

w aterborne coatings, the climate in the Feather River Air Quality Management District during the 

w inter is not conducive to rapid evaporation of the w aterborne product, leading to longer drying 

times.

One of the most notew orthy problems related to the use of w aterborne coatings is that the w ater in 

the coating causes the w ood grain to raise, more than is the case w ith solvent -borne coatings. This 

"grain raise" then requires additional sanding, and re-coating of the product until the w ood product 

meets the level of quality control imposed by the manufacturer of the product. This problem can be 

overcome, but not w ithout the cost imposed by the additional steps.

Emerging Technologies

Efforts are underw ay to improve several technologies that have potential applications in the w ood 

product coating industry. These developments include advances in spray booth design that w ill 

reduce the volume of air exhausted, new curing methods that involve three-dimensional UV curing, 

and research into bio-filtration that w ill improve add-on controls.

Improved Work Practices

Improved w ork practices, such as employing high transfer efficiency applicat ion methods and 

reducing the volume of clean-up solvent, can low er VOC emissions by minimizing the quantity of 

VOC-containing materials used.

Businesses Affected By Rule 3.20

The w ood products industry is characterized by a large number of small businesses typically 

producing w ood household furniture, kitchen cabinets, television cabinets, office furniture, and store 

fixtures. There are approximately 43 businesses in Yuba and Sutter Counties that use some amount 

of w ood products coatings.

The majority of the w ood products industry in the District consists of smaller businesses w hich 

manufacture their ow n w ood products, coat products w hich have been manufactured somew here 

else, or w hich refinish w ood products.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 8

III. SUMMARY OF RULE REQUIREMENTS

Exemptions

Rule 3:20 exempts the follow ing:

1. Sources using less than 55 gallons per year, (singly or in any combination) of w ood 

products coatings and/or strippers.

2. Wood products coatings that are sold in non-refillable aerosol-spray containers.

3. Coating of architectural components that are not coated in a shop environment. 

(Such components are regulated by District Rule 3:15 - ARCHITECTURAL 

COATINGS)

4. Stencil coatings w hen used to comply w ith U.S. Military Specifications.

Note: An exemption for Coating operations for the purpose of manufacturing a finished w ood panel 

intended for attachment to the inside w alls of buildings, including, but not limited to, homes and 

office buildings, mobile homes, trailers, prefabricated buildings and similar structures; or a finished 

exterior w ood siding intended for use in construction has been removed from the draft rule. Other 

districts have adopted a rule for Flat Wood Stock Coating that limits VOC content of coatings for 

this type of application. FRAQMD has not proposed in our attainment plan to adopt a Flat Wood 

Stock Coating rule. Therefore the district does not propose to exempt this source from Rule 3.20.

Standards

Limits for the VOC content of w ood products coatings, strippers, surface preparation materials, and 

cleanup materials are included in the rule, as w ell as alternative requirements for emissions control 

systems. Application equipment requirements indicate the types of equipment to be used in the 

application of w ood products coatings, but w ithout any specified transfer efficiency, since there is 

no EPA approved test method at this time. The application equipment requirements apply to all 

w ood coating businesses, except those using less than 55 gallons of coating and stripper material 

per year.

Coating manufacturers have developed w aterborne coatings that w ork very w ell on new w ood 

products; how ever, these coatings do not w ork as w ell on older furniture that has been coated w ith 

furniture oils and w axes for many years. Because of this, the rule establishes higher VOC standards 

for coatings used in refinishing and repair operations, compared to the standards for new product 

coating operations. 

Administrative Requirements

Administrative requirements for this rule provide the follow ing:

1. The calculation to be used in determining partial vapor pressure. This calculation is 

for the purpose of determining w hich VOC limit applies.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 9

2. The calculation to be used in determining the w eight of VOC per volume of coating, 

less w ater and exempt compounds. This determination is for the purpose of 

calculating the VOC content of a coating.

3. The requirements for the Operation and Maintenance Plan, if an emission control 

device is used in lieu of compliant coatings.

4. The requirements placed on manufacturers to display the maximum VOC content of 

the coating, as applied.

5. A restriction on specifying the application of a w ood product coating that does not 

meet the limits and requirements of this rule.

Records and Test Methods

Businesses regulated by this rule w ill be required to maintain records of the actual products used and 

in storage. The records must include a data sheet or material list, any catalysts, reducers, or other 

components used, and the mix ratio, and the VOC content limit as applied. On a monthly basis, 

records must be kept to indicate the amount (e.g. gallons) of each w ood product coating material 

used.

A person using an emission control system or emission averaging to comply w ith this rule w ill be 

required to maintain daily records during periods of emission producing activities.

Cost-Effectiveness

Radian Corporation, under contract w ith the federal Environmental Protection Agency (EPA), 

prepared a Technical Support Document (TSD) for the Wood Products Coatings Rule. The TSD uses 

cost estimates developed by the South Coast Air Quality Management District SCAQMD). These 

cost estimates have been modified in order to derive a cost-effectiveness figure for the Northern 

Sacramento Valley Air Basin based on 1995 dollars. The cost-effectiveness for Rule 3:20 is 

estimated to range from $.01 per pound of VOC reduced if compliant coatings are used, to $5.80 

per pound of VOC reduced if add-on control devices are used.

Essentially, the costs of complying w ith this rule fall into tw o categories. The first category includes 

the capital cost of new equipment used to apply the coatings, as w ell as the higher cost of the 

compliant coatings. The District estimates that the higher cost of coating application equipment, 

such as the HVLP spray guns, is offset by the higher transfer efficiency and low er amount of coating 

w aste. The higher cost for compliant coatings w ill also be offset by the reduced amount of product 

required, as w ell as the reduced cost of disposing hazardous w aste. The second category includes 

the cost of control equipment that w ould need to be installed if the business operator decides to 

continue the use of non-compliant (higher VOC) coatings.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 10

Emission Reduction

The follow ing data is from the year 2001 ARB CEIDARS database. Estimated VOC emissions for the 

Northern Sacramento Valley Air Basin w ere 0.289 tons per day (105.44 tons per year) from the 

w ood products industry. District contributions are separated as follow s: 

Air Quality Management 

Dist. tons/day tons/year

Butte .035 12.74

Colusa .002 .69

Feather River .133 48.41

Glenn .011 3.85

Shasta .080 29.27

Tehama .029 10.47

NSVAB Totals .289 105.44

The Air Resources Board uses tw o control effectiveness values for estimating emissions reductions 

explained in tw o tiers below :

Tier 1- 40% reduction, Implemented at time of adoption:

Tier 2- 58% reduction, Implemented by year 2005:

Emission Reduction (tpd)

District CEIDARS 2001 ROG 

Emissions (tons/day)

Tier 1 Limits

(assume 40% 

reduction)

Tier 2 Limits

(assume 58% 

reduction)

Butte .035 .014 .020

Colusa .002 .001 .001

Feather River .133 .053 .077

Glenn .011 .004 .006

Shasta .080 .032 .046

Tehama .029 .011 .017

Totals .289 .115 .167
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 11

Note: The reductions are rough estimates and data does not account for emission grow th from 2001 

into the future. Tier 2 reductions are estimates based on limits that have not yet been implemented. 

(1) Air Resources Board, State of California (1998). Industrial Surface Coatings-Wood Furniture and 

Fixtures Emission, June. Inventory Development 

(2) Air Resources Board, State of California. California Emission Inventory Development and 

Reporting System (CEIDARS) database.

IV. OTHER FACTORS:

Enforceability

Record keeping requirements and test methods are included in the rule to increase its enforceability, as required by ARB and EPA.

Public Acceptability

Based on the cost-effectiveness figures previously discussed, the District expects the rule and any 

associated costs to be acceptable to affected industry. If a business chooses to comply w ith the 

requirements of the rule by using compliant w ood product coatings, monthly records w ill be required; 

w hereas those choosing control equipment or emissions averaging must maintain daily records.

Permit Fees

In addition to the actual costs incurred by industry for the compliant coatings, higher transfer 

application equipment, or add-on equipment to destroy VOC emissions, District regulations also 

require payment of permit fees for stationary sources. In the w ood coatings industry, the average 

initial fee w ithin the NSVAB for permitting VOC emissions and proper equipment varies f rom $300-

$500. Each Management District has various factors that determine final fee due.

V. SOCIOECONOMIC IMPACTS:

Type of Industry Affected

This rule w ill affect manufacturers, suppliers, users, and those w ho specify the use of w ood 

coatings, inks, stains, surface preparation materials, cleanup materials, and/or strippers. Those 

businesses using the w ood products coatings w ill be required to comply w ith the solvent and coating 

limits specified in the rule, as w ell as to apply the coatings in a manner that maximized the transfer 

efficiency.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 12

Impact on Employment & Economy of Region

If Rule 3:20 is adopted, no adverse impact on employment or the economy is anticipated in the 

District. The basis for this statement is found in the relatively low cost of compliance, as stated in 

the section on cost-effectiveness. 

Range of Probable Costs

See section dealing w ith Cost-Effectiveness, above.

Alternatives

No alternatives to the Rule are proposed at this time

Necessity for Rule

See Section A, Necessity and Authority.

VI. FINDINGS:

The California Health and Safety Code, Division 26, Air Resources, requires local Districts to comply 

w ith a rule adoption protocol as set forth in Section 40727 of the Code. This section has been 

revised through legislative mandate to contain 6 findings that the District must make w hen 

developing, amending, or repealing a rule. These findings, effective January 1, 1992, and their 

definitions are listed in the follow ing table.
Staff Report Feather River Air Quality Management District

Rule 3.20 - WOOD PRODUCT COATINGS

August 30, 2005

Page 13

FINDING DEFINITION REFERENCE

Authority The District is permitted or required 

to adopt, amend, or repeal the rule by 

a provision of law or a state or federal 

regulation.

California Health and Safety Code; 

Sections 40919(e), 41062(a), and 

41011(b).

Necessity The District has demonstrated that a 

need exists for the rule, or for its 

amendment or repeal.

It is necessary for the District to adopt 

this rule in order to comply w ith the 

2000 Northern Sacramento Valley Air 

Basin Attainment Plan.

Clarity The rule is w ritten or displayed so 

that its meaning can be easily 

understood by the persons directly 

affected by it.

To date, there is no indication that the 

rule is difficult to understand by 

persons directly affected by it.

Consistency The rule is in harmony w ith, and not 

in conflict w ith or contradictory to, 

existing statutes, court decisions, or 

state or federal regulations.

The District has found the proposed 

new rule is consistent w ith, and not in 

conflict w ith, or contrary to existing 

statutes, court decisions, or state or 

federal regulations.

NonduplicationThe rule does not impose the same 

requirements as an existing state or 

federal regulation, unless the District 

finds that the requirements are 

necessary or proper to execute the 

pow ers and duties granted to, and 

imposed upon the District.

Rule 3:20 is being proposed for local 

rule adoption, and does not duplicate an 

existing state or federal regulation.

Reference Any statute, court decision, or other 

provision of law that the District 

implements, interprets, or makes 

specific by adopting, amending, or 

repealing the rule. An example of this 

w ould be the 1988 EPA State 

Implementation Plan call to revise 

District rules.

Adoption of this rule is recommended in

order to meet one of the goals of the 

2000 Northern Sacramento Valley Air 

Basin Attainment Plan.