ATTACHMENT 2 

VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT 

FINDINGSPURSUANT TO HEALTH AND SAFETY CODE 

 SECTIONS 40001, 40703, 40727, 40727.2, 40728.5, AND 40920.6 

FOR PROPOSED AMENDMENTS TO RULE 74.2, ARCHITECTURAL COATINGS 

1. NECESSITY: Amendments to Rule 74.2 are necessary to obtain additional ROC emission 

reductions in order to attain state and federal ambient air quality standards for ozone. 

2. AUTHORITY: The Ventura County Air Pollution Control District is authorized and 

required by the California Health and Safety Code Division 26, Part 3, Sections 40000 and 

40001, to adopt and enforce rules and regulations to meet and maintain state and federal 

ambient air quality standards. 

3. CLARITY: The amendments to Rule 74.2 can be easily understood by the persons directly 

affected by them. 

4. CONSISTENCY: The amendments to Rule 74.2 are in harmony with, and not in conflict 

with or contradictory to, existing statutes, court decisions, or state or federal regulations. 

5. COST-EFFECTIVENESS and SOCIOECONOMIC IMPACTS: Factors related to the costeffectiveness and socioeconomic impacts of adopting amendments to Rule 74.2 are set forth 

in Attachment 4 and have been considered in adopting amendments to Rule 74.2. This rule, 

mainly impacts non-permitted or area sources including paint manufacturers, painting 

contractors, and consumers. The proposed amendments to this rule were developed and its 

economic impacts were analyzed by the South Coast AQMD and the California Air 

Resources Board (ARB). Due to limited district resources, staff is relying on the analyses 

and recommendations by ARB regarding costs and socio-economic impacts. Staff is 

convinced that economic impacts will be minimal because coatings that comply with the 

South Coast AQMD Rule 1113 are already being sold in the county in direct competition 

with higher ROC-containing paints. Support of the proposal by both the National Paint and 

Coatings Association and Dunn Edwards, the largest regional paint supplier, indicate that 

the new proposed standards will enable producers to provide quality products to their 

customers. Although ARB has identified potential cost issues, the magnitude of any price 

increases are believed to be small and well worth the anticipated air quality benefits. 

6. NONDUPLICATION: Amended Rule 74.2 does not impose the same requirements as an 

existing state or federal regulation and are necessary to execute the duties imposed upon the 

District. 
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7. REFERENCE: California Health and Safety Code Division 26, Part 3, Sections 40000 and 

40001 are the sections of state law that will be implemented by the adoption of amendments 

to Rule 74.2. 

8. ATTAINMENT OF AMBIENT AIR QUALITY STANDARDS: Ventura County has been 

designated a severe nonattainment area for both the state and federal ozone ambient air 

quality standards. Reactive organic compound emissions are precursors to the formation of 

ozone. Adoption of amendments to Rule 74.2 will reduce emissions of reactive organic 

compounds, which will help Ventura County move closer to attainment of the state and 

federal ambient air quality standards for ozone. 

9. ANALYSIS OF AIR POLLUTION CONTROL REQUIREMENTS: Section 40727.2 of the 

Health and Safety Code requires that the District prepare a written analysis that identifies 

certain federal, state, and District air pollution control requirements that apply to the same 

equipment or source type regulated by proposed amendments to Rule 74.2. Staff has 

analyzed federal and state emission regulations that correspond with proposed amendments 

to Rule 74.2. This analysis has been prepared and is set forth in Attachment 4. 

10 REASON FOR ADOPTION AND INCREMENTAL COST-EFFECTIVENESS: 

Amendments to Rule 74.2 are necessary to obtain emission reductions required to move 

closer to the goals of meeting state and federal air quality standards for ozone. Further, the 

control option for amending Rule 74.2 that staff is recommending for adoption is 

substantially more cost-effective than the other two rulemaking options which were 

considered. This analysis is contained in Attachment 4. 

CALIFORNIA ENVIRONMENTAL QUALITY ACT FINDINGS FOR PROPOSED 

AMENDED RULE 74.2 

11. Based on the environmental impact analysis of the amended Rule 74.2 set forth in the FEIR 

and substantial evidence in the record before the VCAPCD decision-making body, it is 

determined that this rulemaking project does not have the potential to cause significant 

environmental impacts either on a project specific or cumulative impact basis and therefore 

no mitigation measures are necessary. 
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