### VENTURA COUNTY APCD

FINAL STAFF REPORT
REVISIONS TO RULE 74. 18

, MOTOR VEHICLE
AND MOBILE EQUIPMENT COATING OPERATION

November 11, 2008

EXECUTIVE SUMMARY

As a nonattainment area for both federal and state

ozone air quality standards, Ventura County is subject to requirements of both the federal Clean Air

Act Amendment s of 1990 and the California Clean Air

Act. Health and Safety Code Section 40914 requires a

five percent annual emission reduction unless the District uses an alternative strategy that inc ludes All

Feasible Measures . On October 20, 2005, the

California Air Resources Board (ARB) adopted a Suggested Control Measure (SCM) for Automotive Coatings. This SCM is a feasible measure required to be adopted by Districts to comply with Health and

Saf ety Code Section 40914.

Adopting the SCM by Ventura County APCD will garner significant emission reduction s of Reactive Organic Compounds (ROC), a precursor to ambient

ozone formation. ROC emission reductions of approximately 73 tons per year are expec ted from the proposed new standards for coatings and solvent cleaners used by the automobile and truck refinish industry. These emission re ductions will help the

District to attain its goals of meeting bo th the federal eight

- hour and state one

- hour ozone standards.

The proposed amendments to Rule 74.18 include all

the new requirements established by the SCM for

automotive coatings and cleaners. The most significant proposed change is the new low

- ROC content requirement for color coats used commonly in

ba secoat/clearcoat auto body shop repairs. According to the coating manufacturers, water

- based color coats are the only available coating technology able to meet this proposed new ROC limit. Although

water

- based color coating technology was developed

over a decade ago as described in a 1994 VCAPCD Rule 74.18 staff report

, this new requirement will finally cause this technological break

- through to be implemented.

Two other significant change to the coating ROC limits includes a new limit of 340 gram s per liter for single

- stage topcoats and a new limit of 250 grams per liter for primer sealers. This topcoat limit applies to both metallic or iridescent coatings as well as nonmetallic topcoats. These coatings may still be

solvent

- based as exemplified by two

- component poly urethane coatings. The new primer sealers may also be solvent

- based, and are available in either two

component or ready

- to

- spray, one

- component systems.

Another proposed rule amendment based on the SCM

that impact s coatings is the deletion of the specialty coating category. In the current rule, this was a

catch

- all category of small use coatings that were allowed a higher ROC content limit of 840 grams per liter. Instead of the specialty coating category, the

Air Resources Board has creat ed several individual coating categories to obtain additional emission

reduction s . These new categories include truck bed liner coatings, underbody coatings, and uniform finish coatings. In addition, there is a new default coating category with an ROC li mit of 250 grams per

liter for all those coatings that do not belong to one of the coating categories defined in the rule

.

The other major proposed change to Rule 74.18 based

on the SCM is the new low ROC standard for cleaning

solvents. The new ROC limit for all cleaners, including substrate surface preparation and spray gun cleaning is 25 grams per liter except for a new

small

- use exemption for substrate surface preparation

. Low

- ROC cleaners may include exempt ROC solvents

or exempt solvent blends that contain acetone, methyl acetate, or parachlorobenzotrifluoride (PCBTF)

. Also,

new water

- based cleaners have been developed to clean spray guns using the waterborne coatings.

The new small

- use exemption from the 25 grams per

liter limit for surface prepar ation cleaners is an exception from the SCM, and is based on comments received at the April 29, 2008

, APCD rule workshop and the adoption of a similar exemption by the Santa Barbara County APCD on June 19, 2008. Although the ARB recommends eliminating thi s exemption because of stringency concerns, Santa Barbara’s adopted amendments to Rule 339 were not disapproved because the rule reduces ROC emissions

overall.

The major cost of complying with the proposed rule

amendments to the 13 6

permitted auto and tru ck repair

and refinishing facilities in the county centers around

the conversion to the waterborne color coat. These coatings are typically used at auto body shops to

### Rule 74.18 Staff Report Page 2

repair damaged vehicles. The costs of this conversion for a one spray booth operation w as estimated by ARB to be $6,600 per facility. This includes costs for additional air movement equipment or fans to decrease dry times, new or modified spray equipment, new spray gun washers, and cost of painter training t o understand how to spray the new coatings. The cost

- effectiveness of the proposed rule amendments was estimated by ARB at $1.43 per pound of ROC reduced. This compares favorably with the $9 per pound cost

- effectiveness used to evaluate the cost of air pollution control equipment by new sources.

The proposed rule amendments do provide some relief to industry in the form of reduced recordkeeping requirements. D aily records of coatings applied and mixed will no longer be required, and monthly usage records of specialty coatings will no l onger be

needed.

Finally, the enforcement of the rule by District inspectors will be more easily accomplished by implementing proposed changes to the rule. Two significant changes are the deletion of the averaging provision for multi

- stage topcoats, an d the new requirement that prohibits possession of illegal coatings or cleaning solvents. The averaging provision made the enforcement of the sales prohibition especially difficult for multistage topcoats

because high

- ROC color coats could be averaged wi th low

- ROC clear coats. Now that they will have separate ROC limits, compliance with these rule requirements will be more easily determined. The new prohibition against possession of illegal products will allow inspectors to cite violators without having to observe vehicle refinishing in progress.

This report contains six

additional sections: (1) Background,

(2) Regulatory History ( 3 ) Proposed Rule Requirements, ( 4 ) Comparison of Proposed Rule Requirements with Other Air Pollution Control

Re quirements, ( 5 ) Impact of the Proposed Rule, and ( 6 ) Environmental Impacts of Methods of Compliance/

California Environmen t al Quality Act (CEQA). The first section provides background informat ion including a description of sources affected by Rule 74.18, and health effects of ROC emissions

. The second section describes the regulatory history of the rule since it was adopted in 1992, and the current history of the 2005 SCM. The third section explains the key features of the pr oposed revisions to Rule

74.1 8 . The fourth section compares the proposed requirements with existing federal requirements and

Best Available Contro l Technology (BACT). The

fifth section is an ana lysis of the proposed

amendment s ’ effect on ROC emissions and socioeconomic impacts. The last section examines the environmental impacts of compliance methods and the mitigations of those impacts, and CEQA Compliance.

BACKGROUND

Introduction

Rule 74.18 is applicable to any automotive, truck or mobile equipment coating operation in Vent ura County . Automotive coatings are applied to motor vehicles and mobile equipment to protect and enhance the appearance of exterior surfaces. These coatings may be applied as a last step of a repair following an accident, to rectify damage that occur re d in transit, or to correct a defect that occurred during the manufacturing process. An entire or portion of a

v ehicle may also simply be recoated to change their color or appearance. Finally, mobile equipment may be coated as one of the last steps in th e manufacturing process. Motor vehicle and mobile equipment coating facilities include six broad categories:

• Auto body repair/paint shops

• Production auto body paint shops

• New car dealer repair/paint shops • Fleet operators repair/paint shops

• Truck body

- bu ilders

• Mobile equipment manufacturers/dealers

Coating may be done on a spot, a panel, or the entire vehicle or mobile equipment. Spot repair and paint work is generally performed on a small damaged area. The repair work would generally include the physi cal repair of the damaged area, conditioning of the substrate, and application of primers and topcoats. Panel repair is similar to that of a spot repair except

that the work area is larger, as it may include a hood, fender or door. Complete paint jobs ar e performed to repair a faded color on a vehicle or mobile equipment, or simply to change the color of the vehicle.

Health Effects

ROC emissions from automotive coatings and cleaning solvents are precursors to the formation of

### Rule 74.18 Staff Report Page 3

both ozone and fine parti culate matter (PM). Ventura County exceeds both the state and federal standards for ambient ozone, and the state standard for PM. Ozone is formed from photochemical reactions of oxides of nitrogen and ROCs. Scientific studies show that exposure to ozone can result in reduced lung function, increased respiratory symptoms, and increased airway inflammation. Exposure to ozone is associated with premature death, hospitalization for cardiopulmonary causes, asthma episodes, and restrictions in physical activi ty. Ozone is a strong oxidizer and exposure to leve ls of ozone exceeding the current ambient standards lead to a variety of adverse health effects, as well as reduction of crop production, and damage to plants and property. Emissions of ROCs also react i n the atmosphere to form fine particulate matter (PM10 and PM2.5). Inhalation of these fine particles reduces pulmonary function. Premature death is also linked to PM exposure, and are comparable to deaths from

motor vehicle accidents and second

- hand smo ke.

REGULATORY HISTORY

Introduction

Ventura County APCD Rule 74.18 was first adopted on January 28, 1992, and at the same time the District required APCD Permits for every automotive coating facility in the county, without exception. At the time of the rule adoption, industry voiced concern that underground or “black market” automotive painting shops would have an unfair advantage over the regulated vehicle refinish community. At the time, this industry was one of the largest source of ROC

emissi ons that had not been previously regulated. Also, the District was the recipient of numerous nuisance complaints resulting from overspray or odor problems.

Two of the new requirements from the original adoption of Rule 74.18 not only reduced ROC

emission s but saved costs by reducing material usages. The High Volume Low Pressure spray equipment increased the coating transfer efficiency over conventional sprayers, which reduced overspray. This operational change enabled reduced consumption of coatings whi le enabling the application of a quality finish. The other new requirement from the original rule adoption was the spray gun cleaner, which reduce s cleaning solvent usage. These are two examples of changes to the industry that not only benefitted the env ironment, but made for more efficient operations.

An overall evaluation of the impact of Rule 74.18 over the past sixteen years reveals how industry and APCD have worked together to accomplish both emission reductions with improved environmental practices at the same time as a thriving automotive refinish industry whose end product has improved over the years. The 1992 staff report for the original rule adoption estimated that the rule would impact approximately 100 companies. The District data base

of a ll permitted operations impacted by Rule 74.18 lists 136 facilities (detailed in Appendix A). Clearly, the adoption of this regulation in 1992 has not led to the abandonment, consolidation, or shrinkage of the

vehicle refinish industry in the county.

T he last major amendments to Rule 74.18 were approved by the Ventura County Air Pollution Control District Board on December 13, 1994. The last amendments adopted on September 10, 1996, were minor rule cleanups. The 1994 amendments and a 1998 product vari ance provided industry with extra time to develop the high

- solid

, low

- ROC clear coats at 2.1 pounds ROC per gallon. This coating was used to average with the high

- ROC

, color coats to meet the multistage topcoat limit in Rule 74.18 at 3.5 pounds ROC per ga llon. The new proposal would no longer allow this averaging of ROC contents of color coats with clear coats. One of the major provisions of the proposed rule will require that these high

- ROC

, color

coats be reformulated as low

- ROC coatings. Based

on ear ly adopters of the proposed SCM by auto body shops in the southland, the new technology for color coats will be waterborne coatings.

2005 Suggested Control Measure

On October 20, 2005, the Air Resources Board adopted the Suggested Control Measure (SCM) f or Automotive Coatings. This SCM is designed to adopted by the Districts to further reduce ROC emissions and is a requirement for Districts subject to Health and Safety Code Section 40914. Since Ventura County is a nonattainment area for ozone, VCAPCD is required by this state law to adopt all feasible measures to show progress in achieving these standards. According to a letter from the Air Resources Board, dated June 8, 2007, the ARB has

### Rule 74.18 Staff Report Page 4

determined that the SCM is a feasible measure that must be adopte d by VCAPCD.

In developing the SCM, ARB worked with both industry and the Districts to create a reasonable control measure that will reduce significant ROC emissions. ARB used a survey of automotive coatings sold in California that was performed in 200 1 to assess the emission inventory. Approximately 3.7 million gallons of automotive coatings were sold in California in 2001. On a population basis, this would

translate to sales of about 74,000 gallons per year sold in Ventura County. Approximately 95 percent of

these coatings were supplied by s even automotive coating manufacturers including Dupont, Ak zo Nobel, BASF, Ellis Paint, PPG

, and Sherwin Williams

.

ARB staff reviewed the feasibility and availability of coatings that would comply with the propos ed ROC limits, and determined that complying coatings for all coating categories would be available by January 1, 2009, except for three coating categories including primer sealers, single

- stage coatings, and adhesion promoters. The effective date was pus hed back an additional year to January 1, 2010, for these coatings.

The SCM also contained new ROC limits for surface prep solvents and solvent cleaners used to clean spray guns. This new limit at 25 grams of ROC per liter of material was based on a requ irement from South Coast AQMD Rule 1171, Solvent Cleaning, and a Technology Assessment prepared for the South Coast AQMD entitled, “Assessment, Development,

and Demonstration of Low

- VOC Cleaning Systems for South Coast Air Quality Management District Rule 1171.” This report was prepared in August of 2003 by Mike Morris and Katy Wolf of IRTA.

ARB staff also prepared an environmental impacts analysis and economic impacts analysis of the SCM.

The cost

- effectiveness of the SCM proposal was estimated at $1. 43 per pound of ROC reduced. This is well within the cost range of recently adopted regulations, and much less than the $9 per pound of ROC threshold required for new air pollution sources.

An Exception to the SCM

One exception to the SCM being propose d is a small

use exemption for surface preparation cleaners subject to the new solvent cleaning requirement of 25

grams of ROC /liter, effective January 1, 2010. Staff became convinced that this exemption was needed after hearing comments at the April 29, 2008, rule workshop on the ineffectiveness of existing cleaners meeting the existing 200 g/l limit, not to mention the problems anticipated when the ROC limits drops to 25 g/l.

This proposed exemption (described in detail in the New Proposed Rule Requirem ents section) is based on a similar exemption adopted by Santa Barbara County APCD on June 19 , 2008 . ARB had

recommended that Santa Barbara delete this exemption from their rule proposal based on lower rule stringency (No similar exemption is contained in the SCM), but over half the auto body shops in Santa Barbara county signed a petition requesting the exemption. In the end, ARB did not disapprove the

Santa Barbara rule amendments because ROC emissions were reduced overall, based on the new coating limi ts.

Other Air District Auto Body Rules

On December 2, 2005, the South Coast AQMD adopted amendment s to their Rule 1151, Motor Vehicle and Mobile Equipment Non

- Assembly Line Coating Operations, which were based on the proposed SCM coating limits. In fa ct, the starting point for the SCM development was the SCAQMD Rule 1151. Approximately 90 percent of the proposed emission reduction are due to the lowering the ROC content of the color coat, and its waterborne technology. Waterborne color coats have bee n used in Europe for many years and its use there was mandated starting in January 1, 2007. Thus, the European adoption of this technology set the stage for its implementation in California.

The only other Air District to fully adopt the SCM is

the San Joaquin V

alley APCD, which adopted Rule 4612, Motor Vehicle and Mobile Equipment Coating, Phase II, on September 21, 2006. Recently, Santa Barbara County APCD adopted amendments to their Rule 339, which was based on the SCM except for a small use exempti

on for surface preparation cleaning

solvents.

Field Research

–

Early SCM Adopters

One advantage of not being the first District to adopt new rule requirements is that we can get real

- world feedback from auto body shops that have already adopted the SCM requirements. Staff visited four auto body shops that are currently using the

waterborne color coats and low ROC cleaners. These include three shops in Ventura County: Superior Collision Center in Oxnard, Tony’s Body Shop in Oxnard, and North Ranch Bod y Craft in Thousand Oaks. Also, staff visited 101 Collision in Westlake Village, which is located in Los Angeles County and

### Rule 74.18 Staff Report Page 5

governed by South Coast AQMD Rules 1151 and

1171.

The color coat s used at Superior Collision Center are manufactured by Spies He cker, a German company that has partnered with Dupont. The other shops listed used color coats manufactured by Akzo Nobel’s Sikkens Division, which has th eir headquarters in Amsterdam. It is no surprise that the European multinational companies are intro ducing their products early because European requirements became effective at the beginning of 2007. Another European multinational automotive coating company, BASF, has already converted most of their shops in Ventura County to the new waterborne color c oats.

For all shops visited, the new color coats are performing at levels equal to or superior than the

solvent

- based versions. The transformation from a

solvent

- based to waterborne system has not been without some adjustments by the shops and their pain ters. Capital costs to upgrade shops have been in the thousands of dollars, but the spray booth upgrades can be accomplished in a few days usually over the weekend. These upgrades consists of adding fans or air movement equipment to accelerate the drying of the waterborne coatings.

All four shops were also using the new low

- ROC cleaners at 25 grams per liter for both spray gun cleaning and substrate surface preparation. These

cleaners seem to be working well enough for the shops to maintain their produc t quality without sacrificing production. However, more recent workshop comments have indicated that there may still be problems associated with removing road tar, waxes, and other contaminants from surfaces prior to coating. Based on this limited survey , the bottom line

for each of t hese field visits is that the SCM requirements are feasible to implement, with one exception being the low

- ROC surface preparation

cleaners.

NEW PROPOSED RULE REQUIREMENTS

New ROC Content Standards for Coatings (Section B .1)

The proposed ROC content standard s for coatings are identical to the limits adopted by the ARB in the Suggested Control Measure ( Table 1 ) . The effective dates for most of the new coating requirements including the new color coating category is Januar y 1, 2009. At the time of the adoption of the SCM in October 2005, the coatings industry requested an additional year for some of the coating categories

where additional time was needed for reformulation and testing. These categories included adhesion

pr omoters, the primer sealer category, and the single

stage topcoat category.

A significant proposal, which will increase the enforceability of the rule, will no longer average the

ROC contents of the colorcoat and clearcoat in the former category known as multistage topcoats. Each of these subcategories will have their own ROC content limit as shown in Table 1. This will simplify enforcement and enable inspectors to cite illegal colorcoats or clearcoats without having to determine which coatings belong to gether in a system. This will be especially true at retail coating outlets where determining coating systems in the past was very difficult to prove for on

- the

- shelf coatings in the enforcement of the sales prohibition.

Another significant change to the coating requirements was the deletion of the catch

- all specialty coating category, which allow ed limited use of some high ROC coatings. Instead ARB adopted new individual categories that were formerly included in the specialty coating category. Examples of these former specialty coatings that have their own ROC limit include adhesion promoters, multi

- color coatings, truck bed liner coating, underbody coating, and uniform finish coating. Finally, ARB has proposed a default category with a 250 gram/liter R OC content limit for any coating that is not defined by one of the listed categories.

The proposed rule amendments contain a new exemption for aerosol coatings that meet the state consumer product regulations. Use of these products may be suitable for small use specialized situations, and provide coating choices that were formerly regulated under the specialty coating category.

### Rule 74.18 Staff Report Page 6



### Table 1. Proposed New Coating ROC Regulatory Limits (grams/liter)
Coating Category Effective Adoption Date Effective

January 1

2009 Effective

January 1,

2010

Adhesion Promoter 840 540 Clear Coating 250 Color Coating 760 420

Multi

- Color Coating 840 680 Pretreatment Coating 780 660

Primer 250

Primer Sealer 340 250 Single

- Stage Coating

Nonmetallic/Noniridescen t 420 340

Single Stage Metallic/Iridescent Coating 520 340 Temporary Protective Coating 420 60 Truck Bed Liner Coating 840 310 Underbody Coating 840 430 Uniform Finish Coating 840 540 Water Reducible Electrophoretic Brake Component Coating 440 Any other coating type (default) 840 250

New Cleani ng Standard (Sections B. 8 )

Effective January 1, 2010, t he proposed ROC Content

standard for surface prep, general cleanup

, and application equipment cleaning will be 2 5 grams/liter except for a sma ll

- use surface preparation cleaner exemption (described on the following page)

. Except for this one exemption, t his proposal is identical to the

SCM

.

The existing Rule 74.18 does not have an exemption

for aerosol cleaners nor is a broad

- use aerosol

exemp tion being considered for this rule proposal. However, as part of the small

- use exemption for surface preparation cleaners, limited amounts of aerosol cleaners will be allowed provided all

conditions for use are met. If allowed and used by body shops, th e general use of aerosol cleaners would negate much of the anticipated emission reductions gained by this rule proposal. The

unlimited u se of aerosol cleaners, which have very high ROC content, would undermine the emission reduction potential of the new l ow R OC content cleaner requirement.

Prohibition of Possession (Section B. 10 )

A new enforcement provision from the SCM is the prohibition of possession. This provision will enable District inspectors to cite operators who have illegal coatings or cleanin g solvents at their facility. This will increase the rule’s enforceability by enabling inspectors to cite shops without having to witness the actual use of illegal materials.

Two proposed exemptions from the prohibition of possession are paint strippers and surface prep cleaners designated in a pre

- approved compliance plan and tagged with a unique label or sticker. Paint strippers are not regulated by Rule 74,18, and ROC emissions from surface preparation cleaners are proposed to be limited to 136 pounds of ROC per year per shop

.

Air Toxic Control Measure for Automotive Coatings (Section B.11)

Existing state regulations (Title 17, Section 93112) prohibit the use of coatings containing the air toxics, hexavalent chromium and cadmium. This provision is included in Rule 74.18 to reinforce state regulations that are more stringent than the existing air toxic requirements for chromium and cadmium. Compounds containing hexavalent chromium or cadmium are very hazardous to human health and are considered to b e human carcinogens.

OSHA Standard for Spray Finishing Operations

(Section B.1 4 )

The state Occupational Safety and Health standards for spray finishing operations are cited in Rule 74.18 to emphasize the potential flammability hazard from using acetone o r acetone blends as cleaning agents.

### Rule 74.18 Staff Report Page 7

These state regulations require the proper storage and handling of flammable materials including prevention of spills, closed containers, and adequate

ventilation. The District shall not be liable for the

misuse of an y of these flammable materials.

“Clean Air Solvent” Exemption (Section C.8 )

Clean Air Solvents are proposed to be exempt from the rule because of their low emission potential. The concept of clean air solvents was developed by the South Coast AQMD to en courage the use of low

emitting cleaners. These products are defined by SCAQMD Rule 102 (definitions). A Clean Air Solvent

is a VOC

- containing material used to perform solvent cleaning, solvent finishing, or surface preparation operations or activities w hich:

• Contains no more than 25 grams per liter of material, as applied;

• Has a VOC composite partial vapor pressure less than 5mm of Hg at 20 o C;

• Reacts to form ozone at a rate not exceeding that of toluene;

• Contains no compounds classified as

Hazardous Air Pollutants (HAPs) by the federal Clean Air Act, or ozone

- depleting compounds as defined by SCAQMD, or global

- warming compounds as defined by SCAQMD; and

• Has been certified by the SCAQMD to meet the above criteria using test methods and procedures approve d by the SCAQMD.

A Clean Air Solvent Certificate is issued by the SCAQMD for a solvent that meets the criteria in the above definition. This written proof of certification is

needed to qualify for this proposed exemption from

Rule 74.18.

Exemption for A

gricultural Sources (Section C. 10 )

Senate Bill 700, which was adopted by the legislature in 2003, revised air quality regulations by removing the exemption of agricultural sources of air pollution from permit and local air quality regulations. Since the agricultural sources of vehicle coating emissions is a very small part of inventory, staff is proposing to keep these small operations exempt from Rule 74.18

. The definition of agricultural sources of air pollution in the proposed exemption is derived di rectly from Health and Safety Code Section 39011.5.

Small

- Use Exemption for Surface Preparation Cleaners (Section C.12) The proposed surface preparation cleaner small

- use exemption has been designed to be flexible and

enforceable. The Santa Barbara vers ion is based on an allowance of 20 gallons of non

- compliant cleaner per year (having a maximum 6. 5 pounds ROC per gallon) per shop, and prohibits the use of aerosol cleaners. The Ventura proposal is more flexible

because it allows the use of aerosol clean ers in addition to bulk liquid cleaners by establishing an exemption emission threshold in terms of pounds rather than gallons. Using the Santa Barbara rule, this threshold is proposed to be 13 0 pounds ROC per year (based on 20 gallons X 6. 5 pounds/gallon ).

The Ventura proposal is more enforceable because it requires operators who are interested in obtaining this exemption to implement a simple compliance plan. This compliance plan contains a list of pre

- designated

non

- compliant cleaners and establishes a labeling or tagging system to identify all non

- compliant cleaners in the shop covered under the exemption. Another

one of ARB’s concerns with Santa Barbara’s exemption was that by allowing the use of any noncompliant cleaners, it would nullify the new

p rohibition of possession requirement. This new illegal possession provision increases the rule’s enforceability by providing inspectors with a new enforcement tool to more easily determine compliance. Ventura’s proposal would help restore the

effectivene ss of this provision.

New Recordkeeping Requirements (Section D)

Staff is proposing to delete the daily recordkeeping requirements of coatings applied and mixing ratios. It is no longer necessary to monitor these coatings so closely to enforce the ROC limits in the rule. This is especially true for the waterborne coatings. Instead, monthly purchase records of coatings and cleaning solvents are required.

### Rule 74.1 8 Staff Report Page 8

COMPARISON OF PROPOSED RULE REQUIREMENTS
WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS

Health and Safety Code Section 40727.2 requires Districts to compare the requirements of a proposed revised rule with other air pollution control requirements. These other air pollution control requirements include federal New Source Performance Standards (NSPS ), federal National Emissions Standards for Hazardous Air Pollutants (NESHAPS), Best Available Control Technology (BACT) and any other District rule applying to the same equipment.

Comparison with Federal and APCD

Regulations

On September 11, 1998, the E nvironmental Protection Agency (EPA) promulgated national volatile organic compound (VOC) standards for automobile refinish coatings pursuant to Section 183(e) of the Clean Air Act. On Page 48808 of the Federal Register (September 11, 1998, Volume 63, Nu mber 176), EPA states that although regulated entities in all states will be required to comply with the national standards, some states may wish to promulgate VOC standards more stringent than the national rule to assist in achieving attainment with the f ederal ambient air quality standards for ozone. VOC or ROC emission are precursors to the formation of ozone. The proposed standards adopted by ARB in their SCM are more stringent than the national rule.

On January 9, 2008, EPA adopted a National

Emis sions Standard for Hazardous Air Pollutants (NESHAPs) for Paint Stripping and Automotive Refinishing. These regulations only apply if the shops use paint strippers containing methylene chloride or if the coatings applied contain any one of the following t arget Hazardous Air Pollutants (HAPs): chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni) or cadmium (Cd). Proposed amendments to Rule 74.18 will contain a provision that adopts the California Air Toxic Control Measure restricting the use of

hexavalen t chromium and cadmium.

For those sources that apply toners containing lead,

non

- hexavalent chromium or nickel, they may be subject to the new NESHAP, which has similar requirements to APCD Rule 74.18 with one exception. The EPA regulation has a requir ed painter training provision not found in Rule 74.18. Almost all of the new coating and toners have been reformulated without these toxic metals so that sources may petition EPA to be exempt from the NESHAP.

Comparison with BACT Requirements

Health and Safety Code Section 40727.2 (a) requires the proposed amendments to Rule 74.1 8 be compared

with Best Available Control Technology ( BACT )

. The 2005 SCM developed by the Air Resources Board has new requirements that are considered to be

BACT. This rule de velopment is based directly on and contains all the requirements of the SCM.

IMPACT OF THE PROPOS ED RULE

ROC Emissions Impacts

The current permitted ROC emission inventory from

the vehicle coating operations is about 220 tons of ROC per year. The a ctual ROC emissions are approximately 168 tons per year based on the 200 2 ARB statewide survey, corrected for county population. The estimated control of actual emissions

is about 0.2

tons per day or about 73 tons of ROC per

year.

Cost

- Effectiveness

A ccording to the 2005 ARB staff report for the Suggested Control Measure, the overall estimated

cost

- effectiveness is $1.43 per pound of ROC reduced. ARB performed an analysis of economic impacts on the implementation of the SCM. This analysis may be foun d in Chapter VII of the Staff Report for the Proposed SCM for Automotive Coatings dated October 2005.

Incremental Cost

- Effectiveness Analysis

Health and Safety Code Section 40920.6(a) requires districts to identify one or more potential control options , assess the cost

- effectiveness of those options, and calculate the incremental cost

effectiveness. Health and Safety Code Section 40920.6 also requires an assessment of the

incremental cost

- effectiveness for proposed regulations relative to ozone, carbon monoxide (CO),

### Rule 74.1 8 Staff Report Page 9

sulfur oxides (S O x), nitrogen oxides (NOx), and their

precursors.

Incremental cost

- effectiveness is defined as the difference in control costs divided by the difference in emission reductions between two potential control options achieving the same emission reduction goal of a regulation. The proposed amendments require the most stringent viable ROC limits with no other viable control option that can achieve the same amount of emission reductions. Therefore, the

incremental cost

- effective ness analysis does not apply to this rulemaking.

Socioeconomic Analysis

Assembly Bill 2061 (Polanco), effective January 1, 1992, requires the District Board consider the socioeconomic impacts of any new rule. The Board must evaluate the following socioe conomic information on proposed amendments to Rule 74.1 8

.

(1) The type of industries or businesses, including small business, affected by the rule or regulation.

The adoption of amendments to Rule 74.1 8 will directly affect the sources that coat motor vehicles and mobile equipment in the county (see list in Appendix A ).

(2) The impact of the rule amendments on employment and the economy of the region.

Revisions to Rule 74.1 8 are not expected to have a negative impact on either employment or

the ec onomy of Ventura County. Currently, at least 10 percent of the auto body shops in the county have already adopted the new waterborne color coat technologies

. The ARB staff report in Chapter VII, Section C, evaluated the economic impacts on California bus inesses.

According to this report, the estimated average decline in profitability is about 15 percent for the automotive refinish facilities. If the entire cost of the proposed SCM were passed on to consumers, the average price for a repair or refinish would increase by about $11, which represents an increase of 0.5% for a $2,200 repair. (3) The range of probable costs, including costs to industry or business,and including small business, of the rule or regulation.

According to the ARB staff report, t he

overall cost

- effectiveness is approximately $1.43 per pound of ROC reduced. This compares favorably to new sources that are subject to BACT controls up to $9 per pound of ROC

reduced.

(4) The availability and cost

- effectiveness of

alternatives to th e rule or regulation being proposed or amended.

The SCM adopted by ARB was negotiat ed with the automotive coating manufacturers and the National Paint and Coating Association. Specialty coating categories were included for

low

- use operations requiring h igher ROC coatings. Additionally, implementation dates were delayed by one year for certain coating categories requiring reformulation. No alternatives to the SCM were proposed by ARB.

(5) The emission reduction potential of the rule or regulation.

T he anticipated emission reduction potential of the proposed rule amendments is about 0.2
tons per day of ROC emissions. Over 90 percent

of the ROC emission reductions result from the switch from solvent to waterborne coatings for the color or base coat ap plied at almost all auto body shops.

(6) The necessity of adopting, amending, or repealing the rule or regulation in order to attain state and federal ambient air standards pursuant to Chapter 10 (commencing with Section 40910).

Ven tura County is classi fied as a

nonattainment area for both federal and California Ambient Air Quality Standards for ozone. These proposed rule amendments will reduce ROC emissions that are precursors to the formation of ozone. According to the draft 2007 Air Quality Manageme nt Plan (AQMP), these emission reductions will help the District in its

effort to attain the standards.

### Rule 74.1 8 Staff Report Page 10

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE/CEQA California Public Resources Code Section 21159 requires the District to perform an environmental a nalysis of the reasonably foreseeable methods of compliance. The analysis must include the following information on proposed

revisions to Rule 74.1 8 :

(1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance. (2) An analysis of the reasonably foreseeable mitigation measures

. (3) An analysis of the reasonably foreseeable alternative means of compliance with the rule or regulation.

Table 4 lists all reasonably foreseeable compliance methods, the environmental impacts of those methods, and measures that could be used to mitigate the environmental impacts. In addition, Chapter VI of ARB’s staff report contains an analysis of reasonably foreseeable environmental impacts of the method of compliance with the SCM.

Based on available information, the ARB has determined that no significant adverse environmental impacts should occur as a result of districts adopting the SCM. Chapter VI summarized the potential impacts that the proposed SCM may have on wastewater treatment, ai r quality, and hazardous waste disposal.

Table 4 Environmental Impacts and Mitigations of Methods of Compliance

Compliance Methods (including all reasonably foreseeable alternative means of compliance) Reasonably Foreseeable Environmental Impacts Reaso nably Foreseeable Mitigation Measures

Reformulation of coatings or cleaning

solvents Air Quality Impacts: Reformulation may result in the use of toxic materials. Operators must use reformulated products with less or no toxic

materials. Water Impact s: Improper disposal of cleaning solvents or coatings may cause water impacts Compliance with wastewater discharge standards and waste disposal requirements will mitigate these impacts. Human Health Impacts: Cleaning

solvents and coating s may be replac ed with products containing more toxic compounds. Compliance with OSHA safety guidelines (e.g., personal protective equipment, prevention and response, emergency first aid procedures) reduces these impacts. Hazardous Waste Disposal: Cleaning

solvents an d coatings should be

treated as hazardous waste. Compliance with federal and state hazardous waste disposal requirements should mitigate these impacts.

ARB staff also analyzed the potential for air quality impacts from the use of new low

- ROC coating form

ulations that will comply with the proposed coating ROC standards. During past regulatory efforts affecting coatings, industry representatives have alleged that use of low

- ROC coating s may create certain significant adverse air quality impacts.

While sim

ilar concerns were not raised during the development of the SCM, ARB staff examined the following issues to determine if any of these concerns were applicable:

Issue No.1: Will the use of lower ROC automotive coatings result in a thicker film coating?

AR B Response : No. In previous rulemakings on coatings, some industry representatives contended that lower ROC coatings are formulated with high solids contents and were therefore difficult to handle during application, tending to produce a thick film when applied. A thicker film supposedly indicates that a smaller surface area is covered with a given amount of material, thereby increasing ROC emissions per unit of area covered compared to higher ROC coatings. Although high

- solid, low ROC coatings are bein g used (for single stage topcoats and primers), the

### Rule 74.1 8 Staff Report Page 11

recommended film thickness for these coatings is similar to that for higher ROC coatings. Thus, a lower ROC coating would cover the same or larger surface area than a higher ROC coating. Furthermore, th e largest change to the proposed rule involves the switch from solvent

- based to waterborne coatings, where coating film thickness will be unaffected. In fact, coating manufacturers have claimed that coating material usage for the same job will decrease

wh ich means more coverage per gallon applied and fewer ROC emissions.

Issue No. 2: Will the use of lower ROC automotive coatings result in the illegal thinning of the product?

ARB Response: Excessive thinning is not expected to be a problem because many of the coatings already comply with the SCM limits. Additionally, the ROC limit for color coatings is expected to be met with waterborne formulations. Even if thinning with reducers occurs, it would likely be done with water or exempt solvents. As a

resul t, the potential for excessive thinning is minor and concerns about significant adverse air quality impacts are not

warranted.

Issue No. 3: Will the use of lower ROC automotive coatings require additional priming for proper adhesion to

the substrate?

ARB Response: No. Most automotive coating primers are already solvent

- borne coatings, and many already meet the ROC limits in the proposed SCM. Manufacturer’s data show that substrate preparation for low ROC color coatings is similar to substrate preparati on for higher ROC color coatings. No instances of poor adhesion between primers and low ROC color coatings are expected.

Issue No. 4: Will the use of lower ROC automotive coatings require the use of more topcoats?

ARB Response: In previous rulemaking s on coatings, some industry representatives have claimed that the proposed lower ROC coating limits would yield products that provide inferior coverage, resulting in the use of more coats to provide the same coverage as the high ROC counterparts. This is not the case with automotive coatings. In fact,

some low ROC water

- borne coatings provide greater coverage than their solvent

- based counterparts. So additional coats would not be required to obtain the same quality finish.

Issue No. 5: Will the use of lower ROC automotive coatings require more frequent recoating?

ARB Response : No. Water

- borne automotive coatings have been used successfully by the majority of automobile manufacturers for several years. They are also used in manufacturer’s vehicle pro cessing centers, where cars are touched up prior to distribution. Data from the automotive coatings sector do not support the claim that lower ROC automotive coatings require more frequent recoating.

Issue No. 6: Will the use of lower ROC automotive coat ings result in product substitution by the end

- users?

ARB Response : There are currently available low ROC automotive coatings with performance characteristics comparable to higher ROC automotive coatings. Therefore, it is not anticipated that painters w ill substitute a product from a higher ROC category. Typically, manufacturers market coatings as a system and will not warranty the product’s performance if the user deviates from the recommended coatings. Additionally, the products within each

automotiv e coating category are specific to certain applications, and may not be used successfully for different applications.

Issue No. 7: Will the use of lower ROC automotive coatings result in coatings with higher reactivity?

ARB Response : Using the Maximum I ncremental Reactivity (MIR) scale, developed by Professor Carter of UC Riverside, as the basis for comparing reactivity of ROCs, it is true that some of the solvents in solvent

- based coatings (mineral spirits) have a lower reactivity than some ROCs in wate rborne coatings. For example, a typical solvent in waterborne coatings, propylene glycol, is two to three times more reactive than mineral spirits. However, less reactive solvents such as mineral spirits are not extensively used in automotive coatings. These coatings tend to have solvents with higher reactivity, such as xylene and toluene. The reactivity of propylene glycol is approximately one

- third the reactivity, on a per gram basis, of xylene or toluene. Additionally, it is anticipated that

manufac turers will incorporate the use of water and exempt solvents when formulating to meet the ROC limits of the

### Rule 74.1 8 Staff Report Page 12

SCM. We have concluded, based on this information, that the total reactivity of the lower ROC automotive coatings will be less than the reactivity of the higher ROC automotive coatings.

This analysis demonstrates the adoption of revisions to Rule 74.1 8 will not have a significant effect on the environment due to unusual circumstances. The amendments overall reduce emissions by an estimate of 0.2 tons per day of ROC, and are thus categorically exempt from CEQA under Sections 15307 and 15308 of the state CEQA

Guidelines.

REFERENCES

1. Albright, Brian. Changeover Challenges .Paint & Refinishing Trends & Technology Supplement, May 1, 2007.

2. Air Resources Board. 2001 Airborne Toxic

Control Measure for Emission of Hexavalent

Chromium and Cadmium from Motor Vehicle and Mobile Equipment Coatings. (ATCM, 2001)

3. Air Resources Board, 2002 Automotive Refinishing Survey (ARB, 2005)

4. Air Resources Bo ard. California Almanac of Emissions and Air Quality, 2005. (ARB, 2005)

5. Air Resources Board. Final Program Environmental Impact Report Suggested Control Measure for Architectural Coatings. June 2000. (ARB, 2000)

6. Air Resources Board. Staff Report for Suggested Control Measure for Automotive Coatings. October 2005.(ARB, 2005)

7. Air Resources Board. Environmental Impact

Assessment of Tert

- Butyl Acetate. January 2006. (ARB, 2006)

8. Air Resources Board. Suggested Control

Measure for Automotive Co atings, as approved on October 20, 2005.

9. Air Resources Board. Automotive Coatings SCM Board Hearing Transcripts. October 20,

2005.

10. Air Resources Board. Automotive Coatings: Comparison of 2001 CEIDARS vs. 2001 Survey VOC Emissions. (ARB, 2001)

1 1

. Akzo Nobel. GM Approves Sikkens

Autowave for Akzo Nobel . September 2006. 12

. Akzo Nobel. Sikkens Autowave Debuts with Success in California Shops . September 2006.

13

. Autobody News. AQMD Tightens Up VOC

Standards . January 2006.

14. Carter, W.P.L. Do cumentation of the SAPRC

99 Chemical Mechanism for VOC Reactivity

Assessment . ARB Contract No.92

- 329. (Carter, 2000)

1 5

. Dupont. Dupont Cromax Pro

– The Perfect Solution for Low VOC Requirements . Dupont

Refinisher News. Vol 354. Winter 2008.

16

. Enviro nmental Protection Agency. Air Quality Designations and Classifications for

the 8

- Hour Ozone National Ambient Air Quality Standards . Federal Register Volume 69, Number 84, April 30, 2004.

17. Environmental Protection Agency. National

VOC Emission Standa rds fro Automobile Refinish Coatings . Federal Register Volume 63, Number 176, Sept 11, 1998.

18. Environmental Protection Agency. NESHAPS: Paint Stripping & Miscellaneous Surface Coating Operations at Area Sources

. Federal Register, Volume 73, Number 6, January 9, 2008.

19. Letter dated June 1, 2005 to ARB from Mike Veney, Sherwin Williams Regulatory Affairs.

20. Letter dated June 3, 2005 to ARB from Gareth Hughes, Director of Technology, PPG

Industries.

21. Morris, M.K. and Katy Wolf. Assessment,

Deve lopment and Demonstration of Low

VOC Cleaning Systems for SCAQMD Rule

1171 . Institute of Research and Technical Assistance. August 2003. (IRTA, 2003)

### Rule 74.1 8 Staff Report Page 13

22. 3M. PPS

– Paint Preparation System

. http://solutions.3M.com

23. PCL Automotive Coatings. The PCL System: Compliant Cleaning Solvent. effective July 1,

2005.

24. PCL Automotive Coatings. Super Seal Ready to Spray

– 2.1 VOC. Technical Data Sheet.

25. Sherwin Williams. Direct

- to

- Metal Topcoat

– Low

- VOC Acrylic Po lyurethane . Technical

Data Sheet.

26. Sikkens. Simple System

– California

. www.sikkens.net

27. South Coast AQMD. Socioeconomic Impact Report for Rule 1151

– Motor Vehicle & Mobile Equipment for Non

- Assembly Line

C oating Operations . November 2005. (SCAQMD, 2005)

28. South Coast AQMD. Rule 1151

- Motor Vehicle & Mobile Equipment for Non

Assembly Line Coating Operations

. Revised November 8, 2005.

29. South Coast AQMD. Rule 1171

– Solvent Cleaning Operations . Revis ed July 14, 2006.

30. South Coast AQMD. Staff Report for

Amended Rule 1151. October 2005

. (SCAQMD, 2005)

31. South Coast AQMD. Board Hearing for

Revisions to Rule 1151

– Minutes . December 2, 2005.

32. Ventura County APCD. Staff Report for Adoption of Ru le 74.18, Motor Vehicle and Mobile Equipment Coating Operations

. December 11, 1991. (VCAPCD, 1991)

33. Ventura County APCD. Staff Report for Revisions to Rule 74.18, Motor Vehicle And Mobile Equipment Coating Operations

. December 13, 1994. (VCAPCD, 1994)

DISCLAIMER

This report contains references to company and product names to illustrate product availability. Mention of these names is not to be considered an endorsement by the Ventura County Air Pollution Control District.

### Rule 74.1 8 Staff Report Page 14

Appendix A. Permitted Vehicle Refinish Operations in Ventura County

SIC Code SIC Description Facility Name City

7532 Auto Repair & Painting 1

- Day Paint & Body Centers Inc Oxnard

7532 Auto Repair & Painting 101 Collision LP Oxnard

7532 Auto Repair & Painting 212 Body and Restoration Ojai

7532 Auto Repair & Painting A & A Auto Collision Center Oxnard

7532 Auto Repair & Painting A & G Auto Paint er Santa Paula

7532 Auto Repair & Painting A & R Auto Collision Center, Inc. Oxnard

7532 Auto Repair & Painting A

- 1 Truck and Equipment Co. Ventura

7532 Auto Repair & Pa inting Affordable Collision Center Ventura

7532 Auto Repair & Painting Al Innocenti Oxnard

7532 Auto Repair & Painting America Antiques & Classics Ventura

7532 Auto Repair & Painting Amigos Auto Body Oxnard

7532 Auto Repair & Painting Auto Body International Oxnard

7532 Auto Repair & Painting Auto Body Unlimited, Inc. Simi Valley

7532 Auto Repair & Painting Auto Image Restorations and Customs Camarillo

7532 Auto Repair & Painting Autofinders LLC Oxnard

7532 Auto Repair & Painting Avenue Body Shop Ventura

7532 Auto Repair & Painting B & B Auto Body Thousand Oaks

7532 Auto Repair & Painting Barber Ford Body Shop Ventura

7532 Auto R epair & Painting Becker Automotive Design, Inc. Oxnard

7532 Auto Repair & Painting Biggs Customs Camarillo

5012 Automobile Wholesalers BMW of North America, LLC Oxnard

7532 Auto Repair & Painting Bodymaster U.S.A. Ventura

7532 Auto Repair & Painting Bodytech Ltd. Ventura

7532 Auto Repair & Painting Brue's Body Shop Ojai

7532 Auto Repair & Painting Buena Vista Collision Ctr. of Ven Ventura

7532 Auto Repair & Painting Bump & Shine Ventura

7532 Auto Repair & Painting Bundy & Bevilacqu a Inc. Simi Valley

7532 Auto Repair & Painting Bundy & Bevilacqua Inc. Simi Valley

7532 Auto Repair & Painting Bunnin Buick

- GMC, Inc. Oxnard

7532 Auto Repair & Pai nting California Collision Specialists Ventura

7532 Auto Repair & Painting California Motors LLC Camarillo

7532 Auto Repair & Painting Camarillo Auto Body Camarillo

7532 Auto Repair & Painting Campbell's Custom Paint & Body Moorpark

7532 Auto Repair & Painting Candace Steven dba C & S RV Oxnard

7532 Auto Repair & Painting Channel Island Auto Body Oxnard

7532 Auto Repair & Painting City of Thousand Oaks Thousand Oaks

7532 Auto Repair & Painting Class A Auto Body & Paint Simi Valley

7532 Auto Repair & Painting Classic M otor Cars Oxnard

7532 Auto Repair & Painting Coachcraft Fillmore

7532 Auto Repair & Painting Commercial Auto Body Shop Oxnard

7532 Auto Repa ir & Painting Conejo Valley Auto Body Thousand Oaks

5511 New & Used Car Dealers Courtesy Chevrolet Thousand Oaks

5511 New & Used Car Dealers Crown Dodge dba Crown Auto Body Ventura

7532 Auto Repair & Painting Custom Refinishers Ventura

7532 Auto Repair & Painting Daedalus Auto Body Shop Camarillo

7532 Auto Repair & Painting DJ's Auto Collision Cente r Oxnard

7532 Auto Repair & Painting Don & Sons Body & Paint Oxnard

7532 Auto Repair & Painting Dualans Auto Body Oxnard

7532 Auto Repair & Painting E & I Paint & Body Oxnard

### Rule 74.1 8 Staff Report Page 15

7532 Auto Repair & Painting E. J. Harrison & Sons, Inc. Ventura

7532 Auto Repair & Painting Earl Scheib of California Inc. #89 Oxnard

7532 Auto Repair & Painting EPR Collision Camarillo

7532 Auto Repair & Painting Fender Mender Body Shop Ventura

7532 Auto Repair & Painting First Collision Center Inc. Simi Valley

5511 New & Used Car Dealers Ford of Simi Valley, Inc. Simi Valley

7532 Auto Repair & Painting G.I. Rubbish Company Simi Valley

5511 New & Used Car Dealers Gibbs International T ruck Inc. Oxnard

7532 Auto Repair & Painting Global Auto Processing Services,Inc Port Hueneme

7532 Auto Repair & Painting GM Celes Body Shop Fillmore

7532 Auto Repair & Paintin g Gold Coast Acura Ventura

7532 Auto Repair & Painting Gold Coast Custom Canyon Country

7532 Auto Repair & Painting Great American Auto Body Ventura

7532 Auto Repair & Painting Grimaldo Enterprises Fillmore

7532 Auto Repair & Painting GTS Customs Simi Valley

7532 Auto Repair & Painting Hub Auto Body S aticoy

7532 Auto Repair & Painting Integrity Autobody Collision Oxnard

7532 Auto Repair & Painting Iron Horse Custom Factory Simi Valley

7532 Auto Repair & Painting J & C Auto Body Ventura

7532 Auto Repair & Painting Jazz Auto Body Oxnard

7532 Auto Repair & Painting Jim's Fillmore Towing Fillmore

5511 New & Used Car Dealers Kemp Ford Thousand Oaks

7538 General Auto Repair Shops Ken's Automotive Engine Inc. Ventura

5511 New & Used Car Dealers Kirby Oldsmobile

- Jeep/Eagle Ventura

7532 Auto Repair & Painting Leo's Body Shop Ventura

7532 Auto Repair & Painting Maaco Auto Painting/Body Works Ventura

7532 Auto Repair & Painting Marc Hench Auto Repair Ventura

7532 Auto Repair & Painting Mendez Body Shop Oxnard

7532 Auto Repair & Painting Mike's Auto Body Thousand Oaks

7532 Auto Repair & Painting N ew Era Body Shop Oxnard

5511 New & Used Car Dealers New Image Auto Body Santa Paula

7532 Auto Repair & Painting New Vehicle Auto Body & Paint Oxnard

7532 A uto Repair & Painting Newcastle Motors Simi Valley

7532 Auto Repair & Painting North Ranch Bodycraft Thousand Oaks

7532 Auto Repair & Painting O'Loughlin & Company Simi Valley

7532 Auto

Repair & Painting Ocean Body Shop Ventura

7532 Auto Repair & Painting Ortega's Collision Center Ventura

7532 Auto Repair & Painting Oxnard Auto Collision Center Oxnard

8222 Junior Colleges Oxnard College Oxnard

7532 Auto Repair & Painting Pacific Coast Auto Body Inc. Moorpark

7532 Auto Repair & Painting Pacific Const. & Mai nt. Inc. Santa Paula

5012 Automobile Wholesalers Pacific Vehicle Processors Inc Oxnard

7532 Auto Repair & Painting Paintin' Place Auto Body Thousand Oaks

7532 Auto Repair & Painti ng Palmers Custom Collision Camarillo

5511 New & Used Car Dealers Paradise Chevrolet Ventura

7532 Auto Repair & Painting Performance Collision Camarillo

7532 Auto Repair & Painting Poco Loco Customs Oxnard

5511 New & Used Car Dealers Precision Auto Body Thousand Oaks

7532 Auto Repair & Painting Premier Coach Thousand Oaks

7532 Auto Repair & Painting Prestige Bodyworks Oxnard

5083 Retail Farm Equipment Quinn Company Inc. Oxnard

7532 Auto Repair & Painting R & J Auto Body & Paint Oxnard

### Rule 74.1 8 Staff Report Page 16

7532 Auto Repair & Painting Recon To Go Moorpark

7532 Auto Repair & Painting Santa Paula Airport Association Santa Paula

5511 New & Used Car Dealers Santa Paula Chevrolet Inc. Santa Paula

7532 Auto Repair & Painting Santa Paula Collision Santa Paula

7532 Auto Repair & Painting Santos Truck & Auto Repair Oxnard

7532 Auto Repair & Painting Saticoy Auto Body & Paint Saticoy

7532 Auto Repair & Painting Scotty's Body Shop Thousand Oaks

7532 Auto Repair & Painting Simi Valley Auto Body Simi Valley

7532 Auto Repair & Painting Star Auto Body, Inc. Simi Valley

7532 Auto Repair & Painting Star Paint & Body Oxnard

7532 Auto Repair & Painting Stude baker Srvs. Autobody/Collision Moorpark

7532 Auto Repair & Painting Supercraft Auto Body Oxnard

7532 Auto Repair & Painting Superior Collision, Inc. Simi Valley

7532 Auto Repair & Painting Supertech Paint & Body Ventura

7532 Auto Repair & Painting T&S Auto Refinishing Ventura

7532 Auto Repair & Painting The Body Shop Simi Valley

7532 Auto Repair & Painting The Collision Center, Inc. Thousand Oaks

7532 Auto Repair & Painting The Spot Shop Auto Body Restoration Santa Paula

5511 New & Used Car Dealers Thousand Oaks Toyota Thousand Oaks

7532 Auto Repair & Painting Timeless Kustoms Camarillo

7532 Auto Repair & Painting Tip Top Body & Paint Shop Ventura

7532 Auto Repair & Paintin g Todey Motor Company Inc. Oxnard

7532 Auto Repair & Painting Tony's Body Shop Oxnard

7532 Auto Repair & Painting Tri

- County Auto Body & Paint Ventura

9711 National Security U.S. Coast Guard Oxnard

7532 Auto Repair & Painting Unique Auto Works Ventura

7532 Auto Repair & Painting Ventura Co

- GSA Fleet Services V entura

8222 Junior Colleges Ventura College Ventura

7532 Auto Repair & Painting Ventura County Office of Education Camarillo

7532 Auto Repair & Painting Vilma Inc. Simi Valley

7532 Auto Repair & Painting Virgil's Auto Body Newbury Park

7532 Auto Repair & Painting Vista Ford Oxnard, LLC Oxnard

3711 Motor Vehic le Mfg. Volvo Cars of North America Camarillo

3537 Fork Lift Manufacturing Wiggins Lift Company Inc. Oxnard

7532 Auto Repair & Painting World Class Paint & Body Simi Valley