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 Amendments 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 includes 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 

Safety Code Section 40914. 

Adopting the SCM by Ventura County APCD will 

garner significant emission reductions of Reactive 

Organic Compounds (ROC), a precursor to ambient 

ozone formation. ROC emission reductions of 

approximately 73 tons per year are expected from the 

proposed new standards for coatings and solvent 

cleaners used by the automobile and truck refinish 

industry. These emission reductions will help the 

District to attain its goals of meeting both 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 

basecoat/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 grams 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 

polyurethane coatings. The new primer sealers may 

also be solvent-based, and are available in either twocomponent or ready-to-spray, one-component 

systems.

Another proposed rule amendment based on the SCM

that impacts 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 created several individual 

coating categories to obtain additional emission 

reductions. 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 limit 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 preparation 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 this 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 136 permitted auto and truck 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 was 

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 to 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. Daily records of coatings applied and 

mixed will no longer be required, and monthly usage 

records of specialty coatings will no longer 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, and 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 

with 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 

Requirements, (5) Impact of the Proposed Rule, and 

(6) Environmental Impacts of Methods of Compliance/ 

California Environmental Quality Act (CEQA). The 

first section provides background information 

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 proposed revisions to Rule 

74.18. The fourth section compares the proposed 

requirements with existing federal requirements and 

Best Available Control Technology (BACT). The 

fifth section is an analysis of the proposed 

amendments’ 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 Ventura 

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 occurred

in transit, or to correct a defect that occurred during 

the manufacturing process. An entire or portion of a 

vehicle may also simply be recoated to change their 

color or appearance. Finally, mobile equipment may 

be coated as one of the last steps in the 

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-builders

• 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 physical 

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 are 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 particulate 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 activity.

Ozone is a strong oxidizer and exposure to levels 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 in 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 

emissions 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 

emissions 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 while enabling the 

application of a quality finish. The other new 

requirement from the original rule adoption was the 

spray gun cleaner, which reduces cleaning solvent 

usage. These are two examples of changes to the 

industry that not only benefitted the environment, 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 all 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. 

The 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 variance 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 gallon. 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 early 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) for 

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 adopted 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 2001 

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 seven automotive 

coating manufacturers including Dupont, Akzo Nobel, 

BASF, Ellis Paint, PPG, and Sherwin Williams.

ARB staff reviewed the feasibility and availability of 

coatings that would comply with the proposed 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 pushed 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 requirement 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 proposed is a smalluse 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 Requirements 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 limits. 

Other Air District Auto Body Rules

On December 2, 2005, the South Coast AQMD 

adopted amendments to their Rule 1151, Motor 

Vehicle and Mobile Equipment Non-Assembly Line 

Coating Operations, which were based on the 

proposed SCM coating limits. In fact, 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 been 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 Valley 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 exemption 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 Body 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 coats used at Superior Collision Center are 

manufactured by Spies Hecker, a German company 

that has partnered with Dupont. The other shops 

listed used color coats manufactured by Akzo 

Nobel’s Sikkens Division, which has their 

headquarters in Amsterdam. It is no surprise that the 

European multinational companies are introducing 

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 coats.

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 

painters. 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 product 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 these 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 standards 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 January 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 

promoters, the primer sealer category, and the singlestage 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 together 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 allowed 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 ROC 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/Noniridescent

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 Cleaning Standard (Sections B.8)

Effective January 1, 2010, the proposed ROC Content 

standard for surface prep, general cleanup, and 

application equipment cleaning will be 25 grams/liter

except for a small-use surface preparation cleaner 

exemption (described on the following page). Except 

for this one exemption, this 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 

exemption 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, the general use of aerosol cleaners 

would negate much of the anticipated emission 

reductions gained by this rule proposal. The

unlimited use of aerosol cleaners, which have very 

high ROC content, would undermine the emission 

reduction potential of the new low ROC 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 cleaning 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 be human carcinogens.

OSHA Standard for Spray Finishing 

Operations (Section B.14)

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 or 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 any 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 encourage the use of lowemitting 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 which:

• 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 oC;

• 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 approved 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 Agricultural 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 directly 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 version 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 cleaners 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 130 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 

prohibition 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 

effectiveness 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 74.18 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 Environmental 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, Number 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 federal 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 

Emissions 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 target 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 

hexavalent 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 required 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 74.18 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 development is based directly on 

and contains all the requirements of the SCM.

IMPACT OF THE PROPOSED RULE

ROC Emissions Impacts

The current permitted ROC emission inventory from 

the vehicle coating operations is about 220 tons of 

ROC per year. The actual ROC emissions are 

approximately 168 tons per year based on the 2002

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

According 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 found 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 costeffectiveness. 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 74.18 Staff Report Page 9

sulfur oxides (SOx), 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-effectiveness 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 socioeconomic 

information on proposed amendments to Rule 74.18. 

(1) The type of industries or businesses, 

including small business, affected by the rule or 

regulation.

The adoption of amendments to Rule 74.18

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 74.18 are not expected to 

have a negative impact on either employment or 

the economy 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 businesses.

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, the

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 the rule or regulation being 

proposed or amended.

The SCM adopted by ARB was negotiated

with the automotive coating manufacturers and 

the National Paint and Coating Association. 

Specialty coating categories were included for 

low-use operations requiring higher 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.

The 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 applied 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).

Ventura County is classified 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 Management Plan (AQMP), these 

emission reductions will help the District in its 

effort to attain the standards.
 Rule 74.18 Staff Report Page 10

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE/CEQA

California Public Resources Code Section 21159 requires the District to perform an environmental analysis of the 

reasonably foreseeable methods of compliance. The analysis must include the following information on proposed 

revisions to Rule 74.18:

(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, air 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 

Reasonably 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 Impacts: 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 coatings may be replaced 

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 and 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 formulations that 

will comply with the proposed coating ROC standards. During past regulatory efforts affecting coatings, industry 

representatives have alleged that use of low-ROC coatings may create certain significant adverse air quality impacts. 

While similar 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?

ARB 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 being used (for single stage topcoats and primers), the 
 Rule 74.18 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, the 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 

which 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 

result, 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 preparation 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 rulemakings 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 processing 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 coatings 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 will 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 

automotive 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 Incremental 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 waterborne 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 

manufacturers will incorporate the use of water and exempt solvents when formulating to meet the ROC limits of the 
 Rule 74.18 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 74.18 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 Board. 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 Coatings, 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)

11. 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. Documentation of the SAPRC99 Chemical Mechanism for VOC Reactivity 

Assessment. ARB Contract No.92-329. 

(Carter, 2000)

15. Dupont. Dupont Cromax Pro – The Perfect 

Solution for Low VOC Requirements. Dupont 

Refinisher News. Vol 354. Winter 2008.

16. Environmental 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 Standards 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, 

Development and Demonstration of LowVOC Cleaning Systems for SCAQMD Rule 

1171. Institute of Research and Technical 

Assistance. August 2003. (IRTA, 2003)
 Rule 74.18 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 Polyurethane. 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 

Coating Operations. November 2005. 

(SCAQMD, 2005)

28. South Coast AQMD. Rule 1151 - Motor 

Vehicle & Mobile Equipment for NonAssembly 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 Rule 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 74.18 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 Painter 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 & Painting 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 Repair & 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 & Bevilacqua Inc. Simi Valley 

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

7532 Auto Repair & Painting Bunnin Buick-GMC, Inc. Oxnard 

7532 Auto Repair & Painting 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 Motor Cars Oxnard 

7532 Auto Repair & Painting Coachcraft Fillmore 

7532 Auto Repair & Painting Commercial Auto Body Shop Oxnard 

7532 Auto Repair & 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 Center 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 74.18 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 Truck 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 & Painting 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 Saticoy 

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 New 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 Auto 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. & Maint. Inc. Santa Paula 

5012 Automobile Wholesalers Pacific Vehicle Processors Inc Oxnard 

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

7532 Auto Repair & Painting 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 74.18 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 Studebaker 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 & Painting 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 Ventura 

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 Vehicle 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