ATTACHMENT 2 

PROPOSED LEGISLATIVE FINDINGS 

PURSUANT TO HEALTH AND SAFETY CODE 

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

PROPOSED AMENDED RULE 74.18 

1. NECESSITY: Amendments to Rule 74.18 are necessary to obtain emission reductions 

required to move closer to the goal of meeting state and federal air quality standards for 

ozone. 

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

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

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

ambient air quality standards. 

3. CLARITY: The amendments to Rule 74.18 can be easily understood by the persons directly 

affected by them. 

4. CONSISTENCY: The amendments to Rule 74.18 are in harmony with, and not in conflict 

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

5. COST-EFFECTIVENESS and SOCIOECONOMIC IMPACTS: Factors related to the costeffectiveness and socioeconomic impacts of adopting amendments to Rule 74.18 are set 

forth in Attachment 4 and have been considered in adopting amendments to Rule 74.18. 

6. NONDUPLICATION: Amended Rule 74.18 does not impose the same requirements as an 

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

District. 

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

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

to Rule 74.18. 

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

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

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

ozone. Adoption of amendments to Rule 74.18 will reduce emissions of reactive organic 

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

federal ozone ambient air quality standards. 

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

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

certain federal, state, and District air pollution control requirements that apply to the same 
Air Pollution Control Board Findings 

November 11, 2008 

Page 2 

ATTACHMENT 2

equipment or source type regulated by proposed amendments to Rule 74.18. Staff has 

analyzed federal and state emission regulations that correspond with proposed amendments 

to Rule 74.18. This analysis has been prepared and is set forth in Attachment 4. 

10 REASON FOR ADOPTION AND INCREMENTAL COST-EFFECTIVENESS: 

Amendments to Rule 74.18 are necessary to obtain emission reductions required to move 

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

control option for amending Rule 74.18 that staff is recommending for adoption is 

substantially more cost-effective than the other two options that were considered. This 

analysis is contained in Attachment 4 

PROPOSED FINDINGS 

PURSUANT TO SECTIONS 15307 AND 15308 OF THE 

CALIFORNIA ENVIRONMENTAL QUALITY ACT GUIDELINES 

PROPOSED AMENDED RULE 74.18 

1. CEQA: The adoption of amendments to Rule 74.18 is categorically exempt from the 

California Environmental Quality Act (CEQA) under Sections 15307 and 15308 of the State 

CEQA Guidelines, and no exceptions to these exemptions apply.