FINAL STAFF REPORT

Rule 3.14: Surface Preparation and Clean-up

Rule 3.19: Vehicle and Automotive Coating Operations

Rule 3.20: Wood Product Coatings Operations

Rule 1.1: Definitions

Date of Release: June 6, 2011

Schedule of Meetings

Rule Changes Workshop: April 21, 2011

Public Hearing: June 6, 2011
STAFF REPORT 

Date of Release: June 6, 2011

Scheduled Date of FRAQMD Adoption: June 6, 2011

Feather River AQMD, 1007 Live Oak Blvd, Suite B-3,

Yuba City, California 95991

Contents Page 

1. Executive Summary...........................................................................................1

2. Background........................................................................................................2

3. Legal Mandate ...................................................................................................2

4. Proposed Rule Requirements.............................................................................4

5. Socioeconomic Impact.......................................................................................7

6. Impacts of the Proposed Rule ............................................................................7

7. Estimated Cost Impact .......................................................................................8

8. Environmental Review and Compliance .........................................................10

9. Required Findings............................................................................................10

10. References........................................................................................................11

...........................................

Appendix A: Rule Analysis

Appendix B: Public Notice

Appendix C: Comments and Responses
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1.0 Executive Summary:

Feather River Air Quality Management District (District) is a Bi-County agency that administers local, 

state, and federal air quality management programs for Yuba and Sutter Counties. Under the provisions of 

the California Clean Air Act (CCAA) of 1988, Yuba County and the northern portion of Sutter County 

have been designated as “nonattainment-transitional” for failing to meet the state ozone standard. The

southern portion of Sutter County is designated as “severe” nonattainment for failing to meet the state 

ozone standard.

Ozone is formed when volatile organic compounds (VOCs) react with nitrogen oxides (NOx) in the 

presence of sunlight, and is one component of smog. It is a strong irritant that attacks the respiratory 

system and leads to the damage of lung tissues. Exposure to ozone aggravates asthma, bronchitis and 

other respiratory diseases, as well as cardiovascular diseases. VOC reductions are necessary to attain and 

maintain the state ambient air quality standard for ozone.

The 2009 Air Quality Attainment Plan requires the Northern Sacramento Valley Air Basin (NSVAB) to 

adopt rules and regulations deemed necessary to attain and maintain the state ambient air quality standard 

for criteria pollutants at the earliest practical date. District Staff is proposing to modify District Rule 3.14, 

Solvent Degreasing, to fulfill the commitment made by the District and to help attain the state ambient air 

quality standards for ozone.

Because portions of the District have been designated as nonattainment for failure to meet the federal 8-

hour ground-level ozone standard, the United States Environmental Protection Agency (EPA) requires the 

District to implement measures to reduce ozone precursors. The District has committed to implement 

control measures and reduce pollution through the State Implementation Plan (SIP). The SIP is federally 

enforceable through the EPA and the Federal Clean Air Act (CAA).

District Rule 3.14, Solvent Degreasing, was adopted in June of 1991. For the 2011 amendments, the 

District proposes to rename this rule “Surface Preparation and Clean-up” to account for the various uses 

of solvent. The rule will effectively lower the VOC content limit for the various uses of solvents and 

document procedures to reduce the evaporation of solvents into the atmosphere. Lower VOC content 

limits for these solvents have been achieved for most applications in other Air Districts through the use of 

aqueous technologies or by transitioning to exempt compounds.

Solvent cleaning is performed by manufacturing and service operations for application equipment and 

manufactured or serviced parts. The proposed rule amendments will affect a wide variety of industries.

Any source performing solvent cleaning will be affected, including sources not currently regulated by the 

District. Industries potentially affected include repair shops, automotive service stations, printing/graphic 

arts operations, and various other coating operations.

To limit confusion with the overlap of multiple rules containing solvent requirements, the District is 

proposing to consolidate the surface preparation and clean-up requirements into Rule 3.14. The District 

will remove the requirements for surface preparation and clean-up from District Rule 3.19 and 3.20, 

including applicable VOC limits, equipment requirements, and work practice requirements. The current 

requirements will be in effect in District Rule 3.14 until the more stringent requirements take effect in 

December 2011. Furthermore, the District is proposing to modify District Rule 1.1 to contain the 

definitions for VOC, ROG, and exempt compounds. This will negate the need to list the definitions in 

each prohibitory rule.

Amendments to these rules are expected to lower VOC emissions from solvent cleaning operations in the 

District by 28 tons per year.
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2.0 Background:

Ozone

Reducing VOC emissions is part of the District’s strategy for reducing ozone formation. Ozone is not 

directly emitted from polluting sources and is classified as a secondary pollutant. It forms in the 

atmosphere through complex chemical reactions between VOCs and nitrogen oxides with the presence of 

a catalyst, such as sunlight. Ozone is a highly reactive gas that can be harmful to public health when it is 

in high concentrations at ground level. High concentrations can irritate the nose and throat and can 

aggravate respiratory conditions such as asthma, bronchitis, and emphysema.

Regulations

The EPA and the California Air Resources Board (ARB) have adopted ambient air quality standards to 

determine outdoor pollutant levels considered safe for the public. The standards are health-based and 

designed to provide protection for the most sensitive groups. 

The Federal Clean Air Act (FCAA) requires air districts in nonattainment for the ozone standards to 

prepare a plan describing how the National Ambient Air Quality Standard will be met. The District 

committed as part of the 8-Hour Ozone Attainment Plan to reduce VOC from surface preparation and 

clean-up operations in order to assist in achieving attainment and to demonstrate actual VOC emission 

reductions. On the state level, the California Clean Air Act (CCAA) requires the District to develop a plan 

to achieve attainment with the state ozone standard. 

VOC Emission Reductions

The District is proposing to amend the existing rule by lowering the VOC limits for surface preparation 

and clean-up solvents, which the District expects to be met by increasing the use of aqueous cleaning 

technologies and exempt compounds. For most cleaning activities, low VOC and aqueous solvents have 

been successfully used as a substitute for organic based cleaners in many industrial and commercial 

applications. There are numerous products readily available since other air Districts throughout the State 

have been requiring low VOC cleaners for several years.

3.0 Legal Mandate:

Federal Mandates

In 2004, EPA designated the Sacramento region as one of the nation’s four worst 8-hour ozone 

nonattainment areas. This region, called the Sacramento Federal Nonattainment Area (SFNA), includes 

all of Sacramento and Yolo counties and portions of Placer, El Dorado, Solano, and Sutter counties. 

Federal law and regulations set specific planning requirements for adopting and implementing a plan to 

meet reasonable further progress goals and demonstrate attainment of the 1997 federal ozone standard as 

expeditiously as practicable, but no later than our attainment deadline. This State Implementation Plan 

(SIP) contains a list of control measures which will help the area meet FCAA planning requirements for 

the 1997 health based standards for 8-hour ozone. A modification to Rule 3.14 was included on the list as 

a feasible control measure.

Furthermore, the FCAA requires areas designated as non-attainment and classified moderate and above to 

implement Reasonable Available Control Technology (RACT) for “major sources” of VOCs and NOx

subject to Control Technology Guidelines (CTG) issued by the EPA. RACT is defined as “the lowest 

emission limitation that a particular source is capable of meeting by the application of control technology 

that is reasonably available considering technological and economic feasibility.” District Rule 3.14 is 

based on EPA’s CTG for Industrial Cleaning Solvents, which was issued in September 2006. Granted 
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there are currently no “major sources” of VOCs or NOx within the SFNA portion of the District, adopting 

the rule now will make it easier to enforce federal law if a new major source is constructed. 

State Mandates

The CCAA requires areas designated as nonattainment for ozone to develop a plan, in accordance with 

section 40913 of California Health and Safety Code, to achieve California’s ambient air quality standard 

by the earliest practical date by adopting cost-effective control measures.

The SFNA portion of Sutter County is designated as “severe” nonattainment for the state ozone standard. 

CH&S Code, section 40920 requires the District to adopt a control measure that will use Best Available 

Retrofit Control Technology (BARCT) for all existing stationary sources in this area. BARCT, as defined 

in the CH&S, is as “an emission limitation that is based on the maximum degree of reduction achievable, 

taking into account environmental, energy and economical impacts by each class or category of source.

Yuba County and the northern area of Sutter County are designated as “nonattainment-transitional” for 

the state ozone standard. CH&S Code, section 40925.5 requires the District to adopt a control measure 

that will use RACT for all existing stationary sources in these areas. 

All Feasible Measures Requirements

California Health and Safety Code, section 40914 requires the District’s plan to demonstrate that the plan 

includes “every feasible measure" to control emissions. All feasible control measures are those which 

have the most effective regulatory emissions standards demonstrated in California’s air districts. 

Other districts have already implemented regulations limiting the VOC content in materials used for 

surface preparation and clean-up. A VOC standard of 50 grams per liter for materials, used for general 

cleaning, has been in effect in the South Coast Air Quality Management District (SCAQMD) and the Bay 

Area AQMD (BAAQMD) since 1999. The San Joaquin Valley Air Pollution Control District 

(SJVAPCD) and Sacramento Metropolitan AQMD (SMAQMD) have also adopted the 50 gram per liter 

standard. The ARB has noted in their Identification of Performance Standards that this VOC limit 

represents the most effective strategy for reducing emissions for this source category.

In 2005, the SCAQMD further reduced the VOC standard to 25 grams per liter for materials used for 

general cleaning and have adopted stringent limits for other categories. The SJVAPCD, SMAQMD, and 

Yolo-Solano AQMD (YSAQMD) followed shortly thereafter in 2007-2008.

The District has evaluated the standards in the rule against similar requirements recently adopted by other 

districts. The District has determined that the standards are feasible and have been achieved in practice. 
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4.0 Proposed Rule Requirements:

The District is proposing to lower the VOC limits for certain source categories and to establish VOC 

limits on source categories not previously limited. For most cleaning operations, the District will require 

sources to use cleaning materials with a 50 gram per liter limit for VOCs, effective 12/31/2011. 

Compliance with the new requirements can be achieved through the use of aqueous technologies, exempt 

compounds, or other emission control technologies. 

Operators using cleaning materials with a VOC content of 50 grams per liter or less will be exempt from 

the requirements of Rule 3.14. Any source claiming this exemption is still subject to the requirements of 

Section E.3 Burden of Proof, which can easily be satisfied by having a Material Data Safety Sheet for the 

cleaning material on hand.

The following table summarizes the District’s approach for lowering VOC content limits. The table 

includes current VOC content limits for solvents used for surface preparation and clean-up and cites the 

rules where the requirements are currently found. The table also includes the lower proposed limits and 

new categories.

Table 1: VOC Content Limits

Category

VOC Content Limit 

(grams/Liter)

Prior to 

12/31/2011

Effective 

12/31/2011

Product 

Cleaning

Coatings and Adhesives 50

Vehicles & Mobile Eqmt. 

[Rule 3.19]

Surface Prep 200 50

Handheld Spray 780 50

Wood Products [Rule 3.20] 200 50

Metal Parts and Products 50

Polyester Resins 50

Inks 50

Electrical Apparatus Components & 

Electronic Components 100

Aerospace Components 900

Medical Devices, Pharmaceuticals, and 

Pharmaceutical Products 800

Cleaning of 

Application 

Equipment

Coatings and Adhesives 50

Vehicles & Mobile Eqmt. [Rule 3.19] 50

Wood Products [Rule 3.20] 50

Metal Parts and Products 50

Polyester Resins 50

Printing Operations: Screen Printing,

Lithographic and Letterpress, Ultraviolet, 

Flexographic, Gravure (Publication)

100

Aerospace Components 50

Medical Devices, Pharmaceuticals, and 

Pharmaceutical Products 800

Sterilization of food manufacturing and processing 

equipment 200

General: Industries Not Specified Above 50

Comparison of Similar Solvent Rules enacted in the State

As stated earlier, numerous districts across California have already enacted similar solvent rules. Since 

there are a few variations in the requirements stated in these rules, a side-by-side comparison was 

performed. These comparisons can be seen below in Table 2. 
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Table 2: Comparison of District Rules

FRAQMD

Proposed Rule

Other District Limits

South Coast

AQMD

Sac Metro

AQMD

Yolo-Solano

AQMD

San Joaquin

APCD

Applicability

Exemption Levels

Usage 20 gal/yr NA NA 10 gal/yr 55 gal/yr

VOC Content 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Requirements

Product Cleaning

Coatings, Wood Products, 

Metal Parts, Resins, Inks 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Adhesives 50 g/L 25 g/L <70 g/L 25 g/L 25 g/L

Vehicles & Mobile Equipment 50 g/L 25 g/L 72 g/L 25 g/L 25 g/L

Electrical Apparatus 

Components & Electronic 

Components

100 g/L 100 g/L 100 g/L 100 g/L 100 g/L

Aerospace Components 900 g/L

200 g/L or VOC 

composite 

vapor pressure 

< 45 mm Hg

200 g/L or VOC 

composite 

vapor pressure 

< 45 mm Hg

NA

200 g/L or VOC 

composite 

vapor pressure 

< 45 mm Hg

Medical Devices, 

Pharmaceuticals, and 

Pharmaceutical Products

800 g/L 800 g/L 800 g/L 800 g/L 800 g/L

Requirements

Cleaning of Application Equipment

Coatings, Wood Products, 

Metal Parts, Resins 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Adhesives 50 g/L 25 g/L <70 g/L or 

gun cleaner 25 g/L 25 g/L

Vehicles & Mobile Equipment 50 g/L 25 g/L 72 g/L 25 g/L 25 g/L

Flexographic Printing 100 g/L 25 g/L 25 g/L 100 g/L 100 g/L

Screen Printing, Gravure 

(Publication) 100 g/L 100 g/L 100 g/L 100 g/L 100 g/L

Lithographic and Letterpress & 

Ultraviolet Printing 100 g/L 100 g/L 100 g/L 238 g/L 100 g/L

Aerospace Components 50 g/L 25 g/L 25 g/L 25 g/L 25 g/L

Medical Devices, 

Pharmaceuticals, and 

Pharmaceutical Products

800 g/L NA NA 810 g/L NA

Requirements

Other

Sterilization of food 

manufacturing and processing 

equipment

200 g/L 200 g/L 200 g/L NA NA

Monitoring and Records

Amount of time in which 

records are required to be kept 3 years 3 years 5 years 2 years 5 years

Cleaning Solutions

Common solvents currently used for surface preparation and clean-up include acetone, d-limonene, and 

paint thinner/mineral spirits. Acetone and d-limonene are compliant solvents which do not need a permit,

so many cleaning operations in the District already incorporate these materials. Whereas paint 
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thinner/mineral spirits are the organic based, high VOC solvents which are planned to be phased out for 

high usage facilities.

One alternative to using organic based solvents is to start using aqueous solutions. Aqueous solutions are 

available in a wide ph range from acidic to alkaline. Acidic solutions are typically used for scale or salts, 

but are not as effective for greases and oils. Neutral and alkaline solutions can contain surfactants and rust 

inhibitors to improve effectiveness and prevent rusting or corrosion. Mildly alkaline solutions are suitable 

for oil and greases. The SCAQMD has certified over a hundred cleaners as “Clean Air Solvents” meeting 

specific criteria including the 25 grams per liter VOC content. In addition, SCAQMD maintains a list of 

companies who supply aqueous cleaners systems.

Aqueous Degreasing Systems

Aqueous degreasing systems are generally equipped with a heating element to increase the effectiveness 

of the cleaner. There is more flexibility with cleaning options for aqueous systems because the solutions 

used are not as flammable as traditional organic solvents.

The five common types of cleaning systems that can be used with aqueous solutions are as follows:

1. Sink-on-a-drum: The sink-on-a-drum parts washer consists of a sink mounted on a drum/barrel. 

The unit is equipped with a hose, brush applicator and is a manually operated. They can contain 

filters or skimmers which extend the life of the cleaner. This unit is the most commonly used and 

most comparable to the traditional remote reservoir cleaners.

2. Enzyme System: Enzyme systems are similar to sink-on-a-drum units. They use specially 

formulated enzyme cleaners. Microbes are added to the system through an impregnated filter or 

are added directly to the cleaner. The cleaner emulsifies the grease and the microbes breakdown 

and biodegrade the oils.

3. Immersion Parts Washer: The immersion unit is similar to the sink-on-a-drum, unit except it 

has a false sink, allowing access to a reservoir for cleaning or soaking when removed.

4. Spray Cabinet: The spray unit operates by spraying or flushing high pressure cleaners in an 

enclosed unit. These units are automated.

5. Ultrasonic Cleaner: The ultrasonic units use cavitation energy from sonic waves to clean parts. 

These units are effective for cleaning equipment or parts with small crevices or complex 

geometries, such as transmissions and carburetors. These units are automated.

Additional Rule Amendments

To limit confusion with the overlap of multiple rules containing solvent requirements, the District is 

proposing to consolidate the solvent surface preparation and clean-up requirements into Rule 3.14 Surface 

Preparation and Clean-up. The District will remove the requirements for surface preparation and clean-up 

from District Rule 3.19 and 3.20, including applicable VOC limits, equipment requirements, and work 

practice requirements. The current requirements will be in effect in District Rule 3.14 until the more 

stringent requirements take effect in December 2011. Furthermore, the District is proposing to modify 

District Rule 1.1 to contain the definitions for VOC, ROG, and exempt compounds. This will negate the 

need to list the definitions in each prohibitory rule.

District Rule 3.20 will also be cleaned up to remove deadlines and various other time-related 

requirements that have passed. These changes will make the rule more clear and concise. The District 

believes that no further changes need to be made to the rule at this time. 

The District is aware of the Suggested Control Measure (SCM) proposed by CARB for Automotive 

Coatings. This SCM proposes to reduce the VOC limits of various automotive coatings listed in District 
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Rule 3.19. However, the District will not implement the SCM at this time. The District is planning to 

review the SCM requirements within the next few years and determine if it will be a cost-effective 

measure for Yuba and Sutter Counties. However, District Rule 3.19 will be cleaned up to remove 

deadlines and various other time-related requirements that have passed. These changes will make the rule 

more clear and concise.

5.0 Socioeconomic Impact:

Yuba and Sutter Counties have a combined population of less than 500,000 persons. The Required 

Assessment in subsection (d) of the California Health and Safety Code (Section 40728.5) states, “This 

section does not apply to any district with a population of less than 500,000 persons.” A socioeconomic 

impact analysis is not required.

6.0 Emission Impacts of the Proposed Rule:

The ARB maintains an emission inventory of pollutants emitted from different source categories. The 

source categories are assigned Emission Inventory Codes (EIC) describing the general emission group, 

the specific operation, and material. The District reviewed the categories applying to solvent cleaning and

solvent degreasing. According to the 2005 emissions inventory for the SFNA portion of FRAQMD, 

solvent cleaning and degreasing for all categories account for approximately 3 tons of VOC per year. 

District staff estimates proposed rule amendments will result in a reduction of 1.5 tons of VOC per year, 

or 0.004 tons/day. FRAQMD has made a SIP commitment of reducing VOC emissions by 0.0006

tons/day in the SFNA. It is expected that FRAQMD will exceed its commitment through the 

implementation of this rule.

The rule will have a larger effect on the remaining northern portion of FRAQMD where the majority of 

the stationary sources are located. Staff estimates that there may be over 400 solvent cleaning machines in 

use at repair shops and manufacturing facilities in FRAQMD. Furthermore, the number of sources 

performing solvent cleaning that will be subject to Rule 3.14 is estimated to be in the range of 75 to 150. 

After comparing the current VOC limits with the proposed VOC limits for each category, the District 

determined that there will be approximately a 28 ton per year VOC reduction.
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7.0 Estimated Cost Impact:

CH&SC Section 40703 requires the District, in the process of the adoption of any rule or regulation, to 

consider and make public its findings related to the cost effectiveness of the rule. Cost effectiveness for 

rulemaking purposes is calculated by dividing the cost of air pollution controls required by the rule by the 

amount of air pollution reduced. 

Aqueous Cleaning Systems

The conversion from solvent cleaning degreasers to aqueous cleaning systems has been completed in the 

BAAQMD, SJVAPCD, SCAQMD, SMAQMD, and YSAQMD. Costs for the conversion to aqueous 

systems are based on the staff reports for these rule efforts, a study completed by the Institute for 

Research and Technical Assistance’s Pollution Prevention Center (IRTA) for the EPA and Santa Barbara 

County Air Pollution Control District, and cost information provided by equipment suppliers.

The costs associated with converting equipment include the equipment costs, costs of products used, and 

operating costs. Traditional solvent units are generally leased from waste management companies who 

service the equipment. Equipment, chemicals, and disposal costs are all included in the service charge. 

Costs for aqueous cleaning include specifically, the cost of the aqueous system, solution costs, disposal 

costs for spent solutions and/or filters, filter costs, electricity costs and labor costs. Initial equipment costs 

for aqueous units vary depending on the type of machine, size of the unit, and features. The following 

table demonstrates the range for the different aqueous systems.

Table 2: Average Cost of Equipment

Aqueous Equipment System Cost of Equipment

Sink-on-a-drum $328 - $3,000

Immersion unit $800 - $4,200

Enzyme system $1,000 - $2,400

Spray cabinet $1,600 - $6,400

Ultrasonic unit $2,700 - $12,000

The study performed by IRTA included a cost comparison for different case studies related to converting 

to aqueous cleaning systems. The report concluded a cost savings for facilities operating aqueous cleaning 

systems. The lower costs were attributed to the longer life of the aqueous solutions and to the labor 

savings. The longer life of aqueous solutions meant both the amount of cleaning solution used decreased 

and there was less spent solution to dispose of. Labor savings were reported from the conversions to 

enzyme systems and automated units. Similarly, the SCAQMD reported an overall cost savings for the 

conversion to aqueous systems based on material savings and disposal savings.

The SJVAPCD analyzed the conversion to aqueous systems evaluating different scenarios including:

Facilities with a single solvent degreaser switching to a single aqueous sink on a drum, 

Facilities with a single degreaser switching to an enzyme-cleaning unit, 

Facilities with a single degreaser switching to a batch loaded aqueous unit larger in size, and

Facilities with two solvent degreasers switching to one batch loaded aqueous cleaning unit. 

The SJVAPCD further broke down each scenario taking into account the usage of the unit. The analysis 

was made based on the following assumptions: 

The annual compliance cost includes annual operation and maintenance costs as well as 

annualized capital costs, 

Concentrated aqueous solutions are diluted with water and the cost of water is insignificant, 

Handling of aqueous baths is included in the calculations, 
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Aqueous solutions are more effective when heated and any costs are included in the annual 

compliance cost, 

Labor costs vary by equipment, 

Aqueous baths last longer and require less change out than traditional solvents, and

Seventy percent of solvent is recycled and the remaining thirty percent are emissions. 

The costs and cost effectiveness are reported as follows:

Table 3: Cost and Cost Effectiveness

Usage Annual Cost Cost-Effectiveness

($/ton of VOC reduced)

Converting one solvent degreaser to an aqueous unit:

Low usage $546 $12,937

Average Usage $903 $8,560

High Usage $1393 $6,603

Converting one solvent degreaser to an enzyme unit:

Low usage $368 $8,132

Average Usage $430 $3,805

High Usage $468 $2,068

Converting one solvent degreaser to an automated aqueous unit:

Low usage $128 $9,436

Average Usage $238 $2,316

High Usage $788 $3,832

Converting two solvent degreasers to automated aqueous units:

Low usage -$112 -$2,557

Average Usage -$362 -$3,308

High Usage -$412 -$1,883

The cost effectiveness analysis performed by the SJVAPCD is based on requiring cleaning solutions to 

comply with a VOC content limit of 50 grams per liter. 

General Cleaning / Other Cleaning Operations

The costs associated with lowering the VOC content of cleaning solutions varies depending on the 

category and specific cleaning process. Most cleaning operations use some type of wipe cleaning for 

surface preparation and clean-up. There are no equipment costs for switching to aqueous cleaners for this 

category. Costs accrued are based on the cost of the replacement cleaners. Replacement cleaners include 

aqueous solutions, exempt compounds, or blends. The costs of aqueous solutions are generally higher 

than traditional solvents. However, they are sold in concentrated form and when diluted, the cost of the 

aqueous solution can be less than the cost for traditional solvents. Dilution ratios vary depending on the 

product, and typically range from 1-40% solution in water. 

The SCAQMD reported costs of traditional solvents to range from $4 to $20 per gallon and replacement 

solvents from $2 to $40 per gallon. The BAAQMD reported the average cost for conventional solvents to 

be $12.25 per gallon and $5.97 per gallon for replacement solutions with a median price between $2.31 

and $2.40 per gallon after dilution.
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8.0 Environmental Review and Compliance:

The amendments to rule 3.14 are 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. This exemption is allowed when the rule will help improve air quality in Yuba and 

Sutter County. California Public Resources Code (Section 21159) requires an environmental analysis of 

the reasonably foreseeable methods of compliance. The District has concluded that no reasonably 

foreseeable adverse environmental impacts will be caused by adoption of the proposed rule.

9.0 Required Findings:

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

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

through legislative mandate to contain 6 findings that the District must make when developing, amending, 

or repealing a rule. These findings and their definitions are listed in the following table.

Table 4: Required Findings

FINDING DEFINITION REFERENCE

Authority A district shall adopt rules and regulations 

and do such acts as may be necessary or 

proper to execute the powers and duties 

granted to, and imposed upon, the district 

by this division and other statutory 

provisions

California Health and Safety Code, Sections 

40000, 40001, and 40702 are provisions of 

law that provide air districts with the 

authority to adopt these proposed rules.

Necessity The District has demonstrated that a need 

for the rule, or for rule amendment or 

repeal.

It is necessary for districts to adopt these 

amendments to comply with state law and to 

ensure consistency with neighboring air 

districts.

Clarity The rule is written or displayed so that its 

meaning can easily be understood by the 

persons directly affected by it

There is no indication, at this time, that the 

proposed rules are written in such a manner 

that it cannot be easily understood by 

persons affected by the rule.

Consistency This rule is in harmony with, and not in 

conflict with or contradictory to, existing 

statutes, court decisions, or State or federal 

regulations.

These rules are consistent with applicable 

statutory requirements.

NonDuplicationThe rule does not impose the same 

requirements as an existing State or federal 

regulation, unless the District finds that the 

requirements are necessary and proper to 

execute the powers and duties granted to, 

and imposed upon, the district

The proposed rule does not impose 

requirements that duplicate existing laws or 

regulations.

Reference Any statute, court decision, or other 

provision of law that the district 

implements, interprets, or makes specific 

by adopting, amending, or repealing a 

regulation.

The proposed rule has been developed to 

meet the requirements of the 2003 State 

Implementation Plan.
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10.0 References:

1) EPA 453/R-06-001 “Control Techniques Guidelines: Industrial Cleaning Solvents,” September 

2006

2) Sac-Metro Air Quality Management District, “Final Draft Staff Report for Rule 466 – Solvent 

Cleaning,” August 19, 2010.

3) Sacramento Regional 8-Hour Ozone Attainment and Reasonable Further Progress Plan (September 

2008).

4) San Joaquin Valley Unified Air Pollution Control District, “Final Draft Staff Report for Rules 

4603, 4604, 4605, 4606, 4607, 4612, 4653, 4661, 4662, 4663, and 4684,” August 2007.

5) Santa Barbara Air Pollution Control District, “Rule 321, Solvent Cleaning Machines and Solvent 

Cleaning,” September 20, 2010.

6) South Coast Air Quality Management District, “Clean Air Solvent (CAS) Certification Program.” 

http://www.aqmd.gov/rules/cas/index.html.

7) South Coast Air Quality Management District, “Rule 1122, Solvent Degreasers,” October 1, 2004.

8) South Coast Air Quality Management District, “Rule 1171, Solvent Cleaning Operations,” July 7, 

2006.

9) South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 1122-

Solvent Degreasers,” September 21, 2004.

10) South Coast Air Quality Management District, “Staff Report for Proposed Amended Rule 1171-

Solvent Cleaning Operations,” June 2006.

11) South Coast Air Quality Management District, “Rule 1131- Food Product Manufacturing and 

Processing Operations,” June 6, 2003.

12) Yolo-Solano Air Quality Management District, “Final Draft Staff Report for Rules 1.1, 2.25, 2.26,

2.29, 2.30, 2.31, 2.33, 2.35, 2.39, 2.24,” May 2008.
APPENDIX A

Rule Analysis
APPENDIX B

Public Notice
APPENDIX C

Comments and Responses