1 Final Staff Report with Appendices 

 for Proposed Amendments to Rule 4612 

SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

FINAL STAFF REPORT 

Rule 4612 

(Motor Vehicle and Mobile Equipment Coating Operations) 

October 21, 2010 

Prepared by: Anna Myers, Air Quality Specialist 

Reviewed by: Colette Kincaid, Senior AQ Specialist 

 Dustin Brown, Senior AQ Engineer 

 Koshoua Thao, Senior AQ Specialist 

 Joven Nazareno, Senior AQ Engineer 

 Ryan Hayashi, Compliance Supervisor 

 Michael Carrera, Compliance Manager 

 George Heinen, Rule Development Supervisor 

 Errol Villegas, Strategies and Incentives Program Manager 

 Samir Sheikh, Director of Strategies and Incentives 

 

 

I. SUMMARY 

The source category of Motor Vehicle and Mobile Equipment Coating Operations 

currently includes operations that apply, supply, sell, offer for sale, or solicit the 

application of VOC-containing coatings used in the finishing or refinishing of vehicles 

and equipment, and their parts and components. This category also includes the 

organic solvent cleaning, and the storage and disposal of all solvents and waste solvent 

materials associated with such coating operations. Rule 4602 (Motor Vehicle and 

Mobile Equipment Operations) was adopted in 1991. In September 2006, Rule 4612 

(Motor Vehicle and Mobile Equipment Coating Operations – Phase II) was adopted to 

supersede Rule 4602 to incorporate the elements of the Air Resources Board (ARB) 

Suggested Control Measure (SCM) for this source category with a compliance date of 

January 2009. However, since the implementation of current rule language for Rule 

4612, it has been determined that specific sections need updating in order to remove 

redundant language, clarify the intent of the section, and align the rule with 

requirements previously required. 

 

The purpose of this rule-amendment project is to fulfill the commitment in the San 

Joaquin Valley Air Pollution Control District (District) 2007 Eight-Hour Ozone Plan 

(Ozone Plan) and to update Rule 4612 by removing redundant language and clarify the 

intent of requirements of the rule. The District Ozone Plan committed staff to explore 

the possibility of reducing emissions from this source category by use of incentive 

funding. Staff investigated the possible incentive funds and emissions potentially 

reduced from use of such funds. Staff has concluded that there are currently no specific 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4612 October 21, 2010 

2 Final Staff Report with Appendices 

 For Proposed Amendments to Rule 4612 

funds available and that because operators are currently using all possible measures to 

reduce emissions, there are not further feasible opportunities to reduce emissions 

through incentivized activities. The proposed rule amendments will not affect the 

meaning, scope of, or prohibitions contained in current rule language. 

A. Reasons for Rule Development and Implementation 

The California Air Resources Board (ARB) and the United States Environmental 

Protection Agency (EPA) classified the San Joaquin Valley Air Basin (Valley) as severe 

and extreme non-attainment for the state and federal ozone standards, respectively. In 

accordance with Federal Clean Air Act (CAA) requirements for non-attainment areas, 

the District adopted the Ozone Plan to establish the strategy for attaining the eight-hour 

ozone standards. The ozone attainment strategy of the Ozone Plan is comprised of 

regulatory and incentive-based measures to reduce emissions of nitrogen oxides and 

volatile organic compounds (VOC), a precursor of ground-level ozone. The following 

table is a summary of Ozone Plan Commitments. 

Table 1 - Ozone Plan Commitments

Subject Reference Requirement 

BARCT CH&SC 40919(a)(3) 

2007 Ozone Plan 

 Ozone attainment plan should provide for best available 

retrofit technology (BARCT) for existing permitted sources. 

Deadlines Ozone Plan Adoption of rule amendments by Plan committed deadline. 

Feasible 

Controls CH&SC 40914(a)(2) Ozone attainment plans should include "all feasible control measures." 

RACT CAA 182(b)(2) and 

182(f) 

Ozone attainment plans shall assure that reasonably

available control technology (RACT) for oxides of nitrogen 

(NOx) and volatile organic compounds (VOC) is in use at 

sources and on source categories at or above the RACT 

threshold. 

Reductions Ozone Plan Emission reductions will be calculated during the rule 

development process. 

Timeline CAA Section 172(c)(1) Ozone attainment plans shall implement control measures 

as expeditiously as practicable, and provide for attainment. 

B. Climate Change 

The California Global Warming Solutions Act of 2006 (AB 32) created a comprehensive, 

multi-year program to reduce greenhouse gas (GHG) emissions in California, with the 

goal of restoring emissions to 1990 levels by 2020. In the coming years, the ARB and 

the Legislature will be developing policies and programs to implement Assembly Bill 32 

(AB 32). There are many win-win strategies that can reduce both GHG and criteria/ 

toxic pollutant emissions. However, the District’s primary mission remains to achieve 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Final Staff Report: Rule 4612 October 21, 2010 

3 Final Staff Report with Appendices 

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attainment with air quality standards to protect public health. Therefore, when situations 

that involve tradeoffs between GHG and criteria or toxic pollutants arise, the District will 

give precedence to reducing criteria or toxic pollutant emissions due to the more 

immediate public health concerns associated with such pollutants. 

C. Description of Project 

The 2007 Ozone Plan committed staff to research the possibility of gaining more 

emission reductions from this source category through the use of incentive funding. 

The Ozone Plan also indicates that this rule currently encompasses the most stringent 

coating VOC content limits for this source category. Based on measures taken by 

industry to comply with these standards, staff has determined that there are no 

additional emission reductions available from this source category, even given the 

addition of incentive funding. The proposed amendments do not change the meaning of 

the rule or create more stringent enforcement of emission control standards. As such, 

this rule-amending project is not expected to reduce VOC emissions. 

D. Rule Amendment Process 

The draft rule and draft staff report were published for a 30-day public commenting 

period with no public workshop in July 2010. No comments were received as a result of 

the commenting period. The notice of the public hearing for the proposed amendments 

was published in general circulation newspapers in each of the eight Valley counties, 

and was made available for review on the District website. A summary of the comments 

received and District responses are in Appendix A of the Final Staff Report. 

II. DISCUSSION 

A. Current Regulation 

The purpose of Rule 4612 is to limit VOC emissions from coatings associated with the 

coatings of motor vehicles, mobile equipment, and associated parts and components, 

and to reduce the VOC emissions from the organic solvent cleaning, storage, and 

disposal associated with such operations. Rule 4612 applies to any person who 

supplies, sells, offers for sale, manufacturers, or distributes any automotive coating for 

use within the District, as well as any person who uses, applies, or solicits the use or 

application of any automotive coating within the District. 

Rule 4612 limits VOC emissions by limiting the VOC content of coatings used for 

coating motor vehicles and mobile equipment and associated organic cleaning solvents. 

In lieu of complying with VOC content limits, operators have the option to operate an 

APCO-approved VOC emission control system, subject to rule requirements. 
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 For Proposed Amendments to Rule 4612 

B. Proposed Amendments 

Title 

The title would be amended to remove “Phase II”, which is no longer relevant since 

there is no longer a “Phase I” rule. 

Section 3.0 – Definitions 

Section 3.0 would be amended to define “operator” and “permanent label”. 

Section 4.0 – Exemptions 

Section 4.1.4 would be amended to clarify the intent of this exemption. Current 

language exempts facilities that operate automotive assembly lines, which is a separate 

source category covered by Rule 4602 (Motor Vehicle Assembly Coatings). However, 

Rule 4602 applies only to VOC-containing coatings applied to new automobiles, light-duty 

trucks, heavier vehicles, and other parts coated along with these bodies or body parts 

during the assembly process. 

In 2008 EPA promulgated the Control Techniques Guidelines (CTG) for Automobile and 

Light-Duty Truck Assembly Coatings. The CTG provides control recommendations for 

reducing VOC emissions stemming from the use of coatings in automobile and lightduty truck assembly coating operations. The CTG further states: 

The automobile and light-duty truck assembly coatings product category 

under section 183(e) of the CAA includes primary coatings that are 

applied to new automobiles or new light-duty truck bodies, or body parts 

for new automobiles or new light-duty trucks, and other parts that are 

coating along with these bodies or body parts. The category also includes 

additional coatings applied during the vehicle assembly process. 

Automobile and light-duty truck assembly coatings most commonly are 

applied at automobile or light-duty truck assembly plants. However, this 

183 (e) category also includes coatings used in facilities that perform 

these coating operations on a contractual basis. 

Conversations with the author of the CTG verified that intended applicable facilities 

would be manufacturers of new automobiles, not “upfitting” or refinishing operations, 

even if they operate on an assembly line. District staff also contacted ARB staff to 

clarify SCM language regarding the exemption for assembly operations, as stated in 

current District Rule 4612 Section 4.1.4. Conversations with ARB staff has led District 

staff to conclude that the exemption in Section 4.1.4 was intended to exempt new 

vehicle manufacturers, not upfitting and resurfacing operations. 

Upfitting a vehicle involves the operator receiving a vehicle that is registered with the 

state and has a vehicle identification number (VIN). The operator will modify that 

vehicle to specifications provided by the buyer/owner, and then re-register the 
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completed vehicle with the new weight information, while leaving the VIN number 

unchanged. 

There is one motor vehicle upfitting operation in the Valley that operates using an 

assembly line. As current rule language is written, this upfitting automotive assembly 

line and coating operation would be exempt from Rule 4612, and as explained above, is 

not subject to Rule 4602. As currently written, the operation would, by default, become 

subject to District Rule 4603 (Surface Coating of Metal Parts and Products, Plastic Parts 

and Products, and Pleasure Crafts), which is not the District’s intent. District staff is 

recommending amending the exemption in Section 4.1.4 to clarify that the assembly line 

exemption applies to the assembly of new automobiles subject to District Rule 4602 and 

not refinishing or upfitting operations. Therefore, facilities that operate an assembly line 

for refinishing or upfitting that were previously subject to the motor vehicle and mobile 

equipment coating regulation will remain subject to the motor vehicle and mobile 

equipment regulation. 

Section 5.0 – Requirements 

Section 5.3 would be amended to remove redundant language. 

Section 5.7 Coating Application Methods 

Sections 5.7.3.1 and 5.7.3.2 would be added to specify HVLP requirements that were 

previously in Rule 4602 but were not carried over to Rule 4612 during the rule 

amendment project to adopt Rule 4612. This language also more closely mirrors the 

language in the ARB SCM, of which the amendments were originally based on. The 

additional language does not change the meaning of current language but instead 

clarifies it. 

Section 6.0 – Administrative Requirements 

Section 6.3 would be amended to remove redundant language. 

Section 6.4 (Recordkeeping Requirements for Coatings) would be updated to include 

language specifying that records be kept daily, as was the requirement in the previous 

rule. This language had not been carried over to this new rule from Rule 4602 but was 

requested by EPA for consistency with other air districts. 

C. Incentives 

As committed in the District 2007 Ozone Plan, staff researched the possibility of 

reducing emissions from this source category through use of incentive funding. District 

staff determined there are approximately 126 facilities in the Valley currently subject to 

the motor vehicle and mobile equipment rule. Conversations with the Compliance 

Department have confirmed that facilities have opted to comply with the new VOC 

standards that became effective on January 1, 2010, by using water-based coatings 
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rather than coating with exempt solvents or installing costly capture and control 

systems. 

The November 2008 Ventura County Air Pollution Control District (VCAPCD) Staff 

Report for Rule 74.18 (Motor Vehicle and Mobile Equipment Coating Operation) states 

that the new [water-based] color coats are performing at levels equal to or superior than 

the solvent-based versions. The report continues to say that the upgrades necessary 

for spray booths consist of adding fans or air movement equipment to accelerate the 

drying of the waterborne coatings, and these changes can be made over the time of a 

weekend. 

Rule 4612 new VOC content limits became effective January 1, 2010 and Valley 

operators have already made any necessary adjustments to ensure compliance with the 

new limits and requirements. Rule 4612 has the most stringent VOC content limits for 

this source category and the most stringent solvent cleaning VOC provisions for this 

source category. Staff researched incentive funding possibilities and have determined 

that there are no incentive funds available for this source category at this time. 

The intent of incentive funding from the District to Valley facilities is to provide funding 

that would result in further reductions of emissions. At this time, there are no alternative 

methods to further reduce VOC emissions from this source category. Operators are 

using the most current technology and the lowest VOC content coatings technologically 

feasible. However, District Staff welcome suggestions operators or stakeholders may 

have regarding opportunities for potential incentive programs, should such funds 

become available in the future. 

III. EMISSION REDUCTIONS ANALYSIS 

According to the 2007 Ozone Plan, total VOC emissions from sources subject to Rule 

4612 are estimated to be 1.54 tons per day in 2011. The 2007 Ozone plan called for 

use of incentives to further reduce emissions from this source category. Currently there 

are no incentive funds available for this source category. Additionally, the proposed rule 

amendments will not affect the meaning, scope of, or prohibitions contained in current 

rule language. As such, no emission reductions are expected from this rule amending 

project. 

IV. COST EFFECTIVENESS ANALYSIS 

Pursuant to CH&SC Section 40920.6(a), the District is required to analyze the cost 

effectiveness of new rules or rule amendments that implement Best Available Retrofit 

Control Technology (BARCT) or all feasible measure. Current Rule 4612 already 
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implements BARCT. No new emission control requirements are proposed. As such, 

this project is not subject to the cost effectiveness analysis mandate. 

V. SOCIOECONOMIC ANALYSIS

Pursuant to CH&SC Section 40728.5 (a), an assessment of the socioeconomic impacts 

is not required for any rule or regulation that only adopts a requirement that is 

substantially similar to, or is required by state or federal statute, regulation, or applicable 

formal guidance, such as a federal CTG. Proposed amendments to Rule 4612 are 

substantially similar to the ARB SCM for automotive coatings therefore there is no new 

inputs to operators so a socioeconomic impact analysis is not required. 

VI. RULE CONSISTENCY ANALYSIS 

CH&SC, Section 40727.2, requires District staff to prepare a rule consistency analysis for 

Rule 4612 that compares the elements of amendments with the corresponding elements 

of other District rules, federal regulations and guidelines that apply to the same source 

category or type of equipment. Preliminary analysis has indicated that none of the 

proposed requirements of this rule would conflict with federal rules, regulations, or 

policies covering similar stationary sources. District staff has prepared a rule 

consistency analysis, please refer to Appendix B for this analysis. 

VII. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act (CEQA), District staff investigated the 

likely environmental impacts of the proposed amendments to Rule 4612. Based on the 

lack of evidence to the contrary, District staff has concluded that the proposed 

amendments to the rule will not have any significant adverse effects on the 

environment. Staff recommends filing a Notice of Exemption under the provisions of 

Public Resource Code 15061 (b) (3). 

VIII. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) ANALYSIS 

RACT Discussion 

The Clean Air Act (CAA) Section 182(b)(2) states that ozone attainment plans shall 

assure that RACT for volatile organic compounds (VOC) is applied at certain sources. 

District Rule 4612 is a VOC rule, therefore underwent a RACT analysis during this ruleamending project. A RACT analysis requires an examination of a rule against Federal 

rules, regulations, and technology guidelines as well as comparing it against rules from 

other air districts in California. 
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District staff compared emission limits, optional control requirements, and work practice 

standards in District Rule 4612 to comparable requirements in rules from the other Air 

Districts in California nonattainment areas. Based on that analysis, District staff has 

concluded that District Rule 4612 satisfies RACT for automotive coating operations. 

A. Comparison with Federal Rules and Regulations 

EPA – Control Technique Guidelines (CTG)

1. EPA-450/2-76-028 1976/11 Control of Volatile Organic Emissions from Existing

Stationary Sources - Volume I: Control Methods for Surface Coating Operations 

The CTG applies to surface coating operations located in marginal, moderate, serious 

or severe ozone nonattainment areas that has the potential to emit greater than or equal 

to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for extreme 

ozone nonattainment areas. This CTG will not be compared to District Rule 4612 since 

the source category (Motor Vehicle and Mobile Equipment Coating) is addressed in 

another CTG: EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from 

Existing Stationary Sources – Volume II: Surface Coating of Cans, Coils, Paper, 

Fabrics, Automobiles, and Light-Duty Trucks (See discussion below). 

2. EPA-450/2-77-008 1977/05 Control of Volatile Organic Emissions from Existing

Stationary Sources - Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, 

Automobiles, and Light-Duty Trucks 

The CTG applies to motor vehicle surface coating operations located in marginal, 

moderate, serious or severe ozone nonattainment areas that has the potential to emit 

greater than or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of 

VOC for extreme ozone nonattainment areas. The table below identifies the CTG 

requirements and how Rule 4612 compares to the automobile and light-duty truck 

coating requirements. 

Table 2 - Rule and CTG Comparison 

Coating Type CTG (lb/gal) Rule 4612 (lb/gal) 

Prime 2.8 2.1 

Topcoat 4.2 2.1 

Final Repair Topcoat 5.5 2.1 

3. EPA-453/R-08-006 2008/09 Control Techniques Guidelines for Automobile and LightDuty Truck Assembly Coatings 

The CTG applies to vehicle assembly coating operations located in marginal, moderate, 

serious or severe ozone nonattainment areas that has the potential to emit greater than 

or equal to 25 tons/year of VOC, and equal to greater than 10 tons/year of VOC for 
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9 Final Staff Report with Appendices 

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extreme ozone nonattainment areas. There are no vehicle assembly plants in the 

District and such operations would fall under Rule 4602 therefore, this CTG will not be 

examined. 

EPA - Alternative Control Technology (ACT) 

EPA-453/R-94-017 1994/02 Alternative Control Techniques Document - Surface 

Coating of Automotive/Transportation and Business Machine Plastic Parts 

The ACT applies to the coating of plastic parts for the automotive industry, business 

machines, and other miscellaneous plastic parts. The ACT identifies an automotive 

coating work practice standards, VOC content limits, application methods, and add-on 

control efficiencies based on California air district rules as of 1994. Since SJVAPCD 

Rule 4612 is at least as stringent overall compared to other districts (see analysis below 

in Section III), a detailed evaluation of the ACT is not necessary. 

Standards of Performance for New Stationary Sources (NSPS) 

40 CFR 60 Subpart MM (Standards of Performance for Automobile and Light Duty 

Truck Surface Coating Operations) applies to assembly plant coatings.

There are no vehicle assembly plants in the District; therefore, this NSPS will not be 

examined. 

National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

NESHAPs and MACTs are requirements contained in 40 Code of Federal Regulations 

(CFR) Part 61 and 40 CFR Part 63. Since EPA has delegated the authority to 

implement NESHAP requirements to the District, NESHAPs and MACTs promulgated 

by EPA are usually incorporated by reference into District Rule 4002 (National Emission 

Standards for Hazardous Air Pollutants). It is important to mention that the District 

implements NESHAPs and MACTs by incorporating the emission standards as 

conditions of the Permits to Operate issued to affected sources. 

40 CFR 63 Subpart IIII (National Emission Standards for HAPs: Surface Coating of 

Automobiles and Light-Duty Trucks) 

The requirements in this subpart are not directly comparable to the District Rule 4612 

limits. The NESHAP HAP emission limits which are expressed in terms of % HAP, HAP 

emission concentration, and mass (kg) of HAP per mass (kg) of solids are not directly 

comparable to the coatings VOC limit which is expressed in terms of grams (or lb) of 

VOC per liter (or gallons) of coatings, less water and exempt compounds, as applied. In 

addition, some HAPs may be exempt VOCs, and some VOCs may be HAPs; therefore, 

there is no direct correlation between the NESHAP limits versus District Rule 4612 VOC 

limits.
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B. Comparison with Other California Non-Attainment Areas

District staff compared District Rule 4612 with the rules of other California ozone 

nonattainment air districts’ rules (listed below) auto coating operations. The results of 

the analysis are discussed below. 

• South Coast Air Quality Management District (SCAQMD) Rule 1151 - Motor Vehicle 

and Mobile Equipment Non-Assembly Line Coating Operations (Amended 

December 2, 2005) 

• Bay Area Air Quality Management District (BAAQMD) Regulation 8 Rule 45 – Motor 

Vehicle and Mobile Equipment Coating Operations (Amended January 6, 1999) 

• Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 459 - 

Automotive, Truck and Heavy Equipment Refinishing Operations) (Amended 

• October 2, 1997) 

• Ventura County Air Pollution Control District (VCAPCD) Rule 74.18 - Motor Vehicle 

and Mobile Equipment Coating Operations (Amended September 10, 1996) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

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Table 3 - Rule Comparisons (g/l VOC)

Coating Category 

Bay Area 

(Rule 8-45) 

South Coast 

(Rule 1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 74.18) 

SJVAPCD 

(Rule 4612) 

Adhesion Promoter 

Plastic Parts 540 

Camouflage 420 420 420 340 

Clear Coating 250 

Color Coating 540 685 420 

Pretreatment 780 750 780 780 660 

Precoat 580 600 660 

Primer 250 250 250 

Primer Sealer 340 340 420 340 250 

Primer Surfacer 250 250 250 250 

Single Stage Coating 

(not primer or multicolor) 340 

Topcoat - General 420 340 420 340 250 

Topcoat - Metallic/ Iridescent 520 340 520 520 420 

Topcoat - Metallic/ Iridescent 

(spot repair) 420 420 

Topcoat - Multicolored 540 685 420 

Topcoat - Multistage 340 540 340 340 

Topcoat - Multistage 

(spot repair) 420 340 

Water-Based Temporary 

Transit 420 250 

Coating Category 

Bay Area 

(Rule 8-45) 

South Coast 

(Rule 1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 74.18) 

SJVAPCD 

(Rule 4612) 

Temporary Protective Coating 60 60 60 

Truck Bed Liner 310 

Underbody Coating 540 430 

Uniform Finish Coating 540 

Other 250 

Application Method 

Bay Area 

(Rule 8-45) 

South Coast 

(Rule 1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 74.18) 

SJVAPCD 

(Rule 4612) 

HVLP Spray X 

Transfer Efficiency 

Minimum 65% 65% 

APCO/EPA

Approved 65% 65% 

Add-on Control Efficiency 

Bay Area 

(Rule 8-45) 

South Coast 

(Rule 1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 74.18) 

SJVAPCD 

(Rule 4612) 

Control 85% 

Overall Control 

Equiv to 

compliant 

coating 

emissions 

Equiv to 

compliant 

coating 

emissions 85% 85% by wt 

85 % and 

Equiv to 

compliant 

coating 

emissions 
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Table 3 - Rule Comparisons (g/l VOC) continued

Solvents 

Bay Area 

(Rule 8-45) 

South Coast 

(Rule 1151) 

Sac Metro 

(Rule 459) 

Ventura 

(Rule 74.18) 

SJVAPCD 

(Rule 4612) 

Product Cleaning (General) 72 25 72 200 25 

Repair and Maintenance 

Cleaning 25 72 200 25 

Cleaning of Application 

Equipment 25 72 200 25 

As shown in the table above, SJVAPCD Rule 4612 is as stringent as or more stringent 

than other districts in all categories except for two categories (precoat and Topcoat - 

Metallic/Iridescent). Since the overwhelmingly majority of coating categories are as 

stringent as or more stringent than other districts, Overall SJVAPCD Rule 4612 is at 

least as stringent as Bay Area Rule 8-45, South Coast Rule 1151, Sac Metro Rule 459, 

and Ventura Rule 74.18. 

RACT Analysis Conclusion 

After careful evaluation of federal rules and regulations as well as prohibitory rules in 

other California nonattainment areas, District staff concludes that District Rule 4612 

satisfies RACT for motor vehicle and mobile equipment coating operations. 

IX. REFERENCES 

1. ARB. “Suggested Control Measure for Automotive Coatings as Approved by the 

Board on October 20, 2005”. 

2. EPA. “Control Techniques Guidelines (CTG) for Automobile and Light-Duty Truck 

Assembly Coatings”. 2008. 

3. SJVAPCD. “Ozone Plan”. 2007. 

4. Ventura County APCD. “Final Staff Report Revisions to Rule 74.18, Motor Vehicle 

and Mobile Equipment Coating Operation”. November 11, 2008.