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MEMORANDUM
DATE: February 14, 2026
TO: Camarillo City Council
FROM: Kirsten Marble
SUBJECT: Report on the Activities of the Ventura County Air Pollution Control District (VCAPCD) Advisory Committee in 2025
The VCAPCD Advisory Committee met twice in 2025 to review proposed amendments to the VCAPCD Rules and Regulations and make recommendations to the VCAPCD Board.
The City of Camarillo representative, Kirsten Marble, was in attendance at both meetings and voted in favor of all proposed amendments. The Advisory Committee ultimately recommended approval of all proposed amendments.
The amendments the Advisory Committee recommended for approval in the February 18 meeting were presented to and subsequently approved by the VCAPCD Board in the Board’s April 8 meeting. The amendments the Advisory Committee recommended for approval in the December 16 meeting have not yet been presented to the VCAPCD Board.
The rule amendments and other activities of the VCAPCD Advisory Committee in 2025 are summarized below.
February 18, 2025 Meeting
1. Election of Officers
The Advisory Committee voted to reelect Sara Head as Chair of the Advisory Committee and reelect Paul Meehan as Vice Chair of the Advisory Committee.
2. Proposed Amendments to Rule 33 Part 70 Permits--General, Rule 33.1 Part 70 Permits-- Definitions; and Rule 33.9 Part 70 Permits--Compliance Provisions
The proposed amendments eliminate the federal Tailoring Rule and emergency affirmative defense provisions from Rule 33 as required by the U.S. Environmental Protection Agency (EPA) due to court rulings that deemed these provisions unenforceable.
Following the decision in Massachusetts v. EPA, 549 U.S. 497 (2007), an endangerment finding was issued which identified six greenhouse gases (GHGs) from mobile sources as “air pollution” that endangers public health and welfare by contributing to climate change. In response, the EPA “tailored” the applicability requirements used to determine which emissions sources are considered major sources and thus subject to permitting requirements. 2 of 3
In Utility Regulatory Group v. EPA, 573 U.S. 302 (2014), the Supreme Court ruled that GHGs could not be treated as air pollutants for the purpose of determining what qualifies as a major source of emissions, rendering the rule unenforceable.
The emergency affirmative defense provisions, established by EPA in 1992, allowed facilities to avoid liability for excess emissions during emergencies if specific documentation was provided and mitigation steps were taken. In NRDC v. EPA, 749 F.3d 1055 (D.C. Cir. 2014), the D.C. Circuit Court ruled that these provisions exceeded EPA’s authority, and they were officially removed in 2023.
The proposed amendments are administrative in nature and not expected to affect emissions or increase costs for regulated facilities. The proposed amendments were presented at a public workshop on January 9, 2025. VCAPCD Staff received no comments from the public at the workshop, nor did they receive any written comments.
Recommended for approval, approved by the Board on April 8, 2025
3. Proposed Amendments to Rule 42 Permit Fees
The proposed amendments to Rule 42 increase permit renewal fee rates over the next five fiscal years, effective July 1, 2025. The proposed amendments increase permit renewal fees by 5% or greater annually for three years, reduce the initial late fee from 30% to 15% of the renewal fee, increase the deposit for permit applications from $2,000 to $5,000 and increase the minimum processing fee from $250 to $500 to reflect current labor rates.
The purpose of the proposed amendments is to offset the District’s operating expenses and to rectify deficiencies caused by rounding. The District anticipated a net operating loss of $560,000 in fiscal year 2024-25 due to the potential closure of large oil and gas and power-generating facilities which were significant sources of permit fee revenue. The proposed amendments are expected to increase revenue by approximately $150,000 annually for the next three fiscal years.
The proposed amendments are administrative in nature and not expected to affect emissions. The proposed amendments were presented at a public workshop on January 9, 2025. VCAPCD Staff received no comments from the public at the workshop, nor did they receive any written comments.
Recommended for approval, approved by the Board on April 8, 2025
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December 16, 2025 Meeting
4. Proposed Amendments to Rule 74.22--Natural Gas-Fired, Fan-Type Central Furnaces
Rule 74.22--Natural Gas-Fired, Fan-Type Central Furnaces is a point-of-sale rule which applies to furnaces commonly used in residential or small commercial settings. The proposed amendments would lower the nitrogen oxide (NOx) emission limit for new or replacement furnaces from 40 ng/J to 14 ng/J (ultra-low NOx). A six-month sell-through period would be implemented to facilitate the transition for manufacturers and installers. The proposed amendments also update the certification test methods and allow manufacturers to submit valid certification from the South Coast Air Quality Management District, which has already adopted the 14 ng/J limit, in lieu of the required information set forth in the rule.
The cost difference between standard and ultra-low NOx units is about $550. The District plans to launch an incentive program which would utilize the District’s internal funding in combination with grants from the California Air Resources Board to cover the cost difference between standard and ultra-low NOx units, prioritizing those in disadvantaged or low-income communities. A resolution authorizing the District to administer the incentive program will be presented concurrently with the proposed amendments to Rule 74.22 to the VCAPCD Board.
The proposed amendments are expected to reduce NOx emissions by 104 tons per year. The cost- effectiveness of the proposed amendments is estimated to be $78,867 per ton of NOx emissions reduction.
VCAPCD Staff held a public consultation meeting and a public workshop on July 24, 2025, and October 23, 2025, respectively. All comments were addressed by Staff prior to the Advisory Committee meeting.
Recommended for approval, not yet presented to the Board