Dunn-Edwards Corp. v. South Coast Air Quality Management District

Twenty California paint manufacturers, contractors, and dealers (the Paint Companies) appeal from portions of the judgment granting in part and denying in part their petition for writ of mandate to compel the South Coast Air Quality Management District (the District) to further assess the environmental implications of certain amendments to District rule 1113, adopted on February 2, 1990 (Rule 1113).

The amendments in question were designed to abate emissions of volatile organic compounds (VOC’s) from a number of types of architectural coatings by imposing restrictions on their content. The Paint Companies sought to invalidate the amendments relating to six of the coatings, including “non-flat” (enamel) coatings, on the ground the District violated the Califor nia Environmental Quality Act (CEQA, Pub. Resources Code, § 21000 et seq.) by ignoring seven adverse environmental impacts of each of the six amendments.

The trial court determined the District adequately addressed all environmental issues with respect to nonflat coatings. However, the court found the District failed to adequately address thinning issues relating to the other five coatings in the manner required by…