Greenhouse Gas CEQA Greenhouse Gas CEQA Significance Threshold Significance Threshold

Stakeholder Working Group Stakeholder Working Group #2#2

May 28, 2008SCAQMD

Diamond Bar, California

Policy Objectives - Evaluate Policy Objectives - Evaluate Project’s GHG Emissions or Life Project’s GHG Emissions or Life

Cycle Emissions?Cycle Emissions?• Staff recommendation – Exclude life cycle analysis Staff recommendation – Exclude life cycle analysis

at this time, but analyze direct & indirect project at this time, but analyze direct & indirect project emissionsemissionsLife cycle factors not well established for all processesLife cycle factors not well established for all processesNot all life cycle processes are known or well definedNot all life cycle processes are known or well definedSome life cycle processes occur outside CA.Some life cycle processes occur outside CA.CARB inventory - emissions from each source categoryCARB inventory - emissions from each source categoryGHG reductions as mitigation – direct/indirect emissionsGHG reductions as mitigation – direct/indirect emissions

• May reconsider in the future when the science is May reconsider in the future when the science is more maturemore mature

Policy Objectives – Use GHG Policy Objectives – Use GHG Thresholds as a Means to Thresholds as a Means to

Implement AB 32Implement AB 32• Staff recommendations: No, but will Staff recommendations: No, but will

complement AB 32 effortscomplement AB 32 effortsCEQA intent is to prevent or minimize environmental CEQA intent is to prevent or minimize environmental

degradation, i.e., do not make impacts worsedegradation, i.e., do not make impacts worseAB 32 may be used as a guideline in developing AB 32 may be used as a guideline in developing

significance thresholdssignificance thresholdsReductions from non-regulated sources due to GHG Reductions from non-regulated sources due to GHG

thresholds may contribute to achieving AB 32 thresholds may contribute to achieving AB 32 targetstargets

Complying with AB 32 measures should not Complying with AB 32 measures should not automatically deem a project is not significant for automatically deem a project is not significant for GHGsGHGs

Design Criteria Design Criteria ConsiderationsConsiderations

• Resource impacts – staff Resource impacts – staff recommendations:recommendations:Avoid thresholds that would require EIRs for Avoid thresholds that would require EIRs for

all projectsall projectsEIRs don’t necessarily result in more mitigation EIRs don’t necessarily result in more mitigation

measuresmeasuresSetting the significance threshold(s) too low may Setting the significance threshold(s) too low may

provide disincentive for implementing GHG provide disincentive for implementing GHG mitigation mitigation

Need to consider resource impacts – should Need to consider resource impacts – should not be overly burdensomenot be overly burdensome

Design Criteria Design Criteria ConsiderationsConsiderations

• Short-term (2008 through 2020) vs. Short-term (2008 through 2020) vs. long-term (2021 through 2050) long-term (2021 through 2050) considerations – staff recommendations:considerations – staff recommendations:Consider short-term thresholds at this timeConsider short-term thresholds at this timeThreshold is interim until statewide guidance Threshold is interim until statewide guidance

or threshold establishedor threshold establishedThreshold applicable to SCAQMD jurisdiction Threshold applicable to SCAQMD jurisdiction

onlyonlyReevaluate long-term thresholds later when Reevaluate long-term thresholds later when

statewide guidance establishedstatewide guidance established

Design Criteria Design Criteria ConsiderationsConsiderations

• GHG pollutants – staff GHG pollutants – staff recommendations: recommendations: Analyze the 6 Kyoto pollutants to the Analyze the 6 Kyoto pollutants to the

extent EFs are availableextent EFs are availableAdd others as scientific information Add others as scientific information

becomes available &/or agreed to by becomes available &/or agreed to by national/international protocolsnational/international protocols

Consider carbon black in the future when Consider carbon black in the future when more information is availablemore information is available

Design Criteria Design Criteria ConsiderationsConsiderations

• Mitigation considerations – preferred Mitigation considerations – preferred emission reduction strategies:emission reduction strategies: Incorporate GHG reduction strategies into Incorporate GHG reduction strategies into

project designproject designFor modification projects, mitigate GHGs from For modification projects, mitigate GHGs from

other onsite sourcesother onsite sourcesMitigation may also consist of offsite GHG Mitigation may also consist of offsite GHG

emission reduction projectsemission reduction projectsMitigation applies to both construction & Mitigation applies to both construction &

operational GHG impactsoperational GHG impactsFeasible mitigation considers economic factors Feasible mitigation considers economic factors

(cost) per §15364(cost) per §15364

Design Criteria Design Criteria ConsiderationsConsiderations

• Mitigation considerations – offsite offsets: Mitigation considerations – offsite offsets: Offset purchase acceptable with preference Offset purchase acceptable with preference

toward mitigation in-basin or in-state, offset toward mitigation in-basin or in-state, offset cost a considerationcost a consideration

Offset market still developing, so need to Offset market still developing, so need to ensure offsets are obtained from a creditable ensure offsets are obtained from a creditable sourcesource

Offsets should be provided for at least 10 years Offsets should be provided for at least 10 years of project operation (see SJVAPCD indirect of project operation (see SJVAPCD indirect source rule 9510 §6.2 mitigation requirements)source rule 9510 §6.2 mitigation requirements)

SCAQMD may consider an AQIP-type programSCAQMD may consider an AQIP-type program

Design Criteria Design Criteria ConsiderationsConsiderations

• Time frame of analysis, impacts vs. Time frame of analysis, impacts vs. mitigation – staff recommendations:mitigation – staff recommendations:Analyze GHGs on an annual basis for Analyze GHGs on an annual basis for

both construction & operationboth construction & operationBecause of the long ½-life of CO2, Because of the long ½-life of CO2,

mitigation does not need to be precisely mitigation does not need to be precisely contemporaneous with emission impact, contemporaneous with emission impact, but commitment has to be enforceable but commitment has to be enforceable & timely& timely

DiscussionDiscussion

•Other policy considerations?Other policy considerations?

•Other design criteria Other design criteria considerations?considerations?

GHG Significance Threshold GHG Significance Threshold Staff Proposal – Staff Proposal –

General ConceptsGeneral Concepts• Tiered Approach:

1st – Any applicable exemption; if not2nd – Consistent with approved general plans; if not

• AB 32 reduction targets

• Emissions inventory, tracking and reduction remedy

3rd – Implement prescribed mitigation measures by sector / source; if not

4th – Implement offsite emission reduction projects or offsets (full mitigation required); if not

5th – Project is concluded to be significant