Greenhouse Gas CEQA Greenhouse Gas CEQA Significance Threshold Significance Threshold

Stakeholder Working Group Stakeholder Working Group #4#4

July 30, 2008SCAQMD

Diamond Bar, California

Further Discussion of Significance Screening Level

• Initial proposal based on URBEMIS Initial proposal based on URBEMIS modeling results of one mixed use project modeling results of one mixed use project where NOx emission = 55 #/D or 10 T/yrwhere NOx emission = 55 #/D or 10 T/yr

• Staff modeled 19 additional hypothetic Staff modeled 19 additional hypothetic projects using URBEMIS:projects using URBEMIS:Residential only: single or multi-familyResidential only: single or multi-familyCommercial only: office or bankCommercial only: office or bank Industrial only: general light industry or Industrial only: general light industry or

manufacturingmanufacturingMixed use: single & multi-familyMixed use: single & multi-familyMixed use: office & bankMixed use: office & bankMixed use: light industry & manufacturingMixed use: light industry & manufacturing

Further Discussion of Significance Screening Level

• Staff modeled 19 additional hypothetic Staff modeled 19 additional hypothetic projects continued:projects continued:Mixed use: single family residence & officeMixed use: single family residence & officeMixed use: multi-family residential & officeMixed use: multi-family residential & officeMixed use: single family residence & bankMixed use: single family residence & bankMixed use: multi-family residential & bankMixed use: multi-family residential & bankMixed use: single & multi-family residential & officeMixed use: single & multi-family residential & officeMixed use: single & multi-family residential & bankMixed use: single & multi-family residential & bankMixed use: office & light industryMixed use: office & light industryMixed use: office & manufacturingMixed use: office & manufacturingMixed use: bank & light industryMixed use: bank & light industryMixed use: bank & manufacturingMixed use: bank & manufacturing

Further Discussion of Significance Screening Level

• Results:Results:All modeling based on NOx emissions = 55 #/D or All modeling based on NOx emissions = 55 #/D or

10 T/yr & included area sources10 T/yr & included area sourcesUsed weighted average trip rate, weekday, Sat. & Used weighted average trip rate, weekday, Sat. &

Sun.Sun.GHG emissions ranged from 7,304 to 7,723 GHG emissions ranged from 7,304 to 7,723

MTCO2eq./yrMTCO2eq./yrAverage GHG emissions from URBEMIS modeling Average GHG emissions from URBEMIS modeling

runs = 7,559 MTCO2.eq/yrruns = 7,559 MTCO2.eq/yrAverage emission results are 16% greater than Average emission results are 16% greater than

proposed significance screening levelproposed significance screening levelProvides a safety margin for conversion from Provides a safety margin for conversion from

maximum daily NOx threshold to annual emissions maximum daily NOx threshold to annual emissions (10 tons)(10 tons)

May result in more MNDs &, in some cases, EIRs May result in more MNDs &, in some cases, EIRs being preparedbeing prepared

Further Discussion of Significance Screening Level

• Staff modeled 13 Actual ND/MND projects Staff modeled 13 Actual ND/MND projects using URBEMIS:using URBEMIS:All modeling based on NOx emissions < 55 #/D All modeling based on NOx emissions < 55 #/D

or 10 T/yror 10 T/yrLand uses included single & multi-family Land uses included single & multi-family

residential, office, restaurant, elementary residential, office, restaurant, elementary school, retail (strip mall), & industrial (waste school, retail (strip mall), & industrial (waste recovery)recovery)

GHG emissions ranged from 348 to 5,081 GHG emissions ranged from 348 to 5,081 MTCO2eq./yrMTCO2eq./yr

Average GHG emissions from URBEMIS Average GHG emissions from URBEMIS modeling runs = 1,574 MTCO2.eq/yrmodeling runs = 1,574 MTCO2.eq/yr

Preliminary results indicate NDs or MNDs for Preliminary results indicate NDs or MNDs for typical projects would be less than proposed typical projects would be less than proposed significance screening levelsignificance screening level

Comments on Revised Staff Comments on Revised Staff Proposal #1 from the June 19, Proposal #1 from the June 19,

2008 Stakeholder Meeting2008 Stakeholder Meeting• Carbon neutral fuels, e.g., landfill/digester Carbon neutral fuels, e.g., landfill/digester

gas, should not be included in significance gas, should not be included in significance determination as they are “automatically determination as they are “automatically ‘netted-out’”‘netted-out’”

• Need to devote more time to developing Need to devote more time to developing GHG mitigation measuresGHG mitigation measures

• Performance-based thresholds are Performance-based thresholds are preferable over numerical thresholdspreferable over numerical thresholds

• Construction emissions should be amortized Construction emissions should be amortized over lifetime of the projectover lifetime of the project

Comments on Revised Staff Comments on Revised Staff Proposal #1 from the June 19, Proposal #1 from the June 19,

2008 Stakeholder Meeting 2008 Stakeholder Meeting (Cont.)(Cont.)• Failure to mitigate GHG emissions should not Failure to mitigate GHG emissions should not

trigger EIRtrigger EIR• Projects with statewide benefits, e.g., Projects with statewide benefits, e.g.,

refinery projects to produce clean fuels, refinery projects to produce clean fuels, should be treated differentlyshould be treated differently

• Significance threshold should not be less Significance threshold should not be less than CARB’s reporting threshold, i.e., 25,000 than CARB’s reporting threshold, i.e., 25,000 MTCO2eq./year, otherwise could result in MTCO2eq./year, otherwise could result in cancellation of projectscancellation of projects

• Project should not be considered significant Project should not be considered significant if it meets applicable standards promulgated if it meets applicable standards promulgated by CARBby CARB

Comments on Revised Staff Comments on Revised Staff Proposal #1 from the June 19, Proposal #1 from the June 19,

2008 Stakeholder Meeting 2008 Stakeholder Meeting (Cont.)(Cont.)

• Costly mitigation of desirable energy efficiency features could Costly mitigation of desirable energy efficiency features could result in cancellation of projectsresult in cancellation of projects

• Baseline should not consist of 1990 target inventories, but Baseline should not consist of 1990 target inventories, but existing physical conditions per CEQA Guidelines §15125existing physical conditions per CEQA Guidelines §15125

• Mitigation should focus on incremental emissions increase Mitigation should focus on incremental emissions increase above the baselineabove the baseline

• Any significance thresholds should be consistent with CEQA Any significance thresholds should be consistent with CEQA precedentprecedent Zero threshold not consistent with CEQA precedentZero threshold not consistent with CEQA precedent Numeric threshold can’t be scientifically supportedNumeric threshold can’t be scientifically supported Set a qualitative threshold base on design features, mitigation to Set a qualitative threshold base on design features, mitigation to

improve energy efficiency, or comply with AB 32improve energy efficiency, or comply with AB 32• Should use caution when using existing methodologies to Should use caution when using existing methodologies to

evaluate climate change, e.g., trip rates from ITE use evaluate climate change, e.g., trip rates from ITE use maximum daily trip ratesmaximum daily trip rates

Comments on Revised Staff Comments on Revised Staff Proposal #1 from the June 19, Proposal #1 from the June 19,

2008 Stakeholder Meeting 2008 Stakeholder Meeting (Cont.)(Cont.)• Should add additional options to tier 4Should add additional options to tier 4

Option #4: Project results in net energy efficiencyOption #4: Project results in net energy efficiencyProject meets applicable standards promulgated by Project meets applicable standards promulgated by

CARB, air districts, or agencies/commissionsCARB, air districts, or agencies/commissions• Regardless of project life, construction Regardless of project life, construction

emissions should not be offsetemissions should not be offset• Significance threshold should be based on Significance threshold should be based on

2050 emission reduction targets2050 emission reduction targets• Existing set of exemptions should be retainedExisting set of exemptions should be retained• Analysis is needed to support a finding of no Analysis is needed to support a finding of no

further action for categorically exempt projectsfurther action for categorically exempt projects

Comments on Revised Staff Comments on Revised Staff Proposal #1 from the June 19, Proposal #1 from the June 19,

2008 Stakeholder Meeting 2008 Stakeholder Meeting (Cont.)(Cont.)• Compliance with GHG reduction plan should be Compliance with GHG reduction plan should be

its own tierits own tier• There is a large disconnect between There is a large disconnect between

significance screening level & remaining significance screening level & remaining emissions under the Tier 4 compliance optionsemissions under the Tier 4 compliance options

• Compliance with a target objective should not Compliance with a target objective should not be through offsets alonebe through offsets alone

• Reductions from BAU is not the proper metric Reductions from BAU is not the proper metric for determining significancefor determining significance

• Emission reductions from BAU could penalize Emission reductions from BAU could penalize projects in environmentally progressive areasprojects in environmentally progressive areas

Discussion

•Other comments or discussion on Other comments or discussion on the revised staff proposal?the revised staff proposal?

•Where do we go from here?Where do we go from here?