Greenhouse Gas CEQA Greenhouse Gas CEQA Significance Threshold Significance Threshold

Stakeholder Working GroupStakeholder Working Group

April 30, 2008SCAQMD

Diamond Bar, California

Goals of the Working GroupGoals of the Working Group

• Establish GHG significance thresholdEstablish GHG significance thresholdPolicy considerations – purpose of GHG Policy considerations – purpose of GHG

significance thresholdsignificance thresholdDesign considerationsDesign considerations

• Achieve consensus to the extent possible Achieve consensus to the extent possible from the stakeholder working groupfrom the stakeholder working group

• Approval from SCAQMD Governing BoardApproval from SCAQMD Governing Board

• Advocate for GHG significance thresholdAdvocate for GHG significance threshold

Process and ScheduleProcess and Schedule• Establish monthly working group meetingsEstablish monthly working group meetings

• Discuss feasible significance thresholds; Discuss feasible significance thresholds; eliminate infeasible significance thresholdseliminate infeasible significance thresholds

• Coordinate efforts with other air agencies, Coordinate efforts with other air agencies, e.g. BAAQMD, CARB, etc.e.g. BAAQMD, CARB, etc.

• Establish recommended significance Establish recommended significance thresholdthreshold

• Conduct Public Workshop (Summer 2008)Conduct Public Workshop (Summer 2008)

• Take significance threshold to Governing Take significance threshold to Governing Board for approval (Fall 2008)Board for approval (Fall 2008)

• Provide public outreachProvide public outreach

BackgroundBackground

• Several Attorney General LawsuitsSeveral Attorney General Lawsuits San Bernardino General Plan – failure to San Bernardino General Plan – failure to

analyze GHGsanalyze GHGs ConocoPhillips Bay Area Refinery – failure to ConocoPhillips Bay Area Refinery – failure to

conclude whether or not GHGs significantconclude whether or not GHGs significant

• Association of Environmental Association of Environmental Professionals White Paper on GHG Professionals White Paper on GHG thresholdsthresholds8 approaches for handling GHG analyses8 approaches for handling GHG analyses

• CAPCOA’s White Paper on Climate CAPCOA’s White Paper on Climate ChangeChange

BackgroundBackground

• San Joaquin Valley Significance San Joaquin Valley Significance ThresholdThresholdRecommended draft threshold Recommended draft threshold

established March 2008established March 2008GHG threshold = 38,477 MT CO2eqGHG threshold = 38,477 MT CO2eqBased on CAPCOA threshold option 2.4 – Based on CAPCOA threshold option 2.4 –

Regulated Emissions Inventory CaptureRegulated Emissions Inventory CaptureCurrently, no plans to formally approve Currently, no plans to formally approve

through a public processthrough a public process

BackgroundBackground

• GHGs under state lawGHGs under state law““Air pollutant” includes gases, Air pollutant” includes gases,

particulate matter, dust, carbon, etc.particulate matter, dust, carbon, etc.Districts have primary authority over Districts have primary authority over

pollution from non-vehicular sourcespollution from non-vehicular sourcesAB 32 does not “limit or expand” AB 32 does not “limit or expand”

existing authority of districtsexisting authority of districtsCARB to adopt rules for “sources” CARB to adopt rules for “sources”

including nonvehicular (AB 32)including nonvehicular (AB 32)

Considerations in Preparing Considerations in Preparing Significance ThresholdsSignificance Thresholds

• Evaluate direct GHG emissions or life Evaluate direct GHG emissions or life cycle emissions?cycle emissions?

• Staff recommendation - direct GHG Staff recommendation - direct GHG emissionsemissionsLife cycle factors not well established for all Life cycle factors not well established for all

processesprocessesSome life cycle processes occur outside CA.Some life cycle processes occur outside CA.CEQA requires analysis of impacts in CA.CEQA requires analysis of impacts in CA.CARB inventory - direct emissionsCARB inventory - direct emissionsGHG reductions as mitigation - direct GHG reductions as mitigation - direct

emissionsemissions

Considerations in Preparing Considerations in Preparing Significance Thresholds Significance Thresholds

(Cont.)(Cont.)• CEQA Guidelines §15064 – Determination of CEQA Guidelines §15064 – Determination of

Significance:Significance:Requires careful judgment by public agency Requires careful judgment by public agency

involvedinvolvedShould be based on scientific & factual dataShould be based on scientific & factual data Ironclad definition may not always be possibleIronclad definition may not always be possibleMay vary with settingMay vary with setting

• CEQA Guidelines §15064.7 – Thresholds of CEQA Guidelines §15064.7 – Thresholds of Significance are:Significance are: Identifiable quantitative performance levelsIdentifiable quantitative performance levels Identifiable qualitative performance levelsIdentifiable qualitative performance levels

Considerations in Preparing Considerations in Preparing Significance Thresholds Significance Thresholds

(Cont.)(Cont.)

• If significant, implement feasible If significant, implement feasible mitigation measures to minimize mitigation measures to minimize significant impactsignificant impact

• If significant, requires alternatives, If significant, requires alternatives, which include energy conservationwhich include energy conservation

• Negative Declaration v. EIRNegative Declaration v. EIR

• Cumulative v. project specificCumulative v. project specific

Policy ObjectivesPolicy Objectives

• Use GHG thresholds as a means of complying Use GHG thresholds as a means of complying with AB 32 emission reduction goals?with AB 32 emission reduction goals?

• Use GHG thresholds in parallel with AB 32 to Use GHG thresholds in parallel with AB 32 to achieve reductions from non-regulated achieve reductions from non-regulated sources?sources?

• Use AB 32 as a guideline in developing Use AB 32 as a guideline in developing significance thresholds?significance thresholds?

• Prevent or minimize environmental Prevent or minimize environmental degradation, i.e., do not make impacts worse?degradation, i.e., do not make impacts worse?

Design Criteria Design Criteria ConsiderationsConsiderations

• Resource impacts – costs & staffingResource impacts – costs & staffing Number of EIRs vs. negative declarations or categorical Number of EIRs vs. negative declarations or categorical

exemptionsexemptions

• Administrative burdenAdministrative burden

• A single threshold vs. multiple thresholdsA single threshold vs. multiple thresholds

• Short-term (2008 through 2020) vs. long-term Short-term (2008 through 2020) vs. long-term (2021 through 2050) considerations(2021 through 2050) considerations

• GHG pollutants: 6 Kyoto pollutants to the extent GHG pollutants: 6 Kyoto pollutants to the extent EFs are available (carbon black?)EFs are available (carbon black?)

• Offsite mitigation considerations – discrete Offsite mitigation considerations – discrete (limited life) vs. stream (infinite life, e.g., ERCs)(limited life) vs. stream (infinite life, e.g., ERCs)

• Time frame of analysis, impacts vs. mitigationTime frame of analysis, impacts vs. mitigation

Future Action/MeetingFuture Action/Meeting

• GHG Working Group Website: GHG Working Group Website: http://www.aqmd.gov/ceqa/handbook/GHG/GHG.htmlhttp://www.aqmd.gov/ceqa/handbook/GHG/GHG.html

• Action ItemsAction Items

• Determine meeting scheduleDetermine meeting schedule

• Next meeting: May 2008Next meeting: May 2008

• Topics for considerationTopics for considerationCAPCOA White Paper optionsCAPCOA White Paper optionsOthers?Others?