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Research and analyze surplus project types for off-site air quality mitigation. Assess feasibility, costs, and emissions considerations. Understand requirements, mitigation priorities, and connections to Climate Action Plans.
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Effective Off-Site Air Quality Mitigation Honey L. Walters, Principal Ascent Environmental, Inc.
“Surplus” Real Quantifiable Additional Permanent
Development Considerations • Research and identify “surplus” project types • Determine if readily feasible • Quantify implementation costs • $/pound or ton of criteria air pollutants and precursors • $/metric ton of CO2e • Overall, for off-site mitigation projects: • Feasibility • Applicability • Economic viability
Emissions Considerations • Estimating amount of off-site reduction: • Potential available from “surplus” projects • Needed for new development • Apples-to-Apples • Timing • Emissions types
Requirements • Off-site program • Necessary steps • Requirements • Adoption of rule or regulation • CEQA • Protocol • Instruction for project applicants or lead agency • Methods and tools for quantifying off-site emissions reductions • Reporting requirements
Greenhouse Gas CEQA Mitigation • California Air Resources Board • The 2017 Climate Change Scoping Plan Update • Released Jan. 20th 2017 • First Public Board Meeting Jan. 27th, 2017 • Second Public Board Meeting Feb. 16-17th, 2017 • Extended EA Comment Period (Additional Public Outreach) • Third Public Board Meeting June 22nd, 2017 • https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm
Scoping Plan Guidance Without Qualified CAP • For CEQA projects in jurisdictions without a qualified CAP: • ARB recommends implementing “all feasible measures to reduce GHG emissions” • While the Scoping Plan does not require a “no net increase” or zero net emissions threshold, it states that ARB believes this would be “the correct overall objective.” • Scoping Plan notes that several projects – including the large Newhall Ranch development – have proposed reaching zero net GHG emissions. • Will this increase the need for local off-site CEQA mitigation?
Mitigation • Recommended mitigation scheme priorities • On-site design features • Off-site with direct investments in vicinity of project (e.g. , investment at social cost of carbon into local green fund to support energy efficiency and other demand side programs) • Off-site within the State • Purchase and retire carbon credits from voluntary registry
Climate Action Plan Connection Identifying development and implementation as a reduction action or measure Off-site fees fund other CAP measures Adjust reduction value of program Co-benefits (not just greenhouse gas reductions) Part of consistency checklist
Examples Sacramento Metropolitan Air Quality Management District San Joaquin Valley Air Pollution Control District Imperial County Air Pollution Control District