Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #2

1. Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #2 May 28, 2008 SCAQMD Diamond Bar, California

2. Policy Objectives - Evaluate Project’s GHG Emissions or Life Cycle Emissions? • Staff recommendation – Exclude life cycle analysis at this time, but analyze direct & indirect project emissions • Life cycle factors not well established for all processes • Not all life cycle processes are known or well defined • Some life cycle processes occur outside CA. • CARB inventory - emissions from each source category • GHG reductions as mitigation – direct/indirect emissions • May reconsider in the future when the science is more mature

3. Policy Objectives – Use GHG Thresholds as a Means to Implement AB 32 • Staff recommendations: No, but will complement AB 32 efforts • CEQA intent is to prevent or minimize environmental degradation, i.e., do not make impacts worse • AB 32 may be used as a guideline in developing significance thresholds • Reductions from non-regulated sources due to GHG thresholds may contribute to achieving AB 32 targets • Complying with AB 32 measures should not automatically deem a project is not significant for GHGs

4. Design Criteria Considerations • Resource impacts – staff recommendations: • Avoid thresholds that would require EIRs for all projects • EIRs don’t necessarily result in more mitigation measures • Setting the significance threshold(s) too low may provide disincentive for implementing GHG mitigation • Need to consider resource impacts – should not be overly burdensome

5. Design Criteria Considerations • Short-term (2008 through 2020) vs. long-term (2021 through 2050) considerations – staff recommendations: • Consider short-term thresholds at this time • Threshold is interim until statewide guidance or threshold established • Threshold applicable to SCAQMD jurisdiction only • Reevaluate long-term thresholds later when statewide guidance established

6. Design Criteria Considerations • GHG pollutants – staff recommendations: • Analyze the 6 Kyoto pollutants to the extent EFs are available • Add others as scientific information becomes available &/or agreed to by national/international protocols • Consider carbon black in the future when more information is available

7. Design Criteria Considerations • Mitigation considerations – preferred emission reduction strategies: • Incorporate GHG reduction strategies into project design • For modification projects, mitigate GHGs from other onsite sources • Mitigation may also consist of offsite GHG emission reduction projects • Mitigation applies to both construction & operational GHG impacts • Feasible mitigation considers economic factors (cost) per §15364

8. Design Criteria Considerations • Mitigation considerations – offsite offsets: • Offset purchase acceptable with preference toward mitigation in-basin or in-state, offset cost a consideration • Offset market still developing, so need to ensure offsets are obtained from a creditable source • Offsets should be provided for at least 10 years of project operation (see SJVAPCD indirect source rule 9510 §6.2 mitigation requirements) • SCAQMD may consider an AQIP-type program

9. Design Criteria Considerations • Time frame of analysis, impacts vs. mitigation – staff recommendations: • Analyze GHGs on an annual basis for both construction & operation • Because of the long ½-life of CO2, mitigation does not need to be precisely contemporaneous with emission impact, but commitment has to be enforceable & timely

10. Discussion • Other policy considerations? • Other design criteria considerations?

11. GHG Significance Threshold Staff Proposal – General Concepts • Tiered Approach: • 1st – Any applicable exemption; if not • 2nd – 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