Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #4

1. Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #4 July 30, 2008 SCAQMD Diamond Bar, California

2. Further Discussion of Significance Screening Level • Initial proposal based on URBEMIS modeling results of one mixed use project where NOx emission = 55 #/D or 10 T/yr • Staff modeled 19 additional hypothetic projects using URBEMIS: • Residential only: single or multi-family • Commercial only: office or bank • Industrial only: general light industry or manufacturing • Mixed use: single & multi-family • Mixed use: office & bank • Mixed use: light industry & manufacturing

3. Further Discussion of Significance Screening Level • Staff modeled 19 additional hypothetic projects continued: • Mixed use: single family residence & office • Mixed use: multi-family residential & office • Mixed use: single family residence & bank • Mixed use: multi-family residential & bank • Mixed use: single & multi-family residential & office • Mixed use: single & multi-family residential & bank • Mixed use: office & light industry • Mixed use: office & manufacturing • Mixed use: bank & light industry • Mixed use: bank & manufacturing

4. Further Discussion of Significance Screening Level • Results: • All modeling based on NOx emissions = 55 #/D or 10 T/yr & included area sources • Used weighted average trip rate, weekday, Sat. & Sun. • GHG emissions ranged from 7,304 to 7,723 MTCO2eq./yr • Average GHG emissions from URBEMIS modeling runs = 7,559 MTCO2.eq/yr • Average emission results are 16% greater than proposed significance screening level • Provides a safety margin for conversion from maximum daily NOx threshold to annual emissions (10 tons) • May result in more MNDs &, in some cases, EIRs being prepared

5. Further Discussion of Significance Screening Level • Staff modeled 13 Actual ND/MND projects using URBEMIS: • All modeling based on NOx emissions < 55 #/D or 10 T/yr • Land uses included single & multi-family residential, office, restaurant, elementary school, retail (strip mall), & industrial (waste recovery) • GHG emissions ranged from 348 to 5,081 MTCO2eq./yr • Average GHG emissions from URBEMIS modeling runs = 1,574 MTCO2.eq/yr • Preliminary results indicate NDs or MNDs for typical projects would be less than proposed significance screening level

6. Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting • Carbon neutral fuels, e.g., landfill/digester gas, should not be included in significance determination as they are “automatically ‘netted-out’” • Need to devote more time to developing GHG mitigation measures • Performance-based thresholds are preferable over numerical thresholds • Construction emissions should be amortized over lifetime of the project

7. Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Failure to mitigate GHG emissions should not trigger EIR Projects with statewide benefits, e.g., refinery projects to produce clean fuels, should be treated differently Significance threshold should not be less than CARB’s reporting threshold, i.e., 25,000 MTCO2eq./year, otherwise could result in cancellation of projects Project should not be considered significant if it meets applicable standards promulgated by CARB

8. Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Costly mitigation of desirable energy efficiency features could result in cancellation of projects Baseline should not consist of 1990 target inventories, but existing physical conditions per CEQA Guidelines §15125 Mitigation should focus on incremental emissions increase above the baseline Any significance thresholds should be consistent with CEQA precedent Zero threshold not consistent with CEQA precedent Numeric threshold can’t be scientifically supported Set a qualitative threshold base on design features, mitigation to improve energy efficiency, or comply with AB 32 Should use caution when using existing methodologies to evaluate climate change, e.g., trip rates from ITE use maximum daily trip rates

9. Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Should add additional options to tier 4 Option #4: Project results in net energy efficiency Project meets applicable standards promulgated by CARB, air districts, or agencies/commissions Regardless of project life, construction emissions should not be offset Significance threshold should be based on 2050 emission reduction targets Existing set of exemptions should be retained Analysis is needed to support a finding of no further action for categorically exempt projects

10. Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Compliance with GHG reduction plan should be its own tier There is a large disconnect between significance screening level & remaining emissions under the Tier 4 compliance options Compliance with a target objective should not be through offsets alone Reductions from BAU is not the proper metric for determining significance Emission reductions from BAU could penalize projects in environmentally progressive areas

11. Discussion • Other comments or discussion on the revised staff proposal? • Where do we go from here?