Effective Off-Site Air Quality Mitigation Honey L. Walters, Principal Ascent Environmental, Inc.

“Surplus” Real Quantifiable Additional Permanent Need to avoid crediting projects that would already occur in absence of the offsite mitigation program (i.e., double-counting)

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 Protocol 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/scopi ngplan/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? The Scoping Plan acknowledges that no net increase may not be appropriate or feasible for every project. In these situations, the Scoping Plan suggests that lead agencies could use a different numeric threshold so long as it is supported by evidence showing that the threshold is consistent with the 2030 Scoping Plan and State’s long term goals. The problem facing agencies and applicants that want to use this approach: no one knows how much evidence would be enough to survive judicial scrutiny.

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