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

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

Policy Objectives – Use GHG Thresholds as a Means to Implement AB 32 Staff recommendations: No, but will complement AB 32 efforts 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 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 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 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 Complying with AB 32 measures should not automatically deem a project is not significant for GHGs

Design Criteria Considerations Resource impacts – staff recommendations: Resource impacts – staff recommendations: Avoid thresholds that would require EIRs for all projects 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 Need to consider resource impacts – should not be overly burdensome

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

Design Criteria Considerations GHG pollutants – staff recommendations: GHG pollutants – staff recommendations: Analyze the 6 Kyoto pollutants to the extent EFs are available 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 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 Consider carbon black in the future when more information is available

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

Design Criteria Considerations Mitigation considerations – offsite offsets: Mitigation considerations – offsite offsets: Offset purchase acceptable with preference toward mitigation in-basin or in-state, offset cost a consideration 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 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) 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 SCAQMD may consider an AQIP-type program

Design Criteria Considerations Time frame of analysis, impacts vs. mitigation – staff recommendations: Time frame of analysis, impacts vs. mitigation – staff recommendations: Analyze GHGs on an annual basis for both construction & operation 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 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

Discussion Other policy considerations? Other policy considerations? Other design criteria considerations? Other design criteria considerations?

GHG Significance Threshold Staff Proposal – General Concepts Tiered Approach: 1 st – Any applicable exemption; if not 2 nd – Consistent with approved general plans; if not AB 32 reduction targets Emissions inventory, tracking and reduction remedy 3 rd – Implement prescribed mitigation measures by sector / source; if not 4 th – Implement offsite emission reduction projects or offsets (full mitigation required); if not 5 th – Project is concluded to be significant