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

2. “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)

3. 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

4. Emissions Considerations
Estimating amount of off-site reduction:
Potential available from “surplus” projects
Needed for new development
Apples-to-Apples
Timing
Emissions types

5. 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

6. 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 th, 2017
Extended EA Comment Period (Additional Public Outreach)
Third Public Board Meeting June 22nd, 2017
ngplan/scopingplan.htm

7. 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.

8. 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

9. 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

10. Examples Sacramento Metropolitan Air Quality Management District
San Joaquin Valley Air Pollution Control District
Imperial County Air Pollution Control District