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

2. Goals of the Working Group Establish GHG significance threshold Establish GHG significance threshold Policy considerations – purpose of GHG significance threshold Policy considerations – purpose of GHG significance threshold Design considerations Design considerations Achieve consensus to the extent possible from the stakeholder working group Achieve consensus to the extent possible from the stakeholder working group Approval from SCAQMD Governing Board Approval from SCAQMD Governing Board Advocate for GHG significance threshold Advocate for GHG significance threshold

3. Process and Schedule Establish monthly working group meetings Establish monthly working group meetings Discuss feasible significance thresholds; eliminate infeasible significance thresholds Discuss feasible significance thresholds; eliminate infeasible significance thresholds Coordinate efforts with other air agencies, e.g. BAAQMD, CARB, etc. Coordinate efforts with other air agencies, e.g. BAAQMD, CARB, etc. Establish recommended significance threshold Establish recommended significance threshold Conduct Public Workshop (Summer 2008) Conduct Public Workshop (Summer 2008) Take significance threshold to Governing Board for approval (Fall 2008) Take significance threshold to Governing Board for approval (Fall 2008) Provide public outreach Provide public outreach

4. Background Several Attorney General Lawsuits Several Attorney General Lawsuits San Bernardino General Plan – failure to analyze GHGs San Bernardino General Plan – failure to analyze GHGs ConocoPhillips Bay Area Refinery – failure to conclude whether or not GHGs significant ConocoPhillips Bay Area Refinery – failure to conclude whether or not GHGs significant Association of Environmental Professionals White Paper on GHG thresholds Association of Environmental Professionals White Paper on GHG thresholds 8 approaches for handling GHG analyses 8 approaches for handling GHG analyses CAPCOA’s White Paper on Climate Change CAPCOA’s White Paper on Climate Change

5. Background San Joaquin Valley Significance Threshold San Joaquin Valley Significance Threshold Recommended draft threshold established March 2008 Recommended draft threshold established March 2008 GHG threshold = 38,477 MT CO2eq GHG threshold = 38,477 MT CO2eq Based on CAPCOA threshold option 2.4 – Regulated Emissions Inventory Capture Based on CAPCOA threshold option 2.4 – Regulated Emissions Inventory Capture Currently, no plans to formally approve through a public process Currently, no plans to formally approve through a public process

6. Background GHGs under state law GHGs under state law “Air pollutant” includes gases, particulate matter, dust, carbon, etc. “Air pollutant” includes gases, particulate matter, dust, carbon, etc. Districts have primary authority over pollution from non-vehicular sources Districts have primary authority over pollution from non-vehicular sources AB 32 does not “limit or expand” existing authority of districts AB 32 does not “limit or expand” existing authority of districts CARB to adopt rules for “sources” including nonvehicular (AB 32) CARB to adopt rules for “sources” including nonvehicular (AB 32)

7. Considerations in Preparing Significance Thresholds Evaluate direct GHG emissions or life cycle emissions? Evaluate direct GHG emissions or life cycle emissions? Staff recommendation - direct GHG emissions Staff recommendation - direct GHG emissions Life cycle factors not well established for all processes Life cycle factors not well established for all processes Some life cycle processes occur outside CA. Some life cycle processes occur outside CA. CEQA requires analysis of impacts in CA. CEQA requires analysis of impacts in CA. CARB inventory - direct emissions CARB inventory - direct emissions GHG reductions as mitigation - direct emissions GHG reductions as mitigation - direct emissions

8. Considerations in Preparing Significance Thresholds (Cont.) CEQA Guidelines §15064 – Determination of Significance: CEQA Guidelines §15064 – Determination of Significance: Requires careful judgment by public agency involved Requires careful judgment by public agency involved Should be based on scientific & factual data Should be based on scientific & factual data Ironclad definition may not always be possible Ironclad definition may not always be possible May vary with setting May vary with setting CEQA Guidelines §15064.7 – Thresholds of Significance are: CEQA Guidelines §15064.7 – Thresholds of Significance are: Identifiable quantitative performance levels Identifiable quantitative performance levels Identifiable qualitative performance levels Identifiable qualitative performance levels

9. Considerations in Preparing Significance Thresholds (Cont.) If significant, implement feasible mitigation measures to minimize significant impact If significant, implement feasible mitigation measures to minimize significant impact If significant, requires alternatives, which include energy conservation If significant, requires alternatives, which include energy conservation Negative Declaration v. EIR Negative Declaration v. EIR Cumulative v. project specific Cumulative v. project specific

10. Policy Objectives Use GHG thresholds as a means of complying with AB 32 emission reduction goals? Use GHG thresholds as a means of complying with AB 32 emission reduction goals? Use GHG thresholds in parallel with AB 32 to achieve reductions from non-regulated sources? Use GHG thresholds in parallel with AB 32 to achieve reductions from non-regulated sources? Use AB 32 as a guideline in developing significance thresholds? Use AB 32 as a guideline in developing significance thresholds? Prevent or minimize environmental degradation, i.e., do not make impacts worse? Prevent or minimize environmental degradation, i.e., do not make impacts worse?

11. Design Criteria Considerations Resource impacts – costs & staffing Resource impacts – costs & staffing Number of EIRs vs. negative declarations or categorical exemptions Number of EIRs vs. negative declarations or categorical exemptions Administrative burden Administrative burden A single threshold vs. multiple thresholds A single threshold vs. multiple thresholds Short-term (2008 through 2020) vs. long-term (2021 through 2050) considerations Short-term (2008 through 2020) vs. long-term (2021 through 2050) considerations GHG pollutants: 6 Kyoto pollutants to the extent EFs are available (carbon black?) GHG pollutants: 6 Kyoto pollutants to the extent EFs are available (carbon black?) Offsite mitigation considerations – discrete (limited life) vs. stream (infinite life, e.g., ERCs) Offsite mitigation considerations – discrete (limited life) vs. stream (infinite life, e.g., ERCs) Time frame of analysis, impacts vs. mitigation Time frame of analysis, impacts vs. mitigation

12. Future Action/Meeting GHG Working Group Website: http://www.aqmd.gov/ceqa/handbook/GHG/GHG.html GHG Working Group Website: http://www.aqmd.gov/ceqa/handbook/GHG/GHG.html Action Items Action Items Determine meeting schedule Determine meeting schedule Next meeting: May 2008 Next meeting: May 2008 Topics for consideration Topics for consideration CAPCOA White Paper options CAPCOA White Paper options Others? Others?