Greenhouse Gas CEQA Significance by pengxiang


									  Greenhouse Gas CEQA
  Significance Threshold
Stakeholder Working Group

        April 30, 2008
    Diamond Bar, California
   Goals of the Working Group
• Establish GHG significance threshold
  !Policy considerations – purpose of GHG
   significance threshold
  !Design considerations
• Achieve consensus to the extent possible
  from the stakeholder working group
• Approval from SCAQMD Governing Board
• Advocate for GHG significance threshold
           Process and Schedule
• Establish monthly working group meetings
• Discuss feasible significance thresholds;
    eliminate infeasible significance thresholds
•   Coordinate efforts with other air agencies, e.g.
    BAAQMD, CARB, etc.
•   Establish recommended significance threshold
•   Conduct Public Workshop (Summer 2008)
•   Take significance threshold to Governing Board
    for approval (Fall 2008)
•   Provide public outreach
• Several Attorney General Lawsuits
  ! San Bernardino General Plan – failure to
   analyze GHGs
  ! ConocoPhillips Bay Area Refinery – failure to
   conclude whether or not GHGs significant
• Association of Environmental Professionals
 White Paper on GHG thresholds
  !8 approaches for handling GHG analyses
• CAPCOA’s White Paper on Climate Change

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

• GHGs under state law
  !“Air pollutant” includes gases, particulate
   matter, dust, carbon, etc.
  !Districts have primary authority over pollution
   from non-vehicular sources
  !AB 32 does not “limit or expand” existing
   authority of districts
  !CARB to adopt rules for “sources” including
   nonvehicular (AB 32)
    Considerations in Preparing
      Significance Thresholds
• Evaluate direct GHG emissions or life cycle
• Staff recommendation - direct GHG
  !Life cycle factors not well established for all
  !Some life cycle processes occur outside CA.
  !CEQA requires analysis of impacts in CA.
  !CARB inventory - direct emissions
  !GHG reductions as mitigation - direct emissions
    Considerations in Preparing
  Significance Thresholds (Cont.)
• CEQA Guidelines §15064 – Determination of
  ! Requires careful judgment by public agency involved
  ! Should be based on scientific & factual data
  ! Ironclad definition may not always be possible
  ! May vary with setting
• CEQA Guidelines §15064.7 – Thresholds of
  Significance are:
  ! Identifiable quantitative performance levels
  ! Identifiable qualitative performance levels
   Considerations in Preparing
 Significance Thresholds (Cont.)

• If significant, implement feasible mitigation
  measures to minimize significant impact
• If significant, requires alternatives, which
  include energy conservation
• Negative Declaration v. EIR
• Cumulative v. project specific
             Policy Objectives
• 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 AB 32 as a guideline in developing
    significance thresholds?
•   Prevent or minimize environmental degradation,
    i.e., do not make impacts worse?
    Design Criteria Considerations
• Resource impacts – costs & staffing
    ! Number of EIRs vs. negative declarations or categorical
•   Administrative burden
•   A single threshold vs. multiple thresholds
•   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?)
•   Offsite mitigation considerations – discrete (limited life)
    vs. stream (infinite life, e.g., ERCs)
•   Time frame of analysis, impacts vs. mitigation
        Future Action/Meeting

• GHG Working Group Website:
• Action Items
• Determine meeting schedule
• Next meeting: May 2008
• Topics for consideration
  ! CAPCOA White Paper options
  ! Others?

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