Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group April 30, 2008 SCAQMD 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 Background • 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 Background • 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 Background • 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 emissions? • Staff recommendation - direct GHG emissions !Life cycle factors not well established for all processes !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 Significance: ! 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 exemptions • 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: http://www.aqmd.gov/ceqa/handbook/GHG/GHG.html • Action Items • Determine meeting schedule • Next meeting: May 2008 • Topics for consideration ! CAPCOA White Paper options ! Others?