View
80
Download
0
Category
Tags:
Preview:
DESCRIPTION
CEQA and Climate Change. Evaluating & Addressing GHG Emissions from Projects Barbara Lee, CAPCOA. Air Districts were approached by local governments for help on CEQA & GHG California Air Pollution Control Officers Association coordinated district’s efforts - PowerPoint PPT Presentation
Citation preview
CEQA and Climate Change
Evaluating & Addressing GHG Emissions from Projects
Barbara Lee, CAPCOA
CAPCOA’s Resource Paper
Air Districts were approached by local governments for help on CEQA & GHG
California Air Pollution Control Officers Association coordinated district’s efforts
Resource guide released in January ’08 Intended to provide support for lead agencies
incorporating GHG analysis into CEQA programsNot intended to dictate policy decisionsPlan to provide addendum in 9 - 12 months with
thresholds set, new mitigations, etc.
Overview
Consideration of Fundamental IssuesWhat to do about ThresholdsAnalytical Methods & Tools Mitigation
Fundamental Issues
CEQA Requirement: Public agencies should refrain from approving
projects that have significant adverse environmental impacts if there are feasible alternatives or mitigations that can substantially avoid those impacts
Fair Argument Standard: An EIR must be prepared if it can be fairly argued
(based on substantial evidence in the record) that the project may have a significant environmental impact
More Fundamental Issues
Defensible AnalysesSufficient analysis of environmental consequences to
support informed decisionConclusions supported by substantial evidenceGood faith effort at full disclosure
Statewide ThresholdsOPR to develop GHG mitigation guidance by July ’09,
and Resource Agency to adopt by January ’10ARB could establish statewide approach under AB 32
scoping planInterim Approach
Three Paths Through CEQA
What is Significant?Implementing CEQA with No GHG ThresholdImplementing CEQA with GHG Threshold set at
ZeroImplementing CEQA with a Non-zero Threshold
CEQA with no GHG Threshold
CEQA does not require a lead agency to set a significance threshold
In the absence of a threshold, significance is determined on a case-by-case basis Agency can presume significance (rebutable) Agency can presume insignificance (rebutable) Agency can review each project with no presumption
May create uncertainty for project proponentsMay create workload and resource issues for agency
CEQA with GHG Threshold of Zero
Considers ALL emissions of GHG to be significantAll projects must have EIR or MNDAll emissions must be mitigated to zero or receive
a Statement of Overriding ConsiderationsGreater degree of certainty for project
proponentsCould place substantial workload and resource
burdens on agency and proponents
CEQA with Non-zero Threshold
CAPCOA evaluated two approaches to setting a non-zero threshold:Approach 1- Thresholds based on emission reduction
targets of Statutes and Executive OrdersApproach 2- Tiered thresholds
Other approaches can be used but were not examined in this report
Goal is to maximize environmental benefit while minimizing burden on agencies & proponents
Non-Zero Threshold Approach #1
The Statute & Executive Order Approach would require each project to meet the emission reduction targets of AB 32 and the Governor’s Executive Order.Uniform Percentage for all projectsGreater Percentage for New DevelopmentPercentages by Economic SectorPercentages by Region
Establishing “business as usual” baselineDetermining appropriate percentages
Non-zero Threshold Approach #2
The Tiered Approach would “bin” projects based on established characteristics, with increasing requirements for each bin, or tier
Tier Zero Threshold Quantitative Thresholds Qualitative Thresholds
1Net GHG reduction
= Less than Significant
Emissions below Tier 2 threshold
= Less than significant if Level 1 mitigations applied
Project meets Tier 1 criteria
= Less than significant if Level 1 mitigations applied
2Net GHG increase
mitigated to less than significant
Emissions above Tier 2 threshold
= Less than significant if Level 1 & 2 mitigations applied
Project meets Tier 2 criteria
= Less than significant if Level 1 & 2 mitigations applied
3Net GHG increase
not fully mitigated
Emissions above Tier 3 threshold
= EIR + Level 1, 2 & 3 mitigation
Project meets Tier 3 criteria
= EIR + Level 1, 2 & 3 mitigation
Stepping Through the Analysis
General PlansConsistency with AB 32, or other established
reduction plansProjects
Statutory ExemptionsGreen ListConsistency with PlanTiered Analysis
Analytical Methods & ToolsURBEMIS
Direct Emissions Indirect Emissions
CCAR ProtocolsGeneral Reporting Protocol Specific Protocols (eg., Forestry, Local Government)
Specific Sectors and Source Categories Stationary SourcesWastewater and Solid WasteConstruction
Analytic Scenarios
Existing conditionsAB 32 Baseline = 1990 emissionsBuildout of the Existing General PlanBuildout of the Updated General PlanIncrement between Buildout of the Existing
and Updated General Plans
GHG Mitigation Strategies
Forward Planning: Incorporate GHG reduction strategies into the General Plan Land Use Design- Prioritize Smarter Growth, Connectivity, Compactness,
Diversity, Transportation Facilities, Redevelopment, Jobs-Housing-Balance, and Shipping Mode Shift
Project Level Mitigation: Provide a “toolbox” of strategies to mitigate projects Project Design- Transit, Bike, & Pedestrian support, Alternative Fuel &
Electric Vehicles, Energy & Water Efficiency, Green Building, Landscaping, Low Emission Technologies, and Offsets
GHG Reduction Plan: Implement a specific plan to reduce GHG emissions Establish jurisdictional baseline, reduction targets, deadlines, and
specific mitigation strategies and measures
Mitigation Priorities & Issues
Systemic Design to Avoid EmissionsProject Design to Avoid EmissionsProject Elements that Control EmissionsConcurrent Onsite Actions to Offset EmissionsConcurrent Offsite Actions to Offset EmissionsUse Mitigation FeesUse of Banked Offsets: Real, Permanent,
Quantifiable, Enforceable, Additional
Recommended