Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group #4 July 30, 2008 SCAQMD Diamond Bar, California

Further Discussion of Significance Screening Level Initial proposal based on URBEMIS modeling results of one mixed use project where NOx emission = 55 #/D or 10 T/yr Initial proposal based on URBEMIS modeling results of one mixed use project where NOx emission = 55 #/D or 10 T/yr Staff modeled 19 additional hypothetic projects using URBEMIS: Staff modeled 19 additional hypothetic projects using URBEMIS: Residential only: single or multi-family Residential only: single or multi-family Commercial only: office or bank Commercial only: office or bank Industrial only: general light industry or manufacturing Industrial only: general light industry or manufacturing Mixed use: single & multi-family Mixed use: single & multi-family Mixed use: office & bank Mixed use: office & bank Mixed use: light industry & manufacturing Mixed use: light industry & manufacturing

Further Discussion of Significance Screening Level Staff modeled 19 additional hypothetic projects continued: Staff modeled 19 additional hypothetic projects continued: Mixed use: single family residence & office Mixed use: single family residence & office Mixed use: multi-family residential & office Mixed use: multi-family residential & office Mixed use: single family residence & bank Mixed use: single family residence & bank Mixed use: multi-family residential & bank Mixed use: multi-family residential & bank Mixed use: single & multi-family residential & office Mixed use: single & multi-family residential & office Mixed use: single & multi-family residential & bank Mixed use: single & multi-family residential & bank Mixed use: office & light industry Mixed use: office & light industry Mixed use: office & manufacturing Mixed use: office & manufacturing Mixed use: bank & light industry Mixed use: bank & light industry Mixed use: bank & manufacturing Mixed use: bank & manufacturing

Further Discussion of Significance Screening Level Results: Results: All modeling based on NOx emissions = 55 #/D or 10 T/yr & included area sources All modeling based on NOx emissions = 55 #/D or 10 T/yr & included area sources Used weighted average trip rate, weekday, Sat. & Sun. Used weighted average trip rate, weekday, Sat. & Sun. GHG emissions ranged from 7,304 to 7,723 MTCO2eq./yr GHG emissions ranged from 7,304 to 7,723 MTCO2eq./yr Average GHG emissions from URBEMIS modeling runs = 7,559 MTCO2.eq/yr Average GHG emissions from URBEMIS modeling runs = 7,559 MTCO2.eq/yr Average emission results are 16% greater than proposed significance screening level Average emission results are 16% greater than proposed significance screening level Provides a safety margin for conversion from maximum daily NOx threshold to annual emissions (10 tons) Provides a safety margin for conversion from maximum daily NOx threshold to annual emissions (10 tons) May result in more MNDs &, in some cases, EIRs being prepared May result in more MNDs &, in some cases, EIRs being prepared

Further Discussion of Significance Screening Level Staff modeled 13 Actual ND/MND projects using URBEMIS: Staff modeled 13 Actual ND/MND projects using URBEMIS: All modeling based on NOx emissions < 55 #/D or 10 T/yr All modeling based on NOx emissions < 55 #/D or 10 T/yr Land uses included single & multi-family residential, office, restaurant, elementary school, retail (strip mall), & industrial (waste recovery) Land uses included single & multi-family residential, office, restaurant, elementary school, retail (strip mall), & industrial (waste recovery) GHG emissions ranged from 348 to 5,081 MTCO2eq./yr GHG emissions ranged from 348 to 5,081 MTCO2eq./yr Average GHG emissions from URBEMIS modeling runs = 1,574 MTCO2.eq/yr Average GHG emissions from URBEMIS modeling runs = 1,574 MTCO2.eq/yr Preliminary results indicate NDs or MNDs for typical projects would be less than proposed significance screening level Preliminary results indicate NDs or MNDs for typical projects would be less than proposed significance screening level

Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting Carbon neutral fuels, e.g., landfill/digester gas, should not be included in significance determination as they are “automatically ‘netted- out’” Carbon neutral fuels, e.g., landfill/digester gas, should not be included in significance determination as they are “automatically ‘netted- out’” Need to devote more time to developing GHG mitigation measures Need to devote more time to developing GHG mitigation measures Performance-based thresholds are preferable over numerical thresholds Performance-based thresholds are preferable over numerical thresholds Construction emissions should be amortized over lifetime of the project Construction emissions should be amortized over lifetime of the project

Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Failure to mitigate GHG emissions should not trigger EIR Failure to mitigate GHG emissions should not trigger EIR Projects with statewide benefits, e.g., refinery projects to produce clean fuels, should be treated differently Projects with statewide benefits, e.g., refinery projects to produce clean fuels, should be treated differently Significance threshold should not be less than CARB’s reporting threshold, i.e., 25,000 MTCO2eq./year, otherwise could result in cancellation of projects Significance threshold should not be less than CARB’s reporting threshold, i.e., 25,000 MTCO2eq./year, otherwise could result in cancellation of projects Project should not be considered significant if it meets applicable standards promulgated by CARB Project should not be considered significant if it meets applicable standards promulgated by CARB

Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Costly mitigation of desirable energy efficiency features could result in cancellation of projects Costly mitigation of desirable energy efficiency features could result in cancellation of projects Baseline should not consist of 1990 target inventories, but existing physical conditions per CEQA Guidelines §15125 Baseline should not consist of 1990 target inventories, but existing physical conditions per CEQA Guidelines §15125 Mitigation should focus on incremental emissions increase above the baseline Mitigation should focus on incremental emissions increase above the baseline Any significance thresholds should be consistent with CEQA precedent Any significance thresholds should be consistent with CEQA precedent Zero threshold not consistent with CEQA precedent Zero threshold not consistent with CEQA precedent Numeric threshold can’t be scientifically supported Numeric threshold can’t be scientifically supported Set a qualitative threshold base on design features, mitigation to improve energy efficiency, or comply with AB 32 Set a qualitative threshold base on design features, mitigation to improve energy efficiency, or comply with AB 32 Should use caution when using existing methodologies to evaluate climate change, e.g., trip rates from ITE use maximum daily trip rates Should use caution when using existing methodologies to evaluate climate change, e.g., trip rates from ITE use maximum daily trip rates

Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Should add additional options to tier 4 Should add additional options to tier 4 Option #4: Project results in net energy efficiency Option #4: Project results in net energy efficiency Project meets applicable standards promulgated by CARB, air districts, or agencies/commissions Project meets applicable standards promulgated by CARB, air districts, or agencies/commissions Regardless of project life, construction emissions should not be offset Regardless of project life, construction emissions should not be offset Significance threshold should be based on 2050 emission reduction targets Significance threshold should be based on 2050 emission reduction targets Existing set of exemptions should be retained Existing set of exemptions should be retained Analysis is needed to support a finding of no further action for categorically exempt projects Analysis is needed to support a finding of no further action for categorically exempt projects

Comments on Revised Staff Proposal #1 from the June 19, 2008 Stakeholder Meeting (Cont.) Compliance with GHG reduction plan should be its own tier Compliance with GHG reduction plan should be its own tier There is a large disconnect between significance screening level & remaining emissions under the Tier 4 compliance options There is a large disconnect between significance screening level & remaining emissions under the Tier 4 compliance options Compliance with a target objective should not be through offsets alone Compliance with a target objective should not be through offsets alone Reductions from BAU is not the proper metric for determining significance Reductions from BAU is not the proper metric for determining significance Emission reductions from BAU could penalize projects in environmentally progressive areas Emission reductions from BAU could penalize projects in environmentally progressive areas

Discussion Other comments or discussion on the revised staff proposal? Other comments or discussion on the revised staff proposal? Where do we go from here? Where do we go from here?