Climate Action Plans and CEQA Charlotte Strem Assistant Director, Physical and Environmental Planning University of California Office of the President (510) | Camille Kirk Assistant Director, Environmental Stewardship and Sustainability University of California, Davis (530) |

Issues at hand Why does CEQA have anything to do with CAPs? What does the California Environmental Quality Act (CEQA) require and how does that relate to Climate Action Plans (CAP)? What is the variance between an ACUPCC- compliant CAP and a CEQA-compliant CAP? What is the interplay between a campus’ growth plans and a CAP? What might be some creative mechanisms to address the evolution of the CAP and CEQA?

Quick CEQA Primer CEQA = California Environmental Quality Act Tiering = Using a program environmental analysis document to plan for multiple projects that are in some way connected EIR = Environmental Impact Report Threshold of significance = The level of magnitude beyond which a change to a baseline is considered to have a significant impact which must be mitigated

Why does CEQA have anything to do with CAPs? In a nutshell: AB 32 and the revision of CEQA Guidelines to include GHG emissions as an environmental topic And, tiering – if entities have adopted CEQA Climate Action Plans, they can tier from that analysis.

CEQA Checklist GHG questions Will the project: A) Generate GHG emissions either directly or indirectly that may have a significant impact on the environment? B) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing GHG emissions?

CEQA Section (b)(1) What is required in a CAP for CEQA tiering? A) Quantify GHG emissions both existing and projected for a specified time period resulting from activities in a defined geographic area B) Establish a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by the plan would not be cumulatively considerable C) Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area

CEQA Section (b)(1) What is required in a CAP for CEQA tiering? D) Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by project basis, would collectively achieve the specified emissions level E) Establish a mechanism to monitor the plan’s progress toward achieving the level and to require amendment if the plan is not achieving specified levels F) Be adopted in a public process following environmental review

ACUPCC CAP Final target date and interim milestones for climate neutrality All Scope 1 and 2 emissions, Scope 3 from business air travel and regular commuting Explain how institution intends to: ◦achieve climate neutrality by target date ◦include climate neutrality and sustainability as a part of the curriculum/ educational experience for all students ◦expand research (if applicable), and community engagement Outline mechanisms for tracking progress on goals and actions “The CAP can be viewed as a series of aspirational statements of intent, rather than binding commitments.” (from The ACUPCC Implementation Guide) CEQA Analysis CEQA Guidelines Section Tiering and Streamlining the Analysis of GHG Emissions Certain Scope 1, 2 and 3 emissions Campus-wide GHG analysis and emission reduction versus project-by-project analysis Remember – a “project” as defined by CEQA may be an individual building, or a campus- wide plan

CEQA analysis vs. Climate Action Plan analysis CEQA: baseline is today -Existing + project = future GHG -Mitigate estimated future project GHG Climate Action Plans: baseline is 1990 Interim Goal: 1990 levels by 2020 Ultimate goal: Climate Neutrality -Mitigate existing and estimated future GHG

What might be some creative mechanisms to address the evolution of the CAP and CEQA? UCSF approach – GHG reduction strategy and CAP UC Davis planned approach – CAAP as umbrella