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Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group

This working group aims to establish a greenhouse gas (GHG) significance threshold to analyze and mitigate the impacts of GHGs in the Diamond Bar, California area. The group will coordinate efforts with stakeholders, hold public workshops, and present the threshold to the governing board for approval.

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Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group

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  1. Greenhouse Gas CEQA Significance Threshold Stakeholder Working Group April 30, 2008 SCAQMD Diamond Bar, California

  2. 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

  3. 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

  4. 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

  5. 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

  6. 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)

  7. 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

  8. 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

  9. 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

  10. 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?

  11. 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

  12. 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?

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