2013-050 - Addendum to the Final Environment Imapct Report No. 2006-01

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general and industry- specific protocols for assessing and reporting GHG emissions have been developed. GHG sources are categorized into direct sources (i.e. company owned) and indirect sources (i.e. not company owned). Direct sources include combustion emissions from on -and off -road mobile sources, and fugitive emissions. Indirect sources include off -site electricity generation and non - company owned mobile sources. Greenhouse Gas Emissions Significance Thresholds In response to the requirements of S1397, the State Resources Agency developed guidelines for the treatment of GHG emissions under CEQA. These new guidelines became state laws as part of Title 14 of the California Code of Regulations in March, 2010. The CEQA Appendix G guidelines were modified to include GHG as a required analysis element. A project would have a potentially significant impact if it: • Generates GHG emissions, directly or indirectly, that may have a significant impact on the environment, or, • Conflicts with an applicable plan, policy or regulation adopted to reduce GHG emissions. Section 15064.4 of the Code specifies how significance of GHG emissions is to be evaluated. The process is broken down into quantification of project - related GHG emissions, making a determination of significance, and specification of any appropriate mitigation if impacts are found to be potentially significant. At each of these steps, the new GHG guidelines afford the lead agency with substantial flexibility. Emissions identification may be quantitative, qualitative or based on performance standards. CEQA guidelines allow the lead agency to "select the model or methodology it considers most appropriate." The most common practice for transportation/combustion GHG emissions quantification is to use a computer model such as CalEEMod, as was used in the ensuing analysis. The significance of those emissions then must be evaluated; the selection of a threshold of significance must take into consideration what level of GHG emissions would be cumulatively considerable. The guidelines are clear that they do not support a zero net emissions threshold. If the lead agency does not have sufficient expertise in evaluating GHG impacts, it may rely on thresholds adopted by an agency with greater expertise. On December 5, 2008 the SCAQMD Governing Board adopted an Interim quantitative GHG Significance Threshold for industrial projects where the SCAQMD is the lead agency (e.g., stationary source permit projects, rules, plans, etc.) of 10,000 Metric Tons (MT) COZ equivalentlyear. In September 2010, the Working Group released revisions which recommended a threshold of 3,500 MT COze for residential projects. This 3,500 MT /year recommendation has been used as a guideline for this analysis. Some jurisdictions have adopted a numerical annual GHG emissions level as a CEQA threshold of significance. Others have taken the numerical threshold to be an indicator level that signals a requirement for incorporating reasonable and feasible enhanced "greed' building practices without formal adoption of an absolute significance standard. Ium a rs, AQ .H-