Greenhouse Gas Threshold Options for Ventura County

November 8, 2011

Why?

• California Environmental Quality Act• SB 97 (Dutton)• Consistency • Lead agencies looking to air districts for

guidance

What are the Options?

Three Basic Approaches

• No Threshold– Permitted by CEQA– Still must evaluate GHG emissions– Large number of projects requiring EIRs– More CEQA challenges

Three Basic Approaches (cont.)

• Zero Threshold– Any net increase in GHG emissions significant– Projects may require EIRs for GHG emissions only– More CEQA challenges

Three Basic Approaches (cont.)

• Non-Zero Threshold– Above certain level = significant– Common approach for other air pollutants– Would establish that very small projects do not

contribute substantially to the global GHG load– Would allow approval of small projects without

need for EIRs or mitigation– Would reduce environmental analyses

Non-Zero Threshold Approaches

• Statute and Executive Order Approach– AB 32 & EO S-3-05 objectives– Four options

• Tiered Approach– Layered significance cut points– Seven CAPCOA & three other options

Applicable exemptions

GHG emissions less than one or more significance thresholds adopted by lead agency

GHG emissions consistent with approved local or regional GHG plan or comparable document

No Further Action

Less Than Significant Impact

Significant Impact

No

No

No

Yes

Yes

Yes

Conceptual Tiered Approach

What Options are Air Districts Considering?

• Tiered Approach– GHG Reduction Plan– Efficiency – Bright Line Gap– Quantitative Market Capture– Best Performance Standards– Criteria Pollutant

Options

• GHG Reduction Plan– A General Plan or Area Plan consistent with AB 32

reduction goals• Efficiency

– Project GHG emissions/service population (SP)• Project Level ≈ 4.6 MT CO2e/SP

• Plan Level ≈ 6.6 MT CO2e/SP

Another Option

• Bright Line Gap

More Options

• Quantitative Market Capture– Numeric bright line threshold set to capture 90%

of GHG emissions• Residential ≈ 900 MT CO2e/yr (33% projects)

• Commercial ≈ 1,000 MT CO2e/yr (46% projects)

• Best Performance Standards– Most effective means of reducing GHG emissions

Final Option (for now…)

• Criteria Pollutant– Correlated to District’s criteria pollutant threshold

• Residential - 207 du (3,495 MT CO2e/yr)

• General Office - 233, 470 sq ft (3,628 MT CO2e/yr)

• Shopping Center - 67,640 sq ft (2,528 MT CO2e/yr)

Who’s Doing What?

What Are Staff’s Thoughts?

• Regional consistency is desirable• Tiered approach with simple bright line

thresholds is desirable• Proceed with developing Interim Thresholds

– May revise based on South Coast AQMD thresholds

Done Yet?

• Yes!– Questions?– Comments?