summary of capcoa significance threshold options april 30, 2008 scaqmd diamond bar, california

Summary of CAPCOA Summary of CAPCOA Significance Threshold Significance Threshold

OptionsOptions

April 30, 2008April 30, 2008

SCAQMDSCAQMD

Diamond Bar, CaliforniaDiamond Bar, California

Evaluation of CAPCOA Evaluation of CAPCOA ProposalsProposals

• AQMD staff identified Pros and Cons of AQMD staff identified Pros and Cons of each proposal for discussion purposes, each proposal for discussion purposes, most from CAPCOA White Papermost from CAPCOA White Paper

• Seeking Working Group input:Seeking Working Group input:Additional Pros & ConsAdditional Pros & ConsAny new or modified optionsAny new or modified optionsUse worksheet providedUse worksheet providedShould option be dropped or further Should option be dropped or further

evaluatedevaluated

CAPCOA Proposals - No GHG CAPCOA Proposals - No GHG Significance ThresholdSignificance Threshold

•Pros:Pros: None None•Cons:Cons: - - Cities & counties in the same air Cities & counties in the same air

district could develop a patchwork of GHG district could develop a patchwork of GHG thresholdsthresholdsLack of a GHG threshold does not relieve the Lack of a GHG threshold does not relieve the

lead agency from making a significance lead agency from making a significance determination; could create legal vulnerabilitydetermination; could create legal vulnerability

Significance made on a case-by-case basis, Significance made on a case-by-case basis, resulting in inconsistent policies within or resulting in inconsistent policies within or between agenciesbetween agencies

Lack of GHG threshold could make Lack of GHG threshold could make determining significance more resource determining significance more resource intensive intensive

CAPCOA Proposals - Zero CAPCOA Proposals - Zero Significance ThresholdSignificance Threshold

• Pros:Pros: - Greater GHG emission reductions - Greater GHG emission reductions because mitigation would be required of all because mitigation would be required of all projects with any GHG emission increaseprojects with any GHG emission increase

• Cons:Cons: - - Greater administrative/resources costs Greater administrative/resources costs through preparation of EIRs instead of NDs or NOEsthrough preparation of EIRs instead of NDs or NOEsThere may not be meaningful mitigation for small There may not be meaningful mitigation for small

projectsprojectsAvailable mitigation may consist only of buying Available mitigation may consist only of buying

GHG offsets, which may create EJ concerns GHG offsets, which may create EJ concerns because of associated criteria pollutant emissionsbecause of associated criteria pollutant emissions

Offset creation may not be fully establishedOffset creation may not be fully established

CAPCOA Proposals – Non-zero CAPCOA Proposals – Non-zero Significance Thresholds: Statute/ Significance Thresholds: Statute/

Executive Order ApproachesExecutive Order Approaches

• 1.1: Uniform percentage-based reduction 1.1: Uniform percentage-based reduction from business as usual (BAU) – e.g., 33% from business as usual (BAU) – e.g., 33% based on 2020 target or 80 % based on based on 2020 target or 80 % based on 2050 target2050 targetPros:Pros: Could reduce resource impacts spent Could reduce resource impacts spent

preparing/reviewing environmental analysispreparing/reviewing environmental analysis Achieves GHG reductions in parallel with AB 32Achieves GHG reductions in parallel with AB 32

Single threshold easier to apply to projects & more Single threshold easier to apply to projects & more easily understood by applicants & lead agencieseasily understood by applicants & lead agencies

Cons:Cons: Could be viewed as setting a de minimis levelCould be viewed as setting a de minimis levelFewer projects would trigger significance, therefore, Fewer projects would trigger significance, therefore,

less mitigationless mitigationBAU defined by CARB, may be difficult to define for all BAU defined by CARB, may be difficult to define for all

projectsprojects


Executive Order Approaches Executive Order Approaches (Cont.)(Cont.)

• 1.2: Uniform percentage based reduction 1.2: Uniform percentage based reduction for new development compared to BAUfor new development compared to BAUPros:Pros: same as 1.1 same as 1.1

Would produce greater percentage reductions Would produce greater percentage reductions compared to 1.1compared to 1.1

Single threshold easier to apply to projects & more Single threshold easier to apply to projects & more easily understood by applicants & lead agencieseasily understood by applicants & lead agencies

Cons:Cons: same as 1.1 same as 1.1Would require substantially greater percentage Would require substantially greater percentage

reductions compared to 1.1, which may be difficult to reductions compared to 1.1, which may be difficult to achieveachieve

BAU defined by CARB, may be difficult to define for BAU defined by CARB, may be difficult to define for all projectsall projects


Executive Order Approaches Executive Order Approaches (Cont.)(Cont.)• 1.3: Uniform percentage-based reduction 1.3: Uniform percentage-based reduction

by economic sectorby economic sectorProsPros: : Best regulatory approach for each sectorBest regulatory approach for each sector

Takes into account costs & control technologyTakes into account costs & control technologyAvoids over or under regulation of GHGsAvoids over or under regulation of GHGs

Cons:Cons: Requires extensive information on emission Requires extensive information on emission inventoriesinventoriesRequires extensive information on control Requires extensive information on control

technologiestechnologiesDifficult to determine percent reductions per industryDifficult to determine percent reductions per industryBecause of information requirements, may be more Because of information requirements, may be more

viable in the long termviable in the long term


Executive Order Approaches (Cont.)Executive Order Approaches (Cont.)

• 1.4: Uniform percentage-based 1.4: Uniform percentage-based reduction by regionreduction by region

Pros:Pros: Could tailor GHG reductions to regionCould tailor GHG reductions to region GHG reduction strategies could be GHG reduction strategies could be

integrated with regional GHG reduction integrated with regional GHG reduction plansplans

Cons:Cons: Would need to establish region & Would need to establish region & inventory for the regioninventory for the regionBecause of the need to develop a regional Because of the need to develop a regional

plan, an interim approach may be neededplan, an interim approach may be needed

CAPCOA Proposals – Non-zero CAPCOA Proposals – Non-zero Significance Thresholds: Tiered Significance Thresholds: Tiered

ApproachApproach• 2.1: Decision tree approach, e.g., zero 12.1: Decision tree approach, e.g., zero 1stst

tier, 2tier, 2ndnd tier is quantitative (2.3) tier is quantitative (2.3)Pros:Pros: Allows flexibility by establishing multiple thresholds Allows flexibility by establishing multiple thresholds

to cover a wide range of projectsto cover a wide range of projects22ndnd tier may minimize administrative burden & costs tier may minimize administrative burden & costsTiers could be set at different levels depending on GHG Tiers could be set at different levels depending on GHG

emissions, size, & characteristics of projectsemissions, size, & characteristics of projectsProjects exceeding Tier 2 must implement mitigationProjects exceeding Tier 2 must implement mitigation

Cons:Cons: Tier 1 –Tier 1 – zero threshold, same cons as discussed zero threshold, same cons as discussed under zero threshold overheadunder zero threshold overheadSome Tier 2 applications may need to be included in an Some Tier 2 applications may need to be included in an

approved General Plan or other enforceable mechanismapproved General Plan or other enforceable mechanism


Approach (Cont.)Approach (Cont.)• 2.2: Quantitative threshold based on market 2.2: Quantitative threshold based on market

capture, e.g., 90% of projects (900 MT CO2eq/yr)capture, e.g., 90% of projects (900 MT CO2eq/yr)Pros:Pros: Would capture a much larger percentage of CEQA Would capture a much larger percentage of CEQA

projects (i.e., significant) than currently the case (~42% - 56%)projects (i.e., significant) than currently the case (~42% - 56%) Excludes small projects that have a relatively small Excludes small projects that have a relatively small

contribution to state GHG inventorycontribution to state GHG inventorySingle threshold easier to apply to projects & more easily Single threshold easier to apply to projects & more easily

understood by the public, applicants & lead agenciesunderstood by the public, applicants & lead agenciesCons:Cons: Greater administrative & cost burden, especially on Greater administrative & cost burden, especially on

larger projects & projects in developing & moderate growth areaslarger projects & projects in developing & moderate growth areasMay not be amenable to industrial projects because of the May not be amenable to industrial projects because of the

diversity of these types of projectsdiversity of these types of projectsOn-site mitigation opportunities may be limitedOn-site mitigation opportunities may be limited


Approach (Cont.)Approach (Cont.)• 2.3: CARB reporting threshold 25,000 2.3: CARB reporting threshold 25,000

MT CO2eq/year (or 10,000 MT MT CO2eq/year (or 10,000 MT CO2eq/year - Market Advisory Group)CO2eq/year - Market Advisory Group)Pros:Pros: CARB estimates this would capture 90 % of CARB estimates this would capture 90 % of

all industrial projects (i.e., significant)all industrial projects (i.e., significant)Single threshold easier to apply to projects & Single threshold easier to apply to projects &

more easily understood by applicants & lead more easily understood by applicants & lead agenciesagencies

Cons:Cons: May not be amenable to industrial projects May not be amenable to industrial projects because of the diversity of these types of projectsbecause of the diversity of these types of projectsOn-site mitigation opportunities may be limitedOn-site mitigation opportunities may be limited


Approach (Cont.)Approach (Cont.)• 2.4: Regulated emissions inventory capture 2.4: Regulated emissions inventory capture

– based on ratio of criteria pollutant – based on ratio of criteria pollutant significance threshold to inventory for that significance threshold to inventory for that pollutantpollutantPros:Pros: Single threshold easier to apply to projects Single threshold easier to apply to projects

& more easily understood by applicants & lead & more easily understood by applicants & lead agenciesagencies

Cons:Cons: Threshold is cumbersome to deriveThreshold is cumbersome to deriveThreshold would change regularly as inventory Threshold would change regularly as inventory

emissions go up or downemissions go up or downCould have widely divergent thresholds by air basin Could have widely divergent thresholds by air basin

because agency thresholds and inventories varybecause agency thresholds and inventories vary


Approach (Cont.)Approach (Cont.)

• 2.5: Unit-based thresholds based on 2.5: Unit-based thresholds based on market capture – similar to 2.2, but market capture – similar to 2.2, but based on sector, e.g., 90 % of based on sector, e.g., 90 % of residential, industrial, commercial, residential, industrial, commercial, etc.etc.Pros:Pros: Same as 2.2Same as 2.2

Cons:Cons: Same as 2.2Same as 2.2



• 2.6: Projects of statewide, regional, 2.6: Projects of statewide, regional, or areawide significance [§15206(b)]or areawide significance [§15206(b)]Pros:Pros: Would provide consistency Would provide consistency

throughout Californiathroughout CaliforniaWould capture approximately ½ of future Would capture approximately ½ of future

residential developmentresidential developmentCons:Cons: Would capture substantially less than Would capture substantially less than

½ future commercial development, therefore, ½ future commercial development, therefore, less mitigationless mitigationPercentage capture of Percentage capture of

industrial/manufacturing projects unknownindustrial/manufacturing projects unknown



• 2.7: Efficiency-based thresholds – GHG 2.7: Efficiency-based thresholds – GHG emissions per unit of efficiencyemissions per unit of efficiencyPros:Pros: Would benchmark GHG intensity against Would benchmark GHG intensity against

target levels of efficiencytarget levels of efficiencyThresholds established to provide future Thresholds established to provide future

foreseeable GHG reductions compared to BAUforeseeable GHG reductions compared to BAUWould support AB 32 goalsWould support AB 32 goals

Cons:Cons: Would require substantial data & Would require substantial data & modelingmodelingMay be more appropriate as a long-term May be more appropriate as a long-term

thresholdthreshold

Other ProposalsOther Proposals

• Correlate GHG threshold with Correlate GHG threshold with established criteria pollutant established criteria pollutant significance thresholdssignificance thresholdsPros:Pros: Would capture approximately the same Would capture approximately the same

number of projects as is currently the casenumber of projects as is currently the caseCons:Cons: Could have widely divergent thresholds Could have widely divergent thresholds

by air basin because agency thresholds varyby air basin because agency thresholds varyFewer projects would trigger significance, Fewer projects would trigger significance,

therefore, less mitigationtherefore, less mitigation

Other ProposalsOther Proposals

• Efficiency must exceed by some Efficiency must exceed by some percent, any established efficiency percent, any established efficiency standardsstandardsPros:Pros: Same as 2.7Same as 2.7

Would capture greater number of projects Would capture greater number of projects than 2.7than 2.7

Cons:Cons: Same as 2.7Same as 2.7Would rely on established efficiency standards Would rely on established efficiency standards

that may not be available in the short-termthat may not be available in the short-term

Recommendations Received Recommendations Received from Stakeholdersfrom Stakeholders

• County Sanitation Districts L.A. CountyCounty Sanitation Districts L.A. CountyNeed to develop mitigation measures concurrently Need to develop mitigation measures concurrently

with significance thresholdwith significance thresholdReject no threshold optionReject no threshold optionReject zero threshold optionReject zero threshold optionThreshold should not be used to comply with AB 32Threshold should not be used to comply with AB 32Should harmonize thresholds with other Should harmonize thresholds with other

jurisdictionsjurisdictionsRecommends against using life cycle analysisRecommends against using life cycle analysisMandated GHG emission reductions should not be Mandated GHG emission reductions should not be

required until a regional credit market is required until a regional credit market is establishedestablished

Recommendations Received Recommendations Received from Stakeholdersfrom Stakeholders

• Center for Biological DiversityCenter for Biological DiversityRecommends a zero threshold orRecommends a zero threshold orRecommends a threshold that captures Recommends a threshold that captures

90% of future discretionary projects 90% of future discretionary projects (900 MT CO2eq/year)(900 MT CO2eq/year)

Concerns regarding increased Concerns regarding increased preparation of EIRs can be addressed preparation of EIRs can be addressed with implementation of a mitigation fee with implementation of a mitigation fee & offset program& offset program

summary of capcoa significance threshold options april 30, 2008 scaqmd diamond bar, california

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