CEQA Requirements for Greenhouse Gas Analysis
Expected revisions to CEQA Guidelines.
Having recently spent eight days backpacking in and breathing the pure mountain air of Yosemite's backcountry, the importance of protecting our air quality was driven home in a very personal way.
With recent legislation requiring significant Statewide reductions in the emissions of greenhouse gases (GHG), the burden for achieving these improvements in air quality will fall on cities, counties, and individual development projects
For this issue of our periodic eAlerts, one of our expert air quality and noise associates, Paul Miller, synopsizes the anticipated revisions to the California Environmental Quality Act (CEQA Guidelines
) in response to the GHG legislation, covering:
Feel good at work.
- when to quantify emissions;
- setting GHG significance thresholds for a project: who is responsible; and
- clarifying the basic requirements of an analysis.
To help you keep you alert
after long hours in your chair, we hope you enjoy our 'pose of the month' from
our feature, "Yoga for Desk Jockeys."
Let us know if you need our expertise in evaluating GHG impacts or developing long-term strategies for the reduction of GHG, or if there's anything else we can do to help lighten your work load.
Doug Herring, AICP
[All photos Copyright 2009 by Douglas Herring]
Greenhouse Gases and CEQA
California will soon adopt
amendments to the CEQA Guidelines that address consideration of greenhouse gas emissions in CEQA
documents. The final step in the
rulemaking process began July 3, 2009 with the release of the proposed amendments.
Periodic updates on the status of this process will be posted
at the following website: California Environmental Resources Evaluation System (CERES)
amendments are consistent with CEQA practice, leaving considerable discretion in the matter to the CEQA Lead Agency. Important matters such as determining
when to quantify emissions and setting GHG significance thresholds for a
project are now the responsibility of the Lead Agency.
The proposed amendments
have helped to clarify the basic requirements of an analysis, which are
described in proposed CEQA Guidelines Section 15064.4. The new
section, which can be read in its entirety by following this link: CERES, addresses
the following main points:
THE PROPOSED AMENDMENTS
- A lead agency should make a
good-faith effort, based on available information, to describe, calculate or
estimate the amount of greenhouse gas emissions resulting from a project. It is up to the discretion of the lead
agency to determine whether to use a model or other methodology to quantify
greenhouse gas emissions resulting from a project, and which model or
methodology to use. The lead agency must support its decision on the most
appropriate means to evaluate GHG with substantial evidence. The lead agency may
also use performance-based standards.
- When assessing the
significance of project impacts from GHG emissions on the environment, a lead
agency may consider whether the emissions exceed a threshold of significance
that the lead agency determines applies to the project.
- The lead agency may also
evaluate the extent to which the project complies with regulations or
requirements adopted to implement a Statewide, regional, or local plan for the
reduction or mitigation of greenhouse gas emissions. Such regulations or requirements must be adopted by the
relevant public agency following a public review process, and must include
specific strategies for reducing the incremental contribution of greenhouse gas
emissions from individual projects.
CHANGE IN PROGRAM-LEVEL ANALYSES
- If there is substantial
evidence that the possible effects of a particular project would still be cumulatively
considerable, notwithstanding compliance with the adopted regulations or
requirements, an EIR must be prepared for the project.
Another major issue addressed in a proposed new section of the CEQA Guidelines
is the encouragement of program-level analyses of GHG
emissions in documents such as General Plans or greenhouse gas emissions
. Proposed Section
15183.5 states that a greenhouse gas emissions
reduction plan may:
- Quantify greenhouse gas
emissions, both existing and projected over a specified time period, resulting
from activities within a defined geographic area; and
DHA staff has prepared quantitative greenhouse
- 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.
(for construction and operations) for Mitigated Negative Declarations
and EIRs using techniques consistent with the proposed CEQA Guidelines
amendments - including use of air quality
models that are recommended by the California Attorney General's office. If you need assistance on any of these
matters, we are standing by to help.
| Yoga for Desk Jockeys
by Barbara KaplanChair Pose
- Strengthen your quadriceps and help your knees by taking a Chair Sit at a wall. Have your back and pelvis against the wall and walk your feet away, bending your knees and sliding down the wall to create as close to a right angle with your legs as you can. Check and see that your knees are hip-distance apart, with the two knees bent right over the ankles. You can work towards the thighs becoming parallel to the floor. Relax your shoulders. Breathe, and work to eventually holding the strengthening pose for one minute.
Barbara Kaplan runs the Harmony Yoga Studio in El Cerrito, California. She leads yoga trips to exotic locations such as Mexico, Burma, Peru, and Hawaii. She is leading a trip to Nepal in October 2010. Learn more at Harmony Yoga Studio.
|Who Is Douglas Herring & Associates?
Douglas Herring & Associates (DHA) works with public agencies, developers, and other businesses
in California to expertly obtain the environmental and planning approvals needed to move projects from the conceptual stage to physical, benefit-generating reality in an efficient and cost-effective manner. Since 1997, DHA has helped dozens of California cities and counties and scores of other businesses and organizations save money while obtaining high-quality planning and environmental analysis services necessary to get their projects expeditiously approved and built. DHA can prepare
quantitative greenhouse gas analyses consistent
with the proposed CEQA Guidelines
Learn more on our website: Douglas Herring & Associates
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