CEQA Requirements for Greenhouse Gas Analysis September 2009
In This Issue
Greenhouse Gases and CEQA
Yoga for Desk Jockeys
Who is Douglas Herring & Associates?
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

Expected revisions to CEQA GuidelinesFor 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: 
  • when to quantify emissions;
  • setting GHG significance thresholds for a project: who is responsible; and
  • clarifying the basic requirements of an analysis.

Feel good at work. 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]
Red Peak Pass

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)

The proposed 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: 


  • 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 decisiTop of Red Peak Pass-2on 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.
  • 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 reduction plans.  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
  • 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.

DHA staff has prepared quantitative greenhouse gas analyses (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.

Chair Pose Yoga for Desk Jockeys 

by Barbara Kaplan
Chair 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 amendments. Learn more on our website:  Douglas Herring & Associates.
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