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Summary of CAPCOA Significance Threshold Options

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Lack of GHG threshold could make determining significance more resource intensive ... Pros: Could tailor GHG reductions to region ... – PowerPoint PPT presentation

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Title: Summary of CAPCOA Significance Threshold Options


1
Summary of CAPCOA Significance Threshold Options
  • April 30, 2008
  • SCAQMD
  • Diamond Bar, California

2
Evaluation of CAPCOA Proposals
  • AQMD staff identified Pros and Cons of each
    proposal for discussion purposes, most from
    CAPCOA White Paper
  • Seeking Working Group input
  • Additional Pros Cons
  • Any new or modified options
  • Use worksheet provided
  • Should option be dropped or further evaluated

3
CAPCOA Proposals - No GHG Significance Threshold
  • Pros None
  • Cons - Cities counties in the same air
    district could develop a patchwork of GHG
    thresholds
  • Lack of a GHG threshold does not relieve the lead
    agency from making a significance determination
    could create legal vulnerability
  • Significance made on a case-by-case basis,
    resulting in inconsistent policies within or
    between agencies
  • Lack of GHG threshold could make determining
    significance more resource intensive

4
CAPCOA Proposals - Zero Significance Threshold
  • Pros - Greater GHG emission reductions because
    mitigation would be required of all projects with
    any GHG emission increase
  • Cons - Greater administrative/resources costs
    through preparation of EIRs instead of NDs or
    NOEs
  • There may not be meaningful mitigation for small
    projects
  • Available mitigation may consist only of buying
    GHG offsets, which may create EJ concerns because
    of associated criteria pollutant emissions
  • Offset creation may not be fully established

5
CAPCOA Proposals Non-zero Significance
Thresholds Statute/ Executive Order Approaches
  • 1.1 Uniform percentage-based reduction from
    business as usual (BAU) e.g., 33 based on 2020
    target or 80 based on 2050 target
  • Pros Could reduce resource impacts spent
    preparing/reviewing environmental analysis
  • Achieves GHG reductions in parallel with AB 32
  • Single threshold easier to apply to projects
    more easily understood by applicants lead
    agencies
  • Cons Could be viewed as setting a de minimis
    level
  • Fewer projects would trigger significance,
    therefore, less mitigation
  • BAU defined by CARB, may be difficult to define
    for all projects

6
CAPCOA Proposals Non-zero Significance
Thresholds Statute/ Executive Order Approaches
(Cont.)
  • 1.2 Uniform percentage based reduction for new
    development compared to BAU
  • Pros same as 1.1
  • Would produce greater percentage reductions
    compared to 1.1
  • Single threshold easier to apply to projects
    more easily understood by applicants lead
    agencies
  • Cons same as 1.1
  • Would require substantially greater percentage
    reductions compared to 1.1, which may be
    difficult to achieve
  • BAU defined by CARB, may be difficult to define
    for all projects

7
CAPCOA Proposals Non-zero Significance
Thresholds Statute/ Executive Order Approaches
(Cont.)
  • 1.3 Uniform percentage-based reduction by
    economic sector
  • Pros Best regulatory approach for each sector
  • Takes into account costs control technology
  • Avoids over or under regulation of GHGs
  • Cons Requires extensive information on emission
    inventories
  • Requires extensive information on control
    technologies
  • Difficult to determine percent reductions per
    industry
  • Because of information requirements, may be more
    viable in the long term

8
CAPCOA Proposals Non-zero Significance
Thresholds Statute/ Executive Order Approaches
(Cont.)
  • 1.4 Uniform percentage-based reduction by region
  • Pros Could tailor GHG reductions to region
  • GHG reduction strategies could be integrated
    with regional GHG reduction plans
  • Cons Would need to establish region inventory
    for the region
  • Because of the need to develop a regional plan,
    an interim approach may be needed

9
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach
  • 2.1 Decision tree approach, e.g., zero 1st tier,
    2nd tier is quantitative (2.3)
  • Pros Allows flexibility by establishing multiple
    thresholds to cover a wide range of projects
  • 2nd tier may minimize administrative burden
    costs
  • Tiers could be set at different levels depending
    on GHG emissions, size, characteristics of
    projects
  • Projects exceeding Tier 2 must implement
    mitigation
  • Cons Tier 1 zero threshold, same cons as
    discussed under zero threshold overhead
  • Some Tier 2 applications may need to be included
    in an approved General Plan or other enforceable
    mechanism

10
(No Transcript)
11
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.2 Quantitative threshold based on market
    capture, e.g., 90 of projects (900 MT CO2eq/yr)
  • Pros Would capture a much larger percentage of
    CEQA projects (i.e., significant) than currently
    the case (42 - 56)
  • Excludes small projects that have a relatively
    small contribution to state GHG inventory
  • Single threshold easier to apply to projects
    more easily understood by the public, applicants
    lead agencies
  • Cons Greater administrative cost burden,
    especially on larger projects projects in
    developing moderate growth areas
  • May not be amenable to industrial projects
    because of the diversity of these types of
    projects
  • On-site mitigation opportunities may be limited

12
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.3 CARB reporting threshold 25,000 MT
    CO2eq/year (or 10,000 MT CO2eq/year - Market
    Advisory Group)
  • Pros CARB estimates this would capture 90 of
    all industrial projects (i.e., significant)
  • Single threshold easier to apply to projects
    more easily understood by applicants lead
    agencies
  • Cons May not be amenable to industrial projects
    because of the diversity of these types of
    projects
  • On-site mitigation opportunities may be limited

13
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.4 Regulated emissions inventory capture
    based on ratio of criteria pollutant significance
    threshold to inventory for that pollutant
  • Pros Single threshold easier to apply to
    projects more easily understood by applicants
    lead agencies
  • Cons Threshold is cumbersome to derive
  • Threshold would change regularly as inventory
    emissions go up or down
  • Could have widely divergent thresholds by air
    basin because agency thresholds and inventories
    vary

14
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.5 Unit-based thresholds based on market
    capture similar to 2.2, but based on sector,
    e.g., 90 of residential, industrial,
    commercial, etc.
  • Pros Same as 2.2
  • Cons Same as 2.2

15
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.6 Projects of statewide, regional, or areawide
    significance 15206(b)
  • Pros Would provide consistency throughout
    California
  • Would capture approximately ½ of future
    residential development
  • Cons Would capture substantially less than ½
    future commercial development, therefore, less
    mitigation
  • Percentage capture of industrial/manufacturing
    projects unknown

16
CAPCOA Proposals Non-zero Significance
Thresholds Tiered Approach (Cont.)
  • 2.7 Efficiency-based thresholds GHG emissions
    per unit of efficiency
  • Pros Would benchmark GHG intensity against
    target levels of efficiency
  • Thresholds established to provide future
    foreseeable GHG reductions compared to BAU
  • Would support AB 32 goals
  • Cons Would require substantial data modeling
  • May be more appropriate as a long-term threshold

17
Other Proposals
  • Correlate GHG threshold with established criteria
    pollutant significance thresholds
  • Pros Would capture approximately the same number
    of projects as is currently the case
  • Cons Could have widely divergent thresholds by
    air basin because agency thresholds vary
  • Fewer projects would trigger significance,
    therefore, less mitigation

18
Other Proposals
  • Efficiency must exceed by some percent, any
    established efficiency standards
  • Pros Same as 2.7
  • Would capture greater number of projects than 2.7
  • Cons Same as 2.7
  • Would rely on established efficiency standards
    that may not be available in the short-term

19
Recommendations Received from Stakeholders
  • County Sanitation Districts L.A. County
  • Need to develop mitigation measures concurrently
    with significance threshold
  • Reject no threshold option
  • Reject zero threshold option
  • Threshold should not be used to comply with AB 32
  • Should harmonize thresholds with other
    jurisdictions
  • Recommends against using life cycle analysis
  • Mandated GHG emission reductions should not be
    required until a regional credit market is
    established

20
Recommendations Received from Stakeholders
  • Center for Biological Diversity
  • Recommends a zero threshold or
  • Recommends a threshold that captures 90 of
    future discretionary projects (900 MT CO2eq/year)
  • Concerns regarding increased preparation of EIRs
    can be addressed with implementation of a
    mitigation fee offset program
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