Greenhouse Gas Mitigation – What Does It Cost Business?
November 11th, 2014 by Fiedler Group
In recent months Fiedler Group has experienced cases in both Riverside and San Diego Counties where local Planning Departments are requiring a Greenhouse Gas (GHG) analysis of small (less than one acre) redevelopment projects within existing retail shopping centers.
Although we process many projects through entitlement each year, this relatively new requirement represents a new cost and possible mitigation challenge to project entitlement process and approval.
Why is a GHG analysis required, and how can it impact your project development?
Greenhouse Gas Mitigation History
In 2006 California passed AB 32 – California Global Warming Solutions Act establishing a State requirement to reduce GHG Emissions to 1990 levels by year 2020.
Senate Bill SB97, a companion bill, directed the California Natural Resources Agency to certify and adopt guidelines for the mitigation of GHG or the effects of GHG emission.
This was the legislative directive for the California Natural Resources Agency to specifically establish that GHG emissions and their impacts are appropriate subjects for CEQA analysis.
In December 2009, the California Natural Resources Agency adopted revisions to the State CEQA Guidelines to address GHG analysis and mitigation – which became effective in March 2010.
Local Government Response to Greenhouse Gas
The CEQA Guidelines allow local agencies to perform either a quantified or qualified analysis to determine if the impact from GHG emissions is significant.
Although most jurisdictions use either a 3,000 metric tons per year threshold or a per capita threshold of approximately 4.6-4.8 metric tons CO2e per person per year, San Diego has not adopted thresholds of significance for GHG emissions or measures in place to indicate that a quantitative or qualitative assessment is necessary to insure that a project’s impact is not cumulatively considerable.
As an interim approach to determine whether a GHG analysis is required, San Diego utilizes the California Air Pollution Control Officers Association (CAPCO) 2008 report “CEQA & Climate Change”.
The CAPCO white paper suggests multiple thresholds, but San Diego has chosen the lowest – a 900 metric ton CO2e screening threshold for determining when a GHG analysis is required.
If the project exceeds 900 metric tons, a focused GHG analysis would be required to analyze GHG emissions resulting from construction activities related to the project and on-going operation of the project.
The analysis should include at a minimum the following five primary sources of GHG emissions:
- Vehicular traffic
- Generation of electricity
- Natural gas consumption / combustion
- Solid waste generation
- Water usage
Based on the California Air Resources Board (CARB) 2020 “business-as-usual” forecast model, the proposed project must show a 28.3% reduction to the 2020 business-as-usual model.
Greenhouse Gas Legislation Challenges
The business challenges associated with this legislation are significant:
- Reducing GHG Emissions to 1990 levels by year 2020 (an approximately 15% reduction from business-as-usual levels).
- An 80% GHG emission cut below the 1990 threshold by 2050.
AB 32 compliance is more daunting when one considers the following:
- The State’s population is expected to grow 48% from 29.7 million to 44.1 million residents, 1990-2020.
- Bringing the State’s total GHG emissions to 1990 levels by 2020 will require a cut in per capita emissions of 3.9 metric tons (about 30%) to 9.7 metric tons per person.
- Reductions will not be easy since the State’s economy is already comparatively energy efficient. Californians used an average of 7,400 kilowatts per person in 2005, compared to the national average per capita electricity consumption of almost 13,000 kilowatts.
- Globally, California would rank 18th in total emissions if it were a separate country. The State ranks near the top among the most efficient developed economies, alongside France and Italy, for the fewest GHG emissions per $1,000 GDP.
To learn more about greenhouse gas mitigation and how Fiedler Group is managing this process, please contact us today.
