This document summarizes air quality and greenhouse gas regulations for CEQA analyses. It outlines the regulatory frameworks for criteria air pollutants at the federal, state and local levels. It also discusses modeling tools for estimating construction and operational emissions. Greenhouse gas regulations outlined include definitions, global warming potential, and key California policies like EO S-03-05 and the Global Warming Solutions Act. The document stresses the importance of determining significance and implementing feasible mitigation for GHG emissions in CEQA reviews.
Civic Exchange 2009 The Air We Breathe Conference - U.S. Politics and Laws as...Civic Exchange
Civic Exchange 2009 The Air We Breathe Conference - Experts Symposium 9 January 2009
U.S. Politics and Laws as Drivers for Air Quality Management (AQM)
presented by John G Watson (Desert Research Institute)
http://air.dialogue.org.hk
Civic Exchange 2009 The Air We Breathe Conference - U.S. Politics and Laws as...Civic Exchange
Civic Exchange 2009 The Air We Breathe Conference - Experts Symposium 9 January 2009
U.S. Politics and Laws as Drivers for Air Quality Management (AQM)
presented by John G Watson (Desert Research Institute)
http://air.dialogue.org.hk
Discussion TopicsHistoryClean Air ActPollution ControlsAir PermitsPlant Management
History of Air Pollution Laws
Air pollution is a part of human historyCavemen to Ancient Greece1306 London1881 Chicago and Cincinnati1948 Denora, Pennsylvania
CAA1970First National Clean Air ActNEPA Started the EPA as we know it
1990Pollution control and prevention measuresNAAQS
National Ambient Air Quality Standards3 areas in the USUnclassifiable areaCan not be classified as meeting or not meeting NAAQSAttainment areaArea that meets NAAQS for specific pollutantNonattainment areaDoes not meet standardContributes to AAQ in nearby area that does not meet the NAAQS for specific pollutant
State Implementation Plans (SIPS)Limit EmissionsEstablish Emission offset policiesRequire reportingEstablish penalties and proceduresEstablish state or regional responsibility for administering the permit
Hazardous Air Pollutants (HAPS)Major source of HAPS: Any stationary source (or group of them) located within a contiguous area under common control that can emit more than 10 tons per year of any HAP or 25 tons per year of any combination of HAPS
2 types cited most oftenMobileStationary
Nonattainment AreasIn nonattainment areas, any stationary source that has potential to emit more than 100 tons per year is considered major stationary sourceMust comply with Prevention of Significant Deterioration and New Source Review
Stationary SourcesFixed, nonmoving producers of pollution:Buildings, Structures, facilities or installations that emit an air pollutant for which a national standard is in effect
Problems from Mobile SourcesAir ToxicsPollutants that cause adverse health effectsMost of EPA efforts have been concentrated on carcinogens (cancer)Vehicles emit several pollutants that are classified as known or probable human carcinogensBenzene – knownDiesel – probableFormaldehyde - probable
Air Quality EmissionsEmission StandardMaximum allowable amount of a pollutant legally permitted to be dischargedSingleMobileStationary
Emissions LimitationsRelated to specific numerical emission limitations for the following:LeadCadmiumMercuryDioxinsSulfur dioxide
Federal Air Quality Permit RequirementsOffsetting reductions must have been obtainedNew or modified source will not cause or contribute to emissions levels that exceed permitted allowanceProposed source must meet lowest achievable emission rate
Federal Air Quality Permit RequirementsOwner/Operator of proposed new or modified source shows that all major stationary sources are in complianceMust show that benefits of propsed source significantly outweigh the environmental and social costs imposed
Title V Operating PermitsAll requirements applicable to a sourcePermit fees fund State air programsApplies to all cities which are subject to Federal regulation under the CAA.
Air Quality EmissionsNew Source Review
Emissions TradingA plant with several facilities can decrease pollution at some fac.
Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas DevelopmentTrihydro Corporation
Presentation about the air regulations affecting oil and gas development. Topics covered include NSPS OOOO, Leak Detection and Repair, Greenhouse Gas Inventory/Reporting, Optical Gas Imaging with Infrared Cameras
ALL4's Dan Dix presented at the 23rd Virginia Environmental Symposium about 1-Hour SO2 Implementation Modeling. Dan's presentation consisted of a summary of the NAAQS, an update on NAAQS implementation, NAAQS modeling demonstration approach, and a summary of ambient SO2 monitoring.
BlueScape 2022 Update: CEQA Air Quality & Greenhouse Gas Impact Studies Webin...BlueScape
In 2022, developers completing an Environmental Impact Report (EIR) under the California Environmental Quality Act (CEQA) must complete Air Quality and Greenhouse Gas (GHG) impact technical studies to address the potential for significant environment impacts. In this webinar, you will learn about:
• Status in 2022 of the CEQA Guidelines, and local lead agency air quality and GHG analysis guidelines;
• When Air Quality and Greenhouse Gas technical studies must be completed under CEQA, or as otherwise required by reviewing agencies;
• Project strategies; working with agencies and the public through the process;
• Types of projects and air emission sources, the construction and operation phases, analysis types, and information needs;
• Pollutant types and typical CEQA air quality and GHG analysis significance thresholds;
• Difference between Project Design Elements and Mitigation;
• Typical air quality and GHG mitigation requirements: How to address mitigation and monitoring;
• How to review project alternatives and cumulative impacts with other projects;
• The role of California air districts in CEQA review and relationship to other actions such as air permitting;
• Special non-CEQA analysis cases, such as projects near schools and freeways;
• 2022 update on software tools and guidance documents, including CalEEMod, EMFAC, AERMOD, and HARP2;
• Elements of CEQA Air Quality and Greenhouse Gas technical study reports;
• An example Case Study.
About the instructor:
James A. Westbrook is the President of BlueScape Environmental, with over 30 years of experience completing CEQA Air Quality and Greenhouse Gas technical studies. He has led this type of work for the development of transmission lines, renewable energy farms, petroleum refinery expansion, power plants, manufacturing, landfills, rail expansion, airports, highways, seaports, retail centers, schools, and multifamily housing.
BlueScape and Cooper White - BAAQMD Air Toxics Risk Reduction Rule 11-18 Webi...BlueScape
This webinar by James Westbrook, President of BlueScape Environmental, and Keith Casto, Partner of Cooper, White & Cooper, provides an overview of the new Bay Area AQMD Air Toxics Risk Reduction Rule 11-18, adopted on November 15, 2017.
This webinar provides you with helpful information you can use to understand the potential impacts from Rule 11-18, and to prepare for compliance, including: overview of applicability and requirements; meaning of the Significant Risk Threshold, the Risk Action Level, TBARCT, and other key definitions; description of Rule 11-18 process steps and compliance requirements, from emissions inventory and risk prioritization, to health risk assessment and risk reduction; tips to update and refine your facility Air Toxics Emissions Inventory, and to reduce potential prioritization as a high-risk facility; tips to work with the BAAQMD on preparation of your facility health risk assessment, and to refine the modeling and health risk calculations using technical methods; how to evaluate health risk reduction options and complete a Risk Reduction Plan for BAAQMD approval; how to demonstrate emission sources will meet TBARCT; and, Rule 11-18 compliance timelines for various risk categories and compliance options.
James Westbrook can be reached at jwestbrook@bluescapeinc.com or 877-486-9257. Keith Casto can be reached at 415-765-6272. Please contact us for any questions or support on the implementation of Rule 11-18 for your facility.
Details regarding the 2012 U.S. EPA Air Regulatory Agenda: regulatory proposals regarding greenhouse gases, startup / shutdown / and malfunctions, hazardous air pollutants, new source performance standards, and ozone.
Scott Taylor and Susana Perez with Taylor Environmental Services deliver an update on California environmental issues at the CalAPA Spring Asphalt Pavement Conference & Equipment Expo, April 12-13, 2017 in Ontario, Calif.
Presentation by Scott Taylor, President, Taylor Environmental Services, on the latest changes in environmental regulations for the asphalt industry in California. Taylor is co-chairman of the CalAPA Environmental Committee. Presentation delivered at the CalAPA Spring Asphalt Pavement Conference, held March 20-21, 2019 in Ontario, CA.
Discussion TopicsHistoryClean Air ActPollution ControlsAir PermitsPlant Management
History of Air Pollution Laws
Air pollution is a part of human historyCavemen to Ancient Greece1306 London1881 Chicago and Cincinnati1948 Denora, Pennsylvania
CAA1970First National Clean Air ActNEPA Started the EPA as we know it
1990Pollution control and prevention measuresNAAQS
National Ambient Air Quality Standards3 areas in the USUnclassifiable areaCan not be classified as meeting or not meeting NAAQSAttainment areaArea that meets NAAQS for specific pollutantNonattainment areaDoes not meet standardContributes to AAQ in nearby area that does not meet the NAAQS for specific pollutant
State Implementation Plans (SIPS)Limit EmissionsEstablish Emission offset policiesRequire reportingEstablish penalties and proceduresEstablish state or regional responsibility for administering the permit
Hazardous Air Pollutants (HAPS)Major source of HAPS: Any stationary source (or group of them) located within a contiguous area under common control that can emit more than 10 tons per year of any HAP or 25 tons per year of any combination of HAPS
2 types cited most oftenMobileStationary
Nonattainment AreasIn nonattainment areas, any stationary source that has potential to emit more than 100 tons per year is considered major stationary sourceMust comply with Prevention of Significant Deterioration and New Source Review
Stationary SourcesFixed, nonmoving producers of pollution:Buildings, Structures, facilities or installations that emit an air pollutant for which a national standard is in effect
Problems from Mobile SourcesAir ToxicsPollutants that cause adverse health effectsMost of EPA efforts have been concentrated on carcinogens (cancer)Vehicles emit several pollutants that are classified as known or probable human carcinogensBenzene – knownDiesel – probableFormaldehyde - probable
Air Quality EmissionsEmission StandardMaximum allowable amount of a pollutant legally permitted to be dischargedSingleMobileStationary
Emissions LimitationsRelated to specific numerical emission limitations for the following:LeadCadmiumMercuryDioxinsSulfur dioxide
Federal Air Quality Permit RequirementsOffsetting reductions must have been obtainedNew or modified source will not cause or contribute to emissions levels that exceed permitted allowanceProposed source must meet lowest achievable emission rate
Federal Air Quality Permit RequirementsOwner/Operator of proposed new or modified source shows that all major stationary sources are in complianceMust show that benefits of propsed source significantly outweigh the environmental and social costs imposed
Title V Operating PermitsAll requirements applicable to a sourcePermit fees fund State air programsApplies to all cities which are subject to Federal regulation under the CAA.
Air Quality EmissionsNew Source Review
Emissions TradingA plant with several facilities can decrease pollution at some fac.
Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas DevelopmentTrihydro Corporation
Presentation about the air regulations affecting oil and gas development. Topics covered include NSPS OOOO, Leak Detection and Repair, Greenhouse Gas Inventory/Reporting, Optical Gas Imaging with Infrared Cameras
ALL4's Dan Dix presented at the 23rd Virginia Environmental Symposium about 1-Hour SO2 Implementation Modeling. Dan's presentation consisted of a summary of the NAAQS, an update on NAAQS implementation, NAAQS modeling demonstration approach, and a summary of ambient SO2 monitoring.
BlueScape 2022 Update: CEQA Air Quality & Greenhouse Gas Impact Studies Webin...BlueScape
In 2022, developers completing an Environmental Impact Report (EIR) under the California Environmental Quality Act (CEQA) must complete Air Quality and Greenhouse Gas (GHG) impact technical studies to address the potential for significant environment impacts. In this webinar, you will learn about:
• Status in 2022 of the CEQA Guidelines, and local lead agency air quality and GHG analysis guidelines;
• When Air Quality and Greenhouse Gas technical studies must be completed under CEQA, or as otherwise required by reviewing agencies;
• Project strategies; working with agencies and the public through the process;
• Types of projects and air emission sources, the construction and operation phases, analysis types, and information needs;
• Pollutant types and typical CEQA air quality and GHG analysis significance thresholds;
• Difference between Project Design Elements and Mitigation;
• Typical air quality and GHG mitigation requirements: How to address mitigation and monitoring;
• How to review project alternatives and cumulative impacts with other projects;
• The role of California air districts in CEQA review and relationship to other actions such as air permitting;
• Special non-CEQA analysis cases, such as projects near schools and freeways;
• 2022 update on software tools and guidance documents, including CalEEMod, EMFAC, AERMOD, and HARP2;
• Elements of CEQA Air Quality and Greenhouse Gas technical study reports;
• An example Case Study.
About the instructor:
James A. Westbrook is the President of BlueScape Environmental, with over 30 years of experience completing CEQA Air Quality and Greenhouse Gas technical studies. He has led this type of work for the development of transmission lines, renewable energy farms, petroleum refinery expansion, power plants, manufacturing, landfills, rail expansion, airports, highways, seaports, retail centers, schools, and multifamily housing.
BlueScape and Cooper White - BAAQMD Air Toxics Risk Reduction Rule 11-18 Webi...BlueScape
This webinar by James Westbrook, President of BlueScape Environmental, and Keith Casto, Partner of Cooper, White & Cooper, provides an overview of the new Bay Area AQMD Air Toxics Risk Reduction Rule 11-18, adopted on November 15, 2017.
This webinar provides you with helpful information you can use to understand the potential impacts from Rule 11-18, and to prepare for compliance, including: overview of applicability and requirements; meaning of the Significant Risk Threshold, the Risk Action Level, TBARCT, and other key definitions; description of Rule 11-18 process steps and compliance requirements, from emissions inventory and risk prioritization, to health risk assessment and risk reduction; tips to update and refine your facility Air Toxics Emissions Inventory, and to reduce potential prioritization as a high-risk facility; tips to work with the BAAQMD on preparation of your facility health risk assessment, and to refine the modeling and health risk calculations using technical methods; how to evaluate health risk reduction options and complete a Risk Reduction Plan for BAAQMD approval; how to demonstrate emission sources will meet TBARCT; and, Rule 11-18 compliance timelines for various risk categories and compliance options.
James Westbrook can be reached at jwestbrook@bluescapeinc.com or 877-486-9257. Keith Casto can be reached at 415-765-6272. Please contact us for any questions or support on the implementation of Rule 11-18 for your facility.
Details regarding the 2012 U.S. EPA Air Regulatory Agenda: regulatory proposals regarding greenhouse gases, startup / shutdown / and malfunctions, hazardous air pollutants, new source performance standards, and ozone.
Scott Taylor and Susana Perez with Taylor Environmental Services deliver an update on California environmental issues at the CalAPA Spring Asphalt Pavement Conference & Equipment Expo, April 12-13, 2017 in Ontario, Calif.
Presentation by Scott Taylor, President, Taylor Environmental Services, on the latest changes in environmental regulations for the asphalt industry in California. Taylor is co-chairman of the CalAPA Environmental Committee. Presentation delivered at the CalAPA Spring Asphalt Pavement Conference, held March 20-21, 2019 in Ontario, CA.
4. Regulatory Framework
Definition
Criteria Pollutant: An air pollutant for which acceptable levels of exposure have
been determined and documented (in a criteria document), and for which an
ambient air quality standard has been set.
Other Pollutants: Anything introduced into the air that can cause nuisance,
damage, disease or death to living creatures, or damage to crops or the
environment
Federal
U.S. Environmental Protection Agency (EPA)
Federal Clean Air Act (FCAA) (1970, Amendments 1990)
National Ambient Air Quality Standards (NAAQS) (see handout)
Ozone, PM (10 and 2.5), CO, NO , SO , lead,
2 2
Attainment Designation and Classification
State Implementation Plans (SIPs)
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4
5. California's regulatory forays
predate the federal/EPA
Regulatory Framework regulation, that's why we get
special clearance to regulate
(with permission) tailpipe
State emissions.
California Air Resources Board (ARB)
California Clean Air Act (CCAA) (1988)
California Ambient Air Quality Standards (CAAQS)
Local air district oversight, approving air quality attainment
plans, submitting SIPs to EPA, monitoring, area designations,
Regulatory Authority
On-road/Off-Road Emissions Limits, “In Use” Rules, Permits,
ATCMs, Consumer Products, Agricultural
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6. Regulatory Framework
Local
35 air districts for 15 air basins
Attain and maintain air quality conditions
Air Quality Attainment Plans
Adoption and enforcement of rules and regulations
Permitting
Inspections
CEQA guide
Thresholds of significance
Screening tools
Analysis methodology
Mitigation strategies
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7. Impact Assessments
Construction-Related Operation-Related
Activities Activities
Off-Road Mobile Off-Road Mobile
Sources Sources
On-Road Mobile
Sources
On-Road Mobile
Sources Area Sources
ROG/VOC from paints
and curing asphalt. Area Sources
Stationary Sources
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8. Tools of the Trade….
Models
Urban Emissions Model (URBEMIS)
California Emissions Estimator Model (CalEEMod)
California Emissions Factor Models (EMFAC,
OFFROAD)
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www.firstcarbonsolutions.com
9. Answer me this…CEQA Appendix G
A) Conflict with or obstruct implementation of the
applicable air quality plan
B) Violate any air quality standard or contribute
substantially to an existing or projected air quality
violation
C) Result in a cumulatively considerable net increase of
any Criteria Air Pollutants for which the project region is
non-attainment under an CAAQS or NAAQS
D) Expose sensitive receptors to substantial pollutant
concentrations
E) Create objectionable odors affecting a substantial
number of people
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10. Now you have an impact…..
Thresholds of significance
Mitigation (on- and off-site)
Fees
Construction (e.g., watering, new equipment fleet)
Operational (e.g., trip reduction)
Modified Activity
Buffer Zones
Proving Reduction effectiveness
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11. Greenhouse Gases
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12. GHG, GWP, CO….WTF???
Definition
Any gas or particulate that absorbs infrared
radiation in the atmosphere : CO2, CH4, N2O
Global Warming Potential (GWP)
Used to normalize GHGs to units of CO2 equivalent (CO2e)
Example:
1 ton CH4 * 21 GWP = 21 tons CO2e
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13. Regulatory Framework for GHG
Federal
Mandatory GHG reporting rule
National program to cut GHG emissions and improve fuel
economy for cars and trucks
Endangerment and cause or contribute findings (2009)
States EPA should regulate and develop standards for emissions of
any pollution from any class(es) of new motor vehicles (or
engines), which in judgment cause, or contribute to, air pollution,
which may reasonably be anticipated to endanger public health or
welfare
Climate change adaptation
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14. Regulatory Framework for GHG
State and Local
Executive Order S-03-05
Established GHG emissions targets for California:
By 2010, Reduce to 2000 Levels
By 2020, Reduce to 1990 Levels
By 2050, Reduce to 80% below 1990
Oversight by Secretary of CalEPA with other state departments,
Climate Action Team
Biennial report on progress, impacts of global warming on
California, and mitigation and adaptation plans to combat impacts
No action for implementation to date
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15. Health and Safety Code 38501. The Legislature finds and declares all of the
Global Climate Solutions Act
following: (a) Global warming poses a serious threat to the economic
well-being, public health, natural resources, and the environment of
California.
Required that GHG emissions be reduced to
1990 levels by 2020
Statewide cap on certain emissions to be
phased in, starting in 2012
ARB to develop regulations and reporting
system to track and monitor emission levels
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16. So what does this all mean?
Small incremental emissions can be cumulatively
considerable….e.g. SJVAPCD
Can’t dance around it you have to assess significance and
recommend feasible, enforceable mitigation/alternatives
Absence of State thresholds is not an excuse to avoid
determining significance
Highest priority is securing feasible mitigation and/or
alternatives to reduce carbon emissions, including use of
offsets
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17. Sources of Information and Guidance
CAPCOA Guidance 08’ & 10’
OPR Guidance 08’
ARB Scoping Plan 08’
Attorney Generals Mit. List 10’
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18. ARB’s Scoping Plan
Strategies to achieve reduction includes ARB-
recommended GHG reductions for each emissions
sector of the state’s GHG inventory
Improved emission standards for light-duty vehicles
Low-Carbon Fuel Standard
Energy efficiency measures in buildings and appliances
and the widespread development of combined heat and
power systems
Renewable portfolio standard for electricity production
Reapproved in August 2011
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19. Climate Change, GHG, CEQA….Oh My!
CEQA Guidelines were revised effective March 10,
2010
Key contents:
Determining significance
Use of existing streamlining tools
Appendix F – Energy Conservation
Appendix G – Checklist
Not there: quantified GHG threshold, vulnerability
provisions
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20. Take it District by District
SCAQMD
SJVAPCD
GHG CEQA Significance Threshold Basis: Performance based
Working Group All projects that would result in an
Draft Guidance document - Interim increase in GHG emissions would be
CEQA GHG Significance Threshold subject to San Joaquin Valley APCD’s
(October 2008) Best Performance Standards (BPS)
Significance Threshold (5-Tier Projects implementing BPS would
Approach) be determined to have a less than
Tier 1: Applicable exemptions significant individual and cumulative
Tier 2: GHG emissions within GHG impact on climate change
budgets in approved ? Where are the BPSs
regional plans
Tier 3: GHG emissions incremental
increase below, or
mitigated to less than the
significance screening level
Tier 4: Performance standards
Tier 5: Offsets
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21. Best Performance Standards
BPS Stationary Source Projects
Most stringent GHG emission reductions
technology
Achieved-in-Practice
Pre-quantified GHG emission reductions
BPS Development Projects
Any combination of approved measures
Achieved-In-Practice
Reducing GHG emissions by at least a 29%
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22. Analytical Tools
Urban Emissions Model (URBEMIS) (http://www.urbemis.com/) (On- and Off-Road Mobile, Area)
BAAQMD’s GHG Model Add-on (BGM) (All) (http://www.urbemis.com/) (All)
SCAQMD’s CalEEMod (http://www.aqmd.gov/caleemod/download.htm) (All)
ARB On-Road Emission Factors Model (EMFAC 2011) (http://www.arb.ca.gov/msei/modeling.htm)
ARB Off-Road Emission Factors Model (OFFROAD 2007)
(http://www.arb.ca.gov/msei/offroad/offroad.htm)
EPA Climate Leaders GHG Inventory Guidance (http://www.epa.gov/climateleaders/resources/inventory-
guidance.html) (On- and Off-Road Mobile, Area, Stationary, and Indirect)
California Climate Action Registry (CCAR) General Reporting Protocol
(http://www.climateregistry.org/tools/protocols/general-reporting-protocol.html) (On- and Off-Road
Mobile, Area, Stationary, and Indirect)
World Resources Institute (WRI) GHG Protocol (http://pdf.wri.org/ghg_protocol_2004.pdf) (On- and Off-
Road Mobile, Area, Stationary, and Indirect)
ARB Regulation Order (http://www.arb.ca.gov/regact/2007/ghg2007/isor.pdf) (On- and Off-Road Mobile,
Area, Stationary, and Indirect)
ARB/CCAR/ICLEI/TCR Local Government Operations Protocol
(http://www.arb.ca.gov/cc/protocols/localgov/pubs/final_lgo_protocol_2008-09-25.pdf)
(On- and Off-Road Mobile, Area, Stationary, and Indirect
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23. Sample Projects
Bell Village Project- City of Santa Rosa
Chik-Fa-La Project- City of Santa Rosa
Shore Power Project- Port of Oakland
SunPower Solar Project-County of Kings
Elk Grove SOI Expansion- Sacramento LAFCO
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Editor's Notes
Anything: particulate, aerosol, biological Criteria pollutants: ozone, PM, CO, Nitrogen dioxide, Sulfur dioxide and lead
Some air districts are a single county, some are multi-counties. Some counties are split into multiple air districts (, and some county
(e.g., exhaust emissions from offsite haul truck & worker commute trips) (e.g., offsite haul truck & overall generation of trips and vehicle miles traveled) (e.g., onsite landscape maintenance & natural gas usage)
Each air district assesses these impacts differently. The impacts are also interrelated. Qualitative v. quantitative assessment
Facilities that emit 25,000 metric tons or more per year of GHGs are required to submit annual reports to EPA
AB 32 covers major sources of GHG emissions in the State such as refineries, power plants, industrial facilities, and transportation fuels. The regulation includes an enforceable GHG cap that will decline over time. ARB will distribute allowances, which are tradable permits, equal to the emission allowed under the cap.
These are outside of the local air district guidance Public workshop to discuss CEQA Thresholds of Significance for GHGs (December 2008) Industrial Projects: Quantitative standard of 7,000 metric tons CO2e/yr for operational emissions Performance standard for construction Residential and Commercial Projects: Performance standards for construction, energy, water, waste and transportation Upper limit on project emissions