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4.5 – Greenhouse Gas Emissions Draft Environmental Impact Report February 2021 14800 W. Schulte Road Logistics Center 4.5-20 agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water. Issuance of the Safeguarding California: Implementation Action Plans followed in March 2016 (CNRA 2016). In January 2018, the CNRA released the Safeguarding California Plan: 2018 Update, which communicates current and needed actions that state government should take to build climate change resiliency (CNRA 2018c). Local San Joaquin Valley Air Pollution Control District The San Joaquin Valley Air Pollution Control District (SJVAPCD) does not regulate GHG emissions directly through its permitting responsibilities for stationary sources. Thus, there are no SJVAPCD rules or regulations related to GHGs. The SJVAPCD, however, influences reductions of GHGs from new and modified stationary sources when acting as a lead agency for CEQA. The SJVAPCD implements its GHG policies and reviews whether new or modified stationary sources will implement best performance standards (BPSs). In 2009, the SJVAPCD developed an internal policy and guidance for local land use agencies to use in evaluating GHG impacts under CEQA. In the Final Staff Report – Addressing GHG Emissions Impacts under the California Environmental Quality Act (SJVAPCD 2009a), the SJVAPCD reviewed potential GHG significance thresholds and approaches suggested by or adopted by entities, including a zero threshold, quantification of a project’s GHG impacts without a recommended significance threshold, and specific significance thresholds for different kinds of projects (e.g., residential, mixed use, industrial, plans).4 The following discussion summarizes the SJVAPCD’s conclusions about various categories of GHG significance thresholds. Zero Threshold. The SJVAPCD concluded that “although a zero threshold is appealing in its simplicity; execution of a zero threshold would be difficult or impossible” (SJVAPCD 2009a). Furthermore, the SJVAPCD found that projects that could not reduce their emissions to zero would require preparation of an environmental impact report and adoption of a statement of overriding consideration by the lead agency. Potentially, projects could choose to relocate to a region with a less-stringent threshold, so-called “leakage,” which would still result in GHG emissions outside the SJVAPCD. Finally, the SJVAPCD noted that CARB concluded that zero thresholds are not mandated because some level of GHG emissions is still consistent with climate stabilization, and other regulatory programs will result in GHG reductions. For these reasons, the SJVAPCD did not support a zero threshold. Accordingly, a zero threshold was not selected as an appropriate GHG/climate change threshold for this assessment. Non-Zero Quantitative Thresholds. The SJVAPCD reviewed numerous quantitative thresholds adopted or proposed by other air districts and organizations, including “mass of GHG emissions generate per unit of activity, GHG emissions per capita per unit basis, and percent reduction compared to business-as-usual” (SJVAPCD 2009a). Although a tiered approach was evaluated, with the final tier incorporating a quantitative threshold, the SJVAPCD concluded that “without supporting scientific information, establishment of tier trigger levels could be argued to be arbitrary, and District staff does not believe the available science supports establishing a bright -line threshold, above which emissions are significant and below which they are not” (SJVAPCD 2009a). 4 These documents encompassed the primary approaches for establishing significance thresholds prior to the March 18, 2010, effective date of revisions of the CEQA Guidelines in accordance with SB 97. Additional guidance regarding assessment of GHG impacts were provided in the revised CEQA Guidelines and accompanying Final Statement of Reasons for Regulatory Action – Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB97 (CNRA 2009a). In addition, the California appellate courts and Supreme Court have more recently considered CEQA cases and, in some cases, issued published decisions that provide additional direction regarding the appropriateness of certain GHG assessment methodologies and significance thresholds.