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Draft Supplemental Environmental Impact Report Page IV.D-23 _ Forward Inc. Landfill 2014 Expansion Project Based on the complaint history and the survey information, and the location of the -� proposed landfill areas in relation to potential odor receptors, the odor and fugitive dust impacts would be less than significant, and no additional measures to reduce impacts are required. Mitigation Measure D.3. (Same as 2013 EIR Mitigation Measure D.4.): To reduce the potential for any off-site odor impacts, the Odor Control Management Plan for Forward Landfill shall be modified to include daily management odor inspections when cannery wastes are being processed. Impact D.4. Project operations would generate emissions of GHG that could conflict with the implementation of the California Global Warming Solutions Act of 2006 (AB32) (Revises 2013 EIR Impact D.5.). As with other individual projects, the specific emissions from this project would not be expected to individually have an impact on Global Climate Change,but they are analyzed for the potential for a significant contribution to the cumulative impact on GHG emissions.16 Recent guidance indicates that GHG-related impacts are considered to be exclusively cumulative impacts;there are no non—cumulative GHG emission impacts from a climate change perspective." Three types of analyses are used to determine whether the project could be in conflict with the State goals for reducing GHG emissions. The analyses are as follows: A) Identification of any potential conflicts with the CARB's GHG 39 recommended actions in the adopted Climate Change Scoping Plan 18. B) Evaluation of the relative size of the project. The project's GHG emissions will be compared to the size of major facilities that are required to report GHG emissions (25,000 metric tons/year of CO2e)19 to the State; and the project size will be compared to the estimated State GHG reduction goal of 169 million metric tons Of COze per year by 2020. As noted, the 25,000 metric ton annual limit identifies _ the large stationary point sources in California that make up 94 percent of the stationary emissions. If the project's total emissions are below this limit, the total emissions are equivalent in size to the smaller projects in California that as a group only make up six percent of all stationary emissions. It is assumed that the activities of these smaller projects will not conflict with State's ability to reach overall goals outlined within AB 32. In reaching its goals the CARB will focus upon the largest emitters of GHG emissions. _ C)Any potential conflicts with an applicable plan,policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. 16 Association of Environmental Professionals(AEP),Alternative Approaches to Analyzing ^J Greenhouse Gas Emissions and Global Climate Change in CEQA Documents,2007. 17 California Air Pollution Control Officers Association(CAPCOA),CEQA and Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental — Quality Act,2008. 18 California Air Resources Board,Climate Change Scoping Plan Appendices,Volume 1:Supporting Documents and Measure Detail,Appendix E List of Recommended Actions by Tons.December,2008. 19 The State of California has not provided guidance as to quantitative significance thresholds for assessing the impact of greenhouse gas emissions on climate change and global warming concerns. Nothing in the CEQA Guidelines directly addresses this issue.