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Draft Environrnental Impact Report Page IV.D-26 P P Forward Landfill Expansion maximum non-cancer chronic hazard risk would be an HI of 0.036. These values are below the threshold of 1.0 and thus, the impact is less than significant. rImplementation of the measures identified in Mitigation Measure IV.D-2 would reduce emissions and further reduce both cancer and non-cancer health risks near the project area. fill Mitigation Measure IV.D.5: None required. Impact IV.D.6. Project operations would generate emissions of GHG that could conflict with the implementation of the California Global Warming Solutions Act of 2006 (AB32). 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.22 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.23 Three types of analyses are used to determining whether the project could be in conflict i with the State goals for reducing GHG emissions. The analyses are as follows: F A) Identification of any potential conflicts with the CARB's GHG early action strategies. 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)24 to the State; and the project size will be compared to the estimated State GHG reduction goal of 169 million metric tons s CO2e 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 (~a stationary emissions. If the project's total emissions are below this limit, its 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 ry overall goals outlined within AB 32. In reaching its goals the CARB will focus upon the largest emitters of GHG emissions. C) Evaluation of the basic energy efficiency parameters of a project to determine whether its design is inherently energy efficient. The Forward Landfill will comply with all AB 32 regulations(Item A)that would apply to this project as those regulations are adopted by the State. �i ' Association of Environmental Professionals (AEP), Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents,2007. 73 California Air Pollution Control Officers Association (CAPCOA), CEQA and Climate Change:Evaluating and I Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act,2008. ' The State of California has not provided guidance as to quantitative significance thresholds for assessing y the impact of greenhouse gas emissions on climate change and global warming concerns. Nothing in the CEQA Guidelines directly addresses this issue. i