ARCHIVED REPORTS LEC APPLICATION FOR CERTIFICATION

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5.1 AIR QUALITY CO2/MWh, (CO2,not CO2-equivalent),as shown in Table 5.1-22 above. Therefore,the facility will comply with the EPS. As the CEC's 2007 Integrated Energy Policy Report32 noted: "New natural gas-fueled electricity generation technologies offer efficiency,environmental, and other benefits to California, specifically by reducing the amount of natural gas used— and with less natural gas burned,fewer greenhouse gas emissions. Older combustion and steam turbines use outdated technology that makes them less fuel-and cost-efficient than newer,cleaner plants... The 2003 and 2005 IEPRs noted that the state could help reduce natural gas consumption for electric generation by taking steps to retire older,less efficient natural gas power plants and replace or repower them with new,more efficient power plants." (p. 184) Thus,in both the context of the California Environmental Quality Act and CEC's Integrated Energy Policy Report,the proposed project would not be expected to cause a significant cumulative impact and furthers the state's strategy to reduce fuel use and GHG emissions. Further,even though it is possible to quantify how many gross GHG emissions are attributable to a project,it is difficult to determine whether this will result in a net increase of these emissions, and,if so,by how much. Therefore,it would be speculative to conclude that any given project results in a cumulatively significant adverse impact resulting from greenhouse gas emissions. At this time,neither the state nor the APCD has adopted thresholds of significance or methodologies for analyzing GHG emission impacts under CEQA. The State Office of Planning and Research has recently begun the process of drafting proposed guidelines for analyzing GHG emissions,but these guidelines are not expected to be adopted until January 2010. Additionally, CARB is currently in the process of drafting a scoping plan to achieve the emission reduction targets of AB 32. In the interim period while the AB 32 and CEQA GHG- related regulatory programs are being developed,projects may be judged on whether they will hinder the emission reduction goals of AB 32. The CEC has issued several decisions concerning projects subject to its decision since passage of AB 32. Recently,the Final Commission Decision on the 660 MW Colusa Generating Station (CGS) discussed the schedule by which the CARB will develop regulations to manage GHG emissions and imposed a condition of certification AQ-SC8 that"...requires the project owner to report the quantities of relevant greenhouse gases emitted as a result of electric power production." More important was the following finding: "We find that AQ-SC8,with the reporting of GHG emissions,will enable the project to be consistent with the regulations and policies described above" (referring to AB 32 and Senate Bill 1368 (Electricity Greenhouse Gas Emissions Standards)). As a routine matter,the CEC includes such reporting in its decisions. Such GHG emission reporting is already carried out on a regular basis by NCPA in its annual reports to the California Climate Action Registry under the specific requirements of the Power/Utility Reporting Protocol (April 2005) for each of its generating units. In the absence of established thresholds of significance or methodologies for assessing impacts,this analysis of GHG emission impacts consists of quantifying project-related GHG emissions, determining their significance in comparison to the goals of AB 32, and discussing 32 CEC-100-2007-008-CMF, December 5,2007,accessed at http://www.energy.ca.gov/2007_energypolicy/ SAC/371322/082410013(LEC_5.1_AIR_QUALITY.DOC) 5.1-65