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Draft Environmental Impact Report - East Bay Municipal Utility District

Draft Environmental Impact Report - East Bay Municipal Utility District

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Estates Reservoir Replacement <strong>Draft</strong> <strong>Environmental</strong> <strong>Impact</strong> <strong>Report</strong>Greenhouse GasesTiered Approach with Quantitative Threshold Based on Market CaptureThe goal of a tiered threshold is to maximize reduction predictability while minimizingadministrative burden and costs. This would be accomplished by prescribing feasiblemitigation measures based on project size and type, and reserving the detailed review ofan EIR for those projects of greater size and complexity. This approach may requireinclusion in a General Plan or adoption of specific rules or ordinances in order to fullyand effectively implement it. (CAPCOA 2008)A tiered CEQA significance threshold could establish different levels at which todetermine if a project would have a significant impact. The tiers could be establishedbased on the gross GHG emission estimates for a project or could be based on thephysical size and characteristics of the Project. This approach would then prescribe a setof GHG mitigation strategies that would have to be incorporated into the Project in orderfor the Project to be considered less than significant. The framework for a tieredthreshold would include (CAPCOA 2008):Disclosure of GHG emissions for all projects;Support for city/county/regional GHG emissions reduction planning;Creation and use of a “green list” to promote the construction of projects that havedesirable GHG emission characteristics;A list of mitigation measures;A decision tree approach to tiering; andQuantitative or qualitative thresholds.CEQA guidance that allows multiple methodologies to demonstrate GHGsignificance will facilitate the determination of significance for a broad range ofprojects/plans that would otherwise be difficult to address with a single noncompoundmethodology. Results of analysis would yield one of three results(CAPCOA 2008):- Tier 1 Projects - A net reduction of GHG emissions (Less than Significant or No<strong>Impact</strong>)- Tier 2 Projects - A net increase of GHG emissions but mitigated to zero(Significant but Mitigable)- Tier 3 Projects - Mitigation is infeasible due to the cost or lack of availableoffsets to reduce net emissions to zero (Significant and Unavoidable)A single quantitative threshold was developed in order to ensure capture of 90 percent ormore of likely future discretionary developments. The objective was to set the emissionthreshold low enough to capture a substantial fraction of future residential andnonresidential development that will be constructed to accommodate future statewidepopulation and job growth, while setting the emission threshold high enough to excludesmall development projects that will contribute a relatively small fraction of thecumulative statewide GHG emissions (CAPCOA 2008):sb09_001.doc 3-8.10 7/22/2009

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