Common use of Greenhouse Gas Emissions Clause in Contracts

Greenhouse Gas Emissions. The greenhouse gas (GHG) assessment for the proposed project will evaluate the potential impacts associated with the project’s generation of GHG emissions during construction and operations. GHG emissions attributable to the project will be estimated for the following sources: construction, area sources, mobile sources, energy consumption (electricity and natural gas), water consumption, and solid waste generation, consistent with the recommendation by the Governor’s Office of Planning and Research (OPR) in its Technical Advisory: CEQA and Climate Change (2008). Construction- and operations-related GHG emissions will be quantified using the most recent version of the CalEEMod computer model. Since neither the City nor SCAQMD have adopted a threshold of significance that would be applicable to the project, the GHG assessment will evaluate the project’s emissions in the context of the State and local setting. In addition, ESA is aware that the City had adopted a Greenhouse Gas Reduction Plan (GGRP) in February 2013 that contains goals and policies that direct the City’s approach to climate change, including emission reduction targets and general emission reduction strategies. In accordance with State CEQA Guidelines Section 15183.5, jurisdictions are allowed to analyze and mitigate the significant effects of GHGs at a programmatic level by adopting a plan for the reduction of GHG emissions. In turn, future individual projects that are proposed in the City are allowed to tier from and/or incorporate by reference the existing programmatic review from the plan into the GHG cumulative impacts analysis in their project-specific documents. Based on guidance provided in the City’s GGRP, a project-specific environmental document that relies on the GGRP for its cumulative impacts analysis must identify specific GGRP measures applicable to the project, and how the project incorporates the measures. As such, the GHG analysis for the proposed project would include a demonstration of the project’s compliance with the GGRP. Furthermore, the project’s GHG emissions will also be discussed with respect to the goals and recommended actions of the State’s Climate Change Scoping Plan and other applicable state regulations. If it is determined that the project would need to include design features/mitigation measures to reduce GHG emissions, ESA will work with the Applicant team to identify all applicable measures.

Greenhouse Gas Emissions. The greenhouse gas GHG emissions section will briefly summarize the current state of climate change science based on the most recent findings of the Intergovernmental Panel on Climate Change’s (GHG) assessment IPCC’s), along with applicable regulatory framework and relevant guidance in California and the project area (e.g., BAAQMD 2022 CEQA Guide, 2022 Scoping Plan, City of Brentwood). In accordance with BAAQMD’s recommendations, construction and operational emissions will be quantified and presented. As stated previously, it is assumed that process-related GHG emissions will be provided by the project team. Ascent will supplement these estimates with any additional calculations needed for other operational activities (e.g., onsite equipment use), mobile sources. Project-level impacts for construction will be evaluated using BAAQMD’s adopted best management practice approach. The proposed project is a stationary source; thus, appropriate stationary source thresholds will be summarized and included in the analysis. Understanding that the proposed project may result in reductions to existing waste hauling truck trips, the analysis will address this to the extent substantiated trip reduction data are available (e.g., quantification of associated GHG reductions). If such data are not available, the analysis will address this component qualitatively or treat project-generated operational mobile emissions as new sources. The energy analysis will evaluate the potential impacts based on State CEQA Guidelines Appendix G, analyzing whether the project may result in wasteful, inefficient, or unnecessary consumption of energy or conflict with a plan for renewable energy or energy efficiency. Ascent will quantify energy consumption for construction (e.g., fuel use) and operation (e.g., electricity, fuel use) to supplement process-related energy consumption, assumed to be provided by the project team. In addition, the analysis will address the increase in non-renewable energy sources that would result from the operation of the project, if applicable based on the final design of the system. Fuel consumption rates for on-road and off-road vehicles will be obtained from EMFAC. Fuel consumption from on-site operational equipment will be quantified using project-specific information and activity data (e.g., equipment type and capacity, annual throughput). Any applicable City or project policies/design features that relate to energy conservation or renewable energy will be considered in this analysis. The noise and vibration section will include a brief discussion of noise descriptors, identification of applicable regulations, and a description of existing noise conditions on the project site and in the surrounding area. Ascent’s noise specialist will conduct one 24-hour and two short-term (15-minute to 8- hour) noise measurements to establish existing conditions. Construction noise and operational noise will be modeled and compared to applicable noise standards (i.e., Chapter 10, Noise, of the Brentwood General Plan and Chapter 9.32, Noise Regulations, of the Brentwood Municipal Code). Where specific standards are not available, guidance from regulatory agencies (e.g., California Department of Transportation [Caltrans], Federal Highway Administration [FTA]) will be used. The construction noise assessment will also evaluate potential sources of temporary vibration using approved City methods (e.g., FTA). Operational noise sources would include on-site mechanical equipment and noise associated with increased vehicle trips on new roads, which will be evaluated based on project-specific details (e.g., site plan, traffic data) and assessed using reference noise levels and noise attenuation calculations. All modeling results and noise data will be included as attachments. Pursuant to Senate Bill (SB) 743, Public Resources Code Section 21099, and California Code of Regulations Section 15064.3(a), generally, vehicle miles traveled (VMT) is the most appropriate measure of transportation impacts and a project’s generation of GHG emissions during construction and operationseffect on automobile delay shall no longer constitute a significant impact under CEQA. GHG emissions attributable to Therefore, it is assumed that the transportation analysis will evaluate impacts using VMT. The project will be estimated for the following sources: construction, area sources, mobile sources, energy consumption (electricity and natural gas), water consumption, and solid waste generation, evaluated consistent with guidance and thresholds adopted by the recommendation lead agency (i.e., City of Brentwood). In the absence of any such adopted guidance and thresholds, the Technical Advisory on Evaluating Transportation Impacts in CEQA, published by the Governor’s Office of Planning and Research (OPR) in its Technical Advisory: CEQA and Climate Change (2008). Construction- and operations-related GHG emissions 2018, will be quantified using the most recent version relied upon. State CEQA Guidelines Section 15064.3(b)(3) (Qualitative Analysis) explains that there may be conditions under which a qualitative rather than quantitative analysis of the CalEEMod computer modelVMT is appropriate. Since neither the City nor SCAQMD have adopted This section states that for many projects, a threshold qualitative analysis of significance that would construction traffic may be applicable to the project, the GHG assessment will evaluate the project’s emissions in the context of the State and local settingappropriate. In addition, ESA is aware the Technical Advisory on Evaluating Transportation Impacts in CEQA notes that the City had adopted a Greenhouse Gas Reduction Plan (GGRP) in February 2013 that contains goals and policies that direct the City’s approach to climate change, including emission reduction targets and general emission reduction strategies. In accordance with State CEQA Guidelines Section 15183.5, jurisdictions are allowed to analyze and mitigate the significant effects of GHGs at a programmatic level by adopting a plan for the reduction of GHG emissions. In turn, future individual projects that are proposed generate or attract fewer than 110 trips per day generally may be assumed to cause a less-than-significant transportation impact, absent substantial evidence indicating otherwise (OPR 2018). As detailed in the City are allowed to tier from and/or incorporate by reference the existing programmatic review from the plan into the GHG cumulative impacts analysis in their project-specific documents. Based on guidance provided in the City’s GGRP, a project-specific environmental document that relies on the GGRP for its cumulative impacts analysis must identify specific GGRP measures applicable to the project, and how the project incorporates the measures. As suchOPR technical advisory, the GHG VMT analysis for the proposed purposes of CEQA transportation sections is specific to on- road passenger vehicles, specifically cars and light trucks; thus, heavy truck VMT would not be included in the analysis. This analysis will also consider the long-term regional effect of VMT, presumed to be a net decrease or no net change, compared to existing conditions. Therefore, the VMT analysis would consider the trips associated with all cars and light trucks serving the project would include site (e.g., employee commutes and operational maintenance activities). Ascent will also conduct a demonstration qualitative analysis evaluating the impacts on bicycle, pedestrian, and transit facilities, roadway hazards and obstructions, and emergency access resulting from the implementation of the proposed project’s compliance with the GGRP. Furthermore, the project’s GHG emissions will also be discussed with respect to the goals and recommended actions of the State’s Climate Change Scoping Plan and other applicable state regulations. If it is determined that the project would need to include design features/mitigation measures to reduce GHG emissions, ESA will work with the Applicant team to identify all applicable measures.

Greenhouse Gas Emissions. The greenhouse gas (GHG) emissions assessment for will include a setting and background discussion consisting of a summary of the proposed project greenhouse effect and global climate change, potential changes to the global climate system and to California, and emission inventories at the national, state, and local levels. It will evaluate also include a summary of the potential impacts key federal, state, and local regulatory actions and programs to reduce GHG emissions. Xxxxx will estimate the GHG emissions associated with construction of the project’s generation of GHG project using CalEEMod, based on the same construction scenario utilized in the air quality analysis. Construction emissions during construction will be amortized and operations. GHG emissions attributable added to the project operational emissions. Xxxxx will be estimated for the following sources: constructionestimate project-generated operational GHG emissions, which will include those associated with area sources, mobile sources, energy consumption use (electricity natural gas and natural gaselectricity), water consumptionsupply, wastewater, solid waste disposal, and solid waste generationrefrigerants. When project details are not available, consistent CalEEMod default values will be used to calculate direct- and indirect-source GHG emissions. Xxxxx will present the estimated annual operational GHG emissions and amortized construction GHG emissions in metric tons of carbon dioxide equivalent per year in the analysis. Xxxxx will assess the significance of the project with respect to the Appendix G thresholds; specifically, whether a project would (1) generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, and (2) conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. The City is in the process of developing their climate action and adaptation plan (CAAP) and has completed the draft GHG emissions inventory. While the CAAP may be a qualified plan for GHG emissions reductions under CEQA and allow for individual project tiering or streamlining, that mechanism is not available at this time. As such, we will work with City staff to identify an appropriate threshold approach for evaluating the potential project-generated GHG emissions impacts that does not conflict with the recommendation by the Governor’s Office of Planning and Research (OPR) in its Technical Advisory: CEQA and Climate Change (2008). Construction- and operations-related GHG emissions will be quantified using the most recent version overarching goals of the CalEEMod computer modelCAAP. Since neither the City nor SCAQMD have adopted a threshold of significance that would be applicable to the project, the GHG assessment Xxxxx will also qualitatively evaluate the project’s emissions in the context of the State and local setting. In additionpotential to conflict with other applicable plans, ESA is aware that the City had policies, or regulations adopted a Greenhouse Gas Reduction Plan (GGRP) in February 2013 that contains goals and policies that direct the City’s approach to climate change, including emission reduction targets and general emission reduction strategies. In accordance with State CEQA Guidelines Section 15183.5, jurisdictions are allowed to analyze and mitigate the significant effects of GHGs at a programmatic level by adopting a plan for the purpose of reducing GHG emissions such as state regulations (2030 and 2045 reduction of GHG emissions. In turngoals identified in Senate Bill (SB) 32 and Assembly Bill (AB) 1279, future individual projects that are proposed in the City are allowed to tier from and/or incorporate by reference the existing programmatic review from the plan into the GHG cumulative impacts analysis in their project-specific documents. Based on guidance provided in the City’s GGRPrespectively), a project-specific environmental document that relies on the GGRP for its cumulative impacts analysis must identify specific GGRP measures applicable to the projectCalifornia Air Resources Board scoping plans, and how the project incorporates the measuresSouthern California Association of Governments Regional Transportation Plan/Sustainable Communities Strategy. As suchOf importance, the GHG analysis for the proposed project would include a demonstration of the project’s compliance with the GGRP. Furthermore, the project’s GHG emissions will also be discussed with respect to the goals and recommended actions of the State’s Climate Change Scoping Plan and other applicable state regulations. If it is determined that the project would need to include design features/mitigation measures to reduce GHG emissions, ESA Xxxxx will work with the Applicant project team to identify all applicable measuresthe appropriate threshold and approach prior to initiating the analysis.

Greenhouse Gas Emissions. The Would the project: a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? (a-b) The City of Simi Valley relies upon the expert guidance of the Ventura County Air Pollution Control District (VCAPCD) regarding the methodology and thresholds of significance for the evaluation of air quality impacts within Ventura County. Greenhouse Gas (GHG) assessment emissions are air pollutants that are subject to local control by the VCAPCD. As such, the City looks to the VCAPCD for guidance in the proposed evaluation of GHG impacts. In September 2011, the Ventura County Air Pollution Control Board requested that VCAPCD staff report back on possible GHG significance thresholds for evaluating GHG impacts of land use projects in Ventura County under CEQA. VCAPCD staff responded to this request by preparing a report entitled Greenhouse Gas Thresholds of Significance Options for Land Use Development Projects in Ventura County. This report presents a number of options for GHG significance thresholds and summarizes the most prominent approaches and options either adopted or being considered by all other air districts throughout California. Similar to other air districts, VCAPCD staff members are considering a tiered approach with the main components involving consistency with a locally adopted GHG reduction plan followed by a bright-line threshold for land use projects that would capture 90 percent of project will evaluate GHG emissions. The South Coast Air Quality Management District (SCAQMD) is also considering these strategies for land use projects. The most recent proposal issued by the potential SCAQMD in September 2010 included a screening threshold of 3,000 MTCO2e/year for all non-industrial projects. For the purpose of evaluating the GHG impacts associated with the project’s generation , a threshold of 3,000 MTCO2e/year was used for plan level analyses. This threshold was used since it was developed based on the goal of AB 32 to reduce statewide GHG emissions during construction to 1990 levels by 2020. As outlined in the Air Quality and operationsGreenhouse Gas Study for the project (Ref. #36) the annual net GHG emissions attributable associated with the construction of the project is 22 MTCO2e/year, and the net GHG emissions for project operation is 1,189 MTCO2e/year. Combined, these emissions total to less than the SCAQMD screening threshold for non- industrial projects of 3,000 MTCO2e/year. As part of the General Plan update, the City has adopted a Climate Action Plan (SV-CAP) that includes a baseline GHG emissions inventory, a methodology for tracking and reporting emissions in the future, and recommendations for GHG reduction strategies as a foundation for these efforts. The SV-CAP focuses on the various goals and policies of the General Plan relative to greenhouse gas emissions. The SV-CAP is designed to ensure that the impact of future development on air quality and energy resources is minimized and that land use decisions made by the City and internal operations within the City are consistent with adopted state legislation. The SV-CAP identifies energy reduction measures, including a requirement that new development exceed 2008 Title 24 Part 6 Energy Standards by 20 percent, and water use reduction measures to reduce water demand by 20 percent. The project will be estimated required to comply with a number of ordinances that implement the goals of the SV-CAP. Simi Valley has adopted an Energy Reach Code, which adopts energy efficiency performance standards that reach higher than is required by Title 24 minimums. The main focus is on efficiency measures that are simple to achieve and enforce, and have the greatest influence on community sustainability. The Reach Code increases energy efficiency requirements for residential and nonresidential structures beyond Title 24, set at 10 and 15 percent respectively for new construction and substantial remodels. Chapter 9- 39 of the following sources: constructionCity of Simi Valley Development Code promotes trip reduction and alternative transportation methods (e.g., area sourcescarpools, mobile sourcesvanpools, energy consumption (electricity public transit, bicycles, walking, park-and- ride lots, improvement in the balance between jobs and natural gashousing), water consumptionflexible work hours, telecommuting, and solid waste generation, consistent with the recommendation by the Governor’s Office of Planning and Research parking management programs to address traffic increases from new development. The Water Conservation Program Ordinance (OPROrdinance 1142) in its Technical Advisory: CEQA and Climate Change (2008). Construction- and operations-related GHG emissions will be quantified using the most recent version of the CalEEMod computer model. Since neither reduce water consumption within the City nor SCAQMD have adopted a threshold of significance that would be applicable to Simi Valley through conservation, effective water supply planning, prevention of waste, and will maximize the project, the GHG assessment will evaluate the project’s emissions in the context efficient use of the State and local setting. In addition, ESA is aware that water within the City had adopted a Greenhouse Gas Reduction Plan (GGRP) in February 2013 that contains goals and policies that direct the City’s approach of Simi Valley. The Water Conservation Ordinance is designed to climate change, including emission reduction targets and general emission reduction strategies. In accordance with State CEQA Guidelines Section 15183.5, jurisdictions are allowed to analyze and mitigate the significant effects of GHGs at a programmatic level by adopting a plan for the reduction of GHG emissions. In turn, future individual projects that are proposed reduce water use in the City are allowed to tier at least 15 percent below the 2009 baseline. The City is an early adopter of the CALGreen Building Code, which is intended to improve sustainability of the built environment and reduce GHG emissions from and/or incorporate by reference the existing programmatic review from the plan into the GHG cumulative impacts analysis in their project-specific documentsnew construction. Based on guidance provided in the The City’s GGRPadopting Ordinance 1167 goes further by including a CEC-approved energy reach code, a project-specific environmental document that relies on the GGRP for its cumulative impacts analysis must identify specific GGRP measures applicable to the projectadditional landscape water conservation, and how the project incorporates the measuresincreased recycling. As suchTherefore, the GHG analysis there is a less than significant impact for the proposed project would include a demonstration of the project’s compliance with the GGRP. Furthermore, the project’s GHG emissions will also be discussed with respect to the goals and recommended actions of the State’s Climate Change Scoping Plan and other applicable state regulations. If it is determined that the project would need to include design features/mitigation measures to reduce GHG emissions, ESA will work with the Applicant team to identify all applicable measuresGreenhouse Gas Emissions.

Greenhouse Gas Emissions. The greenhouse gas (GHG) assessment emissions analysis will incorporate the Air Quality and Greenhouse Gas Assessment prepared for the Specific Plan (ECORP Consulting, Inc. 2018). Using this Assessment, the EIR will summarize the proposed project will evaluate the potential impacts associated with the project’s generation of GHG emissions during construction and operations. GHG emissions attributable potential contribution to the project will be estimated for the following sources: construction, area sources, mobile sources, energy consumption (electricity and natural gas), water consumption, and solid waste generation, consistent with the recommendation by the Governor’s Office of Planning and Research (OPR) in its Technical Advisory: CEQA and Climate Change (2008). Construction- and operations-cumulative impacts related GHG emissions will be quantified using the most recent version of the CalEEMod computer model. Since neither the City nor SCAQMD have adopted a threshold of significance that would be applicable to the project, the GHG assessment will evaluate the project’s emissions in the context of the State and local setting. In addition, ESA is aware that the City had adopted a Greenhouse Gas Reduction Plan (GGRP) in February 2013 that contains goals and policies that direct the City’s approach to climate change, including emission reduction targets the proposed project’s potential contribution to cumulative impacts related to climate change. The impact analysis will include an overview of the types and general emission reduction strategies. In accordance with State CEQA Guidelines Section 15183.5sources of GHGs, jurisdictions are allowed to analyze and mitigate the significant potential environmental effects of GHGs at a programmatic level by adopting a plan for and climate change. An overview of the reduction of current regulatory framework regarding GHGs/climate change, including Assembly Bill (AB) 32, Senate Bill (SB) 97, and SB 375, as well as adopted amendments to the State CEQA Guidelines, will also be described. Mitigation measures recommended in the ECORP Assessment will be included in the impact analysis. The Monterey Bay Air Resource District (MBARD) has not formally adopted thresholds to evaluate GHG emissions. In turnthe absence of local guidance, future individual projects that are proposed Consultant will consult with MBARD staff during the preparation of this section to verify the thresholds and assumptions used in the City ECORP Assessment are allowed accurate. In our experience, MBARD encourages lead agencies to tier from and/or incorporate by reference consider a variety of metrics for evaluating GHG emissions and related mitigation measures as they best apply to the existing programmatic review specific project. MBARD has in the past recommended using the adopted San Xxxx Obispo Air Pollution Control District (SLOAPCD) quantitative threshold for land use projects, which may be appropriate here given prior County precedent. To account for the recent court case, Golden Door Properties v. County of San Diego, Consultant will provide a summary justifying the use of this threshold. Finally, using the results from the plan into ECORP CalEEMod run, Consultant will prepare a GHG section that focuses on the GHG cumulative impacts analysis in their project-specific documentsof the proposed project on climate change. The site has been utilized as agricultural land and a residence since its original development prior to 1939. Based on guidance provided the historic usage of the site as an orchard, there is potential for residual pesticide levels to existing in the City’s GGRPshallow soils. A Phase I Environmental Site Assessment has been prepared for the project (Xxxxxxxx Consulting 2015). Consultant will summarize the key findings of this study related to historic and current site use as a cattle grazing operation, a project-specific environmental document that relies on the GGRP for its cumulative impacts analysis must identify specific GGRP measures applicable to the projectincluding: Recognized Environmental Concerns (RECs), aboveground storage tanks, abandoned xxxxx, asbestos, and how lead. The EIR will incorporate the project incorporates the measures. As suchfindings of these studies in a CEQA context, the GHG analysis for the proposed project would include a demonstration of the project’s compliance with the GGRP. Furthermore, the project’s GHG emissions will also be discussed with respect to the goals and recommended actions of the State’s Climate Change Scoping Plan and other applicable state regulations. If it is determined that the project would need to include design features/identifying mitigation measures to reduce GHG emissionswhere appropriate. In the Phase I ESA, ESA will work with Xxxxxxxx Consulting recommended the Applicant team to identify all applicable measurespreparation of a Limited Phase II Subsurface Investigation. Consultant can prepare the Phase II Subsurface Investigation as outlined under Subtask 4.1.