App F - GHG Analysis ASMBLDAppendix F:
Greenhouse Gas Analysis
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Greenhouse Gas Analysis
The Terrace Apartments
City of Orange, Orange County, California
Prepared for:
City of Orange
Planning Division
300 East Chapman Avenue
Orange, CA 92866
714.744.5525
Contact: Robert Garcia, Senior Planner
Prepared by:
FirstCarbon Solutions
250 Commerce, Suite 250
Irvine, CA 92602
714.508.4100
Contact: Jason Brandman, Project Director
Vanessa Welsh, Project Manager
Date: September 13, 2018
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Table of Contents
Acronyms and Abbreviations ......................................................................................................... v
Section 1: Executive Summary ....................................................................................................... 1
1.1 - Purpose and Methods of Analysis ..................................................................................... 1
1.2 - Project Description ............................................................................................................ 1
1.3 - Summary of Analysis Results ............................................................................................. 1
1.4 - Mitigation Measures Applied to the Project ..................................................................... 2
Section 2: Climate Change Setting .................................................................................................. 9
2.1 - Climate Change .................................................................................................................. 9
2.2 - Greenhouse Gases ........................................................................................................... 11
2.3 - Emissions Inventories ...................................................................................................... 14
2.4 - Regulatory Setting ........................................................................................................... 16
Section 3: Modeling Parameters and Assumptions ....................................................................... 37
3.1 - Model Selection and Guidance ....................................................................................... 37
3.2 - Construction .................................................................................................................... 37
3.3 - Operation ........................................................................................................................ 38
Section 4: Thresholds of Significance ............................................................................................ 41
4.1 - Threshold of Significance ................................................................................................ 41
Section 5: Greenhouse Gas Impact Analysis ................................................................................. 45
5.1 - CEQA Guidelines .............................................................................................................. 45
5.2 - Impact Analysis ................................................................................................................ 45
Section 6: References ................................................................................................................... 53
Appendix A: CalEEMod Output
List of Tables
Table 1: Description of Greenhouse Gases ........................................................................................... 12
Table 2: Conceptual Construction Schedule ......................................................................................... 38
Table 3: Estimated Construction-Related Greenhouse Gas Emissions ................................................. 45
Table 4: Operational Greenhouse Gas Emissions ................................................................................. 46
Table 5: Scoping Plan Measures Consistency Analysis ......................................................................... 48
Table 6: Consistency with SB 32 2017 Scoping Plan Update ................................................................ 51
List of Exhibits
Exhibit 1: Regional Location Map ........................................................................................................... 3
Exhibit 2: Local Vicinity Map ................................................................................................................... 5
Exhibit 3: Site Plan .................................................................................................................................. 7
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List of Figures
Figure 1: Observed and Projected Temperatures for Climate Change in Orange County .................... 10
Figure 2: Greenhouse Gas Emissions Trends ........................................................................................ 15
Figure 3: 2016 California Greenhouse Gas Emissions by Sector .......................................................... 16
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ACRONYMS AND ABBREVIATIONS
°C Celsius
°F Fahrenheit
µg/m3 micrograms per cubic meter
AB Assembly Bill
ARB California Air Resources Board
CalEEMod California Emissions Estimator Model
COP Conference of the Parties
BAU Business as Usual
CEQA California Environmental Quality Act
CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
EPA United States Environmental Protection Agency
GHG greenhouse gas
IPCC United Nations Intergovernmental Panel on Climate Change
lbs/MWh pounds per megawatt hour
LEED Leadership in Energy and Environmental Design
MMT million metric tons
MT metric tons
NHTSA National Highway Traffic Safety Administration
NDC nationally determined contributions
N2O nitrous oxide
NF3 nitrogen trifluoride
NOX nitrogen oxides
ppm parts per million
PRC Public Resources Code
SB Senate Bill
SCS Sustainable Communities Strategy
SP service populations
SCAQMD South Coast Air Quality Management District
ZEV Zero emission vehicle
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SECTION 1: EXECUTIVE SUMMARY
1.1 - Purpose and Methods of Analysis
The following greenhouse gas (GHG) analysis was prepared to evaluate whether the estimated GHG
emissions generated from the Terrace Apartments (project) would cause significant impacts to
climate change. This assessment was conducted within the context of the California Environmental
Quality Act (CEQA, California Public Resources Code [PRC] Sections 21000, et seq.). GHG emissions
are evaluated in comparison to targets for local governments suggested in the California Air
Resources Board’s (ARB) Assembly Bill (AB) 32 Scoping Plan (the Scoping Plan). The analysis will
demonstrate consistency with AB 32 reduction targets. The methodology follows City of Orange and
South Coast Air Quality Management District (SCAQMD) draft recommendations for analyzing the
significance of GHG emissions.
1.2 - Project Description
The project involves the redevelopment of 3.3 acres of the existing 16.9-acre multi-family apartment
community. The project proposes to construct an additional three multi-family apartment buildings
as part of the existing Terrace Apartments. The project would add three, 4-story multi-family
apartment buildings, resulting in 177,616 square feet of additional floor area and 167 additional
apartment units. The existing buildings on-site would remain for a total of 608 dwelling units on the
site. Currently, there are 821 existing parking stalls. Construction of the project would remove and
replace 93 stalls and add 329 parking stalls for a total of 422 additional parking stalls. There will be
three subterranean parking structures constructed beneath each of the proposed buildings and the
existing clubhouse courtyard will be converted to a surface parking lot.
The redevelopment will also support a fire lane realignment, on-site fire hydrant relocations, and
new fire department connections. Post-development conditions will mimic the pre-development
conditions, where most of the 3.3-acre project site will consist of impervious building roof area,
asphalt pavement for parking stalls and fire lanes, and decorative landscape area.
The project lies within the South Coast Air Basin. The project’s regional vicinity location is shown in
Exhibit 1. An aerial view of the local vicinity is provided in Exhibit 2, and the site plan design is
provided in Exhibit 3. Detailed construction and operational activity along with analysis assumptions
are provided in Section 3, Modeling Parameters and Assumptions.
1.3 - Summary of Analysis Results
Impact GHG-1: The project would not generate direct and indirect greenhouse gas emissions that
would result in a significant impact on the environment. Less than significant
impact.
Impact GHG-2: The project would not conflict with any applicable plan, policy or regulation of an
agency adopted to reduce the emissions of greenhouse gases. Less than significant
impact.
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1.4 - Mitigation Measures Applied to the Project
No mitigation measures beyond compliance with mandatory regulations were required to
demonstrate that the project would have less than significant GHG impacts.
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Exhibit 1Regiona l Loca tion Ma p
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Project Site
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CITY OF ORANGE • THE TERRACE APARTMENTS GREENHOUSE GAS ANALYSIS50230001 • 09/2018 | 1_regiona l.mxd
Project Site
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50230001 • 09/2018 | 2_loca l_vicinity.mxd
Exhibit 2Loca l Vicinity Ma p
Source: ESRI Ima gery
CITY OF ORANGE • THE TERRACE APARTMENTS GREENHOUSE GAS ANALYSIS
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Source: VAN TILBURG, BANVARD & SODERBERGH, AIA, May 2018.I50230001 • 09/2018 | 3_siteplan.cdr
Exhibit 3
Site Plan
CITY OF ORANGE • THE TERRACE APARTMENTS
GREENHOUSE GAS ANALYSIS
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SECTION 2: CLIMATE CHANGE SETTING
2.1 ‐ Climate Change
Climate change is a change in the average weather of the Earth that is measured by alterations in
wind patterns, storms, precipitation, and temperature. These changes are assessed using historical
records of temperature changes occurring in the past, such as during previous ice ages. This data is
used to extrapolate a level of statistical significance specifically focusing on temperature records
from the last 150 years (the Industrial Age) that differ from previous climate changes in rate and
magnitude.
The United Nations (UN) Intergovernmental Panel on Climate Change (IPCC) constructed several
emission trajectories of GHGs needed to stabilize global temperatures and climate change impacts.
In the IPCC Fourth Assessment Report (AR4), the IPCC predicted that the global mean temperature
changes from 1990 to 2100, given six scenarios, could range from 1.1 degrees Celsius (°C) to 6.4°C.
Regardless of analytical methodology, global average temperatures and sea levels are expected to
rise under all scenarios (IPCC 2007a). The report also concluded that “[w]arming of the climate
system is unequivocal,” and that “[m]ost of the observed increase in global average temperatures
since the mid‐20th century is very likely due to the observed increase in anthropogenic greenhouse
gas concentrations.”
An individual project cannot generate a large amount of GHG emissions to affect a significant change
in global climate. However, the project participates in the potential for global climate change by its
incremental contribution of GHGs combined with the cumulative increase of all other sources of
GHGs, which when taken together constitute potential influences on global climate change.
2.1.1 ‐ Consequences of Climate Change in California
In California, climate change may result in consequences such as the following (California Climate
Change Center [CCCC] 2006; Moser et al. 2009):
A reduction in the quality and supply of water from the Sierra snowpack. If heat‐trapping
emissions continue unabated, more precipitation will fall as rain instead of snow, and the
snow that does fall will melt earlier, reducing the Sierra Nevada spring snowpack by as much
as 70 to 90 percent. This can lead to challenges in securing adequate water supplies, as well
as a potential reduction in hydropower.
Increased risk of large wildfires. If rain increases as temperatures rise, wildfires in the
grasslands and chaparral ecosystems of Southern California are estimated to increase by
approximately 30 percent toward the end of the 21st century because more winter rain will
stimulate the growth of more plant “fuel” available to burn in the fall. In contrast, a hotter,
drier climate could promote up to 90 percent more Northern California fires by the end of the
century by drying out and increasing the flammability of forest vegetation.
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• Reductions in the quality and quantity of certain agricultural products. The crops and
products likely to be adversely affected include wine grapes, fruit, nuts, and milk.
• Exacerbation of air quality problems. If temperatures rise to the medium warming range,
there could be 75 to 85 percent more days with weather conducive to ozone formation in Los
Angeles and the San Joaquin Valley, relative to today’s conditions. This is more than twice the
increase expected if rising temperatures remain in the lower warming range. This increase in
air quality problems could result in an increase in asthma and other health-related problems.
• A rise in sea levels resulting in the displacement of coastal businesses and residences. During
the past century, sea levels along California’s coast have risen about 7 inches. If emissions
continue unabated and temperatures rise into the higher anticipated warming range, sea level is
expected to rise an additional 22 to 35 inches by the end of the century. Elevations of this
magnitude would inundate coastal areas with salt water, accelerate coastal erosion, threaten
vital levees and inland water systems, and disrupt wetlands and natural habitats.
• An increase in temperature and extreme weather events. Climate change is expected to lead
to increases in the frequency, intensity, and duration of extreme heat events and heat waves
in California. More heat waves can exacerbate chronic disease or heat-related illness.
• A decrease in the health and productivity of California’s forests. Climate change can cause an
increase in wildfires, an enhanced insect population, and establishment of non-native species.
2.1.2 - Consequences of Climate Change in the City of Orange Area
Figure 1 displays a chart of measured historical and projected annual average temperatures in the
City of Orange area. As shown in the figure, temperatures are expected to rise in the low and high
GHG emissions scenarios. The results indicate that temperatures are predicted to increase by 3.5
degrees Fahrenheit (°F) under the low-emissions scenario, and 6.0°F under the high emissions
scenario (Cal Adapt 2016).
Figure 1: Observed and Projected Temperatures for Climate Change in Orange County
Source: CalAdapt 2016.
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2.1.3 - Human Health Effects of GHG Emissions
GHG emissions from development projects would not result in concentrations that would directly
impact public health. However, the cumulative effects of GHG emissions on climate change have the
potential to cause adverse effects to human health.
In its report, Global Climate Change Impacts in the U.S. (2009), the US Global Change Research
Program analyzed the degree to which the effects on human health are expected to impact the
United States.
Potential effects of climate change on public health include:
• Direct Temperature Effects: Climate change may directly affect human health through
increases in average temperatures, which are predicted to increase the incidence of heat
waves and hot extremes.
• Extreme Events: Climate change may affect the frequency and severity of extreme weather
events, such as hurricanes and extreme heat and floods, which can be destructive to human
health and well-being.
• Climate—Sensitive Diseases: Climate change may increase the risk of some infectious
diseases, particularly those diseases that appear in warm areas and are spread by mosquitoes
and other insects, such as malaria, dengue fever, yellow fever, and encephalitis.
• Air Quality: Respiratory disorders may be exacerbated by warming-included increases in the
frequency of smog (ground-level ozone) events and particulate air pollution (United States
Environmental Protection Agency [EPA] 2009a).
Although there could be health effects resulting from changes in the climate and the consequences
that can occur, inhalation of GHGs at levels currently in the atmosphere would not result in adverse
health effects, with the exception of ozone and aerosols (particulate matter). The potential health
effects of ozone and particulate matter are discussed in criteria pollutant analyses. At very high
indoor concentrations (not at levels existing outside), carbon dioxide (CO2), methane (CH4), sulfur
hexafluoride, and some chlorofluorocarbons can cause suffocation as the gases can displace oxygen
(Center for Disease Control [CDC] 2010 and Occupational Safety and Health Administration [OSHA]
2003).
2.2 - Greenhouse Gases
Gases that trap heat in the atmosphere are GHGs. The effect is analogous to the way a greenhouse
retains heat. Common GHGs include water vapor, CO2, CH4, nitrous oxides (N2O),
chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, ozone, and
aerosols. Natural processes and human activities emit GHGs. The presence of GHGs in the
atmosphere affects the Earth’s temperature. Emissions from human activities, such as electricity
production and vehicle use, have likely elevated the concentration of some of these gases in the
atmosphere beyond the level of naturally occurring concentrations.
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Climate change is driven by forcings and feedbacks. Radiative forcing is the difference between the
incoming energy and outgoing energy in the climate system. Positive forcing tends to warm the
surface while negative forcing tends to cool it. Radiative forcing values are typically expressed in
watts per square meter. A feedback is a climate process that can strengthen or weaken a forcing.
For example, when ice or snow melts, it reveals darker land underneath that absorbs more radiation
and causes more warming.
The global warming potential is the potential of a gas or aerosol to trap heat in the atmosphere.
Individual GHG compounds have varying global warming potential and atmospheric lifetimes. The
global warming potential of a GHG is a measure of how much a given mass of a GHG contributes to
global warming. Essentially, the global warming potential of a GHG is a measurement of the radiative
forcing of that GHG compared with the reference gas, CO2, which has a global warming potential of 1.
To describe how much global warming a given type and amount of GHG may cause, the carbon
dioxide equivalent (CO2e) is used. The calculation of the CO2e is a consistent methodology for
comparing GHG emissions since it normalizes various GHG emissions to a consistent reference gas
(CO2). For example, methane’s warming potential of 21 indicates that CH4 has 21 times greater
warming affect than CO2 on a molecule per molecule basis. A CO2e is a mass emission of an
individual GHG multiplied by its global warming potential.
GHGs defined by AB 32 (see the Climate Change Regulatory Environment section for a description)
include CO2, CH4, N2O, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride are described
in Table 1. The global warming potential amounts are from the IPCC Second Assessment Report.
The IPCC Fourth Assessment Report AR4 introduced updated global warming potentials; however,
the new amounts have not been used in order to remain consistent with the amounts used to
develop the ARB Scoping Plan.
Table 1: Description of Greenhouse Gases
Greenhouse Gas Description and Physical Properties Sources
Nitrous oxide
(N2O)
Nitrous oxide is a colorless GHG and
has a lifetime of 114 years. Its global
warming potential is 310. (Its current
global warming potential is 298.)
Microbial processes in soil and water, fuel
combustion, and industrial processes.
Methane
(CH4)
Methane is a flammable gas and is the
main component of natural gas. It has
a lifetime of 12 years. Its global
warming potential is 21. (Its current
global warming potential is 25.)
Methane is extracted from geological
deposits (natural gas fields). Other
sources are landfills, fermentation of
manure, and decay of organic matter.
Carbon dioxide
(CO2)
Carbon dioxide is an odorless,
colorless, natural GHG. Carbon
dioxide’s global warming potential is 1.
The concentration in 2005 was 379
parts per million (ppm), which is an
increase of about 1.4 ppm per year
since 1960.
Natural sources include decomposition of
dead organic matter; respiration of
bacteria, plants, animals, and fungus;
evaporation from oceans; and volcanic
outgassing. Anthropogenic sources are
from burning coal, oil, natural gas, and
wood.
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Table 1 (cont.): Description of Greenhouse Gases
Greenhouse Gas Description and Physical Properties Sources
Chlorofluorocarbons Chlorofluorocarbons are gases formed
synthetically by replacing all hydrogen
atoms in CH4 or ethane with chlorine
and/or fluorine atoms. They are non-
toxic, non-flammable, insoluble, and
chemically unreactive in the
troposphere (the level of air at the
Earth’s surface). Global warming
potentials range from 3,800 to 8,100.
Chlorofluorocarbons were synthesized in
1928 for use as refrigerants, aerosol
propellants, and cleaning solvents. They
destroy stratospheric ozone. The 1987
Montreal Protocol on Substances that
Deplete the Ozone Layer prohibited their
production.
Hydrofluorocarbons Hydrofluorocarbons are a group of
GHGs containing carbon, chlorine, and
at least one hydrogen atom. Global
warming potentials range from 140 to
11,700.
Hydrofluorocarbons are synthetic man-
made chemicals used as a substitute for
chlorofluorocarbons in applications such
as automobile air conditioners and
refrigerants.
Perfluorocarbons Perfluorocarbons have stable
molecular structures and only break
down by ultraviolet rays about 60
kilometers above Earth’s surface.
Because of this, they have long
lifetimes, between 10,000 and 50,000
years. Global warming potentials
range from 6,500 to 9,200.
Two main sources of perfluorocarbons are
primary aluminum production and
semiconductor manufacturing.
Sulfur hexafluoride Sulfur hexafluoride is an inorganic,
odorless, colorless, and nontoxic,
nonflammable gas. It has a lifetime of
3,200 years. It has a high global
warming potential, 23,900.
This gas is man-made and used for
insulation in electric power transmission
equipment, in the magnesium industry, in
semiconductor manufacturing, and as a
tracer gas.
Sources: Compiled from a variety of sources, primarily IPCC 2007a and 2007b.
Other GHGs include water vapor, ozone, and aerosols. Water vapor is an important component of
our climate system and is not regulated. Ozone and aerosols are short-lived GHGs; global warming
potentials for short-lived GHGs are not defined by the IPCC. Aerosols can remain suspended in the
atmosphere for approximately a week and can warm the atmosphere by absorbing heat and cool the
atmosphere by reflecting light.
Black carbon is formed by incomplete combustion of fossil fuels, biofuels, and biomass. Sources of
black carbon within a jurisdiction may include exhaust from diesel trucks, vehicles, and equipment,
as well as smoke from biogenic combustion. Biogenic combustion sources of black carbon include
the burning of biofuels used for transportation, the burning of biomass for electricity generation and
heating, the prescribed burning of agricultural residue, and natural and unnatural wildfires. Black
carbon is not a gas but an aerosol, which is made up of particles or liquid droplets suspended in air.
Black carbon only remains in the atmosphere for days to weeks, as opposed to other GHGs that can
remain in the atmosphere for years. When black carbon deposits on snow it absorbs sunlight,
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reduces sunlight reflectivity, and hastens snowmelt. Direct effects of black carbon include absorbing
incoming and outgoing radiation; indirectly, it can also affect cloud reflectivity, precipitation, and
surface dimming (cooling).
The project would emit black carbon through emissions of diesel particulate matter) during
construction. However, procedures to quantify changes due to black carbon emissions have not been
widely accepted or thoroughly researched (IPCC 2007; Wilson and Walters 2012). Therefore, impacts
to climate change from black carbon are speculative at this time and no further discussion is necessary.
Although there could be health effects resulting from changes in the climate and the consequences
that it can bring about, inhalation of GHGs at levels currently in the atmosphere would not result in
adverse health effects, with the exception of ozone and aerosols (particulate matter). The potential
health effects of ozone and particulate matter are discussed in criteria pollutant analyses. At very
high indoor concentrations (not at levels existing outside), CO2, CH4, sulfur hexafluoride, and some
chlorofluorocarbons can cause suffocation as the gases can displace oxygen (CDC 2010; OSHA 2003).
2.3 - Emissions Inventories
2.3.1 - U.S. GHG Inventory
Total U.S. GHG emissions were approximately 1 percent higher in 2014 than in 2013 (EPA 2016).
Figure 2 presents 2014 U.S. GHG emissions by economic sector.
Total U.S. GHG emissions increased by 7.4 percent from 1990 to 2014 (from 6,233.2 million metric
tons [MMT] CO2e in 1990 to 6,870.5 MMT CO2e in 2014). Since 1990, U.S. emissions have increased
at an average annual rate of 0.3 percent. In 2014, cool winter conditions led to an increase in CO2e
emissions associated with fuels used for heating in the residential and commercial sectors.
Transportation emissions also increased because of a small increase in vehicle miles traveled. There
was also an increase in industrial production across multiple sectors, resulting in slight increases in
industrial-sector emissions (EPA 2016).
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Figure 2: Greenhouse Gas Emissions Trends
Source: EPA 2016
Note: Emissions shown do not include carbon sinks such as change in land uses and forestry.
2.3.2 - U.S. GHG Inventory
As the second largest emitter of GHGs in the U.S. and the 12th to 16th largest GHG emitter in the
world, California contributes a large quantity of GHGs to the atmosphere (CEC 2006). Emissions of
CO2 are byproducts of fossil-fuel combustion and are attributable in large part to human activities
associated with transportation, industry/manufacturing, electricity and natural gas consumption,
and agriculture (ARB 2016a and 2016b). In California, the transportation sector is the largest emitter
of GHGs, followed by industry/manufacturing (ARB 2018) (Figure 3).
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Figure 3: 2016 California Greenhouse Gas Emissions by Sector
Sources: ARB 2018
2.4 - Regulatory Setting
2.4.1 - International
Climate change is a global issue involving GHG emissions from all around the world; therefore,
countries such as the ones discussed below have made an effort to reduce GHGs.
Intergovernmental Panel on Climate Change. In 1988, the UN and the World Meteorological
Organization established the IPCC to assess the scientific, technical, and socio-economic information
relevant to understanding the scientific basis of risk of human-induced climate change, its potential
impacts, and options for adaptation and mitigation.
United Nations Framework Convention on Climate Change (Convention). Cap-and-trade refers to a
policy tool where emissions are limited to a certain amount and can be traded, or provides flexibility
on how the emitter can comply. Each emitter caps CO2 emissions from power plants, auctions CO2
emission allowances, and invests the proceeds in strategic energy programs that further reduce
emissions, saves consumers money, creates jobs, and builds a clean energy economy. The Western
Climate Initiative partner jurisdictions have developed a comprehensive initiative to reduce North
America GHG emissions to 15 percent below 2005 levels by 2020. The partners are California, British
Columbia, Manitoba, Ontario, and Quebec. Currently, only California and Quebec are participating
in the Cap-and-Trade Program (C2ES 2015a).
Kyoto Protocol. The Kyoto Protocol is an international agreement linked to the UN Framework
Convention on Climate Change. The major feature of the Kyoto Protocol is that it sets binding
targets for 37 industrialized countries and the European community for reducing GHG emissions at
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an average of five percent against 1990 levels over the 5-year period from 2008–2012. The
Convention (as discussed above) encouraged industrialized countries to stabilize emissions; however,
the Protocol commits them to do so. Developed countries have contributed more emissions over
the last 150 years; therefore, the Protocol places a heavier burden on developed nations under the
principle of “common but differentiated responsibilities.”
In 2001, President George W. Bush indicated that he would not submit the treaty to the U.S. Senate
for ratification, which effectively ended U.S. involvement in the Kyoto Protocol. In December 2009,
international leaders met in Copenhagen to address the future of international climate change
commitments post-Kyoto. No binding agreement was reached in Copenhagen; however, the
Committee identified the long-term goal of limiting the maximum global average temperature
increase to no more than 2°C above pre-industrial levels, subject to a review in 2015. The UN
Climate Change Committee held additional meetings in Durban, South Africa in November 2011;
Doha, Qatar in November 2012; and Warsaw, Poland in November 2013. The meetings are gradually
gaining consensus among participants on individual climate change issues.
On September 23, 2014, more than 100 heads of State and government, and leaders from the
private sector and civil society met at the Climate Summit in New York hosted by the UN. At the
Summit, heads of government, business, and civil society announced actions in areas that would
have the greatest impact on reducing emissions, including climate, finance, energy, transport,
industry, agriculture, cities, forests, and building resilience.
Paris Climate Change Agreement. Parties to the UN Framework Convention on Climate Change
(UNFCCC) reached a landmark agreement on December 12, 2015 in Paris, charting a fundamentally
new course in the 20-year global climate effort. Culminating as the result of a 4-year negotiating
round, the new treaty ends the strict differentiation between developed and developing countries
that characterized earlier efforts, replacing it with a common framework that commits all countries
to put forward their best efforts and to strengthen them in the years ahead. This includes, for the
first time, requirements that all parties report regularly on their emissions and implementation
efforts, and undergo international review.
The agreement and a companion decision by parties were the key outcomes of the conference,
known as the 21st Session of the UNFCCC Conference of the Parties, or COP 21. Together, the Paris
Agreement and the accompanying COP 21 decision:
• Reaffirm the goal of limiting global temperature increase well below 2°C, while urging efforts
to limit the increase to 1.5 °C;
• Establish binding commitments by all parties to make “nationally determined contributions”
(NDCs), and to pursue domestic measures aimed at achieving them;
• Commit all countries to report regularly on their emissions and “progress made in
implementing and achieving” their NDCs, and to undergo international review;
• Commit all countries to submit new NDCs every five years, with the clear expectation that
they will “represent a progression” beyond previous ones;
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• Reaffirm the binding obligations of developed countries under the UNFCCC to support the
efforts of developing countries, while for the first time also encouraging voluntary
contributions by developing countries;
• Extend the current goal of mobilizing $100 billion a year in support by 2020 through 2025,
with a new, higher goal to be set for the period after 2025;
• Extend a mechanism to address “loss and damage” resulting from climate change, which
explicitly will not “involve or provide a basis for any liability or compensation;”
• Require parties engaging in international emissions trading to avoid “double counting;” and
• Call for a new mechanism, similar to the Clean Development Mechanism under the Kyoto
Protocol, enabling emission reductions in one country to be counted toward another country’s
NDC (C2ES 2015b).
On June 1, 2017, President Trump announced the decision for the United States to withdraw from
the Paris Climate Accord (White House 2017). California remains committed to combating climate
change through programs aimed to reduce GHGs (ARB 2017).
2.4.2 - Federal
GHG Endangerment. Massachusetts v. EPA (Supreme Court Case 05-1120) was argued before the U.S.
Supreme Court on November 29, 2006, in which it was petitioned that the EPA regulate four GHGs,
including CO2, under Section 202(a)(1) of the Clean Air Act (CAA). A decision was made on April 2,
2007, in which the Supreme Court found that GHGs are air pollutants covered by the CAA. The Court
held that the Administrator must determine whether emissions of GHGs from new motor vehicles
cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or
welfare, or whether the science is too uncertain to make a reasoned decision. On December 7, 2009,
the EPA Administrator signed two distinct findings regarding GHGs under Section 202(a) of the CAA:
• Endangerment Finding: The Administrator finds that the current and projected concentrations
of the six key well-mixed GHGs—CO2, CH4, N2O, HFCs, PFCs, and SF6—in the atmosphere
threaten the public health and welfare of current and future generations; and
• Cause or Contribute Finding: The Administrator finds that the combined emissions of these
well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the
GHG pollution, which threatens public health and welfare.
These findings do not impose requirements on industry or other entities. However, this was a
prerequisite for implementing GHG emissions standards for vehicles, as discussed under “Clean
Vehicles” below. After a lengthy legal challenge, the U.S. Supreme Court declined to review an
Appeals Court ruling upholding that upheld the EPA Administrator findings.
Consolidated Appropriations Act (Mandatory GHG Reporting). The Consolidated Appropriations Act
of 2008, passed in December 2007, requires the establishment of mandatory GHG reporting
requirements. On September 22, 2009, the EPA issued the Final Mandatory Reporting of Greenhouse
Gases Rule, which became effective January 1, 2010. The rule requires reporting of GHG emissions
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from large sources and suppliers in the U.S., and is intended to collect accurate and timely emissions
data to inform future policy decisions. Under the rule, suppliers of fossil fuels or industrial GHGs,
manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of
GHG emissions are required to submit annual reports to the EPA. The first annual reports for the
largest emitting facilities, covering calendar year 2010, were submitted to the EPA in 2011.
Clean Air Act Permitting Programs (New GHG Source Review). The EPA issued a final rule on May
13, 2010 that establishes thresholds for GHGs that define when permits under the New Source
Review Prevention of Significant Deterioration and Title V Operating Permit programs are required
for new and existing industrial facilities. This final rule “tailors” the requirements of these CAA
permitting programs to limit which facilities will be required to obtain Prevention of Significant
Deterioration and Title V permits. In the preamble to the revisions to the federal code of
regulations, the EPA states:
This rulemaking is necessary because without it the Prevention of Significant
Deterioration and Title V requirements would apply, as of January 2, 2011, at the
100 or 250 tons per year levels provided under the Clean Air Act, greatly increasing
the number of required permits, imposing undue costs on small sources,
overwhelming the resources of permitting authorities, and severely impairing the
functioning of the programs. EPA is relieving these resource burdens by phasing in
the applicability of these programs to greenhouse gas sources, starting with the
largest greenhouse gas emitters. This rule establishes two initial steps of the phase-
in. The rule also commits the agency to take certain actions on future steps
addressing smaller sources, but excludes certain smaller sources from Prevention of
Significant Deterioration and Title V permitting for greenhouse gas emissions until at
least April 30, 2016.
The EPA estimates that facilities responsible for nearly 70 percent of the national GHG emissions
from stationary sources will be subject to permitting requirements under this rule. This includes the
nation’s largest GHG emitters—power plants, refineries, and cement production facilities.
EPA GHG Performance Standards for New Stationary Sources. As required by a settlement
agreement, the EPA proposed new performance standards for emissions of CO2 for new, affected,
fossil fuel-fired electric utility generating units on March 27, 2012. New sources greater than 25-
megawatt would be required to meet an output based standard of 1,000 pounds of CO2 per
megawatt-hour, based on the performance of widely used natural gas combined cycle technology.
Energy Independence and Security Act. The Energy Policy Act of 2005 created the Renewable Fuel
Standard program. The Energy Independence and Security Act of 2007 expanded this program by:
• Expanding the Renewable Fuel Standard program to include diesel in addition to gasoline;
• Increasing the volume of renewable fuel required to be blended into transportation fuel from
9 billion gallons in 2008 to 36 billion gallons by 2022;
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• Establishing new categories of renewable fuel, and setting separate volume requirements for
each one; and
• Requiring EPA to apply life-cycle GHG performance threshold standards to ensure that each
category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.
This expanded Renewable Fuel Standard program lays the foundation for achieving substantial
reductions of GHG emissions from the use of renewable fuels, reducing the use of imported
petroleum, and encouraging the development and expansion of the nation’s renewable-fuels sector.
EPA and National Highway Traffic Safety Administration Light-Duty Vehicle GHG Emission
Standards and Corporate Average Fuel Economy Standards Final Rule. Congress first passed the
Corporate Average Fuel Economy law in 1975 to increase the fuel economy of cars and light-duty
trucks. The law has become more stringent over time. On May 19, 2009, President Obama put in
motion a new national policy to increase fuel economy for all new cars and trucks sold in the U.S. On
April 1, 2010, the EPA and the Department of Transportation’s National Highway Traffic Safety
Administration (NHTSA) announced a joint final rule establishing a national program that would
reduce GHG emissions and improve fuel economy for new cars and trucks sold in the U.S.
The first phase of the national program would apply to passenger cars, light-duty trucks, and
medium-duty passenger vehicles, covering model years 2012 through 2016. These vehicles are
required to meet an estimated combined average emissions level of 250 grams of CO2 per mile,
equivalent to 35.5 miles per gallon if the automobile industry were to meet this CO2 level solely
through fuel economy improvements. Together, these standards would cut CO2 emissions by an
estimated 960 million metric tons and 1.8 billion barrels of oil over the lifetime of the vehicles sold
under the program (model years 2012-2016).
The EPA and the NHTSA issued final rules on a second-phase joint rulemaking, establishing national
standards for light-duty vehicles for model years 2017 through 2025 in August 2012 (EPA 2012). The
new standards for model years 2017 through 2025 apply to passenger cars, light-duty trucks, and
medium-duty passenger vehicles. The final standards are projected to result in an average industry
fleetwide level of 163 grams/mile of CO2 in model year 2025, which is equivalent to 54.5 miles per
gallon (mpg) if achieved exclusively through fuel economy improvements.
Final rules were issued by the EPA and NHTSA for the first national standards to reduce GHG
emissions and improve fuel efficiency of heavy-duty trucks and buses on September 15, 2011, which
became effective November 14, 2011. For combination tractors, the agencies are proposing engine
and vehicle standards that began in the 2014 model year and achieve up to a 20 percent reduction in
CO2 emissions and fuel consumption by the 2018 model year. For heavy-duty pickup trucks and
vans, the agencies are proposing separate gasoline and diesel truck standards, which phase in
starting in the 2014 model year and achieve up to a 10 percent reduction for gasoline vehicles, and a
15 percent reduction for diesel vehicles by 2018 model year (12 and 17 percent respectively if
accounting for air conditioning leakage). Lastly, for vocational vehicles, the engine and vehicle
standards would achieve up to a 10 percent reduction in fuel consumption and CO2 emissions from
the 2014 to 2018 model years.
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The State of California has received a waiver from EPA to have separate, stricter corporate average
fuel economy standards.
2.4.3 - California
California AB 1493: Pavley Regulations and Fuel Efficiency Standards. California AB 1493, enacted
on July 22, 2002, required ARB to develop and adopt regulations that reduce GHGs emitted by
passenger vehicles and light-duty trucks. Implementation of the regulation was delayed by lawsuits
filed by automakers and by the EPA’s denial of an implementation waiver. The EPA subsequently
granted the requested waiver in 2009, which was upheld by the by the U.S. District Court for the
District of Columbia in 2011 (ARB 2013a).
The standards are to be phased in during the 2009 through 2016 model years. When fully phased in,
the near-term (2009–2012) standards will result in an approximately 22 percent reduction compared
with the 2002 fleet, and the mid-term (2013–2016) standards will result in about a 30 percent
reduction. Several technologies stand out as providing significant reductions in emissions at
favorable costs. These include discrete variable valve lift or camless valve actuation to optimize
valve operation rather than relying on fixed valve timing and lift as has historically been done;
turbocharging to boost power and allow for engine downsizing; improved multi-speed
transmissions; and improved air conditioning systems that operate optimally, leak less, and/or use
an alternative refrigerant (ARB 2013b).
The second phase of the implementation for the Pavley Bill was incorporated into Amendments to
the Low-Emission Vehicle Program referred to as LEV III or the Advanced Clean Cars program. The
Advanced Clean Car program combines the control of smog-causing pollutants and GHG emissions
into a single coordinated package of requirements for model years 2017 through 2025. The
regulation will reduce GHGs from new cars by 34 percent from 2016 levels by 2025. The new rules
will reduce pollutants from gasoline and diesel-powered cars, and deliver increasing numbers of
zero-emission technologies, such as full battery electric cars, newly emerging plug-in hybrid electric
vehicles and hydrogen fuel cell cars. The regulations will also ensure adequate fueling infrastructure
is available for the increasing numbers of hydrogen fuel cell vehicles planned for deployment in
California (ARB 2011).
California SB 1078—Renewable Electricity Standards. On September 12, 2002, Governor Gray Davis
signed Senate Bill (SB) 1078, requiring California to generate 20 percent of its electricity from
renewable energy by 2017. SB 107 changed the due date to 2010 instead of 2017. On November
17, 2008, Governor Arnold Schwarzenegger signed Executive Order S-14-08, which established a
Renewable Portfolio Standard target for California requiring that all retail sellers of electricity serve
33 percent of their load with renewable energy by 2020. Governor Schwarzenegger also directed
the ARB (Executive Order S-21-09) to adopt a regulation by July 31, 2010, requiring the State’s load
serving entities to meet a 33 percent renewable energy target by 2020. The ARB Board approved
the Renewable Electricity Standard on September 23, 2010 by Resolution 10-23.
California Executive Order S-3-05. Former California Governor Arnold Schwarzenegger announced
on June 1, 2005, through Executive Order S-3-05, the following reduction targets for GHG emissions:
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• By 2010, reduce GHG emissions to 2000 levels.
• By 2020, reduce GHG emissions to 1990 levels.
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.
The 2050 reduction goal represents what some scientists believe is necessary to reach levels that will
stabilize the climate. The 2020 goal was established to be a mid-term target. Because this is an
executive order, the goals are not legally enforceable for local governments or the private sector.
California AB 32: Global Warming Solutions Act and Scoping Plan. The California State Legislature
enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires that GHGs
emitted in California be reduced to 1990 levels by the year 2020. “Greenhouse gases” as defined
under AB 32 to include CO2, CH4, N2O, HFCs, PFCs, and SF6. Since AB 32 was enacted, a seventh
chemical, nitrogen trifluoride, has also been added to the list of GHGs. ARB is the State agency
charged with monitoring and regulating sources of GHGs. AB 32 states the following:
Global warming poses a serious threat to the economic well-being, public health,
natural resources, and the environment of California. The potential adverse impacts
of global warming include the exacerbation of air quality problems, a reduction in the
quality and supply of water to the state from the Sierra snowpack, a rise in sea levels
resulting in the displacement of thousands of coastal businesses and residences,
damage to marine ecosystems and the natural environment, and an increase in the
incidences of infectious diseases, asthma, and other human health-related problems.
ARB approved the 1990 GHG emissions level of 427 million metric tons of carbon dioxide equivalents
(MMT CO2e) on December 6, 2007 (ARB 2007). Therefore, to meet the State’s target, emissions
generated in California in 2020 are required to be equal to or less than 427 MMT CO2e. Emissions in
2020 in a Business as Usual (BAU) scenario were estimated to be 596 MMT CO2e, which do not account
for reductions from AB 32 regulations (ARB 2008). At that rate, a 28 percent reduction was required to
achieve the 427 MMT CO2e 1990 inventory. In October 2010, ARB prepared an updated 2020 forecast
to account for the effects of the 2008 recession and slower forecasted growth. The 2020 inventory
without the benefits of adopted regulation is now estimated at 545 MMT CO2e. Therefore, under the
updated forecast, a 21.7 percent reduction from BAU is required to achieve 1990 levels (ARB 2010).
The State has made steady progress in implementing AB 32 and achieving targets included in Executive
Order S-3-05. The progress is shown in updated emission inventories prepared by ARB for 2000
through 2012 to show progress achieved to date (ARB 2014a). The State has also achieved the
Executive Order S-3-05 target for 2010 of reducing GHG emissions to 2000 levels. As shown below, the
2010 emission inventory achieved this target. Also shown are the average reductions needed from all
Statewide sources (including all existing sources) to reduce GHG emissions back to 1990 levels.
• 1990: 427 MMT CO2e (AB 32 2020 Target)
• 2000: 463 MMT CO2e (an average 8 percent reduction needed to achieve 1990 base)
• 2010: 450 MMT CO2e (an average 5 percent reduction needed to achieve 1990 base)
• 2020: 545 MMT CO2e BAU (an average 21.7 percent reduction from BAU needed to achieve
1990 base)
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ARB’s Climate Change Scoping Plan (Scoping Plan) contains measures designed to reduce the State’s
emissions to 1990 levels by the year 2020 to comply with AB 32 (ARB 2008). The Scoping Plan
identifies recommended measures for multiple GHG emission sectors and the associated emission
reductions needed to achieve the year 2020 emissions target—each sector has a different emission
reduction target. Most of the measures target the transportation and electricity sectors. As stated
in the Scoping Plan, the key elements of the strategy for achieving the 2020 GHG target include:
• Expanding and strengthening existing energy efficiency programs as well as building and
appliance standards;
• Achieving a Statewide renewables energy mix of 33 percent;
• Developing a California Cap-and-Trade Program that links with other Western Climate
Initiative partner programs to create a regional market system;
• Establishing targets for transportation-related GHG emissions for regions throughout
California and pursuing policies and incentives to achieve those targets;
• Adopting and implementing measures pursuant to existing State laws and policies, including
California’s Clean Car Standards (AB 1493), goods movement measures, and the Low Carbon
Fuel Standard; and
• Creating targeted fees, including a public goods charge on water use, fees on high global
warming potential gases, and a fee to fund the administrative costs of the State’s long-term
commitment to AB 32 implementation.
In addition, the Scoping Plan differentiates between “capped” and “uncapped” strategies. Capped
strategies are subject to the proposed Cap-and-Trade Program. The Scoping Plan states that the
inclusion of these emissions within the Cap-and Trade Program will help ensure that the year 2020
emission targets are met despite some degree of uncertainty in the emission reduction estimates for
any individual measure. Implementation of the capped strategies is calculated to achieve a sufficient
amount of reductions by 2020 in order to achieve the emission target contained in AB 32. Uncapped
strategies that will not be subject to the cap-and-trade emissions caps and requirements are
provided as a margin of safety by accounting for additional GHG emission reductions (ARB 2008).
ARB approved the First Update to the Scoping Plan (Update) on May 22, 2014. The Update identifies
the next steps for California’s climate change strategy. The Update shows how California continues
on its path to meet the near-term 2020 GHG limit, but also sets a path toward long-term, deep GHG
emission reductions. The report establishes a broad framework for continued emission reductions
beyond 2020, on the path to 80 percent below 1990 levels by 2050. The Update identifies progress
made to meet the near-term objectives of AB 32 and defines California’s climate change priorities
and activities for the next several years. The Update does not set new targets for the State, but
describes a path that would achieve the long-term 2050 goal of Executive Order S-05-03 for
emissions to decline to 80 percent below 1990 levels by 2050.
AB 32 does not give ARB a legislative mandate to set a target beyond the 2020 target from AB 32 or
to adopt additional regulations to achieve a post-2020 target. The Update estimates that reductions
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averaging 5.2 percent per year would be required after 2020 to achieve the 2050 goal. With no
estimate of future reduction commitments from the State, identifying a feasible strategy including
plans and measures to be adopted by local agencies is not currently possible (ARB 2014b).
The Cap-and-Trade Program is a key element of the Scoping Plan. It sets a Statewide limit on sources
responsible for 85 percent of California’s GHG emissions, and establishes a price signal needed to
drive long-term investment in cleaner fuels and more efficient use of energy. The program is
designed to provide covered entities the flexibility to seek out and implement the lowest cost
options to reduce emissions. The program conducted its first auction in November 2012.
Compliance obligations began for power plants and large industrial sources in January 2013. Other
significant milestones include linkage to Quebec’s cap-and-trade system in January 2014, and
starting the compliance obligation for distributors of transportation fuels, natural gas, and other
fuels in January 2015 (ARB 2015a).
The Cap-and-Trade Program provides a firm cap, ensuring that the 2020 Statewide emission limit will
not be exceeded. An inherent feature of the Cap-and-Trade Program is that it does not guarantee
GHG emissions reductions in any discrete location or by any particular source. Rather, GHG
emissions reductions are only guaranteed on an accumulative basis. As summarized by ARB in the
First Update (ARB 2014b):
The Cap-and-Trade Regulation gives companies the flexibility to trade allowances
with others or take steps to cost-effectively reduce emissions at their own facilities.
Companies that emit more have to turn in more allowances or other compliance
instruments. Companies that can cut their GHG emissions have to turn in fewer
allowances. But as the cap declines, aggregate emissions must be reduced. In other
words, a covered entity theoretically could increase its GHG emissions every year
and still comply with the Cap-and-Trade Program if there is a reduction in GHG
emissions from other covered entities. Such a focus on aggregate GHG emissions is
considered appropriate because climate change is a global phenomenon, and the
effects of GHG emissions are considered cumulative.
The Cap-and-Trade Program works with other direct regulatory measures and provides an economic
incentive to reduce emissions. If California’s direct regulatory measures reduce GHG emissions more
than expected, then the Cap-and-Trade Program will be responsible for relatively fewer emissions
reductions. If California’s direct regulatory measures reduce GHG emissions less than expected, then
the Cap-and-Trade Program will be responsible for relatively more emissions reductions. Thus, the
Cap-and-Trade Program assures that California will meet its 2020 GHG emissions reduction mandate:
The Cap-and-Trade Program establishes an overall limit on GHG emissions from most
of the California economy—the “capped sectors.” Within the capped sectors, some of
the reductions are being accomplished through direct regulations, such as improved
building and appliance efficiency standards, the [Low Carbon Fuel Standard] LCFS, and
the 33 percent [Renewables Portfolio Standard] RPS. Whatever additional reductions
are needed to bring emissions within the cap is accomplished through price incentives
posed by emissions allowance prices. Together, direct regulation and price incentives
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assure that emissions are brought down cost-effectively to the level of the overall cap.
The Cap-and-Trade Regulation provides assurance that California’s 2020 limit will be
met because the regulation sets a firm limit on 85 percent of California’s GHG
emissions. In sum, the Cap-and-Trade Program will achieve aggregate, rather than site
specific or project-level, GHG emissions reductions. Also, due to the regulatory
architecture adopted by ARB in AB 32, the reductions attributed to the Cap-and-Trade
Program can change over time depending on the State’s emissions forecasts and the
effectiveness of direct regulatory measures.
California SB 375: Sustainable Communities and Climate Protection Act. SB 375 was signed into
law on September 30, 2008. According to SB 375, the transportation sector is the largest contributor
of GHG emissions, which emits over 40 percent of the total GHG emissions in California. SB 375
states, “Without improved land use and transportation policy, California will not be able to achieve
the goals of AB 32.” SB 375 does the following: (1) requires metropolitan planning organizations to
include Sustainable Community Strategy (SCS) in their regional transportation plans for reducing
GHG emissions, (2) aligns planning for transportation and housing, and (3) creates specified
incentives for the implementation of the strategies.
Concerning CEQA, SB 375, as codified in PRC Section 21159.28, states that CEQA findings or
determinations for certain projects are not required to reference, describe, or discuss (1) growth
inducing impacts or (2) any project-specific or cumulative impacts from cars and light-duty truck trips
generated by the project on global warming or the regional transportation network if the project:
1. Is in an area with an approved SCS or an alternative planning strategy that the ARB accepts
as achieving the GHG emission reduction targets;
2. Is consistent with that strategy (in designation, density, building intensity, and applicable
policies); and
3. Incorporates the mitigation measures required by an applicable prior environmental
document.
California SB 1368: Emission Performance Standards. In 2006, the State Legislature adopted SB 1368,
which was subsequently signed into law by the Governor. SB 1368 directs the California Public Utilities
Commission to adopt a performance standard for GHG emissions for the future power purchases of
California utilities. SB 1368 seeks to limit carbon emissions associated with electrical energy consumed
in California by forbidding procurement arrangements for energy longer than 5 years from resources
that exceed the emissions of a relatively clean, combined cycle natural gas power plant. Because of
the carbon content of its fuel source, a coal-fired plant cannot meet this standard because such plants
emit roughly twice as much carbon as natural gas, combined cycle plants. Accordingly, the new law
effectively prevents California’s utilities from investing in, otherwise financially supporting, or
purchasing power from new coal plants located in or out of the State. The California Public Utilities
Commission adopted the regulations required by SB 1368 on August 29, 2007. The regulations
implementing SB 1368 establish a standard for baseload generation owned by, or under long-term
contract to publicly owned utilities, of 1,100 pounds of CO2 per megawatt-hour (MWh).
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California Executive Order S-01-07—Low Carbon Fuel Standard. The Governor signed Executive
Order S 01-07 on January 18, 2007. The order mandates that a Statewide goal shall be established
to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020. In
particular, the executive order established a Low Carbon Fuel Standard (LCFS) and directed the
Secretary for Environmental Protection to coordinate the actions of the California Energy
Commission, the ARB, the University of California, and other agencies to develop and propose
protocols for measuring the “life-cycle carbon intensity” of transportation fuels. This analysis
supporting development of the protocols was included in the State Implementation Plan for
alternative fuels (State Alternative Fuels Plan adopted by California Energy Commission on
December 24, 2007) and was submitted to ARB for consideration as an “early action” item under AB
32. The ARB adopted the LCFS on April 23, 2009.
The LCFS was subject to legal challenge in 2011. Ultimately, on August 8, 2013, the Fifth District
Court of Appeal (California) ruled that ARB failed to comply with CEQA and the Administrative
Procedure Act when adopting regulations for LCFSs. In a partially published opinion, the Court of
Appeals directed that Resolution 09-31 and two executive orders of ARB approving LCFS regulations
promulgated to reduce GHG emissions be set aside. However, the court tailored its remedy to
protect the public interest by allowing the LCFS regulations to remain operative while ARB complies
with the procedural requirements it failed to satisfy.
To address the Court ruling, ARB was required to bring a new LCFS regulation to the Board for
consideration in February 2015. The proposed LCFS regulation was required to contain revisions to
the 2010 LCFS as well as new provisions designed to foster investments in the production of low-
carbon fuels, offer additional flexibility to regulated parties, update critical technical information,
simplify and streamline program operations, and enhance enforcement. The second public hearing
for the new LCFS regulation was held on September 24, 2015, and September 25, 2015, where the
LCFS Regulation was adopted. The final rulemaking package adopting the regulation was filed with
the Office of Administrative Law (OAL) on October 2, 2015. The OAL approved the regulation on
November 16, 2015 (ARB 2015b).
California Executive Order S-13-08. Executive Order S-13-08 states that “climate change in California
during the next century is expected to shift precipitation patterns, accelerate sea level rise and
increase temperatures, thereby posing a serious threat to California’s economy, to the health and
welfare of its population and to its natural resources.” Pursuant to the requirements in the order,
the 2009 California Climate Adaptation Strategy was adopted, which is the “. . . first statewide, multi-
sector, region-specific, and information-based climate change adaptation strategy in the United
States.” Objectives include analyzing risks of climate change in California, identifying and exploring
strategies to adapt to climate change, and specifying a direction for future research.
California SBX 7-7: Water Conservation Act. This 2009 legislation directs urban retail water
suppliers to set individual 2020 per capita water use targets and begin implementing conservation
measures to achieve those goals. Meeting this Statewide goal of a 20 percent decrease in demand
will result in a reduction of almost 2 million acre-feet in urban water use in 2020.
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California SB 350: Clean Energy and Pollution Reduction Act. In 2015, the State legislature
approved and the Governor signed SB 350 which reaffirms California’s commitment to reducing its
GHG emissions and addressing climate change. Key provisions include an increase in the renewables
portfolio standard (RPS), higher energy efficiency requirements for buildings, initial strategies
towards a regional electricity grid, and improved infrastructure for electric vehicle charging stations.
Provisions for a 50 percent reduction in the use of petroleum statewide were removed from the Bill
due to opposition and concern that it would prevent the Bill’s passage. Specifically, SB 350 requires
the following to reduce Statewide GHG emissions (California Leginfo 2015):
• Increase the amount of electricity procured from renewable energy sources from 33 percent
to 50 percent by 2030, with interim targets of 40 percent by 2024, and 25 percent by 2027.
• Double the energy efficiency in existing buildings by 2030. This target will be achieved
through the California Public Utility Commission, the California Energy Commission, and local
publicly owned utilities.
• Reorganize the Independent System Operator to develop more regional electrified
transmission markets and to improve accessibility in these markets, which will facilitate the
growth of renewable energy markets in the western United States.
California Executive Order B-30-15. On April 29, 2015, Governor Edmund G. Brown Jr. issued an
executive order to establish a California GHG reduction target of 40 percent below 1990 levels by
2030. The Governor’s executive order aligns California’s GHG reduction targets with those of leading
international governments ahead of the UN Climate Change Conference in Paris late 2015. The
executive order sets a new interim Statewide GHG emission reduction target to reduce GHG
emissions to 40 percent below 1990 levels by 2030 in order to ensure California meets its target of
reducing GHG emissions to 80 percent below 1990 levels by 2050, and directs the ARB to update the
Climate Change Scoping Plan to express the 2030 target in terms of MMCO2e. The executive order
also requires the State’s climate adaptation plan to be updated every three years and for the State to
continue its climate change research program, among other provisions. As with Executive Order S-3-
05, this executive order is not legally enforceable against local governments and the private sector.
Senate Bill 32. The Governor signed SB 32 in September of 2016, giving ARB the statutory
responsibility to include the 2030 target previously contained in Executive Order B-30-15 in the 2017
Scoping Plan Update. SB 32 states that “In adopting rules and regulations to achieve the maximum
technologically feasible and cost-effective greenhouse gas emissions reductions authorized by this
division, the state [air resources] board shall ensure that statewide greenhouse gas emissions are
reduced to at least 40 percent below the statewide greenhouse gas emissions limit no later than
December 31, 2030.” The 2017 Climate Change Scoping Plan Update addressing the SB 32 targets
was adopted on December 14, 2017. The major elements of the framework proposed to achieve the
2030 target are as follows:
1. SB 350
• Achieve 50 percent RPS by 2030.
• Doubling of energy efficiency savings by 2030.
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2. Low Carbon Fuel Standard (LCFS)
• Increased stringency (reducing carbon intensity 18 percent by 2030, up from 10 percent
in 2020).
3. Mobile Source Strategy (Cleaner Technology and Fuels Scenario)
• Maintaining existing GHG standards for light- and heavy-duty vehicles.
• Put 4.2 million zero-emission vehicles (ZEVs) on the roads.
• Increase ZEV buses, delivery and other trucks.
4. Sustainable Freight Action Plan
• Improve freight system efficiency.
• Maximize use of near-zero emission vehicles and equipment powered by renewable
energy.
• Deploy over 100,000 zero-emission trucks and equipment by 2030.
5. Short-Lived Climate Pollutant (SLCP) Reduction Strategy
• Reduce emissions of methane and hydrofluorocarbons 40 percent below 2013 levels by
2030.
• Reduce emissions of black carbon 50 percent below 2013 levels by 2030.
6. SB 375 Sustainable Communities Strategies
• Increased stringency of 2035 targets.
7. Post-2020 Cap-and-Trade Program
• Declining caps, continued linkage with Québec, and linkage to Ontario, Canada.
• ARB will look for opportunities to strengthen the program to support more air quality
co-benefits, including specific program design elements. In Fall 2016, ARB staff
described potential future amendments including reducing the offset usage limit,
redesigning the allocation strategy to reduce free allocation to support increased
technology and energy investment at covered entities and reducing allocation if the
covered entity increases criteria or toxics emissions over some baseline.
8. 20 percent reduction in GHG emissions from the refinery sector.
9. By 2018, develop Integrated Natural and Working Lands Action Plan to secure California’s
land base as a net carbon sink.
California Code of Regulations Title 20: Appliance Efficiency Regulations. California Code of
Regulations (CCR), Title 20: Division 2, Chapter 4, Article 4, Sections 1601-1608: Appliance Efficiency
Regulations regulates the sale of appliances in California. The Appliance Efficiency Regulations
include standards for both federally regulated appliances and non-federally regulated appliances.
Included in the scope of these regulations are 23 categories of appliances. The standards within
these regulations apply to appliances that are sold or offered for sale in California, except those sold
wholesale in California for final retail sale outside the State and those designed and sold exclusively
for use in recreational vehicles or other mobile equipment (CEC 2012).
California Code of Regulations Title 24: Energy Efficiency Standards. CCR Title 24 Part 6: California’s
Energy Efficiency Standards for Residential and Nonresidential Buildings, was first adopted in 1978 in
response to a legislative mandate to reduce California’s energy consumption. The standards are
updated periodically to allow consideration and possible incorporation of new energy efficient
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technologies and methods. Energy efficient buildings require less electricity; therefore, increased
energy efficiency reduces fossil fuel consumption and decreases GHG emissions. The 2016 Building
Energy Efficiency Standards went into effect on January 1, 2017 (CEC 2016).
California Code of Regulations Title 24: California Green Building Standards Code. CCR Title 24,
Part 11 code, is a comprehensive and uniform regulatory code for all residential, commercial, and
school buildings that went in effect January 1, 2011. The code is updated on a regular basis, with the
most recent update consisting of the 2016 California Green Building Code Standards that became
effective January 1, 2017. Local jurisdictions are permitted to adopt more stringent requirements, as
State law provides methods for local enhancements. The Code recognizes that many jurisdictions
have developed existing construction and demolition ordinances, and defers to them as the ruling
guidance provided they provide a minimum 50-percent diversion requirement. The code also
provides exemptions for areas not served by construction and demolition recycling infrastructure.
State building code provides the minimum standard that buildings need to meet in order to be
certified for occupancy, which is generally enforced by the local building official.
The California Green Building Standards Code (CCR Title 24, Part 11 code) requires:
• Short-term bicycle parking. If a commercial project is anticipated to generate visitor traffic,
provide permanently anchored bicycle racks within 200 feet of the visitors’ entrance, readily
visible to passers-by, for 5 percent of visitor motorized vehicle parking capacity, with a
minimum of one 2-bike capacity rack (5.106.4.1.1).
• Long-term bicycle parking. For buildings with over 10 tenant-occupants, provide secure
bicycle parking for 5 percent of tenant-occupied motorized vehicle parking capacity, with a
minimum of one space (5.106.4.1.2).
• Designated parking. Provide designated parking in commercial projects for any combination
of low-emitting, fuel-efficient and carpool/van pool vehicles as shown in Table 5.106.5.2
(5.106.5.2).
• Recycling by Occupants. Provide readily accessible areas that serve the entire building and
are identified for the depositing, storage and collection of nonhazardous materials for
recycling (5.410.1).
• Construction waste. A minimum 65 percent diversion of construction and demolition waste
from landfills. (5.408.1, A5.408.3.1 [nonresidential], A5.408.3.1 [residential]). All (100
percent) of trees, stumps, rocks and associated vegetation and soils resulting from land
clearing shall be reused or recycled (5.408.3).
• Wastewater reduction. Each building shall reduce the generation of wastewater by one of the
following methods:
1. The installation of water-conserving fixtures or
2. Using non-potable water systems (5.303.4).
• Water use savings. 20 percent mandatory reduction in indoor water use with voluntary goal
standards for 30, 35 and 40 percent reductions (5.303.2, A5303.2.3 [nonresidential]).
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• Water meters. Separate water meters for buildings in excess of 50,000 square feet or
buildings projected to consume more than 1,000 gallons per day (5.303.1).
• Irrigation efficiency. Moisture-sensing irrigation systems for larger landscaped areas (5.304.3).
• Materials pollution control. Low-pollutant emitting interior finish materials such as paints,
carpet, vinyl flooring, and particleboard (5.404).
• Building commissioning. Mandatory inspections of energy systems (i.e., heat furnace, air
conditioner, mechanical equipment) for nonresidential buildings over 10,000 square feet to
ensure that all are working at their maximum capacity according to their design efficiencies
(5.410.2).
California Model Water Efficient Landscape Ordinance. The Model Water Efficient Landscape
Ordinance (Ordinance) was required by AB 1881 Water Conservation Act. The bill required local
agencies to adopt a local landscape ordinance at least as effective in conserving water as the Model
Ordinance by January 1, 2010. Reductions in water use of 20 percent consistent with the (SBX-7-7)
2020 mandate are expected for Ordinance. Governor Brown’s Drought Executive Order of April 1,
2015 (EO B-29-15) directed the Department of Water Resources to update the Ordinance through
expedited regulation. The California Water Commission approved the revised Ordinance on July 15,
2015, which became effective on December 15, 2015. New development projects that include
landscaped areas of 500 square feet or more are subject to the Ordinance. The update requires:
• More efficient irrigation systems
• Incentives for graywater usage
• Improvements in on-site stormwater capture
• Limiting the portion of landscapes that can be planted with high water use plants
• Reporting requirements for local agencies.
California SB 97 and the CEQA Guidelines Update. Passed in August 2007, SB 97 added Section
21083.05 to the PRC. The code states “(a) On or before July 1, 2009, the Office of Planning and
Research shall prepare, develop, and transmit to the Resources Agency guidelines for the mitigation
of GHG emissions or the effects of GHG emissions as required by this division, including, but not
limited to, effects associated with transportation or energy consumption. (b) On or before January
1, 2010, the Resources Agency shall certify and adopt guidelines prepared and developed by the
Office of Planning and Research pursuant to subdivision (a).”
Section 21097 was also added to the PRC, which provided an exemption until January 1, 2010 for
transportation projects funded by the Highway Safety, Traffic Reduction, Air Quality, and Port
Security Bond Act of 2006 or projects funded by the Disaster Preparedness and Flood Prevention
Bond Act of 2006, in stating that the failure to analyze adequately the effects of GHGs would not
violate CEQA. The Natural Resources Agency completed the approval process and the Amendments
became effective on March 18, 2010.
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The 2010 CEQA Amendments provide guidance to public agencies regarding the analysis and
mitigation of the effects of GHG emissions in CEQA documents. The CEQA Amendments fit within
the existing CEQA framework by amending existing CEQA Guidelines to reference climate change.
Section 15064.4(b) of the CEQA Guidelines provides direction for lead agencies for assessing the
significance of impacts of GHG emissions:
• The extent to which the project may increase or reduce GHG emissions as compared to the
existing environmental setting;
• Whether the project emissions exceed a threshold of significance that the lead agency
determines applies to the project; or
• The extent to which the project complies with regulations or requirements adopted to
implement a Statewide, regional, or local plan for the reduction or mitigation of GHG
emissions. Such regulations or requirements must be adopted by the relevant public agency
through a public review process and must include specific requirements that reduce or
mitigate the project’s incremental contribution of GHG emissions. If there is substantial
evidence that the possible effects of a particular project are still cumulatively considerable
notwithstanding compliance with the adopted regulations or requirements, an Environmental
Impact Report (EIR) must be prepared for the project.
The CEQA Guidelines amendments do not identify a threshold of significance for GHG emissions, nor
do they prescribe assessment methodologies or specific mitigation measures. Instead, they call for a
“good-faith effort, based on available information, to describe, calculate, or estimate the amount of
greenhouse gas emissions resulting from a project.” The amendments encourage lead agencies to
consider many factors in performing a CEQA analysis and preserve lead agencies’ discretion to make
their own determinations based upon substantial evidence. The amendments also encourage public
agencies to make use of programmatic mitigation plans and programs from which to tier when they
perform individual project analyses.
Also amended were CEQA Guidelines Sections 15126.4 and 15130, which address mitigation
measures and cumulative impacts, respectively. GHG mitigation measures are referenced in general
terms, but no specific measures are championed. The revision to the cumulative impact discussion
requirement (Section 15130) simply directs agencies to analyze GHG emissions in an EIR when a
project’s incremental contribution of emissions may be cumulatively considerable; however, it does
not answer the question of when emissions are cumulatively considerable.
Section 15183.5 permits programmatic GHG analysis and later project-specific tiering, as well as the
preparation of GHG Reduction Plans. Compliance with such plans can support a determination that
a project’s cumulative effect is not cumulatively considerable, according to Section 15183.5(b).
In addition, the amendments revised Appendix F of the CEQA Guidelines, which focuses on energy
conservation. The sample environmental checklist in Appendix G was amended to include GHG
questions.
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CEQA emphasizes that the effects of GHG emissions are cumulative, and should be analyzed in the
context of CEQA’s requirements for cumulative impacts analysis (see CEQA Guidelines Section
15130(f)).
Center for Biological Diversity (CBD) v. CDFW (California Supreme Court GHG Ruling). In a
November 30, 2015 ruling, the California Supreme Court in Center for Biological Diversity (CBD) v.
California Department of Fish and Wildlife (CDFW) on the Newhall Ranch project concluded that
whether the project was consistent with meeting statewide emission reduction goals is a legally
permissible criterion of significance, but the significance finding for the project was not supported by
a reasoned explanation based on substantial evidence. The Court offered potential solutions on
pages 25–27 of the ruling to address this issue summarized below:
Specifically, the Court advised that:
• Substantiation of Project Reductions from BAU. A lead agency may use a BAU comparison
based on the Scoping Plan’s methodology if it also substantiates the reduction a particular
project must achieve to comply with statewide goals. The Court suggested a lead agency
could examine the “data behind the Scoping Plan’s business-as-usual model” to determine the
necessary project-level reductions from new land use development at the proposed location
(p. 25).
• Compliance with Regulatory Programs or Performance Based Standards. A lead agency “might
assess consistency with A.B. 32’s goal in whole or part by looking to compliance with regulatory
programs designed to reduce greenhouse gas emissions from particular activities. (See Final
Statement of Reasons, supra, at p. 64 [greenhouse gas emissions ‘may be best analyzed and
mitigated at a programmatic level.’].)” To the extent a project’s design features comply with or
exceed the regulations outlined in the Scoping Plan and adopted by the Air Resources Board or
other state agencies, a lead agency could appropriately rely on their use as showing compliance
with ‘performance based standards’ adopted to fulfill ‘a statewide . . . plan for the reduction or
mitigation of greenhouse gas emissions’ (CEQA Guidelines Section 15064.4(a)(2), (b)(3); see also
id., Section 15064(h)(3) [determination that impact is not cumulatively considerable may rest on
compliance with previously adopted plans or regulations, including ‘plans or regulations for the
reduction of greenhouse gas emissions’]) (p. 26).
• Compliance with GHG Reduction Plans or Climate Action Plans. A lead agency may utilize
“geographically specific GHG emission reduction plans” such as climate actions plans or GHG
emission reduction plans to provide a basis for the tiering or streamlining of project-level
CEQA analysis (p. 26).
• Compliance with Local Air District Thresholds. A lead agency may rely on “existing numerical
thresholds of significance for greenhouse gas emissions” adopted by, for example, local air
districts (p. 27).
Therefore, consistent with CEQA Guidelines Appendix G, the three factors identified in CEQA
Guidelines Section 15064.4 and the recently issued Newhall Ranch opinion, the GHG impacts would
be considered significant if the project would:
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• Conflict with a compliant GHG Reduction Plan if adopted by the lead agency;
• Exceed the applicable GHG Reduction Threshold; or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the
emission of GHGs.
2.4.4 - South Coast Air Pollution Management District
South Coast Air Quality Management District Recommendations for Significance
Thresholds
In April 2008, the SCAQMD, in order to provide guidance to local lead agencies on determining the
significance of GHG emissions identified in CEQA documents, convened a “GHG CEQA Significance
Threshold Working Group.” The goal of the working group was to develop and reach consensus on
an acceptable CEQA significance threshold for GHG emissions that would be used on an interim basis
until ARB (or other State agency) develops Statewide guidance on assessing the significance of GHG
emissions under CEQA.
Initially, SCAQMD staff presented the working group with a significance threshold that could be
applied to various types of projects—residential; non-residential; industrial; etc. However, the
threshold is still under development. In December 2008, staff presented the SCAQMD Governing
Board with a significance threshold for industrial projects where it is the lead agency. This threshold
uses a tiered approach to determine a project’s significance. The thresholds have not been adopted
and remain in an interim status. However, the documentation provided by the SCAQMD and its
working group constitute substantial evidence that can be considered by the lead agency in adopting
its own threshold for GHG emissions.
SCAQMD Regulation XXVII, Climate Change
SCAQMD Regulation XXVII currently includes three rules:
• Rule 2700—defines terms and post-global warming potentials.
• Rule 2701—establishes SoCal Climate Solutions Exchange, a voluntary program to encourage,
quantify, and certify voluntary, high quality certified GHG emission reductions in the SCAQMD.
• Rule 2702—adopted on February 6, 2009 this rule created a GHG Reduction Program for
emission reductions within the SCAQMD, which will fund projects through contracts in
response to requests for proposals or purchase reductions from other parties.
2.4.5 - Local
City of Orange
The City of Orange does not currently have formal GHG emissions reduction plans or recommended
emissions thresholds for determining significance associated with GHG emissions from development
projects. However, the City does have an Interim Guidance Memo on how to address GHG emissions
in CEQA documents for which the City is the Lead Agency. The City published interim guidance for
GHG emissions analysis in CEQA documents. The guidance is discussed in more detail below.
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Orange Goes Green
On February 10, 2009, the Orange City Council adopted the “Orange Goes Green! Program.” This
program outlines City policies and actions aimed at guiding the City toward more resource efficient,
environmentally responsible planning, development and operations. The green program focuses on:
• Public Information and Outreach;
• City Planning and Development Policy;
• City Facilities and Operations; and
• Private Development Incentives.
In 2009, the City held Orange Code Academy II focusing on the new energy and green building
standards which will be incorporated into the California Building Code in the coming months. The
Code Academy also included workshops on City waste management and water conservation programs,
and utility provider rebates and City incentives available to Orange residents and businesses.
To set the example, the City has adopted a policy that new public buildings and retrofits (greater
than 10,000 square feet) will be designed to meet the Leadership in Energy and Environmental
Design (LEED) green building standards, provided that the decision is fiscally responsible considering
the environmental benefit, up-front cost and long-term cost savings. In addition, City staff are
evaluating its purchasing, maintenance, and fleet policies and will be making changes to incorporate
greener practices.
To encourage others to build green, the City is offering “Priority Processing” for planning entitlement
and building permits for new third-party certified green buildings in Orange, and for eligible “green
upgrades” to existing buildings. The City is also offering a Local Recognition Program whereby
“green” projects will be recognized and promoted by the City as an example of environmentally
responsible development in Orange.
Interim Guidance for Greenhouse Gas Emissions Analysis
In its Interim Guidance for GHG Emissions Analysis, the City of Orange accepts the “Tier III”
quantitative interim significance thresholds recommended by the SCAQMD for commercial,
industrial, mixed-use, and industrial development projects as follows:
• Industrial Projects—10,000 metric tons of carbon dioxide equivalents (MT CO2e) per year
• Residential, Commercial, and Mixed-Use Projects (including industrial parks, warehouses,
etc.)—3,000 MT CO2e per year.
General Plan
The City of Orange adopted its 2010 General Plan in March 2010. The 2010 General Plan includes
the following applicable goals and policies relevant to GHG emissions. While few of the goals and
policies are directly focused on reducing GHG emissions, there are several policies related to
improving air quality that may also co-benefit climate change impacts.
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Land Use Element
• Policy 2.6: Encourage linkage in and around mixed-use areas using a multi-modal circulation
network, particularly transit, pedestrian sidewalks, paths and paseos, and bicycle and trail
systems.
• Policy 2.7: Ensure that the architecture, landscape design, and site planning of mixed-use
projects are of the highest quality, and that they emphasize a pedestrian orientation and safe,
convenient access between uses.
• Policy 3.4: Discourage commercial and industrial enterprises that have significant adverse soil,
air, water, or noise impacts.
• Policy 6.6: Enhance the walkability of both new and current development.
• Policy 6.8: Maximize landscaping along streetscapes and within development projects to
enhance public health and environmental benefits.
Circulation and Mobility
• Policy 3.3: Require incorporation of transit-oriented design features within major commercial
and employment areas as well as in medium density residential and mixed-use development
areas.
Growth Management Element
• Policy 1.7: Promote the expansion and development of alternative methods of transportation.
• Policy 1.8: Encourage the development of housing within close proximity to jobs and services.
• Policy 1.9: Ensure that new developments incorporate non-motorized and alternative transit
amenities such as bike racks, bus benches and shelters, and pedestrian connections.
• Policy 2.4: Explore infill development or mixed-use opportunities wherever possible as
developable space becomes more limited.
• Policy 2.5: Continue to work with Orange County Transportation Authority and other regional
transit agencies to provide amenities such as bus shelters, shade, and other special streetscape
treatments at transit stations that encourage the use of regional bus and train services.
Natural Resources Element
• Policy 2.2: Support alternative transportation modes, alternative technologies, and bicycle
and pedestrian-friendly neighborhoods to reduce emissions related to vehicular travel.
• Policy 2.3: Reduce the amount of water used for landscaping through the use of native and
drought-tolerant plants, proper soil preparation, and efficient irrigation systems as parks are
built or renovated.
• Policy 2.6: Encourage sustainable building and site designs for new construction and
renovation projects.
• Policy 2.8: Encourage development that incorporates pedestrian- and transit-oriented design
and landscape elements.
• Goal 3.0: Prepare for and adapt to the effects of climate change and promote practices that
decrease the City’s contribution to climate change.
• Policy 3.1: Evaluate the potential effects of climate change on the City’s human and natural
systems and prepare strategies that allow the City to appropriately respond and adapt.
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• Policy 3.2: Develop and adopt a comprehensive strategy to reduce GHGs within Orange by at
least 15 percent from current levels by 2020.
Public Safety Element
• Policy 9.1: Enhance and maintain safe pedestrian and bicycle movement through the
integration of traffic control devices, crosswalks, and pedestrian-oriented lighting into the
design of streets, sidewalks, trails, and school routes throughout Orange.
• Policy 9.2: Support creation of safe routes that encourage children to walk or bike to schools
and recreational facilities.
• Policy 9.3: Identify and attempt to remove impediments to pedestrian and bicycle access
including those associated with rail, street, freeway, and waterway crossings and poorly
marked or maintained pathways and sidewalks.
Infrastructure Element
• Policy 4.4: Encourage integrated and cost-effective design and technology features within new
development to minimize demands on dry utility networks
Urban Design Element
• Policy 6.2: Ensure that new infill development contributes positively to the quality of the
surrounding corridor or neighborhood, including the potential to provide additional park
space, and minimize the visibility of on-site parking.
Orange General Plan Program EIR
The General Plan PEIR includes the following discussion regarding reducing GHG emissions
associated with the 2010 General Plan:
The documentation shall identify measures to be incorporated into the considered project that would
reduce GHG emissions from BAU. Such measures include, but are not limited to the following:
• The City strongly encourages new development and major renovation projects to employ
green building techniques and materials.
- Encourage proposed development projects throughout the City to incorporate LEED
Standards developed by the U.S. Green Building Council or an equivalent program.
- Encourage building orientations and landscaping that enhance natural lighting and sun
exposure.
- Require compliance with State Title 24 building construction standards and Energy Star
conservation standards for all development projects.
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SECTION 3: MODELING PARAMETERS AND ASSUMPTIONS
3.1 - Model Selection and Guidance
GHG emissions can be estimated by using emission factors and a level of activity. Emission factors are
the emission rate of a pollutant given the activity over time; for example, grams of CO2 per horsepower
hour. The ARB has published emission factors for on-road mobile vehicles/trucks in the mobile source
emission model (EMFAC) l and emission factors for off-road equipment and vehicles in the OFFROAD
emissions model. An air emissions model (or calculator) combines the emission factors and the various
levels of activity and outputs the emissions for the various pieces of equipment.
The California Emissions Estimator Model (CalEEMod) was developed in cooperation with the
SCAQMD and other air districts throughout the State. CalEEMod is designed as a uniform platform
for government agencies, land use planners, and environmental professionals to quantify potential
criteria pollutant and GHG emissions associated with construction and operation from a variety of
land uses.
The emissions modeling conducted for the project used the most current version of CalEEMod
version 2016.3.2, to estimate project-generated construction and operation GHG emissions.
3.2 - Construction
Construction emissions can vary substantially from day to day, depending on the level of activity, the
specific type of operation, and prevailing weather conditions. Construction emissions result from
on-site and off-site activities. On-site emissions principally consist of exhaust emissions from the
activity levels of heavy-duty construction equipment, motor vehicle operation, and fugitive dust
(mainly particulate matter less than 10 microns in diameter [PM10]) from disturbed soil. For this
analysis only activities that generate GHG emissions are assessed.
The activity for construction equipment is based on the horsepower and load factors of the
equipment. In general, the horsepower is the power of an engine—the greater the horsepower, the
greater the power. The load factor is the average power of a given piece of equipment while in
operation compared with its maximum rated horsepower. A load factor of 1.0 indicates that a piece
of equipment continually operates at its maximum operating capacity.
The construction equipment assumed for the project is included in the CalEEMod output contained
in Appendix A. The CalEEMod default construction equipment fleet mix was adjusted to match
project-specific equipment.
The project was assumed to start construction in July 2019 and be completed by March 2021. The
construction schedule is shown in Table 2. The construction schedule duration used in the analysis
was based on the estimated construction schedule provided by the project applicant.
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Table 2: Conceptual Construction Schedule
Construction Phase Phase Start Date Phase End Date
Total Number of Working
Days
Demolition 7/1/2019 7/26/2019 20
Site Preparation/Shoring
Operation 7/27/2019 8/11/2019 10
Grading/Excavation Operation 8/12/2019 10/6/2019 40
Paving/Concrete Structure 10/7/2019 3/8/2020 110
Shotcrete 11/11/2019 11/29/2019 15
Building Construction/Framing 3/9/2020 6/14/2020 70
Skin/Finishes/Sitework 6/15/2020 3/5/2021 190
Source: CalEEMod Output (see Appendix A)
3.3 - Operation
Operational emissions are those emissions that occur during operation of the project. The major
sources are summarized below.
3.3.1 - Motor Vehicles
Motor vehicle emissions refer to exhaust emissions from the automobiles that would travel to and
from the project site. The trip generation rate of 4.35 daily weekday trips was obtained from traffic
impact report performed by Linscott, Law and Greenspan.
The vehicle fleet mix is the mix of motor vehicle classes that are associated with the project’s daily
operational trip. Emission factors from the ARB EMFAC model are assigned to the expected vehicle
mix that account for the vehicles’ vehicle class, speed, and fuel use (gasoline and diesel-powered
vehicles). The CalEEMod default vehicle fleet mix for Orange County was used for this analysis.
3.3.2 - Landscape Equipment
The landscaping equipment (leaf blowers, chain saws, mowers) would generate GHG emissions as a
result of fuel combustion assumptions in the CalEEMod model.
3.3.3 - Electricity
There would be emissions from the power plants that would generate electricity to be used by the
project (for lighting, etc.). The Southern California Edison emissions factors are based on compliance
with the Renewable Portfolio Standard. The factors listed below were applied in estimating project
emissions for the year 2021. The emission factors for Southern California Edison are as follows:
• Carbon dioxide: 553.67 pounds per megawatt hour (lbs/MWh)
• Methane: 0.025 lbs/MWh
• Nitrous oxide: 0.005 lbs/MWh
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3.3.4 - Title 24
CalEEMod has three categories for electricity consumption: electricity that is impacted by Title 24
regulations; non-Title 24 electricity; and lighting. The Title 24 uses are defined as the major building
envelope systems covered by California’s Building Code Title 24 Part 6, such as space heating, space
cooling, water heating, and ventilation. Lighting is separate since it can be both part and not part of
Title 24. Since lighting is not part of the building envelope energy budget, CalEEMod does not
consider lighting to have any further association with Title 24 references in the program. Non-Title
24 includes everything else such as appliances and electronics. To properly divide the total
electricity consumption into the three categories, the percentage for each category is determined by
using percentages derived from the CalEEMod default electricity intensity. The percentages are
applied to the electricity consumption to obtain the values used in the analysis.
In addition, the 2016 Title 24 standards became effective on January 1, 2017. Default values from
the 2016.3.2 version of CalEEMod were used.
3.3.5 - Natural Gas
There would be emissions from the combustion of natural gas used for the project (water heaters,
heat, etc.). CalEEMod has two categories for natural gas consumption: Title 24 and non-Title 24.
CalEEMod default natural gas consumption rates were used, based on the proposed land use types.
3.3.6 - Water and Wastewater
There would be GHG emissions from the use of electricity to pump potable water to the project and
to treat wastewater. CalEEMod defaults were used for these sources.
3.3.7 - Solid Waste
GHG emissions would be generated from the decomposition of solid waste generated by the project.
CalEEMod was used to estimate the GHG emissions from this source. The CalEEMod default solid
waste generation rates were used, based on the proposed land use types.
3.3.8 - Vegetation
There is currently little carbon sequestration occurring on-site; therefore, emissions from carbon
sequestration were not included.
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SECTION 4: THRESHOLDS OF SIGNIFICANCE
4.1 - Threshold of Significance
Section 15064.4(b) of the CEQA Guidelines’ amendments for GHG emissions states that a lead
agency may take into account the following three considerations in assessing the significance of
impacts from GHG emissions:
• Consideration #1: The extent to which the project may increase or reduce GHG emissions as
compared to the existing environmental setting.
• Consideration #2: Whether the project emissions exceed a threshold of significance that the
lead agency determines applies to the project.
• Consideration #3: The extent to which the project complies with regulations or requirements
adopted to implement a Statewide, regional, or local plan for the reduction or mitigation of
GHG emissions. Such regulations or requirements must be adopted by the relevant public
agency through a public review process and must include specific requirements that reduce or
mitigate the project’s incremental contribution of GHG emissions. If there is substantial
evidence that the possible effects of a particular project are still cumulatively considerable
notwithstanding compliance with the adopted regulations or requirements, an EIR must be
prepared for the project.
The City of Orange has not adopted its own GHG thresholds, nor has the City prepared a Climate
Action Plan that can be used as a basis for determining project significance. However, in its Interim
Guidance for GHG Emissions Analysis, the City of Orange accepts the “Tier III” quantitative interim
significance thresholds recommended by the SCAQMD for commercial, industrial, mixed-use, and
industrial development projects as follows:
• Industrial Projects—10,000 metric tons of carbon dioxide equivalents (MT CO2e) per year
• Residential, Commercial, and Mixed-Use Projects (including industrial parks, warehouses,
etc.)—3,000 MT CO2e per year
Because of the nature of the project, the applicable GHG significance threshold is 3,000 MT CO2e. If
the project would generate GHG emissions below the threshold, it is acceptable to conclude that the
project’s GHG contribution would not be “cumulatively considerable” and would therefore be “less
than significant” under CEQA.
If the project would generate GHG emissions above the quantitative thresholds identified above, the
analysis should focus on project design features or mitigation measures that would reduce or
sequester GHG emissions, such that project emissions would be reduced to below the SCAQMD
threshold. Feasible off-site GHG emission reduction projects could also be considered as a last
option. Potential mitigation measures are listed in Appendix B of the California Air Pollution Control
Officers Association report. Project level mitigation measures are also identified in the “Addressing
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Climate Change at the Project Level” document developed by the State Attorney General’s Office.
Energy conservation measures are also listed in Appendix F of the CEQA Guidelines.
If the project would continue to generate GHG emissions that exceed the threshold after all feasible
mitigation measures have been incorporated into the project, the analysis should conclude that the
project would contribute GHG emissions which may be “cumulatively considerable” and the impact
would be significant and unavoidable. Findings and a Statement of Overriding Considerations
(associated with an EIR) would then be required, pursuant to CEQA.
Threshold Development
The SCAQMD developed interim recommended significance thresholds for GHGs for local lead
agency consideration (SCAQMD draft local agency threshold) in 2008; however, the SCAQMD Board
has not approved the thresholds as of the date of this analysis. The current interim thresholds
consist of the following tiered approach:
• Tier I—Evaluates whether or not the project qualifies for any applicable exemption under
CEQA.
• Tier II—Determines whether the project is consistent with a GHG reduction plan. If a project
is consistent with a qualifying local GHG reduction plan, it does not have significant GHG
emissions.
• Tier III—Consists of screening values, which the lead agency can choose, but must be
consistent with all projects within its jurisdiction. A project’s construction emissions are
averaged over 30 years and are added to a project’s operational emissions. If a project’s
emissions are under one of the following screening thresholds, then the project is less than
significant:
- All land use types: 3,000 MT CO2e per year
- Based on land use type: residential: 3,500 MT CO2e per year; commercial: 1,400 MT CO2e
per year; industrial: 10,000 MT CO2e; or mixed-use: 3,000 MT CO2e per year
• Tier IV has the following options:
- Option 1: Reduce emissions from business as usual by a certain percentage; this percentage
is currently undefined
- Option 2: Early implementation of applicable AB 32 Scoping Plan measures
- Option 3: 2020 target for service populations (SP), which includes residents and employees:
4.8 MT CO2e/SP/year for projects and 6.6 MT CO2e/SP/year for plans;
- Option 3, 2035 target: 3.0 MT CO2e/SP/year for projects and 4.1 MT CO2e/SP/year for plans
• Tier V involves mitigation offsets to achieve target significance threshold.
The SCAQMD provided substantial evidence in support of its threshold approach. The SCAQMD
discusses its draft thresholds in the following excerpt (SCAQMD 2008):
The overarching policy objective with regard to establishing a GHG [greenhouse gas]
significance threshold for the purposes of analyzing GHG impacts pursuant to CEQA
is to establish a performance standard or target GHG reduction objective that will
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ultimate contribute to reducing GHG emissions to stabilize climate change. Full
implementation of the Governor’s Executive Order S-3-05 would reduce GHG
emissions 80 percent below 1990 levels or 90 percent below current levels by 2050.
It is anticipated that achieving the executive order’s objective would contribute to
worldwide efforts to cap GHG concentrations at 450 ppm, thus, stabilizing global
climate.
As described below, staff’s recommended interim GHG significance threshold
proposal uses a tiered approach to determining significance. Tier 3, which is
expected to be the primary tier by which the AQMD will determine significance for
projects where it is the lead agency, uses the Executive Order S-3-05 goal as the
basis for deriving the screening level. Specifically, the Tier 3 screening level for
stationary sources is based on an emission capture rate of 90 percent for all new or
modified projects. A 90 percent emission capture rate means that 90 percent of
total emissions from all new or modified stationary source projects would be subject
to some type of CEQA analysis, including a negative declaration, a mitigated negative
declaration, or an environmental impact.
Therefore, the policy objective of staff’s recommended interim GHG significance
threshold proposal is to achieve an emission capture rate of 90 percent of all new or
modified stationary source projects. A GHG significance threshold based on a 90
percent emission capture rate may be more appropriate to address the long-term
adverse impacts associated with global climate change. Further, a 90 percent
emission capture rate sets the emission threshold low enough to capture a
substantial fraction of future stationary source projects that will be constructed to
accommodate future statewide population and economic growth, while setting the
emission threshold high enough to exclude small projects that will in aggregate
contribute a relatively small fraction of the cumulative statewide GHG emissions.
This assertion is based on the fact that staff estimates that these GHG emissions
would account for less than one percent of future 2050 statewide GHG emissions
target (85 MMTCO2e/yr). In addition, these small projects would be subject to
future applicable GHG control regulations that would further reduce their overall
future contribution to the statewide GHG inventory.
In summary, the SCAQMD’s draft threshold uses the Executive Order S-3-05 goal as the basis for the
Tier III screening level. The City of Orange uses the SCAQMD’s Tier III approach. Achieving the
executive order objective would contribute to worldwide efforts to cap CO2concentrations at 450
ppm, thus stabilizing global climate.
Thresholds of Significance for this Project
To determine whether the project is significant, this project uses the City of Orange’s threshold of
3,000 MT CO2e per year.
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SECTION 5: GREENHOUSE GAS IMPACT ANALYSIS
5.1 - CEQA Guidelines
CEQA Guidelines define a significant effect on the environment as “a substantial, or potentially
substantial, adverse change in the environment.” To determine if a project would have a significant
impact on GHGs, the type, level, and impact of emissions generated by the project must be evaluated.
The following GHG significance thresholds are contained in Appendix G of the CEQA Guidelines,
which were amendments adopted into the Guidelines on March 18, 2010, pursuant to SB 97. A
significant impact would occur if the project would:
(a) Generate GHG emissions, either directly or indirectly, that may have a significant impact on
the environment; or
(b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose
of reducing the emissions of GHGs.
5.2 - Impact Analysis
5.2.1 - Greenhouse Gas Inventory
Impact GHG-1: The project would generate direct and indirect greenhouse gas emissions;
however, these emissions would not result in a significant impact on the
environment.
Impact Analysis
Construction Emissions
The project would generate GHG emissions during construction activities resulting from emission
sources such as construction equipment, haul trucks, and construction worker vehicles. Although
these emissions would be temporary and short-term in nature, they could represent a substantial
contribution of GHG emissions. Construction emissions were modeled using CalEEMod and the
assumptions described above in Section 3 (Modeling Parameters and Assumptions). See Appendix A
for detailed CalEEMod outputs and assumptions.
Table 3 presents the project’s total construction emissions, which are amortized over the assumed
lifetime of the project and added with annual operational emissions.
Table 3: Estimated Construction-Related Greenhouse Gas Emissions
Construction Activity
Total GHG Emissions
(MT CO2e per year)
2019
Demolition 13
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Table 3 (cont.): Estimated Construction-Related Greenhouse Gas
Emissions
Construction Activity
Total GHG Emissions
(MT CO2e per year)
Site Preparation/Shoring Operation 11
Grading/Excavation Operation 245
Paving/Concrete Structure—2019 43
Shotcrete 27
2020
Paving/Concrete Structure—2020 33
Building Construction/Framing 150
Skin/Finishes/Sitework—2020 141
2021
Skin/Finishes/Sitework—2021 45
Total Construction Duration (2019-2021)
Total Construction Emissions 707
Amortized over 30 years1 24
Notes:
MT CO2e = metric tons of carbon dioxide equivalent
Unrounded emissions were used in calculations, including the reported total; therefore, totals
may not appear to sum exactly due to rounding.
1 Construction GHG emissions are amortized over the 30-year lifetime of the project.
Source: CalEEMod Output (see Appendix A).
Operational Emissions
Following construction of the project, long-term operational emissions would be generated by the
sources described in Section 3 (Modeling Parameters and Assumptions). Table 4 presents the
estimated annual GHG emissions from the project’s operational activities. As shown in Table 4, the
project would generate approximately 1,625 MT CO2e per year after the inclusion of 24 MT CO2e per
year from project construction.
Table 4: Operational Greenhouse Gas Emissions
GHG Emissions Source GHG Emissions (MT CO2e per year)
Area 37
Energy 511
Mobile 965
Waste 32
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Table 4 (cont.): Operational Greenhouse Gas Emissions
GHG Emissions Source GHG Emissions (MT CO2e per year)
Water 56
Amortized Construction Emissions 24
Total Project Emissions 1,625
City of Orange Threshold 3,000
Significant? No
Notes:
MTCO2e = metric tons of carbon dioxide equivalent
Source of emissions: CalEEMod Output (Appendix A).
Source of thresholds: City of Orange Interim Guidance for GHG Emissions
Analysis Memo.
Summary
As shown in Table 4, the project’s combined amortized construction and annual operational GHG
emissions would not exceed the applicable threshold of significance of 3,000 MT CO2e per year.
Thus, the project’s construction and operational GHG emissions would not result in a significant
impact on the environment.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are required.
Level of Significance After Mitigation
Less than significant.
5.2.2 - Greenhouse Gas Reduction Plans
Impact GHG-2 The project would not conflict with any applicable plan, policy or regulation of an
agency adopted to reduce the emissions of greenhouse gases.
Impact Analysis
The City of Orange has not adopted a GHG reduction plan. In addition, the City has not completed
the GHG inventory, benchmarking, and goal-setting process required to identify a reduction target
and to take advantage of the streamlining provisions contained in the CEQA Guidelines amendments
adopted for SB 97. Since no other local or regional climate action plan is in place, the project is
assessed for its consistency with ARB’s adopted Scoping Plan. This would be achieved with an
assessment of the project’s compliance with Scoping Plan measures.
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AB 32 Scoping Plan
The California State Legislature adopted AB 32 in 2006. AB 32 focuses on reducing GHG emissions to
1990 levels by the year 2020. Pursuant to the requirements in AB 32, the ARB adopted the Climate
Change Scoping Plan (Scoping Plan) in 2008, which outlines actions recommended to obtain that
goal. The Scoping Plan calls for an “ambitious but achievable” reduction in California’s GHG
emissions, cutting approximately 30 percent from BAU emission levels projected for 2020, or about
10 percent from 2008 levels. The Scoping Plan contains a variety of strategies to reduce the State’s
emissions. As shown in Table 5, the project is consistent with most of the strategies, while others
are not applicable to the project.
Table 5: Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
1. California Cap-and-Trade Program Linked to Western
Climate Initiative. Implement a broad-based California
Cap-and-Trade program to provide a firm limit on
emissions. Link the California Cap-and-Trade Program
with other Western Climate Initiative Partner programs
to create a regional market system to achieve greater
environmental and economic benefits for California.
Ensure California’s program meets all applicable AB 32
requirements for market-based mechanisms.
Not applicable. Although the cap-and-trade
system has begun, the project is not one targeted
by the cap-and-trade system regulations and
therefore this measure does not apply to the
project.
2. California Light-Duty Vehicle GHG Standards.
Implement adopted standards and planned second
phase of the program. Align zero-emission vehicle,
alternative and renewable fuel and vehicle technology
programs with long-term climate change goals.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or
lead agency. However, the standards would be
applicable to the light-duty vehicles that access
the project site.
3. Energy Efficiency. Maximize energy efficiency building
and appliance standards; pursue additional efficiency
including new technologies, policy, and
implementation mechanisms. Pursue comparable
investment in energy efficiency from all retail
providers of electricity in California.
Consistent. This is a measure for the State to
increase its energy efficiency standards in new
buildings. The project is required to build to the
new standards and would increase its energy
efficiency through compliance.
4. Renewable Portfolio Standard. Achieve 33 percent
renewable energy mix Statewide. Renewable energy
sources include (but are not limited to) wind, solar,
geothermal, small hydroelectric, biomass, anaerobic
digestion, and landfill gas.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or
lead agency. Southern California Edison is
required to increase its percent of power supply
from renewable sources to 33 percent by the
year 2020 pursuant to various regulations. The
project would purchase power that comprises a
greater amount of renewable sources and could
install renewable solar power systems that will
assist the utility in achieving the mandate.
5. Low Carbon Fuel Standard. Develop and adopt the
Low Carbon Fuel Standard.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or
lead agency. All fuel consumption associated
with the project’s construction and operational
activities would use fuel that meets these
standards.
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Table 5 (cont.): Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
6. Regional Transportation-Related GHG Targets.
Develop regional GHG emissions reduction targets for
passenger vehicles. This measure refers to SB 375.
Not applicable. The project is not related to
developing GHG emission reduction targets.
7. Vehicle Efficiency Measures. Implement light-duty
vehicle efficiency measures.
Not applicable. When this measure is initiated,
the standards would be applicable to the light-
duty vehicles that would access the project site.
8. Goods Movement. Implement adopted regulations
for the use of shore power for ships at berth.
Improve efficiency in goods movement activities.
Not applicable. The project does not propose
any changes to maritime, rail, or intermodal
facilities or forms of transportation.
9. Million Solar Roofs Program.
Install 3,000 MW of solar-electric capacity under
California’s existing solar programs.
Consistent. This measure is to increase solar
throughout California, which is being done by
various electricity providers and existing solar
programs. The project would not preclude the
implementation of this strategy.
10. Medium/Heavy-Duty Vehicles. Adopt medium and
heavy-duty vehicle efficiency measures.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or
lead agency.
11. Industrial Emissions. Require assessment of large
industrial sources to determine whether individual
sources within a facility can cost-effectively reduce
GHG emissions and provide other pollution reduction
co-benefits. Reduce GHG emissions from fugitive
emissions from oil and gas extraction and gas
transmission. Adopt and implement regulations to
control fugitive CH4 emissions and reduce flaring at
refineries.
Not applicable. This measure would apply to the
direct GHG emissions at major industrial facilities
emitting more than 500,000 MTCO2e per year.
The project is a residential land use development
project that would generate less than 2,000 MT
CO2e per year (see Table 4).
12. High Speed Rail. Support implementation of a high-
speed rail system.
Not applicable. This is a Statewide measure that
cannot be implemented by a project applicant or
lead agency. The proposed project would not
preclude the implementation of this strategy.
13. Green Building Strategy. Expand the use of green
building practices to reduce the carbon footprint of
California’s new and existing inventory of buildings.
Consistent. The project would comply with the
California Energy Code and thus incorporate
applicable energy efficiency features designed to
reduce project energy consumption.
14. High Global Warming Potential Gases. Adopt
measures to reduce high global warming potential
gases.
Consistent. This measure is applicable to the
high global warming potential gases that would
be used by sources with large equipment (such
as in air conditioning and commercial
refrigerators). It is not anticipated that a
residential development project would include
refrigeration subject to refrigerant management
regulations adopted by ARB. If the project were
to install large air conditioning equipment
subject to the refrigerant management
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Table 5 (cont.): Scoping Plan Measures Consistency Analysis
Scoping Plan Reduction Measure Project Consistency
regulations adopted by ARB, the project would
be required to comply with all ARB requirements
for the Stationary Equipment Refrigerant
Management Program.
15. Recycling and Waste. Reduce CH4 emissions at
landfills. Increase waste diversion, composting, and
commercial recycling. Move toward zero waste.
Consistent. The project would not conflict with
implementation of this measure. The project is
required to achieve the recycling mandates via
compliance with the CALGreen code. The
project would utilize City of Orange recycling
services.
16. Sustainable Forests. Preserve forest sequestration
and encourage the use of forest biomass for
sustainable energy generation.
Not applicable. The project site is in a built-up
urban area. No forested lands exist on-site,
therefore, no on-site preservation is possible.
17. Water. Continue efficiency programs and use cleaner
energy sources to move and treat water.
Consistent. The project would comply with the
California Energy Code and the California
Updated Model Landscape Ordinance. With
adherence to these regulations, the project will
consume energy and water in an efficient
manner.
18. Agriculture. In the near-term, encourage investment
in manure digesters and at the 5-year Scoping Plan
update determine if the program should be made
mandatory by 2020.
Not applicable. The project site is not
designated or in use for agriculture purposes.
No grazing, feedlot, or other agricultural
activities that generate manure occur on-site or
are proposed to be implemented by the project.
Source of ARB Scoping Plan Reduction Measure: ARB 2008.
As shown in Table 5 the project is consistent with the applicable strategies and would not conflict
with the recommendations of AB 32 in achieving a Statewide reduction in GHG emissions.
Considering this information, the project would not significantly hinder or delay the State’s ability to
meet the reduction targets contained in AB 32 or conflict with implementation of the Scoping Plan.
SB 32 2017 Scoping Plan Update
The 2017 Climate Change Scoping Plan Update addressing the SB 32 targets was adopted on
December 14, 2017. Table 6 provides an analysis of the project’s consistency with the 2017 Scoping
Plan Update measures. As shown in Table 6, many of the measures are not applicable to the project,
while the project is consistent with strategies that are applicable.
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Table 6: Consistency with SB 32 2017 Scoping Plan Update
2017 Scoping Plan Update Reduction Measure Project Consistency
SB 350 50 Percent Renewable Mandate. Utilities
subject to the legislation will be required to
increase their renewable energy mix from 33
percent in 2020 to 50 percent in 2030.
Not directly applicable. This measure would apply to
utilities and not to individual development projects.
The project would purchase electricity from a utility
subject to the SB 350 Renewable Mandate.
SB 350 Double Building Energy Efficiency by 2030.
This is equivalent to a 20 percent reduction from
2014 building energy usage compared to current
projected 2030 levels.
Not applicable. This measure applies to existing
buildings. New structures are required to comply with
Title 24 Energy Efficiency Standards that are expected to
increase in stringency over time. The project would
comply with the applicable Title 24 Energy Efficiency
Standards in effect at the time building permits are
received.
Low Carbon Fuel Standard. This measure requires
fuel providers to meet an 18 percent reduction in
carbon content by 2030.
Not directly applicable. This is a Statewide measure
that cannot be implemented by a project applicant or
lead agency. However, vehicles accessing the proposed
residential buildings at the project site would be benefit
from the standards.
Mobile Source Strategy (Cleaner Technology and
Fuels Scenario). Vehicle manufacturers will be
required to meet existing regulations mandated by
the LEV III and Heavy-Duty Vehicle programs. The
strategy includes a goal of having 4.2 million ZEVs
on the road by 2030 and increasing numbers of ZEV
trucks and buses.
Not applicable. This measure is not applicable to the
project; however, vehicles accessing the apartment
buildings at the project site would be benefit from the
increased availability of cleaner technology and fuels.
Future residents and visitors can be expected to
purchase increasing numbers of more fuel efficient and
zero emission cars and trucks each year. Furthermore,
delivery trucks and buses that would serve future
residents will be made by increasing numbers of ZEV
delivery trucks.
Sustainable Freight Action Plan The plan’s target is
to improve freight system efficiency 25 percent by
increasing the value of goods and services
produced from the freight sector, relative to the
amount of carbon that it produces by 2030. This
would be achieved by deploying over 100,000
freight vehicles and equipment capable of zero
emission operation and maximize near-zero
emission freight vehicles and equipment powered
by renewable energy by 2030.
Not directly applicable. This measure applies to
owners and operators of trucks and freight operations.
The project is residential in nature and would support
truck and freight operations. It is expected that
deliveries throughout the State would be made with an
increasing number of ZEV delivery trucks, including
deliveries that would be made to future residents.
Short-Lived Climate Pollutant (SLCP) Reduction
Strategy. The strategy requires the reduction of
SLCPs by 40 percent from 2013 levels by 2030 and
the reduction of black carbon by 50 percent from
2013 levels by 2030.
Consistent. As described the Air Quality Analysis
included as an appendix to the IS/MND prepared for
the project, no woodburning devices are proposed as
part of the project. Natural gas hearths produce very
little black carbon compared to woodburning fireplace;
therefore, the project would not include major sources
of black carbon.
SB 375 Sustainable Communities Strategies.
Requires Regional Transportation Plans to include a
Sustainable Communities Strategy (SCS) for
reduction of per capita vehicle miles traveled.
Not applicable. The project does not include the
development of a Regional Transportation Plan.
Furthermore, the project is not within an SCS priority
area.
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Table 6 (cont.): Consistency with SB 32 2017 Scoping Plan Update
2017 Scoping Plan Update Reduction Measure Project Consistency
Post-2020 Cap-and-Trade Program. The Post 2020
Cap-and-Trade Program continues the existing
program for another 10 years. The Cap-and-Trade
Program applies to large industrial sources such as
power plants, refineries, and cement
manufacturers.
Not applicable. The project is not one targeted by the
cap-and-trade system regulations, and, therefore, this
measure does not apply to the project. However, the
post-2020 Cap-and-Trade Program indirectly affects
people and entities who use the products and services
produced by the regulated industrial sources when
increased cost of products or services (such as
electricity and fuel) are transferred to the consumers.
Natural and Working Lands Action Plan. The ARB is
working in coordination with several other agencies
at the federal, State, and local levels, stakeholders,
and with the public, to develop measures as outlined
in the Scoping Plan Update and the governor’s
Executive Order B-30-15 to reduce GHG emissions
and to cultivate net carbon sequestration potential
for California’s natural and working land.
Not Applicable. The project is residential development
in a built-up urban area and would not be considered
natural or working lands.
Source of ARB 2017 Scoping Plan Update Reduction Measures: ARB 2017.
Summary
As presented in Table 5, the project is consistent with the applicable strategies and would not
conflict with the recommendations of AB 32 in achieving a Statewide reduction in GHG emissions.
Considering this information, the proposed plan would not significantly hinder or delay the State’s
ability to meet the reduction targets contained in AB 32 or conflict with implementation of the
Scoping Plan. Furthermore, as shown in Table 6, implementation of the project would not conflict
with the reduction measures proposed in SB 32. In summary, the proposed plan would not conflict
with any applicable plan, policy, or regulation adopted to reduce the emissions of GHGs. As shown in
Impact GHG-1, the project’s combined amortized construction and annual operational GHG
emissions would not exceed the City of Orange’s threshold of 3,000 MT CO2e per year. Considering
this information, the proposed plan would not conflict with any applicable plan, policy or regulation of
an agency adopted to reduce the emissions of GHGs. The impact would be less than significant.
Level of Significance Before Mitigation
Less than significant.
Mitigation Measures
No mitigation measures are required.
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SECTION 6: REFERENCES
The following references were used in the preparation of this analysis and are referenced in the text
and/or were used to provide the author with background information necessary for the preparation
of thresholds and content.
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California Air Resources Board (ARB). 2008. (includes edits made in 2009) Climate Change Scoping
Plan, a framework for change. Website: http://www.arb.ca.gov/cc/scopingplan/document/
adopted_scoping_plan.pdf. Accessed February 14, 2017.
California Air Resources Board (ARB). 2010. 2020 Greenhouse Gas Emissions Projection and BAU
Scenario Emissions Estimate.
California Air Resources Board (ARB). 2011. Status of Scoping Plan Recommended Measures.
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California Air Resources Board (ARB). 2012. Low-Emission Vehicle Program. Website:
http://www.arb.ca.gov/msprog/levprog/levprog.htm. Accessed April 19, 2013.
California Air Resources Board (ARB). 2013a. Clean Car Standards—Pavley, Assembly Bill 1493.
Website: http://www.arb.ca.gov/cc/ccms/ccms.htm. Accessed February 14, 2017.
California Air Resources Board (ARB). 2013b. Facts About the Clean Cars Program. Website:
http://www.arb.ca.gov/msprog/zevprog/factsheets/advanced_clean_cars_eng.pdf.
Accessed February 14, 2017.
California Air Resources Board (ARB). 2014a. California Greenhouse Gas Emissions for 2000 to
2012—Trends of Emissions and Other Indicators. Website:
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Accessed April 25, 2016.
California Air Resources Board (ARB). 2014b. First Update to the Climate Change Scoping Plan.
Website: http://www.arb.ca.gov/cc/scopingplan/document/updatedscopingplan2013.htm.
Accessed February 14, 2017.
California Air Resources Board (ARB). 2015a. ARB Emissions Trading Program. Website:
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California Air Resources Board (ARB). 2015b. Low Carbon Fuel Standard Regulation. Website:
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California Air Resources Board (ARB). 2017. New Release: California and China Team Up to Push for
Millions More Zero-emission Vehicles. Website: https://www.arb.ca.gov/newsreel/news
release.php?id=934. Accessed June 27, 2017.
California Air Resources Board (ARB). 2018. California Greenhouse Inventory-Graphs. Website:
https://www.arb.ca.gov/cc/inventory/data/graph/graph.htm. Accessed August 27, 2018.
California Climate Change Center (CCCC). 2006. Our Changing Climate, Assessing the Risks to
California: A Summary Report from the California Climate Change Center. July 2006. CEC-
500-2006-077. Website: www.scc.ca.gov/webmaster/ftp/pdf/climate_change
/assessing_risks.pdf. Accessed June 2, 2018.
California Energy Commission (CEC). 2012. 2013 Title 24 Building Energy Efficiency Standards
Adoption Hearing Presentation. Website: http://www.energy.ca.gov/title24/2013
standards/rulemaking/documents/final_rulemaking_documents/31_2013_Adop
tion_Hearing_Presentation_5-31.pdf. Accessed October 19, 2015.
California Energy Commission (CEC). 2016. 2016 Building Energy Efficiency Standards
Frequently Asked Questions. Website: http://www.energy.ca.gov/title24/2016standards/
rulemaking/documents/2016_Building_Energy_Efficiency_Standards_FAQ.pdf. Accessed
December 1, 2016.Center for Climate and Energy Solutions (C2ES). 2015a. Multi-State
Climate Initiatives. Website: http://www.c2es.org/us-states-regions/regional-climate-
initiatives. Accessed April 26, 2016.
Center for Climate and Energy Solutions (C2ES). 2015b. Outcomes of the U.N. Climate Change
Conference. Website: http://www.c2es.org/international/negotiations/cop21-
paris/summary. Accessed April 19, 2016.
Centers for Disease Control and Prevention (CDC). 2010. Department of Health and Human
Services, the National Institute for Occupational Safety and Health. Carbon Dioxide.
Website: www.cdc.gov/niosh/npg/npgd0103.html. Accessed December 2013.
California Legislative Information (California Leginfo). 2015. Senate Bill 350 Clean Energy and
Pollution Reduction Act of 2015. Website:
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB350.
Accessed September 28, 2017.
California Natural Resources Agency. 2009. 2009 California Climate Adaptation Strategy. Website:
http://www.climatechange.ca.gov/adaptation/strategy/index.html. Accessed December
2013.
Intergovernmental Panel on Climate Change (IPCC). 2001. Climate Change 2001: The Scientific
Basis. Website: http://www.grida.no/climate/ipcc_tar/wg1/pdf/WG1_TAR-FRONT.pdf.
Accessed July 18, 2013.
City of Orange—The Terrace Apartments
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FirstCarbon Solutions 55
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Intergovernmental Panel on Climate Change (IPCC). 2007a. Climate Change 2007: The Physical
Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M.
Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge University Press,
Cambridge, United Kingdom and New York, NY, USA, Website: www.ipcc.ch/publications_a
nd_data/ar4/wg1/en/contents.html. Accessed December 2013.
Intergovernmental Panel on Climate Change (IPCC). 2007b. Climate Change 2007: Synthesis Report.
Contribution of Working Groups I, II and III to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K. and
Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland. Website:
www.ipcc.ch/publications_and_data/ar4/syr/en/contents.html. Accessed December 2013.
Intergovernmental Panel on Climate Change (IPCC). 2013. Climate Change 2013: The Physical
Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the
Intergovernmental Panel on Climate Change.
McIntyre, S. and R. McKitrick. 2003. Corrections to the Mann et al. (1998) Proxy Data Base and
Northern Hemisphere Average Temperature Series. Energy and Environment, Vol. 14, No. 6,
Pgs. 751-772. Website: http://www.uoguelph.ca/~rmckitri/research/MM03.pdf. Accessed
July 18, 2013.
McKitrick, Ross. 2005. What is the ‘Hockey Stick’ Debate About? APEC Study Group, Australia.
Website: www.uoguelph.ca/~rmckitri/research/McKitrick-hockeystick.pdf. Accessed July
18, 2013.
Moser et al. 2009. Moser, Susie, Guido Franco, Sarah Pittiglio, Wendy Chou, Dan Cayan. 2009. The
Future Is Now: An Update on Climate Change Science Impacts and Response Options for
California. California Energy Commission, PIER Energy-Related Environmental Research
Program. CEC-500-2008-071. Website: www.energy.ca.gov/2008publications/CEC-500-
2008-071/CEC-500-2008-071.PDF. Accessed December 2013.
Occupational Safety and Health Administration (OSHA). 2003. United States Department of Labor.
Safety and Health Topics: Methane. Website: www.osha.gov/dts/chemicalsampling/
data/CH_250700.html. Accessed March 9, 2015.
City of Orange. 2010. City of Orange 2010 General Plan. March. Website:
http://www.cityoforange.org/depts/commdev/planning/general_plan.asp. Accessed June
7, 2016.
City of Orange. 2010. Program Environmental Impact Report Orange General Plan. March.
Website: http://www.cityoforange.org/civicax/filebank/blobdload.asp. Accessed June 7,
2016.
City of Orange. 2010. Memo: Interim Guidance for Greenhouse Gas Emissions Analysis. April 26.
Website: http://www.cityoforange.org/civicax/filebank/blobdload.aspx?blobid=8204.
Accessed June 7, 2016.
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City of Orange. 2016. Orange Goes Green! A Guide to Green Living in the City of Orange. Website:
http://www.cityoforange.org/depts/commdev/orangegoesgreen/default.asp. Accessed
June 7, 2016.
South Coast Air Quality Management District (SCAQMD). 2008. Board Meeting Date: December 5,
2008, Agenda 31, Interim CEQA GHG Significance Threshold for Stationary Sources, Rules
and Plans. Website: www.aqmd.gov/hb/2008/December/081231a.htm. Draft Guidance
Document—Interim CEQA Greenhouse (GHG) Significance Threshold Document. Website:
http://www.aqmd.gov/hb/attachments/2008/December/081231.exe. Accessed May 7,
2012.
South Coast Air Quality Management District (SCAQMD). 2010. Greenhouse Gas CEQA Threshold
Stakeholder Working Group Meeting #15. September 28. Website: www.aqmd.gov
/ceqa/handbook/GHG/2010/sept28mtg/ghgmtg15-web.pdf. Accessed July 18, 2013.
U.S. Environmental Protection Agency (EPA). 2011. 2011 U.S. Greenhouse Gas Inventory Report.
Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2009. EPA 430-R-11-005.
Website: https://www.epa.gov/ghgemissions/us-greenhouse-gas-inventory-report-archive.
Accessed June 19, 2017.
U.S. Environmental Protection Agency (EPA). 2012. EPA and NHTSA Set Standards to Reduce
Greenhouse Gases and Improve Fuel Economy for Model Years 2017-2025 Cars and Light
Trucks. Website: http://www.epa.gov/otaq/climate/documents/420f12051.pdf. Accessed
August 21, 2016.
U.S. Environmental Protection Agency (EPA). 2016. Inventory of U.S. Greenhouse Gas Emissions
and Sinks: 1990-2014. EPA 430-R-16-002. Website: https://www.epa.gov/sites/production/
files/2017-04/documents/us-ghg-inventory-2016-main-text.pdf. Accessed June 2, 2018.
United Nations Framework Convention on Climate Change. 2010. National Greenhouse Gas
Inventory Data for the Period 1990-2008. Website: http://unfccc.int/resource/docs/2010
/sbi/eng/18.pdf. Accessed December 2013.
University of California, Davis. 1997. Prepared for California Department of Transportation. 1997.
Transportation Project-Level Carbon Monoxide Protocol. Website: www.dot.ca.gov/hq/env
/air/pages/coprot.htm. Accessed December 2013.
Wilson, C. and R. Walters. 2012. Emerging Topics (Chapter 10 in the Association of Environmental
Professionals Forecasting Community-Wide Greenhouse Gas Emissions and Setting
Reduction Targets. Available to Association of Environmental Professionals members only.
The White House. Statement by President Trump on the Paris Climate Accord. Website:
https://www.whitehouse.gov/the-press-office/2017/06/01/statement-president-trump-
paris-climate-accord. Accessed June 23, 2017.
City of Orange—The Terrace Apartments
Greenhouse Gas Analysis
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Appendix A:
CalEEMod Output
THIS PAGE INTENTIONALLY LEFT BLANK
CalEEMod Output
Table of Contents
Unmitigated Project Construction and Operations—Annual Results ................ A-1
CalEEMod Version: CalEEMod.2016.3.2
Date: 9/12/2018 2:24 PM
Terrace Apartments - Unmitigated Construction & Operations - Orange County, Annual
Terrace Apartments - Unmitigated Construction & Operations
Orange County, Annual
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking Structure 422.00 Space 0.50 168,800.00 0
Apartments Mid Rise 167.00 Dwelling Unit 2.80 177,616.00 478
1.2 Other Project Characteristics
Urbanization Urban Wind Speed (m/s)2.2 Precipitation Freq (Days)30
Climate Zone 8 Operational Year 2021
Utility Company Southern California Edison
CO2 Intensity
(lb/MWhr)
553.67 CH4 Intensity
(lb/MWhr)
0.025 N2O Intensity
(lb/MWhr)
0.005
1.3 User Entered Comments & Non-Default Data
Project Characteristics - Adjusted energy intensity factors based on Renewable Portfolio Standard
Land Use - Redevelopment of 3.3-acres of the existing 16.9-acre multifamily apartment community
167 dwelling units
Construction Phase - Anticipated construction schedule
Off-road Equipment - Anticipated construction equipment
Off-road Equipment - Anticipated construction equipment for the demolition phase
Off-road Equipment - Anticipated construction equipment for the grading/excavation phase
Off-road Equipment - Anticipated construction equipment for the paving/concrete structure phase
Off-road Equipment - Anticipated construction equipment for the shotcrete phase
Off-road Equipment - Anticipated construction equipment for the shoring operation phase
Off-road Equipment - Anticipated construction equipment
Trips and VMT - Up to 5,636 haul trips
A-1
Demolition - Existing hardscape - 93 existing spaces to be removed
Vehicle Trips - Project-specific daily trip rate based on traffic study
Woodstoves - Compliance with SCAQMD Rule 445
Construction Off-road Equipment Mitigation - Compliance with SCAQMD Rule 403
Water Mitigation - Compliance with Green Building Code Standards
Waste Mitigation - Statewide diversion/recycling mandate (16% percent reduction)
Table Name Column Name Default Value New Value
tblConstDustMitigation WaterUnpavedRoadMoistureContent 0 12
tblConstDustMitigation WaterUnpavedRoadVehicleSpeed 0 15
tblConstructionPhase NumDays 18.00 190.00
tblConstructionPhase NumDays 230.00 15.00
tblConstructionPhase NumDays 230.00 70.00
tblConstructionPhase NumDays 8.00 40.00
tblConstructionPhase NumDays 18.00 110.00
tblConstructionPhase NumDays 5.00 10.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 8.35 0.00
tblLandUse LandUseSquareFeet 167,000.00 177,616.00
tblLandUse LotAcreage 3.80 0.50
tblLandUse LotAcreage 4.39 2.80
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 6.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
A-2
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 2.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 0.00 1.00
tblOffRoadEquipment PhaseName Demolition
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Site Preparation/Shoring Operation
tblOffRoadEquipment PhaseName Grading/Excavation Operation
tblOffRoadEquipment PhaseName Paving/Concrete Structure
tblOffRoadEquipment PhaseName Paving/Concrete Structure
tblOffRoadEquipment UsageHours 6.00 8.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblOffRoadEquipment UsageHours 8.00 0.00
tblOffRoadEquipment UsageHours 6.00 0.00
tblOffRoadEquipment UsageHours 7.00 0.00
tblOffRoadEquipment UsageHours 8.00 0.00
A-3
tblOffRoadEquipment UsageHours 8.00 0.00
tblProjectCharacteristics CH4IntensityFactor 0.029 0.025
tblProjectCharacteristics CO2IntensityFactor 702.44 553.67
tblProjectCharacteristics N2OIntensityFactor 0.006 0.005
tblTripsAndVMT HaulingTripNumber 0.00 5,636.00
tblVehicleTrips HO_TTP 40.60 41.00
tblVehicleTrips HS_TTP 19.20 19.00
tblVehicleTrips HW_TTP 40.20 40.00
tblVehicleTrips ST_TR 6.39 4.35
tblVehicleTrips SU_TR 5.86 4.35
tblVehicleTrips WD_TR 6.65 4.35
Exhaust
PM10
PM10
Total
tblWoodstoves WoodstoveWoodMass 999.60 0.00
2.0 Emissions Summary
2.1 Overall Construction
NBio- CO2 Total CO2
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
CH4 N2O CO2e
Year tons/yr MT/yr
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
2019 0.1054 1.5718 0.8640 3.5200e-
003
0.0830 0.0392 0.1221 0.0221 0.0365 0.0586 0.0000 337.3652 337.3652 0.0481 0.0000 338.5684
2020 0.6527 1.8232 1.5186 3.6300e-
003
0.1202 0.0865 0.2066 0.0321 0.0817 0.1138 0.0000 322.1535 322.1535 0.0513 0.0000 323.4354
2021 0.1728 0.2907 0.2363 5.1000e-
004
9.5900e-
003
0.0143 0.0239 2.5500e-
003
0.0135 0.0160 0.0000 44.4264 44.4264 8.9500e-
003
0.0000 44.6503
Maximum 0.6527 1.8232 1.5186 3.6300e-
003
0.0513 0.0000 338.56840.1202 0.0865 0.2066 0.0321 0.0817 0.1138 0.0000 337.3652 337.3652
A-4
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction
ROG NOx CO Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
2019 0.1054 1.5718 0.8640 3.5200e-
003
0.0807 0.0392 0.1199 0.0217 0.0365 0.0583 0.0000 337.3651 337.3651 0.0481 0.0000 338.5683
2020 0.6527 1.8232 1.5186 3.6300e-
003
0.1202 0.0865 0.2066 0.0321 0.0817 0.1138 0.0000 322.1533 322.1533 0.0513 0.0000 323.4352
2021 0.1728 0.2907 0.2363 5.1000e-
004
9.5900e-
003
0.0143 0.0239 2.5500e-
003
0.0135 0.0160 0.0000 44.4264 44.4264 8.9500e-
003
0.0000 44.6503
Maximum 0.6527 1.8232 1.5186 3.6300e-
003
0.1202 0.0865 0.2066 0.0321 0.0817 0.1138 0.0000 337.3651 337.3651 0.0513 0.0000 338.5683
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.001.05 0.00 0.64 0.60 0.00 0.18
1.0903 1.0903
0.00 0.00 0.00 0.01 0.00
0.4211 0.4211
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter)Maximum Mitigated ROG + NOX (tons/quarter)
1 7-1-2019 9-30-2019
0.7107 0.7107
2 10-1-2019 12-31-2019 0.5539 0.5539
3 1-1-2020 3-31-2020
0.4610 0.4610
4 4-1-2020 6-30-2020 0.6191 0.6191
5 7-1-2020 9-30-2020
1.0903
6 10-1-2020 12-31-2020 0.7116 0.7116
7 1-1-2021 3-31-2021
Highest 1.0903
A-5
2.2 Overall Operational
Exhaust
PM10
PM10
Total
NBio- CO2 Total CO2
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Area 0.7669 0.0494 1.7439 2.8000e-
004
0.0119 0.0119 0.0119 0.0119 0.0000 36.9112 36.9112 3.4100e-
003
6.2000e-
004
37.1826
Energy 0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 508.9302 508.9302 0.0203 5.5400e-
003
511.0905
Mobile 0.1994 0.8729 2.7732 0.0105 0.9409 7.7300e-
003
0.9486 0.2520 7.2000e-
003
0.2592 0.0000 964.2976 964.2976 0.0401 0.0000 965.2989
Waste 0.0000 0.0000 0.0000 0.0000 15.5938 0.0000 15.5938 0.9216 0.0000 38.6329
Water 0.0000 0.0000 0.0000 0.0000 3.4520 54.7205 58.1724 0.3570 8.8700e-
003
69.7399
Total 0.9766 1.0102 4.5545 0.0113 1.3424 0.0150 1,621.944
8
0.9409 0.0268 0.9676 0.2520 0.0262 0.2782
SO2 Fugitive
PM10
Exhaust
PM10
19.0457 1,564.859
4
1,583.9052
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Operational
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Area 0.7669 0.0494 1.7439 2.8000e-
004
0.0119 0.0119 0.0119 0.0119 0.0000 36.9112 36.9112 3.4100e-
003
6.2000e-
004
37.1826
Energy 0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 508.9302 508.9302 0.0203 5.5400e-
003
511.0905
Mobile 0.1994 0.8729 2.7732 0.0105 0.9409 7.7300e-
003
0.9486 0.2520 7.2000e-
003
0.2592 0.0000 964.2976 964.2976 0.0401 0.0000 965.2989
Waste 0.0000 0.0000 0.0000 0.0000 13.0988 0.0000 13.0988 0.7741 0.0000 32.4516
Water 0.0000 0.0000 0.0000 0.0000 2.7616 43.7764 46.5379 0.2856 7.0900e-
003
55.7919
Total 0.9766 1.0102 4.5545 0.0113 0.9409 0.0268 0.9676 0.2520 0.0262 0.2782 15.8603 1,553.915
3
1,569.7757 1.1235 0.0133 1,601.815
5
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 16.73 0.70 0.89 16.30 11.84 1.24
A-6
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 7/1/2019 7/26/2019 5 20 Approximately 4 weeks
2 Site Preparation/Shoring
Operation
Site Preparation 7/27/2019 8/11/2019 5 10 Approximately 2 weeks
3 Grading/Excavation Operation Grading 8/12/2019 10/6/2019 5 40 Approximately 8 weeks
4 Paving/Concrete Structure Paving 10/7/2019 3/8/2020 5 110 Approximately 22 weeks
70 Approximately 14 weeks
5 Shotcrete Building Construction 11/11/2019 11/29/2019 5
3/5/2021 5
15 3 weeks total all overlapping with
structure duration6Building Construction/Framing Building Construction 3/9/2020 6/14/2020 5
190 Approximately 38 weeks
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0.5
Residential Indoor: 359,672; Residential Outdoor: 119,891; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area:
10,128 (Architectural Coating – sqft)
7 Skin/Finishes/Sitework Architectural Coating 6/15/2020
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 0.00 81 0.73
Demolition Dumpers/Tenders 2 8.00 16 0.38
Demolition Excavators 2 8.00 158 0.38
Site Preparation/Shoring Operation Air Compressors 1 6.00 78 0.48
Site Preparation/Shoring Operation Bore/Drill Rigs 2 4.00 221 0.50
Site Preparation/Shoring Operation Cement and Mortar Mixers 1 8.00 9 0.56
Site Preparation/Shoring Operation Cranes 1 6.00 231 0.29
Site Preparation/Shoring Operation Paving Equipment 1 6.00 132 0.36
Site Preparation/Shoring Operation Skid Steer Loaders 1 8.00 65 0.37
Grading/Excavation Operation Excavators 1 8.00 158 0.38
Grading/Excavation Operation Sweepers/Scrubbers 1 4.00 64 0.46
Grading/Excavation Operation Tractors/Loaders/Backhoes 2 8.00 97 0.37
Paving/Concrete Structure Cement and Mortar Mixers 6 8.00 9 0.56
Paving/Concrete Structure Cranes 1 5.00 231 0.29
A-7
Paving/Concrete Structure Forklifts 2 8.00 89 0.20
Paving/Concrete Structure Pavers 0 0.00 130 0.42
Paving/Concrete Structure Paving Equipment 1 6.00 132 0.36
Paving/Concrete Structure Rollers 0 0.00 80 0.38
Paving/Concrete Structure Tractors/Loaders/Backhoes 0 0.00 97 0.37
Shotcrete Air Compressors 1 6.00 78 0.48
Shotcrete Cement and Mortar Mixers 1 8.00 9 0.56
Shotcrete Paving Equipment 1 6.00 132 0.36
Building Construction/Framing Aerial Lifts 1 6.00 63 0.31
Building Construction/Framing Air Compressors 2 6.00 78 0.48
Building Construction/Framing Cranes 1 7.00 231 0.29
Building Construction/Framing Forklifts 2 8.00 89 0.20
Building Construction/Framing Generator Sets 0 0.00 84 0.74
Building Construction/Framing Tractors/Loaders/Backhoes 0 0.00 97 0.37
Building Construction/Framing Welders 0 0.00 46 0.45
Skin/Finishes/Sitework Aerial Lifts 1 6.00 63 0.31
Skin/Finishes/Sitework Air Compressors 2 6.00 78 0.48
Skin/Finishes/Sitework Cranes 2 6.00 231 0.29
Skin/Finishes/Sitework Forklifts 2 6.00 89 0.20
Hauling
Vehicle
Class
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
14.70
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle
Class
Site
Preparation/Shoring
Operation
7 18.00 0.00 0.00
Demolition 4 10.00 0.00 34.00
HHDT
6.90 20.00 LD_Mix HDT_Mix HHDT
14.70
14.70 6.90 20.00 LD_Mix HDT_Mix
Paving/Concrete
Structure
10 25.00 0.00 0.00
Grading/Excavation
Operation
4 10.00 0.00 5,636.00
HHDT
6.90 20.00 LD_Mix HDT_Mix HHDT
14.70
14.70 6.90 20.00 LD_Mix HDT_Mix
Building
Construction/Framing
6 191.00 46.00 0.00
Shotcrete 3 191.00 46.00 0.00
HDT_Mix HHDT
6.90 20.00 LD_Mix HDT_Mix HHDT
0.00 14.70
14.70 6.90 20.00 LD_Mix
6.90 20.00 LD_Mix HDT_Mix HHDTSkin/Finishes/Sitework 7 38.00 0.00
A-8
3.1 Mitigation Measures Construction
Water Exposed Area
Water Unpaved Roads
Reduce Vehicle Speed on Unpaved Roads
3.2 Demolition - 2019
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 3.6800e-
003
0.0000 3.6800e-
003
5.6000e-
004
0.0000 5.6000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 6.6900e-
003
0.0630 0.0703 1.2000e-
004
2.9400e-
003
2.9400e-
003
2.7400e-
003
2.7400e-
003
0.0000 10.3794 10.3794 3.0500e-
003
0.0000 10.4557
Total 6.6900e-
003
0.0630 0.0703 1.2000e-
004
3.0500e-
003
0.0000 10.45573.6800e-
003
2.9400e-
003
6.6200e-
003
5.6000e-
004
2.7400e-
003
3.3000e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 10.3794 10.3794
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 1.4000e-
004
5.2000e-
003
1.2400e-
003
1.0000e-
005
2.9000e-
004
2.0000e-
005
3.1000e-
004
8.0000e-
005
2.0000e-
005
1.0000e-
004
0.0000 1.3220 1.3220 1.4000e-
004
0.0000 1.3255
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 4.2000e-
004
3.0000e-
004
3.3800e-
003
1.0000e-
005
1.1000e-
003
1.0000e-
005
1.1100e-
003
2.9000e-
004
1.0000e-
005
3.0000e-
004
0.0000 0.9816 0.9816 2.0000e-
005
0.0000 0.9822
Total 5.6000e-
004
5.5000e-
003
4.6200e-
003
2.0000e-
005
1.6000e-
004
0.0000 2.30771.3900e-
003
3.0000e-
005
1.4200e-
003
3.7000e-
004
3.0000e-
005
4.0000e-
004
0.0000 2.3036 2.3036
A-9
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Fugitive Dust 1.4400e-
003
0.0000 1.4400e-
003
2.2000e-
004
0.0000 2.2000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 6.6900e-
003
0.0630 0.0703 1.2000e-
004
2.9400e-
003
2.9400e-
003
2.7400e-
003
2.7400e-
003
0.0000 10.3794 10.3794 3.0500e-
003
0.0000 10.4557
Total 6.6900e-
003
0.0630 0.0703 1.2000e-
004
3.0500e-
003
0.0000 10.45571.4400e-
003
2.9400e-
003
4.3800e-
003
2.2000e-
004
2.7400e-
003
2.9600e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 10.3794 10.3794
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 1.4000e-
004
5.2000e-
003
1.2400e-
003
1.0000e-
005
2.9000e-
004
2.0000e-
005
3.1000e-
004
8.0000e-
005
2.0000e-
005
1.0000e-
004
0.0000 1.3220 1.3220 1.4000e-
004
0.0000 1.3255
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 4.2000e-
004
3.0000e-
004
3.3800e-
003
1.0000e-
005
1.1000e-
003
1.0000e-
005
1.1100e-
003
2.9000e-
004
1.0000e-
005
3.0000e-
004
0.0000 0.9816 0.9816 2.0000e-
005
0.0000 0.9822
Total 5.6000e-
004
5.5000e-
003
4.6200e-
003
2.0000e-
005
1.6000e-
004
0.0000 2.30771.3900e-
003
3.0000e-
005
1.4200e-
003
3.7000e-
004
3.0000e-
005
4.0000e-
004
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 2.3036 2.3036
PM2.5
Total
Bio- CO2 NBio- CO2
3.3 Site Preparation/Shoring Operation - 2019
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 6.1300e-
003
0.0661 0.0461 1.1000e-
004
2.8700e-
003
2.8700e-
003
2.7000e-
003
2.7000e-
003
0.0000 9.9552 9.9552 2.8000e-
003
0.0000 10.0253
Total 6.1300e-
003
0.0661 0.0461 1.1000e-
004
2.8000e-
003
0.0000 10.02530.0000 2.8700e-
003
2.8700e-
003
0.0000 2.7000e-
003
2.7000e-
003
0.0000 9.9552 9.9552
A-10
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.8000e-
004
2.7000e-
004
3.0400e-
003
1.0000e-
005
9.9000e-
004
1.0000e-
005
9.9000e-
004
2.6000e-
004
1.0000e-
005
2.7000e-
004
0.0000 0.8835 0.8835 2.0000e-
005
0.0000 0.8840
Total 3.8000e-
004
2.7000e-
004
3.0400e-
003
1.0000e-
005
2.0000e-
005
0.0000 0.88409.9000e-
004
1.0000e-
005
9.9000e-
004
2.6000e-
004
1.0000e-
005
2.7000e-
004
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 0.8835 0.8835
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 6.1300e-
003
0.0661 0.0461 1.1000e-
004
2.8700e-
003
2.8700e-
003
2.7000e-
003
2.7000e-
003
0.0000 9.9551 9.9551 2.8000e-
003
0.0000 10.0253
Total 6.1300e-
003
0.0661 0.0461 1.1000e-
004
2.8000e-
003
0.0000 10.02530.0000 2.8700e-
003
2.8700e-
003
0.0000 2.7000e-
003
2.7000e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 9.9551 9.9551
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.8000e-
004
2.7000e-
004
3.0400e-
003
1.0000e-
005
9.9000e-
004
1.0000e-
005
9.9000e-
004
2.6000e-
004
1.0000e-
005
2.7000e-
004
0.0000 0.8835 0.8835 2.0000e-
005
0.0000 0.8840
Total 3.8000e-
004
2.7000e-
004
3.0400e-
003
1.0000e-
005
2.0000e-
005
0.0000 0.88409.9000e-
004
1.0000e-
005
9.9000e-
004
2.6000e-
004
1.0000e-
005
2.7000e-
004
0.0000 0.8835 0.8835
A-11
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
3.4 Grading/Excavation Operation - 2019
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0174 0.1719 0.1773 2.5000e-
004
0.0108 0.0108 9.9700e-
003
9.9700e-
003
0.0000 22.7165 22.7165 7.1900e-
003
0.0000 22.8962
Total 0.0174 0.1719 0.1773 2.5000e-
004
7.1900e-
003
0.0000 22.89620.0000 0.0108 0.0108 0.0000 9.9700e-
003
9.9700e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 22.7165 22.7165
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0237 0.8627 0.2055 2.1700e-
003
0.0483 3.2400e-
003
0.0515 0.0133 3.1000e-
003
0.0163 0.0000 219.1397 219.1397 0.0233 0.0000 219.7216
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 8.4000e-
004
6.1000e-
004
6.7700e-
003
2.0000e-
005
2.2000e-
003
1.0000e-
005
2.2100e-
003
5.8000e-
004
1.0000e-
005
6.0000e-
004
0.0000 1.9632 1.9632 5.0000e-
005
0.0000 1.9645
Total 0.0245 0.8633 0.2122 2.1900e-
003
0.0233 0.0000 221.68610.0505 3.2500e-
003
0.0538 0.0138 3.1100e-
003
0.0169
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 221.1029 221.1029
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0174 0.1719 0.1773 2.5000e-
004
0.0108 0.0108 9.9700e-
003
9.9700e-
003
0.0000 22.7165 22.7165 7.1900e-
003
0.0000 22.8962
Total 0.0174 0.1719 0.1773 2.5000e-
004
7.1900e-
003
0.0000 22.89620.0000 0.0108 0.0108 0.0000 9.9700e-
003
9.9700e-
003
0.0000 22.7165 22.7165
A-12
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0237 0.8627 0.2055 2.1700e-
003
0.0483 3.2400e-
003
0.0515 0.0133 3.1000e-
003
0.0163 0.0000 219.1397 219.1397 0.0233 0.0000 219.7216
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 8.4000e-
004
6.1000e-
004
6.7700e-
003
2.0000e-
005
2.2000e-
003
1.0000e-
005
2.2100e-
003
5.8000e-
004
1.0000e-
005
6.0000e-
004
0.0000 1.9632 1.9632 5.0000e-
005
0.0000 1.9645
Total 0.0245 0.8633 0.2122 2.1900e-
003
0.0233 0.0000 221.68610.0505 3.2500e-
003
0.0538 0.0138 3.1100e-
003
0.0169
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 221.1029 221.1029
PM2.5
Total
Bio- CO2 NBio- CO2
3.5 Paving/Concrete Structure - 2019
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0356 0.3259 0.2345 4.3000e-
004
0.0171 0.0171 0.0159 0.0159 0.0000 35.5819 35.5819 9.4500e-
003
0.0000 35.8180
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0356 0.3259 0.2345 4.3000e-
004
9.4500e-
003
0.0000 35.81800.0171 0.0171 0.0159 0.0159
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 35.5819 35.5819
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.2400e-
003
2.3600e-
003
0.0262 8.0000e-
005
8.5100e-
003
6.0000e-
005
8.5700e-
003
2.2600e-
003
5.0000e-
005
2.3100e-
003
0.0000 7.6075 7.6075 1.9000e-
004
0.0000 7.6122
Total 3.2400e-
003
2.3600e-
003
0.0262 8.0000e-
005
1.9000e-
004
0.0000 7.61228.5100e-
003
6.0000e-
005
8.5700e-
003
2.2600e-
003
5.0000e-
005
2.3100e-
003
0.0000 7.6075 7.6075
A-13
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0356 0.3259 0.2345 4.3000e-
004
0.0171 0.0171 0.0159 0.0159 0.0000 35.5818 35.5818 9.4500e-
003
0.0000 35.8180
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0356 0.3259 0.2345 4.3000e-
004
9.4500e-
003
0.0000 35.81800.0171 0.0171 0.0159 0.0159
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 35.5818 35.5818
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.2400e-
003
2.3600e-
003
0.0262 8.0000e-
005
8.5100e-
003
6.0000e-
005
8.5700e-
003
2.2600e-
003
5.0000e-
005
2.3100e-
003
0.0000 7.6075 7.6075 1.9000e-
004
0.0000 7.6122
Total 3.2400e-
003
2.3600e-
003
0.0262 8.0000e-
005
1.9000e-
004
0.0000 7.61228.5100e-
003
6.0000e-
005
8.5700e-
003
2.2600e-
003
5.0000e-
005
2.3100e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 7.6075 7.6075
PM2.5
Total
Bio- CO2 NBio- CO2
3.5 Paving/Concrete Structure - 2020
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0259 0.2347 0.1784 3.4000e-
004
0.0120 0.0120 0.0112 0.0112 0.0000 27.0914 27.0914 7.3100e-
003
0.0000 27.2742
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0259 0.2347 0.1784 3.4000e-
004
7.3100e-
003
0.0000 27.27420.0120 0.0120 0.0112 0.0112 0.0000 27.0914 27.0914
A-14
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 2.3400e-
003
1.6400e-
003
0.0186 6.0000e-
005
6.5900e-
003
4.0000e-
005
6.6300e-
003
1.7500e-
003
4.0000e-
005
1.7900e-
003
0.0000 5.7010 5.7010 1.3000e-
004
0.0000 5.7042
Total 2.3400e-
003
1.6400e-
003
0.0186 6.0000e-
005
1.3000e-
004
0.0000 5.70426.5900e-
003
4.0000e-
005
6.6300e-
003
1.7500e-
003
4.0000e-
005
1.7900e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 5.7010 5.7010
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0259 0.2347 0.1784 3.4000e-
004
0.0120 0.0120 0.0112 0.0112 0.0000 27.0914 27.0914 7.3100e-
003
0.0000 27.2742
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0259 0.2347 0.1784 3.4000e-
004
7.3100e-
003
0.0000 27.27420.0120 0.0120 0.0112 0.0112
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 27.0914 27.0914
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 2.3400e-
003
1.6400e-
003
0.0186 6.0000e-
005
6.5900e-
003
4.0000e-
005
6.6300e-
003
1.7500e-
003
4.0000e-
005
1.7900e-
003
0.0000 5.7010 5.7010 1.3000e-
004
0.0000 5.7042
Total 2.3400e-
003
1.6400e-
003
0.0186 6.0000e-
005
1.3000e-
004
0.0000 5.70426.5900e-
003
4.0000e-
005
6.6300e-
003
1.7500e-
003
4.0000e-
005
1.7900e-
003
0.0000 5.7010 5.7010
A-15
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
3.6 Shotcrete - 2019
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 3.6400e-
003
0.0292 0.0303 5.0000e-
005
1.7000e-
003
1.7000e-
003
1.6500e-
003
1.6500e-
003
0.0000 4.3168 4.3168 8.5000e-
004
0.0000 4.3380
Total 3.6400e-
003
0.0292 0.0303 5.0000e-
005
8.5000e-
004
0.0000 4.33801.7000e-
003
1.7000e-
003
1.6500e-
003
1.6500e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 4.3168 4.3168
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 1.3200e-
003
0.0399 0.0109 9.0000e-
005
2.1700e-
003
2.7000e-
004
2.4400e-
003
6.3000e-
004
2.6000e-
004
8.8000e-
004
0.0000 8.4564 8.4564 7.4000e-
004
0.0000 8.4749
Worker 5.9800e-
003
4.3700e-
003
0.0485 1.6000e-
004
0.0157 1.1000e-
004
0.0158 4.1800e-
003
1.0000e-
004
4.2700e-
003
0.0000 14.0617 14.0617 3.5000e-
004
0.0000 14.0703
Total 7.3000e-
003
0.0443 0.0593 2.5000e-
004
1.0900e-
003
0.0000 22.54520.0179 3.8000e-
004
0.0183 4.8100e-
003
3.6000e-
004
5.1500e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 22.5181 22.5181
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 3.6400e-
003
0.0292 0.0303 5.0000e-
005
1.7000e-
003
1.7000e-
003
1.6500e-
003
1.6500e-
003
0.0000 4.3168 4.3168 8.5000e-
004
0.0000 4.3380
Total 3.6400e-
003
0.0292 0.0303 5.0000e-
005
8.5000e-
004
0.0000 4.33801.7000e-
003
1.7000e-
003
1.6500e-
003
1.6500e-
003
0.0000 4.3168 4.3168
A-16
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 1.3200e-
003
0.0399 0.0109 9.0000e-
005
2.1700e-
003
2.7000e-
004
2.4400e-
003
6.3000e-
004
2.6000e-
004
8.8000e-
004
0.0000 8.4564 8.4564 7.4000e-
004
0.0000 8.4749
Worker 5.9800e-
003
4.3700e-
003
0.0485 1.6000e-
004
0.0157 1.1000e-
004
0.0158 4.1800e-
003
1.0000e-
004
4.2700e-
003
0.0000 14.0617 14.0617 3.5000e-
004
0.0000 14.0703
Total 7.3000e-
003
0.0443 0.0593 2.5000e-
004
1.0900e-
003
0.0000 22.54520.0179 3.8000e-
004
0.0183 4.8100e-
003
3.6000e-
004
5.1500e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 22.5181 22.5181
PM2.5
Total
Bio- CO2 NBio- CO2
3.7 Building Construction/Framing - 2020
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0420 0.3907 0.3043 5.4000e-
004
0.0217 0.0217 0.0206 0.0206 0.0000 46.6703 46.6703 0.0107 0.0000 46.9378
Total 0.0420 0.3907 0.3043 5.4000e-
004
0.0107 0.0000 46.93780.0217 0.0217 0.0206 0.0206
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 46.6703 46.6703
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 5.2400e-
003
0.1708 0.0464 4.0000e-
004
0.0101 8.8000e-
004
0.0110 2.9200e-
003
8.4000e-
004
3.7700e-
003
0.0000 39.1915 39.1915 3.2700e-
003
0.0000 39.2734
Worker 0.0261 0.0183 0.2072 7.0000e-
004
0.0734 4.9000e-
004
0.0739 0.0195 4.5000e-
004
0.0199 0.0000 63.5182 63.5182 1.4500e-
003
0.0000 63.5545
Total 0.0313 0.1890 0.2537 1.1000e-
003
4.7200e-
003
0.0000 102.82780.0835 1.3700e-
003
0.0849 0.0224 1.2900e-
003
0.0237 0.0000 102.7097 102.7097
A-17
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Off-Road 0.0420 0.3907 0.3043 5.4000e-
004
0.0217 0.0217 0.0206 0.0206 0.0000 46.6703 46.6703 0.0107 0.0000 46.9377
Total 0.0420 0.3907 0.3043 5.4000e-
004
0.0107 0.0000 46.93770.0217 0.0217 0.0206 0.0206
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 46.6703 46.6703
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 5.2400e-
003
0.1708 0.0464 4.0000e-
004
0.0101 8.8000e-
004
0.0110 2.9200e-
003
8.4000e-
004
3.7700e-
003
0.0000 39.1915 39.1915 3.2700e-
003
0.0000 39.2734
Worker 0.0261 0.0183 0.2072 7.0000e-
004
0.0734 4.9000e-
004
0.0739 0.0195 4.5000e-
004
0.0199 0.0000 63.5182 63.5182 1.4500e-
003
0.0000 63.5545
Total 0.0313 0.1890 0.2537 1.1000e-
003
4.7200e-
003
0.0000 102.82780.0835 1.3700e-
003
0.0849 0.0224 1.2900e-
003
0.0237
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 102.7097 102.7097
PM2.5
Total
Bio- CO2 NBio- CO2
3.8 Skin/Finishes/Sitework - 2020
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Archit. Coating 0.4390 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.1015 0.9996 0.6787 1.3100e-
003
0.0512 0.0512 0.0484 0.0484 0.0000 113.9847 113.9847 0.0278 0.0000 114.6802
Total 0.5405 0.9996 0.6787 1.3100e-
003
0.0278 0.0000 114.68020.0512 0.0512 0.0484 0.0484 0.0000 113.9847 113.9847
A-18
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0107 7.4700e-
003
0.0848 2.9000e-
004
0.0300 2.0000e-
004
0.0302 7.9800e-
003
1.9000e-
004
8.1600e-
003
0.0000 25.9964 25.9964 5.9000e-
004
0.0000 26.0112
Total 0.0107 7.4700e-
003
0.0848 2.9000e-
004
5.9000e-
004
0.0000 26.01120.0300 2.0000e-
004
0.0302 7.9800e-
003
1.9000e-
004
8.1600e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 25.9964 25.9964
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Archit. Coating 0.4390 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.1015 0.9996 0.6787 1.3100e-
003
0.0512 0.0512 0.0484 0.0484 0.0000 113.9845 113.9845 0.0278 0.0000 114.6801
Total 0.5405 0.9996 0.6787 1.3100e-
003
0.0278 0.0000 114.68010.0512 0.0512 0.0484 0.0484
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 113.9845 113.9845
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0107 7.4700e-
003
0.0848 2.9000e-
004
0.0300 2.0000e-
004
0.0302 7.9800e-
003
1.9000e-
004
8.1600e-
003
0.0000 25.9964 25.9964 5.9000e-
004
0.0000 26.0112
Total 0.0107 7.4700e-
003
0.0848 2.9000e-
004
5.9000e-
004
0.0000 26.01120.0300 2.0000e-
004
0.0302 7.9800e-
003
1.9000e-
004
8.1600e-
003
0.0000 25.9964 25.9964
A-19
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
3.8 Skin/Finishes/Sitework - 2021
Unmitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Archit. Coating 0.1402 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0294 0.2886 0.2112 4.2000e-
004
0.0142 0.0142 0.0134 0.0134 0.0000 36.4102 36.4102 8.7800e-
003
0.0000 36.6298
Total 0.1696 0.2886 0.2112 4.2000e-
004
8.7800e-
003
0.0000 36.62980.0142 0.0142 0.0134 0.0134
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 36.4102 36.4102
PM2.5
Total
Bio- CO2 NBio- CO2
Unmitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.2000e-
003
2.1500e-
003
0.0251 9.0000e-
005
9.5900e-
003
6.0000e-
005
9.6600e-
003
2.5500e-
003
6.0000e-
005
2.6100e-
003
0.0000 8.0162 8.0162 1.7000e-
004
0.0000 8.0205
Total 3.2000e-
003
2.1500e-
003
0.0251 9.0000e-
005
1.7000e-
004
0.0000 8.02059.5900e-
003
6.0000e-
005
9.6600e-
003
2.5500e-
003
6.0000e-
005
2.6100e-
003
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 8.0162 8.0162
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction On-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Archit. Coating 0.1402 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0294 0.2886 0.2112 4.2000e-
004
0.0142 0.0142 0.0134 0.0134 0.0000 36.4101 36.4101 8.7800e-
003
0.0000 36.6297
Total 0.1696 0.2886 0.2112 4.2000e-
004
8.7800e-
003
0.0000 36.62970.0142 0.0142 0.0134 0.0134 0.0000 36.4101 36.4101
A-20
SO2 Fugitive
PM10
Exhaust
PM10
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated Construction Off-Site
ROG NOx CO Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.2000e-
003
2.1500e-
003
0.0251 9.0000e-
005
9.5900e-
003
6.0000e-
005
9.6600e-
003
2.5500e-
003
6.0000e-
005
2.6100e-
003
0.0000 8.0162 8.0162 1.7000e-
004
0.0000 8.0205
Total 3.2000e-
003
2.1500e-
003
0.0251 9.0000e-
005
1.7000e-
004
0.0000 8.02059.5900e-
003
6.0000e-
005
9.6600e-
003
2.5500e-
003
6.0000e-
005
2.6100e-
003
CO SO2 Fugitive
PM10
0.0000 8.0162 8.0162
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
ROG NOx NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Exhaust
PM10
PM10
Total
Mitigated 0.1994 0.8729 2.7732 0.0105 0.9409 7.7300e-
003
0.9486 0.2520 7.2000e-
003
0.2592 0.0000 964.2976 964.2976 0.0401 0.0000 965.2989
Unmitigated 0.1994 0.8729 2.7732 0.0105 0.9409 7.7300e-
003
0.9486 0.2520 7.2000e-
003
0.2592 0.0000 964.2976 964.2976 0.0401 0.0000 965.2989
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Mid Rise 726.45 726.45 726.45 2,480,888 2,480,888
Enclosed Parking Structure 0.00 0.00 0.00
Total 726.45 726.45 726.45 2,480,888 2,480,888
4.3 Trip Type Information
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-
W
H-S or C-C H-O or C-NW Primary Diverted Pass-by
Apartments Mid Rise 14.70 5.90 8.70 40.00 19.00 41.00 86 11 3
Enclosed Parking Structure 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Apartments Mid Rise 0.558976 0.043534 0.209821 0.113949 0.016111 0.005791 0.025447 0.016654 0.001713 0.001553 0.004896 0.000590 0.000966
Enclosed Parking Structure 0.558976 0.043534 0.209821 0.113949 0.016111 0.005791 0.025447 0.016654 0.001713 0.001553 0.004896 0.000590 0.000966
A-21
5.0 Energy Detail
Historical Energy Use: N
5.1 Mitigation Measures Energy
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 407.0915 407.0915 0.0184 3.6800e-
003
408.6466
Electricity
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 407.0915 407.0915 0.0184 3.6800e-
003
408.6466
NaturalGas
Mitigated
0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.4439
NaturalGas
Unmitigated
0.0103 0.0879 0.0374 5.6000e-
004
101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.44397.1100e-
003
7.1100e-
003
7.1100e-
003
ROG NOx CO SO2 Fugitive
PM10
0.00007.1100e-
003
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGa
s Use
NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Exhaust
PM10
Apartments Mid
Rise
1.90839e+
006
0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.4439
Enclosed Parking
Structure
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.4439
Mitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Apartments Mid
Rise
1.90839e+
006
0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.4439
Enclosed Parking
Structure
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0103 0.0879 0.0374 5.6000e-
004
7.1100e-
003
7.1100e-
003
7.1100e-
003
7.1100e-
003
0.0000 101.8387 101.8387 1.9500e-
003
1.8700e-
003
102.4439
A-22
5.3 Energy by Land Use - Electricity
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr t
o
n
MT/yr
Apartments Mid
Rise
663875 166.7259 7.5300e-
003
1.5100e-
003
167.3628
Enclosed Parking
Structure
957096 240.3656 0.0109 2.1700e-
003
241.2837
Total 407.0915 0.0184 3.6800e-
003
408.6465
Mitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr t
o
n
MT/yr
Apartments Mid
Rise
663875 166.7259 7.5300e-
003
1.5100e-
003
167.3628
Enclosed Parking
Structure
957096 240.3656 0.0109 2.1700e-
003
241.2837
Total 407.0915 0.0184 3.6800e-
003
408.6465
6.0 Area Detail
6.1 Mitigation Measures Area
Use only Natural Gas Hearths
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.7669 0.0494 1.7439 2.8000e-
004
0.0119 0.0119 0.0119 0.0119 0.0000 36.9112 36.9112 3.4100e-
003
6.2000e-
004
37.1826
Unmitigated 0.7669 0.0494 1.7439 36.9112 36.9112 3.4100e-
003
6.2000e-
004
2.8000e-
004
0.0119 0.0119 0.0119 0.0119 0.0000 37.1826
A-23
NOx CO SO2 Fugitive
PM10
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
6.2 Area by SubCategory
Unmitigated
ROG NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Exhaust
PM10
PM10
Total
Architectural
Coating
0.0579 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.6527 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 3.4400e-
003
0.0294 0.0125 1.9000e-
004
2.3800e-
003
2.3800e-
003
2.3800e-
003
2.3800e-
003
0.0000 34.0875 34.0875 6.5000e-
004
6.2000e-
004
34.2900
Landscaping 0.0528 0.0200 1.7314 9.0000e-
005
9.5300e-
003
9.5300e-
003
9.5300e-
003
9.5300e-
003
0.0000 2.8237 2.8237 2.7500e-
003
0.0000 2.8925
Total 0.7669 0.0494 1.7439 2.8000e-
004
3.4000e-
003
6.2000e-
004
37.18260.0119 0.0119 0.0119 0.0119
SO2 Fugitive
PM10
Exhaust
PM10
0.0000 36.9112 36.9112
PM2.5
Total
Bio- CO2 NBio- CO2
Mitigated
ROG NOx CO Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
Architectural
Coating
0.0579 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.6527 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 3.4400e-
003
0.0294 0.0125 1.9000e-
004
2.3800e-
003
2.3800e-
003
2.3800e-
003
2.3800e-
003
0.0000 34.0875 34.0875 6.5000e-
004
6.2000e-
004
34.2900
Landscaping 0.0528 0.0200 1.7314 9.0000e-
005
9.5300e-
003
9.5300e-
003
9.5300e-
003
9.5300e-
003
0.0000 2.8237 2.8237 2.7500e-
003
0.0000 2.8925
Total 0.7669 0.0494 1.7439 2.8000e-
004
0.0119 0.0119 0.0119 0.0119 0.0000 36.9112 36.9112 3.4000e-
003
6.2000e-
004
37.1826
A-24
7.0 Water Detail
7.1 Mitigation Measures Water
Apply Water Conservation Strategy
Total CO2 CH4 N2O CO2e
Category t
o
n
MT/yr
Mitigated 46.5379 0.2856 7.0900e-
003
55.7919
Unmitigated 58.1724 0.3570 8.8700e-
003
69.7399
7.2 Water by Land Use
Unmitigated
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal t
o
n
MT/yr
Apartments Mid
Rise
10.8807 /
6.85959
58.1724 0.3570 8.8700e-
003
69.7399
Enclosed Parking
Structure
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 58.1724 0.3570 8.8700e-
003
69.7399
Mitigated
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal t
o
n
MT/yr
Apartments Mid
Rise
8.70458 /
5.48767
46.5379 0.2856 7.0900e-
003
55.7919
Enclosed Parking
Structure
0 / 0 0.0000 0.0000 0.0000 0.0000
Total 46.5379 0.2856 7.0900e-
003
55.7919
A-25
8.0 Waste Detail
8.1 Mitigation Measures Waste
Institute Recycling and Composting Services
Category/Year
Total CO2 CH4 N2O CO2e
t
o
n
MT/yr
Mitigated 13.0988 0.7741 0.0000 32.4516
Unmitigated 15.5938 0.9216 0.0000 38.6329
8.2 Waste by Land Use
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons t
o
n
MT/yr
Apartments Mid
Rise
76.82 15.5938 0.9216 0.0000 38.6329
Enclosed Parking
Structure
0 0.0000 0.0000 0.0000 0.0000
Total 15.5938 0.9216 0.0000 38.6329
Mitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons t
o
n
MT/yr
Apartments Mid
Rise
64.5288 13.0988 0.7741 0.0000
0.7741 0.0000
32.4516
Enclosed Parking
Structure
0 0.0000 0.0000 0.0000 0.0000
32.4516Total13.0988
A-26
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year
Heat Input/Year Boiler Rating Fuel Type
Horse Power Load Factor Fuel Type
Horse Power
User Defined Equipment
Equipment Type Number
11.0 Vegetation
Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day
A-27