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Air District Delays GHG Guidelines

For a second time, the Bay Area Air Quality Management District (BAAQMD) has postponed adoption of California Environmental Quality Act (CEQA) thresholds of significance for greenhouse gas emissions. The district board delayed a decision until April in the face of ongoing opposition to the thresholds from local governments and some environmentalists, who argue the standards could have unintended consequences.

The thresholds of significance are intended to guide cities and counties as they review the potential impact of land use projects, stationary sources of pollution and general plans under CEQA. The air district has intentionally proposed quite strict project thresholds. For example, the typical 55-house subdivision or 77-unit condominium project would generate enough greenhouse gas (GHG) emissions for GHG to be considered a potentially significant impact; therefore, the project would need an environmental impact report.

Planners in Berkeley, Oakland, San Francisco and other cities argue that the thresholds are not adequately location-sensitive and could require that desirable infill and redevelopment projects undergo an EIR, rather than a faster and cheaper level of environmental review. The planners also question whether the thresholds would apply to infill projects that otherwise qualify for exemption from CEQA. The planners as well as development representatives and some environmentalists say the air district should ensure streamlined review of infill proposals.

Other environmentalists and the attorney general's office, meanwhile, have endorsed the thresholds. Air district staff members argue the thresholds are location-sensitive because infill projects close to transit and a mix of land uses would generate fewer GHG emissions than automobile-dependent subdivisions on the fringe. They also say that a project that complies with a city or county climate action plan (many of which are being prepared) could be afforded a "presumption of insignificance" and, therefore, proceed without an EIR.

The BAAQMD would be the first air district in the state to adopt thresholds of significance for greenhouse gas emissions. The proposed thresholds and background documents are available on the district website.

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