Sailing Through CEQA Continued from page 34
agencies during analyses, stay up to date as much as possible
on pending new regulations, standards, and/or guidelines, be
as responsive to agency requests as practicable, and do what
you can to keep the schedule for preparing your CEQA docu-ment
as short as possible.
GHG Analysis
Evaluating the impact of GHG emissions related to climate
change is another topic that has continued to evolve in Califor-nia
over the past decade. While some areas continue to rely on
California regulations or statewide plans, many cities and coun-ties
have adopted Climate Action Plans (CAPs) or other types of
planning documents such as General Plan updates which they
use to guide development decisions related to GHG emissions.
The Air Resources Board has delegated determination and im-plementation
of quantitative thresholds of significance to Cal-ifornia’s
35 air districts, some of which are still engaged in the
drafting, proposal and adopting CEQA guidelines and signifi-cance
criteria for GHG emissions. Such indeterminate criteria
have left proponents struggling for ways to convince the Lead
Agency that a project would have less than significant GHG
emissions or impacts related to climate change. CAPs generally
include requirements for energy efficiency, transit access, wa-ter
36 SOURCE winter 2017
conservation, recycling, and other approaches that reduce
GHG emissions over the long term. One approach especially
applicable to non-industrial projects is to propose that a project
will implement energy efficiency, trip reduction, drought-tol-erant
landscaping, or other measures that reduce GHGs to be-low
“business as usual” (BAU) levels. Most agencies will accept
that a project with definitive mitigation measures that decrease
emissions compared to BAU, whether contained in a local CAP
or statewide goal, would be consistent with the plan, and hence
have less than significant impacts.
In conclusion, we highly recommend careful consideration
of which type of CEQA document will provide the best as-surance
of a successful planning process, as opposed to what
seems most expedient at the time, and then design the project
to minimize impacts. For projects that also require air permits,
be sure that the CEQA document has fully analyzed the ex-pected
emissions, and then some, leaving room for potential
designing changes later. Avoid revising the project once the
process has begun, as changes can significantly throw the
schedule off-track. And keep abreast of potential regulatory
or guideline changes, including those related to GHG emis-sions,
to minimize surprises and the need for rework as much
as possible. S
MANAGER’S CORNER