HomeMy WebLinkAboutItem 15 - COUNCIL READING FILE_g_CAP Appendix C - CEQA GHG Thresholds, Guidance, and Checklist Climate Action Plan for Community Recovery
Attachment C – CEQA GHG Emissions Thresholds and Guidance
City of San Luis Obispo
California Environmental Quality Act (CEQA)
Greenhouse Gas (GHG) Emissions
Thresholds and Guidance
Final
prepared by
City of San Luis Obispo
Office of Sustainability and
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401
prepared with assistance from
Rincon Consultants, Inc.
1530 Monterey Street, Suite D
San Luis Obispo, CA 93401
June 22, 2020
Table of Contents
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City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
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Table of Contents
1 Introduction .............................................................................................................................. 1
2 Climate Action Plan Summary .................................................................................................... 3
2.1 Communitywide GHG Emissions Inventories................................................................... 3
2.2 GHG Emission Reduction Strategy .................................................................................. 3
2.3 GHG Emissions Forecast ................................................................................................. 5
2.4 Qualified GHG Emissions Reduction Plan ........................................................................ 8
3 Regulatory and Legal Setting .................................................................................................... 11
3.1 Relevant CEQA Guidelines Sections .............................................................................. 11
3.2 Relevant State and Regional GHG Reduction Targets .................................................... 15
3.3 Relevant GHG Emissions Analysis Case Law .................................................................. 17
4 Determining Consistency with the City’s Climate Action Plan ................................................... 19
5 Utilizing Quantitative CEQA GHG Thresholds ........................................................................... 22
5.1 GHG Emissions Calculation Methodology ..................................................................... 22
5.2 GHG Thresholds and Use .............................................................................................. 24
5.3 Justification for Thresholds ........................................................................................... 26
6 Quantifying GHG Emissions...................................................................................................... 29
6.1 Construction GHG Emissions ........................................................................................ 29
6.2 Operational GHG Emissions .......................................................................................... 30
6.3 Modeling GHG Emissions from Existing Land Use.......................................................... 33
7 Moving into the Future ............................................................................................................ 35
Tables
Table 1 City of San Luis Obispo 1990, 2005, and 2016 Communitywide GHG Emissions Levels .... 3
Table 2 City of San Luis Obispo Communitywide GHG Emissions Reductions by 2035 .................. 5
Table 3 City of San Luis Obispo GHG Emissions Forecast Through 2035 ....................................... 7
Table 4 CAP Consistency with CEQA Guidelines Section 15183.5(1) for Year 2030 ..................... 10
Table 5 GHG Emissions Forecast for Year 2030 by Type of Development (MT of CO2e) .............. 24
Table 6 City of San Luis Obispo Demographic Projections .......................................................... 24
Table 7 City of San Luis Obispo Locally Applicable Plan- or Project-Specific CEQA GHG Emissions
Thresholds ..................................................................................................................... 25
Table of Contents
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Figures
Figure 1 City of San Luis Obispo GHG Emissions Reduction Targets ........................................ 1
Figure 2 City of San Luis Obispo GHG Emissions Forecast, 2005 to 2035 ................................. 6
Figure 3 Determining Consistency with the City’s Climate Action Plan .................................. 20
Figure 4 Allowable GHG Emissions from Existing and New Development in Year 2030 ......... 23
Figure 5 City of San Luis Obispo GHG Efficiency Thresholds .................................................. 25
Appendices
Appendix A Overview of GHG Emissions and Climate Change
Appendix B CEQA GHG Emissions Analysis Compliance Checklist
Appendix C GHG Threshold Calculations
Appendix D United States Green Building Council Building Area per Employee by Business
Type Rates
Introduction
1
1 Introduction
The California Environmental Quality Act (CEQA) requires discretionary plans and projects to
undergo an environmental review process, which includes an evaluation of plan- or project-related
greenhouse gas (GHG) emissions.1 This GHG thresholds and guidance document is intended to
provide methodological guidance and quantitative thresholds of significance for use by City
planners, applicants, consultants, agencies, and members of the public in the preparation of GHG
emissions analyses under CEQA for plans and projects located within the City of San Luis Obispo.
The City of San Luis Obispo (City) prepared a Draft Climate Action Plan (CAP) dated June 17, 2020
with the aspirational goal of carbon neutrality by 2035.2 While the City Council, City staff, and
community will continue to develop an approach to the long-term aspirational goal of carbon
neutrality, the CAP includes specific actions to achieve the short-term communitywide emissions
reduction targets of 45 percent below 1990 levels by 2030 and 66 percent below 1990 levels by
2035, which is consistent with California’s goal of reducing GHG emissions to 40 percent below 1990
levels (Senate Bill 32) by 2030. See Figure 1 for a representation of City and State GHG emissions
reduction targets.
Figure 1 City of San Luis Obispo GHG Emissions Reduction Targets
The City’s 2030 target was developed to provide substantial progress towards the City’s long-term
aspirational carbon neutrality target and contribute substantial progress toward meeting the State’s
long-term GHG reduction goals identified in SB 32 and Executive Order (EO) B-55-18. Consistent
with this process, the City’s CAP includes procedures to evaluate the City’s emissions in light of the
trajectory of the CAP’s targets to assess its “substantial progress” toward achieving long‐term
reduction targets identified in the CAP and State legislation or EOs. The CAP also includes
commitments and mechanisms to adopt additional policies to achieve further GHG emissions
reductions necessary to avoid interference with, and make substantial progress toward, the long-
1 Refer to Appendix A for an overview of GHG emissions and climate change.
2 Carbon neutrality is defined as net zero carbon emissions, which is achieved either by balancing carbon emissions with carbon removal
or by completely eliminating carbon emissions.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
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term CAP and State targets. This is important because these targets have been set at levels that
achieve California’s fair share of international emissions reduction targets that will stabilize global
climate change effects and avoid the adverse environmental consequences of climate change.
To support progress toward the City’s long-term aspirational carbon neutrality goal, plans and
projects within the City that undergo CEQA review will need to demonstrate consistency with
targets in the CAP, which will be a Qualified GHG Emissions Reduction Plan, consistent with CEQA
Guidelines Section 15183.5, upon adoption of its CEQA review document, specifically the CAP Initial
Study-Negative Declaration (IS-ND), and approval of the CAP by City Council. Chapter 2, Climate
Action Plan Summary, provides an overview of this plan and the associated GHG emissions
inventories, reduction measures, and forecasts included therein. In addition, Chapter 3, Regulatory
and Legal Setting, offers an overview of relevant regulations and case law pertaining to the analysis
of GHG emissions consistent with CEQA and the CEQA Guidelines.
Plans and projects that are consistent with the CAP’s demographic (i.e., residents and employees)
projections and land use assumptions, which are based on the Land Use and Circulation Elements of
the 2014 City General Plan, will be able to tier from the adopted CAP IS-ND pursuant to CEQA
Guidelines Section 15183.5. To streamline this CEQA GHG emissions analysis process, the City has
prepared a CEQA GHG Emissions Analysis Compliance Checklist that can be utilized in plan- and
project-level CEQA review documents to ensure that such proposed plans and projects are
consistent with the CAP GHG emissions reduction strategy. Chapter 4, Determining Consistency with
the City’s C, includes guidance on how to navigate this consistency determination process.
For plans or projects that are not consistent with the CAP’s demographic projections and land use
assumptions, a different methodology and assessment utilizing quantitative thresholds of
significance would be necessary to evaluate GHG emissions impacts. Chapter 5, Utilizing
Quantitative CEQA GHG Thresholds, includes guidance on how to utilize the specific quantitative
thresholds that were developed for purposes of evaluating the level of significance of GHG
emissions impacts.3 Furthermore, Chapter 6, Quantifying GHG Emissions, provides direction
regarding how to quantify a plan or project’s GHG emissions for comparison to the applicable
threshold of significance.
The City’s CAP acknowledges that additional actions beyond those identified in the plan will be
required to achieve its long-term aspirational goal of carbon neutrality by 2035. As a result, the plan
provides a mechanism for updating and adopting a new CAP every other financial plan cycle (i.e., in
conjunction with the 2023-2025, 2027-2029, and 2031-2033 cycles) in order to incorporate new
measures and technologies that will further move the City toward meeting its long-term aspirational
carbon neutrality goal.4 Chapter 7, Moving into the Future, offers further explanation of how CEQA
review of plans and projects could be affected by future updates and/or iterations of the CAP.
3 In compliance with CEQA Guidelines Section 15064.7(b), this guidance document and the quantitative thresholds contained herei n will
be presented to the City Council for formal adoption via resolution through a public review process, which will include a n opportunity
for public input.
4 San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report. November 2019.
Climate Action Plan Summary
3
2 Climate Action Plan Summary
The following sections provide an overview of the City’s CAP, including the 2005 and 2016
communitywide GHG emissions inventories, proposed GHG emission reduction strategy, and the
communitywide GHG emissions forecast for years 2020, 2030, and 2035.
2.1 Communitywide GHG Emissions Inventories
The City has completed communitywide GHG emissions inventories for years 2005 and 2016, which
are summarized in Table 1. Table 1 also provides estimated 1990 emissions levels for informational
purposes. As shown therein, communitywide GHG emissions declined by approximately 12 percent
between 2005 and 2016, which indicates substantial progress toward meeting or exceeding the
City’s target of reducing emissions by approximately 15 percent below 2005 levels by 2020 and the
State’s target of reducing emissions to 1990 levels (i.e., an approximately 15 percent reduction
below 2005 levels) by 2020. The most significant changes occurred in the energy and solid waste
sectors due to increasing decarbonization of the electricity grid, investments in energy efficiency,
and a decrease in the amount of solid waste generated.5
Table 1 City of San Luis Obispo 1990, 2005, and 2016 Communitywide GHG Emissions
Levels
Sector
1990
(MT of CO2e)1
2005
(MT of CO2e)
2016
(MT of CO2e)
Percent Change from
2005 to 2016
Transportation 191,580 225,390 212,980 -6%
Non-residential Energy 49,340 58,050 44,270 -24%
Residential Energy 47,130 55,450 39,410 -29%
Solid Waste 40,580 47,740 42,630 -11%
Total 328,630 386,630 339,290 -12%
MT = metric tons; CO2e = carbon dioxide equivalents
Note: Numbers are rounded to the nearest ten.
1 AB 32 sets a target of reducing GHG emissions to 1990 levels by 2020, which is considered equivalent to a 15 percent reduction in
baseline 2005 levels according to the CARB (2008) Climate Change Scoping Plan. Therefore, to estimate 1990 emissions levels,
inventoried 2005 emissions from each sector were reduced by 15 percent.
Source: San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
2.2 GHG Emission Reduction Strategy
To achieve the City’s long-term aspirational goal of carbon neutrality by 2035, the City’s CAP
includes a series of pillars, measures, and foundational actions that are intended to reduce
communitywide GHG emissions by approximately 66 percent below 1990 levels by 2035, which
provides substantial progress toward meeting the City’s long-term aspirational carbon neutrality
goal while exceeding the State’s goals. The CAP acknowledges that additional actions beyond those
identified in the plan will be necessary to achieve the long-term aspirational goal of carbon
neutrality and therefore provides a mechanism for updating and adopting a new climate action plan
5 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast .
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
4
every other financial plan cycle in order to incorporate new measures and technologies that will
further the City toward meeting its long-term aspirational goal of carbon neutrality.6
The City’s CAP proposes the following six pillars, each of which include a long-term goal, measures,
and foundational actions:7
▪ Pillar 1: Lead by Example. Create a Municipal Action Plan by 2020 and achieve carbon-neutral
government operations by 2030.
▪ Pillar 2: Clean Energy Systems. Achieve 100 percent carbon-free electricity by 2020.
▪ Pillar 3: Green Buildings. Generate no net new building emissions from on-site energy use by
2020 and achieve a 50 percent reduction in existing building on-site emissions (after accounting
for Monterey Bay Community Power) by 2030.
▪ Pillar 4: Connected Community. Achieve the General Plan mode split objective by 2030 and
have 40 percent of vehicle miles travelled by electric vehicles by 2030.
▪ Pillar 5: Circular Economy. Achieve 75 percent diversion of landfilled organic waste by 2025 and
90 percent by 2035.
▪ Pillar 6: Natural Solutions. Increase carbon sequestration on the San Luis Obispo Greenbelt and
Urban Forest through compost application-based carbon farming activities and tree planting to
be ongoing through 2035.
Table 2 summarizes the GHG emissions reductions included in the the CAP that are anticipated to be
achieved by each of these pillars, in addition to State laws and programs, by 2035. As shown therein,
implementation of State laws and programs as well as these pillars would reduce communitywide
emissions by approximately 286,680 MT of CO2e per year, or approximately 66 percent, below 1990
levels to approximately 111,030 MT of CO2e per year. These emission reductions would equate to a
approximately 72 percent reduction below business-as-usual GHG emissions forecast for year 2035.
6 San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report. November 2019.
7 Ibid.
Climate Action Plan Summary
5
Table 2 City of San Luis Obispo Communitywide GHG Emissions Reductions by 2035
Source
Annual Emissions
(MT of CO2e)
1990 Baseline Emissions1 328,630
Business-as-Usual 2035 Emissions2 397,710
State Laws/Programs3 (102,410)
Pillar 2: Clean Energy Systems (39,010)
Pillar 3: Green Buildings (26,740)
Pillar 4: Connected Community (64,170)
Pillar 5: Circular Economy (47,300)
Pillar 6: Natural Solutions (7,050)
Total Emissions Reductions (286,680)
Remaining 2035 Emissions 111,030
Percent Reduction below 1990 Levels (66%)
Percent Reduction below Business-as-Usual 2035 Levels (72%)
MT = metric tons; CO2e = carbon dioxide equivalents; ( ) denotes a negative number
Notes: GHG emissions reductions achieved by Pillar 1: Lead by Example are not included because implementation of the foundational
actions associated with this pillar would serve only to reduce municipal, rather than communitywide, emissions. Numbers are rounded
to the nearest ten.
1 See Table 2.
2 See Table 3.
3 Includes implementation of State vehicle fuel efficiency standards and triennial updates of Title 24. The Renewable Portfolio
Standards program is not included because Pillar 2 already accounts for 100 percent carbon-free electricity by 2020.
Sources: San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast .
San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report. November 2019.
2.3 GHG Emissions Forecast
Figure 2 and Table 3 summarize the communitywide GHG emissions forecast under three scenarios:
1) business-as-usual, 2) implementation of State laws and programs, and 3) implementation of State
laws and programs and the CAP. As shown therein, under the business-as-usual scenario,
communitywide GHG emissions are forecasted to increase by approximately 21 percent between
1990 and 2035 based on economic and population growth. However, with implementation of State
laws and programs, communitywide GHG emissions would decline by approximately 22 percent
between 1990 and 2035. Furthermore, full implementation of the CAP alongside State laws and
programs would reduce communitywide GHG emissions by approximately 66 percent below 1990
levels by 2035.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
6
Figure 2 City of San Luis Obispo GHG Emissions Forecast, 2005 to 2035
Climate Action Plan Summary
7
Table 3 City of San Luis Obispo GHG Emissions Forecast Through 2035
Sector
1990
(MT of CO2e)
2005
(MT of CO2e)
2016
(MT of CO2e)
2030
(MT of CO2e)
2035
(MT of CO2e)
Percent
Change
(1990-2035)
Business-as-Usual
Transportation 191,580 225,390 212,980 234,570 242,280 26%
Non-residential
Energy
49,340 58,050 44,270 51,860 54,880 11%
Residential
Energy
47,130 55,450 39,410 45,660 47,990 2%
Solid Waste 40,580 47,740 42,630 49,880 52,560 30%
Total 328,630 386,630 339,290 381,970 397,710 21%
Implementation of State Laws and Programs1
Transportation 191,580 225,390 212,980 161,290 142,830 (25%)
Non-residential
Energy
49,340 58,050 44,270 33,690 27,720 (44%)
Residential
Energy
47,130 55,450 39,410 35,660 33,180 (30%)
Solid Waste 40,580 47,740 42,630 49,880 52,560 30%
Total 328,630 386,630 339,290 280,520 256,290 (22%)
Implementation of State Laws and Programs and City’s Climate Action Plan
Transportation2 191,580 225,390 212,980 116,050 78,660 (59%)
Non-residential
Energy3
49,340 58,050 44,270 29,710 21,000 (57%)
Residential
Energy3
47,130 55,450 39,410 27,680 13,160 (72%)
Solid Waste4 40,580 47,740 42,630 12,470 5,260 (87%)
Carbon
Sequestration5
0 0 0 (3,610) (7,050) n/a
Total 328,630 386,630 339,290 182,300 111,030 (66%)
MT = metric tons; CO2e = carbon dioxide equivalents; ( ) denotes a negative number
Note: Numbers are rounded to the nearest ten.
1 State laws and programs include State vehicle fuel efficiency standards, the R enewable Portfolio Standard, and triennial updates of
Title 24.
2 Includes implementation of Pillar 4: Connected Community.
3 Includes implementation of Pillar 2: Clean Energy Systems and Pillar 3: Green Buildings.
4 Includes implementation of Pillar 5: Circular Economy.
5 Includes implementation of Pillar 6: Natural Solutions.
Sources: Appendix C; San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
At this time, the State has codified a target of reducing emissions to 40 percent below 1990
emissions levels by 2030 (Senate Bill [SB] 32) and has developed the 2017 Climate Change Scoping
Plan to demonstrate how the State will achieve the 2030 target and make substantial progress
toward the 2050 goal of an 80 percent reduction in 1990 GHG emission levels set by Executive Order
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
8
(EO) S-3-05. The recently signed EO B-55-18 identifies a new goal of carbon neutrality by 2045 and
supersedes the goal established by EO S-3-05.
While State and regional regulations related to energy and transportation systems, along with the
State’s Cap and Trade program, are designed to be set at limits to achieve most of the GHG
emissions reductions needed to achieve the State’s long-term targets, local governments can do
their fair share toward meeting the State’s targets by siting and approving projects that
accommodate planned population growth and projects that are GHG-efficient. The Association of
Environmental Professional (AEP) Climate Change Committee recommends that CEQA GHG analyses
evaluate project emissions in light of the trajectory of State climate change legislation and assess
their “substantial progress” toward achieving long‐term reduction targets identified in available
plans, legislation, or EOs.
The City has adopted a long-term aspirational goal of achieving carbon neutrality by 2035 and has
proposed the CAP as a pathway to make progress toward this goal. As shown in Table 3,
implementation of the CAP would achieve an approximately 45 percent reduction in
communitywide GHG emissions below 1990 levels by 20308 and an approximately 66 percent
reduction in communitywide GHG emissions below 1990 levels by 2035. Therefore, the City’s long-
term aspirational goal of carbon neutrality and the associated CAP establish a trajectory that
provides GHG emissions reductions greater than those required by SB 32 for 2030. Because SB 32 is
considered an interim target toward meeting the 2045 State goal of carbon neutrality,
implementation of the CAP would make substantial progress toward meeting the State’s long-term
2045 goal. Avoiding interference with, and making substantial progress toward, these long-term
State targets is important because these targets have been set at levels that achieve California’s fair
share of international emissions reduction targets that will stabilize global climate change effects
and avoid the adverse environmental consequences described in Appendix A (Executive Order B-55-
18).
2.4 Qualified GHG Emissions Reduction Plan
According to CEQA Guidelines Section 15183.5, project -specific environmental documents can tier
from, or incorporate by reference, the existing programmatic review in a qualified GHG emissions
reduction plan, which allows for project-level evaluation of GHG emissions through the comparison
of the project’s consistency with the GHG emissions reduction strategy included in the qualified
GHG emissions reduction plan. To meet the requirements of CEQA Guidelines Section 15183.5, a
qualified GHG emissions reduction plan must include the following:
Quantify existing and projected GHG emissions within the plan area;
Establish a level, based on substantial evidence, below which the contribution to GHG emissions
from activities covered by the plan would not be cumulatively considerable;
Identify and analyze sector specific GHG emissions within the plan’s geographic area;
Specify measures or a group of measures, including performance standards, that if
implemented, would collectively achieve the specified emissions level;
Establish a tool or mechanism to monitor progress and to require amendment if the plan is not
achieving specified levels; and
Be adopted in a public process following environmental review.
8 (328,630 MT of CO2e – 182,300 MT of CO2e) / 328,630 MT of CO2e = 45% reduction
Climate Action Plan Summary
9
Development projects can demonstrate consistency with a qualified GHG emissions reduction plan if
they are consistent with the plan’s assumptions regarding future growth projections and consistent
with the plan’s GHG emissions reduction measures.9 Projects consistent with the qualified GHG
reduction plan, including conformance with performance measures applicable to the project, would
not require additional GHG emissions analysis or mitigation under CEQA Guidelines Sections
15064(h) and 1513.5(b)(2). The City of San Luis Obispo has developed the CEQA GHG Emissions
Analysis Compliance Checklist to assist with determining project consistency with the CAP. The
checklist is intended to provide individual projects the opportunity to demonstrate that they are
minimizing GHG emissions while ensuring that new development achieves its proportion of
emissions reductions consistent with the assumptions of the CAP. Project consistency with a GHG
emissions reduction plan can also be demonstrated through quantitative analysis that demostrates
the project will not impede (or will facilitate) the City’s ability to meet its GHG emissions reduction
targets or by incorporating the reduction measures included in the GHG emissions reduction plan.
Table 4 summarizes the consistency of the CAP with these requirements for year 2030 (the next
State milestone target year for GHG emission reductions). As shown in Table 4, upon adoption of
the IS-ND and approval of the plan by City Council, the City’s CAP will meet the requirements of a
qualified GHG emission reduction plan per CEQA Guidelines Section 15183.5(1) for projects with
buildout years through 2030.
9 CAPs typically utilize growth projections from the local jurisdiction’s General Plan or applicable Metropolitan Planning Orga nization’s
regional demographic forecast.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
10
Table 4 CAP Consistency with CEQA Guidelines Section 15183.5(1) for Year 2030
CEQA Guidelines Section
15183.5(1) Requirement1 Climate Action Plan Consistency
Quantify GHG emissions, both
existing and projected over a
specified time period, resulting
from activities within a defined
geographic area.
Consistent. The CAP includes communitywide GHG emissions inventories for years
2005 and 2016 and forecasts GHG emissions for years 2020, 2030, and 2035.
Establish a level, based on
substantial evidence, below
which the contribution to GHG
emissions from activities
covered by the plan would not
be cumulatively considerable.
Consistent. A key aspect of a qualified GHG emissions reduction plan is substantial
evidence that the identified GHG emissions reduction target establishes a threshold
where GHG emissions are not cumulatively considerable. The Association of
Environmental Professionals (2016) Beyond Newhall and 2020 white paper identifies
this threshold as being a local target that aligns with the State legislative targets. The
CAP establishes a long-term aspirational goal of carbon neutrality by 2035, and as
discussed in Section 2.3, GHG Emissions Forecast, implementation of the plan will
achieve a 45 percent reduction in 1990 emissions levels by 2030. Therefore, this local
target is more stringent than the State targets of a 40 percent emission reduction in
1990 levels by 2030.
Identify and analyze the GHG
emissions resulting from
specific actions or categories of
actions anticipated within the
geographic area.
Consistent. The CAP breaks down its inventories into four sectors (transportation,
residential energy, non-residential energy, and solid waste). The plan also identifies
six pillars of GHG emission reductions and quantifies the emission reductions that
would be achieved by implementation of each pillar.
Specify measures or a group of
measures, including
performance standards, that
substantial evidence
demonstrates, if implemented
on a project-by-project basis,
would collectively achieve the
specified emissions level.
Consistent. The CAP specifies pillars, measures, and foundational actions that the
City will enact and implement between 2020 and 2035 to further its long-term
aspirational goal of carbon neutrality. As discussed in Section 2.3, GHG Emissions
Forecast, implementation of the plan will achieve a 45 percent reduction in 1990
emissions levels by 2030, which is more stringent than the State target of a 40
percent emission reduction in 1990 levels by 2030 and demonstrates substantial
progress by 2030 toward achieving the City’s long-term aspirational goal of carbon
neutrality by 2035.
Establish a mechanism to
monitor the plan’s progress
toward achieving the level and
to require amendment if the
plan is not achieving specified
levels.
Consistent. The CAP includes a process to update and adopt a new CAP every other
financial plan cycle in order to incorporate new measures and technologies that will
further the City toward meeting its long-term aspirational goal of carbon neutrality.
Be adopted in a public process
following environmental
review.
Consistent. The City has prepared an IS-ND for the CAP that will be circulated for
public review and comment and adopted prior to approval of the CAP and CEQA GHG
Emissions Thresholds and Guidance by City Council.
1 Source: 2019 CEQA Guidelines
Regulatory and Legal Setting
11
3 Regulatory and Legal Setting
The following regulations, executive orders, and case law pertain to the analysis of GHG emissions
consistent with CEQA and the CEQA Guidelines.
3.1 Relevant CEQA Guidelines Sections
Pursuant to the requirements of SB 97, the California Natural Resources Agency has adopted
amendments to the CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of
GHG emissions. The adopted CEQA Guidelines, which were last updated in December 2018, provide
general regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents,
while giving lead agencies the discretion to set quantitative or qualitative thresholds for the
assessment and mitigation of GHG emissions and climate change impacts.
Based on Appendix G of the CEQA Guidelines, impacts related to GHG emissions generated by a
proposed plan/project would be significant if the plan/project would:
▪ Generate GHG emissions, either directly or indirectly, that may have a significant impact on the
environment; and/or
▪ Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the
emissions of GHGs.
The vast majority of individual projects do not generate sufficient GHG emissions to directly
influence climate change. However, physical changes caused by a plan/project can contribute
incrementally to cumulative effects that are significant, even if individual changes resulting from a
plan/project are limited. As discussed in Appendix A, the adverse environmental impacts of
cumulative GHG emissions, including sea level rise, increased average temperatures, more drought
years, and more large forest fires, are already occurring. As a result, cumulative impacts related to
GHG emissions and climate change are significant. Therefore, per CEQA Guidelines Section
15064.4(b), the analysis of GHG emissions under CEQA typically involves an analysis of whether a
plan or project’s contribution towards an impact would be cumulatively considerable. “Cumulatively
considerable” means that the incremental effects of an individual project are significant when
viewed in connection with the effects of past projects, other current projects, and probable future
projects (CEQA Guidelines Section 15064[h][1]).
The following sections of the CEQA Guidelines (last updated on December 28, 2018) pertain to the
creation of significance thresholds and the analysis of a plan/project’s GHG emissions.
CEQA Guidelines Section 15064(b)
The determination of whether a project may have a significant effect on the environment
calls for careful judgment on the part of the public agency involved, based to the extent
possible on scientific and factual data. An ironclad definition of significant effect is not
always possible because the significance of an activity may vary with the setting. For
example, an activity which may not be significant in an urban area may be significant in a
rural area.
Thresholds of significance, as defined in Section 15064.7(a), may assist lead agencies in
determining whether a project may cause a significant impact. When using a threshold, the
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
12
lead agency should briefly explain how compliance with the threshold means that the
project’s impacts are less than significant. Compliance with the threshold does not relieve a
lead agency of the obligation to consider substantial evidence indicating that the project’s
environmental effects may still be significant.10
CEQA Guidelines Section 15064.4
(a) The determination of the significance of GHG emissions calls for a careful judgment by the
lead agency consistent with the provisions in section 15064. A lead agency shall make a
good-faith effort, based to the extent possible on scientific and factual data, to describe,
calculate or estimate the amount of GHG emissions resulting from a project. A lead agency
shall have discretion to determine, in the context of a particular project, whether to
Quantify GHG emissions resulting from a project; and/or
Rely on a qualitative analysis or performance-based standards.
(b) In determining the significance of a project’s GHG emissions, the lead agency should focus
its analysis on the reasonably foreseeable incremental contribution of the project’s
emissions to the effects of climate change. A project’s incremental contribution may be
cumulatively considerable even if it appears relatively small compared to Statewide,
national or global emissions. The agency’s analysis should consider a timeframe that is
appropriate for the project. The agency’s analysis also must reasonably reflect evolving
scientific knowledge and State regulatory schemes. A lead agency should consider the
following factors, among others, when determining the significance of impacts from GHG
emissions on the environment:
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.
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 (see, e.g., section 15183.5[b]). Such requirements must be adopted by the
relevant public agency through a public review process and must 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. In determining the significance of impacts, the lead agency
may consider a project’s consistency with the State’s long-term climate goals or
strategies, provided that substantial evidence supports the agency’s analysis of how
those goals or strategies address the project’s incremental contribution to climate
change and its conclusion that the project’s incremental contribution is not cumulatively
considerable.
(c) A lead agency may use a model or methodology to estimate GHG emissions resulting from a
project. The lead agency has discretion to select the model or methodology it considers
most appropriate to enable decision makers to intelligently take into account the project’s
incremental contribution to climate change. The lead agency must support its selection of a
10 2019 CEQA Guidelines.
Regulatory and Legal Setting
13
model or methodology with substantial evidence. The lead agency should explain the
limitations of the particular model or methodology selected for use.11
CEQA Guidelines Section 15064.7
(a) A threshold of significance is an identifiable quantitative, qualitative or performance level of
a particular environmental effect, non-compliance with which means the effect will
normally be determined to be significant by the agency and compliance with which means
the effect normally will be determined to be less than significant.
(b) Each public agency is encouraged to develop and publish thresholds of significance that the
agency uses in the determination of the significance of environmental effects. Thresholds of
significance to be adopted for general use as part of the lead agency’s environmental review
process must be adopted by ordinance, resolution, rule, or regulation, and developed
through a public review process and be supported by substantial evidence. Lead agencies
may also use thresholds on a case-by-case basis as provided in Section 15064(b)(2).
(c) When adopting or using thresholds of significance, a lead agency may consider thresholds of
significance previously adopted or recommended by other public agencies or recommended
by experts, provided the decision of the lead agency to adopt such thresholds is supported
by substantial evidence.
(d) Using environmental standards as thresholds of significance promotes consistency in
significance determinations and integrates environmental review with other environmental
program planning and regulation. Any public agency may adopt or use an environmental
standard as a threshold of significance. In adopting or using an environmental standard as a
threshold of significance, a public agency shall explain how the particular requirements of
that environmental standard reduce project impacts, including cumulative impacts, to a
level that is less than significant, and why the environmental standard is relevant to the
analysis of the project under consideration. For the purposes of this subdivision, an
“environmental standard” is a rule of general application that is adopted by a public agency
through a public review process and that is all the following:
a quantitative, qualitative or performance requirement found in an ordinance,
resolution, rule, regulation, order, plan or other environmental requirement;
adopted for the purpose of environmental protection;
addresses the environmental effect caused by the project; and,
applies to the project under review.12
CEQA Guidelines Section 15183.5
(a) Lead agencies may analyze and mitigate the significant effects of GHG emissions at a
programmatic level, such as in a general plan, a long-range development plan, or a separate
plan to reduce GHG emissions. Later project-specific environmental documents may tier
from and/or incorporate by reference that existing programmatic review. Project-specific
environmental documents may rely on an EIR containing a programmatic analysis of GHG
emissions as provided in section 15152 (tiering), 15167 (staged EIRs) 15168 (program EIRs),
11 Ibid.
12 Ibid.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
14
15175–15179.5 (Master EIRs), 15182 (EIRs Prepared for Specific Plans), and 15183 (EIRs
Prepared for General Plans, Community Plans, or Zoning).
(b) Plans for the Reduction of GHG Emissions. Public agencies may choose to analyze and
mitigate significant GHG emissions in a plan for the reduction of GHG emissions or similar
document. A plan to reduce GHG emissions may be used in a cumulative impacts analysis as
set forth below. Pursuant to sections 15064(h)(3) and 15130(d), a lead agency may
determine that a project’s incremental contribution to a cumulative effect is not
cumulatively considerable if the project complies with the requirements in a previously
adopted plan or mitigation program under specified circumstances.
Plan Elements. A plan for the reduction of GHG emissions should:
(A) Quantify GHG emissions, both existing and projected over a specified time period,
resulting from activities within a defined geographic area;
(B) Establish a level, based on substantial evidence, below which the contribution to
GHG emissions from activities covered by the plan would not be cumulatively
considerable;
(C) Identify and analyze the GHG emissions resulting from specific actions or categories
of actions anticipated within the geographic area;
(D) Specify measures or a group of measures, including performance standards, that
substantial evidence demonstrates, if implemented on a project-by-project basis,
would collectively achieve the specified emissions level;
(E) Establish a mechanism to monitor the plan’s progress toward achieving the level
and to require amendment if the plan is not achieving specified levels;
(F) Be adopted in a public process following environmental review.
Use with Later Activities. A plan for the reduction of GHG emissions, once adopted
following certification of an EIR or adoption of an environmental document, may be
used in the cumulative impacts analysis of later projects. An environmental document
that relies on a GHG reduction plan for a cumulative impacts analysis must identify
those requirements specified in the plan that apply to the project, and, if those
requirements are not otherwise binding and enforceable, incorporate those
requirements as mitigation measures applicable to the project. If there is substantial
evidence that the effects of a particular project may be cumulatively considerable,
notwithstanding the project’s compliance with the specified requirements in the plan
for the reduction of GHG emissions, an EIR must be prepared for the project.
(c) Special Situations. As provided in Public Resources Code sections 21155.2 and 21159.28,
environmental documents for certain residential and mixed use projects, and transit priority
projects, as defined in section 21155, that are consistent with the general use designation,
density, building intensity, and applicable policies specified for the project area in an
applicable sustainable communities strategy or alternative planning strategy need not
analyze global warming impacts resulting from cars and light duty trucks. A lead agency
should consider whether such projects may result in GHG emissions resulting from other
sources, however, consistent with these Guidelines.13
13 Ibid.
Regulatory and Legal Setting
15
CEQA Guidelines Section 15126.4(c)
Consistent with section 15126.4(a), lead agencies shall consider feasible means, supported by
substantial evidence and subject to monitoring or reporting, of mitigating the significant effects of
GHG emissions. Measures to mitigate the significant effects of GHG emissions may include, among
others:
Measures in an existing plan or mitigation program for the reduction of emissions that are
required as part of the lead agency’s decision;
Reductions in emissions resulting from a project through implementation of project
features, project design, or other measures, such as those described in Appendix F;
Off-site measures, including offsets that are not otherwise required, to mitigate a project’s
emissions;
Measures that sequester GHGs;
In the case of the adoption of a plan, such as a general plan, long range development plan,
or plans for the reduction of GHG emissions, mitigation may include the identification of
specific measures that may be implemented on a project-by-project basis. Mitigation may
also include the incorporation of specific measures or policies found in an adopted
ordinance or regulation that reduces the cumulative effect of emissions.14
3.2 Relevant State and Regional GHG Reduction
Targets
Executive Order S-03-05
On June 1, 2005, the governor issued EO S-03-05, which established a statewide goal of reducing GHG
emissions to 1990 levels by 2020 and created the Climate Action Team. The 2020 GHG reduction
target contained in EO S-03-05 was later codified by Assembly Bill (AB) 32.
Assembly Bill 32
California’s major initiative for reducing GHG emissions is outlined in AB 32, the “California Global
Warming Solutions Act of 2006,” which was signed into law in 2006. AB 32 codifies the Statewide
goal of reducing GHG emissions to 1990 levels by 2020 and requires the California Air Resources
Board (CARB) to prepare a Scoping Plan that outlines the main State strategies for reducing GHG
emissions to meet the 2020 deadline. In addition, AB 32 requires CARB to adopt regulations to
require reporting and verification of Statewide GHG emissions. Based on this guidance, CARB
approved a 1990 Statewide GHG level and 2020 limit of 427 million metric tons (MMT) of carbon
dioxide equivalents (CO2e).15 The Scoping Plan was approved by CARB on December 11, 2008 and
included measures to address GHG emission reduction strategies related to energy efficiency, water
use, and recycling and solid waste, among other measures. Many of the GHG reduction measures
14 Ibid.
15 Different types of GHGs have varying global warming potentials (GWPs). The GWP of a GHG is the potential of a gas or aerosol to trap
heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a co mmon
reference gas, CO2, is used to relate the amount of heat absorbed to the amount of the gas emissions, referred to as carbon dioxide
equivalent (CO2e), and is the amount of a GHG emitted multiplied by its GWP. Carbon dioxide has a 100 -year GWP of one. By
contrast, methane has a GWP of 25, meaning its global warming effect is 25 times greater than CO 2 on a molecule per molecule basis
(Intergovernmental Panel on Climate Change 2007).
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
16
included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and
Cap-and-Trade) have been adopted since approval of the Scoping Plan.16
In May 2014, CARB approved the first update to the AB 32 Scoping Plan. The 2013 Scoping Plan
update defined CARB’s climate change priorities for the next five years and set the groundwork to
reach post-2020 Statewide goals. The update highlighted California’s progress toward meeting the
“near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also
evaluated how to align the State’s longer-term GHG reduction strategies with other State policy
priorities, including those for water, waste, natural resources, clean energy, transportation, and land
use. 17
Executive Order B-30-15
On April 29, 2015, the governor issued EO B-30-15, which established state GHG emission reduction
targets of 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050. The 2030
GHG emissions reduction target contained in EO B-30-15 was later codified by SB 32.
Senate Bill 32
On September 8, 2016, the governor signed SB 32 into law, extending AB 32 by requiring the State
to further reduce GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of
AB 32 remain unchanged). On December 14, 2017, CARB adopted the 2017 Scoping Plan, which
provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the
continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program,
as well as implementation of recently adopted programs and policies, such as SB 350 and SB 1383.
The 2017 Scoping Plan also puts an increased emphasis on innovation, adoption of existing
technology, and strategic investment to support its strategies. As with the 2013 Scoping Plan
update, the 2017 Scoping Plan does not provide project-level thresholds for land use development.
Instead, it recommends that local governments adopt policies and locally appropriate quantitative
thresholds consistent with Statewide per capita goals of six metric tons (MT) of CO2e by 2030 and
two MT of CO2e by 2050. As stated in the 2017 Scoping Plan, these goals may be appropriate for
plan-level analyses (city, county, subregional, or regional level), but not for specific individual
projects because they include all emissions sectors in the State.18
Senate Bill 375
SB 375, signed in August 2008, enhances the state’s ability to reach AB 32 goals by directing CARB to
develop regional GHG emission reduction targets to be achieved from passenger vehicles by 2020
and 2035. SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and
affordable housing allocations. Metropolitan Planning Organizations (MPOs) are required to adopt a
Sustainable Communities Strategy (SCS), which allocates land uses in the MPO’s Regional
Transportation Plan (RTP). Qualified projects consistent with an approved SCS or Alternative Planning
Strategy categorized as “transit priority projects” would receive incentives to streamline CEQA
processing
16 CARB. 2008. Climate Change Scoping Plan . December 2008.
https://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf (accessed January 2020).
17 CARB. 2014. First Update to the Climate Change Scoping Plan . May 15, 2014.
https://ww3.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf (accessed January 2020).
18 CARB. 2017. 2017 Climate Change Scoping Plan. https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf (accessed January
2020).
Regulatory and Legal Setting
17
On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005
levels by 2020 and 2035. The San Luis Obispo Council of Governments (SLOCOG) was assigned
targets of a 3 percent reduction in GHGs from transportation sources by 2020 and an 11 percent
reduction in GHGs from transportation sources by 2035. SLOCOG adopted the 2019 RTP in June
2019, which includes the region’s SCS and meets the requirements of SB 375.19
Executive Order B-55-18
On September 10, 2018, the governor issued EO B-55-18, which established a new Statewide goal of
achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This goal is
in addition to the existing Statewide GHG emission reduction targets established by SB 375, SB 32,
SB 1383, and SB 100. EO B-55-18 also tasks CARB with including a pathway toward the EO B-55-18
carbon neutrality goal in the next Scoping Plan update.
3.3 Relevant GHG Emissions Analysis Case Law
Friends of Oroville v. City of Oroville (Case No. 070448)
The Third District Court of Appeal decision in the Friends of Oroville v. City of Oroville case was
published on August 19, 2013. This decision evaluated the methodology used to analyze GHG
emissions in an Environmental Impact Report (EIR) prepared for a Wal-Mart Supercenter
development project that included replacing an existing Wal-Mart store with a Wal-Mart
Supercenter in Oroville in Butte County. The EIR used consistency with the AB 32 emissions
reduction target as its significance threshold for evaluating the project’s GHG emissions and
compared the magnitude of the proposed project’s emissions to statewide 2004 emission levels as
part of the analysis. The Court found that EIR applied “a meaningless, relative number to determine
insignificant impact” rather than evaluating the project’s emissions in light of the AB 32 emissions
reduction target. The Court also found that the EIR “misapplied the [AB] 32 threshold-of-significance
standard by [1] failing to calculate the GHG emissions for the existing Wal -Mart and [2] failing to
quantitatively or qualitatively ascertain or estimate the effect of the Project’s mitigation measures
on GHG emissions.” The Court determined that the EIR could and should have performed these
quantifications to adequately evaluate the project’s GHG emissions using the AB 32 emissions
reduction target.
Sierra Club v. County of San Diego (Case No. 37-2018-00043084-CU-TT-CTL)
The Fourth District Court of Appeal decision in the Sierra Club v. County of San case was published
on October 29, 2014. This decision evaluated the adequacy of the CAP prepared by the County of
San Diego to satisfy Mitigation Measure CC-1.2 of the program EIR prepared for its 2011 General
Plan. To reduce GHG emissions impacts of the 2011 General Plan to a less-than-significant level,
Mitigation Measure CC-1.2 required the preparation of a CAP that would include “more detailed
GHG emissions reduction targets and deadlines” and that would “achieve comprehensive and
enforceable GHG emissions reduction of 17 percent (totaling 23,572 MT of CO2e) from County
operations from 2006 by 2020 and 9 percent reduction (totaling 479,717 MT of CO2e) in community
emissions from 2006 by 2020.” The Court found the CAP did not include enforceable and feasible
GHG emission reduction measures that would achieve the necessary emissions reductions;
therefore, the CAP did not meet the requirements of Mitigation Measure CC -1.2 and would not
19 San Luis Obispo Council of Governments. 2019. 2019 Regional Transportation Plan: Connecting Communities.
https://slocog.org/2019RTP (accessed January 2020).
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
18
ensure that the mitigation measure would reduce GHG emissions to a less-than-significant impact.
In addition, the Court found that the County failed to evaluate the environmental impacts of the
CAP and its associated thresholds of significance under CEQA.
Center for Biological Diversity v. California Department of Fish and Wildlife
(Case No. 217763)
The California Supreme Court’s decision in the Center for Biological Diversity v. California
Department of Fish and Wildlife case was published on November 30, 2015. This decision evaluated
the methodology used to analyze GHG emissions in an EIR prepared for the Newhall Ranch
development project that included approximately 20,885 dwelling units with 58,000 residents on
12,000 acres of undeveloped land in Los Angeles County. The EIR used a business-as-usual (BAU)
approach to evaluate whether the project would be consistent with the AB 32 Scoping Plan. The
Court found there was insufficient evidence in the record of that project to explain how a project
that reduces its GHG emissions by the same percentage as the BAU reduction identified for the
State to meet its Statewide targets supported a conclusion that project-level impacts were below
the level of significance.
The California Supreme Court suggested regulatory consistency as a pathway to compliance by
stating that a lead agency might assess consistency with the State’s GHG reduction goals by
evaluating for compliance with regulations designed to reduce GHG emissions. This approach is
consistent with CEQA Guidelines Section 15064.4(b), which provides that a determination of an
impact is not cumulatively considerable to the extent to which the project complies with regulations
or requirements implementing a Statewide, regional, or local plan to reduce or mitigate GHG
emissions. The Court also found that a lead agency may rely on numerical and efficiency-based
thresholds of significance for GHG emissions, if supported by substantial evidence.
Golden Door Properties, LLC v. County of San Diego/Sierra Club, LLC v.
County of San Diego (Case No. 072406)
The Fourth District Court of Appeal decision in the Golden Door Properties, LLC v. County of San
Diego case (published on September 28, 2018) evaluated the County of San Diego’s 2016 Guidance
Document’s GHG efficiency metric, which establishes a generally applicable threshold of significance
for proposed projects. The Court held that the County of San Diego is barred from using its 2016
Guidance Document’s threshold of significance of 4.9 MT of CO2e per service person per year for
GHG analysis. The Court stated that the document violated CEQA because it was not adopted
formally by ordinance, rule, resolution, or regulation through a public review process per CEQA
Guidelines Section 15064.7(b). The Court also found that the threshold was not supported by
substantial evidence that adequately explained how a service population threshold derived from
Statewide data could constitute an appropriate GHG metric to be used for all projects in
unincorporated San Diego County. Nevertheless, lead agencies may make plan- or project-specific
GHG emissions threshold determinations.
Determining Consistency with the City’s Climate Action Plan
19
4 Determining Consistency with the City’s
Climate Action Plan
As discussed in Chapter 2, Climate Action Plan Summary, upon public adoption of the CAP IS-ND and
approval of the CAP by City Council, the City’s CAP will be a qualified GHG emission reduction plan
per the requirements of CEQA Guidelines Section 15183.5 for year 2030 and can, therefore, be
utilized to streamline the GHG emissions analysis for plans and projects with buildout years through
2030.20 Projects that are consistent with the demographic forecasts and land use assumptions used
in the CAP can utilize the City’s CEQA GHG Emissions Analysis Compliance Checklist to demonstrate
consistency with the CAP’s GHG emissions reduction strategy, and if consistent, can tier from the
existing programmatic environmental review contained in the adopted IS-ND for the CAP. In doing
so, these projects would result in less-than-significant GHG emissions and would not result in a
cumulatively considerable impact related to GHG emissions and climate change. The following
process, illustrated in Figure 3, explains how to demonstrate a plan/project’s consistency with the
CAP’s GHG emissions reduction strategy and, thereby, tier from the adopted IS-ND for the CAP. This
approach is consistent with the recommendations of the AEP Climate Change Committee (2016) for
tiering from qualified GHG reduction plans that demonstrate substantial progress toward meeting
the next milestone Statewide planning reduction target (i.e., a 40 percent reduction below 1990
levels by 2030 as set forth by SB 32).
20 Projects that are statutorily or categorically exempt from CEQA compliance would not need to perform an analysis of GHG emissions or
tier from the City’s CAP.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
20
Figure 3 Determining Consistency with the City’s Climate Action Plan
Step 1: Consistency with the Demographic Forecasts and Land Use
Assumptions
The demographic forecasts and land use assumptions of the CAP are based on the Land Use and
Circulation Elements of the City’s 2014 General Plan.21 If a plan/project is consistent with the
existing (2014) General Plan land use and zoning designation(s) of the plan area/project site as
identified in the City’s General Plan Land Use and Circulation Elements adopted in 2014, then the
plan/project is consistent with the demographic forecasts and land use assumptions of the CAP and
can move on to Step 2. In this case, the plan/project’s associated GHG emissions were accounted for
21 San Luis Obispo, City of. 2014. City of San Luis Obispo General Plan. Adopted December 9, 2014.
https://www.slocity.org/government/department -directory/community-development/planning-zoning/general-plan (accessed
January 2020).
Determining Consistency with the City’s Climate Action Plan
21
in the GHG emissions forecasts included in the CAP and are within the scope of this plan’s analysis of
communitywide GHG emissions. Accordingly, the analysis of the plan/project’s GHG emissions in its
CEQA document should include a reference to the plan/project’s consistency with the existing
(2014) General Plan land use and zoning designation(s) of the plan area/project site and should
explain the aforementioned connection between the existing (2014) General Plan land use and
zoning designation(s) and the GHG emissions forecasts in the CAP. Then, proceed to Step 2.
If a plan/project is not consistent with the existing (2014) General Plan land use and zoning
designation(s) of the plan area/project site but would result in equivalent or fewer GHG emissions
as compared to existing on-site development, then the plan/project would still be within the
demographic forecasts and land use assumptions of the CAP and can move on to Step 2. To provide
substantial evidence for this determination, GHG emissions generated under existing conditions and
the proposed project need to be quantified and included in the CEQA analysis. See Chapter 6,
Quantifying GHG Emissions, for guidance on quantifying GHG emissions for existing conditions and
the proposed plan/project. In this case, the analysis of the plan/project’s GHG emissions in its CEQA
document should include a quantitative comparison of the proposed plan/project’s GHG emissions
and GHG emissions generated by existing on-site development. The analysis should clearly explain
how the plan/project’s emissions are equivalent or less than those generated by existing on-site
development. Then, proceed to Step 2.
If a plan/project is not consistent with the existing (2014) General Plan land use and zoning
designation(s) of the plan area/project site and would result in either new development of
undeveloped land or redevelopment with higher GHG emissions than existing on-site development,
the plan/project cannot use the CEQA GHG Emissions Analysis Compliance Checklist to tier from the
adopted IS-ND for the CAP. Instead, the plan/project’s GHG emissions can be evaluated using the
quantitative GHG thresholds described in Chapter 5, Utilizing Quantitative CEQA GHG Thresholds, to
evaluate the significance of the plan/project’s GHG emissions. This method can also be utilized for
projects with a post-2030 buildout year.
Step 2: Consistency with CEQA GHG Emissions Analysis Compliance
Checklist
The City has prepared the CEQA GHG Emissions Analysis Compliance Checklist for plans and projects
to ensure that they are consistent with the measures of the CAP (Appendix B). A project applicant
can utilize the checklist to show that the plan/project includes all applicable measures of the CAP.
Projects that use the CEQA GHG Emissions Analysis Compliance Checklist are not required to
quantify reductions from the measures included on the checklist because the reductions from
applicable measures have already been quantified at a programmatic level in the CAP. If a
plan/project is consistent with the applicable measures on the CEQA GHG Emissions Analysis
Compliance Checklist, then the plan/project can tier from the programmatic environmental review
included in the adopted IS-ND for the CAP pursuant to CEQA Guidelines Section 15183.5(b). A
plan/project that is consistent with all applicable measures of the CEQA GHG Emissions Analysis
Compliance Checklist would result in less-than-significant GHG emissions and would not result in a
cumulatively considerable impact related to GHG emissions and climate change. In this case, the
analysis of a plan or project’s GHG emissions in its respective CEQA review document should include
a summary of the plan/project’s consistency with applicable measures of the CEQA GHG Emissions
Analysis Compliance Checklist and an explanation with substantial evidence of why any measures in
the checklist are not applicable to the plan/project.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
22
5 Utilizing Quantitative CEQA GHG
Thresholds
As discussed in Chapter 4, Determining Consistency with the City’s C, if a plan/project is not
consistent with the existing (2014) General Plan land use and zoning designation(s) of the plan
area/project site or has a post-2030 buildout year, then the plan/project cannot use the CEQA GHG
Emissions Analysis Compliance Checklist to tier from the adopted IS-ND for the CAP. Instead, the
significance of the plan/project’s GHG emissions can be evaluated using quantitative GHG
thresholds derived from the assumptions of the CAP. If the plan/project’s emissions are at or below
the applicable threshold, the plan/project can tier from the existing programmatic environmental
review contained in the adopted IS-ND for the CAP if it has a pre-2030 buildout year. In doing so,
these plans/projects would result in less-than-significant GHG emissions and would not result in a
cumulatively considerable impact related to GHG emissions and climate change. For plans/projects
with post-2030 buildout years, emissions at or below the thresholds for 2035, which equate to 0 MT
of CO2e per year, would be considered less-than-significant, and these plans/projects would not
result in a cumulatively considerable impact related to GHG emissions. The following sections
provide an explanation of the methodology used to calculate the thresholds, guidance on how to
utilize the thresholds, and justification for use of these thresholds.
5.1 GHG Emissions Calculation Methodology
CEQA Guidelines Section 15064.4 does not establish a specific quantitative threshold of significance
for evaluating GHG emissions associated with a proposed plan or project. Lead agencies have the
discretion to establish significance thresholds for their respective jurisdictions, and in establishing
those thresholds, a lead agency may appropriately look to thresholds developed by other public
agencies, or suggested by other experts, as long as the threshold chosen is supported by substantial
evidence (CEQA Guidelines Section 15064.7[c]). The following methodology is consistent with
guidance provided by the AEP Climate Change Committee in 2016 for establishing GHG emissions
efficiency thresholds using the local jurisdictional GHG inventory and demographic forecasts.22
An efficiency threshold is a threshold expressed as a per-person metric (e.g., per resident, per
employee, or per service person). Efficiency thresholds are calculated by dividing the allowable GHG
emissions inventory in a selected calendar year by the resident, employee, or service population in
that year.23 The efficiency threshold identifies the quantity of GHG emissions that can be generated
on a per-person basis without significantly impacting the environment.
Locally appropriate, plan- and project-specific GHG emissions efficiency thresholds were derived
from the GHG emissions forecasts calculated for the CAP. These thresholds were created to comply
with CEQA and the CEQA Guidelines and interpretive GHG emissions analysis case law, which are
summarized in Chapter 3, Regulatory and Legal Setting. The City of San Luis Obispo GHG emissions
efficiency thresholds were calculated using the emissions forecasts with all emissions sectors
included, because plans and projects would generate vehicle trips, consume energy, and produce
22 AEP. 2016. Final White Paper Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action
Plan Targets for California. https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf (accessed January 2020).
23 Per the method used by the San Luis Obispo Community Development Department, the service population is equal to the residenti al
population plus half the number of jobs.
Utilizing Quantitative CEQA GHG Thresholds
23
solid waste, thereby generating emissions in all categories. Efficiency thresholds were calculated for
year 2030 to provide GHG emissions thresholds for new development in line with the State’s next
milestone target for year 2030.
GHG emissions efficiency thresholds would be used during the CEQA review process for new
residential, non-residential, and mixed-use plans and projects. Therefore, forecasted GHG emissions
in the CAP were disaggregated into existing development and new development for each threshold
year. Furthermore, forecasted GHG emissions for new development were further disaggregated into
residential and non-residential development for each threshold year for the purpose of calculating
thresholds specific to residential, non-residential, and mixed-use projects. The results of the
disaggregation of the GHG emissions forecast are presented in Figure 4 and Table 5, which
summarizes the total amount of GHG emissions expected to be generated by existing, new
residential, and new non-residential development for threshold year 2030.
Figure 4 Allowable GHG Emissions from Existing and New Development in Year 2030
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
24
Table 5 GHG Emissions Forecast for Year 2030 by Type of Development (MT of CO2e)
Source
2030
Existing Development
New Development
Residential Non-Residential
Baseline GHG Emissions 339,290 24,750 17,930
State Laws/Programs (62,620) (8,560) (4,220)
CAP Pillar 2: Clean Energy
Systems
(23,170) n/a (2,880)
CAP Pillar 3: Green Buildings (8,180) (3,020) (760)
CAP Pillar 4: Connected
Community
(38,660) (4,220) (2,360)
CAP Pillar 5: Circular Economy (31,970) (3,490) (1,950)
CAP Pillar 6: Natural Solutions1 (220) (20) (10)
Remaining Total GHG
Emissions
174,470 5,440 5,750
( ) denotes a negative number; n/a = not applicable
Note: GHG emissions reductions achieved by Pillar 1: Lead by Example are not included because implementation of the foundatio nal
actions associated with this pillar would serve only to reduce municipal, rather than communitywide, emissions.
1 Only includes reductions from Natural Solutions Measure 2 (Tree Planting) because implementation of Natural Solutions Measure 1
(Carbon Farming) is not the responsibility of existing and new development.
See Appendix C for calculations.
Table 6 summarizes the demographic projections for the City of San Luis Obispo that were used in
calculating GHG efficiency thresholds for year 2030. As shown in Table 6, the numbers of residents,
employees, and service persons are all anticipated to increase between 2016 and 2030.
Table 6 City of San Luis Obispo Demographic Projections
Metric 2016 Estimate 2030 Forecast
Net Increase from New
Development
(2016-2030)
Residents 46,117 53,934 7,817
Employees 50,985 59,723 8,738
Service Population1 71,610 83,796 12,186
1 Per the method used by the City of San Luis Obispo Community Development Department, the service population is equal to the
residential population plus half the number of employees.
Source: San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
5.2 GHG Thresholds and Use
The GHG efficiency thresholds for residential, non-residential, and mixed-use projects built prior to
December 31, 2030 are presented in Figure 5 and Table 7. If a plan or project’s emissions do not
exceed the applicable threshold, then it is consistent with the City’s CAP and its GHG emissions
impacts (both project- and cumulative-level) would not result in a cumulatively considerable impact
related to GHG emissions and climate change and would, therefore, be less than significant. If a plan
or project’s emissions exceed the applicable threshold, then mitigation measures must be identified
and respective GHG emissions reduction calculations included within the respective CEQA review
document in order to reduce plan or project GHG emissions to at or below the applicable threshold
Utilizing Quantitative CEQA GHG Thresholds
25
level. These thresholds are applicable to the following plan and project types as identified in Title 17
(Zoning Regulations) Table 2-1 and defined in San Luis Obispo Municipal Code Section 17.156:
▪ Residential. Single-family dwellings, multi-family dwellings, boarding house, caretaker quarters,
fraternities and sororities, high-occupancy residential uses, continuing care communities,
mobile-home parks, or any combination of these uses.
▪ Non-residential. All Commercial uses (including office and retail uses), all Lodging uses, all Public
and Quasi-Public uses, elderly and long term care, hospice in-patient facilities, family day cares,
residential care facilities, supportive and/or transitional housing, sports and entertainment
assembly facilities, all Industry, Manufacturing & Processing, and Wholesaling uses that are not
subject to San Luis Obispo County Air Pollution Control District (SLOAPCD) stationary source
permitting or the State cap-and-trade program, or any combination of these uses.
▪ Mixed-use. A combination of at least one residential and at least one non-residential land use
specified above.
Figure 5 City of San Luis Obispo GHG Efficiency Thresholds
Table 7 City of San Luis Obispo Locally Applicable Plan- or Project-Specific CEQA GHG
Emissions Thresholds
2030
(New Development)
Residential Non-Residential Mixed-Use
GHG Emissions Forecast
(MT of CO2e per year)1
5,440 5,750 11,190
Demographic Metric2 7,817 residents 8,738 employees 12,186 service
persons
GHG Efficiency Threshold
(MT of CO2e per year)
0.7 per resident 0.7 per employee 0.9 per service person
MT = metric tons; CO2e = carbon dioxide equivalents
1 See Table 5.
2 Demographic estimates are for new plans or projects only and were calculated using the forecasts in Table 6.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
26
5.3 Justification for Thresholds
Per CEQA Guidelines Section 15064(b)(1), “the determination of whether a project may have a
significant effect on the environment calls for careful judgment on the part of the public agency
involved, based to the extent possible on scientific and factual data.” In addition, CEQA Guidelines
Section 15064(b)(2) states, “When using a threshold, the lead agency should briefly explain how
compliance with the threshold means that the project’s impacts are less than significant.”
Furthermore, CEQA Guidelines Section 15064.7(b) states “Thresholds of significance to be adopted
for general use as part of the lead agency’s environmental review process must be adopted by
ordinance, resolution, rule, or regulation, and developed through a public review process and be
supported by substantial evidence.” Therefore, the key considerations when developing thresholds
of significance are 1) the thresholds’ basis on scientific and factual data; 2) demonstration of how
compliance with the thresholds reduces project impacts to a less-than-significant level; 3) support of
the thresholds by substantial evidence; and 4) adoption of the thresholds by ordinance, resolution,
rule, or regulation, and developed through a public review process. The following subsections
address these four key considerations.
Basis on Scientific and Factual Data
As discussed in Section 5.1, Calculation Methodology, the quantitative thresholds were developed
using data from the City’s 2005 and 2016 communitywide GHG inventories and the GHG emissions
forecasts for year 2030. These inventories and forecasts were developed by the City in compliance
with all relevant protocols and guidance documents, including the U.S. Community Protocol for
Accounting and Reporting of Greenhouse Gas Emissions, Local Government Operations Protocol,
the Global Protocol for Community Scale GHG Emissions, and the Intergovernmental Panel on
Climate Change (IPCC) Guidelines for National GHG Inventories. Furthermore, the inventories and
forecasts are based on locally appropriate data for the San Luis Obispo jurisdiction provided by
Pacific Gas & Electric (PG&E), Southern California Gas Company, the City of San Luis Obispo Public
Works and Utilities Departments, San Luis Obispo Air Pollution Control District (SLOAPCD), CARB,
and Cold Canyon Landfill (City of San Luis Obispo 2019b).24 Therefore, the emission inventory and
forecast data underlying the thresholds is both scientific and factual.
As discussed in Section 2.3, GHG Emissions Forecast, implementation of the City’s CAP will achieve a
45 percent reduction in 1990 emissions levels by 2030. Therefore, this local target is more stringent
than the State targets of a 40 percent emission reduction in 1990 levels by 2030 and makes
substantial progress toward achieving the State’s long-term goal of carbon neutrality by 2045. The
quantitative thresholds are tied directly to the level of GHG emissions anticipated for new
development in the CAP for year 2030. As a result, because the CAP is consistent with the State’s
2030 GHG emission target, the quantitative thresholds are also consistent with the next State
milestone GHG emission reduction target for 2030 and the State’s long-term goal of carbon
neutrality by 2045. The State’s GHG emission reduction targets for 2030 and 2045 are set at the
levels scientists say are necessary to meet the Paris Agreement goals to reduce GHG emissions and
limit global temperature rise below two degrees Celsius by 2100 in order to avoid dangerous climate
change (CARB 2017; EO B-55-18). Therefore, the City’s emission reduction targets that inform the
CAP and the associated quantitative thresholds are based on scientific and factual data on the level
24 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
Utilizing Quantitative CEQA GHG Thresholds
27
of emissions reductions necessary to ensure the City does not have a cumulatively considerable
contribution to the cumulative impact of climate change.
Reduction of Plan or Project Impacts to a Less-than-Significant Level
As shown in Table 5 in Section 5.1, Calculation Methodology, implementation of the City’s CAP
would reduce communitywide emissions by 45 percent by 2030. The quantitative thresholds are
tied directly to the level of GHG emissions anticipated for new development in the CAP for year
2030. Therefore, the thresholds are consistent with the City’s local emission reduction target, which
is consistent with the State’s GHG emission reduction targets. As mentioned in the preceding
subsection, the State’s GHG emission reduction targets for 2030 and 2045 are set at the levels
scientists say are necessary to meet the Paris Agreement goals to reduce GHG emissions and limit
global temperature rise below two degrees Celsius by 2100 in order to avoid dangerous climate
change (CARB 2017; EO B-55-18). Therefore, the quantitative thresholds are set at the level
necessary to ensure the City does not have a cumulatively considerable contribution to the
cumulative impact of climate change. As a result, projects with GHG emissions at or below the
quantitative thresholds would also not have a cumulatively considerable contribution to the
cumulative impacts of climate change, and project impacts would be less than significant.
Support of Substantial Evidence
Substantial evidence regarding the calculation of the quantitative GHG emissions thresholds is
provided in Section 5.1, Calculation Methodology. The following subsections provide additional
evidence of how the GHG emissions thresholds are locally appropriate and plan- or project-specific;
how the thresholds distinguish between existing and new development; and why interim year
thresholds were developed.
Use of Local Data
The quantitative thresholds were developed using the City’s communitywide GHG emissions
forecasts for year 2030 and are therefore specific to the City of San Luis Obispo. The thresholds are
directly tied to the population and employment growth anticipated by the City’s (2014) General Plan
Land Use and Circulation Elements as well as to the City-specific GHG emission reduction measures
(i.e., pillars, measures, and foundational actions) that the City has proposed to reduce
communitywide emissions. In addition, the magnitude of local GHG emission reductions achieved by
State legislation/policies (i.e., vehicle fuel efficiency standards, the RPS, and Title 24) was estimated
based on City-specific growth and vehicle miles travelled (VMT) forecasts. As a result, these locally
appropriate thresholds directly address the concerns raised in the Golden Door Properties, LLC v.
County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case because they are based on
local GHG emissions data rather than Statewide GHG emissions data.
Disaggregation of Existing versus New Development
The quantitative thresholds were developed by disaggregating the City’s business-as-usual GHG
emissions forecasts for year 2030 into emissions forecasts for existing and new development, which
are shown in Table 5 in Section 5.1, Calculation Methodology. The emissions reductions specific to
new development achieved by State legislation/policies and the CAP were then subtracted from the
business-as-usual forecast to determine emissions “caps” of emissions from new residential and
new non-residential development for year 2030. These “caps” were then divided by the numbers of
residents, employees, and service persons forecasts for new development to determine efficiency
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
28
thresholds for residential, non-residential, and mixed-use development, respectively. Therefore,
these thresholds directly address the concerns raised in the Center for Biological Diversity v.
California Department of Fish and Wildlife (2015) case regarding the different rates of GHG
emissions reductions anticipated for new development as compared to existing development in
order to meet the specified GHG reduction target.
Selection of Sector-Specific Thresholds
The quantitative thresholds are separated into three categories – residential, non-residential, and
mixed-use – which are intended to apply to the three main types of development projects in San
Luis Obispo. These thresholds were calculated by disaggregating the City’s business-as-usual GHG
emissions forecasts for new development in year 2030 into emissions forecasts for new residential
and new non-residential development, which are shown in Table 5 in Section 5.1, Calculation
Methodology. The emissions reductions specific to new residential and new non-residential
development achieved by State legislation/policies and the CAP were then subtracted from the
business-as-usual forecast to determine “caps” of emissions for new residential and new non-
residential development for year 2030. These emissions “caps” were then divided by the numbers
of residents and employees forecast for new development in year 2030 to determine efficiency
thresholds for residential and non-residential projects, respectively. For mixed-use development,
the residential and non-residential emissions “caps” were summed, then divided by the service
population forecast for new development in year 2030 to determine an efficiency threshold for
mixed-use projects. As a result, these project-specific thresholds directly address the concerns
raised in the Center for Biological Diversity v. California Department of Fish and Wildlife (2015) case
because they are specific to each development project type.
Adoption via Public Review Process
In compliance with CEQA Guidelines Section 15064.7(b), this guidance document and the
quantitative thresholds contained herein will be presented to the City Council for formal adoption
via resolution through a public review process, which will include an opportunity for public input.
The public review process for these City of San Luis Obispo CEQA GHG Thresholds and Guidance will
specifically occur via public review of and comment on a joint CAP and CEQA GHG Thresholds and
Guidance Draft IS-ND. The opportunity for public comment will also be available at a public hearing
(i.e., City Council meeting) considering adoption of the CAP and CEQA GHG Thresholds and
Guidance. This process directly addresses the concerns raised in the Golden Door Properties, LLC v.
County of San Diego/Sierra Club, LLC v. County of San Diego (2018) case regarding formal adoption
of new CEQA thresholds and how lead agencies should afford the opportunity for public review and
input prior to adoption and use.
Quantifying GHG Emissions
29
6 Quantifying GHG Emissions
There are a variety of analytical tools available to estimate project-level GHG emissions, including
the California Emissions Estimator Model (CalEEMod),25 which is a free, publicly available computer
model developed for the California Air Pollution Control Officers Association (CAPCOA) in
collaboration with various air quality districts throughout the State. Alternative tools may be used to
quantify emissions if they can be substantiated. In general, the most current version of CalEEMod
should be used to calculate total emissions for discretionary development projects. The analysis
should focus on carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) because these are the
GHGs that most development projects would generate in the largest quantities. Fluorinated gases,
such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluorides, should also considered for
the analysis. Emissions of all GHGs should be converted into their equivalent global warming
potential in terms of CO2 (CO2e). Calculations should be based on the methodologies recommended
by the CAPCOA and the SLOAPCD and include the use of guidance published by CARB.26, 27, 28
6.1 Construction GHG Emissions
Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the
engines of off-road construction equipment and in on-road construction vehicles and in the
commute vehicles of the construction workers. Smaller amounts of GHGs are emitted indirectly
through the energy required for water used for fugitive dust control and lighting for the
construction activity. Every phase of the construction process, including demolition, grading, paving,
and building, emits GHG emissions in volumes proportional to the quantity and type of construction
equipment used. Heavier equipment typically emits more GHGs per hour of than lighter equipment
because of its engine design and greater fuel consumption.
The SLOAPCD recommends amortizing construction-related GHG emissions over the life of the
plan/project and adding amortized construction emissions to annual operational emissions for the
purpose of providing a mechanism for the plan/project to mitigate these impacts alongside
operational impacts. The SLOAPCD recommends an amortization period of 50 years for residential
projects and 25 years for commercial projects.29 The SLOAPCD does not provide a recommended
amortization period for mixed-use projects; however, these projects should use a conservative
amortization period of 30 years, which is consistent with the recommendations of the South Coast
Air Quality Management District.30
25 The most current available version of CalEEMod should be used. As of January 2020, CalEEMod version 2016.3.2 is the most curr ent
version and should be used to quantify project-level emissions.
26 California Air Pollution Control Officers Association. 2008. CEQA and Climate Change: Addressing Climate Change through California
Environmental Quality Act (CEQA). January 2008.
27 SLOAPCD. 2012. CEQA Air Quality Handbook. April 2012. https://www.slocleanair.org/rules-regulations/land-use-ceqa.php (accessed
January 2020).
28 CARB. 2018. EMFAC2017 Volume III – Technical Documentation v.1.0.2. July 20, 2018.
https://ww3.arb.ca.gov/msei/downloads/emfac2017 -volume-iii-technical-documentation.pdf (accessed January 2020).
29 SLOAPCD. 2012. CEQA Air Quality Handbook. April 2012. https://www.slocleanair.org/rules -regulations/land-use-ceqa.php (accessed
January 2020).
30South Coast Air Quality Management District. 2008. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance
Threshold. October 2008. http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance-
thresholds/ghgattachmente.pdf (accessed February 2020).
City of San Luis Obispo
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30
CalEEMod generates a default construction schedule and equipment list based on the plan-/project-
specific information, including land use, project size, location, and construction timeline.31 In
general, if specific applicant-provided information is unknown, the default construction equipment
list and phase lengths are the most appropriate inputs. However, if more detailed site-specific
equipment and phase information (i.e., data from the project applicant) is available, the model’s
default values can (and should) be overridden.32
6.2 Operational GHG Emissions
CalEEMod estimates operational emissions of CO2, N2O, and CH4 generated by area sources, energy
use, waste generation, and water use and conveyance as well as CO2 and CH4 generated by project-
generated vehicle trips (i.e., mobile sources). Operational emissions should be calculated for year
2030, rather than the plan/project buildout year, in order to provide an appropriate comparison of
project emissions to the year 2030 threshold.
Area Source Emissions
Area sources include GHG emissions that would occur from the use of landscaping equipment,
hearths, and woodstoves, which emit GHGs associated with the equipment’s fuel combustion. The
landscaping equipment emission values in CalEEMod are derived from the 2011 Off-Road
Equipment Inventory Model.33 Emission rates for combustion of wood and natural gas for wood
stoves and fireplaces are based on those published by the U.S. EPA in Chapter 1.9 of AP-42.
Typically, no adjustments to landscaping equipment inputs are necessary. The number of hearths
and woodstoves should be adjusted to reflect the project design.
Energy Use Emissions
GHGs are emitted on-site during the combustion of natural gas for cooking, space and water
heating, and decorative uses and off-site during the generation of electricity from fossil fuels in
power plants. CalEEMod estimates GHG emissions from energy use by multiplying average rates of
residential and non-residential energy consumption by the quantities of residential units and non-
residential square footage entered in the land use module to obtain total projected energy use. This
value is then multiplied by electricity and natural gas GHG emission factors applicable to the
plan/project location and utility provider. Building energy use is typically divided into energy
consumed by the built environment and energy consumed by uses that are independent of the
building, such as plug-in appliances. Non-building energy use, or “plug-in energy use,” can be further
subdivided by specific end-use (refrigeration, cooking, office equipment, etc.). In California, Title 24
governs energy consumed by the built environment, mechanical systems, and some types of fixed
lighting.
Electricity emissions are calculated by multiplying the energy use by the carbon intensity of the
utility district per kilowatt hour.34 Projects would be served either by Monterey Bay Community
Power or by PG&E. The specific energy intensity factors (i.e., the amount of CO2, CH4, and N2O per
31CAPCOA. 2017. California Emissions Estimator Model User Guide: Version 2016.3.2. Prepared by BREEZE Software, A Division of Trinity
Consultants in collaboration with South Coast Air Quality Management District and the California Air Districts.
http://www.aqmd.gov/caleemod/user's-guide (accessed January 2020).
32Ibid.
33Ibid.
34Ibid.
Quantifying GHG Emissions
31
kilowatt-hour) for the applicable utility should be used in the calculations of GHG emissions.
CalEEMod does not include Monterey Bay Community Power as a utility company choice; therefore,
users must select “User Defined” and manually enter energy intensity factors. Users should contact
the City's Community Development Department for the most recent energy intensity factors for
Monterey Bay Community Power’s current mix of power. For projects served by PG&E, the energy
intensity factors included in CalEEMod are based on 2009 data by default by default at which time
PG&E had only achieved a 14.1 percent procurement of renewable energy.35 Per SB 100, the
Statewide Renewable Portfolio Standard (RPS) Program requires electricity providers to increase
procurement from eligible renewable energy sources to 33 percent by 2020 and 60 percent by 2030.
Users should contact the City's Community Development Department for the most recent energy
intensity factors for PG&E.
Energy emissions should also be adjusted to account for the effects of new iterations of Title 24. For
examples, CalEEMod version 2016.3.2 does not accoun t for the requirements of the 2019 Title 24
standards, which went into effect on January 1, 2020. According to the California Energy
Commission, single-family homes and nonresidential buildings built to the 2019 Title 24 standards
will use approximately 7 percent and 30 percent less energy, respectively, due to more stringent
energy efficiency measures and lighting upgrades. Therefore, energy usage from single-family
residential usage should be reduced by 7 percent, and non-residential energy usage should be
reduced by 30 percent to account for the requirements of 2019 Title 24 standards.36
In accordance with Section 150.1(b)14 of the 2019 Building Energy Efficiency Standards, all new
residential uses three stories or less must install photovoltaic (PV) solar panels that generate an
amount of electricity equal to expected electricity usage. The calculation method contained in
Section 150.1(b)14 of the 2019 Building Energy Efficiency Standards should be utilized to estimate
the number of kilowatts of PV solar panels that would be required for a residential project three
stories or less. In addition, modeling should account for local regulations pertaining to mandatory
solar provisions.37 Online resources can be used to determine the amount of kilowatt-hours that
would be generated per year by the required solar PV system.38 The energy reduction achieved by
on-site PV solar panels should be included in CalEEMod.
Mobile Source Emissions
CalEEMod quantifies mobile source emissions of CO2, and CH4. If available, project-specific trip
generation rates or VMT data should be input in CalEEMod. To calculate mobile source emissions,
CalEEMod uses CO2 emission factors from the EMFAC2014 Emissions Inventory based on the
aggregated model year and aggregated speed and CH4 emission factors provided by CARB for the
plan/project’s first year of full operations.39 Because CalEEMod does not calculate N2O emissions
35 California Public Utilities Commission. 2011. Renewables Portfolio Standard Quarterly Report. 1st Quarter 2011.
http://www.cpuc.ca.gov/WorkArea/DownloadAsset.aspx?id=5858 (accessed January 2020).
36 California Energy Commission. 2019. “2019 Building Energy Efficiency Standards.” March 2018.
https://ww2.energy.ca.gov/title24/2019standards/documents/2018_Title_24_2019_Building_Standards_FAQ.pdf (accessed January
2020).
37 In 2020, the City Council will consider adoption of the Clean Energy Choice Program for New Buildings, which may include solar
requirements for other types of land uses.
38 Zientara, Ben. 2019. ”How much electricity odes a solar panel produce?” Last updated: November 6, 2019.
https://www.solarpowerrocks.com/solar -basics/how-much-electricity-does-a-solar-panel-produce/ (accessed March 2020).
39CAPCOA. 2017. California Emissions Estimator Model User Guide: Version 2016.3.2. Prepared by BREEZE Software, A Division of Trin ity
Consultants in collaboration with South Coast Air Quality Management District and the California Air Districts.
http://www.aqmd.gov/caleemod/user's-guide (accessed January 2020).
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
32
from mobile sources, N2O emissions should be quantified using guidance from CARB and the
EMFAC2017 Emissions Inventory. 40, 41
Water and Wastewater Emissions
The amount of water used, and the amount of wastewater generated by a plan/project generate
indirect GHG emissions. These emissions are a result of the energy used to supply, convey, and treat
water and wastewater. In addition to the indirect GHG emissions associated with energy use, the
wastewater treatment process itself can directly emit both CH4 and N2O.
The indoor and outdoor water use consumption data for each land use subtype comes from the
Pacific Institute’s (2003) Waste Not, Want Not: The Potential for Urban Water Conservation in
California.42 Based on that report, a percentage of total water consumption is dedicated to
landscape irrigation, which is used to determine outdoor water use. Wastewater generation is
similarly based on a reported percentage of total indoor water use.
New development will be subject to CalGreen, which requires a 20 percent increase in indoor water
use efficiency. Thus, in order to account for compliance with CalGreen, a 20 percent reduction in
indoor water use should be included in the water consumption calculations for new residential, non-
residential, and mixed-use development. In addition to water reductions associated with building
code compliance and project design features, the GHG emissions from the energy used to transport
the water for development should also account for compliance with the RPS using the guidance
provided under “Energy Use Emissions.”
Solid Waste Emissions
The disposal of solid waste produces GHG emissions from the transportation of waste, anaerobic
decomposition in landfills, and incineration. To calculate the GHG emissions generated by solid
waste disposal, the total volume of solid waste is calculated using waste disposal rates identified by
the California Department of Resources Recycling and Recovery (CalRecycle). The methods for
quantifying GHG emissions from solid waste are based on the IPCC method, using the degradable
organic content of waste. Users should contact the City's Community Development Department to
obtain the most recent solid rate diversion rate to be included in the calculation of solid waste GHG
emissions.
Plan or Project Design Features
Users should use the “Mitigation” tabs to include project design features applicable to the
plan/project.43 These features often include increased density, improved destination accessibility,
proximity to transit, integration of below market rate housing, unbundling of parking costs,
provision of transit subsidies, implementation of alternative work schedules, use of energy- and/or
water-efficient appliances, use of reclaimed and/or grey water, and installation of water-efficient
irrigation system. Users should consider the applicability of these features to the plan/project and
40 CARB. 2018. EMFAC2017 Volume III – Technical Documentation v.1.0.2. July 20, 2018.
https://ww3.arb.ca.gov/msei/downloads/emfac2017 -volume-iii-technical-documentation.pdf (accessed January 2020).
41 CARB. 2019. EMFAC2017 Web Database. https://www.arb.ca.gov /emfac/2017 (accessed January 2020).
42CAPCOA. 2017. California Emissions Estimator Model User Guide: Version 2016.3.2. Prepared by BREEZE Software, A Division of Trinity
Consultants in collaboration with South Coast Air Quality Management District and the California Air Districts.
http://www.aqmd.gov/caleemod/user's-guide (accessed January 2020).
43 “Mitigation” is a term of art for the modeling input and is not equivalent to mitigation measures that may apply to the CEQA impact
analysis.
Quantifying GHG Emissions
33
review the CAPCOA Quantifying Greenhouse Gas Mitigation Measures (2010) publication to ensure
that the chosen features are relevant and feasible in light of the plan/project.44
Residents, Employees, and Service Populations
The quantitative thresholds presented in Chapter 5, Utilizing Quantitative CEQA GHG Thresholds,
are expressed in terms of per resident for residential projects, per employee for non-residential
projects, and per service person for mixed-use projects. Estimates of the resident, employee, or
service population for a plan/project should be based on substantial evidence. The City of San Luis
Obispo Community Development Department defines service population as defined as the number
of residents plus half the number of employees for a given project.45 Data provided by the applicant
as well as the following resources may be utilized in estimating resident and employee populations:
▪ City of San Luis Obispo Community Development Department. Users should contact the City's
Community Development Department for the most recent estimate of persons per household in
San Luis Obispo. This estimate can be multiplied by the number of proposed residential units to
estimate a plan/project’s resident population.
▪ Proposed Number of Beds. For projects such as group homes, assisted living facilities, nursing
homes, or similar uses, the number of beds can be used to determine the resident population.
▪ United States Green Building Council. The United States Green Building Council has published a
summary of building area per employee by business type. These rates, which are expressed in
terms of square feet per employee, can be utilized to estimate the number of employees a
plan/project would require. This document is included as Appendix D.
6.3 Modeling GHG Emissions from Existing Land Use
For a plan/project that would result in a change in the plan area/project’s site General Plan land use
designation, emissions anticipated for the existing (2014) General Plan land use designation must be
calculated in conjunction with emissions for the proposed plan/project to demonstrate whether the
plan/project would be more or less GHG-intensive than development anticipated for the existing
(2014) General Plan land use designation for the site. In this case, GHG emissions should be
reported for both the existing and proposed scenarios. Emissions anticipated for the existing land
use should be quantified using the methods described in Section 6.1, Construction Emissions, and
Section 6.2, Operational Emissions with consistent assumptions between the two scenarios as
applicable. Any emission reduction credits applied to the proposed plan/project scenario that are
related to State legislation/policies (e.g., the RPS, vehicle standards, Title 24) or the plan
area/project site location (e.g., proximity to transit, destination accessibility, etc.) should also be
applied to the existing scenario. Emission reduction credits that are specific to the proposed
plan/project (e.g., use of recycled water, increased density, installation of energy and/or water-
efficient appliances, integration of below market rate housing, etc.) should only be included for the
proposed plan/project scenario. In addition, care should be taken to identify any emission reduction
credits that might be unique to the existing land use designation that would not apply to the
proposed plan/project. For example, if the existing land use designation allows for single-family
residences and the proposed land use designation would allow for only commercial uses, then the
existing scenario should include the emission reduction credit associated with the 2019 Building
44 CAPCOA. 2010. Quantifying Greenhouse Gas Mitigation Measures. August 2010. http://www.capcoa.org/wp -
content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf (accessed January 2020).
45 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
City of San Luis Obispo
CEQA GHG Emissions Thresholds and Guidance
34
Energy Efficiency Standards requirements for PV solar panels on residential uses that are three
stories or less whereas the proposed plan/project scenario should not include this credit unless PV
solar panels are included as a plan/project design feature.
Moving into the Future
35
7 Moving into the Future
Full implementation of the City’s CAP will reduce communitywide GHG emissions by approximately
66 percent below 1990 levels by 2035, which would leave a gap of approximately 111,030 MT of
CO2e per year that will need to be addressed to achieve carbon neutrality. This gap represents
emissions that could be addressed by laws, regulations, policies, programs, and ordinances set forth
by the federal and State governments, regional agencies, and local partners. The gap also represents
the uncertainty that the City faces in taking a leadership role in addressing a challenge that has not
been solved before. The City is committed to embracing that uncertainty, committing to constant
learning, engaging in systemic change using the tools and actions that local governments are
uniquely suited to carry out, and positioning itself to take full advantage of future innovations,
technologies, and policies and legislation that may be undertaken at the State and federal level.
Technological innovation, clean-tech innovation, and changes to climate related policy and
regulation occur rapidly. Several of the State’s most successful environmental policy initiatives,
including the RPS, also had a gap between what was known at the time of adoption and eventual
successful implementation. By committing to the ambitious target of carbon neutrality by 2035, the
City intends to catalyze innovation, invite resources from funding sources and partners, and provide
climate leadership.
The CAP acknowledges that additional actions beyond those identified in the plan will be necessary
to achieve carbon neutrality and therefore provides a mechanism for updating and adopting a new
climate action plan every other financial plan cycle (i.e., in conjunction with the 2023-2025, 2027-
2029, and 2031-2033 cycles) in order to incorporate new measures and innovative technologies that
will further the City toward meeting its goal of carbon neutrality.46 As the CAP is updated, the
associated CEQA GHG Emissions Analysis Compliance Checklist will also be updated as needed to
incorporate new pillars, measures, and/or foundational actions that discretionary development
projects will need to incorporate, as applicable, to demonstrate consistency with the CAP. At the
time at which the City identifies measures to achieve its carbon neutrality goal in totality, the City
will adopt those measures in a public process following CEQA review, at which time the CAP will
become a qualified GHG emission reduction plan for projects with post-2030 buildout years.
However, the quantitative thresholds included in this guidance document will not need to be
updated because residential, non-residential, and mixed-use projects with post-2030 buildout years
will still need to achieve GHG emissions equivalent to 0 MT of CO2e per year to demonstrate
consistency with the City’s CAP.
In addition, if future amendments or updates of the City’s General Plan Land Use and Circulation
Elements occur, then these amendments or updates will be incorporated into future updates of the
CAP to ensure that project applicants can continue to utilize the streamlining process, which is
partly dependent on a plan/project’s consistency with the demographic forecasts and land use
assumptions based on the General Plan Land Use and Circulation Elements, to the greatest extent
practicable.
46 San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report. November 2019.
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