The County concurs with the significance thresholds that Bay Area Air Quality Management District (BAAQMD) staff have recommended for projects other than stationary sources. The greenhouse gas (GHG) significance threshold is 1,100 metric tons per year of CO2e or 4.6 metric tons of CO2e per service population (residents and employees) per year. These thresholds are supported by substantial evidence for the reasons stated by BAAQMD staff.
While the project’s GHG emissions are most likely less than the significance threshold of 1,100 MT CO2e/year, used by the BAAQMD, the County has committed to reducing emissions to the maximum extent feasible by implementing all reasonably feasible measures and best available technologies to further reduce greenhouse gas emissions.
The County’s adopted goals and policies include General Plan Policy OSRC-14.4 to reduce greenhouse gas emissions 25% below 1990 levels by 2015. Sonoma County emissions in 2015 were 9% below 1990 levels, while the countywide population grew 4%. In May 2018, the Board of Supervisors adopted a Resolution of Intent to Reduce Greenhouse Gas Emissions that included adoption of the Regional Climate Protection Agency’s goal to further reduce greenhouse gas emissions by 40% below 1990 levels by 2030 and by 80% below 1990 levels by 2050. The Resolution of Intent included specific measures that can further reduce GHG emissions. All new development is required to evaluate all reasonably feasible measures to reduce GHG emissions and enhance carbon sequestration.
The project plans should include reasonably feasible measures to reduce GHG emissions in the design, construction, and long-term operations of the project. The assigned Project Planner will work with the applicant on the appropriate measures to be implemented. If an existing facility is requesting a Use Permit modification and some GHG emissions reduction measures are already being incorporated, description of them should be included in the application.
The measures chosen to be implemented should be incorporated into the project plans and a description of them submitted as part of the application so they can be included in the environmental analysis in the greenhouse gas section of the CEQA document. If measures are not incorporated into the project, then a Greenhouse Gas Reduction Plan that defines measures to reduce greenhouse gas emissions in the design, construction, and long-term operations of the project will be required as a mitigation measure and condition of approval.
An air pollutant emissions analysis should be included with the greenhouse gas emissions analysis since this information will also be required for the preparation of the CEQA document. An air quality consultant can conduct both analyses.