GREENHOUSE GAS ASSESSMENT. MELROSE + OCEANSIDE PLANNED DEVELOPMENT City of Oceanside, CA

Transcription

1 GREENHOUSE GAS ASSESSMENT MELROSE + OCEANSIDE PLANNED DEVELOPMENT City of Oceanside, CA Prepared By: Chisolm Trail Murrieta, CA Prepared For: California West Communities 5927 Priestly Drive, Suite 110 Carlsbad, CA March 31, 2016 Project: Melrose Oceanside GHG Report

2 TABLE OF CONTENTS TABLE OF CONTENTS... II LIST OF FIGURES... III LIST OF TABLES... III APPENDIX... III LIST OF ACRONYMS... IV EXECUTIVE SUMMARY... V 1.0 INTRODUCTION PURPOSE OF THIS STUDY PROJECT LOCATION PROJECT DESCRIPTION EXISTING ENVIRONMENTAL SETTING UNDERSTANDING GREENHOUSE GASSES EXISTING SETTING CLIMATE AND METEOROLOGY CLIMATE CHANGE REGULATORY ENVIRONMENT REGULATORY STANDARDS (ASSEMBLY BILL 32) REGULATORY STANDARDS (ASSEMBLY BILL 341) REGULATORY STANDARDS (SENATE BILL 97) ENERGY INDEPENDENCE AND SECURITY ACT OF AB 1493 (PAVLEY STANDARDS) ADVANCED CLEAN CAR PROGRAM VEHICLE EFFICIENCY MEASURES EXECUTIVE ORDER S EXECUTIVE ORDER S EXECUTIVE ORDER B EXECUTIVE ORDER S TITLE 24 STANDARDS CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) SIGNIFICANCE THRESHOLDS SCOPING PLAN MEASURES CITY OF OCEANSIDE THRESHOLDS OF SIGNIFICANCE METHODOLOGY CONSTRUCTION CO2E EMISSIONS CALCULATION METHODOLOGY OPERATIONAL EMISSIONS CALCULATION METHODOLOGY FINDINGS PROJECT RELATED CONSTRUCTION EMISSIONS PROJECT RELATED OPERATION VEHICULAR EMISSIONS PROJECT-RELATED VEHICULAR EMISSION REDUCTION STRATEGIES INDIRECT ELECTRICITY AND NATURAL GAS DESIGN FEATURES ELECTRICAL UTILITY REDUCTION MEASURES WATER REDUCTIONS PROJECT RELATED SOLID WASTE EMISSIONS REDUCTIONS AREA SOURCE REDUCTIONS MITIGATED GHG EMISSIONS BUSINESS AS USUAL ANALYSIS OF SIGNIFICANCE Ldn Consulting, Inc. 3/31/16 ii Melrose Oceanside GHG Report

3 EFFICIENCY METRIC ANALYSIS OF SIGNIFICANCE PROJECT SERVICE POPULATION EFFICIENCY CALCULATION PROJECT SERVICE POPULATION EFFICIENCY CALCULATION SIGNIFICANCE OF PROJECT GHG IMPACTS FOR 2030 AND REFERENCES CERTIFICATIONS List of Figures FIGURE 1-A: PROJECT VICINITY MAP... 2 FIGURE 1-B: PROPOSED PROJECT SITE DEVELOPMENT PLAN... 3 List of Tables TABLE 4.1: EXPECTED CONSTRUCTION EQUIPMENT TABLE 5.1: EXPECTED ANNUAL CONSTRUCTION CO2E EMISSIONS SUMMARY TABLE 5.2: EXPECTED UNMITIGATED OPERATIONAL EMISSIONS SUMMARY MT/YEAR TABLE 5.3: YEAR 2020 UNMITIGATED AND MITIGATED GHG EMISSIONS TABLE 5.4: YEAR 2030 UNMITIGATED AND MITIGATED GHG EMISSIONS TABLE 5.5: YEAR 2050 UNMITIGATED AND MITIGATED GHG EMISSIONS Appendix CALEEMOD ANNUAL EMISSION MODEL CALEEMOD ANNUAL EMISSION MODEL CALEEMOD ANNUAL EMISSION MODEL Ldn Consulting, Inc. 3/31/16 iii Melrose Oceanside GHG Report

4 LIST OF ACRONYMS Assembly Bill 32 (AB32) Business as Usual (BAU) California Air Pollution Control Officers Association s (CAPCOA) California Air Resource Board (CARB) California Environmental Quality Act (CEQA) Carbon Dioxide (CO 2) Cubic Yards (CY) Environmental Protection Agency (EPA) Green House Gas (GHG) International Residential Code (IRC) Low Carbon Fuel Standard (LCFS) Methane (CH 4) Nitrous Oxide (N 2O) San Diego Air Basin (SDAB) San Diego Air Pollution Control District (SDAPCD) Senate Bill 97 (SB97) Vehicle Miles Traveled (VMT) Ldn Consulting, Inc. 3/31/16 iv Melrose Oceanside GHG Report

5 EXECUTIVE SUMMARY This analysis has been completed in order to quantify Greenhouse Gas (GHG) emissions from the proposed project and was prepared according to guidelines established within the California Global Warming Solutions Act of 2006 Assembly Bill 32 (AB32), Senate Bill 97 (SB97), Executive Order (EO) S-3-05, EO B-30-15, and the California Environmental Quality Act (CEQA). Greenhouse Gasses analyzed in this study are Carbon Dioxide (CO 2), Methane (CH 4), and Nitrous Oxide (N 2O). To simplify greenhouse gas calculations, both CH 4 and N 2O are converted to equivalent amounts of CO 2 and are identified as Carbon Dioxide equivalent (CO 2e). The proposed project would be developed to include 276 multi-family and 37 single-family residential units, 10,000 square feet (SF) of office uses, and 10,000 SF of restaurant space. More specifically, the project would construct 78 townhomes and both the office and restaurant space as part of Planning Area 1 (PA-1), 37 single family residential units as part of Planning Area 2 (PA-2), and 198 two and three-story multifamily units as part of Planning Area 3 (PA-3). All phases (i.e. grading, paving and construction) of the proposed Project are anticipated to start in fall of 2017 and potentially be completed by the end of In the event construction of the project commences later than fall of 2017, emissions would be less than disclosed herein as newer, more efficient construction equipment replaces older, less efficient equipment. The proposed project will emit GHGs directly through the burning of carbon-based fuels such as gasoline and natural gas as well as indirectly through usage of electricity, water and from the anaerobic bacterial breakdown of organic solid waste. The proposed project would generate approximately 4, Metric Tons (MT) of CO 2e each year under business as usual which exceeds California Air Pollution Control Officers Association s (CAPCOA) recommended 900 Metric Ton per year screening threshold. It is important to note that GHGs for projects that exceed this threshold are not necessarily considered significant under CEQA; rather, this threshold is used to determine when additional analysis is required. For projects that exceed the CAPCOA threshold of 900 MT CO 2e, the CAPCOA recommends that CEQA Lead Agencies quantify the GHG emissions, apportion the forecast emissions to relevant source categories, and develop GHG mitigation measures to reduce their emissions by 16% from business as usual (BAU) 2020 conditions. (California Air Pollution Control Officers Association, 2008, p. 48) Another method for evaluating GHG emissions is to utilize the reductions recommended in CARB s 2014 Updated Scoping Plan. Pursuant to Executive Order S-3-05, GHGs statewide shall be reduced to 1990 levels by year The Scoping Plan recommends that local governments target 2020 emissions at 15% below 2 levels to account for emissions growth since 1990 as a proxy for 1990 emissions, since few localities have conducted a detailed GHG emissions inventory to estimate 1990 emission levels. Oceanside GHG emissions from the 2 inventory were 959,772 metric tons carbon dioxide equivalents (MTCO 2e) per year according to Ldn Consulting, Inc. 3/31/16 v Melrose Oceanside GHG Report

6 the City of Oceanside 2 Greenhouse Gas Emissions Inventory (San Diego Foundation, 2011). The 2020 target under State guidance is a 15 percent reduction from 2 emissions; thus, the City-wide target emissions for 2020 would be 815,806 MT CO 2e (85% of 959,772 = 815,806) pursuant to Executive Order S Regulatory measures such as Pavley II rules and California s Low Carbon Fuel Standards, mixed use design, low flow water fixtures and the latest Title 24 Building standards will reduce CO 2e emissions by up to 1, Metric Tons per year, reducing project emissions to 2, MT per year. These CO 2e measures would reduce emissions by as much as 34.04% which would meet the goals of AB 32 and CEQA and would not result in the creation of any significant impacts. Additionally, in order to provide a conservative analysis, this analysis quantifies project emissions in 2030 and 2050 to help establish projections and to assist in verifying future emissions and compatibility with both B and S Given the fact that regulatory emission reductions will continue to improve well beyond what is known at this time, a worstcase prediction of 2, MT is expected in 2030 and 2, MT is expected in Given this, the project s GHG emissions will steadily decrease with time as the State s existing and planned regulatory objectives are implemented and achieved. Also, as statewide regulatory initiatives, including those identified by CARB in the Scoping Plan are implemented, and other technological innovations occur, it is reasonable to assume that the statewide and the proposed project s GHG emissions levels would be reduced further. Based on the results of the analysis, it is estimated that the proposed Project s unmitigated 2020 GHG emissions would total approximately 4, MT CO 2e, but would be reduced through regulatory requirements and Project-specific mitigation to approximately 2,975.5 MT CO 2e. A reduction of this size would reduce the project emissions by 34.04% which will meet and exceed 16% GHG reduction target pursuant to ARB s 2014 Scoping Plan, resulting in lessthan-cumulatively considerable impacts. A service population-based analysis was also conducted to identify an efficiency target as necessary to meet the State s GHG reduction goals as set forth in Executive Order S-3-05, Executive Order B-30-15, and AB 32 to achieve the following GHG reductions: 1) reduce emissions to 1990 levels by 2020; 2) reduce emissions to 40% below 1990 levels by 2030; and 3) reduce emissions to 80% below 1990 levels by A service population-based analysis establishes an efficiency target based on total service population (i.e., residents plus employees) within a given area. Based on limited availability of data, for 2 conditions, the City of Oceanside was found to have an efficiency ratio of 4.43 MT CO 2e/year/service population. In order to achieve the City-wide emission level of 815,806 MT CO 2e, the required efficiency target city-wide in 2020 would be 3.34 MT CO 2e per service population. The Project s mitigated GHG emissions would yield an efficiency ratio of 3.02 MT/year/service Ldn Consulting, Inc. 3/31/16 vi Melrose Oceanside GHG Report

7 population. Accordingly, based on this analysis, Project-related GHG emission impacts in 2020 would be less-than-cumulatively considerable with the incorporation of regulatory requirements and Project-specific mitigation. The purpose of this supplemental analysis is to provide additional project-level analysis of the GHG emissions associated with the Project in response to the California Supreme Court s decision published on November 30, 2015 in Center for Biological Diversity v. California Department of Fish and Wildlife (Case No ) (the Newhall Ranch Case), which permits lead agencies to either use the business as usual (BAU) methodology with supplemental information about the relationship between a project and the assumptions in the state s Scoping Plan or to use other methodologies. Given the difficulties associated with trying to provide supplemental information about the relationship between the Project and the assumptions in the state s Scoping Plan for achieving state GHG reduction targets by 2020, this analysis used the following method to clarify and confirm whether the Project s GHG emissions impacts are cumulatively considerable and whether impacts are less than significant. As noted above, the total amount of GHG emissions within the State, including emissions associated with the proposed project and other cumulative development, would continue to decline as federal, statewide, and local laws and regulatory initiatives, including but not limited to those identified by CARB in its Scoping Plan, are implemented and as technological innovations advance that reduce GHG emissions from fuel combustion and other sources. However, due to an abundance of variables, the exact level of cumulative GHG emissions and emission reductions that will be achieved statewide through mandatory adherence to federal, state, and/or local regulations cannot be precisely calculated. Accordingly, any conclusion as to the significance of the Project s contribution to cumulative, statewide GHG emissions in years 2030 and 2050 would be speculative (CEQA Guidelines 15145). Nonetheless, the analysis herein demonstrates that implementation of the Project would meet and exceed the 2020 GHG reduction target as set forth by EO S-3-05, and Project-related emissions would continue to decline over time beyond Because the Project would reduce emissions by 16% as compared to 2020 BAU conditions, and because the Project would achieve a service population ratio that is less than the calculated City-wide target of 3.34 MT/year/service population for year 2020, the Project would comply with EO S Project compliance with EO S-3-05 demonstrates that the Project would not inhibit the ability of the City of Oceanside or the State of California to achieve the GHG reductions required by EO S-3-05, EO B-30-15, and AB 32 while still accommodating growth. Therefore, the Project s GHG emissions impacts would be less-than-cumulatively considerable with incorporation of mitigation and mandatory adherence to current and future regulations that would assist the State in achieving the AB 32 GHG reduction target. Ldn Consulting, Inc. 3/31/16 vii Melrose Oceanside GHG Report

8 1.0 INTRODUCTION 1.1 Purpose of this Study The purpose of this Green House Gas Assessment (GHG) is to show conformance to the California Global Warming Solutions Act of 2006 Assembly Bill 32 (AB32) and Senate Bill 97 (SB97). AB32 requires that by 2020 the state's greenhouse gas emissions be reduced to 1990 levels and SB97 a "companion" bill directed amendments to the California Environmental Quality Act (CEQA) statute to specifically establish that GHG emissions and their impacts are appropriate subjects for CEQA analysis. Should impacts be determined, the intent of this study would be to recommend suitable design measures to bring the project to a level considered less than significant. 1.2 Project Location The Melrose+Oceanside site is located in the Peacock neighborhood within the east-central portion of the City of Oceanside. The overall project site is comprised of approximately acres of land located along the north side of Oceanside Boulevard / West Bobier Drive (APNs: and & 20). The Plan area is bisected into eastern and western portions by North Melrose Drive. Sports Park Way is located along the eastern portion of the Plan area providing access to the Vista Sports Park. Project access is proposed via Oceanside Boulevard, North Melrose Drive, and Sports Park Way (via West Bobier Drive). A general project vicinity map is shown in Figure 1 A on the following page. 1.3 Project Description The Melrose+Oceanside Plan proposes a coordinated development of a variety of residential, office and restaurant uses within three separate Planning Areas (PAs) on approximately 37.5 gross developable acres across the project site. The proposed plan also designates the preservation of approximately 31.7 acres of natural open space comprising the northern-most portion of the site area and a small area east of Sports Park Way. The Proposed project would be developed to include 276 multi-family, 37 single family residential units, 10,000 SF of office, and 10,000 SF of restaurant space. More specifically, the project would construct 78 townhomes and both the office and restaurant space as part of Planning Area (PA) 1, 37 single family residential units as part of PA-2, and 198 two and three-story multifamily units as part of PA-3. The project would also be designed to maximize pedestrian friendly access to existing transit services providing residents, visitors and workers direct connections to the surrounding community and regional area. A project development plan is shown on Figure 1-B on Page 3 of this report. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

9 Figure 1-A: Project Vicinity Map Project Site Source: (Google 2015, n.d.) Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

10 Figure 1-B: Proposed Project Site Development Plan Source: (Hunsaker & Associates, 2016) Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

11 2.0 EXISTING ENVIRONMENTAL SETTING 2.1 Understanding Greenhouse Gasses GHGs such as water vapor and carbon dioxide are abundant in the earth s atmosphere and they absorb and emit thermal infrared radiation which acts like an insulator to the planet. Without these gases, the earth s ambient temperature would either be extremely hot during the day or blistering cold at night. However, because these gases can both absorb and emit heat, the earth s temperature does not sway too far in either direction. Over the years as human activities require the use of burning fossil fuels, stored carbon is released into the air in the form of CO 2 and to a much lesser extent CO. Additionally, over the years scientists have measured this rise in CO 2 and fear that it may be heating the planet too. Additionally, it is thought that other GHGs such as CH 4 and N 2O are to blame. GHGs of concern as analyzed in this study are CO 2, CH 4, and N 2O. To simplify GHG calculations, both CH 4 and N 2O can be converted to an equivalent amount of CO 2 or CO 2e. CO 2e is calculated by multiplying the calculated levels of CH 4 and N 2O by a Global Warming Potential (GWP). The U.S. Environmental Protection Agency publishes GWPs for various GHGs, and reports that the GWPs for CH 4 and N 2O are 21 and 310, respectively. 2.2 Existing Setting The Project site lies in the in the south eastern portion of Oceanside north of the City of Vista in the San Diego Air Basin (SDAB). The overall site consists of undeveloped gentle to moderate terrain that descends gradually from south to north. Within the Plan area there are two separate pieces of property. The property west of North Melrose Drive contains a knoll that gently slopes up from Oceanside Boulevard and descends to the northern terminus of the property at North Melrose Drive. Elevations within this area range from approximately 334 feet above Mean Sea Level (MSL) at its northern terminus to approximately 429 feet MSL at the top of the knoll near the south central portion of the site. relief in this area is approximately 95 feet. The proposed project is surrounded by residential to the east and west, opens space to the north and land occupied by North County Transit District (NCTD) to the south. More specifically, just south of the project is Melrose Station which offers the Sprinter line which connects Escondido to Oceanside, and connections to the NCTD Coaster, L.A. Metrolink, and Amtrak service. NCTD bus service is also available adjacent to the site. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

12 2.3 Climate and Meteorology Climate within the San Diego Air Basin (SDAB) area often varies dramatically over short geographical distances with cooler temperatures on the western coast gradually warming to the east as prevailing winds from the west heats up. Most of southern California is dominated by high-pressure systems for much of the year, which keeps San Diego mostly sunny and warm. Typically, during the winter months, the high pressure system drops to the south and brings cooler, moister weather from the north. It is common for inversion layers to develop within high-pressure areas, which mostly define pressure patterns over the SDAB. These inversions are caused when a thin layer of the atmosphere increases in temperature with height. An inversion acts like a lid preventing vertical mixing of air through convective overturning. Meteorological trends within Oceanside produce daytime highs typically ranging between 65ºF in the winter to approximately 78ºF in the summer with August usually being the hottest month. Median temperatures range from approximately 55ºF in the winter to approximately 70ºF in the summer. The average humidity is approximately 64% in the winter and about 72% in the summer (City-Data, 2015). Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

13 3.0 CLIMATE CHANGE REGULATORY ENVIRONMENT 3.1 Regulatory Standards (Assembly Bill 32) The Global Warming Solutions Act of 2006 (AB 32), requires that by 2020 the state's greenhouse gas emissions be reduced to 1990 levels or from about 545 metric tons as projected as a 2020 baseline to 427 metric tons which would be required to meet the goal. Significance thresholds have not been adopted but are currently being discussed. AB 32 is specific as to when thresholds shall be defined. The pertinent sections are referenced within Part 4 of AB 32 Titled Greenhouse Gas Emissions Reductions are shown below: Section (b) states: On or before January 1, 2010, the state board shall adopt regulations to implement the measures identified on the list published pursuant to subdivision (a). Section states: (A) On or before January 1, 2011, the state board shall adopt greenhouse gas emission limits and emission reduction measures by regulation to achieve the maximum technologically feasible and cost-effective reductions in greenhouse gas emissions in furtherance of achieving the statewide greenhouse gas emissions limit, to become operative beginning on January 1, (B) In adopting regulations pursuant to this section and Part 5 (commencing with Section (38570), to the extent feasible and in furtherance of achieving the statewide greenhouse gas emissions limit, the state board shall do all of the following: 1. Design the regulations, including distribution of emissions allowances where appropriate, in a manner that is equitable, seeks to minimize costs and maximize the total benefits to California, and encourages early action to reduce greenhouse gas emissions. 2. Ensure that activities undertaken to comply with the regulations do not disproportionately impact low-income communities. 3. Ensure that entities that have voluntarily reduced their greenhouse gas emissions prior to the implementation of this section receive appropriate credit for early voluntary reductions. 4. Ensure that activities undertaken pursuant to the regulations complement, and do not interfere with, efforts to achieve and maintain federal and state ambient air quality standards and to reduce toxic air contaminant emissions. 5. Consider cost-effectiveness of these regulations. 6. Consider overall societal benefits, including reductions in other air pollutants, diversification of energy sources, and other benefits to the economy, environment, and public health. 7. Minimize the administrative burden of implementing and complying with these regulations. 8. Minimize leakage. 9. Consider the significance of the contribution of each source or category of sources to statewide emissions of greenhouse gases. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

14 (C) In furtherance of achieving the statewide greenhouse gas emissions limit, by January 1, 2011, the state board may adopt a regulation that establishes a system of market-based declining annual aggregate emission limits for sources or categories of sources that emit greenhouse gas emissions, applicable from January 1, 2012, to December 31, 2020, inclusive, that the state board determines will achieve the maximum technologically feasible and cost-effective reductions in greenhouse gas emissions, in the aggregate, from those sources or categories of sources. (D) Any regulation adopted by the state board pursuant to this part or Part 5 (commencing with Section 38570) shall ensure all of the following: 1. The greenhouse gas emission reductions achieved are real, permanent, quantifiable, verifiable, and enforceable by the state board. 2. For regulations pursuant to Part 5 (commencing with Section 38570), the reduction is in addition to any greenhouse gas emission reduction otherwise required by law or regulation, and any other greenhouse gas emission reduction that otherwise would occur. 3. If applicable, the greenhouse gas emission reduction occurs over the same time period and is equivalent in amount to any direct emission reduction required pursuant to this division. 3.2 Regulatory Standards (Assembly Bill 341) This bill makes a legislative declaration that it is the policy goal of the state that not less than 75% of solid waste generated be source reduced, recycled, or composted by the year 2020, and would require the Department of Resources Recycling and Recovery, by January 1, 2014, to provide a report to the Legislature that provides strategies to achieve that policy goal and also includes other specified information and recommendations. This bill will increase diversion requirements by an additional 25% over Business as Usual as was defined under AB 939 and SB 1322 which were signed into law as the Integrated Waste Management Act of 1989, which as of the year 2000 only required 50 percent diversion. 3.3 Regulatory Standards (Senate Bill 97) SB 97 requires the Office of Planning and Research to prepare and transmit to the Resources Agency, guidelines and directed amendments to the CEQA statute specifically for the mitigation of greenhouse gas emissions or the effects of greenhouse gas emissions. 3.4 Energy Independence and Security Act of 2007 The Energy Independence and Security Act of 2007 (GPO, 2007) is an energy policy law adopted by congress which consists mainly of provisions designed to increase energy efficiency and the availability of renewable energy. The law will require automakers to boost fleet wide gas mileage averages from the current 25 mpg to 35 mpg by 2020, which will Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

15 reduce energy needs by 28.5%. This fleet wide average is known as the Corporate Average Fuel Economy (CAFE) standard. 3.5 AB 1493 (Pavley Standards) AB 1493 regulations are similar to CAFE Standards but are expected to produce a GHG benefit greater than that of the CAFE Standards doubling the amount of GHGs saved under CAFE. The Pavley rules (also referred to as California Standards) are designed to regulate GHG emissions while the federal standards are aimed at reducing the nation s fuel consumption. Under Pavley I, starting with vehicles produced in 2009, manufacturers have the flexibility in meeting California standards through a combination of reducing tailpipe emissions of CO 2, N 2O, CH 4 and hydrofluorocarbons from vehicle air conditioning systems. Furthermore, the California standards are estimated to increase fuel efficiency to 35.7 miles per gallon by 2016, and under more stringent emission limits (Pavley II), would increase efficiency to 42.5 miles per gallon by 2020 (California Air Resourrce Board, 2013). 3.6 Advanced Clean Car Program Pavley II along with other Low-Emission Vehicle (LEV) regulations including new approaches to increase zero emission vehicles and hybrids have since been combined into a single program termed Advanced Clean Cars (California Air Resource Board, 2014). The new effort uses a number of emission control programs to reduce smog, soot and global warming and would be in effect from 2017 to This program is estimated to reduce GHGs by 4.0 million metric tons or roughly 2.4% beyond that of Pavley I (California Air Resource Board, 2011). 3.7 Vehicle Efficiency Measures Vehicle efficiency measures within the Scoping Plan include Low Friction Oil, Tire Pressure Regulation, Tire Tread Program, and Solar Reflective Automotive Paint and specialized window glazing to reduce GHGs by 4.5 MMTCO2e in To date, however, some of these reduction measures are still under review with the exception of the Tire Pressure Regulations which are estimated to remove 0.6 MMTCO2e. 3.8 Executive Order S Executive Order S was signed by Governor Arnold Schwarzenegger in January 2007 and is effectively known as the Low Carbon Fuel Standard (LCFS). The Executive Order Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

16 seeks to reduce the carbon intensity of California s passenger vehicle fuels by at least 10% by The LCFS will require fuel providers in California to ensure that the mix of fuel they sell into the California market meet, on average, a declining standard for GHG emissions measured in CO 2e grams per unit of fuel energy sold. 3.9 Executive Order S-3-05 Executive Order S-3-05 was signed by Governor Arnold Schwarzenegger in June 2. That the following greenhouse gas emission reduction targets are hereby established for California: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; by 2050, reduce GHG emissions to 80 percent below 1990 levels Executive Order B Executive Order B was signed by Governor Edmund Brown Jr. in April The executive order seeks to establish a California greenhouse gas reduction target of 40 percent below 1990 levels by 2030 which would help the state meet targets of reducing greenhouse gas emissions to 80 percent below 1990 levels by 2050 covered under EO S-3-05 (Office of Governor Edmund G. Brown Jr., 2015) Executive Order S Executive Order S was signed by Governor Arnold Schwarzenegger and is effectively known as the Renewable Portfolio Standard (RPS). According to S-14-08, the RPS will require that all retail sellers of electricity shall serve 33 percent of their load with renewable energy by State government agencies are hereby directed to take all appropriate actions to implement this target in all regulatory proceedings, including siting, permitting, and procurement for renewable energy power plants and transmission lines. Section was added in 2011 to the Public Utilities Code by Governor Brown which was signed by the senate and requires the California Public Utilities Commission (CPUC or Commission), in consultation with the California Energy Commission (CEC), to report to the Legislature by January 1 of every even-numbered year on all of the following: (a) The progress and status of RPS procurement; (b) The status of permitting and siting RPS resources and transmission facilities; (c) The projected ability of each electrical corporation to meet the RPS requirements pursuant to the cost limitations established by Section (d) (d) barriers to, and recommendations for achieving the RPS requirements. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

17 Based on the latest Biennial RPS Program Update per the Section requirements, San Diego Gas and Electric will utilize 43.1% RPS in 2020 which is over 10% higher than required by the state (California Public Utilities Commission, 2016). It should be noted that Governor Jerry Brown is committed to increasing this regulation such that the renewable portfolio in 2030 would be at least 50%. This commitment was entered into agreement with multiple international states signed on May 19, 2015 by California. (Subnational Global Climate Leadership Memorandum of Understanding, 2015). Though this is not law, for purposes of speculative GHG forecasting into 2030 and 2050, it s reasonable to assume that it will be a requirement Title 24 Standards The California Energy Code, or Title 24, Part 6 of the California Code of Regulations, also titled The Energy Efficiency Standards for Residential and Nonresidential Buildings, were established in 1978 in response to a legislative mandate to reduce California's energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods (Wikipedia, n.d.). The Energy Commission adopted the 2008 changes to the Building Energy Efficiency Standards for some of the following reasons and would reduce both Natural Gas and Electrical demand: 1. To provide California with an adequate, reasonably-priced, and environmentallysound supply of energy. 2. To respond to Assembly Bill 32, the Global Warming Solutions Act of 2006, which mandates that California must reduce its greenhouse gas emissions to 1990 levels by To pursue California energy policy that energy efficiency is the resource of first choice for meeting California's energy needs. 4. To act on the findings of California's Integrated Energy Policy Report (IEPR) that Standards are the most cost effective means to achieve energy efficiency, expects the Building Energy Efficiency Standards to continue to be upgraded over time to reduce electricity and peak demand, and recognizes the role of the Standards in reducing energy related to meeting California's water needs and in reducing greenhouse gas emissions. 5. To meet the West Coast Governors' Global Warming Initiative commitment to include aggressive energy efficiency measures into updates of state building codes. 6. To meet the Executive Order in the Green Building Initiative to improve the energy efficiency of nonresidential buildings through aggressive standards. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

18 Title has been found reduce electrical emissions by 22.7% when comparing prototype buildings built to the minimum standards in 2 and then comparing the prototypes within duplicate models built to standards in (Architectural Energy Corporation for California Energy Commission, November 7, 2007) Title incorporated Cal Green standards and added a voluntary tiered approach which compared efficiency over Title (California Building Standards Commission, June 2010). The latest standards are have been updated (Title ) and are effective as of July 1, Looking at the entire construction outlook for low rise single family detached homes, electricity use is reduced by 36.4 percent and natural gas consumption is reduced by 6.5 percent (Architectural Energy Corporation (AEC), 2013). Nonresidential Newly Constructed Buildings would have a reduction from the 2008 Standards of 22 percent for electricity and 17 percent for natural gas California Environmental Quality Act (CEQA) Significance Thresholds As directed by SB 97, the Natural Resources Agency adopted Amendments to Title 14 Division 6 Chapter 3 CEQA Guidelines for greenhouse gas emissions on December 30, On February 16, 2010, the Office of Administrative Law approved the Amendments, and filed them with the Secretary of State for inclusion in the California Code of Regulations. The amendments became effective on March 18, The pertinent sections are shown below: Section Determining the Significance of Impacts from Greenhouse Gas (a) The determination of the significance of greenhouse gas emissions calls for a careful judgment by the lead agency consistent with the provisions in section A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate the amount of greenhouse gas emissions resulting from a project. A lead agency shall have discretion to determine, in the context of a particular project, whether to: 1. Use a model or methodology to quantify greenhouse gas emissions resulting from a project, and which model or methodology to use. The lead agency has discretion to select the model or methodology it considers most appropriate provided it supports its decision with substantial evidence. The lead agency should explain the limitations of the particular model or methodology selected for use; and/or 2. Rely on a qualitative analysis or performance-based standards. (b) A lead agency should consider the following factors, among others, when assessing the significance of impacts from greenhouse gas emissions on the environment: 1. The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting; 2. Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

19 3. The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions. 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 greenhouse gas 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. General Questions recommended within the environmental checklist are: (a) Will the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? (b) Will the project conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? 3.14 Scoping Plan Measures In response to AB 32, California Air Resource Board (ARB) developed the Climate Change Scoping Plan. In that plan, ARB developed GHG emission reduction strategies which expanded energy efficiency programs, increased utility renewable energy requirements, developed clean car standards and LCFS, developed the cap-and-trade program, and identified adopted discretionary measures to assist the state in meeting the 2020 limits established by AB 32. In May 2014, the ARB adopted the first update to the original Scoping Plan which was necessary to establish long-term GHG policies to make deep GHG emission reductions to achieve an 80% reduction below 1990 levels by The update includes key recommendations for six key economic sectors (energy, transportation, agriculture, water, waste management, and natural and working lands) as well as short-lived climate pollutants, green buildings, and the Cap-and-Trade Program. The findings largely affect regulatory measures that will indirectly reduce GHG emissions and generate a need to update local policies. The 2014 Scoping Plan indicates that 2020 emissions would equal approximately 509 Million Metric Tons (MMT) CO 2e under 2020 Business as Usual (BAU) conditions. BAU is the level of emissions that would have occurred in the absence of regulatory emissions reductions, design considerations, or updated standards (e.g Title 24 standards). The 2014 Scoping Plan also determined that in order to meet the 2020 GHG reduction target per Executive Order S-3-05, total GHG emissions state-wide would need to be reduced to 431 MMT CO 2e by 2020, representing a reduction of approximately 16% below 2020 BAU emission levels. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

20 3.15 City of Oceanside Thresholds of Significance The City of Oceanside (City), the County of San Diego, and the San Diego Air Pollution Control District (SDAPCD) have not adopted emission-based thresholds for GHG emissions under the California Environmental Quality Act (CEQA). Accordingly, for purposes of this analysis, it is necessary to establish thresholds against which the project s GHG emissions may be evaluated. It should be noted that the thresholds established herein are intended to be used only for the Melrose + Oceanside project in the absence of formally adopted local thresholds. Two different thresholds have been identified for the purpose of evaluating the significance of the project s GHG emissions. The first method, referred to herein as the Business as Usual approach, relies on the screening thresholds recommended by California Air Pollution Control Officers Association (CAPCOA), and if the screening threshold is exceeded, then additional analysis is required to evaluate whether the project s emissions would be consistent with the ARB s recommended reduction target to reduce 2020 business as usual (BAU) emissions by 16% in order to achieve the 2020 reduction target specified by Executive Order S The second approach, referred to herein as the Efficiency Metric, relies on an efficiency ratio comparing localized GHG emissions to service population (i.e., the total number of residents and jobs) in order to evaluate the project s consistency with the GHG reduction requirements set forth in Executive Order (EO) S-3-05, EO B-30-15, and AB 32. This methodology is intended to demonstrate a link between the Statewide Goal of AB 32, the City s BAU methodology, and a project-level GHG analysis in accordance with the Newhall Ranch case. As noted by CAPCOA, CEQA guidance that allows multiple methodologies to demonstrate GHG significance will facilitate the determination of significance for a broad range of projects/plans that would otherwise be difficult to address with a single non-compound methodology. Even though there could be multiple ways that a project can determine GHG significance using a decision-tree approach, only one methodology need be included in any single CEQA document prepared by the applicant. The presence of multiple methodologies to determine significance is designed to promote flexibility rather than create additional analysis overhead. (California Air Pollution Control Officers Association, 2008). Business as Usual Thresholds of Significance The City of Oceanside suggests using screening thresholds published by CAPCOA for determining the need for additional analyses and mitigation for GHG-related impacts under CEQA which suggest projects producing less than 900 metric tons would be considered less than significant (California Air Pollution Control Officers Association, 2008). Projects Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

21 producing more than 900 metric tons per year of GHGs are required to produce an inventory of project gases and demonstrate reasonable mitigation measures necessary to reduce GHG s by 16% from 2020 BAU conditions, pursuant to ARB s 2014 Scoping Plan (discussed above). It should be noted that mitigation to achieve the 16% requirement cannot include a reduction in the project size or scale. Mitigation identified toward this 16% target cannot include the effects of the Pavley I clean car standard or the 20% Renewable Portfolio Standard because these programs are already included in the calculations that support the 16% mitigation requirement. Other statewide measures, however, can be included without risk of double counting. Renewable Portfolio Standards beyond 20% can be included toward the minimum 16% mitigation requirement as well as the Low Carbon Fuel Standard which can also be included as a part of the 16% mitigation requirement. Currently there has been no legislative action to adopt the GHG reduction target recommended in Executive Order S-3-05 or the interim target recommended in Executive Order B However, in an abundance of caution, the City recommends that a project s emissions for 2030 and 2050 be predicted and demonstrate the progress a project would make towards achieving the GHG reduction goals for these years. Efficiency Metric (Per Service Population) The intent of AB 32 is to accommodate a population and economic growth in California, but in a way that achieves a lower rate of GHG emissions statewide. One commonly-accepted approach for addressing the potential significance of a project s impacts due to GHG emissions is to demonstrate a reduced rate of emissions per service population (i.e., GHG emissions per capita based on the number of City residents and employees) as compared to the existing rate of emissions per service population for the local area. Another very commonly-accepted approach is the Performance-Based Percent Reduction Target threshold approach which would require a project to meet a percent reduction target based on the average reductions needed from the BAU emissions from all GHG sources. Using the 2020 target, this approach would require all discretionary projects to achieve a certain percent reduction from projected business-as-usual emissions in order to be considered less than significant. A more restrictive target could be established in the future to address 2030 and 2050 targets using the same methodology. A number of air districts in the State of California have recommended or adopted efficiency metric or service population thresholds as a method for analyzing cumulative GHG emissions and significance of impacts under CEQA. A project s service population refers to a project s residents plus employees that would be generated by the proposed project s Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

22 development. This efficiency metric is expressed as MT CO 2e per service population per year (MT CO 2e/year/service population). Service population is a term used to express the total GHG emissions associated with a project or study area, divided by the total population and employment forecasted for the local study area. The service population for projects that accommodate only employment and no residences would be the total number of employees accommodated at build-out. Projects that accommodate population (i.e. housing projects) would estimate the number of residents accommodated at full occupancy. Mixed-use projects, such as the proposed Melrose + Oceanside project, would estimate both the number of residents and the employees. Net annual emissions would consider plans and projects that reduce emissions through selection of a project site and adding land use diversity that reduces cumulative area-wide vehicle miles travelled (VMT) with and without the project, GHG-efficient project design features, and other on-site strategies, as well as taking actions off-site and the impact on the project from the state s implementation of GHG-reducing programs and regulations. Net emissions represent the total after cumulative emissions are calculated less these GHG-reducing programs, features and measures. Through the per-capita and performance-based percent reduction approaches, individual projects can demonstrate that project-specific emissions would not interfere with California s ability to accommodate expected population growth and achieve economic development objectives while also abiding by AB 32 s emissions target and supporting efforts to reduce emissions beyond The service population approach allows lead agencies to assess whether any given project or plan would interfere with the State s ability to accommodate population and employment growth in a way that is consistent with the AB 32 Statewide Target, while also accounting for existing sources of GHG emissions and their potential for cumulatively inhibiting the ability of the State and local agencies to achieve the objectives of AB 32. CARB approved the Scoping Plan in 2008, with the most recent update occurring in May The Scoping Plan provides guidance for local communities to meet AB 32 and EO S targets. The Scoping Plan adopted a quantified cap on GHG emission representing 1990 emission levels, instituted a schedule to meet the emission cap, and developed tracking, reporting, and enforcement tools to assist the State in meeting the required GHG emission reductions. The Scoping Plan recommends that local governments target 2020 emissions at 15% below 2 levels to account for emissions growth since 1990, as a proxy for 1990 emissions, since few localities have conducted a detailed GHG emissions inventory to estimate 1990 emission levels. Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report

23 In 2011, the San Diego Foundation prepared a document entitled, City of Oceanside 2 Greenhouse Gas Emissions Inventory (herein, 2 GHG Inventory ) (San Diego Foundation, 2011). The 2 GHG Inventory concluded that total emissions in the City of Oceanside in 2 comprised approximately 959,772 metric tons (MT) of carbon dioxide equivalent (CO 2e) (San Diego Foundation, 2011, p. 33). Accordingly, and based on the Scoping Plan s recommendation, 1990 GHG emissions in the City of Oceanside would have totaled approximately 815,806 MT CO 2e/year. Thus, the total 2020 GHG emission target for the City of Oceanside pursuant to EO S-3-05 would be 815,806 MT CO 2e/year; the 2030 City-wide target pursuant to B would be 489,484 MT CO 2e/year; and the 2050 Citywide target pursuant to AB 32 would be 163,161 MT CO 2e/year. According to the San Diego Association of Governments (SANDAG), the City of Oceanside is estimated to have a total 2020 population of 195,592 with approximately 48,464 jobs. Thus, the 2020 service population for the City of Oceanside would be 244,056 (SANDAG, 2016). In order to achieve the City-wide emission level of 815,806 MT CO2e, the required efficiency target city-wide in 2020 would be 3.34 MT CO 2e per service population. (SANDAG, 2016) EO B requires a reduction of 40% below targeted 1990 levels by 2030; thus, the 2030 emission target for the City would be approximately 489,484 MT CO 2e. Also according to SANDAG, the City of Oceanside is estimated to have a total 2030 population of 209,613 persons, with approximately 54,597 jobs (SANDAG, 2016). Thus, the 2030 service population for the City of Oceanside would be approximately 264,210. Given the 2030 target of 489,484 MT CO 2e per EO B-30-15, the required efficiency target City-wide in 2030 would be 1.85 MT CO 2e/year/service population. AB 32 requires the State of California to reduce GHG emissions to 80% below targeted 1990 levels by Thus, the 2050 target for the City of Oceanside would be approximately 163,161 MT CO 2e. According to SANDAG, the City s 2050 population is estimated to be 217,108 with a total of 67,550 jobs; thus, the 2050 service population would be 284,658 (SANDAG, 2016). Accordingly, the required 2050 efficiency target to reduce emissions by 80% as compared to 1990 emission levels would be 0.57 MT CO 2e/year/per service population. It is important to note that the City of Oceanside and State of California have not adopted thresholds to evaluate project-specific GHG impacts for 2030 and 2050 conditions. This is due, in part, to the fact that it is not possible to accurately project the level of GHG reductions that will be achieved by 2030 or by 2050 pursuant to federal, state, regional, and local regulations that may be adopted in the future to achieve the GHG reduction targets of AB 32. Thus, the analysis herein discloses the estimated level of GHG emissions in 2030 Ldn Consulting, Inc. 3/31/ Melrose Oceanside GHG Report