Chapter 4.7 Greenhouse Gas Emissions

Transcription

1 4.7.1 Introduction This section describes the potential environmental effects of the proposed Project on global climate change, resulting from greenhouse gas emissions. Included is a description of potential greenhouse gas emissions for the construction and operation of the expansion of the Ridgecrest Recycling and Sanitary Landfill (Ridgecrest RSLF) (Project). The greenhouse gas emissions section describes the existing conditions of the Project site, the regulatory setting, and discusses the possible impacts from project implementation, as well as proposed project design features to reduce these impacts. The analysis presented in this chapter is based on site specific information, and the Kern County Waste Management Department Greenhouse Gas Emission Action Plan prepared by the Kern County Waste Management Department in December 2008 (Appendix H). The Emission Action Plan includes the Kern County Waste Management Department Greenhouse Gas Inventory for 1990, 2007, and 2020 prepared by SCS Engineers, updated in 2010 (Appendix H). Based upon the review of the Kern County Waste Management Department Greenhouse Gas Emission Action Plan and the analysis of information presented in this section, no significant impacts to global climate change are expected as a result of the proposed Project. The proposed Project would be compliant with the Kern County Waste Management Department Greenhouse Gas Emission Action Plan and Assembly Bill 32 (AB32) to reduce greenhouse gas emissions to 1990 levels by No specific concerns have been raised in response to the Notice of Preparation with regard to the operations at the site affecting global climate change. The environmental analysis contained herein indicates adverse impacts upon the environment are not expected in regards to global climate change at the site, with the incorporation of project design features Environmental Setting The issue of greenhouse gas emissions as related to global climate change is currently one of the most important and widely debated scientific, economic, and political issues in the world. Climate change is described as a shift in average weather that is measured by changes in temperature, wind patterns, precipitation, and storms; including the potential for more extreme and/or frequent severe weather conditions. While the effects of global climate change may occur on a global, regional, or local basis, the impacts are believed to result from a combination of world-wide increases of anthropogenic (human caused) emissions of greenhouse gases and natural cycles in biogenic (naturally occurring) greenhouse gas emissions. Research suggests that the day to day lifestyle of humans has resulted in an increase in greenhouse gas concentrations. Since pre-industrial times, global atmospheric Draft Environmental Impact Report 4.7-1

2 concentrations of CO 2 have risen about 30 percent, and methane concentrations have doubled (USEPA, 2006). Scientists are concerned about the significant increase in the concentration of CO 2 and other greenhouse gases in the atmosphere. A warming trend of about 0.7 F F occurred during the 20th century, and a number of scientific analyses indicate that rising levels of greenhouse gases in the atmosphere are contributing to global climate change. However, questions still remain as to how much, how long, and to what extent this change in global climate will occur. It is expected that as the already occurring climate change intensifies there will be more substantial environmental effects, which may include the following: Rise in sea level; Reduced surface flow of water; Higher air temperatures; Increased formation of ground level ozone and other air pollutants; Shift in climate zones; Increase in fire hazards; Decrease in precipitation; and Increased risk of heat related illness and death to temperature sensitive plant and animal species. State law defines greenhouse gases as 1) carbon dioxide (CO 2 ); 2) methane (CH 4 ); 3) nitrous oxide (N 2 O); 4) hydrofluorocarbons (HFCs); 5) perfluorocarbons (PFCs); 6) sulfur hexafluoride (SF 6 ); and 7) nitrogen trifluoride. One to two percent of the Earth s atmosphere naturally includes: CO 2, methane, and N 2 O which absorb enough solar radiation to produce a comfortable, temperate climate on the Earth s surface. Without these gases to absorb and reflect solar radiation, the average temperature on Earth would be approximately -2 degrees Fahrenheit, rather than the current 57 degrees Fahrenheit (International Panel on Climate Change [IPCC], 2001). This process is known as the greenhouse effect, and is the Earth s mechanism to balance global temperature. The emission of greenhouse gases into the atmosphere is not in itself an adverse environmental impact. It is the increased concentration of these greenhouse gases in the atmosphere that enhances the greenhouse effect thereby resulting in global climate change and its associated impacts on the environment. Certain greenhouse gases have a greater potential to effect global warming. This potential is called the global warming potential (GWP). The GWP is used to describe the ability of different greenhouse gases to absorb heat. For example, methane has a GWP of 21. This means that one metric ton of methane has the equivalent effect on global climate change as approximately 21 metric tons of CO 2. This can also be described as 21 metric tons of CO 2 equivalents (MTCO 2 E) (IPCC, 2007). Regional Setting CO 2 emissions in California are less than the national average, both in per capita emissions and in emissions per gross state product. Transportation is the largest source of greenhouse gas emissions in California, accounting for approximately 41 Draft Environmental Impact Report 4.7-2

3 percent of total emissions. Electricity generation accounts for approximately 22 percent of greenhouse gas emissions in California, and the industrial sector, in which landfills are included, accounts for approximately 20.5 percent (California Energy Commission, 2006). The California Air Resources Board (CARB) estimates, in their most recent inventory completed in 2004, that landfills account for 1.2 percent of California s greenhouse gas emissions. Project Setting The Kern County Waste Management Department Greenhouse Gas Inventory for 1990, 2007, and 2020, performed by SCS Engineers, as updated in 2010 (Appendix H), was used to establish the baseline (1990) and current (2007) emissions pursuant to AB 32. The calculated emissions levels were used to develop the Kern County Waste Management Department Greenhouse Gas Emissions Action Plan (Appendix H). The operation of the Ridgecrest RSLF results in the generation of CO 2, methane, and N 2 O. Greenhouse gas emissions from the landfill operation are the product of the anaerobic decomposition of waste occurring within the landfill, importation of utilities, and exhaust emissions from light duty vehicles, haul vehicles, and off-road equipment. Most inventory methodologies do not include CO 2 as a greenhouse gas emission from landfill anaerobic decomposition. These methodologies recognize CO 2 as a biogenic emission (naturally occurring) from waste decomposition. As such, it is part of the natural carbon cycle and would have occurred had the landfill been present or not. The 2007 inventory used these methodologies in its calculations, and therefore the biogenic CO 2 emissions are not discussed in detail (see Table 4.7-1). Table Ridgecrest Recycling and Sanitary Landfill Contribution to Global Greenhouse Gas Emissions 1990 & 2007 Year Methane Emissions Electricity Import Haul Vehicles Off-road Equipment Light Duty Vehicles Reductions from Waste Diversion Total contribution to Global greenhouse gases 1990* , , *AB32 Goal 1990 Emissions In 1990 the Ridgecrest RSLF did not have a gas control and collection system (GCCS). Therefore, Land Gas Emissions Model (LandGEM) was used to model the landfill gas generation rates for the landfill. As a result it is estimated that the Ridgecrest RSLF generated approximately MTCO 2 E of methane (see Table 4.7-1). Draft Environmental Impact Report 4.7-3

4 The Ridgecrest RSLF did not have a gatehouse or scales and, therefore, no imported natural gas or electricity for operations. Haul vehicles, off-road equipment, and light duty vehicles contributed 74.4, 257.8, and 22.9 MTCO 2 E respectively. There were no diversion activities occurring on site. Therefore the Ridgecrest RSLF did not receive any credit for emission reductions resulting from waste diversion (see Table 4.7-2), and emitted a total of MTCO 2 E in the year Emissions The 2007 greenhouse gas inventory also used the LandGEM model to develop the landfill gas generation rates. The Ridgecrest RSLF had the potential to emit 2,468.6 MTCO 2 E in 2007, a percent increase from the 1990 level. Additionally, a gatehouse, scale and landfill gas collection control system was installed, which used 21,912 kwh of electricity. The importation of electricity to the Ridgecrest RSLF resulted in an increase of emissions from 1990 by 6.4 MTCO 2 E. Since 1990, the amount of waste accepted at the Ridgecrest RSLF has increased, which increased the emissions from off-road equipment and light duty vehicles to and 35.4 MTCO 2 E, respectively. Emissions from haul vehicles were reduced to 43.4 MTCO 2 E due to the consolidation of waste into larger haul vehicles (see Table 4.7-1). By 2007, the Ridgecrest RSLF made several improvements which significantly decreased and even offset the greenhouse gas emissions. SCS Engineers prepared a Contractor s Report for the California Integrated Waste Management Board (CIWMB) and presented it at the CIWMB April 22, 2008 Meeting (SCS Engineers, 2008b). This report evaluated technologies and management practices concerning greenhouse gas emission reductions from landfills. Many of the best management practices (BMPs) listed in the report have been implemented at the Ridgecrest RSLF. A brief description of these measures is listed on Table below. [This Space Intentionally Left Blank] Draft Environmental Impact Report 4.7-4

5 BMP* Relative Greenhouse Gas Emission Reduction Potential Table Best Management Practices Identified by SCS Engineers Currently in use at Ridgecrest RSLF Description Early Installation of landfill gas systems Maximize borehole and well diameters High Low The landfill gas system at Ridgecrest RSLF was installed and operating in October of 2001 due to groundwater contamination by volatile organic compounds The Ridgecrest RSLF landfill gas system has 24 well boreholes with 6 PVC pipe in-screened sections and 4 PVC non-screened sections. Redundant flare station equipment Maximum capacity of gas control equipment Designing for closure and post closure Modify, limit or remove intermediate cover systems Impacts from landfill operations Low Low Low Low Low Spare equipment is kept in shop inventory and is readily available from local vendors resulting in less down time. The Ridgecrest RSLF carbon system is permitted to run at 150 scfm; nearly double the current operating level. Closure design operations take landfill gas into consideration by working in limited sections of well fields at any given time, minimizing the amount of wells that are taken off-line for construction. The Ridgecrest RSLF uses tarps as ADC creating a more uniform gas flow through the landfill. Additionally, previous intermediate cover material is skimmed with the advancement of a new lift. The impacts of daily operations on the landfill gas systems are reduced by minimizing the active area. In doing so, wells are rarely off-line for extended periods of time. BMP for landfill gas system piping Medium/Low System piping is designed with sumps and condensate knock-outs so landfill gas flow is not limited. Landfill gas master planning Medium/Low Implementation of a landfill gas master plan for long term gas management planning. Mixed Horizontal and vertical well systems Medium According to approved design plans, horizontal collectors will be installed in future modules. Draft Environmental Impact Report 4.7-5

6 BMP* Relative Greenhouse Gas Emission Reduction Potential Description Maximize capacity of gas mover equipment Medium The blower system is designed with a 150 scfm maximum rating so it does not limit gas collection. Horizontal Collectors or Surface Collectors Medium Horizontal collectors collect landfill gas before vertical wells are installed. According to approved design plans, horizontal collectors will be installed as modules are filled. Tighter spacing of landfill gas wells Medium 9 vertical wells are closely spaced across the Ridgecrest RSLF to increase the overlap of the ROI. Enhance seals on landfill gas wells and boreholes High/Medium 2 low permeability seals and 1 well bore seal per vertical well Improves seal and allows more vacuum to be applied to landfill gas wells. All but two landfill gas vertical wells at the Ridgecrest RSLF have 2 seals and a well bore seal. Promote deeper landfills High/Medium Proposed vertical expansion results in a deeper landfill without requiring a larger footprint. Enhanced operations and maintenance Unknown Training of Operators, maintenance, and monitoring is increased. Operators and maintenance personnel receive landfill gas system engineering design training. Monitoring is performed at least every 4 weeks, or more frequently as needed. *Other possible BMPs identified by SCS Engineers are not feasible at the Ridgecrest RSLF due to the arid project location and quantities of landfill gas and/or leachate generation. [This Space Intentionally Left Blank] Draft Environmental Impact Report 4.7-6

7 Due to groundwater contamination by volatile organic compounds, a landfill gas control system was installed in October, This initial system consisted of a network of landfill gas extraction wells manifold to an enclosed flare. Methane concentrations of 15% at 75 SCFM, generated by decomposing refuse within the landfill were significantly lower than the 150 SCFM the system was designed to process. Continued operation of the flare system became increasingly problematic due to the low quantity and quality of the landfill gas, prompting re-evaluation and replacement of the system with an alternative treatment methodology in The enclosed flare system was removed. Using the existing gas extraction system, equipped with a new carbon absorption system, was selected as the most feasible alternative treatment method. This decision was based on a variety of factors, including the ability to control VOC emissions, constructability, and long-term operating costs. The new carbon absorption treatment system was constructed and went into operation in October The current carbon system consists of a positive displacement blower manifold to four 1,000-pound carbon canisters plumbed in series. Multiple canisters allow spent carbon to be replaced before the last unit in the series becomes VOC saturated. The landfill gas control system has been operating under Eastern Kern County Air Pollution Control District (EKAPCD), formerly the Kern County Air Pollution Control District, Permit No B. The Kern County Waste Management Department performs monthly monitoring and maintenance on the system. In addition, the Department evaluates the operation of the landfill gas system and makes necessary adjustments as needed. In addition to the installation of a landfill gas collection and control system, the Ridgecrest RSLF now operates a highly successful recycling program. This program recycles several types of materials as described in Chapter 3, Section of this DEIR. The Kern County Waste Management Department greenhouse gas inventory uses the USEPA Waste Reduction Model (WARM) 1 to estimate the amount of greenhouse gas emissions generated and/or offset by the landfills recycling activities. The WARM is a lifecycle analysis system which calculates overall emissions generated from receiving and processing post-consumer recyclable products for reuse in place of native materials being used for new products. In some cases, these reductions may be substantial and result in a large decrease of global greenhouse gas emissions. If the total emissions offset from the acquisition and processing of post-consumer products in 1 It should be noted that while the WARM is an excellent tool for policy making decisions, there are a number of assumptions in the calculations used in the model itself that the Department feels necessary to address. The WARM is configured to calculate emissions using numbers that have been extracted using national averages. USEPA researchers developed a life-cycle inventory for 34 waste types to determine how each individual waste stream impacted greenhouse gas emissions. The USEPA focused on those aspects of the life cycle that have the potential to emit greenhouse gas as materials change from their raw states to products and then to waste. While these numbers are a fair estimate, it should be noted that the calculations are nonetheless a conservative approach to calculating greenhouse gas emissions, and emissions are likely much lower than WARM indicates (USEPA, 2006) (Appendix H). Draft Environmental Impact Report 4.7-7

8 place of native materials are greater than the emissions from the project, the proposed Project may result in a net decrease of global greenhouse gas emissions. The total greenhouse gas emissions from the Ridgecrest RSLF, not including the recycling offsets, were 2,827.2 MTCO 2 E in The Kern County Waste Management Department Greenhouse Gas Inventory estimates that the County s diversion/recycling programs would result in a decrease of global greenhouse gas emissions by 3,205.7 MTCO 2 E. Therefore, the operations of the landfill in 2007 resulted in a net decrease of global greenhouse gases by MTCO 2 E (see Table 4.7-1) Regulatory Setting Federal The Climate Change Action Plan was developed to address the reduction of greenhouse gases in the United States. The plan consisted of more than 50 voluntary programs. In 1988, the United Nations established the Intergovernmental Panel on Climate Change (IPCC) to evaluate the impacts of global warming and to develop strategies that nations could implement to curtail global climate change. In 1992, the United Nations Framework Convention on Climate Change established an agreement that provided a goal for controlling greenhouse gas emissions, including methane. On April 2, 2007, in Massachusetts v. EPA, 549 U.S. 497 (2007), the Supreme Court found that greenhouse gases are air pollutants covered by the Clean Air Act. The Court held that the Administrator must determine whether or not emissions of greenhouse gases from new motor vehicles cause or contribute to air pollution which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In making these decisions, the Administrator is required to follow the language of Section 202(a) of the Clean Air Act. The Supreme Court decision resulted from a petition for rulemaking under section 202(a) filed by more than a dozen environmental, renewable energy, and other organizations. On April 17, 2009, the Administrator signed proposed endangerment and cause or contribute findings for greenhouse gases under section 202(a) of the Clean Air Act. EPA held a 60-day public comment period, which ended June 23, 2009, and received over 380,000 public comments. These included both written comments as well as testimony at two public hearings in Arlington, Virginia and Seattle, Washington. EPA carefully reviewed, considered, and incorporated public comments. On December 7, 2009, the Administrator signed two distinct findings regarding greenhouse gases under section 202(a) of the Clean Air Act (USEPA, 2009): Endangerment Finding: The Administrator finds that the current and projected concentrations of the six key well-mixed greenhouse gases--carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons Draft Environmental Impact Report 4.7-8

9 (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)--in the atmosphere threaten the public health and welfare of current and future generations. Cause or Contribute Finding: The Administrator finds that the combined emissions of these well-mixed greenhouse gases from new motor vehicles and new motor vehicle engines contribute to the greenhouse gas pollution which threatens public health and welfare. On September 22, 2009, the U.S. Environmental Protection Agency (USEPA) issued a final rule for mandatory reporting of greenhouse gases from large greenhouse gas sources in the United States. This rule has been published as Title 40 of the Code of Federal Regulations (CFR), Part 98: Mandatory Green House Gas Reporting (40 CFR 98). Landfills are covered by Subpart HH of the rule. Affected sources include landfills that accepted refuse after January 1, 1980, which trigger the threshold for mandatory reporting if they emit greenhouse gas in amounts greater than 25,000 metric tons of carbon dioxide equivalent per year. Qualifying landfills must begin collecting data beginning January 1, The first emissions report is due on March 31, 2011, for emissions during State Recent state regulations specifically address greenhouse gas emissions and global climate change. This section provides a background on the legislative treatment of greenhouse gas and climate change in California. At this time, however, there are no specific regulations setting ambient air quality emissions standards for greenhouse gases. Senate Bill 1771 Senate Bill (SB) 1771, chaptered in September of 2000, required the Secretary of the Resources Agency to establish a nonprofit benefit corporation, to be known as the California Climate Action Registry (CCAR). The CCAR is responsible for administering a voluntary greenhouse gas emissions registry to record and register voluntary greenhouse gas reductions that have been achieved since 1990 in the state. SB 1771 required the Energy Commission to qualify third-party organizations to provide assistance for purposes of monitoring and reducing greenhouse gas emissions. In addition, the Energy Commission was required to develop metrics for use by the CCAR and to update the State s inventory of greenhouse gas emissions by January 1, The bill also required the adoption of standards to verify emissions reductions and required the establishment of greenhouse gas emissions reduction goals along with efficiency improvement plans. Executive Order S In 2005, Governor Arnold Schwarzenegger signed Executive Order S-03-05, which proclaimed that California is vulnerable to the impacts of climate change. It declared that increased temperatures could reduce the snow pack of the Sierra Nevada, further Draft Environmental Impact Report 4.7-9

10 exacerbate California s air quality problems, and potentially cause a rise in sea levels. To combat those concerns, Executive Order S established total greenhouse gas emission targets. Specifically, emissions are to be reduced to the 2000 levels by 2010, the 1990 level by 2020, and to 80 percent below the 1990 level by Executive Order S directed the Secretary of the California Environmental Protection Agency (CalEPA) to coordinate a multi-agency effort to reduce greenhouse gas emissions to the above target levels and to submit biannual reports to the governor and state legislature. The reports are to describe: (1) progress made toward reaching the emission targets; (2) impacts of global warming on California s resources; and (3) mitigation and adaptation plans to combat these impacts. To comply with Executive Order S-03-05, the Secretary of CalEPA created a Climate Action Team (CAT) made up of members from various state agencies and commissions. The CAT released its first report in March The report proposed to achieve the targets by building on voluntary actions of California businesses, local government and community actions, and state incentive and regulatory programs (CalEPA, 2006). Assembly Bill 32 In September 2006, Governor Schwarzenegger signed AB 32, the California Global Warming Solutions Act of AB 32 requires statewide greenhouse gas emissions to be reduced to 1990 levels by the year 2020 (representing a 25 percent reduction). This reduction will be accomplished through an enforceable statewide cap on greenhouse gas emissions that will be phased in beginning in To effectively implement the cap, AB 32 directs the CARB to develop and implement regulations to reduce statewide greenhouse gas emissions from stationary sources. AB 32 required the CARB to: adopt a quantified cap on greenhouse gas emissions representing 1990 emission levels and disclose how it arrived at the cap; institute a schedule to meet the emissions cap; and develop tracking, reporting, and enforcement mechanisms to ensure that the state achieves reductions in greenhouse gas emissions necessary to meet the cap. AB 32 also included guidance to institute emissions reductions in an economically efficient manner, and conditions to ensure that businesses and consumers are not unfairly affected by the reductions. AB 32 established the following schedule for the CARB to complete each of these responsibilities, as follows: By July 1, 2007, adopt a list of discrete Early Action greenhouse gas emissions reduction measures; By January 1, 2008, adopt regulations to require the reporting and verification of the greenhouse gases and to monitor and enforce compliance with AB 32 programs; Draft Environmental Impact Report

11 By January 1, 2009, prepare and approve scoping plan for achieving the maximum technology feasible and cost-effective reductions of greenhouse gases from sources or category of sources of greenhouse gas; By January 1, 2010, adopt regulations to implement measures identified as part of the Early Action process; By January 1, 2011, adopt greenhouse gas emission limits and emissionreduction measures by regulation, and establish a system of market-based declining annual emission limits for greenhouse gas sources or categories of sources; and By January 1, 2012, implement and enforce greenhouse gas emission limits and emission reduction measures. The schedule presents an orderly progression of actions, beginning with an initial listing of greenhouse gas emission-reduction measures by July 1, 2007, and ending with an operative (i.e., enforcement) date for greenhouse gas emission limits and emissionreduction measures by January 1, In accordance with AB 32 to achieve the 25 percent reduction goal to reach 1990 greenhouse gas emission levels by the year 2020, CARB has established a schedule which includes adopting regulations to implement measures identified as part of the Early Action process by Nine of the 44 Early Action items are Discrete Early Action items; regulations to reduce specific greenhouse gas emissions adopted by CARB, and are enforceable by January 1, One of these Discrete Early Action items, Early Action Measure ID No. 17, Improved landfill gas capture, pertains specifically to the waste sector (CARB, 2007). This measure requires improved landfill methane capture by setting statewide standards for the installation and performance of active gas collection/control systems at uncontrolled municipal solid waste (MSW) landfills. In 2010, the CARB issued the AB32 Landfill Methane Reduction rule, which sets statewide standards for the applicability, installation, performance, and monitoring of active gas collection/control systems at municipal solid waste (MSW) landfills. This rule was published as Title 17, CCR Article 4, Subarticle 6, sections to Landfills that generate methane over a specific threshold must install landfill gas control equipment and/or perform specified monitoring and reporting. Executive Order S Executive Order S-01-07, the Low Carbon Fuel Standard (LCFS), issued on January 18, 2007, calls for a reduction of at least 10 percent in the carbon intensity of California s transportation fuels by The Order instructed the CalEPA to coordinate activities among the University of California, the CEC and other state agencies to develop and propose a draft compliance schedule to meet the 2020 target. Furthermore, it directed the CARB to consider initiating regulatory proceedings to Draft Environmental Impact Report

12 establish and implement the LCFS. In response, the CARB identified the LCFS as an early action item with a regulation to be adopted and implemented by Senate Bill 375 The recent passage of SB 375 (Steinberg, 2008) creates a process whereby local governments and other stakeholders work together within their region to achieve reduction of greenhouse gas emissions through integrated development patterns, improved transportation planning, and other transportation measures and policies. Senate Bill 97 Governor Schwarzenegger signed SB 97, a CEQA and greenhouse gas emission bill, into law on August 24, SB 97 required the Governor s Office of Planning and Research (OPR) to prepare CEQA guidelines for the mitigation of greenhouse gas emissions, including, but not limited to, effects associated with transportation or energy consumption. OPR was required to prepare these guidelines and transmit them to the Resources Agency. The Resources Agency adopted these guidelines on December 31, 2009 and they became effective on March 18, OPR and the Resources Agency are required to periodically review the guidelines to incorporate new information or criteria adopted by CARB pursuant to AB 32, scheduled for The CEQA Guideline Amendments for Greenhouse Gas Emissions includes requirements for determining the significance of impacts from greenhouse gas emissions (section ), as stated below (CARB, 2008): (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 on available information, 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 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; or (2) Rely on a qualitative analysis or performance based standards. (b) A lead agency should consider the following 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; Draft Environmental Impact Report

13 (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 regulations or requirements must be adopted by the relevant public agency through a public review process and must include specific requirements that 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. The proposed section also provides that a lead agency has the discretion to determine whether to undertake a quantitative or qualitative analysis, or otherwise rely on performance based standards. Finally, the lead agency may consider the following factors when assessing the significance of greenhouse gas emissions: (1) the extent to which the project increases or reduces emission levels, when compared to the existing setting; (2) the extent to which the emissions resulting from the project exceed a threshold of significance that the lead agency determines applies to the project; and, (3) the extent to which the project complies with adopted regulations or requirements adopted to implement a statewide, regional or local plan for the reduction or mitigation of greenhouse gas emissions. Other sections address mitigation measures relating to greenhouse gas emissions; the consideration of greenhouse gas emissions in the cumulative impacts analysis; the consistency of proposed projects with greenhouse gas reduction plans; and, the tiering and streamlining of environmental review through the analysis and mitigation of greenhouse gas emissions at a programmatic level Local Kern County Waste Management Department Greenhouse Gas Emission Action Plan The Kern County Waste Management Department has, in consultation with the Kern County Planning and Community Development Department, developed a plan to: 1) identify and quantify greenhouse gas emissions from solid waste facility operations; and, 2) identify potential measures to further reduce greenhouse gas emissions. This Plan provides an inventory of baseline conditions and estimates project level and system wide impacts for the future. It was developed consistent with similar plans from throughout California (OPR, 2010) Since 1990, the Kern County Waste Management Department has implemented a number of programs, primarily landfill gas collection systems and diversion/recycling programs, which have resulted in decreased levels of greenhouse gas emissions. The 2008 Kern County Waste Management Department Greenhouse Gas Emission Action Plan demonstrates that the Department s system of facilities are already in compliance with the AB 32 greenhouse gas requirements for year 2020, and includes a summary of additional programs and models that could be utilized to further reduce greenhouse gas Draft Environmental Impact Report

14 emission levels and maintain compliance with AB 32 in the future. The 2008 inventory was used to quantify greenhouse gas emissions for the Greenhouse Gas Emissions Action Plan was updated in 2009 to reflect current growth rates at all Department facilities, and again in 2010 to reflect the continuation of operations at the Ridgecrest RSLF (originally to cease accepting waste in 2014). The Kern County Waste Management Department Greenhouse Gas Emissions Action Plan is valid as a programmatic inventory and analysis of greenhouse gas emissions from the County of Kern s publicly owned system of waste management facilities. County owned landfills and other waste-related facilities provide the essential public service of integrated solid waste management to multiple jurisdictions in Kern County; therefore, their greenhouse gas impacts warrant a regional solution. The goal of the Kern County Waste Management Department Greenhouse Gas Emissions Action Plan is balance of the system s carbon footprint in the most cost effective and environmentally effective areas in this regional approach; so that areas where only minor reduction can be made are balanced against those area where major reductions can be accomplished to provide the greatest overall reduction Impacts and Mitigation Measures Methodology The potential impacts associated with the proposed Project are evaluated on a qualitative and quantitative basis through a comparison of the anticipated Project effects on greenhouse gas emissions. The evaluation of Project impacts is based on: the significance criteria adopted by the State of California in AB 32 to reduce greenhouse gas emissions to the 1990 levels by the year 2020, which Kern County has determined to be appropriate criteria for this Draft EIR, and: thresholds of significance adopted by air pollution control agencies in adjacent areas. The greenhouse gas emission sources for the Ridgecrest RSLF are landfill gas, electricity import, haul vehicles, off-road equipment, and light duty vehicles. For a majority of the calculations the California Climate Action Registry (CCAR) General Reporting Protocol was used. The CCAR does not have an overall landfill protocol, only a landfill project protocol; therefore SCS Engineers used the Solid Waste Industry for Climate Solutions (SWICS) methodology when calculating greenhouse gas emissions from landfills (SWICS, 2008). The CEQA Guidelines (California Natural Resources Agency, 2009a) for greenhouse gas emissions specify that a lead agency shall have discretion to select the model or methodology it considers most appropriate provided it supports its decision with substantial evidence. For 1990, greenhouse gas emissions had to be extrapolated from available data. For the 2020 projection, greenhouse gas emissions had to be extrapolated from 2007 data and future waste placement estimates. Draft Environmental Impact Report

15 The 2007 greenhouse gas inventory performed by SCS Engineers (Appendix H), with the 2010 revised emission numbers, was used to establish the baseline (1990), current (2007), and projected future (2020) emissions pursuant to AB 32. The inventory did not address the year 2050 impacts due to the highly speculative nature of calculating the emissions 40 years in advance. The gases included in the inventory are CO 2, methane, and N 2 O. Methane and N 2 O contribute more to global warming per unit of mass than CO 2 ; therefore, the greenhouse gas contributions from methane and N 2 O are converted into metric tons of CO 2 equivalents (MTCO 2 E) using the GWPs published by the Intergovernmental Panel on Climate Change in the Second Assessment Report (SAR). The GWPs have been updated since the SAR, but most inventories use the GWPs from the SAR for consistency, including the statewide CARB inventory. When conducting its inventories, CARB uses default values from the United States Environmental Protection Agency s (USEPA s) Compilation of Air Pollution Emission Factors (AP-42) and New Source Performance Standard (NSPS) rules for estimating landfill gas emissions. SWICS is an informal organization established to provide climate change policy makers with the most accurate information about the solid waste industry and its potential contributions to climate change solutions. SWICS data indicates the default values used by the CARB are very conservative, and out of date for California landfills. SWICS has developed methane oxidation rates based on recent research (Banister, 2009). These SWICS values are based on the cover type at the landfill and the results of surface emissions monitoring (SEM). The SWICS methodology is more specific to the arid regional conditions of the Kern County Waste Management Department s landfills. Therefore, in the Emissions Inventory (Appendix H), where applicable, the SWICS methodology for calculating the site specific, and project level, greenhouse gas emissions from the landfill is used. During the development of the inventory, the Kern County Waste Management Department used the EPA s Waste Reduction Model (WARM) to calculate greenhouse gas emissions reductions resulting from diversion/recycling programs, and to further demonstrate compliance with the goals of AB 32. WARM was developed by the USEPA to aid solid waste planners in tracking greenhouse gas emissions. Both baseline and alternative management practices can be calculated using source reduction, recycling, combustion, composting, and landfilling inputs. WARM uses lifecycle analyses of a wide range of material types that are commonly found in MSW at sanitary landfills and calculates the total emissions in MTCO 2 E. The model recognizes 34 waste types, each of which has a distinct carbon coefficient that determines each waste category s overall impact to landfill emissions (USEPA, 2006). Data from a waste characterization study, specific to the Ridgecrest RSLF, was entered into the model to calculate estimated greenhouse gas emissions. Draft Environmental Impact Report

16 Threshold of Significance The Kern County Environmental Checklist states that a project would have a significant impact on greenhouse gas emissions if it would: a) Generate greenhouse gas emissions, whether directly or indirectly, that may have a significant impact on the environment; or b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. In line with the OPR s June 19, 2008 Technical Advisory titled CEQA AND CLIMATE CHANGE: Addressing Climate Change through CEQA Review and the December 2009 CEQA Guideline amendments, the Kern County Waste Management Department has used the recommended 3-step approach of: 1) Identify and quantify, if possible, the greenhouse gas emissions related to the project; 2) Assess the significance of the impact on climate change; and 3) If the impact is found to be significant, identify alternatives and/or mitigation measures that will reduce the impact below significance. Although it is possible to estimate a project s incremental contribution of greenhouse gas into the atmosphere, it is not possible to determine whether or how a specific project s relatively small incremental contribution might translate into physical effects. Given the complex interaction between various global and regional systems that contribute to the physical expressions of global climate change, current science has yet to establish what amount of greenhouse gas emissions by a specific project would result in any altered conditions. In contrast to the one-size-fits-all quantitative threshold concept, a programmatic approach can better tackle the wide variability of landfill emissions of greenhouse gas by establishing a system-wide landfill carbon footprint (or greenhouse gas emission inventory). The system-wide emission inventory represents a net greenhouse gas emissions profile of all the County landfills. This profile distinguishes between anthropogenic and biogenic sources of carbon dioxide (CO 2 ) and account for the greenhouse gas emission reduction effect of concurrent waste diversion. The systemwide approach represents the baseline greenhouse gas emissions from all landfill system operations and is the sum of the net carbon footprint for each landfill (active and inactive), which may be estimated using a life-cycle analysis, wherever feasible, or other appropriate methodologies. System-wide greenhouse gas emission reduction targets for 2020 have been established based on compliance with AB 32 s 1990 baseline. As long as future landfill expansion projects are found to be consistent with the landfill system-wide greenhouse gas emission reduction plan, or in compliance with the prescribed mitigation measures and performance standards, it can be determined to have an insignificant impact to global climate change. Draft Environmental Impact Report

17 The County of Kern will amend its CEQA Guidelines to include compliance with the Kern County Waste Management Department Greenhouse Gas Emissions Action Plan as an adopted threshold to ensure projects compliance with AB 32. If a proposed Project does not comply with the Kern County Waste Management Department Greenhouse Gas Emission Action Plan, thereby hindering implementation of AB 32, it would be considered significant. Project level thresholds of 10,000 MTCO 2 E have been adopted by other jurisdictions, including both the South Coast and Sacramento metropolitan Air Quality Control Districts. The CARB is currently considering a threshold level of 7,000 MTCO 2 E. The San Joaquin Valley Air Pollution Control District (SJVAPCD) has indicated in the staff report for their adopted December 2009 District Policy that the landfill project threshold (Best Performance Standard) is: Project compliance with the CARB Regulation to Reduce Methane Emissions from Municipal Solid Waste Landfills (SJVAPCD, 2009). The policy further states Projects implementing Best Performance Standards would be determined to have a less than significant individual and cumulative impact on global climate change and would not require project specific quantification of greenhouse gas emissions. The Department has gone beyond this standard and has fully disclosed the potential greenhouse gas impacts of the project. Mitigation at Other Facilities within the Waste Management System CEQA requires lead agencies to mitigated or avoid the significant effects of proposed Projects where it is feasible to do so (PRC, section 21002). While the CEQA Statute does not define mitigation, the State CEQA Guidelines, section 15370(e) defines mitigation to include: Compensating for the impact by replacing or providing substitute resources or environments. As subdivision (e) implies, off-site measures may constitute mitigation under CEQA, and such measures have been upheld as adequate mitigation in CEQA case law (California Natural Resources Agency, 2009b)). Based upon the system-wide approach described above, and the CEQA guidance, it is appropriate to utilize mitigation activities at other waste management facilities to further offset the less than significant greenhouse gas emissions at the Ridgecrest RSLF. Cumulative Impacts Cumulative impacts refer to two or more individual impacts that, when considered together, are considerable or that compound or increase other environmental impacts. The cumulative impact of several projects is the change in the environment that results from the incremental impact of the project when added to other, closely related past, present, or reasonably foreseeable, probable future projects. Although current science Draft Environmental Impact Report

18 cannot address the effect of a specific project on global climate change, the Kern County Waste Management Department has adopted a Greenhouse Gas Emission Action Plan in order to ensure that; on a system wide level, the operations of the Kern County Waste Management Department will not considerably increase or compound the ongoing effects of global climate change. Therefore, the proposed Project s greenhouse gas emissions will be cumulatively considered with other Kern County Waste Management Department projects and the cumulative impact on the Kern County Waste Management Department s compliance with AB 32. If the proposed Project, when considered together with other Department projects, conflict with the Greenhouse Gas Emission Action Plan, thereby hindering the Kern County Waste Management Department s implementation of AB 32, it will be considered cumulatively significant Impacts of the Proposed Project Impact 4.7-1: The proposed Project may hinder attainment of the State s goals of reducing greenhouse gas emissions to 1990 levels by 2020 as stated in AB 32. The Project would result in an increased disposal capacity and life span at the Ridgecrest RSLF. The Project would increase the landfill s total designed air space from 5,992,700 cubic yards to 10,500,000 cubic yards, an increase of 4,507,300 cubic yards. As a result of the increased capacity, the life of the Ridgecrest RSLF would be extended past the current permitted date of 2014, to The Kern County Waste Management Department Greenhouse Gas Inventory for 1990, 2007, and 2020, performed by SCS Engineers, and the inventory updated in 2010 (Appendix H), was used to establish the baseline (1990), current (2007), and projected future (2020) emissions pursuant to AB 32. The inventory did not address emissions beyond 2020 due to the highly speculative nature of calculating the emissions 40+ years in advance. The calculated emissions levels were used to develop the Kern County Waste Management Department Greenhouse Gas Emissions Action Plan (Appendix H) Projected Emissions The 2007 greenhouse inventory used the LandGEM model to develop the landfill gas generation rates for the 2020 projection. The 2007 greenhouse gas inventory was revised for the system-wide 2020 projection utilizing the 2009 waste disposal growth rate for all sites. It is estimated that the Ridgecrest RSLF would emit a total of 2,591.5 MTCO 2 E of methane emissions in It is anticipated that the tons per day of incoming waste would increase, thereby increasing the operational emissions, and emit 70.0, 285.0, and 49.0 MTCO 2 E from haul vehicles, off-road equipment and light duty vehicles, respectively. The Ridgecrest RSLF would be expected to continue to import electricity, resulting in emissions of 6.4 MTCO 2 E (see Table 4.7-3). It is anticipated that as the amount of tonnage disposed increases, so would the amount of material being diverted. Due to the expected increase in future diversion, the total net decrease in global greenhouse gas emissions is estimated to be 3,542.7 MTCO 2 E by Draft Environmental Impact Report

19 2020. When the amount of emissions reduced by utilizing post-consumer products inplace of native materials are included in the calculation, the overall net emissions by the operation of the Ridgecrest RSLF results in a net decrease of MTCO 2 E of greenhouse gas for the year 2020 (See Table 4.7-3). Using the South Coast and Sacramento Metropolitan Air Quality Control Districts and the CARB thresholds as a guide, the worst case scenario of MTCO 2 E total greenhouse gas emissions for this project is well below the established and proposed numerical thresholds of significance. The Project would decrease the total annual levels of greenhouse gases generated from the landfill to below 1990 levels (Table and Figure 4.7-1). Table Ridgecrest Recycling and Sanitary Landfill Contribution to Global Greenhouse Gas Emissions 1990, 2007 & 2020 Year Methane Emissions Electricity Import Haul Vehicles Off-road Equipment Light Duty Vehicles Reductions from Waste Diversion Total contribution to Global greenhouse gases 1990* , , , , *AB32 Goal [This Space Intentionally Left Blank] Draft Environmental Impact Report