4.7 GREENHOUSE GASES/CLIMATE CHANGE Introduction

Transcription

1 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change 4.7 GREENHOUSE GASES/CLIMATE CHANGE Introduction This section describes the existing environmental setting for greenhouse gas (GHG) emissions and global climate change. Potential impacts from implementation of the Proposed Project on both the region and the global climate are analyzed and discussed. Information in this section is based on the following technical reports: Carmelita Air Quality Environmental Assessments, July 2010, Benchmark Resources; Air Quality Technical Information, Air Quality Environmental Impact Analysis Performed for the Proposed Carmelita Mine and Reclamation Project, Sanger, California, Golder Associates Inc., June 2011; and SESPE Consulting 3 rd Party Review Memorandum, September These documents are included in this DEIR as Appendices E-1, E-4, and E-5, respectively. In addition to the Sespe Consulting peer review, the County and its EIR preparer conducted a peer review of these assessments and prepared its own independent analysis and conclusions Environmental Setting Climate change refers to global changes in the average weather of the earth measured by changes in wind patterns, storms, precipitation, and temperature. While climate change is global in scale, California-specific impacts to the climate may result in a loss of snow-pack, increased risk of large wildfires, and a potential reduction in the quality and quantity of certain agricultural products. Gases that trap heat in the atmosphere are GHGs, analogous to the way a greenhouse retains heat. Consequently, these GHG emissions are believed to directly affect the global climate. The accumulation of GHGs in the atmosphere contribute to the regulation of the earth s temperature. Some GHGs can remain in the atmosphere for long periods of time. The following six GHGs are recognized under the Kyoto Protocol and have been found by the International Panel on Climate Change to have an effect on global climate change. Carbon Dioxide (CO 2 ) is an odorless, colorless natural GHG. CO 2 is emitted from natural and anthropogenic sources. Natural sources include the following: decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic sources include burning coal, oil, natural gas, and wood. Methane (CH 4 ) is a flammable GHG. A natural source of CH 4 is from the anaerobic decay of organic matter. Geological deposits, known as natural gas fields, also contain CH 4, which is extracted for fuel. Other sources include landfills, fermentation of manure, and ruminants such as cattle. Nitrous Oxide (N 2 O) is a colorless GHG. N 2 O is produced by microbial processes in soil and water, including those reactions that occur in fertilizer containing nitrogen. In addition to Draft EIR /03/2011

2 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid production, and vehicle emissions) also contribute to its atmospheric load. Hydrofluorocarbons (HFCs) are synthetic chemicals that are used as a substitute for chlorofluorocarbons (CFCs). Of all the GHGs, they are one of three groups with the highest global warming potential. HFCs are human made for applications such as air conditioners and refrigerants. Perfluorocarbons (PFCs) have stable molecular structures and do not break down through the chemical processes in the lower atmosphere; therefore, PFCs have long atmospheric lifetimes, between 10,000 and 50,000 years. The two main sources of PFCs are primary aluminum production and semiconductor manufacturing. Sulfur Hexafluoride (SF 6 ) is an inorganic, odorless, colorless, nontoxic, nonflammable gas. It also has the highest global warming potential of any gas evaluated, 23,900 times that of CO 2. SF 6 is used for insulation in electric power transmission and distribution equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas for leak detection Applicable Policies, Plans and Regulations GHGs in the atmosphere are widely considered to contribute to climate change. Historically, the California Energy Commission (CEC) has maintained an inventory of California s statewide GHG emissions. Table provides a summary of the statewide GHG emissions for 2008 by sector. Table Summary of California s 2008 GHG Emissions Sector CO 2 -equivalent (metric tons) Percentage of Total Transportation 171,986, Electric Power 119,435, Industrial 100,325, Agriculture and Forestry 28,664, Commercial 14,332, Residential 28,664, Other 14,332, Total 477,740, Source: CARB Inventory California, a leader in GHG regulation, has passed several bills and the Governor has signed three executive orders aimed at reducing GHG emissions and related climate change impacts. The most prominent of these is Assembly Bill 32 (AB 32) which was designed to reduce California s statewide GHG emissions to 1990 levels by Assembly Bill 32 states that it is the intent of the Legislature that the California Air Resources Board (CARB) design emission reduction measures to meet the statewide emissions limits for 10/03/ Draft EIR

3 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change GHGs in a manner that minimizes costs and maximizes benefits for California s economy, improves and modernizes California s energy infrastructure and maintains electric system reliability, maximizes additional environmental and economic co benefits for California, and complements the state s efforts to improve air quality. The California Climate Action Registry (CCAR) has developed general and industry specific protocols for assessing and reporting GHG emissions that have been approved for its reporting purposes. CARB has held hearings and has recently finalized regulations for the mandatory reporting of GHG emissions from certain categorical sources and any source that emits 25,000 million tons of carbon dioxide equivalent per year (MTCO 2 e) or more annually. The effective date was December 29, Pursuant to AB 32, CARB first approved its Climate Change Scoping Plan in December The 2008 Scoping Plan established a Business As Usual (BAU) benchmark as a baseline against which project emission reductions could be compared, as well as performance-based mitigation standards and emissions reduction goals (CARB 2008). In currently pending litigation, a California state trial court found that the analysis of the alternatives identified in the 2008 Scoping Plan was not sufficient for informed decision-making and public review under the California Environmental Quality Act (CEQA) (Association of Irritated Residents, et al. v. California Air Resources Board, et al., San Francisco Superior Court, Case Number CPF , May 20, 2011). Due to the adverse court ruling, CARB has revisited the Scoping Plan alternatives and made revisions to the Scoping Plan. A draft document revising the 2008 Scoping Plan was published for public consideration on June 13, On August 24, 2011, CARB adopted the Final Supplement to the Scoping Plan Functionally Equivalent Document (2011 Scoping Plan). Based on the expanded analysis of project alternatives in the revised Scoping Plan, CARB adopted the 2011 Scoping Plan after public review and comment. The 2011 Scoping Plan contains the same objectives and framework for GHG reduction as the 2008 Scoping Plan. There are, however, a few changes that have occurred since the 2008 Scoping Plan was adopted that are taken into account in CARB s new expanded alternatives analysis, including a new BAU benchmark (discussed further below) and revised emissions reduction requirements based on updated emissions projections in light of the economic downturn since Both the 2008 and the 2011 Scoping Plans contain the main strategies that California will use to reduce the GHG emissions. Control measures outlined in the documents that may affect the Proposed Project s emissions include, but are not limited to: Renewables Portfolio Standard. Current electricity generation portfolios are estimated to contain 11 percent renewables and this measure would increase that percentage to 33 percent. This is estimated to reduce GHG emissions from electricity generation by 20 percent over current levels. Low Carbon Fuel Standard. This measure will reduce the carbon intensity of California's transportation fuels by at least ten percent by Goods Movement. This measure is focused on port activities but may extend to the movement of goods from other locations (e.g. aggregate resource areas). Draft EIR /03/2011

4 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation Heavy/Medium Duty Vehicles. This measure focuses on improving aerodynamics, hybridization, and engine efficiency from heavy and medium duty vehicles. Local Government Actions and Regional GHG Targets. This measure, in conjunction with provisions in Senate Bill 375 (SB 375), helps local governments recognize the benefits of permitting local sources of aggregate. SB 375, also known as the Sustainable Communities and Climate Protection Act of 2008, was signed by former Governor Arnold Schwarzenegger on September 30, According to the Governor s press release: SB 375 requires the CARB to develop regional GHG emission reduction targets to be achieved from the automobile and light truck sectors for 2020 and The 18 Metropolitan Planning Organizations (MPOs) in California will prepare a sustainable communities strategy to reduce the amount of vehicle miles traveled (VMT) in their respective regions and demonstrate the ability for the region to attain ARB's targets. CARB would later determine if each region is on track to meet their targets. Builders also would get relief from certain environmental reviews under CEQA if they build projects consistent with the new sustainable community strategies. In addition, cities would get extra time eight years instead of five to update housing plans required by the state ( SB 375 is most concerned with automobile and light truck traffic. However, the goal of reducing GHGs covers all transportation sources based on the need for sustainable communities. Section 65080(a) of the Government Code states that each transportation planning agency... shall prepare and adopt a regional transportation plan directed at achieving a coordinated and balanced regional transportation system, including, but not limited to, mass transportation, highway, railroad, maritime, bicycle, pedestrian, goods movement, and aviation facilities and services. The regional transportation plan is to be an internally consistent document and include a sustainable communities strategy (SCS). The sustainable communities strategy shall... (v) gather and consider the best practically available scientific information regarding resource areas and farmland in the region.... (Gov. Code 65080(b)(2)(B)(v)). Resource areas include areas of the state designated by the State Mining and Geology Board as areas of statewide or regional significance containing considerable construction aggregate resources pursuant to Section 2790 of the Public Resources Code, and lands under Williamson Act contracts. (Gov. Code (a)(4)). Thus, SB 375 recognizes construction aggregate as a regionally significant resource that requires special consideration in transportation and land use planning efforts. The MPOs shall consider financial incentives for cities and counties that have resource areas... (Gov. Code 65080(b)(4)(C)). 10/03/ Draft EIR

5 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change Guidance for Evaluating Climate Change Impacts under CEQA On April 13, 2009, the Governor s Office of Planning and Research (OPR) submitted to the Secretary for Natural Resources its proposed amendments to the state CEQA Guidelines for GHG emissions, as required by Senate Bill 97. Those recommended amendments were developed to provide guidance to public agencies regarding the analysis and mitigation of GHG and the effects of GHG emissions in draft CEQA documents. On July 3, 2009, the Natural Resources Agency commenced the Administrative Procedure Act rulemaking process for certifying and adopting these amendments pursuant to Public Resources Code section Following a 55 day public comment period, and two public hearings, and in response to comments, the Natural Resources Agency proposed revisions to the text of the CEQA Guidelines amendments. The Natural Resources Agency transmitted the adopted amendments and the entire rulemaking file to the Office of Administrative Law (OAL) on December 31, 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, San Joaquin Valley Air Pollution Control District s (SJVAPCD s) Climate Change Action Plan On April 13, 2009, the OPR sent proposed amendments of the CEQA Guidelines to the Secretary of the Natural Resources Agency for promulgation. The proposed amendments require lead agencies (such as the SJVAPCD) to determine whether the GHGs generated by a proposed project would be significant, because of the individual project or in conjunction with the cumulative effects from the individual project and other projects. In response to the amendments promulgated by OPR and the Natural Resources Agency, the Governing Board of the SJVAPCD adopted a Climate Change Action Plan in August 2008 (SJVAPCD, 2008). The Climate Change Action Plan directed the SJVAPCD to develop guidance to assist businesses, land use agencies, and other permitting agencies in addressing GHG emissions as part of the CEQA process. In December 2009, the SJVAPCD released the Final Staff Report Addressing Greenhouse Gas Emissions Impacts under the California Environmental Quality Act (SJVAPCD 2009). The SJVAPCD determined that GHG emissions from development projects (i.e., proposed residential, commercial, industrial, or governmental operations) primarily occur indirectly through energy consumption and VMT and these effects would need to be reduced for a project to have a less than significant cumulative effect on the environment. The SJVAPCD GHG methodology relies on CARB s establishment of the BAU benchmark discussed above. BAU is referenced in CARB s AB 32 Scoping Plan as the BAU emissions occurring in 2020 if the average baseline emissions during the period were grown to 2020 levels, without control. The 2011 Scoping Plan revised the baseline emissions dates to Therefore, emissions factors, on a unit of activity basis, multiplied by the Draft EIR /03/2011

6 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation activity expected to occur in 2020, is an appropriate representation of 2020 BAU (CARB 2011). SJVAPCD uses a performance based standard of mitigation known as Best Performance Standards (BPS). The BPS would be applicable to all projects within the San Joaquin Valley Air Basin (SJVAB) that increase GHG emissions. Under the SJVAPCD Guidance, projects implementing BPS or achieving a 29% GHG emission reduction over BAU, would be determined to have a less than significant individual and cumulative impact for GHG impacts on global climate change and would not require project-specific quantification of GHG emissions. The SJVAPCD relied on the CARB 2008 Scoping Plan to establish its BAU for purposes of establishing baseline. The 2011 Scoping Plan uses the period to calculate BAU and, in light of the current economic downturn, concludes that projected 2020 emissions are less than what was originally projected in the 2008 Scoping Plan. The proposed 2011Scoping Plan, therefore, modifies the required GHG reduction percentage from 29% to 16%. Projects not implementing BPS would require quantification of project-specific GHG emissions unless an EIR is being prepared for a discretionary project in which case the Lead Agency is required to quantify GHG emissions regardless of whether BPS is incorporated into the project Project Impacts and Mitigation Measures Thresholds of Significance Significant impacts to air quality from GHG emissions may result if the Proposed Project would: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs Methodology The primary sources of GHG emissions from the Proposed Project would include the following: Facilities' Energy Usage, Other Equipment Energy Usage, Operation Mobile Equipment, On-site and Off-site Delivery Trucks, On-site and Off-site Worker Vehicles, and Stationary Sources Reductions in any of the above categories, including energy use or reductions in VMT would also have the effect of reducing GHG emissions as compared to BAU. Overall Proposed Project GHG emissions were calculated using guidance from the California Air Pollution Control Officer Association s (CAPCOA) CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act (January 2008); The Climate Registry s General Reporting Protocol, version 1.1 (May 2008); 10/03/ Draft EIR

7 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change and CalEEMod GHGs Emissions Factors. Guidance from the SJVAPCD s Final Staff Report: Addressing Greenhouse Gas Emissions Impacts under the California Environmental Quality Act was also used. Operations would be typical of sand and gravel extraction, with conventional mining practices common to the industry. Proposed Project operations are estimated to occur for up to 3,800 hours per year and up to 24 hours in any given day (although 13 hours per day is the likely maximum under typical conditions). Total maximum aggregate production is estimated to be 1.25 million tons per year marketed (MMtpy), with a product mix divided between asphaltic concrete, readymix concrete, and aggregate (sold to external customers). Aggregate production is expected to increase gradually over time. Therefore, operational activities were evaluated for four operating scenarios: 0.5 MMtpy, 0.75 MMtpy, 1.0 MMtpy, and 1.25 MMtpy. Therefore, to be conservative, Scenario 4 (1.25 MMtpy) was used for the analysis as it represents the most carbon-intensive scenario (refer to Appendix E-5 for GHG model results for all scenarios). Scenario 4 includes the following operational information: 1.25 MMtpy: In the final scenario of development, the Proposed Project would operate such that no more than 1.25 MMtpy of aggregate is transported off-site (less than 1.4 MMtpy will be mined and processed). Conveyor belts would be used to transport mined materials to the processing area, and all off-road equipment would meet Tier 4 emission standards. GHG emissions are generally calculated by determining activity information (i.e. energy usage, miles traveled, etc.), and applying emission factors for each GHG included in the analysis. Emission factors are typically provided in emissions per unit of energy consumed. Aggregate Demand Global climate impacts are substantially driven by population growth which correlates to growth in demand for aggregate and related construction materials. Increased population, therefore, is the underlying trigger to any GHG emission associated with a proposed aggregate mining and processing facility. The assumption that each person will use a certain amount of aggregate every year is a simplification of actual usage patterns, but overall, an increase in the population leads to the use of more aggregate. Over a long enough period, perhaps 20 years or longer, the random impacts of major public construction projects and economic recessions tend to be smoothed out and consumption trends become similar to historic per capita consumption rates. Per capita consumption is a commonly used and accepted national, state, and regional measure for purposes of forecasting. (California Department of Conservation (DOC) 2006, Aggregate Availability in California p. 5.) Demand for aggregate is inelastic (Attachment 9, Environmental Costs of Aggregate). Inelastic demand means that an increase or decrease in the price of aggregate has little or no effect on the quantity of aggregate demanded by consumers. Draft EIR /03/2011

8 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation Transportation plays a major role in the cost of aggregate to the consumer. Aggregate is a lowunit-value, high-bulk-weight commodity, and it must be obtained from nearby sources to minimize both the dollar cost to the aggregate consumer and other environmental and economic costs associated with transportation. If nearby sources do not exist, then transportation costs may significantly increase the cost of the aggregate by the time it reaches the consumer. (DOC 2006, Aggregate Availability in California p. 15.) As local sources of aggregate are depleted and aggregate is hauled longer distances to the consumer, prices will increase. Given aggregate s inelastic demand, however, increased prices will not reduce the demand for aggregate. Conversely, a new aggregate mine that increases local aggregate supply and lowers local aggregate prices by reducing haul distances would have little effect on aggregate demand and, therefore, little effect on use or production. Aggregate shortages in the Fresno area have resulted in rock being imported into the area from Coalinga, a 60-mile haul. (DOC 2006, Aggregate Availability in California, p. 15.) While Coalinga is within the County, it is located on the west side of the County and not near the Fresno Metropolitan area. The unmet demand for aggregate near the Fresno Metropolitan area would continue to require the hauling of material from Coalinga. Delivery trucks are an aspect of the Proposed Project that may result in a regional reduction of GHG emissions. By placing a source of aggregate, ready-mix concrete, and asphalt in a location where supply does not currently meet demand the Project will result in a reduction in VMT for customers. It is expected that many of the Proposed Project s customers will be located within a 30 to 60 mile roundtrip distance from the Proposed Project. In the absence of the Proposed Project, a portion of these customers would otherwise have to travel to Coalinga to obtain these materials, at a roundtrip distance of approximately 120 miles. This reduction in distance traveled for customer vehicles would result in a corresponding reduction in GHG emissions as shown in Table Table On-Road Vehicle CO 2 Emissions Versus Customer Roundtrip Distance Scenario 30-Mile Round Trip Off-site CO 2 Emissions (Proposed Project) 60-Mile Round Trip Off-site CO 2 Emissions 120-Mile Round Trip Off-site CO 2 Emissions (metric tons/yr) (metric tons/yr) (metric tons/yr) 0.5 MM tpy 2,507 4,119 7, MM tpy 3,299 5,602 10, MM tpy 4,186 7,243 13, MM tpy 5,253 9,192 17,069 Source: Sespe Consulting 3rd Party Review Memorandum, September /03/ Draft EIR

9 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change As shown in Table 4.7-2, implementation of the Proposed Project at the full 1.25 MMtpy production rate could reduce CO 2 emissions in the airshed by 3,939 (comparing the Project to a 60-mile round trip) to 11,816 (comparing the Project to 120-mile round trip) metric tons per year. SJVAPCD Existing Rules The Applicant will be required to adhere to, and implement, all applicable SJVAPCD Rules and it is recommended that compliance with these requirements be included as a Condition of Approval Issues Determined to Have No Impact As a result of the analysis conducted for the DEIR, there are not any greenhouse gas issues determined to have no impact with implementation of the Proposed Project Impacts Determined to be Less Than Significant As a result of the analysis conducted, the following areas of environmental concern related to GHG emissions were identified to have less than significant impacts: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Aggregate production from the Proposed Project would increase gradually over time. Therefore, operational activities were evaluated for four operating scenarios: 0.5 MMtpy, 0.75 MMtpy, 1.0 MMtpy, and 1.25 MMtpy. However, Scenario 4 (1.25 MMtpy) was used for the analysis as it represents the most carbon intensive scenario. Refer to Table 4.7-2, above, for the Proposed Project s GHG emissions results. Refer to Appendix E-5 for GHG model results for all scenarios. The 2020 BAU forecast was updated in the Final Supplement to the Scoping Plan Functionally Equivalent Document (CARB, August 24, 2011) such that the proposed amount of reduction required to achieve 1990 levels of emissions is a 16% reduction based on the BAU rather than 29% reductions based on the BAU, which was in the 2008 Scoping Plan and the amount used by SJVAPCD in developing its GHG impact thresholds. As mentioned above, the 2011Scoping Plan has been approved by CARB. As such, based on SJVAPCD s reliance on the 2008 Scoping Plan in establishing baseline, the BAU and emissions reductions analyzed herein are based on the BAU as defined in the 2011 Scoping Plan, the SJVAPCD Guidance, and the 16% GHG emissions reduction goal. In addition, not all sectors achieve the same level of reduction in the Scoping Plan (2008 and 2011 supplement) as the entire State. Therefore, transportation and electricity sectors make greater reductions in emissions while industrial sector sources are assumed to make lesser reductions. The industrial sector GHG reductions basically offset future growth so that emissions levels in the industrial sector remain constant. The Draft BPS for the asphalt plant indicates that a 13.2% reduction can be achieved by using heat from a dryer drum to mix aggregate and binder, using premium efficiency electric motors Draft EIR /03/2011

10 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation and exhaust fan operated with a variable frequency speed control. 17.2% reduction can be achieved when warm-mix technology is used. However, warm-mix asphalt use depends upon specifications for the asphalt mix design. Not all jobs can be completed using warm-mix asphalt and the asphalt plant operator/owner is not always in control of mix design. Nevertheless, the proposed asphalt plant (Gencor Industries, Inc. Ultraplant TM ) is assumed to have state-of-the-art characteristics that will result in an approximate 16% reduction. This level of reduction is consistent with statewide reductions reported in the Final Supplement to the Scoping Plan Functionally Equivalent Document and meets the 16% reduction in the 2011 Scoping Plan. Electricity use will be a source of GHG emissions from the Proposed Project. Because electricity use is a major operative cost, electricity use will be minimized to the extent feasible by the Operator. In addition, the electricity sector will be required to comply with the Renewal Portfolio Standard (RPS) and Renewable Electricity Standard which combine to require 33% renewable energy by The Scoping Plan forecasts that increasing renewable energy to 33% will reduce GHG emissions from electricity generation by approximately 15%. Attachment 8 provides GHG emissions from electricity use. Diesel fuel use in off-road equipment will be a source of GHG emissions from the Proposed Project. To reduce operating costs, fuel use will be minimized to the extent feasible by the Operator. Scenarios 3 (1.0 MMtpy) and 4 (1.25 MMtpy) involve newer equipment and replace the haul truck(s) with a conveyor which is less carbon intensive. The Low Carbon Fuel Standard (LCFS) will reduce emissions from these units by 10% by 2020, which is less than the reduction required by the 2011 Scoping Plan and the proposed revised Scoping Plan. Diesel fuel use in on-road haul trucks is largely outside of the control of the Proposed Project and arguably not induced by the Proposed Project when considered cumulatively with all loads of construction materials within the region. Nevertheless, the LCFS and location of the mine will reduce GHG emissions from haul trucks by 16% which is consistent with the 2011 Scoping Plan. Attachment 8 of Appendix E-5 calculates the Project s fair share of new aggregate trips and related GHG emissions. The BAU method implemented by SJVAPCD includes future growth, 16% less than BAU is a greater amount of reduction than 16% from the existing physical setting. Thus, the BAU approach should be conservative in this case. Population was assumed to grow at a compound annual growth rate of approximately 1.866% based on California Department of Finance (DoF) forecast through 2050 (July 2007). Since aggregate demand is per capita, the number of truck trips within the County will increase the same percentage as will the GHG emissions. DOC estimates that on January 1, 2006, the 50-year aggregate demand for the Fresno P-C Region was 629 million tons. DoF estimates that the population of Fresno and Madera Counties was 1,038,251 at the end of 2006 with roughly half of those individuals residing in the City of Fresno. DoF Population Projections (July 2007) indicate that P-C Region population will be approximately 2,568,791 in Using the 2007 projection, per capita consumption is estimated to be 7.43 tons per person per year assuming that the population of the two counties and the Fresno P-C Region are equal. Under average consumption conditions, aggregate use in 10/03/ Draft EIR

11 Environmental Impact Evaluation 4.7 Greenhouse Gases/Climate Change the P-C Region would be expected to increase from 7.7 MMtpy in 2006 to 10 MMtpy in 2020 of which the Project may provide up to 1.25 MMtpy (12.5%). Project production levels are a fraction of the total production within the Region and thus the Project would be responsible for its fair share of future growth in aggregate transportation and 100% of emissions from the transportation of other materials (Attachment 8). On the basis that new trips representing future growth would be diverted from Coalinga to the Project thereby avoiding 60 VMT each round-trip, the Proposed Project would reduce emissions from off-site transport of aggregate by 879 MTCO2 from BAU in Recycle related trips are excluded from project share assessment primarily because the Project does not induce the generation of recyclables and creating a new location will shorten trips. Attachment 8 of Appendix E-5 shows that with credit given for replacing haul trucks with a conveyor in Scenarios 3 & 4, the Project will result in overall reduction of greater than 16% from BAU in In addition, credit was not taken for potential emissions reductions: Co-locating the concrete plants with the mine is a design feature of the Project that reduces emissions by eliminating on-road truck travel. There are are number of baseline trips originating in Coalinga that will be shortened between 60 and 90 miles due to substitution of materials produced by the Project. The amount of the baseline VMT reduction has not been quantified because the task was not feasible to complete given the time and resources available for the EIR. However, the amount of baseline activity reduction is likely to be substantial as indicated by the fact that the amount of aggregate leaving Coalinga destined for the Fresno Metro area was sufficient to warrant comment by DOC. Given the conservative nature of assumptions and the omission credit that could have been taken for potential reductions, there is likelihood that the actual emissions will be substantially less than estimated. Accordingly, the Project impact on GHG emissions is determined to be consistent with the 2011 Scoping Plan and AB 32. The Project will have a less than significant impact from GHG emissions and may represent a benefit if the additional baseline activity reductions were quantified and included in the analysis. On this basis alone, the Proposed Project would have a less than significant impact on GHG emissions. Would the project potentially conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases? As discussed above, the County has implemented the Applicable SJVAPCD and Appendix G plans, policy and regulations that have been adopted for the purpose of reducing GHG emissions consistent with State and SJVAPCD policies. In addition, the County has evaluated current developments at both the State and SJVAPCD level to discuss potential revisions that may ultimately apply to the Proposed Project upon permit issuance. Finally, the County has quantified the Proposed Project s potential GHG emissions and ensured compliance with applicable BPS and GHG reduction requirements applicable at the time of the circulation of this DEIR. Therefore, this impact is less than significant. Draft EIR /03/2011

12 4.7 Greenhouse Gases/Climate Change Environmental Impact Evaluation Impacts Determined to be Potentially Significant As a result of the analysis conducted for the DEIR, it was determined that there were no issues associated with greenhouse gas emissions that had the potential for resulting in significant impacts. 10/03/ Draft EIR