California Air Resources Board

Principal Investigator/Author: Michael Boswell

Contractor: California Polytechnic State University

Contract Number: 21STC001

Project Status: Active

Relevant CARB Programs: 2022 Scoping Plan for Achieving Carbon Neutrality, (including Appendix D, Local Actions),  Local Actions

Topic Areas: CEQA Greenhouse Gas Mitigation, Voluntary Carbon Offsets, Climate Action Plans, Greenhouse Gas Thresholds

Research Summary:

This project conducts a literature review, interviews CEQA experts, and analyzes Environmental Impact Reports and Air District CEQA guidance to identify best practices for local projects as CEQA mitigation projects and identifies how California air districts and other regional entities encourage and incentivize local greenhouse gas (GHG) mitigation under CEQA.

To do this, the project developed a white paper that 1) identifies best practices for local projects as CEQA mitigation projects, focusing on identifying real-world local examples and best practices that fulfill the requirements for local GHG mitigation projects, and 2) synthesizes the available literature and research resulting from this project. The research examined the following:

1. What local, off-site GHG-reducing projects, including, but not limited to, offsets, have been used as CEQA mitigation?
2. What projects resulted in the purchase and retirement of carbon offsets as CEQA mitigation?
3. What characteristics of those projects helped them fulfill CEQA’s mitigation requirements (e.g., effective, feasible, roughly proportional, enforceable, concurrent, based on substantial evidence, and not otherwise required)?
4. How do standard “on-site” mitigation projects compare to “project attributes” identified in the Local Actions Appendix of the draft 2022 Scoping Plan?
5. What other characteristics of those projects increased their viability? Consider equity, financing, partners involved, timeline, responsible party, etc.
6. What are best practices for local CEQA mitigation projects?
7. What are barriers to the development of local CEQA mitigation projects (based on both the real-world examples found and where real-world examples are lacking)?
8. How have air districts in California used their CEQA responsible agency role to encourage local GHG mitigation under CEQA?
9. What calculation methods and thresholds of significance have been used for GHG emissions?
10. How often do lead agencies use “Statements of Overriding Consideration” for significant GHG impacts?
11. How have other regional entities (e.g., regional collaboratives, metropolitan planning organizations, utilities) played a role in developing and implementing local CEQA mitigation projects?
12. What regional activities have worked to develop and implement local CEQA mitigation projects, and what activities have not worked?
13. What new actions might air districts and other regional entities take to enhance the viability of local CEQA mitigation projects? Consider viability in terms of fulfilling CEQA’s mitigation requirements (listed above), equity considerations, and long-term financial viability.

Keywords: California Environmental Quality Act (CEQA), greenhouse gas (GHG) mitigation, local carbon offsets, voluntary carbon offset credits, statements of overriding considerations, sustainable communities, local government, air district.