3.7 Greenhouse Gas Emissions

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1 This section describes the affected environment and regulatory setting for greenhouse gas (GHG) emissions. It also describes the impacts on GHG emissions that would result from implementation of the project, and mitigation measures that would reduce these impacts. Information in this section is based primarily on the October 2011 Air Quality Reports for the Calipatria Solar Farm I site, Midway Solar Farm I site, and Midway Solar Farm II site, prepared by Chambers Group, Inc. The complete reports are included within Appendix P Environmental Setting The California Air Resources Board (CARB) has divided California into regional air basins according to topographic drainage features. The three proposed project sites are within the Salton Sea Air Basin (SSAB) and are under the jurisdiction of the Imperial County Air Pollution Control Board (ICAPCD). GHGs and Global Climate Change In the early 1960s scientists recognized that carbon dioxide (CO 2 ) levels in the atmosphere were rising every year. It was also noted that several other gases, including methane and nitrous oxides were also increasing. Levels of these gases have increased by about 25 percent since large-scale industrialization began around 150 years ago, according to the United States Environmental Protection Agency (USEPA). After numerous computer simulated model runs on the effects of these increases in the atmosphere, it was concluded that the rising concentrations almost always resulted in an increase of average global temperature. Rising temperatures may, in turn, produce changes in weather, sea levels and land use patterns, commonly referred to as climate change. General scientific consensus suggests that the Earth s climate has warmed over the past century and that human activity affecting the atmosphere is likely an important driving factor. It is difficult to determine the extent of change that humans may be causing due to the natural variability of the Earth s climate. During the planet s history, the climate has changed many times, with events ranging from ice ages to long periods of warmth. Natural factors such as volcanic eruptions, changes in the Earth's orbit, and the amount of energy released from the sun historically have affected the Earth's climate. Human activities associated with the Industrial Revolution beginning in the late 18th century, have also changed the composition of the atmosphere. The burning of fossil fuels, such as coal and oil, and deforestation has caused the concentrations of heat-trapping GHGs to increase significantly in our atmosphere. Many chemical compounds found in the Earth s atmosphere act as GHGs, which allow sunlight to enter the atmosphere freely. When sunlight strikes the Earth s surface, some of it is reflected back towards space as infrared radiation (heat). GHGs absorb this infrared radiation and trap the heat in the atmosphere. Many gases exhibit these greenhouse properties. Some of them occur in nature (water vapor, carbon dioxide, methane, and nitrous oxide), while others are exclusively human-made (like gases used for aerosols). The most relevant GHGs are water vapor (H 2 O), Imperial County Planning & Development Services Department ESA /

2 carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulfur hexafluoride (SF 6 ). GHGs, in most cases, have both natural and anthropogenic sources. Natural mechanisms already exist as part of the carbon cycle for removing GHGs from the atmosphere (often called land or ocean sinks). Levels of GHGs, due to the increase in anthropogenic sources, have exceeded the normal rates of natural absorption. This has resulted in increased atmospheric concentrations of GHGs and potentially human-induced global warming. The U.S. has the second highest emissions of GHGs of any nation on Earth, though 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 CO 2 emissions in California, accounting for approximately 41 percent of total emissions. Electricity generation accounts for approximately 22 percent of CO 2 emissions in California, and the industrial sector accounts for approximately 20.5 percent. California GHG emissions and the increase in project emissions of CO 2, CH 4, and N 2 O, are summarized in Table TABLE CALIFORNIA GREENHOUSE GAS EMISSIONS OF CO 2, CH 4, AND N 2 O Greenhouse Gas Net Million Tons Carbon Dioxide Equivalent Carbon Dioxide (CO 2 ) Methane (CH 4 ) Nitrous Oxide (N 2 O) High GWP Gases (HFC, PFC, SF 6 ) Global Warming Potential SOURCE: California Energy Commission, GHGs are a necessity to life as we know it. They keep the planet's surface warmer than it otherwise would be. However, as the concentrations of these gases increase in the atmosphere and continue to, the Earth's temperature is also increasing, exceeding past levels. Globally, climate change has the potential to impact numerous environmental resources through potential, though uncertain, impacts related to future air temperatures and precipitation patterns. The projected effects of global warming on weather and climate are likely to vary regionally, but are expected to include the following direct effects (IPCC, 2001): Higher maximum temperatures and more hot days over nearly all land areas; Higher minimum temperatures, fewer cold days and frost days over nearly all land areas; Reduced diurnal temperature range over most land areas; Increase of heat index over land areas; and More intense precipitation events. Imperial County Planning & Development Services Department ESA /

3 Also, there are many secondary effects that are projected to result from global warming, including global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity. While the possible outcomes and the feedback mechanisms involved are not fully understood, and much research remains to be done, the potential for substantial environmental, social, and economic consequences over the long term may be great Regulatory Framework In 1988, the United Nations and the World Meteorological Organization 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 (UNFCCC) established an agreement with the goal of controlling GHG emissions, including methane. As a result, the Climate Change Action Plan was developed to address the reduction of GHGs in the United States. The Plan consists of more than 50 voluntary programs. In October 1993, President Bill Clinton announced his Climate Change Action Plan, which had a goal to return GHG emissions to 1990 levels by the year This was to be accomplished through 50 initiatives that relied on innovative voluntary partnerships between the private sector and government aimed at producing cost-effective reductions in GHG emissions (CAPCOA, 2008). On March 21, 1994, the United States joined a number of countries around the world in signing the UNFCCC. Under the UNFCCC, governments do the following: gather and share information on GHG emissions, national policies, and best practices; launch national strategies for addressing GHG emissions and adapting to expected impacts, including the provision of financial and technological support to developing countries; and cooperate in preparing for adaptation to the impacts of climate change (UNFCCC, 2007). A particularly notable result of the UNFCCC efforts was a treaty known as the Kyoto Protocol Treaty, which was negotiated in December The agreement came into force on February 16, 2005 following ratification by Russia on November 18, When countries sign the treaty, they demonstrate their commitment to reduce their emissions of GHGs or engage in emissions trading. As of March 2011, a total of 192 countries and other governmental entities have ratified the agreement. Although the U.S. symbolically signed the Protocol in 1998, in order for the Protocol to be formally ratified, it must be ratified by the U.S. Senate, and this has not occurred to date. Other countries, like India and China, which have ratified the protocol, are not required to reduce carbon emissions under the present agreement despite their relatively large populations. Global warming and climate change have received substantial public attention for more than 15 years. For example, the United States Global Change Research Program was established by the Global Change Research Act of 1990 to enhance the understanding of natural and human-induced changes in the Earth s global environmental system, to monitor, understand and predict global change, and to provide a sound scientific basis for national and international decision making. Even so, the analytical tools have not been developed to determine the effect on worldwide global warming from a particular increase in GHG emissions, or the resulting effects on climate change Imperial County Planning & Development Services Department ESA /

4 in a particular locale. The scientific tools needed to evaluate the impacts that a specific project may have on the environment are even farther in the future. Regulatory oversight for air quality in the SSAB rests at the USEPA at the federal level, CARB at the state level, and at the regional level with the ICAPCD. Federal EPA On April 2, 2007, in Massachusetts v. USEPA, 549 U.S. 497 (2007), the Supreme Court found that GHGs are air pollutants covered by the Clean Air Act (CAA). The Court held that the USEPA must determine whether or not emissions of GHG from new motor vehicles cause or contribute to air pollution that 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 USEPA is required to follow the language of section 202(a) of the CAA. 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 GHGs under Section 202(a) of the CAA. The USEPA 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. The USEPA carefully reviewed, considered, and incorporated public comments and has now issued its final Findings. The USEPA found that six GHGs taken in combination endanger both the public health and the public welfare of current and future generations. The USEPA also found that the combined emissions of these GHGs from new motor vehicles and new motor vehicle engines contribute to the greenhouse effect as air pollution that endangers public health and welfare under CAA section 202(a). These Findings were based on careful consideration of the full weight of scientific evidence and a thorough review of numerous public comments received on the Proposed Findings published April 24, These Findings became effective on January 14, Specific GHG Regulations that the USEPA has adopted to date are as follows: 40 CFR Part 98. Mandatory Reporting of Greenhouse Gases Rule. This rule requires mandatory reporting of GHG emissions for facilities that emit more than 25,000 metric tons of CO 2 e emissions per year (USEPA, 2009). Additionally, reporting of emissions is required for owners of SF 6 - and PFC-insulted equipment when the total nameplate capacity of these insulating gases is above 17,280 pounds. The proposed project would not trigger GHG reporting as required by this regulation. 40 CFR Part 52. Proposed Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule. USEPA recently mandated implementation of the Prevention of Significant Deterioration (PSD) requirements to facilities whose stationary source CO 2 e emissions exceed 75,000 tons per year. The proposed project would not trigger PSD permitting as required by this regulation. Imperial County Planning & Development Services Department ESA /

5 Council on Environmental Quality (CEQ) Draft GHG Guidance On February 18, 2010, the Draft NEPA Guidance on Consideration of the Effects of Climate Change and Greenhouse Gas Emissions (CEQ, 2010) memorandum was published for public review and comment. As described in this memorandum, climate change analysis should provide the decision maker with relevant and timely information about the environmental effects of his or her decision and reasonable alternatives to mitigate those impacts (CEQ, 2010), and the following issues should be considered accordingly: 1. The GHG emissions effects of a proposed action and alternative actions; and 2. The relationship of climate change effects to a proposed action or alternatives, including the relationship to proposal design, environmental impacts, mitigation and adaptation measures. As part of providing meaningful information to decision makers, the memorandum suggests that if a proposed action would be reasonably anticipated to cause direct emissions of 25,000 metric tons or more of CO 2 -equivalent GHG emissions on an annual basis, agencies should consider this an indicator that a quantitative and qualitative assessment may be meaningful to decision makers and the public (CEQ, 2010). State There are a variety of statewide and local air pollution control district-level rules and regulations that have been implemented or are in development in California that mandate the quantification or reduction of GHGs. Under CEQA, an analysis and mitigation of emissions of GHGs and climate change in relation to a proposed project is required where it has been determined that a project would result in a significant addition of GHGs. However, neither thresholds of significance nor methods of analysis have been defined in CEQA. Certain APCDs have proposed their own levels of significance. The ICAPCD has not established a GHG significance threshold. Executive Order S-3-05 In 2005, in recognition of California s vulnerability to the effects of climate change, Governor Schwarzenegger established Executive Order S-3-05, which set forth a series of target dates for statewide emissions of GHGs to be progressively reduced, as follows: By 2010, reduce GHG emissions to 2000 levels; By 2020, reduce GHG emissions to 1990 levels; and By 2050, reduce GHG emissions to 80 percent below 1990 levels This Executive Order does not include any specific requirements that pertain to the proposed project. However, actions taken by the State to implement these goals may affect the project, depending on the specific implementation measures that are developed. Imperial County Planning & Development Services Department ESA /

6 Executive Order S Executive Order S was established by Governor Arnold Schwarzenegger in November Executive Order S establishes a Renewables Portfolio Standard (RPS) for all retail sellers of electricity. The specifics of this executive order include the following: Requires retail sellers of electricity shall serve 33 percent of their load with renewable energy by 2020; Requires various state agencies to streamline processes for the approval of new renewable energy facilities and determine priority renewable energy zones; and Establishes the requirement for the creation/adoption of the Desert Renewable Energy Conservation Plan (DRECP) process for the Mojave and Colorado Desert regions. This Executive Order does not include any specific requirements that pertain directly to the proposed project. However, this project, as a renewable energy project, will help the utility contracting the power from this project to meet the established RPS standard. Senate Bill 1368 Senate Bill 1368 (SB 1368) was enacted in 2006, and required the California Public Utilities Commission (CPUC) to establish a CO 2 emissions standard for base load generation owned by or under long-term contract with publicly owned utilities. The CPUC established a GHG Emissions Performance Standard (EPS) of 1,100 pounds of CO 2 e per megawatt-hour. SB 1368 also requires the posting of notices of public deliberations by publically owned companies on the PUC website and establishes a process to determine compliance with the EPS. The proposed project, as a renewable energy generation facility, is determined to comply with the GHG Emissions Performance Standard requirements of SB1368. Assembly Bill 32 (2006) On September 27, 2006, AB 32, the California Global Warming Solutions Act of 2006 was enacted by the State of California. The legislature stated that global warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California. AB 32 caps California s GHG emissions at 1990 levels by 2020, and defines GHG emissions as all of the following gases: CO 2, CH 4, N 2 O, HFCs, PFCs, and SF 6. This agreement represents the first enforceable statewide program in the U.S. to cap all GHG emissions from major industries that includes penalties for noncompliance. While acknowledging that national and international actions will be necessary to fully address the issue of global warming, AB 32 lays out a program to inventory and reduce GHG emissions in California and from power generation facilities located outside the State that serve California residents and businesses (CAPCOA, 2008). AB 32 charges CARB with responsibility to monitor and regulate sources of GHG emissions in order to reduce those emissions. CARB staff recommended an amount of 427 million metric tons of carbon dioxide equivalent (MMTCO 2 e) as the total statewide GHG 1990 emissions level and 2020 emissions limit. CARB approved the 2020 limit on December 6, This limit is an aggregated statewide limit, rather than sector- or facility-specific. CARB is conducting Imperial County Planning & Development Services Department ESA /

7 rulemaking for reducing GHG emissions to achieve the emissions cap by The rules must take effect no later than In designing emission reduction measures, CARB must aim to minimize costs, maximize benefits, improve and modernize California s energy infrastructure, maintain electric system reliability, maximize additional environmental and economic co-benefits for California, and complement the State s efforts to improve air quality. The AB 32 Scoping Plan (CARB, 2008b) contains the main strategies California will use to reduce the GHGs that cause climate change. The scoping plan has a range of GHG reduction actions, which include direct regulations, alternative compliance mechanisms, monetary and nonmonetary incentives, voluntary actions, market-based mechanisms such as a cap-and-trade system, and an AB 32 cost of implementation fee regulation to fund the program. These measures have been introduced through four workshops that were held between November 30, 2007 and April 17, A draft scoping plan was released for public review and comment on June 26, 2008, followed by more workshops in July and August The proposed scoping plan was released on October 15, 2008, and approved at the CARB hearing on December 12, Per CARB s Updated Scoping Plan Fact Sheet (CARB, 2010b), the following has occurred: Approval of 12 of 30 CARB regulations, including all 9 Discrete Early Actions; Approved measures provide approximately 70 MMTCO2e in percent of California s goal of reducing 169 MMTCO2e; and First year of mandatory reporting complete 97 percent compliance rate. The 39 Recommended Actions included in the Scoping Plan are presented in Table below. TABLE RECOMMENDED ACTIONS OF CLIMATE CHANGE SCOPING PLAN ID # Sector Strategy Name T-1 Transportation Pavley I and II Light-Duty Vehicle GHG Standards T-2 Transportation Low Carbon Fuel Standard (Discrete Early Action) T-3 Transportation Regional Transportation-Related GHG Targets T-4 Transportation Vehicle Efficiency Measures T-5 Transportation Ship Electrification at Ports (Discrete Early Action) T-6 Transportation Goods-movement Efficiency Measures T-7 Transportation Heavy Duty Vehicle Greenhouse Has Emission Reduction Measure Aerodynamic Efficiency (Discrete Early Action) T-8 Transportation Medium and Heavy-Duty Vehicle Hybridization T-9 Transportation High Speed Rail E-1 Electricity and E-2 Electricity and E-3 Electricity and E-4 Electricity and Increased Utility Energy efficiency programs ; More stringent Building and Appliance Standards Increase Combined Heat and Power Use by 30,000 GWh Renewables Portfolio Standard Million Solar Roofs Imperial County Planning & Development Services Department ESA /

8 ID # Sector Strategy Name CR-1 CR-2 Electricity and Electricity and Energy Efficiency Solar Water Heating GB-1 Green Buildings Green Buildings W-1 Water Water Use Efficiency W-2 Water Water Recycling W-3 Water Water System Energy Efficiency W-4 Water Reuse Urban Runoff W-5 Water Increase Renewable Energy Production W-6 Water Public Goods Charge (Water) I-1 Industry Energy Efficiency and Co-benefits Audits for Large Industrial Sources I-2 Industry Oil and Gas Extraction GHG Emission Reduction I-3 Industry GHG Leak Reduction from Oil and Gas Transmission I-4 Industry Refinery Flare Recovery Process Improvements I-5 Industry Removal of Methane Exemption from Existing Refinery Regulations RW-1 Recycling and Waste Management Landfill Methane Control (Discrete Early Action) RW-2 RW-3 Recycling and Waste Management Recycling and Waste Management Additional Reductions in Landfill Methane Capture Improvements High Recycling/Zero Waste F-1 Forestry Sustainable Forest Target H-1 High Global Warming Motor Vehicle Air Conditioning Systems (Discrete Early Action) H-2 High Global Warming H-3 High Global Warming H-4 High Global Warming H-5 High Global Warming H-6 High Global Warming H-7 High Global Warming SF 6 Limits in Non-Utility and Non-Semiconductor Applications (Discrete Early Action) Reduction in Perflourocarbons in Semiconductor Manufacturing (Discrete Early Action) Limit High GWP Use in Consumer Products (Discrete Early Action, Adopted June 2008) High GWP Reductions from Mobile Sources High GWP Reductions from Stationary Sources Mitigation Fee on High GWP Gases A-1 Agriculture Methane Capture at Large Dairies SOURCE: CARB, 2008a. The following recommended action is directly related to the proposed project: (E-3) Renewables Portfolio Standard. The CEC estimates that about 12 percent of California s retail electric load is currently met with renewable resources. Renewable Imperial County Planning & Development Services Department ESA /

9 energy includes (but is not limited to) wind, solar, geothermal, small hydroelectric, biomass, anaerobic digestion, and landfill gas. California s current RPS is intended to increase that share to 20 percent by Increased use of renewables will decrease California s reliance on fossil fuels, thus reducing emissions of GHGs from the electricity sector. Based on Governor Schwarzenegger s call for a statewide 33 percent RPS, the Scoping Plan anticipates that California will have 33 percent of its electricity provided by renewable resources by 2020, and includes this reduction in GHG emissions Local County of Imperial Pursuant to the requirements of SB 97, the Resources Agency adopted amendments to the State CEQA Guidelines to provide regulatory guidance on the analysis and mitigation of GHG emissions in CEQA documents, while giving lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHG and GCC impacts. Formal CEQA thresholds for lead agencies must always be established through a public hearing process. Imperial County has not established formal quantitative or qualitative thresholds through a public rulemaking process, but CEQA permits the lead agency to establish a project-specific threshold of significance if backed by substantial evidence, until such time as a formal threshold is approved Impacts and Mitigation Measures Methodology On December 5, 2008, the SCAQMD Governing Board adopted the staff proposal for an interim GHG significance threshold for projects where the SCAQMD is the lead agency. The interim threshold consists of five tiers of standards that could result in a finding of less than significant impact. The tiers include CEQA exemptions, consistency with regional GHG budgets, less than significant screening levels for industrial projects (10,000 metric tons/year CO 2 e) and commercial/residential projects (3,000 metric tons/year CO 2 e), performance standards (i.e., 30 percent less than Business As Usual [BAU]), and carbon offsets (SCAQMD 2008). Although SCAQMD is not the lead agency for the proposed project, this analysis includes the use of the Tier 3 quantitative thresholds for residential and commercial projects since the ICAPCD has not established GHG thresholds. The SCAQMD proposes that if a project generates GHG emissions below 3,000 metric tons/year of CO 2 e, it could be concluded that the project s GHG contribution is not cumulatively considerable and is therefore less than significant under CEQA. If the project generates GHG emissions above the threshold, the analysis must identify mitigation measures to reduce GHG emissions. Thresholds of Significance Effective March 18, 2010, CEQA Appendix G states that a project would have potentially significant GHG emission impacts if it would: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment or Imperial County Planning & Development Services Department ESA /

10 Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Project Impacts Impact 3.7-1: Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment? Typically, projects can generate GHG emissions in many ways. The project is intended to provide solar power to the grid that would replace other, less efficient, energy sources. The initial energy production for the project would be up to 502,000 Mwh per year, sufficient to power over 87,000 homes and displacing over 346,000 tons of CO 2 e emissions per year when compared to a gasfired power plant or 690,000 tons when compared to a coal-fired power plant. Direct Emissions from Mobile Combustion. Mobile combustion sources are non-stationary emitters of GHGs such as automobiles, motorcycles, trucks, off-road vehicles such as construction equipment, boats, and airplanes. On-road mobile sources include vehicles authorized by the California Department of Motor Vehicles to operate on public roads. Non-road mobile sources include, among other things, trains, ocean-going vessels, and commercial airplane. Mobile emissions from the project can come from the vehicles used doing short term installation activities and from the long-term maintenance activities. a) Construction Mobile GHGs from construction activities were calculated in the Air Quality Reports (Appendix P) using the methods described therein, which estimated that there would be a total of approximately 4,021 tons of CO 2 e. Because construction activity impacts are relatively short-term, they contribute a relatively small portion of the overall lifetime project GHG emissions. Thus, the SCAQMD recommends that construction related emissions be amortized over a 30-year project lifetime, resulting in 134 metric tons of CO 2 e annually. b) Operational Mobile Operational mobile emissions were calculated using the methods described above, which estimated that there would be a total of approximately 162 metric tons of CO 2 e. With the addition of the amortized project construction emissions, emissions would be approximately 296 tons of CO 2 e per year. Since the SCAQMD proposes that if a project generates GHG emissions below 3,000 metric tons/year of CO 2 e, it could be concluded that the project s GHG contribution is not cumulatively considerable and is therefore less than significant. The Permittee shall comply with all ICAPD requirements for dust control and green house gas emissions as previously discussed under the Air Quality section for both construction and operation activities. The following measures would further help to reduce GHG contributions. Measure 3.7-1: Diesel Equipment (compression ignition) Offset Strategies (40% to 60% reduction) Imperial County Planning & Development Services Department ESA /

11 Construction equipment operating on-site shall be equipped with two to four degree engine timing retard or pre-combustion chamber engines. Measure 3.7-2: Vehicular Trip (spark ignition) offset strategies (30 % to 70% reduction) Encourage commute alternatives by informing construction employees and customers about transportation options for reaching your location (i.e. post transit schedules/routes) Help construction employees ride share by posting commuter ride sign-up sheets, employee home, zip code, map, etc. The project proponent must also adhere to Rule 310 Operation Development Fee requirements for the construction of all buildings associated with project such as the Operations and Maintenance building. A construction and operational Dust Control Plan must be prepared and submitted to the Air District 10 days prior to any earth moving activity. The project proponent must ensure that visible dust emissions (VDE) are limited to 20% opacity at all times. A copy of the Dust Plan is to be kept at the site at all times. Should any transformers/generators be used at the property as part of the project, the project proponent must submit an Authority to Construct/Permit to Operate application to the Air District. Impact 3.7-2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs? Neither the County of Imperial or ICAPCD have any specific plans, policies, nor regulations adopted for reducing the emissions of GHGs. However, the project is intended to: (1) reduce importation of power from fossil fuel power plants; and (2) contribute to a reduction in GHGs. GHGs have the potential to adversely affect the environment because such emissions contribute, on a cumulative basis, to global climate change. The proper context for addressing this issue in a CEQA document is as a discussion of cumulative impacts, because although the emissions of one single project will not cause global climate change, GHG emissions from multiple projects, past, present and future, throughout the world could result in a cumulative impact with respect to global climate change. In the global cumulative context, the location of GHG emissions is less relevant than similar emissions of criteria air pollutants or toxic air contaminants. Therefore, even though the net benefit of reducing emissions from fossil fuel power plants would be attributed to the power purchaser as opposed to utilities in Imperial County, the project would aid in California s ambitious goal towards reductions in GHG to 1990 levels. In addition, since the long-term, operational GHG emissions are minimal and the construction emissions are shortterm, the project would not conflict with any applicable plan, policy, or regulation adopted for reducing the emissions of GHGs and would not hinder the State s ability to meet the AB 32 goals. Therefore, impacts are considered less than significant. Mitigation: None required. Imperial County Planning & Development Services Department ESA /