Section 3.5. Greenhouse Gas Emissions Regulatory Framework
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1 Section 3.5 Greenhouse Gas Emissions This section evaluates potential greenhouse gas (GHG) emissions impacts associated with the project. Analysis within this section is based on the Air Quality Technical Report prepared by RECON, and included as Appendix B to this EIR Regulatory Framework Regulations have been developed to reduce national, state, and local GHG emissions by primarily targeting the largest emitters of GHGs: the transportation and energy sectors. Plan goals and regulatory standards are thus largely focused on the automobile industry and public utilities. For the transportation sector, the reduction strategy is generally three pronged: to reduce GHG emissions from vehicles by improving engine design; to reduce the carbon content of transportation fuels through research, funding, and incentives to fuel suppliers; and to reduce the miles vehicles travel through land use change and infrastructure investments. For the energy sector, the reduction strategies aim to reduce energy demand; impose emission caps on energy providers; establish minimum building energy and green building standards; transition to renewable non-fossil fuels; incentivize homeowners and builders; fully recover landfill gas for energy; expand research and development; and so forth. California Assembly Bill (AB) 32, the Global Warming Solutions Act of 2006, requires California s GHG emissions to decrease to 1990 levels by Subsequently, California Senate Bill 97 directed the Office of Planning and Research to adopt CEQA Guidelines on analyzing GHG emissions. The new regulations became effective as part of the CEQA Guidelines on March 18, The Guidelines do not require or recommend a specific analytical methodology or set a quantitative threshold for determining the significance of GHG emissions. They state that lead agencies should analyze each project individually to determine whether the project s GHG impacts are cumulatively considerable, and that the analysis of GHG impacts should consider the extent that the project would increase or reduce GHG emissions or exceed a locally applicable threshold of significance. The project GHG emissions are limited to construction of the water infrastructure improvements and access road, and no operational emissions beyond what currently exist (e.g., maintenance vehicular trips and water system operations) are expected. The federal and state regulatory standards are focused mainly on vehicle emissions and energy emissions that would be associated with land use and development projects. Page 3.5-1
2 Because the emissions associated with the project would be limited to construction, many of these standards would not apply directly to the project. In addition, the Water Authority is currently preparing a Climate Action Plan (CAP) in conjunction with the Regional Water Facilities Optimization and Master Plan Update and a Program Supplemental Environmental Impact Report. The CAP will focus on both greenhouse gas emission reduction and adaptation measures to ensure the Water Authority's water supplies, infrastructure, and services will accommodate the projected impacts of climate change. It will entail a comprehensive look at Water Authority current practices and operations, and include an analysis of feasible measures that could be implemented to reduce greenhouse-gas emissions and prepare for climate-change effects. The CAP, Master Plan update, and its associated Program Environmental Impact Report was released for public review in late Environmental Setting Many scientists are of the opinion that the earth s temperature is increasing and that the increase is expected to have wide-ranging effects on the environment. Although global climate change is anticipated to affect all areas of the globe, there are numerous implications of direct importance to California. Statewide average temperatures are anticipated to increase by between 3 and 10.5 degrees Fahrenheit ( F) by 2100 (California Climate Change Center 2006). Some climate models indicate that this warming may be greater in the summer than in the winter. This could result in widespread adverse impacts to ecosystem health, agricultural production, water use and supply, and energy demand. Increased temperatures could reduce the Sierra Nevada snowpack and put additional strain on the region s water supply. In addition, increased temperatures could result in lower inversion levels leading to a decrease in air quality. It is important to note that even if GHG emissions were to be eliminated or dramatically reduced, it is projected that the effect of those emissions would continue to affect global climate for centuries. The CARB performs statewide GHG inventories divided into nine broad sectors of economic activity: agriculture, commercial, electricity generation, forestry, high global warming potentials (GWP) emitters, industrial, recycling and waste, residential, and transportation. There are numerous GHGs, both manmade and natural, that affect the atmosphere to different degrees. To have a common notation for these various GHGs, the metric used for quantifying GHG emissions is metric tons of carbon dioxide equivalent (MTCO 2 E). Table shows the estimated statewide GHG emissions for the years 1990, 2000, 2004, and Page 3.5-2
3 TABLE CALIFORNIA GHG EMISSIONS BY SECTOR IN 1990, 2000, 2004, AND Emissions in MMTCO 2E (% total) Emissions in MMTCO 2E (% total) Emissions in MMTCO 2E (% total) Emissions in MMTCO 2E (% total) 1 Sector Sources Agriculture 23.4 (5%) (6%) (6%) (6%) Commercial 14.4 (3%) (3%) (3%) (3%) Electricity Generation (26%) (23%) (25%) (24%) Forestry (excluding sinks) 0.2 (<1%) 0.19 (<1%) 0.19 (<1%) 0.19 (<1%) High GWP (2%) (3%) (3%) Industrial (24%) (21%) (19%) (19%) Recycling and Waste (1%) 6.23 (1%) 6.71 (1%) Residential 29.7 (7%) (7%) (6%) (6%) Transportation (35%) (37%) (38%) (37%) Unspecified Remaining (<1%) Subtotal Sinks Forestry Sinks -6.7 (--) (--) (--) (--) TOTAL SOURCE: CARB 2007, 2010a. 1 Percentages may not total 100 due to rounding. 2 Unspecified fuel combustion and ozone depleting substance (ODS) substitute use, which could not be attributed to an individual sector. A San Diego regional emissions inventory was prepared by the University of San Diego School of Law, Energy Policy Initiative Center, which took into account the unique characteristics of the region. Their 2006 emissions inventory for San Diego is duplicated below in Table The sectors included in this inventory are somewhat different from those in the statewide inventory, though comparisons can still be made. TABLE SAN DIEGO COUNTY GHG EMISSIONS BY SECTOR IN Emissions Sector in MMTCO 2 E (% total) 1 Agriculture/Forestry/Land Use 0.7 (2%) Waste 0.7 (2%) Electricity 9.0 (25%) Natural Gas Consumption 3.0 (8%) Industrial Processes & Products 1.6 (5%) On-Road Transportation 16.0 (45%) Off-Road Equipment & Vehicles 1.3 (4%) Civil Aviation 1.7 (5%) Rail 0.3 (<1%) Water-Borne Navigation (<0.5%) Other Fuels/Other 1.1 (3%) TOTAL 35.5 SOURCE: University of San Diego Percentages may not total 100 due to rounding. Page 3.5-3
4 Similar to the statewide emissions, transportation-related GHG emissions contributed the most countywide, followed by emissions associated with energy use. The project area currently consists of the Second San Diego Aqueduct, which includes Pipelines 3, 4, and 4A, all of which are constructed underground, with venting appurtenances exposed along the alignment. The pipeline itself is not a source of GHG emissions. As noted in the project description, there are vehicle trips associated with maintenance operations by Water Authority staff and system operations that are existing and would not change with the construction of the improvements proposed as part of this project Thresholds for Determining Significance With respect to GHG emissions, the following thresholds based on applicable criteria in the state CEQA Guidelines (CCR ), Appendix G, are used to determine if a significant impact related to Greenhouse Gas emissions may occur. A significant impact would occur if the project would: 1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; or 2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gas. The Water Authority does not currently have adopted thresholds of significance for GHG emissions. Therefore, a 900-metric-ton of carbon dioxide equivalent (CO 2 E) screening criterion for determining when a detailed GHG analysis is being used by local jurisdictions following guidance from the California Air Pollution Control Officers Association (CAPCOA) report CEQA & Climate Change dated January The CAPCOA report references the 900-metric-ton guideline as a conservative threshold for requiring further analysis and mitigation. This emission level is based on the amount of vehicle trips, typical energy and water use, and other factors associated with projects Impact Analysis Analysis of Project Effects Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the engines of off-road construction equipment and through combustion of diesel and gasoline in on-road construction vehicles, as well as part of the commute vehicles of the construction workers. Smaller amounts of GHGs are also emitted through the energy use embodied in any water use (for fugitive dust control) and lighting for the construction activity. Every phase of the construction process, including excavation, grading, paving, and building, emits GHGs in volumes proportional to the quantity and type of Page 3.5-4
5 construction equipment used. The heavier equipment typically emits more GHGs per hour of use than the lighter equipment because of their greater fuel consumption and engine design. GHG emissions were estimated as a part of the air quality analysis prepared for this project using the CalEEMod (see Appendix B) and were calculated for the three GHGs of primary concern (carbon dioxide [O 2 ], methane [CH 4 ], and nitrous oxide [N 2 O]) that would be emitted from construction. GHG emissions associated with each phase of project construction are calculated using the anticipated construction equipment and worker trips. Total construction emissions over the entire construction period were calculated. The Association of Environmental Professionals (AEP) has recently recommended that total construction GHG emissions resulting from a project be amortized over 30 years (the estimated lifetime of a given project) and added to operational GHG emissions (AEP 2010). This results in a project s estimated combined annual construction and operational GHG emissions over the lifetime of a project. PIPELINE IMPROVEMENTS (BOTH ALTERNATIVES) A variety of equipment, including excavators, cranes, loaders, and trenchers, would be required for construction under either alternative. Tunneling activities would include: (1) south portal clearing and grubbing, (2) south portal excavation, (3) tunnel excavation, (4) north portal clearing and grubbing, (5) north portal excavation, (6) pipe installation, (7) pipe connections, and (8) site restoration. Open Trench activities would include (1) pipeline clear and grub, excavation, and installation, (2) pipe connections, and (3) site restoration. The equipment, worker trips, and lengths of each phase are detailed in Chapter 2, Project Description. Both construction methods would require the excavation and processing (crushing) of materials, which would occur on the parcel designated as the Staging Area. Crushing equipment at the staging area has been included in the modeling of emissions for both alternatives since material processing would occur at the same time as pipeline replacement activities, and GHG emissions from both activities would occur simultaneously. Tables and show the total projected GHG emissions for Alternative 1 and Alternative 2, respectively. It is assumed that for a majority of the pipeline construction work would occur during normal daytime hours. However, during aqueduct connection, work would proceed at 24 hours per day for a maximum of 10 days. To determine the worst-case emissions during the 24-hour work days, the total emissions that would occur during the pipeline connections phase were multiplied by three to obtain 24-hour emissions. Tunneling would result in a maximum total of metric tons of CO 2 equivalent (MTCO 2 E), which is the equivalent to MTCO 2 E when amortized over 30 years. For open trenching, pipeline improvements would result in a maximum total of MTCO 2 E, an equivalent of MTCO 2 E when amortized over 30 years. Page 3.5-5
6 TABLE ALTERNATIVE 1: TUNNELING PROJECTED CONSTRUCTION GHG EMISSIONS MTCO 2 E (Total Metric Tons) South Portal Clear and Grub Off-Road Construction Equipment Hauling 0.68 Worker Trips 2.24 SUBTOTAL South Portal Excavation Off-Road Construction Equipment Hauling 0.48 Worker Trips SUBTOTAL Tunnel Excavation Off-Road Construction Equipment Hauling 0.21 Worker Trips SUBTOTAL North Portal Clear and Grub Off-Road Construction Equipment Hauling 0.68 Worker Trips 2.24 SUBTOTAL North Portal Excavation Off-Road Construction Equipment Hauling 0.47 Worker Trips 8.24 SUBTOTAL Pipe Installation Off-Road Construction Equipment Hauling 1.34 Worker Trips SUBTOTAL Pipe Connections Off-Road Construction Equipment 4.27 Hauling 2.69 Worker Trips 4.85 SUBTOTAL (8-hour work day) SUBTOTAL (24-hour work day) Site Restoration Off-Road Construction Equipment 5.09 Hauling 1.01 Worker Trips 7.55 SUBTOTAL TOTAL TOTAL AMORTIZED OVER 30 YEARS Page 3.5-6
7 TABLE ALTERNATIVE 2: OPEN TRENCH PROJECTED CONSTRUCTION GHG EMISSIONS MTCO 2 E (Total Metric Tons) Pipeline Clear and Grub, Excavation, and Installation Off-Road Construction Equipment Hauling 2.05 Worker Trips SUBTOTAL Pipe Connections Off-Road Construction Equipment 4.32 Hauling 2.73 Worker Trips 5.05 SUBTOTAL (8-hour work day) SUBTOTAL (24-hour work day) Site Restoration Off-Road Construction Equipment 5.15 Hauling 1.02 Worker Trips 7.77 SUBTOTAL TOTAL TOTAL AMORTIZED OVER 30 YEARS ACCESS ROAD Conventional grading and trenching is anticipated for the access road construction. Construction activities would include clearing and grubbing, rough grading, paving, and other miscellaneous trenching activities for water quality improvements. Using the mix of equipment, worker trips, and length of each phase from Table 3.2-8, the total projected GHG emissions were calculated. As shown in Table 3.5-5, construction of the access road would result in a maximum total of MTCO 2 E. This is equivalent to 1.63 MTCO 2 E when amortized over 30 years. Page 3.5-7
8 TABLE ACCESS ROAD PROJECTED CONSTRUCTION GHG EMISSIONS MTCO 2 E (Total Metric Tons) Clear and Grub Off-Road Construction Equipment 5.39 Hauling 0.35 Worker Trips 2.09 SUBTOTAL 7.83 Grading Off-Road Construction Equipment 8.20 Hauling 0.69 Worker Trips 3.49 SUBTOTAL Paving Off-Road Construction Equipment 2.99 Hauling 1.04 Worker Trips 1.40 SUBTOTAL 5.43 Other Activities Off-Road Construction Equipment Hauling 0.34 Worker Trips 3.97 SUBTOTAL TOTAL TOTAL AMORTIZED OVER 30 YEARS 1.63 STAGING AREA The project site office, off-site equipment staging, and storage would take place at the construction staging area. As stated above, rock processing (i.e., crushing) may be required for either of the alternatives and could take place on the Staging Area parcel. However, since the rock processing would be conducted concurrently with the pipeline improvements, this activity is included in the GHG emissions estimated above for each construction alternative (see Tables and 3.5-4). ALL PROJECT COMPONENTS To obtain the total GHG emissions that would result from construction of the project under either alternative, the emissions resulting from construction of the access road were added to the emissions resulting from each project construction alternative. Total emissions are shown in Table Page 3.5-8
9 TABLE BOTH ALTERNATIVES TOTAL PROJECTED CONSTRUCTION GHG EMISSIONS (MTCO 2 E) Alternative 1: Tunneling Alternative 2: Open Trench Pipeline Improvements Access Road TOTAL TOTAL AMORTIZED OVER 30 YEARS Significance Determination Threshold 1: GHG Emissions Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment? ALL PROJECT COMPONENTS As shown in Table 3.5-6, total emissions from tunneling and the access road construction under Alternative 1 would be MTCO 2 E when amortized over 30 years, and total emissions from open trench and access road construction under Alternative 2 would be MTCO 2 E when amortized over 30 years. Total GHG emissions from both construction alternatives would be less than the threshold 900 MTCO 2 E. Impacts would be less than significant. Threshold 2: Consistency with Plans, Policies, and Regulations Would the project conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHG? ALL PROJECT COMPONENTS The adopted federal and state plans and policies aim to reduce national and state GHG emissions by primarily targeting the largest emitters of GHGs: the transportation and energy sectors. The project GHG emissions are limited to construction of the water infrastructure improvements and access road, and no operational emissions are expected. The project does not alter the land use designation, nor would it affect the growth forecast in the City of San Diego General Plan, and therefore would not affect any regional emissions inventories or planning efforts. As discussed previously, the Water Authority is currently preparing a CAP that addresses GHG emission reduction and adaptation measures. Once adopted by the Board of Directors, all subsequent Water Authority projects would be subject to the measures in the CAP. Therefore, the Page 3.5-9
10 project is consistent with the goals of any applicable plans, policies, or regulations pertaining to the reduction of GHGs. Impacts would be less than significant Analysis of Cumulative Effects Global climate change is, by its nature, a cumulative issue. GHG emissions are exclusively cumulative (i.e., there generally cannot be an individual project of sufficient magnitude to influence climate change itself); any impact is therefore considered a cumulatively considerable impact. As previously discussed throughout this section, the project would have a less than significant contribution to a cumulatively considerable impact Mitigation Measures Impacts from GHG emissions would be less than significant. Therefore, no mitigation measures are required Significance after Mitigation Impacts would remain less than significant. Page
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