Review Principles

The review principles listed in the Policy summarize the existing practices established by the District’s California Environmental Quality Act (CEQA) review program. They serve as guidelines used by District staff when the District acts as a commenting agency to review and comment on the environmental documents prepared by lead agencies. The principles also serve as the basis for the District staff to recommend on-site and off-site mitigation measures for land use projects when concerns are identified pertaining to air quality. When an off-site mitigation measure is considered by lead agencies, the review principles provide the method on how to implement an off-site mitigation measure and what options for the implementation of off-site mitigation measures. 

Criteria Pollutants

The District recommends that the mitigation measure should explicitly identify the anticipated emission reductions and the method to implement.

Calculation of Emission Reductions

The anticipated emission reductions from the mitigation measure implementation should be calculated by one of the following scenarios:

  • If the measure is applied as a feasible measure to offset additional emissions, the anticipated emission reduction shall be calculated based on the amount of emissions exceeding the thresholds for a single season (summer for ozone precursors or winter for PM10).
  • If the measure is applied to support a “less-than-significant” conclusion, the anticipated emission reduction shall be calculated based on the total amount of emissions exceeding the thresholds for each season, until the year in which the project’s operational emissions will be equal to the thresholds, or for a maximum of 20 seasons.

Implementation Method

The District recommends that the off-site mitigation measure for criteria pollutants be implemented by one of the following methods:

  • The applicant can propose its own off-site mitigation project, which is verified by the District that the proposed project will result in an equivalent emission reduction identified by the mitigation measure.
  • The applicant can pay a mitigation fee, which is calculated based on the anticipated emission reduction and cost-effectiveness identified by the District.

Any received off-site mitigation funds is managed under the District's Land Use Air Quality Mitigation Funds Policy (PDF) to fund eligible reduction projects, approved by the District Board.

Greenhouse Gases

The District recommends that the mitigation measure should explicitly identify the anticipated emission reductions and the method to implement.

Calculation of Emission Reductions

The anticipated emission reductions from the mitigation measure implementation be should calculated by one of the following methods;

  • If the measure is applied as a feasible measure, the anticipated emission reduction shall be calculated based on the amount of emissions exceeding the thresholds for one year.
  • If the measure is applied to support a “less-than-significant” conclusion, the anticipated emission reduction shall be calculated based on the total amount of emissions exceeding the threshold for each year, until the year in which the project’s emissions will be equal to the threshold, or for a maximum of 20 years.

Implementation Method

The District recommends that the off-site mitigation measure for greenhouse gases (GHG) emissions be implemented by one of the following methods.

  • The applicant can propose its own off-site mitigation project which generates carbon credits equivalent to the anticipated emission reductions and is implemented by an approved protocol from the California Air Pollution Control Officers Association (CAPCOA), California Air Resources Board, or other similar entities determined acceptable by the District, or
  • The applicant can purchase carbon credits from the CAPCOA GHG Reduction Exchange Program, American Carbon Registry (ACR), Climate Action Reserve (CAR), or other similar carbon credit registry as determined acceptable by the District.

The District encourages the applicant to consider generating or purchasing local and California-only carbon credits as the preferred mechanism to implement the off-site mitigation measure for GHG emissions and facilitate the State to achieve the GHG emission reduction goal. The District will assist lead agencies with reviewing and verifying that the carbon credits, from either the proposed off-site mitigation projects or the purchase certification from the selected carbon credit registries, along with ensuring the credits are retired.

Questions

Questions can be emailed to the District.