[Photo Credit: flickr user Sam Williams]
Earlier this month, the Bay Area Air Quality Management District (BAAQMD) unanimously adopted new air quality guidelines related to greenhouse gas (GHG) emissions and particulate matter (PM 2.5) from land use projects. The comprehensive new guidelines, among the most stringent in the nation, address the impacts of air pollutants, as well as recent changes in state and federal air quality. The guidelines also include air quality significance thresholds and mitigation measures local agencies can use when preparing air quality impact analyses under the California Environmental Quality Act (CEQA).
Some significant changes to the guidelines include:
- Single family housing projects of 56 dwelling units or greater, hotels with more than 83 hotel rooms and general office buildings with more than 53,000 square feet will all be considered to have a significant impact on GHG emissions under CEQA.
- Local governments are encouraged to adopt qualified GHG Reduction Strategies.
- New screening criteria and threshold levels have been set for extremely fine particulate matter emissions and toxic air contaminants. Projects which fall above these new thresholds will be required determine whether the project will result in a significant impact, including evaluation of emissions within a 1,000 foot radius of the proposed project.
Stricter greenhouse gas and particulate matter guidelines are a good thing, right? Not always, say some who argue that the new guidelines may inadvertently lead to more sprawl by making it harder to develop the denser parts of our region. Some worry that the new regulatory obstacles will drive up the costs of future affordable housing, infill, and transit-oriented development (TOD) projects. Developers and cities are concerned that the new guidelines will make compliance with SB 375, the State's law which requires compact development, more difficult.
The guidelines do contain a method for local governments to accelerate the CEQA review process for projects that are infill or transit-oriented. To do this, a city can prepare a GHG Reduction Strategy and have it approved by BAAQMD. Projects or plans consistent with these strategies could then be considered less than significant under CEQA, and therefore exempt from full review. With cities around the region reeling from the budget crisis, and in some cases cutting planning staff, however, resources to develop these strategies are in short supply.
San Francisco has already begun working on a GHG Reduction Strategy, so it is unlikely that the BAAQMD Guidelines will cause significant environmental review process changes for projects in the City; the new air quality standards will likely have more significant impacts on projects and plans in jurisdictions without GHG Reduction Strategies or detailed climate change related policies.
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