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AUGUSTIN BERNAL MOUNTAIN BIKE TRAIL PROJECT DRAFT INITIAL STUDY <br /> 12956 <br />DUDEK 57 April 2022 <br />Regarding impacts from GHGs, the California Air Pollution Control Officers Association (CAPCOA) consider <br />GHG impacts to be exclusively cumulative impacts (CAPCOA 2008); therefore, assessment of significance <br />is based on a determination of whether the GHG emissions from a project represent a cumulatively <br />considerable contribution to the global atmosphere. This analysis uses both a quantitative and a qualitative <br />approach. The quantitative approach is used to address the first significance criterion listed above. The <br />quantifiable thresholds developed by BAAQMD were formulated based on Assembly Bill (AB) 32 and <br />California Climate Change Scoping Plan reduction targets; these strategies will reduce GHG emissions <br />statewide. Thus, a project cannot exceed a numeric BAAQMD threshold without also conflicting with an <br />applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Therefore, if a <br />project exceeds a numeric threshold and results in a significant cumulative impact, it would also result in <br />a significant cumulative impact with respect to consistency with a plan, policy, or regulation, even though <br />the project may incorporate measures or have features that would reduce its contribution to cumulative <br />GHG emissions. <br />The BAAQMD has established the following three separate thresholds of significance for operational <br />emissions from nonstationary sources: <br /> Compliance with a Qualified Greenhouse Gas Reduction Strategy (i.e., if a project is found to be out of <br />compliance with a Qualified Greenhouse Gas Reduction Strategy, its GHG emissions may be considered <br />significant). <br /> 1,100 MT CO2e per year (i.e., emissions above this level may be considered significant). <br /> 4.6 MT CO2e per service population per year (i.e., emissions above this level may be considered <br />significant). (Service population is the sum of residents plus employees expected for a development <br />project.) <br />This analysis uses the quantitative threshold of 1,100 MT CO2e annually. If the project GHG emissions <br />would exceed this threshold, it would be considered to have a cumulatively considerable contribution of <br />GHG emissions and a cumulatively significant impact on climate change. <br />Impact Discussion <br />a) Would the project generate greenhouse gas emissions, either directly or indirectly, that may have <br />a significant impact on the environment? <br />Construction. Construction of the project would result in GHG emissions, primarily due to the use <br />of off-road construction equipment, on-road vendor (material delivery) trucks, and worker vehicles. <br />Since the BAAQMD has not established construction-phase GHG thresholds, construction GHG <br />emissions were compared to the BAAQMD operational GHG threshold. Construction is expected to <br />require approximately 3 months to complete and to generate a total of 63.88 MT CO 2e, as shown <br />in Table 3.8-1. A detailed depiction of the construction schedule – including information regarding <br />equipment, trucks, and worker vehicles – is included in Appendix B.