Climate Change policies, led by implementation of the nation’s first statewide Greenhouse Gas Reduction law, AB 32, has a significant impact on our industry. CBPA is engaged full time on these issues. Here are some key documents and updates:
CEQA Guidlines and Greenhouse Gases
The Governor’s Office of Planning & Research (OPR) has drafted amendments to the CEQA Guidelines for greenhouse gas emissions as required by Senate Bill 97 (SB 97). OPR will be holding two workshops to present the amendments and obtain input from the public. The workshops will include a presentation by OPR and the Resources Agency staff, an overview of the Preliminary Draft CEQA Guideline amendments, and the process for adopting the regulations by 2010.
Workshops will be held on January 22, 2009 in Los Angeles and on January 26, 2009 in Sacramento.
- View the OPR and the Resources Agency workshop agenda
- View the Preliminary Draft CEQA Guideline Amendments
It is extremely important that our industry engage in this process. Your company/firm is highly encouraged to analyze the proposals, attend the workshops, and submit comments. This proceeding will change the template for the environment review process and must be informed by those with practical knowledge on the topic.
CEQA Significance Thresholds for Greenhouse Gases
CBPA has led an effort to draft comments and assemble a large coalition of business and industry groups to help provide guidance to the ARB proceeding to set thresholds of significances. Read the industry comments.
The coalition recommends against the adoption of a straight numeric threshold. Additionally, we advise for the need of development of performance standards that recognize the divergent businesses in this state and problems associated with a pro forma model approach.
AB 32 Scoping Plan – CEQA Comments
The California Air Resources Board (CARB) is expected to adopt the AB 32 Scoping Plan on December 11, 2008. Developing workable and effective CEQA thresholds will be one of the critical steps in working to implement California’s greenhouse gas reduction goals.
To help facilitate that goal, California Business Properties Association (CBPA) and California Building Industry Association (CBIA) have submitted a joint letter regarding the plan’s “Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under the California Environmental Quality Act” (CEQA). Read the CBIA/CBPA AB 32/CEQA Thresholds letter.
AB 32 Economic Analysis Blasted by State’s Own Peer Review Team
The independent economic “peer review” team assembled by the Air Resources Board to analyze the AB 32 Regulatory Plan has concluded that the state has intentionally skewed analysis of the economic effects of the climate change plan to show positive outcomes
The state’s analysis found a net increase in gross state product and individual earnings due to the proposed climate change policies through 2020.
However, all six economists on the review panel found the analysis flawed. Several stated they believe the state cherry-picked data to improve the plan’s arguments for reducing greenhouse gas emissions. This independent economic analysis supports arguments and concerns that CBPA and other business and taxpayer groups have been expressing throughout the regulatory process.
AB 32 Scoping Plan Blasted by California Legislative Analyst
Assembly Republican Leader Mike Villines (R-Clovis) and Assemblymember Roger Niello (R-Sacramento) asked the independent California Legislative Analyst’s Office (LAO) to report on the draft scoping plan of the Air Resources Board (CARB) for implementation of the Global Warming Solutions Act of 2006 (better known as AB 32).
The LAO’s report on the AB 32 Scoping Plan is highly critical of almost every aspect of the plan. Here is a summary of the LAO’s conclusions:
“We conclude that (1) the scoping plan’s overall emissions reductions and purported net economic benefit are highly reliant on one measure—the Pavley regulations, (2) the plan’s evaluation of the costs and savings of some recommended measures is inconsistent and incomplete, (3) Macroeconomic modeling results show a slight net economic benefit to the plan, but ARB failed to demonstrate the analytical rigor of its findings, (4) economic analysis played a limited role in development of scoping plan, and (5) despite its prediction of eventual net economic benefit, the scoping plan fails to lay out an investment pathway to reach its goals for GHG emissions levels in 2020”
The LAO’s conclusions support the many issues and concerns raised by CBPA and many other business and taxpayer groups. You can read the full report here: CA Legislative Analyst’s Office report on AB 32 Scoping Plan. Also read a news account of the LAO analysis.
AB 32 Scoping Plan (October Release)
The California Air Resources Board (CARB) has released the next version of state’s historic greenhouse gas regulations. Known as “the AB 32 Scoping Plan” this document points to the future of how we do business in California. CBPA previously submitted a 12 page comment letter to CARB regarding the Draft Scoping Plan (including the appendices and economic analysis). The relevant documents are listed below:
- AB 32 Scoping Plan (October Release)
- Industry comments on the AB 32 Draft Scoping Plan/Appendices/Economic Analysis
AB 32 Scoping Comments
The AB 32 Draft Scoping Plan / Appendices / and Economic Analysis has been out for public review and comment. These documents contain the details for plans to implement the landmark law, which mandates that California reduce greenhouse gas emissions to 1990 levels. Read the Draft Scoping Plan and Appendices.
CBPA has solicited and collected comments from a broad array of members. Comments have been compiled and submitted to ARB on behalf of our industry. Read CBPA’s AB 32 Draft Scoping Plan/Appendices/Economic Analysis comment letter.
AB 32 Green Building Carbon Credit / Carbon Footprint Study
As part of the AB 32 process, several major Real Estate Groups including CBPA, ICSC, NAIOP, and BOMA California have funded efforts to quantify energy efficiency of new and existing buildings, and to think through the most efficacious way to incent energy efficiency under the regulatory scheme. Click below for more information: