During preparation of an Environmental Impact Report (EIR) under the California Environmental Quality Act (CEQA) for a major refinery upgrade, ALG was requested to provide an analysis of measures to reduce greenhouse gas emissions to the extent feasible, to mitigate the project's impact on global climate change.
ALG worked with the facility and outside legal counsel to formulate an approach to analyze all available greenhouse gas mitigation programs on- and off-site in a systematic fashion, and to recommend feasible measures for incorporation into the project or as independent mitigation measures. ALG's approach called for identifying all potentially applicable mitigation measures, screening out those measures that clearly did not apply to the proposed project, and conducting detailed analyses of the remaining measures to determine whether and the extent to which each measure could be applied to the facility.
The goal of ALG's effort was to identify measures to reduce or offset all greenhouse gas emissions associated with the project. If this was not possible, ALG's analysis was to serve as documentation that all feasible greenhouse gas mitigation measures had been applied to the project, to support a statement of overriding considerations required for the lead agency to approve the project.
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ALG's analysis incorporated AB-32 "early action" measures, California Climate Action Team strategies, American Petroleum Institute guidelines, California Attorney General suggested GHG reduction measures, and the California Air Pollution Control Officers Association guidance. The GHG mitigation program included measures to improve facility energy efficiency, reduce fugitive emissions, reduce transportation emissions, recycle water and waste products, increase carbon sequestration through urban forestry, and implement a community GHG mitigation fund. Although the Attorney General was initially concerned with the GHG mitigation program, the office later agreed that ALG's mitigation approach was acceptable. The lead agency subsequently approved a statement of overriding considerations and approved the proposed refinery upgrade.