CEQA Significance Thresholds

FRAQMD CEQA Significance Thresholds
(Mass Emission, pounds per day)

Project Type	Ozone Precursor Emissions		Respirable Particulate Matter Emissions
Project Type	NOx	ROG	PM10
All	25	25	80

FRAQMD, Board of Directors, Approved Indirect Source Review Thresholds of Significance

How to Apply the ISR Thresholds of Significance

It is the duty of the project proponent to perform an URBEMIS analysis (Screening or Refined) or other air district approved analysis to determine the air emissions associated with the proposed project, to determine if a threshold will be exceeded, to perform an evaluation to determine if the project's emissions pose a "significant effect" on air quality, and to submit a Mitigation Monitoring Plan detailing mitigation measures to be implemented to reduce or eliminate the effects.

Only "indirect sources" are to be considered in this evaluation. Indirect sources may be simply defined as any equipment, process, or other air emitting contrivance that is not regulated by FRAQMD and does not require a state permit to operate. Indirect sources include mobile sources (e.g. onroad and offroad motor vehicles, which account for ~ 70% of the air pollution problem in the Sacramento Valley) and area sources such as fugitive dust from excavation and demolition activities, architectural coatings (e.g. house painting), landscaping equipment (e.g. lawnmower), natural gas hot water heaters, and emissions from consumer products such as household cleansers, deodorants, and barbecue fluid, to name a few.

Contact the District if you need assistance in determining equipment, processes, or other air emitting contrivances regulated by FRAQMD and state permit requirements.

Determination of "Significant Effect" and Mitigation Recommendations

For typical projects in which the construction phase is short-term, use the following criteria: [Example: The construction phase for building 500 homes is a short-term air quality impact compared to the 50 plus years of Area/Operational Phase air pollution impacts generated from the resulting community]

Only the indirect source emissions associated with the long-term Area/Operational Phase of the project is used in this evaluation to determine if a project poses a CEQA “Significant Effect”. A Construction Phase analysis is required only to determine the extent of Construction phase mitigation required. So, a refined URBEMIS analysis is recommended in which every detail of the project is entered.

Procedure for Evaluation of Significant Effect and Recommended Mitigation
Compare the project's emissions derived from the sum of the Area/Operational Phase of the project with the three scenarios listed below to complete the evaluation.

Thresholds Not Exceeded
If a threshold has not been exceeded using a Screening Mode URBEMIS analysis then a refined analysis is not required for construction emissions and Standard Mitigation Measures for All Projects is recommended to address cumulative air quality impacts. These measures include standard Construction Phase and Area/Operational Phase measures. Submit a Mitigation Monitoring Plan, including a screening mode or refined URBEMIS report, for approval. The Lead Agency/FRAQMD may then recommend a Negative Declaration or Mitigated Negative Declaration upon approval of the Mitigation Monitoring Plan.
Thresholds Exceeded But Mitigated
If a threshold has been exceeded then the proponent should perform a refined URBEMIS analysis. Then, appropriate mitigation measures should be selected to reduce the Area/Operational Phase emissions to below each threshold exceeded, starting with Area/Operational measures found in Standard Mitigation Measures for All Projects. In addition, if Construction Phase emissions exceed the thresholds then all feasible measures found in Best Available Mitigation Measures Construction Activity are recommended and should be implemented.

Only the Area/Operational Phase emissions must be mitigated below the thresholds to meet a mitigated negative declaration recommendation, but the plan will not be approved without sufficient construction phase emission reductions. This can be achieved by adopting all recommended measures. If this process is successful, and approved by Lead Agency/FRAQMD staff, then a Mitigation Monitoring Plan, including the refined URBEMIS report, is submitted by the proponent with details regarding the selected measures, associated emission reductions, and the implementation strategy, for approval. The Lead Agency/FRAQMD may then recommend a Mitigated Negative Declaration for an approved Mitigation Monitoring Plan.
Thresholds Exceeded And Not Mitigated
If the project's Area/Operational Phase emissions cannot be mitigated to below the thresholds then this project may be considered a "Significant Effect" project and may be required to implement all feasible measures recommended by the air district.

Perform a refined URBEMIS analysis: For Area/Operational Phase mitigation start with Area/Operational measures from Standard Mitigation Measures for All Projects with extensive focus on BAMM "Point-Value" List implementation (MS Excel 2002 or Adobe PDF). For Construction Phase mitigation Best Available Mitigation Measures Construction Activity must be implemented.

The project proponent should then work closely with air district staff to achieve a minimum 35% Area/Operational Phase mitigation plan, approved by Lead Agency/FRAQMD, to include air district recommended measures, and the recommended Construction Phase mitigation plan. Both the recommended Area/Operational Phase 35% emissions reduction and the recommended Construction Phase measures must be achieved. Submit the approved Mitigation Monitoring Plan, including the refined URBEMIS report, with the Environmental Impact Report (EIR).

For projects in which the construction phase is the "long term" phase or the only phase of the project (such as highway construction projects or Levee projects) use the following criteria: Indirect source emissions associated with all phases of the project (Construction Phase and Area/Operational Phase emissions) are used for this evaluation to determine if a project poses a CEQA “Significant Effect”.

Use a refined URBEMIS analysis for applicable components of the project such as demolition projects.
Use the Roadway Construction Emissions Model (in MS Excel - 1.8 Mb), which is available at the SMAQMD web site, to assist with roadway and possibly levee project emissions estimates. This tool only assesses off-road equipment emissions.
Additional analyses may be required to provide an adequate emissions evaluation.

Procedure for Evaluation of Significant Effect and Recommended Mitigation
Compare the project's emissions derived from all phases of the project with the three scenarios listed below to complete the evaluation.

Thresholds Not Exceeded
If a threshold has not been exceeded then Standard Mitigation Measures for All Projects is recommended to address cumulative impacts. These measures include Construction Phase and Area/Operational Phase measures. Submit a Mitigation Monitoring Plan for approval. The Lead/Agency/FRAQMD may then recommend either a Negative Declaration or Mitigated Negative Declaration upon approval of the Mitigation Monitoring Plan.
Thresholds Exceeded But Mitigated
If a threshold has been exceeded then the proponent should select appropriate mitigation measures to reduce emissions below each threshold exceeded. For Construction Phase mitigation all feasible measures from Best Available Mitigation Measures Construction Activity must be implemented. For Area/Operational Phase emissions Standard Mitigation Measures for All Projects should be implemented at a minimum. If this process is successful, and approved by Lead Agency/FRAQMD staff, then a Mitigation Monitoring Plan, including all feasible Construction Phase and Area/Operational Phase measures, is submitted with details regarding the selected measures, associated emission reductions, and the implementation strategy, for approval. The Lead Agency/FRAQMD may then recommend a Mitigated Negative Declaration for an approved Mitigation Monitoring Plan.
Thresholds Exceeded And Not Mitigated
If the project's emissions cannot be mitigated to below the thresholds then the project may be considered a "Significant Effect" project and may be required to implement all feasible mitigation measures and measures specifically recommended by the air district to achieve a minimum 35% mitigation plan. For Construction Phase mitigation all feasible measures from Best Available Mitigation Measures Construction Activity are recommended. For Area/Operational Phase emissions Standard Mitigation Measures for All Projects should be implemented at a minimum with extensive focus on BAMM "Point-Value" List implementation (MS Excel 2002 or Adobe PDF).

The project proponent should then work closely with air district staff to achieve remaining emission reductions by implementing all feasible measures to achieve the desired minimum 35% mitigation plan for Lead Agency/FRAQMD approval. Emission reductions gained through the project's congestion mitigation improvements may be eligible for mitigation reduction credit. SACOG support and completed emission reduction studies itemizing real emission reductions must be provided for review.

Alternative fuel vehicles and the use of alternative lower-emission fuels should be considered. Voluntary offsite mitigation projects may also be proposed including construction of park and ride lots, lower-emission school bus projects, transit infrastructure, CNG fueling infrastructure, pedestrian infrastructure improvements, and funding for projects that reduce diesel combustion NOx and toxic particulate matter emissions are among acceptable projects to be considered.. Projects not achieving a 35% mitigation may not be approved. Alternative components of the proposed project offering reduced air quality impacts should then be pursued.

Projects for which proponents appear to be reluctant to address the concerns of the District including failure to implement FRAQMD-recommended mitigation measures may be further pursued through the appropriate CEQA and local government political framework in order to ensure community and regional public and regulatory agency support, as well as raising lead agency and approval Board concerns in order to achieve the District's goal of protecting public health.

Submit the approved Mitigation Monitoring Plan with the Environmental Impact Report (EIR).

FRAQMD CEQA Significance Thresholds (Mass Emission, pounds per day)

FRAQMD CEQA Significance Thresholds
(Mass Emission, pounds per day)