Interim Procedure for Approval of Voluntary Offsite Mitigation Funding Projects

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Interim Procedure for Submitting a Voluntary Offsite Mitigation Project Funding Proposal

Until such time that the FRAQMD staff establishes a Board of Director's-approved procedure for offsite mitigation projects and the associated process by which the air district may process voluntary funds submitted for offsite mitigation projects the following procedure may be used as guidance.

Funding for offsite mitigation projects are strictly a voluntary process by which a project proponent may offer to contribute funds or to sponsor an air pollution emissions reduction project approved by FRAQMD in order to receive mitigation credit. All funding arrangements occur between the two project proponents.

Preferred Methodology
All projects should utilize the most current URBEMIS Model to estimate the project's emissions. It may be prudent to run a refined URBEMIS analysis (select the Area and Operational Phases only - not the Construction Phase; select Lower Sacramento Valley) as well as a screening mode analysis to determine the best approach (the screening mode may overestimate emissions). Any mitigation measures selected from within the refined URBEMIS analysis must not overlap with measures selected from outside of the URBEMIS Model to ensure that double credit is not taken. All proponents should utilize the Best Available Mitigation Measures (BAMM) "Point-Value" list and/or other mitigation measures for which an approved emission reduction value has been assigned first, then implement all feasible mitigation measures and any air district recommended measures to lower the emissions deficit as much as possible prior to proposing voluntary contributions for an offsite mitigation project.

Example Project
A mixed-use project is proposed to construct 19 single family residences, a commercial office park, and other large commercial buildings. The project proponent enters the project details into the URBEMIS Model to determine the project's long-term Area/Operational Phase emissions impacts. It is determined that the sum of the Area/Operational NOx, pounds per day, emissions for the project exceeds the 25 pounds per day NOx thresholds and that the PM10 is less than the 80 pound per day threshold; the NOx emissions are at 102 pounds per day and will therefore be the target number to use in determining the emission reductions to be achieved.

The project proponent then begins the process of selecting feasible mitigation measures from the BAMM Point-Value list and other FRAQMD-approved resources until the list is exhausted or the necessary emission reductions have been achieved to mitigate the project. If the necessary emission reductions have been achieved, in this case meaning that the NOx emissions have been reduced to below the 25 pounds per day threshold, then the proponent may apply for a mitigated negative declaration assuming that all selected measures have been approved first by the Lead Agency, or FRAQMD if the lead agency prefers, and submitted in writing in the form of a Mitigation Monitoring Plan as a component of the environmental review document. Otherwise, the project proponent must now calculate the remaining emissions reductions that will be necessary to drop below the 25 pounds per day NOx Threshold of Significance.

Assume that the proponent has exhausted the list of all feasible measures and will only be capable of implementing measures totaling 12 points as approved by FRAQMD and the Lead Agency, which equates to a 12% reduction in all emissions. 12% of 102 pounds per day NOx is a 12.24 pounds per day reduction, leaving a balance of 64.76 pounds per day to be further reduced to achieve a Mitigated Negative Declaration (102 pounds per day NOx - 12.24 pounds per day NOx reductions - 25 pounds per day NOx threshold = 64.76). At this point the NOx pounds per day emission rate needs to be converted to a NOx tons per year value based on a 180-day Ozone season. Therefore, 64.76 pounds per day x 180 days / 2,000 pounds per ton = 5.83 tons of NOx to be mitigated.

Assume that the Carl Moyer Program currently allows projects to be funded up to (not to exceed) a cost-effectiveness value of $13,600 per ton of NOx reduced. However, of the FRAQMD-administered Carl Moyer projects funded to date assume that the average cost per ton was determined by staff to be $3,181.15. Therefore the project proponent could propose to voluntarily donate $18,541 (5.8284 tons x $3,181.15 per ton = $18,541) toward qualifying, approved emission reduction projects from a list provided by the air district or if the project proponent is fortunate to locate a qualifying FRAQMD-approved project(s) on their own behalf that achieves the necessary emission reductions for less funds, or a highly desired community project that may not be cost-effective short-term but provides a means to achieve long-term emissions reductions, such as transit infrastructure projects, then they should simply work out the details and submit their proposal in writing to FRAQMD for review and approval.

Failure to Achieve a Mitigated Negative Declaration
If mitigation is not achieved then it is recommended that the project proponent implement all feasible mitigation measures to achieve a minimum 35% reduction in effecting air emissions and perform an Environmental Impact Report.

Note: A 35% mitigation effort was achieved in the South Sutter County Specific Plan and other Sacramento Valley projects and is therefore considered feasible.