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HomeMy WebLinkAbout10 - Greenhous Gas and Climate Change Genentech Master Plan Update, Draft EIR Page 10-1 10 Greenhouse Gas Emissions and Climate Change This chapter of the Genentech Master Plan Update EIR evaluates the potential impacts of the Project related to greenhouse gas (GHG) emissions and climate change. This chapter also describes the existing conditions and evaluates the extent to which climate change may affect development pursuant to the Master Plan Update as proposed, as well as the extent to which the Master Plan Update (or Project) may contribute to GHG emissions and climate change. Although some of the information in the Environmental Setting draws from the 2012 Supplemental MEIR (SMEIR), setting and regulatory information for GHG emissions and climate change has been updated to reflect current information. Emissions estimates and analysis have been updated for this Program EIR using current data from the following sources: ● Ramboll Environ, Greenhouse Gas Technical Appendix, December 2018 (Appendix 10A) ● the Association of Bay Area Governments and Metropolitan Transportation Commission’s Plan Bay Area 2040 ● the City of South San Francisco’s Climate Action Plan (CAP), February 2014 Environmental Setting Climate Change Overview Greenhouse Gases Gases that trap heat in the Earth’s atmosphere are called greenhouse gases, or GHGs. These gases play a critical role in determining the Earth’s surface temperature. Part of the solar radiation that would have been reflected back into space is absorbed by these gases, resulting in a warming of the atmosphere. Without natural GHGs, the Earth’s surface would be about 61 degrees cooler.1 This phenomenon is known as the greenhouse effect. However, scientists have proven that emissions from human activities such as electricity generation, vehicle emissions and even farming and forestry practices have elevated the concentration of GHGs in the atmosphere beyond naturally occurring concentrations, enhancing the greenhouse effect that contributes to the larger process of global climate change. The six primary GHGs are: ● Carbon dioxide (CO2), emitted when solid waste, fossil fuels (oil, natural gas, and coal), and wood and wood products are burned; ● Methane (CH4), produced through the anaerobic decomposition of waste in landfills, animal digestion, decomposition of animal wastes, production and distribution of natural gas and 1 California Climate Action Team, Report to Governor Schwarzenegger and the California Legislature, April 2006 Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-2 Genentech Master Plan Update, Draft EIR petroleum, coal production, incomplete fossil fuel combustion, and water and wastewater treatment; ● Nitrous oxide (N2O), typically generated as a result of soil cultivation practices, particularly the use of commercial and organic fertilizers, fossil fuel combustion, nitric acid production, and biomass burning; ● Hydrofluorocarbons (HFCs), primarily used as refrigerants; ● Perfluorocarbons (PFCs), originally introduced as alternatives to ozone depleting substances and typically emitted as by-products of industrial and manufacturing processes; and ● Sulfur hexafluoride (SF6), primarily used in electrical transmission and distribution. Though there are other contributors to global warming, these six GHGs are identified explicitly by the U.S. Environmental Protection Agency (EPA) as threatening the public health and welfare of current and future generations. 2 GHGs have varying potential to trap heat in the atmosphere, known as global warming potential (GWP), and atmospheric lifetimes. GWPs reflect how long GHGs remain in the atmosphere, on average, and how strongly they absorb energy. Gases with a higher GWP absorb more energy per pound than gases with a lower GWP, and thus contribute more to warming the Earth. In order to facilitate consideration of different greenhouse gases in comparable terms, GWP is alternatively described as carbon dioxide equivalent, or CO2e. Implications of Climate Change Scientific consensus holds that human activity is increasing atmospheric GHG concentrations to levels far above what would be expected given natural variability. These gases are released as byproducts of fossil fuel combustion, waste disposal, energy use, land use changes and other human activities. GHGs, such as CO2, CH4 and N2O, create a “blanket” around the earth that allows light to pass through but traps heat at the surface, preventing its escape into space. While this is a naturally occurring process known as the greenhouse effect, human activities have accelerated the generation of GHGs beyond natural levels. The over-abundance of GHGs in the atmosphere has led to an unexpected warming of the earth and has already started affecting the Earth’s climate system. The Intergovernmental Panel on Climate Change’s Fifth Assessment Report summarizes current scientific understanding of global climate change and projects future climate change using the most comprehensive set of recognized global climate models. As asserted in the Fifth Assessment Report, if trends remain unchanged, continued GHG emissions above current rates will induce further warming changes in the global climate system and pose even greater risks than those currently witnessed.3 State and Local Implications Research suggests that because of climate change, California will experience hotter and drier conditions, reductions in winter snow, an increase in winter rains, sea level rise, significant changes to the water cycle, and an increased occurrence of extreme weather events. Such compounded impacts will affect economic systems throughout the state. The California Climate Adaptation Strategy estimates that failing to take action 2 US EPA, Overview of Greenhouse Gases, accessed at https://www.epa.gov/ghgemissions/overview-greenhouse-gases 3 IPCC, 2014: Climate Change 2014: Synthesis Report, Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland, 151 pp. accessed at http://www.ipcc.ch/report/ar5/syr/ Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-3 to address the potential impacts of climate change will lead to economic losses of “tens of billions of dollars per year in direct costs” and “expose trillions of dollars of assets to collateral risk.”4 Extreme Heat The State of California Climate Action Team Biennial Report5 predicts that higher temperatures will increase in frequency. Higher temperatures can decrease the water supply through increased evaporation rates and irrigation demand, and lead to an increased incidence of wildfires. Extreme heat events also have dramatic human health impacts. Air Quality The warming climate is also predicted to increase ozone levels in California’s major air basins, leading to upwards of 6 to 30 more days per year with ozone concentrations that exceed federal clean air standards. Water Supply The state’s water supply is already under stress and is anticipated to shrink under even the most conservative climate change scenario. Warmer average global temperatures cause more rainfall than snowfall, making the winter snowfall season shorter and accelerating the rate at which the snowpack melts in the spring. The Sierra snowpack is estimated to experience a 25-40% reduction from its current average by 2050. With rain and snow events becoming less predictable and more variable, the rate of flooding could increase and California’s ability to store and transport fresh water for consumption could decrease. Storm Severity Climate change models predict more intense rainfall events, more frequent or extensive runoff, and more frequent and severe flood events. Localized flood events may increase in periods of heavy rain. Although climate change is likely to lead to a drier climate overall, risks from regular, more intense rainfall events can generate more frequent and/or more severe flooding that upsets this managed balance between storage and protection. Additionally, erosion may increase and water quality may decrease because of increased rainfall amounts. Sea Level Rise Sea level rise occurs from rising average ocean temperatures, thermal expansion and melting of snow and ice. While many different climate change effects will affect San Mateo County, sea level rise has been extensively researched and quantified, allowing for a clearer geographic understanding of its effects. The rate and amount of sea level rise will be influenced by rising average temperatures and the speed of melting glacial ice. There is a degree of uncertainty in many projections, and the present rate of sea level rise is faster than many previous projections have estimated. Sea level rise projections for 2100 in the California 4th Climate Change Assessment (California 4th Assessment) range from 14 - 94 inches (36 centimeters - 239 centimeters) with an additional very low probability worst-case estimate that exceeds 9 feet (274 meters).6 4 California Natural Resources Agency, 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008, 2009 5 California Climate Action Team, State of California Climate Action Team Biennial Report, 2009 6 Griggs, G, Árvai, J, Cayan, D, DeConto, R, Fox, J, Fricker, HA, Kopp, RE, Tebaldi, C, Whiteman, EA (California Ocean Protection Council Science Advisory Team Working Group), Rising Seas in California: An Update on Sea-Level Rise Science, California Ocean Science Trust, April 2017. Available online at: http://www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an- update-on-sea-level-rise-science.pdf Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-4 Genentech Master Plan Update, Draft EIR Greenhouse Gas Inventory Bay Area Greenhouse Gas Emission Estimates and Draft Forecasts 7 The Bay Area Air Quality Management District (BAAQMD) reported its first Bay Area regional GHG emissions inventory in 2007, for base year 2002. Since then, it has generally issued updates on a triennial basis. The 2015 update (for base year 2011), included a “business as usual GHG emission forecasts to 2030, identified the need to extend forecasts to 2050, and to represent GHG-reduction rules and policies already in place. The 2017 BAAQMD Greenhouse Gas Emission Estimates and Draft Forecasts report presents a first step toward developing an extended Bay Area GHG emissions forecast that includes existing and anticipated policies. The BAAQMD considers these 2017 estimates and forecasts to be in draft form. Bay Area Emissions The 2017 Emission Estimates and Draft Forecasts report (for base year 2015) identifies an emissions inventory across several different emission sectors, including transportation, industrial, electricity and cogeneration, commercial and residential , recycling and waste, agriculture and farming, and high GWP gases. The 2017 Emission Estimates and Draft Forecasts report found that the Bay Area’s GHG emissions in 2015 total about 85 million metric tons of carbon dioxide-equivalents (MMTCO2e). Emissions from the seven emission sectors include: ● transportation (on-road and off-road sources), about 41% ● industrial (mostly refineries, natural gas combustion and cement plants), about 26% ● electricity and cogeneration (including both direct combustion and electricity imports), about 14%, ● commercial and residential (mostly fuel combustion for heating and cooking), about 11% ● high GWP gases, about 4% ● recycling and waste facilities, about 3% and ● agriculture and farming operations, about 1% Forecasts A major finding of the 2017 Emission Estimates and Draft Forecasts report is that, with committed and expected policies in place, the Bay Area is not likely to meet the goal of reducing regional GHG emissions to 1990 levels by 2020. The Bay Area’s 1990 GHG emissions were about 72 MMTCO₂e, whereas these projections indicate that total Bay Area emission will be about 80 MMTCO₂e in 2020. In contrast, State projections suggest that California, as a whole, is on track to meet its 2020 GHG goal. This is because the average rate of GHG reduction needed to meet the 2020 target is greater for the Bay Area than for California. The State’s 2020 goal is 431 MMTCO₂e, and the latest statewide estimate (from 2014) of 2020 emissions is 442 MMTCO₂. To reach the 2020 goal, California as a whole must reduce its GHG emissions by about 2 to 3% over the next several years. For the Bay Area only, a 10% reduction from present day (2015) emissions is needed to reach 1990 levels. 7 Bay Area Air Quality Management District, Greenhouse Gas Emission Estimates and Draft Forecasts, DRAFT v2017-Q1, March 2017 Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-5 City of South San Francisco 2005 Baseline Emissions The City of South San Francisco Climate Action Plan (CAP)8 includes an inventory of all major sources of GHGs caused by activities in the jurisdictional boundary of the city, consistent with the methodology recommended by the California Air Resources Board (CARB),9 ICLEI-Local Governments for Sustainability,10 and the Bay Area Air Quality Management District (BAAQMD).11 The Inventory analyzes the following emissions sources: ● Energy: Electricity and natural gas used by residential and nonresidential buildings in South San Francisco ● Transportation: Vehicle miles traveled (VMT) within and to/from the community by on-road vehicles, as well as trips to and from the South San Francisco BART and Caltrain commuter rail stations ● Solid Waste: Methane emissions from the decomposition of waste sent to landfills from South San Francisco ● Landfills: Direct emissions from the Oyster Point Landfill, which is no longer operational but continues to release methane emissions ● Water and Wastewater: The amount of energy required to extract, filter, move and treat all water used by, as well as the wastewater produced in South San Francisco. This sector also includes direct methane emissions caused by the treatment of South San Francisco's wastewater at the South San Francisco/San Bruno Water Quality Control Plant located within the community ● Stationary Sources: Direct emissions from large, stationary, fixed emitters of GHGs permitted by the BAAQMD ● Off-Road: Emissions from construction and lawn & garden equipment and vehicles The 2005 community-wide baseline inventory indicates that the City of South San Francisco emitted 548,600 metric tons of carbon dioxide equivalent (MTC02e) in 2005. Energy use was the single largest source of emissions, responsible for about 47% of the community total. Emissions from transportation were the second-largest category, responsible for about 45% of community-wide emissions. Off-road emissions accounted for 5%, emissions from solid waste account for 3%, landfills 2%, and water and wastewater less than 1 %. For purposes of the CAP, stationary sources, direct landfill emissions and energy use at the Genentech Campus were excluded from this inventory, resulting in community-wide GHG emissions of 442,400 MTCO2e. Stationary sources and direct landfill emissions were excluded because they are regulated by BAAQMD and CARB. The Genentech Campus was also excluded as a stationary emitter that CARB regulates through California’s Cap-and-Trade program.12 8 City Of South San Francisco, Climate Action Plan, February 2014 9 CoolCalifornai.org, Local Government Toolkit, accessed at http://www.coolcalifornia.org/local-government 10 ICLEI _ Local Governments for Sustainability USA, 2009, City of South San Francisco 2005 Government Operations Greenhouse Gas Emissions Inventory, accessed at http://ca- southsanfrancisco.civicplus.co/DocumentsCenter/Home/View/2473 11 BAAQMD, accessed at http://www.baaqmd.gov/plans-and-climate/climate-protection/local-government- support 12 City of South San Francisco, Climate Action Plan, February 2014, page ES1 Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-6 Genentech Master Plan Update, Draft EIR Emissions Forecast The SSF CAP includes a GHG emissions forecast of future GHG emissions for the community based on anticipated changes in population, number of households, employment, driving behavior and other activities. The forecast focuses on two target years: 2020 and 2035. Year 2020 is used for consistency with the targets of AB 32, and year 2035 was chosen for consistency with SB 375. Under a business-as-usual (BAU) scenario, assuming there will be no influence on GHG emissions from local, state, or federal reduction efforts, GHG emissions are projected to grow to 11% above the 2005 baseline (to 491,310 MTCO2e) by year 2020, and to 24% above baseline (or 550,540 MTCO2e) by 2035. An adjusted business-as-usual (ABAU) forecast was also prepared in the SSF CAP, including a number of reduction programs implemented by the State. This scenario presents a more realistic estimate of South San Francisco's future emissions. State actions assessed in the CAP include the following: ● California's Renewables Portfolio Standard (RPS): One of the most ambitious renewable energy standards in the country, RPS mandates that 33% of electricity delivered in California be generated by renewable sources like solar, wind, and geothermal by 2020. ● AB 1493 (Pavley) Vehicle Standards: California's Pavley regulations, established by AB 1493 in 2002, require new passenger vehicles to reduce tailpipe GHG emissions from 2009 to 2020. ● Executive Order S-01-07, Low Carbon Fuel Standard: Beyond including vehicle efficiency improvements through AB 1439, CARB developed a Low Carbon Fuel Standard (LCFS) to reduce the carbon intensity of transportation fuels. Under the BAAQMD's guidance, the LCFS is likely to reduce emissions by at least 7.2%. ● Title 24, Energy Efficiency Standards: Title 24 is a state standard, implemented at the local level by city and county agencies through project review, to increase energy efficiency in new buildings. The energy reductions quantified in the forecast are the mandatory improvements over the 2005 Title 24 code established in 2008. In order to achieve the State-recommended AB 32 reduction target of 15% below 2005 emissions levels by 2020, these statewide actions are not sufficient. As indicated in the CAP, the City will need to continue implementation of existing programs and implement additional goals, policies and actions. The additional actions in the CAP build upon existing efforts and provide a diverse mix of regulatory and incentive-based programs for both new and existing development. The reduction measures also aim to reduce GHG emissions from each emission source to avoid reliance on any one strategy or sector to achieve the target. In total, the state actions plus the GHG reduction measures identified in the CAP are forecast to reduce GHG emissions in South San Francisco by 116,040 MTC02e by 2020 (a 15% reduction below 2005 baseline emissions). Local actions are projected to contribute approximately 40% of the 2020 reductions, while state actions are projected to contribute approximately 60% of 2020 reductions. Existing programs initiated after 2005 will contribute approximately 22% of total local reductions necessary to achieve the AB 32 reduction target. Such projects include municipal energy efficiency retrofits, the City's Transportation Demand Management (TDM) program and community-wide solar installations. Additional measures created under the CAP will be implemented through new and existing programs. In total, existing actions, state programs, and GHG reduction measures in the CAP were estimated to reduce GHG emissions in the City of South San Francisco by 116,040 MTC02e by 2020 (thus achieving the AB 32 target of a 15% emissions reduction below baseline 2005 levels by 2020), and to reduce GHG emissions by 191,540 MTC02e by 2035. Achievement of a 15% reduction in GHG emissions by 2020 will also achieve state recommendations and BAAQMD threshold requirements for developing a Qualified GHG Reduction Strategy. The CAP indicates that, through the implementation of the CAP strategies and programs, South San Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-7 Francisco's per capita GHG emissions will decrease from 4.66 MTC02e annually in 2005, to 3.49 MTC02e annually in 2020, and 3.07 MTC02e annually in 2035.13 The City’s CAP also specifies those measures within the CAP that are applicable to new construction projects in order to demonstrate compliance with GHG emission reduction strategies, and to determine whether a project's GHG emissions are less than significant. To ensure that each new construction project complies with the CAP, the CAP Appendix includes a checklist to be submitted by applicants for each new development project. Genentech GHG Emissions In 2006, Genentech voluntarily joined the California Climate Action Registry and became a participant in the California Cap-and-Trade Program, and was among the first bio-pharmaceutical companies to do so.14 Pursuant to the California Global Warming Solutions Act of 2006 (AB 32), participation in the Program requires annual reporting of GHG emissions by major sources. All GHG emissions data reports must comply with the regulatory requirements. The California Air Resources Board (CARB) implements and oversees a third-party verification program to support the mandatory GHG reporting. All GHG reports subject to the Cap-and-Trade Program must be independently verified by CARB-accredited verification bodies and verifiers. A summary of reported GHG emissions data reported under the mandatory reporting requirements is made public each year, and the data is used by the Cap-and-Trade Program and included in California Greenhouse Gas Inventory. The following Table 10-1 provides a year-by-year summary of GHG emissions from the Genentech South San Francisco Campus, beginning in 2010 and as reported to CARB. The data in this table represent direct stationary-source GHG emissions resulting from the combustion of fossil fuels, chemical and physical processes, vented emissions, geothermal emissions, and emissions from suppliers of carbon dioxide, and also includes CH4 and N2O emissions (converted to CO2e using global warming potentials) from biogenic fuel combustion. Table 10-1: Genentech SSF Campus GHG Emissions Reporting Data (to California Air Resources Board) Year CARB Calculated Covered Emissions (metric tons CO2e) Percent Reduction in Emissions (as compared to 2010) 2010 37,654 2011 36,384 -3.3% 2012 35,531 -5.6% 2013 35,459 -5.8% 2014 31,224 -17.1% 2015 31,057 -17.5% 2016 31,437 -16.5% Source: https://ww2.arb.ca.gov/our-work/programs/mandatory-greenhouse-gas-emissions-reporting/data 13 Ibid, page ES7 14 Genentech, Genentech 2007 Corporate Sustainability Report, page 1 Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-8 Genentech Master Plan Update, Draft EIR The GHG emissions presented above represent emissions from those stationary-source facilities that are subject to the mandatory reporting requirements of CARB, and do not include all GHG emissions sources, such as mobile sources. Genentech also publishes an annual Corporate Sustainability Report, which includes Genentech sustainability data of corporate-wide GHG emissions. However, data presented in the Sustainability report includes emissions from production and finish facilities in South San Francisco, Vacaville and Oceanside, California, and Hillsboro, Oregon, as well as from research, development, commercial and administrative offices at the South San Francisco headquarters and the Louisville, Kentucky distribution facility. Because this publicly available data is not specific to the Project site in SSF, it is not presented herein. Regulatory Setting Federal Regulations Global Change Research Act (1990) In 1990, Congress passed and President George H.W. Bush signed Public Law 101-606, the Global Change Research Act. The purpose of the legislation was to: “. . . Require the establishment of a United States Global Change Research Program aimed at understanding and responding to global change, including the cumulative effects of human activities and natural processes on the environment, to promote discussions towards international protocols in global change research, and for other purposes.” To that end, the Global Change Research Information Office was established in 1991 (it began formal operation in 1993) to serve as a clearinghouse of information. The Act requires a report to Congress every four years on the environmental, economic, health and safety consequences of climate change; however, the first and only one of these reports to date, the National Assessment on Climate Change, was not published until 2000. In February 2004, operational responsibility for the Global Change Research Information Office shifted to the U.S. Climate Change Science Program. GHG Emissions pursuant to the Clean Air Act (2007) On April 2, 2007, in Massachusetts v. EPA, 549 U.S. 497, the Supreme Court found that GHGs are air pollutants covered by the Clean Air Act. The Court held that the Administrator must determine whether emissions of GHGs from new motor vehicles cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. On December 7, 2009, Administrator Lisa Jackson signed a final action, under Section 202(a) of the Clean Air Act, finding that six key well-mixed GHGs constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to the climate change problem. This action was a prerequisite for implementing GHG emissions standards. Current efforts include issuing GHG emission standards for new motor vehicles, developing and implementing renewable fuel standard program regulations, proposing carbon pollution standards for new power plants, setting GHG emissions thresholds to define when permits are required for new and existing industrial facilities under the Clean Air Act, and establishing a GHG reporting program. Energy Independence and Security Act (2007) The Energy Independence and Security Act of 2007 were intended to move the U.S. toward greater energy independence and security. This energy bill increases the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel in Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-9 2022. It also tightens the Corporate Average Fuel Economy standards that regulate the average fuel economy in the vehicles produced by each major automaker. National Fuel Efficiency Policy Standards On May 7, 2010, the U.S. Department of Transportation and EPA jointly issued national fuel efficiency and GHG emissions standards for model year 2012-2016 passenger vehicles and light duty trucks. The National Highway Traffic Safety Administration (NHTSA) issued Corporate Average Fuel Economy (CAFÉ) standards for model year 2012-2016 passenger cars and light trucks under the Energy Policy and Conservation Act and Energy Independence and Security Act and EPA issued national GHG emissions standards under the federal Clean Air Act. These joint GHG and fuel economy standards represented the first phase of the national program to improve fuel economy and reduce GHG emissions from U.S. light-duty vehicles. Starting with 2012 model year vehicles, the rules require automakers to improve fleet-wide fuel economy and reduce fleet-wide GHG emissions by approximately five percent every year. When adopted, these regulations were expected to result in a 2016 fleet average of 35.5 miles per gallon (mpg), conserve about 1.8 billion barrels of oil and reduce nearly 1 billion tons of GHG emissions over the lives of the vehicles covered. In 2012, NHTSA established final passenger car and light truck CAFE standards for model year 2017 through model year 2021. Those CAFE standards required, on an average industry fleet-wide basis for cars and trucks combined, 40.3 to 41 mpg in model year 2021. EPA’s GHG standards, which were consistent with NHTSA’s CAFE standards, were projected to require 163 grams/mile of CO2 in model year 2025. On August 28, 2014, EPA and NHTSA finalized the new national program that would reduce GHG emissions and improve fuel economy for all new cars and trucks sold in the U.S. EPA proposed the first-ever national GHG emissions standards under the Clean Air Act, and NHTSA proposed CAFE standards under the Energy Policy and Conservation Act. This national program allows automobile manufacturers to build a single light- duty national fleet that satisfies all requirements under both federal programs and the standards of California and other states. This program is expected to increase fuel economy to the equivalent of 54.5 miles per gallon for cars and light-duty trucks by model year 2025. In October 2016, the EPA and NHTSA, on behalf of the Department of Transportation, established rules for a comprehensive Phase 2, Heavy-Duty (HD) national program to reduce GHG emissions and fuel consumption from new on-road medium- and heavy-duty vehicles and engines. This Phase 2 program is expected to result in fuel reductions of between 71 and 83 billion gallons, and achieve GHG reductions of between 959 and 1,098 MMT, CO2eq.15 Promoting Energy Independence and Economic Growth (2017) 16 On March 28, 2017, President Trump signed an Executive Order stating that it is the policy of the United States that: “Executive departments and agencies (agencies) immediately review existing regulations that potentially burden the development or use of domestically produced energy resources, and appropriately suspend, revise, or rescind those that unduly burden the development of domestic energy resources beyond the degree necessary to protect the public interest or otherwise comply with the law.” The Order requires the heads of agencies to review all existing regulations, orders, guidance documents, policies and any other similar agency actions that potentially burden the development or use of domestically produced energy resources, with particular attention to oil, natural gas, coal, and nuclear energy resources. 15 Federal Register / Vol. 81, No. 206 / Tuesday, October 25, 2016 / Rules and Regulations 16 https://www.whitehouse.gov/presidential-actions/presidential-executive-order-promoting-energy-independence- economic-growth/ Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-10 Genentech Master Plan Update, Draft EIR Such review shall not include agency actions that are mandated by law, necessary for the public interest, and consistent with the Order. This Executive Order also rescinds certain energy and climate-related Presidential and regulatory actions and reports, including: ● Executive Order 13653 of November 1, 2013 (Preparing the United States for the Impacts of Climate Change) ● the Presidential Memorandum of June 25, 2013 (Power Sector Carbon Pollution Standards) ● the Presidential Memorandum of November 3, 2015 (Mitigating Impacts on Natural Resources from Development and Encouraging Related Private Investment) ● the Presidential Memorandum of September 21, 2016 (Climate Change and National Security) ● the Report of the Executive Office of the President of June 2013 (The President's Climate Action Plan), and ● the Report of the Executive Office of the President of March 2014 (Climate Action Plan Strategy to Reduce Methane Emissions) The Order also calls on the Council on Environmental Quality to rescind its final guidance entitled "Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews" (81 Fed. Reg. 51866, August 5, 2016). State Plans and Regulations – GHG Emissions Assembly Bill 1493 - Pavley (2002, et.seq) Assembly Bill (AB) 1493 (Pavley) amended Health and Safety Code sections 42823 and 43018.5 requiring CARB to develop and adopt regulations that achieve maximum feasible and cost-effective reduction of GHG emissions from passenger vehicles, light-duty trucks, and other vehicles used for noncommercial personal transportation in California. The regulations prescribed by AB 1493 of 2002 took effect on January 1, 2006, and apply only to 2009 and later model year motor vehicles. In September 2004, pursuant to AB 1493, CARB approved regulations to reduce GHG emissions from new motor vehicles. Under the new regulations, one manufacturer fleet average emission standard is established for passenger cars and the lightest trucks, and a separate manufacturer fleet average emission standard is established for heavier trucks. The regulations took effect on January 1, 2006 and set near-term emission standards, phased in from 2009 through 2012, and mid-term emission standards, to be phased in from 2013 through 2016 (referred to as the Pavley Phase 1 rules). For model year 2017 through 2025, CARB has adopted the National Fuel Efficiency Policy standards as previously described. Executive Order S-3-05 (June 2005) Executive Order S-3-05 was signed on June 1, 2005. The Order recognizes California’s vulnerability to climate change, noting that increasing temperatures could potentially reduce snowpack in the Sierra Nevada, which is a primary source of the State’s water supply. Additionally, according to this Order, climate change could influence human health, coastal habitats, microclimates and agricultural yield. The Order set the GHG reduction targets for California: by 2010, reduce GHG emissions to 2000 levels; by 2020 reduce GHG emissions to 1990 levels; by 2050 reduce GHG emissions to 80 percent below 1990 levels. The Order directs the Secretary of the California Environmental Protection Agency to coordinate oversight of efforts made to achieve these targets with other state agencies and, like all executive orders, the Order has no binding legal effect on regional agencies, which are outside of the California Executive Branch. Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-11 AB 32, California Global Warming Solutions Act of (2006, et.seq) AB 32, the California Global Warming Solutions Act (Health and Safety Code Section 38500 et seq.), was signed in September 2006. The Act requires the reduction of statewide GHG emissions to 1990 levels by the year 2020. This change, which is estimated to be a 25 to 35 percent reduction from current emission levels, will be accomplished through an enforceable statewide cap on GHG emissions that was phased in starting in 2012. The Act also directs CARB to develop and implement regulations to reduce statewide GHG emissions from stationary sources and address GHG emissions from vehicles. CARB has stated that the regulatory requirements for stationary sources will be first applied to electricity power generation and utilities, petrochemical refining, cement manufacturing, and industrial/commercial combustion. The second group of target industries will include oil and gas production/distribution, transportation, landfills and other GHG- intensive industrial processes. Climate Change Scoping Plan (2008, et.seq) On December 11, 2008, CARB adopted its Climate Change Scoping Plan (Scoping Plan), which functions as a roadmap of CARB’s plans to achieve GHG reductions in California required by AB 32 through subsequently enacted regulations.17 The Scoping Plan contains the main strategies California will implement to reduce CO2e emissions by 174 million metric tons, or approximately 30 percent, from the State’s projected 2020 emissions level of 596 MMTCO2e under a business as usual scenario. The Scoping Plan also breaks down the amount of GHG emissions reductions the CARB recommends for each emissions sector of the State’s GHG inventory. The Scoping Plan’s recommended measures were developed to reduce GHG emissions from key sources and activities while improving public health, promoting a cleaner environment, preserving natural resources, and ensuring that the impacts of the reductions are equitable and do not disproportionately impact low-income and minority communities. These measures also put the State on a path to meet the long- term goal of reducing California’s GHG emissions by 2050 to 80 percent below 1990 levels. In May 2014, ARB released the First Update to the Climate Change Scoping Plan to identify the next steps in reaching AB 32 goals and evaluate the progress that has been made between 2000 and 2012. According to the update, California was on track to meet the near-term 2020 GHG limit, and was well positioned to maintain and continue reductions beyond 2020. On January 20, 2017, ARB released its Draft 2017 Climate Change Scoping Plan Update (2017 Draft Scoping Plan Update), which lays out the framework for achieving the 2030 reductions as established in EO B-30-15, SB 32, and AB 197 (as of this writing, the Plan has not been finalized). The 2017 Draft Scoping Plan Update identifies the GHG reductions needed by emissions sector to achieve a statewide emissions level that is 40 percent below 1990 levels before 2030. Many of the programs require statewide action, promulgated through regulation, and are outside the ability of sub-state jurisdictions to implement on their own accord. This is important to recognize in terms of GHG emissions efficiency and attaining GHG targets. The ability to attain targets will not only rely on transportation strategies, (e.g., the CTP), but also on land use strategies implemented by local cities and counties (e.g., qualified GHG reduction plans) and controls and actions tied to economy-wide changes promulgated by the State. Examples listed in the 2017 Draft Scoping Plan Update include: ● reliance on SB 350 targets of providing 50 percent of the State’s electricity via renewable resources (this is largely accomplished by actions of utilities); ● attaining 18 percent reduction in carbon intensity of fuels (Low Carbon Fuel Standard); ● vehicle fleet mix that includes 4.2 million zero-emission vehicles (ZEV) by 2030 and similar changes in urban buses and light- and heavy-duty trucks; 17 California Air Resource Board, AB 32 Scoping Plan, accessed at https://www.arb.ca.gov/cc/scopingplan/scopingplan.htm Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-12 Genentech Master Plan Update, Draft EIR ● regulations that reduce short-lived GHGs; ● deployment of 100,000 ZEV freight vehicles by 2030; ● reduction of refinery GHG emissions by 20 percent; ● continuation (past 2020) of the Cap- and Trade-Program; and ● reduction in VMT by implementation of SB 375 and other strategies intended to reduce VMT Some of these programs have already been initiated and others will require legislative or regulatory action by the State. In addition, the 2017 Draft Scoping Plan states that local governments (e.g., cities and counties) play an important role in achieving the State’s long-term GHG goals because they have broad influence, and sometimes-exclusive authority, over activities that enable or thwart uptake of policies that contribute to significant direct and indirect GHG emissions. These actions include community-scale planning and permitting processes, discretionary actions, local codes and ordinances, outreach and education efforts, and municipal operations. ARB states that, to achieve the 2030 target, local governments are essential partners. Their action is required to complement and support State-level actions. ARB also acknowledges that without land use decisions from local governments that allow efficient use and management of land use, longer-term targets cannot be met. ARB recommends that local jurisdictions develop sufficiently detailed and adequately supported GHG reduction plans (including climate action plans [CAPs]) that look holistically at GHG emissions and local strategies to support statewide limits. Cap and Trade California's cap-and-trade program was designed by the California Air Resources Board (CARB), beginning in 2013.18 Cap and trade is a market-based approach to reduce GHG emissions and identified in the AB 32 Scoping Plan as a way to achieve California's desired reductions. Cap and Trade enables industrial emitters to reduce overall emissions by investing in cleaner fuels and energy efficiencies. Under the cap-and-trade program, enforceable limits are set on the amount of emissions that can be produced by large industrial emitters (known as a "cap"), which is gradually reduced over time. Each emitter receives permits for the emissions allowable under their cap. Emitters that do not use all their permits can auction them off to other emitters (“trade”), who can use the additional permits to exceed their cap. CARB collects revenue from the permit auctions, and uses this revenue to invest in offsetting projects that result in reductions in greenhouse gas emissions. CARB has conducted 17 quarterly cap-and trade auctions since November 2012 generating roughly $4.4 billion in state revenue.19 Several pieces of legislation seek to guide revenue from the cap-and-trade program toward efforts to reduce pollution in disproportionately impacted communities. One such example is the California Global Solutions Act of 2006 Greenhouse Gas Reduction Fund (AB 1532). This Act requires administering agencies to allocate funds from the cap-and-trade program to those measures that meet specific criteria, and that are implemented in areas in close proximity to sources that produce toxic levels of air pollution. Measures are to be implemented in areas with an elevated concentration of people who experience low income, high unemployment, low levels of homeownership, high costs of rent and other socioeconomic challenges. The Climate Action Reserve20 (previously the California Climate Action Registry or California Registry) has developed standardized GHG reduction project protocols, serving as a registry for GHG reduction projects, and tracking GHG offsets through a publicly accessible database. The California Environmental Quality Act 18 California Air Resources Board, Cap and trade Program, accessed at https://www.arb.ca.gov/cc/capandtrade/capandtrade.htm 19 California Legislative Analyst’s Office, The 2017-18 Budget: Cap-and-Trade, February 2017, accessed at www.lao.ca.gov/reports/2017/3553/cap-and-trade-021317.pdf 20 Accessed at http://www.climateactionreserve.org/ Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-13 (CEQA) GHG Mitigation Registry, a regional component of the Climate Action Reserve Voluntary GHG Mitigation Registry, enables companies and organizations to invest proactively in projects that will reduce greenhouse gas emissions forecasted to occur, once the projects are fully implemented. It provides a trusted and transparent resource for companies (such as Genentech), organizations, land developers, manufacturing facilities and other large projects, to reduce their carbon footprints in a responsible, consistent and accountable manner. The CEQA GHG Mitigation Registry also enables programs and projects to utilize real, permanent emissions reductions with a high level of environmental integrity. By investing in standardized and conservative quantification methodologies vetted by public and private stakeholders and approved by the Climate Action Reserve, companies and organizations can be issued high quality credits to reflect the mitigation measures implemented.21 Senate Bill 1368 (2006) SB 1368, signed in September 2006, required the California Public Utilities Commission (CPUC) to establish a GHG emissions performance standard for “baseload” generation from investor owned utilities by February 1, 2007. The California Energy Commission (CEC) was required to establish a similar standard for local publicly owned utilities by June 30, 2007. The legislation further required that all electricity provided to California, including imported electricity, must be generated from plants that meet or exceed the standards set by the CPUC and the CEC. In January 2007, the CPUC adopted an interim performance standard for new long-term commitments (1,100 pounds of CO2 per megawatt-hour), and in May 2007, the CEC approved regulations that match the CPUC standard. Executive Order S-01-07, Low Carbon Fuels Standards (January 2007) In January 2007, Executive Order S-01-07 established a Low-Carbon Fuel Standard. The Order calls for a statewide goal to be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020 (2020 Target), and that a LCFS for transportation fuels be established for California. Further, it directs the CARB to determine if an LCFS can be adopted as a discrete early action measure pursuant to AB 32 and if so, to consider the adoption of an LCFS on the list of early action measures required to be identified by June 30, 2007, pursuant to Health and Safety Code Section 38560.5. The LCFS applies to all refiners, blenders, producers or importers (providers) of transportation fuels in California, will be measured on a full fuels cycle basis, and may be met through market-based methods by which providers exceeding the performance required by an LCFS shall receive credits that may be applied to future obligations or traded to providers not meeting the LCFS. In June 2007, the CARB approved the LCFS as a Discrete Early Action item under AB 32 and in April 2009, the CARB approved the new rules and reference values for carbon intensity, with the new regulatory requirements taking effect in January 2011. The standards require providers of transportation fuels to report on the mix of fuels that they provide and demonstrate that they meet the LCFS intensity standards annually. This is accomplished by ensuring that the number of “credits” earned by providing fuels with a lower carbon intensity than the established baseline (or obtained from another party) is equal to or greater than the “deficits” earned from selling higher intensity fuels. In December 2011, the U.S. District Court for the Eastern District of California issued three rulings against the LCFS including a requirement for CARB to abstain from enforcing the LCFS. In April 2012, the Ninth Circuit granted CARB’s motion for a stay of the injunction while it continues to consider CARB’s appeal of the lower court’s decision. 21 http://www.climateactionreserve.org/ceqa-mitigation-registry/ Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-14 Genentech Master Plan Update, Draft EIR Senate Bill 375 (Chapter 728, Statutes of 2008) SB 375, adopted September 30, 2008 helps meet the AB 32 goals of reducing emissions from cars and light duty trucks. SB 375 requires regional planning agencies to include a Sustainable Communities Strategy (SCS) in their Regional Transportation Plan (RTP) that demonstrates how the region could achieve GHG emissions reductions set by CARB through integrated land use and transportation planning. Local governments retain control of land use planning authority; however, SB 375 amended CEQA (Public Resources Code § 21000 et seq.) to ease environmental review of specific types of developments that are anticipated to reduce emissions. Plan Bay Area 2040 is the most recent integrated SCS and RTP for the San Francisco Bay Area, consistent with SB 375. Executive Order S-13-08 (2008) Governor Schwarzenegger signed California Executive Order S-13-08 on November 14, 2008, to address the potential impacts of global climate change, including sea level rise. The order emphasizes the need for timely planning to mitigate and adapt to the potential effects of sea level rise on the State’s resources. As a result, any State agency planning construction projects in areas vulnerable to future sea level rise must evaluate and reduce the potential risks and increase resiliency, to the extent feasible. Planning must consider a range of sea level rise scenarios for 2050 and 2100. Executive Order B-16-2012 (2012) Executive Order B-16-2012 directs State entities to support and facilitate the rapid commercialization of zero- emission vehicles. The order outlines benchmarks for 2015, 2020, and 2025 related to establishing infrastructure to support and accommodate zero-emission vehicles, helping get zero-emission vehicles to market and on the road, and increasing their use for public transportation and public use, among others. It also establishes a goal of an 80 percent reduction of GHG emissions from the transportation sector in California as compared to 1990 levels by 2050. This Executive Order also explicitly states that it “is not intended to, and does not create any rights or benefits, substantive or procedural, enforceable at law or in equity, against the State of California, its agencies, departments, entities, officers, employees, or any other person.” Executive Order B-30-15 (2015) On April 20, 2015, Governor Edmund G. Brown Jr. signed Executive Order B-30-15 to establish a California GHG reduction target of 40 percent below 1990 levels by 2030. The Governor’s executive order aligns California’s GHG reduction targets with those of leading international governments such as the 28-nation European Union, which adopted the same target in October 2014. California’s new emission reduction target of 40 percent below 1990 levels by 2030 will make it possible to reach the ultimate goal of reducing emissions 80 percent under 1990 levels by 2050. This is in line with the scientifically established levels needed in the U.S. to limit global warming below 2 degrees Celsius —the warming threshold at which there will likely be major climate disruptions such as super droughts and rising sea levels according to scientific consensus. SB 32 legislatively implements the targets in this executive order. SB 32 (2016) On September 8, 2016, Governor Brown approved SB 32 (Pavley, Chapter 249, Statutes of 2016), which added a 2030 target to the Global Warming Solutions Act of 2006. SB 32 requires that statewide GHG emissions be reduced to 40 percent below 1990 levels by 2030. This bill was tied to passage of a companion bill, AB 197. Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-15 Assembly Bill 197 Governor Brown signed AB 197 (Garcia, Chapter 250, Statutes of 2016) on September 8, 2016. AB 197 creates a legislative committee to oversee ARB and requires ARB to take specific actions when adopting plans and regulations pursuant to SB 32 related to disadvantaged communities, identification of specific information regarding reduction measures, and information regarding existing greenhouse gases at the local level. Senate Bill No. 100 SB 100 was approved by the Governor in September 2018. This bill revises previous legislation regarding renewable resource targets. Under this new legislation, retail sellers and local publicly owned electric utilities must procure a minimum quantity of electricity products from eligible renewable energy resources so that the total kilowatt hours of those products sold to their retail end-use customers achieve 44% of retail sales by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030. This bill also states the policy goal if for eligible renewable energy resources and zero-carbon resources to supply 100% of retail sales of electricity to California end-use customers, and 100% of electricity procured to serve all state agencies by December 31, 2045. State Plans and Regulations – Sea Level Rise California Climate Adaptation Strategy (2009) In response to EO S-13-08, the California Natural Resources Agency released the California Climate Adaptation Strategy in 2009.22 The strategy proposes a comprehensive set of recommendations designed to inform and guide State agencies in their decision-making processes as they begin to develop policies to protect the State, its residents, and its resources from a range of climate change impacts, including sea level rise. The Climate Adaptation Strategy presents recommendations for seven sectors, including Ocean and Coastal Resources and Transportation and Energy Infrastructure. Climate Adaptation Strategy recommendations specific to Ocean and Coastal Resources emphasize hazard avoidance, adaptation planning, and collaboration with local governments to address sea level rise. The Climate Adaptation Strategy directs State agencies, in general, not to plan, develop or build any new significant structure in a location requiring significant protection from sea level rise, storm surges or coastal erosion during the expected life of the structure. The strategy notes that the most risk-averse approach for minimizing the adverse effects of sea level rise and storm activities is to carefully consider new development within areas vulnerable to inundation and erosion. The Climate Adaptation Strategy also recommends that all State agencies prepare sea level rise adaptation plans, guidance and criteria, as appropriate. The strategy directs State agencies to coordinate with any other agencies with jurisdiction over the coastal zone, (e.g., BCDC, the California Coastal Commission), local governments and regional organizations on regional adaptation planning. The Climate Adaptation Strategy also recommends that State agencies encourage local governments to adopt policies on setbacks, buffer areas, clustered coastal development and engineering solutions, among others. State of California Sea Level Rise Guidance Document (2012 et.seq) EO S-13-08 directs the California Natural Resources Agency, in coordination with other state agencies and the National Academy of Sciences, to assess sea level rise (SLR) for the Pacific Coast and create official sea level rise estimates for state agencies in California, Oregon and Washington. The assessment and official estimates are provided within the State of California Sea-Level Rise Guidance Document. 22 California Natural Resources Agency California Climate Change, Climate Adaptation Strategy, accessed at http://www.climatechange.ca.gov/adaptation/strategy/index.html Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-16 Genentech Master Plan Update, Draft EIR The State of California Sea Level Rise Interim Guidance Document contains eight recommendations for incorporating sea level rise into project planning: ● use the ranges of SLR presented in the June 2012 National Research Council report on Sea Level Rise for the Coasts of California, Oregon, and Washington as a starting place and select SLR values based on agency and context-specific considerations of risk tolerance and adaptive capacity; ● consider timeframes, adaptive capacity, and risk tolerance when selecting estimates of SLR; ● consider storms and other extreme events; ● coordinate with other state agencies when selecting values of SLR and, where appropriate and feasible, use the same projections of SLR; ● future SLR projections should not be based on linear extrapolation of historic sea level observations; ● consider changing shorelines; ● consider predictions in tectonic activity; and ● consider trends in relative local mean sea level The interim guidance document is expected to be updated regularly, to keep pace with scientific advances associated with sea level rise. In March 2013, the California Ocean Protection Council (OPC) presented an update to the State of California Sea Level Rise Guidance Document.23 The purpose of the SLR Guidance was updated to include the best current science, as summarized in the final report from the National Academy of Sciences. Specifically, the 2013 update provides information and recommendations to enhance consistency across agencies in development of approaches to sea-level rise. Although the estimates of future sea level rise were intended to enhance consistency across California state agencies, the document is not intended to prescribe that all state agencies use specific or identical estimates of sea-level rise as part of their assessments or decisions. The underlying premise of the SLR Guidance is that sea level rise potentially will cause many harmful economic, ecological, physical and social impacts and that incorporating sea level rise into agency decisions can help mitigate some of these potential impacts. State Plans and Regulations – Energy Efficiency Title 24, California’s Energy Efficiency Standards (1978, et.seq) Known by the shorthand name of Title 24, the Building Energy Efficiency Standards were first adopted in 1976 and have been updated periodically since then. The Standards contain energy and water efficiency requirements (and indoor air quality requirements) for newly constructed buildings, additions to existing buildings, and alterations to existing buildings. Public Resources Code Sections 25402 subdivisions (a)-(b) and 25402.1 emphasize the importance of building design and construction flexibility by requiring the Energy Commission to establish performance standards, in the form of an “energy budget” in terms of the energy consumption per square foot of floor space. For this reason, the Standards include both a prescriptive option, allowing builders to comply by using methods known to be efficient, and a performance option, allowing builders complete freedom in their designs provided the building achieve the same overall efficiency as an equivalent building using the prescriptive option. Reference Appendices are adopted along with the Standards that contain data and other information that helps builders comply with the Standards. 23 State of California Ocean Protection Council (OPC), State of California Sea-Level Rise Guidance Document, accessed at http://www.opc.ca.gov/2013/04/update-to-the-sea-level-rise-guidance-document/ Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-17 The 2008 update of the Standards incorporated AB 32 mandates, and advanced energy efficiency requirements to meet California’s energy needs. Several State energy policy goals drive the design of the Standards, including: ● the “Loading Order,” which directs California’s growing demand must first be met with cost-effective energy efficiency ● “Zero Net Energy” goals for new homes by 2020 and commercial buildings by 2030 ● Governor Brown’s Executive Order on Green Buildings ● the Green Building Standards Code, and ● AB 32 The 2016 update to the Building Energy Efficiency Standards focuses on several key areas to improve the energy efficiency of newly constructed buildings and additions and alterations to existing buildings. The most significant efficiency improvements to the non-residential Standards include alignment with the ASHRAE 90.1 2013 national standards. New efficiency requirements for elevators and direct digital controls are included in the nonresidential Standards. Public Resources Code Section 25402.1 also requires the Energy Commission to support the performance standards with compliance tools for builders and building designers. The Alternative Calculation Method (ACM) Approval Manual establishes requirements for input, output and calculation uniformity to demonstrate compliance with the Standards. The Standards are divided into three basic sets; 1) the basic set of mandatory requirements that apply to all buildings, 2) a set of performance standards that vary by climate zone and building type, and 3) an alternative to the performance standards that provide a checklist compliance approach. The California Energy Commission completed a study of the environmental impacts of the 2016 Building Energy Efficiency Standards, which estimates that implementation of the 2016 Standards may reduce statewide annual electricity consumption by approximately 281 gigawatt‐hours per year, electrical peak demand by 195 megawatts, and natural gas consumption by 16 million therms per year. The potential effect of these energy savings to air quality may be a net reduction in the emission of statewide greenhouse gases by 160 thousand metric tons CO2e per year.24 CALGreen, California Green Building Standards Code (2008 et.seq) CALGreen was the first-in-the-nation mandatory green building standards code. A voluntary CALGreen Code was published in 2008 and had an effective date of August 2009. The first mandatory measures were adopted in the 2010 triennial code publication, which went into effect in January 2011. CALGreen was developed to: 1) reduce GHG from buildings; 2) promote environmentally responsible, cost-effective, healthier places to live and work; 3) reduce energy and water consumption; and 4) respond to the environmental directives of the administration. The reduction in GHG was mandated via executive order and the passage of the California Global Warming Solutions Act of 2006 (Assembly Bill 32). Local jurisdictions are required to adopt the CALGreen provisions. CALGreen is complimentary with California Energy Code, Title 24 Part 6, which continues to regulate energy efficiency in buildings. CALGreen references Title 24 Part 6 where relevant and several voluntary measures in the CALGreen building code require energy efficient that exceeds Title 24 Part 6 requirements by 15 or 30 percent. 24 California Energy Commission, Initial Study / Proposed Negative Declaration For The 2016 Building Energy Efficiency Standards For Residential And Nonresidential Buildings, February 2015 accessed at : www.energy.ca.gov/2015publications/CEC- 400-2015-012/CEC-400-2015-012.pdf Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-18 Genentech Master Plan Update, Draft EIR The initial 2008 publication identified Administration, Definitions and Green Building chapters, and established a Guide to the 2016 California Green Building Standards Code (Nonresidential) categories of planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, environmental air quality, referenced standards, installer and inspector qualifications, and appendices for residential, nonresidential and referenced standards. The 2010 CALGreen Code established chapters for residential and non-residential mandatory measures. A 20 percent reduction of indoor water use and a 50 percent construction waste reduction were required, along with requirements for waste management plans. The 2013 CALGreen Code clarified and expanded a number of requirements that included non-residential additions and alterations. New sections were added in the areas of water efficiency and conservation, which included a 20 percent reduction in indoor water use. References to the California Energy and Plumbing Codes were also included. Demolition and recycling requirements were further defined. CALGreen 2016 addresses clean air vehicles and increased requirements for electric vehicle charging infrastructure. A new universal waste code section has been incorporated for additions and alterations. Organic waste was added. Water efficiency and conservation includes a new section for food waste disposers. Outdoor water use remains subject to the water-conserving measures that were amended due to the Model Water Efficient Landscape Ordinance (MWELO) emergency standards in 2015. Pursuant to Executive Order #B-29-15 addressing California’s ongoing emergency drought conditions, state agencies proposed water-related emergency standards that were immediately enforceable in June 2015 and later adopted as amendments to the 2013 CALGreen Code. Those amendments have been carried over into the 2016 CALGreen Code. Regional Regulations and Policies BAAQMD Guidance on CEQA Guidelines and Thresholds of Significance On June 2, 2010, the BAAQMD Board of Directors unanimously adopted thresholds of significance to assist in the review of projects under the California Environmental Quality Act. These Thresholds are designed to establish the level at which the District believed air pollution emissions would cause significant environmental impacts under CEQA, and were included in the Air District's updated CEQA Guidelines (updated May 2012). The Thresholds are advisory and may be followed by local agencies at their own discretion. The Thresholds were challenged in court and following litigation, all of the Thresholds were upheld. However, in an opinion issued on December 17, 2015, the California Supreme Court held that CEQA does not generally require an analysis of the impacts of locating development in areas subject to environmental hazards unless the project would exacerbate existing environmental hazards. The Supreme Court also found that CEQA requires the analysis of exposing people to environmental hazards in specific circumstances, including the location of development near airports, schools near sources of toxic contamination, and certain exemptions for infill and workforce housing. The Supreme Court also held that public agencies remain free to conduct this analysis regardless of whether it is required by CEQA. In view of the Supreme Court’s opinion, local agencies may rely on Thresholds designed to reflect the impact of locating development near areas of toxic air contamination where such an analysis is required by CEQA, or if the agency determines that such an analysis would assist in making a decision about the project. However, the Thresholds are not mandatory and agencies should apply them only after determining that they reflect an appropriate measure of a project’s impacts. The Guidelines for implementation of the Thresholds are for information purposes only to assist local agencies. Recommendations in the Guidelines are advisory and should be followed by local governments at their own discretion. These Guidelines may inform environmental review for development projects in the Bay Area, but do not commit local governments or the Air District to any specific course of Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-19 regulatory action. The Air District published a new version of the Guidelines dated May 2017, which includes revisions made to address the Supreme Court’s opinion. The Air District is currently initiating an update to its current CEQA Guidelines and thresholds of significance. There have been substantive changes to the data and assumptions underlying the analytical methodologies, thresholds and mitigation strategies since the last update of the CEQA Guidelines in June 2010 (revised May 2017). In addition, the risks to public health and air quality posed by global climate change have been brought into significantly increased focus and prominence, and the State of California has taken strong legislative and programmatic action to achieve greenhouse gas reductions beyond 2020. Furthermore, substantial court decisions related to CEQA litigation have occurred since 2010. Accordingly, the Air District is initiating an update to reflect new or revised requirements in the State CEQA Guidelines, recent court decisions, improved analytical methodologies and new mitigation strategies. This update is needed to ensure new land-use projects do not interfere with the Bay Area’s ability to attain or maintain health-based federal and State ambient air quality standards, and to meet goals for greenhouse gas reduction pursuant to 2050 climate stabilization science. The Air District intends to review current thresholds of significance criteria and establish new significance criteria where needed. 25 Climate Action Plans San Mateo County Energy Strategy 2012 The San Mateo County Energy Strategy 2012 was created by the County of San Mateo Utilities and Sustainability Task Force, with support from the County of San Mateo, the City/County Association of Governments of San Mateo County (C/CAG) and the Bay Area Air Quality Management District (BAAQMD). Energy Strategy 2012 is a guidance document that identifies general energy reduction strategies appropriate for San Mateo County, regional organizations and municipalities. Most goals, strategies, and actions focus on reducing municipal energy use, several actions aim to reduce community energy use. After releasing the document, C/CAG provided additional educational materials to cities and the County and provided incentives to promote the completion of government operation inventories for cities in the county. San Mateo County Energy Watch San Mateo County Energy Watch is a partnership between C/CAG and PG&E, with the goal of reducing energy usage through energy efficiency in San Mateo County cities and unincorporated areas. San Mateo County Energy Watch provides energy efficiency services to public agencies, nonprofits, small businesses and residential customers. As part of the Energy Watch program, PG&E and the BAAQMD have provided support to C/CAG to develop the Regionally Integrated Climate Action Planning Suite (RICAPS). The County provides standardized tool kits for cities and towns in San Mateo County to create climate action plans. Tool kits include inventory tools, suggestions for quantified reduction measures, and language for Climate Action Plans. San Bruno/South San Francisco Community-Based Transportation Plan Completed in early 2012, the CBTP looks at the transportation needs of the community and recommends steps to address these needs. The CBTP provides a framework for transportation providers and various agencies to work together to better understand the transportation needs of low-income populations. Key strategies in the plan include improving transit stops and amenities, improving transit affordability, and improving access and connectivity to transit stops. Targeting the eastern portion of South San Francisco, the CBTP also informs broader community-wide strategies. 25 http://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-20 Genentech Master Plan Update, Draft EIR San Mateo County Energy Efficiency Climate Action Plan In June 2013, an Energy Efficiency Climate Action Plan (EECAP) was adopted for San Mateo County, outlining policies, implementation strategies, and supporting actions to exceed the State’s GHG reduction target of 15% below 2005 emissions levels by the year 2020. The EECAP identifies specific measures on how the County can achieve its GHG reduction target of 17% below 2005 emissions levels by the year 2020. The plan also includes a forecast and GHG reduction strategies to 2035. Local Regulations and Policies City of South San Francisco Climate Action Plan Adopted on February 13, 2014, the City’s Climate Action Plan builds upon existing environmental preservation, public health and energy-saving efforts by providing goals, policies and programs to reduce GHG emissions, adapt to climate change, and support the goals of AB 32 and SB 375.26 The GHG emission reduction measures included in the CAP include a mix of regulatory and incentive-based programs for both new and existing development that aim to reduce GHG emissions from all sources, to avoid reliance on any one strategy or sector to achieve the target. The two categories of GHG reduction policies in the CAP are existing activities, and additional CAP measures. Existing activities are projects and programs that will result in future GHG reductions, and that were enacted prior to the creation of the 2013 CAP, but after the 2005 baseline year. Such projects include municipal energy efficiency retrofits, the City's Transportation Demand Management (TDM) program and community-wide solar installations. CAP measures are to be implemented through new and existing programs. The CAP is structured around strategy areas addressing: ● Alternative transportation, land use and parking, alternative-fuel vehicles, and off-road vehicles and equipment ● Energy efficiency, energy conservation and renewable energy ● Waste minimization ● Water and wastewater conservation, and ● Municipal operations Each strategy area has corresponding reduction measures and supporting actions necessary for implementation. Existing actions, state programs and GHG reduction measures in the CAP are estimated to reduce GHG emissions in the City of South San Francisco by 116,040 MTC02e by year 2020, thereby achieving the AB 32 target of a 15% emissions reduction below baseline 2005 levels. CAP measures are also expected to reduce GHG emission by 191,540 MTC02e by year 2035, thereby achieving the SB 32 target of a 40% emissions reduction below baseline 2005 levels. Mobile Sources To help reduce traffic, air pollution and GHG emissions, and to provide greater commuting alternatives for its working community, the City of South San Francisco requires implementation of Transportation Demand Management (TDM) programs. The TDM guidelines reduce daily vehicle trips per day by requiring that all projects that generate greater than 100 daily trips achieve a minimum of 28% to 40% alternative mode use (depending on land use type and FAR) by employees. Employers are required to develop and implement a TDM plan with requisite carpooling, shuttle and biking options as well as providing public transit, biking and walking incentives to employees. Annual reports on each TDM plan's implementation levels are submitted to 26 City of South San Francisco, Climate Action Plan, February 2014 Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-21 the City to ensure compliance. The TDM program is supported by a number of other efforts, including the Community-Based Transportation Plan. The CAP estimates that reductions in GHG emissions will be achieved through ongoing implementation of its TDM program, amounting to approximately 4,210 MTC02e by year 2020. Other measures of the CAP that are expected to result in reductions in GHG emissions include expanding the use of alternative-fuel vehicles, expanding active transportation alternatives by providing infrastructure and enhancing connectivity for bicycle and pedestrian access, and supporting expansion of public and private transit programs to reduce employee commutes. Individual actions and programs pursuant to these mobile source-based emission reductions include: ● Adopting policies that support alternative-fuel vehicle infrastructure such as bio-fuels and electric vehicle charging stations ● Revising parking design guidelines to include designated spaces for electric vehicles, carpool vehicles, and other low emissions vehicles ● Expanding facilities for vehicle sharing at transit nodes and at business and commercial destinations ● Requiring new large-scale non-residential developments to provide a conduit for future electric vehicle charging installations, and encouraging installation of conduits or electric vehicle charging stations for all new development ● Partnering with the Peninsula Alliance and other regional partners to implement the Bicycle Master Plan and the 2012 San Bruno/South San Francisco Community-Based Bicycle Transportation Plan to expand bicycle facilities and increase bicycle mode share ● Revising the existing traffic impact fee for development east of US 101 to fund the bicycle and pedestrian improvements for the portions of the city identified in the Bicycle and Pedestrian Master Plans ● Following adoption of a "complete streets" policy in 2012 for transportation consistent with the C/CAG criteria for One Bay Area funding opportunities, establish citywide design standards to incorporate all modes of transportation (public transit, bicycle, pedestrian, and automobile) into "complete streets" designs ● Promoting local bike-share or bike rental programs in key activity areas such as downtown to expand the use of bicycles for employee commutes, integrating with regional efforts and collaborating with private employers such as Genentech ● Collaborating with the Peninsula Alliance, BART, SamTrans, Caltrain, other transit agencies, and neighboring jurisdictions to improve transit service connections and frequency ● Working with businesses to support and expand shuttle connections to transit. ● Continuing to enforce the City's Transportation Demand Management (TDM) program to require employers to demonstrate achieved mode share and to continually adjust their programs to meet the requisite goals ● Partnering with local businesses to expand private shuttle programs for employee commutes, share local lessons learned, and connect businesses to shuttle resources ● Implementing programs and encouraging employers to provide additional voluntary subsidies or incentives Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-22 Genentech Master Plan Update, Draft EIR Energy Efficiency Energy used in local homes and businesses in South San Francisco is generally provided by Pacific Gas and Electric (PG&E). PG&E generates energy from a mix of non-renewable, fossil-fuel based sources, such as coal and natural gas, and renewable sources such as biomass, geothermal, hydroelectric, and wind. Energy efficiency and conservation in daily actions can reduce GHG emissions by reducing the amount of electricity or natural gas that PG&E needs to generate, obtain and transmit. Energy efficiency measures for industry sectors include partnerships with companies and businesses to identify high-energy uses, and implementation of retrofits programs tailored to industry practices and facilities. Measures of the CAP that are expected to result in reductions in GHG emissions through efficiency, energy conservation and renewable energy reductions include: ● Provide incentives (e.g., priority or expedited permit processing) to encourage new development to exceed Title 24 energy efficiency standards, and promote utility-sponsored and statewide incentives for energy efficiency in new construction and remodels ● Work with developers of multi-family properties and nonprofit groups to maximize energy efficiency in new construction ● Encourage the use of CALGreen energy efficiency measures as a preferred mitigation for CAP streamlining ● Encourage the use of energy-efficient or smart-grid-integrated appliances in new development ● Work with PG&E to implement smart grid technology in non-residential properties ● Encourage all non-residential properties to provide buyers or tenants with the previous year's energy use by documenting use through the EPA's EnergyStar Portfolio Manager ● Adopt energy efficiency streamlining provisions that encourage energy retrofits, such as an online building permit application with minimal criteria and review ● Create a special business designation to recognize businesses that complete energy efficiency improvements, and encourage businesses to disclose annual energy use for recognition of the highest efficiencies gained ● Provide self-auditing forms during the tenant improvement process that target buildings 10 years old or older, providing recommendations of potential retro commissioning, retrofits, and deep retrofit opportunities ● Require nonresidential alterations or additions of at least 5,000 square feet or greater in size to comply with minimum CALGreen requirements ● Encourage the use of smart grid, energy-efficient, or Energy Star appliances in new development ● Work with utilities and third-party service providers to encourage new and replacement boilers and water heaters to exceed minimum efficiency standards ● Actively engage the nonresidential sector and work with PG&E to implement deep retrofits and retro commissioning in the existing non-residential building stock ● Promote free and low-cost programs, such as Rightlights, which provides no-cost energy assessments in addition to energy-efficient lighting, refrigeration, and other energy-saving improvements ● Require the construction of any new non-residential conditioned space 5,000 square feet or more, or the conversion of unconditioned space 5,000 square feet or more, to meet a minimum of 50% of modeled building electricity needs with on-site renewable energy sources, or to participate in a power purchase agreement to offset a minimum of 50% of modeled building electricity use, or to Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-23 comply with CALGreen Tier 2 energy efficiency requirements to exceed mandatory energy efficiency requirements by 20% or more ● Require all new development to install conduit to accommodate wiring for solar ● Promote on-site renewable energy or distributed generation energy systems in new and existing residential and nonresidential projects. Encourage developers of multi-family and mixed-use projects to provide options for on-site renewable electricity or install distributed generation energy systems, similar to the statewide Homebuyer Solar program ● Update the City's discretionary review guidelines to recommend the use of on-site renewable energy facilities for residential development as a preferred mitigation measure for environmental review and to meet a substantial amount of energy needs with on-site renewable energy systems, including solar photovoltaics or solar water heaters ● Promote the State's CSI-Thermal program, which provides rebates to utility customers who install solar thermal systems to replace water-heating systems powered by electricity or natural gas ● Participate in regional programs to facilitate the bulk purchase of alternative energy equipment (e.g., solar panels through SunShares or similar programs) to defray the cost of installation for interested businesses, institutions, and residents ● Continue to encourage installation of renewable energy systems through the City's participation in PACE and Energy Upgrade programs Indirect Emissions from Water Use and Wastewater Treatment Water consumption requires energy to pump, treat, distribute, collect and discharge water as it is used by the community, which results in greenhouse gas emissions. Greenhouse gas emissions also occur as a direct process from wastewater treatment. Conservation and efficient use of outdoor water are the focus of strategies to reduce GHG emissions from these uses. Measures of the CAP that are expected to result in reductions in GHG emissions through water conservation, reclamation and recycling include: ● Continue to support implementation of the Urban Water Management Plan to reduce potable water use by at least 20% ● Revitalize implementation and enforcement of the Water Efficient Landscape Ordinance ● Work with water providers to support the installation of smart water meters on all water accounts in the city ● Create water policies for the stormwater management strategy that seek to capture storm runoff (e.g., bio-swale, rainwater collection, and irrigation programs) ● Continue to implement the City's Water Efficient Landscape Guidelines ● Continue to pursue long-term opportunities to implement the Recycled Water Project in collaboration with the City of San Bruno, the San Francisco Public Utilities Commission, and the California Water Service Company (Cal Water) Solid Waste Treatment By reducing the amount of waste sent to landfills, GHG emissions associated with waste disposal can be cut significantly. CAP measures seek to divert waste away from a landfill through increased recycling and the creation of a citywide composting program, and promotion of the capture and use of methane emissions to generate alternative energy. The CAP includes measures to increase recycling and reuse of materials to achieve a 75% diversion of landfilled waste by year 2020, including continued enforcement of the existing Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-24 Genentech Master Plan Update, Draft EIR construction and demolition recycling ordinance, requiring 100% of inert waste and 65% of non-inert waste to be recycled from all eligible projects. Landscaping Measures of the CAP that will result in reductions in GHG emissions from off-road vehicles and landscape equipment include: ● support for the BAAQMD voluntary exchange program ● exchange and rebate programs for garden equipment ● information on limiting idling time and electric, non-powered, and other energy-efficient lawn and garden equipment in public education efforts, and ● working with applicants through the CEQA review process to reduce construction equipment emissions by encouraging the use of alternatively powered or grid-connected equipment Impacts and Mitigation Measures Thresholds of Significance Section 15064.4 of the CEQA Guidelines emphasizes the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance for GHG emissions, consistent with the manner in which other impact areas are handled in CEQA. Appendix G of the CEQA Guidelines does not prescribe specific thresholds, but rather suggests evaluating whether a project would: ● Generate GHG emissions, either directly or indirectly, that may have a significant adverse impact on the environment, or ● Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs CEQA Guidelines section 15064.4(b) states that, in evaluating the significance of impacts from GHG emissions, the lead agency should consider the following factors, among others: ● the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting ● whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and ● the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions Such requirements must be adopted by the relevant public agency through a public review process and must reduce or mitigate the project’s incremental contribution of GHG emissions. The BAAQMD presents its suggested thresholds of significance, along with methods for evaluating compliance, in its 2017 CEQA Guidelines. The 2017 Guidelines recognize that “[n]o single project could generate enough GHG emissions to noticeably change the global average temperature,” and that the relevant inquiry for CEQA purposes is whether a project’s GHG emissions would be “cumulatively considerable.” 27 Accordingly, BAAQMD has set up separate GHG significance thresholds for permitted 27 The 2017 BAAQMD Guidelines, pageD-1 notes that, “BAAQMD’s approach to developing a Threshold of Significance for GHG emissions is to identify the emissions level for which a project would not be expected to substantially conflict with existing California legislation adopted to reduce statewide GHG emissions needed to move us towards climate stabilization.” Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-25 stationary sources and other, non-permitted operational emissions. Project emissions are not deemed “cumulatively considerable” or significant under CEQA if they fall below these thresholds, as described below. Stationary Source Thresholds In evaluating the potential significance of GHG emissions from the Project, future GHG emissions from stationary sources that are subject to California’s Cap-and-Trade program and Air District-permitted stationary sources associated with the Project are evaluated separately from other non-permitted operational emissions, and compared to separate GHG significance thresholds, in line with the 2017 BAAQMD Guidelines. Cap-and-Trade Threshold Pursuant to AB 32, the California ARB has adopted a Climate Change Scoping Plan that outlines the State’s strategy to achieve year 2020 GHG emissions limits. One of the key elements of the Scoping Plan is development of a California Cap-and-Trade program that links with other partner programs to create a regional market system, and that caps sources contributing to the majority of California’s GHG emissions. The Cap-and-Trade program is a market-based approach to reduce GHG emissions that enables large-scale GHG emitters to reduce their overall emissions by investing in offsetting cleaner fuels and energy efficiencies. CARB uses revenue from these investments to sponsor offsetting projects that result in reductions in GHG emissions. The Cap-and-Trade program addresses specific types of stationary source emission that are subject to cap limits, and allows for purchase and/or trade of emissions credits. The following threshold applies to GHG emissions covered under Cap-and-Trade regulations: 1. Those Project-related GHG emissions from stationary sources subject to the California ARB Cap-and- Trade program are not cumulatively considerable contributions to global climate change and are not considered significant - Emissions that comply with the Cap-and-Trade program are excluded from analysis of GHG emissions against a numerical stationary source threshold. Permitted Stationary Source Emissions Threshold The 2017 BAAQMD Guidelines set a GHG significance threshold of 10,000 metric tons (MT) CO2e/year for permitted stationary-source projects. Permitted stationary sources are those processes and equipment that require an Air District permit to operate. Future Air District-permitted GHG emissions associated with the Project would not be deemed cumulatively considerable in and of themselves, if they remain below the following threshold: 2. The Project’s contribution to global climate change would be considered cumulatively considerable if its permitted stationary source emissions of GHG were to exceed 10,000 MT CO2e/year. Thresholds for Other Operational Emissions Operational GHG emissions associated with the Project, but not subject to the Cap-and-Trade program and not associated with a permitted stationary source are measured against land use-based significance thresholds. BAAQMD Guidelines establish three independent thresholds of significance for evaluating the potential significance of these operational GHG emissions. These thresholds are based on: 1) a determination of compliance with a qualified GHG Reduction Strategy; 2) mass emissions of carbon dioxide equivalent (CO2e) per year; and/or 3) a GHG emissions efficiency threshold based on emissions per service population. Compliance with Qualified GHG Reduction Strategy A portion of the operational GHG emissions associated with the Project will be consistent with a Qualified GHG Reduction Strategy (i.e., the City of South San Francisco Climate Action Plan (CAP), as more fully described in the Regulatory Setting, above). The CAP is intended, in part, to streamline project-level approval Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-26 Genentech Master Plan Update, Draft EIR processes for those projects that demonstrate consistency with the CAP, and contains a list of emission reduction measures that project sponsors may apply to their projects to demonstrate this consistency. Although the CAP specifically excludes energy use at the Genentech Campus, direct landfill emissions and emissions covered under Genentech Cap-and-Trade rules, the CAP inventory does includes Genentech GHG emissions from solid waste disposal, water usage and treatment, landscaping, and mobile sources. These categories of emissions are therefore subject to the reduction measures specified in the CAP. The following threshold applies to such GHG emissions: 3. Those Project-related GHG emissions that are fully covered under the City’s Qualified GHG Reduction Strategy (i.e., the CAP) do not represent a cumulatively considerable contribution to global climate change and are not considered significant - Emissions that comply with the CAP are excluded from analysis of GHG emissions against a numerical land use-based threshold. Numerical GHG Significance Thresholds The remaining GHG emissions attributable to the Project that are not subject to the Cap-and-Trade program, are not from a permitted stationary source, and are not covered under the CAP, are measured against numerical significance thresholds. The numerical efficiency metric thresholds used in this EIR represent the amount of GHG reductions required from land use-based projects needed to help achieve the state GHG emission targets by year 2020 as defined under AB 32, and to help achieve the state GHG emission targets by year 2030 as defined under SB 32 and EO B-30-15. Emission Threshold Pursuant to AB 32 The GHG reduction target established for the state pursuant to AB 32 is defined as the reduction of statewide emissions necessary to re-achieve 1990 GHG emissions levels from the land use sector, by year 2020 (taking into account the difference in projected 2020 statewide population and employment levels). In its CEQA Guidelines (2017)28, BAAQMD calculated a district-level GHG project significance efficiency threshold for individual land use projects by dividing the AB 32 GHG target for land use development in California (after accounting for all regulatory measures included in the AB 32 Scoping Plan), by California’s estimated 2020 population and employment levels. The resulting GHG threshold attributes a “fair share” of the “gap” in GHG emission reductions necessary to meet the year 2020 target to each proposed development project in BAAQMD’s jurisdiction. See BAAQMD CEQA Guidelines (2017), pp. D-22, D-27, D-28. Moreover, BAAQMD determined that this approach would allow the Bay Area to meet its specific areawide goal of 1.6 million metric tons/year GHG reductions in order to meet 2020 GHG targets. See BAAQMD CEQA Guidelines, p. D-28. Accordingly, if a new project will have GHG emissions at or below 4.6 metric tons/year GHG emissions per service population, BAAQMD has concluded that the project will allow the District to meet its 1.6 million metric tons/year GHG reduction target. Based on this BAAQMD methodology, the following threshold applies to the Project’s land use-based GHG emissions for year 2020: 4. The Project’s contribution to global climate change is considered cumulatively considerable if its land use-based GHG emissions exceed an efficiency threshold of 4.6 MT of CO2e per service population (project jobs + project residents) at year 2020. Emissions Threshold Pursuant to SB 32/Executive Order B-30-15 Recently enacted SB 32 addresses GHG emissions reduction goals through 2030. To estimate a significance level for land use projects extending beyond 2020 (like the Project), it is necessary to extrapolate the 2020- based threshold (above) established in the BAAQMD CEQA Guidelines to account for the trajectory of anticipated land use related reductions required to meet the state’s 2030 GHG reduction target. The GHG reduction target established for the state pursuant to SB 32 and EO-B-30-15 is defined as the reduction of 28 BAAQMD, California Environmental Quality Act: Air Quality Guidelines, May 2017. Accessed at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-27 statewide emissions necessary to achieve a 40% reduction from the 1990 baseline year GHG emissions levels, by year 2030 (taking into account the difference in projected 2020 statewide population and employment levels). Applying the same BAAQMD methodology described above for assessing consistency with the District’s areawide 2020 GHG reduction goals, the following threshold applies to the Project’s land use-based GHG emissions for year 2030: 5. The Project’s contribution to global climate change is considered cumulatively considerable if its land use-based GHG emissions exceed an efficiency threshold of 2.7 MT of CO2e per service population (project jobs + project residents) at year 2030. Methodology The analysis of future GHG emissions resulting from construction and operation of the Project has been prepared consistent with guidelines and methodologies as prescribed by the Bay Area Air Quality Management District (BAAQMD), the California Air Resources Board (ARB) and the US Environmental Protection Agency (US EPA), as described above. Consistent with CEQA requirements, this GHG analysis evaluates anticipated emissions of GHGs from both construction and operational activities (including traffic generated from the Project), and compares the anticipated operational emissions to the significance thresholds indicated above. Although there are no significance thresholds for construction-related GHG emissions, the Project’s construction emissions are quantified for informational purposes. For each category of emissions type, emissions are estimated based on data for the Project, as presented in detail in Appendix 10A. Stationary Source Emissions Subject to Cap-and-Trade GHG 1: The Project’s stationary source emissions will not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing the emissions of GHGs. Specifically, the Project will comply with the CARB Cap-and-Trade program, which is a method to achieve statewide reduction goals as set forth in AB 32. (Less than Significant with Regulatory Requirements) This following analysis assumes that the Project will include a net addition of the following stationary sources of GHG emissions that are specifically covered under the CARB Cap-and-Trade program: ● Miscellaneous natural gas use, ● A combined heat and power plant (CHP – or co-generation facility), and ● Four new natural gas-fired boilers (boilers with maximum heat capacity greater than 10 million Btu/hr) Cap and Trade Program The California ARB has adopted a Climate Change Scoping Plan, which outlines the State’s strategy to achieve the 2020 GHG limit set by AB 32. This Scoping Plan includes a comprehensive set of actions designed to reduce overall greenhouse gas emissions in California, improve the environment, reduce dependence on oil, diversify energy sources, save energy, create new jobs and enhance public health. One of the key elements of the Scoping Plan is development of a California Cap-and-Trade program that links with other partner programs to create a regional market system, and that caps sources contributing the majority of California’s GHG emissions. California's Cap-and-Trade program was designed by the California ARB as a market-based approach to reduce GHG emissions. Cap and Trade enables industrial emitters to reduce overall emissions by investing in cleaner fuels and energy efficiencies. Under the Cap-and-Trade program, enforceable limits are set on the amount of emissions that can be produced by large industrial emitters (known as a "cap"), and each emitter receives permits for the emissions allowable under their cap. California holds quarterly sales (or auctions) of Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-28 Genentech Master Plan Update, Draft EIR emissions allowances from a permit reserve (the Allowance Price Containment Reserve), and emitters that do not use all their permit cap can auction their reserves to other emitters (i.e., “trade”), who can use the additional permits to exceed their cap.29 CARB collects revenue from the permit auctions, and uses this revenue to invest in offsetting projects that result in reductions in greenhouse gas emissions. The Climate Action Reserve (previously the California Climate Action Registry or California Registry) has developed standardized GHG reduction project protocols, serving as a registry for GHG reduction projects, and tracking GHG offsets. By investing in standardized and conservative quantification methodologies vetted by public and private stakeholders and approved by the Climate Action Reserve, companies and organizations can be issued credits to reflect the offset mitigation value of their investments. Since 2006, Genentech has been a voluntary partner in the California Climate Action Registry/Climate Action Reserve, and was among the first bio-pharmaceutical companies to do so. As such, Genentech has received permits for its emission levels allowed under their cap, may purchase additional emissions allowances from the permit reserve or from the unused reserves of other emitters, and/or may auction its unused permit reserves to other emitters. Covered Emissions The types of GHG emissions that are covered under the Cap-and-Trade program include direct stationary- source GHG emissions that result from the combustion of fossil fuels, chemical and physical processes, vented emissions, geothermal emissions, and emissions from suppliers of carbon dioxide and CH4 and N2O emissions from biogenic fuel combustion. The Project will result in an increase in these “covered” Cap-and- Trade emissions as a result in increased use of natural gas, the addition of up to four new natural gas-fired boilers and the potential construction of a combined heat and power plant (CHP). These Cap-and-Trade covered emissions attributable to the Project are as described below and summarized in Table 10-2. Natural Gas Usage GHG emissions from increased natural gas use from permit-exempt boilers (boilers with maximum heat capacity of less than 10 million British thermal units per hour [MMBtu/hr]) was calculated based on projected increases in natural gas usage attributed to the Project, and emission factors from the Federal Mandatory Greenhouse Gas Reporting Regulation. Combined Heat and Power Plant Combustion GHG emissions from the CHP are estimated based on the emission factors from the Federal Mandatory Greenhouse Gas Reporting Regulation. Emissions from the CHP plant are included in the analysis to provide a conservative estimate of potential emission sources, but Genentech has not committed to installing a CHP plant as part of the Project. Miura Boilers Combustion GHG emissions from the four new Miura boilers are estimated based on the emission factors for these sources, as derived from the Federal Mandatory Greenhouse Gas Reporting Regulation. 29 On January 1, 2014, the California Cap-and-Trade Program and Québec Cap-and-Trade System officially linked, which enabled the mutual acceptance of compliance instruments issued by each jurisdiction, and the jurisdictions to hold joint auctions of greenhouse gas (GHG) allowances. As part of California’s Cap-and-Trade Program and the Québec Cap-and-Trade System, the California Air Resources Board (CARB) and Québec’s Ministry of Sustainable Development, Environment and the Fight against Climate Change (MDDELCC) will hold joint GHG allowance auctions to allow market participants to acquire GHG allowances. Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-29 Table 10-2: Emission Sources Covered by Cap-and-Trade Emissions Category GHG (MTCO2e) Misc. Natural Gas Combustion (see Appendix 10A, Table GHG-8) 17,320 1 CHP (see Appendix 10A, Table GHG-7 33,734 Miura Boilers (see Appendix 10A, Table GHG-6) 21,831 Total: 72,885 Source: Ramboll Environ, Appendix 10A, Table GHG-16, December 2017 Notes: 1. This source category includes emissions from smaller boilers as well as other miscellaneous sources of natural gas use. Regulatory Requirements Stationary source emissions are regulated through the Cap-and-Trade program. Regulatory Requirement GHG 1 – Cap and Trade: Genentech is committed to minimizing emissions from stationary sources and continuing participation in the Cap-and-Trade program. Pursuant to this program, Genentech must meet the requirements by ensuring permits (through increased cap or trade) are obtained for incremental growth in these types of stationary source emissions. The Cap- and-Trade allowances must meet or exceed stationary source emission levels as reported to CARB pursuant to mandatory GHG reporting requirements. Compliance with the Cap-and-Trade program can be verified through publicly accessible data maintained by the California Air Resources Board, which includes statewide and facility-specific information on emissions reporting, offsets and allocations, and facility compliance with the Cap and Trade Program30. Reliance on the Cap-and-Trade program to address these specific types of stationary source emissions is consistent with the City’s Climate Action Plan (CAP), which indicates that emissions from such stationary sources are most effectively addressed and regulated by the BAAQMD, or by federal and state programs. The volume of emissions resulting from energy use at Genentech facilities subject to the Cap-and-Trade program was specifically excluded from the City’s GHG inventory and forecast for the following reasons: ● These facilities are subject to air quality and emissions standards set by the US Environmental Protection Agency (EPA), CARB and the BAAQMD. The CAP’s approach of excluding energy use from sources that are outside of the City's jurisdictional control is consistent with ICLEI's Draft Community- Wide Protocol. ● The Cap-and-Trade program provides multiple avenues for compliance, including options that will be shaped by market factors and the preferences of the individual participating entities. The City is therefore limited in its ability to estimate how facilities subject to Cap-and-Trade will comply with the program. The inclusion of such facilities, lacking an accurate reflection of how Cap-and-Trade will reduce GHG emissions, would make it difficult for South San Francisco to set an achievable GHG reduction target that matches the AB 32 goal, or to use the CAP for future CEQA tiering or streamlining. ● The Cap-and-Trade program is a method to achieve statewide reduction goals set forth in AB 32. Excluding emissions from facilities subject to the cap-and-trade program does not conflict with the overall AB 32 reduction target, but instead allows the City to focus on the emissions sectors that are otherwise not as directly influenced by AB 32. 30 Accessed at https://ww3.arb.ca.gov/cc/capandtrade/public_info.pdf Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-30 Genentech Master Plan Update, Draft EIR ● Excluding energy used at facilities regulated by Cap-and-Trade (e.g., Genentech) more accurately reflects the electricity and natural gas use from non-residential customers in South San Francisco, and allows the City to focus on actions that are within its control.31 Mitigation Measures No further mitigation is required. Permitted Stationary Source Emissions GHG 2: The Project’s stationary source emissions that are not otherwise addressed under the Cap-and-Trade program will not exceed 10,000 MT of CO2e per year, and thus will not contribute to global climate change at a level that is considered cumulatively considerable. (Less than Significant) The Project’s anticipated new emergency generators are stationary emissions sources that are individually permitted by the BAAQMD and are not covered under Genentech’s Cap-and-Trade Program, and therefore are evaluated under the 10,000-MT CO2e threshold. Emergency Generators Currently, the Project area has 57 total emergency generators serving the existing approximately 4.7 million square feet of building space within the Campus. Assuming that new emergency generator needs will be proportional to new building space, this analysis conservatively anticipates the eventual need for an additional net increase of 52 emergency generators to serve the approximately 4.3 million square feet of building space as proposed pursuant to the Project. Equipment specifications for the 2-MW Model 3516C Caterpillar generator have been used in this analysis, as this model generator has been used as representative for the Project because this model has been permitted for the last three generators installed at the Campus. Based on the detailed calculation presented in the GHG Appendix to this EIR, Table 10-3 shows the estimated GHG emissions attributed to new emergency generators pursuant to the Project. Table 10-3: Operational GHG Emissions from New Emergency Generators GHG Emissions Per Emergency Generator (MTCO2e/yr) Number of Generators Total Net New Emissions (MTCO2e/yr) 42 52 2,200 Stationary Source Emissions Threshold: 10,000 Exceed Threshold: No Source: Ramboll Environ, Appendix 10A, Table GHG-5, December 2017 CO2e emission factor obtained from the U.S. Energy Information Administration: http://www.eia.gov/tools/faqs/faq.cfm?id=307&t=11 Mitigation Measures No mitigation measures are required. GHG emissions from those permitted stationary sources not covered under Genentech’s Cap-and-Trade rules (i.e., emergency generators) do not exceed the stationary source threshold. 31 City of South San Francisco, Climate Action Plan, Appendix C (page 123), February 2014 Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-31 Operational Emissions Fully Covered under the SSF CAP GHG 3: The Project’s operational emissions will not conflict with an applicable plan, policy, or regulation adopted for the purposes of reducing the emissions of GHGs. Specifically, the Project is consistent with the City’s Qualified GHG Reduction Strategy (i.e., the SSF Climate Action Program, or CAP). Those operational-related GHG emissions that are fully covered under the SSF CAP do not represent a cumulatively considerable contribution to global climate change, and emissions that comply with the CAP are excluded from analysis of GHG emissions against the numerical land use-based threshold. (Less than Significant) Under the BAAQMD Guidelines, operational GHG emissions that comply with a Qualified GHG Reduction Strategy are deemed less than significant under CEQA. As indicated in the South San Francisco Climate Action Plan (CAP, page 25), the SSF CAP follows both the State and BAAQMD CEQA Guidelines by incorporating the standard elements of a Qualified GHG Reduction Strategy. Appendix C of the SSF CAP provides further, detailed information demonstrating that the SSF CAP meets the requirements and criteria for a Qualified GHG Reduction Strategy. Because the SSF CAP satisfies the requirements of a Qualified GHG Reduction Strategy, the CAP allows the City to determine that future development projects have a less than significant impact on GHG emissions, provided such projects comply with the CAP. As demonstrated below, a portion of the Project’s operational GHG emissions are fully consistent with the City of South San Francisco’s CAP. Although the CAP specifically excluded energy use and stationary source emissions at the Genentech Campus from its inventory, the CAP inventory does include Genentech’s GHG emissions from indirect operational source including mobile sources, water and wastewater use, and solid waste disposal. These categories of emissions are subject to reduction measures as specified in the CAP. GHG emission sources of the Project that are covered by, and in compliance with the CAP are discussed below, and summarized in Table 10-4. Mobile Sources GHG emissions from the Project’s additional employee and vendor vehicle trips were calculated based on the increase in traffic as presented in the Traffic and Transportation chapter of this EIR. The Project’s traffic- related mobile source emissions were evaluated using the emission factors from EMFAC 2014 for the vehicle fleet mix in San Mateo County. Water and Wastewater Use Indirect GHG emissions from water use include indirect emissions from electricity used to deliver and treat water, and emissions from wastewater treatment. Water supply emissions were calculated by multiplying the projected increase in water use attributed to the Project, by CalEEMod’s default values for water electricity intensity for Northern California. This product results in the quantity of electricity required to deliver and treat water supplied to Genentech. This value is then multiplied by the PG&E electricity emission factor to calculate the associated GHG emissions. Similarly, GHG emissions associated with electricity consumption for wastewater treatment are calculated first by multiplying the Project’s projected increase in wastewater flows by CalEEMod’s default values for waste electricity intensity for San Mateo County and by the PG&E electricity emission factor. Additional GHG emissions that occur at the wastewater treatment facility were also added. Solid Waste Disposal GHG emissions from waste disposal include CO2 and CH4 emissions from waste decomposition at the landfill. These emissions were estimated using emission factors from CalEEMod, and projected increases in waste generation for the Project. Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-32 Genentech Master Plan Update, Draft EIR Table 10-4: Emission Sources Covered by the South San Francisco Climate Action Plan Emissions Category Net New GHG (MTCO2e) Mobile Sources (see Appendix 10A, Table GHG-14f and -14g) 25,229 Indirect Water Use (see Appendix 10A, Table GHG-11) 50 Wastewater Treatment (see Appendix 10A, Table GHG-12)1 146 Solid Waste Disposal (see Appendix 10A, Table GHG-13) 424 Landscaping 0.1 Total: 25,849 Source: Ramboll Environ, Appendix 10A, Table GHG-16, December 2017 Notes: 1. Emissions obtained from CalEEMod run using land use information shown in Table GHG-1 These indirect operational emissions, which are covered by the City’s CAP, are excluded from those types of emissions evaluated against the numerical land use-based thresholds (see Impacts GHG-4 and GHG-5, below), and are deemed not significant under CEQA. Consistency with South San Francisco Climate Action Plan Beginning in 2004, Genentech has established company-wide sustainability goals pursuant to its privately developed Sustainability Strategic Plan. Genentech’s sustainability goals address each of the key areas included in the SSF CAP, including mobile source reductions, water and wastewater use, waste to landfill and other key sustainability program areas. These sustainability goals have been developed in multi-year cycles, including the now-current goals for year 2015 through 2020. These goals have evolved over time to track performance and achievement, to build upon prior successes and overcome setbacks, and to respond to science-based models that accurately capture Genentech’s overall environmental footprint.32 A brief summary of these sustainability goals, Genentech’s efforts towards their achievement, and a comparison to CAP implementation measures and programs, is provided below. TDM and Other Mobile Source Emission Reductions Starting in 2006, Genentech began implementation of a TDM program (known as “gRide”), that includes initiatives such as GenenBus commuter service, local shuttles and private ferry service, and transit subsidies and incentives, accompanied by comprehensive marketing and communications. The original goal of Genentech’s gRide TDM program was to increase the percentage of employees using transit, rideshare, walking and bicycling to more than 25%, consistent with the City of South San Francisco's TDM goal in effect at that time. As of the Fall 2017 annual survey,33 approximately 42% of Genentech employees now commute by modes other than driving alone, greater than the currently effective 30% City requirement (for projects in the Business and Technology park district at FARs of between 0.51 and 0.69). This GHG analysis relies on the Project commitment to limit net new AM peak hour trips pursuant to a Trip Cap equal to the total number of AM peak hour single-occupant vehicle trips as assumed in the 2007 MEIR, while exceeding building space and employee assumptions of that 2007 MEIR. To accomplish this Trip Cap, Genentech has established a goal of achieving a 50 percent TDM trip reduction rate by buildout of the Master Plan Update. Genentech will need 32 Genentech, Sustainability Goals and Performance, accessed at: https://www.gene.com/good/sustainability/goals-and- performance 33 Genentech Annual Report for 2017, Attachment 1, South San Francisco Campus Mode Share and Parking Report, Fall 106 Survey, prepared by Nelson|Nygaard, May 2017 Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-33 to grow its current TDM program in capacity and use commensurate with new development, and expand capacity and use of TDM programs to achieve this Campus-wide alternative mode split. The Master Plan Update also includes a proposed Trip Cap to limit Project-generated vehicle trips during the AM peak hour. Both the TDM rate and the Trip Cap will exceed the mobile source GHG emission reductions assumed pursuant to the City’s CAP. The strategies included in Genentech’s updated TDM Plan are designed to build upon the success of existing programs, provide for improvement where needed, and to offer options for new measures that further increase employee travel choice and improve the user experience. The following is a brief summary of proposed TDM strategies: ● GenenBus: Genentech will continue to operate commuter GenenBus routes for employees who live throughout the San Francisco Bay Area, connecting employees from Alameda, Contra Costa, Marin, Santa Clara, San Francisco, San Mateo and Solano Countries to the South San Francisco Campus ● DNA Shuttle Service: Genentech will continue to operate the intra-campus DNA Shuttle routes for employees to travel between Campus buildings, parking facilities and GenenBus stops ● Ferry Service: Genentech has initiated, and will continue to offer a standalone ferry service to markets unserved by public ferry operators, using private high-speed vessels to provide exclusive ferry service for commuting employees ● Transit Subsidy: Genentech will continue to offer a reimbursement program to cover certain employee out of pocket costs for riding public transit to work ● Carpool and Vanpool Incentives: Genentech will continue to offer cash incentive to employees who drive carpools or vanpools to Campus, and carpools and vanpools qualify for preferred parking. Genentech will continue to provide ride-matching services to ease the burden of locating carpool partners by connecting employees who live and work near each other and have similar work hours ● Car Share: Genentech may pursue implementation of car sharing programs that allow for on-demand access to a shared fleet of vehicles on an as-needed basis, potentially working with third-party vendors for on-site placement of car share vehicles ● Guaranteed Ride Home Program: Genentech will continue to offer a Guaranteed Ride Home program to provide a way for employees who commute to work by transit, carpool, vanpool, biking or walking, to travel home when an unexpected need arises ● Flexible Work Arrangements: Genentech employees will continue to have flexibility in their daily work schedules, including working a compressed workweek, telecommuting and other flexible work arrangements ● Biking and Walking Incentives: Genentech will continue to provide incentives to employees who choose to walk or bike to work. The purpose of the incentive is to dissuade drive alone commuting and promote active modes ● On-Site Bicycle Facilities: Genentech buildings will continue to provide locker rooms and showers to serve bicycle commuters who wish to shower or change upon arriving at work ● Bicycle Network Improvements: Genentech will work with the City of South San Francisco to identify and potentially help fund important bikeway improvements ● Preferential Parking for Electric and Alternative-fueled Vehicles: Genentech will continue to offer preferred parking for vehicle types that reduce GHG emissions as compared to traditional autos Mobile source reductions of GHG emissions are fully addressed in the CAP (primarily through required implementation of TDM measures). The Project’s TDM program is in full compliance with (and exceeds) the Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-34 Genentech Master Plan Update, Draft EIR GHG emission reduction strategies of the SSF CAP, and the Project will therefore have a less than significant impact on GHG emissions from mobile sources. Water Conservation Since 2004, Genentech has been committed to improving its water use efficiency, particularly through efficiencies in its manufacturing operations. Significant production efficiencies have been achieved through technological advancements in manufacturing and purification processes, and these advancements were largely responsible for substantial water use efficiencies (e.g., a reduction in manufacturing water use by 87% per kg of product, between 2009 and 2014). The current water conservation goal presented in Genentech’s Sustainability Plan is for a 20% overall water reduction by year 2020, as compared to water use levels in 2010. This is consistent with Measure 6.1 in the 2014 SSF CAP, which calls for a reduction in potable water use by at least 20%. The SSF CAP notes that this goal will be reached through a combination of project-level qualitative measures consistent with SSF’s Urban Water Management Plan.34 Some of the individual projects pursuant to both Genentech’s water conservation goal and water conservation measures in the SSF CAP include: ● Irrigation Savings: Campus-wide include letting lawns go ‘gold’, prioritizing native, drought tolerant planting for newly landscaped areas, replacing some existing turfed areas with native, drought tolerant plants, and using high-efficiency drip and spray irrigation system with weather controls. ● Corporate Awareness Initiatives: Genentech’s Strategic Plan will continue to include water conservation awareness initiatives such as establishment of an annual water awareness month, posted water conservation information on websites, direct communications to employees about how they can reduce water use, and continued participation in the “Connect the Drops” campaign in support of more sustainable management of water resources throughout California. ● Recycling Programs and Projects: Genentech will continue its commitment to use of, or preparation for use of, recycled water for a variety of non-potable water needs. Example on-going recycling projects on the Campus include use greywater from showers and sinks for use in irrigation and toilets, and installation of recycled water distribution lines (i.e., “purple pipes”) throughout the Campus to enable reclaimed water to be transported for internal reuse as it may become available in the future. ● Pilot Programs for Industrial Reuse of Recycled Water: Genentech anticipates continuation of pilot programs and solutions to reuse and recycle water internally (for example, as make-up water in cooling towers), and expects that the expansion of such solutions will drive significant water savings. ● Regional Wastewater Recapture: One of the more promising recycling projects that Genentech is currently exploring involves tapping into the regional wastewater outfall main line that delivers treated wastewater from the treatment plant to its ultimate disposal outfall in the Bay. This high- pressure main line runs through the center of the Campus, and carries all the treated wastewater exiting from the City’s treatment plant. Under this idea, Genentech may be able to siphon off a portion of this treated effluent prior to its disposal in the Bay, provide additional on-site treatment (or “polishing”) of this wastewater flow, and use this treated effluent in its industrial applications at the Campus. If Genentech is successful in designing such a project, and it can be demonstrated to be feasible, cost-efficient and environmentally sound, this project would have the benefits of not only substantially reducing potable water demands needed for on-site industrial applications, but would also commensurately reduce the amount of effluent disposal into the Bay. 34 California Water Service, 2015 Urban Water Management Plan: South San Francisco District, June 2016. Accessed at: https://www.calwater.com/docs/uwmp2015/bay/South_San_Francisco/2015_Urban_Water_Management_Plan_Final_(SSF).pdf Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-35 Indirect GHG emissions attributed to water use and wastewater treatment are fully addressed in the SSF 2014 CAP. Genentech is now, and will continue to implement numerous projects that will achieve water savings and commensurately result in wastewater treatment and disposal savings. The Project’s water conservation and water recycling programs are in full compliance with the GHG emission reduction strategies of the SSF CAP, and the Project will therefore have a less than significant impact related to indirect GHG emissions from water use and wastewater treatment. Solid Waste Disposal Genentech also remains committed to reducing waste generation and reducing its waste-to-landfill stream by minimizing consumption and looking for new opportunities for reuse and recycling. For its biotechnology- based waste materials, Genentech’s Green Bio-Pharma program focuses on reducing the environmental impact generated by its lab operations by creating recycling initiatives for non-standard materials, and sourcing more environmentally-friendly chemicals. The current waste reduction goal presented in Genentech’s Sustainability Plan is to target an 80% absolute reduction in waste to landfill per employee by 2020, as compared to 2010 levels. Some of the individual projects pursuant to this goal include: ● Increased Recycling and Composting: Most landfill reduction achievements have come from increased recycling and composting efforts. The amount of food waste now composted has dramatically increased, with employee-based waste assessment and monitoring efforts; ● Reduction and Reuse: Genentech strives to minimize the amount of materials brought into Campus and to maximize reuse. A key example in the dining process includes a team of employees tasked with right-sizing food purchases for cafeteria and catering operations, and streamlining process for donating surplus food to people in need. ● Green Bio-Pharma: The Genentech Green Bio-Pharma program has had substantial success in programs to provide off-site recycling of materials used in manufacturing processes. Program elements include diverting bioprocess lab waste (i.e., containers, lids and other plastic products) from landfills by providing for their reuse on Campus, and adding disposal containers and reminder signage at lab space benches for recycling of nitrile gloves. Genentech also holds lab supply “sidewalk sales”, where excess and/or waste equipment and supplies are offered to schools and nonprofits, diverting such waste from landfill. Genentech expects to meet its 10-year goal of 80% absolute reduction in waste to landfill per employee by 2020. Indirect GHG emissions attributed to waste disposal are fully addressed in the SSF 2014 CAP. Genentech’s goal is consistent with Measure 5.1 of the SSF CAP, which aims to increase the recycling and reuse of materials to achieve a 75% of landfilled waste by 2020. Genentech is now, and will continue to implement numerous projects that will reduce waste generation and landfill requirements. The Project’s waste diversion programs are in full compliance with the GHG emission reduction strategies of the SSF CAP, and the Project will therefore have a less than significant impact related to indirect GHG emissions from waste disposal. Mitigation Measures No mitigation is required. The Project’s indirect, operational GHG emissions attributable to mobile sources, water use, wastewater treatment and waste disposal are fully addressed in the City of South San Francisco’s Climate Action Plan (a Qualified GHG Reduction Strategy). The CAP allows the City to determine that future development projects will have a less than significant impact on CAP-related GHG emissions if they comply with CAP GHG reduction measures. Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-36 Genentech Master Plan Update, Draft EIR Other Operational GHG Emissions by Year 2020 GHG 4: The Project will not generate land use-based GHG emissions, other than those emissions addressed pursuant to the City CAP, that exceed the efficiency threshold of 4.6 MT of CO2e per year per service population (Project jobs) at year 2020. The Project’s land use-based GHG emissions would not contribute significantly to global climate change, and this impact is considered less than cumulatively considerable. (Less than Significant) As more fully described above (under Impacts GHG-1 through GHG-3, above), certain operational emissions of the Project are excluded from the types of emissions evaluated against numerical land use-based thresholds. The types of GHG emissions excluded from this analysis include all emissions otherwise addressed under Genentech’s participation in CARB’s Cap-and-Trade program, all stationary sources evaluated under the permitted stationary-source threshold and all emissions otherwise addressed under the South San Francisco Climate Action Plan. The types of GHG emissions that remain, and that are compared to the land use-based threshold of 4.6 MT of CO2e per year, include emissions from indirect electricity use, and emissions from process use of CO2 and HFC gas. Emissions from these sources in excess of the 4.6 MT of CO2e per year threshold could potentially impede attainment of statewide GHG reduction targets for 2020 established under AB 32. Indirect Electricity Emissions The Project includes use of increased electricity that will not cause direct emissions on-site, but will cause increased GHG emissions to be emitted at utility plants to produce the electricity that is used by the Project. The Project’s electricity use was calculated by scaling known existing (as of 2016) electricity use by land use type within the current Campus, up to the total for all land uses as projected pursuant to the Project, as shown in Table 10-5, below. Table 10-5: Project’s Net Increase in Electricity Use Land Use Type Square feet Electrical Demand (kW hours per SF) Project’s Net Increase in Electricity Demand Labs / R&D 1,564,000 50 78,200,000 Office 2,424,000 12 29,088,000 Amenity 305,000 15 4,575,000 Total: 111,863,000 Source: Ramboll Environ, Appendix 10A, Table GHG-10, December 2017 The increased electricity demand associated with the Project was then multiplied by PG&E’s CO2 emission factors for energy production at year 2020, to calculate the associated GHG emissions. HFC and CO2 Process Gas Usage The Project is expected to generate additional GHG emissions from HFC use in air conditioning, cooling and fire suppression equipment, and from CO2 in process gas usage. Project HFC and CO2 process gas usage was calculated by scaling known GHG emissions attributed to existing (as of 2016) laboratory land use, up to the total laboratory land uses as projected pursuant to the Project. CalEEMod default values for CH4 and N2O emission factors were then applied to the increased HFC and CO2 use. Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-37 Total GHG Emissions from Land Use Sources For each of these land use-based GHG emissions categories above, emissions are estimated based on data for the Project, as shown in Table 10-6, below. Construction emissions amortized over the project lifetime (assumed at 40 years, consistent with Genentech’s historical data and future projections for building operational lifespans) are included to compare the “worst-case” annual emissions to the applicable GHG emissions threshold. Table 10-6: Net New Emission Sources, Compared to the Year 2020 Land Use Threshold Emission Category Net New GHG (MTCO2e/yr) Construction (see Appendix 10A, Table GHG-16) 1,321 Indirect Electricity (see Appendix 10A, Table GHG-10) 14,845 HFC Gas Use (see Appendix 10A, Table GHG-15) 960 Process CO2 Gas Use (see Appendix 10A, Table GHG-15) 552 Total 17,678 Service Population (net new jobs, no residential) 15,070 MTCO2e per Service Population 1.17 2020 Threshold (MTCO2e/yr/service Population) 4.60 Exceed Threshold? No Notes: The Project Description, Table 3-7 projects the total net new employment pursuant to the Project at approximately 15,000 jobs (12,550 seated workers, or headcount + 2,470 consultants, service workers and visitors Source: Ramboll Environ, Appendix 10A, Table GHG-16, December 2017 Potential Emission Reductions of the Project The total GHG emissions resulting from indirect electrical sources and process gas use as presented in Table 10-6 above are considered conservative or “worst-case” emission values as they are based on a projection of current (2016) use factors per land use type, and applied to the Project’s increase in these land uses. However, pursuant to Genentech’s current sustainability goals, Genentech is targeting a voluntary 30% absolute reduction in CO2 emissions from on-site energy use as compared to 2010 levels. Some of the individual initiatives pursuant to this goal include the following. Green Building Design Genentech’s latest buildings have implemented sustainability ideas and strategies from a variety of sources, including: ● development of a Sustainability Design Checklist based on LEED4 NC (New Construction) to guide the identification of sustainable design areas for evaluation and implementation ● becoming an early partner in the U.S. Green Building Council Northern California Building Health Initiative ● participating in the Department of Energy’s Facility for Low Energy Experiments in Buildings (FLEXLAB) program ● achieving LEED Gold certification that recognizes best-in-class green building practices, and Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-38 Genentech Master Plan Update, Draft EIR ● using WELL Certification, which is the first building standard to focus on the health, productivity, and wellness of the people in the buildings by evaluating various aspects of a healthy building The most recent building additions to the Campus demonstrate Genentech’s commitment to a sustainable campus environment that enhances health, comfort and performance, while minimizing resource consumption. The Master Plan Update anticipates that every new building and Campus improvement will: ● be designed to respect the integrity and biodiversity of natural systems on the Campus ● employ architectural design methods aimed at controlling solar gain, including the use of solar shading devices, white roofing materials and building orientation ● utilize high recycled-content building materials and integrate energy-efficient and water-conserving systems ● utilize landscape with native and drought-tolerant plants ● include bio-swales or similar measures to control rainwater runoff ● be located on sites served by existing infrastructure; and ● will take into account opportunities to support public and alternative transportation modes Not every new building to be constructed pursuant to the Project will have the same opportunities to integrate sustainability into their design, construction and operation. However, these initiatives demonstrate Genentech’s commitment to sustainable, green building design and sustainable campus environments that enhance health, comfort and performance. Directive for Substances of Concern This Genentech (Roche) Directive provides a common basis for complying with international and national regulations and conventions, and the gradual phasing-out of concerned substances adversely affecting the ozone layer and the climate. Genentech’s Directive K6 requires eliminating the use of substances that have a negative impact on the environment caused by ozone depletion, global warming or persistence in the atmosphere with potential long-term negative effects. For Genentech, the K6 Directive requires that use of all chlorofluorocarbons (CFCs) and hydro-chlorofluorocarbons (HCFCs) be eliminated by 2018, and use of all hydrofluorocarbons (HFCs) be eliminated by 2022. Onsite Solar Program Genentech has initiated a solar panel installation program for the Campus that has the potential to generate over 6 million watts of power during peak production. During sunny hours, this system of solar panels could potentially provide up to 25% of on-Campus power needs. The program involves installation of more than 16,000 solar power panels throughout the Campus, covering approximately 277,000 square feet of roof area. The solar panels system could produce up to 9.7 million kWh annually, and as many as 36 electric car charging-stations could be connected to this system. Site Utility Project Genentech has initiated construction of a Site Utility Project that incorporates the latest technologies and high-efficiency system designs for industrial cooling and building air conditioning. This Site Utility Project includes installation of a Campus-wide looped pipe system for refrigerated water distribution, installation of new industrial chillers, and replacement of air conditioning equipment in all buildings on Campus. The environmental performance goal of the project targets a 50% reduction in energy used to produce refrigeration components of process cooling and air conditioning throughout all Campus buildings. The project design optimizes use of the latest available engineering technologies to result in significant Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-39 sustainability benefits. The first new chiller has been installed, meeting expectations of performance. Construction of the entire project is anticipated to run through 2019. Combined Heat and Power (CHP) Plant Genentech is exploring an option of installing a new combined heat and power (CHP) plant on Campus. Potentially, this CHP would be a cogeneration plant that would use a natural gas power station to generate electricity for Campus use and, rather than releasing by-product heat from this facility into the environment, use the residual process to heat water needed for industrial manufacturing and lab operations efficiently. Such a facility would increase use of natural gas (as analyzed above), but could substantially reduce direct electrical consumption at the Campus (perhaps by as much as 70 million kw/year), and offset a substantial portion of the electrical demands of new Campus growth. Mitigation Measures No mitigation is required. As indicated in Table 10-6, even under conservative assumptions regarding energy demand and process gas use, the Project would not exceed the service-based efficiency threshold for land use-based GHG emissions by year 2020. Operation of the Project would not exceed the threshold for GHG emissions per service population, and would result in a less than significant impact. Further, Genentech is now implementing numerous voluntary initiatives that will further reduce climate change emissions and result in significant energy savings. Other Operational GHG Emissions by Year 2030 GHG 5: The Project will not generate land use-based GHG emissions, other than those emissions addressed pursuant to the City CAP, that exceed the efficiency threshold of 2.7 MT of CO2e per year per service population at year 2030. The Project’s land use-based GHG emissions would not contribute significantly to global climate change, and this impact is considered less than cumulatively considerable. (Less than Significant) As described above (under Impacts GHG-1 through GHG-3 above), certain operational emissions of the Project are excluded from the types of emissions evaluated against numerical land use-based thresholds. The types of GHG emissions excluded from this analysis include all emissions otherwise addressed under Genentech’s participation in CARB’s Cap-and-Trade program, all stationary sources evaluated under the permitted stationary-source threshold and all emissions otherwise addressed under the South San Francisco Climate Action Plan. The types of GHG emissions that remain, and that are compared to the year 2030 land use-based threshold of 2.7 MT of CO2e per year per service population include emissions from indirect electricity use and emissions from process use of CO2 and HFC gas. Emissions in excess of the 2.7 MT of CO2e per year thresholds could impede attainment of statewide GHG reduction targets for 2030 established under SB 32 and Executive Order B-30-15 (i.e., a 40% reduction below 1990 levels by 2030, taking into account the difference in projected 2030 statewide population and employment levels). To estimate a significance level for land use projects extending beyond 2020 (like the Project), it is necessary to extrapolate the 2020-based thresholds to account for the trajectory of anticipated land use related GHG emissions reductions that are needed to meet the state’s adopted 2030 GHG goals. SB 32 addresses GHG emissions reduction goals through 2030, and long-term goals for 2030 have been articulated in EO B-30-15. Achieving SB 32 and EO B-30-15 GHG emissions reduction goals will require systemic changes in how energy is produced and consumed through all sectors of the economy. The mix of technologies, strategies and policy choices that the State will ultimately choose to implement toward achievement of the year 2030 goal is not readily ascertainable at this time. Therefore, accounting of future GHG emissions from an individual development project cannot reflect the scope and scale of reductions that may occur as the State transitions Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-40 Genentech Master Plan Update, Draft EIR toward new regulations designed to achieve the new long-term goals. Furthermore, in absence of a definitive State plan to achieve these long-term goals, it is difficult to identify the “fair share” of reductions to be applied at the local level or to the Project. The 2030 threshold used in this EIR is derived from the GHG reduction goal established under SB 32 and EO B-30-15 (i.e., a 40 percent reduction below 1990 levels by 2030, taking into account the 1990 emissions levels and the projected 2030 statewide population and employment levels).35 Emissions in excess of the 2030 threshold of 2.7 MT of CO2e per year per service population could impede attainment of statewide GHG reduction targets for 2030 established under SB 32. The 2030 assessment conservatively assumes full Project build-out by 2030. Table 10-7 compares the incremental GHG emissions at the assumed full buildout year (of 2030), as compared to the threshold of 2.7 MT of CO2e per year per service population. Table 10-7: Net New Emission Sources Compared to the Year 2030 Land Use Threshold Emission Category Net New GHG (MTCO2e/yr) Construction (see Appendix 10A, Table GHG-16) 1,321 Indirect Electricity (see Appendix 10A, Table GHG-10) 14,845 HFC Gas Use (see Appendix 10A, Table GHG-15) 960 Process CO2 Gas Use (see Appendix 10A, Table GHG-15) 552 Total 17,678 Service Population (net new jobs, no residential) 15,070 1 MTCO2e per Service Population 1.17 2030 Threshold (MTCO2e/yr/service Population) 2.70 Exceed Threshold? No Notes: The Project Description, Table 3-7 projects the total net new employment pursuant to the Project at approximately 15,000 jobs (12,550 seated workers, or headcount + 2,470 consultants, service workers and visitors Source: Ramboll Environ, Appendix 10A, Table GHG-16, December 2017 The total GHG emissions resulting from indirect electrical sources and process gas use as presented in Table 10-7 above are considered conservative or “worst-case” emission values. Genentech is targeting a voluntary 30% absolute reduction in CO2 emissions from on-site energy use, as compared to 2010 levels, and these energy reductions are not included in the emissions estimates. Mitigation Measures No mitigation required. As indicated in Table 10-7, even under conservative assumptions, the Project would not exceed the service-based efficiency threshold for land use-based GHG emissions by year 2030. Operation of the Project would not exceed the threshold for GHG emissions per service population, and would result in a less than significant impact. 35 The detailed derivation of this threshold is provided in Appendix 10A, Table GHG-2. Chapter 10: Greenhouse Gas Emissions and Climate Change Genentech Master Plan Update, Draft EIR Page 10-41 Construction-Related GHG Emissions This EIR evaluates anticipated mass emissions of GHGs from construction activities. Although there are no construction-related CEQA significance thresholds for GHG emissions, the Project’s construction emissions are amortized over the project lifetime (assumed to be 40 years, consistent with Genentech’s historical data and future projections for building operational lifespans) and added to the annualized operational GHG emissions for comparison to significance thresholds as shown in Tables 10-6 and 10-7. Construction Emissions GHG emissions from construction include emissions from off-road equipment (primarily diesel-fueled) and on-road vehicles. Methodologies for calculating each type of construction-related emissions are presented below, with detail provided in Appendix 10A - Table GHG-3: Emissions Calculations Methodology. Off-Road Diesel Equipment California Emissions Estimator Model (CalEEMod®)36 was used to generate an inventory of construction equipment including details on the equipment type, quantity, construction dates and hours of operation anticipated for each piece of equipment for each construction phase. CalEEMod® generated the construction equipment inventories based on the Project’s assumed construction area. CalEEMod uses ARB’s 2011 Off- Road Equipment Model (OFFROAD 2011) methodology to estimate emissions from this equipment inventory. OFFROAD 2011 incorporates statewide survey data to develop emission factors based on the fleet average for each year of operation. The OFFROAD 2011 model also identifies default horsepower and load factors for each type of equipment, which are included in CalEEMod. On-Road Vehicles ARB’s Emission Factor model (EMFAC 2014)37 was used to estimate emissions from construction-period haul trucks, vendor trucks and commuting worker vehicles. EMFAC 2014 is an emission inventory model developed to determine emission rates from motor vehicles operating on highways, freeways and local roads in California and is commonly used by ARB to project changes in future emissions from on-road mobile sources. EMFAC 2014, incorporates regional motor vehicle data, information and estimates regarding the distribution of vehicle miles traveled (VMT) by speed, and number of starts per day. ● GHG emission from on-road haul trucks were calculated using emission factors from EMFAC 2014 and the total number of trips. Consistent with CalEEMod defaults, a 20-mile one-way trip length is assumed. The total number of hauling truck trips is estimated based on the total number of demolition and excavation soil quantities. To estimate the soil import/export quantities for the Project, two separate excavation rates (one for projects on steep terrain, and another for projects on flat terrain) were used, based on soil excavation data form prior Genentech projects in the Project area. ● GHG emission factors for vendor trucks were obtained from EMFAC 2014. The total vendor truck trips are estimated by CalEEMod default assumptions of a 7.3-mile, one-way trip length. ● GHG emission factors for commuting worker vehicles are also generated with EMFAC 2014 based on vehicle weight class and default assumptions of a 12.4-mile trip length. 36 California Air Pollution Control Officers Association (CAPCOA), 2016, California Emissions Estimator Model (CalEEMod®). Available online at http://www.caleemod.com/ 37 California Air Resources Board (ARB). 2014. Mobile Source Emission Inventory - EMFAC2014, Available at https://www.arb.ca.gov/msei/categories.htm#onroad_motor_vehicles Chapter 10: Greenhouse Gas Emissions and Climate Change Page 10-42 Genentech Master Plan Update, Draft EIR ● On-road N2O emissions are converted to GHG emissions in accordance with EMFAC-derived emission factors. Total Construction-related GHGs GHG emissions for the construction phases of the Project are estimated at approximately 52,900 metric tons CO2e, as shown in Table 10-8. Table 10-8: Construction-Related GHG Emissions Emission Category Total GHG (MTCO2e) Demolition 748 Site Preparation 221 Grading 4,497 Construction 46,977 Paving 271 Architectural Coating 186 Total 52,900 Source: Ramboll Environ, Appendix 10B, CalEEMod Version: CalEEMod.2016.3.1, aggregate of all construction-related on-site and off- site GHG emission, December 2017 Mitigation Measures No mitigation is required. There is no CEQA threshold of significance for GHG emissions from construction- related activities. Nevertheless, the Project shall implement the following Basic construction mitigation measures as listed in Mitigation Measure Air-1B, which directly reduce GHG emissions: ▪ Idling times shall be minimized, either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). ▪ All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. Cumulative GHG Emissions Analysis of the Project’s climate change impacts as discussed above provides an analysis of the Project’s contribution to cumulatively significant global impacts through its individual emission of GHGs. The cumulative impacts of the Project with respect to the issue of climate change are therefore captured in the project-level analysis (Impacts GHG-1 through Construction Emissions) and no further cumulative analysis is necessary.