Volume 2: Draft Gorst Planned Action Environmental Impact Statement

GORST PLANNED ACTION EIS | AFFECTED ENVIRONMENT, SIGNIFICANT IMPACTS, AND MITIGATION MEASURESdevelopment projects, where projects receiving funding must be evaluated for consistency with state and federalGHG limits and state VMT goals (RCW 70.235.070).Ecology issued guidance in 2010 for SEPA reviews related to GHG emissions, for SEPA actions for which a localgovernment agency is the SEPA lead agency (Ecology 2013a). That guidance indicated all SEPA reviews mustevaluate GHG emissions. The guidance document presented a range of ways that local agencies could setsignificance thresholds and calculate GHG emissions and potentially mitigate those emissions. However, theguidance did not stipulate what GHG significance threshold must be used, nor did it specify what level of GHGemission reductions is required under SEPA. The guidance emphasized those decisions must be made by the SEPAlead agency on a case-by-case basis.Ecology issued revised guidance in June 2011 for SEPA reviews regarding actions where Ecology is the SEPA leadagency (Ecology 2013b). The revised guidance is related to GHG emissions for projects where emissions arepresumed not to be significant and outlining measures for mitigation to meet state emissions reduction limits. Thisguidance is applicable only to projects where Ecology is the lead agency or agency with jurisdiction. The 2011Ecology guidelines do not specify significance thresholds or mitigation requirements for local governmental actionsfor which the municipality is the SEPA lead agency. Regardless, they illustrate the importance of local actions toreduce GHG emissions.In 2011, the Washington State Department of Commerce released an updated Washington State Energy Strategyfor 2012 (Washington State Department of Commerce 2011), which includes short- and long-term policy options tomeet the following goals:1. Maintain competitive energy prices that are fair and reasonable for consumers and businesses and supportWashington’s continued economic success.2. Increase competitiveness by fostering a clean energy economy and jobs through business and workforcedevelopment.3. Meet the state’s obligations to reduce GHG emissions.The Washington State Energy Strategy outlines strategies meeting these goals in the categories of transportationefficiency, building efficiency, distributed energy and pricing.Puget Sound Clean Air Agency RegulationsAll construction sites in the Puget Sound region are required to implement rigorous emission controls to minimizefugitive dust and odors during construction, as required by PSCAA Regulation 1, Section 9.15, Fugitive Dust ControlMeasures.All industrial and commercial air pollutant sources in the Puget Sound region are required to register with PSCAA.Facilities with substantial emissions are required to obtain a Notice of Construction air quality permit beforeconstruction is allowed to begin. The application for this permit requires the facility to install best available controltechnology to reduce emissions, conduct computer modeling to demonstrate that the facility’s emissions will notcause ambient concentrations to exceed the NAAQS limits, and minimize the impacts of odors and toxic airpollutants.In 2004, PSCAA published its strategy document for climate change, entitled Roadmap for Climate Protection:Reducing GHG Emissions in Puget Sound (PSCAA 2004). In this strategy document PSCAA recommended a broadrange of GHG reduction measures including regional vehicle trip reduction, building energy efficiencyimprovements, solid waste reduction, forestry and agriculture practice improvements, and community education.This document also encouraged local municipalities to encourage their own GHG reduction measures; however, itdid not propose a SEPA significance threshold for GHG emissions, nor did it require local governments to imposefuture mitigation measures for future development projects for which the municipality is the SEPA lead agency.Regardless, this document illustrates the importance of local government actions to reduce GHG emissions.Draft | June 2013 3-30