No impact to the General Fund. The cost of processing this GPA is covered 100% by the Department of Conservation and Development (DCD) Land Development Fund.

  
PROJECT DESCRIPTION  
The project is a County-initiated GPA that would add a policy to the Conservation Element of the 2005-2020 County General Plan addressing air quality impacts and greenhouse gas emissions related to certain types of commercial and industrial development.   
  
ENVIRONMENTAL REVIEW  
GPAs qualify as projects under CEQA and are therefore subject to environmental review. Staff determined that the proposed project would not have a significant environmental impact for the following reasons:  
  
a. The proposed GPA would not grant an entitlement or approval for a development project with potential to cause significant environmental impacts;  
b. The proposed GPA would not increase existing or planned densities, alter existing or planned development patterns, or allow development to occur in areas where it is currently prohibited; and  
c. The proposed GPA is environmentally beneficial, as its purpose is to improve air quality and reduce greenhouse gas emissions.  
  
Pursuant to CEQA Guidelines Section 15061(b)(3), the proposed GPA is exempt from CEQA because it can be seen with certainty that the project would not have a significant effect on the environment.  
  
STAFF ANALYSIS  
DCD has seen an influx of applications for development of light industrial projects, particularly in the North Richmond community. While sometimes constructed for a known tenant, these buildings are also developed "on spec," meaning they are built without a particular tenant or use committed to the project at the time of construction. As such, they could eventually house any number of uses including warehouses/distribution centers, food processing facilities, light manufacturing facilities, etc. These uses, and the buildings they occupy, tend to have the following common characteristics:  
  
1) High energy consumption, particularly electricity;  
2) Large, flat roof surfaces and parking areas;  
3) Generate significant amounts of truck traffic; and  
4) Construction involves disturbance of large surface areas.  
  
Certain retail uses, like big-box stores and shopping centers, have similar characteristics. Development of this type can cause direct negative air quality impacts in surrounding communities, during construction and operation, through emissions of particulate matter and other “criteria pollutants.”  
  
Criteria Air Pollutants  
Criteria air pollutants are the following pollutants for which the U.S. Environmental Protection Agency (U.S. EPA) has set National Ambient Air Quality Standards (NAAQS) to protect public health and the environment: Carbon Monoxide (CO), Nitrogen Oxides (NO_X), Particulate Matter (PM₁₀ and PM_2.5), Sulfur Oxides (SO_X), Ozone (O₃), and Lead (Pb). The State of California has adopted its own, more stringent standards known as California Ambient Air Quality Standards (CAAQS). The CAAQS include the pollutants covered under the NAAQS as well as Hydrogen Sulfide (H₂S), Sulfate, Vinyl Chloride, and Visibility Reducing Particles. These pollutants are the typical focus of air quality impact studies conducted as part of CEQA analyses.  
  
During a project’s construction phase, principal sources of criteria pollutants are exhaust from construction equipment, trucks, and automobiles, and ground-disturbing activities (e.g., excavation and grading) that cause particulates to become airborne. During operation, emissions are dependent on the use itself and the type and quantity of its associated traffic. Manufacturing and processing uses, uses involving hazardous compounds, and uses that generate substantial truck traffic generally cause more severe air quality impacts. Numerous published studies from bodies such as the U.S. EPA, California Air Resources Board (CARB), Bay Area Air Quality Management District (BAAQMD), universities and research institutes, and medical professionals have demonstrated a link between increased exposure to diesel truck emissions (especially PM_2.5) and increased rates of asthma, bronchitis, certain types of cancer, and other serious medical conditions.   
  
Toxic Air Contaminants  
CARB has identified numerous other compounds as toxic air contaminants (TACs). Some of these, such as nickel, asbestos, chloroform, formaldehyde, and tobacco smoke are familiar to the general public. Most are generally obscure compounds associated with industrial processes and manufacturing. Particulate matter from diesel-fueled engines, which the proposed General Plan policy would address, is an identified TAC.   
  
Energy Consumption and Greenhouse Gas Emissions  
Light industrial and large commercial uses tend to be significant consumers of electricity, and often natural gas as well. This demand is typically related to machinery and equipment operation, processing activities, and the need to illuminate, heat, and cool large-volume spaces. While air quality in the vicinity of these uses may not necessarily be impacted by their high electrical demand, electricity generation increases cumulative air pollutant and greenhouse gas concentrations whenever that electricity is generated through fossil fuel combustion. Thus, reducing a project’s electrical demand, or increasing its reliance on renewable energy sources, has a positive impact on overall air quality.  
  
Combustion of natural gas, while cleaner than combustion of other fossil fuels such as coal and oil, produces carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), volatile organic compounds (VOCs), NO_x, SO_x, CO, and trace amounts of PM. Several of these compounds are criteria pollutants, while others (CO₂, N₂O, and CH₄) are greenhouse gases. Reducing a project’s demand for natural gas therefore has a positive impact on overall air quality and localized air quality in the project vicinity.  
  
Renewable Energy Potential and Solar-Ready Construction  
Light industrial and commercial projects often have flat and expansive roofs and parking areas that offer opportunities for renewable energy generation through installation of photovoltaic (PV [aka solar]) panels. For the largest projects, like distribution centers and shopping malls, these areas will encompass dozens of acres. Utilizing this resource to its full potential requires thoughtful site planning and building design to avoid unnecessarily obstructing or shading prime areas for solar installation. Buildings must also be structurally capable of supporting solar panels and equipped with adequate conduit and electrical panels. The comprehensive approach to preparing buildings for future solar installation is known as “solar-ready” construction, and is already required by the State of California for certain types of nonresidential buildings.[1] However, actual installation of PV panels is not a State requirement.  
  
Board of Supervisors Direction to Amend the General Plan  
On May 7, 2018, the Board’s Ad Hoc Committee on Sustainability accepted a report from DCD staff on recent efforts to address the impacts and opportunities presented by light industrial development in the North Richmond community (see Attachment 2). The County Planning Commission’s March 14, 2018, approval of a 482,000-square-foot warehouse/ distribution facility in North Richmond was highlighted during the discussion because it included supplemental measures to reduce air quality impacts and greenhouse gas emissions beyond what would normally be required under CEQA or BAAQMD regulations.[2] The following is a partial list of the supplemental requirements included in that approval (the full list is available in Attachment 2):  

• “Solar ready” construction and installation of solar panels sufficient to supply the tenant's base electrical load.
• Loading dock electrification to allow refrigeration trucks and future electric trucks to be plugged in, reducing the need for unnecessary idling to keep the refrigeration units powered.
• Use of "clean fleet" vehicles and electric forklifts.
• Periodic sweeping of driveways and parking areas to remove tire wear, brake dust, and other particulates.
• Restriction on truck idling on-site and in the surrounding neighborhood.
• Payment of a fair-share contribution toward development of a solar project for the benefit of North Richmond residents, as mitigation for increased truck emissions.

• Energy Efficiency 6: Energy-Efficient New Buildings. Support the statewide transition to zero net energy (ZNE)[3] construction for new residential buildings by 2020 and nonresidential buildings by 2030. The performance target is three new ZNE businesses by 2020.
• Renewable Energy 1: Alternative Energy Installations. Promote installation of alternative energy facilities on homes and businesses. The performance target is 10 new businesses with photovoltaic arrays by 2020.
• Land Use and Transportation 3: Off-Road Vehicles and Equipment. Reduce emissions from off-road vehicles and equipment. There is no performance target for commercial and industrial equipment specifically, but reducing emissions from such equipment will help to achieve this measure’s overall reduction target of 10 metric tons of CO₂ equivalent by 2020.

The County General Plan currently does not contain policies directly addressing land uses that are, or may potentially be, sources of significant air pollution and greenhouse gas emissions. Instead, the General Plan indirectly addresses such uses with policies aimed at achieving compliance with State and federal air quality standards. Adoption of the proposed GPA would establish policy for implementing more stringent measures to control air pollution and greenhouse gas emissions from commercial and industrial projects over 10,000 square feet in area. Rejection of the proposed GPA would maintain the status quo.

Adoption of the proposed GPA will establish policy for reducing air quality impacts and greenhouse gas emissions related to certain types of commercial and industrial development. This supports outcomes 2 and 5 as established in the Children's Report Card adopted by the Board of Supervisors: 2) Children and Youth are Healthy and Preparing for Productive Adulthood; and 5) Communities are Safe and Provide a High Quality of Life for Children and Families.