What You Need to Know About BAAQMD’s New GHG Thresholds

What You Need to Know About BAAQMD’s New GHG Thresholds image
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In April 2022, the Bay Area Air Quality Management District (BAAQMD) updated its thresholds of significance for use in determining whether a proposed land use project will have a significant impact on greenhouse gas (GHG) emissions. These thresholds were updated to coincide with the updated California Environmental Quality Act (CEQA) “fair share”-based thresholds.

Why Are Thresholds Changing?

As in most areas of our evolving world, time necessitates change. BAAQMD originally developed these thresholds in 2010 to establish levels at which it was believed air pollution and greenhouse gas (GHG) emissions would cause significant environmental impacts under CEQA in the Bay Area of California.

Since then, California’s GHG targets have shifted. The California Air Resources Board (CARB) 2017 Scoping Plan set GHG targets for 2030, aiming to reduce emissions to 40% below 1990 levels. Local governments also have been asking for updated thresholds to support their planning efforts.

Additionally, significant changes in case law made these changes inevitable. BAAQMD recommends the “fair share” thresholds to follow an approach endorsed by the California Supreme Court in Center for Biological Diversity v. Department of Fish in Wildlife, a 2015 case that ruled projects must be evaluated based on the state’s long-term climate goals.

In land-use projects, “fair use” is identified as maintaining a less-than-significant impact on the global climate. BAAQMD has analyzed what will be required of new land-use development projects to achieve CARB’s 2030 climate target, as well as to meet California’s long-term climate neutrality goal by 2045.

What is Changing?

According to the newly updated GHG thresholds, land-use building project plans must meet one of two requirements:

  1. Projects must feature an all-electric project design, with no natural gas appliances or plumbing, and not result in any wasteful, inefficient, or unnecessary energy usage. Projects must also achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average or meet a locally adopted target and achieve compliance with CALGreen Tier 2 off-street electric vehicle requirements. Or,
  2. Projects must be consistent with a local GHG reduction strategy that meets the criteria under state CEQA guidelines Section 15183.5(b).

BAAQMD recommends these thresholds of significance for use in determining whether a proposed project will have a significant impact on climate change.  

In addition, the updated thresholds require cities and counties adopting general plans and related planning documents to either be consistent with a local GHG reduction strategy or meet the state’s goals to reduce emissions to 40% below 1990 levels by 2030 and carbon neutrality by 2045.

What is Required of Agencies?

CEQA requires agencies in California to analyze climate impacts by evaluating whether a proposed project would make a considerable contribution to the significant cumulative impact on climate change. However, CEQA does not provide specific guidance on what constitutes a “considerable contribution,” so the BAAQMD thresholds serve to guide agencies in determining whether their proposed projects would contribute significantly to global climate change.

According to BAAQMD, if a new land-use project would serve California’s pressing need to provide housing, jobs, and related infrastructure, it may be meeting the “fair share” contribution to combat climate change, and therefore its GHG emissions should not be treated as cumulatively considerable.

As the Supreme Court held, “consistency with meeting those statewide goals is a permissible significance criterion for project emissions,” and an agency’s “choice to use that criterion does not violate CEQA.”

Future-Proof Your Project

While no single project can be expected to solve climate change on its own, each individual project is obligated to do what is necessary to ensure the overall solution is implemented. Within the land use sector, GHG emissions come primarily from building-energy use and transportation, so these are the areas that must be evaluated in the effort to lower GHG emissions. FCS can help with navigating these obligations, ensuring that projects meet their “fair share” of emission reductions in accordance with California’s long-term climate goals.

The BAAQMD is in the process of updating the CEQA Guidelines and will provide details on how projects can apply the new thresholds. While implementation guidelines are meant to assist and inform local agencies in the Bay Area, they are advisory in nature and should be followed by local governments at their own discretion.

Just as these thresholds changed from 2010 to 2022, the global climate crisis will continue evolving, too. Streamlining the often-complex BAAQMD process for your projects is critical for on-time and on-budget completion.


FirstCarbon Solutions (FCS), an ADEC Innovations company, comprises over 100 individuals offering due diligence, technical analysis, planning, environmental compliance, permitting, and mitigation/monitoring services for public and private projects. FCS has more than 30 years of experience navigating the complexities of CEQA and securing project approvals. Contact us for a free consultation to learn more about how we can help with your specific project requirements.


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