Climate Change Obligations By Matt Burris

As the topic of climate change becomes hotter and hotter, we at CTG are increasingly working with clients to help them understand their potential obligations under state laws such as AB 32 and the California Environmental Quality Act (CEQA) to engage in activities that are becoming commonly known as Climate Action Planning. As cities and counties update their General Plans, they are required to implement a climate change program in order to demonstrate how their communities will start transitioning to a low carbon future. What we have found is that there is a growing level of uncertainty as to what might be the appropriate scope of effort to in order to develop an appropriate emissions reduction program.

We are finding that there are generally three types of climate change programs that communities, colleges, and other organizations are developing. These types of programs are largely defined by their difference in detail of the input data, the type of verification or reductions (if any), and the nature of the implementation plan.

1. Policy Grade:
   
   Policy grade programs include GHG inventories that are comprised of a minimum level of detail and statistical data rather than measured data. They present a vision, high-level policies, and measures for the reduction of emissions, but likely do not have a detailed implementation plan. Their purpose is to provide enough information to begin a dialogue on reducing GHG emissions and to establish new policies for reducing GHG emissions.



2. Regulatory Grade:
   
   Regulatory grade programs present moderately detailed GHG inventories, specific emissions reduction measures with quantified emissions reductions potential, a clear foundation for project evaluation and approval, and clear guidance to the private sector on requirements and expectations. Their primary purpose is to assist communities with the review of development applications.



3. Registry Grade:
   
   Registry grade programs present detailed GHG inventories with quantified emissions reductions potential, an implementation framework, a process for verifying reductions in accordance with the procedures of a selected registry, and steps for reporting reductions to a registry. Their purpose is to provide a program for reporting emissions reductions to an organization such as the Climate Action Reserve.

One of the key steps a community must undertake before committing to an emissions reduction program is to determine which program approach is most appropriate. Community leaders should consider what their needs are and how their emissions reduction program will be used when it is complete. Is the program meant to be mainly inspirational and begin a community discussion on how to reduce emissions? Is the program meant to provide a framework for regulating new development? Is the program meant to measure actual fuel use and emissions for reporting to the Climate Action Reserve? Additionally, communities should consider the tiering guidance of SB 97 to ensure a seamless connection with future CEQA compliance.

Communities should also consider the resources they can commit to an emissions reduction program. Very generally speaking, the level of detail involved in developing the emissions inventory and in analyzing the emissions reduction potential of various strategies correlates to the level of effort needed to complete the program. However, this is not always the case as data availability, community involvement, and political environment can also strongly affect the program development process and require additional effort.


As more communities draft emissions reduction programs, the industry will begin to better understand the process and the merits and limitations of the various grades of emissions reduction programs. As the economy recovers and communities begin implementing their emissions reduction programs, this discipline will take a leap forward, informed with the knowledge of which data works and which emissions reductions strategies are most effective, helping to reduce the level of effort needed to prepares these programs and increasing the overall sophistication Climate Action Planning.

-Matt

Matt Burris is a Director with CTG Energetics based in CTG’s Irvine office. He manages the firm’s climate services team and is currently leading efforts to develop emissions reduction programs for communities in State of California.
ctg@ctgenergetics.com