Mitigation Support

When a project is ultimately determined to have significant air quality, health risk, or greenhouse gas (GHG) impacts, the California Environmental Quality Act (CEQA) requires that project to provide mitigation measures for reducing or eliminating significant environmental impacts. Otherwise, the Lead Agency would be required to prepare and publish a Statement of Overriding Considerations in order for a project with significant impacts to proceed.

Mitigation measures are a means of reducing impacts, either directly by reducing emissions at the project source (controls and technology improvements), or indirectly by reducing emission achieved elsewhere and allocated to the project (offsets and sequestration).

Mitigation measures for stationary source operational emissions include:

• Implementation of emission controls beyond those required by Air District rules and regulations;
• Replacement of old high-emitting equipment with new lower-emitting equipment;
• Implementation of lower-emitting alternate basic processes where applicable; and
• Providing permanent emission offsets in excess of those required under New Source Review (NSR) rules.

Mitigation measures for temporary mobile source emissions, such as construction, include:

• Use of newer construction equipment and trucks with lower-emitting diesel engines, particularly heavy earthmoving equipment with large diesel engines;
• Implementation of after-market emission controls not otherwise required by State or federal regulations for certain categories of equipment, i.e., verified diesel emission control strategies (VDECS); and
• More frequent application of water for enhanced dust suppression, use of dust palliatives where effective, and routine street sweeping outside construction site.

Mitigation measures for operational GHG emissions include:

• Energy efficiency surpassing Title 24 standards – high efficiency equipment and lighting;
• Water efficiency and conservation – plumbing fixtures and landscaping;
• Waste reduction and recycling – facility and municipal programs; and
• Carbon sequestration – on-site landscaping and off-site tree planting.

Under CEQA, control strategies otherwise required by State or federal regulations cannot be claimed as mitigation. As such, control and technology mitigation measures must reduce emissions to levels below those needed for regulatory compliance.

For example, if the current rule limit for a gas-fired commercial boiler is a NO_x concentration of 30 parts per million by volume (ppmv) without add-on controls, voluntarily installing Best Available Control Technology (BACT) under permit to further reduce NO_x to 6 ppmv (which would result in an 80% reduction) would be considered mitigation, and the reduction in NO_x mass emissions associated with the voluntary 24 ppmv decrease could be debited from the project emissions balance. Similarly, offsetting emissions only in the amount required under NSR rules cannot be claimed as mitigation; however, offsets provided in excess of the minimum amount can be claimed as mitigation.

As a specialty air quality firm, Yorke Engineering, LLC is well-versed in mitigation options and emission control alternatives for a wide range of stationary and mobile emission sources. We have extensive compliance experience with hundreds of commercial and industrial projects. Our experience is applied to each new project. We will recommend the most efficient, cost-effective solution to reduce compliance costs and ensure the least disruption to construction and operational activities.

Not only can Yorke recommend mitigation measures that will aid in getting the project’s CEQA document approved, but we can also provide support during, and after, the mitigation approval process. For instance, many CEQA approvals include a requirement to prepare a Mitigation Monitoring and Reporting Program (MMRP), which details the mitigation requirements, how they will be implemented, and how compliance with the required mitigation measures will be demonstrated.

In some cases, the MMRP is prepared as part of the MND or EIR, but its preparation can also be a requirement of the approval process. Yorke can assist with the implementation of the MMRP, as well as its preparation. For example, our staff can provide their expertise in tracking construction vehicle usage and emissions to ensure compliance with engine certification and other mitigation requirements.

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Yorke Engineering has assisted over 2,000 industrial and government facilities across California with EH&S consulting and air quality consulting, as well as permitting and compliance for storm water, wastewater, hazardous waste, industrial hygiene, and safety programs. Learn more here: Services – Yorke Engineering, LLC

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