CEQA/NEPA

The California Environmental Quality Act (CEQA) and the National Environmental Policy Act (NEPA) require disclosure to decision-makers and the public of potential significant adverse environmental effects of proposed activities, as well as how those effects can be avoided or reduced.

Ashworth Leininger Group works with public agencies, project applicants, and legal counsel to assess project impacts related to air quality and global climate change, and ways to reduce those impacts to acceptable levels. Following is a list of CEQA/NEPA services we provide:

Air Quality Impacts

ALG conducts air quality impact assessment services consistent with criteria established by the applicable local air quality management agency and/or lead agency. ALG can provide the following air quality impact assessment services:

  • Criteria pollutant emissions estimation and modeling
  • Evaluating carbon monoxide and other pollutant "hot spots"
  • Assessing impacts from odors and other nuisances
  • Evaluating cancer and non-cancer effects associated with air toxics
  • Determining project-level as well as cumulative impacts
  • Looking at impacts associated with project operation as compared to project construction
  • Incorporating emissions associated with stationary, mobile, and area-wide emission sources
  • Assessing project consistency with applicable air quality plans, rules, and policies
  • Identifying opportunities to reduce impacts to a less than significant level

Global Climate Change

Only a few agencies currently have published specific guidelines addressing the impacts of greenhouse gas (GHG) emissions on global climate change in environmental documents prepared under CEQA and NEPA. In the absence of published guidelines, ALG has worked with lead agencies and legal counsel to identify appropriate procedures for addressing global climate change for specific projects, based on published guidelines in other jurisdictions, consistency with adopted plans to reduce GHGs, comparison of future GHGs to "business as usual" emission trends, and other available credible evidence. ALG's assessments consider:

  • Identifying stationary, mobile, and area-wide sources of GHGs
  • Calculating GHG emissions using available credible evidence from agency approved and generally accepted GHG emission calculation techniques and methods
  • Incorporating indirect sources of GHGs resulting from use of electricity, water, wastewater, and other utilities
  • Accounting for the varying global warming potentials for different GHG constituent gases
  • Comparing project operations to "business as usual" emission trends
  • Documenting all calculations, sources, references, and assumptions so that the analysis is transparent and defensible

Mitigation Measures

ALG works with project applicants and lead agencies to identify feasible measures to mitigate air quality and greenhouse gases. Ideally, the goal is to mitigate the identified impact to less than significant. Where this is not possible, ALG works to identify all potential measures to reduce emissions, determine which measures are feasible and which measures are not feasible, and document the extent to which impacts can be mitigated with implementation of all feasible measures.

This analysis supports project approval by local lead agencies, when supported by findings that all feasible mitigation measures have been incorporated and that the project's benefits outweigh its adverse impacts.


Public Participation and Advocacy

Once an Environmental Impact Report is prepared under CEQA (or an Environmental Impact Statement is prepared under NEPA), the lead agency will circulate the document to adjacent landowners, nearby residents, public agencies, and other interested parties for their review. These parties have an opportunity to provide comments on the environmental document or the project itself during the public comment period – either in writing, or in person during a public hearing. ALG works with project applicants and lead agencies to secure approval of the environmental document and the underlying project by providing the following services:

  • Providing comments on behalf of the project applicant to address issues raised by other parties, to supplement information provided in the environmental document itself, or highlight project benefits
  • Preparing suggested responses to public comments on behalf of the lead agency
  • Responding to technical questions regarding the air quality or greenhouse gas analysis at public hearings
  • Testifying on behalf of the project applicant at public hearings regarding the environmental analysis or the proposed project

Health Risk Assessments

Ashworth Leininger Group’s health risk assessment (HRA) practice leverages our expertise in air toxics emissions inventory development, best available control technology for toxics (T-BACT) determination, and air dispersion modeling on behalf of industrial and regulatory clients. As illustrated below, ALG has the capabilities to:

  • Develop defensible toxic air contaminant (TAC) emission inventories under the California Air Toxics Hot Spots Program (AB 2588);
  • Use Geographic Information System (GIS) to develop key input data for HRAs;
  • Perform air dispersion modeling consistent with EPA, ARB, and local air district modeling guidelines;
  • Execute health risk assessment models that use the source emission rates developed in the emission inventory task and the output of the air dispersion modeling to quantify potential health effects;
  • Prepare comprehensive HRA reports; and
  • If necessary, provide assistance in making T-BACT determinations and developing Risk Reduction Plans.

ALG has conducted health risk assessments and other environmental modeling to support CEQA/NEPA determinations; examples include:

  • Evaluated potential health risks to determine the feasibility of a project that would greatly increase the number of diesel-fueled heavy-duty truck trips to an existing industrial facility in southern Los Angeles County. Followed California Air Resources Board and South Coast Air Quality Management District risk assessment protocols for determining mobile source diesel particulate matter emissions and their associated health effects;
  • Assisted with an Environmental Impact Report (EIR) for additions and modifications to a California refinery necessary to produce reformulated gasoline required by the federal Clean Air Act Amendments and the California Air Resources Board. Supervised emissions calculations and directed air dispersion modeling and human health risk assessment. Assisted refinery in negotiating with the South Coast Air Quality Management District as lead agency for the EIR, including development of modeling protocols;
  • Prepared air quality impact analyses in support of a third party EIR for proposed expansion of the ski resort. Analyses included modeling of power plant emissions, including a health risk assessment for diesel engine exhaust; modeling of wood smoke emissions; and modeling of carbon monoxide emissions from resort traffic. A cumulative impact analysis was also performed for particulate emissions

For more information on ALG's HRA services please refer to our HRA brochure.

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"Verification of GHGs is challenging endeavor especially with numerous diverse facilities. Working with ALG has made this detailed process both a success and a valuable learning exercise. Year after year the results have been professional, on time and on budget. We look forward to many more years of verification success with ALG."
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