Back in 2011, the San Luis Obispo County Air Pollution Control District (APCD) Board raised the fees it charges businesses and farmers by 5.2 percent for permits and inspections. It justified the increase on the basis that the money was needed to cover its employees’ increased salary and pension costs. Apparently the agency had enough funding (not withstanding its pleas for more revenue) to develop a whole new regulatory scheme that will suppress economic recovery.
The same regulatory muggers who are promulgating the dunes dust ATV riding ban in Oceano and who levy fees on wineries based upon the amount of gases generated by fermentation (and we thought the aroma was part of the allure) voted six to five to adopt so-called “greenhouse gas threshold” requirements for new construction. This means more trouble and cost for anyone who has the fortitude to attempt to build a housing development, apartment house, hotel, commercial office building, or a manufacturing facility anywhere in San Luis Obispo County (cities and unincorporated area). Proposers of these and other types of development will now be forced to calculate the amount of greenhouse gases (principally, but not limited to carbon dioxide—CO2) likely to be generated during the construction phase of the project and, more significantly, the amounts to be generated each year over the life of the project. Those buildings and groups of homes exceeding the thresholds will be required to reengineer their plans to reduce the amount of CO2 estimated to be generated.
Shockingly, none of this is needed, because the greenhouse gas emissions generated on the Central Coast are meaningless in the context of emissions generated throughout our state and nation, let alone the rest of the world. The fact is the requirements being proposed will have no meaningful impact on the CO2 that exists today or that might exist in the future. Check the math:
It is estimated by the State of California Air Resources Board (CARB) that by the year 2020 greenhouse gas emissions in California from all sources will total more than 500 million metric tons per year. On a geographic basis, more than half of this amount is generated in the San Francisco Bay area and the Los Angeles metropolitan area.
Of this amount, 343 million metric tons will come from land-use-related activities such as transportation, electric power generation, commercial and residential facilities, agriculture and farming, and recycling and waste.
The San Luis Obispo County APCD estimates that, of the 343 million metric tons per year, San Luis Obispo County will generate 2.6 million metric tons in 2020.
The APCD’s greenhouse gas threshold standards for new construction are calculated to remove 13,788 metric tons per year by 2020. This number contains a huge assumption: that there will be enough new construction in the county to actually generate any new greenhouse gases.
Most egregiously, the 13,788 metric tons APCD claims will be reduced amount to only .01 percent of the 2.6 million metric tons estimated to be generated in San Luis Obispo County in 2020. This is statistically insignificant.
New construction (if any) will generate very little because the new building technologies and energy requirements that already exist have already reduced it significantly. Worse and horribly dishonestly, because the APCD staff knows this, they have imputed the non-construction-related impacts of new development into their calculations. Accordingly, they are counting the other things the inhabitants of the new homes and commercial buildings will use as contributors to their numbers. These include your car, lawnmower, boat, water usage, and electrical usage. This is extremely unfair. Why are commercial builders and homebuilders being singled out to be taxed on the CO2 generated by daily living?
The changes, which are in effect coerced, could include a smaller project, costly “green energy” features (solar, water recovery systems, charging stations for electric vehicles etc.), and subsidizing of mass transit. Obviously, some projects could be rendered infeasible and thus abandoned. The requirements stack the deck against freestanding suburban houses, ranchettes, estates, and agricultural processing on farms and ranches, and would force density into existing communities and neighborhoods. The APCD staff suggests that developments that charge more for auto-related features, such as garages and parking spaces, and/or that are within walking distance of retail centers and government services such as schools, will have an easier time complying.
Of course, many of the required infrastructure supports—such as sidewalks, bikeways, parks, transit centers, parking garages, and so forth—generate CO2 as a by-product of the concrete, steel, asphalt, and plastic in the materials used in their manufacture. Once in operation they also generate CO2 as they are illuminated, watered, and maintained. Similarly, dense urban development requires more intense municipal operational supports, including buses, more frequent street cleaning, heavier policing, more street lights, more frequent refuse collection, more homeless services, and intensive public health and social services. The manufacture, operation, and maintenance of the equipment involved are all CO2-generating activities. Developers can also be forced to pay in lieu mitigation fees as an alternative to installing some of these onsite features. The county and cities will then use these funds to construct bikeways, fund mass transit, and provide other “green amenities” elsewhere. Will the original developers then be penalized for the CO2 impacts of these additional projects constructed by government using their mitigation fees?
For the APCD social engineers, the new American dream is a third-floor condo overlooking Albertsons and several fast food restaurants. The garbage truck and the street sweeper grinding through the alley at 4 a.m. combined with the ambulance sirens add to the ambiance. This is yet another government protection racket designed to extract fees and mitigation payments from private individuals and business concerns. It accomplishes nothing real, wastes taxpayer money, and, most appallingly, will suppress valuable projects and the related construction and permanent jobs.
Mike Brown is government affairs director of the Coalition of Labor, Agriculture, and Business of SLO County. Send comments to the executive editor at email@example.com.