BOARD AGENDA MEMORANDUM
Government Code § 84308 Applies: Yes ☐ No ☒
(If “YES” Complete Attachment A - Gov. Code § 84308)
SUBJECT: Title
Santa Clara Valley Water District Greenhouse Gas Reduction Plan and Final Negative Declaration.
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RECOMMENDATION: Recommendation
A. Discuss the potential environmental effects of Santa Clara Valley Water District’s Greenhouse Gas Reduction Plan as discussed in the Final Negative Declaration;
B. Adopt the Resolution ADOPTING THE FINAL INITIAL STUDY/NEGATIVE DECLARATION FOR THE GREENHOUSE GAS REDUCTION PLAN; and
C. Adopt the Resolution ADOPTING THE GREENHOUSE GAS REDUCTION PLAN, INCLUDING A CARBON NEUTRALITY TARGET OF 2045 AND ASSOCIATED EMISSIONS REDUCTION MEASURES.
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SUMMARY:
Santa Clara Valley Water District’s (Valley Water) 2021 Climate Change Action Plan (CCAP) established goals, strategies, and actions to support climate adaptation and ongoing reduction of greenhouse gas emissions. As recommended in the CCAP, Valley Water developed a CEQA-qualified Greenhouse Gas Reduction Plan (GHGRP; Attachment 1) which aims to reduce Valley Water’s emissions, achieve carbon neutrality by 2045, and streamline GHG CEQA analyses for future Valley Water projects that are consistent with the GHGRP.
The GHGRP has been prepared in accordance with CEQA Guidelines Section 15183.5, which allows a public agency to analyze and mitigate greenhouse gas emissions through a qualified greenhouse gas reduction plan, and to use that plan to support tiering and streamlining of greenhouse gas analyses for later projects. To serve this purpose, the plan must quantify existing and projected greenhouse gas emissions within a defined geographic area; establish, based on substantial evidence, an emissions level below which covered activities would not result in a cumulatively considerable greenhouse gas impact; identify and analyze emissions from anticipated actions or categories of actions; specify measures, including performance standards, that substantial evidence demonstrates would collectively achieve the specified emissions level if implemented on a project-by-project basis; establish a mechanism to monitor progress and require amendments if the plan is not achieving the specified levels; and be adopted in a public process following environmental review. The GHGRP is consistent with these criteria because it quantifies Valley Water’s existing and projected emissions through 2045, establishes greenhouse gas reduction targets and a carbon budget, identifies reduction measures and implementation actions to achieve those targets, and includes tracking and adaptive management provisions to monitor progress over time. The GHGRP Consistency Review Checklist provides the project-level mechanism for future discretionary Valley Water projects to demonstrate consistency with the GHGRP by documenting applicable reduction measures or other evidence showing that the project would not impede achievement of the GHGRP’s targets or cause Valley Water to exceed its carbon budget, thereby supporting tiering and streamlining of greenhouse gas analysis in future CEQA documents, as appropriate.
During development of the GHGRP, staff conducted extensive internal and external stakeholder outreach in developing the GHGRP. Throughout 2023-2025, internal subject matter experts (SMEs) reviewed historic and projected emissions calculations for accuracy, reduction measures to ensure they were actionable, and the draft GHGRP. In December 2024, the Draft GHGRP was published on Valley Water’s website for public comment and staff from the Metropolitan Water District’s Office of Sustainability, Resilience, and Innovation completed a peer review with the support of Rincon Consultants. Comments and questions from the public review and peer review mainly related to what was included in Valley Water’s emissions calculations and mitigation suggestions. Staff responded to all comments as well as feedback received from the June 2025 Board Policy and Monitoring Committee and then began the CEQA process. After completing the Initial Study/Negative Declaration (IS/ND), Valley Water posted the CEQA documents and draft GHGRP on Valley Water’s website for a 31-day public comment period. Staff received and responded to two comments, neither of which required edits to the GHGRP or CEQA analysis.
Emissions Inventory
The GHGRP inventories Valley Water GHG emissions in a manner consistent with current guidance from the California Air Resources Board, expanding Valley Water’s original GHG emissions reduction framework. Specifically, the GHGRP emissions inventory accounts for additional indirect (Scope 3) emissions from construction and maintenance activities and other emissions sources not previously included due to lack of data. The emissions inventory establishes Valley Water’s baseline GHG emissions using a five-year average from 2017 to 2021. Using a five-year average accounts for variability in operations and imported water deliveries, which drive annual variability in emissions. The baseline inventory indicates that indirect (Scope 3) emissions from construction, maintenance, and imported water are Valley Water’s largest GHG sources, accounting for approximately 70% of total emissions. These results reflect the success of Valley Water’s previous efforts to reduce direct (Scope 1) emissions and emissions from purchased electricity (Scope 2).
Emissions Forecast
The GHGRP forecasts future emissions through 2045 based on historical trends, consultation with subject matter experts at Valley Water on likely future trends in emissions drivers such as fuel usage, electricity usage, and construction activity, and emissions-reducing regulations. Valley Water’s emissions are forecast to decrease approximately 50% by 2045 due to legislative reductions. Construction emissions will continue to comprise the largest remaining emissions source; they are predicted to account for 67% of Valley Water’s total emissions in 2045. Emissions from future projects that have their own CEQA mitigation measures requiring net-zero construction emissions, such as the Anderson Dam Seismic Retrofit Project, are not included in the GHGRP construction emissions forecast.
Greenhouse Gas Reduction Measures
The GHGRP identifies the gap between forecasted emissions and Valley Water’s 2045 carbon neutrality target and establishes GHG reduction measures to reduce emissions across Valley Water’s operations (Attachment 1). Each measure quantifies cumulative emissions reductions anticipated by 2030 and 2045 and includes specific implementation steps. The largest emissions reductions will be derived from Measures OF-1 (Zero Emission Off-Road Fleet), CN-1 (Zero Emission Off-Road Construction Vehicles), and CS-1 (Sequester Carbon). Measures OF-1 and CN-1 require that zero emission fuels comprise an increasing share of fuel usage by Valley Water’s off-road fleet and contracted off-road construction vehicles. Zero-emission fuels include renewable diesel, biodiesel, electricity, and hydrogen. Measure CS-1 establishes a framework to track emissions reductions derived from the additional carbon sequestered by restoration projects that Valley Water implements, such as the South San Francisco Bay Shoreline Phase I Project (Shoreline Phase I). Restored tidal marsh is highly efficient at sequestering carbon relative to other ecosystems. As demonstrated in the GHGRP, Valley Water can meet its emissions reduction targets by applying a percentage of estimated carbon sequestration from Shoreline Phase I as an emissions reduction. Staff will work with Shoreline Phase I partner agencies to document that carbon sequestration will not be double counted by Valley Water or its partners. Additional restoration projects, such as the Calabazas/San Tomas Aquino Creeks-Marsh Connection Project, will be evaluated for inclusion in Measure CS-1 as projects are identified and on track for implementation. Collectively, the GHGRP reduction measures provide a pathway for Valley Water to achieve carbon neutrality by 2045, consistent with California’s emission reduction targets established by AB 1279.
Implementation and Monitoring Plan
Valley Water will track its future emissions against a carbon budget that provides a maximum limit for emissions from 2025 through 2045. Progress toward meeting GHG reduction targets will be monitored and reported bi-annually, and inventory and forecast updates and the latest technological developments in GHG reduction measures will be incorporated into the GHGRP every five years. This update process will allow Valley Water to refine its GHG reduction measures and actions to account for changing construction project schedules, market conditions, costs, and technological developments.
ENVIRONMENTAL JUSTICE IMPACT:
There is no environmental justice impact associated with the Greenhouse Gas Reduction Plan. Implementation of the GHGRP would reduce Valley Water’s GHG and air pollutant emissions, thereby reducing Valley Water’s overall environmental impact. None of the GHGRP measures would result in a negative impact to environmental justice.
FINANCIAL IMPACT:
Implementing projects identified in the GHGRP will be included in future Valley Water budgets when those projects are approved to be implemented by the Board of Directors. There is no financial impact directly related to the adoption of the GHGRP and Initial Study/Negative Declaration resolution.
CEQA:
Valley Water, acting as the lead agency under the California Environmental Quality Act, prepared a Final Initial Study (IS), which determined that the GHGRP would not have a significant effect on the environment. Therefore, a Negative Declaration (ND) was prepared for the GHGRP. Together, the IS/ND evaluates potential environmental effects of the GHGRP in accordance with CEQA and its implementing regulations, the CEQA Guidelines.
The IS/ND was made available for public review and comment for a 31-day period, from May 8, 2026, to June 8, 2026, in accordance with CEQA Guidelines Section 15105. Valley Water received two comment letters during the public review period. Responses to these comments are included in the Final IS/ND.
Pursuant to CEQA Guidelines Section 15183.5, Valley Water intends to use the GHGRP for tiering and streamlining of the GHG analysis in future Valley Water CEQA documents for projects through 2045. Future discretionary Valley Water projects that have not initiated the CEQA process, and projects currently undergoing CEQA review that have not yet released a CEQA document for public review, may tier from the GHGRP. Projects that tier from the GHGRP must demonstrate consistency with the GHGRP through the Consistency Review Checklist or a quantitative analysis showing that the project would not impede achievement of the GHGRP’s GHG reduction targets or cause Valley Water to exceed its carbon budget.
The Board is requested to adopt the Final IS/ND prior to taking action to approve the GHGRP. Upon Board adoption of the Final IS/ND and approval of the GHGRP, staff will file a Notice of Determination with the Santa Clara County Clerk and the State Clearinghouse within five working days of Board approval, as required by CEQA Guidelines Section 15075.
ATTACHMENTS:
Attachment 1: Reduction Measures and weblink to Final IS/ND and GHGRP
Attachment 2: Board Resolution (CEQA)
Attachment 3: Board Resolution (GHGRP)
Attachment 4: Notice of Determination
Attachment 5: PowerPoint
UNCLASSIFIED MANAGER: Manager
Lisa Bankosh, 408-630-2618