Developer Roundtable: Air District Draft Planning Guidance

Bay Area Air Quality Management District (Air District) staff has been developing a guidance document titled Planning Healthy Places. The draft document is intended to provide recommendations to cities and counties on ways to consider and minimize potential local air pollution exposure when planning infill development. This is not CEQA guidance; it is intended to inform local general plans, specific area plans and other local plans. 

To view the draft document and the draft maps that support the document, please view the Air District’s webpage.

As background, in 2010 Air District staff updated the Air District’s CEQA Guidelines and included recommendations that CEQA documents for sensitive land uses such as residential, schools, and health care should consider health effects of local air pollution on sensitive populations. A number of affordable housing advocates had concerns about how the Air District addressed this issue, centering around concerns that affordable housing projects are already very difficult to implement and concern that the Air District’s 2010 CEQA Guidelines introduced additional time, resources and uncertainty that would alarm developers and provide ammunition to opponents. Air District staff had several meetings with NPH members to discuss the issue. In the current Planning Healthy Places document the Air District has attempted to address those concerns in various ways, such as: focus earlier in the planning process (i.e., local plans) rather than CEQA review; minimize need for modeling/quantitative analysis, and instead rely on best practices; provide certainty and minimize opportunities for unintended consequences.  The draft guidance provides maps of areas with higher levels of pollution and recommends best practices (filtration, setbacks, tree planting, etc.) to reduce exposure to pollution.

The Bay Area Air Quality Management District and NPH invite you to an important discussion about an approach that is protective of public health and also does not present barriers to affordable housing. Air District staff supports infill, TOD and affordable housing as vital to Bay Area air quality and other social needs, and seeks to be sure that this guidance is helpful, not an impediment. Air District staff has a draft document that is ready to review with affordable housing representatives before it is presented to a broader public.