Rethinking Environmental Impacts in Urban Development – Part 1-A
The arc of this (planned) four-part piece is about how we deal with the environmental impacts of urban development now that we have a clearer understanding of the relationship of greenhouse gasses (GHG) to climate change. Part 1 attempted to set the stage by delivering some comments on the changing conception of what we consider to be environmental impacts for the purposes of environmental review in the urban development process. It did not, however, contain a clear introduction to the argument and how the comments of Part 1 fit into it. This appendix to the first part is my attempt to fix that defect.
The evolution of thinking about environmental impacts has been well documented from the preservation/conservation movement that gave us the national and state park systems to the anti-pollution movement that supported the regulation of the release of harmful matter into the air and water from toxic and industrial uses to the climate change movement that is focused on the release of greenhouse gasses by all manner of human activity. NEPA, CEQA, and other state environmental policy acts (SEPAs) were forged in the anti-pollution and conservation mindsets and, consequently, policy and law developed to address the observable and tangible damage and no-growth philosophies inherent in each perspective. As a result, some of the development decisions that were made in response to these kinds of understood environmental impacts may have unintentionally increased other impacts on climate change.
“Environmental review” is a factor in the urban development process that is designed to provide information to the public about how a particular project impacts the natural environment. In the urban planning discipline it is a concept deeply rooted in the rational planning model – the perspective that more information makes better projects. While primarily an informational tool, it can be a tool for slowing or stopping a project if the review is not done properly according to law. In an anti-pollution context one will view the impacts of a particular project one way; in a climate change context one might view the impacts differently. For example, we know that the more vehicle miles traveled, the more greenhouse gasses are released into the atmosphere. Because sprawling urban development increases regional vehicle miles traveled while dense urban development reduces it, in general we would – from a climate change perspective – expect to see better impacts on the environment from dense urban development than from sprawling development. However, from an anti-pollution perspective we might be concerned more about the other impacts from concentrated development. The issue is not whether one should be discarded in favor of the other (to be sure, there is a lot of overlap between localized pollution and GHG release that impacts global conditions), but what standards we must apply to regional and urban development and the role environmental review should play in meeting those standards.
Environmental review can help frame the development envelope despite its essentially informational posture. For this reason, re-crafting a law such as CEQA to better address the planning priorities associated with GHG reduction goals is certainly advisable. This is what SB 375 attempts to do in creating new categories of exemptions to review for projects that meet criteria consistent with the carbon reduction goals and the regional sustainability plans that are also mandated by the new law. To help environmental review to become a useful tool in creating and maintaining a GHG reduction development envelope, changes in scoping and analyzing projects under CEQA are also advisory. This will be addressed in Parts 3 and 4. In Part 2, we’ll turn from environmental review to explore another development institution that could play an even more important role in planning for climate change – the public tools of urban redevelopment.