The California Environmental Quality Act (CEQA) Statute and Guidelines require public agencies, when acting in their Lead Agency role, to provide an opportunity for other public agencies such as the South Coast AQMD, and members of the public to review and comment on the analysis in environmental documents prepared for proposed projects. A Lead Agency is when a public agency has the greatest responsibility for supervising or approving a proposed project and is responsible for the preparation of the appropriate CEQA document.

On a daily basis, South Coast AQMD receives CEQA and other types of environmental documents from Lead Agencies for proposed projects that could adversely affect air quality. Since the South Coast AQMD’s expertise is air quality, the South Coast AQMD is obliged to review the air quality analysis in these documents prepared by other public agencies to ensure that the air quality impacts are accurately identified and analyzed, and that mitigation is applied to lessen significant adverse air quality impacts, if any. The process of reviewing these CEQA and other environmental documents is referred to as intergovernmental review.

The South Coast AQMD’s role as a Commenting Agency is for those projects with potential air quality impacts but no South Coast AQMD air permits are required. However, if air permits are required, the South Coast AQMD’s role under CEQA shifts to being a Responsible Agency.  In both roles, South Coast AQMD staff will review the environmental document and may prepare comments relative to the air quality impacts and the adequacy of the analysis, and recommend mitigation measures as appropriate. 

If South Coast AQMD decides that a comment letter regarding a CEQA or other type of environmental document is necessary, the nature of the remarks may focus on:

• Identifying Discrepancies: Highlighting any discrepancies or inconsistencies in the analysis.
• Assumptions Made, Calculations and Analysis: Reviewing the assumptions and verifying the accuracy of the calculations of the air quality and greenhouse gas analyses and the modeling parameters and results of the health risk assessment.
• Air Permit Requirements: Identifying whether a South Coast AQMD air permit is needed and whether South Coast AQMD may be a Responsible Agency under CEQA.
• Mitigation Measures and Alternatives: Recommending mitigation measures and alternatives to reduce air quality impacts.

Where are the Comment Letters Available?

If South Coast AQMD provided written comments to a Lead Agency regarding a proposed project, the comment letters are posted on South Coast AQMD’s website here: Comment Letters.


To whom should I send CEQA or other type of environmental documents/notices to South Coast AQMD for intergovernmental review?

Please direct CEQA and other types of environmental documents/notices to:
            Sam Wang, Program Supervisor, CEQA-IGR
            Email: [email protected]
            Phone: (909) 396-2649

How does South Coast AQMD Track Statistics Relating to its Intergovernmental Review Activities?

The South Coast AQMD maintains a database which compiles statistics pertaining to:

1. the number of CEQA and other types of environmental documents received for review;
2. the type of land use for each project;
3. the project description;
4. the project location by address and by county along with a tag if the project is located in an environmental justice area, as applicable;
5. the name of the Lead Agency for each project;
6. the dates of the public comment period and the public hearing date;
7. status of review, including whether written comments were transmitted to a Lead Agency and the location where the comment letter may be accessed on South Coast AQMD’s website, as applicable; and
8. whether staff testified at a hearing.

This information is compiled into a monthly written report, Intergovernmental Review of Environmental Documents and CEQA Lead Agency Projects, which is organized into three sections: 1) Attachment A lists all of the environmental documents prepared by other public agencies seeking review by South Coast AQMD that were received during the reporting period; 2) Attachment B lists the active projects for which South Coast AQMD has reviewed or is continuing to conduct a review of the environmental documents prepared by other public agencies; and 3) Attachment C lists the active air permit projects for which South Coast AQMD is a Lead agency.

The purpose of Attachment C is to provide information about when the South Coast AQMD is acting as Lead Agency for a proposed project and is preparing a CEQA document when: 1) air permits are needed; 2) potentially significant adverse impacts have been identified; and 3) South Coast AQMD has primary discretionary authority over the approvals.

Where is this monthly written report available?

A draft of the monthly written report, Intergovernmental Review of Environmental Documents and CEQA Lead Agency Projects, is provided to the South Coast AQMD Mobile Source Committee which typically convenes on the third Friday of each month except July. The final version of this monthly report is considered by the entire South Coast AQMD Governing Board at its Public Hearing which is typically held on the first Friday of each month except July. The agendas for both the Mobile Source Committee meetings and the South Coast AQMD Governing Board Public Hearings are available here: http://www.aqmd.gov/home/news-events/meeting-agendas-minutes.

What is South Coast AQMD’s focus when conducting its intergovernmental review of CEQA and other environmental documents?

Staff focuses on reviewing and preparing comments on environmental documents prepared by other public agencies for proposed projects: 1) that may have significant adverse regional air quality impacts (e.g., special event centers, landfills, goods movement); 2) that may have localized air quality impacts or toxic impacts (e.g., warehouse and distribution centers); 3) when environmental justice concerns have been raised; 4) when another public agency in its Lead Agency or Responsible Agency role has specifically requested South Coast AQMD review; and 5) projects which may require air permits but another public agency is Lead Agency.

Are Environmental Justice and AB617 communities considered when South Coast AQMD conducts its intergovernmental review of CEQA and other environmental documents?

Yes. South Coast AQMD fulfills its intergovernmental review responsibilities, in a manner that is consistent with the South Coast AQMD Governing Board’s 1997 Environmental Justice Guiding Principles and Environmental Justice Initiative #4, by reviewing and commenting on the adequacy of the air quality analysis in the environmental documents prepared by other Lead Agencies.

Also required by the South Coast AQMD Governing Board’s October 2002 Environmental Justice Program Enhancements for fiscal year (FY) 2002-2003, each attachment in the monthly written report includes notes for proposed projects which indicate when South Coast AQMD has been contacted regarding potential air quality-related environmental justice concerns.

Through this structured process for conducting intergovernmental review and flagging projects with potential air quality-related environmental justice concerns, including projects located in AB 617 Communities, the South Coast AQMD helps ensure that land use projects and their associated environmental documents adhere to AB 617 Community Emissions Reduction Plan (CERP) objectives, while minimizing adverse air quality impacts to protect community health in environmental justice areas. As part of implementing the CEQA-related objectives in the South Coast AQMD’s CERPs for the six AB617 communities and in response to concerns raised at various AB617 community meetings, the South Coast AQMD has created a Quick Reference Guide for Land Use Projects and Activities in AB617 Communities.