San Diego Tribal Collaborative Climate Pollution Reduction Grant | Priority Climate Action Plan | March 2024
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San Diego Tribal Collaborative
Climate Pollution Reduction Grant
Priority Climate Action Plan
Prepared by
Blue Tomorrow, LLC
Last Revised: March 1, 2024
Pala Band of Mission Indians
Jamul Indian Village of California
Viejas Band of Kumeyaay Indians
La Posta Band of Mission Indians
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TABLE OF CONTENTS
1.0 INTRODUCTION ........................................................................................................................... 5
1.1 CPRG Objectives ..................................................................................................................... 7
1.2 PCAP Objectives...................................................................................................................... 7
2.0 BACKGROUND ............................................................................................................................. 9
2.1 Pala Band of Mission Indians ................................................................................................... 9
2.2 Jamul Indian Village of California .......................................................................................... 13
2.3 Viejas Band of Kumeyaay Indians .......................................................................................... 15
2.4 La Posta Band of Missions Indians ......................................................................................... 18
3.0 GHG EMISSIONS INVENTORY..................................................................................................... 21
3.1 Pala Band of Mission Indians ................................................................................................. 21
3.2 Jamul Indian Village of California .......................................................................................... 25
3.3 Viejas Band of Kumeyaay Indians .......................................................................................... 27
3.4 La Posta Band of Mission Indians .......................................................................................... 30
4.0 QUANTIFIED GHG REDUCTION MEASURES ................................................................................ 33
4.1 Pala Band of Mission Indians ................................................................................................. 33
4.2 Jamul Indian Village of California .......................................................................................... 37
4.3 Viejas Band of Kumeyaay Indians .......................................................................................... 40
4.4 La Posta Band of Mission Indians .......................................................................................... 45
5.0 BENEFITS ANALYSIS ................................................................................................................... 50
5.1 Pala Band of Mission Indians ................................................................................................. 52
5.2 Jamul Indian Village of California .......................................................................................... 55
5.3 Viejas Band of Kumeyaay Indians .......................................................................................... 56
5.4 La Posta Band of Mission Indians .......................................................................................... 59
6.0 REVIEW OF AUTHORITY TO IMPLEMENT ................................................................................... 62
7.0 APPENDIX .................................................................................................................................. 63
7.1 GHG Emissions Inventory Methodology ................................................................................ 63
7.1.1 Pala Band of Mission Indians ............................................................................................ 63
7.1.2 Jamul Indian Village of California ...................................................................................... 69
7.1.3 Viejas Band of Kumeyaay Indians ...................................................................................... 71
7.1.4 La Posta Band of Mission Indians ...................................................................................... 76
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7.2 Priority Reduction Measures Methodology ........................................................................... 81
7.2.1 Pala Band of Mission Indians ............................................................................................ 81
7.2.2 Jamul Indian Village of California ...................................................................................... 82
7.2.3 Viejas Band of Kumeyaay Indians ...................................................................................... 82
7.2.4 La Posta Band of Mission Indians ...................................................................................... 83
8.0 REFERENCES .............................................................................................................................. 84
TABLES
Table 1 – Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent ................................. 21
Table 2 – Pala Reservation GHG Emissions Percentages by Source ......................................................... 23
Table 3 – Pala Reservation GHG Emissions Percentages by Sector.......................................................... 24
Table 4 – JIVoC Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent ..... 25
Table 5 – JIVoC Reservation Emissions Percentages by Source ............................................................... 26
Table 6 – Viejas Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent .... 27
Table 7 – Viejas Reservation Emissions (MTCO2e) and Percentages by Source ....................................... 28
Table 8 - Viejas Reservation Emissions (MTCO2e) and Percentages by Sector ........................................ 29
Table 9 – La Posta Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent 30
Table 10 – La Posta Reservation Emissions (MTCO2e) and Percentages by Source ................................. 31
Table 11 - La Posta Reservation Emissions (MTCO2e) and Percentages by Sector................................... 32
Table 12 – Pala Reservation Priority GHG Reduction Measures .............................................................. 33
Table 13 – JIVoC Priority GHG Reduction Measures ............................................................................... 37
Table 14 – Viejas Reservation Priority GHG Reduction Measures ........................................................... 40
Table 15 – La Posta Reservation Priority GHG Reduction Measures ....................................................... 45
Table 16 – Pala Top 10 Co-Pollutant Emissions Per Year (EPA, 2024) ...................................................... 52
Table 18 – JIVoC Top 10 Co-Pollutant Emissions Per Year (EPA, 2024) .................................................... 55
Table 19 – Viejas Top 10 Co-Pollutant Emissions Per Year (EPA, 2024) ................................................... 56
Table 17 – La Posta Top 10 Co-Pollutant Emissions Per Year (EPA, 2024) ............................................... 59
Table 20 - Commercial Sector Facility Electricity Use Emissions Estimate ............................................... 64
Table 21 – Pala Reservation Commercial Building Estimated Emissions from Propane Use..................... 66
Table 22 – Pala Reservation Solid Waste Generation Estimates for Residential and Commercial Sectors 67
Table 23 – JIVoC Facility Propane Use Estimate...................................................................................... 70
Table 24 – Viejas Reservation Commercial Sector Electricity Usage and Associated Emissions ............... 72
Table 25 – Viejas Reservation Commercial Sector Propane Usage and Associated Emissions ................. 74
Table 26 – Viejas Reservation Commercial Sector Natural Gas Usage and Associated Emissions ............ 74
Table 27 – Viejas Reservation Waste Generation and Associated Emissions ........................................... 75
Table 28 – La Posta Reservation Commercial Sector Electricity Usage and Associated Emissions............ 77
Table 29 – La Posta Reservation Commercial Sector Propane Usage and Associated Emissions .............. 78
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MAPS
Map 1 – San Diego Tribal Collaborative CPRG Reservation Locations ....................................................... 6
Map 2 – Natural Features of Pala Reservation ....................................................................................... 11
Map 3 – Facilities on Pala Reservation ................................................................................................... 12
Map 4 – Facilities and Natural Features on JIVoC Reservation ............................................................... 14
Map 5 – Natural Features of Viejas Reservation ..................................................................................... 16
Map 6 – Facilities on Viejas Reservation ................................................................................................ 17
Map 7 – Natural Features of La Posta Reservation ................................................................................. 19
Map 8 – Facilities on La Posta Reservation ............................................................................................. 20
FIGURES
Figure 1 – Pala Reservation GHG Emissions (MTCO2e) by Source ........................................................... 23
Figure 2 – Pala Reservation GHG Emissions (MTCO2e) by Sector ........................................................... 24
Figure 3 – JIVoC Reservation Emissions (MTCO2e) by Source ................................................................. 26
Figure 4 – Viejas Reservation Emissions (MTCO2e) by Source ................................................................ 28
Figure 5 – Viejas Reservation Emissions (MTCO2e) by Sector ................................................................. 29
Figure 6 – La Posta Reservation Emissions (MTCO2e) by Source ............................................................ 31
Figure 7 – La Posta Reservation Emissions (MTCO2e) by Sector ............................................................. 32
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1.0 INTRODUCTION
San Diego Tribal Collaborative
The San Diego Tribal Collaborative (SDTC) is a consortium of four Tribal governments in San Diego
County that are coordinating efforts through the Climate Pollution Reduction Grant (CPRG) program.
The four partner Tribes in the SDTC are: Pala Band of Mission Indians (SDTC Lead Organization), Jamul
Indian Village of California, Viejas Band of Kumeyaay Indians, and La Posta Band of Mission Indians (Map
1).
CPRG Overview
The CPRG program supports the development of strategic plans for reducing greenhouse gas (GHG)
emissions and implementation of projects that reduce GHGs and associated co-pollutants. The initial
planning phase includes the development of a Priority Climate Action Plan (PCAP) and Comprehensive
Climate Action Plan (CCAP). This document serves as the SDTC PCAP and contains the required elements
including: GHG emissions inventories, quantified emissions reduction measures, benefits analysis, and
review of authority to implement.
PCAP Overview
The SDTC PCAP is focused on an initial GHG inventory for the base year of 2022. For this inventory, data
was collected from the Tribes in accordance with the Quality Assurance Project Plan (QAPP). Where
available, data from the Reservations included electricity use, point sources, non-point sources, on-road
and non-road mobile sources, solid waste generation, agriculture, land management, water, and
wastewater processing. If site specific data was unavailable, emissions estimates were made using
national or regional databases and downscaled based on Reservation characteristics.
Emissions reduction measures were identified and prioritized by each Tribe to form a strategic plan to
reduce GHG emissions. In determining these measures, the Tribes considered CPRG program alignment,
existing or planned projects, funding and cost considerations, and time constraints for implementation.
Emissions reduction estimates were calculated where feasible and are included in the PCAP.
The included emissions reduction measures benefits analysis contains an inventory of co-pollutants for
each Reservation for the base year of 2022. These estimates are based on the National Emissions
Inventory (NEI) and downscaled by population for each Reservation. Additionally, associated co-
pollutant reductions and general community benefits are discussed for each proposed measure. The
goal of this benefits analysis is to consider pollution reduction and improvements to Tribal economies,
health, safety, and resiliency.
The CCAP will expand on the PCAP to include a comprehensive GHG inventory using more specific
emissions and energy use data, if available, and also include GHG sinks from carbon sequestration. GHG
emissions reduction targets and projects will be included in the CCAP to help gauge the performance
and success of reducing emissions. Plans for funding and workforce requirements will be developed to
build a roadmap to guide the implementation of emissions reduction measures.
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Map 1 – San Diego Tribal Collaborative CPRG Reservation Locations
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1.1
CPRG Objectives
The CPRG program, administered by the U.S. Environmental Protection Agency (EPA), is funded through
the Inflation Reduction Act of 2022 (IRA). Three overarching objectives the EPA intends to achieve
through the IRA include:
▪ Tackle damaging climate polluon while supporng the creaon of good jobs and lowering
energy costs for families
▪ Accelerate work to address environmental injusce and empower community-driven soluons
in overburdened neighborhoods
▪ Deliver cleaner air by reducing harmful air polluon in places where people live, work, play, and
go to school
CPRG is designed to reduce GHG emissions that contribute to climate change by providing funding to
states, municipalities, Tribes, and territories for planning and implementation of emissions reduction
measures. Through implementing GHG emission reduction measures, CPRG also aims to restore
ecosystems, improve deteriorating infrastructure, foster economic growth, and bolster public health by
reducing the pollution burden that disproportionately affects disadvantaged communities.
The two phases of the CPRG program include: 1) Planning (PCAP & CCAP); and 2) Implementation. The
PCAP prioritizes emissions reduction measures that will be pursued during Phase 2. This implementation
phase contains specific goals for Tribes (and other eligible applicants). These include:
1. Implement ambious measures that will achieve signicant cumulave GHG reducons by 2030
and beyond
2. Pursue measures that will achieve substanal community benets (such as reducon of criteria
air pollutants (CAPs) and hazardous air pollutants (HAPs)), parcularly in low-income and
disadvantaged communies
3. Complement other funding sources to maximize these GHG reducons and community benets;
and
4. Pursue innovave policies and programs that are replicable and can be “scaled up” across
mulple jurisdicons
1.2
PCAP Objectives
The primary objective of this PCAP is to serve as a strategic plan for reducing Tribal emissions of GHG's
and other harmful pollutants. This is achieved through the following plan objectives:
▪ Perform intergovernmental collaboration with members of the SDTC consortium
▪ Document baseline GHG emissions
▪ Identify and prioritize emission reduction measures
▪ Evaluate associated GHG reductions and co-benefits from implementing prioritized emissions
reduction measures
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The outcomes of this PCAP, which encompasses GHG and co-pollutant emissions inventories, proposed
GHG reduction measures, and benefits analysis, will ultimately bolster community capacity, increase
economic and climate resilience, and promote energy independence. The PCAP is poised to create
solutions that deliver the maximum benefit to communities that are overburdened and underserved, in
turn furthering the EPA’s goals for the IRA and the CPRG program.
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2.0 BACKGROUND
2.1
Pala Band of Mission Indians
The Pala Band of Mission Indians Reservation (“Pala Reservation”) is home to the Pala Band of Mission
Indians, who trace their heritage to the Cupeños (Kuupangaxwichem) and the Luiseños
(Payómkawichum). These two Tribes have shared territory since 1903. The Cupeños originally occupied
the headwaters of the San Luis Rey River until they were expelled from their homeland and joined the
Luiseño Tribe in what is now called the Pala Reservation (Pala Tribe , 2024). The Reservation is located
east of Fallbrook in northern San Diego County and encompasses 13,000 acres. The Pala Band of Mission
Indians has 918 enrolled Tribal members, most of which reside on the Reservation (PED, 2019). With a
population density of 68 persons per square mile, Pala has 1,573 total residents and 425 housing units
(PED, 2019).
Natural Features
The northern San Diego County area has a Mediterranean to desert climate with hot, dry summers, and
moist, mild winters. The Reservation occurs on a wide alluvial valley surrounded by steep granite
mountains. The largely undeveloped Reservation area is dominated by chaparral and scrub vegetation,
with some woodland and forested areas at higher elevations in the northeastern portion.
The San Luis Rey River laterally bisects the Reservation, dividing the northern and southern sides. During
storm events, the river experiences a significant surge in flow, posing serious flood risks to neighboring
areas. Just west of the Reservation boundary, there is a series of ponds that resulted from a now-closed
sand and gravel operation along the river. Along the riverbanks, invasive plant species such as Arundo
spp., Eucalyptus spp., and Tamarix spp. are widely distributed despite ongoing efforts to manage and
control their populations.
Areas surrounding the Reservation have undergone rapid development, increasing the burden on
natural resources and degrading ecosystems and habitats within its boundaries. The Climate Change
Vulnerability Assessment conducted by the Pala Environmental Department (PED) in 2019 identified the
primary climate change risks for Pala, including significantly elevated temperatures, more frequent
wildfires, less predictable storm and flooding events, as well as prolonged periods of drought. Each of
these risks has the potential to substantially impact human health, socio-economic health, air quality,
and GHG emissions (PED, 2019).
Facilities and Enterprises
Major land uses include agriculture, commercial businesses including gaming and motocross racing, and
residential areas. The most notable facility within the Reservation is the Pala Casino Resort and Spa,
located on the western side of the Reservation. The casino, which employs 1,900 people, has nine
restaurants, four entertainment venues (including the Starlight Theatre), an 11,000 square foot day spa,
and an 86,000 square foot gaming floor with 2,250 slot machines and 84 table games. The Pala Casino
Resort Hotel has 500 rooms, 82 suites, and a conference center (Pala Casino, 2023). The Tribe utilizes its
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earnings to support its members through social services and education, in addition to investing in
infrastructure improvements.
Agricultural land uses on the Reservation include large citrus and avocado orchards, a small parcel of
agricultural land southeast of the junction between the 15 and 76 freeway, and a small, man-made
retention pond for irrigation of crops and orchards along the San Luis Rey River. Additionally, there are
some small parcels of Reservation and tribal land to the east of the main Reservation used for
agriculture (PED, 2019).
The Pala Tribe also owns and operates Pala Mesa Resort and Golf Course, just west of interstate 15. The
resort includes an outdoor swimming pool, a restaurant, a golf shop, a two-story hotel with 133 rooms,
an artist school and retreat, and an 18-hole golf course (Pala Mesa Resort, 2023). The Pala Tribe also
operates Fox Raceway, a professional-grade motocross park with three racetracks.
Other notable facilities on the Reservation include administrative office buildings, a large fitness center,
a day care, a Boys and Girls Club, a fire station, a cultural center, and law offices. A transfer station
manages waste for residents and a hazardous waste curbside pickup service provided by PED.
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Map 2 – Natural Features of Pala Reservation
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Map 3 – Facilities on Pala Reservation
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2.2
Jamul Indian Village of California
Jamul Indian Village of California (JIVoC) is one of the twelve bands that make up the Kumeyaay Nations.
The Reservation is located 25 miles east of San Diego, on moderately steep slopes within the Jamul
mountains. Located on 6.032 acres of trust land, JIVoC is a federally recognized Tribe. The JIVoC Tribe
has 76 Tribal Members, including 49 adults and 27 minors, but none reside on the Reservation. (Prosper
Sustainability & Kimley Horn, 2022). Prior to federal recognition in 1981, residents lived in small huts
made of plywood scraps and the most reliable source of water for residents was Willow Creek, a small
creek which ran through the Reservation. Following federal recognition, Tribal members gained access
to municipal resources for water and electricity infrastructure. In 2016, the Jamul Casino was built, a
360-million-dollar casino that now takes up much of the Reservation land (Jamul Indian Village of
California, 2023).
Natural Features
The primary natural resource is Willow Creek, which runs north to south through the center of the JIVoC
Reservation and maintains an oak woodland riparian corridor (San Diego Integrated Regional Water
Management, 2019).
Facilities and Enterprises
There are five buildings on the Reservation. The most prominent is the 200,000 square foot Jamul
Casino on the east side of the property. It sits on top of an eight-level underground parking garage that
has a capacity of up to 1,800 vehicles. The casino includes seven restaurants and 1,700 slot machines.
Other facilities include an administrative office building, a wastewater treatment facility, a small chapel,
a security office, the Environmental Protection Department (EPD), and a community center. The
administrative offices house the Cultural Department, Accounting, Tribal Council Chambers, and Human
Resources.
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Map 4 – Facilities and Natural Features on JIVoC Reservation
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2.3
Viejas Band of Kumeyaay Indians
The Viejas Band of Kumeyaay Indians is one of the twelve bands of Kumeyaay Indian Nations. This band
traces its lineage back to the residents of the Capitan Grande River Valley, who endured both the loss of
their lands and access to the San Diego River on two distinct occasions. The first was in 1888, when the
completion of the Cuyamaca Dam resulted in the creation of Lake Cuyamaca, located approximately 12
miles northeast of the present-day Reservation. The second was in 1935, when the construction of
another dam resulted in the creation of El Capitan Reservoir, situated roughly 6 miles northwest of the
current Reservation. On both occasions, the developments acted not only to displace the residents from
their ancestral lands, but also to deny access to San Diego River’s waters.
In response, twenty-eight families pooled their resources from the forced sale of their Capitan Grande
land to acquire Viejas Valley land. The current members of the Viejas Band of Kumeyaay Indians are all
direct descendants of these families. Viejas Valley was officially designated as a Reservation by executive
order in 1934.
Today, the Viejas Band of Kumeyaay Indians Reservation (“Viejas Reservation”) is located just east of
Alpine in San Diego County along Interstate 8 within Cleveland National Forest, on 1,609 acres of federal
trust land. The Reservation is home to approximately 289 of the 394 enrolled members, with a total
population of 520 people (Viejas Band of Kumeyaay, 2023).
Natural Features
Viejas Valley is comprised primarily of grassland, wetland, and coastal mountain slope landscapes. The
key land uses in this region include ranching, residential, and commercial zones. The most prominent
vegetive communities in the region are expansive open annual grasslands, chaparral, coastal scrub, and
coastal oak woodlands. The main channel of Viejas Creek flows from east to west, bisecting the
Reservation, and receives tributaries from both the northern and southern sides.
Facilities and Enterprises
Viejas Casino stands as one of California’s most prosperous casinos, significantly contributing to the
economic sovereignty of the Tribe. The 325,000 square foot casino boasts an impressive 129,500 square
foot gaming area, five restaurants, two 128 room hotels (Viejas Resort and Willows Hotel & Spa), and a
large parking garage (Viejas Casino & Resort, 2023). Directly south of the casino is the Viejas Outlet
Center, an extensive shopping center spanning over 1 million square feet, hosting 57 retail stores
featuring a wide array of popular retail brands (BRG Consulting, 2016).
Other facilities in the Viejas Reservation include a recreational vehicle park, a tribal council building and
governmental complex, a fire department, an education department, and a recreation center.
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Map 5 – Natural Features of Viejas Reservation
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Map 6 – Facilities on Viejas Reservation
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2.4
La Posta Band of Missions Indians
The La Posta Band of Mission Indians is one of the twelve bands of the Kumeyaay Indian Nations and
was federally recognized through the Trust Patent in 1893, which established the Reservation. The La
Posta Band of Mission Indians Reservation (“La Posta Reservation”) has preserved much of its rich
heritage and is marked by the presence of numerous archaeological sites and cultural landmarks,
including sacred burial grounds and ancestral habitation sites.
La Posta Reservation encompasses approximately 3,500 acres plus another 200-acre area, named “Little
La Posta,” located 2 miles northwest of the main Reservation. The Reservation is bordered on the
eastern and southeastern sides by the Manzanita and Campo Reservations, respectively. Interstate
Highway 8 runs along the southwestern border of the Reservation. La Posta Reservation is located
between San Diego and El Centro in the Laguna Mountains, and has a population of 55 people, 23 of
which are enrolled tribal members. Much of the Reservation is undeveloped, with a limited number of
structures primarily consisting of residential buildings.
Natural Features
La Posta Reservation resides within the Tijuana River watershed. The region is comprised of freshwater
marshes, southern willow riparian woodlands, southern oak woodlands, great basin sage scrub,
chamise-redshank chaparral, and southern mixed chaparral vegetative communities. The landscape is
characterized by mountainous regions, high deserts, woodlands, small ponds, and various waterways
that contribute to the area’s ecological diversity. In recent years, significant changes to the waterways
and water resources on La Posta Reservation have been observed, with several lakes, aquifers, and
waterways drying up due to drought. Wetlands are also adversely affected by roadway related erosion
and sedimentation.
Facilities and Industries
Most of La Posta Reservation is rural and undeveloped. Aside from 13 residential buildings, the facilities
on the Reservation are the Tribal Administrative Offices, La Posta Tribal Police Department, the Boys and
Girls Club, the Southern Indian Health Substance Abuse Center, and the La Posta Casino (not in
operation). La Posta Casino opened in 2007. It was one of the smallest casinos in San Diego, employing
100 people at its peak, and closed in 2012.
There are also two active water wells on the Reservation that supply drinking water to residents.
However, water insecurity is a growing concern to La Posta environmental staff, who have observed
steady decreases in groundwater levels over the past 10 years (La Posta Band of Mission Indians, 2019).
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Map 7 – Natural Features of La Posta Reservation
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Map 8 – Facilities on La Posta Reservation
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3.0 GHG EMISSIONS INVENTORY
The emissions inventory is organized by the following sources, where applicable: electricity use, point
sources, non-point sources, on-road and non-road mobile sources, solid waste generation, agriculture,
land management, water, and wastewater processing. A comprehensive narrative of the methods and
calculations of emissions for each Tribe is included in the Appendix (Section 7.1)
The quantified emissions are also categorized by the following sectors: residential, commercial, mixed,
and electricity generation. The residential sector is comprised of only emissions related to the people
living within the boundaries of the respective Reservation. The commercial sector is comprised of for-
profit businesses and governmental/administrative enterprises. The electricity generation sector only
includes emissions pertaining to the generation of electricity within the Reservation boundaries. This
does not include electricity purchased from the grid, which is generated elsewhere. The mixed sector
emissions are those which could not be easily separated into any of the above-mentioned sectors. For
this inventory, the only emissions that fall into the “mixed” sector come from on-road mobile sources.
This emissions calculations section outlines the steps taken to calculate each source of GHG emissions
for each Reservation in the SDTC. Wherever possible, data sources and estimation tools are cited and
described below. Tools that were utilized most frequently include the Tribal Greenhouse Gas Inventory
Tool (TGIT), the U.S. Energy Information Administration Commercial Building Energy Consumption
Survey (CBECS), the EPA’s Waste Reduction Model (WARM), and the EPA’s Carbon Footprint Calculator.
3.1
Pala Band of Mission Indians
The total estimated annual GHG emissions derived from sources and activities on the Pala Reservation in
the base year 2022 is 9,776 MTCO2e (Table 1). Within the Pala Reservation, the primary sources of
emissions are stationary non-point sources, electricity consumption, and on-road mobile transportation,
with the on-road mobile contributing the highest emissions among all individual sources.
Table 1 – Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent
Sector
Electricity
Non-point
Sources
Off-road
Mobile
On-road
Mobile
Solid
Waste
Wastewater
Total
Commercial
2,177
2,470.2
2.2
-
357.9
12.6
5,019.9
Residential
908.4
923.1
41.7
-
316
-
2,189.2
Mixed
-
-
-
2,567
-
2,567
Total
3,085.4
3,393.3
43.9
2,567
673.9
12.6
9,776.1
The Pala Casino Spa Resort stands out as a major contributor to GHG emissions due to its extensive and
consistent consumption of both electricity and propane as a large commercial establishment with a high
volume of daily visitors. The total emissions from the Pala Casino Spa Resort electricity and propane
consumption are 2,912 MTCO2e, which is higher than the total emissions from on-road mobile
transportation.
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If emissions are combined into their source category groups, stationary non-point sources contribute
the most to the total emissions on the Reservation (34.7%). The second largest combined source
category is electricity consumption (31.6%), followed by on-road mobile sources (26.3%), solid waste
generation (6.9%), off-road mobile sources (0.4%), and wastewater treatment (0.1%) (Figure 1, Table 2).
When grouped by sector, the commercial sector was the greatest contributor to GHG emissions (Figure
2, Table 3). It is important to note that, given the lack of Reservation specific data, many of these
calculations relied on county-level or national averages for various components. While these
calculations serve as general estimations of emissions on the Reservation, they should be refined with
acquired data for the CCAP emissions inventory.
The per capita annual emissions for residents of the Pala Reservation are 6.56 MTCO2e, although this
value is significantly skewed by emissions from the casino. However, when considering emissions solely
within the residential and mixed sectors (on-road mobile sources, propane consumption, and electricity
use), per capita emissions are reduced to 4.84 MTCO2e per year. For comparison, the City of San Diego
average per capita annual emissions in 2019 was 6.8 MTCO2e (City of San Diego, 2020). In the CCAP
emissions inventory, emissions will be further broken down by sector to calculate per capita averages
with higher specificity.
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Figure 1 – Pala Reservation GHG Emissions (MTCO2e) by Source
Table 2 – Pala Reservation GHG Emissions Percentages by Source
Source
GHG Emissions
Percent
Non-point Sources
3,393.3
34.7%
Electricity
3,085.4
31.6%
On-road Mobile
2,567.0
26.3%
Solid Waste
673.9
6.9%
Off-road Mobile
43.9
0.4%
Wastewater
12.6
0.1%
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Figure 2 – Pala Reservation GHG Emissions (MTCO2e) by Sector
Table 3 – Pala Reservation GHG Emissions Percentages by Sector
Sector
Emissions
Percent
Commercial
5,019.9
51.3%
Mixed
2,567.0
26.3%
Residential
2,189.3
22.4%
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3.2
Jamul Indian Village of California
The total estimated annual GHG emissions derived from sources and activities on the JIVoC Reservation
in the base year 2022 is 5,030 MTCO2e (Table 4). Within the Reservation, the primary sources of
emissions are stationary non-point sources and electricity consumption.
Table 4 – JIVoC Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent
Source
Source Category
Sector
Scope
Emissions (MTCO2e)
On Road Mobile
On-road Mobile
Commercial
1
106.4
Solid Waste Generation
Solid Waste
Commercial
3
64.3
Diesel Backup Generators
Non-point Sources
Commercial
1
1,819.6
Urban Forestry
Urban Forestry
Commercial
1
-1.2
Casino SDGE Electricity Use
Electricity
Commercial
2
2,220.4
Casino Propane Use
Non-point Sources
Commercial
1
773.6
Wastewater
Wastewater
Commercial
1
46.9
Total
5,030.0
The Jamul Casino is the primary source of GHG emissions within the Reservation. The total emissions
from the Jamul Casino electricity, diesel, and propane consumption are 4,813 MTCO2e, which is almost
the entirety of the emissions from JIVoC Reservation.
The per capita annual emissions for the Reservation are difficult to calculate because there are no
residents on the Reservation; the only establishments within its boundaries are commercial or
institutional enterprises (Figure 3, Table 5).
The largest individual source of emissions derived from within the Reservation boundaries come from
non-point sources, specifically casino related propane and diesel fuel combustion. The second largest
source of emissions within the Reservation is electricity consumption. The Jamul Casino is the largest
consumer of electricity and fuel out of all other buildings on the Reservation. This is most likely the case
because it is open daily with a high volume of visitors.
If emissions are combined into their source category groups, stationary non-point sources contribute
the most to the total emissions on the Reservation (51.5%). The second largest combined source
category is electricity consumption (44.1%), followed by on-road mobile sources (2.1%), solid waste
generation (1.3%), and wastewater treatment (0.9%). It is important to note that, given the lack of
Reservation specific data, many of these calculations relied on county-level or national averages for
various components. While these calculations serve as general estimations of emissions on the
Reservation, they should be refined with acquired data for the CCAP emissions inventory.
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Figure 3 – JIVoC Reservation Emissions (MTCO2e) by Source
Table 5 – JIVoC Reservation Emissions Percentages by Source
Source
Emissions
Percent
Non-point Sources
2,593.2
51.5%
Electricity
2,220.4
44.1%
On-road Mobile
100.9
2.1%
Solid Waste
64.3
1.3%
Wastewater
46.9
0.9%
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3.3
Viejas Band of Kumeyaay Indians
The total estimated annual GHG emissions derived from sources and activities on the Viejas Reservation
in the base year 2022 is 11,276 MTCO2e. Within the Viejas Reservation, the primary sources of
emissions are Stationary Non-Point Sources and Electricity, with commercial natural gas use contributing
the highest emissions among all individual sources (Figure 4, Table 7). Viejas Casino & Resort stands out
as a major contributor to GHG emissions due to its extensive and consistent consumption of both
electrical energy and natural gas as a commercial establishment.
Table 6 – Viejas Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent
The per capita emissions for residents of Viejas Reservation are 23 MTCO2e, although this value is
significantly skewed by emissions from the casino and other commercial facilities. However, when
considering emissions solely within the residential sector (mobile sources, propane use, and electricity
use) (Figure 5, Table 8), per capita emissions are significantly reduced to 4 MTCO2e. For comparison, the
San Diego County average per capita annual emissions in 2019 was 7 MTCO2e (City of San Diego, 2020).
In the CCAP emissions inventory, emissions will be further broken down by sector to calculate per capita
averages with higher specificity.
The greatest source of GHG emissions on the Viejas Reservation is the commercial sector, accounting for
a substantial 80.5% of the total annual emissions, or 9,073 metric tons of carbon dioxide equivalent
(MTCO2e). Within the commercial sector, Viejas Casino & Resort most significantly contributes to
emissions, primarily due to its continuous hours of operation and its substantial influx of visitors.
The primary sources of GHG emissions on the Reservation are stationary non-point sources, accounting
for the largest portion of the total emissions at 43.5%. They are followed by Scope 2 sources from
electricity generation, representing 39.2% of emissions, on-road mobile sources at 10.2%, and finally,
solid waste hauling and management at 7.1%. Due to gaps in specific Reservation-level data, many of
these calculations relied on county or national averages for estimating sector emissions. While these
calculations serve as general estimations of emissions on the Reservation, they should be refined with
acquired data for the Comprehensive Climate Action Plan (CCAP).
Sector
Electricity
Non-point
Sources
On-road
Mobile
Solid
Waste
Wastewater
Total
Commercial
4,023.7
4,362.7
25.0
661.7
-
9,073.1
Residential
396.7
537.6
1,126.4
138.0
4.2
2,202.9
Total
4,420.4
4,900.3
1,151.3
799.8
4.2
11,276.0
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Figure 4 – Viejas Reservation Emissions (MTCO2e) by Source
Table 7 – Viejas Reservation Emissions (MTCO2e) and Percentages by Source
Source
Emissions
Percent
Non-point Sources
4,900.3
43.5%
Electricity
4,420.4
39.2%
On-road Mobile
1,151.3
10.2%
Solid Waste
799.8
7.1%
Wastewater
4.2
0%
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Figure 5 – Viejas Reservation Emissions (MTCO2e) by Sector
Table 8 - Viejas Reservation Emissions (MTCO2e) and Percentages by Sector
Sector
Emissions
Percent
Commercial
9,073.1
80.5%
Residential
2,198.7
19.5%
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3.4
La Posta Band of Mission Indians
The total estimated annual GHG emissions derived from sources and activities on the La Posta
Reservation in the base year 2022 is 311 MTCO2e (Table 9). Within the La Posta Reservation, the
primary sources of emissions are Stationary Non-Point Sources and Electricity, with commercial propane
use contributing the highest emissions among all sources (Figure 6, Table 10).
Table 9 – La Posta Reservation Total Emissions by Sector and Source in Metric Tons of CO2 Equivalent
Sector
Electricity
Non-point
Sources
On-road
Mobile
Solid
Waste
Wastewater
Total
Commercial
61.9
130.0
-
-
-
191.9
Residential
26.2
34.9
41.8
4.8
11.6
119.3
Total
88.1
165.0
41.8
4.8
11.6
311.2
The per capita emissions for residents of La Posta Reservation are 7.41 MTCO2e. However, when
considering emissions solely within the residential sector (mobile sources, propane use, and electricity
use) (
Source
Emissions
Percent
Non-point Sources
165.0
53.0%
Electricity
88.1
28.3%
On-road Mobile
41.8
13.4%
Wastewater
11.6
3.7%
Solid Waste
4.8
1.5%
Figure 7, Table 11), per capita emissions are significantly reduced to 2.84 MTCO2e. For comparison, the
San Diego County average per capita annual emissions in 2019 was 6.8 MTCO2e (City of San Diego,
2020). In the Comprehensive Climate Action Plan (CCAP) emissions inventory, emissions will be further
broken down by sector to calculate per capita averages with higher specificity.
The greatest source of GHG emissions on the La Posta Reservation is the commercial sector, accounting
for 61.7% of the total annual emissions, or 192 MTCO2e.
The primary sources of GHG emissions on the Reservation are stationary non-point sources, accounting
for the largest portion of the total emissions at 53.0%. They are followed by Scope 2 sources from
electricity generation, representing 28.3% of emissions, on-road mobile sources at 13.4%, wastewater
management at 3.7%, and finally, solid waste hauling and management at 1.5%. It is important to note
that, given the lack of specific Reservation data, many of these calculations relied on county-level or
national averages for various components. While these calculations serve as general estimations of
emissions on the Reservation, they should be refined with acquired data for the CCAP.
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Figure 6 – La Posta Reservation Emissions (MTCO2e) by Source
Table 10 – La Posta Reservation Emissions (MTCO2e) and Percentages by Source
Source
Emissions
Percent
Non-point Sources
165.0
53.0%
Electricity
88.1
28.3%
On-road Mobile
41.8
13.4%
Wastewater
11.6
3.7%
Solid Waste
4.8
1.5%
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Figure 7 – La Posta Reservation Emissions (MTCO2e) by Sector
Table 11 - La Posta Reservation Emissions (MTCO2e) and Percentages by Sector
Sector
Emissions
Percent
Commercial
191.9
61.7%
Residential
119.3
38.3%
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4.0 QUANTIFIED GHG REDUCTION MEASURES
This section provides information on the priority GHG emissions reduction measures identified by each
Tribe along with a quantified estimate of the GHG reductions that would be achieved if implemented.
The following information is provided for each reduction measure: estimate of the quantifiable GHG
emissions reductions, implementing agency or agencies, implementation schedule and milestones,
milestones for obtaining implementing authority as appropriate, geographic location, metrics for
tracking progress, and the applicable sector. All estimates of quantifiable GHG emissions reductions are
rounded to the nearest metric ton of carbon dioxide equivalent. Refer to the Appendix (Section 7.2). for
an explanation of how these GHG reduction measures were quantified and the assumptions used.
GHG reduction measures were prioritized based on the alignment with projects already in progress, the
benefits for the community, maximum GHG emissions reductions, and the goals of the Tribal
governments. In order to choose projects to propose in this PCAP, each Tribe conducted outreach to
stakeholders and residents via social media and in-person meetings. Determining the feasibility of these
projects involved interdepartmental communication and collaboration, along with occasional Tribal
Council and Elders meetings.
4.1
Pala Band of Mission Indians
The Pala Tribe identified four (4) priority GHG reduction measures for the PCAP (Table 12).
Table 12 – Pala Reservation Priority GHG Reduction Measures
Source
Priority Reduction Measures
Transportation
1. Tribal EV Adoption Program
Electricity
2. EV Charging Station Installation
3. Energy Audits & Retrofits
Solid Waste
4. Community Compost Program
1. Tribal Electric Vehicle (EV) Adoption Program
The Tribe proposes to develop a Tribal EV Adoption Program to encourage the Tribal community to
switch to EVs. The Pala Tribe has a goal of 30% EV adoption within the Tribal community. This measure
will use funding to hire support staff to incentivize the purchase of electric vehicles, perform outreach,
and identify additional funding sources for the purchase of EVs. Depending on allocated funding, it may
be possible to offer rebates or low interest loans for EV purchases. If 30% of residents switch to EV, it is
estimated that emissions would be reduced on the Reservation by 770 MTCO2e per year. This estimate
does not consider the upstream emissions associated with the production of EVs and their batteries.
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Pala Priority Measure #1: Tribal EV Adoption Program
Description
Hire dedicated support staff to guide and assist
Tribal members throughout the EV purchasing
process. Offer comprehensive support to
community members, aiding in the access of
available rebates or incentive programs to
alleviate the costs of upfront EV purchases.
Estimate of the Quantifiable GHG Emissions
Reductions
770 MTCO2e/year
Implementing Agency
Pala Environmental Department
Milestones For Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: Program development/hiring staff
Year 2: 15% EV Adoption
Year 3: 30% EV Adoption
Geographical Location
Pala Reservation
Metrics for Tracking Progress
Number of EVs purchased per year
Avoided GHG emissions per year
Applicable Sector
Transportation
2. EV Charging Station Installation
Expansion of EV charging infrastructure on the Pala Reservation is prioritized to meet the increasing
demand and needs of its workers, residents, and visitors. The Tribe currently has 36 Level 2 chargers
located at the Pala Casino Spa Resort. The proposed GHG emissions reduction measure includes the
installation of ten (10) Level 3 chargers between the Pala Administrative Center and Fleet Department,
as well as an additional 20 Level 2 chargers in high-use areas of the Reservation, such as at the Pala
Casino Spa Resort.
The expansion of the EV charging infrastructure on the Pala Reservation aims to reduce fuel
consumption and encourage the shift from gasoline and diesel-powered vehicles to EVs. With the
addition of 30 EV chargers, this measure promotes the use of cleaner transportation options. In an
optimal scenario where the chargers are used for 12 hours per day, this measure has the potential
reduce up to 3,719 MTCO2e per year. Costs associated with this measure would include the purchase,
installation, and maintenance of EV chargers. Level 3 chargers contain cooling systems and filters that
level 1 and 2 do not have, and therefore require regular maintenance. The industry standard assumption
for the lifespan of EV chargers is ten years.
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Pala Priority Measure #2: EV Charging Station Installation
Description
Install 20 Level 2 chargers and 10 Level 3 chargers
on the Reservation in addition to existing
chargers. Level 3 chargers will be deployed at the
Pala Administrative Center and Fleet
Department. Additional Level 2 chargers will be
installed in high-use areas of the Reservation
such as the Pala Casino Spa Resort.
Estimate of the Quantifiable GHG Emissions
Reductions
3,719 MTCO2e/year
Implementing Agency
Pala Environmental Department
Milestones For Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: Install 10 Level 3 chargers
Year 2: Install 10 Level 2 chargers
Year 3: Install 10 Level 2 chargers
Geographical Location
Pala Administrative Center, Pala Fleet
Department, Pala Casino Spa Resort
Metrics for Tracking Progress
Number of EV charging stations installed per year
EV miles charged per year
Applicable Sector
Transportation and electricity
generation/consumption
3. Energy Audits & Retrofits
Energy audits and retrofits for Tribal homes and facilities are proposed to reduce the electricity and
heating demands for residential, administrative, and commercial buildings. Professional energy auditors
will identify which systems are running efficiently and determine the cost benefits and feasibility of
implementing retrofits. Funds may be allocated to the training and certification of Tribal employees to
accomplish this. Specifically, the Tribe aims to first enhance energy efficiency of the residential sector
through the replacement of liquefied petroleum gas (LPG) heaters on the Reservation. The goal of this
measure is to install heat pumps, electric stoves, and tankless water heaters in 50 Tribal homes to move
away from LPG use. Air source heat pumps are an energy-efficient alternative to furnaces and air
conditioners in all climates. They work by transferring heat between a home and the outside air (U.S.
Department of Energy, 2024). This retrofit has the potential to reduce emissions by 430 MTCO2e per
year. There are additional retrofits that can also be considered later, such as updating or replacing
windows, checking for air leaks, and creating an outreach and marketing program to inform residents of
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the opportunity to lower their energy costs. Residents will approve the identified upgrades and opt in to
purchase the materials and installation.
Pala Priority Measure #3: Energy Audits & Retrofits
Description
Conduct energy audits to identify energy-saving
opportunities for Tribal homes and facilities.
Retrofit 50 Tribal homes and all Tribal facilities
with air-source heat pumps to increase energy
efficiency.
Estimate of the Quantifiable GHG Emissions
Reductions
430 MTCO2e/year
Implementing Agency
Pala Environmental Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: 25 Tribal homes & 25% of facilities
installed with heat pumps
Year 2: 50 Tribal homes & 50% of facilities
installed with heat pumps
Year 3: 100% of Tribal facilities installed with heat
pumps
Geographical Location
Pala commercial and residential areas
Metrics for Tracking Progress
Number of homes installed with heat pumps
Average annual energy savings per home
Tribal member satisfaction surveys
Applicable Sector
Electricity generation/consumption
4. Community Compost Program
A community compost program on the Pala Reservation is proposed to reduce GHG emissions by
diverting organic waste from landfills to composting systems. This would reduce landfill emissions and
create high-quality compost that is beneficial for local agriculture and community gardening projects.
With full community participation and effective composting of organic materials, the program is
expected to diminish the amount of food waste sent to landfills by up to 807 short tons per year and cut
the associated GHG emissions by approximately 495 MTCO2e. Costs associated with this program will
largely be staff time for designing and developing the program. Upfront cost for supplies (i.e., buckets)
to distribute to participating households. Ongoing costs include staff time to coordinate pickups and
transportation of food scraps and compost.
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Pala Priority Measure #4: Community Compost Program
Description
Create a collection system for picking up food
and yard waste from residents and facilities.
Compost produced by the program can be used
by residents and the community at large.
Community programs may also include education
and outreach to encourage the public to engage
with this initiative.
Estimate of the Quantifiable GHG Emissions
Reductions
495 MT CO2e/year
Implementing Agency
Pala Environmental Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: Program planning & outreach
Year 2: Launch program
Geographical Location
Pala Reservation
Metrics for Tracking Progress
Estimated amount of waste diverted from landfill
Number of houses participating in program
Applicable Sector
Solid waste management
4.2 Jamul Indian Village of California
Jamul Indian Village of California identified two (2) priority GHG reduction measures for the PCAP (Table
13).
Table 13 – JIVoC Priority GHG Reduction Measures
Source
Priority Reduction Measures
Electricity
1. EV Charging Station Installation
2. Jamul Casino Microgrid
1. EV Charging Station Installation
Expansion of EV charging infrastructure on the Reservation is proposed to meet the increasing demand
of its visitors. The Tribe currently has eight (8) Level 2 chargers located at the Jamul Casino. This
measure plans to install an additional 10 Level 2 chargers for Jamul Casino Hotel when it opens in 2025.
The expansion of the EV charging infrastructure on the Reservation aims to reduce fuel consumption
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and encourage the shift from gasoline and diesel-powered vehicles to EVs. With the addition of 10 EV
chargers, this measure promotes the use of cleaner transportation options, while potentially reducing
emissions by 232.5 MTCO2e per year. Costs associated with this measure would include the purchase
and installation of EV chargers and associated infrastructure, as well as maintenance.
JIVoC Priority Measure #1: EV Charging Station Installation
Description
Install 10 Level 2 EV charging stations for the
Jamul Casino Hotel.
Estimate of the Quantifiable GHG Emissions
Reductions
232.5 MT CO2e/year
Implementing Agency
JIVoC Environmental Protection Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: Jamul Casino Hotel construction complete
Year 2: Install 10 Level 2 chargers
Geographical Location
Jamul Casino Hotel
Metrics for Tracking Progress
Number of EVs charged by the new installations
Applicable Sector
Transportation and electricity
generation/consumption
2. Jamul Casino Microgrid
The Tribe proposes to install a microgrid to serve the Jamul Casino. A solar microgrid is a localized
electrical grid which uses solar energy for power. Solar panels generate electricity which is transferred to
large backup batteries that can deliver stored power at a later time. This is useful because electricity
from mainstream grid distributors costs more during on-peak hours, when the demand for electricity is
higher. During these times, the microgrid batteries can supply necessary electricity so that there will be
a larger cost savings associated with using solar energy. This is called 'peak-shaving.' Another
functionality of solar microgrids is 'net-metering' which means that in the event the solar panels
generate more electricity than the consumer needs, the microgrid can sell electricity back to the
mainstream grid supplier. This can significantly offset electricity bills. Microgrids systems offer resilience
to power outages by supplying locally generated electricity.
This microgrid would be powered by solar panels installed on the casino roof and on a 4-acre land
parcel. If the casino roof and approximately 80% of the land parcel is installed with solar panels, the
Tribe stands to reduce electricity related emissions by 2,485 MTCO2e per year.
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JIVoC Priority Measure #2: Jamul Casino Microgrid
Description
Deploy a microgrid to serve the Casino to ensure a reliable electricity
supply and ability to maintain power during grid disruptions.
Electricity will be generated by solar panels installed on the casino
roof and a 4-acre parcel set aside for solar panels and associated
infrastructure.
Estimate of the Quantifiable
GHG Emissions Reductions
2,485 MT CO2e/year
Implementing Agency
JIVoC Environmental Protection Department
Milestones for Obtaining
Implementing Authority
Tribal Council Approval
Implementation Schedule and
Milestones
Year 1: Planning & purchasing of materials
Year 2: Install solar panels on Casino roof
Year 3: Set up 4-acre parcel with solar and connect to Casino
Geographical Location
Jamul Casino
Metrics for Tracking Progress
Number of solar panels installed on Casino roof
Number of solar panels installed on parcel
Annual electricity savings from using solar panels instead of the grid
Applicable Sector
Electricity generation/consumption
Additional GHG Emissions Reduction Measures
In addition to the priority GHG emission reduction measures, JIVoC has also identified three (3)
additional measures that are proposed for implementation. For these additional measures,
implementation timeline and scale of the activity were uncertain during development of the PCAP. As a
result, GHG reduction calculations are not included. These GHG reduction measures will be further
explored during the development of the CCAP.
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Source
Additional GHG
Reduction Measures
Description
Electricity
Solarize Tribal Homes
Fully fund solar panel installations for Tribal
member homeowners to reduce electricity
emissions associated with the residential
sector.
Electricity
Wastewater
Renewable Energy
Install solar panels on rooftops/open areas
of wastewater treatment plants to
generate on-site renewable electricity. Pair
photovoltaic systems with energy storage
solutions to store excess energy for use
during peak demand. Consider the
feasibility of small-scale wind turbines to
harness wind energy at wastewater
treatment facilities.
Carbon Removal
Green Infrastructure
Upgrade existing urban infrastructure with
green features, such as permeable
pavements, bioswales, and rain gardens,
which enhance carbon sequestration while
managing stormwater.
4.3 Viejas Band of Kumeyaay Indians
The Viejas Tribe identified four (4) priority GHG reduction measures for the PCAP (Table 14).
Table 14 – Viejas Reservation Priority GHG Reduction Measures
Source
Priority Reduction Measures
Electricity
1. Energy Audits & Retrofits
2. Solarize Tribal Homes
Waste & Materials
3. Establish Recycling Program
Transportation
4. Fleet Electrification
1. Energy Audits & Retrofits
Energy audits and retrofits for Tribal homes and facilities are proposed to reduce the electricity and
heating demands for residential, administrative, and commercial buildings. Professional energy auditors
will identify which systems are running efficiently and determine the cost benefits and feasibility of
implementing retrofits. Funds may be allocated for the training and certification of Tribal employees to
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accomplish this. Specifically, this measure plans to weatherize 200 Tribal homes by replacing standard
double-pane windows with triple-pane ones. Triple-pane windows are more energy efficient than
double-pane windows and improve insulation and minimize energy loss. Triple-pane windows have a
thin third pane to create two air spaces instead of one, and they also have two low-emissivity coatings
that reflect radiant heat (U.S. Department of Energy, 2024). This retrofit has the potential to reduce
emissions by 173 MTCO2e per year. There are additional retrofits that can also be considered later, such
as updating or replacing windows, checking for air leaks, and creating an outreach and marketing
program to inform residents of the opportunity to lower their energy costs. Residents will approve the
identified upgrades and opt in to purchase the materials and installation.
Viejas Priority Measure #1: Energy Audits & Retrofits
Description
Conduct energy audits to identify energy-saving
opportunities for Tribal homes. Retrofit 200
Tribal homes with triple pane windows to
increase energy efficiency and reduce heating
and cooling loss. Homes would also be set up
with energy metering, so energy savings are
documented.
Estimate of the Quantifiable GHG Emissions
Reductions
173 MTCO2e/year
Implementing Agency
Viejas Environmental Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: 25% of Tribal homes retrofitted
Year 2: 50% of Tribal homes retrofitted
Year 3: 75% of Tribal homes retrofitted
Year 4: 100% of Tribal homes retrofitted
Geographical Location
Viejas commercial and residential areas
Metrics for Tracking Progress
Number of homes retrofitted with triple-pane
windows per year
Average annual energy savings per home
Tribal member satisfaction surveys
Applicable Sector
Electricity generation/consumption
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2. Establish Recycling Program
A Reservation-wide recycling program for Tribal homes and facilities will enhance the sustainability of
waste management practices and reduce GHG emissions by diverting recyclable waste from landfills.
With full community participation and effective recycling of materials, the program is expected to
diminish the amount of waste sent to landfills by up to 939 short tons per year and cut the associated
GHG emissions of methane by approximately 290 MTCO2e. Costs associated with this program will
largely be staff time for designing and developing the program. Upfront cost for supplies (i.e., recycling
receptacles) to distribute to homes and commercial areas. Ongoing costs include staff time to
coordinate pickups and transportation of recycling bins to a central location.
Viejas Priority Measure #2: Establish Recycling Program
Description
Establish a Reservation-wide comprehensive
recycling program for various materials including
paper, plastics, glass, and metals. Improve the
proper separation and recycling of industrial
waste streams. Can start with education
programs over a few months and ramp up
awareness over a few years. Supply recycling bins
to each Tribal home.
Estimate of the Quantifiable GHG Emissions
Reductions
290 MT CO2e/year
Implementing Agency
Viejas Environmental Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: Program planning, development, and
outreach
Year 2: Roll out recycling program
Year 3: Ongoing community outreach and
education
Geographical Location
Viejas Reservation
Metrics for Tracking Progress
Estimated amount of waste diverted from
landfills per year
Applicable Sector
Solid Waste Management
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3. Solarize Tribal Homes & Implement Net Metering Policy
This measure aims to provide fully funded installations of solar panel systems with net metering
capabilities for 200 homes on the Reservation. Net metering allows homeowners to sell surplus
electricity generated by solar panels back to the grid electricity provider, in this case, San Diego Gas and
Electric. Net metering not only conserves energy, but also significantly offsets the homeowner’s energy
costs. Given current energy demand, it is estimated that each home would have to install 201 square
feet, or approximately 12 solar panels (17.5 sq ft each), to offset all electricity emissions from the
residential sector. This equates to a reduction of 397 MTCO2e per year, the same amount estimated to
be emitted annually. Depending on the specifics of each solar installation, installing more than 12 solar
panels per home could potentially generate excess electricity homeowners could sell back to the grid.
Viejas Priority Measure #3: Solarize Tribal Homes & Implement Net Metering Policy
Description
Offer fully funded solar panel installation for
community members. Goal is to set up 200
homes on the Reservation with solar and net
metering ability to allow homeowners to receive
credit for excess electricity generated and fed
back to the grid.
Estimate of the Quantifiable GHG Emissions
Reductions
397 MT CO2e/year
Implementing Agency
Viejas Environmental Department
Milestones for Obtaining Implementing Authority
Tribal Council Approval
Implementation Schedule and Milestones
Year 1: 25% of Tribal homes solarized
Year 2: 50% of Tribal homes solarized
Year 3: 75% of Tribal homes solarized
Year 4: 100% of Tribal homes solarized
Geographical Location
Viejas Reservation
Metrics for Tracking Progress
Number of homes installed with solar panels per
year
Avoided GHG emissions per year
Profits made from selling energy back to the grid
Applicable Sector
Electricity Generation & Consumption
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4. Tribal Fleet Electrification
This measure aims to replace 20 light-duty trucks in the Tribal fleet with EVs. The Tribal fleet is currently
made up of 25 light-duty trucks. By switching 20 of these vehicles to electric, it is anticipated that GHG
emissions will be reduced by 20 MTCO2e. This estimate does not consider the upstream emissions
associated with the production of EVs and their batteries.
Viejas Priority Measure #4: Fleet Electrification
Description
Replace 20 light-duty trucks with EVs for the Tribal fleet.
Estimate of the Quantifiable
GHG Emissions Reductions
20 MT CO2e/year
Implementing Agency
Viejas Environmental Department
Milestones for Obtaining
Implementing Authority
Tribal Council Approval
Implementation Schedule and
Milestones
Year 1: Purchase 20 EVs to replace gas-powered trucks
Geographical Location
Viejas Reservation
Metrics for Tracking Progress
GHG emissions saved from electrifying fleet per year
Applicable Sector
Transportation, Electricity Generation & Consumption
Additional Priority Measures
In addition to the priority GHG emission reduction measures, the Viejas Tribe has also identified three
(3) additional measures that are proposed for implementation. For these additional measures, the
implementation timeline and scale of the activity were uncertain during development of the PCAP. As a
result, GHG reduction calculations are not included. These GHG reduction measures will be further
explored during the development of the CCAP.
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Source
Non-Priority Reduction
Measures
Description
Electricity
EV Charging Station
Installation
Install EV Charging stations in high-use areas of the
Reservation, such as the Viejas Casino.
Renewable Heating and
Cooling (RHC) Systems
Install renewable heating systems, such as ground-
source heat pumps, air-source heat pumps, and solar
thermal systems, for residential and commercial
buildings.
Combined Heat and Power
(CHP) Systems
Install CHP systems in Tribal facilities to increase energy
efficiency by simultaneously generating electricity and
useful heat from a single source. During conventional
power generation, heat is lost. By capturing and using
heat that would otherwise be wasted, CHP can achieve
80% efficiency while typical technology only achieves
around 50%.
4.4 La Posta Band of Mission Indians
The La Posta Tribe identified two (2) priority GHG reduction measures for the PCAP (Table 15).
Table 15 – La Posta Reservation Priority GHG Reduction Measures
Source
Priority Reduction Measures
Carbon Removal
1. Implement Erosion Controls for Wetland Restoration
2. Acquire Land for Restoration & Revegetation
Electricity
3. Solarize Tribal Homes & Facilities
1. Implement Erosion Controls for Wetland Restoration
La Posta is proposing to retore wetlands and enhance carbon sequestration to offset its GHG emissions.
Due to a culvert that increases the flow of water from interstate highway 8, 7.41 acres of riparian creek
habitat on the Reservation is being degraded from sedimentation. Erosion controls are needed to inhibit
sediment from discharging into the wetland. Restoring the wetland will require planning, erosion
mitigation, construction, and revegetation activities. The site assessment will be conducted by
environmental professionals, who will identify potential methods for mitigating this habitat destruction.
Methods to reduce flow such as the installation of riprap underneath the outlet of the culvert may be
pursued. Additional restoration techniques such as invasive species removal and native species planting
will also be employed when funding allows. If this area is restored to its fullest potential, it will
sequester an estimated 9.6 MTCO2e per year, decreasing La Posta Reservation’s net GHG emissions.
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La Posta Priority Measure #1: Implement Erosion Controls & Wetland Restoration
Description
Implement erosion controls necessary to facilitate wetland
restoration of surrounding area. Develop a project/program to
restore and protect degraded wetland ecosystems, which are highly
effective at sequestering carbon. Restoration may include removing
invasive plants and planting natives, targeting areas particularly
prone to erosion and desertification. Target native plant vegetation
on degraded lands to prevent further soil erosion and enhance
carbon storage.
Estimate of the quantifiable
GHG emissions reductions
9.6 MT CO2e/year
Implementing agency
La Posta Environmental Department
Milestones for obtaining
implementing authority
Tribal Council Approval
Implementation schedule and
milestones
Year 1: Develop planning document for restoration of project area
Year 2: Begin implementing restoration measures in the project area
Year 3+: Ongoing maintenance & restoration activities
Geographical location
La Posta Reservation
Metrics for tracking progress
Flow rate and sedimentation monitoring
Native Species health and abundance
Applicable sector
Carbon Removal
2. Land Acquisition for Restoration & Revegetation
A 120-acre parcel has been identified by the Tribe for acquisition, in order to restore the area and utilize
it as a preserve. Restoration activities would include planning, identification and removal of invasive
species, and planting of native vegetation. Funding would be allocated toward employing a team of
individuals responsible for assessing habitat quality on the parcel and establishing a restoration plan to
improve the ecosystem benefits. If this parcel is fully restored to the greatest extent possible, it has the
potential to sequester 156 MTCO2e per year, reducing La Posta Reservation’s net GHG emissions.
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La Posta Priority Measure #2: Land Acquisition for Restoration & Revegetation
Description
Evaluate the ecological status of land parcel. Set clear restoration
goals and objectives. Develop comprehensive restoration plan. Clear
invasive species. Identify appropriate native vegetation for the site.
Monitor and evaluate progress with a focus on keystone species.
Estimate of the quantifiable
GHG emissions reductions
156 MT CO2e/year
Implementing agency
La Posta Environmental Department
Milestones for obtaining
implementing authority
Tribal Council Approval
Implementation schedule and
milestones
Year 1: Develop planning document for restoration of project area
Year 2: Begin implementing restoration measures in the project area
Year 3+: Ongoing maintenance & restoration activities
Metrics for tracking progress
Area of land restored per year
Estimated carbon sequestered by area
Keystone species health and presence within the parcel
Applicable sector
Carbon Removal
3. Solarize Tribal Homes & Facilities
This measure aims to provide fully funded installations of solar panels for 13 homes and select Tribal
facilities on the Reservation. Given current energy demand, it is estimated that each home would have
to install 201 square feet, or approximately 12 solar panels (17.5 sq ft each), to offset all electricity
emissions from the residential sector. This equates to a reduction of 26 MTCO2e per year,
approximately the same amount estimated to be emitted annually. Tribal facilities would have to install
a total of 6,276 square feet, or 359 solar panels, to offset all electricity emissions from the commercial
sector, which equates to a reduction of 62 MTCO2e per year. Depending on the specifics of each solar
installation, installing solar panels on a larger area than mentioned above could potentially generate
excess electricity homeowners could sell back to the grid. In total, the Tribe would reduce an estimate
88 MTCO2e per year if Tribal homes and facilities were solarized.
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La Posta Priority Measure #3: Solarize Tribal Homes & Facilities
Description
Transition residence and community buildings to solar power to
reduce use of generator during Public Safety Power Shut Offs (PSPS).
The goal is to provide solar installations to all 13 of the Tribal homes
on the Reservation as well as the following facilities: Tribal
Administration Office, Boys and Girls Club, Old Casino, and Addiction
Treatment Center.
Estimate of the quantifiable
GHG emissions reductions
88 MT CO2e/year
Implementing agency
La Posta Environmental Department
Milestones for obtaining
implementing authority
Tribal Council Approval
Implementation schedule and
milestones
Year 1: Install solar panels on all 13 Tribal homes
Years 2-3: Install solar panels on Tribal facilities
Geographical location
La Posta Reservation
Metrics for tracking progress
Energy savings from solar panels
Profits made from selling energy back to the grid if any
Applicable sector
Electricity Generation & Consumption
Additional Priority Measures
In addition to the priority GHG emission reduction measures, the La Posta Tribe has also identified four
(4) additional measures that are proposed for implementation. For these additional measures, the
implementation timeline and scale of the activity were uncertain during development of the PCAP. As a
result, GHG reduction calculations are not included. These GHG reduction measures will be further
explored during the development of the CCAP.
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Source
Non-Priority Reduction
Measures
Description
Electricity
Energy Audits & Retrofits
Conduct energy audits to identify energy-saving
opportunities for Tribal homes and community
buildings. Offer incentives, low interest loans, or fully
fund energy-efficient retrofits (i.e., replacing appliances
with Energy Star-rated ones).
Waste &
Materials
Community Compost
Enhancement Project
Improve the current community compost program on
the Reservation. Possibly create a collection system for
picking up food and yard waste from residents and
facilities. Compost produced by the program can be
used by residents and the community at large.
Community programs may also include education and
outreach to encourage the public to engage with this
initiative.
Carbon
Removal
Green Infrastructure
Upgrade existing urban infrastructure with green
features, such as permeable pavements, bioswales, and
rain gardens, which enhance carbon sequestration
while managing stormwater. Not only do these added
features sequester carbon themselves, but also protect
wetlands from stormwater.
Establish Buffer Zones to
Protect Critical Habitat
Establish buffer zones around sensitive wild areas or
wetlands to protect them from encroachment and limit
disturbances that reduce carbon stocks.
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5.0 BENEFITS ANALYSIS
For the CPRG PCAP, the EPA mandates a general benefits analysis, as well as a benefits analysis
specifically for disadvantaged communities. Because Native American Reservations are already classified
as disadvantaged communities, this PCAP has one overarching benefits analysis. This approach follows
EPA guidelines and allows Tribes to integrate considerations for all community members uniformly
within their overall climate action strategies.
The benefits analysis will be split into sections for the four SDTC members. For each of these subsequent
benefits analyses, there is a base year (2020) co-pollutant inventory, and a description of both the co-
pollutant related benefits and other community benefits for each quantified GHG reduction measure
proposed. Co-pollutants that are included in this analysis may be criteria air pollutants (CAPs), which are
emphasized, or hazardous air pollutants (HAPs).
At the time this inventory was created, there was no Reservation-specific co-pollutant data available for
this analysis. The EPA NEI was utilized in order to meet PCAP requirements for this section. In order to
provide base year co-pollutant emissions estimates, the San Diego County co-pollutant data from the
NEI was programmatically scaled down to the population of each SDTC Tribe.
Description of Prevalent Co-pollutants
The co-pollutants that are prevalent in the 2020 San Diego County NEI data include volatile organic
compounds (VOCs), carbon monoxide (CO), particulate matter (PM10 and PM2.5), methanol, ammonia,
nitrogen oxides (NOx), formaldehyde, toluene, and xylenes.
Volatile Organic Compounds (VOCs)
VOCs include a variety of compounds frequently found in petroleum fuels, hydraulic fluids, paint
thinners, and dry-cleaning agents. Some VOCs have short term health effects such as eye nose and
throat irritation as well as long term health effects such as exacerbation of asthma and other respiratory
conditions (EPA, 2023).
Carbon Monoxide (CO)
Carbon monoxide is a product of incomplete oxidation of carbon in combustion. Sources of carbon
monoxide include gas stoves and furnaces, generators and other gasoline-powered equipment,
automotive exhaust, and tobacco smoke (EPA, 2023).
Particulate Matter (PM)
Particulate matter includes both solid particles and liquid droplets that are small enough to be inhaled,
which can cause serious adverse health effects. PM2.5 particles are smaller than 2.5 micrometers in
diameter, while PM10 particles are smaller than 10 micrometers in diameter (EPA, 2023). PM can
penetrate into the lungs and bloodstream, leading to respiratory and cardiovascular problems which
may cause premature death.
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Methanol
Methanol is primarily used as an industrial solvent for inks, resins, adhesives, and dyes, as well as for
chemical manufacturing. Exposure to airborne methanol may occur due to inhalation of evaporative
gases from solvent use or vehicle exhaust. Airborne methanol exposure may cause immediate health
effects such as visual disturbances and neurological damage, as well as long term health conditions such
as cancer and reproductive or developmental effects (EPA, 2000).
Ammonia
Airborne ammonia is a toxicant derived from vehicle exhaust, decomposition of waste, and fertilizer
application. The inhalation of ammonia may cause irritation of the eyes, nose, and throat, as well as
increase susceptibility to respiratory infections (EPA, 1995).
Nitrous Oxides (NOx)
Nitrogen oxides (NOx) are a family of poisonous gases emitted via the combustion of fossil fuels. NOx
plays a major role in the atmospheric reactions with VOCs that produce ozone, or smog. The inhalation
of NO
2
can cause respiratory irritation, as well as contribute to the development of asthma and increase
susceptibility to respiratory infections (EPA, 2023).
Formaldehyde
Formaldehyde is a byproduct of combustion and is also found in fuel burning appliances, fertilizers and
pesticides, adhesives, composite wood products, building materials such as insulation, and cosmetics.
Exposure to formaldehyde typically occurs via inhalation, which may cause irritation of the eyes, nose,
and throat, as well as some forms of cancer (EPA, 2023).
Toluene
Toluene is a typically used in a solvent that is added to gasoline. For this reason, vehicle emissions are
the primary sources of airborne toluene. The toxicant is also added to many common household
adhesives, paints, coatings, and inks. The central nervous system is primarily affected by both acute and
long-term toluene exposures. Acute exposure may cause fatigue, headaches, and nausea, while chronic
exposure causes respiratory irritation, central nervous system dysfunction, developmental effects, and
more (EPA, 2012).
Xylene (mixed isomers)
Xylene is usually found as a mixture of three isomers: m-xylene, o-xylene, and p-xylene. Airborne
xylenes are released into the atmosphere as fugitive emissions from industrial sources, vehicles exhaust,
and through volatilization from solvent use. Acute exposure to xylene results in irritation of eyes, nose
and throat, gastrointestinal effects, and neurological effects. Chronic exposure results in central nervous
system effects, respiratory effects, cardiovascular effects, and kidney effects (EPA, 2000)
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5.1
Pala Band of Mission Indians
Co-Pollutant Inventory
The highest co-pollutant emissions from the Pala Tribe are from carbon monoxide, at an estimated
68.67 tons. This was followed by other criteria air pollutants such as VOCs, PM10, nitrogen oxides,
PM2.5, and ammonia (Table 16).
Table 16 – Pala Top 10 Co-Pollutant Emissions Per Year (EPA, 2024)
Pollutant
Pollutant Type
Emissions (tons)
Carbon Monoxide
CAP
68.67
Volatile Organic Compounds
CAP
27.65
PM10 Primary (Filt + Cond)
CAP
14.78
Nitrogen Oxides
CAP
7.79
PM2.5 Primary (Filt + Cond)
CAP
4.45
Ammonia
CAP
2.22
Methanol
HAP
1.03
Toluene
HAP
0.55
Formaldehyde
HAP
0.53
Xylenes (Mixed Isomers)
HAP
0.43
Co-Benefits of Priority Emissions Reduction Measures
1. Tribal EV Adoption Program
Co-pollutant Benefits
The Tribal EV Adoption Program aims to encourage the community to switch to EVs by facilitating
purchases of EVs and providing support for receiving rebates and discounts. The switch to EVs would
greatly benefit the Tribe by reducing CAPs emitted into the atmosphere from fossil fuel use. Fossil fuel
vehicles produce carbon monoxide and nitrogen oxides as products of the combustion process. They
also release fine particles (PM2.5 & 10) through exhaust emissions and from agitating road dust. VOCs
are also released into the atmosphere from the evaporation of gasoline and diesel fuel. Since EVs do not
run on fossil fuels, they have no direct tailpipe emissions. This measure would greatly reduce the
prevalence of these CAPs on the Pala Reservation.
Additional Benefits
The overall reduction in air pollution from EVs will help improve air quality on the Reservation. Improved
air quality would benefit the Tribal community and vulnerable groups such as children and the elderly.
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Exposure to PM2.5 has been linked to premature death, particularly in people who have chronic heart or
lung diseases, and reduced lung function growth in children. PM10 is more likely to deposit on the
surfaces of the larger airways of the upper region of the lung. Short-term exposures to PM10 have been
associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive
pulmonary disease (COPD), leading to increased hospitalization.
Economic benefits from EV adoption include fuel cost savings for Tribal members. The Tribal is also
looking to provide free EV charging on the Reservation for Tribal members, further incentivizing the
adoption of EV’s on the Reservation. Resiliency to price fluctuation due to gasoline shortages and
embargoes would be strengthened with the incorporation of EV’s, particularly with expansion of
solarization and microgrid systems on the Reservation.
2. EV Charging Station Installation
Co-pollutant Benefits
Co-pollutant benefits from the installation of EV charging stations are very similar to the benefits
acquired from switching to EVs. By providing charging infrastructure and thereby promoting the use of
EVs, emissions of carbon monoxide, particulate matter, and nitrogen oxides would be reduced. VOCs
have the potential to be reduced even more from this measure, as gasoline and diesel fuel storage
contribute to VOC emissions. As EV adoption ramps up and more charging infrastructure is installed, it
follows that VOC emissions from gas stations and gas-filling activities would also be reduced.
Additional Benefits
Expanding EV charging infrastructure would lead to improved air quality and community health on the
Reservation (see discussion on Tribal EV Adaption). The proposed emissions reduction measure involves
the installation of ten (10) Level 3 chargers between the Pala Administrative Center and Fleet
Department, as well as an additional 20 Level 2 chargers in high-use areas of the Reservation, such as at
the Pala Casino Spa Resort. If charging stations are discounted or free for Tribal employees, these would
benefit the Tribal workforce that use EV’s and can help with employee retention by subsidizing
transportation costs. Additional charging stations at the Pala Casino Spa Resort can help encourage
visitation and stay duration at Tribal enterprises.
3. Energy Audits & Retrofits
Co-pollutant Benefits
This measure aims to retrofit Tribal homes with air-source heat pump technology instead of using
liquefied petroleum gas (LPG) for heating. LPG combustion releases carbon monoxide, nitrogen oxides,
and formaldehyde into the atmosphere. Switching to air-source heat pumps would eliminate all CAP and
formaldehyde emissions because contrary to LPG heating, heat pumps operate by transferring heat
rather than burning fuel.
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Additional Benefits
This program has the potential to decrease health risks during extreme weather events and climate
disasters by keeping homes cool and well insulated. Members will benefit from better indoor air quality
during wildfires or other high pollution events with the installation of robust air filters, which reduce
health risks associated with air pollution. Additionally, replacing old appliances and installing energy
efficient models can have the added benefit of saving Tribal members money by reducing monthly utility
bills. These upgrades have the potential to increase property value. Based on Tribal member’s
occupations, this program also has the potential to increase job opportunities as labor will be needed to
retrofit Tribal homes. Air-source heat pumps are an energy efficient alternative to traditional heating
that would provide improved indoor air quality and a healthier living environment for Tribal members.
This would be particularly beneficial for sensitive groups such as children, elderly people, and those with
pre-existing health conditions. Aside from the health benefits, heat pumps have lower operating costs
due to low maintenance requirements and a longer lifespan. Although upfront costs are greater, the
benefits over time outweigh those from traditional heating.
4. Community Compost Program
Co-pollutant Benefits
Implementing a community compost program offers substantial benefits in terms of reducing co-
pollutants on the Reservation. By diverting organic waste from landfills to composting facilities, this
measure significantly decreases the volume of waste that undergoes anaerobic decomposition, a
process responsible for generating methane, a potent GHG, and various co-pollutants. Composting
organic material not only reduces emissions of methane but also mitigates the production of VOCs and
ammonia. Additionally, the process helps in minimizing the reliance on chemical fertilizers, the
production and use of which are associated with emissions of nitrogen oxides. The addition of compost
to local soil ecosystems adds valuable bacteria, fungi, and microorganisms, producing what is known as
‘living soil.’ Living soil sequesters carbon as opposed to ‘dead soil,’ which releases carbon and particulate
matter into the atmosphere throughout the process of desertification. Through these mechanisms, a
community compost program would act to reduce co-pollutants, improving air quality and public health
within the Reservation.
Additional Benefits
Implementing a community compost program brings several key benefits to the general community,
such as fostering environmental sustainability and enhancing public health. Through composting,
organic waste is transformed into a nutrient-rich soil additive, beneficial for plant growth and resulting
in more productive gardens and green spaces. Such improvements in local greenery can bolster local
food production and encourage community gardening projects. The addition of compost creates a
healthy soil ecosystem, which reduces erosion, pests, and runoff into local waterways. Additionally, the
compost program may serve as an educational tool, raising awareness about sustainable waste
management practices among Tribal members. Overall, a community compost program not only
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contributes to waste reduction but also supports local ecosystems, enriches soil quality, and promotes a
culture of environmental stewardship within the community.
5.2
Jamul Indian Village of California
Co-Pollutant Inventory
The highest co-pollutant emissions from the Reservation are from carbon monoxide, at an estimated 3.5
tons. This was followed by other criteria air pollutants such as VOCs, PM10, nitrogen oxides, PM2.5, and
ammonia (Table 17).
Table 17 – JIVoC Top 10 Co-Pollutant Emissions Per Year (EPA, 2024)
Pollutant
Pollutant Type
Emissions (tons)
Carbon Monoxide
CAP
3.50
Volatile Organic Compounds
CAP
1.41
PM10 Primary (Filt + Cond)
CAP
0.75
Nitrogen Oxides
CAP
0.40
PM2.5 Primary (Filt + Cond)
CAP
0.23
Ammonia
CAP
0.11
Methanol
HAP
0.05
Toluene
HAP
0.03
Formaldehyde
HAP
0.03
Xylenes (Mixed Isomers)
HAP
0.02
Co-Benefits of Priority Emissions Reduction Measures
1. EV Charging Station Installation
Co-pollutant Benefits
By providing charging infrastructure and thereby promoting the use of EVs, emissions of carbon
monoxide, particulate matter, and nitrogen oxides would be reduced. VOCs have the potential to be
reduced even more from this measure, as gasoline and diesel fuel storage contribute to VOC emissions.
As EV adoption ramps up and more charging infrastructure is installed, it follows that VOC emissions
from gas stations and gas-filling activities would also be reduced.
Additional Benefits
Expanding EV charging infrastructure would lead to reduced air pollution on the Reservation, improving
air quality. This would benefit the community at large, particularly more vulnerable groups such as
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children and elderly people. Tribal members would also save money on fuel because electricity is
generally cheaper than gasoline and use of the charging stations could be offered free of charge or at a
discounted rate for Tribal members.
2. Jamul Casino Microgrid
Co-pollutant Benefits
Grid electricity relies on power generation from a variety of different sources, including ones that utilize
the combustion of fossil fuel to generate power. The combustion of fossil fuels is known to cause
emissions of carbon monoxide, nitrogen oxides, VOCs, particulate matter, and sulfur dioxide. Although
these emissions typically are scope 2 emissions occurring upstream of the site where the electricity is
used, the electricity used still causes these emissions to occur elsewhere. Solar power does not involve
the combustion of fossil fuels, and therefore implementing a solar powered microgrid completely
eliminates emissions of the aforementioned pollutants.
Additional Benefits
There are many general community benefits to implementing solar powered microgrid projects. The
peak saving ability of the grid will allow large batteries to store electricity during off-peak hours to be
provided later, during peak hours. Because electricity costs more during peak hours, this will be a
significant cost savings for Tribal members. The labor required to install and maintenance a local
microgrid system may be sourced directly from tribal members or partners, producing additional
economic benefits for the Tribe. Additionally, using locally generated electricity will reduce the
community’s dependence on outside energy sources. In the event of an emergency or power outage,
the facilities can rely on energy stored by the microgrid batteries, increasing climate resilience.
5.3
Viejas Band of Kumeyaay Indians
Co-Pollutant Inventory
The highest co-pollutant emissions from the Viejas Tribe are from carbon monoxide, at an estimated
23.04 tons. This was followed by other criteria air pollutants such as VOCs, PM10, nitrogen oxides,
PM2.5, and ammonia (Table 18).
Table 18 – Viejas Top 10 Co-Pollutant Emissions Per Year (EPA, 2024)
Pollutant
Pollutant Type
Emissions (tons)
Carbon Monoxide
CAP
23.04
Volatile Organic Compounds
CAP
9.28
PM10 Primary (Filt + Cond)
CAP
4.96
Nitrogen Oxides
CAP
2.61
PM2.5 Primary (Filt + Cond)
CAP
1.50
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Ammonia
CAP
0.74
Methanol
HAP
0.35
Toluene
HAP
0.18
Formaldehyde
HAP
0.18
Xylenes (Mixed Isomers)
HAP
0.14
Co-Benefits of Priority Emissions Reduction Measures
1. Energy Audits & Retrofits
Co-pollutant Benefits
This measure plans to weatherize 200 Tribal homes by replacing standard double pane windows with
energy efficient triple pane windows to improve insulation and minimize energy loss. With better
insulation, residents would use less energy towards heating and cooling the home. This would reduce
emissions related to scope 2 emissions from fossil-fuel combustion for electric power, such as carbon
monoxide, nitrogen oxides, VOCs, particulate matter, and sulfur dioxide. Additionally, the reduction in
propane furnace use due to better insulation would greatly reduce indoor criteria air pollutant pollution
and improve ambient indoor air quality.
Additional Benefits
Triple-pane windows provide a variety of benefits such as enhanced energy efficiency, increased
comfort for homeowners, and reduced electricity and propane bills as a result of using less energy. In
addition to the economic benefits to Tribal members, improved indoor air quality will reduce the risk of
exacerbating respiratory and cardiovascular illnesses due to indoor criteria air pollutant emissions. The
labor required to conduct home energy audits and install retrofits may be sourced from directly within
the community, increasing economic and workforce resilience. In addition, home weatherization may
increase climate resilience by better protecting homes from severe climate related weather events such
as heat waves, extreme winter weather, high winds, and wildfire smoke.
2. Solarize Tribal Homes
Co-pollutant Benefits
Grid electricity relies on power generation from a variety of different sources, including ones that utilize
the combustion of fossil fuel to generate power. The combustion of fossil fuels is known to cause
emissions of carbon monoxide, nitrogen oxides, VOCs, particulate matter, and sulfur dioxide. Although
these emissions typically are scope 2 emissions occurring upstream of the site where the electricity is
used, the electricity used still causes these emissions to occur elsewhere. Solar power does not involve
the combustion of fossil fuels, and therefore solarizing Tribal homes would eliminate emissions of the
aforementioned pollutants.
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Additional Benefits
Installing solar panels on Tribal homes offers many advantages, including financial savings,
environmental benefits, and increased energy independence. Tribal homeowners could significantly
reduce their electricity bills, with the potential of selling excess electricity back to grid through net
metering. Having a renewable solar system supplying electricity also increases resilience during power
outages and allows residences to be more energy independent. The labor required to assess project
feasibility and install solar panels may also be sourced directly from Tribal members, increasing
workforce stability and economic resilience.
3. Establish a Recycling Program
Co-pollutant Benefits
Implementing a recycling program offers substantial benefits in terms of reducing co-pollutants on the
Reservation. By diverting recyclable waste from landfills to recycling facilities, this measure significantly
decreases the volume of waste that undergoes anaerobic decomposition, a process responsible for
generating methane, a potent GHG, and various co-pollutants. Recycling also reduces the use of raw
materials, and the process of recycling generates less emissions than is generated from using raw
materials. Through avoided landfill waste, this program would act to reduce co-pollutants, improving air
quality and public health within the Reservation.
Additional Benefits
A recycling program delivers a wide range of benefits, including resource conservation, energy savings,
waste reduction, economic growth, and community engagement. This program would benefit the Tribe
by promoting sustainable practices, reducing pollution emitted from landfills, and opening opportunities
for community engagement and education. Recycling also reduces the use of raw materials, and the
process of recycling generates less upstream pollution than is generated from using raw materials. This
measure would primarily focus on educational campaigns, which would enhance community
engagement and increase awareness of general sustainability practices.
4. Fleet Electrification
Co-pollutant Benefits
This reduction measure targets older and less fuel-efficient vehicles for replacement with EVs. The
switch to EVs would greatly benefit the Tribe by reducing CAPs emitted into the atmosphere from fossil
fuel use. Fossil fuel vehicles produce carbon monoxide and nitrogen oxides as products of the
combustion process. They also release fine particles (PM2.5 & 10) through exhaust emissions and from
agitating road dust. VOCs are also released into the atmosphere from the evaporation of gasoline and
diesel fuel. Since EVs do not run on fossil fuels, they have no direct tailpipe emissions. This measure
would greatly reduce the prevalence of these CAPs on the Reservation.
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Additional Benefits
The overall reduction in air pollution from the shift to EV use will help improve air quality on the
Reservation, which would benefit the community at large, particularly more vulnerable groups such as
children and elderly people. The cost of fuel for the Tribal fleet would also be reduced, as electricity is
generally cheaper than gasoline and EV charging would likely be free of charge for Tribal fleet vehicles.
In the event of an emergency or power outage, EVs may be utilized to provide backup power for
essential services such as medical equipment, thus enhancing climate resilience.
5.4
La Posta Band of Mission Indians
Co-Pollutant Inventory
The highest co-pollutant emissions from the La Posta Tribe are from carbon monoxide, at an estimated
1.94 tons. This was followed by other criteria air pollutants such as VOCs, PM10, nitrogen oxides, PM2.5,
and ammonia (Table 19).
Table 19 – La Posta Top 10 Co-Pollutant Emissions Per Year (EPA, 2024)
Pollutant
Pollutant Type
Emissions (tons)
Carbon Monoxide
CAP
1.94
Volatile Organic Compounds
CAP
0.78
PM10 Primary (Filt + Cond)
CAP
0.42
Nitrogen Oxides
CAP
0.22
PM2.5 Primary (Filt + Cond)
CAP
0.13
Ammonia
CAP
0.06
Methanol
HAP
0.03
Toluene
HAP
0.02
Formaldehyde
HAP
0.02
Xylenes (Mixed Isomers)
HAP
0.01
Co-Benefits of Priority Emissions Reduction Measures
1. Implement Erosion Controls for Wetland Restoration
Co-pollutant Benefits
Wetlands play a large role in carbon sequestration, capturing and storing carbon dioxide from the
atmosphere. Wetlands reduce nitrogen oxide and ammonia pollution, as microbial activity in the soils
goes through the process of denitrification. Particulate matter emissions could also be reduced by
wetlands as they help to trap and filter particulate matter from the air and water. Vegetation structure
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could also act as a natural barrier, reducing the concentration of PM2.5 and PM10 in the surrounding air
and water.
Additional Benefits
Wetland restoration has many ecological and societal benefits. Wetlands are among the most
biologically diverse ecosystems, providing critical habitat for a variety of plant and animal species.
Wetlands act as natural filters and enhance water quality by trapping and removing pollutants from
water. Furthermore, vegetation and root systems in wetlands stabilize soils and prevent erosion, which
also provides benefits for flood control and stormwater management. Wetlands may also have cultural
value to the Tribe and restoring them helps to preserve cultural heritage and traditional knowledge.
Overall, wetlands enhance ecosystem services and strengthen climate resilience which can highly
benefit the Tribal community.
2. Acquire Land for Restoration & Revegetation
Co-pollutant Benefits
Increasing vegetation and ecological diversity of unproductive or previously developed land greatly
increases its ability to sequester carbon and filter criteria air pollutants. Enhancing root systems
underground will increase moisture retention, reducing PM emissions from windy days. Vegetation also
acts as a natural air filter, limiting the concentration of VOCs, nitrogen oxides, and sulfur dioxide.
Revegetation also improves soil health, limiting the breakdown of organic material underground, which
leads to lower emissions of criteria air pollutants.
Additional Benefits
Ecological restoration has many environmental and societal benefits. The program will focus on re-
establishing species that are culturally and historically valuable to the La Posta Tribe. The labor required
to implement this project may lead to volunteering or employment opportunities for tribal residents and
community members. This will create increased workforce development and many valuable educational
opportunities. This open-space area may also offer recreational activities such as hiking, biking, and
birdwatching, which will positively impact the physical and mental health of community members.
3. Solarize Tribal Homes & Facilities
Co-pollutant Benefits
Grid electricity relies on power generation from a variety of different sources, including ones that utilize
the combustion of fossil fuel to generate power. The combustion of fossil fuels is known to cause
emissions of carbon monoxide, nitrogen oxides, VOCs, particulate matter, and sulfur dioxide. Although
these emissions typically are scope 2 emissions occurring upstream of the site where the electricity is
used, the electricity used still causes these emissions to occur elsewhere. Solar power does not involve
the combustion of fossil fuels, and therefore solarizing Tribal homes and facilities would eliminate
emissions of the aforementioned pollutants on the Reservation.
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Additional Benefits
Installing solar panels on Tribal homes and facilities offers many advantages, including financial savings,
environmental benefits, and increased energy independence. Tribal homeowners could significantly
reduce their electricity bills, with the potential of selling excess electricity back to grid through net
metering. Having a renewable solar system supplying electricity also increases resilience during power
outages and allows the Tribe to be more energy independent.
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6.0 REVIEW OF AUTHORITY TO IMPLEMENT
Each Tribe in the SDTC has the authority to implement GHG emissions reduction measures that are
located on their respective Reservations and other lands held in federal trust. The governments of
sovereign Tribal nations maintain the power to determine their own governance structures and enforce
their own laws and regulations within their jurisdiction, including the implementation of GHG reduction
measures. All the GHG emissions reduction measures identified in Section 4.0 are located on
Reservation land. For each Tribe, approval from Tribal Council is required prior to implementing any
GHG reduction measure.
If an emissions reduction measure is funded through a CPRG implementation grant, an official resolution
would be adopted by the respective Tribal Council to approve acceptance of the grant and authorize the
implementation of the project. A cultural monitor will be required for any GHG emissions reduction
measures that will result in ground disturbance.
Section 4.0 contains a schedule of milestones for obtaining implementing authority for each priority
emissions reduction measure.
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7.0 APPENDIX
7.1
GHG Emissions Inventory Methodology
This emissions calculations section outlines the steps taken to calculate each source of GHG emissions
on each Reservation. Wherever possible, data sources and estimation tools are cited and described
below. Tools that were utilized most frequently include the Tribal Greenhouse Gas Inventory Tool (TGIT)
(EPA, 2010), the U.S. Energy Information Administration Commercial Building Energy Consumption
Survey (CBECS) (EIA, 2024), and the EPA’s Waste Reduction Model (WARM) (EPA, 2024).
7.1.1 Pala Band of Mission Indians
Electricity Consumption Sources
This section of the inventory includes Scope 2 emissions from electricity consumption, which are
emissions derived from electricity that is consumed within the geographical scope of this inventory but
generated elsewhere.
The Pala Reservation is served by the San Diego Gas and Electric (SDGE) utility provider which is part of
the CAMX eGrid subregion. According to the 2022 SDGE power content label, energy from this source
emits 508 lbs. CO2e per MWh generated (SDGE, 2023).
Commercial Sector Electricity Use
In the absence of Reservation-specific data for commercial electricity usage, estimates were calculated
using national averages provided by the U.S. Energy Information Administration (EIA) 2018 Commercial
Building Energy Consumption Survey (CBECS). CBECS table C21 contains average electricity use in kWh
per square foot for buildings of various sizes, uses, occupancy, climate zone, and more. The Pala
Reservation’s commercial buildings were classified by activity type and size to estimate the electricity
consumption of each. The CBECS average energy use factors do not include all building activity types, so
buildings are categorized within the activity type that matches each building the closest. The estimated
total commercial electricity use is 9,447,013 kWh, resulting in emissions of 2,177 MTCO2e (SDGE, 2023).
See Table 20 on the next page for an in-depth breakdown of the facilities electricity use estimate.
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Table 20 - Commercial Sector Facility Electricity Use Emissions Estimate
Facility
Principal Building Activity
Area
(sq ft)
Energy Use
by area
(kWh/sq ft)
Electricity
use (kWh)
MTCO2e
Pala Casino
Open continuously
259,887
20.7
5,379,660.9
1,239.6
Gas station and Minimart
Gas station with convenience
store
5,561
224.7
1,249,556.7
287.9
Casino Hotel
Lodging
52,663
13.6
716,216.8
165.0
Administration Building
Office
20,749
13.2
273,886.8
63.1
Pala Fire Station
Office
20,433
13.2
269,715.6
62.1
Pala Casino Warehouse
Warehouse and storage
38,776
5.6
217,145.6
50.0
Casino Poolside Café
Food service
4,493
44.8
201,286.4
46.4
Pala Fitness Center
Public assembly
16,246
12.1
196,576.6
45.3
Pala Mission
Public assembly
12,774
12.1
154,565.4
35.6
Vivian Banks School
Education
14,857
9.3
138,170.1
31.8
Casino Spa
Service
16,473
6.9
113,663.7
26.2
San Juan Diego Center
Religious worship
23,980
4.7
112,706.0
26.0
Pala Learning Center
Education
7,979
11.2
89,364.8
20.6
Pala Youth Center
Education
5,174
11.2
57,948.8
13.4
Pala Childcare Center
Education
3,774
11.2
42,268.8
9.7
Utilities Office
Office
3,008
11.4
34,291.2
7.9
Pala Housing Resource
Center
Education
2,792
11.2
31,270.4
7.2
Maintenance Office
Office
2,658
11.4
30,301.2
7.0
Fleet Maintenance
Warehouse and storage
5,708
5.1
29,110.8
6.7
Utilities Storage
Warehouse and storage
5,398
5.1
27,529.8
6.3
Pala Post Office
Office
1,440
11.4
16,416.0
3.8
Utilities Garage
Warehouse and storage
3,262
5.1
16,636.2
3.8
Law Enforcement Office
Office
1,351
11.4
15,401.4
3.5
Maintenance Garage
Warehouse and storage
2,874
5.1
14,657.4
3.4
KOPA Radio Station
Office
1,088
11.4
12,403.2
2.9
Maintenance Storage
Warehouse and storage
1,228
5.1
6,262.8
1.4
Total
9,447,013
2,177
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Residential Sector Electricity Use
In the absence of Reservation-specific data for residential electricity usage, the values were estimated
using national averages provided by the U.S. Energy Information Administration (EIA). The EIA reported
that, in 2020, the average household in the western United States consumed approximately 8,608 kWh
of electricity per year (EIA, 2023). The Covid-19 pandemic may have influenced this average electricity
use slightly, but the previous EIA residential energy use survey was completed in 2015, and this was
believed to be too outdated to include in this report. With 458 homes on the Reservation, this EIA
average was used to estimate a total residential electricity usage of 3,942,464 kWh annually, resulting in
emissions of 908 MTCO2e (EPA, 2010).
Stationary Point Sources
A point source is a single, identifiable source of pollution, such as a large facility that emits pollution
from a single place. Sources that are geographically numerous and difficult to keep track of (i.e., gas-
fired water heating tanks) are considered non-point sources. There are no identifiable point sources on
the Pala Reservation, so this section is intentionally left blank.
Stationary Non-Point Sources
Non-point sources are any source of pollution which is outside of the definition of point sources in the
above section. A stationary non-point source of GHGs is one that is not mobile, but too many to count
individually or keep track of easily. The sources that are estimated and included in this section are
propane heaters and water boilers, and small electricity generators.
Generator Sources
There is one generator located at the Casino and two at the Administration building in case of
emergencies such as blackouts. At the time this inventory was created there was no data available on
the fuel consumption or annual use of these generators, so they are not included in the inventory
calculations. In preparation for the Comprehensive Climate Action Plan (CCAP) emissions inventory, data
will be collected on all non-point sources such as generators.
Commercial Sector Propane Use
Within the Pala Reservation, all facilities use propane gas for cooking and heating. PED conducted an
emissions inventory (EI) in 2011 which provides facility propane use data for 2010. Since then, new
facilities have been established, and the CBECS estimation was used to generate estimates of their
annual propane consumption. Facilities propane use emissions included in the Pala Reservation 2011
emissions inventory were within an acceptable range of the CBECS estimation for the same buildings, so
the original values were included in this inventory for completeness. The buildings included in the 2011
EI are the administration building, fitness center, day care, boys and girls club, fire station, utilities,
cultural center, law office, and mini mart. The propane use of these buildings totaled 24,245 gallons of
propane amounting to emissions of 139.23 MTCO2e (EPA, 2010).
For the remaining commercial buildings that were not included in the above-mentioned 2011 EI, the
CBECS estimation method was used to generate estimates. Emissions from these buildings totaled 2,331
MTCO2e (EPA, 2023), and the calculations are outlined in the below table.
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Table 21 – Pala Reservation Commercial Building Estimated Emissions from Propane Use
Facility
Principal
Building
Activity
Area
(sq ft)
Energy
Intensity by
area (Mbtu/sq
ft)
Energy
Intensity
(MMBtu)
Propane
Usage
(mcf/yr)
MTCO2e
Pala Casino
Open
continuously
259,887
104.3
27,106.2
10,773.5
1,672.8
Casino Hotel
Lodging
52,663
85.7
4,513.2
1,793.8
278.5
Missions
Public
Assembly
12,774
81.1
1,036.0
411.8
63.9
Vivian Banks
School
Education
14,857
62.7
931.5
370.2
57.5
San Juan Diego
Center
Religious
worship
23,980
35.3
846.5
336.4
52.2
Casino Spa
Service
16,473
50.9
838.5
333.3
51.8
Gas Station
Other
5,561
134.8
749.6
297.9
46.3
Pala Learning
Center
Education
7,979
62.7
500.3
198.8
30.9
Pala Tribal
Services
Public
Assembly
4,595
81.1
372.7
148.1
23.0
Casino Poolside
Café
Food service
4,493
64.1
288.0
114.5
17.8
Pala Housing
Resource
Center
Public
Assembly
2,792
81.1
226.4
90.0
14.0
Maintenance
Office
Office
2,658
65.5
174.1
69.2
10.7
Pala Post Office
Public
Assembly
1,440
81.1
116.8
46.4
7.2
KOPA Radio
Station
Office
1,088
65.6
71.4
28.4
4.4
Total
37,771
15,012
2,331
Residential Sector LPG use
All residences located within the boundaries of the Pala Reservation use liquified petroleum gas (LPG)
for heating and cooking. A survey conducted by PED in 2011 found that an average of 336.5 gallons of
LPG is used per household per year (Jones, 2012). There are 458 households currently located on the
Pala Reservation. Using this average from the residential LPG use survey, it is estimated that a total of
154,117 gallons of LPG is consumed per year for all residences within the Reservation boundaries. This
fuel consumption would result in emissions of 923 MTCO2e per year (EPA, 2010).
Solid Waste Generation Sources
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The emissions associated with solid waste generation on the Pala Reservation are known as Scope 3
emissions. Scope 3 emissions can be described as “downstream” emissions, where the activity from one
region subsequently causes emissions in another region. This is the case with Pala’s solid waste
generation as there is no landfill located within the Reservation boundaries. The Pala Reservation’s
contribution to methane emissions associated with decomposing waste material is estimated below.
The Pala Reservation has a solid waste transfer station within its boundaries, where garbage is
compacted and reloaded into larger vehicles. At the time this inventory was created, there was no data
available from the solid waste transfer station. It is anticipated that due to the longer timeline available
for creating the CCAP emissions inventory, it will be possible to obtain Reservation-specific solid waste
generation data from the Pala Transfer Station.
In the absence of Reservation-specific solid waste generation data, the CalRecycle Estimated Solid Waste
Generation Rates were used to generate an estimate of residential and commercially generated solid
waste.
Table 22 – Pala Reservation Solid Waste Generation Estimates for Residential and Commercial Sectors
Sector
Units
Waste Generation Rate
Waste Generated
(short tons)
MTCO2e
Commercial
487,883 sq ft
13 lbs/1000 sq ft/day
1,158
358
Residential
458 households
12.23 lbs/household/day
1,022
316
Total
2,180
674
Residential Sector Solid Waste Generation
The CalRecycle Estimated Solid Waste Generation Rates webpage cites that an average of 12.23 pounds
of solid waste is generated per household per day (CalRecycle, 2024). This is equivalent to 4,463 pounds
per household per year. There are 458 households on the Pala Reservation, which means that there is
an estimated 1,022 short tons of solid waste generated by the Pala Reservation residents annually. The
resulting emissions associated with the decomposition of this amount of solid waste is 316 MTCO2e
(EPA, 2024).
Commercial Sector Solid Waste Generation
The CalRecycle Estimated Solid Waste Generation Rates webpage cites that an average of 13 pounds of
solid waste is generated per 1,000 square feet of commercial space per day. This is equivalent to 4.745
pounds per square foot per year (CalRecycle, 2024). A list of commercial and institutional buildings on
the Pala Reservation was created, omitting buildings that typically would not generate waste such as
pump houses, warehouses, storage, wastewater facilities, and parking lots. The total indoor area of all of
these buildings combined was 487,883 square feet. Using the estimation factor listed above, the total
estimated annual waste generated was 1,157.5 short tons. The resulting emissions associated with the
decomposition of this amount of solid waste is 358 MTCO2e (EPA, 2024).
On-Road Mobile Sources
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On-road mobile emissions include any sources that are within the transportation sector that originate
from paved roadways. A comprehensive inventory of all Pala Reservation roads was previously
conducted by the PED, capturing data on road surface type, average daily traffic, length, and total VMT.
Annual emissions from on-Reservation mobile sources were calculated using the total VMT obtained
from this road inventory and the estimated average vehicle miles per gallon of fuel from the Tribal
Greenhouse Gas Inventory Tool (TGIT) provided by the EPA. With an estimated annual VMT of 7,046,453
miles (Jones, 2012) and an average fuel efficiency of 24.1 mpg (EPA, 2010), a total of 292,384 gallons of
gasoline were projected to have led to emissions totaling 2,567 MTCO2e in 2022. Emissions from this
source are from both the commercial and residential sectors, so it is categorized in the “mixed” sector.
Non-Road Mobile Sources
Non-road mobile sources of emissions include any source that is not stationary and does not travel on
paved roadways. These emissions are also frequently known as “off-road mobile” sources. The sources
on the Pala Reservation that fit in this category include the Fox Raceway and lawn and garden
equipment.
Fox Raceway Motocross Track
A mileage study in 2012 of the Fox Motocross Racetrack shows an estimated 135,213 miles travelled per
year. The EPA’s emissions factors for 2-stroke gas recreational equipment are 7.81 g CH4 and 0.03 g N20
per gallon for 2 stroke vehicles. For four stroke vehicles, the estimate is 8.45 g CH4 and 0.19 g N2O per
gallon (EPA, 2023). By researching equipment specifications of popular dirt bikes and their fuel economy
while on the racetrack, an average of 30 mpg was estimated. Combining this average mpg with the total
vehicle miles travelled from the mileage study yields a total of 4,507.1 gallons of gasoline consumed per
year at the racetrack. This fuel consumption would result in emissions of 41.72 MTCO2E per year (EPA,
2010). With the longer timeline to complete the CCAP comprehensive emissions inventory, it may be
possible to obtain an updated mileage study from the Fox Raceway to represent emissions more
accurately.
Lawn and Garden Equipment
The 2011 Pala Reservation Emissions Inventory used data which tracked the commercial use of lawn and
garden equipment. According to this source, the emissions resulting from lawn and garden equipment
use is 2.2 MTCO2e per year. In preparation for completing the comprehensive emissions inventory for
the CCAP, it may be possible to obtain additional more recent data pertaining to the use of lawn and
garden equipment in both the commercial and residential sectors.
Agriculture & Land Management
The Pala Reservation owns several large grapefruit and avocado orchards. At the time this inventory was
created, there was no data available on fertilizer use within these agricultural industries. In improving
this inventory for the CCAP, data will be collected that will allow for an estimate of nitrous oxide
emissions from fertilizer application.
Water
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The Pala Reservation does not import any water. At the time that this baseline inventory was created,
there was no data available on energy used for water pumping. For the CCAP emissions inventory, it
may be possible to collect data to represent water pumping related emissions more accurately.
Wastewater
The Pala Reservation operates a wastewater treatment plant (WWTP) which utilizes a pump station,
sludge removal tank, sedimentation tank, aeration tank, and disinfection tank. The WWTP serves the
entirety of the Reservation. Using the framework that the TGIT employs to estimate wastewater related
GHG emissions, the emissions were estimated to be 12.59 MTCO2E annually (EPA, 2010).
7.1.2 Jamul Indian Village of California
Electricity Consumption Sources
The Reservation is served by the San Diego Gas and Electric (SDGE) utility provider which is part of the
CAMX eGrid subregion. According to the 2022 SDGE power content label, energy from this source emits
508 lbs. CO2e per MWh generated (SDGE, 2023).
Commercial Sector Electricity Use
The VP of Non-Gaming at Jamul Casino supplied a record from recent years that cites an average,
continuous power usage of 1.1 MW for the Reservation. In addition, two diesel generators are used to
generate additional electricity during peak hours when the power delivered by SDGE is not enough to
supply casino energy needs. The emissions associated with these diesel generators are discussed in the
non-point sources section.
The continuous use of 1.1 MW amounts to a total annual energy usage of 9,636,000 kWh. The
generation of this amount of electricity by SDGE power sources results in 2,220 MTCO2e per year (SDGE,
2023).
Stationary Point Sources
There are no identifiable point sources on the Reservation, so this section is intentionally left blank.
Stationary Non-Point Sources
Generator Sources
There are two diesel 2,000 kW rated generators on the Reservation. There was no specific data available
on the capacity that these generators operate at, or the total fuel consumed. In preparation of the CCAP
emissions inventory, it may be possible to obtain specific data on fuel consumption of these generators.
The number of hours the generators were operated during 2022 was obtained from the VP of Non-
Gaming at Jamul Casino: one of the generators ran for 882.7 hours while the other ran for 833.6 hours,
totaling 1,716.3 hours. In order to use the annual hours of operation data to estimate emissions from
these generators, it is assumed that they were operating at an average of 75% load capacity. For
generators of this power rating operating at 75% capacity, an estimated 103.5 gallons of diesel is
consumed per hour (Generator Source, LLC, 2024). Using the total hours of operation and the hourly
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fuel consumption rate, it was estimated that these generators consumed 177,637 gallons of diesel in
2022. This would result in emissions of 1,820 MTCO2E per year (EPA, 2010).
Commercial Sector Propane Use
The Tribe relies on propane gas for all kitchens, heating, and seven water boilers. In the absence of
Reservation-specific propane consumption data, the United States Energy Information Administration’s
2018 Commercial Buildings Energy Consumption Survey (CBECS) was utilized. CBECS table C11 contains
national average fuel consumption per square foot data for buildings of different principal activity types
(EIA, 2024). The propane facilities calculation for buildings located on the Reservation is displayed below
in Table 1. It is estimated that Reservation facilities uses about 134,676 gallons of propane gas per year,
resulting in emissions of 774 MTCO2E per year (EPA, 2023).
Table 23 – JIVoC Facility Propane Use Estimate
Facility
Principal
Building
Activity
Area (sq
ft)
Energy Intensity by
Area (Mbtu/sq ft)
Energy
Intensity
(MMBtu)
Propane
Usage
(gal/yr)
MTCO2e
Casino
Open
continuously
112,640
104.3
11,748.4
129,102.8
741.6
Administrative
Office
Office
2,660
65.6
174.5
1,917.5
11.0
Chapel
Religious
worship
1,910
35.3
67.4
740.9
4.3
Community
Center
Public
assembly
3,270
81.1
265.2
2,914.3
16.7
Total
12,255.5
134,675.5
773.6
Solid Waste Generation Sources
The emissions associated with solid waste generation on the Reservation are known as Scope 3
emissions. Scope 3 emissions can be described as “downstream” emissions, where the activity from one
region subsequently causes emissions in another region. This is the case with JIVoC’s solid waste
generation, as there is no landfill located within the Reservation boundaries.
The Vice President of Non-Gaming at Jamul Casino indicated that, according to Jamul Casino records, an
average of 208 tons of solid waste is generated by the Reservation per year. The resulting scope 3
emissions associated with the decomposition of this amount of solid waste is 64.3 MTCO2e (EPA, 2024).
On-Road Mobile Sources
JIVoC Reservation has a one-way road that surrounds the casino which is about 0.4 miles long. According
to the Vice President of Non-Gaming at Jamul Casino, there are an estimated 2,000 cars that travel the
entire length of that road each day. This adds up to a total of 292,000 miles driven per year. Using an
average fuel efficiency of 24.1 (EPA, 2010), it is estimated that 12,116 gallons of gasoline are consumed
annually on the Reservation, which would result in emissions of 106.38 MTCO2e (EPA, 2010). With the
longer timeline anticipated to complete the comprehensive emissions inventory for the CCAP, it may be
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possible to obtain more accurate roadway travel data for the Reservation. This may include sampling
delivery truck idling, other vehicle types present, and specific VMT data.
Water
The Reservation does not use any local water sources; all of the water needs on the Reservation are met
by importing water from Otay Reservoir. With the longer timeline anticipated to complete the
comprehensive emissions inventory for the CCAP, it may be possible to obtain specific water importing
data for the JIVoC Reservation.
Wastewater
The Jamul Casino operates a wastewater treatment plant (WWTP) which is a tertiary facility that utilizes
a combination of sub-surface disposal and trucking disposal. The WWTP serves about 5,550 people, and
treats wastewater physically, biochemically, and chemically using screens, aeration basins, membrane
bioreactors, reverse osmosis, ozone, UV, and sodium hypochlorite disinfectant systems, and an
anaerobic digester (Jamul Indian Village of California, 2017). Currently, only the method of trucking for
the disposal of wastewater is utilized to dispose of treated wastewater (Acorn Environmental, 2022).
Using the framework that the TGIT employs to estimate wastewater related GHG emissions, the
emissions were estimated to be 46.9 MTCO2E annually.
Carbon Sinks
Urban Forestry
The urban forestry section of this report details the carbon absorbed from the atmosphere by organic
material. This estimate of carbon sequestration follows the estimation framework of the TGIT, which is
based on the percent of urban canopy present at the Reservation.
The Environmental Director of Jamul Indian Village of California indicated that the urban area of the
Reservation is about one-half acre, which contains about 75% tree cover. The Jamul Casino also utilizes
green roof technology to sequester runoff, which also sequesters a minor amount of carbon. Using the
framework set up in the TGIT, the reduction in net emissions due to this urban forestry is estimated to
be (-)1.24 MTCO2e (EPA, 2010).
7.1.3 Viejas Band of Kumeyaay Indians
Electricity Sources
The electricity sector primarily relies on San Diego Gas and Electric (SDGE) within the CAMX eGRID
subregion. Some facilities are powered in part by solar photovoltaic (PV) panels, but SDGE provides a
vast majority of electric power to the Viejas Reservation. The combined electricity generating sources of
the SDGE grid emit 508 lbs CO2e per MWh of electricity generated (SDGE, 2024). This section of the
inventory includes Scope 2 emissions from electricity consumption, which are emissions derived from
electricity that is consumed within the Reservation but generated elsewhere.
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Commercial Sector
The commercial sector on Viejas Reservation includes commercial, administrative, and critical facilities
such as the recreation center, the Viejas Tribal Council building (administrative), the Viejas Fire
Department, and businesses such as the Viejas Casino & Resort, Willows Hotel and Spa, and Viejas
Outlet Center. In the absence of Reservation-specific data for commercial electricity usage, the value
was estimated using national averages of 2018, provided by the U.S. Energy Information Administration
(EIA). Estimates of electricity energy intensity in kWh/sq ft was reported by principal building activity to
estimate annual electricity usage of these facilities (EIA, 2024). The cumulative annual electricity
consumption for the commercial sector amounted to 14,514,302 kWh, resulting in emissions of 3,345
MTCO2e (Table 24) (EPA, 2010; SDGE, 2024).
Table 24 – Viejas Reservation Commercial Sector Electricity Usage and Associated Emissions
Facility
Principal Building
Activity
Area
(sq ft)
Electricity Use
(kWh/sq ft)
Annual Usage
(kWh)
MTCO2e
Fire Department
Public Order and
Safety
2,828
14.2
40,158
9.3
Recreation Center
Public Assembly
28,004
12.1
338,848
78.1
Tribal Council
Office
11,688
13.2
154,282
35.6
Viejas Casino &
Resort
Open
Continuously
366,037
20.7
7,576,966
1,745.9
Willows Hotel and
Spa
Lodging
257,369
13.6
3,500,218
806.5
Viejas Outlet
Center (all
buildings)
Mercantile Retail
278,648
21.0
5,851,608
1,348.4
Total
17,462,080
4,023.7
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Residential Sector
In the absence of Reservation-specific data for residential electricity usage, the value was estimated
using national averages provided by the U.S. EIA. The EIA reported that, in 2020, the average household
in the western United States consumed approximately 8,608 kWh of electricity per year (EIA, 2023).
While the COVID-19 pandemic may have had a marginal impact on average electricity consumption,
there do not appear to be significant differences when comparing data trends from 2010 to 2020. With
200 homes currently residing on the Reservation, this EIA average was used to estimate a total
residential electricity usage of 1,721,600 kWh annually, resulting in emissions of 397 MTCO2 (EPA, 2010;
SDGE, 2024)
Stationary Point Sources
No point sources have been identified on Viejas Reservation.
Stationary Non-Point Sources
Generators
Generators are used within the residential sector of the Reservation. There are a total of 200 Kohler 48
kW Emergency Standby Power Generators available for use on the Reservation. However, only about 40
of them are currently connected and used intermittently, functioning solely as emergency backups. As a
result, data on individual generator fuel consumption and operating hours are unavailable, making it
impossible to estimate GHG emissions from residential generator use at this time.
Residential Propane Use
All homes on the Reservation are reported to use propane for heating and cooking. The EPA’s household
carbon footprint calculator (EPA, 2024) assumes that the average household consumes 39 gallons of
propane per month. For the 200 homes and 500 residents on the Viejas Reservation, the annual use of
propane is estimated to be 93,600 gallons, for a total energy use of 8,518 MMBtu and resulting in
emissions of 538 MTCO2e annually (EPA, 2010).
Commercial Propane Use
The commercial and institutional facilities on Viejas Reservation (excluding Viejas Casino & Resort, Viejas
Outlet Center, and Willows Hotel and Spa) use propane for heating and cooking. EIA published data
concerning fuel consumption in 2022 for commercial buildings categorized by building use type (EIA,
2024). In the absence of propane usage data, the relevant values for gross energy intensity per square
foot were selected for the Recreation Center, Fire Department, and Tribal Council building, and used to
estimate their respective annual propane usage in gallons (Table 25). Using an average heat content of
0.091 MMBtu per gallon for propane gas, it was estimated that 38,028 gallons were used in commercial
and institutional facilities, resulting in emissions of 219 MTCO2e (Table 25) (EPA, 2010) .
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Table 25 – Viejas Reservation Commercial Sector Propane Usage and Associated Emissions
Facility
Principal
Building
Activity
Area
(sq ft)
Energy
Intensity by
area
(MBtu/sq ft)
Energy
Intensity
(MMBtu)
Propane
Usage
(gal/yr)
MTCO2e
Recreation
Center
Public
Assembly
28,004
89.5
2,506.4
27,406
157.6
Fire
Department
Public Order
and Safety
2,828
76.1
215.2
2,353
13.5
Tribal Council
Office
11,688
64.7
756.2
8,269
47.6
Total
3,477.8
38,028
218.72
Commercial Natural Gas Use
Among the commercial facilities within the Reservation, only Viejas Casino & Resort, Viejas Outlet
Center, and Willows Hotel and Spa are connected to a natural gas line. In the absence of natural gas
usage data for these facilities, the value was estimated using national averages of 2022 reported by the
EIA for commercial buildings categorized by building use type (EIA, 2024). The relevant values for gross
energy intensity per square foot were selected for the facilities and used to estimate their respective
annual natural gas usage in thousand cubic feet (mcf) (Table 26). In total, it was estimated that with
1.037 MMBtu generated per thousand cubic feet, 75,309 mcf were used in commercial and institutional
facilities, resulting in emissions of 4,144 MTCO2e (Table 26) (EPA, 2010).
Table 26 – Viejas Reservation Commercial Sector Natural Gas Usage and Associated Emissions
Facility
Principal
Building Activity
Area
(sq ft)
Energy
Intensity by
area
(MBtu/sq ft)
Energy
Intensity
(MMBtu)
Natural Gas
Usage
(mcf/yr)
MTCO2e
Viejas
Casino &
Resort
Open
Continuously
366,037
104.3
38,177.7
36,815.5
2025.8
Willows
Hotel & Spa
Lodging
257,369
85.7
22,056.5
21,269.6
1170.4
Viejas
Outlet
Center
Mercantile
Retail
278,648
64.1
17,861.3
17,224.1
947.8
Total
78,095.5
75,309.1
4,144.0
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Solid Waste Generation
The emissions associated with solid waste generation on the Viejas Reservation are known as Scope 3
emissions. Scope 3 emissions can be described as “downstream” emissions, where the activity from one
region subsequently causes emissions in another region, as is the case with solid waste generation on
Viejas Reservation. There is no landfill located within the Reservation boundaries, and waste is hauled to
Miramar landfill by Republic Services. Viejas Reservation’s contribution to methane emissions associated
with decomposing waste material at these locations is accounted for in this section.
In the absence of solid waste hauling data, GHG emissions from residential and commercial landfill
waste were estimated using CalRecycle’s daily waste generation averages for major waste sources
(CalRecycle, 2024) and the Waste Reduction Model (WARM) Tool provided by the EPA (EPA, 2024). The
commercial sector generated 2,140 short tons of waste, resulting in 662 MTCO2e. The residential sector
generated 446 short tons, resulting in 138 MTCO2e. In total, 2,587 short tons of waste were generated
on the Reservation, resulting in 800 MTCO2e of Scope 3 emissions (Table 27).
Table 27 – Viejas Reservation Waste Generation and Associated Emissions
Sector/Facility
Units
Waste Generation Rate
Waste Generated
(short tons)
MTCO2e
Commercial
902,054 sq ft
13lbs/1000 sq ft/day
2,140
661.74
Residential
200 households
12.23lbs/
household/day
446
138.04
Total
2,587
799.78
On-Road Mobile Sources
This section includes a summary of mobile sources of GHG emissions from residential use and from the
Tribal fleet.
Residential Mobile
At the time this inventory was constructed, there was no data available on vehicles or vehicle miles
travelled by residents. To address these data gaps, estimates from the National Emissions Inventory for
San Diego County for passenger light-duty vehicles (EPA, 2024) were scaled to calculate per capita
emissions and to obtain metrics for the population of Viejas Reservation. The approximate GHG
emissions from residential mobile sources was determined to be 1,126 MTCO2e.
Tribal Fleet On-Road Mobile
The Viejas Tribal Government Public Works Department provided information concerning the Tribal
fleet vehicles and their annual usage. This fleet is comprised of 25 light-duty trucks, each traveling
approximately 2,000 miles per year, for a total of 50,000 miles annually. With an average mileage of
18.5 miles per gallon, the Tribal fleet consumes 2,703 gallons of gasoline annually, resulting in emissions
of 25 MTCO2e (EPA, 2010).
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Non-Road Mobile Sources
No non-road mobile sources of GHG emissions have been identified at this time on the Viejas
Reservation.
Agriculture & Land Management Sources
Agricultural and land management sources of GHG emissions have not been identified at this time on
the Viejas Reservation.
Water
Viejas Reservation does not import any water. There are no known Scope 2 emissions associated with
water usage including for electricity use or other emissions associated with providing water to the
Reservation.
Wastewater
Since July 2000, the Viejas Wastewater Treatment Plant (WWTP) has employed immersed ultrafiltration
membranes that adhere to strict California Department of Health Services guidelines and California
Code and Regulations. It uses an immersed ultrafiltration membrane bioreactor which significantly
expands treatment capacity and enhances plant performance with nutrient removal. This plant meets
California’s stringent standards for recycled water by producing effluent with turbidities that are
approximately one-tenth the allowed limit. Nitrogen concentration tends to fall between 5 and 10 parts
per million. The WWTP serves the Reservation by aerobically treating wastewater with
nitrification/denitrification processes. For 500 residents, it is estimated that 4 MTCO2e is emitted
annually by wastewater treatment (EPA, 2010).
7.1.4 La Posta Band of Mission Indians
Electricity Sources
The electricity sector relies on San Diego Gas and Electric (SDGE) within the CAMX eGRID subregion to
provides electric power to the whole Reservation. The combined electricity generating sources of the
SDGE grid emit 508 lbs CO2e per MWh of electricity generated (SDGE, 2024). This section of the
inventory includes Scope 2 emissions from electricity consumption, which are emissions derived from
electricity that is consumed within the geographical scope of this inventory but generated elsewhere.
Commercial Sector
There are six buildings operated by the La Posta Tribe that make up the commercial sector. These are
the Tribal Administrative Building, the air monitoring station, the drinking water facility, the boys and
girls club, Substance Abuse Center, and the old casino that is no longer in operation. The old casino is
currently vacant and does not purchase or use any electricity. In 2022, the Tribal Administrative Building
purchased 44,642 kWh and the air monitoring station purchased 45,305 kWh. No Reservation-specific
data concerning electricity purchased for the drinking water facility, the Substance Abuse Center, and
the boys and girls club were available. Electricity use for these buildings was estimated using national
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averages for 2022, provided by the U.S. Energy Information Administration (EIA). Estimates of electricity
energy intensity in kWh/sq ft was reported by principal building activity to estimate annual electricity
usage of these facilities (EIA, 2024). The cumulative annual electricity consumption for the commercial
sector amounted to 268,479 kWh, resulting in emissions of 61.86 MTCO2e (Table 24) (EPA, 2010; SDGE,
2024).
Table 28 – La Posta Reservation Commercial Sector Electricity Usage and Associated Emissions
Facility
Principal Building
Activity
Area
(sq ft)
Electricity Use
(kWh/sq ft)
Annual Usage
(kWh)
MTCO2e
Actual
Air Monitoring
Station
-
-
-
44,642
10.29
Tribal
Administrative
Building
-
14,386
-
45,305
10.44
Estimated
Boys and Girls Club
Public Assembly
7,265
10.4
75,556
17.41
Drinking Water
Facility
Other
1680
9.5
15,960
3.68
Substance Abuse
Center
Outpatient Health
Care
5,840
14.9
87,016
20.05
Total
268,479
61.86
Residential Sector
In the absence of Reservation-specific data for residential electricity usage, the value was estimated
using national averages provided by the U.S. Energy Information Administration (EIA). The EIA reported
that, in 2020, the average household in the western United States consumed approximately 8,608 kWh
of electricity per year (EIA, 2023). While the COVID-19 pandemic may have had a marginal impact on
average electricity consumption, there do not appear to be any significant differences when comparing
data trends from 2010 to 2020. With 13 homes currently residing on the Reservation, this EIA average
was used to estimate a total residential electricity usage of 111,904 kWh consumed in 2020, resulting in
emissions of 26.2 MTCO2e (EPA, 2010; SDGE, 2024) .
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Stationary Point Sources
No point sources have been identified on La Posta Reservation.
Stationary Non-Point Sources
Residential Propane Use
All homes on the Reservation are reported to use propane for heating and cooking. The EPA’s household
carbon footprint calculator (EPA, 2024) assumes that the average household consumes 39 gallons of
propane per month. For the 13 homes on the La Posta Reservation, the annual use of propane is
estimated to be 6,084 gallons, for a total energy use of 554 MMBtu and resulting in emissions of 35
MTCO2e annually (EPA, 2010).
Commercial Propane Use
The commercial and institutional facilities that serve La Posta Reservation use propane for heating and
various purposes. EIA published data concerning fuel consumption in 2022 for commercial buildings
categorized by building use type (EIA, 2024). In the absence of propane usage data, the relevant values
for gross energy intensity per square foot were selected for the Tribal administrative building, boys and
girls club, and the Substance Abuse Center, and used to estimate their respective annual propane usage
in gallons. In total, it was estimated that with 0.091 MMBtu generated per gallon of propane, 22,636
were used in commercial and institutional facilities, resulting in emissions of 130 MTCO2e (Table 25)
(EPA, 2010) .
Table 29 – La Posta Reservation Commercial Sector Propane Usage and Associated Emissions
Facility
Principal
Building
Activity
Area
(sq ft)
Energy
Intensity by
area
(MBtu/sq ft)
Energy
Intensity
(MMBtu)
Propane
Usage
(gal/yr)
MTCO2e
Boys and Girls
Club
Public
Assembly
7,265
89.5
650.22
7,145
41.03
Substance
Abuse Center
Outpatient
Health Care
5,840
82.0
478.88
5,262
30.23
Tribal
Administrative
Building
Office
14,386
64.7
930.77
10,228
58.75
Total
2,059.87
22,636
130.01
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Solid Waste Generation
The emissions associated with solid waste generation on the La Posta Reservation are known as Scope 3
emissions. Scope 3 emissions can be described as “downstream” emissions, where the activity from one
region subsequently causes emissions in another region, as is the case with solid waste generation on La
Posta Reservation. There is no landfill located within the Reservation boundaries, and waste is hauled by
EDCO Waste and Recycling Services. La Posta Reservation’s contribution to methane emissions
associated with decomposing waste material at these locations is accounted for in this section.
In 2022, La Posta Reservation saw the disposal of 14.4 short tons of solid waste into landfills. GHG
emissions from residential and commercial landfill waste were estimated using the Waste Reduction
Model (WARM) Tool provided by the EPA (EPA, 2024). It is estimated that, in total, 4.77 MTCO2e was
emitted from the hauled solid waste. Of this, the commercial sector, consisting of 5 buildings,
contributed 28% of emissions for 1.34 MTCO2e and the residential sector, consisting of 13 buildings,
contributed to 72% of emissions for 3.43 MTCO2e.
On-Road Mobile Sources
Residential Mobile
At the time this inventory was constructed, no specific data regarding the number of vehicles and
vehicle miles traveled by residents on the Reservation were available. According to information
provided by the La Posta Environmental Department, ten residents commute to work daily by car, with
half using passenger vehicles and the other half using light duty trucks. The total road network within
the Reservation spans 13.65 miles in length. To estimate vehicle miles traveled, fuel consumption, and
GHG emissions on the Reservation, passenger vehicles were estimated to have an average fuel efficiency
of 24.1 mpg, while light duty trucks achieve 18.5 mpg (EPA, 2010). Each commuter was assumed to
travel the total span of roads on the Reservation in both directions of their daily two-way commute. For
each vehicle type, 49,822.5 miles were estimated to be traveled annually, resulting in a total fuel
consumption of 4,760.3 gallons and emissions of 41.8 MTCO2e (EPA, 2010).
Non-Road Mobile Sources
No non-road mobile sources of GHG emissions have been identified at this time on the La Posta
Reservation.
Agriculture & Land Management Sources
Agricultural and land management sources of GHG emissions have not been identified at this time on
the La Posta Reservation.
Water
La Posta Reservation does not import any water. There are no known Scope 2 emissions associated with
water usage including for electricity use or other emissions associated with providing water to the
Reservation.
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Wastewater
All households on La Posta Reservation are served by septic tanks to manage wastewater. Using the
TGIT framework for wastewater emissions, it is estimated that septic systems generate 11.6 MTCO2e
annually (EPA, 2010).
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7.2
Priority Reduction Measures Methodology
7.2.1 Pala Band of Mission Indians
Tribal EV Adoption Program
The estimated annual VMT for the Pala Reservation is 7,046,453 miles which the TGIT estimates to emit
2,567 MTCO2e (EPA, 2010). The Tribe has a goal of achieving 30% EV adoption through the
implementation of this measure, which would ideally reduce these emissions by 30%. Assuming 30%
adoption of EVs by the Tribal community, the estimated emissions reduction is 770 MTCO2e per year if
the measure is successful.
EV Charging Station Installation
Emissions reductions achieved by installing EV charging stations were quantified by utilizing miles
charged per year. Assuming each charger is used 12 hours per day, the chargers combined would
theoretically be able to provide electricity for 10,512,000 miles per year. Using the current average fuel
efficiency of 24.1 miles per gallon for passenger gasoline-powered vehicles (EPA, 2010), the Reservation
could see an annual reduction in emissions of 3,718 MTCO2e.
Energy Audits & Retrofits
The Tribe aims to enhance energy efficiency of the residential sector through the replacement of
liquefied petroleum gas (LPG) heaters on the Reservation. The emissions inventory estimates that the
residential sector uses a total of 154,117 gallons of LPG per year, resulting in emissions of 923 MTCO2e
per year (EPA, 2010). The goal of this measure is to install heat pumps, electric stoves, and tankless
water heaters in 50 Tribal homes to move away from LPG use. Heat pumps increase energy efficiency in
the home by 65% (U.S. Department of Energy, 2024). Under the assumption that, nationally, 52% of
electricity used in homes is devoted to heating and cooling (EIA, 2023) the installation of heat pumps
alone would reduce emissions by 329 MTCO2e. Furthermore, by assuming that 50 home’s worth of LPG-
related emissions would be eliminated, the installation of these retrofits would reduce GHG emissions
by up to 430 MTCO2e in total.
Community Compost Program
This measure aims to reduce the amount of compostable waste that is sent to the landfill by the Tribe.
Using a 2012-13 City of San Diego Waste Characterization Study, it was found that 37% of potentially
compostable waste was landfilled (City of San Diego, 2014). On the Pala Reservation, an estimated 2,180
tons of solid waste is generated per year (Section 3.1). Using the average proportion of food scraps from
solid waste generation in San Diego County (37%), it is estimated that the Reservation sends 806.6 tons
of compostable food waste to the landfill per year. Composting this amount of food waste instead of
landfilling it would reduce annual emissions by 495 MTCO2e (EPA, 2024).
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7.2.2 Jamul Indian Village of California
EV Charging Station Installation
Emissions reductions achieved by installing EV charging stations were quantified by utilizing miles
charged per year. Assuming each charger is used 12 hours per day, the chargers combined would
theoretically be able to charge 65,700 miles per year. Using the current average fuel efficiency of 24.1
miles per gallon for passenger gasoline-powered vehicles (EPA, 2010), the Reservation could see an
annual reduction in emissions of 232 MTCO2e.
Jamul Casino Microgrid
This measure aims to deploy a microgrid for the Jamul Casino. This deployment involves installing solar
panels on the roof of the Casino and on a 4-acre parcel of land. Given an annual average POA irradiance
of approximately 214 kWh per square feet per year (NREL, 2024) and assuming 20% of solar panel
efficiency (Enel X, 2024), solar panels installed on the Casino roof would generate approximately 4,819
MWh of electricity per year. Assuming 80% of the 4-acre land parcel is dedicated to solar panels, this
area would produce approximately 5,963 MWh of electricity per year. With these two sources powering
the Casino instead of traditional grid electricity, the Tribe stands to reduce emissions by approximately
2,485 MTCO2e per year.
7.2.3 Viejas Band of Kumeyaay Indians
Energy Audits & Retrofits
The Tribe aims to enhance energy efficiency of the residential sector through energy audits and retrofits.
As many as 200 Tribal homes would be retrofitted with triple-pane windows on the Reservation. The
residential electricity use for the 200 homes on the Viejas Reservation was estimated to use 1,721,600
kWh per year (Section 7.1.3). According to the EPA’s Carbon Footprint Calculator, 14% of electricity use
comes from air conditioning use, on average (EPA, 2024). Using this average, it was estimated that about
241,024 kWh is used for air conditioning on the Reservation, resulting in emissions of 55.58 MTCO2e.
The Tribal homes rely on propane for space heating. The residential propane use on the Reservation was
estimated to be 93,600 gallons per year, amounting to emissions of 538 MTCO2e (Section 7.1.3). The
average percentage of propane used for home heating is 70% (EPA, 2024), indicating that an estimated
376.6 MTCO2e is generated by home heating in the Reservation. In total, emissions associated with
heating and cooling homes on the Viejas Reservation are 432 MTCO2e. Installing triple-pane windows
can improve HVAC-related energy performance by 40% or more (U.S. Department of Energy, 2024).
Assuming 200 homes are retrofitted with triple-pane windows, this measure would reduce the
emissions related to home heating and cooling by an estimated 173 MTCO2e per year.
Solarize Tribal Homes
This reduction measure was quantified by calculating the number of solar panels necessary to offset all
emissions related to residential electricity use. Given an annual average plane of array (POA) irradiance
of 215 kWh per square foot per year (NREL, 2024) and a solar conversion efficiency of 20% (Enel X,
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2024), it is estimated that twelve (12) solar panels, each covering 17.5 sq ft, would suffice to meet the
sector’s energy needs. The solarization of Tribal homes would reduce emissions by up to 397 MTCO2e
annually. If sufficient battery storage capacity and net metering were to be incorporated, the installation
of additional solar panels would generate supplemental energy. The surplus could be sold to SDG&E to
further reduce Scope 2 emissions linked to off-Reservation electricity generation.
Establish a Recycling Program
The City of San Diego Waste Characterization Study found that approximately 33% of solid waste was
recoverable in the residential sector and 37% was recoverable in the commercial sector (City of San
Diego, 2014). The total estimated solid waste from Viejas Reservation is 661.7 tons for the commercial
sector and 138 tons for the residential sector. With active engagement, the program can diminish the
amount of waste sent to landfills by up to 147 and 792 short tons, for the residential and commercial
sector, respectively. In total, 939 short tons of recyclables may be diverted, resulting in emissions
reductions of 290 MTCO2e annually (EPA, 2024).
Fleet Electrification
The Viejas Tribal fleet is currently made up of 25 light-duty gasoline-powered trucks. This reduction
measure plans to replace 20 of the vehicles from the existing fleet with all-electric vehicles (EVs). Each of
these vehicles typically travels 2,000 miles annually. The TGIT estimates that each vehicle emits 1
MTCO2e annually (EPA, 2010). In total, the replacement of 20 Tribal fleet vehicles would result in
emissions reductions of 20 MTCO2e.
7.2.4 La Posta Band of Mission Indians
Implement Erosion Controls & Acquire Land for Wetland Restoration
Assuming freshwater wetland carbon sequestration is approximately 1.43 tons per acre per year (Lal, et
al., 2018), the area on the Reservation that would be restored (approximately 127.41 acres) has the
potential to sequester 165 MTCO2e per year.
Solarize Tribal Homes & Facilities
This reduction measure was quantified by calculating the number of solar panels necessary to offset all
emissions related to residential and commercial electricity use. Given an annual average plane of array
(POA) irradiance of approximately 214 kWh per square feet per year (NREL, 2024) and assuming 20%
solar panel efficiency (Enel X, 2024), each Tribal home would need to install approximately 201 square
feet of solar panels (12 solar panels) on their roof to offset all residential emissions (26.2 MTCO2e).
Tribal facilities would have to install approximately 6,276 square feet of solar panels (358 solar panels)
across all buildings to offset all commercial emissions (61.9 MTCO2e) for a total reduction of 87.6
MTCO2e per year for this measure.
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8.0 REFERENCES
Acorn Environmental. (2022). Draft Tribal Environmental Impact Report. Jamul, CA: Jamul Indian Village
of California.
Acorn Environmental. (2022). Jamul Casino Hotel and Event Center Project: Tribal Environmental Impact
Report. Jamul, CA: Jamul Indian Village of California.
BRG Consulting. (2016). Viejas Casino & Resort Phase 3 Project. Alpine, CA: The Viejas Band of Kumeyaay
Indians.
California Energy Commission. (2017). 2016 Nonresidential Compliance Manual. Retrieved from
California Energy Commission: https://www.energy.ca.gov/filebrowser/download/2384
CalRecycle. (2024, January). Estimated Solid Waste Generation Rates. Retrieved from CA.gov:
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates
CalRecycle. (2024). Estimated Solid Waste Generation Rates . Retrieved from CalRecycle:
https://www2.calrecycle.ca.gov/wastecharacterization/general/rates
City of San Diego. (2014). 2012-2013 Final Report Waste Characterization Study. San Diego, CA: Cascadia
Consulting Group.
City of San Diego. (2020). City of San Diego Climate Action Plan 2020 Annual Report Appendix. San Diego:
City of San Diego.
EIA. (2023, December 18). Use of energy explained - Energy use in homes . Retrieved from U.S. Energy
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use-in-
homes.php#:~:text=The%20average%20U.S.%20household%20consumes,kilowatthours%20(kW
h)%20per%20year.
EIA. (2024, January). Commercial Buildings Energy Consumption Survey (CBECS): 2018 Survey Data.
Retrieved from U.S. Energy Information Administration:
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