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Home My WebLink About8.2 Attch 2, Exh C Comment Letters . Buiia~~ COUNTY OF ALAMEDA CE-E-Y OF of {y~p y° PUBLIC WORKS AGENCY m ~ DEVELOPMENT SERVICES DEPARTMENT AIjU 0 2(;;(; • 951 Turner Court, Room 100 d PUBLIC Hayward, CA 94545-2698 WORKS (510) 670-6601 9eSO~rces FAX (510) 670-5269 July 27, 2010 Martha Aja City of Dublin 100 Civic Plaza Dublin, CA 94568 Dear Ms. Aja: Subject: Notice of Intent to Adopt a Negative Declaration for Dublin Climate Action Plan (CAP) Reference is made to your transmittal of a copy of Draft Initial Study and Negative Declaration for the adoption of the Draft Climate Action Plan, a document that provide policies and measures aimed at reducing greenhouse gas (GHG) emissions within the City of Dublin. We have reviewed the submitted documents and have no comments to offer at this time. If you have any questions, please ca11 me at (510) 670-5209. Very truly yours, R s e De Leon , A si gineer Development Services Department /RDL EXHIBIT C TO TO SERVE AND PRESERVE OUR COMMiJNITY ATTACHMENT 2 Yage 1 oi 1 Martha Aja From: Diane Lowart Sent: Wednesday, August 04, 2010 9:43 AM To: Martha Aja Subject: Climate Action Plan Martha: Thank you for the opportunity to review the Negative Declaration for the Dublin Climate Action Plan. For the record, I have no comments. Diane Lowart Parks & Community Services Director City of.Dublin 8/4/2010 Au~7 5. 2;i1 ii 4;3F'M V:. :l i~ F. ~'',eION sEq pIC ~4j.. h d DUBLIN 7051 bublin 6oulevard SAN RAMON p ~ Dublin, Californis 44568 P h+ PhOne: 925 628 0515 SEI2VICES 'tng ftlOTein')r", . RAX: 925 829 1180 i. DTSTRIG"Z' S~NCE 1953 f~~ "~v dsrsd.com August 4, 2010 Martha Aja, Enviroiunental Specialist City of Dublin - City Manager's Office 100 Civic Plaza Dublin, CA 94568 Subject: Notice oF Intent fo Adopt a Negative Declaration for tlie Dab13n Climate Action Plnu (C.AP) Dear Ms. Aja: Thank you for the oppoi-tunity to conunent on the zbove subject dociiment. The Dublin San Raanon Services District (DSRSD) has reviewed the Draft Climate Action P(an (CAP) and Iias the following comment. The actions in the Draft CAP, wvhich primarily addresses green.house gas (GHG) emissrons, will not materia3lq affect DSRSD or its operations, Neveilheless, DSRSD is in favor of the adoption of the Draft CAP in order to ensure the Ciry of Dttblin adequately addresses the issue of CrHG emissions. DSTZSD will eontinue to work with the City of Dublili to mutua.lly provicle services to our clastorners and residencs wlrile protecting our valuable enviroiunevt. Thpnkc yott fot the opporttunity to review the Draft Cliinate Action Plan. Yf you have any qLYestions regarding DSRSD's coxnn.lents, please contact me at (925) 875-2253. Sincerely, STANLEY LODZI Associate Engiueer SK/st cc, Dave Requa U~blln 4en h'=on Senice: Dislricl ie a NFlit Entip' HAENQMprnCk~WOI to adoptNegneo for the AubUn Climsta AcUon Plan nug 20104oc 08/05;2010 THU 15:22 [T1iiRH F1O 65001 U 001 ~ ~ Ci~CEiVED August 5, 2010 ~I~ OF ~}f,~p°0N `I MarthaAja AiG 17 2010 B A Y A R E A City Manager's Office ~r_!~ 100 Civic Plaza AIRQUALITY Dublin, CA 94568 MANAGEMENT Subject: Draft Dublin Climate Action Plan D t s r a I c r S I N C E 19 5 5 Dear Martha Aja: Bay Area Air Quality Management District (District) staff reviewed the City's Draft Climate Action Plan (CAP) and the Draft Negative Declaration. We ALAMEDA COUNTY understand that the project is the adoption of the CAP, a document that provides Tom aates policies and measures aimed at reducing greenhouse gas (GHG) emissions within (Vice-Chairperson) the City. The goal of the CAP is to reduce the City's communitywide GHG Scott Haggerty Jennifer Hosterman emissions by 25% below a business-as-usual scenario by 2020. The CAP Nate Miley describes the baseline GHG emissions produced in Dublin in 2005 and estimates coNrRn cosrn couNrr GHG emissions in 2020 that could be expected if the CAP is not implemented. John Gioia The City expects emission reductions to be achieved by a range of ineasures ~ v d H~d on under the City's control, coupled with state initiatives aimed at reducing GHG Mark Ross emissions. Gayle B. Uilkema MARIN COUNTY The District applauds the City's proactive approach to reducing GHG emissions Harold C. Brown, Jr. and supports its efforts in developing the CAP. Further, the District believes a NAPA COUNTY Qualified GHG Reduction Strategy, as in this case the City's CAP, is an effective Brad Wagenknecht and efficient strategy to address GHG emissions. We offer our assistance towards (Chairperson) ensuring the CAP meets the City of Dublin's goals and the District's standard SAN FRANCISCO COUNTY elements of a Qualified GHG Reduction Strategy set forth in our recently updated Chris Er c Mary CEQA Guidelines (June, 2010). Gavin Newsom SAN MATEO COUNTY The District has the following specific comments on the CAP. Carol Klatt Carole Groom SANTA CLARA COUNTY Baseline GHG Emissions Inventorv - Susan Garner Ash Kalra The methodology used by the City is not consistent with the DistricYs Liz Kniss recommended methodology for quantifying a plan's GHG emission inventory and Ken Yeager therefore should not be compared to the District's significance threshold to SOLANO COUNTY determine the significance of the CA.P's GHG impacts as is stated in the City's James Spering Negative Declaration. (BAAQMD CEQA Air Quality Guidelines, at page 9-3; SONOMA COUNTY Draft Negative Declaration at page 6.) To clarify, the CAP should be designed by Shirlee Zane following the District's recommended methodology and thus meet the District's Pamela Torliatt criteria of a Qualified GHG Reduction Strategy. Jack P. Broadbent EXECUTIVE OFFICER/APCO ~',vvr~~~/ f1~? ~l~1 f . r The Air District is a Certified Green Business Prin[ed using soy-based inks on 100% post-consumer recycled content paper 'F~~~+roGree~OUhc¢ 939 ELLIS SI'REET • SAN FRANCISCO CAL[FOAN[A 94109 • 415.771.6000 •WWWBfAQMD.G0V Martha Aja - 2- August 5, 2010 The District recommends the CAP's emissions inventory account, at a minimum, for municipal and communitywide emissions from the following sectors: 1. Transportation 2. Commercial 3. Industrial 4. Residential 5. Solid Waste The CAP's emissions inventory, however, excludes certain emission sources and may lack sufficient information. First, District staff was unable to determine how the CAP addresses tlie relationship betiueen energy and water. The inventory may lack emissions, for example, from wastewater treatment processes. The CAP states at page 17, "water related emissions were not included in the inventory While water related emissions are typically embodied in the energy data for residential, commercial, and industrial sectors, emissions associated with wastewater may not be. The District recommends the CAP follow the guidance on quantifying emissions from wastewater treatment processes, located in the District's GHG Plan Level Quantification Guidance at section 1.4.3. This document may be found on the District's web site under CEQA Guidelines, Tools and Methodology. Second, the CAP further states that emissions from industrial electricity and natural gas use, as well as Direct Access electricity use have not been included in the inventory. (Draft Climate Action Plan, July, 2010, at page 20.) The District can assist local governments in developing and providing non-proprietary GHG emissions data for industrial facilities that are permitted by the Air Distnct. Reduction Target It does not appear that the City's GHG emissions reduction target meets any of the three options provided in the District's CEQA Guidelines for establishing a GHG reduction target (BAAQNID CEQA Air Quality Guidelines, at page 4-10.) The emissions reduction target in the CAP aims to reduce GHG emissions by 25°ro below the City's 2005 business-as-usual inventory by 2020. The District's CEQA Guidelines recommend that a Qualified GHG Reduction Strategy, in this case the City's CAP, establish a target that is consistent with the goals of AB 32. The CAP should provide substantial quantitative evidence that the City's goal is consistent with AB32. GHG Emissions Forecast The District recommends that the GHG emission projection, or forecast, for communities reflect a business-as-usual approach, in which emissions are projected in the absence of any policies or actions that would occur beyond the base year. Emission reductions from policies or actions that take place prior to the base would be accounted for in the business-as-usual forecast. It is unclear whether the City has followed this approach. For example, the CAP states at page 31 that, "The City of Dublin has a high-density Martha Aja - 3- August 5, 2010 residential land use designation, which allows 25.1 + dwelling units per acre If this . land use designation was adopted prior to the 2005 base year, then any future developments adhering to it would be considered part of the business-as-usual forecast and the CAP should not use this policy as an emission reduction measure toward the 25% reduction goal. The District understands that the CAP uses population and employment information based on growth-rate projections from the Association of Bay Area Governments (ABAG) Projections 2005 report. The District recommends the CAP use the most recent demographic information available, which would be from ABAG's Projections 2009 report. GHG Reduction Measures A fundamental purpose of a Qualified GHG Reduction Plan is to evaluate and provide a range of possibilities and outcomes which would allow future proj ects to select mitigation measures that are most applicable and effective, sparing future projects from performing redundant analysis. The City may have unintentionally excluded feasible and effective reduction measures applicable to communitywide emission sources other than those listed in the CAP's Appendix D. District staff recommends the City expand upon the measures identified in the CAP's Appendix D that, if implemented, would collectively achieve the specified emissions reduction goal. The current measures address only portions of communitywide emissions sources and may only apply to specific types of projects. For example, additional measures could include, but are not limited to, improving water efficiency, implementing additional transportation and land use measures, and requiring energy efficiency retrofits. See BAAQMD CEQA Air Quality Guidelines: Mitigating Plan-Level Impacts, beginning at page 9-8 for a list of specific measures that should be considered to reduce the City's GHG emissions. The CAP repeatedly states that, "Estimating the growth of City infrastructure or services was not within the scope of this project, and, therefore, this document does not include a forecast of government operations emissions. Consequently, the emissions reductions for this nzeasure are not included as part of the reduction target. "(Draft Climate Action Plan, July, 2010, at page 40.) Emissions from municipal operations are typically embodied in the communitywide inventory and forecast. Therefore, it is not necessary to develop a separate forecast for municipal operations in order to account for the emission reductions from municipal emission reduction measures. The District recommends the City quantify reductions from municipal operations measures and include those reductions in its accounting towards its GHG reduction target. In addition, the District was unable to verify the applicability and effectiveness of some of the reduction measures included in the CAP. The Green Building Ordinance, as an example, listed under Energy Measures only applies to residential projects with 20 or inore units. There is little detail provided as to how effective this ordinance has been in Martha Aja - 4- August 5, 2010 the past or as to identifying the types of green building techniques that have been required. Similarly, it is unclear how many prior projects were not required to comply with the ordinance or how many future projects will likely be 19 units or less. While the CAP does provide some examples of past projects (Id. at page 34), it is uncertain if these exainples are representative of the type and scale of new development Dublin can reasonably anticipate occurring in the future. The City should clarify how the standards in the Green Building Ordinance would apply to new residential development, thus ensuring the City is able to justify their estimated reductions credited by this strategy. Regarding the CAP's reliance on measures implemented by the State, the einission reduction calculations for the CAP's stated measures are not transparent and verifiable. The einission reduction discussion for each ineasure should clearly state which emission sector the measure is targeting and how the emission reduction was calculated. For example, in the discussion on the state's Renewable Portfolio Standard, the CAP assumes that a 19% reduction in the City's 2020 electricity use emissions will result in a reduction of 33,594 MTC02E/year in 2020. The CAP's inventory does not list the GHG emissions for the City's electricity sector for 2005 or 2020, making it unclear how the 19% reduction is being calculated for electricity use. The City's estimated electricity use reductions cannot be verified with the given information. Lastly, it is unclear how the CAP estiinates emission reductions from AB 1493. The CAP should clearly list the total GHG emissions in the emission inventory's on-road passenger/light duty transportation sector and how a 15.75% emission reduction would result in a 46,034 MTC02e/year reduction. District staff recognizes that the Draft CAP includes valuable analysis and policies, and represents a significant commitment by the City. District staff is available to assist the City staff in addressing these comments. If you have any questions, please do not hesitate to contact Ian Peterson, Environmental Planner II, at (415) 749-4783. Sincerely, 7nJeRoggenk y Air Pollution Control Officer cc: BAAQMD Vice-Chairperson Tom Bates BAAQMD Director Scott Haggerty BAAQMD Director Jennifer Hosterman BAAQMD Director Nate Miley OF Dp~ 19 11~ az City Manager's Office MEMORANDUM Bonnie Terra Dublin Fire Prevention DATE: 7uly 7, 2010 D JUL 0 7 2010 TO: City~Staff 'u CITY OF DUBLIN FROM: ` 1Vlartha Aja, Environmental Specialist FIRE PREVENTION SUBJECT: NOTICE OF INTENT TO ADOPT A NEGATIVE DECLARATION FOR THE DUBLIN CLIMATE ACTION PLAN The City of Dublin is circulating a Negative Declaration for public review for the Draft Climate Action Plan (CAP). The goal of the Draft CAP is to reduce Dublin's community-wide GHG emissions by 25% below a business as usual scenario by 2020. The Draft CAP identifies a variety of ineasures to achieve the City's GHG reduction target. Attached for your review is a copy of the Draft Climate Action Plan and the Initial Study/Negative Declaration. Please forward any comments you may have to me no later than August Sth, 2010. The comment period for the Negative Declaration begins on Wednesday July 7, 2010 and closes at 5:00 p.m. on Thursday August 5`h, 2010. cc: Chris Foss, Assistant City Manager Roger Bradley, Administrative Analyst (VN OF DUB City Manager's Office . 1`82 MEMORANDUM Commander Casey Nice ~~LIFpR~~ Police Services DATE: 7uly 7, 2010 To: City Staff FROM: Martha Aja, Environmental Specialist SUSJECT: NOTICE OF INTENT TO ADOPT A NEGATIVE DECLARATION FOR THE DUBLIN CLIMATE ACTION PLAN The City of Dublin is circulating a Negative Declaration for public review for the Draft Climate Action Plan (CAP). The goal of the Draft CAP is to reduce Dublin's community-wide GHG emissions by 25°/a below a business as usual scenario by 2020. The Draft CAP identifies a variety of ineasures to achieve the City's GHG reduction target. Attached for your review is a copy of the Draft Climate Action Plan and the Initial Study/Negative Declaration. Please forward any comments you may have to me no later than August Sth, 2010. The comment period for the Negative Declaration begins on Wednesday July 7, 2010 and closes at 5:00 p.m. on Thursday August 5`h, 2010. cc: Chris Foss, Assistant City Manager Roger Bradley, Administrarive Analyst f~f : -jp ~