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HomeMy WebLinkAbout8.2 Attch 2 Exh C Comment Letters ® V01 GGl av I 10.14) Vnn/ r.vv,(VV I 1 a a� 9 a® ON SF,Rp�c DUBLIN 7051 Dublin Boulevard SAN RAMON Dublin,California 94568 A , Phone:925 828 0515 SERVICES 'eti%t0t4-tile, 4,11"t�a � FAX:925 829 1180 DISTRICT ONCE 1953 www.dsrsd.com August 21, 2013 Via Fax Martha Aja,Principal Planner City of Dublin, Community Development Dept. 100 Civic Plaza Dublin, CA 94565 Subject: Notice of Intent to Adopt a Negative Declaration for the Dublin Climate Action Plan (CAP)Update Dear Ms. Aja: Thank you for the opportunity to review and comment on the Notice of Intent to Adopt a Negative Declaration for the Dublin Climate Action Plan (CAP) Update. The City of Dublin (City) is within the service area where Dublin San Ramon Services District (DSRSD) currently provides potable water service, recycled water service and wastewater collection services. This specific CAP Update does not anticipate any changes by the City that would impact DSRSD's providing potable water, recycled water or wastewater collection and treatment services in the City of Dublin. We also agree that the Dublin Climate Action Plan Update of July 2013 would have less than a significant impact on the environment. In regards to future Climate Action Plan Updates, conceivable mitigation measures in a CAP could impact DSRSD operations. For this reason DSRSD desires to comment on future updates to the City of Dublin climate policies. Sincerely s STANLEY K LODZ ,P.E. Associate Engineer SK/ST cc: Dave Requa, DSRSD Rhodora Biagtan,DSRSD Dublin San Ramon BeMcn District Is a Public Entity H:IENODEPTICEQAIDSRSD Response to CEQA DocumentslCiry of DublinU01 MCoinments on NOI to Adopt a Neg Dec Dublin Climate Action Plan Update 8-21- 1�a-- EXHIBIT C TO Received Time Aug. 22. 2018 4:43PM No. 1282 ATTACHMENT 2 Tb=E•OF CALIFORNIA-THE NATURAL RESOUR'--,AGENCY EDMUND G.BROWN,JR.,Governor COLORADO RIVER BOARD OF � -+LIFORNIA ig 770 FAIRMONT AVENUE, SUITE 100 GLENDALE,CA 91203-1068(818)500-1625 �� �� (818)543-4685 FAX AUG 2 3 2013 CITY OF WELIN C1—9y MANAGER'S®FFYCE August 19, 2013 State Clearinghouse ` P.O. Box 3044 Sacramento, CA 95812-3044 Regarding: SCH9 2010 072 012 - Notice of Intent to Adopt a Negative Declaration for updating the existing Dublin Climate Action Plan, City of Dublin, Alameda County, California To Whom It May Concern: The Colorado River Board of California (CRB) has received and reviewed a copy of Notice of Intent to Adopt a Negative Declaration for updating the existing Dublin Climate Action Plan, City of Dublin, Alameda County, California. At this juncture, the CRB has determined that it has no comments regarding the Notice. If you have any questions, please feel free to contact Dr. Jay Chen at (818) 500-1625. Sincerely, Tanya M. Trujillo Executive Director cc: Ms. Martha Aja, Environmental Coordinator, City Manager's Office, City of Dublin E A pft :`'. September 5, 2013 psft/ , 0—kow lx' Martha Aja I/ Environmental Coordinator City Manager's Office BAY A PE A 100 Civic Plaza AIR QUALITY Dublin, CA 94568 Subject: City of Dublin Climate Action Plan Update MANAGEMENT Di S R i C Dear Ms. Aja, Bay Area Air Quality Management District (District) staff has reviewed the City of ALAMEDA COUNTY Dublin's (City) Climate Action Plan Update (Plan). We understand that the City's Scott Tom aggerty intentions in updating the Plan are to track progress toward achieving the City's Nate Miley greenhouse gas (GI-TG) reduction target, and to update the Plan with additional (vice chair) Tim Sbranti activities the City s undertaking is to reduce GI IG emissions. We further understand CONTRA COSTA COUNTY that the City intends to use the Plan to streamline CEQA review of new land use John Gioia projects. David Hudson Mary Piepho Mark Ross The District acknowledges that reviewing, modifying and tracking the MARIN COUNTY implementation of local climate action plans is critical to achieving local GHG Susan Adams reduction goals. In undertaking this effort, the City has added important strategies NAPA COUNTY to its Plan, such as the Green Building Ordinance, the opening of the West Dublin Brad wagenknecht BART Station and transit-oriented development around the Station, and significant SAN FRANCISCO COUNTY solar energy and waste reduction programs. John Avalos Edwin M. Lee Eric Mar The District has the following specific comments on the Plan. SAN MATEO COUNTY Carole Groom The GHG Reduction Target (Secretary) Carol Klatt The Plan's GHG reduction target is to reduce GI IG emissions 15% below 2010 SANTA CL RA COUNTY levels by 2020. This is inconsistent with the State's AB 32 Scoping Plan, which (Chair) calls on local jurisdictions to reduce GHG emissions 15% below 2008 levels by Liz Kniss 2020. While the Plan includes a justification for changing the original climate Jan Pepper Ken Yeager action plan's base year from 2005 to 2010, District staff recommends that the Plan SOLANO COUNY also include a quantitative explanation of how the 2010 base year will achieve an James Spering equivalent GHG reduction to the target called for in the Scoping Plan. SONOMA COUNTY Teresa Barrett As the 2020 target year nears, it is increasingly important to address what will Shirlee Zane happen to GHG emissions in the community after 2020. The Plan should include a discussion of the climate stabilization GHG reduction target for 2050 called for in Jack P. Broadbent EXECUTIVE OFFICERIAPCO Executive Order S-3-05, namely, the State will reduce GI IG emissions 80% below 1990 levels by 2050. This discussion could address how the Plan's strategies and policies will place the community on a trajectory toward achieving the 2050 target. Ms. Aia September 5, 2013 The GHG Emission Reduction Measures In order to meet California's GI-IG reduction goals for AB 32 and, more importantly, for Executive Order 5-3-05, California will need to create more efficient, low-emission new development as well as achieve significant emission reductions from the built community. The Plan states that Dublin is a high-growth community, and so includes many mandatory measures aimed at reducing GHG emissions from new development. The District supports this approach. However, relying on new development to be more efficient will likely not be enough to achieve the State's aggressive 2020 and 2050 GHG reduction targets. Therefore, the District has identified additional feasible measures that have proven effective at reducing GHG emissions in other jurisdictions that have not been included in the Plan. The District recommends that the Plan strengthen its GIIG reduction approach in the following ways: - Expand the City's Green Building Program (A.2.1) beyond new residential development to also require energy efficiency standards beyond Title 24 for all new commercial construction and for significant remodels of residential and commercial buildings (example: San Rafael CIimate Action Plan (CAP)). - Add a time of sale energy efficiency upgrade requirement to residential and commercial buildings, such as a residential/commercial energy conservation ordinance (RECO/CECO). An alternative would be to consider the approach taken by the City of Pleasanton, wherein they are implementing a voluntary time of sale energy upgrade program, but if performance goals are not met, the program becomes mandatory. - Add heat island mitigation strategies to reduce outdoor air temperatures and air conditioning needs by requiring cool rooting and cool paving materials be used in new development and significant remodels (example: Santa Rosa CAP). - Add a transportation demand management(TDM) requirement, such as requiring employers of 50 or more employees to offer TDM programs to their employees. The TDM programs should include strategies such as employer-paid subsidies for commuting by transit or vanpool; employer-provided bus, shuttle or vanpool service; or other programs such as telecommuting,rideshare matching, etc. These strategies would complement the District's upcoming region-wide commuter benefits program, currently under development, authorized by Senate Bill 1339 (example: Solano County CAP). - Add measures addressing parking policies, such as parking pricing, reducing parking requirements for new development/imposing parking maximums, etc. (example: Santa Rosa CAP) Appendix D: Emissions Reduction Calculations and Assumptions should include more detailed information on the assumptions behind the emission reduction estimations. For example, for Measure A.1.1 Transit-oriented Development, Appendix D lists the assumption as "25% reduction in per-household VMT for each new transit-oriented unit"— District staff recommends that this be expanded to include what the average VMT per household is and how that average was determined. In other cases, such as with Measures A.3.1-6 Solid Waste and Recycling Measures, there should be more justification for how the 3% reduction in the waste diversion rate is achieved. Through conversations with City staff it is understood that this back-up data exists, and District staff recommends this data be included in Appendix D. 2 Ms. Aja September 5, 2013 We commend the City for its efforts to address the critical issue of climate change through local action. We also support the City's efforts in monitoring the implementation of the Plan and adding important 01-IG reduction measures to the Plan. By addressing the recommendations in this letter, District staff believes that the Plan would be more likely to achieve its GHG reduction target and the City would be in a better position to use the Plan as a tierable document under CEQA. District staff is available to assist the City in addressing these comments. If you have any questions, please contact Abby Young, Principal Environmental Planner, at (415) 749-4754. Sincerely, tf� ,�VA Je n oggenkam D - ty Air Pollun o trol Officer cc: BAAQMD Director Tom Bates BAAQMD Director Scott IIaggerty BAAQMD Vice Chair Nate Miley BAAQMD Director Tim Sbranti 3