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