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Comment 8 for Comments on industrial project approach for CEQA (ceqa-ind-ws) - 2nd Workshop.


First Name: Rhys
Last Name: Rowland
Email Address: rrowland@cityofdavis.org
Affiliation: City of Davis

Subject: Industrial Standards
Comment:
Our comments are specifically on the following proposed standards.

•	If categorically exempt project, then exempt from further
analysis.

Comment:  We believe there are circumstances where categorically
exempt projects may emit a considerable amount of green house gas
emissions relative to the overall emissions for small community. 
We suggest reviewing this and setting a number that could be
universally accepted as less than significant.  

•	If not categorically exempt, then the analysis must show that a
project:

o	Meets the CARB standards for construction and transportation;
and

o	Emit not more than 7,000 MT of CO2 or equivalent per year

Comment:  7,000 MT is equivalent to approximately a 425 unit
subdivision considering the average current emissions for the State
at 16.47 MT per unit per year.  We suggest that this number for a
smaller community may represent a substantial percentage of the
overall emissions.  We believe this number to be high.  We believe
projects should be limited to their “fair share” of emissions.  If
our city felt the standard was too high could we set a lower number
to hold projects to?  This would be consistent with other
jurisdictions setting their own thresholds of significance.  We
believe this is consistent with State Law as long as the standard
is not less that the State’s adopted guideline.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2009-01-14 16:34:51



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