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Comment 1 for Comments on staff's approoach on residential and commercial projects under the CEQA (ceqa-rescom-ws) - 1st Workshop.
First Name: Nora
Last Name: Monette
Email Address: nmonette@davidjpowers.com
Affiliation: David J. Powers & Associates
Subject: Attachment B - Residential and Commercial Projects
Comment:
Box 2 1. What about projects that ultimately may be covered by multiple Plans, such as a Regional Plan (MTC), a Climate Action Plan and a General Plan? Would “inconsistency” with one of the plans trigger going to Box 3? 2. Please define “community level GHG target”. Does the target need to use 1990 emissions as a baseline? What if the community uses a later date, say 2002, for their baseline because they have better data? Would that invalidate the Plan for tiering purposes? Box 3 1. Will it be up to the Lead Agency to come up with a methodology to determine what mitigation is equivalent to performance standards (i.e., Tier II) or will there be some type of crosswalk to help Lead Agencies determine equivalence? 2. Statement (b) implies that all projects, no matter how large, would be required to meet the same cap. 3. For Statement (b), what about using performance standards (emissions/dwelling unit or emissions/square foot) rather than a cap? Box 4 1. Lead Agencies will need expertise and a mechanism for review of mitigation measures for those projects that trigger preparation of an EIR based upon GHG emissions. Will ARB, Air Management Districts, or another appropriate entity assist Lead Agencies with lists of feasible mitigation measures/performance levels that should be considered as mitigation measures? Alternatively, could a review process (similar to an Architectural Review Board, but possibly on a regional or County basis) be outlined that could assist Lead Agencies with identifying and evaluating mitigation measures?
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Date and Time Comment Was Submitted: 2008-10-28 15:54:00
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