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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?


Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-10-28 15:54:00



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