Comment Log Display

With respect to categorical exemptions in general.

•	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 a small community. 
We suggest reviewing this proposed standard and setting a number
that could be universally accepted as less than significant.  In
addition, no background or explanations are given as to how the
thresholds were established.  Even a small amount of information
would be helpful to the reader (e.g.  the industrial threshold of
7,000MT for ?? number of small industrial projects anticipated
between 2010 and 2020 represents ??% of the overall state wide GHG
emission total predicted for 2020 and is therefore considered less
than significant).

With respect to the proposed 7,000 MT CO2 or equivalent threshold
for industrial projects.

•	Comment:  Based on research the City has conducted with a UC
Davis professor, 7,000 MT is equivalent to approximately a 425 unit
subdivision (including GHG emissions from both energy and
transportation associated with the residential use).  Based on this
research that used the State GHG inventory to establish local
baseline emissions, we calculate that each housing unit constructed
in Davis produces an average of  16.5 MT per unit per year (2010
baseline).  Based on these calculations, we suggest that when the
threshold for industrial projects is applied to a smaller
community, it  may represent a substantial percentage of the
overall emissions.  We believe this number to be high.  We would
encourage the CARB to consider an alternative thresholds
methodology, perhaps using a system that has these relatively small
projects contribute to a GHG emissions mitigation fund that can be
tapped by local jurisdictions to off-set local GHG emissions in an
amount roughly equal to the impact (e.g. energy efficiency
upgrades/retrofit of existing housing stock).  We assume that as
permitted under the current CEQA, local jurisdictions are permitted
to set a more stringent local standard. We believe this is
consistent with State Law as long as the standard is not less that
the State’s adopted guideline.

For residential and commercial projects.

•	Comment:  CEQA guidelines Section 15322(d) currently exempt
infill projects of 5 acres or less.  If this were to be applied to
residential or commercial projects, we believe a project may
potentially have substantial emissions.  The City strongly supports
infill projects but needs greater understanding of how “Infill”
would be interpreted for the purposes of this exemption.

For the proposed operations:

o	Meets an CEC Tier II energy use performance standard; and

o	Meets CARB performance standard for water, waste and
transportation; and

•	Comment:  Why are these standards not also applied to industrial
projects?

Other questions:

•	How do we evaluate projects that do not fall into these three
use categories?  
•	Does a “commercial” project include projects which are
public/semi-public, office, churches, schools, or other?  
•	Comment:  We think more guidance will be necessary since
substantial categories of projects would not be evaluated under the
proposed thresholds. 
•	Is a "de minimus" approach per project sensible?
•	What does a threshold number mean to a project in terms of
financial cost?
•	How does x MT of CO2 or equivalent translate to VMT's?