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Comment #4 for Comments on Performance Standards for CEQA GHG Thresholds
(ceqa-ps-ws) - 2nd Workshop

First Name: Rhys
Last Name: Rowland
Email Address: rrowland@cityofdavis.org
AffiliationCity of Davis
SubjectResidential and Commercial Standards
Comment
General comments on the proposed residential and commercial
standards are as follows:

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

Comment:  The 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 have
substantial emissions.  We need greater understanding of how
“Infill” would be interpreted for the purposes of this exemption.

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

o	Complies with an approved plan for GHG emissions, like the CAT
is doing and we have an certified EIR; or  

o	Meets the CARB standard for construction; and

o	For operations:

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

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

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

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

Original File Name:

Date and Time Comment Was Submitted: 2009-01-14 16:38:02


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