HomeMy WebLinkAboutCC Resolution 13682 (Carryout Bag EIR)RESOLUTION NO. 13682
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL
CERTIFYING A FINAL ENVIRONMENTAL IMPACT REPORT (FEIR) (SCH #
2013062049) AND ADOPTING AN EIR ADDENDUM PREPARED FOR A
SINGLE -USE CARRYOUT BAG REDUCTION ORDINANCE
P13-011
The City Council of the City of San Rafael finds and determines that:
WHEREAS, in 2009, the City of San Rafael adopted the City of San Rafael Climate
Change Action Plan (CLAP), which includes a number of programs and recommended measures to
promote sustainability. Among the CCAP programs is LF17 which recommends that the City
"investigate options for banning non -recyclable single -use items such as plastic bags and
polystyrene takeout food containers;" and
WHEREAS, in 2012, the City Council directed staff to proceed with drafting an ordinance
that would regulate, citywide, the use and type of single -use carryout bags. During this time, other
cities and towns in Marin County expressed an interest in adopting similar ordinances.
Collectively, the cities and towns worked with Marin County Hazardous and Solid Waste
Management to form a Joint Powers Authority (JPA). The purpose of the JPA is to serve as a lead
in: a) developing a "model ordinance" that could be considered for adoption by all participating
cities and towns; and b) administering the environmental review of the model ordinance, as
required by the California Environmental Quality Act (CEQA) Guidelines; and
WHEREAS, in 2013, JPA prepared a draft Model Single Use Carryout Bag Reduction
Ordinance (model ordinance) that participating JPA member agencies within Marin County
(including the City of San Rafael) can consider for adoption; and
WHEREAS, because adoption of a Single Use Carryout Bag Reduction Ordinance would
be a discretionary action subject to the environmental review requirements of CEQA (Pub.
Resources Code, § 21000 et seq.), the JPA prepared an Initial Study and determined that an
Environmental Impact Report (EIR) should be prepared examining the potential environmental
impacts of adopting and implementing the draft model ordinance. The Initial Study recommends
that the EIR assess the potential impacts in the topic areas of air quality, biological resources,
greenhouse gas emissions/climate change, hydrology and water quality, utilities and service
systems, cumulative impacts, growth -inducing impacts and project alternatives; and
WHEREAS, acting as a "Co -Lead Agency," the JPA was assigned the role of
administering the CEQA process through Final EIR completion for the member municipalities.
The JPA prepared a Notice of Preparation (NOP) of an EIR for the draft model ordinance, which
was published on June 21, 2013, initiating a 30 -day review period. On July 9, 2013, the JPA
conducted a public scoping meeting. Four comment letters were received in response to the NOP;
and
WHEREAS, on November 1, 2013, the Single Use Carryout Bag Reduction Ordinance
Draft EIR was completed and published for public review (SCH # 2013062049). Commencing on
November 1, 2013, a 45 -day public review period was observed, ending on December 15, 2013.
The Draft EIR concluded that: a) for each environmental issue area studied, impacts would either
be less -than -significant or beneficial; b) the draft model ordinance would not result in any
significant, unavoidable impacts, or any significant impacts that require mitigation. Further, as
required by the CEQA Guidelines, the Draft EIR must analyze alternatives to the project (model
ordinance) and identify an environmentally superior alternative to the project. Seven alternatives
were assessed, which are variations of the model ordinance. The Draft EIR concluded (Section 6.0,
Alternatives) that Alternative 4 (Mandatory Charge of $0.10 for Recyclable Paper Carryout Bags)
would be environmentally superior compared to the draft model ordinance; and
WHEREAS, as a Co -Lead Agency, on December 2, 2013, the City of San Rafael City
Council conducted a public hearing on the Draft EIR, which is required by the City of San Rafael
Environmental Assessment Procedures Manual. Comments received during the public hearing
were submitted to the JPA for response and incorporation into the Final Environmental Impact
Report (Final EIR). Further, as part of this public hearing process, the City Council expressed
support for considering an ordinance that would be similar to EIR Alternative 4 (with some
additions), and directed staff to prepare a draft ordinance. The City Council also commented that
EIR Alternative 7 (Mandatory Charge of $0.25 for Recyclable Carryout Bags) may be a direction
to consider following one vear of enactine a bag reduction ordinance; and
WHEREAS, pursuant to Public Resources Code Section 21091(d)(2)(A) and CEQA
Guidelines Sections 15088 and 15089, the JPA responded to all the environmental comments that
were submitted on the Draft EIR during the public review period, including a written comment by
the City of San Rafael summarizing the comments received at the December 2, 2013 City Council
hearing, and a Final EIR was prepared and published; and
WHEREAS, on January 16, 2014, the JPA Board of Directors held a duly -noticed public
hearing on the Final EIR, accepting all oral and written public testimony and the written report of
the JPA staff. Following closure of the public hearing and deliberation, the Board of Directors, on
an 1 1-0 vote, adopted Resolution No. 2014-01 certifying the Single Use Bag Reduction Ordinance
Final EIR. This certification was based on and supported by findings, which are incorporated
herein by reference, and reaffirmed below; and
WHEREAS, in January 2014, the City of San Rafael prepared a draft ordinance
("proposed ordinance") for adoption consideration by the City Council. Similar to EIR Alternative
4, the proposed ordinance bag reduction regulations would also apply to special events such as a
farmer's market; and
WHEREAS, since the project (proposed ordinance) is slightly different than EIR
Alternative 4 analyzed in the Final EIR, the Final EIR was reviewed to ensure that the
environmental impacts of this proposed ordinance have been adequately analyzed and addressed.
The purpose of this review was to determine whether an Addendum to the Final EIR, Supplemental
EIR or Subsequent EIR would be appropriate to address environmental review for the project.
Public Resources Code Section 21166 and CEQA Guidelines Section 15162 set forth limited
situations in which a Supplemental EIR or Subsequent EIR in required once a Final EIR has been
certified. Further, CEQA Guidelines Section 15164 provides for the preparation of an EIR
Addendum if no Supplemental EIR or Subsequent EIR is required; and
WHEREAS, it has been determined that the proposed ordinance would not result in any
new, additional or significantly different information, nor would it result in new, significant
impacts that have not been previously studied or disclosed. As a result, the Addendum to the
Marin County Hazardous and Solid Waste Management JPA Single -Use Carryout Bag Reduction
Ordinance Final EIR (EIR Addendum) was prepared; and
WHEREAS, on February 18, 2014, the San Rafael City Council held a duly -noticed
public hearing on the Final EIR and EIR Addendum, accepting all oral and written public
testimony and the written report of the City Manager's Office staff; and
WHEREAS, the custodian of documents which constitute the record of proceedings upon
which this decision is based, is the City Clerk's Office.
NOW, THEREFORE, BE IT RESOLVED, as a Co -Lead Agency, the City Council of
the City of San Rafael hereby certifies the Marin County Hazardous and Solid Waste Management
JPA Single -Use Carryout Bag Ordinance Final Environmental Impact Report (Final EIR) based on
the following findings:
The Final EIR has been completed in compliance with the CEQA Guidelines and the City of
San Rafael Environmental Review Procedures following the appropriate format, content,
technical analysis of potential impact areas, and assessment of project alternatives. Further, the
prescribed public review periods and duly -noticed public hearings were held for the initial
Notice of Preparation (NOP); the Notice of Completion (NOC) for public review of the Draft
EIR; and the Notice of Availability following publication of the Final EIR.
2. The Final EIR has been prepared using the City's independent judgment and analysis finding
that it:
a. appropriately analyzes and presents conclusions on impacts;
b. analyzes a reasonable range of alternatives to the project that could feasibly attain most of
the basic objectives of the project while avoiding or substantially lessening any significant
effect of the project; and
c. concludes that all potentially significant impacts have been determined to be less -than -
significant, dismissed as having no impact or beneficial. Therefore, the Final EIR does not
include nor does it recommend any mitigation measures to substantially lessen or avoid the
otherwise significant adverse environmental impacts of the project. The findings and
recommendations in the document are supported by technical studies prepared by
professionals experienced in the specific areas of study.
The information contained in the Final EIR is current, correct and complete for document
certification. The Final EIR presents factual, quantitative and qualitative data and studies,
which find and support the conclusion that the proposed ordinance will not result in any
significant environmental impacts that necessitate mitigation.
BE IT FURTHER RESOLVED that the City Council of the City of San Rafael adopts
the Addendum to the Marin County Hazardous and Solid Waste Management JPA Single -Use
Carryout Bag Reduction Ordinance Final EIR (EIR Addendum) presented in attached Exhibit A,
based on the following findings:
CEQA Section 21166 and its corresponding CEQA Guidelines Sections 15162 and 15163,
provide that once an EIR has been prepared, no subsequent or supplemental EIR shall be
required by the lead agency unless: (a) substantial changes are proposed in the project,
requiring major revisions in the EIR due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant effects; (b)
substantial changes arise in the circumstances of the project's undertaking, requiring major
revisions in the EIR due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects; or (c) new
information, which was not known and could not have been known at the time the EIR was
certified, shows any of the following:
1-3
➢ The project will have one or more significant effects not discussed in the previous EIR;
➢ Significant effects previously examined will be substantially more severe than shown
in the previous EIR;
➢ Mitigation measures or alternatives previously found not to be feasible would in fact
be feasible, and would substantially reduce one or more significant effects of the
project, but the project proponents decline to adopt the mitigation measure or
alternative; or
➢ Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline the mitigation measure
or alternative.
2. CEQA Guidelines Section 15164(a) provides that a lead agency shall prepare an Addendum to
a certified Final EIR if some changes or additions to the certified EIR are necessary but none of
the conditions calling for the preparation of a supplemental EIR have occurred. Based on the
analysis and documentation presented in the EIR Addendum, none of the situations described
in CEQA Section 21 166 and CEQA Guidelines Sections 15162 and 15163 apply here. Based
on the results of the supportive documentation in the EIR Addendum, the City has concluded
that the proposed ordinance would not result in significant changes to the findings presented in
the certified Final EIR or significant new information.
3. The EIR Addendum has been prepared in accordance with CEQA, the CEQA Guidelines, and
the provisions of the City of San Rafael Environmental Assessment Procedures Manual.
4. The EIR Addendum has been presented to the City Council who has reviewed and considered
the information in the EIR Addendum and the JPA -certified Final EIR prior to taking action on
the proposed ordinance.
5. The EIR Addendum considered with the information presented in the Final EIR reflects the
City Council's independent judgment and analysis.
I, ESTHER C. BEIRNE, Clerk of the City of San Rafael, hereby certify that the forgoing
resolution was duly and regularly introduced and adopted at a regular meeting of the City Council
held Tuesday, the 18°i of February, 2014, by the following vote, to wit:
AYES: COUNCIL MEMBERS: Bushey, Colin, Connolly, McCullough & Mayor Phillips
NOES: COUNCIL MEMBERS: None
ABSENT: COUNCIL MEMBERS: None
EXHIBIT A: EIR Addendum
11-4
ESTHER C. BEIRNE, City Clerk
Exhibit A
City of San Rafael
Single Use Carryout Bag
Reduction Ordinance
Addendum to the Marin County
Hazardous and Solid Waste
Management JPA Single Use
Carryout Bag Reduction
Ordinance Final EIR
January 2014
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
San Rafael
Single Use Carryout Bag Reduction Ordinance
Addendum to the Final EIR
TABLE OF CONTENTS
Page
Introduction.......................................................................................................................1
Project Description
..........................................2
Environmental Impacts....................................................................................................4
AirQuality................................................................................................................4
Biological Resources................................................................................................6
Greenhouse Gas Emissions....................................................................................6
Hydrology and Water Quality ..............................................................................7
Utilities and Service Systems..................................................................................8
Conclusion......................................................................................................................10
References.......................................................................................................................11
ReportPreparers............................................................................................................13
City of San Rafael
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
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City of San Rafael
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
INTRODUCTION
This document is an addendum to the Marin County Hazardous and Solid Waste Management
Joint Powers Authority (JPA) Single Use Carryout Bag Reduction Final Environmental Impact
Report (FEIR). On January 16, 2014, the JPA adopted Resolution No. 2014-01 certifying the FEIR
(SCH # 2013062049). The JPA represents 10 Marin County municipalities that have a common
interest in adopting a local ordinance regulating the use of single -use bags. For this reason, the
FEIR defines and covers a "Study Area' encompassing all cities, towns and the unincorporated
areas of Marin County. The FEIR analyzes the environmental impacts of the project, which is a
draft "model ordinance" that is scoped to: a) regulate the use of single -use plastic and recyclable
paper carryout bags for larger retail stores; and b) require retail establishments to charge
customers $0.05 for each recycled carryout paper bags. The "model ordinance" is intended to
be used as a template for those Marin County municipalities that will pursue a drafting and
adoption of a local ordinance regulating single -use carryout bags. Consistent with the
provisions of the CEQA Guidelines, the FEIR includes an assessment of seven alternatives to the
"model ordinance" project (FEIR Alternatives 1 through 4).
As one of the 10 participating municipalities in Marin County, the City of San Rafael has
reviewed the model ordinance and FEIR and has determined to propose adoption of an
ordinance ("proposed ordinance") to regulate single -use bags that is largely consistent with
FEIR Alternative 4. Alternative 4 is similar in scope to the model ordinance but would establish
a mandatory charge of $0.10 per recyclable paper bags. In addition, the proposed ordinance
would be applicable to special events such as the farmer's markets. The addendum is required
to address the possible environmental effects associated with adoption and enforcement of the
proposed ordinance by San Rafael.
In accordance with Section 15164 of the California Environmental Qualihj Act (CEQA) Guidelines,
an addendum to a previously certified FEIR is the appropriate environmental document in
instances when "only minor technical changes or additions are necessary" and when the new
information does not involve new significant environmental effects beyond those identified in
an adopted FEIR. The changes being contemplated involve adopting the proposed ordinance,
which is slightly different than the model ordinance assessed as the project in the FEIR. The
differences are discussed below in the project description.
The proposed ordinance would result in no new significant environmental effects beyond those
identified and assessed in the FEIR. Since the proposed oordinance does not require substantial
changes to the those analyzed in Alternative 4 of the FEIR, major revisions of the EIR analysis
are not warranted. As such, a subsequent EIR pursuant to Section 15162 of the CEQA Guidelines
would not be warranted and an addendum is the appropriate environmental document under
CEQA. TI -ds addendum includes a description of the currently proposed ordinance and a
comparison of the impacts of this ordinance to those identified for FEIR Alternative 4.
City of San Rafael
1
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
PROJECT DESCRIPTION
The proposed San Rafael Single Use Carryout Bag Reduction Ordinance (referred to herein as
"proposed ordinance") would ban the issuance of single use plastic carryout bags to customers
at the point of sale and would charge a minimum of ten cents ($0.10) for a recyclable paper
carryout bag or a reusable bag. The proposed ordinance would apply to retail establishments,
including, but not limited to, drug stores, pharmacies, supermarkets, grocery stores,
convenience food stores, food marts, or other similar retail stores or entities engaged in the
retail sale of grocery items. The proposed ordinance would not apply to some retailers who
distribute single use plastic carryout bags including restaurants and other non -grocery related
retailers such as clothing or hardware stores.
As discussed above, the proposed ordinance is similar to FEIR Alternative 4. As stated in the
FEIR, Alternative 4, like the model ordinance, which proposes a $0.05 fee for recyclable paper
carryout bags (the Draft Model Ordinance), would continue to prohibit Study Area retail
establishments from providing single use plastic carryout bags to customers at the point of sale,
but would increase the mandatory charge for a recyclable paper carryout bag from $0.05 to
$0.10. Like Alternative 4, the proposed ordinance would have a mandatory charge of $0.10 for
recyclable paper carryout bags and reusable bags. However, the City's Proposed Ordinance
would also include minor revisions that are specific to San Rafael.
The differences between the proposed ordinance and FEIR Alternative 4 are as follows:
• Under FEIR Alternative 4, only "stores," as defined, would be regulated. Under the
proposed ordinance, stores and vendors at "public events" which, as defined,
include farmers' markets, parades, craft fairs, festivals, concerts, performances or
other exhibitions would also be regulated.
• Under FEIR Alternative 4, the effective date of the ordinance is not defined. In the
City's proposed ordinance, the operative date is defined as being on or after
September 15, 2014.
• Under FEIR Alternative 4, stores may provide reusable bags to customers at no cost
only when combined with a time-limited store promotional program and those
events that do not exceed a total of 60 days within any consecutive 12 -month period.
For the City's proposed ordinance, such events are not to exceed a total of 30 days
within any consecutive 12 -month period.
• Under FEIR Alternative 4, the appropriate enforcement official is not defined. For
the City's proposed ordinance, the authority to enforce the ordinance is held with
the City Manager or such code enforcement officials as may be designated by the
City Manager.
• For the City's proposed ordinance there is a provision for store self -enforcement via
written or online registration, which is not included under FEIR Alternative 4.
The above -listed differences between the City's proposed ordinance and FEIR Alternative 4 are
minor and insignificant changes and revisions that would result in minimal/ negligible changes
to bag use (less than 0.25% of total existing single use plastic bag use related to vendors at
City of San Rafael
2
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
public events) and, therefore, would not significantly alter any of the bag use assumptions in
the certified FEIR. Consistent with the analysis for FEIR Alternative 4, with a ban on single use
plastic carryout bags and a minimum charge of 10 cents for recyclable paper bags, it is assumed
for the City's proposed ordinance that 65% of single use plastic bag use would be switched to
reusable bags and 30% would switch to recyclable paper bags? An estimated 30,894,642 single
use plastic bags are currently used annually in the City of San Rafael. As shown in Table 1
below, with the City's proposed ordinance, total bag use would be reduced to approximately
11,199,308 carryout bags per year in San Rafael. This bag use was considered in the FEIR
analysis for Alternative 4, which analyzed bag use in the 10, participating Marin municipalities
including San Rafael. Thus, even with the minor changes to the text of the Ordinance, the total
bag use that would result from the City's proposed ordinance would be similar as that analyzed
in the FEIR.
Table 1
Existing and Proposed Bag Use
Under A $0.10 Recyclable Paper and Reusable Carryout Bag Fee
Proposed Plastic
Area Existing Bags: 5%
Plastic Bags Remain (exempt
retailers) '
JPA EIR Study
Area 95,226,354 4,761,318
(Alternative 4)
San Rafael 30,894,642 1,544,732
Proposed Paper
Bags: 30%
Switch to
Paper'
28,567,906
9,268,393
Proposed
Reusable Bags:
65% Switch to
Reusable'
1,190, 329
386,183
Proposed Total
Carryout Bags
34,519,553
11,199,308
' Rates utilized in the County of San Mateo Final EIR, SCH #2012042013, and City of San Jose Final EIR, SCH # 2009102095,
October 2010.
The City's objectives for the proposed ordinance would be the same as FEIR project objectives
for the draft "model ordinance' analyzed in the FEIR. The project objectives include:
• Reducing the environmental impacts related to single use plastic carryout bags, such
as impacts to biological resources (including marine environments), zoater qualihj
and utilities (solid waste equipment and facilities)
• Deterring the use of paper carryout bags by retail customers
• Promoting a shift toward the use of reusable carryout bags by retail customers
• Reducing the amount of single use plastic carryout bags in landfill volumes
• Reducing litter and the associated adverse impacts to stornuvater systems, aesthetics
and marine and terrestrial environments
' Assumption from Table B-2, Herrera Fiscal Analysis, 2010 and City of San Jose Single -Use Carryout Bag
Ordinance FOR (SCH # 2009102095).
City of San Rafael
3
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
ENVIRONMENTAL IMPACTS
This section addresses each of the environmental issues studied in the FEIR, comparing the
effects of the City's proposed ordinance with the effects of FEIR Alternative 4 analyzed in
Section 6.0, Alternatives, of the certified FEIR. In addition to stating the JPA's finding for each
impact statement, the analysis includes a discussion of the City's impacts related to adopting its
own ordinance, as well as the impacts associated with implementation of such an ordinance
citywide.
The City's proposed ordinance would not change any of the impacts identified as less -than -
significant in the JPA -prepared Initial Study (Appendix A of the JPA's Draft EIR). Each of those
impacts would remain less -than -significant for the City's proposed ordinance. As such, further
discussion of these issues in this addendum is not warranted. Nevertheless, the certified FEIR
including the Initial Study in DEIR Appendix A and all other Appendices is incorporated by
reference.
Air Ouality
The City's proposed ordinance would have impacts related to Air Quality similar to those of the
previously studied FEIR Alternative 4. The City's existing and proposed bag use was
considered in the FEIR analysis, which analyzed bag use throughout the Study Area. Therefore,
all of the carryout bags that would be subject to the City's proposed ordinance have already
been analyzed for air quality impacts as part of the FEIR Alternatives analysis (for Alternative
4) and, as shown below, impacts would be no greater than what was already determined in the
FEIR (see Section 6.4, in Section 6.0, Alternatives). As is the case with the FEIR analysis, the City's
proposed ordinance does not involve any construction activities; therefore, there would be no
regional or localized construction impacts, and consideration of construction air quality impacts
is not relevant. Thus, this analysis focuses on operational impacts. As studied in the FEIR,
operational impacts include emissions associated with bag manufacturing, transportation, and
use as well as emissions resulting from increased delivery trips.
Emissions from Manufacture, Transportation and Use
As described in Section 6.4.2 (a) (see page 6-19) of the FEIR, under Alternative 4, if all
participating municipalities were to adopt such an ordinance, it would be expected to result in
an overall decrease in ozone and atmospheric acidification (AA) emissions. Table 2 shows the
estimated daily emission changes that would result if all the participating municipalities in the
JPA Study Area (including San Rafael) were to implement a plastic bag ban ordinance similar to
FEIR Alternative 4. The emissions related to converting from single use plastic bags to
recyclable paper and reusable bags as a result of the City's proposed ordinance are also shown
in Table 2. As shown, ozone and atmospheric acidification emissions would decrease in San
Rafael. Therefore, similar to the determination presented in the FEIR for Alternative 4, air
quality impacts from the manufacturing, transportation and use of carryout would be beneficial
compared to existing conditions.
City of San Rafael
4
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
Table 2
Estimated Emission Changes Due to All Participating Municipalities
in JPA Study Area Adopting an Ordinance and the City's Ordinance
Emission Source Ozone Emissions per AA Emissions per year
year(kg) (kg)
JPA Study Area (All
participating municipalities (-1,186) (41,455)
adopt Alternative 4)
City of San Rafael Ordinance (-385) (-11,467)
() denotes decrease in emissions compared to existing conditions
Source: JPA Final EIR, Table 6-12 and Appendix D
Emissions Resulting From Increased Delivery Trips
Similar to the FEIR analysis for Alternative 4, the City's proposed ordinance would be expected
to cause a potential increase in delivery truck trips required to transport paper and reusable
carryout bags to affected stores. As stated in the FEIR, Alternative 4 would result in an overall
increase of approximately 0.27 truck trips per day in the Study Area. Using the FEIR
methodology to determine truck trips, the City of San Rafael's contribution to this increase
would be approximately 0.13 truck trips per day?
As shown in Table 3, similar to the County of Marin single -use carryout bag ordinance, the
increase of truck trips in the City would not result in any thresholds of significance set by the
Bay Area Air Quality Management District (BAAQMD) to be exceeded. Consistent with the
Marin County's adopted ordinance, impacts related to mobile emissions from the City's
proposed ordinance would be less -than -significant.
Table 3
Estimated Daily Emissions From Increased Truck Trips
Emissions (lbs/day)
Emission Source
ROG
NOx 1311112.5
PM10
JPA Study Area
<0.01
0.03 <0.01
<0.01
City of San Rafael Ordinance
<0.01
0.02 <0.01
<0.01
BAAQMD Threshold
54
54 82
54
Significant Impact?
No
No No
No
County Ordinance Significant
No
No No
No
Impact?
Source: JPA Final EIR, Table 6-13; and, URBEMIS output (see Appendix A).
2 Existing bag use in San Rafael estimated to be 30,894,642 plastic bags per year. Assuming that 30% of existing
plastic bag use would switch to paper (9,268,393 paper bags), 65% would switch to reusable bags (386,183 reusable
bags assuming 52 uses a year) and 5% would remain (1,544,732 plastic bags) to account for exempt retailers.
Assuming 2,080,000 plastic bags per truck load, 217,665 paper bags per truck load, and 108,862 reusable bags per
truck load.
City of San Rafael
5
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
Biolozical Resources
As with the model ordinance analyzed in the certified FEIR, the City's proposed ordinance
would result in a reduction in the use and disposal of plastic carryout bags and an increase in
the use and disposal of recycled paper and reusable bags. As such, the City's proposed
ordinance would incrementally reduce the amount of single -use plastic bag litter that could
enter the marine environment and affect sensitive species. The City's proposed rdinance would
also be anticipated to increase consumer use of recycled paper and reusable carryout bags,
which, as discussed in the FEIR, have not been widely noted to have adverse impacts upon
biological resources. Although reusable bags may become a part of the waste stream, because
they can be reused multiple times and are heavier than plastic carryout bags, the number of
reusable bags that would likely end up as litter which could impact biological resources would
be lower than the number of plastic or paper carryout bags. In addition, because paper bags are
not as resistant to biodegradation, paper bags do not persist in the marine environment for as
long as plastic bags. For the reasons stated above, consistent with the findings of the certified
FEIR, the City's proposed ordinance would result in no significant adverse impacts to biological
resources.
Greenhouse Gas Emissions
Carryout bags have the potential to contribute to the generation of greenhouse gas emissions
(GHGs) either through emissions associated with manufacturing process of carryout bags, truck
trips delivering carryout bags to retailers or through disposal during landfill degradation. For
this analysis, the City's proposed ordinance is evaluated based on the project -level threshold of
4.6 metric tons CO2E per service population per year (BAAQMD, June 2010). Based on existing
population and employment data provided by the California Department of Finance (2013), the
existing population in San Rafael is approximately 58,182.
Manufacturing, Transportation, and Disposal
As discussed in the JPA's EIR, the manufacture, transport, and disposal of a recyclable paper
bag generates 2.97 times more GHG emissions than the manufacture, transport, and disposal of
a single -use plastic bag. If only used once, the manufacture, use, and disposal of a reusable
cotton carryout bag results in 131 times the GHG emissions of a single -use plastic bag.
However, reusable carryout bags are intended to be used multiple times. With reuse of carryout
bags, the total carryout bags that would be manufactured, transported and disposed of would
be reduced.
As stated in the FEIR, if every municipality within the JPA adopted FEIR Alternative 4, it would
contribute indirectly to an expected overall increase of approximately 7,897 metric tons of CONE
emissions per year, or 0.044 metric tons CO2E per person (shown in Table 4). Thus, the FEIR
determined that Alternative 4 would not exceed BAAQMD thresholds and therefore impacts
related to the manufacturing of paper bags would be less -than -significant. Similarly, for the
City's proposed ordinance, the conversion of plastic to paper and reusable bags would increase
GHG emissions in the City by approximately 2,562 metric tons per year or 0.044 metric tons per
City of San Rafael
6
EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
person as shown in Table 4. As such, consistent with the findings of the JPA's Final EIR, the
City's proposed ordinance would have a less -than -significant impact related to GHG emissions.
Table 4
Estimated GHG Emissions
Emission Source CO2e Emissions Metric Tons per Year
(metric tons/year)' per Capita
JPA EIR 7,897 0.044
City of San Rafael 2,562 0.044
Ordinance
' Represents a net change in GHG emissions compared to existing plastic bag use
Source: San Mateo County Draft Program EIR, August 2012
Consistency with Applicable GHG Plans and Policies
As was determined in the analysis of the model ordinance in the FEIR, the City's proposed
ordinance would be consistent with the CAT strategies and measures suggested in the Attorney
General's Greenhouse Gas Reduction Report, as presented in Tables 4.3-3 and 4.3-4 of the FEIR.
In addition, as stated in Section 4.3, Greenhouse Gases of the FEIR, San Rafael's Climate Action
Plan (CCAP) has several measures to reduce material consumption and increase resource re-
use. Program LF17 calls for investigating "options for banning non -recyclable single use items,
such as plastic bags and polystyrene takeout food containers." In addition, the San Rafael
General Plan 2020 Sustainability Element includes Policy SU -9h "Non -Recyclable Single Use
Items," which suggests the City should "Investigate options for banning non -recyclable single -
use items, such as plastic bags and polystyrene takeout food containers". The City's proposed
ordinance is specifically aimed at reducing the number of single use plastic carryout bags and
would be consistent with Program LF17, with San Rafael's CCAP and the General Plan 2020
Sustainability Element. Therefore, the City's proposed ordinance would be consistent with the
objectives of AB 32, SB 97, and SB 375. Impacts would be less -than -significant.
Hydrology and Water Quality
Hydrology and water quality impacts would be similar to those identified for the model
ordinance in the FEIR. The following discusses the impacts related to drainage and surface
water quality that would result from implementation of the City's proposed ordinance.
Drainage
As was determined in the analysis of the model ordinance in the FEIR, the City's proposed
oordinance would not require construction of new structures or additional storm water
infrastructure. Consequently, the capacity of existing storm water drainage would remain
unchanged and redirecting storm water flows would be unnecessary. Single -use plastic bags
that become litter may enter storm drains from surface water runoff or may be blown directly
into local waterways by the wind. By bmu-ting plastic carryout bags within the City, the
proposed ordinance would improve the existing drainage capacity by removing a significant
source of trash that can clog features of the system and reduce its capacity. Therefore, consistent
City of San Rafael
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EXHIBIT A
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Environmental Impact Report Addendum
with the findings presented in the FEIR for the model ordinance, the proposed ordinance would
not result in significant adverse impacts to hydrology and water quality related to drainage.
Surface Water Quality
As noted in the FEIR, the manufacturing processes for single -use plastic, single -use paper, and
reusable bags utilize various chemicals and materials. The City's proposed ordinance would
reduce plastic bag use by 95% and increase the use of recycled paper and reusable bags. With
implementation of the City's ordinance, approximately 11.2 million single -use bags (including
recyclable paper, single -use plastic and reusable bags) would be manufactured for use in the
City —a decrease of approximately 64% compared to existing conditions. Consequently, the
City's proposed ordinance would reduce the overall impacts to water quality associated with
bag manufacturing. Furthermore, manufacturing facilities would be required to adhere to
existing federal, state and local regulations. Therefore, impacts to water quality related to the
potential change of processing activities as a result of the City's proposed ordinance would be
less -than -significant, which is the same finding presented in the FEIR.
Utilities and Service Systems
Potential impacts to utilities and service systems resulting from the City's proposed ordinance
would be similar to impacts determined for the model ordinance in the FEIR. The following
summarizes the impacts related to wastewater collection and treatment, water supply, and solid
waste for the City's proposed ordinance compared to the findings for the model ordinance
contained in the FEIR.
Water Supply
Carryout bags would indirectly result in water use through the manufacturing process of
carryout bags. As discussed in the FEIR, the conversion from plastic bags to paper carryout
bags and reusable carryout bags would result in an increase of water use from the
manufacturing process of paper and reusable bags. Manufacturing facilities of carryout bags are
not known to be located within Marin County or in the City of San Rafael. Therefore,
manufacturing facilities would not utilize the water supplies of the County or of the City of San
Rafael.
In addition to water use from manufacturing carryout bags, the City's proposed ordinance may
result in increased water use as reusable bags would be washed. The FEIR determined that
under Alternative 4, the water demand from washing reusable bags would increase by 92.29
acre-feet per year (AFY) compared to existing conditions. The City's contribution to this
countywide increase resulting from the proposed ordinance would be 29.94 AFY. Total existing
water use in Marin County is estimated to be 40,610 AFY on average. The increase of water
demand would represent approximately 0.002% of the total water supplied to the County. This
increase would result in less -than -significant impacts. As noted above, there is no known
manufacturing and production of paper carryout bags in the Study Area (or in the City of San
Rafael). Therefore, any increase in water supply necessary for paper carryout bag
manufacturing would not impact suppliers in Marin County. Further, the impacts resulting
City of San Rafael
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EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
from the implementation of the proposed ordinance would be consistent with FEIR, which finds
that there would be no anticipated need for new or expanded water entitlements. Consistent
with the FEIR analysis for Alternative 4, impacts would be less -than -significant.
Wastewater Generation
As discussed in the FEIR, no manufacturing facilities for recyclable paper or reusable carryout
bags are located within the Study Area. Therefore, any increase in wastewater generation due to
recyclable paper or reusable carryout bag manufacturing would not affect wastewater treatment
providers in the Study Area. Nevertheless, the FEIR assumes that 100% of the water used to
wash reusable bags would become wastewater, which would result in an expected increase in
wastewater of approximately 92.29 AFY per year (30,071,480 gallons) or approximately 82,388
gallons per day. The City's portion of this wastewater that would result from the
implementation of the proposed ordinance would be approximately 29.94 AFY per year
(9,756,203 gallons) or approximately 26,729 gallons per day. The Central Marin Sanitation
Agency, which serves San Rafael, has a remaining capacity of 4.2 million gallons per day (MGD)
and therefore has capacity to treat the increase in wastewater (26,729 gallons per day) from the
City's proposed ordinance. The City's proposed ordinance would not change the conclusions
regarding wastewater generation since the estimated increase of wastewater and impacts
related to wastewater generation for the City's proposed ordinance would be less -than -
significant.
Solid Waste
As described in the FEIR, based on the Ecobilan LCA data, adoption and implementation of
FEIR Alternative 4 would increase solid waste by 0.12 tons per day. Of this, approximately 0.04
tons per day would be attributable to the City of San Rafael. Table 5 also shows solid waste
estimates calculated using the Boustead data. The FEIR determined that the model ordinance
would result in an increase of approximately 1.06 tons of solid waste per day. Of this total
countywide, approximately 0.34 tons per day would be directly related to implementation of
the City's proposed ordinance. As stated in the FEIR, the permitted daily maximum throughput
of the Redwood Landfill and Recycling Center, which serves the City of San Rafael, is 1,390 tons
per day. For the City's proposed ordinance, using the worst case scenario (the Boustead data)
the potential increase of 0.34 tons of solid waste per day would represent approximately
0.00024% of the daily capacity of the landfill. Thus, the existing waste disposal facilities in the
City could accommodate any indirect increases in solid waste related to the City's proposed
Ordinance. Similar to the findings in the FEIR, impacts related to solid waste would be less -
than -significant.
City of San Rafael
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EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
Table 5
Solid Waste Generation Due to Plastic and Paper Carryout Bags
Solid Waste Generation
Solid Waste Sources (tons per day)
Ecobilan Boustead
San Mateo County Ordinance 0.12 1.06
City of San Rafael Ordinance 0.04 0.34
Sources: JPA Final EIR, Section 6. 0, Alternatives, and, Utilities Calculations (see Appendix E),
Conclusion
As discussed above, impacts from the City's proposed ordinance related to air quality,
biological resources, greenhouse gases, hydrology and water quality, and utilities and service
systems were determined to have similar impacts as FEIR Alternative 4. All of these issues were
determined to result in either less -than -significant impacts or beneficial impacts. Based on the
City's determination that none of the impacts of the proposed ordinance would be significant,
no new significant environmental effects beyond those already analyzed in the FEIR would
occur.
City of San Rafael
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EXHIBIT A
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Environmental Impact Report Addendum
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EXHIBIT A
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Environmental Impact Report Addendum
California Energy Commission: Consumer Energy Center, 2010. Water Use Rates for Washing
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EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
Ecobilan. February 2004. Environmental Impact Assessment of Carrefour Bags: An Analysis of the Life
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REPORT PREPARERS
Rincon Consultants, Inc.
Joe Power, AICP CEP, Principal
Matt Maddox, AICP, MESM, Senior Program Manager
Abe Leider, AICP CEP, Senior Planner
Ryan Gardner, MESM, Sustainability Associate
City of San Rafael
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EXHIBIT A
Single Use Carryout Bag Reduction Ordinance
Environmental Impact Report Addendum
Karly Kaufman, MESM, Environmental Planner
Katie Stanulis, Production Coordinator
City of San Rafael
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