HomeMy WebLinkAboutPlanning Commission 2011-06-26 #7CITY OF
SAN RAFAEL
FILE NO.: P11-009
AGENDA ITEM NO.: _________
Community Development Department – Planning Division
P.O. BOX 151560, SAN RAFAEL, CA 94915-1560
PHONE: (415) 485-3085/FAX: (415) 485-3184
MEETING DATE: June 14, 2011
REPORT TO PLANNING COMMISSION
SUBJECT: Greenhouse Gas Emissions Reduction Strategy; Applicant: City of San Rafael;
File No.: P11-009.
SUBMITTED BY: Robert Brown APPROVED BY: Robert Brown
(Community Development Director) Community Development Director
ISSUE
• Review the draft Greenhouse Gas Emissions Reduction Strategy
RECOMMENDATION
It is recommended that the Planning Commission raise questions and provide feedback to staff
regarding the proposed Greenhouse Gas Emissions Reduction Strategy.
BACKGROUND/ PROJECT DESCRIPTION
Why a GHG Reduction Strategy?
In 2010 the Bay Area Air Quality Management District (BAAQMD) updated their CEQA Air
Quality Guidelines for the Bay Area to include evaluation of the generation of greenhouse
gasses (GHG) from new projects. As an alternative to project-by-project GHG analysis, the
Guidelines allow the preparation and adoption of a GHG Emissions Reduction Plan to examine
emissions and reduction strategies at a community-wide level. BAAQMD encourages this
community-level approach as a more proactive means of achieving desired air quality changes.
Preparation of the GHG Emissions Reduction Plan also provided an opportunity to revisit and
recalculate the numerous programs contained in the City’s Climate Change Action Plan (CCAP)
which was adopted in April, 2009. There has been a great deal of research and evaluation of
GHG reduction strategies and best practices since preparation of the CCAP in late 2008.
The Plan would be reviewed by BAAQMD, and adopted as an appendix to the City’s Climate
Change Action Plan. An environmental assessment of the Plan could be used by future
development projects or planning documents which are consistent with the Plan to eliminate the
need for project-by-project GHG evaluation. BAAQMD requires annual reporting on progress of
implementation of Plan programs and regular monitoring of community-wide GHG levels to
assure that Plan objectives are being met. This document is expected to be updated frequently
as programs are completed, others added and emission data is refined.
The BAAQMD’s CEQA Air Quality Guidelines for preparation of a Qualified Greenhouse Gas
Reduction Strategy are attached as Exhibit 1.
ANALYSIS
REPORT TO PLANNING COMMISSION / PAGE 2 FILE NO: P11-009
2005 GHG Emissions Inventory
As part of the preparation of the City’s Climate Change Action Plan (2009), the City completed
an inventory of greenhouse gas production in San Rafael in the year 2005, both from the entire
community and from the City’s municipal operations. The protocols for doing community-scale
and municipal operation GHG reporting are being revised by ICLEI (Local Governments for
Sustainability) and should be formally adopted by the California Air Resources Board this fall.
The 2005 inventory previously prepared has been updated using what we believe will be the
adopted protocols, and shows a reduced level of community-wide GHG emissions (412,804
annual metric tons of GHG compared to the CCAP Inventory figure of 524,148 metric tons) and
somewhat different proportional contributions by the four sectors (transportation, waste,
residential buildings and commercial buildings). GHG emissions calculated from the
transportation sector were reduced from 61% to 43% due to reduced counting of pass-through
vehicular trips on the freeways. Waste emissions increased from 5% to 14%.
Previous 2005 Community GHG Emissions Revised 2005 Community GHG Emissions
GHG Emissions Projections and Reduction Target
The GHG Reduction Strategy projects future community GHG emissions due to growth in
population, housing units, jobs and vehicle miles travelled, assuming no reductions in the rate of
emissions – called the “Business as Usual” scenario. Without implementation of GHG reduction
programs, San Rafael’s GHG emissions are forecasted to increase from 2005 levels by 7.9% in
2020 and by 20% by 2035.
As part of the 2009 Climate Change Action Plan (CCAP) process, the appointed Green Ribbon
Committee recommended a community reduction goal of 25% by 2020 and 80% by 2050. The
California Air Resources Board’s AB 32 Scoping Plan recommends a 15% reduction from local
governments’ actions by 2020. The Committee’s recommended 25% reduction goal included a
15% reduction from implementing the CCAP programs and an additional 10% “stretch”
reduction from cumulative federal, state, regional and community actions.
In preparation of a Qualified Greenhouse Gas Reduction Strategy a city may include reductions
from likely state-level programs, including the Pavley vehicle fuel efficiency standards, the
Renewable Portfolio Standard mandating an increasing proportion of renewable power in
utilities’ electric power mix, updates to Title 24 building energy efficiency standards and the
California Solar Initiative rebates. In addition, the City can take credit for the GHG reductions
attributable to the Marin Energy Authority.
REPORT TO PLANNING COMMISSION / PAGE 3 FILE NO: P11-009
The following chart shows the Business-as-Usual forecast, the 2005 Baseline level from which
we measure our reduction goals, adjustments due to state-level programs, the AB-32
recommended reduction goal and our CCAP reduction goal:
Quantification of Reduction Measures
Preparation of the GHG Reduction Strategy provided an opportunity to requantify the expected
GHG reductions that are likely to result from implementation of the programs in the CCAP.
There are much more refined forecasting tools and data available today than in 2008 when
calculations were done for the CCAP. It also offered an opportunity to reexamine the wording of
each program to assure that it is written with sufficient specificity to actually produce GHG
reductions. Three additional programs were recommended for inclusion due to their sizable
GHG reduction potential (encouraging use of high albedo (reflectivity) materials, implementation
of the Resilient Businesses and Neighborhoods programs, the shift of municipal electricity
accounts to MCE’s Deep Green option by 2020 and seeking funding for conversion of
streetlights to LEDs). For each quantifiable program the Strategy lists the assumptions and
source data to justify the projected reductions.
The relative reduction benefits of the quantifiable programs are summarized in Exhibit 2.
Ability to Achieve Reduction Goals
The GHG Reduction Strategy estimates that implementation of short-term programs in the
CCAP will reduce GHG emissions by 59,336 metric tons by 2020 and 89,437 metric tons by
2035. Reductions from state programs (fuel efficiency standards, required proportion of
renewable power from utilities and increasing energy efficiency building code requirements)
would contribute a 32,527 metric ton reduction in San Rafael by 2020, and the Marin Energy
Authority will reduce emissions by an additional 26,836 metric tons. These all add up to a
reduction of 118,699 metric tons from 2005 levels by 2020.
REPORT TO PLANNING COMMISSION / PAGE 4 FILE NO: P11-009
When anticipated growth in population, vehicle trips,
buildings and waste between 2005 and 2020 are
factored in, the reduction goals must be increased
by 32,441 metric tons, to a CCAP goal of 135,642
metric tons.
The GHG Emissions Reduction Strategy
demonstrates:
That state, MEA and local actions identified in
the CCAP will exceed the State-
recommended local reduction of 15% below
2005 levels by 2020 (they would constitute
about a 21% reduction). This would enable
the GHG Emissions Reduction Strategy to
meet the requirements of BAAQMD.
That state, MEA and local actions identified in the CCAP will not meet the 25% CCAP
goal for federal, state, regional and community actions. One could conclude that there is
a need for additional federal and community actions beyond the CCAP programs to
achieve the full 25% goal.
That additional CCAP, federal, state and regional programs will be needed to meet the
State-recommended reduction target for San Rafael of 309,062 metric tons by 2035.
Monitoring
The BAAQMD guidelines require that Qualified GHG Emission Reduction Strategies must be
regularly monitored and updated to determine the level of success in meeting reduction goals
and achieving program assumptions. This will entail:
Preparation a compliance checklists for new development projects demonstrating project
compliance with the GHG Emission Reduction Strategy,
0
10,000
20,000
30,000
40,000
50,000
60,000
State
Programs
Marin Energy
Authority
CCAP
Programs San Rafael GHG Emission Reductions 2005 to 2020
REPORT TO PLANNING COMMISSION / PAGE 5 FILE NO: P11-009
Annual reports to the Planning Commission and City Council on implementation of the
GHG Emission Reduction Strategy, and
Updates of the local GHG emissions inventory for both the community and municipal
operations every five years (due for completion at the end of 2011 for year 2010 emission
levels).
It is expected that the CCAP and the Qualified GHG Emission Reduction Strategy will be
dynamic documents which are frequently updated to reflect accomplishment of existing
programs, modification of programs as needed and inclusion of additional programs to achieve
reduction goals. As part of our consultant contract the City has been provided with a detailed
Excel database which will allow the input of data changes to recalculate emissions into the
future.
Adoption
It is proposed that the GHG Emission Reduction Strategy be adopted as Appendix E of the
City’s Climate Change Action Plan. A CEQA analysis of the Reduction Strategy has been
prepared as part of an Addendum to the General Plan 2020 EIR, which would be used as a
tiering document for future development projects.
A copy of the Draft GHG Emission Reduction Strategy has been sent to BAAQMD for their
review and comments.
EXHIBITS
1. BAAQMD CEQA Air Quality Guidelines for preparation of a Qualified Greenhouse Gas
Emissions Reduction Strategy
2. Anticipated GHG Reductions of CCAP Programs
REPORT TO PLANNING COMMISSION / PAGE 6 FILE NO: P11-009
EXHIBIT 1
Bay Area Air Quality Management District CEQA Air Quality Guidelines (May 2011)
4.3. GREENHOUSE GAS REDUCTION STRATEGIES
The Air District encourages local governments to adopt a qualified GHG Reduction Strategy that is
consistent with AB 32 goals. If a project is consistent with an adopted qualified GHG Reduction Strategy
that meets the standards laid out below, it can be presumed that the project will not have significant GHG
emission impacts. This approach is consistent with the State CEQA Guidelines, Section 15183.5 (see text
in box below).
§15183.5. Tiering and Streamlining the Analysis of Greenhouse Gas Emissions.
(a) Lead agencies may analyze and mitigate the significant effects of greenhouse gas emissions at a
programmatic level, such as in a general plan, a long range development plan, or a separate plan to
reduce greenhouse gas emissions. Later project-specific environmental documents may tier from
and/or incorporate by reference that existing programmatic review. Project-specific environmental
documents may rely on an EIR containing a programmatic analysis of greenhouse gas emissions as
provided in section 15152 (tiering), 15167 (staged EIRs) 15168 (program EIRs), 15175-15179.5
(Master EIRs), 15182 (EIRs Prepared for Specific Plans), and 15183 (EIRs Prepared for General
Plans, Community Plans, or Zoning).
(b) Plans for the Reduction of Greenhouse Gas Emissions. Public agencies may choose to analyze and
mitigate significant greenhouse gas emissions in a plan for the reduction of greenhouse gas
emissions or similar document. A plan to reduce greenhouse gas emissions may be used in a
cumulative impacts analysis as set forth below. Pursuant to sections 15064(h)(3) and 15130(d), a
lead agency may determine that a project’s incremental contribution to a cumulative effect is not
cumulatively considerable if the project complies with the requirements in a previously adopted plan
or mitigation program under specified circumstances.
(1) Plan Elements. A plan for the reduction of greenhouse gas emissions should:
(A) Quantify greenhouse gas emissions, both existing and projected over a specified time period,
resulting from activities within a defined geographic area;
(B) Establish a level, based on substantial evidence, below which the contribution to greenhouse
gas emissions from activities covered by the plan would not be cumulatively considerable;
(C) Identify and analyze the greenhouse gas emissions resulting from specific actions or
categories of actions anticipated within the geographic area;
(D) Specify measures or a group of measures, including performance standards, that substantial
evidence demonstrates, if implemented on a project-by-project basis, would collectively
achieve the specified emissions level;
(E) Establish a mechanism to monitor the plan’s progress toward achieving the level and to
require amendment if the plan is not achieving specified levels;
(F) Be adopted in a public process following environmental review
(2) Use with Later Activities. A plan for the reduction of greenhouse gas emissions, once adopted
following certification of an EIR or adoption of an environmental document, may be used in the
cumulative impacts analysis of later projects. An environmental document that relies on a
greenhouse gas reduction plan for a cumulative impacts analysis must identify those
requirements specified in the plan that apply to the project, and, if those requirements are not
otherwise binding and enforceable, incorporate those requirements as mitigation measures
applicable to the project. If there is substantial evidence that the effects of a particular project
may be cumulatively considerable notwithstanding the project’s compliance with the specified
requirements in the plan for the reduction of greenhouse gas emissions, an EIR must be
prepared for the project.
Standard Elements of a GHG Reduction Strategy
The Air District recommends the Plan Elements in the state CEQA Guidelines as the minimum standard
to meet the GHG Reduction Strategy Thresholds of Significance option. A GHG Reduction Strategy may
be one single plan, such as a general plan or climate action plan, or could be comprised of a collection of
climate action policies, ordinances and programs that have been legislatively adopted by a local
jurisdiction. The GHG Reduction Strategy should identify goals, policies and implementation measures
REPORT TO PLANNING COMMISSION / PAGE 7 FILE NO: P11-009
that would achieve AB 32 goals for the entire community. Plans with horizon years beyond 2020 should
consider continuing the downward reduction path set by AB 32 and move toward climate stabilization
goals established in Executive Order S-3-05. Assessing and Mitigating Operational-Related Impacts
Bay Area Air Quality Management District Page | 4-9 CEQA Guidelines Updated May 2011
To meet this threshold of significance, a GHG Reduction Strategy must include the following elements
(corresponding to the State CEQA Guidelines Plan Elements):
(A) Quantify greenhouse gas emissions, both existing and projected over a specified time period,
resulting from activities within a defined geographic area.
A GHG Reduction Strategy must include an emissions inventory that quantifies an existing baseline level
of emissions and projected GHG emissions from a business-as-usual, no-plan, forecast scenario of the
horizon year. The baseline year is based on the existing growth pattern defined by an existing general
plan. The projected GHG emissions are based on the emissions from the existing growth pattern or
general plan through to 2020, and if different, the year used for the forecast. If the forecast year is beyond
2020, BAAQMD recommends also doing a forecast for 2020 to establish a trend. The forecast does not
include new growth estimates based on a new or draft general plan.
When conducting the baseline emissions inventory and forecast, ARB‘s business-as-usual 2020
forecasting methodology should be followed to the extent possible, including the following recommended
methodology and assumptions:
• The baseline inventory should include one complete calendar year of data for 2008 or earlier. CO2
must be inventoried across all sectors (residential, commercial, industrial, transportation and waste at
a minimum); accounting of CH4, N20, SF6, HFC and PFC emission sources can also be included
where reliable estimation methodologies and data are available.
• Business-as-usual emissions are projected in the absence of any policies or actions that would
reduce emissions. The forecast should include only adopted and funded projects.
• The business-as-usual forecast should project emissions from the baseline year using growth factors
specific to each of the different economic sectors.
BAAQMD‘s GHG Plan Level Quantification Guidance contains detailed recommendations for developing
GHG emission inventories and projections and for quantifying emission reductions from policies and
mitigation measures. This document is available at BAAQMD‘s website,
http://www.baaqmd.gov/Divisions/Planning-and-Research/CEQA-GUIDELINES.aspx.
(B) Establish a level, based on substantial evidence, below which the contribution to GHG
emissions from activities covered by the plan would not be cumulatively considerable.
A GHG Reduction Strategy must establish a target that is adopted by legislation that meets or exceeds
one of the following options, all based on AB 32 goals:
• Reduce emissions to 1990 level by 20201
• Reduce emissions 15 percent below baseline (2008 or earlier) emission level by 20202
• Meet the plan efficiency threshold of 6.6 MT CO2e/service population/year
If the target year for a GHG reduction goal exceeds 2020, then the GHG emission reduction target should
be in line with the goals outlined in Executive Order S-3-05, and also include an interim goal for 2020.
(C) Identify and analyze the GHG emissions resulting from specific actions or categories of
actions anticipated within the geographic area.
REPORT TO PLANNING COMMISSION / PAGE 8 FILE NO: P11-009
A Strategy should identify and analyze GHG reductions from anticipated actions in order to understand
the amount of reductions needed to meet its target. Anticipated actions refer to local and state policies
and regulations that may be planned or adopted but not implemented. For example, ARB‘s Scoping Plan
contains a number of measures that are planned but not yet implemented. BAAQMD recommends for the
Strategy to include an additional forecast analyzing anticipated actions. Element (C), together with (A), is
meant to identify the scope of GHG emissions to be reduced through Element (D).
(D) Specify measures or a group of measures, including performance standards that substantial
evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve
the specified emissions level.
The GHG Reduction Strategy should include mandatory and enforceable measures that impact new
development projects, such as mandatory energy efficiency standards, density requirements,
transportation demand management policies, etc., as well as existing development. These measures may
exist in codes or other policies and may be included in the Strategy by reference.
The GHG Reduction Strategy should include quantification of expected GHG reductions from each
identified measure or categories of measures (such as residential energy efficiency measures,
bike/pedestrian measures, recycling measures, etc.), including disclosure of calculation methods and
assumptions. Quantification should reflect annual GHG reductions and demonstrate how the GHG
reduction target will be met. The Strategy should specify which measures apply to new development
projects. For assistance in quantifying potential GHG reductions from different mitigation measures, Lead
Agencies may refer to CAPCOA‘s report, Quantifying Greenhouse Gas Mitigation Measures.
(E) Monitor the plan’s progress
To ensure that all new development projects are incorporating all applicable measures contained within
the GHG Reduction Strategy, the Strategy should include an Implementation Plan containing the
following:
• Identification of which measures apply to new development projects vs. existing development,
discerning between voluntary and mandatory measures.
• Mechanism for reviewing and determining if all applicable mandatory and voluntary measures are
being adequately applied to new development projects.
• Identification of implementation steps and parties responsible for ensuring implementation of each
action.
• Schedule of implementation identifying near-term and longer-term implementation steps.
• Procedures for monitoring and updating the GHG inventory and reduction measures every 3-5 years
before 2020.
• Annual review and reporting to the jurisdiction‘s governing body on the progress of implementation of
individual measures, including assessment of how new development projects have been
incorporating Strategy measures. Review should also include an assessment of the implementation
of Scoping Plan measures in order to determine if adjustments to local Strategy must be made to
account for any shortfalls in Scoping Plan implementation.
(F) Adopt the GHG Reduction Strategy in a public process following environmental review
A GHG Reduction Strategy should undergo an environmental review which may include a negative
declaration or EIR.
If the GHG Reduction Strategy consists of a number of different elements, such as a general plan, a
climate action plan and/or separate codes, ordinances and policies, each element that is applicable to
REPORT TO PLANNING COMMISSION / PAGE 9 FILE NO: P11-009
new development projects would have to complete an environmental review in order to allow tiering for
new development projects.
REPORT TO PLANNING COMMISSION / PAGE 10 FILE NO: P11-009
EXHIBIT 2
CCAP Program
Proportion of 2020
GHG Reduction
Zero Waste 39.60%
Marin Clean Energy 31.50%
Resilient Neighborhoods 15.90%
Green Building Ordinance 4.40%
Energy Efficiency Financing 3.70%
Bike and Pedestrian Master Plan 1.60%
Transit Oriented Development 0.70%
City Electricity - MEA 0.70%
City Employee Commute Incentives 0.40%
SMART 0.20%
Safe Routes to School 0.20%
Alternative and Fuel Efficient Vehicles 0.20%
Energy Efficiency Outreach 0.20%
City Streetlights & Traffic Signals 0.20%
Bike Sharing 0.10%
Provide Affordable Housing 0.10%
City Facility Energy Audits/Upgrades 0.10%
Transit Service 0.00%
Increase Tree Plantings 0.00%
City Environmental Purchasing Policy 0.00%
City 4th Street Tree Lights 0.00%
City Alternative Fuel Vehicles 0.00%