Agmt21 Environmental Science Associates

Browse Search

Proposed Work Program June 2021 City of Redwood City / Gatekeeper Projects Subsequent EIR 16 environmental science associates criteria as a basis to conclude that the project would not create a significant health risk impact. ESA will collaborate with City staff to develop an appropriate project(s) for this analysis. Cl imate Change (Greenhouse Gas Emissions, Energy and Sea Level Rise) Greenhouse Gas Emissions. The DTPP Final EIR determined greenhouse gas emission impacts under the DTPP would be less than significant. The DTPP Final EIR used the BAAQMD’s project-level GHG emission efficiency metric threshold of 4.6 metric tons of CO2e per service population (future residents and full-time workers) per year to determine GHG impacts. However, this threshold only covers development through the year 2020 because it was based on the State’s 2020 target codified in Assembly Bill (AB) 32.3 To incorporate Senate Bill (SB) 32’s 2030 target into City-level planning, the City adopted its Climate Action Plan (CAP) in November 2020. The CAP focuses on reducing community-wide GHG emissions from activities within the City based on its General Plan 2030 land use forecasts and sets a target of a 50 percent reduction below 2005 levels by 2030, which is generally consistent with AB 32. The CAP also sets a long-term target of achieving carbon neutrality before 2045, which is consistent with the EO S-3-05 target of 80 percent below 1990 emission levels by 2050. CEQA Guidelines §15064(h)(3) provides that a lead agency may evaluate GHG emission impacts in the context of applicable programs and/or other regulatory schemes to reduce GHG emissions. The programmatic analysis of GHG emissions can therefore be based in part on consistency with the CAP’s GHG reduction strategies and actions as they apply to new development. However, because the CAP is based on the City’s General Plan 2030 land use forecasts and associated General Plan Final EIR, and the Gatekeeper Projects may exceed the General Plan’s citywide land use forecasts and require General Plan amendments, it is unlikely that the Gatekeeper Projects are included in the CAPs emissions forecasts, targets, and emission reduction strategies.4 Consequently, determining GHG impacts for the Gatekeeper Projects necessitates more than a consistency analysis with the CAP’s strategies and actions, as required by CEQA Guidelines §15183.5(b)(1)(B), (C), and (D). ESA will collaborate with City staff to develop an appropriate project-specific GHG threshold for the Gatekeeper Projects based on the City’s CAP and in response to recent GHG case law including Newhall Ranch and Golden Door.5 The SEIR will also evaluate GHG emission impacts with respect to consistency with the applicable regulatory plans and policies to reduce GHG emissions, including the emissions reduction measures discussed within CARB’s 2030 Climate Change Scoping Plan (2017), the BAAQMD Clean Air Plan (2017), the Metropolitan Transportation Commission Plan Bay Area 2040 (2017), and the City’s General Plan (2010). 3 The BAAQMD has not adopted thresholds beyond 2020; the most relevant legislative standard establishing a GHG reduction target beyond 2020 is Senate Bill (SB) 32, which requires a reduction of 40 percent in statewide GHG emissions from 1990 levels by 2030. 4 In addition, it is ESA’s understanding that the CAP’s emissions forecast and emission reduction measure analysis was based on the Regionally Integrated Climate Action Planning Suite (RICAPS) tool, which incorporates socioeconomic projections from the City’s 2010 General Plan and Plan Bay Area 2013, neither of which include the development proposed under the Gatekeeper Projects. 5 For example, the threshold may represent emissions per service population allowed for new development based on the City’s 2030 target and 2030 projected service population; transportation emissions may be evaluated using the City’s new VMT metric thresholds by land use type. REV: 06-23-21 MI ATTY/AGR.2021.150/Environmental Sciences Associates (Gatekeeper Projects) (Page 26 of 58)