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Proposed Work Program <br />June 2021 City of Redwood City / Transit District Subsequent EIR 15 <br />Environmental science associates <br />REV: 06-22-21 MI <br />included in the CAPs emissions forecasts, targets, and emission reduction strategies.2 Consequently, <br />determining GHG impacts for the Transit District necessitates more than a consistency analysis with the CAP’s <br />strategies and actions, as required by CEQA Guidelines §15183.5(b)(1)(B), (C), and (D). <br />ESA will collaborate with City staff to develop an appropriate project-specific GHG threshold for the Transit <br />District based on the City’s CAP and in response to recent GHG case law including Newhall Ranch and Golden <br />Door.3 The SEIR will also evaluate GHG emission impacts with respect to consistency with the applicable <br />regulatory plans and policies to reduce GHG emissions, including the emissions reduction measures discussed <br />within CARB’s 2030 Climate Change Scoping Plan (2017), the BAAQMD Clean Air Plan (2017), the Metropolitan <br />Transportation Commission Plan Bay Area 2040 (2017), and the City’s General Plan (2010). <br />If applicable, ESA will identify feasible measures to mitigate any adverse impacts on climate based on <br />professional standards and on requirements of the CAP, the BAAQMD, and the City’s General Plan policies. <br />Energy. In December 2018, the California Natural Resources Agency made changes to the CEQA Guidelines, <br />reflecting recent case law in providing new guidance for analyzing a project’s impacts related to energy <br />consumption. <br />A description of the energy resources available in the project area and greater Bay Area will be described, in <br />addition to the regulatory context for energy resources in the Bay Area. Federal and State regulations relative <br />to energy resources and energy efficiency that would be applicable to the plans will also be described. ESA will <br />discuss environmental setting in terms of the current fuel and electricity use in the region based on annual <br />California Energy Commission fuel and electricity consumption data. Potential energy consumption from <br />implementation of the Transit District, including any renewable energy resource features, will be discussed <br />qualitatively, as well as a determination would have the potential to result in wasteful, inefficient, or <br />unnecessary consumption of energy resources, during project construction and operation and whether they <br />could conflict with or obstruct a state or local plan for renewable energy or energy efficiency. <br />Sea Level Rise. The DTPP Final EIR identified potential flooding due to sea level rise as a potentially significant <br />impact. However, California Supreme Court’s decision in California Building Industry Association (CBIA) v. Bay <br />Area Air Quality Management District (2015) confirmed that CEQA, with several certain exceptions, is <br />concerned with the impacts of a project on the environment, not the effects the existing environment may have <br />on a project. Consequently, the sea level rise assessment in the SEIR will focus on whether the Transit District <br />project may exacerbate sea level rise. On-going citywide and regional planning efforts addressing sea level rise <br />will also be discussed in the SEIR. <br />Hazards and Hazardous Materials <br />The DTPP Final EIR determined potential impacts to hazards and hazardous under the DTPP would be less than <br />significant. <br />2 In addition, it is ESA’s understanding that the CAP’s emissions forecast and emission reduction measure analysis <br />was based on the Regionally Integrated Climate Action Planning Suite (RICAPS) tool, which incorporates <br />socioeconomic projections from the City’s 2010 General Plan and Plan Bay Area 2013, neither of which include the <br />development proposed under the Transit District. <br />3 For example, the threshold may represent emissions per service population allowed for new development based <br />on the City’s 2030 target and 2030 projected service population; transportation emissions may be evaluated using <br />the City’s new VMT metric thresholds by land use type. <br />ATTY/AGR.2021.149/ESA (Transit District CEQA) (Page 25 of 26)