3.0 Responses to Comments
by CARBs Scoping Plan. 9 The methodology and threshold applied in the GHG analysis of the Proposed Alternative was revised and recirculated in the RP-DEIR on May 31st, 2012. See Section 2.B of the RP-DEIR for the revised analysis of GHG impacts, as well as Corrections and Additions to revisions to the RP-DEIR. 27-52 The comment states that the Original DEIR misuses the rational under which circumstances a categorical exemption could be applied as advanced by the California Air Pollution Control Officers Association’s (CAPCOA) CEQA and Climate Change guidance document. The comment is taken under consideration and while Page 16-12 of the Original DEIR accurately states CAPCOA’s language, the comment is correct in that the Original DEIR mistakenly applied the Categorical Exemption criteria to the Proposed Alternative. The Original DEIR stated that it adopted a “zero-emission” threshold in evaluating the Proposed Alternative’s GHG impacts. A “zero-emission” threshold is based on a determination that any degree of project-related increase in GHG emissions would contribute considerably to climate change and therefore would be a significant impact. In applying this approach, a lead agency needs to demonstrate that a project can fully mitigate all increases in GHG emissions so as not to result in a significant impact on climate change. After further consideration, it was determined that the consequences of this approach would have costly and impractical implications. Given this, it was decided to pursue a combined quantitative and qualitative approach that represents the best available option in accommodating future development while taking vigorous action to reduce GHG emissions. The methodology and threshold applied in the GHG analysis of the Proposed Alternative was revised and recirculated in the RP-DEIR on May 31st, 2012. See Section 2.B of the RP-DEIR for the revised analysis of GHG impacts. 27-53 The comment states that quantification of GHG emissions was no included in the Original DEIR. See Response to Comment 27-51 and Section 2.B of the RP-DEIR for the revised quantification of GHG impacts. 27-54 The comment states that the Original DEIR did not follow GHG impact evaluation guidance available at the time of preparation and refers to guidance published by the Attorney General’s Office, SCAQMD and CARB. While guidance has been available as to methodology in calculating greenhouse gas emissions, no agency with jurisdiction in Southern California has adopted a specific GHG threshold necessary in determining a significant impact. 10 In October of 2008, SCAQMD released the Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold. The Draft Guidance Document discusses a tiered threshold approach discussed below. Currently, the Attorney General’s website refers to the CAPCOA CEQA and Climate Change guidance document. 11 9
CARB Scoping Plan
10
The South Coast Air Quality Management District has formed a GHG Significance Threshold Working Group. More information on this Working Group is available at www.aqmd.gov/ceqa/handbook/GHG/GHG.html.
11
The Office of the Attorney General website http://oag.ca.gov/environment/ceqa/measures (accessed on 0629/12)
Cornfield Arroyo Seco Specific Plan FEIR
3-45