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225 Bush Street Suite 1700 San Francisco, CA94104 ATTACHMENT 1 415.896.5900 nhc H- 415.896.0332 + memorandum date September 27, 2010 to Laura Ryan, Daniel Smith, City of Pleasanton from Dan Sicular, Jeff Caton, ESA subject City of Pleasanton Climate Action Plan, CAP Format, Approach, and Content This memo outlines ESA's recommendation for the format, approach, and content of the City of Pleasanton Climate Action Plan (CAP), based on our knowledge of State policy, CAP best practices, and our review of existing CAPs produced by other Bay Area cities. The CAP has two primary purposes: fulfilling the terns of the Final Settlement Agreement; and providing a framework both for reducing greenhouse gas (GHG) emissions in the City and for adapting to climate change. Other goals and requirements include compliance with the requirements of a BAAQMD "qualified CAP" for the purposes of CEQA streamlining, and incorporating State policy for GHG reduction, as expressed in AB 32 and elsewhere, into City policy. Finally, the process of developing the CAP is intended to engage a broad range of stakeholders representing various interests in the Pleasanton community in understanding climate change, how it is likely to affect our region and the world, and how to address it effectively at the local level. The CAP is a planning document that will establish City policies regarding climate action, and that will lay out a path to implementing these policies. Policies will take the form of overall plan goals, specific objectives, and particular strategies for achieving the goals and objectives. Per the Final Settlement Agreement, CAP policies will be incorporated into the City's General Plan; both the CAP itself and the General Plan amendment will undergo CEQA review prior to adoption. Over a dozen Bay Area communities have already prepared CAPs, as have many more communities throughout California. In the absence of specific State requirements or guidelines for CAPs, individual jurisdictions have been free to select a format for their own CAP, and tailor CAP goals, objectives, methods for program evaluation, and degree of specificity in program description and projected effectiveness, to their own purposes and means. In June, 2010, the Bay Area Air Quality Management District (BAAQMD) established in its new CEQA Guidelines minimum standards for a "qualified" CAP. Projects undergoing CEQA review that are consistent with a qualified CAP arc considered to have less - than - significant greenhouse gas (GHG) emissions. In its recent review of the City of Dublin's CAP, BAAQMD identified several aspects that do not comply with its standards for a qualified CAP. In particular, BAAQMD informed the City of Dublin that it had excluded certain emissions sources (most notably, water and wastewater - related emissions), had not adequately forecasted emissions and developed a reduction target for 2020, and had not provided sufficiently transparent and verifiable calculations for proposed emission reduction measures. We interpret the BAAQMD review as an indication that the District plans to scrutinize CAPs vis -a -vis its new guidelines, and that it is prepared to take on a more general role as the regulatory oversight agency tasked with determining the adequacy of CAPS.