11 ATTACHMENTS 6 TO 13 - Laserfiche WebLink

Planning Commission September 22, 2010 Page 3 This brings in all the transaction costs, uncertainty, need for expertise, time delay, and bureaucratic wrangling of the old points systems, for a far smaller window of increased excellence in green building construction. More accurately, no increase in green building excellence as shown by the Staff analysis of CalGreen Tier 1 compared to the LEED system, and Build It Green system showing CalGreen Tier 1 exceeds the minimum points required under both point systems. The Problem with Maintaining Separate Local Regulatory Systems The real efficacy of locally maintained systems of standards is questionable. While statewide training classes will be readily available on CalGreen standards, there won't be statewide training, expertise, and experience to draw upon for the evolution of our unique local standards. In fact, the assignment of point equivalence between the unique local point system may not necessarily keep up with the real green sustainability of the CalGreen Tier 1 approach, which will now evolve in synch with the rising CalGreen basic standards. For the City Staff, maintaining a parallel local green points system will be like fighting a two front war, soon followed by neglected and irrational green requirements. In fact, local standards are already subject to erratic and irrational political outcomes, as politicians vie to out -green each other at the expense of applicants, such as what happened with the Raney project in downtown Pleasanton. When the Raney project came to City Council, Councilmember McGovern suggested that striving to obtain a good green score is not enough, and moved to make a "green" score of 105 points mandatory for this project. Her motion was approved by a well meaning City Council (Condition 25 of PUD -72). For a smorgasbord system like Build It Green, the whole system is built around getting to 50 points, so getting to 105 points amounts to doing every conceivable green thing possible, at astronomical cost. In response to similar local nonsense from the City of Santa Rosa, the Build It Green governing body wrote the letter attached to the City of Santa Rosa explaining that super numerical requirements are not consistent with the intent of the regulatory scheme. CEQA Does Not Require Inefficiency While matching the minimum points required by LEEDS and Build it Green, CalGreen Tier 1 falls short within particular categories analyzed by Staff. Staff apparently assumes that any reduction in points under any one of our local green categories creates a significant environmental impact that must be mitigated. But if the total points are satisfactory under CalGreen Tier 1, then that is the mitigation, and the change to a better designed set of standards would not be a significant impact. Moreover, the internal inconsistencies of these point systems are a bad joke among builders, who point out, for example, that the system requires use of fly ash to minimize use of cement, while requiring storm drain systems that use substantially more concrete than standard building practices. CEQA gives the City discretion to adopt a single coherent green building system like CalGreen Tier 1, and not be locked into the Rube