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City of Pleasanton <br /> CEQA GHG Emissions Thresholds and Guidance <br /> directly tied to the population and employment growth anticipated by the Regional Metropolitan <br /> Planning Organization,the Association of Bay Area Governments(ABAG) and in alignment with the <br /> Pleasanton 2005-2025 General Plan Land Use/Community Character and Housing Elements as well <br /> as to the City-specific GHG emission reduction measures that the City has proposed to reduce <br /> communitywide and per capita emissions. In addition,the magnitude of local GHG emission <br /> reduction achieved by State legislation/policies(i.e.,vehicle fuel efficiency standards,the <br /> Renewable Portfolio Standard [RPS], and Title 24)was estimated based on City-specific growth and <br /> vehicle miles travelled (VMT)forecasts. As a result,these locally appropriate thresholds directly <br /> address the concerns raised in the Golden Door Properties, LLC v. County of San Diego/Sierra Club, <br /> LLC v. County of San Diego(2018) case, because they are based on local GHG emissions data rather <br /> than Statewide GHG emissions data. <br /> Disaggregation of Existing versus New Development <br /> For the City of Pleasanton,a GHG threshold disaggregated between new and existing development <br /> places a disproportionately high emphasis on emissions reduction from existing development,given <br /> the proposed CAP measures.This necessitated applying the emissions reduction across both new <br /> development and measures impacting existing development to produce per capita GHG thresholds. <br /> CAP-adjusted emissions for existing and new development were combined to create <br /> communitywide GHG emissions thresholds.This approach is more conservative than disaggregating <br /> by new versus existing development as it accounts for the relative ease for new development to be <br /> decarbonized and builds in some buffer for emissions reduction required of existing development to <br /> achieve CAP 2.0 reductions.Therefore,these thresholds directly address the concerns raised in the <br /> Center for Biological Diversity v. California Department of Fish and Wildlife(2015)case regarding the <br /> different rates of GHG emissions reduction anticipated for new development as compared to <br /> existing development in order to meet the specified GHG reduction target. <br /> Selection of Sector-Specific Thresholds <br /> The quantitative thresholds are separated into three categories—residential, non-residential, and <br /> mixed-use—which are intended to apply to the three main types of development projects in <br /> Pleasanton.These thresholds were calculated by disaggregating the City's business-as-usual GHG <br /> emissions forecasts for residential and non-residential development.The emissions reduction <br /> specific to residential and non-residential development achieved by State legislation/policies and <br /> the CAP 2.0 were then subtracted from the business-as-usual forecast to determine "caps"of <br /> emissions for new residential and new non-residential development for year 2030.These emissions <br /> "caps"were then divided by the numbers of residents and employees forecast for the year 2030 to <br /> determine efficiency thresholds for residential and non-residential projects, respectively. For mixed- <br /> use development,the residential and non-residential emissions"caps"were summed,then divided <br /> by the service population forecast for 2030 to determine an efficiency threshold for mixed-use <br /> projects.As a result,these project-specific thresholds directly address the concerns raised in the <br /> Center for Biological Diversity v. California Department of Fish and Wildlife(2015) case, because <br /> they are specific to each development project type. <br /> Adoption via Public Review Process <br /> In compliance with CEQA Guidelines Section 15064.7(b),this guidance document and the <br /> quantitative thresholds contained herein will be presented to the City Council for formal adoption <br /> via resolution through a public review process,which will include an opportunity for public input. <br /> The public review process for these City of Pleasanton CEQA GHG Thresholds and Guidance will <br /> 30 <br />