2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
constructed
in
accordance
with
industry
practices
and
the
performance
standards
set
forth
in
current
California
Building
Code
requirements.
See
5
for
discussion
regarding
compliance
with
the
law
as
mitigation
under
CEQA.
The
BAAQMD
CEQA
website
now
identifies
CalEEMod
as
the
model
to
be
used
in
CEQA
analysis
as
of
August
5,
2013.
The
Draft
EIR
was
published
in
June
of
2013
prior
to
the
release
of
the
updated
version
of
CalEEMod
and
the
BAAQMD’s
specification.
The
Final
EIR
now
includes
an
updated
estimation
of
Project
Site
development-related
GHG
emissions
based
on
the
latest
version
of
the
CalEEMod
model.
The
updated
emission
inventory
is
provided
as
a
text
revision
in
Section
4.F,
Greenhouse
Gas
Emissions
.
GHG
emissions
under
the
CPP
and
CPP-V
scenarios
evaluated
based
on
the
latest
version
of
the
CalEEMod
model
are
estimated
to
be
3.2
metric
tons
per
year
per
service
population,
and
are
below
the
GHG
significance
threshold.
Consequently,
the
CPP
and
CPP-V
scenarios
would
have
a
less
than
significant
impact
with
regard
to
GHG
emissions.
The
data
presented
in
pages
4.F-4
and
4.F-5
of
the
Draft
EIR
are
intended
to
provide
the
existing
setting
information
relative
to
GHGs,
i.e.,
existing
conditions
on
the
project
site.
Presentation
of
this
data
does
not
restrict
the
City’s
ability
to
require
mitigation
measures
consistent
with
CEQA.
GHG
emissions
from
manufacturing
and
transport
of
goods
are
considered
life-
cycle
emissions.
Although
there
is
no
regulatory
definition
for
“lifecycle
emissions,”
the
term
is
generally
used
to
refer
to
all
emissions
associated
with
the
creation
and
existence
of
a
project,
including
emissions
from
the
manufacture
and
transportation
of
component
materials,
and
even
emissions
from
the
manufacture
of
the
machines
required
to
produce
those
materials.
However,
since
it
is
impossible
to
accurately
estimate
the
entire
chain
of
emissions
associated
with
any
given
project,
lifecycle
analyses
are
not
required
under
CEQA
10
.
In
December
2009,
the
California
Natural
Resources
Agency
(CNRA)
issued
new
energy
conservation
guidelines
for
EIRs
that
make
no
reference
to
lifecycle
emissions
11
.
CNRA
explained
that:
(1)
there
exists
no
standard
regulatory
definition
for
lifecycle
emissions,
and
(2)
even
if
a
standard
definition
for
‘lifecycle’
existed,
the
term
might
be
interpreted
to
refer
to
emissions
“beyond
those
that
could
be
considered
‘indirect
effects’”
as
defined
by
CEQA
10
California
Natural
Resources
Agency,
2009.
Final
Statement
of
Reasons
for
Regulatory
Action:
Amendments
to
the
State
CEQA
Guidelines
Addressing
Analysis
and
Mitigation
of
Greenhouse
Gas
Emissions
Pursuant
to
SB97
,
pp.
71
72.
http://ceres.ca.gov/ceqa/docs/Final_Statement_of_Reasons.pdf,
accessed
February
4,
2010.
11
State
CEQA
Guidelines,
Appendix
F.
These
new
guidelines
were
part
of
amendments
issued
pursuant
to
SB97.
A
copy
of
this
document
is
available
for
public
review
at
the
San
Francisco
Planning
Department,
1650
Mission
Street,
Suite
400,
in
Case
File
No.
2007.0903E.
Brisbane
Baylands
Final
EIR
2.9.2-77
May
2015