2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
Guidelines,
and
therefore,
beyond
what
an
EIR
is
required
to
estimate
and
for
which
mitigation
can
be
proposed.
The
data
presented
in
pages
4.F-7
of
the
Draft
EIR
present
the
existing
GHG
regulatory
background
relative
to
CEQA.
The
quoted
text
in
the
comment
is
directly
from
CEQA
Guidelines
Section
15064(h)(3).
A
previously
approved
plan
or
mitigation
program
could
consist
of
the
State
of
California’s
Climate
Change
Scoping
Plan.
Pursuant
to
AB
32,
the
CARB
adopted
a
Climate
Change
Scoping
Plan
in
December
2008.
Such
a
Plan
may
also
include
a
local
Climate
Action
Plan.
Currently,
the
City
of
Brisbane
has
not
adopted
a
local
Climate
Action
Plan.
Consistency
with
the
Climate
Change
Scoping
Plan
is
assessed
in
Impact
4.F-2
of
the
Draft
EIR,
which
identified
a
less
than
significant
impact
with
regard
to
consistency
with
the
state
Scoping
Plan
for
scenarios
DSP
and
DSP-V
and
a
significant
impact
with
regard
to
scenarios
CPP
and
CPP-V.
The
Final
EIR
now
includes
an
updated
estimation
of
Project
Site
development-
related
GHG
emissions
based
on
the
latest
version
of
the
CalEEMod
model,
which
was
not
available
at
the
time
of
Draft
EIR
publication.
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
below
the
GHG
significance
threshold.
Consequently,
the
CPP
and
CPP-V
scenarios
would
not
only
have
a
less
than
significant
impact
with
regard
to
GHG
emissions
but
also
would
be
consistent
with
the
AB32
and
the
state
Scoping
Plan
because
the
GHG
efficiency
metrics
were
developed
for
the
emissions
rates
at
the
state
level
for
the
land
use
sector
that
would
accommodate
projected
growth
(as
indicated
by
population
and
employment
growth)
under
trend
forecast
conditions,
and
the
emission
rates
needed
to
accommodate
growth
while
allowing
for
consistency
with
the
goals
of
AB
32
(i.e.,
1990
GHG
emissions
levels
by
2020)
(BAAQMD,
2009).
As
a
result,
all
four
scenarios
would
not
impair
attainment
of
GHG
reduction
goals
established
pursuant
to
AB
32
in
the
Climate
Change
Scoping
Plan
.
BAAQMD
thresholds
were
crafted
in
a
manner
that
defined
a
project’s
emissions
significant
if
the
Project
Site
development
would
emit
GHG
in
excess
of
the
level
needed
to
facilitate
achievement
of
AB
32
goals.
The
BAAQMD
has
identified
a
potential
bright-line
threshold
of
1,100
metric
tons
per
year
of
CO2e
as
discussed
on
page
4.F-12
of
the
Draft
EIR.
As
a
practical
matter,
this
threshold
is
relatively
stringent
and
is
exceeded
by
most
development
projects
of
more
than
500
residential
units
or
100,000
square
feet
of
retail
or
350,000
square
feet
of
office.
In
an
effort
to
encourage
mixed-use
development,
focus
on
the
efficiency
of
Brisbane
Baylands
Final
EIR
2.9.2-78
May
2015