proposed development, and provide for analysis and mitigation of numerous smaller development projects, BAAQMD identified the service population12-based efficiency threshold used in this analysis, which is more applicable to assessing the impacts of a Specific Plan. BAAQMD indicates its intent to have the efficiency threshold apply to Specific Plans in Table 2-5, Thresholds of Significance for Plans, in its 2011 CEQA Air Quality Guidelines, which specifically states that specific plans should use the project-level threshold of 4.6 CO2e per service population per year.

BCC-207

[See page 5-203 for the original comment] The differences in GHG emissions between the four scenarios are explained on Draft EIR page 4.F-19, which immediately follows Table 4.F-2. As described on Draft EIR page 4.F-19, the difference between the number of trips in the CPP/CPP-V scenarios and the DSP/DSP-V scenarios is primarily a function of the types of land uses proposed for the Baylands site under each scenario. The following cross reference to Draft EIR Chapter 4.N, Traffic and Circulation, has been added to the discussion of the differences in GHG emissions on Draft EIR page 4.F-19:

The CPP and CPP-V scenarios would produce between 1 and 25 percent more GHG emissions than the DSP and DSP-V scenarios. The primary reason for this difference in impact is that the number of vehicle trips generated by the CPP and CPP-V scenarios is predicted to be 81 and 72 percent greater than the number generated by the DSP and DSP-V scenarios, respectively. The methodology used to determine vehicle trips generated by each scenario is described starting on page 4.N-72 of this Draft EIR. The larger number of vehicle trips occurring in the CPP and CPP-V scenarios results from the physical separation between onsite employment opportunities and offsite housing for Project Site employees.

See Master Response 25 for a discussion of the linkage between jobs and housing and how that linkage affects traffic and vehicles miles travelled, including related air pollutant and GHG emissions.

BCC-208

[See page 5-203 for the original comment] The ICLEI model is a tool used for inventorying community-wide GHG emissions and is used primarily for the purposes of developing Climate Action Plans. The BAAQMD now identifies CalEEMod as the model to be used in CEQA analyses of GHG emissions 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.

 


12 “Service Population” (SP) is an efficiency-based measure used by BAAQMD to estimate the development potential of a general or area plan. SP is determined by adding the number of residents to the number of jobs estimated for a given point in time.

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