2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
analyses
in
Section
4.P
include:
PG&E
Rule
20A;
Title
13
CCR
Section
2485;
Title
24
CCR;
and
Brisbane
Municipal
Code
Section
15.80.
The
term
“lifecycle”
in
the
context
of
resource
use
and
environmental
impacts
is
generally
used
to
refer
to
all
resource
use
and
emissions
associated
with
the
creation
and
existence
of
a
project,
including
resource
use
and
emissions
from
the
manufacture
and
transportation
of
component
materials
(referred
to
as
embodied
energy),
and
even
the
resource
use
and
emissions
from
the
manufacture
of
machines
required
to
produce
those
materials.
Prior
to
2009,
this
term
was
used
in
the
guidelines
for
preparing
energy
conservation
analyses
under
CEQA
(contained
in
Appendix
F
of
the
CEQA
Guidelines).
In
2009,
the
California
Natural
Resources
Agency
(CNRA)
issued
new
energy
conservation
guidelines
in
Appendix
F.
In
its
statement
of
reasons
for
amending
these
guidelines,
CNRA
stated
that
lifecycle
analyses
are
not
required
under
CEQA
for
multiple
reasons
(CNRA,
2009).
CEQA
requires
analysis
of
impacts
that
are
directly
or
indirectly
attributable
to
the
project
under
consideration.
In
some
instances,
materials
may
be
manufactured
for
many
different
projects
as
a
result
of
general
market
demand,
regardless
of
whether
one
particular
project
proceeds,
and
different
manufacturers
may
use
different
processes
and
materials
or
change
processes
and
materials
over
time.
Similarly,
a
lead
agency
may
not
be
able
to
require
mitigation
for
impacts
that
result
from
offsite
manufacturing
processes.
For
these
reasons,
an
analysis
of
lifecycle
energy
consumption
is
not
included
in
the
Draft
EIR.
This
comment
correctly
notes
that
a
substantial
increase
in
onsite
electrical
demand
(and
related
CO
2
emissions)
will
result
from
proposed
Baylands
development.
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
proposed
development,
and
provide
for
analysis
and
mitigation
of
numerous
smaller
development
projects,
BAAQMD
identified
the
service
population
6
-
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.
6
“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.
Brisbane
Baylands
Final
EIR
2.9.3-124
May
2015