2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
UPC
2-21
Given
the
high
intensity
nature
of
proposed
Baylands
development
under
each
scenario,
and
considering
that
each
development
scenario
exceeds
ABAG’s
development
projections
for
the
Baylands,
implementation
of
mitigation
measures
for
energy
consumption
in
addition
to
implementation
of
Title
24
and
Brisbane
Municipal
Code
requirements
is
appropriate.
The
threshold
for
Impact
4.P-2
addresses
not
only
the
efficiency
of
Project
site
development’s
energy
use
(i.e.,
use
energy
in
a
wasteful
manner),
but
also
whether
Project
site
buildings
and
other
onsite
operations
would
use
“large
amounts
of
energy.”
The
intent
of
Mitigation
Measure
4.P-2a
is
to
establish
the
minimum
performance
standard
as
exceeding
the
Title
24
energy
efficiency
standards
effective
as
of
the
date
of
certification
of
the
Baylands
EIR
by
at
least
20
percent,
using
the
LEED
Gold
rating,
rather
than
the
LEED
Silver
rating
now
required
by
the
Municipal
Code,
as
one
measurement
for
achievement
of
that
standard.
A
15-20
%
increase
in
energy
efficiency
compared
to
current
Title
24
standards
is
currently
being
implemented
as
part
of
climate
action
plans
throughout
the
state
as
a
means
of
reducing
energy
consumption
and
resulting
greenhouse
gas
emissions.
Because
the
specific
standards
that
may
be
adopted
in
the
future
as
part
of
Title
24
cannot
be
known,
the
feasibility
of
exceeding
the
efficiency
of
those
future
standards
by
20
percent
also
cannot
be
known.
For
that
reason,
proposed
energy
efficiency
standards
are
tied
to
the
current
provisions
of
Title
24.
Brisbane
Baylands
Final
EIR
2.9.15-41
May
2015