HomeMy WebLinkAbout8/18/2020 Item 15, Mansoor
T 805.781.5912 F 805.781.1002 W slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401
Via Email
August 18, 2020
Chris Read
City of San Luis Obispo
919 Palm Street
San Luis Obispo, CA 93401
cread@slocity.org
SUBJECT: APCD Comments Regarding the Draft City of SLO Climate Action Plan
Update and CEQA GHG Emission Thresholds
Dear Chris Read:
Thank you for including the San Luis Obispo County Air Pollution Control District (APCD) in
the environmental review process. We have completed our review of the proposed Draft
City of SLO Climate Action Plan (CAP) Update and CEQA GHG Emission Thresholds. The
APCD supports the adoption of the documents. We also support the mechanism built into
the plan for updating and adopting a new CAP with every other financial plan cycle. The
plan acknowledges that these updates will allow the incorporation of new emission
reduction measures and technologies to help the City meet its long-term goals.
The CAP appears to meet the requirements of CEQA Guidelines Section 15183.5, indicating
the CAP is a qualified action plan. For those projects that are inconsistent with the CAP, the
proposed thresholds appear to have been developed appropriately in accordance with SB
32 to guide projects to the level necessary to bring GHG impact s to a level of
insignificance.
Project GHG impacts can be mitigated by first implementing all feasible GHG reducing
measures on-site. If additional mitigation measures are needed to bring the project’s GHG
impacts to a level of insignificance, the project can look to retrofit the existing built
environment with a program such as the Home Energy Savings Program (HES)
administered by the Tri-County Energy Regional Network (3C-REN) and implemented by
the Community Action Partnership of San Luis Obispo (CAPSLO).
If further mitigation is needed, the project can acquire GHG offsets. While the APCD does
not endorse individual offset programs, the California Air Resources Board (CARB)
provides a list of CARB approved GHG offset project registries. The first three bullets below
are the current registries in this CARB list. These bullets also include links within the
registries to identify California generated offsets available for purchase. The fourth bullet
APCD Comments for the Draft City of SLO Climate Action Plan & CEQA GHG Update
August 18, 2020
Page 2 of 2
is another offset concept that could considered for securing California generated GHG offsets.
• American Carbon Registry
• Climate Action Reserve
• Verra
• Climate Forward
Other California generated offset programs could be considered if the offsets are real, verifiable,
and additional to regulatory requirements. If SLO County, regional, or California generated offsets
are not available, then North American offsets are the next option. If North American offsets are not
available, then worldwide offsets are the next option. All offsets should meet the real, verifiable, and
additional to regulatory requirements consistent with the CARB registry.
Again, thank you for the opportunity to comment on this proposal. If you have any questions or
comments, feel free to contact me at (805) 781-5912.
Sincerely,
JACKIE MANSOOR
Air Quality Specialist
JNM/jjh
cc: Teresa McClish, City of San Luis Obispo