Next Generation Climate Action Plans - Are They Ready for CEQA Compliance?

摘要

BAAQMD's extensive review of CAPs has led to the conclusion that the CAP's implementation and monitoring mechanisms are critical to the ability of future projects to tier off the CAP's environmental review. In order to take advantage of the tiering benefit and avoid environmental review for GHG impacts, the project proponent must be able to demonstrate that the CAP is being fully implemented, and that the project is consistent with the CAP (meaning that all applicable mandatory and voluntary mitigation measures contained in the CAP are being included in the project's design). BAAQMD therefore recommends to local agencies that CAP implementation strategies include: annual reporting on the implementation of all mitigation measures in the plan; periodic (every 3-5 years) updates to the GHG inventory; and a compliance checklist or similar mechanism for projects to demonstrate consistency with the CAP. The cities of San Francisco and Vallejo have developed such checklists, which will also facilitate their annual reporting on CAP implementation.