https://outlook.office.com/mail/inbox/id/AAQkADdkZTQwMmFmLWNmYzUtNDg4My1iMTIxLWIxYmIzNWYzYTQ4NQAQANbq3%2FvjnUQ6kpz0bmKrg… 1/3 From: BAAQMD CEQA <[email protected]>
Sent: Wednesday, April 5, 2023 2:48 PM
To: Mar n Rolph <Mar [email protected]>
Cc: Abby Young <[email protected]>
Subject: RE: New GHG Thresholds
Hi Mar n,
Thanks for this ques on. We agree with your assessment that a convenience store with gas pumps is a typical commercial land use and that the Air District’s recommended climate impact thresholds adopted April 2022 can appropriately be used to evaluate this project. Of course, a lead agency has the discre on to use a different threshold for climate or air quality impacts as long as they provide the substan al evidence for that determina on.
You don't often get email from [email protected]. Learn why this is important Hope this answer helped. If not please let us know.
Wendy
Wendy Goodfriend, Ph.D. | Ac ng Director of Planning and Climate Protec on Pronouns: she/her
Planning and Climate Protec on Division
Bay Area Air Quality Management District
Office: 415-749-4641 | Mobile: 415-308-6518
From: Mar n Rolph <Mar [email protected]>
Sent: Wednesday, April 5, 2023 1:32 PM
To: BAAQMD CEQA <[email protected]>
Subject: New GHG Thresholds
CAUTION: This email originated from outside of the BAAQMD network. Do not click links or open a achments unless you recognize the sender and know the content is safe.
I am working on an Air Quality and Greenhouse Gas Emissions analysis and report for a project in the City of Santa Rosa, The project, 43 Middle Ricon Road 7-Eleven, involves the demoli on of an exis ng convenience store and construc ng/opera ng a new, slightly larger convenience store with gas pumps.
The dra GHG analysis relies on BAAQMD’s performance standard based GHG thresholds defined and jus fied in the CEQA Thresholds for Evalua ng the Significance of Climate Impacts From Land Use Projects and Plans (April 2022). The City A orney has raised a ques on about whether the new performance standard based thresholds are applicable to a convenience store and gas sta on project. The City’s concern stems from the first two sentences in sec on 1.3 (Important Considera ons for Using These Thresholds; p. 3) of the jus fica on report:
The Air District has developed these thresholds of significance based on typical residential and commercial land use projects and typical long-term communitywide planning documents such as general plans and similar long-range development plans. As such, these thresholds may not be appropriate for other types of projects that do not fit into the mold of a typical residen al or commercial project or general plan update.
Attachment 11
4/13/23, 12:13 PM Mail - Toomians, Kristinae - Outlook
https://outlook.office.com/mail/inbox/id/AAQkADdkZTQwMmFmLWNmYzUtNDg4My1iMTIxLWIxYmIzNWYzYTQ4NQAQANbq3%2FvjnUQ6kpz0bmKrg… 2/3 Is a convenience store with gas pumps considered a typical commercial land use for which the thresholds were developed?
It seems to me that a convenience store with gas pumps is pre y typical (it is one of the retail land uses available in CalEEMod and the primary GHG sources are vehicle trips and building energy use) and would not be considered a “unique or unusual” project, but I would like to hear BAAQMD’s opinion on this issue.
Thanks for your help, I’m most easily reachable at this email address or on my cell phone 530-306-7375, Mar n
Martin Rolph
Air Quality/ Noise Specialist
HELIX Environmental Planning, Inc.
1180 Iron Point Road, Suite 130
Folsom, CA 95630
916.435.1205 tel
619.462.0552 fax
[email protected]
helixepi.com | LinkedIn | Facebook | Twi er
Know someone who’s looking for a new career opportunity? We’re hiring!