Preparation of EIR Addendum with a Revised Greenhouse Gas ... · PDF filePreparation of EIR Addendum with a Revised Greenhouse Gas ... 2011 scopes of work to prepare an EIR Addendum

Attachment No. 1

City Council Staff Report

Rincon Contract Amendment

GP 07-04

April 5, 2011

Rincon Consultants, inc.

1530 Monterey Street, Suite D

San Luis Obispo, California 93401

805 547 0900

FAX 547 0901

[email protected]

www. rinconconsultants.com

February 25, 2011

Project 07-61640

Lucille Breese, AICP, Planning Manager

City of Lompoc

Community Development Department/Planning Division

100 Civic Center Plaza

Lompoc, California 93436

Subject: Lompoc General Plan Update

Combined Add Services Request and Fee Estimate for

Preparation of EIR Addendum with a Revised Greenhouse Gas (GHG) Emissions Impact Analysis and Evaluation of Land Use and Policy Changes

Dear Ms. Breese:

The purpose of this letter is to identify the combined fees associated with proceeding with both of the individual February 25, 2011 scopes of work to prepare an EIR Addendum that includes both a revised greenhouse gas (GHG) emissions impact analysis and an evaluation of proposed land use and policy changes requested by the City Council. The independent scopes of work and fee estimates provided for each of these components assume preparation and circulation of an EIR Addendum, circulation of the Addendum, responding to public comments, and preparation of a Final EIR Addendum. As shown in the table below completion of an EIR Addendum that addresses only the revised GHG analysis component is estimated to cost a total of $22,459. Completion of an EIR Addendum that addresses only the proposed land use and policy changes is estimated to cost a total of $22,564. However, if both of these components were to be included in a single EIR Addendum, the document would only need to be circulated to the public a single time, a single response to comments effort would be required, a single version of both the draft and final EIR Addendum would need to be produced, and attendance at a single set of hearings would be required. Accordingly, the combined total cost of preparing an EIR

Addendum that addresses both components would be $29,617.

Combined Fee Estimate Summary

Task Fee

EIR Addendum that Addresses Revised GHG Analysis

Only (Per February 25, 2011 Scope of Work)

$22459

EIR Addendum that Addresses Land Use and Policy

Changes Only (Per February 25, 2011 Scope ot Work)

$22,564

Combined Fee Estimate for EIR Addendum that

Addresses Both Component

$29,617

Environmental Scientists Planners Engineers

This combined add-services request in the amount of $29,617 can be authorized by signing this letter

below.

Lucille Breese, AICP

Planning Manager

City of Lompoc

Date

Thank you for your consideration of this request to provide additional environmental consulting services

for this project. Please call Richard Daulton directly if you have any questions or need any additional

information.

Sincerely,

RINCON CONSULTANTS, INC.

Richard Daultcin, MURP

Principal

Stephen Svete, AldP, LEED AP President


Rincon Consultants, Inc.



805 547 0900

FAX 547 0901

[email protected]

www. rinconcon5Ultants.com

February 25, 2011

Project 07-61640


City of Lompoc




Subject: Lompoc General Plan Update Scope of Work and Fee Estimate for Additional Consulting Services:

EIR Addendum to Address Land Use Designation and Policy Changes

Dear Ms. Breese:

The purpose of this letter is to request additional fees for environmental review services that exceed those included in the October 17, 2007 contract scope of work for the General Plan Update and Environmental Impact Report (EIR), and subsequent contract amendment. These additional tasks include preparation, circulation, and responding to comments regarding an EIR Addendum that addresses- (1) land use designation changes on properties for which the City was formerly contemplating zoning changes to establish consistency between the General Plan Land Use Element designations and zoning designations; and (2) changes to the strength of policy language as requested

by the City Council.

Revised Scope of Work for Additional Tasks

Task 1 Analysis of Land Use Designation Changes. Rincon will evaluate the environmental impacts associated with changes to residential land use designations compared to the land uses evaluated in the Draft and Final EIR for the General Plan Update. These land use changes would occur on residential parcels distributed throughout the City, and would have the effect of allowing residential densities that are consistent with the current underlying zoning for the parcels. The buildout assumptions used in the EIR were based on geographical information system (GIS) analysis of proposed land use designations. Therefore, the proposed land use changes would slightly increase the level of buildout currently anticipated and evaluated in the EIR. However, due to the distribution of affected parcels and the relatively small change to overall buildout in the City, the environmental impacts associated with this change are anticipated to be negligible. Rincon will revise the EIR project description including buildout projections, based on information to be provided by the City regarding the number and location of affected parcels. Rincon will also provide a summary of the minor increase in

environmental impacts attributable to the land use changes.

E n v i r o n m e n t a I S c i e n t i s t s Planners Engineers

Task 2. Analysis of Changes to Land Use Element Policies. It is our understanding that the City

Council has requested that a number of Land Use Element policies be revised to be permissive rather

than mandatory. Since the EIR impact evaluation relied upon several of these policies as enforceable

measures that would reduce impacts below significance thresholds, impact conclusions and mitigation

discussions may require revision. For all impacts for which policies were identified to reduce impacts

below threshold levels, Rincon will determine whether additional mitigation measures would be required

to reduce impacts, identify substitute or supplemental mitigation measures for the impacts as

necessary, and determine whether the substitute or supplemental mitigation measures would sufficiently

reduce impacts below threshold levels.

This scope of work assumes that City staff will revise the text of the Land Use Element policies in

accordance with City Council requests.

Task 3. Prepare and Circulate Draft EIR Addendum

Rincon Consultants will circulate the additional analysis as described in Tasks 1 and 2, and adhere to

public circulation requirements. Specifically, we anticipate the following process:

• Prepare Draft EIR Addendum

• Circulate Draft EIR Addendum (for required 45 day review period)

• Respond to Comments on the Draft EIR Addendum

• Publish Final EIR Addendum, which will include responses to comments on the

original Draft EIR (Previously Scoped) as well as responses to comments on the Draft

EIR Addendum

• Certification of Final EIR Addendum, which encompasses original documents from

original Draft EIR, as well as the EIR Addendum and responses to comments on both

the Draft EIR and EIR Addendum.

Task 3.1. Administrative Draft EIR Addendum

Rincon will prepare an Administrative Draft EIR Addendum for review by City staff. The Administrative

Draft EIR Addendum will include the following content:

• Introduction, explaining the relationship of this document to previous analysis, and

CEQA requirements for circulation of a Draft EIR Addendum; and

• The environmental impact sections, revised as described in Tasks 1 and 2. This

scope of work and fee estimate assume that most of the EIR impact sections would

require revision as a result of the analysis completed in Tasks 1 and 2. Accordingly,

most of the EIR impact sections would be addressed in the Draft EIR Addendum and

circulated to the public.

The Administrative Draft EIR Addendum will be transmitted digitally for City staff review. No hard copies

will be prepared.

Task 3.2. Draft EIR Addendum Publication

Rincon will address City comments on the Administrative Draft EIR Addendum and prepare the Draft EIR Addendum for publication. The Draft EIR Addendum to be circulated will include only the contents

noted in Task 3.1, and will not revisit the previous Draft or Final EIR documents in their entirety. We assume the City will handle noticing and circulation of the document. When circulated, interested


readers will be referred to the City web-site if they wish to review the original Draft and Final EIR.

Rincon will produce 30 hard copies of the Draft EIR Addendum.

Task 3.3. Administrative Final EIR Addendum (Responses to Comments)

The Draft EIR Addendum will be circulated to the public for a 45 day public review period. The Final

EIR Addendum will be prepared following this period, and will include the following contents:

• Responses to Comments on the Draft EIR Addendum. The Final EIR Addendum will include

responses to written comments on the Draft EIR Addendum. CEQA requires responses to only

those comments on the revised portions of the Draft EIR received during the Draft EIR Addendum

public review period. Any changes to the text of the Draft EIR Addendum as a result of the

comments will be noted in the text. For the purposes of this proposal, we have assumed that up to

24 hours of professional time will be needed to address comments submitted on the Draft EIR

Addendum. Rincon will prepare an Administrative Final EIR Addendum/Responses to Comments

for City staff review. The Administrative Final EIR Addendum will be transmitted digitally for City

staff review. No hard copies will be prepared.

Note that the Final EIR includes responses to written comments received during the original public

review period. This task was previously completed as part of the original EIR contract and is not

included in the enclosed fee estimate.

Task 3.4. Final EIR Addendum Publication

Rincon will address City comments on the Administrative Final EIR Addendum and prepare the Final

EiR Addendum for publication. Rincon will produce 35 hard copies of the Final EIR Addendum. We assume the City will handle distribution of the document. Rincon will attend up to five public hearings

regarding the Final EIR Addendum.

Task 3.5. Revised Findings/Overriding Considerations

Rincon will revise the CEQA Findings and Statement of Overriding Considerations to address revisions

to the EIR. The corresponding resolution would comply with Section 15091 and 15093 of the State

CEQA Guidelines and would be submitted in an electronic format.

Fee Estimate

We are estimating fees in the amount of $22,564 to complete this revised scope of work, to be billed on a time and materials basis in accordance with the terms of our existing contract with the

City.

The fee estimate has been revised to reflect the requested changes to the scope of work noted above.


wsr

City of Lompoc General Plan Update and EIR

EIR Evaluation of Land Use Designation and Policy Changes and EIR Addendum Preparation

Cost Estimate Februaiy 25, 2011


This add-services request can be authorized by signing this letter below.

Lucille Breese, A1CP

Planning Manager

City of Lompoc

Date

—— ■ ■ ^ :—

Thank you for your consideration of this request to provide additional environmental consulting services for

this project. Please call Richard Daulton directly if you have any questions or need any additional

information.

Sincerely,


Richard Dault

Principal

Stephen Svete,

President

LEED AP


Rincon Consultants, inc.



805 547 0900

FAX 547 0901

[email protected]

www. rinconconsjltants.com

February 25, 2011

Project 07-61640


City of Lompoc




Subject: Lompoc General Plan Update Scope of Work and Fee Estimate for Additional Consulting Services:

Revised Greenhouse Gas (GHG) Emissions Impact Analysis and EIR

Addendum Preparation and Circulation

Dear Ms. Breese:

The purpose of this letter is to request additional fees for environmental review services that exceed those included in the October 17, 2007 contract scope of work for the General Plan Update and Environmental Impact Report (EIR), and subsequent contract amendment. These additional tasks include: (1) preparation and circulation of an EIR Addendum that includes a revised Greenhouse Gas

(GHG) Emissions impact section; and (2), responding to public comments, and preparing a Final EIR

Addendum.

Revised Scope of Work for Additional Tasks

Task 1: Revised GHG Emissions Impact Analysis Rincon proposes to prepare a Revised GHG Emissions Impact Analysis that analyzes the impacts of the proposed project (General Plan buildout) on climate change, as well as the impacts of climate change

on the City.

Task 1.1: Baseline GHG Emissions Inventory (Existing Conditions)

Rincon will develop an existing conditions baseline GHG emissions inventory, in conjunction with City staff Rincon will base the GHG emissions inventory on the City's existing land use inventory and will estimate GHG emissions from existing land uses using the URBEMIS 2007 computer model and the California Climate Action Registry's General Reporting Protocol (January 2009). Rincon will identify and quantify all direct (stationary, area, and mobile source emissions) and indirect (emissions resulting from energy consumption) GHG emissions produced within the City's jurisdictional boundary. In addition, the analysis of this scenario will include separate emissions calculations for the Bailey Avenue Specific

Plan, River, Miguelito Canyon, and Wye Residential annexation areas.

Environmental Scientists anners Engineers

The existing conditions analysis will be based on the date of release of the Notice of Preparation (NOP)

for the General Plan Update, which occurred in 2008.

The analysis will include quantification of carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O) emissions, as well as a qualitative discussion of other GHGs, including hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Emissions associated with electricity use, as well as CH4 and N2O emissions from transportation sources, will be calculated based on the General Reporting Protocol, while CO2 emissions associated with vehicle trips and non-electricity area sources will be

estimated using the latest version of the URBEMIS air quality model. The various GHGs will then be aggregated and reported as carbon dioxide equivalent units (CO2e), a commonly used unit that combines greenhouse gases with different global warming potentials into one weighted unit.

Task 1.2:1990 GHG Emissions Estimate

The Global Warming Solutions Act of 2006 (AB 32) mandates that California reduce its greenhouse gas emissions to 1990 levels by 2020. In order to demonstrate consistency with this State target, Rincon will prepare an estimate of Lompoc's 1990 emissions, as part of the GHG Emissions Inventory.

The current methodology for estimating 1990 GHG emissions levels, called "back-casting," calculates 1990 emissions levels based on existing GHG emissions levels and adjusts them for 1990 population and job statistics Back-casting is an indefinite science; it does not take into account changes in energy generation efficiency, consumer behavior, or vehicle efficiency, and it relies heavily upon finding reliable data from almost two decades ago. Nevertheless, Rincon will estimate Lompoc's 1990 emissions levels using this methodology in order to provide decision makers and the community with longitudinal information of the City's long-term GHG emissions trajectory and GHG emissions reduction goals. The analysis of this scenario will also include separate emissions calculations for the Bailey Avenue Specific

Plan, River, Miguelito Canyon, and Wye Residential annexation areas.

Task 1.3: 2030 GHG Emissions Forecast (General Plan Buildout Conditions)

Rincon will update the existing "business-as-usual" GHG emissions forecast, utilizing emissions factors from the version 3 1 of the California Climate Action Registry's General Reporting Protocol and the most recent energy consumption factors available from the U.S. Energy Information Administration. In addition average vehicle trip lengths will be adjusted in order to accurately account for the land use pattern proposed by the General Plan Update. This forecast provides an estimate of the growth in GHG emissions that would occur under General Plan buildout absent of any new policies or actions that would reduce emissions, consistent with direction from the California Attorney General's Office. The 2030 forecast will be based on maximum development potential (build out) of the General Plan land use scenario through 2030, which is the City's General Plan horizon, and will also include separate emissions calculations for the Bailey Avenue Specific Plan, River, Miguelito Canyon, and Wye

Residential annexation areas.

Task 1.4: Thresholds of Significance and Impact Assessment

According to the State CEQA Guidelines, the project's GHG emissions are considered potentially

significant if the project would:

. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant

impact on the environment; or

Environme ntal Scientists Planners Engineers

• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the

emissions of greenhouse gases.

These qualitative thresholds are informed by goals set by Executive Order S-3-05 and the legislative requirements of AB 32. According to the Attorney General's Office, a General Plan that is consistent with these thresholds will ensure that "GHG emissions from projects in a City's jurisdiction and subject to its general plan are on an emissions trajectory that, if adopted on a larger scale, is consistent with avoiding dangerous climate change" (Attorney General's Office, Climate Change, CEQA & General

Plans, 2009).

To determine whether GHG emissions from the proposed updates to the Land Use, Circulation, and Housing Element would be significant, Rincon recommends using an "efficiency-based" threshold, which is supported by the Attorney General's Office, the California Air Pollution Control Officers Association

(CAPCOA) and the California Air Resources Board. This approach, which is applicable to local governments across California, establishes maximum quantities of emissions per service population, defined as residents plus employees, which are based on the statewide GHG emissions targets and projected statewide population and employment. This approach is intended to avoid penalizing large projects such as general plans, that are GHG-efficient (e.g., contain compact infill and/or mixed-use development patterns that reduce average GHG emissions when compared to less efficient land use

patterns).

Rincon will compare the 2030 emissions forecast (General Plan Buildout Conditions) to the identified emissions threshold If the projected emissions exceed the identified threshold, then the quantified difference would be the amount of emissions that would need to be reduced to mitigate the project s

impact on climate change.

As part of the impact analysis, Rincon will update the EIR analysis of areas governed by the General Plan that may be affected by reasonably foreseeable impacts of climate change based on recent

readily-available information.

Task 1.5: GHG Emissions Mitigation Measures

Rincon will identify feasible and applicable mitigation measures from a variety of sources, including CAPCOA's white paper OPR's Technical Advisory, and the mitigation list on the Attorney General s website Consistent with section 15126.4(a) of the CEQA Guidelines, these measures must be fully enforceable. In general, mitigation measures that could potentially be applied to the General Plan Update will include goals, objectives, and policies intended to:

• Improve energy efficiency (in new construction and existing buildings); . Facilitate residential and commercial renewable energy facilities (on-site and off-site renewable

energy), such as solar array installations, individual wind energy generators, etc.;

- Establish energy-efficiency standards for public facilities;

. Improve the local jobs/housing balance to reduce commute distance and vehicle miles

traveled;

. Provide incentives for alternative transportation and other vehicle trip reduction measures;

. Conserve water to reduce emissions from pumping and water delivery;

. Facilitate water recycling for use on landscaping, agricultural operations, and other applications

where potable water is not required, to reduce pumping-related emissions;


• Promote recycling and waste recovery; and . Provide public education and outreach for public practices to decrease energy use, increase

reliance on alternative transportation, and reduce vehicle trips.

Task 1 6- 2030 General Plan Buildout Mitigated Emissions Forecast

For this task Rincon will identify and quantify the GHG measures needed to reduce GHG emissions under the General Plan. Several measures included in the AB 32 Scoping Plan have been implemented a he State level pursuant to the GHG emissions reduction goals in AB 32. Policies ̂ t would reduce GHG emissions and were adopted subsequent to AB 32 are appropriate to apply to GHG, emis ons reduction plans, because the AB 32 goal is based on a trajectory that was formulate ,n the b ence of these policies These State measures are not accounted for in the business-as-usual GHG emissions

ecas but would reduce local GHG emissions; therefore, these measures may be takeri in o account in the m tigated GHG emissions forecast. Of particular importance are the Renewable Portfolio Standard the Pavley I and II regulations, and the California Green Building Code. Once these are acounted' or Rincon will calculate the remaining emissions that need to be reduced and selec feasible maSon measures accordingly. GHG reductions from these ̂ ^^ZToZlT estimated usinq ICLEI's Climate and Air Pollution Planning Assistant (CAPPA) version 1.5 and CAPCOA's Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emiss on Red ctions from Greenhouse Gas Mitigation Measures (August 2010). Rincon will fhen compare the mitigated emissions projection to the CEQA thresholds of sign, cance described above to determine whether impacts would be mitigated to a less than significant level.

Task 1 7: GHG Emissions EIR Impact Section

As oart of this task Rincon will develop the revised GHG emissions analysis for inclusion in the Lompoc Genera IP En Update Rnal EIR, pursuant to CEQA. Rincon will provide the City with editable electron, and hard copies of the all original data, technical calculations, and any material necessary for the

practical use of the data and/or documents.

Task 2-Prepare and Circulate Draft EIR Addendum

Rncon Consultants will recirculate the additional GHG CEQA analysis as described in Tasks 1.1 through 17', and ;adhere to public circulation requirements. Specifically, we anticipate the following

process:

Prepare Draft EIR Addendum

Circulate Draft EIR Addendum (for required 45 day review period) Respond to Comments on the Draft EIR Addendum

Publish Final EIR Addendum, which will include responses to comments on the original Draft EIR (Previously Scoped) as well as responses to comments on the Draft

EIR Addendum

Certification of Final EIR Addendum, which encompasses original documents from original Draft EIR, as well as the EIR Addendum and responses to comments on both

the Draft EIR and EIR Addendum.

Draft EIR Addendum will include the following content:

Planners Engineers £ n v i r o n m e n t a / Scientists Planners

• Introduction, explaining the relationship of this document to previous analysis, and

CEQA requirements for circulation of a Draft EIR Addendum; and

• The revised GHG environmental impact section, as described in Task 1.7.

The Administrative Draft EIR Addendum will be transmitted digitally for City staff review, No hard copies

will be prepared.

Task 2.2: Draft EIR Addendum Publication

Rincon will address City comments on the Administrative Draft EIR Addendum and prepare the Draft

EIR Addendum for publication. The Draft EIR Addendum to be circulated will include only contents

noted in Task 2.1, and will not revisit the previous Draft or Final EIR documents in their entirety. We

assume the City will handle noticing and circulation of the document. When circulated, interested

readers will be referred to the City web-site if they wish to review the original Draft and Final EIR.

Rincon will produce 30 hard copies of the Draft EIR Addendum.

Task 2.3: Administrative Final EIR Addendum (Responses to Comments)

The Draft EIR Addendum will be circulated to the public for a 45 day public review period. The Final

EIR Addendum will be prepared following this period, and will include the following contents:

• Responses to Comments on the Draft EIR Addendum . The Final EIR Addendum will include

responses to written comments on the Draft EIR Addendum. CEQA requires responses to only

those comments on the revised portions of the Draft EIR received during the Draft EIR Addendum

public review period. Any changes to the text of the Draft EIR Addendum as a result of the

comments will be noted in the text. For the purposes of this proposal, we have assumed that up to

24 hours of professional time will be needed to address comments submitted on the Draft EIR

Addendum. Rincon will prepare an Administrative Final EIR Addendum/Responses to Comments

for City staff review. The Administrative Final EIR Addendum will be transmitted digitally for City

staff review. No hard copies will be prepared.

Note that the Final EIR includes responses to written comments received during the original public

review period. This task was previously completed as part of the original EIR contract and is not

included in the enclosed fee estimate.

Task 2.4: Final EIR Addendum Publication

Rincon will address City comments on the Administrative Final EIR Addendum and prepare the Final

EIR Addendum for publication. Rincon will produce 35 hard copies of the Final EIR Addendum. We

assume the City will handle distribution of the document. Rincon will attend up to 5 public hearings

regarding the Final EIR Addendum.

Task 2.5: Revised Findings/Overriding Considerations

Rincon will revise the CEQA Findings and Statement of Overriding Considerations to address revisions

to the EIR. The corresponding resolution would comply with Section 15091 and 15093 of the State

CEQA Guidelines and would be submitted in an electronic format.

This scope of work assumes that City staff will prepare minor revisions to the text of the Land Use

Element policies in accordance with City Council requests. Rincon will prepare major policy revisions

on a time and materials basis.


Fee Estimate

We are estimating fees in the amount of $22,459 to complete this revised scope of work, to be

billed on a time and materials basis in accordance with the terms of our existing contract with the

City.

The fee estimate has been revised to reflect the requested changes to the scope of work noted above.


City of Lompoc General Plan Update and EIR

Revised GHG Impact Analysis and EIR Addendum Preparation

Cost Estimate February 25, 2011

Environmental Scientists a n n e r s Engineers

m

This add-services request can be authorized by signing this letter below.

Lucille Breese, AICP

Planning Manager

City of Lompoc

Date

Thank you for your consideration of this request to provide additional environmental consulting services for

this project. Please call Richard Daulton directly if you have any questions or need any additional

information.

Sincerely,


Richard Daultiri, MURP7

Principal

Stephen

President

)P, LEED AP


Documents

Preparation of EIR Addendum with a Revised Greenhouse Gas ... · PDF filePreparation of EIR Addendum with a Revised Greenhouse Gas ... 2011 scopes of work to prepare an EIR Addendum