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Consultants: net‑zero offset requirement removed but energy and design measures remain
Summary
ESA explained that removal of the EIR's net‑zero threshold eliminated a CEQA mandate to achieve or track a specific greenhouse gas target, but that the specific plan retains multiple design‑level GHG mitigation measures including solar fields, building efficiency standards, battery storage and a TDM program.
Brian Schuster of ESA told the Planning Commission that Impact GHG‑1 (the net‑zero, offset‑based mitigation) was removed from the final EIR and therefore the CEQA document no longer contains a requirement for the project to meet a specific net‑zero GHG threshold or to track emissions as a CEQA mitigation measure. "The removal of Impact GHG‑1 also removed any mandate to achieve a specific greenhouse gas target for the project and any tracking that goes along with that," Schuster said.
He emphasized that other project requirements remain: onsite renewable energy, a solar field and up to 500 megawatts of battery storage in the specific plan, LEED/GreenPoint design standards, low‑GWP refrigerants, renewable fuel shuttles and a TDM program to reduce VMT. Schuster and other commenters also said that tracking emissions voluntarily or via provisions in a development agreement or city policy remains possible even if CEQA no longer requires it. Commissioners asked staff whether the city could require annual GHG tracking; staff said the specific plan does not include a tracking requirement but that the commission could recommend additional monitoring or contractual obligations in the development agreement or policy context.
