OPR CEQA Guideline Amendments Comment Ltr 020209

February 2, 2009 Ms. Cynthia Bryant Director Governor’s Office of Planning and Research P.O. Box 3044 Sacramento, CA 95812-3044 Re: Preliminary Draft Guideline Amendments for Greenhouse Gas Emissions Dear Ms. Bryant: The California State Association of Counties (CSAC) would like to thank the Governor’s Office of Planning and Research (OPR), and especially Terry Roberts, State Clearinghouse Director, for all of the stakeholder and public outreach efforts over the past eighteen months during the development of the Preliminary Draft Guideline Amendments for Greenhouse Gas (GHG) Emissions. CSAC staff as well as various county staff from planning, public works, environmental, and legal departments across the state have found these outreach and discussion opportunities to be invaluable as local governments struggle to integrate climate change and GHG emissions considerations into general plan updates, specific plans, and project level environmental analysis. CSAC supports the overall direction the preliminary amendments take the CEQA Guidelines and would like to submit the following specific comments for your further consideration: Section 15064(h)(3) adds climate action plans and sustainable communities strategies to the list of plans that an agency can use to determine whether a proposed project will have a significant cumulative impact. This provision, if retained, will be very helpful in clarifying a preferred approach to assessing ...