SB 97 CEQA GUIDELINES COMMENT LETTER

VIA E-MAIL: CEQA.GHG@opr.ca.gov, and Hand Delivery February 2, 2009 Cynthia Bryant, Director Governor’s Office of Planning and Research State of California P.O. Box 3022 Sacramento, CA 95812-3044 Re: Preliminary Draft CEQA Guideline Amendments for Greenhouse Gas Emissions Dear Ms. Bryant: On behalf of the above-mentioned organizations, thank you for providing us with the opportunity to comment on the preliminary draft CEQA Guideline Amendments for Greenhouse Gas (GHG) emissions. The preliminary draft does a good job of balancing the need for further guidance on how to treat GHG emissions with the discretionary authority granted to local lead agencies that are in the best position to meet the goals of AB 32 while taking into consideration local circumstances. SB 97 directs the Office of Planning and Research to develop CEQA guidelines on how state and local agencies should analyze, and when necessary, mitigate greenhouse gas emissions. The Governor, in his signing message, noted that “litigation under CEQA is not the best approach to reduce greenhouse gas emissions and maintain a sound and vibrant economy. To achieve these goals, we need a coordinated policy, not a piecemeal approach dictated by litigation.” It is our hope that these proposed Guidelines will achieve this goal. The proposed guidelines, Section 15093 adds a new subdivision (d) to allow an agency to consider region-wide or statewide benefits ...