LETTER RESPONSE Response to Comment AA-1 CAP Appendix A has been updated to include a more detailed methodology for how the GHG reduction from implementation of a CCA or another program was determined. Please see specifically CAP Appendix pages A-5 through A-10 for the methodology for CCA or another program. Greater detail has been provided for the forecasted GHG reductions for all of the CAP Actions. RTC-61 LETTER RESPONSE Response to Comment AA-2 Comment noted. Revisions to the CAP and CAP Appendix A separate out the emissions reductions associated with Community Choice Aggregation or another program that are attributable to the statewide Renewable Portfolio Standard. This change decreased the amount of reductions achieved at the local level, and increased the amount at the State level—the overall level of reductions remained the same. RTC-62 LETTER RESPONSE Response to Comment AA-3 See Response to Comment AA-2. All GHG reductions attributable to State actions have been categorized as such in the CAP and the FEIR. Response to Comment AA-4 As specified in the CAP, on page 35, the City will “[c]omplete a citywide Community Choice Aggregation Feasibility Study” as part of the implementation strategy for Action 2.1, which will consider these issues. Calculations are based on reasonable assumptions. Please see CAP Chapter 3 regarding CAP implementation monitoring and reporting, including annual reporting. RTC-63 LETTER RESPONSE Response to Comment AA-5 Natural gas is not a 100 percent renewable energy source, and thus, was not included specifically in the CAP strategies. CAP Appendix A includes natural gas, as it is an energy source currently in use. Response to Comment AA-6 The CAP’s reference to the “potential contribution of a large-scaled pumped storage project toward meeting the City’s renewable energy needs” is in a list of examples of the “Growing Presence of Renewable Energy in San Diego.” It describes a partnership between the City and the San Diego County Water Authority to conduct an in-depth study of the feasibility of a multi-year renewable energy project at San Vicente Reservoir. The CAP does not include any reductions attributable to this reference. RTC-64 LETTER RESPONSE Response to Comment AA-7 The purpose of the CAP is to assess the policies and actions needed to reduce emissions to meet specified targets. Please see CAP Chapter 3 regarding CAP implementation monitoring and reporting, including annual reporting. Response to Comment AA-8 Recent changes to legislation either remain consistent with current GHG estimates in the CAP or are anticipated to generate additional reductions. The CAP calculations assume a 50 percent level of renewable energy for 2030, consistent with SB 350. Please see CAP Chapter 3 regarding CAP implementation monitoring and reporting, including annual reporting. Please also see Response to Comment U-5. Response to Comment AA-9 The Draft EIR has been revised to reflect that the CMAP Alternative is the environmentally superior alternative in that it would eliminate or reduce the severity of impacts related to the implementation of large-scale renewable energy projects. The commenter is correct that local GHG emissions achieved under the CAP would be lower than those in the CMAP Alternative, but that overall reductions in the CAP would be greater than those shown in the CMAP because additional state and federal reductions are included in the CAP. The lower locally-achieved actions are due to rapidly changing federal and state regulatory environment. Where state and federal programs result in certain greenhouse gas emissions reductions, implementation of certain local measures become obsolete. RTC-65 LETTER RESPONSE Response to Comment AA-10 This comment does not address the adequacy of the Draft EIR. Regarding the CMAP Alternative more generally, please see Response to Comment AA-9. RTC-66 LETTER RESPONSE IBernment Letter All It is precisely the type of analysis Hlat should be completed for all of the Climate Action Plan's proposed local reduction measures le.g., Strategies 1 through 5) to provide the City and its taxpayng residents with a clear. concise. and readily understandable rnap outlining the relatiVe cost-effectiveness of each proposed strategy. The cast?clicctivcnese analysis Would also provide a more rigorours baseline for determining. the actual superiorin of the Climate Action Plan relative to the No Project and ?ltEf?a?VE?. as outlined in the PEIR. strongly encourages the City of San Diego to complete a detailed analysis of the expected costs {in 2 l15 dollars] for each of the proposed local reduction strategies prior to adopting the Climate Action Plan. The City has repeatedly stated that the Climate Action Planr if adopted, will be reviewed annually without specifying what that review may include or what parameters it would be based upon. A thorough cost-etiwtiveness analysis, when completed, would provide a logical framework for annual review of each of the local GHG reduction strategies and their overall eth?ctiveness in achieving the GHG reduction objectives outlined within the Climate Action Plan. The City has provided exactly this type of financial analysis with previous plans. so it is concerning that nothing has been provided to date for the Climate Action Plan. Transportation Altai-natives The Transportation Strategy focuses on reducing emissions by reducing vehicle miles travetcd (Worm through multimoclal transportation options; and by decreasing the energy intensity per miles travel by reducing idling and increasing electric vehicle use by improving the electric vehicle infrastructure. In addition to its support for electric vehicles, strongly bel ieves that natural gas is a critical component of minitahle and sustainable energy and rliinale action policies. Unlorhmately, the does not include the role and benefits of tunnel gas in the tmmpurlah'on Sector. Contrary to the discussion in the PM. natural gas is not jut-it used for "generating electricity" and "heating homes and businesses? {Omit EIR page 3.63}. Natural gas isreliecl upon every day by residents antl businesses throughout the City of San Diego to cook food. heat water, operate fleets legs transit bones. school buses, refuse trucks], LID laundry. and for trpace heating. San Diego?s lending institutions - the mililary: universities and colleges, hospitals, hotels, restaurants, and leading manufacturers - depend on natural gas for their energy needs. Unfortunately, both the draft Climate Action Plan and the PEER tail to consider the vital role of neutral gas in San Diego and the documented potential environmental benefits of natural gas. particularly with respect to electric generation to reliably meet daily peak usage and in reducing emissions from petroleum-lmsed heavy-duty transportation. Response to Comment AA-11 See Response to Comment AA-5. RTC-67 LETTER RESPONSE Response to Comment AA-12 As stated in Section 8, Alternatives, in addition to the lack of jurisdiction over transit projects, the environmental justice alternative was not selected because actions to improve conditions in environmental justice communities are already included in the General Plan, Housing Element, and CAP. Response to Comment AA-13 The following text changes have been made: “SDG&E purchases raw energy supplies from various suppliers located outside of the city and transports those energy sources to local plants for processing. SDG&E purchases electricity from the Otay Mesa Energy Center, owned by Calpine, and SDG&E owns and operates the Palomar Energy Center in Escondido. SDG&E produces electricity at the Cabrillo (Encina) and South Bay Power Plants, as well other smaller power plants in the San Diego area. Once the energy is processed, it is sent to customers via SDG&E’s system of transmission lines.” (Introduction, page 1-11) “…Gas and Electric Substations and Transmission Lines, identifies some of SDG&E’s facilities within the City. SDG&E produces electricity primarily at the Cabrillo (Encina) and South Bay Power Plants, as well other smaller power plants SDG&E purchases electricity from the Otay Mesa Energy Center, owned by Calpine, and SDG&E owns and operates the Palomar Energy Center in Escondido, which is then sent to customers through various transmission lines.” (Section 3.G Utilities, Page 3.G-7) RTC-68 LETTER RESPONSE Comment Letter AA looka- fnrward to helping the City nf San Dir: In develop its; (Jinnah:- Actinn Flam and achieve San Diego's environmental goals in the anL ell'ecrive and mm-elleclive way pussiblu. I'hank you, 4! .157 1 R. Scott Pea r5011 Director Em'i I'onmenlal Scn'lucs If. RTC-69