May 19, 2014 Mayor Kevin Faulconer City of San Diego 202 C Street San Diego, CA 92101 Re: Support for February 2014 Draft City of San Diego Climate Action Plan Dear Mayor Faulconer, The undersigned 19 organizations and businesses represent over 42,000 individuals in the San Diego region and are committed to protecting the health, quality of life, natural resources, built environment, and economic future for all San Diegans. We support the commitments of the City s General Plan to achieve a healthy, sustainable, and thriving future for our City. Critical to fulfilling the General Plan s vision and legally binding obligations under its Mitigation and Monitoring Reporting Program (MMRP) is mitigating climate change consistent with state law, including AB32 and EO S-3-05, and approving and implementing an enforceable climate action plan that extends through the timeframe of the General Plan. We are pleased to write you today with our support of the February 2014 Draft Climate Action Plan (CAP). We urge you to advance the CAP to environmental review, with funding for plan completion and implementation in the FY15 budget, and on to Council for approval as expeditiously as possible, without delay or weakening. As you know, the City has been developing the CAP for over three years with input from stakeholders representing all sectors and all Council districts, including members of the City s Economic and Environmental Sustainability Task Force (EESTF). City Council established the EESTF in 2010 to provide input on the development of a City climate plan. Each Councilmember and the Mayor appointed one representative, resulting in a diverse membership that represents business, environmental interests, energy interests, the building industry, transportation interests, the Navy, and social equity interests. The EESTF has met regularly since January 2011, providing the City with advice on the CAP s development, alongside input from a variety of experts and stakeholders. This process is finally near completion and we proudly stand behind its product. Several organizations as well as the City s Economic and Environmental Sustainability Task Force have submitted letters of support for the February 2014 draft CAP, along with suggestions to further bolster the plan s commitment to local action and social equity. With these recommendations incorporated, we believe the latest draft CAP will allow to the City meet its General Plan legal obligation to mitigate climate change, as well as provide many benefits including community resiliency, improved air quality and health, economic and infrastructure development, and improved quality of life for all San Diegans and future generations. 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 1
We again urge you to support this plan that has been developed through years of public input and is supported by the EESTF and a diverse set of stakeholders. Any weakening of the plan from the February 2014 draft would undermine the City s ability to meet the legal obligations of its General Plan and state laws and regulations. Weakening also would undermine the City s ability to proactively address the great threat climate change poses to our City s environment, economy, wildlife, and livability. We specifically support continued inclusion of the following goals and actions, which have already been supported by the EESTF, are already incorporated in the City s latest draft CAP, and which we believe to be essential to meeting the City s legal obligations: 1. Act Now To Reduce Emissions Through 2035, Consistent with State Policy Targets and the City s General Plan The CAP s 15% and 49% greenhouse gas (GHG) reductions targets for 2020 and 2035, respectively, are consistent with the GHG reduction trajectories of AB32 and California Executive Order S-3-05 and represent the best available science recognized by the State on the GHG reductions needed to slow the pace of climate change and mitigate significant impacts. Importantly, the mitigation measures necessary to meet those targets are practical, feasible and can be implemented within the plan s timeframe. The timeframe of the CAP s GHG reduction targets (through 2035) is consistent with the 20- to 30-year planning horizon of the City s General Plan. Not only does this consistency make good planning sense, it is necessary because the City is obligated through the MMRP for the 2007 General Plan Update Program Environmental Impact Report to: mitigate the cumulatively significant global warming impacts of the General Plan 1 reduce the City s carbon footprint 2 develop and adopt new or amended regulations, programs, and incentives as appropriate to implement the goals and policies set forth, 3 regularly monitor, update and implement the City s Climate Protection Action Plan to ensure, at a minimum compliance with all applicable federal, state and local laws. 4 2. Take Aggressive Local Action Now; Without Delay or Reliance on Uncertain State and Federal Policies The data clearly show that meeting the CAP s 2035 GHG reduction goal will require the City to take aggressive action at the local and regional level right away, as many actions may take years to fully implement and see the full GHG reduction benefits. The City cannot legally nor practically rely on uncertain state and federal government future actions. The City must take charge of its own future with aggressive local action in order to meet its legal obligations. This 1 Mitigation Monitoring and Reporting Program for City of San Diego General Plan Final Program EIR, City of San Diego Development Services Department, September 28, 2007, at p49. http://www.sandiego.gov/planning/genplan/pdf/peir/mmrp.pdf 2 City of San Diego General Plan Update, Conservation Element CE.A.2 3 City of San Diego General Plan Update, Conservation Element CE.A.2 4 City of San Diego General Plan Update, Conservation Element CE.A.13 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 2
will also provide many benefits including making our community more resilient against the impacts of climate change, supporting a growing green economy with construction of green infrastructure, supporting social equity, and improving San Diegans quality of life. 3. Demonstrably Meet the GHG Goals and Obligations Under CEQA with Enforceable Policies and Actions We support that the CAP includes a spectrum of actions ranging from educational and incentive-based to enforceable regulations. History shows us relying solely on voluntary mechanisms is insufficient, and the CAP must include measurable and enforceable mechanisms in order to provide certainty and evidence the City will meet its GHG targets. Additionally, because the City has committed to climate change mitigation under its General Plan MMRP, the CAP is subject to CEQA guidelines that mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments. 5 Finally, because the City has indicated its intentions for the CAP to be a CEQA tiering document, the CAP is subject to CEQA guidelines to include specific measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level. 6 Substantial evidence shows unenforceable greenhouse-gas reduction policies alone are insufficiently effective, and mandatory actions are needed to achieve the emissions targets. These conclusions are consistent with the findings of Judge Taylor in the 2013 Sierra Club suit against the County of San Diego on its Climate Action Plan. 4. Maximize Support of Local, Quality Jobs that Make our Community Healthier Because of the City s prevailing wage ordinance and with the proper emphasis on local action to reduce climate change through investments in local renewable energy, energy efficient buildings, and sustainable transportation infrastructure, the CAP has the opportunity to support local, skilled jobs. For example, the Center on Policy Initiatives estimates that the CAP s solar PV goal could create 5,608 local job years (years of full time employment) for installing solar alone by 2020, plus an additional 10,335 indirect and induced job years within the state of California due to increased demand for goods and services required for PV installation (not including the manufacturing of solar modules) and the growth of economic activity due to this spending. In addition, the Political Economy Research Institute at the University of Massachusetts estimates that every $1 million invested in solar creates 14 jobs, every $1 million invested in building retrofits creates 17 jobs, and every $1 million invested in mass transit or fright rail creates 22 jobs. On the other hand, $1 million invested in natural gas would create only about 5 jobs. We are excited these kinds of sustainable energy and transportation projects can make our environment and communities cleaner, while also creating local jobs. 5 CEQA Guideline 15126.4(a)(2) 6 CEQA Guideline 15183.5 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 3
5. Achieve 100% Clean Energy By 2035; Reduce Energy Demand in Existing Buildings; Increase Use of Transit, Walking, and Biking The draft CAP includes many actions with regards to energy and transportation that are essential to meeting the 2035 GHG reduction goal and can provide the additional benefits of local job creation and improving San Diegan s quality of life. For example, we strongly support the CAP s goal to reach 100% Clean Renewable Energy by 2035 citywide, potentially through adoption of a community choice aggregation program. Meeting this goal using local clean energy production and hiring local, skilled workers would maximize benefits to the city. We also support the CAP s proposal to reduce energy and water use in existing buildings through a Point-of-Sale Water and Energy Conservation Ordinance. Tackling energy use in existing buildings, by expanding the City s existing plumbing retrofit ordinance, is absolutely essential to achieving the GHG targets with certainty and as a way to minimize the need for building new energy generation. Furthermore, we support the CAP s aims to increase the use of mass transit, walking biking, and urban green infrastructure through strategic investment in key areas. We see this as an opportunity to bring vital infrastructure and improve quality of life in San Diego s most underserved communities. Finally, we support the CAP s commitment to develop a stand-alone, actionable adaptation plan to further bolster our resiliency against the impacts of climate change such as sea level rise and wildfires, protect infrastructure, public health and safety, and precious natural resources and coastline. In conclusion, we urge you to accept our recommendations to advance the February 2014 draft to environmental review and Council and to ensure adequate funding in completing and implementing the CAP in FY15 and beyond. We believe the draft Climate Action Plan can preserve the environment, expand business development, and create more jobs. We welcome the opportunity to meet with you to discuss our recommendations. Respectfully, Diane Takvorian Environmental Health Coalition Douglas Kot Board Member & Advocacy Chair San Diego Green Building Council Clare Crawford Center on Policy Initiatives Johnny Simpson Business Manager IBEW Local 569 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 4
Emily Wier Steering Committee Member SanDiego350 Daniel Sullivan President Sullivan Solar Power Janice Webb, Regional President, San Diego California Nurses Association National Nurses United Julia Chunn-Heer Policy Manager San Diego County Surfrider San Diego County Chapter Bill Tippets Senior Project Director The Nature Conservancy Marco Gonzalez Coastal Environmental Rights Foundation Matt O'Malley Waterkeeper San Diego Coastkeeper Kenneth Grimes City Heights Community Development Corporation James A. Peugh Conservation Committee Chair San Diego Audubon Society Samantha Ollinger BikeSD Arnulfo Manriquez President & CEO MAAC Anne S. Fege, Ph.D., M.B.A., Program Manager San Diego Children and Nature Collaborative 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 5
Kevin C. Wood Chair San Diego County Bicycle Coalition Kay Ragan President League of Women Voters of San Diego John Reaves Founding Director Citizens Climate Lobby Cc: City Councilmembers Bill Fulton, Director, Planning, Neighborhoods & Economic Development Department Brian Schoenfisch, Sr. Planner, Planning, Neighborhoods & Economic Development Department David Weil, Deputy Director, Energy, Sustainability & Environmental Protection 5/19/14 - Support for Feb 2014 Draft City of San Diego Climate Action Plan, p. 6