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AGENDA BILL Agenda Item No. 7(B) Date: May 21, 2013 To: El Cerrito City Council From: Maria Sanders, Environmental Analyst Melanie Mintz, Community Development Interim Director Subject: Adoption of El Cerrito Climate Action Plan ACTIONS REQUESTED Approve a resolution adopting the El Cerrito Climate Action Plan. BACKGROUND Since 2006, the El Cerrito City Council has consistently supported local, regional and state initiatives to cut the pollution that causes global warming and climate change. The following Council resolutions laid the groundwork for developing a local Climate Action Plan (CAP): • Resolution 2006-61 endorsed the U.S. Mayors Climate Protection Agreement, in which local governments agree to take greenhouse gas (GHG) reduction measures, including the development of a Climate Action Plan; • Resolution 2006-93 endorsed the reduction targets of the California Global Warming Solutions Act (AB 32); and • Resolution 2011-12 adopted GHG emission reduction targets of 15% below 2005 levels by the year 2020 and 30% below 2005 levels by 2035 for both municipal operations and the El Cerrito community. Development of the CAP started in 2010 and has been informed by input from the public, City Council, and City staff. The City administered a survey in 2010 of 450 residents,1 held three public workshops in late 2010 to brainstorm GHG reduction strategies,2 and held another workshop in 2012 to review the final set of strategies. In addition, staff provided numerous updates at publicly noticed meetings of both the City Council and the Environmental Quality Committee (EQC). The draft Climate Action Plan was released for public review in February 2013, the results of which are discussed in this Agenda Bill. 1 See CAP, Vol.2, Appendix L, Climate Action Survey Results. 2 See CAP, Vol.2, Appendix M, Public Workshop Notes. ---PAGE BREAK--- Agenda Item No. 7(B) Page 2 DISCUSSION CAP Elements: The purpose of the CAP is to provide a roadmap for the City in pursuing both community-wide and municipal reductions in GHG emissions. Development of the CAP is based on a methodology advanced by ICLEI Local Governments for Sustainability and further refined by the Bay Area Air Quality Management District (BAAQMD). This methodology investigates the potential of reducing local GHG emissions from transportation, energy consumption, water use, and waste generation at the local level. The CAP models GHG emissions from both community and municipal sources using the baseline year of 2005 and projects the growth in these emissions under a Business-As-Usual (BAU) scenario and under a Reduction Targets Scenario (see CAP Chapter 2, El Cerrito’s Greenhouse Gas Emissions). The CAP also identifies potential reductions in emissions from actions taken at both the community and municipal levels (see Chapter 3, Community Climate Action Strategies and Chapter 4, Municipal Climate Action Strategies). Under each emissions source, the CAP outlines and quantifies carbon dioxide (CO2) reductions from a number of goals, objectives and strategies that will help achieve the reduction targets set by City Council. The areas of action are summarized below: • Transportation: Land Use, Community Development and Transportation measures to reduce the vehicle miles traveled in El Cerrito by encouraging higher-density, transit-oriented development; making pedestrian- and bicycle- friendly infrastructure improvements; promoting urban greening; and offering trip reduction programs. • Energy and Water: Resource conservation measures designed to achieve greater energy efficiency, water efficiency, and renewable energy in existing and new buildings through education, incentives, and ordinances. • Waste: Waste reduction and recycling measures to increase participation in waste reduction programs and to expand recycling opportunities at the Recycling and Environmental Resource Center. Also included under this section is development of a Zero-Waste 2035 Plan. • Municipal Operations: Cross-sector measures to reduce GHG emissions from municipal operations, particularly those associated with transportation, energy and water use, procurement, and waste generation in municipal operations. A comprehensive list of all goals, objectives and strategies is contained in CAP Volume 2, Appendix G, Summary of Goals, Objectives and Strategies and Consistency with General Plan. Many of these strategies are already being advanced by the City as part of its overall efforts towards creating a more livable, safe and sustainable community. New policies, programs, or projects proposed in the CAP would be further investigated, planned and implemented after the CAP is adopted. As appropriate, each will go through its own processes of public review, adoption, funding and implementation. ---PAGE BREAK--- Agenda Item No. 7(B) Page 3 In addition, as discussed in Chapter 6, Implementation, El Cerrito’s progress towards meeting these targets will be monitored over time. Through this monitoring process, CAP implementation will be reexamined as part of an adaptive management approach that will take into account updated information, changing policy, and advancements in technology. Qualified Climate Action Plans under CEQA: In 2007, Senate Bill 97 required GHG emissions to be analyzed under CEQA. The California Resources Agency (CRA) developed guidelines for evaluating GHG emissions from development projects. These guidelines provided jurisdictions with the option to develop “Qualified” Climate Action Plans that could be used as tiering documents for the purpose of streamlining the analysis of GHG emissions under CEQA. While the City’s CAP contains all the elements required under the CRA guidelines, staff determined that the cost of maintaining a Qualified CAP outweighed the benefits of allowing developments to streamline this one relatively inexpensive aspect of CEQA analysis. Staff’s determination took into account that the City is in the process of completing the San Pablo Avenue Specific Plan and will be updating its General Plan. These documents will incorporate the goals of the Climate Action Plan and will be developed to be more comprehensive as tiering documents. CAP Public Review Process: The City released the draft CAP and related environmental documents on February 12, 2013 and held 2 meetings to outline the elements of the CAP and to receive public comment. The City Council also received an informational presentation on the contents of the draft CAP on February 19, 2012. The public comment period lasted 32 days and was closed on March 15, 2013. The draft CAP and related environmental documents were also circulated to the State Clearinghouse and to the Bay Area Air Quality Management District (BAAQMD). Staff revised the CAP based on comments received during the public comment period. The revised CAP was considered by both the EQC and the Planning Commission during their regular meetings on April 9 and April 10, respectively. Both bodies took formal action recommending approval of the CAP by the City Council. Public Comments Received: During the public comment period, 26 members of the public provided either verbal or written comments on the draft CAP. A large majority of comments received were positive. Several comments focused on whether the reduction targets set by City Council were aggressive enough. One commenter questioned the validity of the science behind global warming and the reality of a changing climate, and was therefore against the development of a Climate Action Plan. Most comments were suggestions for additional strategies to be included in the CAP. Most of the suggested strategies were either included in the CAP as an already identified measure streamline and create permitting incentives to encourage home weatherization) or as a possible avenue of implementation under an already identified measure. For instance, one comment suggested “providing incentives for solar,” which, depending on available resources, could be an element of the Go Solar strategy under Objective EW-3.1, ---PAGE BREAK--- Agenda Item No. 7(B) Page 4 “Develop and implement a strategy to facilitate greater adoption of solar and renewable energy use in the residential and commercial sectors.” A smaller set of comments were added as new strategies to the CAP under existing CAP goals and objectives. These strategies were added because they were consistent with results of the public workshops held thus far for the CAP, consistent with the overall scope and methodology of the CAP, and consistent with the CAP goal and objective under which they were added. Finally, some suggestions were not included in the CAP because they were either outside the scope of the CAP did not have an obvious greenhouse gas emissions reduction benefit), were never aired during the public input process, or were inconsistent with the City’s current General Plan or other goals in the CAP. Attached is a summary of public comments, including a list of changes incorporated into the final CAP. FINANCIAL CONSIDERATIONS There are no financial obligations associated with adoption of the CAP. However, implementation of the CAP does have associated costs. Much of the CAP will be implemented by existing staff and through existing programs and practices and/or outside resources. If and when additional City funds are necessary for a specific project or program to be implemented, financial considerations will be discussed and City Council authorization will be sought at that time. It should be noted that there are many factors that will mitigate CAP implementation costs, since climate protection activities are often implemented in the course of completing other actions. For instance, most measures intended to reduce vehicle miles traveled, such as Transit-Oriented Development and improved pedestrian amenities, are goals already advanced in the General Plan and other related plans and policies, and thus their implementation would not be solely to reduce emissions. Other emissions reduction measures, such as those that result in increased energy, water, and fuel efficiencies, can be very cost effective and result in long-term cost savings. Finally, there are sources of state and federal funding available for programs and projects that reduce greenhouse gases. Staff will pursue such funding to advance the implementation of the CAP. LEGAL CONSIDERATIONS Pursuant to CEQA, the City prepared an Initial Study (IS). The Initial Study did not identify any significant environmental impacts presented by the CAP and a Negative Declaration (ND) was prepared. Both the CAP and the IS/ND were reviewed by the City Attorney. A Notice of Intent to adopt a Negative Declaration was posted on February 14, 2013. The Negative Declaration was also filed with the State Clearinghouse at the California Office of Planning a Research. Public comment on the environmental documents also closed on March 15, 2013. Staff did not receive any public comments resulting from the circulation of the Draft Initial Study/Negative Declaration. At its April 10, 2013 meeting, the Planning Commission passed Resolution PC13-06, adopting the Final Negative Declaration for the CAP. ---PAGE BREAK--- Agenda Item No. 7(8) Reviewed by: Scott Hanin, City Manager Attachments: 1. Resolution 2. Final El Cerrito Climate Action Plan 3. Summary of Public Comment and Responses Page 5 ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 1 RESOLUTION 2013-XX RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL CERRITO ADOPTING THE EL CERRITO CLIMATE ACTION PLAN WHEREAS, there is a scientific consensus, as established by the Intergovernmental Panel on Climate Change and confirmed by the National Academy of Sciences, that the continued buildup of anthropogenic greenhouse gases in the atmosphere threatens the stability of the global climate; and WHEREAS, there are significant long-term risks to the economy and the environment of the United States, California, and the City of El Cerrito from the climatic disruptions that are projected to result from increased greenhouse gas concentrations; and WHEREAS, the City of El Cerrito has adopted resolutions supporting state and local actions to reduce greenhouse gas emissions, including Resolution 2006-61 endorsing the U.S. Mayors Climate Protection Agreement and Resolution 2006-93 endorsing the reduction targets of the California Global Warming Solutions Act (AB 32); and WHEREAS, local governments greatly influence their community’s greenhouse gas emissions by providing leadership and by exercising key powers over land-use, transportation infrastructure, building construction, and waste management; and WHEREAS, local government actions to reduce greenhouse gas emissions provide multiple local benefits by decreasing air pollution, creating jobs, reducing energy expenditures, and saving money for City government, its businesses, and its citizens; and WHEREAS, the City of El Cerrito adopted Resolution 2008-33 accepting El Cerrito’s 2005 baseline greenhouse gas emissions inventory and directing staff to develop a Climate Action Plan; and WHEREAS, the City of El Cerrito adopted Resolution 2011-12 adopting the following greenhouse gas emissions reduction targets for the El Cerrito community and its own city operations of 15% below 2005 emissions levels by 2020 and 30% below 2005 levels by 2035; and WHEREAS, the El Cerrito Climate Action Plan has been drafted in order to guide implementation of the greenhouse gas emissions targets adopted by City Council; and WHEREAS, the City administered a survey involving 450 residents and conducted four public meetings as part of the development of the Climate Action Plan; and ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 1 WHEREAS, the Environmental Quality Committee held two public meetings to receive public comment on the draft Climate Action Plan and, on April 9, 2013, passed a motion recommending City Council adoption of the Climate Action Plan; and WHEREAS, a Negative Declaration was prepared and duly noticed for the Climate Action Plan pursuant to the California Environmental Quality Act, and the Planning Commission passed Resolution PC13-06 adopting the Negative Declaration and recommending City Council adoption of the Climate Action Plan on April 10, 2013. NOW THEREFORE, BE IT RESOLVED by the City Council of the City of El Cerrito that it hereby adopts the El Cerrito Climate Action Plan, herein attached as Exhibit A to this resolution and incorporated by reference. BE IT FURTHER RESOLVED, that this Resolution shall become effective immediately upon passage and adoption. I CERTIFY that at a regular meeting on May 21, 2013 the City Council of the City of El Cerrito passed this Resolution by the following vote: AYES: COUNCILMEMBERS: NOES: COUNCILMEMBERS: ABSENT: COUNCILMEMBERS: IN WITNESS of this action, I sign this document and affix the corporate seal of the City of El Cerrito on 2013. Cheryl Morse, City Clerk APPROVED: Gregory B. Lyman, Mayor ---PAGE BREAK--- OFFICE OF THE CITY CLERK CITY HALL 10890 San Pablo Avenue, El Cerrito, CA 94523-3034 Telephone (510) 215-4305 Fax (510) 215-4379 http://www.el-cerrito.org May 21, 2013 Regular City Council Meeting Agenda Item No. 7(B) - Climate Action Plan Adoption Attachment 2 – Final Plan and Appendices are available for review on the City’s website: Download document (excluding appendices) - large PDF Or, download by section: (all PDF) Executive Summary (and table of contents) Chapter 1: Climate Change in Context Chapter 2: El Cerrito's Greenhouse Gas Emissions Chapter 3: Community Climate Action Strategies Chapter 4: Municipal Climate Action Strategies Chapter 5: Personal Climate Action Chapter 6: Implementation Appendices Hardcopies of the report and appendices are available for review at: Office of the City Clerk and The El Cerrito Library 10890 San Pablo Avenue 6510 Stockton Avenue El Cerrito, CA El Cerrito, CA (510) 215-4305 ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 Attachment 3 El Cerrito Draft Climate Action Plan Public Comment and Responses April 9, 2013 Summary of Changes Made to the Climate Action Plan Based on public comment received during the public review period of February 12 through March 15, 2013, the following have been included in the Final Climate Action Plan. Executive Summary Page IX: Footnote added to define green house gas emissions: “Gases that trap heat in the atmosphere are called greenhouse gases. While there are many natural sources of greenhouse gases, the burning of fossil fuels- such as coal, natural gas, and oil - is a common man-made source of greenhouse gases.” Page IX: Footnote added to describe Assembly Bill 32: “AB 32, signed by Governor Schwarzenegger in 2006, requires California to reduce statewide GHG emissions to 1990 levels by 2020.” Chapter 1: Climate Change in Context Page 3: Footnote added to define “tiering”: “Tiering under CEQA typically refers to the analysis of broad environmental issues associated with development under a plan, program, or ordinance in a program EIR and the subsequent preparation of more narrowly focused individual project EIRs.” Page 8: Existing footnote added to text to emphasize consumer cost savings. Error in cost savings corrected: “In 2005, El Cerritans spent approximately $48.6 million on energy, fuel, water, and waste disposal. If each household reduced their use of these commodities just 15%, they would have another $700 per year of disposable income.” Chapter 2: El Cerrito’s GHG Emissions Page 16: Statistics for “Population” and “Tons CO2e per Capita” added to Figure 2.5 “GHG Forecast and Reduction Targets.” Chapter 3: Community Climate Action Strategies Land Use, Transportation, and Community Development Page 21: Underlined text added to list of “Climate Actions Since 2005”: ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 “Worked with El Cerrito Trail Trekers towards restoring the City’s network of public paths and trails.” Page 26: To make more legible, Figure 3.1, Del Norte BART Station repeated in larger form to Appendix K: Home Location of BART Riders by Mode. Page 27: Underlined text added to strategy under Objective SC-2.1: “Link the City’s main commercial nodes through a network of open space, public art, and other cultural, historic amenities that encourage people to linger longer.” Page 28: Underlined text added to Objective SC-2.2: “Enhance neighborhood-serving commercial nodes and encourage the development of commercial spaces in mixed-use areas that can better serve the daily needs of residents, businesses, and people who work in El Cerrito.” Page 30: Underlined text added to strategy under Objective SC-3.2: “Develop a wayfinding signage program to promote use of pedestrian trails and stairs, including as a way to improve pedestrian access to schools and transit.” Page 30: Underlined text added under Objective SC-3.3: “The Ohlone Greenway Master Plan, adopted in 2009, sets forth the vision of how the Ohlone Greenway will evolve and develop over time, provides design guidelines, and priotizes public improvements to maximize the public’s safety, use, and enjoyment of this major pedestrian and bicycle path connecting the entire length of the City.” Page 31: Underlined text added to Objective SC-3.4: “Expand and improve the City’s transit, bicycle, pedestrian, and zero-emissions vehicle infrastructure.” “The City received funding in 2012 to update the Bicycle and Pedestrian Circulation Plan (Bike/Ped Plan), which is anticipated to be complete in 2014. During the community input process for the CAP, participants provided the following suggestions for improving El Cerrito’s bicycle and pedestrian infrastructure, which will be reviewed as part of the Bike/Ped Plan update:” Underlined text added to descriptor under Objective SC-3.4: ”Develop strategies for facilitating greater bike/ pedestrian connections between transit facilities along San Pablo Avenue and the hillside neighborhoods, such as encouraging casual carpool sites, an electric “zoo train” or funicular on major east-west corridors, such as Moeser Avenue.” ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 Underlined text added to strategy under Objective SC-3.4: “Work in conjunction with regional efforts to support the development of electric vehicle charging stations in appropriate locations throughout El Cerrito.” Page 32: Underlined text added to Objective SC-3.5: “Collaborate with the West Contra Costa Transportation Advisory Committee (WCCTAC), BART, AC Transit, WestCAT, major employers, and schools to support improvements and greater access to transit facilities throughout El Cerrito.” Underlined text added and strikethrough text deleted to strategies under Objective SC-3.5: “Seek grant opportunities to implement improvements identified in the West County Transportation Enhancement and Transit Wayfinding Projects and to fund pilot projects that increase access to transit.” “Work with WCCTAC, 511 Contra Costa, employers, shopping centers, and schools in El Cerrito and nearby communities (such as Berkeley National Lab’s new Richmond Field Campus) to develop commuter trip reduction programs to decrease single-occupant vehicle use in El Cerrito’s transit, commercial, and educational centers. parking in and around the BART stations in El Cerrito.” “Identify and help mitigate barriers, such as lack of access to high speed broadband in business centers, to employers being able to use high tech solutions, such as video conferencing, to cut down on business travel.” Page 35: Underlined text added to Objective SC-4.2: “Promote Bay-Friendly tree planting and landscaping, and the creation of green and open space that is attractive and helps restore natural processes, sequester carbon, clean storm water, conserve resources, and connect citizens to El Cerrito’s natural environment.” Underlined text added as a strategy under Objective SC-4.2: “Seek funding to increase the urban forest through a variety of programs, including a street tree planting and stewardship program.” Page 36: Underlined text added as a strategy under Objective SC-5.2: “Promote organized hiking events to increase use and awareness of the City’s pedestrian paths and trail network.” Chapter 3: Community Climate Action Strategies Energy and Water Page 46: Underlined text added as strategies under Objective EW-4.2: “Seek grant opportunities to provide incentives for water conservation strategies.” ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 “Work with East Bay Municipal Utility District to bring recycled water to El Cerrito.” Chapter 3: Municipal Climate Action Strategies Page 56: Underlined text added to descriptor under Municipal Goal “In addition, City employee commutes to and from work, resulting in a significant amount of vehicle miles traveled (VMT), are the 3rd largest source of GHG emissions associated with municipal operations.” Appendices: Pages 32-50 Updated “Appendix G: Summary of Goals, Objectives, and Strategies” to include all changes to strategies and objectives described above. Page 63: Added “Appendix K: Home Location of BART Riders by Mode” Response to Other Public Comments Received Comment Response General Are the GHG emission reduction targets ambitious enough given the scale of the problem? These reduction targets were adopted by the City Council in 2011 and can be revised by Council. Due to El Cerrito’s residential nature where the majority of emissions come from 10’s of 1,000’s of individual decision makers, these targets are ambitious. Instead of focusing on a relatively few large sources, El Cerrito’s success in reaching these targets will need to come from the many small, aggregated actions taken by its residents and businesses, which will require significant education and outreach. Do we have enough buffer identified in the Plan to achieve our reduction targets if all the strategies are not fully implemented? During the monitoring process, we will be able to monitor progress towards the reduction targets. During updates to the Plan, new actions can be added, especially as new funding, programs and technologies become available. The CAP should have a more explicit implementation timeline and indicators or metrics that the City and public can use to measure progress over time. Given the changing nature of funding opportunities and access to resources and programs that can help implement the CAP, prioritization of actions for implementation is more appropriate as part of the annual CAP Implementation Report, as discussed in the “Monitoring and Continuous Improvement” section of Chapter 6, Implementation. The City is currently developing progress indicators in conjunction with the STAR (Sustainability Tools for Assessing and Rating) Communities Index, a national consensus-based framework for gauging the sustainability and livability of US communities. Climate, energy, transportation, and community health indicators are being developed as part of this process. ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 The premise of developing a Climate Action Plan is faulty because human caused climate change and global warming is a lie. The CAP was developed as part of a long-term, open public process that has engaged hundreds of citizens, the vast majority of whom believe, when surveyed, that climate change is a serious problem requiring action. The CAP should include actions responding to sea level rise, wildfire, structural fire, public health, and include other “adaptations” to make El Cerrito more resilient to the impacts of climate change. While there is a discussion of the effects of climate change on El Cerrito (beginning on page 5) and a preliminary list of issues and strategies (page 52), “adaptation” planning is beyond the scope of the current CAP. Because adaptation planning intersects with infrastructure improvements and emergency preparedness, it should be undertaken in conjunction with updating the General Plan and the Local Hazards Mitigation Plan. Land Use, Transportation, and Community Development Increase Allowable Densities Not Just Along San Pablo Avenue: Several comments suggested also increasing allowable densities beyond the San Pablo Avenue Corridor and also allowing more neighborhood serving businesses in neighborhoods. These suggestions were not included for the primary reason that the CAP should not be inconsistent with the El Cerrito General Plan, which currently seeks to preserve the existing nature of residential neighborhoods. The more appropriate time to consider these suggestions is during an update to the General Plan. The CAP should add historic preservation as a way to ensure that El Cerrito retains its sense of place to increase pedestrian activity. While historic preservation may be a place making strategy, it is not explicitly a GHG reduction strategy and was therefore outside the scope of the CAP. Energy and Water Provide Incentives for Energy and Water Savings: Multiple comments requested the City provide incentives for home energy reports and the installation of resource conserving technologies such as solar electric and hot water systems, rain barrels, laundry-to- garden gray water kits, and energy efficiency upgrades. These suggestions were not explicitly incorporated into the CAP because they fall under existing strategies as possible program elements in the design of any of the public outreach and education programs. Availability of any incentives would be contingent on assistance from available outside resources, such as grants. Develop ordinances requiring energy performance reports and/or energy efficiency improvements at time-of-sale or lease: Multiple comments suggested the development of ordinances that would require either disclosure or improvements at Time-of-Sale for both residential and These approaches are investigated as possible avenues of action under “EW-1.3: Utilize existing points of interaction with the City to encourage and/or require cost-effective energy and water efficiency improvements.” However, as stated on page 39, participants in the CAP public workshops preferred education and incentives to reach our goals, with the option of using a more regulatory approach at later phases, if voluntary measures fell short. For commercial properties, disclosure of the energy ---PAGE BREAK--- Agenda Item No. 7(B) Attachment 3 commercial property. performance of a building at time-of-sale or lease is already mandate by Assembly Bill 1103, see page 41 of the CAP. Allow retroactive rewards/ incentives back to 2005 for upgrades and reductions. Most, if not all, incentive programs are designed to encourage new participation. Incentives for energy and water efficiency will most likely be available through grants or utility funds, which explicitly prohibit retroactive rewards. Ban leaf-blowers and other tools using fossil-fuel powered 2- stroke engines. Fuel consumption and emissions from this type of equipment is not easily measured or monitored and was not included in the CAP’s baseline inventory. In addition, such a ban was never discussed during the CAP public input process. It is therefore currently not included as a GHG reduction measure. However, in future updates of the CAP or through policy making outside the CAP, regulation of these sources of pollution could be investigated by the City. As is the case with the development of any policy item, a ban would need to go through its own planning and public review process. Waste Require landlords to provide GHG and recycling information to tenants. It is mandatory in California for all multi-family buildings with more than 5 units to provide recycling services. As part of implementing that law, the City has conducted outreach to the owners and managers of these properties and has provided recycling information. Provide incentives to homeowners, tenants, landlords, and trash company to support infrequent smaller trash loads. The Franchise Agreement with East Bay Sanitary, Company - and the rates it charges to homeowners, tenants and landlords – currently provides incentives to support infrequent collection of small trash containers. The City Council has given policy direction to maintain the current incentive structure in the future. Provide a Tool-Lending Library This could be a possible avenue of implementation as part of the Zero-Waste Plan mentioned on page 51 and would be investigated as part of that strategy.