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page 2 Applying the metrics of Pleasanton's recently completed "Non-Residential Development Housing Linkage Fee Nexus Study",the "Nexus-Based Affordable Housing Fee Analysis for For-Sale Housing", and the "Nexus-Based Affordable Housing Fee Analysis for Rental Housing", all the alternatives proposed will generate demand for housing affordable to households with incomes below 80%and 50%AMI in excess of the amount of such housing provided. The EPSP assumes, optimistically, that plan will provide only 15% of the 30 du/acre portion of the development in apartments affordable to households earning less than 80%and/or 50%AMI.This is far less affordable housing than the need generated by the Plan's proposed market rate residential and commercial development. In addition, some of the Alternatives, including the Preferred Plan, fail to provide adequate (market rate) housing to accommodate the workforce demand generated by proposed nonresidential development. (See attached table). The nexus study also notes that, "...According to the U.S. Census Bureau's 'On the Map', 49.6 percent of all jobs located in the City of Pleasanton in 2010 paid less than $40,000 per year, which equates to the 'very low income' level for the County." Although Pleasanton has recently experienced a dramatic increase in higher paying jobs in the Information industry sector, the PEDSP also indicates that "...Pleasanton comprises nearly 40 percent of the Tri-Valley's 13.4 million square feet of retail in Pleasanton, Dublin, and Livermore...(and) leads the Tri-Valley in total taxable retail sales..." Retail sales jobs are among the lowest paying and, from 1995 to 2009, increased as a portion of Pleasanton's total jobs from 9%to 11%.The industry sector of Administration, Support, Waste Management & Remediation, another area providing Very Low Income jobs, also increased as a portion of all jobs,from 5.4%to 6.9%. Additionally, this sector led all others in startups, with an average of 112 annually, in contrast to the Information sector's 19 startups.The lowest paying Accommodations and Food Services sector also grew from 2,520 to 3,658 jobs,though it fell as a portion of the whole from 6.1%to 5.4%. Notwithstanding the lower wages paid by these industry sectors, Pleasanton encourages their growth, and reaps benefits from substantial sales tax revenue. However,the lower pay required to provide competitively priced goods and services currently precludes these sectors' employees from finding housing in Pleasanton, resulting in long commutes, and increasing greenhouse gas emissions. Given the rising percentage of employees commuting from beyond the Tri-Valley, the DEIR should identify, based on current Pleasanton employment for all industry sectors, (see Figure 19 of the "Pleasanton Economic Development Strategic Plan Background Report"), the amount of housing in the EPSP that will be affordable to employees currently holding jobs in Pleasanton. Also, per the Pleasanton Nexus Studies, please analyze project impacts based on generation of unmet lower income housing demand. Review the commute pattern information provided in the PEDSP (Figures 9-13), and additional information from U.S. Census Longitudinal Employer- Household Dynamics, 2010. Also review housing prices within Pleasanton's commute shed to determine where the additional lower income employees will reside if the EPSP builds out with the very limited amount of affordable workforce housing currently proposed.Then determine the air quality impacts of the additional in-commute of lower income workers who will provide services to EPSP residents and businesses.