SUPPLEMENTAL MATERIAL - Laserfiche WebLink

Citizens for a Caring Community P.O. Box 1781 , Pleasanton CA 94566 September 2, 2014 Mayor Jerry Thorne &JU ? L a RA-k Pleasanton City Council ProvidOei to tNo City Couftd0 Re: Housing Element Draft AftOr oitlt$ibuUUon of PP et Dear Mayor Thorne and City Councilmembers, DM Citizens for a Caring Community has reviewed the staff report and the amended draft of the Housing Element. Because you have already received a significant amount of input from us on the Draft,these comments will focus on the new, but related, question of environmental impacts of implementing the Housing Element as proposed and the EIR Addendum prepared by PMC. We do not believe their analysis is adequate,and that the City is required to prepare a supplemental EIR. Since the adoption of the Housing Element for 2007-2014,the City has new information regarding the probable impacts of implementing its Housing Element.The City acquired this information as a result of the Nexus Study it commissioned in 2012 regarding the housing need generated by various forms of commercial and residential development. In addition,the City has learned how much affordable housing development on land zoned 30 units/acre will yield under the Pleasanton's unenforceable IZO, including various incentives available to market rate developers and property owners. Below see the number and percentages of affordable units produced under the current Housing Element goals and policies.This includes the Inclusionary Zoning Ordinance (IZO),which is not proposed for any changes although the lack of an enforceable ordinance has proved a severe impediment to fulfilling Pleasanton's regional housing responsibilities (RHNA). Here is the number of affordable units out of the 1,534 HDR units approved as of September 2013. Very Low and Extremely Low Income(<50%AMI) Low Income(51-80%AMI) Units affordable at<49% AMI: 0 approved Units affordable at 60% AMI:16 approved Units affordable at 50%AMI: 147 approved Units affordable at 80%AMI: 16 approved 1,076 needed for 0-50% per RHNA. 1,599 needed per RHNA. 14% of total need approved 3.4% of total need approved Therefore, according to point 3 A and B on page 3.0-2 of the Environmental Analysis, a Supplemental DR is required. The metrics of the Nexus Study show a net increase in affordable housing demand created by the very high percentage of market rate units allowed under the IZO. The City could mitigate these impacts (a quantifiable increase in Pleasanton's unmet affordable workforce housing demand, increased commute traffic, and increased greenhouse gas emissions)with policies and programs to provide nonprofit housing on land zoned for RHNA at 30 units/acre. However, the City has chosen not to pursue a nonprofit development strategy on land it zones for affordable housing, and has declined to implement a funding strategy to support an adequate amount of nonprofit housing to meet the needs of Pleasanton's workforce. Therefore, 3D also applies, which covers the circumstance where "project proponents" (City of Pleasanton), decline to implement a mitigation measure. Given the availability of new information, the recommendation not to change the core IZO regulation causing the impact, and the City's decision not to adequately fund mitigation of increased workforce housing demand and increased GHG emissions, the current ER addendum is not appropriate. Very sincerely, & ck y oiann za Citizens for a Caring Community •