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