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December 5, 2022 Megan Campbell, Associate Planner City of Pleasanton Post Office Box 520 Pleasanton, CA, 94566 SUBJECT: Response to the Draft Environmental Impact Report (DEIR) for the City of Pleasanton Housing Element Update Dear Megan, Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the City of Pleasanton Housing Element Update. In order to meet the City’s Regional Housing Needs Assessment targets, the proposed Housing Element Update identifies 25 sites for potential rezoning to accommodate a maximum of 7,795 units able to house up to 18,044 residents. The City of Pleasanton’s Sphere of Influence covers 42.2 miles of incorporated land within Pleasanton city limits as well as unincorporated lands, and will serve as the project’s boundary and service area. The General Plan and Specific Plan will be amended as needed to maintain consistency with the updated Housing Element. The Alameda County Transportation Commission (Alameda CTC) respectfully submits the following comments: x Alameda CTC appreciates the use of the Countywide Travel Demand Model to determine the project’s impacts to Vehicle Miles Traveled (VMT), as well as the DEIR’s acknowledgement that the model does not reflect the impacts of the COVID-19 pandemic on travel patterns. However, on page 3.14-9, the DEIR states that the Travel Model “includes data from February of 2020.” Please note that the latest version of the Countywide Travel Model, updated in May 2019, uses 2010 as a base year to forecast 2020 conditions. x On page 3.14-10, the DEIR states that the methodology for the transportation impact analysis is based on VMT in accordance with Senate Bill 743, however a Level of Service (LOS) analysis is required by the City of Pleasanton’s General Plan and will therefore be conducted separately. Current Congestion Management Program legislation also requires an analysis of potential impacts on regionally significant roadways using a delay-based metric, such as LOS. This analysis may not be used to determine project impacts or required mitigations, and may be provided to Alameda CTC outside the CEQA process. Please make this legislatively required document available to Alameda CTC as well as the City of Pleasanton. x Alameda CTC appreciates the identification of active transportation improvements from the City of Pleasanton’s Master Plan, which will be located near the project area, beginning on page 3.14- 7. Many of these improvements, such as plans for facilities on Stoneridge Drive and Stoneridge Mall Road, are phased, with protected infrastructure recommended in the long-term. Alameda CTC encourages the City of Pleasanton to implement projects that follow best practices in the near-term wherever possible, and prioritize corridors on the Countywide Bikeways Network (which, in Pleasanton, includes West Las Positas, Foothill, Bernal, Pleasanton-Sunol, Santa Rita, $/$0('$&7& 3DJHRI