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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations 34 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx Findings: Less than significant impact. Facts in Support of Findings: Development consistent with the Housing Element Update would generate GHG emissions during temporary (short-term) construction activities such as site grading, operation of construction equipment, operation of on-site heavy-duty construction vehicles, hauling of materials to and from the future project sites, asphalt paving, and construction worker vehicle trips. Long-term operational GHG emissions would result from project-generated vehicular traffic, utilization of any landscaping equipment, off-site generation of electrical power, use of energy required to convey water to and wastewater to the potential sites for housing, hauling and disposal of solid waste from the potential sites for housing, any fugitive refrigerants from air conditioning or refrigerators, and operation of any proposed stationary sources such as backup generators or fire pumps. As previously discussed, the BAAQMD’s 2022 GHG significance thresholds state that a land use development plan, such as the Housing Element Update, has the potential to result in a significant impact if it cannot demonstrate consistency with Criterion A or Criterion B: A. Meet the State’s goals to reduce emissions to 40 percent below 1990 levels by 2030 and carbon neutrality by 2045; or B. Be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b). The Housing Element Update is analyzed under the BAAQMD’s Criterion B. By demonstrating that the Housing Element Update is consistent with the goals and policies of the CAP 2.0, this analysis also demonstrates that the Housing Element Update would support the State’s goals to reduce emissions by 40 percent below 1990 levels by 2030 and to achieve carbon neutrality by 2045, since the CAP 2.0 was adopted to support the achievement of those goals. The BAAQMD encourages the incorporation of Best Management Practices (BMPs) to reduce GHG emissions during construction. The BMPs recommended by the BAAQMD to reduce construction-related GHG emissions include maximizing the use of alternative fueled construction vehicles and equipment and local building materials as well as recycling or reusing construction and demolition waste to the maximum extent practicable. The General Plan and Municipal Code include policies and programs specifically designed to address GHG emissions during project construction activities. The General Plan includes GHG reduction strategies for developments approved prior to the adoption of the CAP 2.0 and required the adoption of the CAP 2.0. Municipal Code Section 9.20.080 supports reducing and recycling solid waste, recyclables, and organic waste. Municipal Code Section 9.21.030 includes development of waste management plans to divert construction waste from landfill. Recovering salvageable materials for recycling would lead to further reductions of GHG emissions. Future development projects where the City is the lead agency would need to show consistency with the BAAQMD’s 2022 GHG significance thresholds for land use development projects or incorporate mitigation to reduce impacts to less than significant levels. Additionally, the City requires that development projects demonstrate consistency with the CAP 2.0 by submitting the CAP 2.0 CEQA GHG Emissions Analysis Compliance Checklist to ensure projects comply with the GHG reduction strategies outlined in the CAP 2.0. For land use development projects, the BAAQMD recommends that the project