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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update <br />CEQA Findings of Fact and Statement of Overriding Considerations <br /> <br /> <br />FirstCarbon Solutions 87 <br />Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx <br />Conditions of Approval prior to issuance of grading or building permit, whichever is <br />sooner. <br />Outdoor Air Quality–Individual and common exterior open space, including <br />playgrounds, patios, and decks, shall either be shielded from the source of air pollution <br />by buildings or otherwise buffered to further reduce air pollution for project occupants. <br />Facts in Support of Findings: The current AQP applicable to the Housing Element Update is the 2017 <br />Clean Air Plan. A proposed land use plan is consistent with the AQP if it would (1) support the <br />primary goals of the AQP, (2) include applicable control measures from the AQP, (3) not disrupt or <br />hinder implementation of any AQP control measures, and (4) the plan’s projected VMT increase <br />must be less than or equal to its projected population growth. <br />1. The Housing Element Update Supports the Primary Goals of the AQP: The primary goals of the <br />2017 Clean Air Plan are to (1) attain air quality standards, (2) reduce population exposure and <br />protect public health, and (3) reduce GHG emissions and protect the climate. <br />Attain Air Quality Standards: Long-term criteria pollutant emissions would result from the <br />operation of potential residential uses facilitated by the Housing Element Update. <br />Operational air quality emissions are principally generated from area sources, energy sources, <br />and mobile sources. The method for determining whether a project or plan supports the <br />goals of the AQP is to determine whether that project or plan is consistent with a BAAQMD- <br />approved CEQA threshold of significance. The BAAQMD determines a plan, such as the <br />Housing Element Update, to result in an exceedance of recommended significance thresholds <br />if a plan facilitates growth in VMT that exceeds the growth in population over that same time. <br />The Housing Element Update would result in population growth which outpaces forecasted <br />VMT growth, and thus the Housing Element Update would not result in an exceedance under <br />this criterion. <br />In measuring whether an individual development project would have potentially significant <br />impacts on local and regional air quality, including consideration of an individual <br />development project’s contribution to an existing or forecasted air quality violation, the <br />BAAQMD recommends project-level significance thresholds for criteria pollutants and ozone <br />precursors. Considering the BAAQMD’s recommended significance thresholds and that the <br />SFBAAB is currently in nonattainment for PM standards, individual development projects <br />facilitated by the Housing Element Update would be considered to have potentially <br />significant site-specific or project-specific impacts related to the generation of fugitive dust <br />during construction activities if they do not implement BMP targeting dust control and <br />sediment migration. Therefore, Mitigation Measure (MM) AIR-1a, which would require <br />individual development projects to employ dust control measures recommended by the <br />BAAQMD during construction, would ensure that all future development projects facilitated <br />by the Housing Element Update would not result in potentially significant impacts related to <br />construction fugitive dust and contribute to the region’s current nonattainment status for <br />PM.