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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations 90 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx Mitigation Measures Implement MM AIR-1a and MM AIR-1b. Facts in Support of Findings: Construction: Future development facilitated by the Housing Element Update would result in short-term construction-related criteria pollutant emissions that have the potential to have an adverse effect on air quality. Short-term criteria pollutant emissions would occur during demolition, site preparation, grading, building construction, paving, and architectural coating activities associated with individual development projects. ROG and NOX emissions are primarily associated with gasoline and diesel equipment exhaust and the application of architectural coatings. Fugitive dust emissions (PM10 and PM2.5) are primarily associated with site preparation and vary as a function of such parameters as soil silt content, soil moisture, wind speed, acreage of disturbance area, and VMT by construction vehicles on- and off-site. Typical construction equipment associated with development and redevelopment projects includes dozers, graders, excavators, loaders, and trucks. The BAAQMD maintains and recommends project-level thresholds to which potential future development projects consistent with the Housing Element Update would be subject. For all projects, the BAAQMD recommends implementation of eight Basic Construction Measures to reduce construction fugitive dust emissions, as outlined on Page 3.2-53–54 of the Draft Program EIR. The BAAQMD determines a less than significant impact with respect to construction fugitive dust emissions if the eight measures are implemented during project construction. Criterion identified by the BAAQMD for determining plan-level significance with respect to criteria air pollutants and ozone precursors is determining project consistency with the current AQP control measures, which are intended to ensure the region's achievement and maintenance of attainment of federal and State AAQS. As the SFBAAB is currently designated as a nonattainment area for PM, and considering that the BAAQMD’s recommended significance threshold for construction fugitive dust is binary—meaning if a project includes dust control BMPs then construction fugitive dust emissions would be less than significant, but if a project does not explicitly include dust control BMPs then construction fugitive dust emissions would be potentially significant—MM AIR-1a would be required to ensure that individual development projects facilitated by the Housing Element Update would result in less than significant construction fugitive dust impacts. MM AIR-1a contains BAAQMD’s Basic Construction Mitigation Measures Recommended for All Proposed Projects, as included in the BAAQMD’s 2017 CEQA Air Quality Guidelines, which are recommended by the BAAQMD to reduce construction fugitive dust emissions. Operation–Consistency with Air Quality Plan Control Measures: It was assumed all housing facilitated by the Housing Element Update would become fully operational in 2031. Implementation of the Housing Element Update could result in the development and operation of up to 7,787 net new residential units. As the City receives applications for subsequent development, those applications would be reviewed by the City for compliance with MM AIR-1a and MM AIR-1b and the programs and policies in the General Plan, which may require additional site-specific or project-specific measures to reduce any potential impacts and ensure that impacts remain less than significant. As discussed in Impact AIR-1, the Housing Element Update would be consistent with the 2017 Clean Air Plan control measures. As such, the Housing Element Update would be consistent with the current AQP control measures.