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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations FirstCarbon Solutions 93 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx potential new sensitive receptors to less than significant levels. Adherence to the policies and programs of the General Plan would ensure compliance with existing BAAQMD policies to ensure the reduction of sensitive receptors exposure to toxic air contaminant. (Draft Program EIR, Page 3.2-55– 58). The City finds that MM AIR-1b is feasible, is adopted, and will further reduce impacts to related air quality. Accordingly, the City finds that, pursuant to Public Resources Code Section 21081(a)(1) and State CEQA Guidelines Section 15091(a)(1), changes or alterations have been required in, or incorporated into, the Housing Element Update that mitigate or avoid the potentially significant impacts as identified in the Program EIR. Therefore, impacts associated with air quality would be less than significant with mitigation incorporated. Cumulative Impacts: Cumulative impacts related to air quality would be potentially significant, but would be reduced to less than significant with implementation of MM AIR-1a and MM AIR-1b. (Draft Program EIR, Page 3.2-59–63). Findings: Less than significant impact with mitigation incorporated. (Draft Program EIR, Page 3.2-63). Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effects as identified in the Program EIR. (State CEQA Guidelines, § 15091(a)(1)) Mitigation Measures Implement MM AIR-1a and AIR-1b. Facts in Support of Findings: The geographic scope of the cumulative impact analysis for air quality is the SFBAAB. By its nature, air pollution is largely a cumulative impact resulting from emissions generated over a large geographic region. The nonattainment status of regional pollutants is a result of past and present development within an air basin, and this regional impact is a cumulative impact. In other words, new development projects (such as development consistent with the Housing Element Update) within the SFBAAB would contribute to this impact only on a cumulative basis. No single project would be sufficient in size, by itself, to result in nonattainment of regional air quality standards. Instead, a project’s emissions may be individually limited but cumulatively considerable when taken in combination with past, present, and future development projects. All new development that would result in an increase in air pollutant emissions above those assumed in regional AQPs would contribute to cumulative air quality impacts. The existence of significant cumulative impacts caused by other projects alone does not constitute substantial evidence that a project’s incremental effects would be cumulatively considerable. Rather, the determination of cumulative air quality impacts for construction and operational emissions is based on whether a project would result in regional emissions that exceed the BAAQMD regional thresholds of significance. Projects that generate emissions below the significance thresholds would be consistent with regional air quality planning efforts and would not be cumulatively considerable. The nonattainment regional pollutants of concern for the SFBAAB are ozone, PM10 and PM2.5. Ozone is a regional pollutant formed by a photochemical reaction in the atmosphere and not directly emitted into the air. Ozone precursors, such as VOC and NOX, react in the atmosphere in the