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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 113 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx appropriate by the City (e.g., to account for project-specific information and/or to reflect future updates to the Alameda Countywide Travel Demand [Alameda CTC] Model and/or other methodologies acceptable to the City), shall provide a VMT analysis using the methods applied in this Draft Program EIR, with modifications as deemed appropriate by the City (e.g., to account for project-specific information and/or to reflect future updates to the Alameda CTC Model and/or other methodologies acceptable to the City), and reduce VMT impacts to less than the applicable VMT thresholds, to the extent feasible. Facts in Support of Findings: As shown in Table 3.14-2 on Page 3.14-23 – 25 of the Draft Program EIR, development consistent with the Housing Element Update is estimated to reduce the home- based VMT per resident, with an average of 22.3 VMT per resident in 2040. This does not result in the VMT being below the threshold of significance of 15.0 (i.e., 15 percent below the Alameda County 2040 No Project Average home-based VMT per capita). Although development consistent with the Housing Element Update as a whole would result in a home-based VMT per resident reduction, the average does not drop below the threshold of significance, as shown in Table 3.14-2, and almost all of the sites are above the threshold of significance as shown in Table 3.14-3. As shown in Table 3.14-4, development consistent with the Housing Element Update would reduce the VMT per service population for the potential sites for housing by about 17 percent, from 36.9 to 30.5. However, the VMT of 30.5 for the potential sites for housing is above the threshold of significance of 22.0, indicating a significant impact related to VMT. Mitigation Measure (MM) TRANS-2 requires individual housing project development proposals that do not screen out from a VMT impact analysis to provide a quantitative VMT analysis using the methodology used for the Draft Program EIR analysis and, if results indicate the VMT associated with the individual housing project would be above the threshold, it would be required to include VMT reduction measures. Projects which result in a significant impact may implement Transportation Demand Management (TDM) measures and physical measures to reduce VMT. The measures would not be additive and combining the reduction measures reduces their effectiveness resulting in a cap on the total VMT reduction these measures can provide. Because the effectiveness of the VMT reduction measures in reducing an individual development project’s VMT impact to a less than significant level cannot be confirmed in the analysis provided in the Draft Program EIR, the impact would remain significant and unavoidable with mitigation (Draft Program EIR, Page 3.14-23). Consequently, implementation of MM TRANS-2 would reduce project VMT; however, implementation of MM TRANS-2 would not be sufficient to reduce impacts to less than significant levels. The City finds that MM TRANS-2 is feasible, is adopted, and will reduce impacts to the greatest extent feasible. However, impacts would remain significant and unavoidable even with mitigation incorporated. Cumulative Impacts: Development consistent with the Housing Element Update would result in a significant and unavoidable cumulatively considerable contribution to the existing cumulative VMT impact even with mitigation incorporated (Draft Program EIR, Page 3.14-27–29). Findings: Changes or alterations have been required in, or incorporated into, the Housing Element Update which avoid or substantially lessen the significant environmental