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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations 114 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx effects as identified in the Program EIR. (State CEQA Guidelines, § 15091(a)(1)). However, impacts would still remain significant and unavoidable even with mitigation incorporated. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measure or project alternatives identified in the Program EIR. (State CEQA Guidelines, § 15091(a)(3)) Mitigation Measures Implement MM TRANS-2. Facts in Support of Findings: The geographic scope of the cumulative impact analysis for transportation is the City of Pleasanton as well as the surrounding cities of Livermore, Dublin, and San Ramon and the Town of Danville. VMT: All cumulative projects would be required to comply with applicable federal, State, and local policies and ordinances and General Plan and Specific Plan programs and policies that address VMT, as well as mitigate their fair share of impacts related to VMT. Although development consistent with the Housing Element Update as a whole would result in a reduction in home-based VMT per resident it does not drop below the threshold of significance. Although development consistent with the Housing Element Update would reduce total VMT per service population by about 17 percent, from 36.9 to 30.5, the VMT would remain above the thresholds of significance of 22.0, indicating a significant impact related to VMT. MM TRANS-2 requires individual housing project development proposals in the city 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, with modifications as necessary, and analysis as part of the development application, and, if results indicate the VMT associated with the individual housing project would be above the applicable threshold, it would be required to include VMT reduction measures. However, even with incorporation of MM TRANS-2, which would partially reduce VMT impacts, the impacts associated with the Housing Element Update as a whole would remain significant and unavoidable. Therefore, development consistent with the Housing Element Update would result in a significant and unavoidable VMT impact and the Housing Element Update’s incremental contribution to the cumulative impact is significant; therefore, development consistent with the Housing Element Update’s contribution to cumulative VMT impacts would remain cumulatively considerable even with implementation of identified mitigation measures, resulting in a significant and unavoidable cumulative impact related to VMT. Even with incorporation of MM TRANS-2, the City may not achieve the overall VMT threshold reduction level due to uncertainty in the cumulative effectiveness of TDM measures as well as unknowns related to transit service levels, transportation technology, and travel behavior. Moreover, these policies and mitigation measures primarily apply to new developments; existing land uses that have already been approved and are under construction are generally not affected. Because of the programmatic nature of the Housing Element Update, no additional cumulative mitigation measures are available (Draft Program EIR, Page 3.14-27–29). Consequently, implementation of MM TRANS-2 would reduce the project’s contribution to cumulative VMT impacts; however, implementation of MM TRANS-2 would not be sufficient to