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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update CEQA Findings of Fact and Statement of Overriding Considerations 120 FirstCarbon Solutions Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/FOF/21480022 Pleasanton Housing Element FOF.docx 1.8 - Findings Regarding Alternatives 1.8.1 - Introduction This section presents findings regarding alternatives to the Housing Element Update. The section provides a summary and discussion of the feasibility of the following alternatives evaluated in the Draft Program EIR: • No Project Alternative. • Alternative 1: Remove Select Industrial and Commercial Sites. • Alternative 2: Transit-Oriented Focus Alternative. • Alternative 3: Site Rankings Focus. In accordance with State CEQA Guidelines Section 15126.6, the Program EIR contained a comparative impact assessment of alternatives to the Housing Element Update. The primary purpose of this analysis is to provide decision-makers and interested agencies, organizations and individuals with information about a reasonable range of potentially feasible alternatives, which could avoid or reduce any of the Housing Element Update’s significant adverse environmental effects. Important considerations for this alternatives analysis are noted below: • An EIR need not consider every conceivable alternative to a project; • An EIR should identify alternatives that were considered by the lead agency, but rejected as infeasible during the scoping process; • Reasons for rejecting an alternative include: - Failure to meet most of the basic project objectives identified in Section1.3.2 - Infeasibility; and - Inability to avoid significant environmental effects. CEQA does not require that an analysis of alternate sites always be included in an EIR. Pursuant to State CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternate site, the “key question and first step in analysis is whether any of the significant effects of the project would be avoided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.” Because the City already completed an exhaustive evaluation of potential sites for rezoning, alternative sites would not meet the project objectives, and further evaluation of alternate sites as an alternative to the sites included in the proposed Housing Element Update would not be appropriate. Therefore, this alternative is rejected from further consideration. CEQA requires that an EIR analyze a “no project” alternative (State CEQA Guidelines § 15126.6(e)). Where, as here, this alternative means a project would not proceed, the discussion “[sh]ould compare the environmental effects of the property remaining in its existing state against environmental effects which would occur if the project is approved” (State CEQA Guidelines, § 15126.6(e)(3)(B)).