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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update Responses to Written Comments Final EIR 2-70 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480022/EIR/4 - Final EIR/21480022 Sec02-00 Responses to Written Comments_TRACKS.docx There is no generally applied or accepted methodology for forecasting the potential application of density bonuses, which could range from an increase of 5 percent to 50 percent of the base units (see Cal. Govt. Code Section 65915). The City cannot reasonably foresee which developers would partake in a density bonus, and at which range, and such an attempt would be entirely speculative for the reasons listed above. Therefore, the only way to evaluate the density bonuses as requested by the commenter would be to assume that the developer for each site would partake in a density bonus; this speculative worst-case scenario could greatly overstate impacts and result in a meaningless analysis. Therefore, the City evaluated each site at the maximum allowable density to provide for a conservative analysis, which would allow subsequent activities, pursuant to CEQA Guidelines Section 15168I and 15183, to utilize the Program EIR to evaluate environmental impacts. As stated in Chapter 2, Project Description, on page 2-41: As a program-level analysis, this Draft Program EIR considers the reasonably anticipated environmental effects related to the implementation of the Housing Element Update and associated land use and planning revisions. The analysis in this Draft Program EIR does not examine the site-specific effects of individual projects that may occur in the future. Once the Final Program EIR has been certified, subsequent activities within the program must be evaluated to determine whether an additional CEQA document needs to be prepared. Many subsequent activities could be found to be within the scope of the certified Final Program EIR or consistent with the Housing Element Update and General Plan such that additional environmental analysis may not be required (State CEQA Guidelines § 15168I; 15183). CEQA Guidelines Section 15154 states “[i]f after a thorough investigation, a Lead Agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact.” Therefore, this Draft Program EIR appropriately includes an evaluation of density bonus, and any further discussion would be speculative and is not required by CEQA. Response to MACYS-2 The commenter notes that the Draft Program EIR and the Housing Element Update assume certain sites would be developed at particular affordability levels but does not provide an explanation. The Housing Element Update sites are categorized into affordability levels based on California Department of Housing and Community Development guidance. The comment does not specifically address the adequacy of the Draft Program EIR or identify any potentially significant adverse environmental impacts. The comment is noted and will be provided to City decision-makers. Response to MACYS-3 The commenter requests that the City fully evaluate the feasibility of developing affordable and market rate housing in light of significant financial burden associated with impact fees.