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Megan Campbell December 5, 2022 Page 4 SEIP-58196\2713340.1 (DEIR, at ES-3.) CEQA requires an alternatives analysis that discusses feasible project alternatives that could reduce a project’s potentially significant environmental impacts while also attaining most of the project’s basic objectives. Here, the DEIR includes Alternative Two, which excludes several housing inventory sites not concentrated around transit centers. However, this Alternative is not feasible because, among other things, it would not meet most of the project objectives at all or to the same degree as the Kiewit Project as proposed by the City (which includes the Kiewit Site). As noted above, the Kiewit Site is the largest vacant rezone site within City limits. Several factors make it more likely that homes will be constructed here as compared to other sites.6 For example, unlike several other rezone sites, the Kiewit Site has unified ownership, which has been working cooperatively with the existing tenant to ensure it is ready to vacate when requested by Seefried to do so. Seefried is also fully engaged, experienced in land use entitlements, and committed to pursuing its residential proposal as demonstrated by the substantial monies and effort it has and will continue to expend in connection with the City’s HEU as well as its own site planning and entitlement process. With its development team, Seefried has already prepared numerous conceptual land and architectural plans to reflect a high-quality, cohesive residential development that incorporates an appropriate level of diversity in housing type, while also taking into consideration market demands related to infrastructure and cost efficiencies to help ensure this proposal can come to fruition in the very near future. In fact, based on current site planning efforts, Seefried anticipates it can deliver several hundred market rate units and more than a total of 150 affordable units that would be deed restricted at various income levels within a relatively short period of time, assuming the City adopts a compliant Housing Element with the appropriate land use designations and other required elements. By providing an opportunity for rapid and substantial residential development on a vacant site owned by a developer that is posed to proceed, inclusion of the Kiewit Site helps establish credibility for the HEU in the eyes of HCD and helps to ensure an HCD compliance finding within the timelines required under state law. This is particularly important as HCD is closely scrutinizing the viability of housing inventory sites included in 6 th Cycle housing elements. 6 In contrast with the Kiewit Site, the assumption that other large rezone sites in the City will be developed as assumed in the HEU DEIR is far from certain. Among other reasons, many of these sites have multiple existing buildings and improvements occupied by active tenants and thus would require full-blown redevelopment efforts to occur in an uncertain economic market. Several other rezone sites each have multiple owners, not all of whom may be interested in, let alone committed to, pursuing and developing residential uses. 6(()5,(' 3DJHRI &217