02 ATTACHMENT 1 - Laserfiche WebLink

City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update Final EIR Responses to Written Comments FirstCarbon Solutions 2-81 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 Seefried Properties (SEEFRIED) Response to SEEFRIED-1 The commenter provides a description of the Kiewit Property (identified in the Draft Program EIR as Site 21) and notes that development of the site would assist the City in making significant and rapid progress toward satisfying its RHNA obligations. This comment introduces the comment letter; no response is required. Response to SEEFRIED-2 The commenter asserts that, in order to provide an accurate, stable, and consistent project description in the Program EIR, the City should assign one specific land use designation to accommodate the type and number of units anticipated for the relevant portion of each site. Exhibit A is a development plan and is included in this Final Program EIR as SEEFRIED-5. As indicated in CEQA Guidelines Section 15146 and long standing CEQA caselaw, the level of specificity in an EIR depends on the degree of specificity in the proposed activity and the rule of reason. An EIR has adequately disclosed potential environmental impacts where it bases its analysis on a reasonable worst-case, or conservative, scenario. Planning & Conserv. League v. Castaic Lake Water Agency (2009) 180 CA4th 210, 244. As part of finalizing and adopting the Housing Element Update, which is anticipated to occur prior to January 31, 2023, the City will provide a specific and discrete (non-overlapping) General Plan land use designation for each site. The City will also provide accompanying guidance that will specify how to implement those land use designations. The Draft Program EIR evaluated each site at its maximum density establishing a reasonably conservative scenario given the programmatic nature of the analysis. None of the potential sites for housing would have a General Plan land use designation that would allow more dense housing than was disclosed in the Draft Program EIR. Therefore, the Draft Program EIR has adequately disclosed potential environmental impacts in compliance with CEQA. Response to SEEFRIED-3 The commenter states that development of Site 21a and 21b (Kiewit) site is essential for the City to meet the Housing Element Update objectives. They go onto assert that the Transit-Oriented Focus Alternative (Alternative 2) is not feasible because, among other things, it would not meet most of the project objectives at all or to the same degree as if Site 21a and 21b (Kiewit) is included. Pursuant to CEQA Guidelines Section 15126.6, the City, in its discretion as the Lead Agency, chose alternatives that would (1) accomplish most of the basic goals and objectives of the Housing Element Update, including accommodating the RHNA; (2) would lessen the identified significant and unavoidable environmental effects of the Housing Element Update; and (3) would be feasible considering site suitability, available of infrastructure, general plan consistency, and consistency with other applicable plans and regulator limitations. As described in Chapter 6, Alternatives, of the Draft Program EIR, analysis of alternatives to the proposed Housing Element Update provides full disclosure and allows decision-makers to consider the proposed Housing Element Update in light of hypothetical alternative development scenarios. The sites included in each Build Alternative were chosen by the City given site constraints, market conditions, and other relevant factors, while reducing potential environmental impacts including sites necessary to provide adequate sites to