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02 ATTACHMENT 1
City of Pleasanton
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2023
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012623 SPECIAL
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02 ATTACHMENT 1
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CITY CLERK
CITY CLERK - TYPE
AGENDA REPORT
DOCUMENT DATE
1/26/2023
DESTRUCT DATE
15Y
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City of Pleasanton 2023-2031 (6th Cycle) Housing Element Update <br />Final EIR Responses to Written Comments <br /> <br /> <br />FirstCarbon Solutions 2-81 <br />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 <br />Seefried Properties (SEEFRIED) <br />Response to SEEFRIED-1 <br />The commenter provides a description of the Kiewit Property (identified in the Draft Program EIR as <br />Site 21) and notes that development of the site would assist the City in making significant and rapid <br />progress toward satisfying its RHNA obligations. <br />This comment introduces the comment letter; no response is required. <br />Response to SEEFRIED-2 <br />The commenter asserts that, in order to provide an accurate, stable, and consistent project <br />description in the Program EIR, the City should assign one specific land use designation to <br />accommodate the type and number of units anticipated for the relevant portion of each site. Exhibit <br />A is a development plan and is included in this Final Program EIR as SEEFRIED-5. <br />As indicated in CEQA Guidelines Section 15146 and long standing CEQA caselaw, the level of <br />specificity in an EIR depends on the degree of specificity in the proposed activity and the rule of <br />reason. An EIR has adequately disclosed potential environmental impacts where it bases its analysis <br />on a reasonable worst-case, or conservative, scenario. Planning & Conserv. League v. Castaic Lake <br />Water Agency (2009) 180 CA4th 210, 244. As part of finalizing and adopting the Housing Element <br />Update, which is anticipated to occur prior to January 31, 2023, the City will provide a specific and <br />discrete (non-overlapping) General Plan land use designation for each site. The City will also provide <br />accompanying guidance that will specify how to implement those land use designations. The Draft <br />Program EIR evaluated each site at its maximum density establishing a reasonably conservative <br />scenario given the programmatic nature of the analysis. None of the potential sites for housing <br />would have a General Plan land use designation that would allow more dense housing than was <br />disclosed in the Draft Program EIR. Therefore, the Draft Program EIR has adequately disclosed <br />potential environmental impacts in compliance with CEQA. <br />Response to SEEFRIED-3 <br />The commenter states that development of Site 21a and 21b (Kiewit) site is essential for the City to <br />meet the Housing Element Update objectives. They go onto assert that the Transit-Oriented Focus <br />Alternative (Alternative 2) is not feasible because, among other things, it would not meet most of <br />the project objectives at all or to the same degree as if Site 21a and 21b (Kiewit) is included. <br />Pursuant to CEQA Guidelines Section 15126.6, the City, in its discretion as the Lead Agency, chose <br />alternatives that would (1) accomplish most of the basic goals and objectives of the Housing Element <br />Update, including accommodating the RHNA; (2) would lessen the identified significant and <br />unavoidable environmental effects of the Housing Element Update; and (3) would be feasible <br />considering site suitability, available of infrastructure, general plan consistency, and consistency with <br />other applicable plans and regulator limitations. As described in Chapter 6, Alternatives, of the Draft <br />Program EIR, analysis of alternatives to the proposed Housing Element Update provides full <br />disclosure and allows decision-makers to consider the proposed Housing Element Update in light of <br />hypothetical alternative development scenarios. The sites included in each Build Alternative were <br />chosen by the City given site constraints, market conditions, and other relevant factors, while <br />reducing potential environmental impacts including sites necessary to provide adequate sites to
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