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December 5, 2022 <br />Megan Campbell, Associate Planner <br />City of Pleasanton <br />Post Office Box 520 <br />Pleasanton, CA, 94566 <br />SUBJECT: Response to the Draft Environmental Impact Report (DEIR) for the City of Pleasanton <br />Housing Element Update <br />Dear Megan, <br />Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the <br />City of Pleasanton Housing Element Update. In order to meet the City’s Regional Housing Needs <br />Assessment targets, the proposed Housing Element Update identifies 25 sites for potential rezoning to <br />accommodate a maximum of 7,795 units able to house up to 18,044 residents. The City of Pleasanton’s <br />Sphere of Influence covers 42.2 miles of incorporated land within Pleasanton city limits as well as <br />unincorporated lands, and will serve as the project’s boundary and service area. The General Plan and <br />Specific Plan will be amended as needed to maintain consistency with the updated Housing Element. <br />The Alameda County Transportation Commission (Alameda CTC) respectfully submits the following <br />comments: <br />x Alameda CTC appreciates the use of the Countywide Travel Demand Model to determine the <br />project’s impacts to Vehicle Miles Traveled (VMT), as well as the DEIR’s acknowledgement that <br />the model does not reflect the impacts of the COVID-19 pandemic on travel patterns. However, <br />on page 3.14-9, the DEIR states that the Travel Model “includes data from February of 2020.” <br />Please note that the latest version of the Countywide Travel Model, updated in May 2019, uses <br />2010 as a base year to forecast 2020 conditions. <br />x On page 3.14-10, the DEIR states that the methodology for the transportation impact analysis is <br />based on VMT in accordance with Senate Bill 743, however a Level of Service (LOS) analysis is <br />required by the City of Pleasanton’s General Plan and will therefore be conducted separately. <br />Current Congestion Management Program legislation also requires an analysis of potential <br />impacts on regionally significant roadways using a delay-based metric, such as LOS. This analysis <br />may not be used to determine project impacts or required mitigations, and may be provided to <br />Alameda CTC outside the CEQA process. Please make this legislatively required document <br />available to Alameda CTC as well as the City of Pleasanton. <br />x Alameda CTC appreciates the identification of active transportation improvements from the City <br />of Pleasanton’s Master Plan, which will be located near the project area, beginning on page 3.14- <br />7. Many of these improvements, such as plans for facilities on Stoneridge Drive and Stoneridge <br />Mall Road, are phased, with protected infrastructure recommended in the long-term. Alameda <br />CTC encourages the City of Pleasanton to implement projects that follow best practices in the <br />near-term wherever possible, and prioritize corridors on the Countywide Bikeways Network <br />(which, in Pleasanton, includes West Las Positas, Foothill, Bernal, Pleasanton-Sunol, Santa Rita, <br />$/$0('$&7& <br />3DJHRI <br /> <br /> <br />