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