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City of Pleasanton <br />Proposal to Prepare a CEQA Guidelines Section 15182 Consistency Analysis <br />for the 4212 and 4226 First Street Residential Project <br />2 <br />CEQA Approach <br />Pursuant to Government Code Section 65457 and CEQA Guidelines Section 15182, certain residential <br />projects that are consistent with a specific plan are exempt from CEQA. As discussed in Section <br />15182.c, if a residential project is consistent with a specific plan and none of the events described in <br />Section 15162 would occur, no further CEQA review is required. Section 15162 includes the following <br />circumstances that would make a project ineligible for this exemption: <br />a) Substantial changes are proposed in the project which will require major revisions of the previous <br />EIR or negative declaration due to the involvement of new significant environmental effects or a <br />substantial increase in the severity of previously identified significant effects; <br />b) Substantial changes occur with respect to the circumstances under which the project is undertaken <br />which will require major revisions of the previous EIR or Negative Declaration due to the involvement <br />of new significant environmental effects or a substantial increase in the severity of previously <br />identified significant effects; or <br />c) New information of substantial importance, which was not known and could not have been known <br />with the exercise of reasonable diligence at the time the previous EIR was certified as complete or <br />the Negative Declaration was adopted, shows any of the following: <br />i. The project will have one or more significant effects not discussed in the previous EIR or negative <br />declaration; <br />ii. Significant effects previously examined will be substantially more severe than shown in the <br />previous EIR; <br />iii. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, <br />and would substantially reduce one or more significant effects of the project, but the project <br />proponents decline to adopt the mitigation measure or alternative; or <br />iv. Mitigation measures or alternatives which are considerably different from those analyzed in the <br />previous EIR would substantially reduce one or more significant effects on the environment, but <br />the project proponents decline to adopt the mitigation measure or alternative. <br />As the project would be consistent with the DSP, the City would only need to find that none of these <br />circumstances would occur to confirm the project’s eligibility for a Section 15182 exemption. Based on <br />our preliminary understanding of the proposed project, this scope of work assumes that the project <br />would not result in new or substantially increased significant impacts and that, pursuant to CEQA <br />Guidelines sections 15162 and 15168, a determination of general consistency with the DSP and <br />confirmation that none of the 15162 circumstances would occur would be the appropriate level of CEQA <br />review for the project. <br />Scope of Work <br />Our scope of work and cost estimate anticipate preparation of a CEQA Guidelines Section 15182 <br />consistency analysis. In the event that our analysis indicates that the project is not consistent with the <br />DSP or that one of the circumstances listed in Section 15162 would occur, Rincon will notify the City <br />immediately to discuss the appropriate course of action, which could include additional costs for <br />preparation of a mitigated negative declaration or focused EIR. <br />DocuSign Envelope ID: FF612D3A-D9AB-47B7-BC6D-B4068941C343DocuSign Envelope ID: 365E70E7-A0EC-491F-9D81-6B86F626F7CE