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<br />4. Comment: The Response to Comments document does not provide adequate <br /> responses to Housing Element related comments. Specifically. <br /> Response L17 is conclusory in implying that 3,232 housing units <br /> (the surplus of 8,100 housing units over those 4,868 needed to <br /> accommodate Pleasanton workers) would be sufficient to <br /> accommodate those households who desire to live in Pleasanton <br /> but work elsewhere. There is no factual basis given to justify this <br /> conclusion. <br /> Response: CEQA establishes no mandate for cities to satisfy the housing <br /> preferences of a future population not employed locally. EIRs <br /> conventionally address the balance between local jobs and local <br /> employed residents because it is a measure (albeit a very indirect <br /> one) of potential congestion and air quality implications of land use <br /> patterns. A more direct measure is the air quality analysis itself, <br /> which is in turn based on regional and subregional traffic impact <br /> analysis. Where such direct measures of impact are available, <br /> their use provides a better understanding of actual physical effects <br /> on the environment ("Effects analyzed under CEQA must be <br /> related to a physical change. - [Guidelines ~15358(b)]) than a <br /> jobslhousing ratio. <br />5. Comment: The Response to Comments document appears to suggest that the <br /> environmental review of at least one major project proposed in the <br /> draft General Plan, the realignment of Vineyard A venue, should <br /> be deferred until a later stage. This is clearly contrary to State <br /> law, which requires that the environmental review of a project be <br /> conducted at the earliest stage and prohibits the adoption of future <br /> studies in lieu of adequate mitigation. <br /> Response: The CEQA Guidelines recognize that EIRs are prepared on general <br /> plans, zoning changes, and development projects. and that these <br /> EIRs. while they may encompass the same geographical area, will <br /> vary in the level of detail they provide. Tiering is recommended <br /> (Guidelines ~15152(a) so as to "focus the EIR on the actual issues <br /> ripe for decision at each level of environmental review." The <br /> Guidelines specifically recognize that geBCral matters will be <br /> covered -in broader EIRs (such as on general plans or policy <br /> statements) with subsequent narrower EIRs or ultimately <br /> site-specific EIRs incorporating by reference the general discussion <br /> and concentrating solely on the issues specific to the EIR <br /> subsequently prepared." (CEQA Guidelines ~ 15385) <br /> 4 <br />