Planning Commission Meeting Agenda Packet (1)

Hidden Canyon Project Draft EIR Planning Commission 4 of 6 mitigation measures, as well as any additional measures identified through preparation of the Final Environmental Impact Report (FEIR), will be included in the Mitigation Monitoring and Reporting Program in the FEIR. The DEIR has identified that the proposed project would result in a significant and unavoidable adverse impact on one transportation impact area because the project would be inconsistent with CEQA Guidelines Section 15064.3(b). This section requires that transportation impacts be evaluated based on VMT, which considers the amount and distance of automobile travel attributed to different types of land use projects. According to the analysis in the DEIR, while the City has not formally adopted VMT thresholds or a specific methodology for evaluating VMT impacts, the City’s Housing Element EIR referenced the Governor’s Office of Land Use and Climate Innovation (LCI) approach for evaluating transportation impacts under CEQA. This methodology allows for a presumption of a less-than-significant impact if a development project meets certain screening criteria, such as being located in a low-VMT area or near public transit, which would exempt it from a detailed VMT analysis. The proposed project does not qualify for these screening criteria; therefore, a detailed VMT analysis was performed to determine the proposed project’s potential for a significant VMT impact. The analysis established a significance threshold for VMT, that residential VMT per capita should remain 15 percent below Alameda County’s average, and is consistent with the methodologies utilized in the City’s Housing Element EIR. The analysis concluded that even with the incorporation of feasible VMT reduction strategies, the project would only achieve a 14 percent reduction in VMT, inconsistent with this threshold. Therefore, because the proposed project would continue to exceed the 15 percent below-average residential VMT per capita threshold for Alameda County, it would result in a significant and unavoidable impact in terms of consistency with CEQA Guidelines Section 15064.3(b). In order to certify an EIR for a proposed project that would result in any significant and unavoidable impacts, the City must make findings that the benefits of the project outweigh the significant and unavoidable impacts and adopt a Statement of Overriding Considerations prior to approving the project, in accordance with CEQA Guidelines Section 15093. The Statement of Overriding Considerations specifies the reason why the City is certifying the EIR and approving the project, despite the significant and unavoidable impact related to VMT. Additionally, this document discusses why the alternatives analyzed in the DEIR would not achieve either all or part of the project objectives. DEIR - Project Alternatives CEQA Guidelines Section 15026.6 requires the EIR examine reasonable alternatives to the project that meet at least some of the project objectives. This analysis considers the level of impact to each environmental resource area resulting from the development scenario analyzed under each alternative. Below is a summary of the project alternatives considered in Section 6, Alternatives to the Proposed Project, in the DEIR.