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January 13, 204)9 Page 5 increasing number of Tri- Valley workers who live in cast Contra Costa County and in San Joaquin Cotmty resulting in long commutes to work via the congested freeway system. 'though the City recognizes the shortfall in current housing, particularly affordable 18.1 housirg. the General Plan Update dues. nothing to curtail the problem. It therefore will Ibrce ever more local employees to find housing in distant communities, create more sprawl. lead to more greenhouse gas emissions and other air pollution. and increase dependence on foreign oil. That is not acceptable. Comments Regarding Pleasanton's General Plan Update HEIR A. Climate Change Impaets The DEIR fails to sufficiently identify, analyze or mitigate the significant climate change impacts associated with its proposed buildout. In large pan due to the job'housing imbalance authorized by the General Plan Update. the DEIR finds That the Project would result in a 46% increase in Vehicle Miles Traveled, thereby significantly increasing carton dioxide emissions that contribute to climate change, As discussed above. il'California does not address growth in VMMT, it will completely overwhelm the other advances the state is making to control transpartation emissions. The planning policies outlined in the City's General Plan Update do not adequately address growth in V M'f and in fact. set the stage for the City to increase VMT at a rate I 1% higher than the average increase projected for Alameda County. In addition. the DEIR states that the development sanctioned by the General Plan Update. "would contribute to long -term increases in greenhouse gases as a result of traffic increases (mohitc sources) and residential and commercial? industrial operations associated with healing, energ; use, and solid waste disposal (arca sources)."" The City quantifies the increases. stating that tie emissions from buildout represent approximately .7 percent of tnual Bay Arca greenhouse gases emitted in 2002. which amounts to 595,000 tons CQ,eq per year. However, the DEIR makes an erroneous determination that the Project's climate change effects are insignificant and therefore it does not include mitigation measures or examine alternatives that would reduce the impacts, I. Threshold of Significance Despite the massive 46% increase in WWI the DEIR concludes that the climate change impacts of this project will be less than significant This finding is premised on a flawed threshold of significance and incorrect baseline conditions against which project impacts are cvalui.ted. Linder CEQA, the determination of significance must focus on changes to the existing DEII: at )JQ-B. rd al 3 10• I I. Table 3.10• I "!j al 3.10.14. Id !j