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FIRSTCARBON Letter SOLUTIO \1S Proposal FCS INTERNATIONAL.INC. As vehicle delay based metrics can no longer be used in CEQA documents to identify environmental impacts, Fehr& Peers has included evaluation of vehicle level of service as a non-EIR task that would be presented in a community-concerns document. Impacts to the transportation system related to the housing element sites will instead be largely based on the VMT generated by future residents of each potential site.As new housing element sites have not yet been identified, Fehr& Peers would develop VMT maps of the City and provide LOS calculations(see Task 1)to aid the City and LWC in the selection of housing sites that have the potential to generate less VMT on a per-capita basis and have less impact on LOS,and thus,would have a greater potential for a less-than-significant transportation impact. Subtask 4.5.1:VMT Analysis Fehr& Peers will conduct a VMT assessment for each housing element site (up to 20) based on the OPR guidelines,and any adopted policies in place by the City of Pleasanton and Alameda County at the time the Program EIR is prepared. Fehr& Peers expects that this analysis would be conducted using the Alameda CTC model, unless the City has adopted other procedures by the time this project commences. For this assessment, Fehr&Peers would increase the number of housing units in the respective TAZ by the new housing development potential on each housing element site; land uses that would no longer be constructed on each respective housing element site would be removed from the model. The following VMT estimates will be prepared for the baseline and cumulative scenarios, both without and with the housing element sites: • Citywide—All VMT • Citywide—home based VMT • Each housing element site—home based VMT Subtask 4.5.2: Policy and Plan Consistency Fehr&Peers will review various local and regional transportation plans to identify if development on housing element sites could potentially result in a conflict with an adopted policy or plan.This task does not include addressing new metrics that may be developed by Alameda CTC as they update their Land Use Analysis Program to reflect Senate Bill 743. If new metrics are adopted by Alameda CTC during the completion of the Program EIR, a budget amendment to cover additional analysis would be prepared for City approval. Subtask 4.5.3: Community Concern Issues Although vehicle LOS cannot be used as a metric to identify significant impacts under CEQA, recurring congestion and projects that have the potential to increase congestion are of concern to the community. Therefore, an intersection operations assessment will be conducted for select intersections.The level of vehicle trips that could be generated by each site,as compared to the approved or pending land uses, will also be estimated as a part of this task. NORTH AMERICA I EUROPE I AFRICA 1 AUSTRALIA I ASIA 12 FI RSTCARBONSOLUTIONS.COM