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cAL <br /> Jan 26, 2023 <br /> City of Pleasanton <br /> P.O. Box 520 <br /> Pleasanton, CA 94566 <br /> By Email:citycouncil@cityofpleasantonca.gov;kbrown©cityofpleasantonca.gov; <br /> varkin®cityofpleasantonca.gov;jbalch@cityofpleasantonca.gov; <br /> knarum@cityofpleasantonca.gov;jtesta@cityofpleasantonca.gov <br /> CC:dsodergren@cityofpleasantonca.gov <br /> Re:Proposed Objective Design Standards for Qualifying Housing Developments <br /> Dear City Council, <br /> The California Housing Defense Fund(CaIHDF) submits this letter to inform the Pleasanton <br /> City Council that it has an obligation to abide by all relevant state laws when considering the <br /> proposed Objective Design Standards for Qualifying Housing Developments (the"proposed <br /> standards"). Specifically,the Council must comply with the California Environmental Quality <br /> Act (CEQA), the Housing Crisis Act of 2019 (SB 330), and other state housing laws. The <br /> proposed standards, as currently drafted, run afoul of these laws. Many of the proposed <br /> standards fail to accomplish the ordinances' stated goal and a key requirement of SB 330: <br /> they fail to articulate objective requirements for development. Further, many of the <br /> standards would add significant costs to development proposals, threatening to reduce <br /> development intensity and effectively downzone areas where they apply. <br /> I. THE COUNCIL CANNOT CLAIM AN EXEMPTION FROM CEQA IN ADOPTING THE <br /> PROPOSED STANDARDS <br /> Under CEQA, city governments must prepare an environmental impact report (EIR) on <br /> projects "which may have a significant effect on the environment,"(Cal.Pub.Resources Code <br /> § 21151, subd. (a).) The Planning Commission recommends the Council find no EIR is <br /> necessary to adopt the proposed standards, relying on two exemptions to the EIR <br /> requirement:the"common sense"exemption(14 Cal.Code Regs.§15061,subd.(b)(3))and the <br /> exemption for projects consistent with the City's general plan (14 Cal. Code Regs. § 15183). <br /> Neither of these two exemptions applies,however, and adopting the proposed standards in <br /> reliance on either or both of them would violate CEQA. <br /> 360 Grand Ave#323, Oakland 94610 <br /> hi@calhdf.org <br />