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City of Pleasanton—Hidden Canyon Residences and Preserve Project <br />CEQA Findings of Fact and Statement of Overriding Considerations <br /> <br /> <br />42 FirstCarbon Solutions <br />Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480016/FOF/21480016 Pleasanton Hidden Canyon Residences and Preserve Project FOF.docx <br />the potentially significant impacts as identified in the EIR. Therefore, impacts associated with post- <br />fire slope instability or drainage changes would be less than significant with mitigation incorporated. <br />1.7 - Impacts Identified in the EIR as Being Significant and Unavoidable Even <br />After the Incorporation of All Feasible Mitigation Measures <br />The Lead Agency hereby finds that, despite the incorporation of mitigation measures outlined in the <br />EIR and the attached Mitigation Monitoring and Reporting Program (MMRP), the following impacts <br />from the proposed project and related approvals cannot be fully mitigated to a less than significant <br />level and a Statement of Overriding Considerations is therefore included herein. <br />1.7.1 - Transportation and Traffic <br />Impact TRANS-2: The proposed project would conflict or be inconsistent with CEQA Guidelines <br />Section 15064.3, subdivision b. <br />Findings: Changes or alterations have been required in, or incorporated into, the project <br />which avoid or substantially lessen the significant environmental effects as identified <br />in the EIR. (CEQA Guidelines § 15091(a)(1)). However, impacts would still remain <br />significant and unavoidable. (Draft EIR, p. 3.14-14). Specific economic, legal, social, <br />technological, or other considerations, including provision of employment <br />opportunities for highly trained workers, make infeasible the mitigation measure or <br />project alternatives identified in the EIR. (CEQA Guidelines § 15091(a)(1)). <br />Mitigation Measures <br />No feasible mitigation measures. <br />Facts in Support of Findings: Although the City has not formally adopted VMT thresholds or a <br />specific methodology for evaluating VMT impacts, the City’s Housing Element Update Program EIR <br />referenced the California Governor’s Office of Land Use and Climate Innovation (LCI) approach for <br />evaluating transportation impacts under CEQA. Since the proposed project did not meet screening <br />criteria, a detailed VMT analysis was performed to analyze the proposed project’s potential for a <br />significant VMT impact with respect to the LCI’s recommendation that residential VMT per capita <br />should remain 15 percent below Alameda County’s average. For the proposed project’s VMT impact <br />to be less than significant, the residential VMT per capita would be required to be reduced by 54.91 <br />percent to be considered less than significant. Although the proposed project would achieve up to a <br />14 percent reduction through the deployment of all feasible VMT reduction strategies recommended <br />by the Alameda County Transportation Commission VMT Tool and required by the City’s Housing <br />Element (see MM TRANS 2, Housing Element Update Program EIR), the proposed project would also <br />require an additional 40.91 percent reduction in VMT to achieve a less than significant VMT impact. <br />(Draft EIR, p. 3.14-13). This reduction is consistent with the findings of the City’s Housing Element <br />Update Program EIR, which included the project site as a candidate site in the City’s Housing Element <br />Update Program EIR and found that impacts on VMT would be significant and unavoidable even after <br />implementation of all feasible VMT reduction strategies. (Draft EIR, p. 3.14-14). Therefore, consistent <br />with the findings of the Housing Element Program EIR, which considered the deployment of all <br />   <br /><br /> <br /> <br />