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City of Pleasanton <br />July 27, 2026 <br />Page 4 <br /> <br /> <br /> <br />Draft EIR to annex the Project into the City and approve the proposed development of the <br />Project site. The City expressly requested that Alternative 2 include a discussion of whether <br />this alternative would “…require new or expanded wastewater treatment facilities and <br />whether the LAVWMA has adequate capacity to serve projected demand in addition to their <br />existing commitments…” <br />As you know, Appendix G of the State CEQA Guidelines, Section XIX, subsections a <br />and c, Utilities and Service Systems, indicates a project will have a signiflcant <br />environmental impact if it would "require or result in . . . the construction of new or <br />expanded wastewater treatment . . . facilities, the construction . . . of which could cause <br />signiflcant environmental effects", or if it would "result in a determination by the <br />wastewater treatment provider which serves or may serve the project" that it lacks <br />adequate capacity "to serve the project's projected demand in addition to the provider's <br />existing commitments." As noted above, the District and the City have both identifled <br />impacts to the EALS that will be needed to convey the additional fiows from the Project and <br />other development in the east Pleasanton area to the WWTP. The CEQA documents for this <br />Project must identify, analyze, and adopt all feasible mitigation for these signiflcant <br />environmental impacts. Unless the City Council adopts the two conditions set forth above, <br />the City's environmental documents will not meet this standard. <br />As you know, the signiflcant environmental impacts to the regional WWTP resulting <br />from Arroyo Lago, the East Lakes Project, and other future development do not result <br />simply from the generation of additional fiow. While the fiow from the Project would not <br />exceed the 7.135 million gallons per day (mgd) of "Pleasanton 'Committed Flow'" as <br />deflned in the Agreement for Wastewater Disposal Services of November 3, 1992 (sections <br />3 and 8(c)), the District's 1992 Agreement with the City also sets limits on "Treatment <br />Capacity" with reference to Biological Oxygen Demand ("BOD5") and Total Suspended <br />Solids ("TSS") in addition to fiow. In other words, fiow is just one component of "Treatment <br />Capacity" under the District's 1992 Agreement with the City. <br />The additional fiow, BOD, and TSS generated by the Project in combination with <br />other reasonably foreseeable future developments will exceed the City's allocated capacity <br />in the regional WWTP. Indeed, water conservation has had a major impact on the ratio of <br />fiows to solids that are received at the regional WWTP. Because of conservation and <br />reduced per capita water use, fiows to the WWTP have remained relatively constant even <br />as growth has occurred, but solids have continued to increase. As these water use trends <br />project into the future, solids are likely to be the constraint in treating future wastewater <br />fiows. <br />Moreover, the 1992 Agreement clearly states that neither the District nor the City <br />can take any action that would cause the District to violate its National Pollution Discharge <br />Elimination System ("NPDES") permits. (This is consistent with the Appendix G requirement <br />that environmental documents should analyze whether the Project would "violate any <br />Page 159 of 373