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City of Pleasanton—Additional Housing Sites Rezonings Project <br />CEQA Guidelines Section 15164 Addendum Addendum <br /> <br /> <br /> 125 <br />b) Vehicle Miles Traveled <br />Would the project: Would the project conflict or be inconsistent with CEQA Guidelines <br />Section 15064.3, subdivision (b)? <br />Summary of Prior FEIR <br />This checklist question was added to the CEQA Guidelines after certification <br />of the Prior FEIR and was not previously a separate City CEQA threshold for <br />traffic. However, the Prior FEIR addressed VMT in the Air Quality and Climate <br />Change section under Impact AQ-1, and VMT was found to have a <br />significant and unavoidable impact, for which the City adopted a Statement <br />of Overriding Considerations in certifying the Prior FEIR. <br />Consistent with PRC Section 21166 and CEQA Guidelines sections 15162 <br />through 15164, the purpose of this Addendum is to determine whether the <br />proposed project would result in new significant environmental effects, a <br />substantial increase in the severity of previously identified significant effects, <br />or new information of substantial importance that would require preparation <br />of a subsequent or supplemental EIR. Although VMT was a known metric at <br />the time, because the prior environmental document was prepared before <br />the statewide transition to VMT as the metric for evaluating transportation <br />impacts under CEQA Guidelines Section 15064.3, VMT does not constitute <br />“new information” within the meaning of Section 15162, subdivision (a)(3). <br />Rather, it reflects a change in analytical methodology, not a change in the <br />physical environmental impacts of the project or the circumstances under <br />which the project would be undertaken. As such, the inclusion of a VMT <br />analysis in this Addendum is not required to support the CEQA determination <br />and is provided for informational purposes only. <br />Proposed Project Analysis and Conclusion <br />A program-level VMT analysis was prepared to evaluate the proposed <br />project under cumulative (2040) conditions. The analysis evaluated both <br />home-based VMT per resident and total VMT per service population, using a <br />threshold of significance defined as 15 percent below the Alameda County <br />average. <br />Under the 2040 Plus Project conditions, the proposed sites would generate <br />home-based VMT per resident (14.2) below the applicable threshold (15.2), <br />and total VMT per service population (18.9) would also remain below the <br />applicable threshold (22.1); thus, the proposed project would not result in any <br />new or more severe impacts than discussed in the Prior FEIR. Although Site B <br />exceeds the per-resident VMT threshold when evaluated individually (19.4),