3B Public Hearing 2007 0904 - Laserfiche WebLink

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~ulnn IU~RC~ LLr I Q^. I I"-;;"U-;:JU,);) nues, L;J LUUI U.;J..JLQlIl I UU.J'UU~ RUTAN , AT"':'"C'l:t~fr~ .~'j'" t,,>t.'W. Mayor and Members of the City Council of the City of San Leandro August 29, 2007 Page 3 impacts analysis may be as broad as a watershed or the air basin, or BARTs transit network, depending upon the impact which is being analyzed. Therefore, projects outside of the City boundaries should have been included in the cumulative impacts analysis in areas including, but not limited to, air quality, public services and transportation, circulation, population and housing, land use, and hydrology and water quality. Air Quality Impacts . The EIR notes that consistency with Clean Air Plan projections is a standard of significance for air quality. The EIR then states that the current applicable clean air plan is the 2005 Clean Air Plan which is based on the 2003 ABAG projections. It goes on to state that the TOD Strategy's consistency with the 2005 Clean Air Plan therefore depends upon how its projected growth compares to the 2003 ABAG projectioJ;ls and more directly, whether the growth exceeds or is less than what has been assumed in the 2005 Clean Air Plan. The 2003 ABAG projections through 2015 are depicted in Table 4.2-3 of the EIR. From that table, the EIR concludes that the increased growth resulting from the TOD Strategy will be less than the growth assumed in the 2003 ABAG projections, and therefore the TOO Strategy is consistent with the 2005 Clean Air Plan. 1b.is is an incorrect conclusion. Table 3~5 of the EIR notes that the TOO Strategy will result in an increase of 439 housing units over and above the General Plan estimate for 2015. The General Plan 2015 estimate is 32,770 households. 439 additional households resulting from the implementation of the Strategy, when added to the General Plan's 32,770 estimated households results in a total estimated 2015 household number of33,263. The 2003 ABAG projections (and thus the 2005 Clean Air Plan) estimates a total of 33,130 households. Therefore, the increase that will be created by the TOO Strategy exceeds that estimated in the Clean Air Plan and therefore, the implementation of the TOD Strategy would be inconsistent with the Clean Air Plan, which is a significant impact. This significant impact needs to be identified, evaluated, and mitigated if feasible. . The failure of the EIR to adequately identify other projects in the region for purposes of cumulative impacts analysis, as noted above, is particularly egregious in the context of analyzing air quality impacts, the effects of which are not limited to the limited boundaries in the vicinity of the TOO Strategy area. . Regarding greenhouse gas emissions, the EIR indicates that the project's contribution to cumulative global climate change impacts would be considered significant if the project failed to implement all feasible and relevant greenhouse gas emission reduction strategies contained in the EP A Climate Action Team Report. The specific strategies contained in this report are not identified anywhere in the EIR, nor does the City propose to adopt any of these specific strategies as mitigation measures, in violation of CEQA. 2901023592-001$ 839931.01 aOSJ29/07