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To meet the RHNA allocation of 2,114 units and provide the required "buffer units" to account for development projects that fail to meet the allocation numbers, Lafayette must plan for a total of approximately 3,400 residential units. Scenarios were examined at more than one location with the Draft EIR addressing distributed sites beyond the downtown core and a second scenario with downtown-only housing. By analyzing and sharing the preliminary environmental impacts, along with mitigating actions that can be made, Luke Evans, Lafayette's CEQA consultant and project manager hired to develop the housing element draft, said decision-makers and the public can better understand and provide comments while the final draft is being completed.
Evans presented an overview of the project and project alternatives, and identified four potentially significant issues likely to experience significant, adverse effects. The short list began with aesthetics. If there are any increased densities, particularly in the downtown area, Evans said there would be unavoidable impact to the visual environment and scenic vistas that people may find objectionable. Buildings can be designed to be attractive, he said, but the aesthetic changes to meet the housing requirements would be considerable. A second area of environmental impact related to air quality metrics associated with large construction projects due to emissions. Evans again said negative air quality impacts could not be avoided, even with mitigation requirements in place.
Cultural resources was a third factor with significant possible change that could impact historic buildings, although there are no prospective projects currently involving historic property in Lafayette. Importantly, buildings older than 45 years are age-eligible for designation as historic landmarks. There are no stated guarantees such properties might not be affected or would be excluded in Housing Element projects. Lastly, all future housing developments located more than a mile from mass transit hubs - in Lafayette, the BART station - now require that transportation evaluations focus on and measure vehicle miles traveled per day (MTD). Both the distributed and the downtown-only scenarios under consideration by council include projects that might result in higher MTD metrics.
Questions asked by council began with a request for specific information about operational air emissions after projects are completed and health risks rising from the sites proximate to Highway 24. Evans said the former might actually decrease and the impact from the highway would be "diluted out" and not significant.
Asked about the three other areas of primary concern and if different locations would alter the conclusions drawn, he said the draft EIR alternative sites he analyzed showed only MTD might be affected in locations outside the BART location. The other environmental impacts would remain largely the same regardless of the choice between distributed or downtown-only scenarios.
Planning and Building Director Greg Wolff clarified that a dedicated page on the city's website allows anyone to view the draft, which was published on Feb. 18. (It is available at lovelafayette.org/ceqa.) Evans said each public comment will receive an individual response. If someone raises a comment that addresses an EIR inadequacy that proves to be accurate, the final draft will be revised accordingly.
When Council Member Susan Candell expressed concern about a ladder truck the Contra Costa Fire Protection District says it needed for emergency services to serve taller buildings in Lafayette, and that current fire stations couldn't accommodate a ladder truck, Evans said if the current fire station isn't able to accommodate a truck, that would be a separate issue the city would have to discuss under CEQA.
Vice Mayor Carl Anduri said budget increases requested of the council in July 2021 during the EIR process were in part related to evacuation analysis and resulted in $161,000 being added to the budget. Evans said legal nuance made the issue complex, but the basic threshold for CEQA is whether or not a project would conflict with or impair an evacuation plan. The Housing Element update at this time does not interfere with the execution of the city's established evacuation plans, he said.
Evans and city staff said decisions about allowing or restricting accessory dwelling units as well as related updates, requirements and standards will be included in the Housing Element plan but will not be addressed in the EIR specifically. Likewise, future mitigation measures such as utilities needed due to increased density or for other reasons related to new development projects are in the city's overall planning, but cannot be anticipated in detail until a given project demonstrates a need.
During the public comment portion, Eliot Hudson said the city's current housing element plans were not adequate to address increased density. He said a small fire near the Lafayette tennis courts during which an evacuation route near Acalanes High School was "nearly impassable" proved his point. "The fact that the city 'might' update its evacuation plan to be compliant with state law would have been totally meaningless (on that day)," he said.
The draft EIR, an over 500-page document, is available online and summarizes all environmental impacts in 17 categories. The draft is being shared with the public for just over 45 days ending April 4. A March 7 Planning Commission meeting accepted verbal comments from the public and Evans emphasized people can continue to communicate their comments to the city in written form at any time up to April 4.
Mayor Teresa Gerringer said staff would be looking into scheduling an additional public comment meeting and information will be made available to the public.
To view the draft EIR, visit
http://lafayette.granicus.com/GeneratedAgendaViewer.php?clip_id=0f52f80d-f0b5-11eb-81b1-0050569183fa
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