The EIR fails to analyze the potential significant effect on the environment of the general lack of affordability of the residential portions of the project.

The EIR acknowledges that there is currently an imbalance of jobs and housing in Alameda and, indeed, in Alameda County as a whole. (pages 158-59) And the discussion of the issue recognizes that: [a] community can also have a balance between jobs and housing, yet also have none of its housing stock affordable to its work force. (page 157) However, the methodology then applied in the analysis of the jobs/ housing imbalances of the project fails to account for housing affordability. (pages 157-58)

There are models and methodologies available to assess the impact of the relative affordability of housing in a proposed project in relation to the relative wages paid to workers in a proposed non-residential. It is common for planning and community development professionals to use these models in analyzing the potential impacts of both single use and mixed use developments. Consequently, for the EIR to adequately assess the impacts of the relation between jobs and the number of employed residents it must contain such an analysis.

Given the relative high price of the vast majority of the housing proposed by the Project, there is a strong likelihood that little if any of it will accommodate Alameda?s existing critical need for low and very low income housing, let alone address the needs of the 4600 employees that the Project will add. (page 161) Without analysis of the relation between the affordability of the planned units and housing payment capacity of the expected workforce, the EIR finding that the jobs/housing and housing affordability effects will be ?less than significant? is unsupported. (pages. 162-163)

Somewhat disingenuously, the EIR states that ?under CEQA, socioeconomic impacts [such as jobs/housing imbalance and gentrification] are not considered significant.? ( pages. 162-63). That is incorrect. Where socio-economic impacts would have direct impacts on the physical environment, Public Resources Code §21080(e) mandates that an EIR analyze the impacts.

The EIR contains other related errors. It implies that, despite its failure to include any meaningful analysis of the issue, 15% of the housing in the proposed Project will be affordable to low and moderate income households. (page 163) Yet the 15% figure is the statutory requirement of the state Community Redevelopment Law that mandates that 15% of the aggregate of the units development in a redevelopment project area be affordable. Nothing in the EIR indicates that there is a mandatory requirement that 15% of the Project housing will be affordable. The Project description only guarantees 39 such units out of 539.

Additional Analysis and Correction Required: Analyze Project impacts on jobs-housing balance and correct erroneous information.

The measure proposed to mitigate the significant impact of the displacement of the 590 existing east housing units is unsupported.

The EIR concludes that the impact cannot be fully mitigated without considering information submitted in response to the Notice of Preparation.

The EIR first argues that the housing loss impact is the net loss of 51 units. In fact, the impact is the net loss of 551 units affordable to very low income households (590 - 39). Until the potential impact of the lack of affordability of the proposed 500 units is analyzed, as discussed above, the EIR lacks adequate basis for the contention that the impact is limited to the net loss of units. The units may have been vacant since 1996 due to recalcitrance by the Navy and the City, but they were once occupied and included in the housing stock of the City. (See Housing Element, page 11-2) Their loss is tremendously significant when it is considered that the City?s fair share of the regional need for housing for very low income households, determined before East Housing was vacated, was 548 units.

The EIR next states that East Housing ?was never made available to the public and, as a result, does not constitute a loss of publicly available housing.? (p. 164) This statement contradicts the City's long standing position, confirmed earlier in the EIR (page 121) that the military housing must be counted as part of Alameda?s housing stock because, even though it was reserved for military personnel, because it fulfilled a need that would otherwise spill into the rest of the community. (See Housing Element, page D-1) The statement is also inconsistent with the City?s Housing Element, which purports to count the housing now occupied by the Coast Guard as housing that is part of the city?s housing stock. (Housing Element, page B-3).

Lastly, the EIR cites the Housing Feasibility Study for the Naval Air Station Alameda for the proposition that rehabilitation of East Housing is ?possibly cost prohibitive? (sic). The general conclusion of this study prepared by Bay Area Economics was that rehabilitation was clearly feasible. And the proposal made to the City by the East Bay Asian Local Development Corporation (EBALDC) for rehabilitation of the housing relies, in part, on that very study. Indeed, the EIR is conspicuous in its failure to mention the EBALDC proposal anywhere in its text.

Additional Mitigation Required: Reanalyze housing loss impacts and consider the LOCAL WORK FORCE ALTERNATIVE PROJECT as a mitigation.

The EIR fails to adequately assess the cumulative impacts of the project on population and housing.

Just as the failure to address the impact of the lack of affordability on the jobs/housing imbalance renders the analysis of the population and housing impacts fatally incomplete, the analysis of cumulative impacts on population and housing is categorically incomplete unless the impact of the lack of affordability is analyzed. Although the EIR acknowledges that the Project?s incremental contribution to demand for housing in the area represents a significant cumulative impact, it states without basis that the impact is unavoidable. This cannot be known unless an analysis of the affordability impacts, using established and frequently used methodologies, is performed. (page 490-91) The EIR also postulates that the 539 proposed units could accommodate all the households generated by the Project. This also cannot be known without an analysis of the relation between job creation and unit affordability, locally and in the area.

Additional information required: Reanalyze cumulative housing impacts and make a serious attempt to mitigate these impacts.

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Cover Letter - Project Alternative - Analysis Failures - Deferred Mitigations
Report Organization - Land Use - Population and Housing - Traffic - Air Quality
Public Services - Noise - Drainage and Hydrology - Hazards

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