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11/18/2013 streamlining only applies to projects that truly benefit the environment and meet both SB 375 and 226 goals. Eligible projects would thus inciude 1) projects located in TAZs with 75%or lawer regionaf per capita VMT or 2) projects located in a yellow zane (75-100%of per capita regional VMT) that can reduce their VMT to 75%of regional average VMT through project design ele.ments. Projects located in red zanes should not be eligible for � streamlining.This means eliminating achievement of CALGreen alane as a raute to eligibility. 3. Rerfarmance Standards Should ConsiderAffardable Hausing Needs Arnong Residential Infill Prajects. The praposed perfarmance standards da not cansider eftects an underserved communities. SB 226 makes clear that the CEQA Guidelines to be adopted by the Natural Resaurces Agency "shall promote"the implementation of the land use and transportation palicies of Senate Bill 375 ("SB 375"}, or the Sustainable Cammunities and Glimate Protection Act of 2008. Cal. Pub. Resources Cade § 21094.5.5(b)(1}. SB 375 contains many provisions local gavernments must abide by with respect to affardable housing: � Hausing element law must make "adequate provision for the hausing needs of all econamic segments of the community:' CaI. Govt. Code 65583(c). � Hausing elsment law must"assist in the develapment af adequate housing to meet the needs af extremely low, very low, low-, and moderate-income hausaholds." Id. § 65583(c)(1}(G)(2}. • Housing element law must"[c]onserve and improve the condition of the existing affordable housing stock,which may include addressing ways to mitigate the lass of dwelling units demolished by public ar private actian" !d. § G5583(c)(1)(C}(4). � Transit Priority Prajects cannot "resuft in any net loss in the number af affordable hausing units within the project area." Cal. Pub. Res. Cade § 21155.1(b)(3). � Transit Prinrity Projects must ensure that minimum percentages of housing be sold or rented ta very low, low-, and moderate-income families and that develapers pravide legal commitments to ensure contlnued availability of affordable housing units, or payment of in- lieu fees far development af affordable housing. Id. § 21155.1(c). The Praposed CEQA Guidelines'faur performanae standards applicable to all projects (i.e., renewable energy, active transit,transit station area plans, and sail and water remediation)and additianal VMT performance standard for residential prnjects.fail ta account for the statewide policy objective to maintain and develop affordable housing. While we understand OPR's objective is ta employ the fewest standards necessary ta pramate a number of environmental objectives, simplicity �annot come at the risk of displacing low-incame communities or precluding low-incame communities from the recognized benefits of infill develapment. Accordingly, we propose that affardable housing pravisions be included in the perfarmance standards. Recommendation: For all projects— Residential, Cammercial, Office Buildings, or a Small Community Walkable Project—it should be made clear that no project can result in a net lass of affordable housing units within a praject area. For Residential projects in particular, additional performance standards related ta minimum provisions of affordable housing for rent or purchase, and sufficient legal commitments to ensure the cantinued availability of hausing far all income levels,should be an added qualification for CEQA streamlining. Specifically,we recommend a requirement that no less than 15%af the units be affordable for lower income households, fi%affordable to vary law-incame and 9%affardable to low-incume. 3 RESO.#15305 MUFF#603