On February 16, 2022, the City of Piedmont issued a Notice of Preparation of a Draft Environmental Impact Report for the proposed City of Piedmont 2023-2031 Housing Element update and associated amendments to the Piedmont General Plan.
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The City of Piedmont is preparing a Draft Environmental Impact Report (EIR) for the City’s Housing Element update (“the project”) and is requesting comments on the scope and content of the Draft EIR. This scoping stage of EIR preparation seeks comments that would answer the following questions:
- What do we need to know to prepare the EIR for the Housing Element update?
- What potential environmental impacts from the City’s Regional Housing Needs Allocation (RHNA) of 587 housing units should be studied as part of the EIR?
The EIR is being prepared by the City of Piedmont, which is the lead agency for the project, in accordance with the California Environmental Quality Act (CEQA) and CEQA Guidelines. In accordance with CEQA Guidelines section 15082, the Notice of Preparation (NOP) was sent to the California State Clearinghouse, Alameda County Clerk, responsible agencies, trustee agencies, adjacent cities, and is being made available to members of the public, including individuals and organizations, to solicit comments on the scope and content of the analysis in the EIR.
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Written Comments: Responses to the NOP and any questions or comments should be directed in writing to: Kevin Jackson, Planning & Building Director, City of Piedmont, 120 Vista Avenue, Piedmont, CA 94611; or kjackson@piedmont.ca.gov.
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Responses to the NOP must be received on or before 5 p.m. on Friday, March 18, 2022. In addition, comments may be provided at the EIR Scoping Meeting (see details below). Comments should focus on the scope and content of the EIR, such as significant environmental issues, reasonable alternatives, and mitigation measures.
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EIR Public Scoping Meeting: The City of Piedmont will conduct a public scoping session on Tuesday, March 1, 2022, as part of a special Planning Commission meeting to receive comments on the scope and contents of the EIR. The meeting will start at 5:30 p.m. and be held via video and teleconference. Information about how to join the meeting is available: here
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Project Location: The project, which is an update to the Housing Element of the City’s General Plan, is
applicable to the entire City of Piedmont (citywide). The City of Piedmont is located in the East Bay of the San Francisco Bay Area in northern Alameda County. The City of Piedmont encompasses approximately 1.7 square miles with a population of approximately 11,300 residents and 4,000 housing units. The Housing Element is one of the 7 state-mandated elements of the local General Plan and is required by the State of California to be updated every 8 years. Detailed project description information and background information are provided in the NOP, located
here.
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Probable Environmental Effects: Approval of the proposed Housing Element update would not include approval of any physical development (e.g., construction of housing or infrastructure). However, the EIR will assume that such actions are reasonably foreseeable future outcomes of the Housing Element update. The EIR will evaluate the potential physical environmental impacts that could result from future actions for implementing the policies proposed under the Housing Element update at a programmatic level, in accordance with CEQA Guidelines Section 15168. The topical areas that will be addressed in the EIR are: Aesthetics, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, Land Use and Planning, Population and Housing, Public Services and Recreation, Transportation, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire.
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The Draft EIR will also examine a reasonable range of alternatives to the proposed project, including the CEQA-mandated No Project Alternative and other potential alternatives that may be capable of reducing or avoiding potential environmental effects while meeting most of the basic objectives of the project. In addition, the EIR will address cumulative impacts, growth inducing impacts, and other issues required by CEQA.
It may be difficult for the community to provide meaningful comments for the EIR scope as a draft Housing Element does not exist.
Policies, programs and zoning changes proposed for the HE have been discussed at workshops and it would help to solicit comments were the city to briefly summarize those discussions for the community during this comment period.
As I understand it, the elimination of single-family zoning is one concept staff is considering for the HE though I may have that wrong. Another is to raise the allowed height for ADUs to 22ft and eliminate the requirement that the ADU design match that of the residence. There are others proposals as well.
Those interested on commenting should visit the “Piedmont is Home” website to learn more about what the city is considering for the HE.
It would seem that the project needs to be defined before any meaningful analysis of its impacts could be assessed. I do not see in the above city notice enough to comment upon. Maybe there should have been included a link to something more substantive.
The best description of a project can be found at the “Piedmont is Home” website but this is mainly a compilation of many meeting materials.
A link in the notice to this website would have helped but better yet would be a synopsis of the policies staff is considering for the Housing Element.
Several Planning Commissioners supported this idea. As a simple solution, The city should extend the comment period for the EIR Scope to April 1, which falls after an upcoming update on the Housing Element. A well-defined project is needed if staff wants meaningful comments.
Staff did indicate that this will be a programmatic EIR, applicable to whatever policies the city adopts in the Housing Element at a future date.
So it will suffice for whatever housing projects are ultimately developed. For example, were Blair Park to be converted to housing two years from now there would be no EIR conducted. Staff says the reason is to save money on development, but is that fair to the neighborhoods? Will Piedmont have difficulty finding developers to build in our city?