On March 1, 2022, a Scoping Meeting for the Housing Element EIR was held by the Planning Commission
Click to view the video of the meeting. In response to comments during the scoping meeting, the following information is being provided to community members who may be interested in providing comments on the scope and preparation of the EIR. Please click on the links provided below (in blue font).
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This is a list of the environmental factors that are required to be examined under an Environmental Impact Report.
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In this Appendix, for each environmental factor, a list of questions is provided that an agency might ask when studying potential environmental impacts.
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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?
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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. 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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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
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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.
At the suggestion of the Planning Commission, staff has added this information about the EIR. I recall Commissioners also asking that a synopsis or executive summary of the draft Housing Element also be added to the informational materials. Staff could easily summarize the HE elements (Housing Elements) of the workshops into a list of the physical changes, programs and policies being considered. Three that I recall are elimination of single family zoning city-wide, increasing the allowable height of ADUs and building dimensions and facades for multifamily buildings.
Staff indicated that this will be a programmatic EIR that will suffice for future projects developed under the HE. How accurate can that be for future projects? For example, the Blair Park proposal had the highest GHG emissions of the alternatives because of its impact on traffic speed on Moraga Avenue. Will the HE EIR get into that level of detail without a defined project? Likewise for noise. The road diet for Grand added to congestion – what will rezoning that section to multifamily do to traffic? I attended the EIR scoping meeting and as I understood it that won’t be considered. I’d appreciate Commissioners or traffic planners weighing in here to explain. PCA should post that traffic slide from the Scoping presentation with an explanation.
As I understood it, staff indicated that this EIR approach is being adopted to reduce costs for developers of future multifamily projects – they won’t be required to prepare an EIR for their projects. Given the high housing prices in Piedmont, will it be difficult to find developers to work with?
Finally development of the HE appears to be proceeding without an assessment of the impact of SB 9, the law that allows by right lot splits and duplex development on single family lots. The potential for this development to assist in the city attaining it’s housing goals is hard to assess but should be factored into the EIR. A simple assessment of eligible lots could be easily prepared and used to quantify units that could be added to Piedmont housing numbers.
Thanks Garrett for closely following this. I particularly agree with your question about staff’s failure to evaluate the impact of SB9 and ADUs. SB9 allows the conversion of Piedmont homes to duplexes, by right. No public hearings or neighbors’ input. The same with ADUs, over the counter approval without notice to anyone. Presumably, the State passed these laws expecting that they will produce a significant number of new and needed housing. Yet these expected new dwellings don’t seem to count in Piedmont’s Housing Element process. I would hope that planning ask for and receive a City Attorney’s opinion that confirms staff’s position that SB9 and ADUs cannot be counted toward meeting the 587 unit RHNA. Without such confirmation, the current process seems seriously flawed.
The city approved 22 ADU/yr in 2020 and 2021. That’s a very consistent number perhaps determined by the process rate of the Planning Department. Over 8 years that comes to 160 additional units. Could SB9 produce that many new units over 8 years? Half that? How many SB9 applications has the city received since January 1, 2020? It would be bad planning to not account for SB9.
Given the builtout nature of Piedmont, ADUs and SB9 duplexes may be the principal means for Piedmont to produce any significant new residential development.Rezoning already dense, existing SFR development to higher densities will have little to no effect because of the high land costs. I don’t think the Legislature meant that cities were to cannibalize their parks and shopping areas to produce more housing. Assessing the potential of ADUs and duplexes is needed to complete an adequate Housing Element.