OPINION: Concerns: Piedmont Moraga Canyon Plan RFP
Hello City Council:
I’ve reviewed the staff report and draft RFP for the Moraga Canyon Specific Plan (MCSP) and submit the following comments and questions. Hopefully you can delve into them.
The MCSP is good planning, but clearly the RFP is being developed to expedite a City application for Measure A funds by 2024. Perhaps for that reason, the RFP is short on explaining how the plan addresses important city policies. Table 2 list these policies but the RFP states that these policies “may” be considered and only stipulates that the consultant team will demonstrate “professional experience and knowledge of the personnel general principles and background law applicable to specific plans, land development and affordable housing development requirements”. There are important sustainability policies outlined in the General Plan and Climate Action Plan and the City should stipulate this a credential it seeks on the consultant team. Does the team have a sustainability expert like our City does? Traffic safety is another core credential that should be requested.
The staff report and RFP suggests that additional environmental review beyond the programmatic EIR will be conducted based on the impacts of the specific projects in the MCSP. That makes sense but is predicated on a robust programmatic EIR which has yet to be released. Without the programmatic EIR being public at this time, the generalities of that assessment may be used to gloss over specific impacts of the projects at a later date. One way to alleviate this concern is to assure that the programmatic EIR will have a response to comments process as a project specific EIR does. Staff should confirm this publicly. Subsection m. in scope of services should clarify this point as well.
One important EIR consideration is whether an assessment of GHG emissions will be undertaken in the MCSP. This assessment may occur in the “built out” programmatic EIR so this may not be a factor but without that document, who can say? To resolve this question, staff should clarify whether these GHG emission calculations are being conducted as a part of the programmatic EIR. According to state guidance, GHG emissions are to be part of a CEQA analysis: CEQA GHG. However, based on certain criteria, affordable housing projects under 100 units are exempt from CEQA and staff should clarify this as well CEQA Housing. Indeed, staff should clarify whether CEQA is applicable to all the projects being considered in the MCSP, particularly the low-income housing projects.
The staff report and RFP do not clarify whether the relocation of the Corporation Yard will be studied as part of the MCSP. The only possible reference to this is that “replacement” of the Corporation Yard be considered. The City should clarify this in the RFP so as to provide consultants the widest latitude to develop creative proposals for the canyon. Indeed, this latitude may provide for the subdivisions of parcels and development standards that are attractive to builders of housing at all income levels. As staff envisioned with civic center sites, the City could leverage better housing for the project if the Corporation Yard is moved to less desirable building site in the canyon.
Following are more specific comments/questions to the RFP:
The project timeline on page 5 of the staff report is particularly short on detail. The City seems not to have identified the type of public process it intend to conduct.
Under “Specific Plan for Success” there is no mention of field lighting as part of the recreational facilities to be developed. Is it the intent of the City and this Council not to proceed with the installation of lights at Coaches Field? There is some precedent for this.
The landscape plan makes no mention that it is to comply with the City’s municipal Bay Friendly Landscape Ordinance which has specific criteria for vegetation and water use.
Garrett Keating, Former Piedmont City Council Member
Good work, Garrett, yes, I assume that the Specific Plan will be funded by a grant which earmarks the spending for planning purposes only. I’d hate to think that the hundreds of thousands of dollars this exercise will inevitably cost are coming out of the general fund. Housing Element law does not require that a Specific Plan be provided for each prospective site in a city’site inventory. I’m only guessing that this effort is occurring because staff feels a Specific Plan may be helpful in convincing HCD that this Moraga Canyon site is credible, rather than dubious. If dubiosness is the standard, there are other sites in the inventory that should also be included.