At its upcoming meeting on September 8th, the Piedmont City Council is planning to discuss the plan for development in Blair Park. It appears that the Council wants to move the plan directly into the EIR process without allowing sufficient time for the community to review the revised plan. Friends of Moraga Canyon is sending the following letter to the City Council, and members of the group plan to present our position at the meeting.

If you can, please join us at the meeting on September 8th at 7:30 to show your support for Moraga Canyon. The updated agenda should be posted to the Piedmont City Council website by the Friday before.

The Friends of Moraga Canyon request that the Blair Park item be tabled to allow the Parks, Recreation and Planning Commissions, and the neighborhood and the community, to review the plan before beginning the EIR. The EIR process is designed to review the environmental impacts of the plan, not the plan itself. That review should occur prior to the EIR being started and in fact is required by the City’s Municipal Code.

FOMC also notes the following:

The community has had only four days to review the plan and those four days started on the Friday before Labor Day.

There are two appeals on the agenda for September 8. It is a well-known principle of agenda management that a City Council does not take up a discretionary item if there are required agenda items, such as appeals, that require a significant amount of time. Citizens who have to leave for work early on Wednesday, or who have school children, may end up having to leave the meeting before they have an opportunity to comment on the proposal. Since there is no reason why the Blair Park item cannot be continued, it appears that testimony will be limited unnecessarily.

The Parks and Recreation Commission and the Planning Commission have not had an opportunity to review the plan. Since Blair Park has other potential uses than a sports complex, the Parks Commission should have an opportunity to consider its use. The Planning Commission is required by Government Code Section 65402 to make a finding of conformity to the General Plan for such a project. In addition, the City’s own ordinances, Section 25.3 (a), 25.5 (a) and 25.7 (a) of the Municipal Code, clearly require review by all three commissions.

The project is not being handled as other projects in Piedmont. Examples are cited below:

• The June 2, 2008 City Council staff report for the Hampton Field renovation states: “The plan was fully vetted to the public at meetings which took place in October, 2006, January 2007 and at joint meetings of the Park and Recreation Commissions in June and July of 2007. The current master plan is based on a criteria list generated from these meetings which included representatives from the neighborhood, the City Council, Park & Recreation Commissions, sports groups.(soccer, baseball, tennis and basketball) and members of the Piedmont Play School and Board. The plan has a broad consensus of support including unanimous approval from both the Park and Recreation Commissions.” Why has a much more major project not been reviewed in the normal Piedmont manner?
• Another example of how Piedmont handles recreation improvement projects is the Dracena Children’s Play Area. The City Council staff report of July 19, 2004, states: “after months of consideration and comment by the community through the Recreation Commission with input of the Park Commission, the City Council approved a final design.” If a children’s play area receives this much review, why not a major sports complex?
• Regarding Planning Commission design review, on November 13, 2007, the City of Piedmont was the applicant for a proposed city bus shelter. It was noted that such a structure “requires design review.” Why does a major sports complex not require Design Review?

There is no need to rush this project. One example of the unusual haste which characterizes the project is the fact that no Scoping Session has been scheduled. As we are sure your CEQA consultant can affirm, this is highly unusual, particularly for a controversial project.

FOMC have repeatedly requested the opportunity to review the project. Anyone proposing to modify their residence would be required to work with their neighbors and the project would have to be reviewed by the Planning Commission. In addition, story poles would be required for any project whose height would impact the neighbors. Why is such a significant project as Blair Park being fast-tracked and community review being avoided?

The project will cost at least seven million dollars. It will crowd out all other CIP projects for years. Putting Blair Park at the top of the CIP list without any discussion by the Recreation and Planning Commissions is inappropriate. The City’s General Plan survey listed 15 CIP projects and asked which should be the highest priority. Support for additional recreation facilities as the highest priority was less than 10 percent (less than 93 people).

Maintenance of the complex will be extremely expensive and will probably ensure that the Parcel Tax must be set at its highest rate for many years. A discussion of the financial impacts of this project on the budget is essential.

The EIR will cost a significant amount of money. The decision to go forward with the EIR should not occur until the appropriate level of Recreation Commission and Planning Commission review has occurred. Money programmed for the EIR could be used to help preserve essential City services.

We believe it is vitally important for the Council to pause in its headlong rush to approve this project and allow the Recreation and Parks Commission, the Planning Commission, the neighbors, and the community to discuss whether this should be the City’s highest CIP priority, whether this project is actually needed, whether this design is appropriate and whether the City is willing to commit a significant portion of its maintenance budget for decades to this project.

The City’s staff report of May 18, 2009 states that LSA and Benson Lee requested the City provide additional information to define the proposed project. “LSA points out that there cannot be significant changes to the description of the project between the Notice of Preparation (the first CEQA document prepared) and the Draft EIR (the Second CEQA document prepared).”

In other words, the City’s own consultant noted that the project had not yet been defined as of May, 2009, and that the project cannot be changed during the CEQA review process. How can the City now give the community only four days in which to review it?

That discussion needs to be completed before beginning the EIR process. We note once again that CEQA is not an appropriate vehicle for public input on a project. That input should occur prior to finalizing the plan for CEQA review. The appropriate vehicle is the Recreation Commission and the Planning Commission and citizen workshops to review the plan.

Lastly, we note that in the past the Council has requested that we not speak at public hearings if we had already submitted a letter or email. We do not consider emailed correspondence to the City Council to be a substitute for public testimony. People attending the meeting or watching it televised should hear our comments and concerns, which are an important part of the public decision making process.